### 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 fo llowing SERs submitted four sets of written comments, which are provide d in this appendix:

 Todd Green, American Environmental Landfill

 Curt Publow, Decatur Hills, Inc.

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

 Anne Germain, Environmental Industry Asso ciations on behalf of Caroline County,
Maryland

o Cosigned: Michael E. Michels, Corner stone Environmental Group on behalf of
Riverview, Michigan

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

o Cosigned: Kimberly Smelker, Granger Waste ServicesP: \ LFG \ REGULATIONS \ NSPS REVISIONS \ 2014 PROPOSED REVISI ONS \ SBAR PANEL EG COMMEN TS SER

- PONCA CITY.DOCX

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 comment s on the briefing materials for the Municipal Solid Waste (MSW) Landfills Emission Guidelines (EG) , which was presented

at t he April 14, 2015 SBAR o utreach 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 h as served the industry for many years

, and many small entities have

establish ed 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 need ed to operate, maintain, monitor

, and comply. Considering these costs, small entities must carefully consider possible landf ill expansions and/or increase in waste acceptance fees. As such, it is requested that applicability and current thresho lds not be changed at this

time

In order to help promote consistency across state lines

, we recommended that with any proposed cha nges to the EG that the EPA also prepare the Federal Implementation Plan (FIP ) for the EG at the same time. This will allow state s without too much variation , to

us e 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

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- PONCA CITY.DOCX Weaver Consultants Group Specific Comments

Size and emission thresholds

– For the reasons discussed above

, the size and emission

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

will have some a dditional 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 Was te 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 (m 3 ). The

current threshold continues to ensure that the rule will achieve the maximum level of potential emissio ns reductions cost

- effectively. T he current design capacit y threshold of 2.5 million Mg and 2.5 million cubic meters, remains appropriate because there has been no change in the circumstances und erlying 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 sit es 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 incr ease cost of control by more than 26 percent while redu cing 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 EP A’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 t he wellhead oxygen/nitrogen operational levels when subjected to continuous vacuum. If EPA finalizes a lower NMOC threshold, this problem will become moreMs. Muellerleile

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- PONCA CITY.DOCX Weaver Consultants Group pronounced. Many closed landfills struggle to maintain sufficient gas flow to operate

their cont rol s ystems 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, wh ich 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 thresho ld 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 ap proach 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 th e 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 owner s /operators to perform SEM to show that surface emissions at a site

remain low ev en 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 testin g
, a site specific N MOC 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 mathema tical 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 c ould 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

po int following a Tier 1 o r Tier 2 test in which the NMOC s have been calculated to be greater than the NMOC threshold and prior to the required installation of the GCCS. InMs. Muellerleile

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- PONCA CITY.DOCX Weaver Consultants Group addition, we propose that this method also be used in determining when to remove th e 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 bri efing 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

exceed ance 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

-- Methan e 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 f ive 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 res ults 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 monitori ng 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

a cres monitored. Similarly, the re is a significant amount of cost and burden associated

with integrated monitoring, with insignifican t results. The se 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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- PONCA CITY.DOCX Weaver Consultants Group 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 suffici ent 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 landfil l 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 pro ven with years of experience as proof

, that surface emissions are being detected and corrected

P lea se note that by adding a wind speed requirement, there will be additional recording keeping, monitoring, and reporting burdens. It is highly li kely that during a SEM event

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

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

or re s chedule SEM due wind speed will create an addit ional 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 stan dards

– 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 s tate 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 perf

ormance 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 wa ste is placed over the collectors ceasing air intrusion.Ms. Muellerleile

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- PONCA CITY.DOCX Weaver Consultants Group 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 temper atures 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. Altho ugh 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 simpl y 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 ga s. 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 prac tices 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 n early 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 coll ection 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 re commended 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 proposedMs. Muellerleile

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- PONCA CITY.DOCX Weaver Consultants Group 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 no t 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 ap proved 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 en couraged 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 ServicesApril 28 , 2015

Caryn Muellerleile (via e

- mail) Office of Policy

U.S. Environmental Protection A gency 1200 Pennsylvania Avenue, NW Washington, DC 20460

RE: Comments on the Municipal Solid Waste Landfills Emissions Guidelines

Dear Ms. Muellerleile :

As a Small Entity Representative s (SER), we are pleased to offer the follow ing

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 ) O utreach Briefing and discussed at the April 14 meeting with the SERs

.

General Comment s

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 201 3, 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 redu ctions of this magnitude. This demonstrates that the NSPS and EG works well in effectively controlling landfill emissions. Further, t he emissions

reductions achieved to date have been at a reasonable cost 1

.

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 i s the appropriate level of staffing to address these

1 EPA has available recently published information on the efficacy of the L andfill 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).r ules 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. Th ese example s 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 nin e 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 y ears after the EG was originally promulgated . Unlike 1996 when most landfills were subject to the NSPS, this

time m ost 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 promulga ted , 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 m ore than one juri sdiction. 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 rulemak ing 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 N SPS 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 implementa tion 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

co ntrol requirements, design plan requirements, NMOC thresholds, test methodsand 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

fr ameworks that may achieve a larger fraction of methane emission reductions from existing landfills than the current performance based standard of a well

designed and well

- operated GCCS.” ( 79 Fed. Reg. 41781 ).

Direct regulation of methane is unlikely to aff ect 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

- operate d 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 polluta nt 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

dir ectly. EPA has not demonstrated nor even suggested that there is a more effective way to address methane emissions tha n 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 prev iously 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 s ame 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 pollu tant 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 st ate 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

potent ial 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 greenho use gases under the Prevention of Signification (PSD) program.

Given the foregoing, r evisions to the existing rule should maintain the well

designed 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 Subpart s Cc and WWW.

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

– The briefing

materials indi cate 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 soug ht 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 ope ration 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. 4 1805 ). 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 i n 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/m 3 threshold wouldcapture 85 percent of NMOC emissions potential, while e xempting 90 percent of

existing small landfills. EPA noted in 1996 the trend towards development of a smaller number of large, new landfills, and this t rend has become more pronounced in the last two decades. Closed landfills have no revenue stream to

supp ort 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 plan s

. Furthermore, this form of retroactive regulati ons of those closed or near closed sites would disproportionately affect small facilities.

