SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 1 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 

## APPENDIX B

Emission Reductions Analysis For Revised Proposed New Rule 4566

August 18, 2011SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 2 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 This page intentionally blank.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 3 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 EMISSION REDUCTION ANALYSIS FOR PROPOSED NEW RULE 4566 (ORGANIC MATERIAL COMPOSTING OPERATIONS)

I. SUMMARY

This appendix details the estimated volatile organi c compounds (VOC) emissions and emission reductions for Revised Proposed New Rule 4 566 (Organic Material Composting Operations). Revised Proposed New Rule 4566 would begin achieving emissions reductions in 2012, with full implementat ion starting in 2016.

In the course of rule development for Rule 4566, th e District found that the total emissions inventory for the Composting-Greenwaste c ategory is much smaller than

estimated in the 2007 Ozone Plan . However, the District also found that there is a much greater emissions reduction percentage than pr eviously estimated. Table 1 summarizes the baseline inventory and reductions fr om the 2007 Ozone Plan as compared to the inventory compiled during the devel opment of Rule 4566. The actual percent reduction from the rule can be applied to t he plan baseline to determine the estimated reductions as a “SIP currency” equivalent . Section III of this appendix provides more detail on this data and calculations.

Table 1: Summary of Composting VOC Emissions and Em ission Reductions

Year Inventory Estimated

baseline

emissions (tons/year) Estimated

emissions

after control (tons/year) Estimated VOC

emission

reductions (tons/year) Percent

reduction

2012 2007 Ozone Plan 20,805 17,520 3,285 16%

Updated, Rule 4566 5,064 3,799 1,265 25% 1

Revised reductions, SIP currency equivalent. Apply Rule 4566 percent reduction to 2007

Ozone Plan baseline. 5,201
(14 tons per day)

2017 2007 Ozone Plan 23,360 19,710 3,650 16%

Updated, Rule 4566 5,064 3,546 1,518 30% 2

Revised reductions, SIP currency equivalent. Apply Rule 4566 percent reduction to 2007

Ozone Plan baseline. 7,008
(19 tons per day) 1. 2012 emission reductions include stockpile and w atering system requirements after one year of rule adoption date. The emission reductions from o ne facility that is subject to the finished compost cover requirements and is already implement ing the finished compost cover is included. 2. 2017 emissions reductions include all requiremen ts after five years of rule adoption date.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 4 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 The 2007 Ozone Plan estimated an emission reduction for the Composting Green Waste (S-GOV-5) control measure of 16% from the Pla n baseline, upon final implementation of the rule requirements. The estim ates are based on the best available information at the time that this report was writte n. Based on the updated data, District staff estimates emission reductions of approximatel y 1,265 tons per year (tpy) or a reduction of 25% of the baseline VOC emissions by 2 012. The emissions reduction that would be achieved by 2012 include all facilities th at would be implementing the watering system and the facility that is already in complian ce with both the watering system and finished compost cover requirements.

When the 2010 emission inventory baseline reduction s (overall of 30%) are applied to the 2017 Ozone Plan baseline emissions of 23,360 to ns per year, the equivalent reduction is 19 tons per day by the time that this rule is fully implemented. The

emission reductions that would be achieved with the Revised Proposed New Rule 4566 requirements exceed the projected reductions in the 2007 Ozone Plan and would also

meet RACT.

II. INTRODUCTION

The purpose of Revised Proposed New Rule 4566 is to control VOC emissions from composting facilities. This rule applies to facili ties involved with the composting or stockpiling of organic materials. Operators would be required to control the VOC emissions from their organic material stockpiles an d composting piles. Operators will have the option to utilize the rule-required contro l measures or alternative control measures that demonstrate equivalent VOC emission r eductions. For this emissions reduction analysis, the breakdown of carbon-based c hemicals by microorganisms in the organic material is the source of VOC emissions. S ection III of this appendix details the

calculations for the estimated emissions and emissi on reductions.

III. EMISSION REDUCTION ANALYSIS

A. Throughput Calculations

Throughout the rulemaking process, District staff h as researched and acquired available data for the organic material throughput for green material facilities. District staff has involved stakeholders in this process to obtain the best estimates for the amount of organic material that is generated in and imported into the San Joaquin Valley Air Basin (SJVAB) for the 2010 source inventory. Staff will continue to refine the analysis as new information and data becomes available during the r ule development process.

