Appendix D:  

Written Comments Submitted by Small Entity Representatives in 2015

Small Business Advocacy Review Panel on EPA’s Planned Proposed Rules

Standards of Performance for Municipal Solid Waste Landfills and Review of Emissions

Guidelines for Municipal Solid Waste Landfills

For the April 14, 2015 Panel outreach meeting, the following SERs submitted four sets of written 

comments, which are provided in this appendix: 

 Todd Green, American Environmental Landfill 

 Curt Publow, Decatur Hills, Inc. 

 Matt Stutz, Weaver Consultants Group on behalf of Ponca City, Oklahoma 

 Anne Germain, Environmental Industry Associations on behalf of Caroline County, 

Maryland 

o Cosigned: Michael E. Michels, Cornerstone Environmental Group on behalf of 

Riverview, Michigan 

o Cosigned: Alek M. Orloff, Alpine Waste & Recycling 

o Cosigned: Kimberly Smelker, Granger Waste Services 




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35 E. Wacker Drive • Suite 1250 • Chicago, Illinois 60601 • 312.922.1030 • wcgrp.com • Offices Nationwide

April 28, 2015

Caryn Muellerleile (via e-mail)

Office of Policy 

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20460

RE: Comments on the Municipal Solid Waste Landfills Emissions Guidelines

Dear Ms. Muellerleile:

The purpose of this letter is to submit comments on the briefing materials for the

Municipal Solid Waste (MSW) Landfills Emission Guidelines (EG) , which was presented 

at the April 14, 2015 SBAR outreach meeting with the Small Entity Representatives 

(SERs). As a SER, I am pleased to offer the following comments and appreciate the 

EPA’s willingness to carefully consider how proposed changes to the MSW EG will 

affect small entities. 

General Comments

The current EG rule has served the industry for many years, and many small entities have 

established business models that account for the possible costs associated with expanding 

over the current design capacity threshold. Given the limited cash flow and resources of 

a small entity, even small changes in timing, duration, or applicability associated with 

landfill gas control have significant effects on the viability of small entities. For 

example, above and beyond the capital costs for installing a landfill gas collection and 

control system (GCCS), are the costs associated with installing the need electrical 

infrastructure to power blowers, the additional electrical costs, and the staff needed to 

operate, maintain, monitor, and comply. Considering these costs, small entities must 

carefully consider possible landfill expansions and/or increase in waste acceptance fees. 

As such, it is requested that applicability and current thresholds not be changed at this 

time 

In order to help promote consistency across state lines, we recommended that with any 

proposed changes to the EG that the EPA also prepare the Federal Implementation Plan 

(FIP) for the EG at the same time. This will allow states without too much variation, to

use the FIP as a model for their SIP. 

The following address each of the items as they were presented at the April 14, 2015 

meeting.
Ms. Muellerleile

April 28, 2015

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Specific Comments

Size and emission thresholds – For the reasons discussed above, the size and emission 

thresholds should remain unchanged. Certainly, lowering the size and emission threshold 

will have some additional benefit of reducing NMOCs and methane; however, the cost 

and burden is too great. In the EPA’s Economic Impact Analysis (EIA) (docket ID 

Number EPA-HQ-OAR-2003-0215-0045) and the preamble discussion and the Air 

Emissions from Municipal Solid Waste Landfills – Background Information for Final 

Standards and Guidelines, EPA-453/R-94-021 (BID) for the 1996 NSPS support the

design capacity of 2.5 million megagrams (Mg) and 2.5 million cubic meters (m3). The 

current threshold continues to ensure that the rule will achieve the maximum level of 

potential emissions reductions cost-effectively. The current design capacity threshold of 

2.5 million Mg and 2.5 million cubic meters, remains appropriate because there has been 

no change in the circumstances underlying EPA’s original standard. 

If EPA lowered the design capacity, the additional sites brought into the program would 

be smaller, older, and predominantly closed landfills with far less capacity for LFG 

generation and far less potential for achieving emissions reductions, particularly if they 

are unable to support an active gas collection system. Closed landfills have no revenue 

stream to support new regulatory requirements beyond those anticipated in the closure 

plan. Furthermore, regulating those sites would disproportionately affect small facilities.

It was discussed in the meeting that the EPA also is considering reducing the NMOC 

emissions threshold from the current 50 Mg/yr to 40 or 34 Mg/yr. 

Similar to changes in the design capacity, there is concern that lowering the emissions 

threshold will only have a slight reduction in NMOCs with a substantial impact on costs 

and regulatory burden. EPA found that reducing the NMOC threshold would increase 

cost of control by more than 26 percent while reducing NMOC emissions by only 13 

percent (79 Fed. Reg. 41809).

It is important to note that the cost increase is much higher than what was presented in 

the EPA’s cost/benefit. The EPA’s analysis did not assess the consequence of lowering 

the NMOC threshold for older and closed landfills with declining gas production. If EPA 

proposed to reduce the NMOC threshold in the EG, older and closed landfills would bear 

significant economic burden. Reducing the emissions threshold from 50 to 40 Mg/yr

NMOC will further delay the point at which a closed landfill can petition to remove 

controls, exacerbating a situation that is already occurring at the higher threshold. As 

landfill gas declines over time, some wells will not produce sufficient levels of LFG to 

maintain the wellhead oxygen/nitrogen operational levels when subjected to continuous 

vacuum. If EPA finalizes a lower NMOC threshold, this problem will become more 
Ms. Muellerleile

April 28, 2015

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pronounced. Many closed landfills struggle to maintain sufficient gas flow to operate 

their control systems under the 50 Mg/yr threshold. At the lower 40 Mg/yr threshold, 

landfill owner/operators will need to use increasing amounts of fossil fuel to maintain 

flare operation as well as the extra energy costs to run blowers. This increases GHG 

emissions, which is highly counterproductive.

Lowering the size and emission threshold would have the most direct and significant 

impact to small entities, and given that EPA has not demonstrated that the current 

threshold is no longer appropriate; the current threshold should be maintained.

 

Alternative Emissions Threshold Determination (Tier 4) – We support the development 

of a Tier 4 method. We see real value in the current SEM requirements and would 

recommend that SEM become more incorporated as a valuable method in determining the 

timing of the removal as well as the installation of a GCCS. Incorporating SEM into the 

process of determining when a GCCS must be installed, removed, and/or 

decommissioned will provide for a more site specific and data driven approach to making 

the decision about when landfill gas emissions need to be controlled. Given that landfills 

are faced with different climates, waste acceptance, and cover soil materials, the use of a 

SEM method as a key tool would mean that determining the need for a GCCS will be 

based on actual site specific information. 

Small entities requested that EPA consider adding a more flexible option that would 

allow landfill owners/operators to perform SEM to show that surface emissions at a site 

remain low even where the modeled emission rate shows a threshold exceedance. 

By simply relying on a single Tier 1 or Tier 2 test, many sites have and could in the 

future be required install a GCCS when the site conditions do not warrant control. With

Tier 2 testing, a site specific NMOC concentration is determined. This concentration is 

then used in a mathematical methane generation model which is then used to estimate 

projected NMOC generation. However, experience has shown that the difference 

between a mathematical model of potential generation and actual emissions can be 

substantial. By incorporating the use of SEM procedures in determining the need for 

installing or decommissioning or removing a GCCS, wasteful spending, consumption of 

resources, and power could greatly be minimized while the environment will remain fully 

protected. 

We recommend that implementation of “Tier 4” not be a sequential procedure, but rather 

that it be a method that could be employed instead of a Tier 1 or Tier 2 test or at any 

point following a Tier 1 or Tier 2 test in which the NMOCs have been calculated to be 

greater than the NMOC threshold and prior to the required installation of the GCCS. In 
Ms. Muellerleile

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addition, we propose that this method also be used in determining when to remove the 

NSPS requirements for all or portions of an existing GCCS. This approach to using “Tier 

4” would enable SEM to gather site-specific information at a landfill or area of a landfill 

to determine if the actual data supports the need for a GCCS. 

EPA’s briefing package for the SBAR indicates that corrective action might not be 

allowed if a landfill uses the Tier 4 option. This would be counterproductive and 

undermine the usefulness of the tiered approach. It is also inconsistent with the California 

Landfill Methane Rule, which allows a landfill owner/operator to take steps to remediate 

a methane exceedance such as adjustments to the gas collection system or cover repairs. 

If those actions correct the exceedance as documented with re-monitoring, then a new or

expanded GCCS would be unnecessary. Should a site owner/operator be unable to 

remediate an exceedance, the site will be required to prepare a GCCS design plan within 

one year of the initial Tier 4 SEM exceedance, and within 30 months of the initial 

exceedance a GCCS would be installed within the monitored area. 

The addition of a Tier 4 method has all the benefits of protecting the environment, 

providing for site specific conditions that vary across the country, and reduce 

unnecessary use of resources and costs. 

Enhanced surface monitoring – We recommend that the surface emissions monitoring 

(SEM) requirements not be changed. EPA asked for the SER’s comments on three 

provisions in the California Air Resources Board’s (CARB) Final Regulation -- Methane 

Emissions from MSW Landfills (CA LMR) including: 1) reducing the interval for the 

walking pattern from 30 meters (98 ft.) to 25 ft.; 2) adding an integrated methane 

concentration measurement; and 3) allowing sampling only when the average wind speed 

is five miles per hour or lower, or the instantaneous wind speed is below 10 miles per 

hour.

In response, we support the study by SCS Engineers commissioned by Waste 

Management and Republic Services which compared the level of effort, costs, and 

monitoring results associated with implementing the CA LMR at public and private 

landfills to the SEM requirements in subpart WWW. 

The study found that reducing the walking pattern interval for instantaneous monitoring 

from 30 meters (98 ft) to 25 ft did not deliver commensurate benefits. There is an 

extraordinary amount of costs to detect exceedances at merely a fraction of additional

acres monitored. Similarly, there is a significant amount of cost and burden associated 

with integrated monitoring, with insignificant results. These increased monitoring costs 

would place a significant burden on both large and small entities, but particularly for 

small local governments that own and operate landfills.
Ms. Muellerleile

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Given that the SEM takes place with a probe near the surface, the effect of wind speed is 

minimal. Adding wind speed parameters will make it very costly if not impossible to be 

able to perform SEM at some sites. The intent of SEM is to determine if and when 

additional collection devices are needed. If there is sufficient surface emissions 

occurring to warrant the installation of a collection device, the wind speed at ground level 

will not be an issue and it will be detected. It is understood that surface emissions from 

isolated small cracks or crevices in the landfill surface may not get detected at higher 

wind speeds; however, as previously mentioned, the intent is to find the areas with 

sufficient amount of LFG escaping that it would warrant collection devices. The current 

SEM program and requirements have been proven with years of experience as proof, that 

surface emissions are being detected and corrected

Please note that by adding a wind speed requirement, there will be additional recording 

keeping, monitoring, and reporting burdens. It is highly likely that during a SEM event, 

the monitoring would need to be postponed or rescheduled with changes in wind speed. 

In most cases the SEM is contracted to a third party, the added cost of having to postpone 

or reschedule SEM due wind speed will create an additional cost burden. 

Adding a wind speed requirement would fall in to the category of adding costs and 

burden without adding benefits and as a SER it is recommend that a wind speed 

parameter not be included in the proposed EG. 

Wellhead operating standards – As has been stated in previous comment letters, it is 

recommended that EPA remove the temperature and oxygen/nitrogen wellhead operating 

parameters from the NSPS and EG rules. Members of the landfill sector have provided 

these comments to EPA and state agencies over the past several years with the proposed 

amendments to the NSPS. It has been identified that there are many problems with the 

wellhead parameters that make their implementation counterproductive to optimizing gas 

collection, system performance and methane emissions reduction. 

First, the oxygen/nitrogen and temperature wellhead parameters are poor indicators of the 

presence of landfill fires or of inhibited decomposition. Oxygen is rarely seen in a gas 

well, particularly when the system is recovering sufficient gas and producing stable gas 

flows. When greater than five percent oxygen is detected in a well, the most common 

problem is a collapsed or pinched well, or a loose fitting or coupling that allows 

atmospheric air to enter the well. Alternatively, where the landfill owner/operator is 

implementing early gas collection using shallow horizontal collectors or the leachate 

collection system, air can easily be pulled into the collectors, causing a temporary 

increase in oxygen until more waste is placed over the collectors ceasing air intrusion. 
Ms. Muellerleile

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None of these examples would cause or contribute to a landfill fire, but they are the most 

typical circumstances for high oxygen readings in a wellhead.

The temperature of flowing LFG varies widely under normal landfill conditions. Landfill 

gas is generated by a biological reaction and the greater the intensity of this reaction, the 

greater the heat produced by the biological activity. Therefore, some newly installed gas 

wells exhibit elevated temperatures naturally. In order to reduce temperature to meet 

compliance, the gas flow to the well must be turned off or significantly reduced. This 

undermines the optimal operation of the system and reduces the overall quantity of 

landfill gas collected. Although the regulations offer landfill owners the opportunity to 

establish a higher operating value (HOV) for the well, these alternatives are often ignored 

or denied by the agencies. Some regulatory agencies claim they are unable to authorize 

an HOV and simply tell the landfill operator to expand the system, completely ignoring 

the fact that expansion of the well field will not alleviate the elevated temperature. 

Second, the wellhead parameters present barriers to implementing early collection of 

landfill gas. Many landfill owners/operators understand the environmental benefits of 

reducing odors and methane emissions by using interim gas collection practices prior to 

the point at which the landfill is producing enough LFG to warrant a full GCCS. Two 

such practices include connecting to the leachate collection system and installing 

horizontal collectors. However, many NSPS/EG sites do not take advantage of these 

practices solely because of compliance issues with the wellhead operating requirements. 

Based on nearly two decades of experience with operating gas collection systems, the 

landfill sector urges EPA to remove the temperature and oxygen/nitrogen wellhead 

parameters, and instead rely on negative pressure and SEM to ensure proper operation of 

the gas collection system. Some states are concerned about landfill safety should the 

parameters be removed, while other states are supportive of their removal. Although 

states can always maintain the parameters within their state plans for EG implementation, 

it is recommended that EPA provide guidance through model rule language. In addition, 

EPA can provide guidance to the states regarding the problems posed by inflexible 

adherence to the parameters as good measures of system performance. If states desire to 

maintain the parameters, EPA might suggest streamlined approaches to approval of 

HOVs and alternative timelines for corrective action to reduce administrative burdens on 

the state environmental agencies and the regulated community. 

Landfill gas treatment – As a small entity interested in the possible conversion of landfill 

gas to energy, we need to have all barriers removed that are not directly associated with 

protection of the environment. As such, we recommend not changing the current 

definition of treatment by adding numerical requirements and monitoring. The proposed 
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change would be a burden, with no corresponding environmental benefit, that would 

adversely affect the ability to install and operate a landfill gas to energy facility. 

The treatment systems are not a source of emissions. Unlike on-site flaring or 

combustion of landfill gas, the treatment of landfill gas does not itself control emissions 

of NMOCs or HAPs and does not produce emissions that are vented to the atmosphere. 

Instead, treatment is a physical process that filters particulate matter from the gas stream 

and knocks out moisture in preparation for combustion. Any post combustion of treated 

landfill gas will be permitted and approved as part of the facility’s air permitting. For 

example, there are already NSPS and NESHAP requirements for engines, boilers, and 

turbines in addition to local and state permitting requirements. Therefore, the protection 

of the environment will be maintained and regulated at the point of combustion or release

and should not be placed on the treatment equipment. 

EPA needs to consider the loss of valuable renewable energy projects that displace fossil 

fuel powered electrical generation, provide a reliable source of base load energy, and 

assist in meeting EPA’s and states’ greenhouse gas reduction goals before proposing 

requirements that will impact such projects. 

Organics management – Encouraging or possibly mandating organics diversion was 

discussed in the meeting. This should not be mandated or even encouraged in this 

proposed rulemaking. There is no evidence to support that organics diversion from 

landfills is more protective of the environment. In fact to the contrary, it has been shown 

that organic diversion to composting has an increase effect in greenhouse gas and volatile 

organic emissions. Landfills are highly regulated and controlled facilities that are 

designed to handle waste materials. The diversion of waste away from controlled 

landfills to facilities that are less regulated or controlled has the potential to create a 

myriad of environmental concerns. 

I appreciate the opportunity to provide these comments and to serve as SER. In addition 

to the comments presented in this letter, I support the comments presented by the 

National Waste and Recycling Association. Should you have any questions, please 

contact me at mstutz@wcgrp.com or at 817-735-9770.

Sincerely,

Weaver Consultants Group, LLC

Matt K. Stutz, P.E.

Principal/LFG & Air Quality Services
April 28, 2015

Caryn Muellerleile (via e-mail)

Office of Policy 

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20460

RE: Comments on the Municipal Solid Waste Landfills Emissions Guidelines

Dear Ms. Muellerleile:

As a Small Entity Representatives (SER), we are pleased to offer the following 

comments to the briefing materials on Municipal Solid Waste (MSW) Landfills

Emission Guidelines (EG). The briefing materials provided a much more focused 

approach to the MSW EG than the advanced notice of proposed rulemaking 

(ANPRM) issued last year. As such, these comments focus on addressing the issues 

contained in the Small Business Advocacy (SBAR) Outreach Briefing and discussed 

at the April 14 meeting with the SERs.

General Comments

Emissions reductions by the solid waste and recycling sector have been significant.

According to EPA’s U.S. GHG Emissions Inventory, landfills reduced methane

emissions by 38.4% between 1990 and 2013, and many of the emissions reductions 

are a result of the current New Source Performance Standards (NSPS) and EG for 

MSW Landfills. MSW landfills are one of the only sectors that can claim direct GHG 

emissions reductions of this magnitude. This demonstrates that the NSPS and EG

works well in effectively controlling landfill emissions. Further, the emissions 

reductions achieved to date have been at a reasonable cost1.

Should EPA choose to finalize changes to the applicability thresholds associated 

with landfill size or NMOC threshold, an increasing number of smaller, older mostly 

closed landfills will be swept into regulation under the EG. The cost burden for 

compliance e.g., installing a landfill gas system is significantly greater for a small 

facility than for a large one, especially if the facility is closed and generates no 

revenue. For example, a significant cost can be incurred simply to mobilize a drill 

rig. For a facility that installs many wells, the mobilization costs can be distributed 

over the costs of the wells. For smaller facilities with fewer wells, the individual well 

cost is greater. Another example is the appropriate level of staffing to address these 

 

1 EPA has available recently published information on the efficacy of the Landfill NSPS standards and 

has discretion to determine, pursuant to section 111(b) of the Clean Air Act, that eight year review is 

not appropriate for new sources. The Clean Air Act does not mandate eight year review for existing 

sources. See CAA Section 111(d).
rules and the operation of a GCCS. Larger operations can distribute personnel 

effectively over multiple sites for efficient and cost effective measures. Smaller 

operations having one or two sites must either contract services at a premium, or 

have internal personnel that are justified on a part-time basis. These examples can 

be carried forward on almost every component of the landfill gas collection and 

control system: from design, through permitting and construction, to monitoring 

and operations. Therefore, when considering the burden on small entities, the costs 

will be significant.

In addition, the considerations, which led to the landfill size and non-methane 

organic compound (NMOC) applicability thresholds that were in force during the 

original rulemaking, are unchanged. Therefore, it does not appear that there is any 

need to modify the rule for additional emissions reductions.

Specific Comments

1. Federal plan or model rule language – When the EG was originally promulgated 

in 1996, states had nine months (December 12, 1996) to submit their State 

Plans. For many states, EPA extended the State Plan deadline twice giving them 

until July 31, 1998. For entities without timely State Plans, EPA finalized Federal 

Plan GGG on November 8, 1999, nearly 3.5 years after the EG was originally 

promulgated. Unlike 1996 when most landfills were subject to the NSPS, this 

time most landfills will be subject to the EG. Therefore, it is especially important 

to ensure smooth transition from promulgation to adoption of a plan. Given the 

state/local agency resource constraints to prepare state plans, many may opt to 

simply wait 3.5 years for the Federal Plan. Alternatively, if model rule language is 

developed when the rule is promulgated, states may use it as a template for State 

Plans. This will significantly reduce burden on state/local agencies and 

ultimately the EPA as well as provide consistency across the country. It will also 

reduce burden on the regulated community that operate in more than one 

jurisdiction. Therefore, we strongly recommend that EPA develop a Federal Plan 

or model rule language for states to use in developing their state plans.

By developing a model Federal Plan or a template for an approvable State Plan at 

this point in the rulemaking process, EPA would reduce considerable additional 

burden on the states. EPA would also reduce confusion over regulatory 

interpretation and inconsistent application of requirements across the states.

The existing inconsistency of implementation of the NSPS across states and even 

EPA Regions creates significant workload and administrative burden for 

regulators and the regulated community alike. The burden is even greater for 

small entities that lack staff or consultant resources to manage these 

implementation problems.

We note that when EPA promulgated the EG Rule in 1996, it provided regulatory 

language that outlined how a state could develop an approvable plan by linking 

emission guidelines requirements to the applicability thresholds, collection and 

control requirements, design plan requirements, NMOC thresholds, test methods 
and procedures, reporting and recordkeeping requirements and compliance 

timelines found in the NSPS. Many states chose to simply adopt the NSPS 

requirements by reference into their State Plans for the EG. EPA appears to 

desire a similar linkage between the revised NSPS and revised EG, so a model 

Federal Plan or State Plan template could be developed in the same manner.

2. Methane as the regulated pollutant – In the ANPRM, EPA sought input “on the 

extent to which methane should be addressed under the revised emissions 

guidelines” as well as “potential implementation issues associated with any 

adjustments that could be made to the current rule framework or any alternative 

frameworks that may achieve a larger fraction of methane emission reductions 

from existing landfills than the current performance based standard of a welldesigned and well-operated GCCS.” (79 Fed. Reg. 41781).

Direct regulation of methane is unlikely to affect the structure of or benefits of 

the Landfill EG. Landfill gas is composed of roughly 50% methane, 50% carbon 

dioxide and 1% NMOC (79 Fed. Reg. 41777). The current Best System for 

Emissions Reduction (BSER) is based on the well-designed and well-operated 

landfill gas collection system, and a control system for collected LFG that 

achieves 98% reduction of NMOC (79 Fed. Reg. 41803). This system of BSER is 

effective for all components of LFG, notwithstanding that EPA identified NMOC 

as surrogate for LFG in the initial Subpart WWW/EG rulemaking in 1996 (79 

Fed. Reg. 48100). In essence, by collecting one compound, you collect them all.

Collection systems are not designed or constructed specific to one compound or 

another. Therefore, adding methane as a pollutant under the Landfill NSPS/EG 

will not further reduce methane emissions, because they have already been 

addressed as a component of LFG, and are inseparable from the NMOCs in the 

LFG. There would be simply no environmental benefit to regulating methane 

directly. EPA has not demonstrated nor even suggested that there is a more 

effective way to address methane emissions than already established via the 

EG’s regulation of landfill gas emissions as a whole. It does not appear that there 

is any more effective or feasible manner in which to reduce methane emissions 

from landfills than through a well-designed and well-operated landfill gas 

collection system and control of collected gas to a 98% reduction standard for 

NMOC, which EPA has reaffirmed is BSER. EPA previously noted, the design and 

operational standards are appropriate because there is no technically feasible 

technology available to measure the landfill gas available for collection in 

comparison to the amount actually collected (56 Fed. Reg. 24484). The same 

types of collection and control systems reviewed in 1996 continue to be 

prominently used to reduce landfill gas emissions today and the design and 

operational standards continue to be robust. Without such a showing, regulation 

of methane makes no sense. Additionally, regulated entities have made 

significant investments to design, develop, and install control systems to meet 

the current 98% NMOC destruction criteria. Re-configuring these existing 

systems, if possible, in order to target a different pollutant would impose 

unnecessary financial burdens without any significant reduction in emissions.
Direct regulation of methane would create administrative burden and legal 

uncertainty for landfills. First, methane emissions are not typically identified as a

separate pollutant in landfills’ Title V permits; regulation of methane under the 

EG, as separate from the current regulation of NMOC emissions, could create 

uncertainty and delay within state permitting programs. Further, given that 

certain state programs may seek to be more stringent than the NSPS standard, 

especially with respect to NSPS-based monitoring, recordkeeping and reporting 

requirements based on state authority, there is an unknown but significant 

potential for additional burden, misapplication of regulatory requirements and 

technical difficulty that may arise in this context. 

Second, the direct regulation of methane would certainly result in further 

confusion with respect to EPA’s regulation of greenhouse gases under the 

Prevention of Signification (PSD) program.

Given the foregoing, revisions to the existing rule should maintain the welldesigned and well-operated landfill gas collection and control of the collected 

gas to a 98% reduction of NMOC to demonstrate compliance. The best format for 

the standard remains a combination of design and operational standards, as 

currently contained in Subparts Cc and WWW.

3. Regulatory Proposal Options (Size & NMOC emissions threshold) – The briefing 

materials indicate that EPA is considering reducing the NMOC emissions 

threshold from the current 50 Mg/yr to 40 Mg/yr or possibly 34 Mg/yr. The 

SERs find this surprising. In the proposed NSPS EPA chose to reduce the NMOC 

threshold to 40 Mg/yr, and while the Agency sought comment on reducing the 

threshold in the ANPRM for the emissions guidelines, EPA did not offer a 

particular threshold level for comment.

It is important to recognize that decisions regarding the existing design capacity 

and NMOC threshold for potential landfill emissions are derived using 

conservative modeling assumptions because it is not technically feasible to 

measure the amount of gas available for collection. It was on this basis that EPA 

concluded that it was necessary to establish a design and operation standard for 

gas collection systems instead of a standard of performance. EPA even 

recognizes that the default values to determine when a landfill could exceed the 

threshold and be required to install controls are conservatively high (79 Fed. 

Reg. 41805). Because of this any emission benefits would be significantly 

overstated and would result in significant capital expenditures with marginal 

emissions reductions.

By lowering the design capacity, the additional sites brought into the program 

would be smaller, older, and predominantly closed landfills with far less capacity 

for LFG generation and far less potential for achieving emissions reductions, 

particularly if they are unable to support an active gas collection system. EPA 

considered this in the Air Emissions from Municipal Solid Waste Landfills –

Background Information for Final Standards and Guidelines, EPA-453/R-94-021 

(BID) where it was estimated that the 2.5 million Mg/m3 threshold would 
capture 85 percent of NMOC emissions potential, while exempting 90 percent of 

existing small landfills. EPA noted in 1996 the trend towards development of a 

smaller number of large, new landfills, and this trend has become more 

pronounced in the last two decades. Closed landfills have no revenue stream to 

support new regulatory requirements, nor was there the need to consider these 

types of future costs during the actual operating life of the facility beyond those 

regulatory conditions anticipated in the closure and post-closure plans. 

Furthermore, this form of retroactive regulations of those closed or near closed 

sites would disproportionately affect small facilities.

Reducing the emissions threshold from 50 to as low as 34 Mg/yr NMOC will 

further delay the point at which a closed landfill can petition to remove controls, 

exacerbating a situation that is already occurring at the higher threshold. As LFG 

generation declines over time, some wells will not produce sufficient levels of 

LFG to maintain the wellhead oxygen/nitrogen operational levels when 

subjected to continuous vacuum. If EPA finalizes a lower NMOC threshold, this 

problem will become more pronounced. Many closed landfills struggle to 

maintain sufficient gas flow to operate their control systems under the 50 

Mg/year threshold. At the lower 35 or 40 Mg threshold, landfill 

owner/operators will need to use increasing amounts of fossil fuel to maintain 

flare operation. This increases GHG emissions, which is highly 

counterproductive.

There have been no changes in the circumstances underlying EPA’s original 

standard. EPA has not demonstrated that the current standards are no longer 

appropriate so no revisions are needed. Any reduction will not result in 

significant additional emission reductions and thus could impose an 

unnecessary burden for little or no benefit which will impact mostly closed 

landfills that do not generate revenue. Many of these landfills are owned by 

municipalities that would need to pass these costs on to their communities.

4. Alternative Emissions Threshold Determination (Tier 4) – Small entities 

previously requested a more flexible option that would allow landfill 

owner/operators to perform surface emissions monitoring (SEM) to 

demonstrate that emissions remain low despite modeled emissions showing a 

threshold exceedance.

We support a Tier 4 utilizing the SEM results and recommend that it be available 

at any point in the life of a landfill, to determine when the GCCS installation 

requirements are triggered. A Tier 4 method is appropriate because the existing 

methods of determining when a GCCS system is required are overly conservative 

or as in the case of the Tier 3 method not even used due to the expense and 

operational challenges. The existing Tier 1 modeling which every site must use 

often over predicts the generation of landfill gas and underestimates the amount 

of methane oxidation that occurs in daily and intermediate cover. A Tier 2 

calculation for site specific NMOC concentration emissions is also available; 

however the site specific concentration is then used in a conservative 

mathematical methane generation model that only provides a prediction of 
potential landfill gas generation. We support Tier 4 being allowed out of 

sequence or instead of Tiers 1-3.

A key benefit of the SEM option is that it incentivizes sites to implement methane 

reduction practices such as upgrading cover or installing interim gas collection 

(horizontal pipes, tie-in to leachate collection system) as quickly as possible. 

These practices can be implemented far more quickly and cost-effectively than 

designing, constructing and installing a GCCS. Further, based on the fill 

progression plan, it may be better for GCCS operations if temporary, interim

control measures are allowed followed by a final system when conditions 

warrant.

A second important benefit is that the SEM results will reflect the differences in 

gas generation as a result of different climates. These differences are lost in the 

default Tier 1 calculations and an exacerbated in Tier 2. As stated previously 

above, EPA has even recognized that the default values are conservatively high 

for when a landfill triggers installation of a GCCS. A Tier 4 approach would allow 

the landfill owner/operator to quickly determine whether remedial work with 

the cover will correct the emissions exceedance or whether installation of the 

gas collection system is warranted. This will prevent installing a GCCS

prematurely at a landfill that would be costly and difficult to operate because the 

gas quality and quantity are not sufficient due to the conservative model used for 

triggering a GCCS installation. In dry climate where the model defaults 

overestimate LFG generation, and NMOC concentrations tend to be higher, GCCS 

requirements are triggered at landfills where SEM requirements can easily be 

met in the absence of a GCCS. For smaller sites, this could mean the difference 

between an interim GCCS followed by a final system versus a one-time 

installation that serves both functions poorly.

We suggest implementing Tier 4 SEM as follows: The owner/operator would

follow the Tier 4 SEM utilizing the same SEM methods currently established in 

subpart WWW. If during this monitoring event no exceedance of 500 ppm over 

background is detected, then the installation of a GCCS will not be required and 

quarterly SEM testing will be performed thereafter until the landfill or area of 

the landfill is closed. Closed portions of an active landfill may also be reviewed 

using the SEM approach; however, if no SEM exceedances are detected, those 

closed areas will no longer be required to be tested as a part of any subsequent 

Tier 4 SEM events. States would review and verify the use of Tier 4 in the same 

manner that they review and verify quarterly surface emissions monitoring and 

threshold determinations under the current Subpart WWW.

EPA’s briefing package for the SBAR indicates that corrective action might not be 

allowed if a landfill uses the Tier 4 option. This would be counterproductive and 

undermine the usefulness of the tiered approach. It is also inconsistent with the 

California Landfill Methane Rule, which allows a landfill owner/operator to take 

steps to remediate a methane exceedance such as adjustments to the gas 

collection system or cover repairs. If those actions correct the exceedance as 
documented with re-monitoring, then a new or expanded GCCS would be 

unnecessary. Should a site owner/operator be unable to remediate an 

exceedance, the site will be required to prepare a GCCS design plan within one 

year of the initial Tier 4 SEM exceedance, and within 30-months of the initial 

exceedance a GCCS would be installed within the monitored area. 

5. Enhanced surface monitoring – EPA asked for the SER’s comments on three

provisions in the California Air Resources Board’s (CARB) Final Regulation --

Methane Emissions from MSW Landfills (CA LMR) including: 1) reducing the 

interval for the walking pattern from 30 meters (98 ft.) to 25 ft.; 2) adding an 

integrated methane concentration measurement; and 3) allowing sampling only 

when the average wind speed is five miles per hour or lower, or the 

instantaneous wind speed is below 10 miles per hour.

In response, the SERs would point EPA to the study by SCS Engineers 

commissioned by Waste Management and Republic comparing the level of effort, 

costs and monitoring results associated with implementing the CA LMR at public 

and private landfills to the SEM requirements in subpart WWW. A copy of this 

study was provided to EPA2

SCS analyzed data from 72 California landfills regulated under the CA LMR, 

which took effect in mid-2011. Because CA LMR requirements are more 

stringent than the NSPS, after mid-2011, the landfills subject to the NSPS (42) in 

the dataset followed LMR requirements and reported the relevant data to the 

State of California and EPA, as appropriate. SCS obtained the aggregate NSPS 

monitoring results by reviewing quarterly monitoring reports developed from 

up to two years (8 quarters) prior to implementation of the CA LMR (3rd quarter 

2009 through mid-2011). Of the total 72 landfills in the study, 41 were publiclyowned and 31 privately-owned. Small entities own or operate at least seven of 

the studied landfills. The study focused, however, on the 42 NSPS landfills 

looking at pre and post CA LMR surface emission monitoring programs.

The study found that reducing the walking pattern interval for instantaneous 

monitoring from 30 meters (98 ft) to 25 (ft) and monitoring all penetrations did 

not deliver commensurate benefits. In the two years before CA LMR, 

exceedances were detected at only 1.6% of all acres monitored and only 2.7% of 

all monitored penetrations. Only 1.2% of all exceedances were unable to be 

remedied by simple cover repair or collection system adjustments within the 

first 20 days, thus triggering the 120-day GCCS expansion requirement. All of 

these exceedances occurred at one landfill, which subsequently expanded its 

GCCS.

In the 30 months since CA LMR implementation, the increased density of the 

required monitoring resulted in detection of more exceedances during the 

 

2 SCS Engineers, A Comparison of Monitoring Results for California Landfills under the New Source 

Performance Standards and the California Landfill Methane Rule, October 2014. 
surface walking. Exceedances were detected at 4.4% of acres monitored, yet the 

vast majority were easily remedied with cover repairs and did not require 

installation or expansion of GCCS. Importantly, only two additional landfills were 

required to expand their GCCS under the CA LMR.

Under the CA LMR program the number of penetrations monitored increased by 

84%, but exceedances were detected at only 1.1% of the additional penetrations 

monitored. It appears that the effort expended to monitor every penetration at a 

landfill is far less effective in finding exceedances than the more targeted 

approach of monitoring penetrations when there is a visual or olfactory 

indication of a problem.