Reducing the emissions threshold from 50 to as low as 3 4 Mg /yr NMOC will further delay the point at which a closed landfill can pet ition 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 whe n 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 lowe r 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 under lying E PA’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 bu rden for li ttle 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 s upport 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 determin ing 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 land fill 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 conser vative mathematical methane generation model that only provides a prediction ofpotential 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 incentivize s sites to im plement methane reduction practices s uch 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, c onstructing 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 importan t benefit is that the SEM results will reflect the differen ces in gas generation as a result of different climate s

. These differen ces are lost in the

default Tier 1 calculations and an exacerbated in Tier 2. As stated previously above, EPA has even recogni zed 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 wil l correct the emissions exceedan ce or whether installation of the gas collection system is warranted. Thi s 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 conservativ e 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 ab sence 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 require d to be test ed 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 asdocumented with re

- monito ring, 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 wit h implementing the CA LMR at public and private landfills to the SEM requirements in subpart WWW. A copy of this study was provided to EPA 2

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

which took effect in mid

- 2011. Because C A 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 aggrega te NSPS monitoring results by reviewing quarterly monitoring reports developed from up to two years (8 quarters) prior to implementation of the CA LMR (3 rd quarter 2009 through mid

- 2011). Of the total 72 landfills in the study, 41 were publicly

owned and 3 1 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 p attern 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 o ccurred 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. E xceedances were detected at 4.4% of acres monitored

, yet t he

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 tha t 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 landfill s , at most, based on the SCS analysis. The increased monitoring costs would place a significant burden on both large and small entities, but particularly f or 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 integrat ed 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 moni toring, 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. M embers 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

r equire ment 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 indicator s for

determin ing potential air intrusion ; they were not promulgated t o ensure proper collection system operation or t o 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 we llhead 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 per cent 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 us ing 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 act ivation 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 natur ally. 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 Su bpart 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 th e 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

- nsps

1400009.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 thatallow for higher oxygen at wells wi th 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 requ est 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 compl iance limbo. Most recently, the a genc y determinations have changed course and are deny ing 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 atta ched). 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. F urther, t his 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 an d 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 “Catch

22” of either risk ing 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 i llustrate pape rwork

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 advant age 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 par ameters.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 t hree decades of experience with operating gas collection systems, the landf

ill 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. S ome states

are concerned about landfill safety should the parame ters 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,

B ay 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 d irection 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 requirem ents 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 w as 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

, tur bines , or other end use equipment

. T he docket for the proposed NSPS di d 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 andare 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 ar e not an emission source, additional requirements will not result in any emission reductions. Given the above, we suggest that these requirements

are unnecessary. A fter all, treatment systems merely optimize the characteristics of the gas to match the spec ifications 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 w ith 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

u nder. 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 C AA 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 requirement s 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 project s 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 elec tricity 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

suc h 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 equipm ent, 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 regulat ory 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 ensuri ng 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 tha t 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, a nd 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 comprom ised. 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 manag e ment

– 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 document s 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

affect s 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. Whi le 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 year s 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 o wners 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

interm ittent 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

- fits

all 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 t he 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 t o 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 todrop 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 f orced 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 IIGreen Waste Compost EF Report September 15, 2010

2 I. Introduction

This report provides the basis for the District’s o rganic material composting volatile organic compound (VOC) emission factors (E Fs). The organic material composting EFs contain the following categories: gr een waste, food waste, and grape pomace. However, the focus will be on green waste, since the San Joaquin Valley’s inventory of organic material comp ost is primarily green waste. The EFs will be used for Rule 4566 ( Organic Material Management ) development and permitting applications in the San Joaquin Vall ey. These organic material composting EFs are not applicable to biosolids, ani mal manure, or poultry litter, which have been attributed a separate EF.

Accurate emission factors are required for the prop er 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 availa ble 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 Medi terranean climate characterized by hot, dry summers and cool, foggy w inters. 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 o zone (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 th e earlier serious and severeGreen 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 V OCs, fine particulate matter, ammonia (NH 3 ), and greenhouse gases such as carbon dioxide (CO 2 ) and methane (CH 4 ). The emissions are directly emitted from the dec omposition of organic material in the San Joaquin Valley. Com posting is a process that involves the biological break down of organic matte r, typically into marketable products (soil amendments, animal bedding, and alte rnative daily cover at landfills). Composting uses wastes from a wide-var iety of sources, such as curbside green waste, landscaping, agricultural process ing, crop harvesting, food consumption, and forest management.

There are two general categories of composting, aer obic and anaerobic:

Aerobic composting is the decomposition of organic material by microbiological organisms (microbes) in the presence of oxygen (O 2 ). This oxidation process theoretically results in CO 2 , water (H 2 O), 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 organi c matter by microbes in the
absence of O 2 . During this digestion process, a gas primarily c omposed of CH 4 and CO 2 , known as biogas, waste gas or digester gas is pro duced. Biogas also consists of nitrogen (N 2 ), O 2 , NH 3 , hydrogen sulfide (H 2 S), and various VOCs. However, these additional products are generated in relatively small amounts when compared to the amount of CH 4 and CO 2 produced.

1 http://www.londonfoodrecycling.co.ukGreen 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 hea lth agency whose mission is to improve the health and quality of life for all Vall ey residents through efficient, effective and entrepreneurial air quality managemen t strategies. To protect the health of Valley residents, the District works towa rd achieving attainment with health-based ambient air quality standards as requi red under State and Federal law. To achieve this goal, the District develops a nd adopts air quality attainment plans that include control measures aimed at furthe r 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 dev eloping the ozone attainment plan every feasible measure to reduce emissions of ozone precursors (VOC and NOx) was explored. Green waste composting was a co ntrol 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 re lying on the state and federal governments to significantly reduce emissions from mobile sources of pollution, the San Joaquin Valley will still need the developm ent and adoption of future, not-yet-developed, clean air technologies to reach attainment by the 2023 deadline. Achieving the goal of attainment with ai r quality standards will require continued contributions from all industries, busine sses, 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 qualit y regulations is the issuance of conditional construction and operating permits to c ommercial, industrial, and agricultural sources of air pollution. Since the 1 970s, the San Joaquin Valley Air Pollution Control District and its predecessors hav e issued tens of thousands of conditional permits that are being used to assure c ompliance with air pollution control requirements throughout the Valley. Distri ct permits address the requirements of federal standards, state regulation s, and District rules that specifically apply to a source of air pollution. N ew and modified sources of air pollution are also subject to the more protective r equirements of “New Source Review”, which are determined on a case-by-case bas is and are also included in the permit. Permit holders, District Inspectors, a nd others use these District permits, rather than directly reference the complex and voluminous underlying regulations, to verify compliance with applicable a ir quality requirements.

For new sources, the District begins permitting the m as we become aware of their emissions. The permitting threshold for thes e types of operations is 2 lbpollutant/day. Currently the District quantifies V OC and NH 3 emissions to composting operations. Therefore, any organic mate rial composting operationGreen Waste Compost EF Report September 15, 2010

5 which has the potential to emit more than 2 lbs of either VOC or NH 3 per day is subject to District permitting.

