First Name | Dennis |
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Last Name | Burke |
Email Address | dab@cyclus.com |
Affiliation | Engineering Consultant |
Subject | Early Action #8 and #31 |
Comment | Gentleman: I am deeply concerned about the proposed timing of agricultural early action # 8, "manure management" (methane digester protocol) and agricultural early action # 31, “collaborative research on greenhouse gas reductions from land application”. The anaerobic digestion of manure should not be implemented without the control of ammonia and nitrogen emissions. The manure management protocol is scheduled to be completed by the third quarter of 2008 whereas the collaborative research on greenhouse gas emissions will not be completed until the fourth quarter of 2010. As you must be aware the Central Valley of California suffers from significant ammonia emissions from the existing manure holding ponds. Although the existing manure holding ponds are very inefficient anaerobic reactors (partially covered anaerobic and anaerobic ponds) they still emit ammonia loads that are toxic. Implementation of more efficient anaerobic reactors will result in even larger discharges of ammonia. The ammonia will be discharged with the liquid effluent from the anaerobic reactor. Covering lagoons will not control the ammonia discharges. Ammonia discharges will only be enhanced by covering the ponds since ammonia will be emitted from the irrigation water. The ammonia discharges are in and of themselves toxic. They lead to the formation of PM 2.5 that is also hazardous to human health. Ammonia discharges will eventually be deposited on agricultural lands and undergo nitrification and denitrification leading to significant nitrous oxide emissions. The bottom line is that in an effort to control methane emissions from open ponds, by covering those ponds and thereby creating more efficient anaerobic reactors, that we will increase the discharge of toxic gaseous pollutants as well as other powerful greenhouse gases. If you implement a methane control strategy from agricultural ponds you must also implement an ammonia nitrogen control strategy for the liquid and gaseous effluents from most ponds. Options to be considered include the use of aerobic treatment technologies, ammonia stripping and sequestering technologies, and or delays in implementing early action number 8 until early action number 31 has been completed. Sincerely, Dennis A. Burke PE (C 21404) |
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Date and Time Comment Was Submitted | 2007-10-24 13:30:51 |
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