EPA’s cost analysis for implementing the enhanced monitoring regime (see 

Table 5, 79 Fed. Reg. 41823) indicates that adopting the CA LMR approach in the 

proposed NSPS would increase monitoring costs by more than seven times 

(from a total annual cost of $50,000 to $362,900) for using a walking pattern 

that is four times as dense. Further, EPA’s recent cost estimates for EG sites 

indicate incremental annual cost per landfill of $71,400, which is more than 7 

times the current estimated SEM costs for an EG site (see Slide 12 of SBAR 

Outreach Briefing). This is an extraordinary amount of money to spend detecting 

exceedances at merely an additional 2.8% of acres monitored, while increasing 

gas collection at only two landfills, at most, based on the SCS analysis. The 

increased monitoring costs would place a significant burden on both large and 

small entities, but particularly for small local governments that own and operate 

landfills. The burden is further exacerbated for owners/operators of closed 

landfills which have no sources of revenue to offset the incremental costs.

Because the current NSPS/EG does not require integrated monitoring, it is not 

possible to conduct a before- and after- CA LMR comparison. The available data, 

however, indicate that integrated exceedances were detected in 2.1% of the 

grids monitored, and one-half of one percent (0.5%) of grids monitored were 

required to expand. Furthermore, EPA reviewed and rejected integrated surface 

monitoring in developing the 1996 NSPS for landfills, and there appears to be no 

reason to alter that conclusion. Given the additional cost burden associated with 

integrated monitoring, and the modest results, we oppose adopting this 

approach under the proposed NSPS.

6. Wellhead operating standards - The regulated community, including small 

entities, recommended that EPA maintain the monthly monitoring requirement 

but remove the temperature and oxygen/nitrogen wellhead operating 

parameters from the NSPS and EG rules. The sector recommended that EPA 

instead rely on maintaining the wellhead pressure standard and quarterly SEM 

to assure the proper operation of the GCCS. Members of the landfill sector have 

provided these comments to EPA and state agencies over the last eight years as 

EPA has contemplated amendments to the NSPS.
In the 1996 NSPS preamble (61 Fed. Reg. at 9912) EPA described the 

requirement for SEM and the maintenance of negative pressure at all wells, 

except under specified conditions, as the means to ensure proper collection 

system design and operation. The wellhead operating parameters for 

temperature and oxygen/nitrogen were described simply as indicators for

determining potential air intrusion; they were not promulgated to ensure proper 

collection system operation or to determine compliance. Nonetheless, the 

indicators have been applied in the same manner as compliance standards by 

several state agencies.

The sector identified many challenges with the wellhead parameters that make 

their implementation counterproductive to optimizing gas collection, system 

performance and methane emissions reduction. 

First, the oxygen/nitrogen and temperature wellhead parameters are poor 

indicators of the presence of landfill fires or of inhibited decomposition. Oxygen 

is rarely seen in a gas well, particularly when the system is recovering sufficient 

gas and producing stable gas flows. When greater than five percent oxygen is 

detected in a well the most common problem is a collapsed or pinched well, or a 

loose fitting or coupling that allows atmospheric air to enter the well.

Alternatively, where the landfill owner/operator is implementing early gas 

collection using shallow horizontal collectors or the leachate collection system, 

air can easily be pulled into the collectors, causing a temporary increase in 

oxygen until more waste is placed over the collectors ceasing air intrusion,

thereby discouraging earlier activation of the horizontal collection system. None 

of these examples would cause or contribute to a landfill fire, but they are the 

most typical circumstances for high oxygen readings in a wellhead.

The temperature of flowing LFG varies widely under normal landfill conditions.

Landfill gas is generated by a biological reaction and the greater the intensity of 

this reaction, the greater the heat produced by the biological activity. Therefore, 

some newly installed gas wells exhibit elevated temperatures naturally. In order 

to reduce temperature to meet NSPS compliance, the gas flow to the well must 

be turned off or significantly reduced. This undermines the optimal operation of 

the system and reduces the overall quantity of landfill gas collected.

Although Subpart WWW offers landfill owners the opportunity to establish a 

higher operating value (HOV) for the well, these alternatives are often ignored or 

denied by the agencies. Some regulatory agencies claim they are unable to 

authorize an HOV and simply tell the landfill operator to expand the system at a 

significant and unnecessary cost, completely ignoring the fact that expansion of 

the well field will not alleviate the elevated temperature. Recently an agency 

denied temperature HOV simply because the methane was not between 40 and 

50% (see ADI Number 1400009, http://cfpub.epa.gov/adi/pdf/adi-nsps1400009.pdf.). The agency’s interpretation is arbitrary, actually prevents sites 

from implementing early collection BMPs (i.e., tie-in to leachate collection 

system) and denies operating flexibility for non-producing wells in closed areas.

Further this determination appears to conflict with previous determination that 
allow for higher oxygen at wells with low methane quality (see ADI Number

0800040 and http://cfpub.epa.gov/adi/pdf/adi-nsps-0800040.pdf)

In addition to HOV requests and determinations, landfill owner and operators 

also request alternative timelines to complete expansion or corrective actions 

other than expansion. As with HOV requests, the amount of paperwork can be 

burdensome and time necessary to obtain an agency response or denial of a 

request can place a facility in compliance limbo. Most recently, the agency 

determinations have changed course and are denying sufficient time to 

determine the root cause of the exceedance and identify necessary repairs based 

on “EPA Guidance” (see 2/3/14 and 4/3/14 agency correspondence attached). A 

facility cannot realistically diagnose the reason for the exceedance in 15 days in 

all cases, yet the agency automatically denies requests based solely on this 

criterion. In addition, agencies are also denying requests if the landfill cannot 

provide “substantial reasons beyond the control of the facility owner or operator 

as to why the exceedances are not completed within 15 days.” This written EPA 

Guidance is burdensome and counter-productive to proper diagnostics and 

operation of the GCCS. Further, this EPA Guidance was never formally published 

for stakeholder review and comment or communicated to stakeholders; it just 

appeared in recent agency determinations.

Sites and agencies spend an enormous amount of resources preparing, 

processing and justifying HOV and alternative timeline requests and responses.

In many cases sites are forced to reduce gas extraction to meet wellhead 

operating parameters as agencies threaten NSPS violations. It becomes a “Catch22” of either risking compliance with agency directives or expanding the system 

in a manner, which will not alleviate the wellhead parameter issue, runs counter 

to proper operation of the GCCS, and in many cases increases the exceedances.

As part of our previous comments, we provided examples of agency 

correspondence on HOV requests and subsequent approvals and denials. We 

have attached additional examples for your review that illustrate paperwork 

burden and but also the amount of time it takes to get an agency response.

Second, the wellhead parameters present barriers to implementing early 

collection of landfill gas. Many landfill owners/operators understand the 

environmental benefits of reducing odors and methane emissions by using 

interim gas collection practices prior to the point at which the landfill is 

producing enough LFG to warrant a full GCCS. Two such practices include 

connecting to the leachate collection system and installing horizontal collectors.

These early activated systems require a maximum flexibility of design, 

installation and operation in order to deal with the changing decomposition rate, 

fill operations and potential early moisture conditions. However, many NSPS/EG 

sites do not take advantage of these practices solely because of compliance 

issues with the wellhead operating requirements. Horizontal collectors and 

leachate systems are effective at capturing early gas production, but often have 

difficulty meeting NSPS wellhead operational parameters.
Despite the environmental benefits of early gas collection, only a few states have 

accommodated early collection systems with flexible alternatives to the 

wellhead operating parameters. However, too few agencies are willing to review 

and grant such flexibilities for various reasons including lack of resources, 

conflicting determinations from EPA and lack of personnel who understand 

landfill operations.

Based on nearly three decades of experience with operating gas collection 

systems, the landfill sector urges EPA to remove the temperature and 

oxygen/nitrogen wellhead parameters, and instead rely on negative pressure 

and SEM to ensure proper operation of the gas collection system. Some states 

are concerned about landfill safety should the parameters be removed, while 

other states are supportive of their removal. California did not include 

temperature and oxygen/nitrogen wellhead parameters in its Landfill Methane 

Rule. In addition, several local California air management districts (South Coast, 

Bay Area AQMD) promulgated landfill rules prior to 40 CFR WWW. These air 

basin rules do not include temperature and oxygen/nitrogen wellhead 

parameters. Over the last 20 years, no negative impact to safety or the 

environment can be associated with lack of temperature and oxygen/nitrogen 

wellhead parameters in the air basin rules or the recent California landfill 

methane rule. 

Although states can always maintain the parameters within their state plans for 

EG implementation, we recommend EPA provide clear direction to agencies

through model rule language. In addition, EPA can provide guidance to the states 

regarding the problems posed by inflexible adherence to the parameters as good 

measures of system performance. If states desire to maintain the parameters, 

EPA might suggest streamlined approaches to approval of HOVs and alternative 

timelines for corrective action to reduce administrative burdens on the state 

environmental agencies and the regulated community.

Note that the oxygen and temperature requirements were not included in the CA 

LMR, based on CARB’s review of similar experiences as detailed above.

7. Landfill gas treatment –The landfill sector has been implementing beneficial, 

landfill gas-to-energy (LFGTE) projects long before the Landfill NSPS was 

implemented. After more than two decades of successful operation of LFGTE 

projects, it was disappointing that EPA was considering prescriptive LFG 

treatment requirements not required in manufacturer’s specifications for proper 

operation of our engines, turbines, or other end use equipment. The docket for 

the proposed NSPS did not provide any analysis or demonstration of the 

emissions reductions that would occur from the proposed changes to treatment 

requirements, and provided little detail regarding a cost analysis. The only 

analysis found in the docket was a 2005 memorandum, nearly a decade old, 

evaluating Jenbacher and Waukesha engines, and Solar turbines. Not only have 

the engine manufacturer’s updated their operating specifications for the engines 

since 2005, but the engines are not widely used within the landfill industry and 
are thus not relevant to a review of operational requirements for beneficial 

LFGTE projects.

In addition, treatment systems are not an emissions source. Because treatment 

systems are not an emission source, additional requirements will not result in 

any emission reductions. Given the above, we suggest that these requirements

are unnecessary. After all, treatment systems merely optimize the characteristics 

of the gas to match the specifications required by the end-use activity for which 

it is intended. 

Unlike on-site flaring or combustion of landfill gas, the treatment of landfill gas 

does not itself control emissions of NMOCs or HAPs and does not produce 

emissions that are vented to the atmosphere. Instead, treatment is a physical 

process that filters particulate matter from the gas stream and knocks out 

moisture in preparation for combustion. In light of the physical properties of 

landfill gas, the treatment system may be equipped with emergency or safety 

vents for non-routine emissions. For any such vent, the Landfill NSPS requires 

98% control of NMOC or an outlet concentration of less than 20 ppmvd at 3% 

oxygen, consistent with control device, emission standards established there 

under. See 40 CFR §60752(b)(2)(iii)(C). Under the currently effective 

regulations, EPA did not establish any emission limit or operating requirements 

that would apply to the treatment process itself, correctly reflecting that landfill 

gas treatment does not produce emissions that may be monitored or subjected 

to specific operating parameters. The CAA defines standard of performance to 

mean a “standard for emission of air pollutants.” 42 U.S.C. § 7411(a)(1).

Moreover, the central thrust of Part 60 is to require owners and operators to 

“maintain and operate any affected facility, including associated air pollution 

control equipment, in a manner consistent with good air pollution control 

practice for minimizing emissions.” 40 CFR § 60.11(d). Given that EPA has already 

determined that the routing of collected gas to a treatment system is an effective 

alternative to a control device, and since no emissions occur from the treatment 

process, no additional requirements for such treatment are warranted.

The landfill sector is very concerned that the costs of implementing the 

proposed treatment and monitoring requirements will be so great that many 

existing LFGTE projects will be forced to shut down and few new projects will be 

feasible. Chiller installation is expected to cost $500,000 with an additional 

$150,000 cost for continuous emissions monitors, instrumentation and controls. 

Operation and maintenance of the equipment is at least $60,000 per year and 

typical electricity costs are another $60,000 per year. These enormous 

expenditures will significantly burden small public and private entities and most 

importantly, will provide no additional emissions reductions.

EPA needs to consider the loss of valuable renewable energy projects that 

displace fossil fuel powered electrical generation, provide a reliable source of 

base load energy, and assist in meeting EPA’s and states’ greenhouse gas 

reduction goals before proposing requirements that will significantly impact 

such projects.
Instead of meeting a numerical standard, EPA can implement a work practice 

standard that includes manufacturer or end user specifications outlined in a 

project-specific Preventive Maintenance Plan (PMP). By tying treatment 

requirements to either end-user or manufacturer specifications that are 

documented in a PMP, EPA and the delegated states will have verifiable records 

of proper operation. PMPs are used in a variety of environmental programs that 

are premised on proper operation of equipment, such as pollution control 

devices. The PMP provides a system for documenting management and 

maintenance practices that protect equipment; maintain warranties; document 

contractual obligations to third-party users of the treated LFG; and afford 

regulatory staff an ongoing mechanism for oversight. Typically, states require 

that a copy of the PMP and all maintenance records be available on site for 

inspection and/or have identified elements that must be periodically reported to 

the state agency. A number of states have issued guidance that outlines required 

elements of an acceptable PMP.

As EPA noted in the preamble discussion of the alternative approach to 

treatment, the owner/operator of a LFG beneficial use project has a significant 

interest in ensuring that project devices receive only properly treated LFG that 

meets the manufacturer’s specifications for the device. This will ensure efficient 

operation of the project, reduce long-term maintenance costs, or provide 

assurance to end-users of the LFG that it meets their specifications for quality 

and composition. A “one-size-fits-all” approach to setting LFG treatment 

standards cannot accommodate the variety of end uses or 

combustion/conversion technologies available. A PMP can incorporate the 

specificity needed to ensure that LFG is properly treated for its end use, and can 

provide an enforceable recordkeeping mechanism to ensure regulators of the 

same.

Numeric standards coupled with continuous monitoring and recordkeeping are 

highly counterproductive, and would punish first movers who pioneered LFG 

beneficial use projects, and might endanger their continued operation due to the 

inordinate costs of installing unnecessary treatment equipment. The economic 

viability of some projects has already been compromised. If the Agency pursues 

numeric standards for treatment system in the NSPS and/or EG, the result will 

be destabilization in the renewable energy from LFG sector.

8. Organics management – As discussed, EPA’s WARM model establishes landfill 

with GCCS and energy recovery to produce fewer greenhouse gases than 

composting facilities. Indeed, there are other numerous reports demonstrating 

higher, uncontrolled emissions including volatile organic compounds (VOC) 

from composting facilities. See attached documents for more information. 

Therefore, we do not recommend that the rule take either approach proposed in 

the briefing. 
9. Installation and expansion and removal of the GCCS – The existing GCCS 

installation and expansion timeframes should be maintained. In particular, 

reducing the five-year timeframe for active areas of the landfill can lead to 

personnel safety concerns, as well as frequent damage to the system from heavy 

equipment and normal waste filling operations. Furthermore, early installation 

of gas collection equipment can cause increased waste settlement, which in turn 

affects gas header and piping alignment. This results in system disruptions and 

downtimes due to the need for frequent repairs. Finally, permitting a GCCS can 

be a lengthy process. A construction permit is required prior to initiating 

construction of a GCCS. While EPA assumes that sites can obtain permits within 

six months of application, permitting often takes more time. Depending upon the 

size and location of the project, the air permitting process for the control devices 

could extend several months to two years after the permit application is 

submitted. Since the facility cannot commence construction of the GCCS (i.e., 

excavation, delivery of equipment) until the final permit has been issued, 

permitting can cause unforeseen delays.

10. We also recommend that EPA also consider the criteria and timing of when a 

GCCS can be capped or removed. At that time, additional environmental benefits 

could be realized by clarifying that the GCCS does not have to be capped and 

removed when the criteria are met. Instead landfill owners should be allowed to 

operate the GCCS but no longer be required to comply with the NSPS 

requirements. Some landfills may still want to intermittently operate the gas 

system but the rule language could be misconstrued to not allow on-going but 

intermittent operation. 

The difficulties associated with operating a landfill gas collection and control 

system on low gas flow also suggest that EPA should reconsider its one-size-fitsall requirement that such systems must operate for a minimum of 15 years. The 

only reason continued operation of those systems is appropriate for closed 

landfills at all is to ensure emissions are minimized until the generation of 

landfill gas slows enough to warrant a discontinuation of control efforts, 

regardless of how long the system has actually been in operation. The 15-year 

requirement has also led to confusion and inconsistent interpretations among 

some states due to the lack of clarity regarding when the 15-year clock should 

start. EPA needs to reconsider the need for an arbitrary 15-year requirement for 

continued operation of controls on a closed landfill. As an alternative, EPA could

at least clarify that requirement by providing clear guidance regarding when the 

15-year clock should begin to run. 

The change in the NMOC threshold discussed above will be even more significant 

for landfills once they are closed and seeking to shutdown the controls system 

and exit the NSPS program. At a lower 34 - 40 Mg threshold, landfill 

owner/operators will need to use increasing amounts of fossil fuel to maintain 

flare operation. This increases GHG emissions, which is counterproductive. 

Because EPA does not plan to change the criteria for determining when a GCCS 

may be capped or removed, and those criteria currently require emissions to 
drop below the same threshold that triggers the need for the system, EPA’s 

decision to lower that threshold from 50 Mg/yr will have significant implications 

for the closure of landfills. 

Even under the current threshold of 50 Mg/yr, many closed landfills struggle to 

maintain sufficient gas flow to continue operating their control systems. At a 

lower threshold, operation of a control system will become even more difficult 

and likely much more expensive, as landfills will be forced to make even more 

costly modifications to the system just to keep it running on such a low flow of 

gas. 

The below listed small entities appreciate the opportunity to provide these 

comments. Should you have any questions, please contact Anne Germain at 

agermain@wasterecycling.org or Alek Orloff at aorloff@alpinewaste.com.

Very truly yours,

Anne M. Germain, P.E., BCEE

Director of Waste & Recycling Technology

National Waste & Recycling Association

Alek M. Orloff

Alpine Waste & Recycling

Michael S. Michaels, P.E.

On behalf of the City of Riverview, Michigan

Executive Vice President 

Cornerstone Environmental Group

Kimberly Smelker, P.E.

Operations Manager

Granger Waste Services

Attachments
Compost VOC Emission Factors 

September 15, 2010 

Reviewers:

Jim Swaney, P.E., Permit Services Manager 

Sheraz Gill, Supervising Air Quality Engineer 

Authors:

Brian Clements, Senior Air Quality Engineer 

Ramon Norman, Air Quality Engineer II 

Kai Chan, Air Quality Engineer II 
Green Waste Compost EF Report 

September 15, 2010 

2

I. Introduction

This report provides the basis for the District’s organic material composting 

volatile organic compound (VOC) emission factors (EFs). The organic material 

composting EFs contain the following categories: green waste, food waste, and 

grape pomace. However, the focus will be on green waste, since the San 

Joaquin Valley’s inventory of organic material compost is primarily green waste. 

The EFs will be used for Rule 4566 (Organic Material Management) development 

and permitting applications in the San Joaquin Valley. These organic material 

composting EFs are not applicable to biosolids, animal manure, or poultry litter, 

which have been attributed a separate EF. 

Accurate emission factors are required for the proper implementation of 

applicable air quality regulations and also for the evaluation of appropriate 

technologies and practices to reduce emissions. The VOC EFs proposed in this 

report are based on a detailed review of the available science. As would be the 

case with EFs for other sources, the District’s EF should reflect the best scientific 

information that is currently available. 

The District composting EFs are summarized below. 

Table 1: Summary of District Composting EFs.

Compost Type Stockpile 

(lb-VOC/wet ton/day) 

Windrow EF 

Per composting cycle 

(lb-VOC/wet ton) 

Green Waste, Food Waste, 

Grape Pomace 1.063 5.71 

Co-Composting Biosolids, 

Animal Manure, Poultry Litter - 1.78 

II. Background

A. Air Quality 

The San Joaquin Valley air basin has an inland Mediterranean climate 

characterized by hot, dry summers and cool, foggy winters. The San Joaquin 

Valley is surrounded by mountains on the east, west, and south sides. This 

creates stagnant air patterns that trap pollution, particularly in the south of the 

San Joaquin Valley. Additionally, the sunshine and hot weather, which are 

prevalent in the summer, lead to the formation of ozone (photochemical smog). 

Because of the San Joaquin Valley’s geographic and meteorological conditions, 

it is extremely sensitive to increases in emissions and experiences some of the 

worst air quality in the nation. 

The San Joaquin Valley Air Basin is now classified as an extreme non-attainment 

area for the health-based, Federal eight-hour ozone standard because of the 

inability to reach attainment of the standard by the earlier serious and severe 
Green Waste Compost EF Report 

September 15, 2010 

3

classification attainment dates. The air basin is also classified as a nonattainment area for the Federal PM-2.5 (ultra-fine particulate matter) standard. 

B. Composting 

Compost operations can be sources of smog-forming VOCs, fine particulate 

matter, ammonia (NH3), and greenhouse gases such as carbon dioxide (CO2) 

and methane (CH4). The emissions are directly emitted from the decomposition 

of organic material in the San Joaquin Valley. Composting is a process that 

involves the biological break down of organic matter, typically into marketable 

products (soil amendments, animal bedding, and alternative daily cover at 

landfills). Composting uses wastes from a wide-variety of sources, such as curbside green waste, landscaping, agricultural processing, crop harvesting, food 

consumption, and forest management. 

There are two general categories of composting, aerobic and anaerobic: 

Aerobic composting is the decomposition of organic material by microbiological 

organisms (microbes) in the presence of oxygen (O2). This oxidation process 

theoretically results in CO2, water (H2O), and organic matter, including nitrates, 

sulphates and other minerals. Figure 1 below is a visual presentation of theoretic 

aerobic composting: 

Figure 1: Aerobic Compost. (1) 

Anaerobic composting is the decomposition of organic matter by microbes in the 

absence of O2. During this digestion process, a gas primarily composed of CH4

and CO2, known as biogas, waste gas or digester gas is produced. Biogas also 

consists of nitrogen (N2), O2, NH3, hydrogen sulfide (H2S), and various VOCs. 

However, these additional products are generated in relatively small amounts 

when compared to the amount of CH4 and CO2 produced. 

 

1

http://www.londonfoodrecycling.co.uk 
Green Waste Compost EF Report 

September 15, 2010 

4

C. Purpose of the San Joaquin Valley Air Pollution Control District 

The San Joaquin Valley Air District is a public health agency whose mission is to 

improve the health and quality of life for all Valley residents through efficient, 

effective and entrepreneurial air quality management strategies. To protect the 

health of Valley residents, the District works toward achieving attainment with 

health-based ambient air quality standards as required under State and Federal 

law. To achieve this goal, the District develops and adopts air quality attainment 

plans that include control measures aimed at further reducing emissions from a 

broad range of sources, commercial, industrial, and agricultural. 

As mandated by Federal Law, the San Joaquin Valley Air District adopted its 8-hr 

ozone attainment plan to demonstrate how the Valley would reach attainment 

with the Federal eight-hour ozone standard. In developing the ozone attainment 

plan every feasible measure to reduce emissions of ozone precursors (VOC and 

NOx) was explored. Green waste composting was a control measured identified 

in the ozone plan. As such, plans to develop Rule 4566 (Organic Material 

Management) are in place. However, even though the District will be requiring 

every practical VOC and NOx control, and will be relying on the state and federal 

governments to significantly reduce emissions from mobile sources of pollution, 

the San Joaquin Valley will still need the development and adoption of future, 

not-yet-developed, clean air technologies to reach attainment by the 2023 

deadline. Achieving the goal of attainment with air quality standards will require 

continued contributions from all industries, businesses, and individuals in the San 

Joaquin Valley. 

D. Permitting Requirements 

A critical tool that the air districts use to limit increases in emissions of air 

pollutants and to assure compliance with air quality regulations is the issuance of 

conditional construction and operating permits to commercial, industrial, and 

agricultural sources of air pollution. Since the 1970s, the San Joaquin Valley Air 

Pollution Control District and its predecessors have issued tens of thousands of 

conditional permits that are being used to assure compliance with air pollution 

control requirements throughout the Valley. District permits address the 

requirements of federal standards, state regulations, and District rules that 

specifically apply to a source of air pollution. New and modified sources of air 

pollution are also subject to the more protective requirements of “New Source 

Review”, which are determined on a case-by-case basis and are also included in 

the permit. Permit holders, District Inspectors, and others use these District 

permits, rather than directly reference the complex and voluminous underlying 

regulations, to verify compliance with applicable air quality requirements. 

For new sources, the District begins permitting them as we become aware of 

their emissions. The permitting threshold for these types of operations is 2 lbpollutant/day. Currently the District quantifies VOC and NH3 emissions to 

composting operations. Therefore, any organic material composting operation 
Green Waste Compost EF Report 

September 15, 2010 

5

which has the potential to emit more than 2 lbs of either VOC or NH3 per day is 

subject to District permitting. 

III. EF Determination Analysis

Many factors, which are related, affect the composting process that makes it 

difficult to scientifically analyze composting from an air emissions standpoint. 

The major factors affecting compost are oxygen, moisture, seasonal temperature 

fluctuation, temperature increases resulting from microbial respiration, nutrients 

(especially carbon and nitrogen), feedstock variability and pH. As such, the 

District will rely heavily on actual test data for this emission factor determination. 

A. Green Waste Composting EFs 

The chosen EFs are based on the available source test data for organic material 

composting sites. The District contracted a review of this data to Charles E. 

Schmidt with the goal of establishing green waste EFs for rule making purposes. 

The report was intended to identify the tests that utilized appropriate sampling 

and analytical methods and that were statistically relevant. As a result, the 

following report was prepared: “Organic Material Composting and Drying 

focusing on Greenwaste Compost Air Emissions Data Review”, by Thomas R. 

Card and Charles E. Schmidt, June 2008 (see the Appendix A for the full report). 

This report will be referred to as the “green waste report” hereafter within this 

document. 

The tests were based on the concept of flux emissions escaping the green waste 

piles. In this context, flux means the rate of mass flow of fluid gases through a 

given surface area. For example, the flux emissions may be measured in units of 

mg-VOC/min-m2

. Knowing the total composting period of time, surface pile area, 

and pile mass, the flux emission factors may be converted to typical EFs used for 

permitting and rule making, such as in units of lb-VOC/ton. The flux emissions 

were primarily sampled using the SCAQMD Modified USEPA surface emission 

isolation flux chamber method, and analyzed using SCAQMD Method 25.3 for 

total VOCs. 

Table 5.1 of the green waste report summarizes the most relevant green waste 

composting data. The relevant test locations identified in Table 5.1 are Site X, 

CIWMB Modesto, NorCal, CIWMB Tierra Verde, and two at SCAQMD Inland. 

Since the compilation of the green waste report, another relevant test was 

performed at the Northern Recycling Zamora Compost Facility. This test was 

also conducted by Card and Schmidt. The summary is contained in Tables 2 

and 3 below. 
Green Waste Compost EF Report 

September 15, 2010 

6

1.) Green Waste Stockpile EF 

The green waste EFs shown in the Table 2 below are based on a one day 

stockpile period. While a one day stockpiling period may not be how every 

facility in the SJV operates, the EF can be applied on a case-by-case basis when 

stockpiling time periods are known. Also of note, the source test reports do not 

show the Table 2 numbers directly. The source tests each reported the stockpile 

EF based on their own site-specific stockpile period. For example, the Northern 

Recycling Zamora stockpile test assumed the EF for a 90-day stockpile time. 

The Northern Recycling Zamora stockpile sampling was performed on days 1 

and 7, which is representative of normal SJV stockpiling. To arrive at the 90-day 

stockpile EF, it was assumed the average rates measured on days 1 and 7 were 

emitted for 90 days. The District reduced the EF to a one-day basis for this EF 

report. Each of the other stockpile EFs were normalized to a one day basis as 

well. 

Table 2: Green Waste Stockpile VOC EF 

Site Sampling Age of 

Material 

Season Samples 

Taken 

EF 

(lb-VOC/wet ton/day) 

Northern Recycling 

Zamora Day 1 & Day 7 Spring 0.126 

NorCal 

Jepson Prairie 

(Vacaville) 

Day 1 Summer 0.422 

SCAQMD 

Inland Day 2 Fall 0.907 

SCAQMD 

Inland Day 2 Fall 2.798 

Average 1.063 

The District surveyed the green waste composting facilities in the San Joaquin 

Valley. The result of the survey indicates an average stockpile time of 3.85 days, 

and ranged from 0-21 days. The Site X stockpile EF was based on sampling at 

day 45, and is not representative of stockpiling in the San Joaquin Valley. As 

such, the Site X stockpile test was not included in the stockpile EF. The test at 

CIWMB (Modesto) contained no stockpile data and does not factor into the green 

waste stockpile EF. The test at CIWMB Tierra Verde contained no uncontrolled 

stockpile data and does not factor into the green waste stockpile EF. 
Green Waste Compost EF Report 

September 15, 2010 

7

2.) Green Waste Windrow EF 

Table 3: Green Waste Windrow VOC EF 

Site Sampling Age of 

Material 

Season 

Samples Taken 

EF 

(lb-VOC/wet ton/day)

CIWMB (Modesto) Spring 0.85* 

Site X Summer 6.30 

NorCal 

Jepson Prairie 

(Vacaville)

Fall 5.65 

Northern Recycling 

(Zamora) 

Over the Active 

+ Curing Phase 

(days not 

sampled were 

interpolated) 

Fall 10.03 

Average 5.71 

*1.54 was identified in the green waste report after a recalculation to better 

represent other sites; however, 0.85 was the actual value reported from this test 

site and will be used in the EF determination. 

The test results for CIWMB Tierra Verde indicate the testing was performed for 

other management strategies, not a typical baseline facility; therefore, does not 

factor into the green waste windrow EF. The two test results for SCAQMD Inland 

indicate the windrows tested were extremely small; therefore, does not factor into 

the green waste windrow EF. 

Please note, the values are based on the input material (as wet tons), not 

finished material. The green waste windrow composting EF is based on a typical 

active + curing phase composting life cycle (minimum 60 days). The activephase has been defined at a minimum 22 days for District purposes. The District 

has also examined the VOC profile split over the course of a windrow cycle. The 

results are summarized below. 

Table 4: Green Waste Windrow VOC EF Active-Phase vs Curing-Phase. 

Windrow Phase 

Overall EF 

Active + Curing 

(lb-VOC/wet ton) 

VOC Profile Split 

(%) 

Phase EF 

(lb-VOC/wet ton) 

Active-Phase 90% 5.14 

Curing-Phase 5.71 10% 0.57 

B. Food Waste Composting EFs 

The District has not been able to identify an emission factor for uncontrolled food 

waste composting. Source tests from controlled composting operations have 

yielded emission factors ranging from 3.4 lb VOC per ton food waste composted 
Green Waste Compost EF Report 

September 15, 2010 

8

(micropore cover) to 37.1 lb VOC per ton food waste 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 

windrow commonly used by facilities in the District. This is because covered 

systems offer many process control advantages including weather protection and 

water retention. 

Source testing was conducted at the City of Modesto compost facility as a field 

test study for the California Integrated Waste Management Board (CIWMB). Two 

goals of this test were to determine VOC emissions from green waste 

composting and food waste composting. The food waste composting windrows 

contained approximately 15% food waste (from local food processing plants (e.g. 

peppers, tomatoes, peaches, and syrup) and 85% ground green waste. The 

resulting EFs were 0.85 lb-VOC/ton and 1.95 lb-VOC/ton for green waste and 

food waste respectively. As predicted, the food waste EF was higher than the 

green waste EF, 2.3 times higher for this test site. Since the average green 

waste EF has been established at 5.71 lb-VOC/ton, the District considers the 

food waste EF to be too low to be usable as a stand-alone food waste 

composting EF since it would be lower than the green waste EF. However, if 

more data were to become available for food waste composting, the food waste 

EF from the City of Modesto test site may be used in combination with the new 

data. 

For these reasons, the District will use the green waste composting emission 

factor to represent this feed stock until a more representative emission factor can 

be identified. 

C. Grape Pomace Composting EFs 

The District has not been able to identify an emission factor for grape pomace 

composting. Therefore, the District will use the green waste composting 

emission factor to represent this feed stock until a more data is available. 

D. Biosolids, Animal Manure, Poultry Litter Composting EFs 

Biosolids and animal manure composting emission factors were taken from 

source tests conducted by the South Coast Air Quality Management District 

(SCAQMD) in support of their Rule 1133 (Emission Reductions from Composting 

and Related Operations). These emission factors were calculated as an average 

of emissions from three co-composting facilities (SCAQMD, 2002) as presented 

in the Table below. 

The District has not been able to identify an emission factor for poultry litter 

composting. The District will use the biosolids composting emission factor to 

represent this feed stock until a more representative emission factor can be 

identified. 
Green Waste Compost EF Report 

September 15, 2010 

9

Table 5: Biosolids, Animal Manure, and Poultry Litter EFs. 

 Summary of Co-Composting Emission Factors Developed by SCAQMD 

Emission Factors (lb/wet-ton) Location VOC NH3

RECYC Inc 0.53 2.70 

EKO Systems 1.70 3.28 

San Joaquin Composting 3.12 2.81 

Average 1.78 2.93 

Summary

The District composting EFs are summarized below. 

Table 6: Summary of District Composting EFs.

