### ATTACHMENT A TO THE STAFF REPORT

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Technology Assessment for:

PROPOSED RULE 1133: EMISSION REDUCTIONS FROM COMPOSTING

AND RELATED OPERATIONS

March 22, 2002

Deputy Executive Officer Planning, Rule Development and Area Sources Elaine Chang, DrPH

Assistant Deputy Executive Officer Planning, Rule Development and Area Sources Laki Tisopulos, Ph.D., P.E.

Planning and Rules Manager Planning, Rule Development and Area Sources Alene Taber, AICP

Authors: Shah Dabirian, Ph.D. Air Quality Specialist Tuyet-Le Pham Transportation Specialist Barbara Radlein Air Quality Specialist Ricardo A. Rivera Air Quality Specialist

Reviewed by: Frances Keeler Se nior Deputy District Counsel Julia Lester, Ph.D. Program Supervisor

Contributors: Fred Braganza Air Quality Inspector II Mike Garibay Air Quality Engineer II Rick Gluck Air Quality Inspector II John Higuchi Source Testing & Monitoring Manager Lori Inga Sr. Office Assistant Dave Jones Air Quality Analysis & Compliance Supervisor Rodney Millican Senior Air Quality Engineer Arun Roychowdhury Supervising Air Quality Engineer Dan Russell Air Quality Specialist Kathy C. Stevens Air Quality Specialist Rich Tambara Supervising Air Quality InspectorSOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

GOVERNING BOARD

CHAIR: NORMA J. GLOVER Councilmember, City of Newport Beach Cities Representative, Orange County

VICE CHAIR: WILLIAM A. BURKE, Ed.D. Speaker of the Assembly Appointee

MEMBERS:

MICHAEL D. ANTONOVICH Supervisor, Fifth District Los Angeles County Representative

HAL BERNSON Councilmember, City of Los Angeles Cities Representative, Los Angeles County, Western Region

JANE CARNEY Senate Rules Committee Appointee

JAMES W. SILVA Supervisor, Second District Orange County Representative

BEATRICE J.S. LAPISTO-KIRTLEY Councilmember, City of Bradbury Cities Representative, Los Angeles County, Eastern Region

RONALD O. LOVERIDGE Mayor, City of Riverside Cities Representative, Riverside County

JON D. MIKELS Supervisor, Second District San Bernardino County Representative

LEONARD PAULITZ Mayor Pro Tem, City of Montclair Cities Representative, San Bernardino County

CYNTHIA VERDUGO-PERALTA Governor's Appointee

S. ROY WILSON, Ed.D. Supervisor, Fourth District Riverside County Representative

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.LIST OF ACRONYMS AND ABBREVIATIONS

AB Assembly Bill AQMD South Coast Air Qualit y Management District AQMP Air Quality Management Plan

BACT Best Availabl e Control Technology

CARB California Air Resources Board CEQA California Environmental Quality Act CIWMB California Integrated Waste Management Board EPA U.S. Environmental Protection Agency LEA Local Enforcement Agency

NH 3 Ammonia NPDES National Pollutant Discharge Elimination System PM10 Particulate Matter with Aerodyna mic Diameter less than 10 Microns RWQCB Regional Water Quality Control Board RCRA Resource Conservation and Recovery Act ROG Reactive Organic Gas

SIC Standard Industrial Classification SIP State Implementation Plan VOC Volatile Organic CompoundTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 i March 2002 

### TABLE OF CONTENTS

TABLE OF CONTENTS .................................................................................................. i

TABLES OF TABLES .................................................................................................... iii

TABLE OF FIGURES ................................................................................................... iii

EXECUTIVE SUMMARY ........................................................................................ES-1

CHAPTER I – BACKGROUND INFORMATION Air Quality ........................................................................................................... 1-1 Composting Process............................................................................................. 1-3 Chipping and Grinding Activities........................................................................ 1-8

Overview of Current Re gulatory Requirements .................................................. 1-9 Other Issues Facing the Composting Industry................................................... 1-14 Necessity for Proposed Rule 1133..................................................................... 1-20

CHAPTER II – INDUSTRY PR OFILE AND EMISSIONS Industry Profile .................................................................................................... 2-1 Emissions Inventory............................................................................................. 2-2

CHAPTER III – CONTROL TECHNOLOGY ASSESSMENT Composting Methods........................................................................................... 3-1 Emission Control System..................................................................................... 3-4

Demonstrated Control Efficiencies...................................................................... 3-6 Chipping and Grinding Methods ......................................................................... 3-7

CHAPTER IV - PROPOSED RULE 1133

Emission Re ductions............................................................................................ 4-1

Cost-Effectiveness ............................................................................................... 4-5

CHAPTER V - RECOMENDATIONS AQMD Staff Recommendations.......................................................................... 5-1

CHAPTER VI – OUTREACH, KEY ISSUES, AND RESPONSES

Public Outreach.................................................................................................... 6-1Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 ii March 2002 REFERENCES ..........................................................................................................Ref. 1

APPENDIX A - List of Operation al ASP Facilities In the U.S. ............... Appendix-A-1

APPENDIX B – List of Operational In-Vessel Composting

Facilities In the U.S. ....................................................... Appendix-B-1

APPENDIX C – Biofilters In Operation At Composting

Facilities In the United States ...................................... Appendix-C-1Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 iii March 2002 

### TABLE OF TABLES

Table 1-1 Solid Waste Tipping Fee Survey of California 1-9

Table 1-2 2000-2001 Public Complaints/AQMD Enforcement Actions On Composting and Chipping and Grinding Operations 1-14

Table 1-3 Types of Organics Contributing to Waste Stream 1-16

Table 1-4 Top Ten Materials in Waste Stream 1-16

Table 1-5 CIWMB Identified Examples of Programs to Divert

Greenwaste 1-17

Table 1-6 CIWMB Statewide ADC Analysis (tons/year) 1-19

Table 2-1 Composting Industry and Related Operations 2-1

Table 2-2 Composting Facilities by County 2-2

Table 2-3 Windrow Emissions Factors 2-3

Table 2-4 Composite Emission Rates (Early Fall Test) 2-5

Table 2-5 Composite Emission Factors 2-6

Table 2-6 Emission Factors for Greenwaste Composting 2-6

Table 2-7 Emission Rates 2-6

Table 2-8 Emission Factors 2-7

Table 2-9 Emission Factors for Greenwaste-Composting 2-7

Table 2-10 Weighted-Average Emission Factors for Greenwaste Composting 2-7

Table 2-11 Emissions Inventory 2-8

Table 3-1 Optimal Composting Conditions 3-1

Table 3-2 Composting Methods, Capture and Control Efficiencies 3-6

Table 4-1 Co-Composting Scenarios 4-3

Table 4-2 Greenwaste Scenarios 4-4

Table 4-3 Number of Facilities by Sales and Employees 4-6

Table 4-4 Co-Composting Annualized Cost and Cost Effectiveness by

Scenario 4-8

Table 4-5 Greenwaste-Only Annualized Cost and Cost-effectiveness by

Scenario 4-9

Table 4-6 Potential Cost Impacts of the Proposed Rule on Selected CoComposting Facilities 4-11

Table 4-7 Potential Cost Impacts of the Proposed Rule on Selected Greenwaste-only Facilities 4-11



### TABLE OF FIGURES

Figure 1-1 Phases During Composting 1-5

Figure 2-1 Methane Emissions vs. Time 2-4

Figure 2-2 Ammonia Emissions vs. Time 2-4

### EXECUTIVE SUMMARYTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 ES - 1 March 2002 

### INTRODUCTION

9 This chapter provides an Executive Summary



### EXECUTIVE SUMMARY

Background The South Coast Air Quality Management District (AQMD) is the local agency responsible for air quality a ssessment and improvement in the four-county area that includes Orange, the non-desert porti ons of Los Angeles and San Bernardino Counties, and most of Riverside County. In order to accomplish its mandate, AQMD is required to adopt and implement an Ai r Quality Management Plan (AQMP) that identifies the control strategies to achiev e federal ambient air quality standards and demonstrate compliance with the state and federal clean air acts. The South Coast Air Basin (Basin) is a seri ous non-attainment area for PM10 (particulate matter less than 10 microns) and must attain the standa rd by 2006. The Basin is the only extreme

ozone non-attainment area and must attain the standard by 2010. Ammonia is a precursor of PM10, particularly aerosol ammonium nitrate and ammonium sulfate. Volatile Organic Compounds (VOCs) are prec ursors to ozone. As shown in this report, composting of greenwaste only pr oduces significant VOC emissions and appreciable ammonia emissions. Composti ng of sewage sludge and manure produces significant ammonia emissions in localized areas, as well as VOC emissions.

The 1997 AQMP and the 1999 Amendments to the 1997 Ozone State Implementation Plan (SIP) for the South Coast Air Ba sin included Control Measure WST-02 – Emission Reductions from Composting. Th is technology assessmen t report provides information developed as part of the rule development efforts undertaken to date by AQMD staff to implement Control Measure WST-02.

This report provides background information and rule development recommendationsthat will be submitted to the AQMD Governing Board at the April 5, 2001 PreHearing for Proposed Rule 1133 – Emissi ons Reductions from Composting and Related Operations.

Industry Profile The composting and related operations industry within the AQMD’s jurisdiction includes 277 facilities categ orized as follows: co-composting facilities; greenwaste only composting facilities; chi pping and grinding facilities; and, exempt facilities. Co-composting facilities use putrescible ma terials, such as, wastewater sludge, manure, or food waste in combination with greenwaste as their process feedstock. Greenwaste composting facilities are compos ting facilities that only use greenwaste as process feedstock. Chipping and grinding facilities are facilities dedicated to the size reduction of greenwaste for uses such as alternative daily cover, biomass fuel, mulch, soil amendments, or composting feed stock. Finally; exempt facilities are facilities that are part of th is industry but are likely to be exempt from regulation under Proposed Rule 1133.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 March 2002 Emissions Inventory The baseline emissions inventory estimated for the industry is 4.7 and 6.8 tons per day for ammonia and VOC, respectively. The co-composting emissions inventory is estimated at 3.7 and 2.2 tons per day of ammonia and VOC, respectively. The greenwaste composting emissions inventory is estimated at 1.0 and 4.4 tons per day of ammonia and VOC, respectively.

The largest co-composting facilities are es timated each to emit 100 to 300 tons per year of VOC and 150 to 500 t ons per year of ammonia. The largest greenwaste composting facilities are estimated each to emit 250 to 600 tons per year of VOC emissions, which would rank them among the largest VOC sources in the Basin.

The baseline emission inventory is base d on source tests and emissions studies conducted by AQMD staff. The CIWMB subse quently conducted a series of source tests at greenwaste processing and com posting facilities in December of 2001. Although the final results have not been completely reviewed by AQMD staff in time to be included in this report, AQMD staff will incorporate those test results to the greewaste composting emissions analysis and report the revised analysis to stakeholders as soon as possible.

Technical Assessment AQMD staff has conducted a technology asse ssment of the composting and related operations industry. The technology assessment reviews composting processes available to industry including the following: windrow, aerated static piles, and invessel. The analysis also evaluated ASP systems and enclosures in combination with bio-filtration systems. Based on this anal ysis, AQMD staff demons trated that there are technological options that will sign ificantly reduce emissions from the composting and related operations industry.

Control Options and Socioeconomic Analysis AQMD staff developed three control scenarios to evaluate the potential emission reductions and cost of controlling co-composting and greenwaste composting.

Scenario one assumes the enclosure of the active and curing parts of the composting process, the use of an ASP or in-vessel sy stem, and venting of emissions to control equipment (i.e., biofilter). Scenario two assumes enclosure of the active phase of the process and the use of an ASP or in-vessel system with emissions vented to control equipment. For the curing phase of the pro cess, scenario two has a variation for cocomposting and greenwaste composting. Fo r co-composting, scenario two assumes the use of a negative-pressure ASP system with emissions vented to controls (no enclosure). For the greenwaste composting, scenario two assumes no controls for the curing phase of the process. Finally, scenario three assumes the use of a negativepressure ASP system for both the active and curing phases of the process with emissions vented to control equipment (no enclosures).

As part of the cost analysis, AQMD staff has analyzed cost-effectiveness and compliance affordability. In general, while the control options for the co-composting sector of the industry are seen as feas ible and effective, they are costly.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 March 2002 Relative to co-composting, the control opti ons for the greenwaste composting sector of the industry are more cost effective. However, the affordability analysis, as presented in Chapter IV, demonstrates that the cost impact for this industry would be

substantial.

Recommendation Based on information in this report, AQMD staff is reco mmending that AQMP

Control Measure WST-2 – Emission Reductio ns from Composting, be implemented in two phases. The first phase would consist of an adoption of a fact-finding rule that

would have the elements listed below. Th e first phase would also include control requirements for new co-composting faciliti es with total throughput design capacity of 100,000 tons per year. The second pha se would consider composting control technologies for new and existing facilities ba sed on the results of additional technical

work described below.

Requirements for Co-Composting As described in this report, co-composting facilities are major sources of VOC and ammonia emissions (e.g., a 100,000 ton/year total throughput f acility has annual emissions of 89 tons/year VOC and 147 tons/year ammonia). Based on local community concerns and industry studies, si ting of large co-composing facilities in urban areas now requires active consideration of enclosed and controlled facilities to address public health and nuisance concerns. Enclosed ASP or in-vessel systems with control equipment, while feasible and effective at significantly reducing emissions, are costly. Therefore, AQMD staff recommendations are as follows:

Existing and new Co-Composting Facilities

• One-time registration with AQMD;

• Annual reporting requirements;

• PM10 controls to prevent visible PM10 emissions over the property line during operations and from compost piles; and,

• Compliance with all applicable AQM D rules, regulations and permit

conditions.

New Co-Composting Facilities with a Design Capacity > 100,000 tpy

• Scenario II control requirements for new facilities with total throughput designed capacity of 100,000 tons per year;

9 Enclosure and ASP for the active phas e of the process with emissions vented to a bio-filtration system;

9 Open ASP for the curing phase of th e process with emission vented to a bio-filtration system;

Greenwaste Composting As described in this report, the greenwaste industry represents a significant source of VOC emissions. Control options, in genera l, are more cost-effective; however, our affordability analysis indicates that these controls may have adverse impacts on the industry. As a result, the staff is proposing minimal requirements on greenwasteTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 March 2002 composting at this time. The requirements are intended to primarily track operations and emissions, so that emission reductions can be claimed if specific controls are implemented in the future. The following summarizes the proposed requirements for existing and new greenwaste composting operations.

• One-time registration

• Annual reporting requirements

• PM10 controls to prevent visible PM10 emissions over the property line during operations and from compost piles; and,

• Compliance with all applicable AQM D rules, regulations and permit

conditions.

In light of the fact that there are feasible control options for this industry that are not yet affordable, AQMD staff is recommending th at, through the Dist rict’s Legislative Committee, special funding from the state legi slature be sought to implement state-ofthe-art composting methods, including but not limited to, enclosed ASP. AQMD

staff will work with the CIWMB and CARB to seek additional funding and/or make existing funding directed more towards air quality spending.

The administrative requirements for the propos ed rule are detailed in Chapter V of this report. These requirements would include a one-time registration with AQMD and annual reporting.

Chipping and Grinding Operations Chipping and grinding operations can be sources of PM10 and VOCs. PM10 results from the chipping, grinding and screening of gr een materials. It can also result when high winds entrain material from proce ssed material piles. Chipped and ground

material that is not removed or furthe r processed can decompose anaerobically, resulting in odors and higher levels of VOCs. To address these issues, AQMD staff is proposing the following requirements:

• One-time registration;

• PM10 controls to prevent visible PM10 emissions over the property line during operations and from pr ocessed material piles;

• Holding time restrictions on curbside fine s and processed green material piles;

and

• Compliance with all applicable AQM D rules, regulations and permit

conditions

As part of this proposal, AQMD staff is also recommending that the Governing Board direct staff to continue the rule development efforts with the following objectives: 1) continue to evaluate ongoing emissions stud ies and refine the em issions inventory for the industry; 2) refine the socioeconomic an alysis; 3) work with the Integrated Waste Management Board, sanitation districts a nd other pertinent agencies to identify sources of funding to help reduce the cost of compliance for the greenwaste composting sector of the composing indus try. Finally, AQMD staff is further recommending that a Technical Advisory Co mmittee be formed and serve as a forumTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 5 March 2002 to address technical issues related to Propos ed Rule 1133. There will be annual status reports to the AQMD Stationary Source Committee on facility emissions and the feasibility of implementing addi tional cost-effective controls.