In November 2007, the District distributed applicat ions to all organic material processing facilities within the SJVAB to determine permit sta tus. More recently, District staff hasSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 5 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 worked with the facilities to update and refine the source inventory with 2010 data for a more accurate analysis.

An inventory was identified for organic material co mposting using the following sources:

• CalRecycle’s Solid Waste Information System (SWIS) (available online at http://www.calrecycle.ca.gov/SWFacilities/Directory / )

• Lists of green material facilities, submitted by C alRecycle in November 2007 and January 2008

• Public comment letters

• Stakeholders’ comments and facility information

• The District Permit to Operate database

• Completed PTO applications

An estimated throughput of the facilities within th e District’s three regions is provided in Table 2. The Northern Region consists of facilitie s located within San Joaquin County, Stanislaus County, and Merced County. The Central Region consists of the facilities located within Madera County, Fresno County, and Ki ngs County. The Southern Region consists of facilities located within Tulare County and Kern County. For the purpose of this rule development project, District staff used the actual throughput to conduct the emissions analysis. The potential thro ughput is the maximum permitted throughput and is used for the permitting process t hrough the District’s Permit Services Department. Some composting facilities that are cu rrently operating and not included in the District’s regional totals in Table 2 are co-co mposting facilities and are already subject to District Rule 4565 requirements.

Table 2: Composting Facilities Organic Material Thr oughputs

Region Actual Throughputs 1 (Tons/Year)

Northern 435,678 Central 131,798
Southern 490,707

TOTAL 1,058,183

1. Actual Throughputs: based on 2010 data from oper ators.

The estimates from Table 2 were used to determine t he emissions and emissions reduction for composting facilities.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

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For Revised Proposed New Rule 4566 B. Emission Factors

In May 2008, the District hired a consultant to rev iew and analyze all available emissions factors from several source tests for gre en material composting. A copy of the District’s Compost VOC Emission Factors report can be found at the following link: http://www.valleyair.org/Workshops/postings/2010/9- 22-10- rule4566/SJVAPCD%20Compost%20VOC%20EF%20Report%209- 15-10.pdf

The District has not identified relevant emission f actors for uncontrolled food material composting. Source tests from controlled compostin g operations have yielded emission factors ranging from 3.4 lb VOC per ton of food mat erial composted (micropore cover) to 37.1 lb VOC per ton of food material composted ( Ag Bag). In addition to the wide range of values observed, it is also unlikely that emissions from a covered system would accurately represent emissions from the open windro w commonly used by facilities in the District. This is because covered systems offe r many process control advantages, including weather protection and water retention. For these reasons, the District will use the green material composting emission factors as determined in the preliminary Green Waste Compost Report to represent this feed s tock until a more representative

emission factor can be identified.

The Composting VOC Emission Factors report presents the emission factors that the District will use for permitting and rule developme nt purposes. The emission factors used for all calculations are presented in Table 3, below. The emission factors presented are subject to revision should additional information become available.

Table 3: Emission Factors (EF)

Process Type Stockpile EF (lb/ton/day) Active Phase Windrow

Composting EF (lb/ton processed) Curing Phase Windrow Composting EF (lb/ton processed)

Organic material 1.06 5.14 0.57

C. Emission Reduction Efficiencies Used

Stockpile Operations The stockpile VOC emission reduction efficiency was estimated from the composting facilities typical stockpile storage times and the proposed rule required maximum threeday or ten-day stockpile storage time. The resulti ng VOC emission reduction efficiency will be used for this analysis as listed below:

• Maximum Three-Day Stockpile Storage Time : Consists of removing, covering, or composting the stockpiled organic materials with in three days of receipt. This option would limit the storage time for the compost ing operation with an organic material receiving volume of greater than or equal to 100,000 tpy.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 7 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 • Maximum Ten-Day Stockpile Storage Time : Consists of removing, covering, or composting the stockpiled organic materials within ten days of receipt. This option would provide a significant emission reducti on for composting opration with an organic material receiving volumes of less than 100,000 tpy.

