1 Final Draft Staff Report with Appendices For Proposed New Rule 4566 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL D ISTRICT

FINAL DRAFT STAFF REPORT

Revised Proposed New Rule 4566 (Organic Material Composting Operations)

August 18, 2011

Prepared by: Koshoua Thao, Senior Air Quality Speci alist, Rule Development

Kai Chan, Air Quality Engineer, Permits Brian Clements, Senior Air Quality Engineer, Permit s James Sweet, Senior Air Quality Specialist, Plan De velopment Sandra Lowe-Leseth, Air Quality Engineer, Permits George Heinen, Senior Air Quality Engineer, Permits

Reviewed by: Lori Sheridan, Air Quality Inspector, Compliance

David Garner, Senior Air Quality Specialist, Permit s Mike Buss, Senior Air Quality Engineer, Permits Jessica Fierro, Supervising Air Quality Specialist , Plan Development Leonard Scandura, Manager, Permits Scott Nester, Senior Projects Manager, Administrat ion Jim Swaney, Manager, Permits Errol Villegas, Manager, Strategies and Incentives Samir Sheikh, Director, Strategies and Incentives

I. SUMMARY

Under their regulatory authority to assess the heal th impact of air pollutants and to establish air quality requirements, the California Air Resources Board (ARB) and United States Environmental Protection Agency (EPA) have e stablished standards for ozone levels that impact public health. The San Joaquin Valley Unified Air Pollution Control District (District) adopted the 2007 Ozone Plan to establish the strategy for attaining the eight-hour ozone standards through regulatory and i ncentive-based measures to reduce emissions of nitrogen oxides (NOx) and volatile org anic compounds (VOC).

Conversion of organic material to compost (composti ng) emits VOC but provides benefits by reducing odors, eliminating pathogens, and reducing the bulk of organic material. In comparison to natural decay, bacteria l activity in the conversion of material to compost provides a benefit for reduction of glob al warming emissions by keeping carbon in the bacterial cell structure thereby redu cing the total amount of carbon escaping into the air. EPA evaluated composting an d determined that the thirty year (life cycle analysis) retention by carbon sequestra tion results in reduction of global warming that far outweighs the other composting emi ssions of carbon and nitrous oxide. Further discussion of this topic is included in the Climate Change section of this staffSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

2 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 report. Composting converts material into a form that makes nutrients available for plant growth, resulting in material that is a rich soil amendment. Composting also eases the burden on landfills by helping cities and count ies meet landfill diversion targets.

Throughout the development of the District’s New Ru le 4566 (Organic Material Composting Operations), which would apply to the Va lley’s composting operations that compost and stockpile organic material, the Distric t has sought to balance requiring reduction of composting VOC emissions with allowing for the continued benefits achieved by composting. The District’s goal in Rev ised Proposed New Rule 4566 is to reduce VOC emissions through requirements that can be feasibly implemented without resulting in operational expenses or finished produ ct costs that would render composting operations economically inoperable.

District efforts to develop a regulation that would reduce emissions from organic material composting operations began in 2007. Afte r extensive review and collaboration with stakeholders, the District resch eduled the rule adoption in 2009 to allow for additional research and analysis. In 200 9, the District collaborated with numerous stakeholders and agencies to direct a fiel d study designed to measure the effectiveness of four candidate best management pra ctices: finished compost cover, watering system, interactive management, and smalle r piles. Based on the results of this field study, which was successfully completed in 2010, the Revised Proposed New Rule 4566 would focus on the finished compost cover and the watering system. The

District will continue to work with the affected in dustry to address any items regarding control costs, technical feasibility, economic impa cts, and other limitations or benefits to this regulatory approach.

A. Reasons for Rule Development and Implementation

The San Joaquin Valley Air Basin (SJVAB) is nonatta inment for the National Ambient Air Quality Standard (NAAQS) for 8-hour ozone. The Valley is also nonattainment for

the California ozone standards. The District’s 2007 Ozone Plan included a green material composting control measure (S-GOV-5, Rule 4566) to reduce VOCs from this source category. Although VOC emissions contribute to ozone, VOC reductions are generally less important to the Valley’s long-term attainment goals as compared to reductions in NOx. However, since the District pro posed to develop a rule as part of the

2007 Ozone Plan

commitment, the rule seeks to obtain as much VOC r eductions as expeditiously practical, technologically feasible, and as economically reasonable as determined by the Governing Board.

In the 2007 Ozone Plan , District staff estimated that the total VOC emiss ions from composting operations would be about 62 tons per da y (tpd) in 2014, based on the best

data available at that time. Staff noted that rese arch was being conducted to refine the emission factors for this source category, since th e Air Resources Board (ARB) inventories did not yet account for green material composting. Through collaboration with the composting stakeholders, current information indica tes that the total VOC emission, basedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

3 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 on actual throughput levels, is about 14 tpd. The revised emission estimate is less than previously expected, but still a significant portio n of the total VOC inventory.

Development of Revised Proposed New Rule 4566 is in tended to obtain as much VOC emissions reduction from the source category as is technologically and economically feasible, as determined by the District's Governing Board.

B. Description of the Project

Consistent with the 2007 Ozone Plan commitments, Revised Proposed New Rule 4566 would establish VOC limits, including operational a nd administrative requirements, for organic material composting operations. Specific c omposting operations that would be subject to the proposed rule requirements include s tockpiling and composting of organic material. Organic material is defined in the rule as food material, green material, or a mixture thereof, and may include wood material and a total of less than 100 wet tons per year of biosolids, animal manure, or poultry li tter. Composting operations with more than 100 wet tons of biosolids, animal manure, or p oultry litter are subject to District Rule 4565 (Biosolids, Animal Manure, and Poultry Li tter Operations) for that portion of the organic material.

The District recognizes stakeholders’ efforts to co mply with regulations from various agencies involving the disposal and recycling of or ganic material, particularly for composting. While composting of organic material i s one of the desired alternative methods to divert reusable material from landfills, there are potential impacts to the air quality within the SJVAB. However, the District al so recognizes that several composting operations are already taking measures to help redu ce emissions through responsible composting practices.

During composting operations, the active phase of c omposting is a significant part of the process in which the compost feedstock is rapidly d ecomposing. VOC emissions occur in the highest amounts during the active phase. Fo llowing that, the curing phase is characterized by lower VOC emission rates. Revised Proposed New Rule 4566 utilizes the significant difference in emissions between the active phase and curing phase as a

means to focus the VOC reduction efforts to a short er period of the compost development process. This focus reduces the cost o f implementation of the rule while ensuring sufficient VOC reduction effectiveness.

Revised Proposed New Rule 4566 would establish VOC emission reduction requirements on the basis of actual throughputs, ra ther than the maximum allowable capacity limits, for the composting operations, whi ch is representative of the current baseline emissions for this source category. The p roposed requirements are as follows:

• Composting operations with an organic material rec eiving volume of less than 200,000 wet tons per year of organic material would be subject to the wateringSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

4 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 system requirements or alternative mitigation measu res that demonstrate at least a 19% reduction, by weight, in VOC emissions.

• Composting operations with an organic material rec eiving volume of greater than or equal to 200,000 tons per year and less than 750 ,000 tons per year would be subject to both the watering system and the finishe d compost cover requirements or alternative mitigation measures that demonstrate at least a 60% reduction, by weight, in VOC emissions.

• Composting operations with total throughput of 750 ,000 tons per year or more would be subject to mitigation measures that demons trate at least 80% reduction, by weight, in VOC emissions for organic material.

The proposed rule further reduces VOC emissions fro m composting operations by limiting the number of days that the organic materi al could be stockpiled. Please refer to Section III (Current and Proposed Regulations) o f this report for additional

information.

• Composting operations with less than 100,000 tons per year of organic material would be subject to a 10-day stockpile requirement.

• Composting operations with 100,000 tons per year o r more of the material would be subject to a three-day stockpile requirement.

Table 1 shows the summary of the proposed rule requ irements for composting operations, based on the total throughput of the co mposting operation.

Table 1 – Summary of Revised Proposed New Rule 4566 Requirements

Throughput Classification Proposed Requirements

Remove or

Cover the stockpile Composting Controls during

Active Composting

Throughput < 100K tpy

Within 10 days Watering system or an equivalent VOC reduction mitigation measure 100K tpy ≤ Throughput < 200K tpy

Within 3 days Watering system or an equivalent VOC reduction mitigation measure

200K tpy ≤ Throughput < 750K tpy Within 3 days Watering System and Compost Cover or an equivalent VOC reduction mitigation measure Throughput ≥ 750K tpy

Within 3 days Mitigation measure that

demonstrates at least 80% reduction, by weight, in VOC

emissionsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

5 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 C. Rule Development Process

District staff began the rule development process w ith extensive research in 2007, which was followed by a public scoping meeting on J anuary 10, 2008. Based on the

research conducted and information obtained with th e best available data, the District created a draft version of Rule 4566 that proposed to adopt a menu based approach and require the implementation of various managemen t practices (such as monitoring carbon to nitrogen ratios, moisture content measure ments, oxygen concentration, etc.), including installation of engineered control system s. To obtain comments on the draft rule, the District held a public workshop in April 2008 and convened several site visits and technical workgroup meetings during 2008 and 20 09 to work with various stakeholders to address costs, technical feasibilit y, economic impacts, and other limitations or benefits to this regulatory approach

.