### CHAPTER I

BACKGROUND INFORMATIONTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 1 March 2002 

### INTRODUCTION

This chapter discusses the following:

9 Air quality;

9 Composting Process;

9 Chipping and Grinding Activities;

9 Overview of Current Regulatory Requirements;

9 Other Issues Facing the Co mposting Industry; and,

9 Necessity for Proposed Rule 1133.



### AIR QUALITY The AQMD is the local government agency responsible for air quality assessment and improvement in Orange county, the non-de sert portions of Los Angeles and San Bernardino counties, and most of Rivers ide county. AQMD ju risdictional boundaries

include all of the South Coast Air Basin (SCAB) and portions of the Salton Sea Air Basin (SSAB). AQMD air monito ring indicates that these ai r basins exceed State and federal health-based air quality standards for PM10 (small particulate matter less than 10 microns in diameter) and ozone. Acco rdingly, the U.S. EPA has designated both the SCAB and the SSAB as serious non-attainment areas for PM10. The designation

for ozone is extreme and severe-17 1 for SCAB and SSAB, receptively. Under the federal Clean Air Act, the AQM D is required to attain th e PM10 standards for both of these air basins by 2006. For ozone, the AQMD is required to attain the ozone standards by 2010 and 2007 for SC AB and SSAB, respectively.

In order to attain healthful air, federal and state laws require the AQMD to adopt an Air Quality Management Plan (AQMP) th at identifies a control strategy to demonstrate compliance with federal ambien t air quality standards and expeditious progress toward state air quality standards. 2 To address these state and federal mandates, the 1997 AQMP and 1999 Amendments to the 1997 Ozone State Implementation Plan for the SCAB incl uded Control Measure WST-02 – Emission Reductions from Composting. These air pl ans identified composting as a source of ammonia, PM10, and VOC emissions. As such, Control Measure WST-02 calls for the development of viable controls to reduce the emissions from this industry by 2001. Proposed Rule 1133 – Emission Reductions from Composting Operations and Related Operations, has been developed to implement Control Measure WST-02.

Following is a brief description of the heal th and environmental concerns with air contaminants emitted from composting and related operations that contribute to the

formation of PM10 and ozone. Bioaeros ols, which are organisms (including aspergillus fumigatus, endoctoxin, and orga nic dust) dispersed through the air that can affect human health, are not addressed in this report. Finally, since U.S. EPA regulates pathogens, which are bacteria, viru ses, and parasites found in most compost

1 Name given to a severe ozone non-attainments are with a 1988 ozone design value between

0.19 and 0.28. The attainment date is 17 years (ins tead of 15 years) after the date of enactment

of the Clean Air Act Amendments of 1990.

2 California Health and Safe ty Code Section 40460(a).Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 2 March 2002 feedstocks, and the regulations are consider ed effective in pat hogen destruction by experts in the field, this issue is also not addressed in this technology assessment.

Particulate Matter (PM10) Composting and related operations (i.e., chi pping and grinding) are sources of direct PM10 and ammonia, which is a PM10 precursor . Ammonia in the atmosphere reacts with nitric acid and sulfuric acid to produ ce nitrate and sulfate pa rticles, a constituent

of PM10.

PM10 is generated when composting pile s are turned, moved, and from wind entrainment of static uncovered piles. Associated activities like chipping and grinding also produces PM10 emissions when the wood and greenwaste are mechanically ground and shredded. Biological degradation (or decomposition) of organic materials (i.e., yard waste, manur e, sewer sludge, etc.) that occurs during composting and when chipped and ground materi al begins to rot produces ammonia. Ammonia is produced in both aerobic (in th e presence of oxygen) and anaerobic (in the absence of oxygen) environments. Co mposting is an aerob ic process but can become anaerobic when for example, a pile is built incorrectly, the pile gets too little oxygen, the temperature is too high, or ther e is too little or too much moisture. Chipped and ground material that is left unmanaged likewise begins to decompose and produce ammonia emissions for the same reasons as composting.

PM10 is a public health concern since part icles less than 10 microns can be deposited in, and can damage, the airways of the lowe r respiratory tract and the gas-exchange portions of the lung. The adverse health e ffects of particulates, especially PM10, are

well documented. Various health studies have linked PM10 emissions to increased respiratory infections, more severe asth ma, declines in pulmonary function, and shortened life spans. Specifically, recent studies indicate that the current ambient levels of PM10 (30 to 150 μ g/m 3 ) experienced in many different communities in the

United States are associated with increases in daily cardio-respiratory mortality and in total mortality, excluding accidental and su icide deaths. Increases in ambient PM10

levels have also been shown to result in increases in acute respiratory hospital admissions, school absences in children, and increases in the use of medications in

children and adults with asthma.

Ozone VOCs are produced during the anaerobic (in the absence of oxygen) decomposition of organic material. Decomposition occurs when chipped and ground material is composted or when the material is left in an unmanaged state and begins to rot.

There are no state or national ambient ai r quality standards for VOCs because they are not classified as criteria pollutants. VOCs are regulated, however, because VOCs

contribute to the formation of ozone and are transformed into organic aerosols in the atmosphere, contributing to higher PM10 and lower visibility levels. Ozone is formed in the atmosphere through a photoc hemical reaction of VOC and NOx.

Ozone is a deep lung irritant, causing the lung passages to become inflamed and swollen. Exposure to ozone produces al terations in respiration, the most characteristic of which is shallow, rapi d breathing and a decr ease in pulmonaryTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 3 March 2002 performance. Ozone reduces the respiratory system's ability to fi ght infection and to remove foreign particles. People who su ffer from respiratory diseases such as asthma, emphysema, and chronic bronchitis are more sensitive to ozone's effects. Early studies suggested that long-term exposure to ozone re sults in adverse effects on morphology and function of the lung and acceleration of lung-tumor formation and aging. Ozone exposure also increases the sensitivity of the lung to bronchoconstrictive agents such as histamine, acetylcholine, and allergens.



### COMPOSTING PROCESS Composting is a biological process where or ganic materials (i.e., leaves and grass, yard trimmings, agricultural crop residues, etc.) are decomposed by microorganisms to create a soil-like material called compos t. While decomposition occurs naturally anywhere plants grow, the process has also been industrialized whereby green and wood wastes are mechanically ground a nd shredded accelerate and control the decomposition process.

Sometimes the green and wood waste is mixe d with putrescible wastes (i.e., manure, horse shavings, food waste, sewer sludge, etc.). In this region, with the exception of three facilities, the material is moved with front-end loaders into long piles called

windrows. The windrows are then mechanic ally turned generally with front-end loaders to increase aeration and provide oxygen to facilitate the decomposition process. The temperature and moisture are monitored to optimize and hasten decomposition. After two to four months in the windrows, the material becomes
compost.

Composting is an important component of the solid waste industry. It provides resource conservation through source reduction, recycling, and reuse. However, as with other industrial processe s, composting produces air em issions that are currently uncontrolled. In terms of air quality, co mposting is an exothermic process that releases carbon dioxide, water vapor, and ot her organic and inorga nic gases such as ammonia, methane, VOCs, amines, and sulfides. The emissions impacts of composting are presented in the emissi on inventory section of this report.

From an industrial perspective, composting is a three-stage process that begins as soon as appropriate materials are combined and piled together. The initial stage of the process is referred to as active compos ting followed by curing or finishing, and storage and/or processing of composted products.

During the composting process microorga nisms such as bacteria, fungi, and actinomycetes, consume oxygen while feeding on organic material such as wood/greenwaste, food-waste, livestock manur e, sewer sludge (the semisolid residue of domestic sewage treatment processes) and other putrescible materials. The microbial activity results in the decay of the initial mixture and at the completion of the composting cycle wastes are transformed into a stable, pathogen-free composted

material.

The microorganisms that contribute to the composting process contain both thermophilic and mesophilic species. Themophilic and mesophilic microorganismsTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 4 March 2002 are microorganisms that can su stain life under high (110-150 o F) and low (50–105 o F) temperatures, respectively. The type of microbial activity present can characterize the active and curing stages of the compos ting process. Active composting is where the thermophilic microorganisms’ populatio n is the highest. This stage is characterized by high temperatures, high level of oxygen demand and high evaporation rates due to temperature. Conve rsely, the curing stage of the process is where the mesophilic microorganism populat ion is the highest and the need for oxygen and the evaporation rates decreases. There is also a linkage between the microbial activity and the VOC emissions profile from composting operations. Specifically, emissions can be correlated to the activity of these microorganisms in that the emissions are generally higher during thermophilic temperatures and lower during mesophilic temperatures. Figur e 1-1 illustrates the oxygen demand and microbial profile of the various composti ng stages. This figure can be used to illustrate the corresponding VOC emissions.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 5 March 2002 Figure 1-1

PHASES DURING COMPOSTINGOXYGEN DEMAND RATE, *CARBON DIOXIDE EVOLUTIONTEMPERATURE

SCREENING COMPOSTING CURING

TIME THERMOPHILIC

MESOPHILIC COMPOST IS

STABLE PHASES DURING COMPOSTING

This graphic was provided by Eliot Epstein, Ph.D. Chief Environmental Scientist, Tetra Tech, Inc.

*VOC emissions are expected to follow the similar profile as oxygen demand.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 6 March 2002 As stated before, it is the ability to cont rol the physical and chemical characteristics of the process that makes composting a viab le industrial process. Following is a description of the main characteristics that are optimized in an industrial composting

process.

Carbon-to-Nitrogen ratio (C:N) represents the weight of decomposable carbon to the weight of total nitrogen in an organic material. Carbon and nitrogen are two

fundamental elements for microbial activ ity. Microorganisms utilize carbon for energy and growth, and nitrogen for protein and reproduction. C:N ratio is significant to the composting process because insuffi cient nitrogen (higher ratio) will limit microbial growth, but excess nitrogen (lower ratio) will generate ammonia or other compounds that cause odors. For the best composting, the recommended C:N range from 25:1 to 40:1, and a ratio of 30:1 is ideal. C:N ra tio can be adjusted by adding organic materials high in nitrogen such as gr ass, sewage sludge, or animal manure, or by adding materials high in car bon such as leaves. Using commercial fertilizer as nitrogen supplement is not recommended becau se it will modify salt concentration in the compost and impede microbial activity.

Moisture content is the water portion of the material's total weight, expressed in a percentage. Moisture is an essential part of composting. It allows microorganisms to move about and transport nutrients, as we ll as provides the medium for chemical

reactions. Insufficient moisture content will lead to microorganisms entering a dormant stage. Excessive moisture will limit air movement to and in the compost pile, causing an anaerobic decomposition that generates unpleasant odors. In addition, excessive moisture will also resu lt in leachate. Since moisture content decreases as composting proceeds, a starti ng moisture content of 40% to 60% is recommended, and 50% to 60% is considered to be ideal. Usually, a mixture that feels moist, like a well-wrung sponge, indicate s sufficient moisture. Moisture content can be adjusted either by adding water or moisture-rich organic materials, such as liquid sewage sludge, or by a dding dry bulking agents such as leaves or wood chips.

Oxygen is critical to composting, esp ecially during the early stage when microorganisms rapidly metabolize and grow. Insufficient oxygen supply will slow down the composting process a nd lead to an anaerobic d ecomposition that generates obnoxious odors, and ammonia and VOC emissi ons. Excess oxygen (or air) will also lower the pile's temperature slowing down the composting rate. Oxygen concentration fluctuates in response to the microbial activity. Usually, at the beginning of the composting process, oxygen concentration within the pore spaces is identical to oxygen concentration in the ai r (about 15% to 20%). However, as the compost ages, the oxygen concentration decr eases and carbon dioxide concentration increases. A 5% to 15% oxyge n concentration must be ma intained for fast, aerobic composting. Oxygen (or air) can be provi ded by mechanical turning or by forced aeration, where air is either drawn or forced through the compost pile.

Temperature is an important aspect of compos ting since composti ng occurs within two temperatures ranges, known as mesophilic (50 o F to 105 o F) and thermophilic (over 105 o F). Thermophilic temperatures are preferred because they promote rapidTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 7 March 2002 composting, and destroy pathogens, weed s eeds, as well as fly larvae. However, extreme temperatures (above 160 o F) will kill most of the active, important microorganisms. According to composting experts, temperatures in the range of

110 o F to 150 o F are best for composting. The U.S. EPA requires that a minimum temperature of 131 o F be maintained for several days to eliminate bacteria and pathogens. Usually, adding external h eat is unnecessary because during the composting process, heat is generated by microorganisms and is accumulated due to the pile's self-insulation. To prevent the temperature from rising to an extreme level that creates a fire hazard, fr equent aeration is necessary.

pH value indicates the level of acid or base in the compost. pH value is critical to composting since it affects the nutrient an d metabolism of the microorganisms. Microorganisms consume organic acid very quickly; however, the majority of them

can not survive an extreme acidic environmen t (i.e., where the pH value is far less than 7). According to composting experts, optimum pH values range between 6.5 and 8.0. Increasing the pH value by the addition of lime or other additives is not advised because of the potential ammonia loss. pH values above 8.5 encourage the conversion of nitrogen compounds to ammonia, creating an odor problem. pH value changes during the composting process, and it can be adjusted by aeration or through a natural process called carbonate buffe ring. Through the carbonate buffering process, carbon dioxide combines with water to produce carbonic acid that will lower the compost pH. As a result, the final com post product always ha s a stable, close to neutral pH value.

Particle size affects the efficiency of the composting process. Generally, microbial activity occurs on the surface of the particles. Therefore, an increase in the surface area by using smaller particle s will increase the rate of decomposition. However, smaller particles also reduce the porosity, which is a measurement of the air space within the composting mass. This can result in poor aera tion and increased emissions. Good particle sizes range from 1/8 to 2 inches average diameter and can be achieved by chopping, shredding, mowing, or breaking up the materials.

Pile structure , in particular the mixing of materi als, size and shape are important to start off the composting process properly. The materials to be composted must be thoroughly blended to evenly distribute mois ture, porosity, and C:N ratio. A compost pile must be well constructed to prevent rapid dissipation of heat and moisture, yet allow good air circulation. The pile should be at least 3 ft x 3 ft x 3ft (1 cubic yard) to keep sufficient heat, but not larger than 5 ft x 5 ft x any length so air can diffuse to the center of the pile. Some composting system use forced air or mechanical turning to compensate for larger size piles.

Feedstock also affects the composting process. One of the most important aspects of

feedstock is how it affects the C:N rati o of the compost pile overall. Some feedstocks, like grass clippi ngs, digested sewer sludge an d food waste are higher in nitrogen content, while tree limbs and wood scraps are lower in nitrogen content. As such, waste materials are blended to achieve an optimum C:N ratio and decomposition rate. For the purpose of this rule, the composting industry has been divided into two main categories based on feedstocks handled: co-composting andTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 8 March 2002 greenwaste composting. Co-composting us es putrescible feedstock materials including, but limited to, sewer sludge, cow and horse manure, and food waste combined with bulking agents like greenwaste or wood chips. The feedstock comes from sewage treatment plants, dairies, horse stables, restaurants, etc.

Greenwaste composting only uses greenwast e feedstock materials such as wood,

leaves and related raw materials. The feedstock comes from landscape maintenance activities, construction sites, agriculture, curb side recycling programs, etc. One of the primary factors affecting greenwaste supp ly from curb side recycling programs is the level of contamination (i.e., mixing of ya rd waste with other trash). The level of contamination varies widely among curb si de recycling programs and is influenced by the amount of public outreach, the contai nment method, and frequency of pick-up.

Products Produced Composted products are used in many applications depending on the characteristics of the raw materials and the quality of the product produced. In general, high quality compost may be used in agriculture, horticu lture, landscaping and home gardening. Composting facilities that use sewer sludge as a feedstock genera lly rate the quality of their compost as high. Medium quality compost can be used in applications such

as erosion control and roadsi de landscaping. Low quality compost can be used as a landfill cover or in land reclamation projects. In southern California, most of the composting products are used in agricultural and horticultural operations. Smaller markets for composting products include munici pal, Caltrans, local residents, etc. Most composting facilities make between one and five different composting products. Some compost facilities also provide spec ialized services in cluding special product blending, spreading, bagging and delivery.



