[USCC] Fwd: Landfill Gas Energy Recovery, NRC Position

[Jim McNelly]

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From: "Peter Anderson" <anderson@recycleworlds.org>
To: <jim_leyshon@nrel.gov>
Subject: Landfill Gas Energy Recovery - National Recycling Coalition=
 Position
Date: Mon, 5 Nov 2001 14:43:27 -0600
I represent the Landfill Group of the National Recycling Coalition. As part=
=20
of our work, we have done the only extensive investigation of the factual=20
underpinnings of the landfill gas energy recovery (LFGER) issue from a=20
party that is independent of those with a financial interest in maintaining=
=20
dependence on landfills.
We have found that the current underpinnings of the policy to encourage=20
LFGER in the report cited below, "Forecasting the Growth of Green Power=20
Markets in the U.S," as with others from DOE and EPA, are, first,=20
inaccurate and, second, fail to look "outside the landfill box" where more=
=20
energy can be recovered compared to LFGER systems and without the fatal=20
flaws in current landfill designs.
For both these reasons, and as is summarized below, the inclusion of=20
landfill gas among the sources of green power would be a major setback for=
=20
the green power movement. For one thing, if maximizing energy recovery from=
=20
the latent energy value of discarded materials is the criteria,=20
bioconversion of source-separated organic matter will generate several=20
times more electricity than the very small fraction of methane generation=20
actually captured in gas extraction systems in landfills. For another,=20
marketing green power depends upon its sources being free of substantive=20
controversy over its environmental benefits. LFGER derives from obsolete=20
practices being abandoned in the rest of the developed world because of=20
their insoluble environmental impacts.
We fully understand the DOE's and green marketers' basis for supporting=20
LFGER under the assumption that, by productively utilizing the Btu value in=
=20
the gases otherwise flared, combustion -- and methane emissions -- in power=
=20
production elsewhere is displaced.
However, here are some of the key facts that the landfill industry may have=
=20
failed to share with green marketers about the landfill environment that=20
completely turns conventional wisdom upside down:
(1) There is no factual basis for EPA's assumption that 75% of landfill=20
gases are captured at those sites with gas collection systems.
(2) It would be difficult to make a factual case that much more than 10% of=
=20
total gas emissions from landfills are actually captured.*
(3) Concerns with landfill gas emissions are not bounded by methane=20
emissions, but also, include both carcinogenic volatile organic compounds,=
=20
the bioaccumulative dimethyl form of mercury that is a lethal nerve gas=20
produced during decomposition, and presumably other toxic compounds from as=
=20
yet poorly understood interactions in a landfill environment.
(4) A manager operating a landfill for energy recovery will tend to=20
increase the vacuum pressures at the core of the landfill where methane=20
generation is densest, and consequently reduce draw from the periphery of=20
the site. This operational change tends to increase non-methane emissions=20
released in closest proximity to those living or working near the landfill.
(5) Because landfill barriers, liquid removal and monitoring systems "will=
=20
ultimately fail" in decades (EPA's words), while everyone acknowledges the=
=20
waste load in lined landfills remain hazardous for centuries, current=20
designs do not prevent groundwater contamination. Rather, they only delay=20
the onset of pollution, and to the very worst time -- after all of the=20
responsible parties have left the scene and the detection and liquids=20
removal systems have failed.
(6) The key common component of all these environmental threats is the=20
organic fraction of the waste stream (unrecovered paper, food scraps and=20
yard trimmings constituting 63% of currently landfilled waste after current=
=20
recovery efforts are accounted for). As organic matter decomposes, it=20
creates leachate that draws out the toxic constituents from the waste that=
=20
ultimately find their way into drinking water supplies after the barriers=20
fail. Organics also generate the greenhouse gas methane that transports=20
VOCs and dimethyl mercury into the atmosphere. This is precisely why the=20
European Community has regulated the phase-out of land disposal of organic=
=20
matter, and why co-disposal of organics and non-compostable waste in the=20
ground is a discredited and obsolete practice that is out-of-place in the=20
21st century.