Composting Operations

District staff has reviewed the results from the 20 09 compost field study conducted by the San Diego State University Research Foundation. The field study assessed the feasibility and effectiveness of VOC emission reduc tions from four mitigation measures. Two of the most effective mitigation measures ident ified in the field study were used for the composting operations analysis and are listed b elow:

• Watering System : Operator applies water to the windrows before eac h turn. The VOC reduction efficiency for this mitigation measur e is determined to be at least 19% by weight during active composting, as defined in the proposed rule.

• Finished Compost Cover : Operator applies a minimum 6-inch layer of finish ed compost on top of the windrows after each turn. Th e VOC reduction efficiency for this mitigation measure is determined to be at least 56% by weight during active composting, as defined in the proposed rule.

The watering system requirements would apply to a c omposting operation with an organic material receiving volume of less than 200, 000 tpy. For a composting operation with an organic material receiving volume of greate r than or equal to 200,000 tpy and less than 750,000 tpy, the operator would be requir ed to comply with both the watering system and the finished compost cover requirements. As show below, the District staff has derived a VOC control efficiency factor for imp lementing both the watering system and finished compost cover during active composting

.

The maximum combined control efficiency would assum e the control systems do not lose any of their individual effectiveness when com bined. However, since there is no supporting data for this, the combined control effi ciency will be discounted. Without actual test data on the combined controls, a 50% fa ctor has been chosen and will be applied to the increase in control due to the combi ned controls. Due to the nature of the controls, the District does not expect the effectiv eness of a control to lose more than

50% of its effectiveness when combined with another . As such, the District is comfortable with a 50% factor applied to the increa se as a conservative estimate.

By using the individual control efficiencies from t he mitigation measures above, the maximum combined VOC control efficiency resulted in at least 64% by weight of the material, calculated as follows:SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

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For Revised Proposed New Rule 4566 Combined VOC control efficiency = 56% + [(1 - 56%) x 19%] = 64%

Where: 56% = VOC control efficiency for the finishe d compost cover 19% = VOC control efficiency for the watering syst em

As stated above, the increase in VOC control effici ency from combining the mitigations measures will be conservatively reduced by 50% as f ollows:

Increase in control due to combining controls = 64% - 56% = 8%

Where: 64% = Maximum Combined VOC control efficienc y 56% = VOC control efficiency for the finished comp ost cover

Final Combined VOC control efficiency = 56% + (8% x 50%) = 60%

The combined VOC control efficiency of implementing both the finished compost cover and watering system during active composting is the refore 60%.

D. Emission and Reduction Calculations

In performing the analyses, several assumptions wer e made to estimate the emission

reductions. These include:

• All of the existing composting facilities would im plement the proposed mitigation measures or an equivalent alternative mitigation me asure, based on the facility throughput limit.

• Emission reductions from composting operations wit h an organic material receiving volume of less than 100,000 tpy are based on implementing the watering system and the maximum ten-day stockpile s torage time mitigation

measures.

• Emission reductions from composting operations wit h an organic material receiving volume of greater than or equal to 100,00 0 tpy and less than 200,000 tpy are based on implementing the watering system a nd the maximum three-day stockpile storage time mitigation measures.

• Emission reductions from composting operations wit h an organic material receiving volume of greater than or equal to 200,00 0 tpy and less than 750,000 tpy are based on implementing the watering system, finished compost cover and the maximum three-day stockpile storage time mitiga tion measures.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 9 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 • Emission reductions from composting operations wit h an organic material receiving volume of greater than or equal to 750,00 0 tpy are based on implementing the watering system, finished compost cover and the maximum three-day stockpile storage time mitigation measure s.

Stockpile and Composting Operations

Using the throughput information from the operators , staff calculated the estimated actual VOC emissions using the following equations:

Actual Stockpile VOC Emissions (tpy) = [Throughput (tpy) × Stockpile Storage Time (days)

× Stockpile EF (lb/ton/day)] ÷ 2,000 lb/ton

Actual Windrow VOC Emissions (tpy) = [Throughput (t py) × (Active Phase Windrow EF (lb/ton) + (Curing Phase Windrow EF (lb/ton))] ÷ 2,000 lb/ton

Total Current VOC Emissions (tpy) = Actual Stockpil e VOC Emissions (tpy) + Actual Windrow VOC Emissions (tpy)