### CHIPPING AND GRINDING ACTIVITIES The chipping and grinding component of the composting and related operations industry include operations that are dedicate d mainly to the mechanical size reduction of greenwaste. Mobile chippers and/or tub grinders are used to shred the green material. Sometimes the equipment is connected to screens and magnetic separators to produce certain end products and improve the quality of the end product. These operations chip and grind greenwaste such as tree trunks, residential and commercial landscaping, curbside green-waste recycling, and debris from construction sites. The chipped and ground material produced is then used as an alternative daily cover (ADC) at landfills, fuel in waste-to energy facilities, mulch, raw material for greenwaste composting, or bulking agents for co-composting operations. Chip and grind operations can be a stand-alone operati on or a part of a composting facility.

Business Structure Composting and chipping and grinding facilities generate income from two sources. First, these facilities charge haulers “ti pping” fees when they drop off the raw feedstocks. Second, these facilities sell the final products (e.g., compost, fuel for waste-to-energy plants, mulch, etc.). Tippi ng fees vary across the state. Table 1-1 provides a summary of tipping fees thr oughout California from a study sponsored by the CIWMB in 2000. The study indicates that southern California has lower tipping

fees than northern California.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 9 March 2002 Table 1-1 Solid Waste Tipping Fee Survey of California

Region Average Tipping Fee (per ton) Northern $58.49 Bay Area $47.73 Central Coast $39.21 Central Valley $35.79 Southern (includes SCAB) $35.42

In the SCAB, based on staff survey, tipping fees for greenwaste range from $10 to $15 per ton and tipping fees for sewer sludge ra nge from $30 to $40 per ton. If the material was landfilled, the tipping fee would be $30 per ton.

The sale price of compost varies widely a nd competes with fertilizers. Composting facilities generally sell thei r final compost product for ar ound $30 per ton. Very high quality and specialty compost can command a price of $90 a ton. Chipping and grinding facilities sell a fina l product like fuel for waste-to-energy plants for about $10 per ton.

For facilities that compost by windrowing the feedstock (which is the dominate method in the SCAB) operational costs in clude leasing unimproved land, leasing equipment (i.e., grinders and front-end loaders), and low-skilled labor. These operations are generally not labor intensive. An average size composting facility has 5 to 10 employees. Operational costs are highe r for facilities that transport their final products since they incur additional costs for tr ucks and drivers. Generally, these cost are recouped by having the custom er pay shipping costs. Ch ippers and grinders incur similar costs to composting facilities.

Sanitation agencies that do not currently compost sewer sludge incur costs for disposing of the sludge by land spreading. These agencies must pay for the sludge to be transported (to Kerns, Kings, and/or Ri verside Counties). Currently the transport cost including labor and tippi ng fee is approximately $38 per ton and is expected to increase if the disposal site is further away from the SCAB.



### OVERVIEW OF CURRENT RE GULATORY REQUIREMENTS There are three levels of regulatory requirements that apply to the composting and chipping and grinding industries: 1) federa l requirements (i.e., U.S. Environmental Protection Agency or EPA; 2) state (i.e., the California Air Resources Board (CARB) and the California Integrated Waste Mana gement Board (CIWMB)), and, 3) local (i.e., the AQMD, local governments, and local enforcement agencies). Each of these agencies’ regulatory structure is designed to deal with different issues and while not necessarily driven by air issues some may i ndirectly benefit air qu ality. None of the existing regulations directly address air quality impacts from these operations. The following is an overview of federal, state and local regulatory programs that are applicable to the chipping and gr inding and composting industries.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 10 March 2002 Federal Requirements The federal Clean Air Act requires the AQM D to adopt an AQMP that identifies a control strategy to demonstrate compliance with the federal ambient air quality standards. To address this federal mandate, the 1997 AQMP and 1999 Amendments to the 1997 Ozone State Implementation Plan for the SCAB included Control

Measure WST-02 – Emission Reductions from Composting. The U.S. EPA approved these plans making the development of this control measure federally enforceable. In addition to air quality issues, there are ot her federal requirements that apply to composting operations. Specifically, the fe deral requirements focus mainly on water and solid waste (i.e., sewage sludge) issues . The following is a brief summary of these requirements.

Resource Conservation and Recovery Act In 1976, Congress enacted th e Resource Conservation and Recovery Act (RCRA), an amendment to the 1965 Solid Waste Disposal Act. RCRA calls for conservation of energy and natural resources, waste reduction, and environmentally sound waste management practices. In addition, RCRA encourages states to develop plans for

non-hazardous industrial solid waste and m unicipal solid waste (MSW) management, sets criteria for MSW landfills, as well as for other solid waste disposal facilities, and prohibits the opening dumping of solid waste. Congress delegated authority to U.S. EPA to develop specific regulations to im plement the requirements of RCRA. Solid waste regulations have been promulgated in the Code of Fede ral Regulations under Title 40, Chapter I, Subchapter I, Parts 240-282 (40 CFR Parts 240-282). As a result of RCRA’s prohibition on open dumping of solid waste other disposal alternatives for sewage sludge has been pursu ed including land spreading (t reated sludge is spread over crop land as fertilizer), aer obic digestion, and composting.

National Pollutant Discharge Elimination SystemThe National Pollutant Discharge Elimination System (NPDES) is an EPAimplemented program that requires permits for discharging pollutants from facility operations into water 3 . Even though the NPDES progr am focuses on water pollution from all types of industries, NPDES also a pplies to owners or ope rators of facilities that treat and handle sewage sludge, incl uding composting with sewage sludge. The criteria and standards for NPDES are quite extensive and have been promulgated in several parts of the Code of Federal Regulations under Title 40, Chapter I, Subchapter D, Parts 122, 123, 124 and 125 (40 CFR Parts 122–125).

Sewage Sludge Disposal Standards EPA promulgated standards for the use or disposal of sewage sludge in Title 40, Chapter I, Subchapter O, Part 503 of the Code of Federal Regulations (40 CFR Part 503). 40 CFR Part 503 contains requirements for the control of pathogens, vectors, and heavy metal for sludge composting operations . In particular, to qualify as Class A compost Appendix B to Part 503-Pathogen Tr eatment Processes, generally requires processes to further reduce pathogens ( PFRP). PFRP requires that open windrow composting maintain the temperature of the compost to be 55 0 C or higher for 15 days or longer, and during this time there must be a minimum of 5 turnings of the

3 40 CFR Part 122, §122.1 (b).Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 11 March 2002 windrows. For in-vessel or aerated static pile (ASP) co mposting, the PFRP requires the active pile temperature be at least 55 0 C or higher for 3 days.

State Requirements State law also requires the AQMD to a dopt an AQMP that identifies a control strategy to demonstrate progress towards achieving the state ambient air quality standards. The 1997 AQMP and 1999 Amendments to the 1997 Ozone State Implementation Plan for the SCAB th at included Control Measure WST-02 – Emission Reductions from Composting, was also submitted to the CARB to comply with state law. These air plans identified composting as a source of ammonia, PM10, and VOC emissions. As such, Control Me asure WST-02 required the development of viable control to reduce the emissions from this industry by 2003. In addition to air quality requirements, there are several ot her state requirements that may apply to chipping and grinding and composting op erations. Specifically, these state requirements focus on air, water and solid waste (i.e., sewage sludge) issues. The following is a summary of these requirements.

California Air Resources Board In addition to reviewing and approvi ng the AQMP, CARB permitting requirements can affect composting and chipping and grinding operations that use portable equipment. As of December 1, 1999, CARB runs the “Statewide Registration Program” which regulates portable engine s and portable engine-driven equipment units. Once equipment is registered in th is program, engines and equipment units can operate throughout California without the n eed to get individual permits from local air pollution control districts, such as the AQMD. The AQMD is preempted from permitting, registering, or regulating por table engines and portable equipment units properly registered with the CARB.

Owners and operators of porta ble engines and portable equi pment units that meet the definitions and requirements of the registration program are eligible for statewide registration. Facilities that conduct chi pping and grinding or composting activities operate portable engines that are affiliate d with equipment, including but not limited to, wood chippers, tub grinders and trommel screens. It is common for these types of facilities to have equipment operating pursu ant to Statewide Registration Permits.

California State Legislature: Californ ia Integrated Waste Management Act Recognizing the need for integrated wast e management practices, in September 1989, the California state legislature passed Asse mbly Bill (AB) 939 – California Integrated Waste Management Act, into law, which was incorporated into the California Public Resources Code, Division 30, §40000 et seq. (Division 30). Division 30 is implemented by CIWMB. Section 41780-41786 of the law contains mandates for

cities and counties to achieve a total wa ste diversion of 25 percent by 1995, and a total waste diversion of 50 percent by 2000, as established by a 1990 baseline. Division 30 also requires California to s ecure and plan for adequate long-term disposal capacity. Since organic materials, such as food and gr eenwastes, represented approximately 25 percent of California’s wast e stream in 1999, recycling, reuse, and source reduction have been widely promoted to achieve the goals of Division 30.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 12 March 2002 California Integrated Wa ste Management Board In June 1995, the CIWMB promulgated a set of regulations governing composting operations and facilities. The CIWMB currently regulates approximately 87 composting facilities operating in Californi a in accordance with the California Code of Regulations, Title 14, Division 7, Chapter 3.1 – Composting Operations Regulatory Requirements (Chapter 3.1). Depending on the type of composting materials and the throughputs, affected fac ilities are required to obtain a Registration Permit, a Standardized Composting Permit, or a Full Solid Waste Facilities Permit (Full Permit). Full Permits require the preparation of an Environmental Impact Report (EIR) and are issued by CIWMB while Registration and Standardized Permits are issued through local enforcement agencies (LEAs), such as the environmental health departments. According to the CIWMB data-base, sixteen of the twenty-seven facilities in the AQMD’s jurisdiction ar e identified as having a CIWMB permit.

Currently, the CIWMB is revising these regul ations to address a number of issues relating to composting activities including an increasing number of complaints regarding odor at compostable organic mate rials transfer/proce ssing operations and

facilities. The CIWMB’s staff is concerne d that continued problems with odors could limit the growth of the composting industry. As such, the CIWMB is proposing to revise its regulations to require odor minimization plans developed by the composting facilities. The odor minimization plans w ould be reviewed only if there exists a documented public nuisance. While odors ar e under the regulatory oversight of the jurisdiction’s local en forcement agency, odors are an indication that the piles are emitting ammonia and VOCs. The AQMD retains authority over emissions from

these facilities.

Though chipping/grinding facilities are not currently required to obtain permits, CIWMB is developing a proposal to amend the permit requirements in Chapter 3.1 to include chipping/grinding and other operat ions that handle compostable organic

materials.

Regional Water Quality Control Board The Regional Water Quality Control Boar d (RWQCB), a state agency with regional offices throughout California, enforces EP A-issued National Pollutant Discharge Elimination System (NPDES) permits. In addition, the RWQCB focuses on wastewater generation, water demand, the cap acity of existing or planned stormwater drainage systems and potential new sour ces of polluted run-off, and potential depletion of groundwater supplies or interfer ence with groundwater recharge. In the case of composting and chip ping/grinding facilities , the RWQCB has required various sites to be graded, paved, and su rrounded by berms and other drainage-related protections to prevent run-off and th e leaching of composted/chipped ground materials into the groundwater.

Local Requirements There are several local requirements that may apply to chipping/grinding and composting operations. Specifically, these requirements focus on air, land use and solid waste (i.e., sewage sludge) issues. The following is a summary of these requirements.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 13 March 2002 AQMD Rule Requirements Currently, operators of composting and chi pping/grinding faciliti es located in the district are required to comply with AQMD Rule 402 – Nuisance, Rule 403 – Fugitive Dust, and Rule 203 – Permit to Operate for equipment that require permits. However, none of these rule s require specific emission controls at composting or

related facilities.

Local Enforcement Agency Requirements There are several different local (i.e., city or county) enforcement agencies or LEAs that act as the either the permitting or enforcement division of the CIWMB, depending on the throughput and type of co mpostable materials. For example, the local department of health services, on beha lf of the CIWMB, issues Registration and Standardized permits and enforces the requir ements in these permits for facilities with lower throughputs. However, for facilities that have throughputs that require a Full Permit issued by the CIWMB, the LEA is only responsible for enforcing the requirements in the Full Permit. For either type of permit scenario, the LEAs are responsible for handling a nd investigating complaints from composting and chipping/grinding operations.

City or county offices in the jurisdiction wh ere a facility is locat ed approve or deny conditional use permits, and have the auth ority over land use and the siting of composting facilities, transfer stations, or other solid waste management activities.

Sewage Sludge Ordinances In addition to EPA’s federal requirements regarding the use or disposal of sewage sludge, there are local ordinances or restrictions th roughout California and other states that ban the import and land applicati on use of certain grades of sewage sludge. For example, 14 counties within California , with Riverside county being the only one located within the AQMD’s jurisdiction, have passed ordinances or permitting requirements that either ban or restrict the application of certain grades of sewer sludge onto farmland 4 . In addition, recent litigation a nd regulations in both Kern and Kings counties have resulted in ordinances that ban the import of certain classes of sewage sludge starting early 2003. Other states such as Pennsylvania, Vermont, and New Hampshire, have also passed similar ordi nances to ban or lim it the application of sewer sludge onto land. These restrictions will likely force the water treatment plants within the AQMD’s jurisdiction, throughout California and the nation to further process the sewage sludge so that it ca n be recycled and used on farmland.

Local Governments Local government zoning and general plan standards determine where composting and chipping and grinding activities can occu r. In addition, local governments grant conditional use permits if the jurisdiction ha s determined that special conditions and approvals are necessary. Local governments, through curb side recycling programs, may also be providing some composters with greenwaste feedstock.

4 County of Riverside Ordinance No. 744 – Regulating the Processing of Greenwaste.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 14 March 2002 

### OTHER ISSUES FACING TH E COMPOSTING INDUSTRY

Public Nuisance Issues Uncontrolled emissions, odors, and dus t generated by windrow composting and chipping and grinding operations are often sources of public complaints. Emissions and odors can dramatically in crease if the windrows are not maintained properly or chipped and ground material is allowed to decompose. Some feedstocks like food waste, dairy products, manure, sewer sl udge, are odorous. Also, some outdoor blending operations of putre scible feedstocks generate odor related public nuisance complaints. Dust may also result from open feedstock preparation areas, chipping and grinding operations, and compost turning, curing, screening, storage, and loading. The problem can be worse during high winds.

Over the last two years, thousands of odor and dust complaints have been filed with the AQMD and with local enforcement agen cies (LEAs). In particular, between January 1, 2000 and December 31, 2001, the AQMD received 470 public complaints regarding composting and chipping and grinding operations. The LEAs have received over 2,600 complaints regarding composting and chipping and grinding operations. 5 The AQMD staff has issued notices to comply (NC) and notices of violation (NOVs). The AQMD does not have records of enforcement actions taken by the LEAs. Table 1-2 summarizes this information.

Table 1-2 2000-2001 Public Complaints/AQMD Enforcement Actions

On Composting and Chipping and Grinding Operations

Agency # of Complaints # of NCs/NOVs AQMD 470 55 (30 NCs and 27 NOVs) LEAs 2,600+ N/A

The AQMD’s role in addressing public complaints from these facilities has been affected by AB 59 that become law in 1995. Under this law, a ll air districts in California are to refer public complaints pertaining to odors from a composting facility that is subject to the CIWMB’s regulatory requirements to the LEA. Odors from non-composting activitie s like chipping and grinding activities, mulching, and ADC are under the AQMD’s jurisdiction. Non-odor related public complaints including dust-, permitting-, or emissions-r elated nuisances affecting the public are within the AQMD’s jurisdiction.

