Comment Log Display

May 6, 2009

Richard Boyd, Manager
Process Evaluation Section
California Air Resources Board
Stationary Source Division
1001 I Street
PO Box 2815
Sacramento, CA 95812

RE:	Comments Regarding Draft Proposed Regulation Order – Methane
Emissions from Municipal Solid Waste Landfills (3/18/09 Version)

Dear Mr. Boyd:

The Riverside County Waste Management Department (RCWMD) has been
conducting methane surface emissions at fourteen MSW landfills for
over twenty years under South Coast Air Quality Management
District’s (SCAQMD) Rule 1150.1.  SCAQMD has granted RCWMD several
exemptions to Rule 1150.1 based on historical data from the RCWMD’s
extensive surface monitoring over decades that show little to no
methane surface emissions and we believe it is critical that CARB
adopt the same reasonable approach.  The current draft regulation
order inadequately addresses landfills that have extensive
historical data documenting compliance and a provision should be
made that would allow historical data to be used in lieu of the
25-foot grid spacing or 25 ppm integrated surface emissions
monitoring requirement.
Additionally, if this regulation were to be adopted in its current
form, RCWMD would have to double its current field staff to comply
with the extra monitoring and reporting created by this regulation.
 This would create an undue hardship on RCWMD because, due to the
state of the economy, the Riverside County Board of Supervisors
currently has implemented a hiring freeze.
The RCWMD is formally providing these comments on the draft
proposed regulation order for the Methane Emissions from Municipal
Solid Waste Landfills (MSW) (Article 4, Subarticle 6, Sections
95460 to 95477, Title 17, California Code of Regulations, 3/18/09
Version).
Section 95468(b) Alternative Compliance Plans
Section 95468(b) currently states, “Criteria that the Executive
Officer may use to evaluate alternative compliance options requests
include but are not limited to:…”  The RCWMD requests that this
language be changed as follows to be more affirmative: 
“Criteria that the Executive Officer may use will use to evaluate
alternative compliance options requests include, but are not
limited to:…”.
The RCWMD believes that 20 years of quarterly, semi-annual and
annual historical data of 100-foot spacing for integrated as well
as instantaneous surface sampling is just as good or better than
one-year’s worth of quarterly 25-foot spacing.  If allowed, the
RCWMD intends on submitting decades of historic surface sampling
data in lieu of one-year worth of quarterly monitoring at 25-foot
spacing for integrated and instantaneous methane surface monitoring
and go straight to 100-foot spacing for methane surface
monitoring.

Section 95470(b)(1) Reporting Requirements
The RCWMD requests that Section 95470 (b)(1) Closure notification,
be stricken from the regulation order.  Closure notification is
already reported to the California Integrated Waste Management
Board (CIWMB), Regional Water Quality Control Board (RWQCB) and
SCAQMD.
Section 95471(b) Test Methods and Procedures, Determination of
Landfill Gas Heat Input Capacity
The RCWMD has discussed this section with CARB staff member
Renaldo Crooks and sent several e-mails on this topic.  The section
was not clear on how to measure gas heat input capacity where an
existing control device is in place, e.g. flares.  It appears that
the last line in Section 95471 (b)(1), “Site-specific data may be
substituted when available”, was added to the 3/18/09 version of
the regulation order to try to address this concern.  However, the
RCWMD requests that this last sentence be changed as follows:
 “Site-specific data may can be substituted when available.”  
The RCWRMD has communicated with Mr. Crooks regarding adding a 4th
option to section 95471 "Test Methods and Procedures" (b)
"Determination of Landfill Gas Heat Input Capacity" to the order. 
Currently, the draft proposed order lists three types of devices:
(1) Landfills Without Carbon Adsorption Systems; (2) Landfills With
Carbon Adsorption Systems; and (3) Landfills with Passive Venting
Systems.  The RCWMD currently operates ten flares and believes that
this data can be determined from annual flare source test reports. 
The RCWMD requests that the following be added to the final
regulations to allow for the heat input capacity determination for
flares:
95471(b)(4) Enclosed Flare:  The landfill gas heat capacity must
be determined by measuring the actual total landfill gas flow rate,
in standard cubic feet per minute (scfm), using a flow meter or
other flow measuring device such as a standard pitot tube and
methane concentration (percent by volume) using a hydrocarbon
detector meeting the requirements of 95471(a). The total landfill
gas flow rate must be multiplied by the methane concentration and
then multiplied by the gross heating value (GHV) of methane of
1,012 Btu/scf to determine the landfill gas heat input capacity.
Section 95471(e) Test Methods and Procedures, Determination of
Expected Gas Generation Flow Rate
Section 95471(e) states, “The expected gas generation flow rate
must be determined as prescribed in the 2006 Inter Governmental
Panel on Climate Change (IPCC) Guidelines for National Greenhouse
Gas Inventories, Chapter 3, which is incorporated by reference
herein, using a recover rate of 75 percent.”  The RCWMD requests
that the text be changed as follows:
The expected gas generation flow rate must be determined as
prescribed in the 2006 Inter Governmental Panel on Climate Change
(IPCC) Guidelines for National Greenhouse Gas Inventories, Chapter
3, which is incorporated by reference herein, using a recover rate
of 75 percent.  Site-specific data can be substituted when
available.

The RCWMD believes that using the existing flare flow rate
multiplied by 133% (the inverse of 75%) is a much better
determination of the gas generation flow rate than using the IPCC
spreadsheet that many landfill gas industry members have documented
as over estimating landfill gas flow rate in semi-arid and arid
environments.
Please feel free to call me or Mark Hunt of my staff at (951)
486-3200 should you have any questions or would like to discuss any
of the issues in our comment letter.

								Sincerely,
								Hans W. Kernkamp
								General Manager-Chief Engineer

ACMD/MH:acmd/mh

cc: 	Renaldo Crooks, CARB
	Daniel E. Donohoue, CARB
	Joe McCannAngela DufresneMark HuntNoah Rau

PD# 77555