III. EF Determination Analysis

Many factors, which are related, affect the compost ing process that makes it difficult to scientifically analyze composting from an air emissions standpoint. The major factors affecting compost are oxygen, moi sture, seasonal temperature fluctuation, temperature increases resulting from m icrobial respiration, nutrients (especially carbon and nitrogen), feedstock variabi lity 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 te st 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 E Fs 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 Co mposting and Drying focusing on Greenwaste Compost Air Emissions Data R eview ”, by Thomas R. Card and Charles E. Schmidt, June 2008 (see the App endix 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 emissio ns escaping the green waste piles. In this context, flux means the rate of mas s flow of fluid gases through a given surface area. For example, the flux emission s may be measured in units of mg-VOC/min-m 2 . Knowing the total composting period of time, sur face pile area, and pile mass, the flux emission factors may be con verted 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 US EPA surface emission isolation flux chamber method, and analyzed using S CAQMD 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 ident ified 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, an other 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 peri od 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 test s each reported the stockpile EF based on their own site-specific stockpile perio d. For example, the Northern Recycling Zamora stockpile test assumed the EF for a 90-day stockpile time. The Northern Recycling Zamora stockpile sampling wa s performed on days 1 and 7, which is representative of normal SJV stockp iling. To arrive at the 90-day stockpile EF, it was assumed the average rates meas ured on days 1 and 7 were emitted for 90 days. The District reduced the EF t o a one-day basis for this EF report. Each of the other stockpile EFs were norma lized 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 fa cilities in the San Joaquin Valley. The result of the survey indicates an aver age 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 doe s 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 w aste 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 afte r 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 th e testing was performed for other management strategies, not a typical baseline facility; therefore, does not factor into the green waste windrow EF. The two te st 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 mate rial (as wet tons), not finished material. The green waste windrow compost ing EF is based on a typical active + curing phase composting life cycle (minimu m 60 days). The activephase has been defined at a minimum 22 days for Dis trict purposes. The District has also examined the VOC profile split over the co urse 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 emiss ion factor for uncontrolled food waste composting. Source tests from controlled com posting operations have yielded emission factors ranging from 3.4 lb VOC pe r ton food waste compostedGreen 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 i s also unlikely that emissions from a covered system would accurately represent em issions from the open windrow commonly used by facilities in the District . This is because covered systems offer many process control advantages inclu ding 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 Mana gement Board (CIWMB). Two goals of this test were to determine VOC emissions from green waste composting and food waste composting. The food was te composting windrows contained approximately 15% food waste (from local food processing plants (e.g. peppers, tomatoes, peaches, and syrup) and 85% grou nd 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 w aste 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, t he 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 gree n waste EF. However, if
more data were to become available for food waste c omposting, the food waste EF from the City of Modesto test site may be used i n 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 re presentative emission factor can
be identified.

C. Grape Pomace Composting EFs

The District has not been able to identify an emiss ion factor for grape pomace composting. Therefore, the District will use the g reen waste composting emission factor to represent this feed stock until a more data is available.

D. Biosolids, Animal Manure, Poultry Litter Compos ting EFs

Biosolids and animal manure composting emission fac tors were taken from source tests conducted by the South Coast Air Quali ty Management District (SCAQMD) in support of their Rule 1133 (Emission Re ductions from Composting and Related Operations). These emission factors we re calculated as an average of emissions from three co-composting facilities (S CAQMD, 2002) as presented
in the Table below.

The District has not been able to identify an emiss ion factor for poultry litter composting. The District will use the biosolids co mposting emission factor to represent this feed stock until a more representati ve emission factor can be
identified.Green Waste Compost EF Report September 15, 2010

9 Table 5: Biosolids, Animal Manure, and Poultry Litt er EFs. Summary of Co-Composting Emission Factors Develope d by SCAQMD
Emission Factors (lb/wet-ton) Location VOC NH 3 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 Emiss ions Data
Review ” Appendix C: “Northern Recycling Zamora Compost Faci lity 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 2 008San 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 Con sulting 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 gree nwaste 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 eff ect 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).

F igure 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 Rep ort Reviews

B Technical Memorandum

– Recalculating CIWMB Modesto Emissions
C Confidential Site X Emissions Rep ort1



## 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, i s 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 we re 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 fu r ther. 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 dat a 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 Inte grated 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 d i viding 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 through put (compost substrate and2

amendment ) . A ll 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).

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 No rCal 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

fa cilities. 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 d ata sets (#VOC/ton feedstock per compost day).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 thei r data appear unrealistically low and are significantly outside the bounds o f all the other data set s

.

The most relevant food waste composting data was from only one site and provided emissions for various covered compost technologies. The food wast e compost technologies were Ag

- Bag ® , Compostex ® , and micropore covers. These cover technologies are described in more detail in the report text. Food waste w indrow emission factors ranged from 1.7 to 36.7 pounds VOC per ton of throughput. Food waste

s to ckpile 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

addit ion, 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 p lus 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 f acilities

 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 directio n

 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 emissi on 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 magnitu d e of most of these variables, including seasonal emission s 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 f unction of variable. There has been some previo us work showing that the carbon

– nitrogen ratio significantly affects air emissions, but again, insufficient information is available to define this effect. Temperature has been studied4

and there are some dat a 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).

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 annua l basis. However, these limited data do justify the range of emission factors repo r ted 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 fa ctors measured; 3) Define the key variables that e ffect 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 r esearch 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 I ntroduction

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 dat a 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 ha s 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 ft 2 . They are normally underlain with an air distribution system that provides air by either suction or pressure. There also are some hybrid tech nologies 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 o n 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 stockpi les 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 approve d 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 there6

can be significant spatial variability as well. For each compost day, from 2

- to

- 8 individual samples sho uld 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 operati ng 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 p ile composting biosolids in Philadelphia (Hentz et al 1996)

.

Figure 2.1 Example d aily emissions from a greenwaste composting windrow (VOC and ammonia)

.7

Figure 2. 2 The effect of pile temperature on VOC emissions (from Hent z et al 1996).



## 3.0 Data Ev aluation 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

comp ost 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

f acilities. 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 , t he full cycle emissions are then estimated by the following procedures.



### 4.1 Compost Pile Configuration

Compost pile dimension s have a high degree of variability. However, they all m atch 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 volu me 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

.9

Figure 4. 2

. – Range of area to volume ratios for t ypical 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

c ompost process, should then added and the sum of the individual daily emissions should

be totalized. T he emission factor consists of the full total cycle emissions (in pounds) divided by the incoming feedstock weight (in tons).



### 4.5 Emission s 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 f or m. The paragraph s below discuss the data points in detail.10

Table 5.1 Summary of most relevant green waste composting data.



### 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

measureme nts , 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 time s) 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 ra tio.