(7) The source of the methane from landfills -- most of which is NOT=20
captured -- derives from the anaerobic decomposition of those same organic=
=20
materials that create the myriad environmental problems which cannot safely=
=20
be managed in the ground (described in par. 6). For this reason, it is=20
important that those promoting LFGER understand the debilitating failings=20
of landfill systems.
(8) One solution that appears to be extremely promising is to build on=20
current diversion policies that have shown themselves to be practical and=20
successful. Just like we currently source separate approximately 30% of our=
=20
containers, newspapers and cardboard for recycling, we should give the most=
=20
serious consideration to source separating our organic material for either=
=20
composting or other bioconversion technologies to create methane. And,=20
controlled in-vessel decomposition of that single-stream organic matter=20
would recover 100% of the waste's energy value without toxic complications,=
=20
not the 10-20% captured from landfills with all of the associated concerns=
=20
for public health.
While recovery of landfill gas for energy should be accomplished where it=20
already exists, recovery should be mandated to protect local populations=20
and to meet air pollution and/or climate change related laws and policies.=
=20
Subsidizing the recovery is counter-productive in that it creates=20
significant disincentives in the marketplace for the constructive -- and=20
truly "green" -- alternative to take hold.
The purpose of mentioning all this is to suggest that the discussion of=20
renewable options on these pages ought to include debate over these=20
contrarian facts that undermine one facet of current green marketing plans.=
=20
The opposing facts are so compelling that it is only a matter of time=20
before any green marketer associated with landfill gas will find his or her=
=20
entire portfolio needlessly compromised.
For these reasons, we request an opportunity to present a paper laying out=
=20
these issues, and the citations for them, so that others may react and a=20
debate unfurl. We would hope that you would agree that any further=20
encouragement of LFGER as part of a portfolio of green energy options ought=
=20
to await the fuller analysis we propose.
Thank you for your attention.
Peter Anderson, Chair
Landfill Group
National Recycling Coalition
_______________________
* One of the reasons why landfill gas extraction systems are so inefficient=
=20
is that the vertical collection pipe that pull some of the gas from the=20
landfill with a vacuum pump cannot properly be perforated to draw gas into=
=20
the line at the top to =BD of the tube. Otherwise oxygen might also be=
 pulled=20
from the surface that would be explosive when mixed with methane. Nor can=20
the pipes be drilled to the bottom of the waste load or the pipe will=20
penetrate the bottle liner when the waste load decomposes and subsides.=20
These factors significantly limit the draw at the top and bottom of the=20
landfill.
In addition, variation in waste densities and barriers to gas flow in a=20
landfill from plastic garbage bags and other impediments makes it difficult=
=20
to uniformly draw the gas that aggregates in pools unless the pipe happens=
=20
to have, by chance, been drilled directly adjacent to a gas pool.=20
Similarity, pools of leachate that can be found perched high in the waste=20
load can flood the pipes, and the gravel pack surrounding pipes can become=
=20
plugged. At greater depths, the densities become so great that permeability=
=20
is reduced to the point that water flows are impeded.
An even greater set of operating limitations is not reflected in the 50%=20
estimates. Often gas collection systems are not installed for 7-10 years=20
after waste emplacement begins. By that time, almost half of the first wave=
=20
of gas has been generated and emitted uncontrolled into the atmosphere.=20
Moreover, far more than half of the total gas generated by today s=20
landfills will occur in a second wave of gas generation decades in the=20
future after the end of the mandated post-closure period when the landfill=
=20
cover will fail and rainfall enters the site. By that time, the gas=20
collection systems will have been removed from service and all gas releases=
=20
will be uncontrolled.
Lastly, EPA rules mandating the installation of gas collection systems only=
=20
covered 54% of the waste in the ground in 2000, the rest being at sites=20
which were closed before the effective date of the air regulations for=20
landfills, or are in landfills smaller than the threshold for coverage set=
=20
by the rules.