Although the meetings and visits in 2008 were inten ded to culminate in the Governing Board adoption of Rule 4566 in the first quarter of 2009, information that came to light during those meetings showed that more time would b e needed to increase the scientific justification behind proposed rule requi rements which would allow the District to develop an effective composting rule. District staff had determined that emissions from this source category were much lower than prev iously estimated in the 2007

Ozone Plan . There was also insufficient information availabl e, at that time, on the effectiveness of reducing VOCs from potential mitig ation measures. For these reasons,

District staff determined that additional time was needed to study the effectiveness of

various control methods. District staff therefore requested an extension to the rule development schedule, and the District Governing Bo ard amended the 2007 Ozone

Plan on December 18, 2008 to extend the Rule 4566 adopt ion schedule from the first quarter of 2009 to the fourth quarter of 2010.

In 2009, multiple agencies contributed $200,000 for the composting field study, which was conducted at Tulare County Composting by the San Diego State University Research Foundation. The District engaged in exten sive stakeholder involvement and numerous technical workgroup meetings to help defin e the parameters of the field study. Participants of these meetings included com posting operators, ARB, California Department of Resources Recycling and Recovery (Cal Recycle), agricultural groups, environmental advocates, other air districts, and c ity and county agencies. The results of this study were successfully completed in 2010 a nd formed the basis for the Revised Proposed New Rule 4566. The compost study identifi ed two promising mitigation measures, watering system and finished compost cove rs.

In September 2010, the District held a workshop to present and discuss the proposed rule concepts. Based on the results of the study, the District drafted rule requirements that would require facilities with annual throughpu ts of more than 10,000 tons year and less than 25,000 tons per year to implement the wat ering system requirements, whereas, composting facilities with throughputs gre ater than 25,000 tons per year would have been required to implement the finished compos t cover. Based on the industrySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

6 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 reaction to the proposed rule requirements, Distric t staff worked closely with the affected stakeholders to refine the rule requiremen ts, as well as address the cost impacts to affected facilities and feasibility conc erns for the watering system and finished compost cover requirements. The District convened additional technical working group meetings to discuss potential applica bility thresholds greater than the 10,000 ton per year limit and refine other proposed rule requirements.

Approaching the extension deadline with a number of questions still remaining regarding the feasibility and cost of actually impl ementing these various potential emission reduction strategies; in December 2010, Di strict staff provided an update to the District’s Governing Board on the status of thi s project with plans to bring forth a proposed rule for Governing Board consideration in 2011.

Following the December 2010 Governing Board update, District staff continued to work closely with stakeholders to address these remainin g issues. District staff conducted weekly discussions with affected operators and comp osting representatives to obtain

cost estimates and devise solutions to overcome fea sibility questions. Staff and management have conducted additional site visits th roughout the Valley to discuss stakeholder concerns in person and in order to bett er understand the implications of proposed rule requirements to the operations. Base d on the collaboration with the interested stakeholders, the District was able to r efine the rule requirements and minimize the overall impacts associated with the pr oposed rule.

During this time period, District staff also collab orated with South Coast Air Quality Management District (SCAQMD) staff to share informa tion as they concurrently work to develop a rule impacting similar sources in their r egion. Outreach efforts have also led to discussions with CalRecycle and Local Enforcemen t Agency (LEA) staff to discuss chipping and grinding regulations and the state’s T itle 14 requirements.

Based on several discussions and additional informa tion from stakeholders, District staff was able to refine the draft rule concepts to inclu de detailed information on the watering system requirements for composting operations with less than 200,000 tons per year of organic material and finished compost cover require ments for composting operations with 200,000 tons per year or more of organic mater ial. To further solicit input from affected stakeholders, the District held a technica l working group meeting in March 2010 and presented the revised rule concepts to the workgroup. The rule concepts would allow operators the ability to comply with th e requirements with minimal impact to the composting operations. District staff also add ressed operators concerns with rain events and water run off issues with implementing t he watering system. After the meeting, District staff continued to work with the operators to address the costs of implementing the mitigation measures, update the fa cility throughput information, and gather information on the feasibility of implementi ng the finished compost cover.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

7 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 While feasibility concerns were no longer a primary concern, costs of implementing the proposed rule requirements was still a concern for one operator. Staff has worked closely with this operator to understand and refine their cost estimates to develop the best information possible for evaluation of potenti al rule requirements.

District staff conducted a public workshop on June 23, 2011 to present, discuss and receive comments on the draft rule, staff report, a nd a socioeconomic analysis report. As with previous workshops, the District provided a two week commenting period after the workshop for any additional public comments. D uring the commenting period,

District staff continued to work with the affected stakeholders to resolve any remaining concerns, specifically on industry’s costs of imple menting the watering system and the feasibility of implementing the finished compost co ver for one facility. District staff has incorporated the additional information received fr om stakeholders into the staff report and proposed rule, as appropriate. To address the remaining operator’s concern with implementing the finished compost cover requirement s, the proposed rule would extend the schedule for the finished compost cover to five years. District staff recognizes the potential implications that the proposed requiremen ts may have on the remaining operator’s facility and will continue to work with the operator to evaluate ways to comply with the rule. The schedule would allow the operat or to determine and develop effective control strategies specific to the facility’s opera tion. The additional time would also allow for any incremental absorption of costs or in crease in tipping fees/sales.

The proposed rule, staff report with appendices, an d final draft socioeconomic analysis report will be published on July 19, 2011. The pub lication will allow affected sources and interested parties an additional opportunity to review and comment on the proposal prior to a public hearing before the District Gover ning Board on August 18, 2011, who will consider adoption of the Revised Proposed New Rule 4566.

To gain first-hand knowledge of these operations, D istrict staff conducted several visits to the following composting facilities since 2008:

• City of Modesto

• Community Recycling Lamont Composting Facility

• Highway 59 Compost Facility

• Mariposa County Solid Waste Composting Facility

• South Kern Compost Manufacturing Facility

• Tulare County Composting & Biomass, Inc.

• Recology Grover Environmental Products (Vernalis)

II. BACKGROUND

Composting material can enrich the soil, replace fe rtilizer, divert waste from landfills, and serve other purposes. Composting is often adva ntageous for bulk reduction, pathogen reduction, and odor reduction. It also pr oduces a material with variousSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

8 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 beneficial uses, such as landscape, soil amendment, road use, and alternative daily covers (ADC) at landfills. Composting also helps l ocal government agencies meet state solid waste diversion goals to preserve landfill ca pacity by reducing the amount of organic waste sent to landfills for disposal.

The composting industry has been expanding and will continue to expand. CalRecycle’s Strategic Directive 6.1 aims to reduce the amount of organics in the waste stream by 50% by 2020. Diversion of half of CalRec ycle’s 2006 baseline of 29.7 million tons would require the development of 50 to 100 new composting operations in

California. While diversion of materials from land fill disposal to composting will help

ease the burden on landfills and achieve associated environmental benefits, the increase in composting will also increase VOC emiss ions associated with the operations and possibly NOx emissions from increased trucking of organic materials from outside of the SJVAB. Implementation of the proposed mitig ation measures can help minimize impacts in the Valley. Air quality goals must be b alanced with diversion goals. The primary objective of Revised Proposed New Rule 4566 will be to reduce VOC emissions from organic material composting operations, includ ing stockpiling at composting operations, as required in the 2007 Ozone Plan, without making composting cost prohibitive.

A. The Composting Process

Organic material naturally decomposes by both bacte rial (biotic) and nonbacterial (abiotic) natural processes. Organic waste decompo ses naturally in the presence of water, warmth, and oxygen. Composting accelerates the process of decomposition by adding moisture and creating a physical arrangement (such as windrows) that maintain an elevated temperature and provide an ideal enviro nment to facilitate biotic decomposition to transform the stock material into nutrient-rich humus like material commonly referred to as compost. The composition a nd density of stock material affect the rate of decomposition.

The composting process typically involves six major steps:

1. Recovery and Preparation . Operators receive the organic material from eith er private or public industries and may screen the mat erial for physical contaminants, pursuant to Title 14, Div. 7, Chapter 3.1, Article 7, Section 17868.5. The feedstock may also need to undergo ch ipping or shredding to obtain the appropriate size material for the compos ting process.

2. Mixing . Feedstock may be mixed with additives or amendme nts to adjust the bulk weight, carbon to nitrogen ratio, moisture con tent, and porosity of the material. The mix enhances the composting process, provides structural support for the compost piles, or produces compost with spe cific characteristics. Operators often select additives and amendments bas ed on availability, cost, and degradable content. Some additives and amendments include overs, peanutSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

9 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 hulls, rice hulls, sawdust, straw, shredded tires, and wood chips. However, shredded tires and wood chips do not readily compos t and may be recycled through multiple composting cycles.

3. Piling . The compost material is typically placed into pil es on open fields or enclosed in an in-vessel system. The piles can str etch up to a few hundred yards in length.

4. Active Composting . Microorganisms break down the material and consum e the most easily degradable organic matter. These micro organisms give off significant heat, raising the temperature of the co mpost and destroying pathogens. The material is aerated by turning or b y forcing air through the piles to provide oxygen for the microorganisms. Most of the VOC emissions generated by composting are expected to occur durin g the active stage.

5. Curing Composting . The microbial populations shift to bacteria and fungi, which break down the less degradable organic matter like chitin, cellulose, and lignin. The curing process stabilizes the compost by transforming it to a material that cannot be further easily decomposed. Heat and VOC emissions are more stable during the curing phase, as compared to the active compost phase.