### 5.2 California Integrated Waste Management Board (CIWMB)

Modesto

This data set was taken in 200 6 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 w as 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 m easurements , 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 strate gies 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 greenwast e VOC emission factors (#/ton feedstock)

.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 ar t flux chamber techniques at the time of the sampling.

T he 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 2 0 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 ®13

polypropyle ne cover. The cover is very po rous, but does supply insulation and some

water retention.

Table 6 .1 Summary of most relevant food waste composting data.

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 weath er 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 unco vered 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 mi nute 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 da ta found to be most relevant in characterizing bios o lids composting emissions in the State of California. Table 7.1 presents a summary of this

data in both an emission factor and unit emi ssion rate form. The paragraph s below discuss the data points in det ail.14

Table 7 .1 Summary of most relevant biosolids composting data.

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.

T hree data sets do not really represent baseline/uncontrolled emissions. The Cedar Grove

data set utiliz ed 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 wi ndrow. 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 contro l 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 retentio n.



## 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 Summarie s

### 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 h ave 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. Ea ch 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 c ompost 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 rat e 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 SchmidtSUMMARY 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 Compost ing 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 applicati on)


### 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 an d 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: Int ravia Rock and Sand, Inc. Upland, CA


### TITLE: “Ammonia and Volatile Organic Compound (VOC) Emissions From A Non

Curbside Greenwaste Chipping and Grinding Facility ”



### SITE: Rancho Las Virgenes Municipal Water District, Calabasas, CA


### TITLE: “Characterization o f 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: Sa n Joaquin Composting, Inc, Lost Hills, CA



### TITLE: “Characterization of Ammonia, T otal 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 Compos t 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 conduct ed 01/07 to 03/07)



### PROJECT OBJECTIVE: Evaluate VOC and ammonia emissions for biosolids composting using the Gore

mic r opore/ASP cover system, and to determine the control efficiency for the cover
system.



### FACILITY OPERATIONS: Cedar Grove composting utiliz es 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

ch ambers 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 r ounds, two buried flux Phase 1, Day 4

- Same, plus full replicate testsPhase 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:

Bioso lids 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 und er 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 inl et 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 begin ning 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 f or 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 Con ducted 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 compostin g 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, CO 2, 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 R ecycling 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 compos t, 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 sample s 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 tha t 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 s tack 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 review ed.



### 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 s ite. 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 FA CT 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 sys tem.



### 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, etha ne, 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 f

inish 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

- SamePhase 1, Compost, Day 22

- Same

Phase 1, C ompost, 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, Co mpost, 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 w as 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



### D ATE: 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 Pra ctices (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.



### SAMP LE 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

- Sam e 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 freque ncy 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 finish ed 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 finish

covered pile, which was estimated by screening to b e 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 representat iveness 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 Fr om 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 stat ic 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 kn own 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:

Ammo nia 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 appr opriate 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 p rovided. 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 O BJECTIVE:

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

bu lking 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, SC AQMD 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 flo w 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 a dsorption 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 co nducted 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 was te, 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 samp le 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 0.00 06 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 ANNO TATED 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 ai r 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 O PERATIONS: 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 con ducted 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 Cham ber 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 w as 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 conclus ion 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 O BJECTIVE: 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 Emiss ions 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 ref erence.



### 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 To tal 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 comp ost 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 (c ondensable 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 METHO DS: 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 th e 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



### CON CLUSIONS: 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, an d 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: Sa n 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 Willou ghby



### 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

emissio n 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, al though 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.



### S AMPLE 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 poi nts 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 prepa red 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 app ropriate 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 auth ors. 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 Re port

- 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 no n

- 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 ch amber.



### 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 ty pically 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 increa sing 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 f low.

## 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”



### A UTHORS: 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 Or ganics 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:

Me thane, 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 surf ace 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 perio d. 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)

Compo st 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)

Cu ring 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 o f 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 in ternal 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

ammon ia 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 Co mpostex 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 uti lizes 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 emi ssions post mixing. Receiving and finish was also tested.

Feedstock as received and aged 2 Flux tests

- fresh and 24 hours oldCompost Day 1, covered 4 Flux tests, (T1, T2, S1, S2)

Variability Test, Day 1, covered 4 Flux tests, (T1, T2, S 1, 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)

Com post 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 Fl ux 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 av ailable. 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 modifica tions 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 #VO C/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 assessmentproduced representative life

- cycle emissions from the Micropore cover system on food

wast e 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, (te sting 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 efficie ncy o f the biofilter s for both VOC s 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 ch amber.



### 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 prim ary 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 tes tingincluded triplicate stack testing in order to establish inlet concentrations and flow rates

into the biofilters for destruction efficiency determinations.

Process Stack Test s Flux Locations

Primary Composting Compost Surface

- Day 5, 11, 16 No ne 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 m ethod 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

th e recent, validated modifications to the SCAQMD Rule 1133 recommended procedure (6” port, 10% helium tracer). The modifications included the redesigned sweep air inletsystem and stack testing in extended stack, backup tracer, and internal mixer. Data wa s

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 AS P system and biofiltration control.

### Appendix B
Technical Memorandum
CIWMB Modesto Data RecalculationTechnical MEMORANDUM Environmental Management Consulting

41125 278 th 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 Com posting Report

Analysis

A n 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 Joaqu in 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 reason s 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 (SCAQM D) emission factor is presented for comparative

purposes.

Table 1. Preliminary Results



## Basis of Rec alculation

VOC Species

This report calculated VOC emissions as methan e 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 s hown 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.Page 2 of 7

Figure 1

. Assumed Windrow Configuration and Mensuration Formulas

The CIWMB reported the s urface area as 206.4 m 2 . This report calculates the surface area as

212 m 2 . The CIWMB reports the initial bulk density as 360 kg/m 3 . This report calculates the density as 510 kg/m 3 . 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 calculati on, but based on the emissions profile (late cycle emissions go to essentially zero) this should not have significant impact.

The compost win drow 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 th e phenomena extensively. How ever, the data suggest that the vent channels had no more emission s 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 instrum ent screening data are not good
indicators of VOC flux or emissions . Therefore, for this report all top surface values are averagedPage 3 of 7

Table 2

. Windrow Dimensions and CapacitiesPage 4 of 7

Figure 2

. CIWMB Windrow Cross Section (Figure 1. from the CIWMB repor t).

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 i s linearl y interpolated from the measured data. Figure 3 shows the daily emissions profile

.Page 5 of 7

Table 4

. Simulated VOC Emissions Profile.Page 6 of 7

Figure 3. Simulated VOC Emissions Profile.



### Summary

An independent analysis of the Modesto flux data as su pplied 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

emiss ion 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 prod uct.

 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 + /

- 0.7 5 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)Page 7 of 7

 Emission factors for the other test piles are not offered at this time.

