Comment Log Display

Comments on California’s Climate Change Draft Scoping Plan
June 2008 Discussion Draft

These comments pertain to Section 7 (Recycling and Waste
Management)

Other Measures Under Evaluation

Another aspect of California’s waste management sector that should
be included in the Climate Change Scoping Plan is the clean-up of
waste management facilities.  These are facilities at which wastes
have been mismanaged in the past, often resulting in soil and/or
ground water contamination.  Clean-up efforts can last decades and
often require high usage of fossil fuels and electricity, which
generates greenhouse gases.  It is DTSC’s interest to improve
clean-ups at waste management facilities so that their use of
fossil fuels and electricity is reduced, while at the same time
the effectiveness of the clean-ups is assured.

Opportunities for reducing greenhouse gas emissions during
clean-ups include:

•	Using biodiesel fuel in construction and excavation equipment
any time during the remedial process, which starts with
investigation and cleanup of sites
•	Running pumps and other equipment on solar or wind power rather
than grid electricity
•	Treating contamination with biologic processes rather than
energy-intensive mechanical or thermal processes

DTSC has begun exploring methodologies for evaluating existing
clean-ups to reduce their greenhouse gas emissions.  We are also
exploring ways to include a review of expected greenhouse gas
emissions as a factor in decision-making when we are selecting new
clean-up remedies or improving existing clean-up remedies.  In
addition, DTSC is currently testing proto-type methodologies at a
pilot site in California.  Federal EPA is also involved in similar
efforts.
  
Recommendations for actions are:

•	Develop a methodology for estimating green house gas emissions
from clean-up sites
•	Identify opportunities for reducing green house gas emissions
from these existing clean-ups
•	Apply the methodology to new clean-up decisions
•	Apply the methodology for evaluation of the remediation once the
remedy is in place (often referred to as “remediation process
optimization”)

Clean-ups in California are conducted under a variety of State
programs, including Brownfields and Environmental Restoration
Program and Hazardous Waste Management Permitting Programs. 
Federal EPA also conducts clean-ups in California under federal
Superfund, RCRA* Corrective Action, and Underground Tank programs.
 At present there are no state or federal regulatory requirements
for including greenhouse gas emissions as a factor in
decision-making for clean-ups.  However, DTSC is exploring ways in
which to encourage facility owners or responsible parties to
participate in reviews of their clean-ups.  

DTSC is still at an early stage in understanding the levels of
emissions of greenhouse gases that occur as a result of clean-ups
of waste management facilities, and therefore do not have
estimates for potential 2020 reductions to be realized as a result
of the recommended actions noted above.  However, it is important
to include these clean-ups of waste management facilities in the
Climate Change Scoping Plan in order to create awareness of this
additional source of greenhouse gases that could potentially be
reduced.

We include as references the following documents and web links,
which we believe will be useful as descriptions of potential
climate impacts from hazardous waste sites remediation:

DTSC’s Emerging Issues – Green Remediation: 
http://www.dtsc.ca.gov/emerging_issues.cfm
EPA's Green Remediation Website: 
http://cluin.org/greenremediation/
EPA's Green Remediation Primer: 
http://cluin.org/download/remed/Green-Remediation-Primer.pdf
Fact Sheet on Green Remediation: forwarded as pdf

* Resource Conservation and Recovery Act