Compost Type Stockpile 

(lb-VOC/wet ton/day) 

Windrow EF 

Per composting cycle 

(lb-VOC/wet ton) 

Green Waste, Food Waste, 

Grape Pomace 1.063 5.71 

Co-Composting Biosolids, 

Animal Manure, Poultry Litter - 1.78 

Appendices

Appendix A: “Organic Material Composting and Drying focusing on Greenwaste 

Compost Air Emissions Data Review”, by Thomas R. Card and 

Charles E. Schmidt, June 2008 

Appendix B: Comments and Responses to the “Organic Material Composting 

and Drying focusing on Greenwaste Compost Air Emissions Data 

Review” 

Appendix C: “Northern Recycling Zamora Compost Facility Air Emissions 

Source Test”, by Thomas R. Card and Charles E. Schmidt, May 

2009 
Appendix A 

“Organic Material Composting and Drying focusing on Greenwaste Compost Air 

Emissions Data Review”, by Thomas R. Card and Charles E. Schmidt, June 2008
San Joaquin Valley

Air Pollution Control District

Organic Material Composting and Drying 

focusing on

Greenwaste Compost

Air Emissions Data Review

Report

June 2008

Prepared by

Thomas R. Card, PE

Environmental Management Consulting

41125 278th Way SE, Enumclaw, WA 98022

360-802-5540 Fax: 360-802-5541

E-Mail: trcard@earthlink.net

Charles E. Schmidt, PhD

19200 Live Oak Road, Red Bluff, CA 96080

530-529-4256 Fax:530-529-4878
Contents 

Executive Summary...................................................................................................................................... 1

1.0 Introduction......................................................................................................................................... 5

2.0 Background ......................................................................................................................................... 5

3.0 Data Evaluation Methodology ........................................................................................................... 7

Target Species............................................................................................................................................ 7

Sample Collection Methods....................................................................................................................... 7

Analytical Methods.................................................................................................................................... 7

4.0 Emission Factor Development ........................................................................................................... 8

4.1 Compost Pile Configuration ............................................................................................................... 8

4.2 Full Compost Cycle Simulation ........................................................................................................... 9

4.5 Emissions from Feedstock and Product Storage ................................................................................. 9

5.0 Most Relevant Green Waste Compost Data ................................................................................ 9

5.1 Confidential Site (Site X) ....................................................................................................................10

5.2 California Integrated Waste Management Board (CIWMB) Modesto ...............................................10

5.3 NorCal Waste Systems........................................................................................................................11

5.4 CIWMB Tierra Verde .........................................................................................................................11

5.5 SCAQMD Data ...................................................................................................................................11

5.6 Discussion...........................................................................................................................................11

6.0 Most Relevant Food Waste Compost Data .................................................................................12

7.0 Most Relevant Biosolids Compost Data ......................................................................................13

8.0 References......................................................................................................................................14
Tables

Table ES 1 Summary of greenwaste composting full site VOC emission data (#/ton of 

feedstock).

Table 5.1 Summary of most relevant green waste composting data.

Table 5.2 Summary of greenwaste VOC emission factors (#/ton feedstock).

Table 6.1 Summary of most relevant food waste composting data.

Figures

Figure ES 1 VOC emission profile for each of the three complete data sets (#VOC/ton 

feedstock per compost day).

Figure ES 2 The effect of pile temperature on VOC emissions (from Hentz et al 1996).

Figure 2.1 Example daily emissions from a greenwaste composting windrow (VOC and 

ammonia).

Figure 2.2 The effect of pile temperature on VOC emissions (from Hentz et al 1996).

Figure 4.1 Compost Windrow Configuration.

Figure 4.2 Range of area to volume ratios for typical windrow cross-section dimensions.

Figure 5.1 Daily VOC emissions profile from Site X, CIWMB Modesto, and NorCal.

Appendices

A SJVAPCD Reference Table and Complete Report Reviews

B Technical Memorandum – Recalculating CIWMB Modesto Emissions

C Confidential Site X Emissions Report
1

Executive Summary

Useful information regarding air emissions from compost sites can be obtained by 

assessing the flux (mass transfer from the test surface) of hydrocarbon compounds and 

other compounds such as ammonia, and then expressing these data as emission factors. 

An emission factor is obtained by taking representative flux data for an operable unit at a 

compost site, such as a greenwaste in windrow, multiplying the average flux from the 

windrow by the surface area of the windrow, and generating an emission factor (mass 

emitted per time per source). These data can be expressed on a per ton basis, and the site 

air emissions can be obtained by summing the emission per operable unit, which are 

obtained by multiplying the mass or surface area of each unit by the respective emission 

factor. As such, the goal of any air pathway analysis intended to assess air emissions 

from a compost facility, is to obtain representative emission factor data.

The focus of this research effort is to provide to the District a report of relevant and 

useful emission factors that can be used in the regulatory process to assess air emissions 

from a variety of compost facilities. Compost emission factor data from 14 reports were 

reviewed and prioritized for data quality and completeness. These data consisted of 

emissions test data from greenwaste, biosolids-greenwaste co-composting, and food 

waste. All the reports were summarized and critiqued with the individual critiques 

attached in this report’s appendix. A summary table was prepared by San Joaquin Valley 

Air Pollution Control District (SJVAPCD) staff and is provided in the same attachment.

This report is focused on total VOC emissions as measured by South Coast Air Quality 

Management District (SCAQMD) Method 25.3. This method is a comprehensive total 

VOC method and is generally not comparable to other total VOC methods including 

USEPA Method 25 series and USEPA Method TO-12. Ammonia and some methane 

data is reported as well, but in general is not discussed further. All VOC data reported 

here, unless otherwise noted, is VOC per SCAQMD Method 25.3.

The green waste composting data was looked at specifically for data that would be both 

complete and accurate enough to provide a rule making basis. Three data sets were found 

to be both complete enough and used the appropriate sampling an analytical methods to 

generate full site emissions. However, one of the data sets did not have stockpile 

emissions.

The data from these greenwaste composting sites is summarized below in Table ES 1. 

The data are averaged for reference only with no implication that the average is 

representative of green waste compost emissions for the SJVAPCD jurisdiction. The 

California Integrated Waste Management Board’s (CIWMB) values are from their 

Modesto report and were recalculated to be more comparative to the other data (see 

attached Technical Memorandum). The emission factor was calculated by taking the 

total process emissions and dividing that by the mass of material that was in the compost 

process. For most situations, a facility can estimate their annual emissions using these 

factors by multiplying the factor times the total annual throughput (compost substrate and 
2

amendment). All mass values are for input, not output. There is normally significant 

mass loss during the composting process.

Table ES 1 Summary of greenwaste composting full site VOC emission data (#/ton of 

feedstock).

Source Site X CIWMB NorCal Average

Stockpile 7.76 2.95 5.36

Windrow 6.30 1.54 5.65 4.50

Total 14.06 8.60 9.85

These data are even more diverse than this table may indicate. Figure ES-1 shows the 

daily compost windrow emissions for each of these data sets. The NorCal profile 

particularly shows a unique characteristic initial cycle VOC spike.

There were other important data sets. The CIWMB Tierra Verde data shows the likely 

range of unit flux values that will be encountered in California green waste composting 

facilities. These values bracket the data from the three complete sites suggesting that the 

complete sites may represent the likely working range of emissions from these types of 

sites.

Figure ES 1 VOC emission profile for each of the three complete data sets (#VOC/ton 

feedstock per compost day).

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1 6 11 16 21 26 31 36 41 46 51 56 61 66 71 76

Compost Process Day

Daily Single Windrow Emissions (#/ton)

Site X

CIWMB Modesto

NorCal
3

SCAQMD emission factors, currently the only official regulatory values, are briefly 

discussed noting that they mostly represent stockpile emissions and not compost 

emissions. The compost emissions from their data appear unrealistically low and are 

significantly outside the bounds of all the other data sets.

The most relevant food waste composting data was from only one site and provided 

emissions for various covered compost technologies. The food waste compost 

technologies were Ag-Bag®, Compostex®, and micropore covers. These cover 

technologies are described in more detail in the report text. Food waste windrow 

emission factors ranged from 1.7 to 36.7 pounds VOC per ton of throughput. Food waste 

stockpile emission factors ranged from 0.42 to 1.8 pounds VOC per ton of throughput.

The most relevant biosolids composting data came from two sites. A third site (Las 

Virgenes) was reported but did not present complete system emissions. One of the sites 

(LACSD) reported data from both on top of, and underneath, a micropore cover system. 

The under the cover measured emissions are likely not representative of a normal 

uncovered process because the affect that the cover has temperature and moisture. In 

addition, this was a pilot scale facility. The other site was a compliance test for a very 

large aerated static pile biosolids facility near Bakersfield. The biosolids composting 

emission factors ranged from 0.2 to 3.7 pounds VOC per ton of total (biosolids plus 

amendment) throughput.

There is some discussion in this report as to why there is a large variability of emissions 

found in the compost industry. There are several reasons for this:

 Regional differences is feed stock materials processed at compost facilities

 Seasonal differences in feed stock materials

 Seasonal metrological differences

 Differences in operating procedures and facility management practices

 Size and age of feedstock piles

 Size, shape and orientation of windrows to dominant wind direction

 Solid waste handling equipment

 Control of parameters in the composting process such as aeration or mixing, water 

content, and temperature

 Compost composition, specifically ratio of carbon-to-nitrogen

The most significant sources of variability in emission factors is likely mostly due to 

windrow size, feedstock characteristics, waste pile and windrow temperature, and 

operating characteristics. There was not sufficient data to determine the magnitude of 

most of these variables, including seasonal emissions variability. Said another way, it is 

not possible to generate seasonal emission factors for these sources. Seasonal variability 

likely has both a temperature and feedstock component, which further complicates the 

determination of emission factor as a function of variable. There has been some previous 

work showing that the carbon–nitrogen ratio significantly affects air emissions, but again, 

insufficient information is available to define this effect. Temperature has been studied 
4

and there are some data available showing increased air emissions or greater emission 

factors with increased compost temperature as shown below. This figure shows how 

temperature affected VOC emissions from an aerated static pile composting biosolids in 

Philadelphia (Hentz et al 1996).

Figure ES 2 The effect of pile temperature on VOC emissions (from Hentz et al 1996).

Temperature ( oF)

80 100 120 140 160

0

50

100

150

200

250

300

ppmv as Carbon (Method 25C)

The data set can not at this time be used to assess the impact of these variable on

emission factors or compost site air emissions expressed on an annual basis. However, 

these limited data do justify the range of emission factors reported herein.

In summary, this report serves to:

1) Present the status quo of the industry air emission data base for the Central Valley;

2) Define the range of emission factors measured;

3) Define the key variables that effect air emissions from compost facilities;

4) Describe current and recommended testing protocols used to assess air emissions at 

compost facilities;

5) Provide an annotated bibliography of the relevant research with commentary on testing 

protocols, frequency of sample collection, analytical method, and emission factor 

generation; and 

6) Present the emission factors supported by the data base.
5

1.0 Introduction

This report provides a comprehensive review of greenwaste composting air emissions 

data with focus on total hydrocarbon and ammonia emissions. Methane emissions are 

also presented to a limited extent. The report also presents some limited data on 

composting biosolids and food waste.

All raw data and original data reports were provided by San Joaquin Valley Air Pollution 

Control District (SJVAPCD) Staff. Since the method of analysis of total hydrocarbon is 

regulatory important, and SJVAPCD has adopted South Coast Air Quality Management 

District (SCAQMD) Method 25.3 as their standard, data is limited to recently tested 

California sources.

2.0 Background

The air emissions assessment of composting operations is both complicated and resource 

intensive. Composting can take place either in windrows or in aerated static piles (ASP). 

Windrows are naturally ventilated and normally mechanically turned on a process 

schedule. Typical compost windrow dimensions are 3 to 7 feet high, 8 to 20 feet wide, 

and 50 to 500 feet long. ASP’s are large piles that are 8 to 16 feet high with plan form 

areas of 2,500 to 25,000 ft2. They are normally underlain with an air distribution system 

that provides air by either suction or pressure. There also are some hybrid technologies 

that use a cover on a windrow that also have forced air ventilation systems. Most, if not 

all, greenwaste in California is composted in windrows that are mechanically turned.

A normal compost cycle lasts from 45 to 90 days. Most greenwaste is on a 60 day cycle. 

The first half of the cycle can be designated as composting and the last half as curing. 

In addition to the windrows, there are also material stockpiles on composting sites that 

store feedstock and product. The size of these stockpiles is widely variable and is a 

significant factor in overall site emissions variability.

The emissions from these facilities are difficult to quantify. The emissions from a 

windrow change daily over the compost cycle. Testing is conducted using approved area 

source assessment technologies with the goal of collecting representative flux data (mass 

per time-area) that can be used to calculate emission factors for sources found on 

compost sites, or operable units (e.g., feed stock piles, windrows, product piles, etc.) 

Emission factors from operable units or sources are expressed as emissions per ton of 

materials received, and these data are used to estimate emissions (mass per time) for the 

facility on an annual basis. 

Figure 2.1 shows a daily emissions profile from windrow greenwaste composting. In 

order to generate this curve, the windrow has to be sampled on several of the 60 process 

days. As shown on the curve, this sampling should be more intensive at the start of the 

compost cycle because most of the emissions occur at the start of the cycle and the daily 

emissions are the most temporally variable. In windrows that are less well mixed there 
6

can be significant spatial variability as well. For each compost day, from 2-to-8 

individual samples should be taken to assure that the spatial variability is accommodated.

Emissions from these sources tend to be variable. The likely important factors in 

variability are seasonal temperatures, feedstock variability (regionally and seasonally), 

and operating parameters. Not a lot is known about how these factors affect emissions. 

The only quantitative data available are the affects that pile temperature has on VOC 

emissions. Figure 2.2 shows how temperature affected VOC emissions from an aerated 

static pile composting biosolids in Philadelphia (Hentz et al 1996).

Figure 2.1 Example daily emissions from a greenwaste composting windrow (VOC and 

ammonia).

0

50

100

150

200

250

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59

Compost Process Day

VOC Daily Emissions (Pounds)

0.0

0.5

1.0

1.5

2.0

2.5

NH3 Daily Emissions (Pounds)

WC VOC

WC NH3
7

Figure 2.2 The effect of pile temperature on VOC emissions (from Hentz et al 1996).

Temperature ( oF)

80 100 120 140 160

0

50

100

150

200

250

300

ppmv as Carbon (Method 25C)

3.0 Data Evaluation Methodology

This section covers the methodology for the sampling phase of the air emissions 

assessment and how the data sets were evaluated.

Target Species

The selection of target species was evaluated as best representing VOC emissions. For 

compost sites, all work was compared to SCAQMD Method 25.3 since it has been shown 

that this method is capable of collecting and analyzing for all condensable and volatile 

hydrocarbon species believed to exist on greenwaste, food waste, and biosolids compost 

facilities. Data representativeness will be discounted in the review for other methods, 

including SCAQMD 25.1 and USEPA Method TO-15 as compared to SCAQMD Method 

25.3.

Sample Collection Methods

As demonstrated by the SCAQMD and indicated in Rule 1133, the preferred method for 

sample collection or assessment of compound emissions from sources at compost sites is 

the SCAQMD Modified USEPA surface emission isolation flux chamber technology. 

All the research reviewed used this technology except one, and this work (Hanaford 

Compost Site) was discounted as non-applicable and non-representative. On occasion, 

the USEPA technology was used without the SCAQMD modification, in which case a 

bias in emission may have been encountered.

Analytical Methods

The appropriate analytical methods for this research are SCAQMD Method 25.3 for 

VOCs (or total non-methane non-ethane organic compounds) and SCAQMD Method 

207.1 for ammonia. Other methods fall short and are identified as such.
8

4.0 Emission Factor Development

Once the unit flux data has been obtained, the full cycle emissions are then estimated by 

the following procedures.

4.1 Compost Pile Configuration

Compost pile dimensions have a high degree of variability. However, they all match the 

shape shown in Figure 4.1. The key property for the configuration is the surface area to 

volume ratio. Figure 4.2 shows how this varies for different cross sections. There is over 

a factor of two difference in surface area to volume ratio between shallow and deep 

windrows. For the same unit surface flux rate, the smaller row will have twice the 

emissions on a per ton input basis.

Figure 4.1. – Compost Windrow Configuration.

Length

Height

Top Width

Bottom Width



2

2

1 2 1 2

2

1 2

(( )/ 2)

3

( )

2

h WB WT s

h A A A A

V

s A

p p

S

  

 









Mensuration formulas

where S = total surface area, p 1 = bottom

perimeter, p 2 = top perimeter, s = slant height,

V=volume, h=vertical height, A 1 = bottom area,

A2 = top area,  = bottom angle
9

Figure 4.2. – Range of area to volume ratios for typical windrow cross-section dimensions.

4.2 Full Compost Cycle Simulation

The unit emission data should be extended to estimate emissions from the full compost 

cycle using linear interpolation and averaging. Full cycle emissions for each day of the 

compost process, should then added and the sum of the individual daily emissions should 

be totalized. The emission factor consists of the full total cycle emissions (in pounds) 

divided by the incoming feedstock weight (in tons). 

4.5 Emissions from Feedstock and Product Storage

The emissions from feedstock and product storage typically are calculated by taking unit 

flux data (apportioned to different types of materials) and multiplying by the average 

annual storage surface area. For some data sets, there was more area in storage than in 

windrows.

5.0 Most Relevant Green Waste Compost Data

This section presents the data found to be most relevant in characterizing greenwaste 

emissions in the State of California. Table 5.1 presents a summary of this data in both an 

emission factor and unit emission rate form. The paragraphs below discuss the data 

points in detail.

0

0.5

1

1.5

2

2.5

3

10 11 12 13 14 15 16 17 18 19 20

Windrow Bottom Width (ft) Area to Volume Ration (ft2/ft3)

3 ft windrow height

4 ft windrow height

5 ft windrow height

6 ft windrow height

7 ft windrow height
10

Table 5.1 Summary of most relevant green waste composting data.

EF EF

Location Material Activity (#/ton) Peak Avg Min Peak Avg Min (#/ton) Peak Avg Min Peak Avg Min

Site X Stockpiles 7.76 186 111 37 2.30 1.38 0.46 0.03 0.62 0.39 0.16 0.01 0.00 0.002

Windrows 6.30 23 11 3 0.29 0.13 0.04 2.34 26.56 12.07 0.20 0.33 0.15 0.003

Total 14.06 2.37

Windrows 1.54 42 9 0.1 0.51 0.11 0.001

`

NorCal Stockpiles 2.95 110 54 4 1.36 0.66 0.046 0.08 2.1 1.21 0.61 0.03 0.01 0.008

Windrows 5.65 376 73 1 4.65 0.90 0.010 0.54 7.29 1.68 0.22 0.09 0.02 0.003

Total 8.60 0.62

CIWMB TV Mix HCN 124 42 2 1.53 0.52 0.02

Mix LCN 443 110 1 5.48 1.36 0.02

UnMix HCN 23 6 1 0.28 0.07 0.01

UnMix LCN 38 10 1 0.47 0.13 0.01

Stockpiles 4.75 24 0.30 0.01 6.55 0.081

Windrows 0.3 6 0.08 1.31 0.32 0.004

Total 5.05 1.32

Stockpiles 1.96 20 0.25 0.29 2.67 0.033

Windrows 0.5 6 0.08 0.03 0.32 0.004

Total 2.47 0.32

Unit Flux (mg/minm2)Unit Flux (mg/minm2)

VOC NH3

Unit Flux (#/hr1,000ft2)Unit Flux (#/hr1,000ft2)

SCAQMD 

Inland 

Winter

Landscape 

Waste

CIWMB 

Modesto

SCAQMD 

Inland 

Summer

5.1 Confidential Site (Site X)

This is the most recent data set, taken in the Spring of 2008. This is a confidential source 

composting greenwaste in the SJVAPCD. The data set consists of about 20 

measurements, all collected with the newly modified SCAQMD flux method and 

acceptable laboratory method and practice. This site had large stockpiles with about one 

half the emissions coming from the stockpiles. The stockpiles had about 50% of the 

surface area as the windrows. The windrow emissions from this site were about an order 

of magnitude (10 times) the emissions measured by the SCAQMD in 2001, but were not 

the highest measured of this data group. The site was very well operated with significant 

attention to process control. This site uses very small windrows with a high surface area 

to volume ratio.

5.2 California Integrated Waste Management Board (CIWMB) 

Modesto

This data set was taken in 2006 using the current state of the art methods for that time. 

The emission factor in this table (1.5 # VOC per ton) was recalculated to better represent 

the other projects and is about twice the factor presented in their report (see attached 

TM). Note that the average unit flux value is the same as Site X (about 10 mg/min-m

2

), 

but the emissions are a factor of 4 lower. This is due to a combination of the larger 

windrows used on this site and the rapid fall off of emissions after initial composting. 

This was also a well run site. The data set consisted of 36 measurements.
11

5.3 NorCal Waste Systems

This site is located near Vacaville, CA. The data was taken in 2006. It is a well operated 

site with larger windrows. The data set consisted of a total of 12 measurements, which is 

a small number for use in estimating life-cycle emissions. This site had VOC emissions 

that were about four times greater than the CIWMB Modesto report. The average flux 

rate was about eight times higher. 

5.4 CIWMB Tierra Verde

This data was not sufficient to develop a full site emission factor. What it does provide is 

a range of unit flux rates for the various process management strategies tested, including 

carbon/nitrogen ratio and mixing. These average unit flux values, ranging from 6 to 100 

mg/min-m

2

, completely bracket the previous data sets and appear to provide a valid range 

of emission rates for the greenwaste composting process. However, the data are 

insufficient to draw specific conclusions about mixing because there could be high 

emissions from either handling or stockpiling compost from the non-mixed process.

5.5 SCAQMD Data

The SCAQMD data are provided purely for reference. However, it should be noted that 

the windrow emissions are extremely small (5 times lower than CIWMB Modesto) and 

most of the emission factor is from stockpiles. The windrow data is derived from a total 

of four measurements.

5.6 Discussion

Figure 5.1 presents the daily emission profile for VOC for the three sites that had 

complete data. Note that the NorCal emissions are dominated by a severe emissions peak 

that occurred early in the process followed by lower emissions that the other sources 

immediately after the peak.

Table 5.2 presents a summary of the valid data points with the average value shown. 

This does not imply that the average value is representative, is only shown for reference.

Table 5.2 Summary of greenwaste VOC emission factors (#/ton feedstock).

Source Site X CIWMB NorCal Average

Stockpile 7.76 2.95 5.36

Windrow 6.30 1.54 5.65 4.50

Total 14.06 8.60 9.85
12

Figure 5.1 Daily VOC emissions profile from Site X, CIWMB Modesto, and NorCal.

6.0 Most Relevant Food Waste Compost Data

This section presents the data found to be most relevant in characterizing food waste 

emissions in the State of California. Table 6.1 presents a summary of this data in both an 

emission factor and unit emission rate form. The paragraphs below discuss the data 

points in detail.

All the food waste data was taken from the NorCal site near Vacaville, CA. The 

emissions data consists of very comprehensive tests on four food waste composting 

technologies. All the data utilized SCAQMD Method 25.3 and used the current state of 

the art flux chamber techniques at the time of the sampling.

The first technology tested was the use of the AgBag®vessel reactor. This consists of a 

polyethylene bag encapsulated compost windrow that has a small amount of forced air 

(100 – 300 cfm) into it. The bag is vented by small (5 cm dia) port placed every 20 feet 

along the bags length on each side. The compost cycle consists of 30 days in the bag and 

then 30 days of curing out of the bag. During the cure phase, the windrow is mixed every 

three days using the standard Rotoshredder/Scarab windrow mixer.

The second technology used was the Compostex cover technology. This consists of a 

standard windrow that is placed and mixed, then covered with the Compostex®

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1 6 11 16 21 26 31 36 41 46 51 56 61 66 71 76

Compost Process Day

Daily Single Windrow Emissions (#/ton)

Site X

CIWMB Modesto

NorCal
13

polypropylene cover. The cover is very porous, but does supply insulation and some 

water retention.

Table 6.1 Summary of most relevant food waste composting data.

EF EF

Location Technology Activity (#/ton) Peak Avg Min Peak Avg Min (#/ton) Peak Avg Min Peak Avg Min

NorCal AgBag Stockpile 0.42 9 4 0.5 0.12 0.06 0.01 0.02 1.05 0.39 0.03 0.01 0.01 0.000

Windrow 36.7 9,603 1,729 1 119 21.38 0.01 0.7 98.84 13.82 0.01 1.22 0.17 0.000

Total 37.1 0.7

Compostex Stockpile 1.5 31 12 0.33 0.38 0.15 0.00 0.002 0.02 0.01 0.01 0.000 0.000 0.000

Windrow 25.4 899 143 0.4 11.11 1.76 0.01 8.1 173 12 0.01 2.14 0.15 0.000

Total 26.9 8.1

Micropore 30 Stockpile 1.8 27 13 8 0.34 0.17 0.10 0.1 6.48 1.45 0.10 0.08 0.02 0.001

Windrow 9.0 195 32 0.1 2.41 0.39 0.00 14.1 370 21.3 0.00 4.57 0.26 0.000

Total 10.8 14.2

Micropore 45 Stockpile 1.7 27 13 8 0.34 0.17 0.10 0.1 6 1 0.1 0.08 0.02 0.001

Windrow 1.7 622 33 0.1 7.70 0.40 0.00 1.3 56.4 2.87 0.00 0.70 0.04 0.000

Total 3.4 1.4

Unit Flux (mg/minm2)Unit Flux (mg/minm2)

VOC NH3

Unit Flux (#/hr1,000ft2)Unit Flux (#/hr1,000ft2)

The last two technologies were micropore covers. These covers are expanded 

polytetrafluoroethylene (PTFE) membranes encased in a polyester protective covering. 

The pore size of the PTFE membrane is controlled to maximize oxygen transfer while 

minimizing water vapor loss. This pore size is a barrier to most non-methane 

hydrocarbons but not in general to ammonia. The cover provides an opportunity for 

superior process control due to weather protection and moisture control. The covering 

system is substantially more costly than the Compostex®system. For the micropore 

cover system, two cases were evaluated. The first case was for covering the windrow for 

30 days, followed by a 30 day uncovered cure period. The second case was for covering 

the windrow for 45 days, followed by a 15 day cure period. Both cure periods had 

mechanical mixing every three days. While covered, the micropore windrow received 

about 300 cfm of forced air on a 10 minute on/20 minute off cycle.

There is really no baseline/no control data for food waste. All the data consists of some 

level of control technology. The micropore cover system provides the highest level of 

control at the highest cost. From a regulatory standpoint at NorCal, the AgBag 

technology was considered baseline. Note that for food waste, better process control that 

lowers VOC emissions may actually increase ammonia emissions.

7.0 Most Relevant Biosolids Compost Data

This section presents the data found to be most relevant in characterizing biosolids 

composting emissions in the State of California. Table 7.1 presents a summary of this 

data in both an emission factor and unit emission rate form. The paragraphs below 

discuss the data points in detail.
14

Table7.1 Summary of most relevant biosolids composting data.

EF EF

Location Technology Activity (#/ton) Peak Avg Min Peak Avg Min (#/ton) Peak Avg Min Peak Avg Min

Uncovered ASP 3.7 74 15 0.3 0.92 0.46 0.00 4.6 200 27.94 1.56 2.47 1.24 0.019

Micropore ASP 0.2 21 2.9 0.3 0.26 0.13 0.003 1.8 279 17.72 1.40 3.44 1.73 0.02

SKIC ASP/Biofilter Whole Site 0.2 3.0 0.8 0.2 0.04 0.010 0.002 0.1 5 1.81 0.18 0.06 0.02 0.002

Biofilter In 0.8 3.1 0.04 0.7 2.9 0.04

VOC NH3

Unit Flux (#/hr1,000ft2)Unit Flux (#/hr1,000ft2)

LACSD/ 

Cedar 

Grove

SCAQMD 

Las 

Virgenes

Unit Flux (mg/minm2)Unit Flux (mg/minm2)

There were only four biosolids data sets that utilized a VOC test method (SCAQMD 

25.1/25.3) that would provide meaningful regulatory data for SJVAPCD. All biosolids 

composting utilizes some bulking agent or amendment that is almost always greenwaste. 

So essentially almost all biosolids composting is co-composting with greenwaste.

Three data sets do not really represent baseline/uncontrolled emissions. The Cedar Grove 

data set utilized an under-the-cover measurement to establish control efficiency for a 

micropore cover system. The micropore cover does influence the entire compost process 

so even the under the cover measurement is likely lower in emissions than an uncovered 

pile or windrow. The Las Virgenes data is from a compost structure, so it represents the 

uncontrolled emissions from composting in a building, not outdoor composting.

The SKIC data set is from a compliance test at the South Kern Industrial Complex near 

Bakersfield. The facility was a very large aerated static pile (ASP) facility that had 

induced air flow controlled by biofilters.

The Cedar Grove data is from the test of a micropore cover for Los Angeles County 

Sanitation District’s biosolids from the Joint Water Pollution Control Plant in Carson, 

CA. The actual test occurred in Everett, Washington at a facility that was designed to 

compost greenwaste under micropore covers. As mentioned earlier, under the cover 

measurements were utilized to estimate cover control efficiency. However, it is unlikely 

that an uncovered system would perform even as well as the under the cover micropore 

system. This is because the micropore system offers many process control advantages 

including weather protection and water retention.

8.0 References

Hentz Jr, L. H., W. E. Toffey, and C. E. Schmidt. 1996. Understanding the Synergy 

Between Composting and Air Emissions. BioCycle. 37(3):67-75.
Appendix A

SJVAPCD Literature Table

and

Individual Report Summaries
TECHNICAL MEMORANDUM

Date: May 9 2008

To: SJAQMD Staff

From: CE Schmidt

RE: Annotated Bibliography in Support of the SJVAPCD Greenwaste Baseline 

Composting Document

The core documents collected and reviewed by the SJVAPCD staff supporting the 

baseline document preparation as foundational to the proposed Rule 4566 have been 

reviewed with a focus on: project objective, sample collection technology, analytical 

methodology, and representativeness of the reported and tabulated flux or emission rate 

data. Each of the research reports has been reviewed, and an annotated bibliography has 

been prepared, and is contained herein. 

The purpose of this effort was to provide council to the SJVAPCD staff with regard to 

using the available information regarding the compost industry in rule making. A 

companion document has been prepared in a similar vein with regard to the flux data use 

in these documents, emission calculation algorithm and assumptions used in the process, 

and the overall usability of the emission rate data. These two documents, constitutes the 

contracted support to the SJVAPCD staff for the purpose of rule making.

The annotated bibliographies are provided as an attachment to this memorandum.

Note that three studies have been added to the reference list for your review.

CE Schmidt
SUMMARY OF ANNOTATED BIBLIOGRAPHY ATTACHMENTS

SITE: Cedar Grove Composting, Everett, WA; 

TITLE: “Full Scale Evaluation of Gore Technology On LACSD Biosolids at Cedar 

Grove Composting, Everett, WA”

SITE: Inland Composting and Organic Recycling Facility, Colton, CA; City of LA 

Anchorage Green Material Facility, San Pedro, CA; City of LA Van Norman Green 

Material Mulching Facility, San Fernando Valley, CA, and Scholl Canyon Landfill Site 

(alternative daily cover application)

TITLE: “Air Emissions Tests Conducted at Green Material Processing Facilities”

SITE: Jepson Prairie Organics Compost Facility, Vacaville, CA

TITLE: “Air Emissions Source Test- Emissions Evaluation of Complete Compost 

Cycle VOC and Ammonia Emissions”

SITE: City of Modesto Compost Facility, Modesto, CA

TITLE: “Emissions Testing of Volatile Organic Compounds from Greenwaste 

Composting at the Modesto Compost Facility in the San Joaquin Valley”

SITE: Inland Empire Composting, Colton, CA

TITLE: “Ammonia and Volatile Organic Compound (VOC) Emissions From A 

Greenwaste Composting Facility ”

SITE: Westlake Farms Co-Composting Facility, Stratford, CA

TITLE: “Assessment of Volatile Organic Compound and Ammonia Emissions from a 

Bulking Agent Stockpile”

SITE: Intravia Rock and Sand, Inc. Upland, CA

TITLE: “Ammonia and Volatile Organic Compound (VOC) Emissions From A NonCurbside Greenwaste Chipping and Grinding Facility ”

SITE: Rancho Las Virgenes Municipal Water District, Calabasas, CA

TITLE: “Characterization of Ammonia, Total Amine, Organic Sulfur Compound, and 

Total Non-Methane Organic Compound Emissions from Composting Operations ”

SITE: Little Hanaford Farms, Centralaia, WA

TITLE: “Technical Support Document Little Hanaford Farms”

SITE: EKO Systems, Corona, CA

TITLE: “Characterization of Ammonia, Total Amine, Organic Sulfur Compound, and 

Total Non-Methane Organic Compound (TGNMOC) Emissions From Composting 

Operations ”
SITE: San Joaquin Composting, Inc, Lost Hills, CA

TITLE: “Characterization of Ammonia, Total Amine, Organic Sulfur Compound, and 

Total Non-Methane Organic Compound (TGNMOC) Emissions From Composting 

Operations ”

SITE: Tierra Verde Industries, Irvine, CA

TITLE: “Technical Report- Best Management Practices for Greenwaste Composting 

Operations: Air Emissions Tests vs. Feedstock Controls and Aeration Techniques”

SITE: Jepson Prairie Organics Compost Facility, Vacaville, CA

TITLE: “Jepson Prairie Organics Facility Compostex Cover System- Air Emissions 

Report”

SITE: Jepson Prairie Organics Compost Facility, Vacaville, CA

TITLE: “Jepson Prairie Organics Facility Micropore Cover System- Air Emissions 

Report”

SITE: South Kern Industrial Complex (SKIC) LLC, Taft, CA

TITLE: “SKIC Air Emissions Compliance Report”
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Biosolids

SITE: Cedar Grove Composting, Everett, WA

PAPER TITLE: “Full Scale Evaluation of Gore Technology On LACSD Biosolids at 

Cedar Grove Composting, Everett, WA”

AUTHORS: Tom Card, CE Schmidt

DATE: August, 2007 (testing conducted 01/07 to 03/07)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia emissions for biosolids composting using the Gore 

micropore/ASP cover system, and to determine the control efficiency for the cover 

system.

FACILITY OPERATIONS:

Cedar Grove composting utilizes a three-phase compost operation with a 28 day active 

phase (covered), a 13 day maturation phase (covered ) and a 14 day cure phase 

(uncovered). 

TARGET SPECIES:

Methane, ethane, CO2, CO, Total non-methane organic carbon (condensable and 

volatile), and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, tracer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD Method 207.1, and USEPA Method TO-14/GC-ECD 

for the tracer SF6.

SCOPE OF WORK:

Over 100 flux measurements conducted over a 43-day time period. Test locations were 

selected to represent side and top of pile with test locations, and top and side under the 

cover test locations. Testing was conducted on head space under the cover, from flux 

chambers under the cover, on the cover (top and side locations), during phase transitions 

and mixed compost, on cover seams, and repeat testing on different portions of the 

covered compost.,

Phase 1, Day 2- three flux tests on cover per round per day, two rounds, two buried flux

Phase 1, Day 4- Same, plus full replicate tests
Phase 1, Day 7- Same

Phase1, Day 14- Same

Phase 1,Day 28- Same

Transition P1/P2- breakdown compost, mixed compost, covered compost tests; multiple

Phase 2, Day 1- Same as covered

Phase 2, Day 13- Same as covered

Phase 3, Day 1- Same as covered

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank, replicate, and repeat samples are reported.

QC data indicated overall acceptable method performance.

