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Comment 60 for Recycling Comments for the GHG Scoping Plan (sp-recyc-waste-ws) - 1st Workshop.
First Name: Tayseer
Last Name: Mahmoud
Email Address: tmahmoud@dtsc.ca.gov
Affiliation: Department of Toxic Substances Control
Subject: Comments on Section 7 (Recycling and Waste Management)
Comment:
Comments on California’s Climate Change Draft Scoping Plan June 2008 Discussion Draft These comments pertain to Section 7 (Recycling and Waste Management) Other Measures Under Evaluation Another aspect of California’s waste management sector that should be included in the Climate Change Scoping Plan is the clean-up of waste management facilities. These are facilities at which wastes have been mismanaged in the past, often resulting in soil and/or ground water contamination. Clean-up efforts can last decades and often require high usage of fossil fuels and electricity, which generates greenhouse gases. It is DTSC’s interest to improve clean-ups at waste management facilities so that their use of fossil fuels and electricity is reduced, while at the same time the effectiveness of the clean-ups is assured. Opportunities for reducing greenhouse gas emissions during clean-ups include: • Using biodiesel fuel in construction and excavation equipment any time during the remedial process, which starts with investigation and cleanup of sites • Running pumps and other equipment on solar or wind power rather than grid electricity • Treating contamination with biologic processes rather than energy-intensive mechanical or thermal processes DTSC has begun exploring methodologies for evaluating existing clean-ups to reduce their greenhouse gas emissions. We are also exploring ways to include a review of expected greenhouse gas emissions as a factor in decision-making when we are selecting new clean-up remedies or improving existing clean-up remedies. In addition, DTSC is currently testing proto-type methodologies at a pilot site in California. Federal EPA is also involved in similar efforts. Recommendations for actions are: • Develop a methodology for estimating green house gas emissions from clean-up sites • Identify opportunities for reducing green house gas emissions from these existing clean-ups • Apply the methodology to new clean-up decisions • Apply the methodology for evaluation of the remediation once the remedy is in place (often referred to as “remediation process optimization”) Clean-ups in California are conducted under a variety of State programs, including Brownfields and Environmental Restoration Program and Hazardous Waste Management Permitting Programs. Federal EPA also conducts clean-ups in California under federal Superfund, RCRA* Corrective Action, and Underground Tank programs. At present there are no state or federal regulatory requirements for including greenhouse gas emissions as a factor in decision-making for clean-ups. However, DTSC is exploring ways in which to encourage facility owners or responsible parties to participate in reviews of their clean-ups. DTSC is still at an early stage in understanding the levels of emissions of greenhouse gases that occur as a result of clean-ups of waste management facilities, and therefore do not have estimates for potential 2020 reductions to be realized as a result of the recommended actions noted above. However, it is important to include these clean-ups of waste management facilities in the Climate Change Scoping Plan in order to create awareness of this additional source of greenhouse gases that could potentially be reduced. We include as references the following documents and web links, which we believe will be useful as descriptions of potential climate impacts from hazardous waste sites remediation: DTSC’s Emerging Issues – Green Remediation: http://www.dtsc.ca.gov/emerging_issues.cfm EPA's Green Remediation Website: http://cluin.org/greenremediation/ EPA's Green Remediation Primer: http://cluin.org/download/remed/Green-Remediation-Primer.pdf Fact Sheet on Green Remediation: forwarded as pdf * Resource Conservation and Recovery Act
Attachment: www.arb.ca.gov/lists/sp-recyc-waste-ws/68-gr_quick_ref_fs_2-26-08.pdf
Original File Name: GR quick ref FS 2-26-08.pdf
Date and Time Comment Was Submitted: 2008-09-29 09:04:43
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