SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions March 30, 2007

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Final Staff Report for Rule 4565

APPENDIX B

EMISSION REDUCTION ANALYSIS FOR REVISED PROPOSED NEW 

RULE 4565 (BIOSOLIDS, ANIMAL MANURE, AND POULTRY LITTER 

OPERATIONS)

March 30, 2007
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions March 30, 2007

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I. SUMMARY

This appendix details the estimated VOC emissions and emission reductions for 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 Section 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

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

TOTALS 3,530.5 2,101.2 1,429.2

II. INTRODUCTION

The purpose 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 

requirements. The menu provides operators with the flexibility to find the most costeffective 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 ANALYSIS

A. Throughput Calculations

The rule applies to three types of operations: landfill, land application, and compost/cocomposting. Of the three, composting/co-composting operations have at least some 

information about throughput. The California Integrated Waste Management Board 

(CIWMB) Solid Waste Information System (SWIS) is a database that tracks the 

maximum throughput of all types of solid waste handling facilities required to report 

operational data to CIWMB 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 
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in the calculations. The term “agricultural” could include animal bedding with manure or 

litter mixed in. Maximum throughput in units other than tpy was converted, as needed. 

When 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 and 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 quantity 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 disposal, 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 requirements 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 biosolid-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 requirements, 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 emission reductions are expected as part of 
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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 significant 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-Composting 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, meaning 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 phase 

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 1/20th of 1.42 

pounds VOC per ton each day that it was not land incorporated. 

C. Control Efficiencies 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 animal 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 at 

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 
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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 system 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 reductions 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 

land 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 conversations 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. The 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 calculation 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.
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Table 2 – Emissions and Emission Reductions from Land Application

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 emissions 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)

Estimated 

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

Emissions 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 compliance with the rule requirements.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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Table 4 summarizes the results of the emissions and emission reduction calculations of 

Tables 2 and 3. District 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. Table 4 is a duplicate of 

Table 1 above.

TABLE 4 – Summary 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
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions March 30, 2007

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