FINDINGS:

Biosolids Uncontrolled test pile)- 1.8 #VOC/ton and 4.0 #NH3/ton

Fugitive Emissions with Gore Cover- 0.2 #VOC/ton and 1.8 #NH3/ton

Note- Uncontrolled emissions, as well as the control efficiency estimate reference 

measurements taken from two flux chambers under the cover during the life-cycle testing 

effort.

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, with the 

exception that recent SCAQMD Modified USEPA flux chamber techniques were not 

used (redesigned sweep air inlet system and stack testing in extended stack), although the 

flow rates were probably low enough so that the sample collection technique was not 

biased. 

COMMENTS:

Climatic conditions may have influenced the composting operations, in particular the 

beginning of the cycle. The LACSCD biosolids arrived in a semi-frozen state, and this 

may have hampered complete mixing of the biosolids with bulking agent, and delayed the 

starting of the composting process. The cool winter weather with light precipitation for 

the area probably had little effect on the composting operations. The testing effort was 

not hampered by the weather.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Greenwaste 

SITE: Inland Composting and Organic Recycling Facility, Colton, CA; City of LA 

Anchorage Green Material Facility, San Pedro, CA; City of LA Van Norman Green 

Material Mulching Facility, San Fernando Valley, CA, and Scholl Canyon Landfill Site 

(alternative daily cover application)

PAPER TITLE: “Air Emissions Tests Conducted at Green Material Processing 

Facilities”

AUTHORS: CIWMB Brenda Smyth, CE Schmidt

DATE: February 22, 2002 (testing conducted 12/03/01, 12/06/01, and 12/07/01)

PROJECT OBJECTIVE: 

Evaluate baseline VOC and ammonia emissions for greenwaste composting operations in 

the SCAQMD.

FACILITY OPERATIONS:

All three compost facilities receive, grind, static pile compost, and screen product in 

similar fashion. The landfill uses greenwaste mulch as alternative daily cover.

TARGET SPECIES:

Methane, ethane, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile), and ammonia.

SAMPLE COLLECTION METHODS:

USEPA surface emission isolation flux chamber, standard chamber. Side-by-side open 

path optical remote sensing by SCAQMD at the Inland Empire 

ANALYTICAL METHODS:

NMAM 6015 for ammonia, EPA Method 25C for methane and TNMHC, Method TO-15 

for VOC species, and SCQAMD Method 25.3 for condensable and non-condensable 

organic compounds (by SCAQMD Lab).

SCOPE OF WORK:

Inland Composting and Organics Recycling Facility

14 Flux chamber tests: raw greenwaste, Day 17 compost, Day 45 compost, Day 90 overs 

material, screened product fines.

Anchorage Facility

18 Flux chamber tests: Day 1 compost, Day 3 compost, and Day 7 compost, Day 14 

compost, Day 28 compost, Day 80 compost, Day 90 overs. 
Van Norman Facility

24 Flux chamber tests: Day 1 compost, Day 3 compost, Day 5 compost (raw, coarse 

mulch, fine mulch, superfine mulch)

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank samples reported; no replicate samples.

QC data indicated overall acceptable method performance.

FINDINGS:

Greenwaste- 0.186 #VOC/hr-1000ft2 and 0.002 #NH3/hr-1,000ft2 (mean values for the 

collective data set). 

Note- The frequency of testing is limited in that there are many different area sources in a 

compost cycle and life cycle emission estimates must include operational considerations, 

spatial variability, and time-dependent emissions per source. 54 data points collected at 

three different facilities does not constitute a robust program. 

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, with the 

exception that recent SCAQMD Modified USEPA flux chamber techniques were not 

used (redesigned sweep air inlet system and stack testing in extended stack), although the 

flow rates were probably low enough so that the sample collection technique was not 

biased. The use of the flux data, estimate of surface area, and representativeness of the 

emissions estimate should be reviewed.

COMMENTS:

The results of these test show much lower ammonia emissions and lower VOC emissions 

from facilities located in the SCAQMD area compared the SCAQMD published values of 

0.224 #VOC/hr-1,000ft2 and 0.091 #NH3/hr-1,000ft2 from the Inland Empire site. This 

is suggested to be related to the difference in seasonal flux and the analytical methods: 

higher emissions in the summer and more compound detection with SCAQMD Method 

25.3 as compared to Method 25C. 
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Food Waste with Ag Bag Cover and Greenwaste

SITE: Jepson Prairie Organics Compost Facility, Vacaville, CA

PAPER TITLE: “Air Emissions Source Test- Emissions Evaluation of Complete 

Compost Cycle VOC and Ammonia Emissions”

AUTHORS: Tom Card, CE Schmidt

DATE: May, 2006 (testing conducted 08/23/05 to 08/25/05)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia site wide baseline emissions for food waste composting 

using the Ag Bag cover system and the static greenwaste windrow compost system.

FACILITY OPERATIONS:

Jepson Prairie Organics Compost facility utilizes a two-phase compost operation with a 

30-day active phase (food waste in the Ag Bag, covered) and ASP system, and a 30 day 

cure phase (uncovered). 

TARGET SPECIES:

Methane, ethane, CO2, CO, Total non-methane organic carbon (condensable and 

volatile), and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, tracer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD Method 207.1, and USEPA Method TO-14/GC-ECD 

for the tracer SF6.

SCOPE OF WORK:

Over 46 flux measurements conducted over a 3-day time period. Test locations were 

selected to represent Ag Bag ports, and the side and top of curing or greenwaste piles. 

Receiving and finish was also tested.

Food Waste/Ag Bag

Phase 1 Compost, Day 1- Two flux tests on bag ports

Phase 1, Compost, Day 4- Same

Phase 1, Compost, Day 5- Same

Phase 1, Compost, Day 8- Same

Phase 1, Compost, Day 10- Same
Phase 1, Compost, Day 22- Same

Phase 1, Compost, Day 30- Same

Phase 2, Cure, Day 0 unmixed, one flux test

Phase 2, Cure, Day 3, unmixed and mixed- three flux tests

Phase 2, Cure, Day 7- unmixed, one flux test

Phase 2, Cure, Day 10, unmixed and mixed- two flux tests

Phase 2, Cure, Day 13- one flux test

Phase 2, Cure, Day 19, unmixed and mixed- two flux tests

Phase 2, Cure, Day 25- one flux test

Phase 2, Cure, Day 31, unmixed and mixed- two flux tests

Finish- three flux tests

Greenwaste Static Pile

Phase 1, Compost, Day 3- one flux test

Phase 1, Compost, Day 6- Same

Phase 1, Compost, Day 7- three flux tests

Phase 1, Compost, Day 15- one flux test

Phase 1, Compost, Day 30- Same

Phase 2, Cure, Day 50 unmixed, one flux test

Finish- three flux tests

Phase 3, Day 1- Same as covered

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank, replicate, and repeat samples are reported.

QC data indicated overall acceptable method performance.

FINDINGS:

Food Waste in Ag Bag- 37 #VOC/ton and 0.7 #NH3/ton

Static Pile Greenwaste Composting- 14 #VOC/ton and 0.5 #NH3/ton

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, with the 

exception that recent SCAQMD Modified USEPA flux chamber techniques were not 

used (redesigned sweep air inlet system and stack testing in extended stack), although the 

flow rates were probably low enough so that the sample collection technique was not 

biased. 

COMMENTS:

The Ag Bag showed very low emissions during the in-vessel phase with little emissions 

from the open ports and little effect by the blower fans. Most of the emissions occurred 

during the curing phase. The greenwaste static pile was occasionally watered and mixed.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Greenwaste and Greenwaste with Food Waste

SITE: City of Modesto Compost Facility, Modesto, CA

PAPER TITLE: “Emissions Testing of Volatile Organic Compounds from 

Greenwaste Composting at the Modesto Compost Facility in the San Joaquin Valley”

AUTHORS: Brenda Smyth, Fatih Buksonamez, CE Schmidt

DATE: October 31, 2007 (testing conducted 10/19/06 to 12/14/06)

PROJECT OBJECTIVE: 

Evaluate baseline VOC emissions during greenwaste composting and greenwaste that 

includes food waste, and to assess VOC emissions reduction potential of Best 

Management Practices (BMP) including application of a finished compost blanket on top 

of the greenwaste windrow and application of two chemical additives to greenwaste 

windrow.

FACILITY OPERATIONS:

City of Modesto- 250 to 300 tons of greenwaste per day, some paper and residential food 

waste; 30 acre site with maximum 500 tons per day capacity. Greenwaste source is 

residential, landscape business, and municipal pruning. The process is static composting 

in windrows: greenwaste is tipped on a concrete pad, processed in a grinder, shaped in 

windrows, and mixed by Scarab-type turner approx. once per week with infrequent 

watering.

TARGET SPECIES:

Methane, ethane, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile) with CO used as a tracer species.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, tracer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3.

SCOPE OF WORK:

Over 100 flux measurements conducted over a 57-day time period. Test locations were 

selected to represent bottom, middle and top of pile with test locations selected by real 

time instrument data.

Greenwaste (control test pile)
Day 1- Three-to-four flux tests per pile per day

Day 2- Same

Day 3- Same

Day 6- Same

Day 8- Same

Day 14- Same

Day 21- Same

Day 30- Same

Day 44- Same

Day 57- Same

Greenwaste with 15% food waste- Same

Greenwaste capped with finished compost blanket- Same

Greenwaste inoculated with two chemical additives- Same

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank samples reported; no replicate samples.

QC data indicated overall acceptable method performance.

FINDINGS:

Greenwaste (control test pile)- 0.8 to 0.9 #VOC/ton

Greenwaste with 15% food waste- 1.3 to 2.6 #VOC/ton

Greenwaste capped with finished compost blanket- 0.1 to 0.4 #VOC/ton

Greenwaste inoculated with two chemical additives- 0.5 to 0.6 #VOC/ton

Note- surface area of vented sources estimated at 10% for all piles except biofilter finishcovered pile, which was estimated by screening to be 1% to 2%. Fall season and frequent 

site watering my have influenced the flux data.

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, with the 

exception that recent SCAQMD Modified USEPA flux chamber techniques were not 

used (redesigned sweep air inlet system and stack testing in extended stack), although the 

flow rates were probably low enough so that the sample collection technique was not 

biased. The use of the flux data, estimate of surface area, and representativeness of the 

emissions estimate should be reviewed.

COMMENTS:

None.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Greenwaste

SITE: Inland Empire Composting, Colton, CA

PAPER TITLE: “Ammonia and Volatile Organic Compound (VOC) Emissions From 

A Greenwaste Composting Facility ”

AUTHORS: SCAQMD, Wayne Stredwick

DATE: Testing conducted 09/27/01 and 10/04/01)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia emissions during greenwaste composting including: tipping 

pile, static piles, and windrows. 

FACILITY OPERATIONS:

The site processes 350 tons of greenwaste per day. The waste is received and stored up 

to two days, stored in a static pile after grinding for up to 14 days, placed in windrow for 

up to 45 days and screened. The process is static composting in windrows: greenwaste is 

tipped on a concrete pad, processed in a grinder, shaped in windrows, and mixed by 

Scarab-type turner approx. once per week with infrequent watering.

TARGET SPECIES:

Methane, ethane, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile) with helium used as a tracer species and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer) USEPA surface emission isolation flux 

chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3 and SCAQMD Method 207.1.

SCOPE OF WORK:

Over 30 flux measurements conducted over a two-day time period. 

Tipping pile- 10 tests; 0-2 day old tested.

Static piles- 10 tests; 7 day old tested.

Windrow- 10 tests; day 7 and day 30 tested.

QC DATA:

It is not known if a work plan was prepared or is available.
Blank samples and replicate sample data were not reported or commented on, with the 

exception of problems encountered. Note that all 25.3 samples were taken in duplicate as 

per the method.

FINDINGS:

Ammonia Methane TNMNEOC 

(lb/hr-1000ft2) (lb/hr-1000ft2) (lb/hr-1000ft2)

Tipping Pile 0.091 0.079 0.368

Static, Fines and ADC 

Pile

0.071 0.024 0.226

Windrow 0.004 0.005 0.079

Site Total (lb/ton) 1.32 #/ton 0.83 #/ton 5.05 #/ton

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed including the 

SCAQMD Modified USEPA flux chamber technique. No discussion was provided about 

specific surface area testing, designation of sub area per type of source, and no QC data 

was provided. The use of the flux data, estimate of surface area, and representativeness 

of the emissions estimate should be reviewed.

COMMENTS:

None.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Bulking Agent Stockpile

SITE: Westlake Farms Co-Composting Facility, Stratford, CA

PAPER TITLE: “Assessment of Volatile Organic Compound and Ammonia 

Emissions from a Bulking Agent Stockpile”

AUTHORS: LACSD, CH2MHill, Tom Card, CE Schmidt

DATE: April 27, 2005 (testing conducted 03/24/ 2005)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia emissions for the Westlake Farms Co-Composting site 

bulking agent, shredded almond wood waste (orchard waste).

FACILITY OPERATIONS:

The Westlake Farms Co-Composting facility ATC includes utilizing orchard waste as a 

bulking agent for a negative ASP/biofilter biosolids composting operation. The 

emissions from the bulking agent are part of the site emissions estimate.

TARGET SPECIES:

Methane, ethane, CO2, CO, Total non-methane organic carbon (condensable and 

volatile), ammonia, and total hydrocarbon species.

SAMPLE COLLECTION METHODS:

USEPA surface emission isolation flux chamber (standard chamber design- no significant 

advective flow from the source) and tracer recovery (CO).

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD Method 207.1, and USEPA Method TO-12. Real 

time instrument data was used to select sample collection from test locations (FID/PID) 

and CO tracer recovery.

SCOPE OF WORK:

Eight flux measurements were conducted over a 1-day time period, where four of the 

eight locations were selected for sample collection by Methods 25.3 and 207.1. All 

screening data was similar, and based on field screening data the two highest flux and the 

two lowest flux locations were selected for testing.

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank, replicate, and repeat samples are reported.
QC data indicated overall acceptable method performance.

FINDINGS:

Static Pile Flux- 0.00000073 #VOC/hr,ft-1 and 0.0000000079 #NH3/hr,ft-1

Advective flow was calibrated based on a field test that generated recovery of CO tracer 

(36%) from a thin layer of wood chips divorced from the static pile (not composting).

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed. The 

SCAQMD Modified USEPA flux chamber techniques were not used given that advective 

flow was not anticipated. All data were at or below MDL for the methods and the 

emissions could potentially overestimate the emissions from the source based on 

demonstrated adsorption of the CO tracer species. The non-detect TO-14 results 

supported the very low/non-detect Method 25.3 results.

COMMENTS:

The flux from the orchard waste showed very low VOC and even lower ammonia 

emissions.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Greenwaste

SITE: Intravia Rock and Sand, Inc. Upland, CA

PAPER TITLE: “Ammonia and Volatile Organic Compound (VOC) Emissions From 

A Non-Curbside Greenwaste Chipping and Grinding Facility ”

AUTHORS: SCAQMD, Mei Wang

DATE: Testing conducted 07/12/02)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia emissions during greenwaste composting including: tipping 

pile, static piles, and windrows. 

FACILITY OPERATIONS:

The site receives non-curbside greenwaste, stores the wastes, grinds the waste, and ships 

the waste off site. Composting is not conducted on site. The material stays on site for 

about 30 days. Little information was available regarding the site operations.

TARGET SPECIES:

Methane, ethane, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile) with helium used as a tracer species and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer) USEPA surface emission isolation flux 

chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3 and SCAQMD Method 207.1.

SCOPE OF WORK:

Over 20 flux measurements conducted over a one-day time period. 

Tipping pile- 10 tests.

Ground material pile- 10 tests.

QC DATA:

It is not known if a work plan was prepared or is available.

Blank samples and replicate sample data were not reported or commented on. Note that 

all 25.3 samples were taken in duplicate as per the method.

FINDINGS:
Ammonia Methane TNMNEOC 

(lb/hr-1000ft2) (lb/hr-1000ft2) (lb/hr-1000ft2)

Tipping Pile 0.0030 0.0029 0.228

Ground Piles 0.0006 0.0097 0.153

Site Total (lb/ton) 0.017 #/ton 0.058 #/ton 1.5 #/ton

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed including the 

SCAQMD Modified USEPA flux chamber technique. No discussion was provided about 

specific surface area testing, designation of sub area per type of source, and no QC data 

was provided. The use of the flux data, estimate of surface area, and representativeness 

of the emissions estimate should be reviewed.

COMMENTS:

None.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Biosolids Bulked with Wood Chips

SITE: Rancho Las Virgenes Municipal Water District, Calabasas, CA

PAPER TITLE: “Characterization of Ammonia, Total Amine, Organic Sulfur 

Compound, and Total Non-Methane Organic Compound Emissions from Composting 

Operations ”

AUTHORS: SCAQMD, Carey Willoughby

DATE: Testing conducted 12/19/95 and 12/20/95)

PROJECT OBJECTIVE: 

Verify the flux chamber sampling method for assessing emission from compost 

operations, and evaluate air emissions from the biosolids compost operations. 

Method verification was accomplished by flux testing on the compost in an enclosed 

building, then comparing those emissions to the mass loading on the biofilter inlet line 

from the enclosure.

FACILITY OPERATIONS:

The site receives dewatered biosolids, mixes the biosolid waste with wood chips, 

constructs windrows on subsurface vents in an enclosure structure, supplies positive air 

flow to the piles for 45 days, and collects the enclosure air and runs the air through a 

biofiltration system. 

TARGET SPECIES:

Methane, Total non-methane organic carbon (condensable and volatile) with helium used 

as a tracer species and ammonia, CO2, O2, amines, and organic sulfur compounds.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer) USEPA surface emission isolation flux 

chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.1, SCAQMD Method 207.1, and non-specified methods for total 

amines and organic sulfur.

SCOPE OF WORK:

Over 34 flux measurements conducted over a two-day time period. 

Flux chamber testing on compost windrows in one cell or area, 17 locations per day, two 

days.

Simultaneous biofilter (replicate) inlet testing for the facility. 
QC DATA:

It is not known if a work plan was prepared or is available.

Blank samples and replicate sample data were not reported or commented on. 

FINDINGS:

Source Ammonia Methane TNMOC CS

(lb/hr-1000ft2) (lb/hr-1000ft2) (lb/hr-1000ft2) (lb/hr-1000ft2)

Inlet Sampling 0.036 0.025 0.038 0.038

Flux Chamber 

on Compost

0.012 NA NA NA

Site Total 

(lb/ton)

0.70 #/ton 0.50 #/ton 0.76 #/ton 0.69

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed including the 

SCAQMD Modified USEPA flux chamber technique. No discussion was provided about 

specific surface area testing, designation of sub area per type of source, and no QC data 

was provided. The use of the flux data, estimate of surface area, and representativeness 

of the emissions estimate should be reviewed.

The conclusion from the technical team indicated that the USEPA flux chamber method, 

for a variety of reasons, was „the preferred method‟ for estimating and comparing 

emissions from compost sites.

COMMENTS:

None.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Waste material- not specified

SITE: Little Hanaford Farms, Centralaia, WA

PAPER TITLE: “Technical Support Document Little Hanaford Farms”

AUTHORS: Clint Lamoreaux, Southwest Clean Air Agency

DATE: April, 2005 (testing conducted 08/04)

PROJECT OBJECTIVE: 

Comply with permit requirements.

FACILITY OPERATIONS:

75,000 Ton per year static pile windrow composting operation that receives solid waste 

of unspecified type and origin and produces compost and soil amendments.

TARGET SPECIES:

Eight amines plus ammonia, two sulfur compounds, and eight oxygenated compounds are 

listed. No total VOC.

SAMPLE COLLECTION METHODS:

None specified.

ANALYTICAL METHODS:

None specified.

SCOPE OF WORK:

None provided. Emission rate data provided as final number for amines, two sulfur 

compounds, ammonia, and a short list of oxygenated compounds. Sample collection 

technique not specified. Sample count and sampling strategy not specified. Analytical 

method not specified.

QC DATA:

None provided.

FINDINGS:

VOC Emissions factor- 0.10 #VOC/ton and 0.062#NH3/ton

Note- No method information, scope of work or test data was provided. These findings 

provide no useful information. Discount this reference.
CONCLUSIONS:

No useful information is provided. Discount this reference.

COMMENTS:

You have to be kidding me!
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Biosolids (20%) and Manure (80%)

SITE: EKO Systems, Corona, CA

PAPER TITLE: “Characterization of Ammonia, Total Amine, Organic Sulfur 

Compound, and Total Non-Methane Organic Compound (TGNMOC) Emissions From 

Composting Operations ”

AUTHORS: SCAQMD, Carey Willoughby

DATE: Testing conducted 11/16/95, 01/24, and 01/26/96

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia emissions during greenwaste composting by testing three 

different ages of compost; Day 2, Day 20 and Day 50. Based in temperature, the peak 

emission was expected on Day 20. 

FACILITY OPERATIONS:

The site receives biosolids and manure and produces compost by static pile windrow (50 

day compost cycle) and a non-specified curing phase in larger piles. No mention was 

made regarding bulking agent, although it is likely that bedding or fiber was present in 

the manure.

TARGET SPECIES:

Methane, O2, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile) with helium used as a tracer species, total sulfur compounds, ammonia and 

amines.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer, mixing fan) USEPA surface emission 

isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.1, Amines, Sulfur Compounds, and SCAQMD Method 207.1.

SCOPE OF WORK:

Nine sampling points per source (Day 2, 20, 50) prior to turning and five sampling points 

post turning per source. Note- number of samples is not specified, and the SCAQMD 

often collects composite samples. It is possible that only six composite samples were 

collected per these 42 flux tests (9 x 3 plus 5 x 3).
QC DATA:

It is not known if a work plan was prepared or is available.

Blank samples and replicate sample data were not reported or commented on. Note that 

all 25.3 samples were taken in duplicate as per the method.

FINDINGS:

Compounds Emission Factor

(lb/ton)

Ammonia 3.28

Amines <0.0003

Methane 2.23

TGNMOC 1.7

Total Sulfur Compounds 0.015

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed including the 

SCAQMD Modified USEPA flux chamber technique. No discussion was provided about 

specific surface area testing, designation of sub area per type of source, and no QC data 

was provided. The use of the flux data, estimate of surface area, and representativeness 

of the emissions estimate should be reviewed.

COMMENTS:

None.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Biosolids (50%) and Greenwaste (50%)

SITE: San Joaquin Composting, Inc, Lost Hills, CA

PAPER TITLE: “Characterization of Ammonia, Total Amine, Organic Sulfur 

Compound, and Total Non-Methane Organic Compound (TGNMOC) Emissions From 

Composting Operations ”

AUTHORS: SCAQMD, Carey Willoughby

DATE: Testing conducted 02/15/96, 03/01/96, and 03/11/96

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia emissions during greenwaste composting by testing three 

different ages of compost; Day3, Day 45 and Day 57. Based in temperature, the peak 

emission was expected on Day 45. 

FACILITY OPERATIONS:

The site receives biosolids and manure and produces compost by static pile windrow (50 

day compost cycle) and a non-specified curing phase in larger piles. No mention was 

made regarding bulking agent, although it is likely that bedding or fiber was present in 

the manure.

TARGET SPECIES:

Methane, O2, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile) with helium used as a tracer species, total sulfur compounds, ammonia and 

amines.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer, mixing fan) USEPA surface emission 

isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.1, Amines, Sulfur Compounds, and SCAQMD Method 207.1.

SCOPE OF WORK:

Nine sampling points per source (Day 3, 45, 57) prior to turning and five sampling points 

post turning per source. Note- number of samples is not specified, and the SCAQMD 

often collects composite samples. It is possible that only six composite samples were 

collected per these 42 flux tests (9 x 3 plus 5 x 3). These locations were screened with an 

FID and these field data may have been used to select locations for sample collection, 

either composite or discrete samples.
QC DATA:

It is not known if a work plan was prepared or is available.

Blank samples and replicate sample data were not reported or commented on. 

FINDINGS:

Compounds Emission Factor

(lb/ton)

Ammonia 2.81

Amines 0.19

Methane 33.49

TGNMOC 3.1

Total Sulfur Compounds 0.22

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed including the 

SCAQMD Modified USEPA flux chamber technique. No discussion was provided about 

specific surface area testing, designation of sub area per type of source, and no QC data 

was provided. The use of the flux data, estimate of surface area, and representativeness 

of the emissions estimate should be reviewed.

COMMENTS:

The compost site had experienced heavy rain prior the Day 3 testing resulting in higher 

emissions as per the authors. The greenwaste stockpile combusted during the 03/11/96 

testing event.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Greenwaste Engineering Evaluation (Not Life 

Cycle)

SITE: Tierra Verde Industries, Irvine, CA

PAPER TITLE: “Technical Report- Best Management Practices for Greenwaste 

Composting Operations: Air Emissions Tests vs. Feedstock Controls and Aeration 

Techniques”

AUTHORS: Brenda Smyth, CE Schmidt

DATE: July 29, 2003 (testing conducted 10/29-30/02, 11/06-07/02, and 02/04-05/03)

PROJECT OBJECTIVE: 

Evaluate baseline air emissions from feedstock blends (C:N) and aeration techniques and 

to determine how changing these variables affects air emissions from the compost.

FACILITY OPERATIONS:

Engineering evaluations were performed on four, custom-made windrow piles. Two 

piles were made with higher C:N and two with lower C:N. One of each type of blends 

were mechanically aerated while the others were not mixed at all. The resulting matrix 

was as follows: low C:N aerated and low C:N non-aerated; and high C:N aerated and 

high C:N non-aerated. Aeration was facilitated by turning three times per week. Of the 

100 day cycle, testing was conduced on Day 3 and 4, and Day 11 and 12, and Day 101 

and 102.

TARGET SPECIES:

Methane, ethane, CO2, CO, and Total non-methane organic carbon (condensable and 

volatile) with CO used as a tracer species.

SAMPLE COLLECTION METHODS:

Standard USEPA Flux Chamber (bottom and sides) and SCAQMD Modified (6” port, 

CO tracer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD 207.1, and ASTM Odor.

SCOPE OF WORK:

52 Flux measurements conducted over a 103-day time period. Test locations were 

selected to represent bottom, middle and top of pile with the top test location typically 

replicated. 
QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank samples and replicate samples reported in Tech Memo. QC 

data indicated overall acceptable method performance.

FINDINGS:

Ammonia emissions were generally below method detection limit.

VOC emissions by Method 25.3:

Test Pile #VOC per day/ton

Static, Low C:N 0.055

Turned, Low C:N 0.848

Static, High C:N 0.038

Turned, High C:N 0.240

Total 0.247

CONCLUSIONS:

VOC emissions decreased with increasing C:N. Higher VOC emissions were observed 

for turned versus non-turned piles. VOC emissions peaked during the first week. It was 

not possible to determine if static verses turned piles were higher or lower VOC emitters. 

Life cycle for turned compost is shorter that static compost. 

COMMENTS:

The engineering evaluation of C:N ratio and aeration provide useful operational 

information, but life-cycle emission factor data is difficult to extract from these data.

Note that only one 6” diameter exhaust port chamber was used (top location) and a 

standard chamber was used for the middle and bottom-side locations. Although a tracer 

gas was used (CO), a bias in sampling could have resulted from back pressure in the 

standard chamber as related to advective flow.
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Food Waste with Compostex Cover 

SITE: Jepson Prairie Organics Compost Facility, Vacaville, CA

PAPER TITLE: “Jepson Prairie Organics Facility Compostex Cover System- Air 

Emissions Report”

AUTHORS: Tom Card, CE Schmidt

DATE: April 2008, (testing conducted 02/05-07/08)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia site wide baseline emissions for food waste composting 

using the Compostex Cover System.

FACILITY OPERATIONS:

Jepson Prairie Organics Compost facility utilizes the Compostex cover system. The 

compost operation includes food waste grinding, mixing with a greenwaste bulking 

agent, a 45-day active compost phase (food waste covered) and a cure phase (uncovered). 

TARGET SPECIES:

Methane, ethane, CO2, CO, Total non-methane organic carbon (condensable and 

volatile), and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer with modified air introduction system 

and stack testing approach and mixer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD Method 207.1, and USEPA Method TO-14/GC-ECD 

for the tracer SF6 (verification on tracer study).

SCOPE OF WORK:

Over 71 flux measurements conducted over a 3-day time period. Test locations were 

selected to represent the life-cycle emissions from the operations including uncovering, 

mixing, and time-dependent emissions post mixing. Receiving and finish was also tested.

Feedstock as received and aged 2 Flux tests- fresh and 24 hours old

Compost Day 1, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 3, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 7, covered 4 Flux tests, (T1, T2, S1, S2)
Variability Test, Day 7 4 Flux tests, (T1, T2, S1, S2)

Compost Day 15, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 28, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 28, uncovered and unmixed 4 Flux tests, (T1, T2, S1, S2)

Compost Day 28, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1, T1, S1)

Curing Day 45, uncovered and unmixed 4 Flux tests, (T1, T2, S1, S2)

Variability Test, Day 45 4 Flux tests, (T1, T2, S1, S2)

Curing Day 55, uncovered and unmixed 4 Flux tests, (T1, T2, S1, S2)

Curing Day 55, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1, T1, S1)

Finish Product- post screening 4 Flux tests- 2 fresh, 2 aged

Blank testing 9 Flux tests

Replicate testing 8 Flux tests________________

TOTAL 71 Flux tests

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank, replicate, and repeat samples are reported.

QC data indicated overall acceptable method performance.

FINDINGS:

Food Waste with Compostex- 27 #VOC/ton and 8.1 #NH3/ton

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, including 

the recent, validated modifications to the SCAQMD Rule 1133 recommended procedure 

(6” port, 10% helium tracer). The modifications included the redesigned sweep air inlet 

system and stack testing in extended stack, backup tracer, and internal mixer. Data was 

collected without an adverse affect from high winds. 

COMMENTS:

The Compostex cover system showed a reduced air emissions for VOC (27 #VOC/ton 

versus 37 #VOC/ton) as compared to the historic Ag Bag compost system, but higher 

ammonia emissions (8.1 #NH3/ton versus 1.0 #NH#/ton). The robust assessment 

produced representative life-cycle emissions from the Compostex cover system on food 

waste at this site. 
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Food Waste with Compostex Cover 

SITE: Jepson Prairie Organics Compost Facility, Vacaville, CA

PAPER TITLE: “Jepson Prairie Organics Facility Micropore Cover System- Air 

Emissions Report”

AUTHORS: Tom Card, CE Schmidt

DATE: April 2008, (testing conducted 01/17/08 – 02/15/08)

PROJECT OBJECTIVE: 

Evaluate VOC and ammonia site wide baseline emissions for food waste composting 

using the Micropore Cover System; 30 day and 45 day covered operations

FACILITY OPERATIONS:

Jepson Prairie Organics Compost facility typically utilizes the Compostex cover system, 

and a test was conducted using micropore fabric with forced air (Mor and GE covers). 

The micropore test used a compost operation that included food waste grinding, mixing 

with a greenwaste bulking agent, a 30-day and a 45-day active compost phase (food 

waste covered with micropore) and a cure phase (uncovered). 

TARGET SPECIES:

Methane, ethane, CO2, CO, Total non-methane organic carbon (condensable and 

volatile), and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer with modified air introduction system 

and stack testing approach and mixer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD Method 207.1, and USEPA Method TO-14/GC-ECD 

for the tracer SF6 (verification on tracer study).

SCOPE OF WORK:

95 Flux measurements were conducted over multiple field trips. Test locations were 

selected to represent the life-cycle emissions from the operations including uncovering, 

mixing, and time-dependent emissions post mixing. Receiving and finish was also tested.

Feedstock as received and aged 2 Flux tests- fresh and 24 hours old
Compost Day 1, covered 4 Flux tests, (T1, T2, S1, S2)

Variability Test, Day 1, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 8, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 18, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 31, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 31, uncovered and unmixed 4 Flux tests, (T1, T2, S1, S2)

Compost Day 32, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1; T1, S1)

Compost Day 45, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 45, uncovered and unmixed 4 Flux tests, (T1, T2, S1, S2)

Compost Day 45, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1, T1, S1)

Compost Day 46, uncovered and unmixed 4 Flux tests, (T1, T2, S1, S2)

Compost Day 46, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1, T1, S1)

Compost Day 55, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1, T1, S1)

Compost Day 58, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 58, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, S1, T1, S1)

Compost Day 60, covered 4 Flux tests, (T1, T2, S1, S2)

Variability Test, Day 60, covered 4 Flux tests, (T1, T2, S1, S2)

Compost Day 60, Mix Decay (hr 1, hr 4) 4 Flux tests, (T1, T2, S1, S2)

Finish Product- post screening 4 Flux tests- 2 fresh, 2 aged

Blank testing 9 Flux tests

Replicate testing 8 Flux tests________________

TOTAL 95 Flux tests

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank, replicate, and repeat samples are reported.

QC data indicated overall acceptable method performance.

FINDINGS:

Food Waste with 30-Day Micropore Cover- 11 #VOC/ton and 14 #NH3/ton

Food Waste with 45-Day Micropore Cover- 3.4 #VOC/ton and 114 #NH3/ton

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, including 

the recent, validated modifications to the SCAQMD Rule 1133 recommended procedure 

(6” port, 10% helium tracer). The modifications included the redesigned sweep air inlet 

system and stack testing in extended stack, backup tracer, and internal mixer. Data was 

collected without an adverse affect from high winds. 

COMMENTS:

The 30-Day Micropore cover system showed a reduced air emissions for VOCs (11 

#VOC/ton versus 27 #VOC/ton) as compared to the baseline Compostex cover system, 

but higher ammonia emissions (14 #NH3/ton versus 8.1 #NH#/ton). And, the 30-Day 

Micropore cover system showed a reduced air emissions for VOCs (3.4 #VOC/ton versus 

11 #VOC/ton) as compared to the 30-Day Micropore cover system, and also lower 

ammonia emissions (1.4 #NH3/ton versus 14 #NH#/ton). The robust assessment 
produced representative life-cycle emissions from the Micropore cover system on food 

waste at this site. 
SJVAPCD ANNOTATED BIBLIOGRAPHY FACT SHEET

COMPOST TYPE: Biosolids 

SITE: South Kern Industrial Complex (SKIC) LLC, Taft, CA

PAPER TITLE: “SKIC Air Emissions Compliance Report”

AUTHORS: Tom Card, CE Schmidt

DATE: January 2008, (testing conducted 08/08-12/07 and 12/04-06/08)

PROJECT OBJECTIVE: 

Determine the air emissions of VOCs and ammonia from the primary and secondary 

ASPs and the biofilters (mixing building, primary, and secondary biofilters); and 

determine the control efficiency of the biofilters for both VOCs and ammonia.