### Appendix C
Technical Memorandum Site X Emission ReportTechnical MEMORANDUM Environmental Management Consulting

41125 278 th 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,
d o 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 confide ntial).
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.

Ta ble 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)Figure 1. Emissions Profile

Table 3. Key AssumptionsCE Schmidt, Ph.D.

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### TECHNICAL MEMORANDUM

FLUX CHAMBER SOURCE TESTING OF FUGITIVE AIR

EMISSIONS FROM SITE X C O MPOST FACILITY

Prepared By:

Mr. Tom Card Environmental Management Consulting

41125 278 th Way SE Enumclaw, WA 98022

Dr. C.E. Schmidt

Environm ental Consultant

19200 Live Oak Road
Red Bluff, California 96080

Ma y 7 , 2008CE Schmidt, Ph.D.

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CES#052008. Site X .TM TABLE OF CONTENTS

Page

Executive Summary ii

I. Introduction ............................

.......... 1

II. Test Methodolo gy ............................

. 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 Repo rts

ReferencesCE Schmidt, Ph.D.

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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 f

or 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 comp arison to a full life

- cycle emissions assessment, these data provide a good estimate of process emissions as tested.

T he 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 hig her 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 methods for VOCs or reactive org anic 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

wa s 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 CO MPOSTING OPER ATION

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 1 0

, 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.

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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 2 0 Flux tests

Testing w as 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

SCA QMD Method 207.1 for ammonia. The assessment of the test surfaces included 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

windro w compost ing ( 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 . T here is no scientific justification for apply ing a specific bias correction factor generated from one laboratory to another laboratory, since a given analytical method bias is unique to th at laboratory and not intrinsic to the method.

The data tab les generated and reported in this document describe the fugitive air emission from

the sources test ed on site. These flux data, combined with engineering data that describes the composting operations, can be used to generate a facility emission factor da ta base and a facility

baseline emission esti mate for total VOCs and ammonia. The engineering estimate for VOC and ammonia emissions is reported elsewhere.CE Schmidt, Ph.D.

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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 M s

. Katie Schmidt on March 10, 2008

. Site preparation included arranging for the test pil e s 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 facil ity. This was accomplished by select i n g 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 proce dures, results, discussion of the results, and summary statements.CE Schmidt, Ph.D.

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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 sit e 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 on

site.

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 compo st 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 inter vals, 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 ( ac id 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 c ollection (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 d iscontinued by shutting off the sweep air,CE Schmidt, Ph.D.

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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 da ta sheet. The equipment was then relocated to the next test location and steps 1) through 8) were repeated.CE Schmidt, Ph.D.

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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 form s, 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 w as performed and the recovery of the spike was 101%. These data indicate acceptable method performance.

Cali bration

– 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 w as co llected and the level reported w as <0.00 4 mg per sample (MDL 0.00 4 mg) or below method detection . These data indicate acceptable method performance.

Field Replicate Sample Analysis

-- One field sample w as collected in replicate and analyzed for the project. The RPD va lues for sample/replicate pair was 12 (QC criteria 50 RPD). T hese 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 qual ity control included method blank determinations, and method response to four

- point calibration curves. All method QC testing was with method specifications,

and t hese data indicate acceptable method performance.

Field System Blank

– One blank sample s w a s analyzed a s blind QC sample. T NMNEO levels in the blank sample were less that < 1.0 ppmvC for the condensable, volatile and total hydrocarbon analysis (meth od detection limit 1 ppmvC)

. These data establish sensitivity for the method (project QC

criteria ), and indicate acceptable method performance

.CE Schmidt, Ph.D.

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5 Field Replicate Sample

– One field sample w as collected and analyzed in replicate. In this data set, study compounds detected showed precision within precision criteria for field samples (RPD 50) for

the TN MNEO or total VOC concentration. The RPD for the data set was 9.0 indicat ing 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

av ailable at this time.

Laboratory Precision

– Laboratory QC sample data are not available at this time.

Tracer Recovery Sample

- One media blank sample w as collected in the field by filling a canister for analysis in order to determine tracer recovery a part from the flux measurement technology or the advective flow from sources. The tracer was recovered from the media blank samples with a value

of 10 5 % (QC criteria + 50% , or 50% to 150% recovery ). These data indicate acceptable method performance.

Fie ld Replicate Sample

– One field sample w as 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.

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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 p resented in Table 1

. All laboratory data including q uality control data are presented in Table 2. These flux data include measured adv ective flow rate in the flux

calculation. Surface flux data are shown in flux units for hydrocarbon emissions (mg/m2,mi n

- 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

mi nute [or 0.005 m3/min] plus advective flow [ m3 /min], surface area of 0.13 square meters [m 2 ]). 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 me ters per minute [m 3 /min]), the species concentration Yi (micrograms per cubic meter [mg/m 3 )], and exposure to the chamber surface area A (square meters [m 2 ]), as follows:

Fi = (Q) (Yi) / (A)

Emission rate of from a given static windrow t est 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 jus tification 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.

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7 V. SUMMARY

Emission testing w as performe d on the Site X static windrow, greenwaste compos t operations in

order to generate a n 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 comp ost cycle for the purpose of obtaining representative air emissions of ammonia a nd 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 o n 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 u sing the USEPA recommended surface flux chamber technology as modified by the SCAQMD for advective flow sourc es 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 w as 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 sa mple 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 justif ication 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 testin g 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 ‘f

ront

- 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.

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8  The flux data can be used to estimate am monia

, 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.

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9 REFERENCES

USEPA. 1986. "Measurement of Gaseous Emission Rates From Land Surface s 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 BlankTable 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 purposesTable 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 purposesCE Schmidt, Ph.D.

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EMISSION MEASUREMENT DATA SHEETSCE Schmidt, Ph.D.

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CHAIN OF CUSTODYCE Schmidt, Ph.D.

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CES#052008. Site X .TM ATTACHMENT C

LABORATORY REPORTSGreen Waste Compost EF Report September 15, 2010

11 

### Appendix B

Comments and Responses to the “Organic Material Com posting 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 “Org anic Material Composting and Drying focusing on Greenwaste Compost Air Emissions Data Review ”, by Thomas R. Card and Charles E. Schmidt, June 2008. This repor t will be referred to as the “green waste report” hereafter within this document.

Summary of comments from Center on Race, Poverty an d the Environment (CRPE) /
Committee for a Better Arvin:

CRPE 1: The CIWMB Modesto Study should be excluded from co nsideration because it did not include emissions from the stockpiles.

Response: The green waste report included separate VOC emiss ion factors for the windrows and the stockpiles. The report averaged t he 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 emis sion factor for the windrows.

CRPE 2: The CIWMB Modesto Study should be excluded from co nsideration because the results are not replicable.