Waste Diversion (AB 939) AQMD staff has received public testimony th at composting is an integral program used to comply with AB 939 (the Califor nia Integrated Waste Management Act of 1989) Waste Diversion requirements. AB 939 is implemented by the CIWMB, and mandates cities and counties to achieve a 25 percent total waste diversion by the year

5 This number underestimates the total number of co mplaints to LEAs because not all the LEAs maintain the data in a tabulated format and not all the composting and chipping and grinding facilities were included in the AQMD’s data request.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 15 March 2002 1995, and a 50 percent waste diversion by the year 2000, based on the 1990 baseline year. Organic materials, one component of the waste stream, can be diverted from landfills through methods including use as ADC , fuel at waste-to-energy facilities, mulch, composting, soil amen dments and erosion control.

AQMD staff has conducted an evaluation of the current practices in achieving the waste diversion goals of AB 939. The CIWMB measures compliance with AB 939 waste diversion goals by measuring the re duction in the amount a given jurisdiction disposes to the landfill. There is no quantifiable measurement of the quantity of waste actually being diverted. For each jurisdiction a maximum allowable disposal amount is calculated which represents a 50 percent reduction of disposed waste from 1990. To meet the diversion rate requireme nt, a jurisdiction may not dispose more than the maximum allowed amount. Each jurisdiction must also submit an annual report that includes information on all progr ams being implemented to divert waste disposal to a landfill. Organics are only one of the waste categories that is affected to achieve the AB 939 goals. Jurisdictions also promote source reduction and the recycling of paper, glass, and alumin um cans, and household hazardous waste.

The CIWMB estimates that the year 2000 statewide diversion rate is at 42 percent. As indicated above, it is unknown how mu ch each individual waste diversion program contributes to the overall waste diversion rate. AB 939 requires each jurisdiction to prepare, adopt, and submit to the CIWMB a source reduction and recycling element (SRRE) that demonstrates how the jurisdiction will meet the CIWMB’s mandated diversion goals. The CIWMB approves the information submitted by each jurisdiction, but does not keep track of each individual program’s

effect on diversion. It is the burden of each individual jurisdiction to show to the

CIWMB that the diversion mandate is be ing met. While the database does not provide specific information on the amount of waste diverted from each of these programs, it does indicate an intention to di vert waste by using a variety of programs. These programs include: source reduction, composting, recycling, specials waste, public education, poli cy incentives, f acility recovery, transformation, and household hazardous waste. Recycling and source reduc tion are the preferred programs used by the most number of jurisdictions to achieve the targets. Recycling programs included curb-side pick up, drop-off programs and special programs. Source reduction included thrift shops, business programs, xeriscaping, and backyard composting (proposed to be exempt from PR 1133).

The CIWMB further analyzes the SRRE documents to determine waste stream

characteristics. Based on a 1999 waste characterization study conducted by the CIWMB, all organics contri bute about 35.1 percent to the overall waste stream. Organics include materials that are eligible for composting programs. Organics waste includes food, landscaping materi als, agricultural crop residues , manures, textiles, etc. Table 103 lists a break-down of the orga nics-only waste stream based on the

CIWMB’s records.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 16 March 2002 Table 1-3 Types of Organics Contributing to Waste Stream

Organic Material Type Percentage of Waste Stream

Food 15.7%

Leaves & Grass 7.9% Prunings & Trimmings 2.2% Branches & Stumps 0.1% Agricultural Crop Residues 0.0%

Manures 0.1%

Textiles 2.1% Remainder/Composite Organic 6.9%

Recent studies by the CIWMB show that while organics are prevalent in the waste stream, many of these organic materials ar e also associated w ith odor and emissions problems. For example, Table 1-4 indicates the top ten materials in the waste stream. Food waste makes up the highest percentage of the waste stream. The AQMD staff has received a significant number of odor complaints from composting-related

activities that includes food wastes. Grass is another organic waste material that has odor problems associated with it. Grass can be an issue in greenwaste composting leading to higher emissions and odors because of its moisture and rapid decomposition.

Table 1-4 Top Ten Materials in Waste Stream

Material Percentage of Waste Stream

Food 15.7% Remainder/Composite Paper 9.6%

Leaves & Grass 7.9% Remainder/Composite Organic 6.9%

Lumber 4.9% Uncoated Corrugated Cardboard 4.6% Other Miscellaneous Paper 4.4% Newspaper 4.3%

Film Plastic 3.9%

Other Ferrous Metal 2.4%

There are a number of different programs bei ng used to divert green waste that rely on source reduction, transformation, public education, incentive programs, and composting. These programs are listed in Table 1-5.

Table 1-5 CIWMB Identified Examples of Programs to Divert GreenwasteTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 17 March 2002 Programs Description Xeriscaping, grasscycling Landscaping to reduce waste Backyard composting Composting at home by residents Mulching Gardening product Seasonal Collections Holiday foliage Commercial Composting Creation of co mmercially sold gardening products Alternative Daily Cover Substitute cover for soil at landfills Fuel For waste-to-energy facilities Bulking agent For use in co-composting of sewer sludge, food

waste, manure
Landfill ban on
greenwaste Not accept greenwaste

Tipping fee incentives Structure fe es to benefit source reduction

Collection rate incentives Structure fees to benefit source reduction School composting Composting conducted at schools with on-site

materials

A review of the CIWMB’s database on lo cal government’s SRRE’s indicates ADC appears to be an importan t program currently being us ing to achieve the AB 939 diversion targets. For example, in the facility recovery component of the SRRE, approximately 58 local governme nts (in the four counties) in dicated that they rely on a composting facility program, while appr oximately 103 local governments indicated they rely on ADC programs.

A study was also conducted by the CIWMB to assess California’s compost and mulch producing infrastructure. The study analyzed both composters and processors (i.e., process material, but do not compost). The surveys of the chippe rs and grinders are good general indicators of the types of programs being relied upon to divert greenwaste from landfills for several reasons. All the greenwaste that is diverted from landfills must be processed (i.e., ch ipped and ground) before it can be put to other uses, including the greenwaste collected by local jurisdictions in curb-side recycling programs. The chippers and gr inders in the survey are stand-alone operations that do not compost on site, so it is good indication of the overall market demands for processed greenwaste. 6 There are more chippers and grinders (47) than composters (28) in the AQMD’s jurisdiction and the chippers and grinders handle 3 times more greenwaste than the composters. This study (focusing on the chippers and grinders data) indicates that in southern California alternative daily cover (ADC) is the most heavily relied upon method jurisd ictions use to divert greenwaste from landfills (46%), followed by fuel for waste– to-energy facilities (25%), and then composting (18%). The study also acknowled ged that southern California’s use of ADC leads other regions in California. Even when the composters’ product distribution is considered, ADC and fuel ar e still important to waste diversion.

6 The survey of the chippers and grinders was viewed as a better overall indicator of the markets since chippers and grinders facilities serve as the first stage in the diversion process. For example, chippers and grinders provide raw feedstock to composters. Therefore, using composter data may result in double counting of product markets. Further, any chipping and grinding performed by the composters is primarily for processing composting-related products and not as reflective of the other markets for processed green

waste.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 18 March 2002 Composters in southern California produce compost (50% of their products), ADC (16%), fuel (6%), and mulch (13%).

The AQMD staff conducted a survey of composting and related facilities in the region. The composting facilities and most of the chipping and grinding facilities were visited by AQMD staff and the surveys completed as part of that visit. Surveys

were also mailed to other facilities and some facilities were surveyed over the telephone. Part of the AQMD’s survey included collecting information on the amount of greenwaste that was being composted in the AQMD’s jurisdictional boundaries. The AQMD’s survey of the chipping and grindi ng and composting facilities supports the finding that ADC and fuel for waste-to-energy facilities are key programs being relied on by local governments in general for achieving the AB 939 waste diversion goals. Based on this surv ey, the AQMD staff also determined that the total amount of gr eenwaste used either as a bulking agent fo r co-composting or at a greenwaste composting facilities was approxi mately 1.1 million tons a year. Of the 3 million tons of material processed at chi pping and grinding facilities, approximately
15-40% of the material is used for wast e-to-energy, 50-60% for ADC, and 10% for mulching or composting.

The prevalence of ADC as a key program fo r greenwaste diversion is also recognized by the CIWMB. The CIWMB has summari zed the reported waste-derived ADC

since 1996 in Table 1-6.

Table 1-6 CIWMB Statewide ADC Analysis (tons/year) ADC Type 1996 1997 1998 1999 2000
Green Material 560,266 625,198 1,083,673 1,396,026 4,302,443 7

Other (mainly Sludge;

Treated Auto Shredder Residue; C&D) 383,669 659,339 587,285 791,786 666,042

Total ADC 943,935 1,284,537 1,670,958 2,187,812 4,968,485 ADC % of Total Disposal 3.0% 3.5% 4.5% 5.5% 15%

Based on available data, AQMD staff has not been able to quantify the extent to which these programs are actually bein g utilized to achieve the AB 939 waste diversion goals. There are no records that indicate which programs are the most important to achieving the AB 939 waste di version goals. Therefore, a qualitative assessment of surveys and other informati on has been conducted to determine the relative importance of each program in diverting waste.

To further address the waste problem in California, the CIWMB is exploring conversion technologies that would convert organic materi als, including greenwaste, into high-value products like energy, alternative fuels (eth anol), solvents, and other products. These technologies include hyd rolysis, gasification, and anaerobic digestion. Hydrolysis is the chemical d ecompostion process that uses water to split the chemical bounds of substances. This proc ess can be used to create products such

7 Preliminary amounts. CIWMB Staff is currently reviewing revised DRS reports from counties.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 19 March 2002 as ethanol, specialty chemicals, fuels, a nd citric acid for the beverage industry. Gasification is a process that uses heat, pressure, and steam to convert materials directly into a gas composed primaril y of carbon monoxide and hydrogen. The products from this process can be used as a fuel to generate electricity or a gasoline additive. Anaerobic digestion is the bi ological decomposition of matter in the absence of oxygen and is used to produce co mpost, fertilizer, and methane. The emissions from all of these processes ar e controlled unlike the emissions from windrow composting.

The CIWMB is currently analyzing the re gulatory issues surrounding the use of conversion technologies including permitting, public health standards, and diversion credits. The current law allows for 10 per cent of the diversion credit to be met by these transformation technologies if certain requirements are met.

Regardless of the fact that composting does not appear to be as highly relied upon as other programs, the AQMD staff is cogni zant of the AB 939 requirements on local governments and is striving to draft a regulatory program that would not adversely affect AB 939, while achieving clean air obj ectives. For this reason, AQMD staff has focussed its efforts in identifying and quantifying the impacts to the specific industries affected by the proposal.

Environmental Justice In California, environmental justice is generally considered to be a call for the fair treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and enforcement of environmental laws and polices. In October 1997 the AQMD Governing Board adopted an environmental justice policy. The four guiding principles are:

• All basin residents have the right to liv e and work in an environment of clean air, free of airborne health threats;

• Government is obligated to protect public health;

• The public and private sectors have the right to be informed of scientific findings concerning hazardous and toxic em ission levels, and to participate in the development and implementation of ad equate environmental regulations in their communities; and

• The (AQMD) governing board is to uphol d the civic expectation that the public and private sectors of the basin will engage in practices that contribute to a healthy economy and trul y livable environment."

Environmental justice can be an issue in the siting of composting operations because of odors and dust impacts on neighborhoods from uncontr olled operations. The number of public nuisance complaints that the AQMD and LEAs have received regarding composting and rela ted activities shows that th ese operations are having an impact on the surrounding community. As su ch, regardless of air quality regulations, environmental justice issues will affect the ability for future expansion of composting operations unless these issues can be adeq uately addressed. Controls to reduce emissions are expected to go a long way in addressing these impacts and would be consistent with the AQMD’s environmental justice policy.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 1 - 20 March 2002 Regulatory Limits on Land-Application of Wastewater Sludge Currently, sewer sludge that has been treat ed to reduce pathogens and metals is trucked from this region to Kings and Kern Counties where it is spread on croplands. Sewer sludge enriches the soil and can supplem ent or replace commercial fertilizers. There are two classes of processed sludge . Class A sludge must undergo pathogen

reduction to be below detectable levels. Cl ass A can be used on edible vegetables and plants. Class B sludge must undergo pat hogen reduction to ensure the pathogens are reduced to levels that are protective of public health and the environment. Class B sludge is only used on non-edible crops, fo rests, and reclamation sites. Class B sludge can not be used for composting. Public concerns over Class B sludge used on croplands in Kings and Kern Counties has resulted in these jurisdictions placing limitations on Class B sludge. As a result, a dditional options to deal with the Class B sludge will need to be developed. This could include additiona l composting of sludge in the region if the sludge is treated to Cla ss A levels. Therefore, there is an increased need to resolve the environmental impacts issues associated with co-composting operation so that additional co-composting facilities can be sited in the AQMD’s jurisdiction. The majority of the co-composting facilities in the region have already indicated that they will enclose active co mposting and vent emissions to a control

device.



### NECESSITY FOR PR OPOSED RULE 1133 PR 1133 was developed to fulfill the AQMD’s commitment in the 1997 AQMP and 1999 Amendments to reduce ammonia and VOC emissions from composting and related operations. As such, this rulemaking is part of an integral plan to achieve healthful air in the region. Currently, the manner in which composting is conducted by windrows results in a source of VOC and ammonia emissions. Composting is also a source of numerous public nuisance comp laints regarding dus t and odors. The former would be addressed by this rulemaking. Various control techniques have been applied to bio-solid composting throughout the U.S. to reduce emissions and public nuisance complaints. This report examin es viable control options for the local composting industry.

### CHAPTER II

INDUSTRY PROFILE AND EMISSIONS INVENTORYTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 1 March 2002 

### INTRODUCTION This chapter discusses the following:
9 Industry Profile; and,
9 Emissions Inventory.



### INDUSTRY PROFILE The AQMD staff developed an industry profile for the composting and related operations industry based on information ob tained from the CIWMB permit database, AQMD permit system, AQMD-conducted surveys and site visits, and comments from the public. Through this process, the AQMD staff identified 277 facilities. For the purpose of rule development, the facilities that make up the composting and related operations industry are classifi ed into four categories: 1) co-composting facilities; 2) greenwaste composting facilities; 3) chipping and grinding facilities; and, 4) exempt

facilities.

Co-composting facilities include facilities th at compost putrescible materials such as, sewage sludge, manure, and food wastes in combination with greenwaste. Greenwaste composting facilities are compos ting facilities that use only greenwaste

as feedstock materials. Ch ipping and grinding facilities are facilities that chip and grind greenwaste for use in composting, wast e-to-energy, and alternate daily recovery (ADC) at landfills, or to produce mulches. Finally, exempt facilities are those facilities that are categorical ly exempt from Proposed Ru le 1133 based on the type of operation (i.e., transfer station/MRF, sewage treatment, fertilizer blending/bagging, manure shredding, landscaping/nursery/gard ening, agricultural farm composting, winery, community composting, porta ble chipping/grinding, botanical garden/arboretum, and public park/camping.)

Facility and throughput information was compiled based on information obtained from the CIWMB, the AQMD Permit System , the AQMD-conducted surveys and site visits, and independent c ontractor’s studies.

Table 2-1 - Composting Industry and Related Operations, provides a profile of the composting and related operations industry.

Table 2-1 Composting Industry and Related Operations

CATEGORY Number

of

Facilities Throughput (tons/year) Co-Composting 12 922,190 Greenwaste-composting 16 832,191 Chipping/Grinding 47 3,033,092 Exempt Facilities 202 36,865

Total 277 4,824,338Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 2 March 2002 The geographical distribution of the com posting and related operations industry is approximately 42, 19, 16, and 23 percent for Los Angeles, Orange, Riverside, and San Bernardino counties, respectively. Ta ble 2-2, Composting Facilities by County, provides number of facilities and thr oughputs in each of the counties by industry

sector.