FACILITY OPERATIONS:

SKIC operates a co-composting facility that uses aerated static pile and biofilters. The 

biosolids are received in a building, mixed with greenwaste bulking agent, heap piled, 

placed in primary composting under negative aeration via subsurface ventilation and 

covered with a layer of finish biosolids (30 days), broke-down and transported to 

secondary curing which is also under negative aeration via subsurface ventilation but not 

covered with finish, screened, and sold as product. Gases collected from the mixing 

building, primary and secondary are routed though separate biofiltration consisting of 

wood chip media maintained by irrigation.

TARGET SPECIES:

Methane, ethane, CO2, CO, Total non-methane organic carbon (condensable and 

volatile), and ammonia.

SAMPLE COLLECTION METHODS:

SCAQMD Modified (6” port, 10% helium tracer with modified air introduction system 

and stack testing approach and mixer) USEPA surface emission isolation flux chamber.

ANALYTICAL METHODS:

SCQAMD Method 25.3, SCAQMD Method 207.1, and USEPA Method TO-14/GC-ECD 

for the tracer SF6 (verification on tracer study).

SCOPE OF WORK:

Approximately 103flux or stack measurements were conducted over two field trips. The 

primary composting and biofilter was tested in August and the secondary and biofilter 

along with the mixing building biofilter was tested in December. Test locations were 

selected to represent the life-cycle emissions from the operations. Biofilter inlet testing 
included triplicate stack testing in order to establish inlet concentrations and flow rates 

into the biofilters for destruction efficiency determinations.

Process Stack Tests Flux Locations

Primary Composting

Compost Surface- Day 

5, 11, 16

None 9

Secondary Composting

Compost Surface- Day 

22, 28, 36

None 9

Mixing Building 

Biofilter

Biofilter In 3 + 3 None

Biofilter Surface- 16 cell 

grid

None 16

Primary Biofilter

Biofilter In 3 None

Biofilter Surface- 16 cell 

grid

None 16

Secondary Biofilter

Biofilter In 3 None

Biofilter Surface- 16 cell 

grid

None 16

QC DATA:

Work plan was prepared and is available.

Adequate frequency of blank, replicate, and repeat samples are reported.

QC data indicated overall acceptable method performance.

FINDINGS:

Facility Emissions- 0.31 #VOC/ton and 0.14 #NH3/ton

Biofilter Destruction Efficiency; VOCs- 88% to 97%, NH3- 81% to 97%

CONCLUSIONS:

The appropriate sample collection and analytical techniques were employed, including 

the recent, validated modifications to the SCAQMD Rule 1133 recommended procedure 

(6” port, 10% helium tracer). The modifications included the redesigned sweep air inlet 
system and stack testing in extended stack, backup tracer, and internal mixer. Data was 

collected without an adverse affect from high winds. 

COMMENTS:

The ASP composting system complete with biofilter blanket on primary composting, 

negative aeration and biofilter control, and secondary curing negative aeration and 

biofilter control shows low emissions of VOCs and ammonia. Destruction efficiencies 

for both VOCs and ammonia from maintained wood chip biofiltration range from 81% to 

97% or these species. The robust assessment produced representative life-cycle 

emissions from the negative ASP system and biofiltration control.
Appendix B

Technical Memorandum

CIWMB Modesto Data Recalculation
Technical MEMORANDUM Environmental Management Consulting

41125 278th Way SE, Enumclaw, WA 98022 USA

Phone: 360-802-5540 Fax: 360-802-5541

E-Mail: trcard@earthlink.net

TO: Chuck Schmidt

FROM: Tom Card

DATE: June 19, 2008

SUBJECT: CIWMB Modesto Composting Report

Analysis

An analysis has been made of the California Integrated Waste Management Board’s (CIWMB) 

report entitled Emissions Testing of Volatile Organic Compounds from Greenwaste 

Composting at the Modesto Compost Facility in the San Joaquin Valley. It was not possible 

to reproduce the calculations in the report to verify their accuracy. Instead, the emissions are 

recalculated using the quantitative and written descriptions of the site and the testing procedures. 

There can be many reasons why this calculation is different than the report’s calculation. Those 

differences are discussed in detail below.

Table 1 summarizes the results of this analysis compared to the report’s findings. The South 

Coast Air Quality Management District (SCAQMD) emission factor is presented for comparative 

purposes.

Table 1. Preliminary Results

Basis of Recalculation

VOC Species

This report calculated VOC emissions as methane with no method bias factor applied. The 

SCAQMD presents VOC emissions as hexane carbon and includes a method bias factor. This 

report did not present the VOC data in this manner since most jurisdictions report VOC as 

methane with no method bias factor.

Compost Process

The compost process tested was greenwaste in windrows. The compost was placed in the 

windrow and mixed eleven times over a 60 day cycle. No attempt was made in the CIWMB 

report to quantify immediate mixing emissions. Previous work has shown that mixing emissions 

are irrelevant in well mixed aerobic windrows, but mixing emissions dominate in poorly mixed and 

poorly vented windrows. Based on the descriptions and data in the report, this windrow likely 

trends to the former condition. Figure 1 presents the windrow configuration that this report 

assumed along with the mensuration formulas used. Table 2 presents the windrow calculated 

data. 

Source VOC (#/ton mix)

Recalculation of CIWMB Results 1.5

CIWMB Report 0.6 - 0.7

SCAQMD Emssion Factor 3.8
Page 2 of 7

Figure 1. Assumed Windrow Configuration and Mensuration Formulas

Length

Height

Top Width

Bottom Width



2

2

1 2 1 2

2

1 2

(( )/ 2)

3

( )

2

h WB WT s

h A A A A

V

s A

p p

S

  

 









Mensuration formulas

where S = total surface area, p 1 = bottom

perimeter, p 2 = top perimeter, s = slant height,

V=volume, h=vertical height, A 1 = bottom area,

A2 = top area,  = bottom angle

The CIWMB reported the surface area as 206.4 m2. This report calculates the surface area as 

212 m2. The CIWMB reports the initial bulk density as 360 kg/m3. This report calculates the 

density as 510 kg/m3. The density difference is significant and could be one of the primary 

causes of the differences in results. The CIWMB number is significantly lower than any density 

value for greenwaste compost seen by this author. The compost windrow normally shrinks during 

the cycle. This shrinkage was not incorporated in this calculation, but based on the emissions 

profile (late cycle emissions go to essentially zero) this should not have significant impact.

The compost windrow was sampled typically at two locations on the top of the windrow, on the 

middle of the side and at the bottom of the side. Figure 2 is taken directly out of the CIWMB 

report to show the portions of the windrow that these samples represent. Table 3 shows this 

report’s allocation of the surface areas compared to the CIWMB allocation of surface areas. It 

was not possible to determine how the CIWMB calculated their area ratios.

Compost Venting

Compost often cracks and develops vent channels so that a large portion of the vent air goes 

through few channels. The CIWMB report discussed the phenomena extensively. However, the 

data suggest that the vent channels had no more emissions than the rest of the top surface. 

Many of the non-vented top surfaces had emissions exceeding the vented surfaces, which 

suggests that for the added volumetric flow even the field instrument screening data are not good 

indicators of VOC flux or emissions. Therefore, for this report all top surface values are averaged
Page 3 of 7

Table 2. Windrow Dimensions and Capacities

Property Units Value

Length ft 102.0

Height ft 6.8

Bottom Width ft 14.4

Top Width ft 5.6

Top Length ft 93

alpha R 1.00

o 57

Top Perimeter ft 198

Top Area ft2 522

Bottom Perimeter ft 233

Bottom Area ft2 1,469

Slant height ft 8.1

Surface Area ft2 2,265

m2 212

Volume ft3 6,497

yd3 241

m3 184

Conversion Factors ft2/m2 10.7

ft3/yd3 27

ft3/m3 35.31

Top Area Ratio 0.230

Mass Tons 103

Density #/yd3 856

kg/m3 509

Mensuration frmulas

Mensuration frmulas



2

2

1 2 1 2

2

1 2

( ( ) / 2)

3

( )

2

h WB WTs

h A A A A

V

s A

p p

S

  

 









M e nsuration formulas

w here S = total surface area, p1 = b

perimeter, p 2 = top perimeter, s = s

V=volume, h=vertical height, A 1 = b

A2 = top area,  = bottom angle
Page 4 of 7

Figure 2. CIWMB Windrow Cross Section (Figure 1. from the CIWMB report).

Table 3. Comparison of Surface Area Allocations.

Emission Factor Calculation

Table 4. presents a simulated full 60 day compost cycle emissions based on the CIWMB data. 

The highlighted values are measured unit emissions, the rest of the data is linearly interpolated 

from the measured data. Figure 3 shows the daily emissions profile.

Source Top Middle Side

This Report 0.5 0.25 0.25

CIWMB Report 0.26 0.37 0.37
Page 5 of 7

Table 4. Simulated VOC Emissions Profile.

Surface Area Emissions

Compost 

Day RH RL Mid Bot Total RH RL Mid Bot Total (m2) VOC (#)

1 0.25 0.25 0.25 0.25 1.00 19.05 34.78 2.71 36.93 23.4 212 15.7

2 0.25 0.25 0.25 0.25 1.00 30.16 38.95 1.96 19.13 22.5 212 15.2

3 0.25 0.25 0.25 0.25 1.00 34.44 41.58 1.21 1.34 19.6 212 13.2

4 0.25 0.25 0.25 0.25 1.00 31.23 38.12 0.94 1.04 17.8 212 12.0

5 0.25 0.25 0.25 0.25 1.00 28.01 34.66 0.68 0.75 16.0 212 10.8

6 0.25 0.25 0.25 0.25 1.00 24.80 31.20 0.41 0.46 14.2 212 9.6

7 0.25 0.25 0.25 0.25 1.00 22.76 27.74 3.49 1.79 13.9 212 9.4

8 0.25 0.25 0.25 0.25 1.00 20.71 24.28 6.57 3.13 13.7 212 9.2

9 0.25 0.25 0.25 0.25 1.00 19.52 20.83 5.54 2.67 12.1 212 8.2

10 0.25 0.25 0.25 0.25 1.00 18.33 17.37 4.51 2.20 10.6 212 7.1

11 0.25 0.25 0.25 0.25 1.00 17.14 13.91 3.48 1.73 9.1 212 6.1

12 0.25 0.25 0.25 0.25 1.00 15.95 10.45 2.45 1.27 7.5 212 5.1

13 0.25 0.25 0.25 0.25 1.00 14.76 6.99 1.42 0.80 6.0 212 4.0

14 0.25 0.25 0.25 0.25 1.00 13.57 3.53 0.39 0.34 4.5 212 3.0

15 0.25 0.25 0.25 0.25 1.00 11.83 3.21 0.35 0.33 3.9 212 2.6

16 0.25 0.25 0.25 0.25 1.00 10.10 2.89 0.30 0.32 3.4 212 2.3

17 0.25 0.25 0.25 0.25 1.00 8.36 2.57 0.26 0.30 2.9 212 1.9

18 0.25 0.25 0.25 0.25 1.00 6.63 2.25 0.22 0.29 2.3 212 1.6

19 0.25 0.25 0.25 0.25 1.00 4.89 1.93 0.18 0.28 1.8 212 1.2

20 0.25 0.25 0.25 0.25 1.00 3.15 1.60 0.14 0.27 1.3 212 0.9

21 0.25 0.25 0.25 0.25 1.00 1.42 1.28 0.10 0.26 0.8 212 0.5

22 0.25 0.25 0.25 0.25 1.00 1.44 1.38 0.09 0.24 0.8 212 0.5

23 0.25 0.25 0.25 0.25 1.00 1.46 1.48 0.09 0.22 0.8 212 0.5

24 0.25 0.25 0.25 0.25 1.00 1.48 1.58 0.09 0.20 0.8 212 0.6

25 0.25 0.25 0.25 0.25 1.00 1.51 1.68 0.09 0.19 0.9 212 0.6

26 0.25 0.25 0.25 0.25 1.00 1.53 1.77 0.09 0.17 0.9 212 0.6

27 0.25 0.25 0.25 0.25 1.00 1.55 1.87 0.09 0.15 0.9 212 0.6

28 0.25 0.25 0.25 0.25 1.00 1.57 1.97 0.09 0.13 0.9 212 0.6

29 0.25 0.25 0.25 0.25 1.00 1.59 2.07 0.09 0.11 1.0 212 0.6

30 0.25 0.25 0.25 0.25 1.00 1.62 2.17 0.09 0.10 1.0 212 0.7

31 0.25 0.25 0.25 0.25 1.00 1.62 2.05 0.10 0.10 1.0 212 0.6

32 0.25 0.25 0.25 0.25 1.00 1.63 1.92 0.11 0.10 0.9 212 0.6

33 0.25 0.25 0.25 0.25 1.00 1.64 1.80 0.13 0.10 0.9 212 0.6

34 0.25 0.25 0.25 0.25 1.00 1.65 1.68 0.14 0.11 0.9 212 0.6

35 0.25 0.25 0.25 0.25 1.00 1.66 1.56 0.15 0.11 0.9 212 0.6

36 0.25 0.25 0.25 0.25 1.00 1.67 1.44 0.17 0.11 0.8 212 0.6

37 0.25 0.25 0.25 0.25 1.00 1.68 1.32 0.18 0.11 0.8 212 0.6

38 0.25 0.25 0.25 0.25 1.00 1.69 1.20 0.20 0.12 0.8 212 0.5

39 0.25 0.25 0.25 0.25 1.00 1.70 1.08 0.21 0.12 0.8 212 0.5

40 0.25 0.25 0.25 0.25 1.00 1.71 0.96 0.22 0.12 0.8 212 0.5

41 0.25 0.25 0.25 0.25 1.00 1.72 0.84 0.24 0.12 0.7 212 0.5

42 0.25 0.25 0.25 0.25 1.00 1.73 0.72 0.25 0.12 0.7 212 0.5

43 0.25 0.25 0.25 0.25 1.00 1.73 0.60 0.26 0.13 0.7 212 0.5

44 0.25 0.25 0.25 0.25 1.00 1.74 0.48 0.28 0.13 0.7 212 0.4

45 0.25 0.25 0.25 0.25 1.00 1.64 0.55 0.27 0.13 0.6 212 0.4

46 0.25 0.25 0.25 0.25 1.00 1.54 0.62 0.26 0.13 0.6 212 0.4

47 0.25 0.25 0.25 0.25 1.00 1.43 0.68 0.25 0.14 0.6 212 0.4

48 0.25 0.25 0.25 0.25 1.00 1.33 0.75 0.24 0.14 0.6 212 0.4

49 0.25 0.25 0.25 0.25 1.00 1.22 0.82 0.23 0.14 0.6 212 0.4

50 0.25 0.25 0.25 0.25 1.00 1.12 0.89 0.22 0.14 0.6 212 0.4

51 0.25 0.25 0.25 0.25 1.00 1.01 0.96 0.21 0.14 0.6 212 0.4

52 0.25 0.25 0.25 0.25 1.00 0.91 1.02 0.20 0.15 0.6 212 0.4

53 0.25 0.25 0.25 0.25 1.00 0.81 1.09 0.19 0.15 0.6 212 0.4

54 0.25 0.25 0.25 0.25 1.00 0.70 1.16 0.18 0.15 0.5 212 0.4

55 0.25 0.25 0.25 0.25 1.00 0.60 1.23 0.18 0.15 0.5 212 0.4

56 0.25 0.25 0.25 0.25 1.00 0.49 1.30 0.17 0.15 0.5 212 0.4

57 0.25 0.25 0.25 0.25 1.00 0.39 1.37 0.16 0.16 0.5 212 0.3

58 0.25 0.25 0.25 0.25 1.00 0.39 1.37 0.16 0.16 0.5 212 0.3

59 0.25 0.25 0.25 0.25 1.00 0.39 1.37 0.16 0.16 0.5 212 0.3

60 0.25 0.25 0.25 0.25 1.00 0.39 1.37 0.16 0.16 0.5 212 0.3

159

Emission Factor (#/ton) 1.5

Weighting Factors Unit Flux (mg/min-m2)
Page 6 of 7

Figure 3. Simulated VOC Emissions Profile.

Summary

An independent analysis of the Modesto flux data as supplied in the CE Schmidt Technical 

Memorandum was conducted. The emission estimate reported in the CIWMB report could not be 

duplicated, and the differences in assumptions, especially those that may be more significant 

have been identified and discussed. All things considered, the independent recalculation of the 

Modesto site emission factors are surprisingly similar to the CIWMB emission factors. This 

recalculation, again considering the differences and the similarity of the independently derived 

emission factors indicates that:

 Assumptions thought to be significant probably have less of an influence on the emission 

factor development process;

 The similarity in the emission factor estimates clearly establishes the ‘ball park’ for 

greenwaste emissions as those representing a site complying with a given site operations 

plan with regular maintenance and inspection. In other words, these data may represent 

sites that are capable of maintaining lower VOC emissions while producing an acceptable 

compost product.

 Given that the accuracy and precision specifications for flux chamber testing with GC 

analysis is +/- 50%, the data should be viewed as stated below:

o 0.7 +/- 0.35 Range is 0.35 #/ton to 1.1 #/ton

o 1.5 +/- 0.75 Range is 0.75 #/ton to 2.3 #/ton

 Note that these ranges overlap indicating no statistical difference in the numbers (0.7 and 

1.5) 

0

2

4

6

8

10

12

14

16

18

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59

Compost Day

Daily VOC Emissions per Windrow (pounds VOC)
Page 7 of 7

 Emission factors for the other test piles are not offered at this time.
Appendix C

Technical Memorandum

Site X Emission Report
Technical MEMORANDUM Environmental Management Consulting

41125 278th Way SE, Enumclaw, WA 98022 USA

Phone: 360-802-5540 Fax: 360-802-5541

E-Mail: trcard@earthlink.net

TO: ▓▓▓▓▓▓▓▓▓▓▓▓▓▓▓▓

COPY: Chuck Schmidt

FROM: Tom Card

DATE: April 24, 2008

SUBJECT: Compost Emissions Source Test

Preliminary Results

A preliminary analysis has been made for your site emissions and this memo presents those 

results. The results are not final yet, but we are not expecting any dramatic changes. However, 

do not make important decisions regarding these results until they are finalized.

Table 1 summarizes the results for you site and Table 2 provides comparison data (windrow 

emissions only) from the SCAQMD and a site similar to yours (that must remain confidential). 

You are about twice the SCAQMD number for VOC and about four times for ammonia. However,

you are lower in VOC than a similar tested site. Figure 1 shows the emissions profile for a typical 

windrow.

One of our concerns regarding the data set is that the flow rate through the flux chambers was 

about five times higher than we would expect. This is likely due to the wind speed. Unfortunately 

your site is located in a high wind area and there is not much that can be done to mitigate wind 

speed.

Table 3 is a list of assumptions made about your operation that have a direct bearing on the 

emissions estimate. Please review these assumptions and correct them where appropriate.

Table 1. Preliminary Results

Table 2. Comparative Results (Windrow only)

Source VOC Ammonia

Site X 6.30 2.34

SCAQMD 3.80 0.50

Site Z 14.22 0.54

Emissions (pounds per ton received)

Source VOC Ammonia

Receiving Stockpile 7.76 0.03

Windrows 6.30 2.34

Total 14.06 2.37

Emissions (pounds per ton received)
Figure 1. Emissions Profile

Table 3. Key Assumptions

0

5

10

15

20

25

30

35

40

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 61 63 65 67 69 71 73 75 77 79

Compost Day Daily Emissions (pounds per windrow)

VOC

NH3

Item Value Units

Average daily throughput 356 Tons

Stockpile density 800 #/yd3

Average stockpile duration 45 days

Mass in windrow 200 tons

Compost cycle duration 80 days
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

TECHNICAL MEMORANDUM

FLUX CHAMBER SOURCE TESTING OF FUGITIVE AIR 

EMISSIONS FROM SITE X COMPOST FACILITY

Prepared By:

Mr. Tom Card

Environmental Management Consulting

41125 278th Way SE

Enumclaw, WA 98022

Dr. C.E. Schmidt

Environmental Consultant

19200 Live Oak Road

Red Bluff, California 96080

May 7, 2008
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

TABLE OF CONTENTS

Page

Executive Summary ii

I. Introduction ...................................... 1

II. Test Methodology ............................. 2

III. Quality Control ................................. 4

IV. Results and Discussions .................... 6

V. Summary ........................................... 7

Attachments

A- Emissions Measurement Data Sheets

B- Chain of Custody

C- Lab Reports

References
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

ii

EXECUTIVE SUMMARY

Field measurements were conducted at the Site X compost facility located in the California

Central Valley. Testing was conducted on the pre-compost windrow and compost windrow area 

sources on site for the purpose of assessing total volatile organic compound (VOC- expressed as 

total non-methane non-ethane organic compounds by SCAQMD Method 25.3) emissions and 

ammonia emissions from the composting of greenwaste on site. Although the scope of work was 

limited by comparison to a full life-cycle emissions assessment, these data provide a good 

estimate of process emissions as tested. 

The testing was conducted on March 10, 2008; the one-day testing effort was conducted on a day 

with winds running about 13 mph to 14 mph for the duration of the testing activities. Because 

most information points toward higher air emissions during windy conditions, it is possible that 

the measured flux data and thus site emission data were influenced by the higher winds resulting 

in a higher air emissions estimate.

The data collection approach included using the USEPA-recommended flux chamber modified as 

per the SCAQMD Rule 1133 as approved by recent method improvements, and standard air sample 

collection methodsfor VOCs or reactive organic gases, and ammonia. This approach provided data 

of high quality (accuracy and precision) representative of air emissions of study compounds from the 

organic composting process and the greenwaste static pile windrow composting process. The testing 

was scheduled so that fugitive air emissions could be measured at key times in the composting 

processes studied. The organic composting system was evaluated by collecting fugitive emission 

samples from the following area sources:

GREENWASTE COMPOSTING OPERATION

Feedstock as received and aged Not tested

Compost Day 0 2 Flux tests, (T1, S2)

Compost Day 6 2 Flux tests, (T1, S1)

Compost Day 10 4 Flux tests, (T1, T2, S1, S2)

Compost Day 10, 1-hr post mixed 2 Flux tests, (T1, S1)

Compost Day 10, 3-hr post mixed 2 Flux tests, (T1, S1)

Compost Day 10, 5-hr post mixed 2 Flux tests, (T1, S1)
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

iii

Compost Day 30 2 Flux tests, (T1, S1)

Compost Day 79 2 Flux tests, (T1, S1)

Blank testing 1 Flux test

Replicate testing 1 Flux test________________

TOTAL 20 Flux tests

Testing was conducted using the USEPA surface emission isolation flux chamber, real time 

detection for ammonia (screening-level analysis), SCAQMD Method 25.3 for total VOCs, and 

SCAQMD Method 207.1 for ammonia. The assessment of the test surfacesincluded screening using 

real time detection in the field (colorometric tubes for ammonia), and flow conditions in the flux 

chamber as a result of advective flow from the area sources tested. Advective flow from the 

windrow composting (gas production and wind) was quantitatively assessed by using a tracer gas 

(10% helium) in the flux chamber, gas collection in evacuated stainless steel canisters, and analysis 

off site by gas chromatography/thermal conductivity detection (GC/TCD). The dilution of helium 

was used to calculate advective flow, and these data were used in the calculation of compound 

emissions from the test sources.

Note that the recommended SCAQMD method bias factor correction of 1.086 was not applied to 

these data. There is no scientific justification for applying a specific bias correction factor 

generated from one laboratory to another laboratory, since a given analytical method bias is 

unique to that laboratory and not intrinsic to the method.

The data tables generated and reported in this document describe the fugitive air emission from 

the sources tested on site. These flux data, combined with engineering data that describes the 

composting operations, can be used to generate a facility emission factor data base and a facility 

baseline emission estimate for total VOCs and ammonia. The engineering estimate for VOC and 

ammonia emissions is reported elsewhere.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

1

I. INTRODUCTION

This technical memorandum describes the field testing that was conducted in order to assess air 

emissions of ammonia, and VOC air emissions from the Site X greenwaste compost facility. Testing 

was conducted by Dr. C.E. Schmidt , Mr. Tom Card, and Ms. Katie Schmidt on March 10, 2008. 

Site preparation included arranging for the test piles and providing access to the facility. 

The objective of the study was to provide representative, fugitive air emissions of study compounds 

from the purpose of generating ammonia and VOC emission estimates from the composting of 

greenwaste at the facility. This was accomplished by selecting representative test locations, and 

quantitative analysis of air emissions producing representative average air emissions data.

This memorandum includes a discussion of the testing methodology, quality control procedures, 

results, discussion of the results, and summary statements.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

2

II. TEST METHODOLOGY

Testing for surface flux was conducted using the USEPA recommended Surface Isolation Flux 

Chamber (USEPA. Radian Corporation, February 1986). Flux chamber sampling was performed on 

static windrow piles of greenwaste materials as found on site the day of testing. 

The operation of the surface flux chamber is given below:

1) Flux chamber, sweep air, sample collection equipment, and field documents were located onsite. 

2) The site information, location information, equipment information, date, and proposed time 

of testing were documented on the Emissions Measurement Field Data Sheet.

3) The exact test location was selected and placed about 0.25” to 0.5” into compost matrix 

sealing the chamber for surface testing, or on the agricultural bag positioned to achieve a 

chamber/interface seal. . 

4) The sweep air flow rate (ultra high purity air with a carbon monoxide tracer gas additive) was 

initiated and the rotometer, which stabilizes the flow rate, was set at 5.0 liters per minute. A 

constant sweep air flow rate was maintained throughout the measurement for each sampling 

location.

5) Flux chamber data were recorded every residence interval (6 minutes) for five intervals, or 30 

minutes. 

6) At steady-state (assumed to be greater than 5 residence intervals), the screening by 

colorimetric tube and real-time instrument was performed. After screening, sample 

collection was performed by interfacing the sample container (acid impinger, trap and 

canister, and tedlar bag (if scheduled) sequentially) to the purged, sample line and filling the 

container with sample gas or collecting the desired sample following sample collection 

protocols as per the work plan.

7) After sample collection (impinger solution, trap and evacuated canister, and tedlar bag) all 

sample media was sealed, labeled, and stored as per protocol, and sample collection 

information was documented on the data sheet. 

8) After sampling, the flux measurement was discontinued by shutting off the sweep air, 
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

3

removing the chamber, and securing the equipment. The chamber was cleaned by dry wipe 

with a clean paper towel and the sample lines were purged with UHP air. 

9) Sampling locations were recorded on the field data sheet. The equipment was then relocated 

to the next test location and steps 1) through 8) were repeated.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

4

III. QUALITY CONTROL

Control procedures that were used to assure that data of sufficient quality resulted from the flux 

chamber study are listed and described below. The application and frequency of these procedures 

were developed to meet the program data quality objectives as described in SCAQMD Rule 1133a 

with some modifications. 

Field Documentation -- A field notebook containing data forms, including sample chain-of-custody 

(COC) forms, was maintained for the testing program. Attachment A contains the Emission 

Measurement Data Sheets.

Chain-of-Custody -- COC forms were not used for field data collection. Field data were recorded on 

the Chain-of-Custody forms provided in Attachment B.

Ammonia Analysis by SCAQMD Method 207.1

Laboratory Spike Recovery- One laboratory spike sample was performed and the recovery of the 

spike was 101%. These data indicate acceptable method performance.

Calibration – A five point calibration curve was performed for the ammonia method, and the 

correlation curve was reported within method specification. These data indicate acceptable method 

performance.

Trip Blank—One trip blank sample was collected and the level reported was <0.004 mg per sample 

(MDL 0.004 mg) or below method detection. These data indicate acceptable method performance.

Field Replicate Sample Analysis -- One field sample was collected in replicate and analyzed for the 

project. The RPD values for sample/replicate pair was 12 (QC criteria 50 RPD). These data indicate 

acceptable method repeatability and method performance.

 

Total Non-Methane and Non-Ethane Organic Compound Analysis by SCAQMD Method 25.3

Method Quality Control –Method quality control included method blank determinations, and method 

response to four-point calibration curves. All method QC testing was with method specifications, 

and these data indicate acceptable method performance.

Field System Blank – One blank samples was analyzed as blind QC sample. TNMNEO levels in the 

blank sample were less that <1.0 ppmvC for the condensable, volatile and total hydrocarbon analysis 

(method detection limit 1 ppmvC). These data establish sensitivity for the method (project QC 

criteria), and indicate acceptable method performance.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

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Field Replicate Sample – One field sample was collected and analyzed in replicate. In this data set, 

study compounds detected showed precision within precision criteria for field samples (RPD 50) for 

the TNMNEO or total VOC concentration. The RPD for the data set was 9.0 indicating acceptable 

method precision and performance.

Tracer Helium Analysis by GC/TCD

Laboratory Control Spike and QC Duplicate Analysis- Laboratory control spike sample data are not 

available at this time. 

Laboratory Precision– Laboratory QC sample data are not available at this time. 

Tracer Recovery Sample- One media blank sample was collected in the field by filling a canister for 

analysis in order to determine tracer recovery apart from the flux measurement technology or the 

advective flow from sources. The tracer was recovered from the media blank samples with a value 

of 105% (QC criteria +50%, or 50% to 150% recovery). These data indicate acceptable method 

performance.

Field Replicate Sample – One field sample was collected in replicate. The precision (relative percent 

difference) for the field replicate sample pair was 0.0, which is less than the QC criteria of 50 RPD. 

These data indicate acceptable method performance.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

6

IV. RESULTS AND DISCUSSIONS

A summary of the field sample collection for the field testing is shown in Table 1. All field data for 

the on site surface flux chamber testing (screening for ammonia, temperature), and sample 

identification information are presented in Table 1. All laboratory data including quality control data 

are presented in Table 2. These flux data include measured advective flow rate in the flux 

calculation. Surface flux data are shown in flux units for hydrocarbon emissions (mg/m2,min-1 as 

methane, ppmvC) and for ammonia (mg/m2,min-1 as ammonia). 

Surface flux data for a surface area source are calculated using measured target compound 

concentrations and flux chamber operating parameter data (sweep air flow rate of 5.0 liters per 

minute [or 0.005 m3/min] plus advective flow [m3/min], surface area of 0.13 square meters [m2]). 

The site emissions can be calculated by multiplying the flux by the surface area of the source. The 

flux is calculated from the sweep air flow rate Q (cubic meters per minute [m3/min]), the species 

concentration Yi (micrograms per cubic meter [mg/m3)], and exposure to the chamber surface area A 

(square meters [m2]), as follows:

Fi = (Q) (Yi) / (A)

Emission rate of from a given static windrow test pile can be calculated by multiplying unit or 

average flux data per compound by surface area and reported as a function of area source.

Note that the recommended SCAQMD method bias factor correction of 1.086 was not applied to 

these data. There is no scientific justification for applying a specific bias correction factor 

generated from one laboratory to another laboratory, since a given analytical method bias is 

unique to that laboratory and not intrinsic to the method.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

7

V. SUMMARY

Emission testing was performed on the Site X static windrow, greenwaste compost operations in 

order to generate an estimate of the facility baseline emissions for VOCs and ammonia. Testing was 

conducted at key times (compost at different age and under different conditions) in the compost cycle 

for the purpose of obtaining representative air emissions of ammonia and VOCs from the test piles. 

The following is a summary of activities and results associated with this objective:

 Surface flux measurements of study compounds were measured on static windrow piles in 

the compost cycle, from the pre-compost windrow piles to near the end-of-cycle compost 

(Day 79). Testing was performed using the USEPA recommended surface flux chamber 

technology as modified by the SCAQMD for advective flow sources at compost sites. This 

technology quantitatively measures flux at the test surface of study compounds. 

 Field and laboratory quality control data indicate acceptable data quality for SCAQMD 

Method 207.1 (ammonia) and SCAQMD Method 25.3 (organic gases). System blank levels 

were acceptable, and precision between a sample and replicate field samples was within the 

RPD criteria of 50. The recovery of the helium tracer QC showed acceptable method 

performance, and the use of the helium recovery data per sample demonstrated to be a 

effective and representative approach to assessing volumetric flow from the sources tested. 

 Note that the recommended SCAQMD method bias factor correction of 1.086 was not 

applied to these data. There is no scientific justification for applying a specific bias 

correction factor generated from one laboratory to another laboratory, since a given 

analytical method bias is unique to that laboratory and not intrinsic to the method.

 The wind speeds experienced on the day of testing may have affected the emission 

estimate. It is believed that higher winds generate higher flux and thus air emissions. 

The winds on the day of testing ranged from 13 mph to 14 mph. This is a high wind area, 

however, using these test data to represent an annual emissions estimate may result in a 

bias in the emissions.

 Two samples were collected on a ‘pre-compost’ windrow, meaning that material prepared 

composting was tested and the pile was not yet included in the life-cycle process. Data 

from this ‘front-end’ area source, although small in surface area, was used to represent 

greenwaste material on site prior to entering the composting operations, including the 

tipping piles, screening piles, and storing piles.
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

8

 The flux data can be used to estimate ammonia, and VOC emissions from the test pile 

surfaces. Emission rate data is obtained by multiplying surface areas of the test piles by 

the surface area of the test piles. 
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

9

REFERENCES

USEPA. 1986. "Measurement of Gaseous Emission Rates From Land Surfaces Using an Emission 

Isolation Flux Chamber, Users Guide." EPA Environmental Monitoring Systems Laboratory, Las 

Vegas, Nevada, EPA Contract No. 68-02-3889, Work Assignment No. 18, Radian Corporation, 

February 1986. NTIS # PB 86-223161.
Table 1. Summary of Test Information.