Where: Throughput = Facility throughput in tons per year Stockpile Storage Time = Facility stated stockpile storage time in days. Stockpile EF = 1.063 lb/ton/day

Active Phase Windrow EF = 5.14 lb/ton Curing Phase Windrow EF = 0.57 lb/ton 2,000 lb/ton = Conversion factor

The VOC emissions resulting from the mitigation mea sures identified in Section III.C. above will be calculated using the following equati on:

Stockpile Emissions After Reductions (tpy) = [Throu ghput (tpy) × 3-day Stockpile Storage Time or Facility’s Storage Time, which ever is less

× Stockpile EF (lb/ton/day)] ÷ 2,000 lb/ton

Stockpile Emissions After Reductions (tpy) = [Throu ghput (tpy) × 10-day Stockpile Storage Time or Facility’s Storage Time, which ever is

less

× Stockpile EF (lb/ton/day)] ÷ 2,000 lb/ton

Active Phase Emissions After Reductions (tpy) = [Th roughput (tpy) × (Active Phase EF (lb/ton)

× (1 – CE)] ÷ 2,000 lb/ton

Curing Phase Emissions After Reductions (tpy) = [Th roughput (tpy) × (Curing Phase EF (lb/ton)

× (1 – CE)] ÷ 2,000 lb/ton

Total Emissions After Reductions (tpy) = Stockpile Emissions After Reductions (tpy) + Active Phase Emissions After Reductions (tpy) + Curing Phase Emissions After Reductions (tpy)SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 10 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 Where: Throughput = Facility throughput in tons per year Stockpile EF = 1.063 lb/ton/day

Active Phase Windrow EF = 5.14 lb/ton Curing Phase Windrow EF = 0.57 lb/ton CE = Percentage reductions from the mitigation mea sure. 2,000 lb/ton = Conversion factor

Table 4 shows the estimated current VOC emissions f rom composting facilities within

the District.

Table 4 : Total Current VOC Emissions from Composting Facilities

Throughput Number

of

Facilitie

s Estimated Throughput (tpy) Stockpile

Emissions (tpy) ActivePhase

Emissions (tpy) CuringPhase

Emissions (tpy) Total

Current

Emissions (tpy)
throughput < 100,000 tpy 13 397,457 1,551 1,021 113 2,685 100,000 tpy ≤ throughput < 200,000 tpy 1 103,108 110 265 29 404 200,000 tpy ≤ throughput < 750,000 tpy 2 557,618 384 1,432 159 1 ,975 throughput > 750,000 tpy N/A 0 0 0 0 0

Total 16 1,058,183 2,045 2,718 301 5,064SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reductions Analysis August 18 , 2011

B - 11 Final Staff Report with Appendices

For Revised Proposed New Rule 4566 Table 5 shows the estimated VOC emissions after red uctions from composting facilities

within the District.

Table 5 : Total VOC Emission After Reductions from Composting

Throughput

Classification Number of

Facilities Estimated

Throughput (tpy) Stockpile

Emissions (tpy) Active-Phase

Emissions (tpy) Curing-Phase

Emissions (tpy) Total Emissions

After Reductions (tpy)
throughput < 100,000 tpy 13 397,457 1,136 (Control) 827

(19% Control) 113

(No Control) 2,076

100,000 tpy ≤ throughput < 200,000 tpy 1 103,108 110 (Control) 215

(19% Control) 29

(No Control) 354

200,000 tpy ≤ throughput < 750,000 tpy 2 557,618 384 (Control) 573

(60% Control) 159

(No Control) 1,116

throughput > 750,000 tpy 0 0 0 (Control) 0

(80% Control) 0

(No Control) 0

Total 16 1,058,183 1,630 1

, 615 30 1 3,54 6

The total estimated composting emission reductions are the following:

Estimated VOC Emission Reductions = Total Current V OC Emissions (tpy)

-Total VOC Emissions After Reduction (tpy) = 5,064 tpy – 3,546 tpy

= 1,518 tpy

District staff estimates that current VOC emissions from current composting facilities are about 5,064 tons per year. After full rule impleme ntation, the current facilities will emit about 3,546 tons per year of VOCs for an estimated VOC emission reduction of about 1,518 tons per year or 30%.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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