6. Finished Composting . During the final stage, compost may be stored to complete the maturing process and to ensure that th e compost material is resistant to further microbial breakdown, which cou ld potentially harm living plants. Once the maturing process is complete, the finished compost undergoes screening for sale or use.

B. Composting Parameters for Windrow Composting

Operators maintain their windrows within specific p arameter ranges to efficiently convert the incoming materials to finished compost. The pa rameters discussed in this section are oxygen, temperature, moisture, pH, and carbon-t o-nitrogen ratio. The parameters

affect the immediate environment and interact with each other. As an example, readilyavailable carbon can increase the microbial activit y which increases the temperature of the windrow. The increased activity decreases the oxygen level within the pore space because the microbes utilize the oxygen as part of the degradation process. The increased temperature may cause the water to evapor ate faster, reducing the moisture in the vicinity of the increased microbial activity . Decreased moisture can mean that the temperature increases even more because there is le ss water to absorb the heat generated by the composting reactions. Or, if too d ry, the microbes can go dormant or

die from lack of water.

Although the parameters described below are measura ble characteristics of effective composting operations, District staff is not consid ering a prescribed range of values for the parameters as part of the proposed rule require ments for organic material. Based onSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

10 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 discussions with the composting operators, many of the parameters below are already being monitored as part of the composting operation to promote best practices and to produce quality products. Since the composting pro cess is unique to each facility, there are several methods that operators use to define th ese parameters. To require specific test methods for these facilities would potentially result in significant costs and change in operation to the affected operators. For this r eason, the provisions of Rule 4566 will focus on other compost emission control strategies.

Oxygen Aerobic processes utilize oxygen acquired from the environment, namely through the diffusion of oxygen from air into the water film wh ere the aerobes (microorganisms that utilize oxygen in their life processes) reside. Ma intaining a healthy oxygen level within the pore space promotes aerobic respiration—which i n turn, increases biological breakdown of the composting materials and reduces o dors As the oxygen level in the area decreases, anaerobic microorganisms increase a t the expense of the aerobes because the aerobes have less oxygen available for their life processes.

In order to reduce the amount of anaerobic degradat ion, the pore-space’s air needs to

be “refreshed” from time to time as the aerobes use up the available oxygen in the enclosed space. The simplest way to get more oxyge n to the aerobes is to break up the windrow and re-mix the partially-composted material . The pore-space is broken up and exposed to fresh air and re-formed into a windrow i n a “turning event.” In an ideal turning event, the windrow material is completely r earranged where all of the porespaces are broken open, exposed to fresh air, and t hen reformed into new pore spaces.

Moisture Water plays an essential role in composting. It se rves as the medium for the microorganisms that perform the decomposition. Wat er is also an extraction solvent to remove organic molecules from the substrate and fro m the air. Because of its fluidity, water serves to circulate oxygen and extracted comp ounds to the aerobes as well as circulating expelled compounds to other microorgani sms in the water film. Water also absorbs heat from the chemical breakdown of the org anic molecules.

In composting, there must be enough water to perfor m all the necessary functions, but not so much water that the aerobes drown, meaning t hat there is not enough oxygen diffusing into the water film where the biological activity is taking place to allow aerobic decomposition. On the other extreme, there should not be so much air passing through that the water film evaporates. As a rule of thumb , windrow moisture content between 40% and 70% is ideal for composting. Below 40%, mi crobial activity becomes very limited. Above 70% moisture content, the pore is s o filled with water that there is little air in the pore space, and therefore, the aerobes u se up the available oxygen in a short

time. A windrow’s overall moisture content can be maintained by turning the windrow to break up pockets of too wet or too dry material and more evenly distribute the moisture

within the windrow.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

11 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Temperature Temperature can be an indication of biological acti vity for composting operations and is fairly easy to measure. However, the temperature d oes not necessarily indicate that there is biological activity in the windrow, especi ally on certain summer days, between high air temperature and a sunny location.

Assuming that there are other indications of microb ial activity, the temperature increase in a composting windrow is due to the chemical reac tions performed by the microbes, which liberate heat as a by-product of the reaction . In general, windrow temperatures between 20°C and 60°C (72°F and 140°F) are ideal si nce it is indication of desirable ongoing biological processes. Above about 65°C (150° F), microbial activity is hindered. Additionally, piles may burn at high temperatures; so many operators have a maximum temperature that they use to trigger a turning even t.

The temperature in an active windrow can affect com post operations in variety of ways. Since higher temperatures indicate high microbial a ctivity; the oxygen level in the pore space would be depleted quickly causing anaerobic c onditions discussed above. For this reason, some operators turn composting windrow s more frequently during the early stage of composting to dissipate heat generated by intense microbial activity.

pH In any biological process, pH is an important facto r since it affects the microbial activity. Most organisms require a growth media with a near-n eutral pH, meaning pH in the vicinity of 7.0.

Carbon to Nitrogen (C:N) Ratio All organic matter is made up of substantial amount s of carbon (C) combined with lesser amounts of nitrogen (N). The balance of these two elements in an organism is called the carbon-to-nitrogen ratio (C:N ratio). For best performance, the compost microorganisms require the correct proportion of ca rbon for energy and nitrogen for protein production. Composting organisms use about 30 times more C than N. However, the carbon and nitrogen must be in a form that the microorganisms can process. Woody materials, for example, have carbon that is difficult for the composting microorganisms to extract, so even though there is high amounts of carbon in woody material, it cannot be used directly by most microb es. In a compost windrow with a 30:1 carbon-to-nitrogen ratio that utilized only wood ch ips as the carbon source, composting may not actually occur because the carbon in wood c hips is not readily available to the microorganisms and the organisms might starve for l ack of an energy source.

In addition, operators may not be able to choose th e composition of their feed stock. Municipalities with curbside recycling, for example , must accept and process the material brought to the composting operation throug h the curbside program, regardless of the gathered materials’ makeup. The type of org anic material accepted at the compost operations could also vary from season to s eason.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

12 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 C. Locally Studied VOC Emission Control Technologie s for Composting

District staff obtained an understanding of compost ing factors through discussions with

stakeholders and scientists who have researched com post emissions. Some factors that affect the process of composting require profe ssional judgment by the operator during the composting process, while other factors provide a more routine and quantifiable response that was determined to be mor e suitable for research on possible mitigation approaches. District staff, in discussi on with stakeholders, set up a research evaluation of composting in 2009, designating one w indrow as a scientific “control” with standard procedures to compare to other windrows wi th application of water prior to turning; application of finished compost cover to a ct as a passive biofilter; alternative interactive management; and a small windrow reducin g the height and volume compared to the control. During the composting pro cess, the compost pile is turned every few days to prevent compaction and maintain a ir space within the pile material. The finished compost cover was reapplied after each turn during the composting process for one windrow.

Based on the study results (SJVAPSA, Draft 2011), b oth the practices of applying water before turning and of applying a finished compost c over after turning were found to reduce VOC emission. The following figure provides a comparison of the control windrow to the windrow with application of finished compost applied as a cover. Figure 1 show that most of the VOC reduction is accomplish ed in the first 22 days which was the time period of the active phase of composting f or the control windrow.

Figure 1 - Compost Emission Comparison

0 50 100 150 200 250 300 350 400

2 3 5 7 10 15 22 29 36 41 50 64 78 99

Day of Composting ProcessVOC Emissions * Typical Compost Windrow Application of Finished Compost Cover

* VOC measurements are comparison values, not conve rted to per compost ton or per windrow units

Source: Appendix I to study results report (SJVAPSA , Draft 2011)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

13 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Reducing volume of the windrow was found to actuall y increase VOC emissions. Interactive management was determined to be a diffi cult process to quantify. In addition to the research results, staff learned from stakeho lder and researcher communications about other factors that have been found to negativ ely impact the composting process. For example, stacking materials too high or compact ing materials too tightly causes areas of the pile to have low oxygen levels, result ing in anaerobic decomposition, which

increases odor emissions. Odor emissions include s ome VOC compounds, therefore, proper management to control odor may also reduce V OC emissions.

D. Potential VOC Emission Control Measures for Comp osting

In addition to the methods examined in the District ’s composting study, available technologies for collecting and controlling VOC emi ssions are described below. Several of these control technologies are currently operate d by a few co-composting operations, which handle primarily biosolids, animal manure, an d poultry litter. These facilities are relatively new and designed their facilities to inc lude these controls to satisfy Best Available Control Technologies (BACT) and other per mitting requirements. At this time, District staff is not aware of any composting opera tions in the SJVAB that operate these controls for organic material.

Aerated Static Pile (ASP) system For the ASP method, operators pile the feedstock ov er a base of porous materials. Perforated pipes or plates are connected to a blowe r that either pulls (negative pressure) or pushes (positive pressure) air through the pile. Several operations in California and other parts of the country use ASP v ented to controls, such a biofilter,

with control efficiencies of at least 80%. Additio nal information on these controls can be found on the following page.

There are two forms of ASP systems. The first form generally uses long triangular piles with a base width that is two times as long as the height. Aeration pipes run lengthwise beneath the ridge of each pile and serve the entire pile. Each pile contains feedstock of roughly the same mixture and age.

