**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 1 **Final Staff Report for Rule 4565** 

# APPENDIX B **EMISSION REDUCTION A**  **NA LYSIS FOR REVISED PROPOSED NEW**  **RULE 4565 (**  **BIOSOLIDS, A NIMA**  **L MA NURE, A**  **ND POULTRY LI TTER**  **OPERA TIONS**  **) March 30, 2007** **SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 2 **Final Staff Report for Rul e 4565**  **I. SUMMA**  **RY** This appendix details the estimated VOC emissions and emission reductions fo r Rule 4565 ( Biosolids, Animal Manure, and Poultry Litter Operations) . These estimates are based on the best available information at the time that this report was written. Table 1 summarizes the results of the detailed calculations, which are shown in S ection III. Based on this data, District staff estimates emission reductions of approximately 1,430 tons per year (tpy) or a reduction of 41% of the baseline VOC emissions. TABLE 1

– Summary of Emissions and Emission Reductions Operation Category Estim ated Current

Emissions (tpy) Estimated Emissions

After Control (tpy) Estimated VOC Emission Reductions (tpy) Landfill 0.0 0.0 0.0 Land Application 847.8 56.5 791.3 Compost 2,682.6 2,044.7 637.9 TOTALS 3,530.5 2,101.2 1,429.2
**II. INTRODUCTION**  The pu rpose of Rule 4565 is to control VOC emissions from biosolids, animal manure and poultry litter. The rule applies to facilities that landfill, land apply, or compost these materials. Operators would have a menu of control options to meet the rule require ments. The menu provides operators with the flexibility to find the most cost
effective compliance option for their processes. For this emission reduction analysis, the breakdown of carbon
- based chemicals by microorganisms in the biosolid, manure, or litter is the source of VOC emissions. Section III of this appendix details the assumptions and calculations for the estimated emissions and emission reductions. Section IV lists the references used in performing this analysis.
**III. EMISSION REDUCTION A**  **NA LYSIS**  **A. Throughput Calculations**  The rule applies to three types of operations: landfill, land application, and compost/co
composting. Of the three, composting/co
- composting operations have at least some information about throughput. The California In tegrated W aste Management Board (CIW MB) Solid W aste Information System (SW IS) is a database that tracks the maximum throughput of all types of solid waste handling facilities required to report operational data to CIW MB and the database is updated at least weekly. This database was queried on May 9, 2006 for composting facilities. Facilities within the District that list biosolids, manure, or “agricultural” as an accepted waste were included**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 3 **Final Staff Report for Rul e 4565**  in the calculations. The term “agricultural” could include anim al bedding with manure or litter mixed in. Maximum throughput in units other than tpy was converted, as needed. Wh en more than one waste stream was listed, District staff assumed that 50% of the throughput was greenwaste with a bulk density of 0.38 tons per cubic yard and the balance was biosolid, manure, or poultry litter with bulk density of 0.78 tons per cubic yard. There was one facility listed as accepting biosolids exclusively. Additionally, facilities were assumed to be open five days per week an d closed for ten holidays per year, meaning that wastes were delivered 250 days per year. Unless specified otherwise, all throughputs are in wet tons. The amount of biosolids, manure, or litter either disposed of in landfills or applied to land could not be determined directly. The California Association of Sanitation Agencies (CASA) did a survey in 1998. According to the survey, biosolids in California were managed in the following ways:

 4% surface disposed  5% incinerated or stored in temporary storage  6% disposed of in landfills  12% used as alternative daily cover (ADC) at landfills  54% land
- applied  16% composted The amount of biosolids being composted in the San Joaquin Valley was calculated by assuming that, for facilities that specifically list that they accept biosolids in addition to other materials, 50% of the facility’s throughput was biosolids. The quantity of composted biosolids was then adjusted using the state
- wide percentages above to determine the quantity that is land
- applied. The q uantity of manure or litter applied to land could not be determined, so District staff assumed that the calculated amount of biosolids includes the total amount of biosolids, manure, and litter that is land
- applied. This rule does not address surface disp osal, storage, or incineration, so these categories were not included in the emissions calculations. Landfills are required, by state regulations, to cover the solid waste at the end of each working day, so no emission reductions would be expected from re quirements imposed by Rule 4565. However, the use of biosolids as ADC would be limited. Rule 4565 requires that biosolids be covered by six inches of soil, six inches of finished compost, waterproof covering or other material, other than biosolids or bio solid
- derived material, specified for ADC in the California Health and Safety Code. Operators choosing to use biosolids or biosolid
- derived material as ADC would be required to notify the District and may be subject to Best Available Control Technology re quirements, as well as any toher requirements triggered through District Rule 2201 (New and Modified Stationary Source Review Rule), like emission offsets and public notification. Since no landfill in the District currently uses biosolids as ADC, no emiss ion reductions are expected as part of**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 4 **Final Staff Report for Rul e 4565**  this rule. By putting the requirements in place, however, allows the use of biosolids as ADC with controls on VOC emissions from such an operation. **B. Emission Factors Used**  Currently there is research proposed to further refine the emission factors for various types of composting facilities. However, due to the District's Extreme Ozone Plan commitment to adopt a rule regulating VOC emissions from composting facilities by the first quarter of 2007 and the significa nt quantity of research conducted by the South Coast Air Quality Management District (SCAQMD), staff believes there is sufficient information to proceed with the rule development process. District staff will incorporate new research findings as they become peer- reviewed and finalized, as the rule
- making schedule allows. For purposes of this analysis, two different emission factors were used. For composting/co
- composting facilities, the factor from SCAQMD Rule 1133.2 (Emission Reductions from Co
- Composti ng Operations) of 1.78 pounds VOC per ton of processed material was used. This factor was developed for passive windrow composting. It was assumed that all composting facilities mixed biosolids, manure, or litter with bulking agent before composting, mea ning that all composting operations that use these materials were co
- composting operations. The second emission factor was also taken from SCAQMD. This emission factor was for active composting only. Based on operator comments, the active composting pha se was assumed to be 20 days long and the total emissions for the 20
- day period would be 1.42 pounds VOC per ton of processed material. It was assumed that while biosolids/manure/litter was exposed to the air, it would emit VOC at the same rate as active composting. In the case of land application, the factor was adjusted to take into account that the biosolids/manure/litter would emit VOCs at the rate of 1/20 th of 1.42 pounds VOC per ton each day that it was not land incorporated. **C. Control Efficienc**  **ies Used** For purposes of this analysis, the handling of biosolids is assumed to be similar to animal manure. In 2002, Iowa State University and The University of Iowa Study Group compiled information about air quality issues related to “concentrated anim al feeding operations.” In the study group’s report, the documented control efficiency of various emission
- reducing strategies was tabulated. The final report is titled “Concentrated Animal Feeding Operations Air Quality Study” and is available on
- line a t http://www.ehsrc.uiowa.edu/CAFOstudy.htm. For purposes of this analysis, small composting facilities were assumed to have an emission reduction of 10% overall and facilities with throughputs from 20,000 wet tons per year but less than 100,000 tons per year were assumed to have a 20% overall**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 5 **Final Staff Report for Rul e 4565**  reduction. For large composting facilities, the capture efficiency was assumed to be 33%, similar to the SCAQMD technical assessment of SCAQMD Rule 1133.2. District rule provisions would require a VOC control syst em efficiency of at least 80%, therefore, the rule's total capture and control efficiency is 33% times 80%, or 26.4% overall. The rule provisions require essentially 100% capture through the monitoring provisions of Section 5.4. Thus, the VOC emission re ductions actually achieved is expected to be higher than the 26.4% used in the calculations. **D. Emissions and Reductions Calculations**  In performing the analysis, several assumptions were made to conservatively estimate emission reductions. These include :
 Landfill operators are not currently using biosolids as alternative daily cover and, therefore, have no emissions reductions associated with the draft rule provisions.