Response: This comment is based on Schmidt’s recalculation o f the results, and his conclusion that the published results of the Modest o Study are incorrect. The District has reviewed Dr. Schmidt’s recalculation, and has d etermined that there is not enough justification within the analysis to support the re calculation of previously published study results. Therefore, the District will use the orig inally published emission factor of 0.8 to
0.9 lb-VOC/ton.

CRPE 3: The CIWMB Modesto Study should be excluded from co nsideration 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 oper ations. Conditions during emission measurements at each of the study sites we re representative of conditions during actual operations. It is not possible to de termine if wind is expected to have a significant effect on the VOC emission rates or adj ust measured emission rates without full speciation of the compounds measured. The stu dies 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 foun d to capture a higher proportion of the total VOC emissions when compared to other m ethods. Additionally, there are currently no validated procedures to adjust the mea sured rates for differing wind velocities. In conclusion, the District is using t he 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 conduct ed during the hotter months in the Central Valley. The Modesto report w as 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 ac count 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 pur pose 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 temperat ure for October is actually higher than both March and April. It must also be noted t hat the NorCal study was conducted during August in Vacaville, CA, and records indicat e that the average summer temperatures in Vacaville are very similar to summe r temperatures found in the Central Valley.

The annual compost VOC emission factor developed fr om the studies are intended to be representative of average annual emissions rathe r than peak daily emissions. The
studies that were determined to be suitable for dev eloping 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 Wa ste Systems, Inc. Note that
this letter includes comments on both the emission factor report and the rulemaking process. Only those comments on the emission facto r 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 c onsidered 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. Regard ing the recalculation of the Modesto Study and lack of stockpile emissions – see respons es 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 c omposting cycle in deriving "average"Green Waste Compost EF Report September 15, 2010

14 emission factors. There is insufficient documentat ion provided to allow for independent analysis of temporal or spatial factors as they rel ate to the reported flux rates.

Response: The District agrees that there were limited data a vailable 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 t he variation throughout the composting process. The individual emission factor s from each study referenced in the report were developed from emission measurements fo r different stages throughout complete composting cycle at each site. Additional information on the time and location of emission measurements is available in the origin al study reports referenced.

ERM 4: The data from the green waste report should not b e averaged for the purpose of developing emission factors for regulatory purpo ses.

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 b e averaged for the purpose of calculating annual emissions. There is insuffic ient 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 s tudy reports referenced.

ERM 6: The impact of compost process temperature on emis sions should be considered. It is ERM's professional judgment that temperature variations relate more to the time in the composting cycle than seasonal v ariation 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 re ferenced in the report were developed from emission measurements at differ ent stages throughout the composting cycle at each site, which accounts for t emperature variation of the piles during the composting process. Additional informat ion on temperature measurements may be available in the original study reports refe renced.

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 informat ion becomes available on emissions released during turning of composting windrows, the District will review this information and incorporate it if appropriate. Based on discus sions with Dr. Schmidt, elevated
emissions have been measured from windrows immediat ely after turning but only for aGreen Waste Compost EF Report September 15, 2010

15 few hours, at most, and would not be significant ov er the life cycle of well-managed composting operations.

ERM 8: Data presented for Site X as well as the South Co ast Air Quality Management District (SCAQMD) data yielded higher emissions fro m 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 stockp ile 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 stockpil e EF since it is not representative of SJV stockpiling. The SCAQMD stockpile data is consider ed 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 conditio ns that were representative of conditions found during actual operations and are c onsidered representative of emissions from these operations.

ERM 9: The green waste report states that the Norcal dat a 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 representat ive 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 s pike may be characteristic of some types of composting operatio ns. Additional source test documentation may be available in the original stud y 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 onl y considered data that were measured using SCAQMD Method 25.3. Data collected by other methods may provide
useful relative contributions from the different un it 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 sourc e. However, the resulting emission
factor is based on the best science available at th e time. SCAQMD Method 25.3 has been found to capture a higher proportion of the to tal VOC emissions than the other methods mentioned; therefore, this method was the m ost appropriate for development of VOC emissions factors. The District acknowledge s that data collected by other methods may still be valuable for uses other than d evelopment of emission factors. The District agrees that peer review of reports can be valuable and is generally desirableGreen 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 Distric t source tests are typically not peer
reviewed.

Summary of Comments from California Integrated Wast e Management Board (CIWMB), now know as Department of Resources Recycling and R ecovery (CalRecycle):

CIWMB 1: The green waste report states that the emission fa ctors from each study are averaged for reference only with no implication tha t the average is representative of green waste compost emissions in the San Joaquin Va lley. 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 emissi on factors are not representative of green waste compost emissions, bu t is based on a limited data set from studies suitable for developing emission facto rs. The average emission factors are presented for reference purposes, per District requ est, and are based on the best
science available at the time to calculate annual e missions 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 o f the green waste composting
emissions factors.

Response: Each study at the different composting sites was f ound to have sufficient measurements for the purpose of generating valid em ission factors; therefore, each study is weighted equally to capture the variabilit y of composting operations. The
District used the best scientific information avail able to develop the green waste composting emission factor and is willing to evalua te and discuss any additional scientific information presented related to the emi ssion factor.

CIWMB 3: The report states "The data are even more diverse than this table may indicate." A reasonable interpretation of this comm ent and the one above is that there is too little data to formulate an emissions factor ap plicable 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 c omment 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. Schm idt should review the Day 3 NorCal sampling event to determine whether there are other confounding circumstances.

Response: Other composting studies have also shown an initi al increase in emissions during the composting cycle (see referenced report on Tierra Verde Industries composting operation and ERM comment 7, above). Th ere 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 suppor t the contention that
smaller windrows increase emissions. It seems more reasonable that emissions will
correlate with the amount of materials in the windr ow and operational factors and this is the rationale for having an emissions factor. Assum ing that similar materials have similar potential emissions, a smaller windrow migh t have higher emissions earlier in the process but these emissions should trail off more r apidly.

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 ba sis.” This is true. As long as the surface flux rates remain the same, smaller windrow s will have greater emissions on a per ton basis. However, the District agrees that t he flux rate for the smaller windrow would likely decline more rapidly resulting in simi lar 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 m ore 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 con sisted 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 Modes to data set consists of 100 flux chamber samples, including emission measur ements from green waste composting, food waste composting, composting with a pseudo-biofilter cover, and composting with chemical additives. Only the 36 em ission measurements from uncontrolled green waste composting were considered in this section of the report since the purpose was to evaluate emissions studies for u se in developing an emission factor for uncontrolled green waste composting.

CIWMB 10: The report states that there is no baseline data f or food waste composting. The CIWMB Modesto study includes an emissions profi le 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 operat ions that include some food

waste.