The second form uses extended piles consisting of i ndividual cells that are stacked against each other. Cells of new feedstock are con structed in one pile, and cells of nearly mature compost are placed in another pile. The space between the piles allows for the removal of old cells from one pile and the addition of new cells to another pile. Generally, there is also an individual blower and t imer during the aeration process of each cell. The captured VOC emissions from the ASP system may be transferred to a control, such as a biofilter, for VOC reductions.

Enclosed Aerated Systems In enclosed aerated systems, the material is placed in a bag, container, or other enclosure, and then the material is aerated. The a eration method controls moisture, temperature, and airflow; however, it does not vent the air in the enclosure to a controlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

14 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 device. The system achieves VOC emission reduction s by increasing the percent of aerobic composting and decreasing the percent of an aerobic composting by providing oxygen to promote aerobic activities.

Within-Vessel and In-Vessel Composting The within-vessel and in-vessel composting methods allow the operator to control the moisture, temperature, and airflow to a more exact science and to capture most of the emissions. The VOC capture efficiency for in-vesse l systems ranges from 90% to 99%, while the VOC capture efficiency for within-vessel systems ranges from 70% to 90%. Within-vessel composting operations are performed b y processing the feedstock material and loading it into bags or containers. I n-vessel composting operations occur in a permanent enclosure under negative pressure. An electric blower system controls airflow and temperature for both systems. A second ary control receives and further reduces the captured VOC emissions. The secondary control includes, but is not limited to, a biofilter or a liquid capture and con trol system.

VOC Controls, including biofilters VOC controls can reduce VOC emissions captured from collection systems, such as ASPs. Typical VOC controls include biofilters, car bon adsorption systems, and packed tower scrubbers. Biofiliters are the most commonly -used controls at composting operations. Currently, biofilters are used at over 200 composting operations in Europe, over twenty composting operations in the U.S., and at least five composting operations

in California.

The typical biofilter design consists of fans, duct s, media support (a bed liner), an air plenum, and the media (often a blend of finished co mpost or soil, and wood chips). Wall ventilation and pit fans blow air from the bui lding and pit through ducts, then into an air plenum below the biofilter media. The air pass es through the media, where microorganisms treat the air before it escapes to t he atmosphere. Figure 2 shows a schematic of an enclosed biofilter system. Recent District BACT determinations

indicate that biolfilters have a VOC destruction ef ficiency of at least 80%.

Figure 2 - Sample Biofilter Design

Scrubbed

Exhaust Air Enclosure with Compost

Pit Air Duct

Air Plenum Media Vent Fan Biofilter Set-UpSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

15 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Aside from biofilters, stakeholders have also indic ated the possibility of applying pseudobiofilters (or finished compost covers) on to p of static piles or aerated static piles as a viable emission reductions technology. The ap plication has been used in many situations to reduce odors from composting faciliti es. District staff is currently not aware

of studies that show actual reduction in VOC when a pplying the finished compost cover on top of static piles or aerated static piles. Ho wever, based on recent field studies, the use of finished compost cover on top of windrows ha s shown to be an effective mitigation measure in reducing VOC. The actual VOC reduction from the finished compost cover application could vary between windro w composting and static piles or aerated static piles, which operate differently. T he District will consider any future studies and information on the effectiveness using finished compost on top of static piles and aerated static piles for organic material s.

III. CURRENT AND PROPOSED REGULATIONS

A. Current Regulations

District staff has reviewed applicable regulations from the District, other air districts, and other agencies to assist in the development of Revi sed Proposed New Rule 4566. District Rule 4565 (Biosolids, Animal Manure, and P oultry Litter Operations), which was adopted in March of 2007, regulates the composting and co-composting of biosolids, animal manure, and poultry litter. Currently, the District does not have any prohibitory rules that specifically regulate VOC emissions from composting and stockpiling of organic material.

The development of Revised Proposed New Rule 4566 i s not intended to replace any more stringent local, state, federal, or other gove rnmental agency requirements. Where multiple rules apply to a facility, the operator mu st comply with all applicable rules. Composting operations in the Valley may also be sub ject to regulations from other agencies:

• Title 14, Div. 7, Chapter 3.1 Article 6, Section 1 7867, along with other California Code of Regulations;

• Waste discharge requirements of the Porter-Cologne Water Quality Act (California Code of Regulations Section 13020), as administered by the Regional Water Quality Control Board (RWQCB). Based on disc ussion with RWQCB, composting of organic material, specifically green material, is not currently regulated by the agency.

B. Review of Other Air District Related Regulations

The South Coast Air Quality Management District (SC AQMD) and Antelope Valley AQMD have adopted regulations for co-composting (co mposting that involves animalSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

16 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 manure or poultry litter). Green material composti ng operations is not currently regulated by Antelope Valley AQMD. SCAQMD recently adopted Rule 1133.3 (Emission Reductions from Greenwaste Composting Ope rations) for composting of green material and food material. As previously me ntioned, District staff collaborated with SCAQMD staff to share information as they conc urrently work to develop a rule impacting similar sources in their region. Please refer to the Reasonable Available Control Technology section for further discussion o n SCAQMD’s Rule 1133.3.

C. Proposed Regulation

1. Section 1.0 Purpose / Section 2.0 Applicability

Revised Proposed New Rule 4566 would limit VOC emis sions from composting operations, which include composting and stockpilin g of organic material at composting operations. Revised Proposed New Rule 4566 would r egulate organic material, which is defined as food material, green material, or a m ixture thereof, and may include wood material and a total of less than 100 wet tons per year of biosolids, animal manure, or poultry litter. Other than recordkeeping, wood ma terial that is source separated and is not mixed with other organic material is exempt fro m the proposed rule requirements. Revised Proposed New Rule 4566 would allow operator s to compost a total of less than 100 wet tons per year of biosolids, animal manure, or poultry litter to address materials that operators may inadvertently receive at the fac ility for composting.

2. Section 3.0 Definitions

Several definitions presented in this rule are from existing regulations from the District, other air districts, and state and local agencies. District staff also included additional definitions to further clarify the intent of the pr oposed rule requirements.

The definitions for the active phase and curing pha se are intended to provide operators the flexibility to choose from several methods to c omply with the rule requirements. As explained in Section II.C., Figure 1, most of the V OC emissions occur in the first 22 days for a typical windrow, which is the time perio d of the active phase. The curing phase begins immediately after the active phase and typically last for a period of 40 days. The number of consecutive days for both acti ve phase and curing phase would be considered the lower time limit, unless operator s determine a shorter time limit through other test methods. The test methods in th e proposed rule include: Specific Oxygen Uptake Rate, Carbon Dioxide Evolution Rate, and the Solvita® Maturity Index. However, operators may use an alternative test meth od to satisfy the rule requirements for which a written approval from the APCO has been obtained. The test methods would typically be used in cases where operators im plement other alternative mitigation measures that result in shorter time periods. The number of days and various test methods for the active phase and curing phase are c urrently used in practice and are similar to the definitions from the following air d istricts’ rules:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

17 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 • San Joaquin Valley Unified APCD - Rule 4565 (Bioso lids, Animal Manure, and Poultry Litter)

• South Coast AQMD - Rule 1133.2 (Emission Reduction s from Co-composting Operations)

• Antelope Valley AQMD - Rule 1133 (Composting and R elated Operations)

The limits for the test methods above are from the Compost Stability Index (Table 05.08-1), which can be found in the Test Methods fo r the Examination of Composting and Compost (TMECC) manual by the US Composting Cou ncil Research and

Educational Foundation.

3. Section 4.0 Exemptions

Stockpile and composting operations that are subjec t to Rule 4565 (Biosolids, Animal Manure, and Poultry Litter Operations) would be exe mpted from Revised Proposed New Rule 4566. However, a facility could have two oper ations on site where both Rule 4565 and Revised Proposed New Rule 4566 would apply. Co mposting operations claiming exemption under Rule 4565 must handle biosolids, an imal manure, or poultry litter as part of the operation but would only be exempted fo r the materials that are cocomposted. If the operator also had a composting o peration that did not include cocomposted material, then that part of the facility would fall under Rule 4566.

Other Stockpile Operations Operations that stockpile organic material and are not required to obtain a composting permit from the District or a Compostable Materials Handling Facility Permit in accordance with Title 14 would be exempt from Revis ed Proposed New Rule 4566 requirements. An example of when a facility would have one permit and not the other is a facility that does not compost organic material b ut has a Compostable Materials Handling Facility Permit. Title 14 has more string ent stockpile requirements for chipping and grinding operations; however, there are current ly no stockpile requirements for a site that is regulated as a compostable material ha ndling operation or facility.

There are several small-scale operations that typic ally generate and process the organic material on site, where immediate access to daily covers or other resources are not available. Other examples include small commun ity-operated residential/neighborhood organic material drop-off sites where small residential

communities do not have access to truck collections and have a designated location to drop off organic materials, such as yard clippings. These sites typically have roll-off containers for the incoming organic materials. Sma ll community drop off sites, that use containers and manage the site, encourage trip redu ction and is an economically viable option for many small residential communities. The operations above do not compost and do not have a Compostable Materials Handling Fa cility Permit.

Revised Proposed New Rule 4566 would exempt stockpi ling of wood material, finished compost, overs, and organic material that is used s pecifically for animal feed orSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

18 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 nutritional products, provided that the material is not mixed with other organic material and the operator maintains records. Wood material is typically a dry material, which has a low moisture level and is slow to compost. Wood material that is separated from green material prior to complying with the stockpil e requirements would also be exempt from the proposed rule. For finished compost, the material has already gone through the composting process and has minimal emissions. Overs have also gone through the composting process and primarily consist of woody m aterial; therefore, overs would be treated the same as wood material and finished comp ost. As explained in Section II.B., the low level of moisture content or lack of nitrog en in these materials would limit their biological breakdown.

