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SE6T EKY:Commerce ;12- 9-91 3:23AM ;# S j. f 3 • PEn believes that there are no defensible studies to show that returning condensate to a landfill has any bearing on groundwater contamination. Further, PEn believes there are no studies to show groundwater quality improvement due to proscribing condensate return. Furthermore, PEn believes it will not be possible to perform such successful studies because the impacts of condensate return, or failure to return$ has no measurable impact on groundwater quality. Justifications for these views are presented below. CONDENSATE- - WHAT IS IT Leachate is the liquid formed in wastes due to the chemical formation of Water, the gradual liberation of bound water in the waste, the incorporation of free 11 Id. in the wastes themselves, and the addition of exogenous liquids to the waste (i .e. , rainwater infiltration) . Leachate typically contains very high concentrations of dissolved and ionic solids, including heavy metal compounds, along with significant amounts of all the organic species found in condensate. It tends to be very high in dissolved and suspended solids. It may also contain some oils and non- volatile li qAids that have been introduced as part of the waste stream. The Appendix shows typical leachate composition data. In contrast, landfill gas condensate is mostly water With small amounts of the various volatile organic substances normally j present in landfill gas . Thug it contains small amounts of the over organic acide, chlorinated hydrocarbons and other trace species. In addition, it is likely to contain small amounts of leachate that may be transported as aerosol or by shear forces up the collection system well pipes. Typically it is very low in ionic species , such as sodium, sulfates and Meavy metals . CONDENSATE REMOVAL/RETURN Estimates * Rated of Liguid Extrac pion with LFfi It can be seen that the amount of moisture typically removed from a landfill with extracted LFQ is very small. It is on the order of two- tenths of one percent per year. Regardingthe amount returned, this is even less since some of the mosture enters the combustion unit (flare or, in Pacific Energy's case, reciprocating engines) and is discharged to the atmosphere. The amount requiring disposal is probably on the order of one- tenth of one percent per year of the total landfill moisture content.