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Comment 54 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.
First Name: Jim
Last Name: Stewart
Email Address: drjimstewart@gmail.com
Affiliation:
Subject: Research to include in regulating landfills
Comment:
Landfill Gas-to-Energy Projects May Release More Greenhouse Gases Than Flaring Prepared by Jim R. Stewart, PhD, January 2013 When preparing regulations for landfills, published research shows there are 3.8 - 7.8 times more net GHG emissions from energy recovery projects compared to flaring. See attached paper. Summary of Policy Recommendations In summary, to reduce global warming requires the following steps to be implemented immediately: 1. Use current GHG impact value of 33 (over 100 years) or 105 (over 20 years) for methane to calculate the impacts of methane emissions from landfills. 2. Divert all organics (except sewage sludge) from landfills to reduce uncollected emissions. 3. Either compost all organics or digest them in sealed processors that capture all methane. 4. Segregate remaining organics in landfills for the most effective and cost-efficient gas collection (always maintaining high suction). 5. Keep out all liquids from landfills (including not recirculating leachate) to reduce fugitive emissions. 6. Cap landfills with temporary covers over the working face to keep out rain and then install permanent synthetic covers and gas collection systems as soon as possible (within months is important). (The current 5-year NSPS requirement harms our environment and health.) 7. All captured methane should be burned in a flare, boiler or a high efficiency turbine, or used to replace natural gas for heating or fuel cells (after proper filtration to remove harmful gasses); internal combustion (IC) engines should not be used because of unburned methane releases. 8. Stop new landfill gas to energy projects and don't give “renewable energy” credits to landfill gas (unless capture rates over the entire landfill and destruction efficiencies are constantly monitored and demonstrated to be equal to those of a flare.) (The argument that credits should be given if gas collection projects are installed earlier than local or NSPS requirements should not apply, since fugitive emissions have been found to be so large. The only way to eliminate these fugitive emissions is to eliminate organics from landfills, which would make landfill gas to energy projects uneconomic. Giving renewable energy credits to landfill gas allows it to undercut clean sources like wind and solar and, most importantly, puts source reduction, reuse, recycling, diversion, composting, and anaerobic digestion at a competitive disadvantage.)
Attachment: www.arb.ca.gov/lists/com-attach/59-slcpdraftstrategy-ws-VTkHYF0yUGdQMAlg.pdf
Original File Name: Landfill-gas-to-energyIncreasesGHG-Jan30,2013.pdf
Date and Time Comment Was Submitted: 2015-10-30 06:27:36
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