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Leslie Kochan, Waste Reduction Specialist, NW region, Oregon
DEQ
Please reference the attached materials, as required. I am
asking the DEQ for aformal statement which clarifies the additional
credit available for eliminating
the methane plume from a landfill and the emissions from the
exhaust stream.
The DEQ recognizes maximizing the benefit of recycling solid
waste, wastewatersludge, and biomass. The DEQs additional credit
assessment is currently atodds with the IRS tax code. The IRS tax
code repeals the tax exempt bondfinancing safe harbor for
infrastructure based upon recycling volumes. Accordingto the IRS
tax code, waste recycled above 35% by weight or volume, is
treatedas a commodity. Any political subdivision (city, county,
wasteshed, municipalservice district, utility district or regional
waste authority in the state) utilizing tax-exempt bond financing
of landfills or waste water treatment facilities recyclingabove
that threshold indicates an IRS finding that the political
subdivision is
engaged in non tax-exempt recycling.
We suggest that the best way for a political subdivision to
comply with Oregonlaw and the IRS tax code is to transfer title
through an exchange (goods orservices for title). Our solution is
to offer a tolling arrangement (transfer care,custody, and control
of the recyclable materials for value added goods andservices in
the form of other valuable consideration) at the point of
custodytransfer. Political subdivisions wont give away a commodity
without anexchange (ORS) of goods and services.
Our solution for attaining maximum compliance while generating
the greatest
additional credit from DEQ enables our facility to assign the
additional credit tothe political subdivision. The DEQ recognizes
that all recycling/remediationefforts are not equal. Rewarding
better environment attributes should beawarded (additional
credits). From DEQs publication:
2% of composting should translate to 2% additional credit.
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These additional credits can be evaluated and quantified through
a full audittrail of real time data collection. A DEQ
representative should address regularmeter settlement dates at the
recycling facility at least once per quarter.Calibration of test
equipment and certifiable results assure each community ofmaximum
benefits by weeding out less capable technologies.
All impacts should be measured. Notably the storm water effluent
parameters(outgassing and leaching or seepage) and the volumes
treated. The net resultsprescribe how the total volumes are
diminished (variable data). A comprehensiveassessment for
additional credits is factually predicated. SCADA provides apublic
record for awarding additional credits from all point source
pollution orwaste streams.
Separating the combustible waste at the MRRF is the least level
of compliancepossible. After recyclables and non-combustibles are
removed the remainingfractions of solid waste, biomass, plastics,
and sludge can be incinerated and
reduced to ash, electricity, and exhaust gases. The wastesheds
that burnprocessed waste can recycle by conversion near 100% of the
remainingcombustibles. That would leave no left over portions to
outgas or seep via landfillentrainment.
A ZESC process should earn additional credit over traditional
waste-to-energyconversion (i.e. Covanta)
1) Turning the ash into the greenest brick or foamed
cellularconcrete.
Covantas facility in Brooks entrains their ash in the landfill.
Our process utilizesthat ash as building/construction
materials.
2) Converting the CO2, NOx, and SOx into near zero
emissions.
Covantas facility in Brooks emits gaseous effluent from
smokestacks. Ourprocess does not require a smokestack. What
additional credits would a ZESCearn for not emitting Hg, As, or 50
micron particulates like coal-fired emissions?
3) Eliminating the invisible methane plume rising above the
landfill.
The waste that the Metro wasteshed transfers out to the
Arlington Landfilloutgases methane. Our process prevents landfill
oxidation and decompositionthat produces methane emissions. RPS
enables greentags, carbon offsets orRECs to be tied to electronic
measures of additional credits issued by the DEQper pound/ton or
KWh.
4) Reducing/Eliminating the threat of a cracked HDPE liner that
mightallow seepage or leaching into the fresh water aquifer.
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By diverting combustibles, we assist the landfill in maintaining
integrity of theirliners. Extending the landfill life and allowing
excavation/remediation of facilitiesand testing or monitoring
conditions. What credit will the DEQ award forpreserving our fresh
water aquifer from invasion?
Our process deserves additional credit by providing direct SCADA
telemetrydelivered to the DEQ which enables remote monitoring of
the critical variables:
A. Scale weights of all deliveries.B. Exhaust gas emissions data
with pre-set alarmsC. Monitoring by GC the methane out-gassing
profile of the landfillD. Ground water sampling and testing.
We have proposed to underwrite the equipment costs and
installation costs
rather than requesting DEQ/taxpayer laying out capital, assets,
or credit.
Please describe the DEQs additional credit criteria that would
be awarded by theDEQ for results confirmable as described.
Sincerely,
Marni ZollingerZESC Developer
Cc:
METRO CouncilJessica Zulofo, Director, USDARepresentative Nick
KahlState Senator Laurie Monnes AndersonMary Gautreux, State
Director for Senator Wyden