Table 2 – 2 Composting Facilities by County

Number of Facilities by County (Throughputs – tons/year) Category Los Angeles Orange Riverside San Bernardino Co-Composting 3 (18,570) 2 (38,329) 1 (365,000) 6 (500,291)

Greenwastecomposting 6 (52,516) 3 (240,490) 4 (189,745) 3 (349,690)

Chipping/Grinding 20 9 13 5 Exempt Facilities 87 39 26 50

Total 116 53 44 64



### EMISSIONS INVENTORY The 2001 baseline emissions inventory for the composting and related operations industry includes emissions from 12 co -composting and 16 greenwaste composting facilities operating in the AQMD’s jurisdiction. Emissions for co-composting and greenwaste composting were estimated by multiplying the facilities’ annual throughput with facility-wide average emission factors. For all but two facilities that compost in an aerated static pile (ASP) and an in-vessel system, the emissions are considered to be baseline emissions repres enting the existing se tting and do not take into consideration future plans. In addi tion, the inventory in cludes emissions from the exempt facilities. This inventory theref ore, represents the existing settings. The emissions inventory does not include PM10 emissions from fugitive dust at any of the facilities including chipping and grinding operations. From work on similar facilities (Rules 1158, 403, 1186), public nuisance comp laints, and site visits, the AQMD staff

believes that there are PM10 emissions from these operations. As such, the total air quality impact of this industry is underestimated.

Emission Factor Development The emission factors used for the developm ent of the inventory are based on field measurements that were conducted by the AQMD’s Technical Services Division. Specifically, field measurements were c onducted at four co-composting facilities including, three outdoor windrow co-com posting facilities and one in-vessel composting facility. The AQMD staff al so conducted tests at one greenwaste composting facility. Complete source test reports are available from the AQMD.

In general, the field measurements conduc ted included several sa mples in order to develop an emissions profile that would be reflective of different phases of the composting process (i.e., active composti ng and curing). The following sectionTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 3 March 2002 provides more information on the developmen t of the emission factors and emissions profiles for co-composting and greenwaste composting only.

Emission Factors for Co-Composting In 1995, as part of the PM10 Technical Enhancement Program (PTEP), the AQMD

staff conducted an emission evaluation of four co-composting facilities, using the EPA approved Emission Isolation Flux Cham ber method. The following summarizes

the results of the source tests. Full source test reports are available from the AQMD.

Based on the PTEP data for three windrow co-composting facilities, the AQMD staff developed the emission factors used to estimate ammonia and VOC emissions from co-composting operations. Only data from th e windrow type of operations were used since the windrow composting me thod represents the current state of the industry, and this method of composting is considered to be the source of baseline emissions. The estimated emission factors for ammonia and VOC are 2.93 and 1.78 lb/ton mix, respectively. The estimated emission fact ors were calculated as the arithmetic average of data presented in Table 2-3 – Windrow Emissions Factors.

Table 2-3
Windrow Emissions Factors

Facilities NH3 E.F. (lb/ton mix) (VOC) E.F. (lb/ton mix)
RECYC Inc. @ Corona (1995) 2.7 0.53

EKO System @ Corona (1996) 3.28 1.7

San Joaquin Composting, Inc. @ Lost Hills (1996) 2.81 3.12

Average 2.93 1.78

The emission factors presented in Table 2-3 are the weighted-average emissions factors for emission rates from different compos t piles at different days in the cycle. The source tests used for this analysis contain data from the second day through the sixtieth day of composting cycle.

Based on the available source test da ta, EPA’s pathogen reduction 15-day requirement, and information from othe r studies, for emissions purposes, staff assumed that the active phase of the composting cycle takes approximately 22 days. The active composting phase of the process is the time period where organic material decomposes at its fastest rate and emi ssions are generated at a high rate.

The 22-day assumption is anecdotally supported by information found in EPA 503 regulations and other studies found in the literature. In particular, an odor-emission study on manure composting conducted by Universi ty of Minnesota demonstrates thatTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 4 March 2002 odor emissions generated from 3-day piles are at least six times greater than odor emissions of 28-day piles. By way of example, Figures 2-1 and 2-2 provide a graphical representation of the compos ting process, based on the source test conducted. These figures representing me thane and ammonia emissions over time, which are consistent with AQMD staff assumptions on the emissions split time period for the active and initial curing pha ses of the composting process.

Figure 2-1 - Methane Emissions vs. Time

Figure 2-2 - Ammonia Emissions vs. Time

Furthermore, PTEP data was also used to determine the emissions distribution for the co-composting process. The weighted-avera ge emission factors of composting piles up to 22-days old were used to calculate the emission fact ors for the active phase of composting process. The weighted-average emissions factors of composting piles up to 60-days old were used to calculate the emission factors for the curing stage of the

process.

Based on the 22-day assumption, staff analys is indicated that, for ammonia, 50% of the emissions are released during the active phase and 50% of the emissions are released during the cu ring phase of the process. Fo r VOC, staff analysis indicated 0 0.2 0.4 0.6 0.8

0 10 20 30 40 50 60

dayslbs/hr - ft2

0 0.05

0.1 0.15

0.2 0.25

0.3

0 10 20 30 40 50 60

dayslbs/hr - ft2Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 5 March 2002 that 80% of the emissions are released dur ing active phase and 20% of the emissions are released during the curing phase of the process.

Based on the results of emissions profile analysis, the estimated ammonia emission

factor for both active and curi ng phases of the process is eq ually estimated to be 1.47 lb/ton mix. For VOC, the estimated emi ssion factors are 1.42 lb/ton mix and 0.36 lb/ton mix, for the active and curing phases, respectively.

Emission Factors for Greenwaste Composting The AQMD staff conducted two source tes ting for greenwaste in September and

November-December of 2001. Based on th e weather conditions, the September and November-December tests are referred to as early fall and early winter tests, respectively. The early fall test was conducted using the EPA approved Emission Isolation Flux Chamber method. The early winter test was conducted using a remote sensing measurement technology called Boreal Laser Gas Finder. Basically, this technique measures the con centration and the volumetric airflow rate through large cross sections of the pile. The results of th e cross section analysis are used to provide an estimate of emissions from the entire pile . For the purpose of this analysis, both early fall and early winter test results were used to develop the weighted-average emission factors for greenwaste composting. The early fall source test report is available upon request, and the early winter source test report will be available shortly.

The following summarizes the results of AQMD staff’s greenwaste composting source tests and the development of related emission’s factors.

Early Fall Source Testing The early fall test was conducted on four piles that were approximately 2-day, 14- day, 45-day, and 70-day-old. Different age pi les were tested to ensure representation at various stages of the composting process.

To obtain the composite samples, testing was also conducted at various positions (up to ten positions) of each pile. The results of the composite sample’s emission rates are presented in Table 2-4 – Composite Emission Rates (Early Fall Test).

Table 2-4 Composite Emission Rates (Early Fall Test)

2-day Pile 14-day Pile 45-day & 70-day Pile

NH 3 Emission Rate (lb/hr • 1000 ft 2 ) 0.091 0.071 0.004*

VOC Emission Rate (lb/hr • 1000 ft 2 ) 0.368 0.226 0.079*
(*) Average of two piles

The above emission rates were then used to estimate the emission factors presented in Table 2-5 – Composite Emission Factors (Early Fall Test).Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 6 March 2002 Table 2-5 Composite Emission Factors (Early Fall Test)

2-day Pile 14-day Pile 45-day & 70-day Pile

NH 3 Emission Factor (lb/ton greenwaste) 0.69 0.61 0.02

VOC Emission Factor (lb/ton greenwaste) 2.8 1.95 0.3

Based on previously described 22-day active phase assumption, the estimated active and curing emissions factors for greenwaste composting are presented in Table 2-6 – Emission Factors for Greenwaste Composting (Early Fall Test).

Table 2-6 Emission Factors for Greenwaste Composting (Early Fall Test)

Active Composting Curing

NH 3 Emission Factor (lb/ton greenwaste) 1.3 0.02

VOC Emission Rate (lb/ton greenwastes) 4.75 0.3

Early Winter Source Testing The early winter test was conducted on thr ee piles that were approximately 2-days and 14-days old. Different aged piles were also tested to ensure representation at various stages of composting process; howev er, the winter test was not conducted on the curing pile. Instead, the aver age emission rates in lb/hr/1000 ft 2 of the 45 and 70- day piles from the early fall test were used to represent curing emissions for the early

winter test.

The early winter emission rates are presen ted in Table 2-7 – Emission Rates (Early Winter Test).

Table 2-7 Emission Rates (Early Winter Test)

2-day Pile 14-day Pile 45-day & 70-day Pile

NH 3 Emission Rate (lb/hr • 1000 ft 2 ) 0.018 0.048* 0.004

VOC Emission Rate (lb/hr • 1000 ft 2 ) 0.28 0.21* 0.079
(*) Average of two piles

The above emission rates were then used to estimate the emission factors presented in Table 2-8 – Emission Factors (Early Winter Test).Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 7 March 2002 Table 2-8 Emission Factors (Early Winter Test)

2-day Pile 14-day Pile 45-day & 70-day Pile

NH 3 Emission Factor (lb/ton greenwaste) 0.06 0.24 0.03

VOC Emission Factor (lb/ton greenwaste) 0.91 1.06 0.5

Based on previously described 22-day active phase assumption, the estimated active and curing emissions factors for greenwaste composting are presented in Table 2-9 – Emission Factors for Greenwaste Composting (Early Winter Test).

Table 2-9 Emission Factors for Greenwaste-Composting (Early Winter Test)

Active Composting Curing

NH 3 Emission Factor (lb/ton greenwaste) 0.3 0.02

VOC Emission Rate (lb/ton greenwaste) 1.96 0.5

In summary, greenwaste composting weighted -average emission factors presented in Table 2-10 are used to develop an emissi on inventory profile of the composting and related operations industry.

Table 2-10 Weighted-Average Emission Fact ors for Greenwaste Composting

Active Composting Curing

NH 3 Emission Factor (lb/ton greenwaste) 0.83 0.02

VOC Emission Rate (lb/ton greenwastes) 3.44 0.4

Based on this analysis, it was determined that for greenwaste composting, the majority of ammonia and VOC emissions are generated during active composting. These emission factors are believed to represent emissions for the current state of the industry. In general, instead of using windrow composting, with frequent turning by scarabs or wildcats, greenwa ste facilities process mounded stockpiles of greenwaste without frequent turning.

Additional Greenwastes Testing In addition to the early fall and early wi nter source testing conducted by the AQMD, the CIWMB and the City of Los Angeles also conducted three source tests: one at a chipping/grinding facility and two tests as greenwaste composting facilities, one ofTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 2 - 8 March 2002 which is using the windrow composting technique. The testing was conducted with the Emission Isolation Flux Chamber approach . The staff, at both CIWMB and City of Los Angeles, have worked cooperatively with the AQMD staff to ensure consistent emissions analysis. Although the final result s have not been completely reviewed by AQMD staff in time to be included in this report, AQMD staff will incorporate those test results to the greenwaste composting em issions analysis and report the revised analysis to stakeholders as soon as possible.

Baseline Emissions Table 2-11 – Baseline Emissions Inventory provides an emission inventory profile of the composting and related operations industry. As shown in Table 2-11, the composting and related operations industry, as a whole, generates approximately 6.8 tons per day of VOC emissions, which would place this industry as the second largest stationary source category, with the refi nery industry being the highest source
category.

Table 2-11 Emissions Inventory

Emissions (tons/year) Total Emissions (tons/year)

Emissions

Factors NH 3 VOC

Process Throughput Tons/year NH 3 lbs/ton VOC

lbs/ton Active Curing Active Curing NH 3 VOC

Co-Composting 922,190 2.93 1.78 677.8 677.8 654.8 166.0 1355.6 820.8

GreenwasteComposting 832,191 0.85 3.84 345.4 8.3 1431.4 166.4 353.7 1597.8 Chipping/ Grinding 3,033,092 N/A N/A N/A N/A N/A N/A N/A N/A

Exempt

Facilities 36,865 0.85 3.84 15.3 0.4 63.4 7.4 15.7 70.8

Total 1038.5 686.5 2149.6 339.8 1725 2489.4

Totals in tons per day based on 365 days per year 2.8 1.9 5.9 0.9 4.7 6.8

Of this inventory, there are 7 co-composting and 12 greenwaste composting facilities that generate an annual VOC emissions exceeding the 10 tons per year threshold for major

sources as defined in District Rule 3001. Depending on the throughput, the largest greenwaste facility is estimated to emit up to 600 tons per year of VOC, which would be considered among the top 5 VOC emitters in the SCAB.CHAPTER III

CONTROL TECHNOLOGY ASSESSMENTTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 1 March 2002 INTRODUCTION

This chapter discusses the following:

9 Composting Methods;

9 Emission Control System (Biofilter);

9 Demonstrated Control Efficiencies; and

9 Chipping and Grinding Methods.



### COMPOSTING METHODS

Emissions from composting can be reduced by maintaining optimal aerobic conditions, or utilizing stat e-of-the art emissions cont rol technologies, such as aeration static pile (ASP), in-vessel, and biofilters.

Optimized Practices Maintaining optimal aerobic composting c onditions can reduce some emissions and odors from composting operations. The mi croorganisms responsible for composting function best within a given range of para meters such as carbon to nitrogen ratio, moisture content, oxygen concentration, pH, and temperature of the compost piles. Although optimal conditions can vary based on the type of feedstock, preferred ranges are typically in the following:

Table 3-1 Optimal Composting Conditions

Characteristic Preferred Range Carbon:Nitrogen ratio 25:1 to 40:1

Moisture content 50% to 60% Oxygen concentration 5% to 15%

PH 6.5 to 8.0 Temperature 130 ° F to 150 ° F

Additionally, good practices fo r compost mixing, curing a nd storage can also reduce odors, dust and emissions; however, the amount of reduction cannot be easily quantified.

Aerated Static Pile (ASP) ASP was developed to eliminate substa ntial land space requirement and other problems associated with windrow composti ng. ASP is an established technology where forced aeration is applied to pr ovide direct, precise control of oxygen, temperature, and moisture conditions to th e pile. Currently, there are approximately 118 operational composting facilities in the U. S. utilizing the ASP technology, two of them are located in the AQMD jurisdiction. Some of the ASP facilities operate

within enclosures for further control. These facilities ha ndle a daily throughput ranging from about 0.1 dry ton to 300 dry to ns. In addition, se veral groups in the AQMD jurisdiction also consider ASP for their facilities.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 2 March 2002 With the ASP, feedstock is piled over a base of porous materials such as wood chips, which contains perforated aeration pipes. In order to avoid short circuiting, the porous base should be smaller than the base of the pile. The perforated pipes are connected to a blower that either pulls (negative pressure or suction) or pushes (positive pressure) air through the pile. Th e blower should be operated intermittently to maintain the 5% to 15% oxygen range and the uniform temperature. To provide insulation and prevent escape of odors during composting, the pile is usually covered with a thick layer (12 to 18 inches) of finished compost or bulking agent.

With positive pressure aeration, contaminated air is pushed through the pile to the outer surface; therefore, is difficult to be collected for odor treatment. However, positive pressure aeration is more effective at cooling the pile because it provides

better airflow.

With a suction system, air is pulled thr ough the pile from the outer surface.

Contaminated air is collected in the aerat ion pipes and can be directed to an odor treatment system. To avoid clogging, conde nsed moist air drawn from the pile must be removed before reaching the blower . Negative aeration might create uneven drying of the pile due to its airflow patterns.

A study conducted by City of Columbus, Oh io demonstrates that the weightedaverage odor emissions from an outdoor nega tive aeration pile is approximately 67% lower than those from an outdoor positive aeration pile. However, to provide flexibility in operations, some composti ng facilities aerate in both positive and negative modes. Negative aeration is us ually used during the beginning of the composting process to greatly reduce odors. In enclosed active composting area, negative pressure aeration also reduces moisture released into the building, and thus, reduces fogging. Positive aeration is us ed mostly near the end of the composting cycle for more efficient drying of the compost.

In summary, compared to traditional wi ndrow composting, ASP provides a more precise control of oxygen and temperature conditions; therefore, it can reduce odors and emissions by promoting optimal aerobic conditions. However, currently there is no field measure available to quantify any additional emission bene fit of ASP (i.e., lower pile emissions). An ASP confined in a building enclosure would capture 100%

of its emissions to an emission control device that will be discussed later in this chapter. ASP also provides better flexibility to handle changes in compost feedstock quantity and quality. In addition, it requires less time to complete the active composting phase. With proper operation, active composting from an ASP might be completed within 20 to 28 days; therefore, more finished compost can be produced in a smaller footprint. Study conducted by S ynagro Composting Facil ity indicates that, in comparison to windrows, ASP reduces the landspace requirement on the order of
60%. There are two common forms of ASP: individual piles and extended piles.

