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SEPT BY:Commerce ;12- 9-91 3:27RM i 7 i technically sound. Pacific Energy stands ready to provide any supporting data it has available and to assist in such review or in any other way it can. PEn summarizes its position as follows: e The quantity of condensate generated with extracted landfill gas is very small compared with the amount of liquid present in typical landfilled wastes. w Returning condensate to a landfill does not constitute 1°adding liquid" and the operation of the ener recovery facility results in a net reduction of 1 quids in the landf ill e r Returning condensate to a landfill does not eaningfully increase the likelihood of leachate intercepting the groundwater; nor does prohibiting such return meaningfully decrease that likelihood. • Condensate may have a foul odor, but laboratory analyses show that condensate is extremely low in dissolved substances. . Typically these are in the tens or hundreds of parts per billion or substances which are not severely toxic. • If condensate were to intercept the groundwater it probably would represent a small subordinate plume of much cleaner water within a plume of : leachate- cont inated (and severely contaminated) groundwater. It would almost certainly not represent significant degradation compared with the probable existing situation. e 'There are no studies to show any effect of condensate return or non- return ongroundwater quality. This is not the case for leachate. • The route to groundwater protection is leachate control. without leachate control condensate return is unlikely to affect groundwater contamination to any meaningful or measurable degree-. and leachate is almost curtain to be the problem if there is one. If leachate is effectively controlled, the groundwater problem is controlled, d condensate return is again irrelevant, f Proscribing condensate return represents an unnecessary significant burden on entities which extract and help control landfill gas emissions. It certainly provides no demonstrable benefit-- nor one that can reasonably be anticipated.