In addition to recordkeeping and not mixing the org anic material that is stored for animal feed or nutritional products with other materials a t a composting facility, the proposed rule would not allow operators to conduct pathogen reduction on the organic material. Organic material that is used for animal feed or nu tritional products would not be subject to the stockpile requirements for composting operat ions as the organic materials are treated differently from typical composting operati ons.

Other Composting Operations The proposed rule would exempt small-scale composti ng and composting of organic material that is generated and used onsite. Specif ic composting operations that would be exempt from the proposed rule includes agricultu ral composting, community composting, household composting, nursery compostin g and recreational facilities composting.

Other Operations Also exempt are facilities and operations that hand le organic material as part of their operations and are already subject to similar requi rements from other District rules. Facilities and operations that would be exempt unde r Section 4.0 include the following:

• Facilities subject to Rule 4204 (Cotton Gins) and cotton ginning facilities that are specifically exempt from Rule 4204.

• Agricultural operations subject to Rule 4550 (Cons ervation Management Practices) and agricultural operations that are spe cifically exempt from Rule

4550.

• Facilities subject to Rule 4570 (Confined Animal F acilities) and facilities that are specifically exempt from Rule 4570.

4. Section 5.0 Requirements

Section 5.0 addresses requirements for stockpiling and composting operations.

Stockpile Requirements The proposed rule would reduce VOC emissions from c omposting facilities that stockpile organic material. Organic material that would be exempt under Section 4.0SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

19 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 would not be subject to the requirements under this section. For operations that do not compost but stockpile the organic material on site and have a compostable materials handling facility permit in accordance with Title 1 4, operators would be required to comply with all applicable stockpile requirements. As previously mentioned in the Exemptions section, Title 14 does not have stockpil e provisions for a site that is regulated as a compostable material handling operat ion or facility.

Operators that receive organic material at a compos ting facility typically stockpile the material until there is enough material onsite to c hip or grind and put into windrows. The organic material may be stockpiled up to severa l days, depending on the amount of materials that a facility receives. For example, a facility that receives fewer amounts of materials on a daily basis may require more days to generate enough materials to form a windrow for composting. To reduce emissions from stockpiles, operators of composting operations, with throughputs less than 1 00,000 wet tons of organic material per year, would be required to remove the materials from the facility or compost the material within ten days of receipt. Composting op erations with throughputs of 100,000 wet tons of organic materials or more per year woul d be required to remove the materials within three days of receipt.

According to information received from composting o perators that handle less than 100,000 wet tons of organic material per year, the number of days that the materials are stockpiled onsite can vary up to 21 days, depending on the facility. Day one of the stockpile begins on the first day that organic mate rial is received and placed into a newly formed pile. The day the same stockpile is r emoved or covered, regardless of whether new organic material is added to the stockp ile, is the end date.

Based on information received from the operators, D istrict staff has determined that 10 days is reasonable for operators that have less tha n 100,000 wet tons per year of organic materials to remove the stockpile. The 10 day limit was determined as follows:

• Up to 3 business days to receive enough organic ma terial for a windrow

• Up to 2 business days to chip and grind organic ma terial

• Up to 2 business days to move the chipped or groun d material for composting

• Up to 3 non-working days to compensate for weekend s and holidays

The breakdown of the days above is based on discuss ion with operators. However, the chipping and grinding process could occur at anytim e within the 10-day limit. District staff does not expect the chipping and grinding pro cess to have a significant impact on the stockpile holding times because the stockpile e mission factor takes into account emissions from stockpiles that have been chipped an d ground and stockpiles that have not been chipped or ground. Composting operators s ubject to this requirement have indicated that they either already satisfy or would be able to satisfy the requirements.

For composting operations with throughput of 100,00 0 tons per year or more, operators would have up to three days (of receipt) to remove or cover the organic material. BasedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

20 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 on information received from composting operators t hat process 100,000 tons per year or more of organic materials, the operations alread y satisfy the requirements.

While many operators already satisfy the stockpile holding times above, establishing the requirements not only help capture emissions from s ome operations that currently stockpile the materials longer, but would help mini mize stagnant piles.

The District will not address operations from land application, land incorporation, and other operations that stockpile organic material as part of the proposed rule since there is not enough information at this time to obtain ad ditional VOC reductions from these operations. Additional information includes the nu mber of operations in the SJVAB, the number of stockpiling days, and the actual throughp ut. Land application and land incorporation are generally excluded under Title 14 regulations. While District staff intends to obtain as much reductions as possible fr om this source category, additional reductions from other operations would be difficult to achieve without sufficient data. In addition, the control measure for Revised Proposed New Rule 4566 was intended for composting operations that process green materials and therefore, District staff will address those operations at this time. District st aff will address any additional reductions from other source categories as part of future projects.

Table 2 – Summary of Stockpile Requirements
Operations Subject to

Control Proposed Rule Requirements Minimum Number of Stockpile Days

Throughput < 100,000 tpy • Remove organic material from the facility, or

• Start the active phase of composting, or

• Cover the material, or

• Implement an alternative 10 days of Receipt

Throughput ≥ 100,000 tpy • Remove organic material from the facility, or

• Start the active phase of composting, or

• Cover the material, or

• Implement an alternative 3 days of Receipt

*tpy: tons per year

Composting Requirements Data from the San Joaquin Valley Air Pollution Stud y Agency’s (Study Agency) field study showed that the watering system would provide a 19% reduction in VOC emissions during the active phase. In addition, ap plication of finished compost as a cover (acting as a passive biofilter) during the ac tive phase can achieve a 56% reduction in VOC in comparison to standard operatio ns of windrow composting without the finished compost cover. The field study demons trated that these methods are effective in reducing VOC emission from composting of organic material and are feasible to implement. District staff has also con sidered combining both the watering system and finished compost cover requirements, sin ce both mitigation measures have been achieved in practice at one composting facilit y in the Valley. By requiring both the watering system and finished compost cover applicat ion, operators would be able toSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

21 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 achieve 60% reduction in VOC. Please refer to Appe ndix B for further discussion on the

reduction limit.

Composting procedures, equipment, and resources typ ically vary among the composting operations in the SJVAB. The rule conce pts for the selected mitigation measures below takes into account the processes con ducted as part of the field study and the processes that would be feasible for operat ors to implement. Operators would have the flexibility to implement the control optio ns using equipment and resources that are available and appropriate for the facility’s co mposting operation. The mitigation measures described below are for the active phase o f composting only. For windrow composting, the proposed rule would require a minim um of three turns during the first 22 consecutive days, for both mitigation measures. Based on discussion with the operators, District staff has found that three turn s is the minimum number that could be achieved as part of a facility’s typical composting operation during the active phase. The throughput threshold for the composting operati ons was determined based on the District’s feasibility and economic analyses, which are further explained in Appendix C of this staff report.

Table 3 – Summary of Composting Requirements during Active Composting

Operations Subject to

Control Proposed Rule Requirements Minimum % Reduction, by Weight, in VOC

Emissions

Throughput < 200K tpy • Implement a watering system 2 , or

• Implement an alternative At least 19%

200K tpy ≤ Throughput < 750K tpy • Implement a watering system 2
and finished compost cover 3 , or

• Implement and alternative At least 60%

Throughput ≥ 750K tpy • Implement an engineered control
system, or

• Implement an alternative At least 80%

1. tpy: tons per year 2. Watering system requires a minimum of three turn s during active composting and would be implemented after one year of rule adoption. 3. Finished compost cover requires a minimum of fou r covers for initial windrow formation and three tu rns and would be implemented after five years of rule a doption.

Composting Operations with Total Throughput less th an 200,000 TPY Revised Proposed New Rule 4566 would require operat ors of composting operations with total throughput less than 200,000 tons per ye ar of organic material to implement the watering system requirements during the active phase. Operators would use a watering system to apply water to the windrow befor e turning, or use an alternate mitigation measure that provides equivalent VOC red uctions.

The purpose of applying water to the surface of the windrow before turning during active composting is to capture the VOC emissions during t urning, similar to a wet scrubberSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

22 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 effect, which helps capture water soluble pollutant s. According to the field study, most VOCs from the composting process are water soluble.

The proposed rule would also require the ball test, or squeeze test, as part of the watering system requirements to ensure that adequat e water is applied to the compost pile before a turn and to address concerns with wat er run off and rain events. Although the ball test could also help operators determine t he moisture level in a windrow, the purpose of the test is to show whether adequate amo unt of water has been applied prior to turning.

According to the compost study and site visits to s everal facilities, a sprinkler system covers the top half of the pile and a water truck t ypically covers the entire pile. The proposed requirements would allow operators to cond uct the ball test at least three inches in depth of the windrow and anywhere above t he vertical midpoint to the peak of

the windrow.

District staff recognizes the different type of wat ering systems that could be applied at each of the composting operations and has provided two flexible categories for operators to satisfy rule requirements. The wateri ng system is differentiated by two types of setup: one that is connected to a mechanic al turner (integrated) and one that is separate from a mechanical turner (independent).