______________________________
Peter Anderson
RECYCLEWORLDS CONSULTING Corp
4513 Vernon Blvd. Suite 15
Madison, WI 53705
(608) 231-1100
Fax (608) 233-0011
<mailto:anderson@recycleworlds.org>anderson@recycleworlds.org

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From: &quot;Peter Anderson&quot; &lt;anderson@recycleworlds.org&gt;=20
<br>
To: &lt;jim_leyshon@nrel.gov&gt; <br>
Subject: Landfill Gas Energy Recovery - National Recycling Coalition
Position <br>
Date: Mon, 5 Nov 2001 14:43:27 -0600<br>
I represent the Landfill Group of the National Recycling Coalition. As
part of our work, we have done the only extensive investigation of the
factual underpinnings of the landfill gas energy recovery (LFGER) issue
from a party that is independent of those with a financial interest in
maintaining dependence on landfills.<br>
We have found that the current underpinnings of the policy to encourage
LFGER in the report cited below, &quot;Forecasting the Growth of Green
Power Markets in the U.S,&quot; as with others from DOE and EPA, are,
first, inaccurate and, second, fail to look &quot;outside the landfill
box&quot; where more energy can be recovered compared to LFGER systems
and without the fatal flaws in current landfill designs.<br>
For both these reasons, and as is summarized below, the inclusion of
landfill gas among the sources of green power would be a major setback
for the green power movement. For one thing, if maximizing energy
recovery from the latent energy value of discarded materials is the
criteria, bioconversion of source-separated organic matter will generate
several times more electricity than the very small fraction of methane
generation actually captured in gas extraction systems in landfills. For
another, marketing green power depends upon its sources being free of
substantive controversy over its environmental benefits. LFGER derives
from obsolete practices being abandoned in the rest of the developed
world because of their insoluble environmental impacts.<br>
We fully understand the DOE's and green marketers' basis for supporting
LFGER under the assumption that, by productively utilizing the Btu value
in the gases otherwise flared, combustion -- and methane emissions -- in
power production elsewhere is displaced. <br>
However, here are some of the key facts that the landfill industry may
have failed to share with green marketers about the landfill environment
that completely turns conventional wisdom upside down:<br>
(1) There is no factual basis for EPA's assumption that 75% of landfill
gases are captured at those sites with gas collection systems.<br>
(2) It would be difficult to make a factual case that much more than 10%
of total gas emissions from landfills are actually captured.*<br>
(3) Concerns with landfill gas emissions are not bounded by methane
emissions, but also, include both carcinogenic volatile organic
compounds, the bioaccumulative dimethyl form of mercury that is a lethal
nerve gas produced during decomposition, and presumably other toxic
compounds from as yet poorly understood interactions in a landfill
environment.<br>
(4) A manager operating a landfill for energy recovery will tend to
increase the vacuum pressures at the core of the landfill where methane
generation is densest, and consequently reduce draw from the periphery of
the site. This operational change tends to increase non-methane emissions
released in closest proximity to those living or working near the
landfill.<br>
(5) Because landfill barriers, liquid removal and monitoring systems
&quot;will ultimately fail&quot; in decades (EPA's words), while everyone
acknowledges the waste load in lined landfills remain hazardous for
centuries, current designs do not prevent groundwater contamination.