Individual Piles Individual piles are long triangular piles that are usually constructed with a width equal to about twice the height. The aera tion pipes run lengthwis e beneath the ridge of each pile and serve the entire pile. E ach pile contains feedstock of roughly theTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 3 March 2002 same recipe and age. Individual piles are practical when feedstock is available for composting at intervals.

Extended piles

To make more effective use of available space, another pile c onfiguration called the extended aerated pile has been developed. Studies indicate that the area required for an extended pile is about 50% less than that for an individual pile. Extended piles

consist of individual cells that are stacked against each other. Cells of new feedstock are constructed in one pile, and cells of n earing mature compost are placed in other. The space between the two piles allows the re moval of an old cell from one pile and adding of a new cell to the other. Cells are usually constructed with a width equals to the pile’s height. Each cell contains one da y’s volume of feedstock. Generally, each cell is aerated by its own blower and cont rolled by its own timer or temperature sensor. However, cells contain feedstock of roughly the same age can share a single blower by connecting the pipes with a header . Connecting several cells to one blower minimizes the number of blowers required, but also complicates the blower control
system.

Appendix A contains the list of ASP com posting achieved in practice, which based mainly on the 1998 Biocycle survey.

In-Vessel Composting In-vessel is developed to eliminate subs tantial land space requirement for windrow composting, as well as to overcome the deficiencies in windrow. In-vessel composting is an established technology wh ere feedstock is confined within a building, a container, or a vessel. In-v essel methods rely on forced aeration and mechanical turning to speed up the composting. Currently, there are approximately 50 operational composting faciliti es in the U.S. utilizing in -vessel technology; one of

them is located in the District. These facilities handle a daily throughput ranging from less than 1 dry ton to over 100 dry tons . There are different types of in-vessel, such as silos, rotating drums, transporta ble containers, bin composting, and agitated bed, which are designed/manufacture d by about 15 companies; however, bin composting, silo, and agitated bed are consid ered the most popular in-vessel systems used in composting operations.

Bin Composting Bin composting is the most basic and simple in-vessel technique, where feedstock is

contained in a bin with or without roof. Essentially, bi n composting operates like the ASP; it includes forced aeration in the floor of the bin and requires little or no turning of the feedstock. Besides having the advant ages of an ASP, bin composting can also eliminate weather problems, provide better temperature control, and reduce odors released to the atmosphere.

Silo In composting operations, vertical silo is the most popular system where air is provided from the base through the feedstock. Contaminated air can be collected from the top of the silo and vented to an odor or emission control equipment. Feedstock is loaded at the top of the silo, and finished compost is removed from theTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 4 March 2002 base. Typical active composti ng time is 14 days, so one-fou rteenth of the silo volume must be removed and replaced daily. Compost is often cured in a second aerated silo, which minimizes land space. However, th is composting method may be difficult to operate due to compaction, temperature a nd air-flow problems, which are associated with this process.

Agitated Bed Agitated bed is a system where contro lled aeration and periodic turning are combined. With this system, feedstock is placed at the front end of a long, narrow channel (bed). As the turning machine move s forward, it mixes the organic materials and discharges it behind itself. With each turning, the machine moves the feedstock a

set distance toward the end of the bed. The length of a bed and the turning frequency determine the composting period. If the m achine moves the organic materials 10 feet at each turning and the bed is 100 feet long, the composting period is ten days. Suggested composting periods for agitated bed system ranges from two to three

weeks.

Between turnings, aeration is provided through a set of aeration pipes, which locate in

the floor of the bed. Since the organic materials along the bed are at different stages of composting, the bed is divided into diffe rent aeration zones. Each blower supplies air to one zone and is controlled by a temperature sensor or a time clock.

Agitated bed composting, in combination wi th the use of build ing enclosures, are capable of capturing 100% of the process of emission and odors. This method also provides better process controls. This type of process can produ ce consistent quality compost, reduce the composting time cycle, and reduce operational costs, which can help offset its high capital costs.

Attachment B contains the list of operationa l in-vessel composting facilities in the U.S. This list is compiled based on the 1998 Biocycle survey and the input from one major in-vessel designer firm.



### EMISSION CONTROL SYSTEMS (BIOFILTER) There are several types of em issions control systems that are capable of controlling ammonia and VOC emissions; however, this di scussion is limited to biofilters, since it is the most economically f easible and most common type of control equipment in composting operations.

Biofiltration is a well-established emission and odor control technology in Europe

where over two hundred biofilters were in use as of 1984 (Eitner, 1984). In the United States, biofilters have been mainly utilized for th e treatment of odors as well as VOC in wastewater treatment plans. Biofilters have recently gained better acceptance by composting and other ope rations such as body repair shops, MRF/transfer stations, pharmaceuticals, b eer breweries, etc. To date, AQMD has issued 17 Permits to Operate biofilters and is processing 15 additional applications.

Basically, biofilters use microorganisms that live in the biofilm; a thin layer of moisture surrounds the particles that make up the media, to adsorb and biologicallyTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 5 March 2002 degrade contaminated air into non-harmful substances. In particular, VOC is oxidized to carbon dioxide and water, and am monia is degraded into nitrate without creating aggravating pollution issues.

In biofilter design, the selec tion of a media is a critical factor. For a biofilter to operate efficiently, a media must have a good adsorption capacity and good resistance to compaction, be able to provide a suitable environment for microorganism growth and reproduction, and have high porosity for minimal b ack pressure. Typically, biofilter media is made up of wood waste an d small portion of compost, which would provide an air-filled poros ity between 40% and 60% and a pH between 6 and 8.

In order for a biofilter to perform at its best, several parameters should also be

maintained:

Moisture Content Maintaining proper and consistent moisture content in the biofilter media is essential to support microorganisms and to remove ammonia (by disso lution). Ideally, moisture levels in the media should be kept between 40% and 60% at all times; however, a range of 30% to 65% are proven acceptable. Since the media has a tendency to dry out due to the airflow, biofilters usua lly have a pretreatment stage that moisturizes the contaminated air before it reaches the media. However, moisture content should be carefully monitored to avoid biofilter clogging.

Temperature The optimum operating temperature for a biofilter is between 80 o F to 100 o F. In order to avoid damaging to microorgani sms, influent gas in excess of 105 o F might require cooling prior to entering the biofilter.

Backpressure There is no absolute number for optimal backpressure (increase in pressure above normal operating gauge pressure). Backpr essure varies depending upon media type, bed depth, unit airflow, media age, and may range from less than 1 inch water column to over 10 inches water column. Backpressu re will rise as biofilter media ages (if there are no leaks, shortcircuits, ch annels, or fissures in the media.)

Maintenance Sophisticated monitoring protocols are he lpful; however, they should not take the place of regular inspection for dry spots, leak s, cracks, fissures of the media, and the presence of odors.

In composting, biofilters are usually used in conjunction with aerated static piles or in-vessel systems. Biofilters are know n for their competi tive capital and low operating costs compared to conventional technologies, such as carbon filtration, chemical scrubbers, or oxidation; however , it may take up a large land space.

Biofilters are also known as the best systems to remove multiple odor-causing compounds at low concentration. If prope rly designed and operated, biofilter would achieve an overall control efficiency of 75% for ammonia and 90% for VOC (Appendix C).Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 6 March 2002 There are several types of biofilters, such as single-layer open bed, multi-layer stack bed, etc. They all have two basic components: a media, and a piping system that

distributes contaminated air through the biofilter.

Single-Layer Open Bed Biofilter Single-layer open bed biofilter is the most typical biofilter used in the composting operations. With this type of biofilter, contaminated air is introduced though a distribution system, which typically contains perforated plastic pipes, embedded in a layer of gravel. Above this layer, there is a media of approximately 4-ft thick. The typical airflow rate is in the range of 3 cfm and 5cfm per ft 2 of biofilter surface. An open bed biofilter also has a sprinkler system to keep the media moist, and a drainage system to drain excess water in the event of over watering or rain.

Single-layer open bed biofilter takes up a lo t of space and often causes compaction of the media, which results in an increased h ead loss. Depending on the usage, biofilter media might need replacement every 2 to 3 years.

Multi-Layers Stack Biofilter Multi-layers stack biofilter is an enclosed system that can prevent compaction of the media and also minimize the space requirement. Since multiple units can be run in parallel, the biofilter will not be shut down during media replacement. This type biofilter can also minimize the risk of channeling of the contaminated air stream.



### DEMONSTRATED EMISSION S CONTROL EFFICIENCY Biofiltration is an emission control system that has been widely used by the composting industry in the United States. The emissions control effectiveness for biofiltration is published in num erous studies. In addition, independent emissions and

odors evaluations have also been conducted by facilities employing biofiltration. Appendix C – Biofilters in Operation at Co mposting Facilities in the United States, provide information on inlet and outlet emission rates for the biofilters systems cited. Based on these data, AQMD estimated the destru ction efficiency of biofiltration to be 75 and 90 percent for ammonia and VOC, respectively.

Table 3-2 – Composting Methods, Capture and Control Efficiencies, provides a summary of methods used in the composti ng and related operations industry and their respective efficiencies in term s of controlling air emissions.

Table 3-2 – Composting Methods, Capture and Control Efficiencies

Control Equipment Efficiency Over-all Control Efficiency Composting

Method Emissions Capture Efficiency Ammonia VOC Ammonia VOC

Windrow 0% n/a n/a 0 % 0%

ASP* 25 to 33 % 75.0% 90.0% 18.8 – 24.7% 22.5 – 45.0

In-Vessel 100% 75.0% 90.0% 75.0% 90.0%

*Additional emission reduction potential from ASP cannot be quantified at this time.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 3 - 7 March 2002 

### CHIPPING AND GRINDING METHODS

Chipping/grinding facilities chip and grind wood/green waste, which was mostly collected from landscaping or from cities’ cu rbside collection programs, and stockpile the processed materials until they are transferred to other facilities for different usage such as alternative daily cover (ADC), biomass fu el, mulch, or composting feedstock. Stockpiling green waste, especially those from the curbside collection where other putrescible wastes are not normally separated, for a period of time under certain moisture and temperature, will allow the organic materials to decompose anaerobically and generate odors as well as emissions. High temperature and VOC monitoring data obtained during the AQMD site visits of the chipping/grinding faciliti es demonstrate that those piles were in the process of decomposing.

To prevent wood/green waste from deco mposing, staff recommends that certain processed and unprocessed materials to be remo ved from the site within certain time limit

that will be determined later in the rule de velopment process. The explicit holding times might vary by the source of unprocessed mate rials and by the end usage of chipped and ground materials.

Beside VOCs, chipping and grinding operati ons can also be sources of PM10. PM10 results from the chipping, gri nding and screening of wood/green materials. It can also result when high winds entrain materials from processed material piles. To address these issues, AQMD staff is recommending consider ation of the following PM10 dust controls,

which are based on the Best Available Cont rol Measures (BACM) listed in Rule 403, Fugitive Dust:

• Cover the chipped/ground material with ta rps, plastic or similar covering; or

• Install a three-sided barriers equal the height of the piles; or

• Water the piles; or

• Cease all outdoor chipping/grinding activ ities during high winds (greater than 25 mph) or when visible plume extends more than 100 feet from the equipment.

### CHAPTER IV

EMISSION REDUCTIONS AND COST EFFECTIVENESSTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 1 March 2002 INTRODUCTION

This chapter discusses the following:

9 Emission Reductions; and,

9 Cost-Effectiveness.

EMISSIONS REDUCTIONS AQMD staff has evaluated three control scenarios for co-composting and three for green-waste composting. Additionally, AQM D has analyzed the impact of hauling the green and sewer sludge wastes to landfills.

Co-Composting AQMD staff analyzed the following three control scenarios for the co-composting sector of the composting industry:

Scenario 1

• Enclosure of the active and curing phase of the process and the utilization of Aerated Static Pile (ASP) system; and,

• Venting of emissions to a control device (biofilter).

Scenario 2

• Enclosure of the active phase of the process and the utilization of ASP

• Utilization of a ASP system under negative pressure for the curing phase of the process (no enclosure); and,

• Venting of emissions to a control device (biofilter).

Scenario 3

• Utilization of a ASP system under negative pressure for the active and curing phase of the process (no enclosure); and,

• Venting of emissions to a control device (biofilter).

The following assumptions were made to an alyze the previously described control scenarios for co-composting:

1. The seven largest windrow facilities with a combined throughput of 894,175 tons/yr would be subject to control;

2. The ammonia emissions factor for the act ive phase of the process is the same as the emission factor for the curing ph ase of the process: 1.47 lbs/ton mix;

3. The VOC emission factor for the active phase of composting is 1.42 lbs/ ton mix;

4. The VOC emission factor for the curing phase of composting is 0.36 lbs/ton mix;

5. The windrow method of composting is a ssumed to be the baseline source of emissions, having no emissions capture efficiency (0%);

6. No emission reduction benefit for resting pile emissions is assumed for an ASP;

7. The capture efficiency of negative-ASP during the active phase of the process is assumed to be 33%;Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 2 March 2002 8. The capture efficiency of negative-ASP during the curing phase of the process is assumed to be 25%;

9. Enclosure is assumed to mean total enclosure and therefore, having a capture efficiency of 100%;

10. The destruction efficiency of biofiltration for ammonia emissions is assumed to be 75%; and,

11. The destruction efficiency of biofiltration for VOC emissions is assumed to be 90% percent.

The following equations where used to calculate emission reductions:

Emissions (tons/yr)

[Total throughput (tons/yr) X Emissions Factor (lbs/ton)]/2000 (lbs/tons),

where,

• Total throughput is the total combined throughput of 7 composting facilities using the windrow method of composting; and,

• The emissions factor is a variable de pendant on the pollutant and process phase.

Emission Reductions (tons/yr)

[Emissions (tons/yr) X Control Efficiency %]

where,

• The emissions are a variable dependant on the pollutant and process phase; and,

• Control Efficiency is the result of the capture efficiency multiplied by the destruction efficiency of the control devi ce. Control Efficiency is a variable dependant on the pollutant and process phase.

Table 4-1 – Co-Composting Scenarios, provides a summary of the emission reductions for each of the control scenarios analyzed for co-composting.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 3 March 2002 Table 4-1 – Co-Composting Scenarios

Ammonia

Scenario Composting

Method Uncontrolled

Emissions (tons/yr) Over-all Control Efficiency % Emission Reductions (tons/yr) Total ER (tons/yr) Active Curing Active Curing Active Curing Active Curing

1 Enclosed

ASP Enclosed

ASP 654.98 654.98 75 75 491.24 491.24 982.47

2 Enclosed

ASP Negative

Pressure

ASP 654.98 654.98 75 19 491.24 122.81 614.05 3 Negative

Pressure

ASP Negative

Pressure

ASP 654.98 654.98 25 19 162.11 123.23 285.34

VOC

1 Enclosed

ASP Enclosed

ASP 636.65 159.16 90 90 572.99 143.24 716.23

2 Enclosed

ASP Negative

Pressure

ASP 636.65 159.16 90 23 572.99 35.81 608.80 3 Negative

Pressure

ASP Negative

Pressure

ASP 636.65 159.16 30 23 188.70 36.21 224.92

Greenwaste-Composting AQMD staff analyzed the following three control scenarios for the greenwastecomposting sector of the composting industry:

Scenario 1

• Enclosure of the active and curing phases of the process and the utilization of an Aerated Static Pile (ASP) system;

• Venting of emissions to a control device (biofilter).

Scenario 2

• Enclosure of the active phase of the proce ss and the utilization of an ASP system;

• No control for the curing phase of the process; and,

• Venting of the active composting emissi ons to a control de vice (biofilter).

Scenario 3

• Utilization of an ASP system under negati ve pressure for the active and curing phases of the process (no enclosure); and,

• Venting of emissions to a control device (biofilter).