DATE TIME SOURCE COMPOST Section TEST LOCATION NH3 Helium TRACER 25.3 207.1 IN SURF IN AIR OUT SURF OUT AIR WINDS COMMENT

DAY PILE (ppmv) (%) SF6 ID ID o

F

o

F

o

F

o

F (mph)

3/10/2008 941 Windrow Compost 10 D-16 Top- T1 10 10.31 1.046 G-101 A-101 63 83 63 61 13 Mixed and water added 3 days prior, pile 4.5' tall, 10' base

3/10/2008 942 Windrow Compost 10 D-16 Top-T2 12 10.22 1.049 G-102 A-102 89 95 84 61 13 Mixed and water added 3 days prior

3/10/2008 942 Windrow Compost 10 D-16 Side- S1 12 10.20 1.058 G-103 A-103 66 92 66 66 13 Mixed and water added 3 days prior

3/10/2008 943 Windrow Compost 10 D-16 Side- S2 4 10.33 1.042 G-104 A-104 58 75 58 62 13 Mixed and water added 3 days prior

3/10/2008 1136 Windrow Compost 6 D-18 Top- T1 28 10.33 1.042 G-105 A-105 64 100 64 68 13

3/10/2008 1139 Windrow Compost 6 D-18 Side- S1 2 10.31 1.046 G-106 A-106 62 90 62 68 13

3/10/2008 1144 Windrow Compost- Post Mix Hr-1 10 D-16 Top- T1 8 10.20 1.058 G-107 A-107 66 92 66 70 13 Mixed at 1107

3/10/2008 1148 Windrow Compost- Post Mix Hr-1 10 D-16 Side- S1 12 10.22 1.049 G-108 A-108 125 95 125 68 13 Mixed at 1107

3/10/2008 1250 Windrow Compost- Post Mix Hr-3 10 D-16 Top- T1 10 10.20 1.058 G-111 A-111 65 84 65 76 14 Mixed at 1107

3/10/2008 1343 Windrow Compost- Post Mix Hr-3 10 D-16 Side- S2 20 10.22 1.049 G-112 A-112 60 90 60 77 14 Mixed at 1107

3/10/2008 1351 Windrow Compost 30 E-7 Top- T1 8 10.33 1.042 G-109 A-109 60 104 60 76 ND Pile 4' tall, 10' wide base

3/10/2008 1351 Windrow Compost 30 E-7 Side- S1 6 10.31 1.046 G-110 A-110 62 92 62 77 ND

3/10/2008 1535 Windrow Compost- Post Mix Hr-5 10 D-16 Top- T1 8 10.20 1.058 G-113 A-113 63 80 63 75 ND Mixed at 1107

3/10/2008 1537 Windrow Compost- Post Mix Hr-5 10 D-16 Side-2 16 10.22 1.049 G-114 A-114 66 86 66 77 ND Mixed at 1107

3/10/2008 1548 Windrow Compost 79 B-10 Top- T1 4 10.31 1.046 G-115 A-115 64 93 64 75 ND Pile 3.5' tall and 9 ' wide base

3/10/2008 1549 Windrow Compost 79 B-10 Side- S2 2 10.33 1.042 G-116 A-116 70 81 70 76 ND

3/10/2008 1707 Windrow Compost- Prep Pile 0 C-12 Top- T1 <0.05 10.20 1.058 G-117 A-117 72 82 72 78 ND

3/10/2008 1715 Windrow Compost- Prep Pile 0 C-12 Side- S1 1 10.20 1.058 G-118 A-118 74 79 74 78 ND

3/10/2008 1715 Sample Replicate 0 C-12 Side- S1 1 10.20 1.058 G-119 A-119 74 79 74 78 ND Sample Replicate

3/10/2008 1715 Media Blank N/A N/A N/A N/A 10.20 1.058 G-120 A-120 N/A N/A N/A N/A NA Reagent Blank
Table 2. Summary of Flux Data (mg/m2,min-1).

SOURCE COMPOST TEST LOCATION 25.3 207.1 Methane Ethane TNMNEO NMNEO Trap NMNEO Tank NH3 NH3 Vol NH3 Helium

DAY ID ID (ppmv) (ppmv) (ppmv) (ppmv) (ppmv) (mg) (m3) (mg/m3) %

Windrow Compost 10 Top- T1 G-101 A-101 27.4 ND 12.2 6.06 6.12 0.365 0.0295 12.4 10.31

Windrow Compost 10 Top-T2 G-102 A-102 16.7 ND 11.8 11.2 1.0 0.489 0.0268 18.2 10.22

Windrow Compost 10 Side- S1 G-103 A-103 93 ND 21.0 20.1 1.0 0.278 0.0282 9.9 10.20

Windrow Compost 10 Side- S2 G-104 A-104 17.2 ND 4.25 3.58 1.0 0.055 0.0248 2.2 10.33

Windrow Compost 6 Top- T1 G-105 A-105 10 ND 17.7 17.2 1.0 0.505 0.0311 16.2 10.33

Windrow Compost 6 Side- S1 G-106 A-106 65 ND 9.94 9.37 1.0 0.029 0.0303 0.96 10.31

Windrow Compost- Post Mix Hr-1 10 Top- T1 G-107 A-107 14.9 ND 5.62 4.89 1.0 0.113 ###### 3.8 10.20

Windrow Compost- Post Mix Hr-1 10 Side- S1 G-108 A-108 65.7 ND 10.6 9.45 1.14 0.239 0.0332 7.2 10.22

Windrow Compost- Post Mix Hr-3 10 Top- T1 G-111 A-111 11.5 ND 5.77 5.23 1.0 0.123 0.0271 4.5 10.20

Windrow Compost- Post Mix Hr-3 10 Side- S2 G-112 A-112 48.7 ND 7.15 5.65 1.49 0.202 0.0254 8.0 10.22

Windrow Compost 30 Top- T1 G-109 A-109 58.3 ND 5.97 5.57 1.0 0.050 0.0130 3.8 10.33

Windrow Compost 30 Side- S1 G-110 A-110 574 ND 6.65 5.82 1.0 0.002 0.0103 0.19 10.31

Windrow Compost- Post Mix Hr-5 10 Top- T1 G-113 A-113 19.3 ND 3.91 3.34 1.0 0.089 0.0231 3.9 10.20

Windrow Compost- Post Mix Hr-5 10 Side-2 G-114 A-114 42.0 ND 5.19 4.14 0.163 0.0219 7.4 10.22

Windrow Compost 79 Top- T1 G-115 A-115 100 ND 5.41 2.91 0.011 0.0587 0.19 10.31

Windrow Compost 79 Side- S2 G-116 A-116 79.60 ND 5.70 4.27 0.009 0.0588 0.15 10.33

Windrow Compost- Prep Pile 0 Top- T1 G-117 A-117 2.13 ND 27.6 27.6 1.0 0.004 0.0509 0.08 10.20

Windrow Compost- Prep Pile 0 Side- S1 G-118 A-118 47.20 ND 116 115 1.0 0.013 0.0512 0.25 10.20

Sample Replicate 0 Side- S1 G-119 A-119 46.70 ND 106 105 1.0 0.013 0.0605 0.21 10.20

Media Blank N/A N/A G-120 A-120 1.0 ND 1.0 1.0 1.0 0.004 0.0540 0.074 10.20

Flux Unit: mg/m2,min-1

Note 1- Methane Flux = (CH4 ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 CH4

Note 2- TNMNEO Flux = (TNMNEO ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 TNMNEO

Note 3- Ammonia Flux = (NH3 mg/m3)(m3/min)/(0.13 m2) = mg/m2,min-1 NH3

Note 4- Total Flow = (Helium %/Helium % recovered)(0.005 m3/min) = m3/min total flow

Note 5- MDL value used for ND or non-detect for calcuation purposes
Table 2. Summary of Flux Data (mg/m2,min-1).

Trace Total Flow SF6 UHP SF6 Detect Methane TNMNEO NH3 SOURCE TEST LOCATION COMPOST COMMENT

% (m3/min) (ppbv) (ppbv) Flux Flux Flux DAY

0.20 0.2578 N/A N/A 35.47 16 25 Windrow Compost Top- T1 10

0.27 0.1893 N/A N/A 15.88 11 27 Windrow Compost Top-T2 10

0.23 0.2217 N/A N/A 103.58 23 17 Windrow Compost Side- S1 10

0.19 0.2718 N/A N/A 23.49 5.8 4.6 Windrow Compost Side- S2 10

0.27 0.1913 N/A N/A 9.49 17 24 Windrow Compost Top- T1 6

0.16 0.3222 N/A N/A 105.52 16 2.4 Windrow Compost Side- S1 6

0.15 0.3400 N/A N/A 25.45 9.6 10 Windrow Compost- Post Mix Hr-1 Top- T1 10

0.19 0.2689 N/A N/A 88.76 14 15 Windrow Compost- Post Mix Hr-1 Side- S1 10

0.12 0.4250 N/A N/A 24.55 12 15 Windrow Compost- Post Mix Hr-3 Top- T1 10

0.16 0.3194 N/A N/A 78.13 11 20 Windrow Compost- Post Mix Hr-3 Side- S2 10

0.28 0.1845 N/A N/A 54.02 5.5 5.5 Windrow Compost Top- T1 30

0.24 0.2148 N/A N/A 619.30 7.2 0.32 Windrow Compost Side- S1 30

0.12 0.4250 N/A N/A 41.20 8.3 13 Windrow Compost- Post Mix Hr-5 Top- T1 10

0.18 0.2839 N/A N/A 59.89 7.4 16 Windrow Compost- Post Mix Hr-5 Side-2 10

0.47 0.1097 N/A N/A 55.09 3.0 0.16 Windrow Compost Top- T1 79

0.30 0.1722 N/A N/A 68.84 4.9 0.20 Windrow Compost Side- S2 79

0.19 0.2684 N/A N/A 2.87 37 0.16 Windrow Compost- Prep Pile Top- T1 0 Representative of Tipping Pile/Pre Pile

0.16 0.3188 N/A N/A 75.57 186 0.62 Windrow Compost- Prep Pile Side- S1 0

0.16 0.3188 N/A N/A 74.77 170 0.53 Sample Replicate Side- S1 0

10.7 0.005 N/A N/A 0.025 0.025 0.0028 Media Blank N/A N/A 105 Percent Recovery of He Tracer

MDL Value Used Note 1- Methane Flux = (CH4 ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 CH4

Note 2- TNMNEO Flux = (TNMNEO ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 TNMNEO

Note 3- Ammonia Flux = (NH3 mg/m3)(m3/min)/(0.13 m2) = mg/m2,min-1 NH3

Note 4- Total Flow = (Helium %/Helium % recovered)(0.005 m3/min) = m3/min total flow

Note 5- MDL value used for ND or non-detect for calcuation purposes
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

ATTACHMENT A

EMISSION MEASUREMENT DATA SHEETS
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

ATTACHMENT B

CHAIN OF CUSTODY
CE Schmidt, Ph.D.

Environmental Consultant

19200 Live Oak Road Red Bluff, CA 96080 (530) 529-4256 Fax- 4878

CES#052008.Site X.TM

ATTACHMENT C

LABORATORY REPORTS
Green Waste Compost EF Report 

September 15, 2010 

11

Appendix B 

Comments and Responses to the “Organic Material Composting and Drying focusing on 

Greenwaste Compost Air Emissions Data Review” 
Green Waste Compost EF Report 

September 15, 2010 

12

Responses to Comments on the document entitled “Organic Material Composting and 

Drying focusing on Greenwaste Compost Air Emissions Data Review”, by Thomas R. 

Card and Charles E. Schmidt, June 2008. This report will be referred to as the “green 

waste report” hereafter within this document. 

Summary of comments from Center on Race, Poverty and the Environment (CRPE) / 

Committee for a Better Arvin:

CRPE 1: The CIWMB Modesto Study should be excluded from consideration because it 

did not include emissions from the stockpiles. 

Response: The green waste report included separate VOC emission factors for the 

windrows and the stockpiles. The report averaged the measurement results for each of 

these two processes separately. The CIWMB Modesto Study measurement was used 

only in developing the windrow VOC emission factor. The lack of a stockpile emission 

factor from this study does not affect the VOC emission factor for the windrows. 

CRPE 2: The CIWMB Modesto Study should be excluded from consideration because 

the results are not replicable. 

Response: This comment is based on Schmidt’s recalculation of the results, and his 

conclusion that the published results of the Modesto Study are incorrect. The District 

has reviewed Dr. Schmidt’s recalculation, and has determined that there is not enough 

justification within the analysis to support the recalculation of previously published study 

results. Therefore, the District will use the originally published emission factor of 0.8 to 

0.9 lb-VOC/ton. 

CRPE 3: The CIWMB Modesto Study should be excluded from consideration because it 

did not account for the effect of wind on emissions. 

Response: The studies that were chosen for inclusion in the green waste report were 

the studies that were found to be the most complete and valid for the purpose of 

generating VOC emission factors for composting operations. Conditions during 

emission measurements at each of the study sites were representative of conditions 

during actual operations. It is not possible to determine if wind is expected to have a 

significant effect on the VOC emission rates or adjust measured emission rates without 

full speciation of the compounds measured. The studies that were determined to be the 

most valid, including the CIWMB Modesto Study, used total VOC methods without 

speciation because total VOC methods have been found to capture a higher proportion 

of the total VOC emissions when compared to other methods. Additionally, there are 

currently no validated procedures to adjust the measured rates for differing wind 

velocities. In conclusion, the District is using the most complete scientific data available 

to update the composting emission factor. As with other emission factors, the proposed 

composting VOC emission factor will be periodically updated to incorporate if new 

scientific information indicates that revisions may be necessary. 
Green Waste Compost EF Report 

September 15, 2010 

13

CRPE 4: None of the three studies relied upon were conducted during the hotter 

months in the Central Valley. The Modesto report was conducted between October and 

December, some of the coldest months of the year in the Central Valley. The studies 

may underestimate emissions because they did not account for the high summer 

temperatures common in the Central Valley. 

Response: As stated above, the studies that were chosen were the studies that were 

found to be the most complete and valid for the purpose of generating emission factors. 

In regards to the comment that the testing for the Modesto report was conducted in the 

coldest part of the year, records indicate that the coldest months in the Central Valley 

are December-February and that the average temperature for October is actually higher 

than both March and April. It must also be noted that the NorCal study was conducted 

during August in Vacaville, CA, and records indicate that the average summer 

temperatures in Vacaville are very similar to summer temperatures found in the Central 

Valley. 

The annual compost VOC emission factor developed from the studies are intended to 

be representative of average annual emissions rather than peak daily emissions. The 

studies that were determined to be suitable for developing VOC emission factors are 

actually very representative of seasonal variation throughout the year with testing 

performed in the spring (Site X testing in March), autumn to early winter (CIWMB, 

Modesto testing in October - December), and summer (NorCal testing in August). 

Summary of Comments from ERM on behalf of Norcal Waste Systems, Inc. Note that 

this letter includes comments on both the emission factor report and the rulemaking 

process. Only those comments on the emission factor report are presented here: 

ERM 1: The data is limited. 

Response: The District agrees that the data is limited, but the purpose of this report was 

to find all studies that were robust enough to be considered useful in determining an 

emission factor. The resulting emission factor is based on the best science available at 

the time. 

ERM 2: Limited duration of testing. Site X only one day of testing. Also, Modesto study 

was recalculated, and did not include stockpiles. 

Response: Regarding the one day of testing at Site X: While all sampling was 

conducted on one day, piles of different ages were sampled in order to obtain flux 

measurements throughout the life of a pile. Regarding the recalculation of the Modesto 

Study and lack of stockpile emissions – see responses to CPRE comments 2 and 1, 

above. 

ERM 3: The emissions data are extremely variable. There appeared to be no attempt 

to account for temporal variations throughout the composting cycle in deriving "average" 
Green Waste Compost EF Report 

September 15, 2010 

14

emission factors. There is insufficient documentation provided to allow for independent 

analysis of temporal or spatial factors as they relate to the reported flux rates. 

Response: The District agrees that there were limited data available that were complete 

and valid for developing emission factors given the variability of the source. However, 

the resulting emission factor is based on the best science available at the time. Each 

individual study used in the report accounted for the variation throughout the 

composting process. The individual emission factors from each study referenced in the 

report were developed from emission measurements for different stages throughout 

complete composting cycle at each site. Additional information on the time and location 

of emission measurements is available in the original study reports referenced. 

ERM 4: The data from the green waste report should not be averaged for the purpose 

of developing emission factors for regulatory purposes. 

Response: The average emission factors are based on the best science available at the 

time for calculating VOC emissions from composting.

ERM 5: The data from the green waste report should not be averaged for the purpose 

of calculating annual emissions. There is insufficient documentation provided in the 

report to allow for an independent analysis of the data relative to the type of composting 

operation, throughput, size of piles, and length of composting cycle. 

Response: See response to ERM comment 4, above. Additional information on each 

composting operation is available in the original study reports referenced. 

ERM 6: The impact of compost process temperature on emissions should be 

considered. It is ERM's professional judgment that temperature variations relate more 

to the time in the composting cycle than seasonal variation in ambient temperature. No 

information was given in the green waste report as to the location of temperature 

measurements. 

Response: The individual emission factors from each study referenced in the report 

were developed from emission measurements at different stages throughout the 

composting cycle at each site, which accounts for temperature variation of the piles 

during the composting process. Additional information on temperature measurements 

may be available in the original study reports referenced. 

 

ERM 7: The emissions released during turning of windrows were not addressed in the 

green waste report. 

Response: The District is not aware of any studies that measured emissions released 

during turning of windrows. If additional information becomes available on emissions 

released during turning of composting windrows, the District will review this information 

and incorporate it if appropriate. Based on discussions with Dr. Schmidt, elevated 

emissions have been measured from windrows immediately after turning but only for a 
Green Waste Compost EF Report 

September 15, 2010 

15

few hours, at most, and would not be significant over the life cycle of well-managed 

composting operations. 

ERM 8: Data presented for Site X as well as the South Coast Air Quality Management 

District (SCAQMD) data yielded higher emissions from stockpiles than from the 

windrows, which ERM considers unlikely. 

Response: The District surveyed the green waste composting facilities in the San 

Joaquin Valley. The result of the survey indicates an average stockpile time of 3.85 

days, and ranged from 0-21 days. The Site X stockpile EF was based on sampling at 

day 45, and is not representative of stockpiling in the San Joaquin Valley. The Site X 

stockpile test will not be included in the stockpile EF since it is not representative of SJV 

stockpiling. The SCAQMD stockpile data is considered as some of the most relevant 

green waste composting data available according to the green waste report. The 

SCAQMD samples were taken on a very representative day 2 stockpile. These 

emission measurements were conducted under conditions that were representative of 

conditions found during actual operations and are considered representative of 

emissions from these operations. 

ERM 9: The green waste report states that the Norcal data exhibits a VOC "spike" in 

emissions during the first few days of composting. It is ERM's experience from green 

waste compost testing that this is very representative of the typical windrow composting 

emissions cycle. Source test documentation should be made available and analyzed 

systematically to ensure proper review of the test data and a statistical analysis of all 

test data should be performed. 

Response: The District agrees that the measured emissions spike may be 

characteristic of some types of composting operations. Additional source test 

documentation may be available in the original study reports and from agencies that 

performed the studies. 

ERM 10: The green waste report’s conclusions are based on highly variable and 

extremely limited data. The green waste report only considered data that were 

measured using SCAQMD Method 25.3. Data collected by other methods may provide 

useful relative contributions from the different unit processes and temporal variability. A 

peer review of the NorCal report prior to issuance may have provided the opportunity to 

address some of the comments in this letter. 

Response: The District agrees that there were limited data available for developing 

emission factors given the variability of the source. However, the resulting emission 

factor is based on the best science available at the time. SCAQMD Method 25.3 has 

been found to capture a higher proportion of the total VOC emissions than the other 

methods mentioned; therefore, this method was the most appropriate for development 

of VOC emissions factors. The District acknowledges that data collected by other 

methods may still be valuable for uses other than development of emission factors. The 

District agrees that peer review of reports can be valuable and is generally desirable 
Green Waste Compost EF Report 

September 15, 2010 

16

when time and resource constraints allow. However, the NorCal report was created for 

another District, the Yolo-Solano APCD, and District source tests are typically not peer 

reviewed. 

Summary of Comments from California Integrated Waste Management Board (CIWMB), 

now know as Department of Resources Recycling and Recovery (CalRecycle):

CIWMB 1: The green waste report states that the emission factors from each study are 

averaged for reference only with no implication that the average is representative of 

green waste compost emissions in the San Joaquin Valley. If the average is not 

representative of green waste compost emissions, it should not be displayed. 

Response: The report does not state that the average emission factors are not 

representative of green waste compost emissions, but is based on a limited data set 

from studies suitable for developing emission factors. The average emission factors are 

presented for reference purposes, per District request, and are based on the best 

science available at the time to calculate annual emissions from green waste 

composting. The District will base the final EF on the average of valid, representative 

test data. As more relevant data becomes available, the EF should be adjusted 

accordingly. 

CIWMB 2: The weighted average of the three studies based on number of samples 

presents a better starting point for negotiations of the green waste composting 

emissions factors. 

Response: Each study at the different composting sites was found to have sufficient 

measurements for the purpose of generating valid emission factors; therefore, each 

study is weighted equally to capture the variability of composting operations. The 

District used the best scientific information available to develop the green waste 

composting emission factor and is willing to evaluate and discuss any additional 

scientific information presented related to the emission factor. 

CIWMB 3: The report states "The data are even more diverse than this table may 

indicate." A reasonable interpretation of this comment and the one above is that there is 

too little data to formulate an emissions factor applicable to composting facilities in the 

San Joaquin Valley. 

Response: The District understands this comment to refer to the variation in daily 

emissions throughout the composting cycle, which is not clearly evident when 

presenting the single overall emission factors for each site. This interpretation is 

supported by the fact that immediately after this comment the report refers to a figure 

showing daily compost windrow emissions. Also see responses to ERM comment 1, 

above. 
Green Waste Compost EF Report 

September 15, 2010 

17

CIWMB 4: The spike in VOC emissions at the NorCal site may be an outlier since it is 

based on one flux sample. The District and Dr. Schmidt should review the Day 3 NorCal 

sampling event to determine whether there are other confounding circumstances. 

Response: Other composting studies have also shown an initial increase in emissions 

during the composting cycle (see referenced report on Tierra Verde Industries 

composting operation and ERM comment 7, above). There is no indication in the report 

that the measured emission point was an outlier and comparatively high emissions were 

also measured on day 6 of the composting operation.

CIWMB 5: Is Figure 2.1 based on actual measured data or is it figurative? 

Response: Figure 2.1 of the report is based on actual data from the NorCal composting 

site. 

CIWMB 6: Figure 2.2 appears to be identical to Figure ES 2 on page 4. 

Response: The District agrees. 

CIWMB 7: We question whether there is enough data to support the contention that 

smaller windrows increase emissions. It seems more reasonable that emissions will 

correlate with the amount of materials in the windrow and operational factors and this is 

the rationale for having an emissions factor. Assuming that similar materials have 

similar potential emissions, a smaller windrow might have higher emissions earlier in the 

process but these emissions should trail off more rapidly. 

Response: The report states that “For the same unit surface flux rate, the smaller row 

will have twice the emissions on a per ton input basis.” This is true. As long as the 

surface flux rates remain the same, smaller windrows will have greater emissions on a 

per ton basis. However, the District agrees that the flux rate for the smaller windrow 

would likely decline more rapidly resulting in similar emissions on a per ton basis. 

CIWMB 8: We believe we can identify Site X and believe the site receives overflow 

green waste from San Francisco and the East Bay and may include some food waste. 

Therefore, it is possible that the Site X data is more representative of food waste 

composting than green waste composting. 

Response: The technical memorandum for the study performed at Site X did not 

indicate that the composting piles that were tested at the site included food waste. The 

District’s understanding is that the piles at Site X that were tested did not include food 

waste. The District but will evaluate any evidence that conclusively demonstrates that 

this was not the case at the time of testing. 

CIWMB 9: The report states that the CIWMB Modesto study consisted of 36 

measurements. The CIWMB Modesto data set consists of 100 flux chamber samples 

and 9 quality control samples. 
Green Waste Compost EF Report 

September 15, 2010 

18

Response: The District agrees that the complete CIWMB Modesto data set consists of 

100 flux chamber samples, including emission measurements from green waste 

composting, food waste composting, composting with a pseudo-biofilter cover, and 

composting with chemical additives. Only the 36 emission measurements from 

uncontrolled green waste composting were considered in this section of the report since 

the purpose was to evaluate emissions studies for use in developing an emission factor 

for uncontrolled green waste composting. 

CIWMB 10: The report states that there is no baseline data for food waste composting. 

The CIWMB Modesto study includes an emissions profile for an uncontrolled windrow of 

85% green waste and 15% food waste. 

Response: The District agrees that the CIWMB Modesto study may provide useful 

information on VOC emissions from composting operations that include some food 

waste. 

CIWMB 11: We question the assumptions and procedures used to recalculate the 

emissions reported in the CIWMB Modesto study report. 

Response: See response to CPRE comment 2, above. 

CIWMB 12: Have the results of the emissions study test at Site X been finalized? 

Response: These results have been finalized. 

CIWMB 13: What is Site Z and why is that data blacked out? 

Response: Site Z is a composting operation in California. The Green waste report only 

included data that was provided to the District. Site Z was not evaluated in the report 

because this information was not included in the composting emission studies provided 

to the District from the responsible government agency. Additionally, the report authors 

indicated that the emissions information was from an older study and this operation was 

not considered to be representative of current composting practices. 

CIWMB 14: What is the basis for the daily throughput number for Site X? This number 

appears to be less than we expect.

Response: The basis of this number is information reported from the facility. 

CIWMB 15: Table 3 in the report for Site X indicates that the average age of the 

feedstock piles is 45 days. We believe that this feedstock pile is anaerobic. If 

anaerobic materials are used to create windrows, initial emissions may be expected to 

be higher.

Response: While this may be the case, the resulting windrow VOC EF at Site X, 6.30 

lb/ton, is very close to the NorCal windrow VOC EF of 5.65 lb/ton, and less than the 
Green Waste Compost EF Report 

September 15, 2010 

19

Zamora windrow VOC EF of 10.03 lb/ton. As such, the emission measurements at Site 

X are considered representative of emissions from green waste windrows. 

CIWMB 16: We believe the emissions factors developed from the studies at Site X and 

NorCal are skewed high because of high wind speed, low sample count, inclusion of 

food waste, and small windrow piles. 

Response: See responses to CIWMB comments 7, 8, and 15 and ERM comments 1 

and 2, above. 
Green Waste Compost EF Report 

September 15, 2010 

20

Appendix C 

“Northern Recycling Zamora Compost Facility Air Emissions Source Test”, by Thomas 

R. Card and Charles E. Schmidt, May 2009 
Northern Recycling

Zamora Compost Facility

Baseline Air Emissions Assessment

Air Emissions Source Test

Evaluation of Complete Compost Cycle VOC and Ammonia Emissions

Report

Revision 2

May 2009

Prepared by

Thomas R. Card, PE

Environmental Management Consulting

41125 278th Way SE, Enumclaw, WA 98022

360-802-5540 Fax: 360-802-5541

E-Mail: trcard@earthlink.net

Charles E. Schmidt, PhD

19200 Live Oak Road, Red Bluff, CA 96080

530-529-4256 Fax:530-529-4878
Contents 

EXECUTIVE SUMMARY ............................................................................................................................. 1

1.0 INTRODUCTION .............................................................................................................................. 4

2.0 PROCESS DESCRIPTION AND SAMPLING ......................................................................................... 4

3.0 SAMPLING RESULTS ........................................................................................................................ 6

4.0 EMISSIONS CALCULATIONS............................................................................................................. 9

4.1 COMPOST PILE CONFIGURATION ................................................................................................................. 9

4.2 FULL COMPOST CYCLE SIMULATION............................................................................................................ 11

4.4 SIMULATED EMISSIONS PROFILE ................................................................................................................ 11

4.5 EMISSIONS FROM FEEDSTOCK AND PRODUCT STORAGE .................................................................................. 13

Appendices

A Full Cycle Simulation Table

B Photographs

C Data Validation Technical Memorandum

Tables

Table ES-1a. Calculated VOC and NH3 emissions from the feedstock storage, compost cycle, 

and finished product storage (with winery waste).

Table ES-1b. Calculated VOC and NH3 emissions from the feedstock storage, compost cycle, 

and finished product storage (without winery waste).

Table ES-2. Comparative greenwaste compost emissions (from SJVAPCD).

Table 2.1 Amount of Material Assumed to be on Site for Baseline Emissions Estimate

Table 3.1a Summary of Event 1 sampling results (compost with winery waste).

Table 3.1b Summary of Event 2 sampling results (compost without winery waste).

Table 4.1. Compost Windrow Dimensions and Calculations.

Table 4.2a. Event 1 Feedstock emission calculations (with winery waste).

Table 4.2b. Event 2 Feedstock emission calculations (without winery waste).

Table 4.3. Finished product storage emission calculations.

Figures

Figure 1.1 Site Vicinity Map

Figure 4.1 Compost Windrow Configuration.

Figure 4.2 Simulated VOC Emissions Profile (per windrow). 

Figure 4.3 Simulated NH3 Emissions Profile (per windrow). 
1

Executive Summary

This report documents the completed project of assessing baseline air emissions for the 

new Northern Recycling greenwaste composting facility located near Zamora, California.

This report contains the results of two sampling events. The first event was completed in 

October 2008 and included winery waste in the compost mix. The second event was 

completed in April 2009 with no winery waste present. USEPA flux chamber samples 

were taken from actual compost operations to provide unit emissions data that were used 

to complete the calculation of full scale annual emissions for VOC and ammonia. All 

sampling and analysis were completed in compliance with the source test protocol 

document previously submitted to Yolo-Solano APCD.

Emissions were calculated based on a simulation of a full 80 day compost cycle by 

sampling key process days and interpolating the emissions between those days. Three 

mixing cycle events were sampled during the first event and mixing was found to be a 

significant contributor to emissions.

Table ES-1a and ES-1b summarizes the results of this baseline emissions assessment. 

The measured compost emission factor for compost with winery waste of 16.55 # VOC 

per ton of composting material is substantially higher than the most comparable 

previously measured values (5.65 # and 6.3 # VOC per ton compost mix) reported by the 

San Joaquin Valley APCD (see Table ES-2). The factor without winery waste was 10.03 

# VOC per ton of compost mix.

Total site emissions for VOC were 3,030 tons per year with about two thirds of that 

attributed to the emissions from the feedstock stockpile for compost with winery waste. 

Total site emissions for VOC were 1,070 tons per year with about one half of that 

attributed to the emissions from the feedstock stockpile for compost without winery 

waste. The annual emissions calculations were based on 100,000 tons per year of 

throughput. No attempt was made in this report to prorate actual annual emissions based 

on the presence or absence of winery waste.

A concern about this data set are the extremely low ammonia emissions from Event 1 

when winery waste was present. The emissions on this site are over an order of 

magnitude lower than comparable facilities. Most of the ammonia samples were below 

the method detection limit. The method detection limit for ammonia for this project was 

typically between 0.2 and 0.4 mg/m3. These are very low detection limits, about a factor 

of three lower than most SCAQMD Method 207.1 method detection limits. No other 

comments or explanations are offered for this with the exception that the ammonia 

sampling and analysis was in full compliance with the QA/QC program and the 

laboratory samples agreed with the field screening samples. The ammonia emissions 

without winery waste, however, were essentially the same as other greenwaste compost 

facilities.
2

Table ES-1a. – Calculated VOC and NH3 emissions from the feedstock storage, compost 

cycle, and finished product storage (with winery waste).

Table ES-1b. – Calculated VOC and NH3 emissions from the feedstock storage, compost 

cycle, and finished product storage (without winery waste).

Mass on 

Site

Emission 

Factor

Total 

Emissions

Emission 

Factor

Total 

Emissions

Source (tons) (pounds/ton) (Tons/year) (pounds/ton) (Tons/year)

Feedstock Storage 27,000 44.03 2,201 0.017 0.94

Composting 20,000 16.55 828 0.011 0.573

Product Storage 3,000 0.02 1.2 0.0004 0.014

Total 50,000 3,030 1.52

Overall Emission Factor (#/ton) 60.61 0.030

VOC Ammonia

Mass on 

Site

Emission 

Factor

Total 

Emissions

Emission 

Factor

Total 

Emissions

Source (tons) (pounds/ton) (Tons/year) (pounds/ton) (Tons/year)

Feedstock Storage 27,000 11.34 567 1.643 89.93

Composting 20,000 10.03 502 0.445 22.236

Product Storage 3,000 0.02 1.2 0.0004 0.014

Total 50,000 1,070 112.18

Overall Emission Factor (#/ton) 21.40 2.244

VOC Ammonia
3

Table ES-2. – Comparative greenwaste compost emissions (from SJVAPCD).

EF EF

Location Material Activity (#/ton) Peak Avg Min Peak Avg Min (#/ton) Peak Avg Min Peak Avg Min

Site X Stockpiles 7.76 186 111 37 2.30 1.38 0.46 0.03 0.62 0.39 0.16 0.01 0.00 0.002

Windrows 6.30 23 11 3 0.29 0.13 0.04 2.34 26.56 12.07 0.20 0.33 0.15 0.003

Total 14.06 2.37

Windrows 1.54 42 9 0.1 0.51 0.11 0.001

`

NorCal Stockpiles 2.95 110 54 4 1.36 0.66 0.046 0.08 2.1 1.21 0.61 0.03 0.01 0.008

Windrows 5.65 376 73 1 4.65 0.90 0.010 0.54 7.29 1.68 0.22 0.09 0.02 0.003

Total 8.60 0.62

CIWMB TV Mix HCN 124 42 2 1.53 0.52 0.02

Mix LCN 443 110 1 5.48 1.36 0.02

UnMix HCN 23 6 1 0.28 0.07 0.01

UnMix LCN 38 10 1 0.47 0.13 0.01

Stockpiles 4.75 24 0.30 0.01 6.55 0.081

Windrows 0.3 6 0.08 1.31 0.32 0.004

Total 5.05 1.32

Stockpiles 1.96 20 0.25 0.29 2.67 0.033

Windrows 0.5 6 0.08 0.03 0.32 0.004

Total 2.47 0.32

Unit Flux (mg/minm2)Unit Flux (mg/minm2)

VOC NH3

Unit Flux (#/hr1,000ft2)Unit Flux (#/hr1,000ft2)

SCAQMD 

Inland 

Winter

Landscape 

Waste

CIWMB 

Modesto

SCAQMD 

Inland 

Summer
4

1.0 Introduction

This project directly measured the VOC and ammonia air emissions from greenwaste 

composting to develop a baseline air emissions value for a full compost/cure cycle plus 

feedstock and product storage. All compost operations were located at the Northern 

Recycling Compost Facility in Zamora, CA as shown in Figure 1.1.

Figure 1.1 Site Vicinity Map

2.0 Process Description and Sampling

This is a new compost facility that composts greenwaste material into a high value 

landscaping material. Compost is received in a stockpile. The stockpiled material is then 

ground and placed into windrows. The windrows are mechanically mixed approximately 

20 times during an 80 day composting cycle. The windrows are then broken down and 

screened into the final product. The site is permitted to have a total of 50,000 tons of 

material on site. Table 2.1 shows the amount of material assumed to be on site for the 

baseline emissions assessment.

