On November 10th, RCRC submitted formal comments to the California Air Resources Board (CARB) on its proposed updates to the Landfill Methane Regulation.
RCRC joined a broad industry and local government coalition letter (available here) and also submitted its own comment letter (found here) focusing on more granular policy and implementation challenges.
CARB proposed updates to its existing Landfill Methane Regulation (LMR) on September 23 and will conduct a public hearing on the measure at CARB’s November 20th Board Meeting.
The Notice of Public Hearing can be found here, the Initial Statement of Reasons here, and the Proposed Regulation here. RCRC’s draft summary of the proposed changes can be found here.
Originally adopted in 2010, the LMR was one of the state’s first efforts to reduce greenhouse gas emissions under Assembly Bill 32. The LMR requires landfills to install and operate landfill gas collection and control systems, with a few exceptions for very small facilities.
The proposed updates to the LMR are expected to improve methane control, monitoring, and detection to reduce emissions and facilitate the earlier detection and prevention of subsurface elevated temperature events.
Some of the major provisions identified by CARB include:
- Methane emissions monitoring and repair actions:
- Requiring inspection and repair when operators are notified of a remotely-detected methane emission plume;
- Increasing the stringency of landfill surface and component leak monitoring procedures, including increasing coverage by removing exemptions from monitoring, reducing corrective action timelines, and increasing frequency at certain landfills; and
- Reconsidering all previously-approved existing alternative compliance measures.
- Improving GCCS operations:
- Requiring earlier installation and operation of gas collection infrastructure in areas of new waste deposition;
- Limiting periods of GCCS downtime to 120 hours per year;
- Expanding wellhead monitoring parameters and analysis, and requiring response actions for out-of-range values or large changes in values; and
- Requiring more frequent monitoring, analysis, and mitigation measures including cover improvement in areas with persistent leaks or other issues.
For more information, contact RCRC Senior Policy Advocate, John Kennedy.