The following assumptions were made to an alyze the previously described control scenarios for greenwaste-composting:

1. The ten largest facilities are open static piles windrow type operations and combined, these facilities have a total throughput of 819,461 tons/yr;

2. The emission factor for ammonia for the active phase of the composting process is 0.83 lbs/ton greenwaste;Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 4 March 2002 3. The emission factor for ammonia for the curing phase of the composting process is 0.02 lbs/ton greenwaste;

4. The VOC emission factor for the active phase of composting is 3.44 lbs/ ton

greenwaste;
5. The VOC emission factor for the curing phase of composting is 0.4 lbs/ton

greenwaste;

6. The static windrow piles method of com posting is assumed to be the baseline source of emissions, having no emi ssions capture efficiency (0%);

7. The capture efficiency of negative-A SP during the active and curing phases of the process phase of the pro cess is assumed to be 25%;

8. Enclosure is assumed to mean total enclosure and therefore, having a capture efficiency of 100%;

9. The ammonia destruction efficiency for biofiltration is assumed to be 75%;

10. The VOC destruction efficiency for biofiltration is assumed to be 90% percent: and,

11. No emission reduction benefit for resting pile emissions is assumed for an

ASP.

Emission reductions were calculated using the previously listed equations. Table 4-2 – Greenwaste-Composting Scenarios, provi des a summary of the emission reduction for the three scenarios evaluated for greenwaste-composting.

Table 4-2

Greenwaste Scenarios

Ammonia

Scenario Composting

Method Uncontrolled

Emissions (tons/yr) Over-all Control Efficiency % Emission Reductions (tons/yr) Total ER (tons/yr) Active Curing Active Curing Active Curing Active Curing

1 Enclosed

ASP Enclosed

ASP 340.50 8.23 75 75 255.4 6.2 261.60

2 Enclosed

ASP No

Control 340.50 8.23 75 0 255.38 0 255.38

3 Negative

Pressure

ASP Negative

Pressure

ASP 340.50 8.23 19 19 63.97 1.54 65.51

VOC

1 Enclosed

ASP Enclosed

ASP 1,411.22 162.55 90 90 1,270.16 147.50 1,417.66

2 Enclosed

ASP No

Control 1,411.22 162.55 90 0 1,270.28 0 1,270.28

3 Negative

Pressure

ASP Negative

Pressure

ASP 1,411.22 162.55 23 23 317.13 37.29 354.42

Summary As illustrated in both Tables 4-1 and 4-2, full enclosure of active and curing piles would generate the greatest emission reductions with open ASP pr oviding the least reductions. However, the emission reduction potential coul d be higher than the data presented in

Tables 4-1 and 4-2 for all thr ee scenarios, if additional emi ssion reduction benefits fromTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 5 March 2002 ASP operations can be quantified. It ma y also modify the incremental difference

between scenarios 2 and 3.



### COST-EFFECTIVENESS

Affected Facilities The control scenarios analyzed affect co mposting and chipping a nd grinding facilities in the AQMD jurisdiction. The affected facilities mainly belong to SIC 4952 (Sewerage System) and 4953 (Refuse System). Of these affected facilities, only 17 composting facilities are required to install control equipment, and, therefore, would incur significant additional costs. Of th e 17 composting facilities, ten facilities are greenwaste-only and the remaining seve n are co-composting facilities. Three composting facilities (18%) are located in Los Angeles County, three facilities (18%) in Orange County, four facilities (23%) in Riverside County, and the remaining seven facilities (41%) are located in San Bernardino County.

Small Business Impacts The AQMD defines a "small business" in Ru le 102 as one which employs ten or fewer persons and which earns less than $500,000 in gross annual receipts. In addition to the AQMD's definition of a sma ll business, the federal Small Business Administration (SBA), the federal Clean Air Act Amendments (CAAA) of 1990, and the California Department of Health Services (DHS) also provide their own

definitions of a small business.

The SBA's definition of a small business us es the criterion of either gross annual receipts (ranging from $0.5 million to $17 million, depending on industry type) or number of employees (ranging from 100 to 1,500). The SBA definitions of small businesses vary by 4-digit SIC code. The industries affected by the proposed Rule 1133 mainly belong to SIC 4952 and 4953

⎯ sanitary and refuse systems (miscellaneous processes). For the facili ties affected by the proposed rule, gross annual receipts of $5 million is the criterion below which a business is considered small under the federal SBA definition. The CAAA classifies a facility as a "small business stationary source" if it: (1) employs 100 or fe wer employees, (2) does not emit more than ten tons per year of either VOC or NOx, and (3) is a small business as defined by SBA. The DHS definition of a sm all business uses an annual gross receipt criterion (ranging from $1 million to $9. 5 million, depending on industry type) for non-manufacturing industries and an empl oyment criterion of fewer than 250 employees for manufacturing industries.

Of the 17 affected composting facilities, te n have gross annual receipts and employee information reported in the 2000 Dun & Bradstreet database acquired by the AQMD. Based on the AQMD’s Rule 102 definition, onl y one of the ten facilities would be considered a small business. With the federal SBA’s definition, three facilities would

be considered small businesses. With th e CAAA’s, ten could be considered small businesses. Table 4-3 provi des the range of the gross annual sales and number of employees for these facilities.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 6 March 2002 

### Table 4-3 Number of Facilities by Sales and Employees

Gross Annual Sales (millions $) Number of

Facilities Number of Employees Number of

Facilities Less than $0.5 1 5 to 9 2

> $0.5 and < $1 1 10 to 19 0
>$1 and < $2.5 3 20 to 49 6
> $2.5 and < $5 2 50 and above 2

> $20 and < $50 3 100 to 500 3

Cost Assumptions Some of the control scenarios require active co-composting and greenwaste-only processes to be enclosed and to have for ced aeration, either th rough an in-vessel or aerated static pile (ASP) system. Emissions from the enclosure must be vented to a biofilter or other control device that achieves a control efficiency of 75 percent reduction for ammonia and 90 percent reduction for VOC.

Compliance costs of the control scenarios were estimated based on the cost of the building enclosures, ASP, and biofilters. The cost of building enclosures was estimated based on the enclosure area (squa re feet) required relative to the total annual throughput of an affect ed facility. It should be noted that total throughput includes feedstock (sewer sl udge/manure) and bulking agen t. In addition, for the building enclosure, two different structural designs were assumed: concrete and fabric

structures. For concrete and fabric st ructures, estimated costs of $50 and $30 per square feet were assumed, respectively. These estimates include building structure, air exchanges and fire protection systems, and were based on City of Redlands and the IEUA RP-1 conceptual design plan. For the enclosure of active and curing, 1.5 square feet per ton of annua l throughput and for enclosure of active piles only, 0.75 square feet per ton of annual throughput wa s used. These estimated were based on Inland Empire Utility Agency (IEUA) RP-1 conceptual design, IKEA (IEUA) site design, and city of Davenport design plans.

The cost for ASP in the city of Colum bus conceptual design and the city of Davenport’s plan was used. The annualized cost of ASP was estimated at $6.75 per ton of throughput. This estimate includes fl ooring, piping, and aeration equipment.

The Biofilter estimate was derived based on biofilter surface required for emissions

treatment. The biofilter cost was estimated at $12 per square feet of biofilter surface. This estimate was provided by Black and Veatch Company, and includes cost components such as biofilter fans, ducks, and biofilter media.

It is assumed that the economic life of build ing enclosures, ASP, and biofilters is 15 years each. Operating and maintenance cost for the total enclosure was assumed to be 10 percent of the total capital cost. For the biofilters, the cost of media change every three years is included in their ope rating cost. The tota l annual throughput of

the affected facilities is estimated at 1,713,636 tons, of which 894,175 tons are from co-composting and the remaining 819,461 are from greenwaste only facilities.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 7 March 2002 Compliance Costs Table 4-4 and 4-5 present a nnualized cost and cost ef fectiveness of the three scenarios for co-composting and greenwast e-only facilities. For co-composting facilities, cost-effectiveness ranges from $21,154 to $42,515 per ton of VOC reduction. The corresponding annualized cost s of scenarios one, two, and three are estimated at $27.1 and $22 million, $19.9 and $17.3 million, and $12.9 million, respectively.

The annualized cost of each scenario incl udes both annualized cost of capital and annual operating and maintenance costs (10 % of total annual cost). The total capital cost includes cost of building enclosure, ASP, and biofilter. The capital cost is annualized by multiplying total capital cost by a capital recovery factor (CRF) of 0.090. The CRF 0.090 is based on a 15-year period (the assumed equipment lifetime) and with a 4 percent real interest rate.

For the purpose of illustration, the total annualized cost of a typical facility with an annual throughput of 200,000 tons is estim ated at $4,497,300, as shown below:

Capital Cost

Total Building Cost: $7,500,000

Total ASP Cost: $14,250,000

Total Biofilter Cost: $1,920,000

Total Capital Cost: $23,670,000

Operating Cost

O & M Cost: 0.1 x($23,670,000) = $2,367,000

Total Annualized Cost = Total Capital Cost x CRF (0.090) + O & M Cost

= ($23,670,000 x 0.090) + $2,367,000 = $4,497,300

For each scenario, cost-effectiveness is ca lculated based on both overall emission

reductions and VOC emission reductions only for both conc rete and fabric structure designs. The cost-effectiveness analysis uses the Discounted Cash Flow (DCF) method to compute the present value of the proposed rule’s cost s over a 15-year period (the assumed equipment lifetime) with a 4 percent real interest rate, which gives the present value factor of 11.118. DCF cost effectiveness can then be calculated as:



## ( )

years ductions R Emission Costs M O Annual Costs Capital

ess Effectiven Cost

tons/yr 15 e 118

. 11 &

× × +

=Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 8 March 2002 Table 4-4 

### Co-Composting Annualized Cost and Cost-effectiveness by S cenario ($/ton)

Scenarios Description Annualized Cost (Millions $) C-E for VOC Only C-E for VOC &

Ammonia

Concrete Fabric Concrete Fabric Concrete Fabric

1 Enclose *
Active and

Curing

Piles

+ASP +

Biofilter $27.1 $22 $28,052 $22,779 $11,828 $9,604

2 Enclose*

Active Piles only
+ASP +

Biofilter $19.9 $17.3 $24,255 $21,154 $12,076 $10,531

3 Open ASP + Biofilter $12.9 $42,515 $18,740

* Includes Static and Tipping Piles.

As with the co-composting, three scenario s representing three di fferent levels of

control were selected to an alyze the effectiveness of th e proposed rule on greenwasteonly facilities.

Table 4-5 presents annualized cost and co st-effectiveness of the three scenarios for greenwaste-only facilities. Cost-effectiveness ranges from $8,929 to $24,726 per ton

of VOC reduced. Cost-effectiveness ra nges from $9,604 to $18,740 per ton of combined VOC and ammonia reduced. The corresponding annualized costs of scenarios one, two, and three are estim ated at $24.8 and $20.1 million, $17.6 and $15.3 million, and $11.8 million, respectively. There is no building enclosure requirement for the scenario three.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 9 March 2002 

### Table 4-5 Greenwaste-Only Annu alized Cost and

Cost-effectiveness by S cenario ($/ton)

Scenarios Description Annualized Cost (Millions $) C-E for VOC Only C-E for VOC &

Ammonia

Concrete Fabric Concrete Fabric Concrete Fabric

1 Enclose *
Active and

Curing

Piles

+ASP +

Biofilter $24.8 $20.1 $12,988 $10,547 $10,962 $8,901

2 Enclose*

Active Piles only
+ASP +

Biofilter no

Control on

Curing $17.6 $15.3 $10,291 $8,929 $8,568 $7,434

3 Open ASP + Biofilter $11.8 $24,726 $20,869

* Includes Static and Tipping Piles.

Due to lack of sufficient data at this time, PM10 emission reductions and additional emission reductions from ASP technology (i.e., lower pile emissions) have not been quantified for all scenarios. As a result, it is expected that emission reductions could be larger and control process would be more cost-effective than is currently established. PM10 emissions inventory as well as emission reductions will be further

evaluated.

Incremental Cost-effectiveness H&SC Section 40920.6, requires that increm ental cost effectiv eness be performed whenever more than one control option is available to meet emission reduction requirements for a proposed rule or amendment relating to ozone, carbon monoxide (CO), oxides of sulfur (SO

x ), oxides of nitrogen (NO

x ), and their precursors. Incremental cost effectiveness is defined as the difference in costs divided by the difference in emissions between one level of control and the next more stringent control. The incremental cost-effectiveness analysis related to the VOC portion of the proposed rule will be presented in the final staff report.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 10 March 2002 Unquantified Savings Some control scenarios require active compos ting process to be en closed and to have forced aeration either through an in-vessel or aera ted static pile (ASP) system. This process provides a more precise control of oxygen and temperature conditions, and can greatly reduce odors and emissions by promoting optimal aerobic conditions. Furthermore, this process requires fewer spaces for active composting and reduces time required to produce final composting pr oduct. For example, the Los Angeles County Sanitation District (LACSD) com posting study shows that with the ASP technology the actual surface area required fo r composting could be up to 60 percent less than the footprint required for active wi ndrow composting piles. Therefore, ASP facilities sited could reduce capital investments in land acquisition.

In addition, with proper operation, active co mposting from an enclosed ASP could be completed in far fewer days than the 45 to 60 days under traditional windrow composting. Therefore, the volume of finished compost product and revenue generated from selling them coul d possibly increase. To the extent it could occur, an enclosed ASP system could reduce even more emissions generated from this additional throughput. Since th e capital cost of enclosed ASP systems would remain relatively constant during the process, more throughputs would make this process

more cost-effective.

Hauling Scenarios Staff has developed two additional scenarios to further evaluate the potential cost impact, which could incur as a result of the proposed rule. Scenario one assumes that the proposed rule would cause complete shut down of all composti ng facilities in the district, and, as a result, one hundred percent of the bioso lid and greenwaste materials are hauled away and dumped out of the state. This estimate was based on hauling 1,713,636 tons per year of materials to landf ills out of state. This estimate includes both transportation cost and tipping fees co st. Based on both LA County Sanitation District and the AQMD’s survey, hauling co st is estimated at $18 per ton. This estimate includes fuel cost, driver’s sala ry, benefits, food and depreciation of the vehicle. The tipping fees for outside of the state is assumed to be $20 per ton. Based on these assumptions, the total annual cost of hauling scenario is estimated at $38 per ton. The annual cost of this scenario is estimated at $65.1 million.

Scenario two is similar to scenario one , but assumes that only 75 percent of the biosolids and greenwaste materials would be shipped out of the state and the remaining 25 percent would be hauled to th e local landfills. The annual cost includes both transportation cost a nd tipping fees cost. Base d on the Integrated Waste Management Board (IWMB) survey data (1995-2000), the average tipping fee at the local landfill is estimated at $35 per ton. The annual cost of this scenario is estimated at $67.5 million.

According to the recent information received by staff, the projected cost of hauling waste is estimated at $63 per ton, wh ich includes $33 per ton for transporting materials to out of state (Arizona) and $30 per ton for tipping fees charged by the landfills located outside of California. This could significantly increase the cost of the hauling scenario s described above.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 11 March 2002 In response to stakeholders questions, AQMD staff also analyzed the transportation emissions impact from increased hauling. The [potential emissions increase from hauling scenario is estimated at 13 ton of VOC, 57 tons of CO, 290.5 tons of Nox, and 7.50 tons of PM10 (Diesel) per year. These emissions are estimated based on the ARB’s EMFAC 2001 emission factors from the above pollutants. The remaining assumptions are as follows:

Total Throughput per year 1,713,636 Load per Truck 23 tons Round trip Miles 400 Number of truck Trip per year 74,506 Total number of Miles per day 81,650 Total Number of Miles per day (District) 40,825 (Based on GIS Analysis)

Affordability Analysis For the purpose of evaluating of the financial impacts, staff has estimated the annualized cost per ton of throughput of the most likely contro l scenario, Scenario 2, for selected number of affected facilities. Furthermore, due to lack of financial information from these facilities, revenues from tipping fees an d product sales were estim ated and used as a surrogate to a facility’s total revenue.

Table 4-6 and 4-7 present both annual co mpliance costs and revenues per ton of throughput for the selected co-composting and greenwaste-only facilities.



