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Comment 7 for Short-Lived Climate Pollutant Draft Strategy (slcpdraftstrategy-ws) - 1st Workshop.
First Name: Larry
Last Name: Buckle
Email Address: Buckle@ies-eng.com
Affiliation: International Engineering Services, Inc.
Subject: Landfilling of Organic Waste
Comment:
International Engineering Services, Inc. fully supports the efforts of CARB to reduce short-lived climate pollutants. The following comments will address issues associated with methane generated from solid waste. We fully support the diversion of 90% of organic waste from landfill disposal by 2025. To accomplish this a significant portion of this waste will need to go to anaerobic digestion (AD) for stabilization. - Conventional composting will generate significant volumes of methane if volatile feedstocks are introduced. Food waste and similar volatile feedstock should be ban from windrow, static pile and other compost processes with the potential to produce VOC from volatile feedstock. - Digestate produced from AD must not be disposed of in a landfill. Best management practice (BMP) must be utilized in collection, processing (cleaning and sized reduction) and digestion of feedstock to insure production of digestate appropriate for land application. - Any AD digestate landfill disposed will be considered disposed organic waste. - Wastewater treatment plant biosolids will be considered organic waste, and when disposed in a landfill will be considered disposed organic waste. This will also apply to biosolids used for landfill alternate daily cover. - All wastewater treatment plants should anaerobically digest primary and secondary solids to reduce emission of VOC. - Gasification of organic waste should be allowed after BMP capture of marketable materials. Thank you for your solicitation of comments.
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Date and Time Comment Was Submitted: 2015-10-19 14:26:42
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