Zamora Site
5

Table 2.1 Amount of Material Assumed to be on Site for Baseline Emissions Estimate

The sampling and analysis was conducted in compliance with the document entitled 

PROTOCOL FOR FLUX CHAMBER SOURCE TESTING OF FUGITIVE AIR 

EMISSIONS FROM THE NORTHERN RECYCLING COMPOST (NRC) ZAMORA 

FACILITY, plus a supplemental protocol for the second event, that was previously 

submitted to the Yolo-Solano APCD.

All sampling took place between October 28 and 30, 2008 for the first event (compost 

with winery waste) and on April 12, 2009 (compost without winery waste). All surface 

samples were taken using USEPA Surface Isolation Emission Flux Chamber technology 

per the source test protocol. Total VOC was analyzed per SCAQMD Method 25.3 and 

ammonia was measured per SCAQMD Method 207.1. The technical memorandum in 

Appendix C presents a summary of data validation, project documentation, and 

laboratory methods used for this project.

The following compost operations were sampled:

Event 1

1. Incoming feedstock (12 samples)

2. Compost Day 1 (4 samples)

3. Compost Day 3 (4 samples)

4. Compost Day 3 Mixing Event (4 samples)

5. Compost Day 7 (4 samples)

6. Compost Day 15 (4 samples)

7. Compost Day 15 Mixing Event (4 samples)

8. Compost Day 29 (4 samples)

9. Compost Day 29 Mixing Event (4 samples)

10. Compost Day 63 (4 samples)

11. Finished product (4 samples)

Event 2

1. Incoming feedstock (4 samples)

2. Compost Day 1 (2 samples)

3. Compost Day 5 (4 samples)

4. Compost Day 8 (2 samples)

5. Compost Day 16 (2 samples)

6. Compost Day 31 (2 samples)

Material

Total Tons 

on Site

Feedstock Storage 27,000

Composting 20,000

Product Storage 3,000

Total Tons 50,000
6

3.0 Sampling Results

Figure 3.1a presents of a summary of sampling results for Event 1. The appendix 

contains complete sampling data. Note that the vast majority of the ammonia data points 

had no ammonia detected. The typical ammonia detection limit for this project was 

between 0.2 and 0.4 mg/m3.

Figure 3.1b presents a summary of sampling results for Event 2. This data was typical or 

previous greenwaste compost sampling events at other facilities.
7

Table 3.1a Summary of Event 1 sampling results (compost with winery waste).

SOURCE TEST CONDITION VOC NH3 COMMENT

Flux Flux

Windrow- Day 1 T1 282 0.0131 Windrow- Day 1 

Windrow- Day 1 T2 79.2 0.0130

Windrow- Day 1 S1 136 0.0157

Windrow- Day 1 Replicate 33.5 0.0174 Replicate

Windrow- Day 1 S2 11.2 0.0104

Windrow- Day 3 T1 453 0.0219 Windrow- Day 3

Windrow- Day 3 T2 36.9 0.0227

Windrow- Day 3 S1 16.1 0.0179

Windrow- Day 3 S2 35.8 0.0232

Windrow- Day 3 Post Mix, T1- Hour 0 1631 0.0232 Post Mix, T1- Hour 0

Windrow- Day 3 Post Mix, S1- Hour 0 742 0.0171 Post Mix, S1- Hour 0

Windrow- Day 3 Post Mix, T1- Hour 4 724 0.0187 Post Mix, T1- Hour 4

Windrow- Day 3 Post Mix, S1- Hour 4 254 0.0231 Post Mix, S1- Hour 4

Windrow- Day 7 T1 148 0.108 Windrow- Day 7

Windrow- Day 7 T2 764 0.0233

Windrow- Day 7 S1 4.52 0.0418

Windrow- Day 7 S2 1.81 0.0245

Windrow- Day 15 T1 5.72 0.0332 Windrow- Day 15

Windrow- Day 15 T2 26.5 0.0401

Windrow- Day 15 S1 2.36 0.0266

Windrow- Day 15 S2 2.65 0.0236

Windrow- Day 15 Replicate 1.30 0.0257 Replicate

Windrow- Day 15 Post Mix, T2- Hour 0 56.0 0.0244 Post Mix, T2- Hour 0

Windrow- Day 15 Post Mix, S2- Hour 0 6.82 0.0250 Post Mix, S2- Hour 0

Windrow- Day 15 Replicate 9.46 0.0246 Replicate

Windrow- Day 15 Post Mix, T2- Hour 4 40.1 0.0252 Post Mix, T2- Hour 4

Windrow- Day 15 Post Mix, S2- Hour 4 6.29 0.0222 Post Mix, S2- Hour 4

Windrow- Day 29 T1 0.454 0.0155 Windrow- Day 29

Windrow- Day 29 T2 1.10 0.0192

Windrow- Day 29 S1 0.645 0.0151

Windrow- Day 29 S2 0.381 0.00782

Windrow- Day 29 Post Mix, T2- Hour 0 27.4 0.0301 Post Mix, T2- Hour 0

Windrow- Day 29 Post Mix, S1- Hour 0 4.39 0.0216 Post Mix, S1- Hour 0

Windrow- Day 29 Post Mix, T2- Hour 4 15.4 0.0369 Post Mix, T2- Hour 4

Windrow- Day 29 Post Mix, S1- Hour 4 3.95 0.0245 Post Mix, S1- Hour 4

Windrow- Day 63 T1 0.955 0.0141 Windrow- Day 63

Windrow- Day 63 T2 0.671 0.00994

Windrow- Day 63 S1 0.223 0.0108

Windrow- Day 63 S2 0.507 0.0137

Tipping- Old T1 6.91 0.0290 Tipping- Old

Tipping- Old T2 1.33 0.0229

Tipping- Old T3 7.10 0.0241

Tipping- Old T4 7.54 0.0204

Tipping- Middle Age T1 3.82 0.0387 Tipping- Middle Age

Tipping- Middle Age T2 6.97 0.529

Tipping- Middle Age T3 3.13 0.0702

Tipping- Middle Age Replicate 2.61 0.0718 Replicate

Tipping- Middle Age T4 2.40 0.272 Tipping- New

Tipping- New T1 308 0.0399

Tipping- New T2 153 0.0452

Tipping- New T3 882 0.0202

Tipping- New Replicate 848 0.0302 Replicate

Tipping- New T4 743 0.0293

Fresh Product- Day 1 T1 1.13 0.0123 Fresh Product- Day 1

Fresh Product- Day 1 T2 1.48 0.00687

Aged Product- Day 60 S1 0.220 0.00876 Aged Product- Day 60

Aged Product- Day 60 S2 2.83 0.0400

QC Blank 0.139 0.00342 QC- Blank

QC Blank 0.137 0.00342

QC Blank 0.112 0.00440

QC Blank 0.0929 0.00440

QC Blank 0.0736 0.00440

Flux Unit: mg/m2,min-1

Note 1- Methane Flux = (CH4 ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 CH4

Note 2- TNMNEO Flux = (TNMNEO ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 TNMNEO

Note 3- Ammonia Flux = (NH3 mg/m3)(m3/min)/(0.13 m2) = mg/m2,min-1 NH3

Note 4- Total Flow = (Helium %/Helium % recovered)(0.005 m3/min) = m3/min total flow

Note 5- MDL value used for ND or non-detect for calculation purposes
8

Table 3.1b Summary of Event 2 sampling results (compost without winery waste).

SOURCE TEST CONDITION VOC NH3 COMMENT

Flux Flux

Tipping Day 1, T1 166 16 Tipping Pile, Day 1

Tipping Day 1, S1 14 6.7 Tipping Pile, Day 1

Tipping Day 7, T1 17 5.7 Tipping Pile, Day 7

Tipping Day 7, S1 7.8 4.3 Tipping Pile, Day 7

Tipping Replicate 7.7 4.1 Replicate Sample

Compost Day 1, S1 83 1.6 Day 1

Compost Day 1, T1 27 0.26 Day 1

Compost Day 5, S1 15 1.9 Day 5

Compost Day 5, T1 242 13 Day 5

Compost Day 8, S1 2.4 0.078 Day 8

Compost Day 8, T1 157 2.5 Day 8

Compost Day 8, S2 1.5 0.26 Day 8

Compost Day 8, T2 131 5.0 Day 8

Compost Day 16, S1 1.3 0.15 Day 16

Compost Day 16, T1 9.4 2.56 Day 16

Compost Day 31, S1 3.0 0.17 Day 31

Compost Day 31, T1 1.0 0.17 Day 31

QC Blank 0.025 0.0031 99.4% Recovery of helium tracer

Flux Unit: mg/m2,min-1

Note 1- Methane Flux = (CH4 ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 CH4

Note 2- TNMNEO Flux = (TNMNEO ppmv)(0.653)(m3/min)/0.13 = mg/m2,min-1 TNMNEO

Note 3- Ammonia Flux = (NH3 mg/m3)(m3/min)/(0.13 m2) = mg/m2,min-1 NH3

Note 4- Total Flow = (Helium %/Helium % recovered)(0.005 m3/min) = m3/min total flow

Note 5- MDL value used for ND or non-detect for calculation purposes
9

4.0 Emissions Calculations

4.1 Compost Pile Configuration

The windrow compost operation consisted of placing ground greenwaste feedstock in a 

windrow for 80 days. Figure 4.1 shows the typical windrow cross-section for windrow 

composting as well as the formulas used to compute volume and exposed surface area. 

Each windrow initially contained about 320 tons of material. Table 4.1 provides the 

windrow dimensions and calculations.

Figure 4.1. – Compost Windrow Configuration.

Length

Top Width

Bottom Width



2

2

1 2 1 2

2

1 2

(( )/ 2)

3

( )

2

h WB WTs

h A A A A

V

s A

p p

S

  

 









Mensuration formulas

where S = total surface area, p 1 = bottom

perimeter, p 2 = top perimeter, s = slant height,

V=volume, h=vertical height, A 1 = bottom area,

A2 = top area,  = bottom angle
10

Table 4.1. – Compost Windrow Dimensions and Calculations.

Property Units Value

Length ft 455

Height ft 4.5

Bottom Width ft 14

Top Width ft 7.0

Top Length ft 448

alpha R 0.91

o 52

Top Perimeter ft 910

Top Area ft2 3,136

Bottom Perimeter ft 938

Bottom Area ft2 6,370

Slant height ft 5.7

Surface Area ft2 8,404

m2 785

Volume ft3 20,963

yd3 776

Conversion Factors ft2/m2 10.7

ft3/yd3 27

Top Area Ratio 0.373173

Density #/yd3 823

#/ft3 30.5

Mass # 638,990

ton 319

Mensuration frmulas

Mensuration frmulas



2

2

1 2 1 2

2

1 2

( ( ) / 2)

3

( )

2

h WB WTs

h A A A A

V

s A

p p

S

  

 









M e nsuration formulas

w here S = total surface area, p1 = bottom

perimeter, p 2 = top perimeter, s = slant height,

V=volume, h=vertical height, A 1 = bottom area,

A2 = top area,  = bottom angle
11

4.2 Full Compost Cycle Simulation

The unit emission data was extended to estimate emissions from the full compost cycle 

using linear interpolation and averaging, as noted in Section 2, above. 

Full cycle emissions for each day of the compost process, are then added and the sum of 

the individual daily emissions are totalized. Consistent with the approved protocol, the 

emission factor consists of the full total (in pounds) cycle emissions divided by the 

incoming feedstock weight (in tons). The full site emissions are then calculated be 

multiplying the annual throughput of material by this calculated emission factor. The 

simulation data tables are provided in the Appendix.

4.4 Simulated Emissions Profile

Figure 4.2 and 4.3 presents the full cycle emissions profile developed for VOC and 

ammonia. These emissions profiles were developed using a combination of data 

averaging and linear interpolation between the data points. The spikes on the graphs are 

due to mixing events. Three mixing events were measured and mixing was found to be a 

significant contributor to emissions.

Figure 4.2 Simulated VOC Emissions Profile (per windrow). 

0

100

200

300

400

500

600

700

800

1 4 7 1 0 1 3 1 6 1 9 2 2 2 5 2 8 3 1 3 4 3 7 4 0 4 3 4 6 4 9 5 2 5 5 5 8 6 1 6 4 6 7 7 0 7 3 7 6 7 9

# of Emissions per Day

Compost Process Day

Event 1 (with winery 

waste)

Event 2 (without winery 

waste)
12

Figure 4.3 Simulated NH3 Emissions Profile (per windrow). 

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

9.00

10.00

1 4 7 1 01 31 61 92 22 52 83 13 43 74 04 34 64 95 25 55 86 16 46 77 07 37 67 9

# of Emissions per Day

Compost Process Day

Event 1 (with winery 

waste)

Event 2 (without winery 

waste)
13

4.5 Emissions from Feedstock and Product Storage

Table 4.2a, 4.2b, and 4.3 present the VOC and ammonia emission calculations while

feedstock is being stored prior to windrowing and from finished compost product storage. 

The product emissions were assumed to be the same for the winery waste and non-winery 

waste compost product.

Table 4.2a. – Event 1 Feedstock emission calculations (with winery waste).

Mass 300 tons/day

Density 443 #/yd3

16.4 #/ft3

Storage Duration 90 day

Total Tons Stored 27,000 tons

Pile Volume 121,896 yd3

3,291,196 ft3

Pile shape Frustrum

Pile Height 20 feet

Pile Length 577

Pile Width 300

Pile Area 173,208 feet

Slant Height 28

Pile Area 204,560 ft2

19,118 m2

VOC NH3

Unit Emissions 198.74 0.084 mg/min-m2

Total Emissions 5,471,153 2,326 gms/day

12,063 5.1 pounds/day

2,201 0.9 tons/year

Emission Factor 44.03 0.01709 pounds/ton
14

Table 4.2b. – Event 2 Feedstock emission calculations (without winery waste).

Mass 300 tons/day

Density 443 #/yd3

16.4 #/ft3

Storage Duration 90 day

Total Tons Stored 27,000 tons

Pile Volume 121,896 yd3

3,291,196 ft3

Pile shape Frustrum

Pile Height 20 feet

Pile Length 577

Pile Width 300

Pile Area 173,208 feet

Slant Height 28

Pile Area 204,560 ft2

19,118 m2

VOC NH3

Unit Emissions 51.19 8.118 mg/min-m2

Total Emissions 1,409,351 223,497 gms/day

3,107 492.8 pounds/day

567 89.9 tons/year

Emission Factor 11.34 1.64254 pounds/ton
15

Table 4.3. – Finished product storage emission calculations (used for both winery and 

non-winery waste containing compost).

Mass 200 tons/day

Density 1123 #/yd3

41.6 #/ft3

Storage Duration 15 day

Total Tons Stored 3000 tons

Pile Volume 5,343 yd3

144,256 ft3

Pile shape Frustrum

Pile Height 20 feet

Pile Length 90

Pile Width 100

Pile Area 8,977 feet

Slant Height 28

Pile Area 15,186 ft2

1,419 m2

VOC NH3

Unit Emissions 1.42 0.017 mg/min-m2

Total Emissions 2,894 35 gms/day

6 0.08 pounds/day

1 0.014 tons/year

Emission Factor 0.02 0.00038 pounds/ton
Appendix A

Full Cycle Simulation Table
Table A1a VOC Cycle Simulation Calculations for Event 1

Unit Flux (mg/min-m2) UF Area Daily Emissions

Compost 

Day Top Side Total Mix

(mg/mm2) (m2) (mg) (#)

1 181 60 105 2.1 221 785 249,958,006 551

2 213 43 107 1 107 785 120,450,583 266

3 245 26 108 1 108 785 121,873,545 269

4 298 20 124 1.9 235 785 266,173,572 587

5 351 15 140 1 140 785 158,309,162 349

6 403 9 156 1 156 785 176,526,971 389

7 456 3 172 1.7 293 785 331,066,126 730

8 401 3 152 1 152 785 171,472,778 378

9 346 3 131 1 131 785 148,200,776 327

10 291 3 110 1.6 177 785 199,886,039 441

11 236 3 90 1 90 785 101,656,773 224

12 181 3 69 1.6 111 785 125,415,633 277

13 126 3 49 1 49 785 55,112,769 122

14 71 3 28 1 28 785 31,840,767 70

15 16 3 8 1.5 11 785 12,853,148 28

16 15 2 7 1 7 785 8,006,131 18

17 14 2 7 1 7 785 7,443,497 16

18 13 2 6 2 12 785 13,761,725 30

19 12 2 6 1 6 785 6,318,228 14

20 11 2 5 1 5 785 5,755,594 13

21 10 2 5 2.5 11 785 12,982,399 29

22 8 2 4 1 4.1 785 4,630,326 10

23 7 1 4 1 3.6 785 4,067,691 9

24 6 1 3 3 9.3 785 10,515,171 23

25 5 1 3 1 2.6 785 2,942,423 6

26 4 1 2 1 2.1 785 2,379,789 5

27 3 1 2 3.5 5.6 785 6,360,040 14

28 2 1 1 1 1.1 785 1,254,520 2.8

29 0.8 0.5 1 4.7 2.9 785 3,251,863 7.2

30 0.78 0.51 0.61 1 0.6 785 689,246 1.5

31 0.78 0.50 0.61 1 0.6 785 686,606 1.5

32 0.78 0.50 0.60 1 0.6 785 683,967 1.5

33 0.78 0.50 0.60 4 2.4 785 2,725,308 6.0

34 0.78 0.49 0.60 1 0.6 785 678,687 1.5

35 0.78 0.49 0.60 1 0.6 785 676,048 1.5

36 0.78 0.48 0.60 1 0.6 785 673,408 1.5

37 0.79 0.48 0.59 3 1.8 785 2,012,305 4.4

38 0.79 0.47 0.59 1 0.6 785 668,129 1.5

39 0.79 0.47 0.59 1 0.6 785 665,489 1.5

40 0.79 0.47 0.59 1 0.6 785 662,849 1.5

41 0.79 0.46 0.58 2 1.2 785 1,320,419 2.9

42 0.79 0.46 0.58 1 0.6 785 657,570 1.4

43 0.79 0.45 0.58 1 0.6 785 654,930 1.4

44 0.79 0.45 0.58 1 0.6 785 652,290 1.4

45 0.79 0.44 0.57 1 0.6 785 649,651 1.4

46 0.80 0.44 0.57 1.5 0.9 785 970,517 2.1

47 0.80 0.43 0.57 1 0.6 785 644,371 1.4

48 0.80 0.43 0.57 1 0.6 785 641,732 1.4

49 0.80 0.43 0.57 1 0.6 785 639,092 1.4

50 0.80 0.42 0.56 1 0.6 785 636,452 1.4

51 0.80 0.42 0.56 1 0.6 785 633,813 1.4

52 0.80 0.41 0.56 1.5 0.8 785 946,759 2.1

53 0.80 0.41 0.56 1 0.6 785 628,533 1.4

54 0.80 0.40 0.55 1 0.6 785 625,894 1.4

55 0.80 0.40 0.55 1 0.6 785 623,254 1.4

56 0.81 0.40 0.55 1 0.5 785 620,614 1.4

57 0.81 0.39 0.55 1 0.5 785 617,974 1.4

58 0.81 0.39 0.54 1.5 0.8 785 923,002 2.0

59 0.81 0.38 0.54 1 0.5 785 612,695 1.4

60 0.81 0.38 0.54 1 0.5 785 610,055 1.3

61 0.81 0.37 0.54 1.5 0.8 785 911,124 2.0

62 0.81 0.37 0.53 1 0.5 785 604,776 1.3

63 0.8 0.4 0.53 1 0.5 785 602,136 1.3

64 0.81 0.37 0.53 1 0.5 785 602,136 1.3

65 0.81 0.37 0.53 1 0.5 785 602,136 1.3

66 0.81 0.37 0.53 1 0.5 785 602,136 1.3

67 0.81 0.37 0.53 1.5 0.8 785 903,205 2.0

68 0.81 0.37 0.53 1 0.5 785 602,136 1.3

69 0.81 0.37 0.53 1 0.5 785 602,136 1.3

70 0.81 0.37 0.53 1 0.5 785 602,136 1.3

71 0.81 0.37 0.53 1 0.5 785 602,136 1.3

72 0.81 0.37 0.53 1.5 0.8 785 903,205 2.0

73 0.81 0.37 0.53 1 0.5 785 602,136 1.3

74 0.81 0.37 0.53 1 0.5 785 602,136 1.3

75 0.81 0.37 0.53 1 0.5 785 602,136 1.3

76 0.81 0.37 0.53 1.5 0.8 785 903,205 2.0

77 0.81 0.37 0.53 1 0.5 785 602,136 1.3

78 0.81 0.37 0.53 1 0.5 785 602,136 1.3

79 0.81 0.37 0.53 1 0.5 785 602,136 1.3

80 0.81 0.37 0.53 1 0.5 785 602,136 1.3

Total Emissions 5,289

16.55 #/Ton
Table A1a NH3 Cycle Simulation Calculations for Event 1

Unit Flux (mg/min-m2) UF Area Daily Emissions

Compost 

Day Top Side Total Mix

(mg/mm2) (m2) (mg) (#)

1 0.01 0.01 0.01 1.1 0.02 785 17,391 0.04

2 0.02 0.02 0.02 1 0.02 785 19,897 0.04

3 0.02 0.02 0.02 1 0.02 785 23,985 0.05

4 0.03 0.02 0.03 1.1 0.03 785 33,880 0.07

5 0.04 0.03 0.03 1 0.03 785 37,615 0.08

6 0.05 0.03 0.04 1 0.04 785 44,431 0.10

7 0.07 0.03 0.05 1.1 0.05 785 56,370 0.12

8 0.06 0.03 0.04 1 0.04 785 48,999 0.11

9 0.06 0.03 0.04 1 0.04 785 46,752 0.10

10 0.05 0.03 0.04 1.1 0.04 785 48,956 0.11

11 0.05 0.03 0.04 1 0.04 785 42,258 0.09

12 0.05 0.03 0.04 1.1 0.04 785 44,013 0.10

13 0.04 0.03 0.03 1 0.03 785 37,765 0.08

14 0.04 0.03 0.03 1 0.03 785 35,518 0.08

15 0.04 0.03 0.03 1.1 0.03 785 36,598 0.08

16 0.04 0.02 0.03 1 0.03 785 31,996 0.07

17 0.03 0.02 0.03 1 0.03 785 30,720 0.07

18 0.03 0.02 0.03 1.1 0.03 785 32,390 0.07

19 0.03 0.02 0.02 1 0.02 785 28,170 0.06

20 0.03 0.02 0.02 1 0.02 785 26,894 0.06

21 0.03 0.02 0.02 1.1 0.02 785 28,181 0.06

22 0.03 0.02 0.02 1 0.02 785 24,344 0.05

23 0.03 0.02 0.02 1 0.02 785 23,069 0.05

24 0.02 0.02 0.02 1.1 0.02 785 23,973 0.05

25 0.02 0.02 0.02 1 0.02 785 20,518 0.05

26 0.02 0.01 0.02 1 0.02 785 19,243 0.04

27 0.02 0.01 0.02 1.1 0.02 785 19,764 0.04

28 0.02 0.01 0.01 1 0.01 785 16,692 0.04

29 0.02 0.01 0.01 1.1 0.01 785 16,958 0.04

30 0.02 0.01 0.01 1 0.01 785 15,367 0.03

31 0.02 0.01 0.01 1 0.01 785 15,318 0.03

32 0.02 0.01 0.01 1 0.01 785 15,269 0.03

33 0.02 0.01 0.01 1.1 0.01 785 16,742 0.04

34 0.02 0.01 0.01 1 0.01 785 15,171 0.03

35 0.02 0.01 0.01 1 0.01 785 15,122 0.03

36 0.02 0.01 0.01 1 0.01 785 15,072 0.03

37 0.02 0.01 0.01 1.1 0.01 785 16,525 0.04

38 0.02 0.01 0.01 1 0.01 785 14,974 0.03

39 0.02 0.01 0.01 1 0.01 785 14,925 0.03

40 0.02 0.01 0.01 1 0.01 785 14,876 0.03

41 0.02 0.01 0.01 1.1 0.01 785 16,309 0.04

42 0.02 0.01 0.01 1 0.01 785 14,777 0.03

43 0.02 0.01 0.01 1 0.01 785 14,728 0.03

44 0.01 0.01 0.01 1 0.01 785 14,679 0.03

45 0.01 0.01 0.01 1 0.01 785 14,630 0.03

46 0.01 0.01 0.01 1.1 0.01 785 16,038 0.04

47 0.01 0.01 0.01 1 0.01 785 14,531 0.03

48 0.01 0.01 0.01 1 0.01 785 14,482 0.03

49 0.01 0.01 0.01 1 0.01 785 14,433 0.03

50 0.01 0.01 0.01 1 0.01 785 14,384 0.03

51 0.01 0.01 0.01 1 0.01 785 14,334 0.03

52 0.01 0.01 0.01 1.1 0.01 785 15,714 0.03

53 0.01 0.01 0.01 1 0.01 785 14,236 0.03

54 0.01 0.01 0.01 1 0.01 785 14,187 0.03

55 0.01 0.01 0.01 1 0.01 785 14,138 0.03

56 0.01 0.01 0.01 1 0.01 785 14,089 0.03

57 0.01 0.01 0.01 1 0.01 785 14,039 0.03

58 0.01 0.01 0.01 1.1 0.01 785 15,389 0.03

59 0.01 0.01 0.01 1 0.01 785 13,941 0.03

60 0.01 0.01 0.01 1 0.01 785 13,892 0.03

61 0.01 0.01 0.01 1.1 0.01 785 15,227 0.03

62 0.01 0.01 0.01 1 0.01 785 13,793 0.03

63 0.0 0.0 0.01 1 0.01 785 13,744 0.03

64 0.01 0.01 0.01 1 0.01 785 13,744 0.03

65 0.01 0.01 0.01 1 0.01 785 13,744 0.03

66 0.01 0.01 0.01 1 0.01 785 13,744 0.03

67 0.01 0.01 0.01 1.1 0.01 785 15,119 0.03

68 0.01 0.01 0.01 1 0.01 785 13,744 0.03

69 0.01 0.01 0.01 1 0.01 785 13,744 0.03

70 0.01 0.01 0.01 1 0.01 785 13,744 0.03

71 0.01 0.01 0.01 1 0.01 785 13,744 0.03

72 0.01 0.01 0.01 1.1 0.01 785 15,119 0.03

73 0.01 0.01 0.01 1 0.01 785 13,744 0.03

74 0.01 0.01 0.01 1 0.01 785 13,744 0.03

75 0.01 0.01 0.01 1 0.01 785 13,744 0.03

76 0.01 0.01 0.01 1.1 0.01 785 15,119 0.03

77 0.01 0.01 0.01 1 0.01 785 13,744 0.03

78 0.01 0.01 0.01 1 0.01 785 13,744 0.03

79 0.01 0.01 0.01 1 0.01 785 13,744 0.03

80 0.01 0.01 0.01 1 0.01 785 13,744 0.03

Total Emissions 4

0.011 #/Ton
Table A1b VOC Cycle Simulation Calculations for Event 2

Unit Flux (mg/min-m2) UF Area Daily Emissions

Compost 

Day Top Side Total Mix

(mg/mm2) (m2) (mg) (#)

1 27 83 62 2.1 131 785 147,843,960 326

2 81 66 72 1 72 785 80,987,316 179

3 135 49 81 1 81 785 91,572,747 202

4 188 32 90 1.9 172 785 194,100,537 428

5 242 15 100 1 100 785 112,743,608 249

6 210 11 85 1 85 785 95,912,037 211

7 177 6 70 1.7 119 785 134,436,791 296

8 144 2 55 1 55 785 62,248,894 137

9 127 2 49 1 49 785 55,076,966 121

10 111 2 42 1.6 68 785 76,648,060 169

11 94 2 36 1 36 785 40,733,109 90

12 77 2 30 1.6 47 785 53,697,889 118

13 60 2 23 1 23 785 26,389,252 58

14 43 1 17 1 17 785 19,217,324 42

15 26 1 11 1.5 16 785 18,068,093 40

16 9 1 4 1 4 785 4,873,467 11

17 9 1 4 1 4 785 4,717,702 10

18 8 2 4 2 8 785 9,123,874 20

19 8 2 4 1 4 785 4,406,173 10

20 7 2 4 1 4 785 4,250,408 9

21 7 2 4 2.5 9 785 10,236,608 23

22 6 2 3 1 3.5 785 3,938,879 9

23 5 2 3 1 3.3 785 3,783,114 8

24 5 2 3 3 9.6 785 10,882,048 24

25 4 2 3 1 3.1 785 3,471,585 8

26 4 2 3 1 2.9 785 3,315,820 7

27 3 3 3 3.5 9.8 785 11,060,193 24

28 3 3 3 1 2.7 785 3,004,291 6.6

29 2 3 3 4.7 11.8 785 13,388,072 29.5

30 2 3 2 1 2.4 785 2,692,761 5.9

31 1.04 2.96 2 1 2.2 785 2,536,997 5.6

32 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

33 1.04 2.96 2.24 4 9.0 785 10,147,986 22.4

34 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

35 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

36 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

37 1.04 2.96 2.24 3 6.7 785 7,610,990 16.8

38 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

39 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

40 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

41 1.04 2.96 2.24 2 4.5 785 5,073,993 11.2

42 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

43 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

44 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

45 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

46 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

47 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

48 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

49 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

50 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

51 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

52 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

53 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

54 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

55 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

56 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

57 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

58 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

59 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

60 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

61 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

62 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

63 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

64 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

65 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

66 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

67 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

68 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

69 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

70 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

71 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

72 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

73 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

74 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

75 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

76 1.04 2.96 2.24 1.5 3.4 785 3,805,495 8.4

77 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

78 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

79 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

80 1.04 2.96 2.24 1 2.2 785 2,536,997 5.6

Total Emissions 3,205

10.03 #/Ton
Table A1b NH3 Cycle Simulation Calculations for Event 2

Unit Flux (mg/min-m2) UF Area Daily Emissions

Compost 

Day Top Side Total Mix

(mg/mm2) (m2) (mg) (#)

1 0 2 1.13 1.1 1.24 785 1,406,757 3.10

2 3 2 2.35 1 2.35 785 2,657,139 5.86

3 7 2 3.57 1 3.57 785 4,035,408 8.90

4 10 2 3.43 1.1 3.77 785 4,263,343 9.40

5 13 2 3.29 1 3.29 785 3,716,125 8.19

6 10 1 3.14 1 3.14 785 3,556,483 7.84

7 7 1 3.00 1.1 3.30 785 3,736,525 8.24

8 4 0 2.77 1 2.77 785 3,128,743 6.90

9 4 0 2.53 1 2.53 785 2,860,644 6.31

10 3 0 2.29 1.1 2.52 785 2,851,800 6.29

11 3 0 2.06 1 2.06 785 2,324,447 5.12

12 3 0 1.82 1.1 2.00 785 2,261,983 4.99

13 3 0 1.58 1 1.58 785 1,788,249 3.94

14 3 0 1.34 1 1.34 785 1,520,151 3.35

15 3 0 1.11 1.1 1.22 785 1,377,257 3.04

16 3 0 1.05 1 1.05 785 1,185,635 2.61

17 2 0 0.99 1 0.99 785 1,119,218 2.47

18 2 0 0.93 1.1 1.02 785 1,158,081 2.55

19 2 0 0.87 1 0.87 785 986,384 2.17

20 2 0 0.81 1 0.81 785 919,967 2.03

21 2 0 0.75 1.1 0.83 785 938,905 2.07

22 2 0 0.70 1 0.70 785 787,133 1.74

23 1 0 0.64 1 0.64 785 720,715 1.59

24 1 0 0.58 1.1 0.64 785 719,728 1.59

25 1 0 0.52 1 0.52 785 587,881 1.30

26 1 0 0.46 1 0.46 785 521,464 1.15

27 1 0 0.40 1.1 0.44 785 500,552 1.10

28 1 0 0.34 1 0.34 785 388,630 0.86

29 0 0 0.28 1.1 0.31 785 354,434 0.78

30 0 0 0.28 1 0.28 785 318,295 0.70

31 0.17 0.17 0.28 1 0.28 785 314,376 0.69

32 0.17 0.17 0.27 1 0.27 785 310,458 0.68

33 0.17 0.17 0.27 1.1 0.30 785 337,194 0.74

34 0.17 0.17 0.27 1 0.27 785 302,621 0.67

35 0.17 0.17 0.26 1 0.26 785 298,703 0.66

36 0.17 0.17 0.26 1 0.26 785 294,785 0.65

37 0.17 0.17 0.26 1.1 0.28 785 319,953 0.71

38 0.17 0.17 0.25 1 0.25 785 286,948 0.63

39 0.17 0.17 0.25 1 0.25 785 283,030 0.62

40 0.17 0.17 0.25 1 0.25 785 279,111 0.62

41 0.17 0.17 0.24 1.1 0.27 785 302,712 0.67

42 0.17 0.17 0.24 1 0.24 785 271,275 0.60

43 0.17 0.17 0.24 1 0.24 785 267,356 0.59

44 0.17 0.17 0.23 1 0.23 785 263,438 0.58

45 0.17 0.17 0.23 1 0.23 785 259,520 0.57

46 0.17 0.17 0.23 1.1 0.25 785 281,162 0.62

47 0.17 0.17 0.22 1 0.22 785 251,683 0.55

48 0.17 0.17 0.22 1 0.22 785 247,765 0.55

49 0.17 0.17 0.22 1 0.22 785 243,847 0.54

50 0.17 0.17 0.21 1 0.21 785 239,928 0.53

51 0.17 0.17 0.21 1 0.21 785 236,010 0.52

52 0.17 0.17 0.21 1.1 0.23 785 255,301 0.56

53 0.17 0.17 0.20 1 0.20 785 228,173 0.50

54 0.17 0.17 0.20 1 0.20 785 224,255 0.49

55 0.17 0.17 0.19 1 0.19 785 220,337 0.49

56 0.17 0.17 0.19 1 0.19 785 216,418 0.48

57 0.17 0.17 0.19 1 0.19 785 212,500 0.47

58 0.17 0.17 0.18 1.1 0.20 785 229,440 0.51

59 0.17 0.17 0.18 1 0.18 785 204,663 0.45

60 0.17 0.17 0.18 1 0.18 785 200,745 0.44

61 0.17 0.17 0.17 1.1 0.19 785 216,509 0.48

62 0.17 0.17 0.17 1 0.17 785 192,908 0.43

63 0.17 0.17 0.17 1 0.17 785 188,990 0.42

64 0.17 0.17 0.17 1 0.17 785 188,990 0.42

65 0.17 0.17 0.17 1 0.17 785 188,990 0.42

66 0.17 0.17 0.17 1 0.17 785 188,990 0.42

67 0.17 0.17 0.17 1.1 0.18 785 207,889 0.46

68 0.17 0.17 0.17 1 0.17 785 188,990 0.42

69 0.17 0.17 0.17 1 0.17 785 188,990 0.42

70 0.17 0.17 0.17 1 0.17 785 188,990 0.42

71 0.17 0.17 0.17 1 0.17 785 188,990 0.42

72 0.17 0.17 0.17 1.1 0.18 785 207,889 0.46

73 0.17 0.17 0.17 1 0.17 785 188,990 0.42

74 0.17 0.17 0.17 1 0.17 785 188,990 0.42

75 0.17 0.17 0.17 1 0.17 785 188,990 0.42

76 0.17 0.17 0.17 1.1 0.18 785 207,889 0.46

77 0.17 0.17 0.17 1 0.17 785 188,990 0.42

78 0.17 0.17 0.17 1 0.17 785 188,990 0.42

79 0.17 0.17 0.17 1 0.17 785 188,990 0.42

80 0.17 0.17 0.17 1 0.17 785 188,990 0.42

Total Emissions 142

0.445 #/Ton
Appendix B

Photographs
Appendix C

Data Validation Technical Memorandum
 California Environmental Protection Agency 

 AIR RESOURCES BOARD 

STAFF REPORT: INITIAL STATEMENT OF REASONS 

FOR THE PROPOSED REGULATION TO REDUCE 

METHANE EMISSIONS FROM MUNICIPAL SOLID 

WASTE LANDFILLS 

Stationary Source Division 

Emissions Assessment Branch 

May 2009 
ES-8 

control devices such as flares to ensure that these devices are operating optimally and 

meeting the destruction efficiency standards. 