### Table 4-6 Potential Cost Impacts of the Pr oposed Rule (Scenario 2) on Selected Co-Composting Facilities

Facility Annual Throughput Status Annualized

Control

Costs Incremental

Costs

Per ton of Throughput Surrogate Revenue From Tipping Fees

and Product Sales per Year ($/ton)** A 365,000 Private $8,134,755 $22 $18,213,500 ($40 and $30 ) B 200,500 Private $4,468,343 $22 $10,004,501 ($40 and $30 )
C 250,000 Public/

Private $5,571,750 $22 $7,475,000 ($20 and $30)

**It was assumed that only 33% of co-composting materials would be converted to a final composting product.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 4 - 12 March 2002 

### Table 4-7 Potential Cost Impacts of the Pr oposed Rule (Scenario 2) on Selected Greenwaste-only Facilities

Facility Annual Throughput Status Annualized

Control

Cost Incremental

Costs

Per ton of Throughput Surrogate Revenue From Tipping Fees

and Product Sales per Year ($/ton)** A 312,000 Private $6,717,017 $22 $13,728,000 ($20 and $30 ) B 187,200 Private $4,030,210 $22 $7,675,200 ($25 and $20 ) C 130,000 Private $2,798,757 $22 $3,640,000 ($12 and $20 ) ** It was assumed that only 80% of greenwast e-only materials would be converted to a final composting product.

The annualized compliance costs of Scenario 2 is about 50 percent of the annual revenue received by both co-composting and greenwaste-only facilities.

Financial Incentives The facilities affected by Proposed Rule 1133 may seek funding to help defray the cost of the proposed rule. For exampl e, the California IWMB offers funding opportunities authorized by legislation to assist public and private entities in the safe and effective management of the waste st ream. The Recycling Market Development Zone Revolving Loan Program (RMDZ) provide s direct loans to businesses that use post-consumer or secondary waste materi als to manufacture new products or that undertake projects to reduce the waste resul ting from the manufacture of a product.

Since 1998, the RMDZ program has provide d financing totaling $2,146,875 (less than 10 percent of the total funding) to five companies invo lved in composting and $682,000 to one company involved in mulching. The RMDZ loan program is driven by increased diversion from landfills and a development of markets for recycled or recycled content products.

In addition to the RMDZ program, there are other po tential sources of financial

assistance for affected facilities as follows:

• Air Resources Board: Grant or lo an programs regarding air quality

• California Communities: Solid Waste/Recycling–Land, Building, and Equipment

Loans

• State Treasurers Office: Various bond fi nancing and loan guarantee programs

• California Technology, Trade and Commerce: Programs for small businesses

• U.S. Small Business Administration: Various loans guarantee programs

• AQMD Small Business Assistance: Various loans guarantee programs

### CHAPTER V

RECOMMENDATIONSTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 5 - 1 March 2002 

### INTRODUCTION

This chapter discusses the following:

9 AQMD staff Recommendations



### AQMD STAFF RECOMMENDATION Based on information from this report, AQMD staff is recommending that AQMP Control Measure WST-2 – Emission Reductions from Composting and Related Operations, be implemented in two phases. The first phase would consist of an adoption of a fact-finding rule that would have the elemen ts listed below. The first phase would also include control requireme nts for new co-composting facilities with total design capacity of 100,000 tons per year. The second phase would consider composting control technologies for new and ex isting facilities base d on the results of

additional technical work described below. AQMD staff proposes to bring the first phase rule to the Board for consideration in mid-year 2002.

Co-Composting As described in this report, co-composting facilities are major sources of VOC and ammonia emissions (e.g., a 100,000 ton/year total throughput f acility has annual emissions of 89 tons/year VOC and 147 tons/year ammonia). Based on local community concerns and industry studies, si ting of large co-composing facilities in urban areas now requires active consideration of enclosed and controlled facilities to address public health and nuisance concerns . Enclosed ASP or in-vessel systems with control equipment, while feasible and effective at signi ficantly reducing emissions, are costly. Based on industry comment and the staff’s analysis, there may

be additional emission reductions associated with ASP systems that have not been quantified in this report (e.g., reduced p ile emissions due to forced aeration). Additional testing of ASP systems, such as that proposed by Southern California Association of POTWS (SCAP), would allo w the emission reduction potential of all control scenarios to be refined. Also, a dditional operational and cost information for an enclosed ASP system will be available subsequent to the opening of IEUA's’RP-1 facility in 2003. Th is information would allow this report’s conservative costeffectiveness analysis to be refined. PR 1133 woul d require that new co-composting facilities above 100,000 tons/year total th roughput meet the Scenario 2 control requirements (i.e., enclosed active composting with controls) and all existing operations and new operations under 100,000 tons/year of total throughput would meet certain registration and annual reporting requirements. Specifically:

• Scenario II control requirements for new facilities with total throughput designed capacity of 100,000 tons per year;

9 Enclosure and ASP for the active phas e of the process with emissions vented to a bio-filtration system;

9 Open ASP for the curing phase of the process with emission vented to a bio-filtration system;

• One-time registration with AQMD;

• Annual reporting requirements; and,Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 5 - 2 March 2002 • Compliance with all applicable AQM D rules, regulations and permit

conditions.

This proposal is consistent with Best Av ailable Control Technology practices and is designed to address potential public nuisanc e and emission issues. AQMD staff is aware that three out of four existing fac ilities with designed capacities of 100,000 tons per year or more, are planning to clos e operations at their existing sites and move to other locations where they are expected to meet or exceed Scenario II control requirements. Furthermore, it is reco mmended that the AQMD staff take the following actions:

• Establish a Composting Techni cal Advisory Group (CTAC):

AQMD staff will continue to evaluate all source testing and other studies currently under development including, but not limited to, the SCAP study and testing conducted by the Integrated Waste Management Board. As part of this evaluation process, AQMD staff is recommending th at a Composting Technical Advisory Committee (CTAC) be formed to address the te chnical concerns of this sector of the composting and related operations industry. The TAC would include members of the regulated community, staff from the In tegrated Waste Management Board and AQMD, representatives from sanitati on district and utility agencies.

• Report to the AQMD Stationary Source Co mmittee in six months on findings from the SCAP study. The SCAP study is designed to test the effectiveness of an open ASP system and some select ope rating parameters and is expected to be completed by June 2002. Staff w ill summarize the technical findings and provide recommendations as appropriate in seeking cost-effective control opportunities.

• Provide technical assistance to local or state jurisdiction on air quality issues during permitting or the preparation of CEQA documents. During this rulemaking, the staff has obtained a gr eat deal of information on composting air emissions and it would be beneficial to the permitting or lead agency to give adequate air quality considerati on in its decision-making. It also provides an opportunity to evaluate em ission reduction pot ential on a case-bycase basis.

Greenwaste Composting As described in Chapters 2 and 4 of this re port, the greenwastes industry represents a significant source of VOC emissions and its co ntrol options in gene ral are considered cost-effective even without taking accounti ng for additional reduction potential from an ASP system. However, the affordability analysis and potential increase in tipping

fees indicate that these controls are infeasib le at this time without government grants to help finance controls. As a result, th e staff is proposing minimal requirements on the industry at this time and the proposed requirements would primarily track its operations and emissions inventory and to claim SIP reductions should site-specific controls be implemented. The followi ng summarizes the proposed requirements:Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 5 - 3 March 2002 • One-time registration

• Annual reporting requirements

• Compliance with all applicable AQM D rules, regulations and permit

conditions In light of the fact that th ere are cost-effective control options for this industry that are not yet affordable, AQMD staff is r ecommending that, through the District’s Legislative Committee, special funding from the state legislature be sought to implement state of the art composting met hods, including but not limited to, enclosed ASP. AQMD staff will work with the CIWMB and CARB to seek additional funding and/or make existing funding directed more towards air quality spending.

Chipping and Grinding Requirements

• One-time registration;

• Compliance with all applicable AQM D rules, regulations and permit conditions;

• Holding time restrictions by source of unprocessed materials and by the end usage of chipped and ground materials; and

• PM10 controls to prevent visible PM10 emissions over the property line during operations and from pr ocessed material piles.

Exemptions

• Portable chipping and grinding

• Community composting

• Agricultural composting

• Nurseries

• Small Operations (throughput threshold to be determined)

Registration and Annual Reporting Requirements The one time registration requirement will, at a minimum, require facility owners and/or operators to provide the following information:

9 Facility name;

9 Facility location and mailing address;

9 Facility legal owner;

9 Facility operator;

9 Facility contact person;

9 Facility IWMB identificati on number and contact person;

9 LEA identification number and contact person;

9 Facility designed capacity (throughput);

9 Feedstock description;

9 Composting process description;

9 Products produced;

9 Customers profile;

9 Tipping fee schedule; and,

9 Number of employees.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 5 - 4 March 2002 The annual reporting requirements would require the following information:

9 Update of registration information, as pertinent;

9 Annual actual throughput;

9 Number of enforcement actions agains t the facility by enforcing agency;

Annual Status Report The information received from the co-composting and greenwaste facilities and their emission estimates will be summarized and presented as an annual status report to the AQMD Stationary Source Committee. As pa rt of this report, funding opportunities, composting technology, progresses in emi ssion reductions will also be included.

### CHAPTER VI

PUBLIC OUTREACHTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 6 - 1 March 2002 

### INTRODUCTION

This chapter discusses the following:
9 Public Outreach



### PUBLIC OUTREACH The public outreach efforts for Proposed Rule 1133 – Composting and Related Operations, included public meetings, focu sed presentations, and site visits. The meetings were well attended. In general, the average number of people in attendance for each of the meetings range from 60 to 80 people. Following is chronological listing of the public meetings.

♦ Public Consultation Meeting, October 5, 2000

♦ Proposed Rule 1133 Working Group Meeting, August 22, 2001

♦ Public Workshop, September 5, 2001

♦ Proposed Rule 1133 Working Group Meeting, September 28, 2001

♦ Proposed Rule 1133 Working Group Meeting, January 15, 2002

♦ Proposed Rule 1133 Working Group Meeting, February 19, 2002

Focused presentation on Proposed Ru le 1133 where given to the following

entities:

♦ Orange County League of Cities

♦ San Gabriel Valley COG Solid Waste Committee

♦ California League of Cities – Environmental Quality Committee

9 Membership includes all cities in the State of California

♦ San Bernardino County Solid Waste Advisory Task Force

♦ California Contract Cities Asso ciation, Legislative Committee

♦ SCAG Solid Waste Task Force

♦ Los Angeles County Solid Waste Management Committee Integrated Waste

Management Task Force

♦ AQMD’s Ethnic Community Advisory GroupTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 6 - 2 March 2002 ♦ AQMD’s Local Governments and Small Business Advisory roup

♦ AQMD’s Stationary Source Committee

AQMD staff conducted site visits to the following facilities:

♦ Aguinaga Fertilizer

♦ B. P. Hauling

♦ California Biomass

♦ Community Recycling & Resource Recovery, Inc.

♦ Empire Utilities Agency Composting Facility

♦ Inland Empire Composting

♦ Leisure World

♦ Los Angeles City – Archrorage

♦ Los Angeles City – Griffith Park

♦ Los Angles City – VanNorman

♦ R & S Dumping Service

♦ Rancho Las Virgenes Composting Facility

♦ River Ranch Recycling Organics

♦ Salado Creek – Coachella Landfill Composting

♦ Sierra Soil Company

♦ Synagro

♦ Tierra Verde Industries

♦ Whittier Fertilizer

In addition to the site visits, AQMD sta ff has met numerous times with industry and sanitation district(s) representatives, indivi dually and in groups, to address specific rule proposal issues and discuss research plans.

Following is a list of all the cities and governmental agencies that to date have been active in the rulemaking process for Proposed Rule 1133:

♦ City of Burbank

♦ City of Cerritos

♦ City of Chino

♦ City of Chino Hills

♦ City of Colton

♦ City of El SegundoTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 6 - 3 March 2002 ♦ City of Glendale

♦ City of La Canada-Flintridge

♦ City of Los Angeles

♦ City of Newport Beach

♦ City of Palm Springs

♦ City of Pasadena

♦ City of Pico Rivera

♦ City of Redlands

♦ City of San Diego

♦ City of San Marino

♦ City of Santa Fe Springs

♦ City of Upland

♦ City of West Covina

♦ City of Whittier

♦ Eastern Municipal Water District

♦ Inland Empire Utilities Agency

♦ Las Virgenes Municipal Water District

♦ Los Angeles City Dept. of Water & Power

♦ Los Angeles County – Dept. of Parks & Recreation

♦ Los Angeles County – Public Works Dept.

♦ Los Angeles County Arboretum & Botanical Gardens

♦ Los Angeles County DPW

♦ Los Angeles County LEA

♦ Los Angeles County Sanitation District

♦ Municipal Water District

♦ Orange County Council of Governments

♦ Orange County Integrated Waste Management

♦ Orange County Sanitation District

♦ Riverside County Environmental Health

♦ Riverside County Waste Management Dept.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 6 - 4 March 2002 ♦ San Bernadino County LEA

♦ San Bernadino County Solid Waste Management District

♦ Southern California Alliance of Publicly Owned Treatment Works

♦ Southern California Association of Governments

♦ Ventura County Air Pollution Control District

♦ Ventura County LEA

♦ Western Riverside Council of Governments

### REFERENCESTechnology Assessment for Proposed Rule 1133

Proposed Rule 1133 REF - 1 March 2002 REFERENCES

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and Ammonia Emissions from the In-Vessel Composter Odor Control System at Joint

Water Pollution Control – Carson Plant . July 1995.

Black & Veatch Corp. Operation and Main tenance Manual for Rancho Compost Facility

Odor Control Biofilter . April 2000.

Black & Veatch Corporation. Biofiltration for Odor Control.

City of Columbus, Ohio. Conceptual Design Report for Compost Facility . October

1999.

City of Columbus, Ohio. Technica l Evaluation Report for Compost Facility . January

2001.

Inland Empire Utilities Agency. Chino Basi n Organics Management Strategy Business

Plan . May 2001.

Inland Empire Utilities Agency. RP-1 Co mpost Facility. Conceptual Pre-Design Workshop Handout . August 2001.

New Jersey Department of Environmenta l Protection. Response-to-Comments Document – Burlington County Co-Composti ng Facility Air Pollution Control Permit &

NJPDES Permit No. NJ0082741 . 1996.

PBS&J. Philadelphia Water Department – Biosolids Recycling Center. VOC and Odor Emissions Study . September 2001.

Robert Rynk et al., On-Farm Composting Handbook . New York: Northeast Regional Agricultural Engineering Service, June 1992.

Rosenfeld, Paul, Ph.D. Synagro’s Odor C ontrol and Pathogen Reduc tion Pilot Program. August 1999.

SCAQMD. Emission Rate Characterizati on of Open Windrow Sludge Composting Operations . October 1995.

SCAQMD. Characterization of Ammonia, To tal Amine, Organic Sulfur Compound, and Total Non-Methane Organic Compound (TGNMOC) Emission s from Composting Operations . Source Test Report for EKO Systems. May 1996.Technology Assessment for Proposed Rule 1133

Proposed Rule 1133 REF - 2 March 2002 SCAQMD. Characterization of Ammonia, To tal Amine, Organic Sulfur Compound, and Total Non-Methane Organic Compound (TGNMOC) Emission s from Composting Operations . Source Test Report for San Joaqui n Composting, Inc. November 1996.

SCAQMD. Draft Ammonia and Volatile Or ganic Compound (VOC) Emissions from a Greenwaste Composting Operation . March 2002.

SCAQMD. Draft Remote Sensing Test fo r Ammonia and Volatile Organic Compound (VOC) Emissions from a Greenwaste Composting Operation . In preparation, March

2002.

SCEC. Compliance Source Testing Plan for Las Virgenes Municipal Water District. August 1994.

SCEC. El Toro Water District Water Recy cling Plant - Biofilter Odor Control System Compliance Source Test Report . April 1999.

SCEC. Valley Sanitary District Regional Wastewater Reclamation Plant – Headworks Biofilter 1999 Compliance Source Test Report . June 1999.

SCEC. Western Riverside County Regional Wa stewater Reclamation Plant – Headworks Biofilter 1998 Compliance Source Test Report . November 1998.

Synagro. Proposal for Corona, Califor nia. Compost Facility Enclosure . February 2001. Waste Management of New York/Bio Gro a nd Wright-Pierce. Rockland County CoComposting Facility Acceptance Test Report. Volume I . July 1999.