Operators would be required to apply water to the w indrow and test for adequate water within three hours of turning. If there is a rain event, operators would be able to test the windrow prior to watering. District staff has work ed closely with the affected industry to gain firsthand knowledge and understanding of the d ifferent types of watering system and operations on site. Based on discussion with t he operators, all of them would be able to comply with the proposed watering system re quirements.

Composting Operations with Total Throughput of 200, 000 TPY or More and Less than 750,000 TPY Revised Proposed New Rule 4566 would require operat ors of composting operations with total throughput of 200,000 wet tons per year or more and less than 750,000 wet tons per year of organic material to comply with bo th the watering system and the finished compost cover requirements for each windro w during the active phase of composting, or use an alternate mitigation measure which provides equivalent VOC reductions. The requirements for the watering syst em and finished compost cover would be implemented in a two-phase approach. The watering system requirements for this category would be the same as composting opera tions with total throughput below 200,000 tpy and operators would be required to comp ly with the requirements after one year of rule adoption. For the finished compost co ver requirements, the compliance schedule would be five years after rule adoption to allow time for operators to develop and implement an effective control strategy. Opera tors would be required to cover the

windrow after formation and after the first three t urns. The finished compost cover should be applied with at least six inches at the p eak of the pile. This will create aSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

23 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 natural fall with some materials tapering over the upper third of the windrow, similar to the study. According to demonstrations at two faci lities, the finished compost cover could taper over the upper half of the windrow; how ever, the draft rule requirements would require at least the top third to be covered to be more closely aligned with the compost study. Based on the study, the proposed ru le would require that the entire length of the windrow be covered with a minimum of six inches in height of finished compost cover at the peak of each windrow.

District staff has revised the language for the fin ished compost cover requirements from the July 19, 2011 version of the proposed rule for clarification purposes. The concepts and requirements have not changed due to the revisi on.

The finished compost cover is made up of pre-screen ed finished compost and may include a mixture of screened finished compost or o vers. According to the field study, the finished compost cover can be used to control e missions effectively and yielded the highest amount of reductions in VOC compared to oth er mitigations measures that were

studied.

District staff has also worked with the composting industry to address feasibility and costs of implementing of the finished compost cover requirements, which are further explained in Appendix C of this staff report. Base d on District’s analysis and information received from the operators, it is not feasible for composting operations with less than 200,000 tpy to implement the finished compost cover due to the size of the operation in relation to the cost of the equipment. However, Di strict staff has found that one composting facility that has more than 200,000 tpy has been successfully implementing both the watering system and finished compost cover mitigation measures for several years. There are currently two operations above th is limit, which make up over half of the total inventory for this source category. At t his time, the second facility only has a watering system in place and is expected to increas e its actual throughput in the next few years. As mentioned, the schedule for implemen ting the finished compost cover would allow this facility more time to develop and implement an effective control
strategy.

Composting Operations with Total Throughput of 750, 000 TPY or More Revised Proposed New Rule 4566 would require the op erator of a composting operation with a total throughput of greater than o r equal to 750,000 wet tons per year of organic material to implement an APCO approved m itigation measure that demonstrates at least 80% reduction, by weight, in VOC emissions for organic material undergoing the active phase of composting. At this time, there are no composting operations in the SJVAB that are above this limit. However, the District would recommend more stringent controls should composting operations exceed such limit in the future. For example, there is one facility tha t could potentially exceed this limit in the future based on permitted throughput information.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

24 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Given the various emissions control technologies th at are available and technologies that may become available in the future, operators would comply with the 80% reduction requirements through working with the District afte r rule adoption on an APCO approved mitigation measure. As a result, this rule would n ot specify any additional requirements for this category.

5. Section 6.0 Administrative Requirements

Section 6.0 includes administrative requirements fo r implementing the mitigation measures, administrative requirements for an altern ative mitigation measures compliance plan, recordkeeping requirements, and in formation on test methods. District staff also included TMECC Method 05-08-A (SOUR: Spe cific Oxygen Uptake Rate) for testing the compost maturity/stability of the compo sting phase, which would be consistent with other air district’s requirement fo r a direct respirometry.

Section 6.1 for the facility emission mitigation pl an also requires that operators submit an Authority-to-Construct (ATC) application. The r equirements to obtain an ATC are governed by District Rule 2010, where the District has always required the submittal of an ATC application if there are changes to permit c onditions even though no physical changes are warranted with the modification. Howev er, the District will look into determining ways to expedite the permitting process ing that fits the permit modifications for composting operations subject to this rule.

6. Section 7.0 Compliance Schedule

Table 4 and Table 5 shows the compliance schedule f or composting operations subject

to this rule.

Table 4: Compliance Schedule for Facility Emission Mitigation Plan (FEMP) and Authority-to-Construct (ATC) Application
Requirements Compliance Schedule Watering system requirements or an APCO approved al ternative mitigation measure that demonstrates at least 19% r eduction, by weight, in VOC emissions. (six (6) months prior to full compliance)

Finished compost cover requirements, along with the watering system requirements. In lieu of complying with bot h of the finished compost cover and watering system requirements, imp lement an APCO approved alternative mitigation measure that d emonstrates at least 60% reduction, by weight, in VOC emissions

. (one (1) year prior to full compliance)

APCO approved mitigation measure that demonstrates at least 80% reduction, by weight, in VOC emissions for organic material during the active phase. (one (1) year prior to full compliance)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

25 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Table 5 – Compliance Schedule

Facility Size Proposed Rule Requirements Compliance Period (Year After Rule Adoption Date) Composting Requirements During Active Composting

Throughput < 200K tpy • Implement a watering system, or

• Implement an alternative One Year

200K tpy ≤ Throughput < 750K tpy • Implement a watering system and finished compost cover, or

• Implement an alternative One Year for the watering system and

Five Years for the finished compost

Cover

Throughput ≥ 750K tpy • Implement an engineered control
system, or

• Implement an alternative Five Years

Stockpile Requirements

Throughputs < 100,000 tpy Within 10 days,

• Remove organic material from the facility or

• Compost the organic material, or

• Cover the material or

• Implement an alternative One Year

Throughputs ≥ 100,000 tpy Within 3 days,

• Remove organic material from the facility or

• Compost the organic material or

• Cover the material or

• Implement an alternative One Year

IV. BASELINE INVENTORY AND EMISSION REDUCTIONS

Based on data, District staff estimates emission re ductions of approximately 4.2 tons per day (1,518 tons per year) or a total reduction of 30% of the baseline VOC emissions after full implementation of the rule requirements. When the revised emission inventory baseline reductions (overall of 30%) are applied to the 2017 Ozone Plan baseline emissions, the equivalent reduction is 19 tons per day by the time that this rule is fully implemented, which equates to achieving an addition al reduction of 9 tons per day of VOC emissions from the source category. The VOC em ission reduction analysis is included in Appendix B of the Final Draft Staff Rep ort.

V. COSTS AND COST EFFECTIVENESS ANALYSIS

The purpose of conducting a cost effectiveness anal ysis is to evaluate the economic reasonableness of the pollution control measure or rule. The analysis also serves as aSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

26 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 guideline in developing the control requirements. District staff has evaluated costs and cost effectiveness for composting operations affect ed by Revised Proposed New Rule

4566.

District staff has conducted several discussions an d meetings with affected operators and composting representatives to refine the cost e stimates. For composting operations that are subject to the watering system requirements, the cost effectiveness is about $390 per ton VOC reduced. For composting operations subject to both the watering system and finished compost cover requirem ents, the cost effectiveness ranges from about $2,393 to $2,525/ton of VOC reduc ed.

Please see Appendix C of the final draft staff repo rt for District staff’s analysis of the costs and cost effectiveness of the mitigation meas ures.

VI. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC 40728.5, District staff is requir ed to analyze the socioeconomic impacts of any proposed rule or rule amendment that significantly affects air quality or strengthens an emission limitation. District staff held a socioeconomic focus group meeting for this rule development project in Septem ber 2010. District staff has worked with the stakeholders to determine direct complianc e costs of the mitigation measures. A final draft socioeconomic analysis report is avai lable as part of Appendix D for public review and has been updated to incorporate stakehol der’s comments. District staff will use the socioeconomic analysis to refine the rule c oncepts as appropriate and mitigate any adverse effects to the extent feasible and reas onable. District staff plans to present the final socioeconomic report to the District Gove rning Board at the public hearing in August, along with the proposed rule package, in or der to disclose any expected economic impacts.

VII. GLOBAL CLIMATE CHANGE

Briefly stated, global climate change (GCC) is the cumulative change in the average weather of the earth that may be measured by change s in temperature, precipitation, storms, or wind. Global Climate Change is now gener ally accepted by the scientific community to be occurring and caused by “greenhouse gases” (GHG). Greenhouse gases are gases which allow direct sunlight (relati ve shortwave energy) to reach the Earth's surface unimpeded. As the shortwave energy (that in the visible and ultraviolet portion of the spectra) heats the surface, longer-w ave (infrared) energy (heat) is reradiated to the atmosphere. Greenhouse gases abso rb this energy, thereby allowing less heat to escape back to space, and 'trapping' i t in the lower atmosphere.

The scientific and political communities in the Sta te of California have collectively concluded that a significant and growing scientific body of evidence supports the needSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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27 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 for regulating GHG emissions. The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, multi-year program to reduce GHG emissions in California, to 1990 levels by the year 2020.