3. Wellhead Monitoring

Monthly well monitoring is required to demonstrate that the gas extraction rate for an 

active gas collection system is sufficient. This requirement (in conjunction with the 

surface emission standards) helps to minimize groundwater impacts by ensuring that 

methane is routed through the gas collection system to a gas control device. A negative 

pressure must be maintained at each wellhead, except under certain conditions (a 

landfill subsurface fire, fire prevention, repair of the gas collection system, or 

construction activities). If a positive pressure is measured, the owner or operator must 

initiate corrective action within five days. If the corrective action is not successful, an 

expansion of the gas collection may be necessary and must be completed within 

120 days of the date the positive pressure was measured. 

G. Recordkeeping and Reporting Requirements 

In order to assure and monitor compliance with the requirements of the proposed 

regulation, landfill owners and operators are subject to recordkeeping and reporting 

requirements. These requirements include maintaining records of a landfill’s waste 

acceptance rates, instantaneous and integrating surfacing sampling measurements, 

component leak checks, equipment downtime, gas flow rates, and control device 

destruction efficiency testing. Most records are required to be kept for a five-year 

period; however, control device records must be maintained for the life of the control 

device. Some of these recordkeeping items are required to be included in the annual 

report, which must be submitted annually and cover the period of January 1 through 

December 31 of each year. Additionally, there are some specific reports that need to be 

submitted under specific conditions, such as a waste-in-place report for landfills with 

less than 450,000 tons of waste-in-place or a closure notification report for landfills that 

are ceasing waste acceptance and closing. Additionally, an equipment removal report 

is required when a landfill is seeking to decommission the gas collection and control 

system. These reporting requirements are similar to what is already required in local air 

district and federal rules for many landfills in California. 

III. IMPACTS OF THE PROPOSED REGULATION 

A. Emissions and Emissions Reductions 

Based on ARB staff’s estimate, there would be a reduction of about 0.4 MMTCO2E due 

to bringing 14 uncontrolled MSW landfills into compliance with the proposed regulation 

in 2020. The implementation and enforcement of this proposed regulation for the 

remaining estimated 204 affected MSW landfills (including those with gas collections 

systems already installed) is expected to result in an additional estimated emission 

reduction of 1.1 MMTCO2E in 2020. This total 1.5 MMTCO2E emission reduction 
 

SOURCE TEST REPORT

96-0007/96-0008/96-0009

CONDUCTED AT

San Joaquin Composting, Inc.

Holloway Road

Lost Hills, CA.

CHARACTERIZATION OF AMMONIA, TOTAL AMINE, ORGANIC SULFUR COMPOUND, AND

TOTAL NON-METHANE ORGANIC COMPOUND (TGNMOC) EMISSIONS FROM

COMPOSTING OPERATIONS

TESTED: February 15, 1996

March 1 & 11, 1996

ISSUED:

REPORTED BY: Carey Willoughby

Air Quality Engineer I

REVIEWED BY:

 

Michael Garibay

Air Quality Engineer II

 

Arun Roy Chowdhury

Supervising Air Quality Engineer

SOURCE TESTING AND ENGINEERING BRANCH

 

APPLIED SCIENCE AND TECHNOLOGY
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -2- Date: 3/1, 11/96

SUMMARY

San Joaquin Composting, Inc.

525 N. Shafter Avenue

a. Firm and Mailing Address......................... Shafter, CA, 93263-1505 

Holloway Road

b. Site Location .............................................. Lost Hills, Ca. 

c. Unit Tested ................................................ Windrow Piles with 3, 45, & 57 day mixes 

d. Test Requested by ......................................Julia Lester, Planning, (909) 396-3162 

e. Reason for Test Request............................Information for the AQMP 

f. Date of Test ................................................ February 15, & March 1 & 11, 1996 

Ken Sanchez, David Carrillo, Mike Garibay,

g. Source Test Performed by.........................C. Willoughby, Paul Williamson 

h. Test Arrangements Made Through............J. Deatherage, General Manager, (805) 746-6723 

h. Test Observed by........................................ T. L. Allard, Site Manager, (805) 797-2914 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -3- Date: 3/1, 11/96

RESULTS

3 Day Pile Average Emission Summary

Contaminant Emissions per

Windrow Pile

Emissions per hour per

ton of Compost Mix

Emissions per hour per

1000 ft2 of Compost

Ammonia (pre turning)

Ammonia (post turning)

Ammonia (wtd. avg)

Amines

Total Sulfur Compounds

Methane

TGNMOC

1.54 lb/hr

1.37 lb/hr

1.54 lb/hr

 0.13 lb/hr

0.08 lb/hr

36.46 lb/hr

3.29 lb/hr

3.09E-03 lb/hr-ton mix

2.75E-03 lb/hr-ton mix

3.09E-03 lb/hr-ton mix

2.59E-04 lb/hr-ton mix

1.68E-04 lb/hr-ton mix

7.29E-02 lb/hr-ton mix

6.58E-03 lb/hr-ton mix

0.155 lb/hr-1000ft2

0.138 lb/hr-1000ft2

0.155 lb/hr-1000ft2

1.30E-02 lb/hr-1000ft2

8.41E-03 lb/hr-1000ft2

3.65 lb/hr-1000ft2

0.329 lb/hr-1000ft2

45 Day Pile Average Emission Summary

Contaminant Emissions per

Windrow Pile

Emissions per hour per

ton of Compost Mix

Emissions per hour per

1000 ft2 of Compost

Ammonia (pre turning)

Ammonia (post turning)

Ammonia (wtd. avg.)

Amines

Methane

TGNMOC

1.41 lb/hr

1.56 lb/hr

1.41 lb/hr

0.04 lb/hr

0.11 lb/hr

0.12 lb/hr

2.82E-03 lb/hr-ton mix

3.11E-03 lb/hr-ton mix

2.83E-03 lb/hr-ton mix

8.67E-05 lb/hr-ton mix

2.20E-04 lb/hr-ton mix

2.36E-04 lb/hr-ton mix

0.146 lb/hr-1000ft2

0.162 lb/hr-1000ft2

0.146 lb/hr-1000ft2

4.50E-03 lb/hr-1000ft2

1.14E-02 lb/hr-1000ft2

1.23E-02 lb/hr-1000ft2
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -4- Date: 3/1, 11/96

57 Day Pile Average Emission Summary

Contaminant Emissions per

Windrow Pile

Emissions per hour per ton

of Compost Mix

Emissions per hour per

1000 ft2 of Compost

Ammonia (pre turning)

Ammonia (post turning)

Ammonia (wtd. avg.)

Amines

Total Sulfur Compounds

Methane

TGNMOC

0.13 lb/hr

2.48 lb/hr

0.18 lb/hr

<0.003 lb/hr

0.08 lb/hr

<0.13 lb/hr

<0.12 lb/hr

2.66E-04 lb/hr-ton mix

4.97E-03 lb/hr-ton mix

3.68E-04 lb/hr-ton mix

<6.58E-06 lb/hr-ton mix

1.58E-04 lb/hr-ton mix

<2.67E-04 lb/hr-ton mix

<2.39E-04 lb/hr-ton mix

1.42E-02 lb/hr-1000ft2

2.65E-01 lb/hr-1000ft2

1.97E-02 lb/hr-1000ft2

<3.51E-04 lb/hr-1000ft2

8.43E-03 lb/hr-1000ft2

<1.43E-02 lb/hr-1000ft2

<1.27E-02 lb/hr-1000ft2

Average of 3-day, 45-day, & 57-day piles

Contaminant Emissions per ton

of Compost Mix

Emissions per 1000 ft2 of

Compost Surface Area

Emission per hour -

ton of Compost Mix

Ammonia

Amines

Total Sulfur Comp.

Methane

TGNMOC

2.81 lb/ton mix

0.19 lb/ton mix

0.22 lb/ton mix

33.49 lb/ton mix

3.12 lb/ton mix

0.107 lb/hr-1000ft2

6.0E-03 lb/hr-1000ft2

8.42E-03 lb/hr-1000ft2

1.23 lb/hr-1000ft2

0.11 lb/hr-1000ft2

2.07E-03 lb/hr-ton

1.17E-04 lb/hr-ton

1.63E-04 lb/hr-ton

2.4E-02 lb/hr-ton

2.28E-03 lb/hr-ton

Notes: Total sulfur compounds based on 3-day and 57-day piles only.

 Results do not include emissions from curing piles or emissions during actual turning.

 Ton of compost mix refers to original mass as measured by Lost Hills before composting.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -5- Date: 3/1, 11/96

 For emissions of individual sulfur compounds, refer to calculations section.

 TGNMOC may be subject to change upon receipt of modified method 25.1 results.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -6- Date: 3/1, 11/96

INTRODUCTION

On February 15, 1996, and March 1 & 11, 1996, personnel from the South Coast Air Quality Management

District (SCAQMD), conducted source tests at San Joaquin Composting, Inc. The tests are intended to

measure the emission profile of the operation over its composting cycle. The tests were conducted on

compost piles consisting of a mixture of dewatered sewage sludge and green waste. The ages of the piles

were 3 days, 45 days, & 57 days. These compost ages were chosen as beginning and end compost where

activity is theoretically beginning and ending, and at peak temperature (45 days) when activity is expected

to be greatest. The results presented in this report represent windrow emissions only since sampling for

curing pile emissions was not performed.

Since the composting process is specifically designed to optimize agitation for maximum aerobic content

verses internal heat and activity, it was imperative that the process be tested in place and undisturbed. The

piles are generally turned once to three times per week depending on workload constraints. The tests were

scheduled to coincide with the pile turning, so a pile was tested for ammonia emissions before and after

turning, and for the remaining pollutants, before turning only. Sampling was not conducted during turning,

however, due to sampling difficulties under turning conditions. Previous testing has shown that the

emission remain at the elevated emission rate for approximately 90 minutes after turning, after which

emissions return to baseline levels. The "before turning" condition is considered as representing baseline

emissions.

The test was requested by the SCAQMD Planning Division in order to inventory emissions from sludge

composting operations in the South Coast District and evaluate the impact for possible inclusion to the

Air Quality Management Plan (AQMP). San Joaquin Composting has volunteered the use of its Lost Hills

facility for purposes of testing emissions to the atmosphere

The following is a summary of operating conditions during the tests:

Average Row Height - 5’ (3 Day), 4.5’ (45 Day), 4’ (57 Day)

Average Row Width at Base - 18’

Average Row Width at Top - 8’

Average Row Length - 450’

Compost Temperature - See Table on page 20

Average Pile Surface Area - 9,990 ft2 (2 Day), 9,630 ft2 (20 Day), 9,360 ft2 (50 Day)

Average Pile Compost Volume - 29,250 ft3 (3 Day), 26,325 ft3 (45 Day), 23,400 ft3 (57 Day)

Compost Composition - 50% sludge, 50% green waste (by initial weight)

Total Number of Windrow Piles - 120 - 130

Total Number of Curing Piles - 30 - 40
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -7- Date: 3/1, 11/96

EQUIPMENT AND PROCESS DESCRIPTION

A variety of wastes can be utilized as compost materials including manure, dewatered sewage sludge,

wood chips, agricultural (or other) "green" wastes, and stable wastes. The materials are transported to the

compost facilities where they can be mixed with organic bulking agents in order to improve porosity for

the aerobic composting process. Bulking agents can be made up of a variety of organic or green wastes.

The compost composition is thought to have an impact on emissions since the process is dependent on

micro-biological activity and oxygen availability.

During the composting process, bacteria are allowed to decompose the mixture in a combination of

aerobic and anaerobic activity. The dominating airborne by-product of aerobic activity is carbon dioxide.

Airborne by-products of the anaerobic activity which are largely reduced compounds include relatively

large amounts of methane and ammonia, and relatively smaller amounts of amines, hydrogen sulfide, other

reduced sulfur compounds, and other hydrocarbons. The anaerobic activity is less desirable due to

emissions of toxic and odor-causing compounds. Fugitive dust can be a direct source of PM-10

emissions, particularly during periods of high temperatures, high wind and low humidity.

The heat generated by the exothermic reactions raises the compost's internal temperature to 120-150oF.

The heat also serves the purpose of reducing pathogenic activity. For composting, the mixture can be

shaped into various configurations. Pile dimensions may vary greatly depending on application. The piles

can also be aerated by a number of means.

At the Lost Hills facility, the compost is typically initially composed of 50% digested sewage sludge and

50% green waste by weight. The compost materials are generated predominantly from the Los Angeles

area. The green waste is typically composed of municipal tree and shrub trimmings along with backyard

waste from curbside recycling. For composting, the mixture is shaped into several windrow piles of a

length of 500 ft and a trapezoidal cross-sectional area. The piles shrink in size as they proceed through the

composting period due to the bacterial consumption of the organic material. The piles are turned over

every one to three times per week using a diesel driven machine known appropriately as a Scarab. The

Scarab straddles a pile as it mixes in air with large rotating till type blades as it travels down the length of

the pile. The Scarab uses an adjustable hood to reshape the piles into the trapezoidal shape as it makes its

20-45 minute journey down the pile's length. This process continues typically for 57 days depending on

space constraints. For space saving purposes the compost is then relocated to larger curing piles of

approximately 20 ft height. Aeration is achieved in the curing piles by turning over with a back-hoe. The

composting continues to a lesser degree in the curing piles until the desired consistency is achieved for

up to six months and is shipped out as product demand dictates.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -8- Date: 3/1, 11/96

SAMPLING AND ANALYTICAL PROCEDURES

Compost Composition

A sample of the compost mix was analyzed for nitrate, ammonia, phosphate, minerals, salts, moisture, and

bulk density. This analysis was performed by Soil and Plant Laboratory Inc., who performs analyses for

the composting industry. Refer to the attached laboratory report for the results of the compost analysis.

This analysis may prove useful in emissions evaluations with respect to compost composition.

EPA Emission Isolation Flux Chamber

The procedure for measuring emissions from the compost pile surfaces is a modified form of the

procedures found in the US Environmental Protection Agency's (EPA) Measurement of Gaseous

Emission Rates from Land Surfaces Using an Emission Isolation Flux Chamber User's Guide.

Under the EPA procedures, gaseous emissions from surface migration are collected from an isolated

surface area with an enclosure device called an emission isolation flux chamber. Clean, dry sweep air or

nitrogen is introduced to the flux chamber at a fixed, controlled rate (5.0 lit/min recommended) as a

carrier where it mixes with the contaminants from the surface migration. The flux chamber encompasses a

fixed surface area (1.4 ft2), and is designed to isolate the surface from phenomena that can influence the

air surface interface such as wind speed, other meteorological conditions, or properties of the waste

itself. The flux chamber is sunk to a depth of one inch into the surface in order to create a seal between

the flux chamber and the surface. The flux chamber and sweep air system is designed such that the

contents are well mixed and no internal stratification exists. A probe is located in the flux chamber to

extract a gaseous sample for subsequent analysis. The probe is of such a design that the sample represents

a composite of various altitudes from within the flux chamber. Sampling is conducted at a rate of lesser

than or equal to the sweep air rate. The remainder of the flux chamber contents are allowed to vent

through a small opening located strategically on the flux chamber dome. For measuring flux chamber

internal temperature, a thermocouple is also located within the flux chamber. Refer to Figure 1 for

specifications and exact dimensions of the flux chamber design.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -9- Date: 3/1, 11/96

Modifications to the Flux Chamber Method

The Flux Chamber procedure is intended primarily for surface migration from landfills, hazardous waste

treatment facilities, and hazardous spill remediation covered under the RCRA and CERCLA acts. The

procedure assumes that gaseous emissions from the surface within the chamber area are much less than

that of the sweep air rate. Under this assumption, mass emissions of a given contaminant is a product of

the measured sample concentration and sweep air rate and reported per unit of surface area. Upon field

evaluation of the flux chamber, it was discovered that the surface flux migration rate was more

appreciable in the composting operation and could not be ignored as compared to the sweep air rate. The

calculation of mass emissions of a given contaminant thus becomes a product of the measured sample

concentration, sweep air rate, and surface migration rate. Furthermore this migration rate could not be

directly measured due to the discovery that any attempt to employ a measuring device resulted in an

impedance of the surface migration.

As an amendment to the EPA procedure, the surface migration rate must be determined. A procedure for

calculating surface migration employs a material balance and concentrations taken from the sample

analysis of an inert known component initially mixed into the sweep gas (refer to material balance

section). For this reason, the sweep gas is composed of 10% helium (balance ultra-pure grade air) as a

component to perform the analysis and material balance.

For the purposes of this test, the flux chamber's shell and sample path was constructed entirely of non

reactive materials. Since sulfur compounds were measured, this also meant that metals of any kind could

not be used in its construction to avoid catalytic decomposition. The following sampling specifications

were used during testing:

Sweep Air Type: 10% Helium, 90% Air (99.999 % purity)

Sweep Air Rate: 5.0 lit/min

Bag Sampling Rate: 1.0 lit/min

Ammonia Sampling Rate: 1.0 lit/min

Amines Sampling Rate: 1.0 lit/min

Each sampling run was integrated over several points to insure representativeness. In order to account for

general spatial variabilities, the flux chamber samples were drawn and integrated over several points
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -10- Date: 3/1, 11/96

Modifications to the Flux Chamber Method (Con’t.)

along the pile length for an averaging effect. This is also known as composite sampling. A evaluation of

methane migration was conducted using a portable Flame Ionization Detector (FID) to determine spatial

variations in emissions from the compost (Refer to page 20). The FID was also used to determine flux

chamber period of equilibration with surface emissions for each sampling point. Equilibration was

indicated by a steady plateau in the methane readings.

A small mixing fan is mounted within the flux chamber to ensure complete mixing within the flux

chamber and allow for a homogeneous sample. The fan speed was set at approximately 110 rpm during all

sampling and equilibration periods. A bench-top smoke study revealed that at 110 rpm, the fan can

perform adequate mixing without affecting vertical surface migration.

Results are reported as concentration (ppm) in the flux chamber and emission rates are calculated in

lb/hr-ft2 of surface area. Final mass emission rates are reported on a per pile and per unit of compost

basis using the pile dimensions within the facility. The number of sampling points used in each run and

real time FID readings at each sampling point are presented on page 20 as well for statistical

considerations. The FID readings are to be used primarily to indicate steady state and degree of point to

point variability. For quantification purposes, the FID readings are considered to be less accurate than the

sampling methods shown below.

Ammonia Sampling

An ammonia sample was collected during each sampling run from the flux chamber sample line using

Draft SCAQMD Method 207.1. The midget sampling train consisted of two midget impingers each filled

with 15 ml of 0.1N Sulfuric Acid, an empty bubbler, and a bubbler filled with tared silica gel, as shown in

Figure 2. A minimal amount of condensation was observed in the sample line leading to the ammonia

train. The impingers and bubblers were contained in an ice bath to condense ammonia, water vapor, and

other condensable matter present in the sample stream.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -11- Date: 3/1, 11/96

Ammonia Sampling (Con’t.)

The samples from the 3 day pile were collected for a period of 18 minutes over six sampling points

before turning and 12 minutes over four sampling points after turning at a sampling rate of 1.0 lit/min.

The samples taken from the 45 and 57 days piles were each collected for approximately 24 minutes over

eight sampling points before turning and 15 minutes over five sampling points after turning at a sampling

rate of 1.0 lit/min.

The SCAQMD laboratory analyzed for ammonia deposited in the impingers as ammonium by ion

chromatography. Moisture gain was determined volumetrically in the impingers, and gravimetrically in the

silica gel. Ammonia concentration in the flux chamber was determined using the ammonia content

collected in the impingers, along with the sampling rate and net elapsed sampling time.

A blank field sample train from each of the three sampling days was analyzed in a manner consistent with

the above analysis for quality control purposes.

Amines Sampling

An amines sample was collected during each "before turning" sampling run from the flux chamber sample

line using the Ninhydrin Method. This method will detect primary and secondary but not tertiary amines

which are not expected to be significant. The sampling train consists of two midget impingers, each filled

with 10 ml of acidified isopropanol, an empty bubbler, and a bubbler filled with tared silica gel. The silica

gel impinger is connected to the vacuum side of a leak-free sample pump and a calibrated rotameter, as

shown in Figure 3. The impingers and bubblers were contained in an ice bath to condense amines, water

vapor, and other condensable matter present in the sample stream.

The sample was collected for the same time period as the “before turning” ammonia samples at a sampling

rate of 1.0 lit/min.

The contents of the impingers were reacted with a 0.2% Ninhydrin (1,2,3 tri-ketohydrindene) in

isopropanol reagent to produce "Ruhemann's purple." The SCAQMD laboratory then analyzed for primary

and secondary amines using a spectrophotometer and Beer's law. Moisture gain was determined

volumetrically in the impingers, and gravimetrically in the silica gel for quality control purposes. Amines

concentration in the flux chamber was determined using the amines content collected in the impingers,

along with the sampling rate and net elapsed sampling time. The results are reported as n-butyl amine. A

blank field sample reagent was analyzed in a manner consistent with the above analysis for quality control

purposes.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -12- Date: 3/1, 11/96

Integrated Gas Sampling

An integrated gas sample was collected during each "before turning" sampling run from the flux chamber

sample line using the vacuum side of a leak-free sample pump and a calibrated rotameter. These samples

were collected in Tedlar bags as shown in Figure 4. The contents of the Tedlar bags were analyzed for

organic sulfur compounds. Due to the reactivity of the sulfur compounds, that analysis was performed

within 4 hours of sampling. The gases were separated by gas chromatography. Selected toxic sulfur

compounds were analyzed using a flame photo-ionization detector.

Modified Method 25.1 - Non-Methane Organics

An integrated gas sample was collected during each "before turning" sampling run from the flux chamber

using a modified 25.1 sampling apparatus. The apparatus consists of small Teflon impinger containing 5

ml of HPLC grade water connected to a six liter summa polished canister as shown in Figure 5. This

method has recently been recognized in the source testing community as the method of choice for low

concentration organics. This is the only currently known method of detecting both condensable and

gaseous organic emissions with acceptable precision at low concentration. This method is used for nonmethane organics concentration below 25 ppm.

Results were reported as Total Gaseous Non-Methane Organic Compounds (TGNMOC). The liquid within

the impinges was analyzed with an infrared total carbon analyzer. The contents of the canister were

analyzed using the gaseous analytical procedure of existing SCAQMD Method 25.1 by the total

combustion analysis (TCA) technique using a flame ionization detector (FID). Since it was discovered

after analysis that the concentrations of non-methane organics were all above 25 ppm, the results of the

Modified Method 25.1 were discarded in favor of the standard Method 25.1 results (see next section).
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -13- Date: 3/1, 11/96

Method 25.1 - Non-Methane Organics

Integrated gas samples were taken during each "before turning" sampling run from the flux chamber using

SCAQMD Method No. 25.1. Duplicate gas samples were collected in dry ice cooled condensate traps and

in nine liter evacuated tanks (Figure 6). This method is used for non-methane organics concentration

above 25 ppm.

The contents of the traps and the tanks were analyzed at the SCAQMD laboratory for CO, CO2, O2, CH4

and total gaseous non-methane organic compounds (TGNMOC). CO, CH4 and TGNMOC concentrations

were analyzed by the total combustion analysis (TCA) technique using a flame ionization detector (FID);

SCAQMD Method No. 25.1. The O2 and CO2 concentrations were determined by gas chromatography

(GC) using a thermal conductivity detector (TCD).

Compost Internal Temperature

The compost was monitored with a type “K” thermocouple at various depths in the compost at each of the

locations the sampling took place. Results were reported as an average temperature encountered at each

location. The results are reported on page 20.

TEST CRITIQUE

The test was conducted under normal operating conditions on a pre-arranged basis.

Refer to “Soil and Plant Laboratory, Inc.” Analysis sheet for compost composition.

Sulfur compounds were not analyzed for the 45 day pile due to staffing difficulties within the SCAQMD

laboratory on that day. Results are reported without the contribution of the 45 day pile sulfur compounds.

The "after-turning" sampling does not include emissions while turning but those a few minutes after

turning. Emissions during turning were not determined due to difficulties in obtaining representative

samples under the turning conditions. The turning process has been observed to cause a strong but short

burst of emissions based on the observation of a steam plume and strong odors. Because of this, the

estimations developed in the report are assumed to underestimate actual emissions by an unknown

amount.

Other factors such as EPA reported potential 20% low bias in the flux chamber method and possible

condensation in the sampling lines can also be responsible for a low bias. It should be noted that for
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -14- Date: 3/1, 11/96

TEST CRITIQUE (Con’t)

purposes of establishing emissions baseline estimates and subsequent emissions reduction estimates that

a low bias will always occur.

A heavy rain event occurred one or two days before the 3 day pile sampling. This had the effect of

increasing both compost mass and moisture content over the original compost mixture, and over the 45

and 57 day piles which were sampled during dryer periods. Higher TGNMOC and methane emissions

from the 3 day pile supports the theory that compost moisture has a great effect on emissions and

anaerobic activity.

During the March 11 sampling event, some of the material in the green waste stockpile area in the facility

was observed to be spontaneously combusting. The “smoldering” effect, according to the facility, was

caused by dry high winds from the previous night. This phenomena was observed to generate an

indeterminable amount of white smoke which may result in a potential source of direct PM-10 emissions.

The effect did not occur on the windrow compost that was sampled.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -15- Date: 3/1, 11/96

Sweep

Gas

10% He

in Air
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -16- Date: 3/1, 11/96

Empty Midget Bubbler

Bubbler w/ Tared Silica Gel

Sample Pump Calibrated Rotameter

Midget Impingers with 0.1 M Sulfuric acid

From Flux Chamber

Sample In
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -17- Date: 3/1, 11/96

Empty Midget Bubbler

Bubbler w/ Tared Silica Gel

Sample Pump Calibrated Rotameter

Midget Impingers with

Acidified Isopropanol

From Flux Chamber

S am ple In

Figure 3 Amines Midget Sampling Train
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -18- Date: 3/1, 11/96

Teflon Tubing

Sample In Tedlar Sample Bag

Sample Line from Flux

Chamber

Sample Pump

Figure 4 Integrated Gas Sampling Apparatus
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -19- Date: 3/1, 11/96

Figure 5 Modified 25.1 Sampling Apparatus

(From Flux Chamber)
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -20- Date: 3/1, 11/96

Figure 6 Method 25.1 Sampling Apparatus

Nozzle

Flow Control Valve (fine)

Minihelic Differential

Pressure Gauge

Vacuum Regulator

Condensate Trap

Evacuated Tank

Condensate Trap

Container

Sample Control Valve

Vacuum Gauge
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -21- Date: 3/1, 11/96

Number of Sampling Points, Compost Temp. and FID Readings at Each Sampling Point

Before Turning

 3 Day Pile 45 Day Pile 57 Day Pile

Sampling

Point

Zone #

FID

Reading

(ppm)

Internal

Temp.

(o F)

Sampling

Point

Zone #

FID

Reading

(ppm)

Internal

Temp.

(o F)

Sampling

Point Zone

#

FID

Reading

(ppm)

Internal

Temp.

(o F)

1 45 120 1 11 153 1 2.3 137

2 110 120 2 6 159 2 2.1 129

3 4,500 99 3 7 121 3 2.2 137

4 7,000 104 4 3 148 4 2 102

5 2,900 94 5 80 125 5 4 122

6 500 114 6 4 148 6 4.5 90

7 N/A N/A 7 2.5 159 7 2.5 104

8 N/A N/A 8 35 153 8 2.1 115

9 N/A N/A 9 N/A N/A 9 N/A N/A

After Turning

3 Day Pile 45 Day Pile 57 Day Pile

1 150 97 1 20 143 1 11 135

2 200 100 2 110 151 2 2 140

3 500 110 3 18 130 3 3 145

4 110 119 4 11 146 4 2 138

5 N/A N/A 5 5 156 5 N/A N/A
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -22- Date: 3/1, 11/96

Material Balance for Compost Surface Migration Rate

For calculating the compost surface migration rate, a helium material balance was performed around the

flux chamber. Helium was the chosen constituent because of inert properties and its ease of accurate

analysis. The material balance is derived as follows:

F

c

C

c

F

g

C

g

F

s

C

s F

v

C

v

Where:

Fg = Sweep Gas Flow Rate (measured)

Cg = Sweep Gas Helium Concentration (analyzed)

Fs = Sample Flow Rate (measured)

Cs = Sample Helium Concentration (analyzed)

Fv = Vent Flow Rate (unknown)

Cv = Vent Helium Concentration (assume = Cs)

Fc = Compost Surface Migration Flow Rate (unknown)

Cc = Compost Surface Migration Helium Concentration (assumed zero)

Flow Balance:

Fv = Fc + Fg - Fs

Helium Balance:

FcCc + FgCg = FsCs + FvCv
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -23- Date: 3/1, 11/96

Material Balance for Compost Surface Migration Rate (continued)

Substitute:

Cc = 0

Cv = Cs

Fv = Flow Balance

then:

FgCg = FsCs + (Fc + Fg - Fs)Cs

FgCg - FcCs = FsCs + FgCs - FsCs

FcCs = FgCg - FgCs

 Fg(Cg - Cs)

Fc = 

 Cs
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -24- Date: 3/1, 11/96

EMISSION ESTIMATION CALCULATIONS

Windrow emissions are based on the surface area of the windrows and the results of the flux chamber

sampling reported per unit of surface area. The weighted average for ammonia assumes that the windrows

emit at the elevated "after turning" emission rate for 90 minutes and that the piles are turned 2.5 times per

week. Piles emit “after turning” rates 2.2% of the time. The facility wide emissions do not include

curing pile emissions and are calculated using the average of the three windrow ages.

The following data was used for the calculations:

Pile Height - 5’ (3 Day), 4.5’ (45 Day), 4’ (57 Day)

Pile Width at Base - 18’

Pile Width at Top - 8’

Pile Length - 450’

Pile Side Length - 7.1’ (3 Day), 6.7’ (45 Day), 6.4’ (57 Day)

Pile Surface Area - 9,990 ft2 (3 Day), 9,630 ft2 (45 Day), 9,360 ft2 (57 Day)

Avg. Pile Surface Area - 9,660 ft2

Pile Volume - 29,250 ft3 (3 Day), 26,325 ft3 (45 Day), 23,400 ft3 (57 Day)

Density - 1,200 lb/yd3 (3 Day), 1,014 lb/yd3 (45 Day), 972 lb/yd3 (57 Day)

Mass - 650 tons (3 Days),

Original Pile Mass from Losthills scale - 500 tons*

Total Number of Windrow Piles - 125 - 130

Time in Windrow - 57 Days

NH3 weighted average = (NH3 before turning * 0.978) + (NH3 after turning * 0.022)

For 3 - Day

NH3 Weighted Avg. = (1.54E-04 x 0.978) + (1.38E-04 x 0.022) = 1.54E-04 lb/hr-ft2

For 45 - Day

NH3 Weighted Avg. = (1.46E-04 x 0.978) + (1.62E-04 x 0.022) = 1.46E-04 lb/hr-ft2

For 57 - Day

NH3 Weighted Avg. = (1.42E-05 x 0.978) + (2.65E-04 x 0.022) = 1.97E-05 lb/hr-ft2

Avg. of Weighted Average = 1.07E-04 lb/hr-ft2

* Difference between calculated mass at 3 days and measured mass at 0 days can be attributed to moisture gain due to rain event.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

 21865 E. Copley Drive, Diamond Bar, CA 91765

 96-0007 2/15/96

Test No: 96-0008, 96-0009 -25- Date: 3/1, 11/96

Averages:*

Contaminant Annual

Emissions

Emissions per ton of

Compost Mix

Mass Rate per 1000 ft2 of

Compost

Mass Rate

per row

Mass Rate per

lb/hr-ton

Ammonia

Amines

Methane

TGNMOC

Total Sulfur Compounds

577 ton/year

39 ton/year

6,862 ton/year

639 ton/year

45 ton/year

2.81 lb/ton mix

 0.19 lb/ton mix

33.49 lb/ton mix

3.12 lb/ton mix

0.22 lb/ton mix

0.107 lb/hr-1000ft2

 6.0E-03 lb/hr-1000 ft2

1.23 lb/hr-1000ft2

0.11 lb/hr-1000ft2

8.42E-03 lb/hr-1000ft2

1.03 lb/hr

 0.07 lb/hr

12.24 lb/hr

1.14 lb/hr

0.081 lb/hr

2.07E-03 lb/hr-ton

1.17E-04 lb/hr-ton

2.4E-02 lb/hr-ton

2.28E-03 lb/hr-ton

1.63E-04 lb/hr-ton

Ton/Yr = lb/hr * 128 windrow piles * 24 hr/day * 365 day/yr * ton/2,000 lb

Lb/Ton Compost = lb/hr * pile/500 ton * 24 hr/day * 57 day

Lb/Hr-1000 FT2 = (Avg. lb/hr-ft2) * 1,000

Lb/Hr = (Avg. lb/hr-ft2) * (Avg. Pile Surface Area)

Lb/Hr-Ton = (Avg. lb/hr-ft2) * (Avg. Pile Surface Area) / Original Pile Mass

* Rain event before 3-day pile test. See test critique.