Rather, they only delay the onset of pollution, and to the very worst
time -- after all of the responsible parties have left the scene and the
detection and liquids removal systems have failed.<br>
(6) The key common component of all these environmental threats is the
organic fraction of the waste stream (unrecovered paper, food scraps and
yard trimmings constituting 63% of currently landfilled waste after
current recovery efforts are accounted for). As organic matter
decomposes, it creates leachate that draws out the toxic constituents
from the waste that ultimately find their way into drinking water
supplies after the barriers fail. Organics also generate the greenhouse
gas methane that transports VOCs and dimethyl mercury into the
atmosphere. This is precisely why the European Community has regulated
the phase-out of land disposal of organic matter, and why co-disposal of
organics and non-compostable waste in the ground is a discredited and
obsolete practice that is out-of-place in the 21st century.<br>
(7) The source of the methane from landfills -- most of which is NOT
captured -- derives from the anaerobic decomposition of those same
organic materials that create the myriad environmental problems which
cannot safely be managed in the ground (described in par. 6). For this
reason, it is important that those promoting LFGER understand the
debilitating failings of landfill systems.<br>
(8) One solution that appears to be extremely promising is to build on
current diversion policies that have shown themselves to be practical and
successful. Just like we currently source separate approximately 30% of
our containers, newspapers and cardboard for recycling, we should give
the most serious consideration to source separating our organic material
for either composting or other bioconversion technologies to create
methane. And, controlled in-vessel decomposition of that single-stream
organic matter would recover 100% of the waste's energy value without
toxic complications, not the 10-20% captured from landfills with all of
the associated concerns for public health.<br>
While recovery of landfill gas for energy should be accomplished where it
already exists, recovery should be mandated to protect local populations
and to meet air pollution and/or climate change related laws and
policies. Subsidizing the recovery is counter-productive in that it
creates significant disincentives in the marketplace for the constructive
-- and truly &quot;green&quot; -- alternative to take hold. <br>
The purpose of mentioning all this is to suggest that the discussion of
renewable options on these pages ought to include debate over these
contrarian facts that undermine one facet of current green marketing
plans. The opposing facts are so compelling that it is only a matter of
time before any green marketer associated with landfill gas will find his
or her entire portfolio needlessly compromised.<br>
For these reasons, we request an opportunity to present a paper laying
out these issues, and the citations for them, so that others may react
and a debate unfurl. We would hope that you would agree that any further
encouragement of LFGER as part of a portfolio of green energy options
ought to await the fuller analysis we propose.<br>
Thank you for your attention.<br>
Peter Anderson, Chair <br>
Landfill Group <br>
National Recycling Coalition<br>
_______________________ <br>
* One of the reasons why landfill gas extraction systems are so
inefficient is that the vertical collection pipe that pull some of the
gas from the landfill with a vacuum pump cannot properly be perforated to
draw gas into the line at the top to =BD of the tube. Otherwise oxygen
might also be pulled from the surface that would be explosive when mixed
with methane. Nor can the pipes be drilled to the bottom of the waste
load or the pipe will penetrate the bottle liner when the waste load
decomposes and subsides. These factors significantly limit the draw at
the top and bottom of the landfill.<br>
In addition, variation in waste densities and barriers to gas flow in a
landfill from plastic garbage bags and other impediments makes it
difficult to uniformly draw the gas that aggregates in pools unless the
pipe happens to have, by chance, been drilled directly adjacent to a gas
pool. Similarity, pools of leachate that can be found perched high in the
waste load can flood the pipes, and the gravel pack surrounding pipes can
become plugged. At greater depths, the densities become so great that
permeability is reduced to the point that water flows are impeded.<br>
An even greater set of operating limitations is not reflected in the 50%
estimates. Often gas collection systems are not installed for 7-10 years
after waste emplacement begins. By that time, almost half of the first
wave of gas has been generated and emitted uncontrolled into the
atmosphere. Moreover, far more than half of the total gas generated by
today s landfills will occur in a second wave of gas generation decades
in the future after the end of the mandated post-closure period when the
landfill cover will fail and rainfall enters the site. By that time, the
gas collection systems will have been removed from service and all gas
releases will be uncontrolled.<br>
Lastly, EPA rules mandating the installation of gas collection systems
only covered 54% of the waste in the ground in 2000, the rest being at
sites which were closed before the effective date of the air regulations
for landfills, or are in landfills smaller than the threshold for
coverage set by the rules.<br>
<br>
______________________________ <br>
Peter Anderson <br>
RECYCLEWORLDS CONSULTING Corp <br>
4513 Vernon Blvd. Suite 15 <br>
Madison, WI 53705 <br>
(608) 231-1100 <br>
Fax (608) 233-0011 <br>
&lt;<a href=3D"mailto:anderson@recycleworlds.org" eudora=3D"autourl"><font=
 color=3D"#0000FF"><u>mailto:anderson@recycleworlds.</a><a=
 href=3D"mailto:anderson@recycleworlds.org"=
 eudora=3D"autourl">org</a></u></font>&gt;anderson@recycleworlds.org<br>
</html>

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