 Incorporation of biosolids/animal manure/poultry litter into soil at facilities that l and apply these materials typically takes 15 days from spreading of the biosolids/animal manure/poultry litter onto the ground until the material is incorporated.

 It was assumed that none of the existing composting facilities with throughputs at least 100, 000 tpy are implementing any of the mitigation measures.

 For composting facilities with maximum throughputs less than 100,000 tpy, approximately 50% of the facilities are in compliance with draft rule management practice requirements, based on conversatio ns with facility owners, operators, inspectors, and employees (with percentage weighting for facilities that only implement some of the practices). This means that all of the emission reductions will occur at the remaining 50% of composting facilities. T he percent of facilities already implementing controls is based on contact with industry and review of the Districts permits. The VOC emissions are estimated actual emissions, considering controls currently utilized by facilities. Table 2 shows the calcu lation for estimated emission reductions from land application of biosolids, animal manure, and poultry litter. Table 3 outlines the same things for existing composting/co
- composting facilities.**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 6 **Final Staff Report for Rul e 4565**  Table 2

– Emissions and Emission Reductions from Land Appli cation Throughput (tpy) Emission Factor Number of days Estimated Emissions (tpy) Estimated current 1,592,170 1.42 lb/20 days 15 847.8 Estimated after control 1,592,170 1.42 lb/20 days 1 56.5 Estimated Emission Reduction (tpy) (Estimated current emissi ons minus estimated after
- control emissions) 791.3

Table 3

– Emissions and Emission Reductions from Composting/Co
- Composting **Facility Permitted Throughput (tpy)**  **Number Facilities**  **Estimated Total**

**Throughput (tpy) Emission Factor** 

**(lb/ton throughput) Esti**  **mated Emissions (tpy)**  **Estimated Current Emissions** Between 100 & 20,000* 12 97,787 1.78 82.7 Between 20,000 & 100,000* 9 431,149 1.78 345.4 At least 100,000 8 2,533,250 1.78 2,254.6 Total Estimated Current 3,062,186 2,682.6 **Emis sions After Rule Implementation**  Between 100 & 20,000 12 97,787 Overall 10% reduction 78.3 Between 20,000 & 100,000 9 431,149 Overall 20% reduction 307.0 At least 100,000 8 2,533,250 33% capture/ 80% control 1,659.4 Estimated Total After Control 3,062,186 2,044.7 **Estimated Composting Emission Reduction (= Total Estimated Current**  **– Estimated Total after Controls)**  **637.9** ***** The calculations are adjusted to recognize that 50% of the facilities in this category are already in complia nce with the rule requirements.**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 7 **Final Staff Report for Rul e 4565**  Table 4 summarizes the results of the emissions and emission reduction calculations of Tables 2 and 3. D istrict staff estimates that current VOC emissions from the management of biosolids, animal manure, and poultry litter are about 3,500 tons per year. After full rule implementation, the current facilities will emit about 2,100 tons per year of VOCs for an estimated VOC emission reduction of about 1,430 tons per year. T able 4 is a duplicate of Table 1 above. TABLE 4

– S ummary of VOC Emissions and VOC Emission Reductions

Estimated Current Emissions (tpy) Estimated Emissions

After Control (tpy) Estimated VOC Emission Reductions (tpy) Landfill 0.0 0.0 0.0 Land Application 847.8 56.5 791.3 Compost 2,682.6 2,044.7 637.9

TOTAL 3,530.5 2,101.2 1,429.2**SA N JOA** **QUIN VA LLEY UNIFIED A** **IR POLLUTION CONTROL DISTRICT**

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- 8 **Final Staff Report for Rul e 4565**  This page intentionally blank.