CIWMB 11: We question the assumptions and procedures used to recalculate the emissions reported in the CIWMB Modesto study repor t.

Response: See response to CPRE comment 2, above.

CIWMB 12: Have the results of the emissions study test at Si te 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. S ite Z was not evaluated in the report
because this information was not included in the co mposting emission studies provided to the District from the responsible government age ncy. Additionally, the report authors
indicated that the emissions information was from a n older study and this operation was not considered to be representative of current comp osting 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 t he average age of the feedstock piles is 45 days. We believe that this f eedstock pile is anaerobic. If anaerobic materials are used to create windrows, in itial 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 theGreen Waste Compost EF Report September 15, 2010

19 Zamora windrow VOC EF of 10.03 lb/ton. As such, th e emission measurements at Site X are considered representative of emissions from g reen waste windrows.

CIWMB 16: We believe the emissions factors developed from t he 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 Emi ssions Source Test ”, by Thomas R. Card and Charles E. Schmidt, May 2009Northern 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 R ESULTS

................................ ................................ ................................ ........................ 6

4.0 EMISSIONS CALCULATIO NS

................................ ................................ ................................ ............. 9

4.1 C OMPOST P ILE C ONFIGURATION

................................ ................................ ................................ ................. 9

4.2 F ULL C OMPOST C Y CLE S IMULATION

................................ ................................ ................................ ............ 11

4.4 S IMULATED E MISSIONS P ROFILE

................................ ................................ ................................ ................ 11

4.5 E MISSIONS FROM F EEDSTOCK AND P RODUCT S TORAGE

................................ ................................ .................. 13



### Appendices

A Full Cycle Simulation Table

B Photographs
C Data Validation Technical Memorandum



### Tables

Table ES

- 1 a

. Calculated VOC and NH3 emissions from the f eedstock s torage, compost cycle,

and finished product storage (with winery waste)

. Table ES

- 1 b

. Calculated VOC and NH3 emissions from the f eedstock s torage, 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 3.1 a Summary of Event 1 sampling results (compost with winery waste)

. Table 3.1 b Summary of Event 2 sampling results (compost with out winery waste)

. Table 4.1. Compost Windrow Dimensions and Calculations.

Table 4.2 a

. Event 1 Feedstock e mission c alculati ons (with winery waste).

Table 4.2 b

. Event 2 Feedstock e mission c alculati ons (with out winery waste).

Tab le 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 wa ste in the compost mix . The sec ond event was completed in April 2009 with no winery waste present. USEPA flux chamber samples were taken from actual compost oper ations 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

- 1 a 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 val ue s ( 5.65 # and 6.3 # VOC per ton compost m ix ) 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 co mpost with winery waste

. Total site emissions for VOC were 1 ,0 7 0 tons per year with about o ne half of that attributed to the emissions from the feedstock stockpile for co mpost with out winery

waste

. The annual emission s 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 ammon ia 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 det ection 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 a nd the laboratory samples agreed with the field screening samples. The ammonia emissions without winery waste, however, were essential ly the same as other greenwaste compost

facilities

.2

Table ES

- 1 a

. – Calculated VOC and NH3 emissions from the f eedstock s torage, compost cycle, and finished product storage (with winery waste)

.

Table ES

- 1 b

. – Calculated VOC and NH3 emissions from the f eedstock s torage, compost cycle, and finished product storage (without winery waste)

.3

Table ES

- 2.

– Comparative greenwaste compost emissions (from SJVAPCD).4



## 1.0 Introduction

This project directly measure d the VOC and ammonia air emissions from green waste
compost ing to develop a baseline air emission s 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 F igure 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 Site5

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 fir st 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 2 9 (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 1 6 ( 2 samples)

6. Compost Day 3 1 ( 2 samples)6



## 3.0 Sampling Results

Figure 3.1 a 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 de tection limit for this project was between 0.2 and 0.4 mg/m 3

.

Figure 3.1b presents a summary of sampling results for Event 2. T his data was typical or

p revious greenwaste compost sampling events at other facilities.7

Table 3.1 a Summary of Event 1 sampling results (compost with winery waste)

.8

Table 3.1 b Summary of Event 2 sampling results (compost with out winery waste)

.9



## 4.0 Emission s Calculations

4.1 Compost Pile Configuration

The windrow compost operation consisted of placing ground green waste feedstock in a

windrow for 8 0 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 3 20 tons of material. Table 4.1 provides the

windrow dimensions and calculations.

Figure 4.1.

– Compost Windrow Configuration

.10

Table 4.1.

– Compost Windrow Dimensions and Calculations.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 table s 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 )

.12

Figure 4.3 Simulated NH 3 Emissions Pro file (per windrow)

.13



### 4.5 Emissions from Feedstock and Product Storage

Table 4.2 a, 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 a ssumed to be the same for the winery waste and non

- winery waste compost product.

Table 4.2 a

. – Event 1 Feedstock e mission c alculati ons (with winery waste).14

Table 4.2 b

. – Event 2 Feedstock e mission c alculati ons (with out winery waste).15

Table 4.3.

– Finishe d p roduct s torage e mission c alculations (used for both winery and

non
- win e ry waste containing compost)

.

### Appendix A Full Cycle Simulation TableTable A1 a VOC Cycle Simulation Calculations for Event 1Table A1 a NH3 Cycle Simulation Calculations for Event 1Table A1 b VOC Cycle Simulation Calculations for Event 2Table A1 b NH3 Cycle Simulation Calculations for Event 2

### 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 2009ES-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 r equirement (in conjunction with the surface emission standards) helps to minimize groun dwater 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, excep t under certain conditions (a landfill subsurface fire, fire prevention, repair o f the gas collection system, or construction activities). If a positive pressure i s measured, the owner or operator must initiate corrective action within five days. If th e corrective action is not successful, an expansion of the gas collection may be necessary an d must be completed within 120 days of the date the positive pressure was meas ured.

G. Recordkeeping and Reporting Requirements

In order to assure and monitor compliance with the requirements of the proposed regulation, landfill owners and operators are subje ct to recordkeeping and reporting requirements. These requirements include maintaini ng records of a landfill’s waste acceptance rates, instantaneous and integrating sur facing sampling measurements, component leak checks, equipment downtime, gas flow rates, and control device destruction efficiency testing. Most records are r equired to be kept for a five-year period; however, control device records must be mai ntained for the life of the control device. Some of these recordkeeping items are requ ired 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 wast e-in-place report for landfills with less than 450,000 tons of waste-in-place or a closu re notification report for landfills that are ceasing waste acceptance and closing. Addition ally, an equipment removal report is required when a landfill is seeking to decommiss ion the gas collection and control system. These reporting requirements are similar t o what is already required in local air district and federal rules for many landfills in Ca lifornia.