The District believes that the evidence and the rat ionale that climate change is occurring is compelling and convincing. In addition to the lo ng-term consequences of climate change, the District is concerned with the potentia l ramifications of more moderate but imminent changes in weather patterns. The Valley de pends heavily on agriculture for its economy and has developed agricultural practices ba sed on the last several decades of weather patterns. Unanticipated and large fluctuati ons in these patterns could have a devastating effect on the Valley’s economy.

While there are many win-win strategies that can re duce both GHG and criteria/toxic pollutant emissions, when faced with situations tha t involve tradeoffs between the two, District staff believes that the more immediate pub lic health concerns that may arise from an increase in criteria or toxic pollutant emi ssions should take precedence.

A. Greenhouse Gases and Atmospheric Chemistry

Some greenhouse gases such as water vapor occur nat urally and are emitted to the atmosphere through natural processes as well as thr ough human activities. The most common GHG that results from human activity is carb on dioxide, followed by methane and nitrous oxide. GHGs can include: water vapor, o zone, aerosols, chlorofluorocarbons, carbon dioxide, methane, nitro us oxide, and fluorinated gases (such as hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).

Recent studies support a conclusion that global war ming is also affected by changes in tropospheric ozone (O 3 ). Tropospheric ozone is both generated and destroy ed by photochemistry within the atmosphere. Volatile orga nic compounds (VOC) and nitrogen oxides (NOx) are two pollutants which form troposph eric ozone through photochemical reactions. Decreasing these pollutants within the a tmosphere reduces formation of tropospheric ozone and thus, has an indirect, posit ive influence on global climate change.

B. Composting Impacts

Natural decomposition of organic matter occurs from both nonbacterial (abiotic) and bacterial (biotic) processes. Biotic processes tran sform carbon into cellular mass but result in waste gas emissions of carbon dioxide, me thane and nitrous oxide. Composting accelerates the biotic process which res ults in more rapid emission of VOC, CO and methane. The speed of emission is not s ignificant as a global warming

issue since the material will break down with or wi thout composting. The speed is important for ozone formation as this could potenti ally result in higher daily concentrations of tropospheric ozone.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

28 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Composting is viewed as having an environmental ben efit as compared to natural decomposition. Natural decomposition of materials l eft in place to decay is relatively inefficient and releases more gaseous emissions int o the air. The effect of piling the material in the composting process delays release o f gases into the air and allows more bacterial activity that turns these gaseous emissio ns into stored carbon. As a global warming issue, the total amount of carbon released is to be considered. The amount of carbon in different forms is decreased by the amoun t processed by bacteria into cell

matter. The United States Environmental Protection Agency (USEPA) has assessed the balance between the cellular uptake and the amount of carbon emissions and nitrous oxide emissions. USEPA determined that the thirty y ear retention of carbon far outweighed the combined emissions of carbon and nit rous oxide converted into equivalents of carbon.

VII. ENVIRONMENTAL IMPACTS

A. Effects of Revised Proposed New Rule 4566

Implementation of Revised Proposed New Rule 4566 is not expected to either increase or decrease the amount of composting activity that currently occurs within the San Joaquin Valley air basin. In that regard, the impac t of rule implementation is environmentally neutral.

As presented in the Emission Reduction Analysis, implementation of Revised Proposed New Rule 4566 is expected to reduce VOC emissions f rom composting by 1,518 tons/year (4.2 tons/day). Reducing VOC emissions re duces formation of tropospheric ozone. Thus, implementation of the proposed VOC con trol measures would have an indirect, positive influence on global climate chan ge.

Implementation of certain control measures could re sult in increased fossil fuel use. The

District estimates that increased fossil fuel use c ould result in a 1.4 tons/year increase in oxides of nitrogen (NOx), a 0.2 tons/year increase in VOC, a 0.1 tons/year increase in particulate matter 10 microns (PM10), and a 183 ton s/year increase in CO 2 emissions.

B. Cumulative Impacts on Global Climate Change

On February 16, 2010, the California Office of Admi nistrative Law approved amendments to the California Code of Regulations, e mphasizing that the effects of GHG are cumulative impacts and should be analyzed i n the cumulative impacts analysis. To assist lead agencies in determining th e significance of project related greenhouse gas emissions a new subdivision was adde d to the CEQA Guidelines; Section 15064.4 (Determining The Significance of Im pacts From Greenhouse Gas)

. This section provides that when assessing cumulativ e significance of project specific GHG emissions on global climate change, a lead agen cy should consider, among otherSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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29 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 factors, the extent to which the project may increa se or reduce greenhouse gas emissions as compared to the existing environmental setting.

Quantification of potential changes in global clima te change that may result from implementation of Revised Proposed New Rule 4566 re quires a degree of speculation and conjecture that is inappropriate and discourage d under CEQA (CCR §15187(d)). From a qualitative perspective, the District conclu des that overall reductions in VOC emissions and the concomitant reduction in troposph eric ozone formation outweigh potential increases in NOx emissions and CO 2 emissions associated with increased fossil fuel consumption.

The District finds that there is no substantial evi dence, in light of the whole record before the District, that the project could have a cumulatively significant impact on global climate change.

IX. RULE CONSISTENCY ANALYSIS

Pursuant to California Health & Safety Code Section 40727.2, District staff has prepared a rule consistency analysis that identifies and com pares the air pollution control elements of the Revised Proposed New Rule 4566 with the corresponding elements of other District, state, and federal regulations and guidelines that apply to the same source category. Staff found that facilities could comply with Rule 4566 and all existing District Rules. Furthermore, staff found that none of the requirements of Rule 4566 would conflict with local, state, or federal rules, regulations, or policies. Please refer to Appendix E for further discussion on the analysis.

X. REASONABLE AVAILABLE CONTROL TECHNOLOGY (RACT)

Section 172(c)(1) of the federal Clean Air Act requ ires air quality plans for nonattainment areas to “provide for the implementat ion of all reasonable available control measures as expeditiously as practicable (i ncluding such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control techn ology (RACT)) and shall provide for attainment of the national primary ambient air qual ity standards.” RACT is also defined

in the 2007 Ozone Plan as devices, systems, process modifications, or oth er apparatus or techniques that are reasonably available taking into account the necessity of imposing such controls in order to attain and maint ain a national ambient air quality standard; the social, environmental, and economic i mpact of such controls; and alternative means of providing for attainment and m aintenance of such standard.

In the greater context of air pollution control lev els, RACT is understood as the “floorlevel” of air pollution controls, not the “ceiling- level.” More effective levels of emissions control are termed Best Available Control Technolog y (BACT) and Lowest AchievableSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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30 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 Emission Rate (LAER). BACT and LAER are required f or new sources, and for existing sources undergoing modification. Under state and f ederal air pollution programs, new facilities face more stringent pollution control re quirements than existing facilities, with the understanding that better controls can be more easily implemented before a facility is built, than after it is built. New sources must generally implement BACT 1 and existing sources must implement a less stringent level of co ntrol such as Reasonably Available Control Technology (RACT). Additionally, Californi a law establishes an intermediate

level of control that is the “best available” for “ retrofit” to existing sources (entitled Best Available Retrofit Control Technology – BARCT 2 ), recognizing that the state’s worst ozone problems demands more effective pollution con trol than what is usually considered “reasonably available.”

The following section evaluates the requirements of Revised Proposed New Rule 4566 in light of the above RACT and BARCT definition.

How does District Rule 4566 compare with federal ru les and regulations?

A. EPA – Control Technique Guidelines (CTG) There is no EPA CTG guidance document for organic m aterial composting operations.

B. EPA - Alternative Control Technology (ACT) There is no EPA ACT guidance document for organic m aterial composting operations.

C. Standards of Performance for New Stationary Sour ces (NSPS) There is no NSPS guidance document for organic mate rial composting operations.

D. National Emission Standards for Hazardous Air Po llutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs) There is no NSPS guidance document for organic mate rial composting operations.

How does District Rule 4566 compare to rules in oth er air districts?

District staff compared VOC limits, optional contro l requirements, and work practice standards in District Rule 4566 to comparable requi rements in rules from the following

California nonattainment areas:

1 Federal regulations for permitting new facilities require Best Available Control Technology (BACT) fo r new sources in attainment areas, and Lowest Achieva ble Emission Rate (LAER) – a generally more stringent level –for new sources in nonattainment a reas. LAER differs from BACT in that economic cost s

are not considered for candidate LAER controls that are co nsidered “Achieved in Practice.” Under California state law, the District is required to a pply “BACT” for new sources under essentially the s ame requirements as federal LAER. The District’s “BACT ” determinations thus fulfill the federal LAER requirements.

2 California Health and Safety Code (CH&SC) 40406: ... "best available retrofit control technology" means

an emission limitation that is based on the maximum degree of reduction achievable, taking into accoun t environmental, energy, and economic impacts by each class or category of source.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

31 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 • South Coast AQMD Rule 1133.3 – Emission Reductions from Greenwaste Composting Operations

• Bay Area AQMD, Sacramento Metropolitan AQMD and Ve ntura County APCD do not have rules that apply to organic material compo sting operations.

South Coast Air Quality Management District (SCAQMD ) Rule 1133.3 (Emission Reductions from Greenwaste Composting Operations)

South Coast AQMD recently adopted Rule 1133.3 on Ju ly 8, 2011. District staff has worked closely with SCAQMD staff to share informati on and rule concepts. Staff notes that there may be differences between District Rule 4566 and SCAQMD Rule 1133.3. This should not be interpreted to mean that one rul e is more stringent than the other,

but due instead to additional factors:

1. South Coast AQMD is a VOC limited area and VOC e missions reductions have a greater impact towards Ozone attainment, whereas the San Joaquin Valley is a NOx limited area; 2. The socioeconomic climate of the SCAQMD is signi ficantly different from that of

the District.

District has also worked closely with the affected stakeholders to evaluate the available controls and determine the additional costs of impl ementing the controls. Based on the District’s cost-effectiveness analysis in Appendix C, it would not be economically feasible for operators to implement more stringent controls than what is already proposed in the rule. The cost to implement more s tringent controls, such as engineered systems, would more than triple the cost for these operators. In addition, the results from the District’s socioeconomic repor t shows that the proposed requirements, specifically the finished compost cov er, would have an economic impact on at least one of the composting facility. Please refer to Appendix C and Appendix D

for further discussion on the cost-effectiveness an d socioeconomic analyses.

After careful evaluation of federal and California regulations and the technological and economical feasibility of potential mitigation meas ures, District staff concludes that new Rule 4566 would satisfy, if not go beyond, RACT and BARCT requirements for this source category based on the same required evaluati on.

XI. CURRENT VOC REGULATION BY MASS AND ALTERNATIVE REGULATION

BY OZONE CONTRIBUTION

EPA requires compliance efforts for the ozone stand ard to be established in terms of

the mass of emissions reduced. The District has re commended to EPA that flexibility be provided to consider and prioritize reductions t hat have the most benefit in reducing ozone emissions and subsequently reduce population exposure, with greater credit provided for reductions in Environmental Justice co mmunities. Until such time as EPASAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

32 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 considers and makes regulatory adjustments in respo nse to this District request, the mass based approach remains the regulatory requirem ent.

A. Explanation of the Regulatory Approach

The District regulates on a mass, or weight, basis all volatile organic compound (VOC) emissions that have been determined by EPA to have more than a minimal contribution to harmful ozone in the air we breathe. District p ermits, regulations and compliance

tests establish limits for VOC emissions that are b ased on the mass of emissions emitted, excluding only those compounds that EPA ac cepts as having little or no impact

on formation of harmful ozone. The value of exclud ing the minimal contributing compounds is to encourage source types which have t he ability to reformulate their materials or emissions to use minimal ozone forming compounds in replacement of compounds that form greater amounts of ozone.

B. Alternative to Current Regulatory Approach

EPA acknowledges that assessing the amount of ozone formed by each compound (defined as atmospheric reactivity) could be used a s an alternative basis for regulation instead of using just the amount of emissions (by w eight or mass); however, if this approach were to be adopted, associated with the al ternative approach there are additional requirements, proofs, and evaluations re quired for the District and the state, and different compliance requirements for operators

.

The alternative regulatory approach is referred to as a “reactivity” approach because the method is based on assessing how much a specific VO C compound reacts in the atmosphere either to form ozone or increase the amo unt of ozone formed by other compounds. The “reactivity” value is multiplied by the amount (by mass or weight) to determine the full impact of the emitted material o n a basis that accounts for both the

amount of emission and the different relative contr ibution to formation of ozone.

There are thousands of different VOC compounds and each has a different contribution to the harmful ozone, either directly or by influen cing the amount of ozone formed by other compounds. The difficulty in establishing th e appropriate value for each compound, changing regulations to require measureme nt and permitting by compound, and required supporting evaluations and approvals b y EPA and ARB preclude this as a viable approach for the District at this time.

ARB has established reactivity values for the refor mulation of architectural coatings and has received approval for this regulatory approach for that category of emissions. Approval to regulate the specific source category w ith the reactivity approach required removal of the exemption for minimally ozone formin g compounds for these sources. The requirements for the District to pursue a simil ar approach for a specific regulation or for all District regulations are extensive.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

33 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 C. Value of VOC Specific Compound Data

The District recognizes the value of measuring emis sions from each source type as accurately as possible, including the identificatio n of specific VOC compounds and

amounts. The current use for this information is t o update the emission inventory identification of compounds emitted by a source typ e, referred to as the speciation signature for a source. Speciation signatures are u sed in regional modeling for photochemical assessment of the effect of growth tr ends and emission controls. The modeling projections predict future ozone levels an d assist in developing plans designed to achieve the health based federal ozone standards. Speciated measurement of emissions is not routinely required for most sources due to the technical difficulty and expense for obtaining data at this level of detail.

The additional potential value of the speciation da ta and assessment of ozone reactivity is to identify compounds that have minimal ozone co ntribution and may be considered for de-listing by EPA. De-listing would remove the requirement for the compound to be limited and regulated. Such assessments must be do ne carefully and in accordance with nationally recognized protocols. Not only mus t the contribution to ozone be considered, but also the potential for the VOC comp ound to contribute to formation of fine particulate matter (PM2.5). Particulate forme d in the atmosphere from VOC emission is called secondary organic aerosol (SOA). SOA is PM2.5 that must be regulated to achieve the federal health based stand ard for fine particulate matter.

D. Applicability to Compost Emission Regulation

District rule development for regulation of VOC fro m composting operations will rely on the current mass basis used for all District regula tions. While information on the relative ozone forming contribution of different VOC compoun ds emitted by compost operations is of interest and value for proper characterizatio n of the impact of these emissions on regional ozone levels, such data would not constitu te a sufficient basis for the District to establish regulatory requirements to focus on speci fic emitted compounds. Even if a specific compound was identified as more reactive t han other compounds emitted in the composting operation, the District lacks sufficient technical foundation to establish a specific change to composting procedures that would eliminate or reduce any specific VOC compound.

XII. REFERENCES

1. California Code of Regulations, Title 14, Divisi on 7, Chapter 3.1 available at http://www.ciwmb.ca.gov/Regulations/Title14

. 2. California Code of Regulations, Title 27, Divisi on 2 available at http://www.ciwmb.ca.gov/Regulations/Title27/

. 3. San Joaquin Valley Unified Air Pollution Control District Rule 4565, Rule 4565 Staff Report and Appendices.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Draft Staff Report: Revised Proposed New Rule 4566 August 18, 2011

34 Final Draft Staff Report with Appendices For Revised Proposed New Rule 4566 4. SCAQMD Rule 1133, staff report, and technology a ssessment.

5. SJVUAPCD 2007 Ozone Plan 6. California Department of Resources Recycling and Recovery, Strategic Directive 6 ,

available at: http://www.calrecycle.ca.gov/AboutUs/StrategicPlan/ 2009/SD06.htm 7. ENVIRONMENTAL PROTECTION AGENCY, 40 CFR Part 51, Section V, “Interim Guidance on Control of Volatile Organic Compounds i n Ozone State Implementation

Plans.” 8. Reactivity Research Working Group (RRWG), Sectio n 2.1.3.1 Impacts of Volatility Thresholds and Test Methods, “VOC Reactivity Policy White Paper,” October 1, 1999. and ENVIRONMENTAL PROTECTION AGENCY, 40 CFR P arts 51 and 52, 6560-50-P, “Revisions to the California State Imple mentation Plan and Revision to the Definition of Volatile Organic Compounds (VOC) - Removal of VOC Exemptions for California’s Aerosol Coating Products Reactivit y-based Regulation.” 9. ENVIRONMENTAL PROTECTION AGENCY, 40 CFR Part 51, Section IV and V, “Interim Guidance on Control of Volatile Organic Co mpounds in Ozone State Implementation Plans.” 10. ENVIRONMENTAL PROTECTION AGENCY, 40 CFR Parts 5 1 and 52, 6560-50-P, “Revisions to the California State Implementation P lan and Revision to the Definition of Volatile Organic Compounds (VOC) - Removal of VO C Exemptions for California’s Aerosol Coating Products Reactivity-ba sed Regulation.” 11. Reactivity Research Working Group (RRWG), Secti on 4.2.3.2 Control Measure Design and Implementation, “VOC Reactivity Policy W hite Paper,” October 1, 1999.

12. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY: SOLID WASTE MANAGEMENT AND GREENHOUSE GASES, A Life-Cycle Asses sment of Emissions and Sinks, 3rd EDITION, September 2006. 13. California Air Resources Board, Composting issu es website: http://www.arb.ca.gov/cc/compost/compost.htm 14. California Air Resources Board, Climate Change Proposed Scoping Plan Appendices, VOLUME I: SUPPORTING DOCUMENTS AND MEAS URE DETAIL, measure RW-3, C161, October 2008. http://www.arb.ca.gov/cc/scopingplan/document/appen dix1.pdf

15. California Air Resources Board “PROPOSED METHOD FOR ESTIMATING

GREENHOUSE GAS EMISSION REDUCTIONS FROM COMPOST FRO M COMMERCIAL ORGANIC WASTE,” August 31, 2010 16. San Joaquin Valleywide Air Pollution Study Agen cy [SJVAPSA]. (Draft 2011). Comparison of Mitigation Measures for Reduction of Emissions Resulting from Greenwaste Composting. Fresno, CA: San Joaquin Valleywide Air Pollution St udy Agency. Retrieved from http://www.valleyair.org/busind/pto/emission_factor s/Criteria/Criteria/Composting/Co mpost%20Study%20Draft%20Report.pdf (Draft Report) and http://www.valleyair.org/busind/pto/emission_factor s/Criteria/Criteria/Composting/Co mpost%20Study%20Appendices.pdf (Appendices)