III. IMPACTS OF THE PROPOSED REGULATION

A. Emissions and Emissions Reductions

Based on ARB staff’s estimate, there would be a red uction of about 0.4 MMTCO 2 E due to bringing 14 uncontrolled MSW landfills into comp liance with the proposed regulation in 2020. The implementation and enforcement of thi s proposed regulation for the remaining estimated 204 affected MSW landfills (inc luding those with gas collections systems already installed) is expected to result in an additional estimated emission
reduction of 1.1 MMTCO 2 E in 2020. This total 1.5 MMTCO 2 E emission reductionSOURCE 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 TECHNOLOGYSOUTH 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 Loc ation

................................ .............. 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) 797-2914SOUTH 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 ft 2 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-1000ft 2

0.138 lb/hr-1000ft 2

0.155 lb/hr-1000ft 2

1.30E-02 lb/hr-1000ft 2

8.41E-03 lb/hr-1000ft 2

3.65 lb/hr-1000ft 2

0.329 lb/hr-1000ft 2

45 Day Pile Average Emission Summary

Contaminant Emissions per

Windrow Pile Emissions per hour per

ton of Compost Mix Emissions per hour per

1000 ft 2 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-1000ft 2

0.162 lb/hr-1000ft 2

0.146 lb/hr-1000ft 2

4.50E-03 lb/hr-1000ft 2

1.14E-02 lb/hr-1000ft 2

1.23E-02 lb/hr-1000ft 2SOUTH 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 ft 2 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-1000ft 2

2.65E-01 lb/hr-1000ft 2

1.97E-02 lb/hr-1000ft 2

<3.51E-04 lb/hr-1000ft 2

8.43E-03 lb/hr-1000ft 2

<1.43E-02 lb/hr-1000ft 2

<1.27E-02 lb/hr-1000ft 2

Average of 3-day, 45-day, & 57-day piles

Contaminant Emissions per ton

of Compost Mix Emissions per 1000 ft 2 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-1000ft 2

6.0E-03 lb/hr-1000ft 2

8.42E-03 lb/hr-1000ft 2

1.23 lb/hr-1000ft 2

0.11 lb/hr-1000ft 2 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

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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 ft 2 (2 Day), 9,630 ft 2 (20 Day), 9,360 ft 2 (50 Day) Average Pile Compost Volume - 29,250 ft 3 (3 Day), 26,325 ft 3 (45 Day), 23,400 ft 3 (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 - 40SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

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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 120-150 o F. 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 ft 2 ), 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 pointsSOUTH 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-ft 2 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 andgaseous 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, CO 2 , O 2 , CH 4 and total gaseous non-methane organic compounds (TGNMOC). CO, CH 4 and TGNMOC concentrations were analyzed by the total combustion analysis (TCA) technique using a flame ionization detector (FID); SCAQMD Method No. 25.1. The O 2 and CO 2 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 forSOUTH 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 AirSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

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Test No: 96-0008, 96-0009

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Empty Midget Bubbler

B u b b l e r w / T a r

e d S i l i c a G e l

Sample Pump Calibrated Rotameter Midget Impingers with 0.1 M Sulfuric acid

From Flux Chamber Sample InSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

96-0007 2/15/96
Test No: 96-0008, 96-0009

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Empty Midget Bubbler

B u b b l e r w / T a r

e d S i l i c a G e l

Sample Pump Calibrated Rotameter Midget Impingers with Acidified Isopropanol

From Flux Chamber S a m p l e I n



# Figure 3 Amines Midget Sampling TrainSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

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Teflon Tubing

Sample In Tedlar Sample Bag Sample Line from Flux

Chamber

Sample Pump



## Figure 4 Integrated Gas Sampling ApparatusSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

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Test No: 96-0008, 96-0009

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# Figure 5 Modified 25.1 Sampling Apparatus (From Flux Chamber)SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

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Test No: 96-0008, 96-0009

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# 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 GaugeSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 21865 E. Copley Drive, Diamond Bar, CA 91765

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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/ASOUTH 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:

F g = Sweep Gas Flow Rate (measured)

C g = Sweep Gas Helium Concentration (analyzed)

F s = Sample Flow Rate (measured)

C s = Sample Helium Concentration (analyzed)

F v = Vent Flow Rate (unknown)

C v = Vent Helium Concentration (assume = C

s 

### )

F c = Compost Surface Migration Flow Rate (unknown)

C c = Compost Surface Migration Helium Concentration (assumed zero)

Flow Balance:

F v = F c + F g - F s

Helium Balance:

F c C c + F g C g = F s C s + F v C vSOUTH 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:

C c = 0

C v = C s

F v = Flow Balance

then:

F g C g = F s C s + (F c + F g - F s )C s

F g C g - F c C s = F s C s + F g C s - F s C s

F c C s = F g C g - F g C s

F g 

### (C g 

### - C s 

### ) F c = C sSOUTH 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 ft 2 (3 Day), 9,630 ft 2 (45 Day), 9,360 ft 2 (57 Day) Avg. Pile Surface Area - 9,660 ft 2

Pile Volume - 29,250 ft 3 (3 Day), 26,325 ft 3 (45 Day), 23,400 ft 3 (57 Day) Density - 1,200 lb/yd 3 (3 Day), 1,014 lb/yd 3 (45 Day), 972 lb/yd 3 (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

NH 3 weighted average = (NH 3 before turning * 0.978) + (NH 3 after turning * 0.022)

For 3 - Day

NH 3 Weighted Avg. = (1.54E-04 x 0.978) + (1.38E-04 x 0.022) = 1.54E-04 lb/hr-ft 2

For 45 - Day

NH 3 Weighted Avg. = (1.46E-04 x 0.978) + (1.62E-04 x 0.022) = 1.46E-04 lb/hr-ft 2

For 57 - Day

NH 3 Weighted Avg. = (1.42E-05 x 0.978) + (2.65E-04 x 0.022) = 1.97E-05 lb/hr-ft 2

Avg. of Weighted Average = 1.07E-04 lb/hr-ft 2

* 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 ft 2 

### 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-1000ft 2



### 6.0E-03 lb/hr-1000 ft 2



### 1.23 lb/hr-1000ft 2



### 0.11 lb/hr-1000ft 2



### 8.42E-03 lb/hr-1000ft 2 

### 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 FT

2 = (Avg. lb/hr-ft 2 ) * 1,000

Lb/Hr = (Avg. lb/hr-ft 2 ) * (Avg. Pile Surface Area)

Lb/Hr-Ton = (Avg. lb/hr-ft 2 ) * (Avg. Pile Surface Area) / Original Pile Mass

* Rain event before 3-day pile test. See test critique.