### SOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

FINAL STAFF REPORT

PROPOSED AMENDED RULE 1133.1 – CHIPPING AND GRINDING
ACTIVITIES

PROPOSED RULE 1133.3 – EMISSION REDUCTIONS FROM GREENWASTE
COMPOSTING OPERATIONS

July 2011

Planning, Rule Development, and Area Sources

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

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

Assistant Deputy Executive Officer Engineering and Compliance Jill Whynot

Author: Jong Hoon Lee, Ph.D. – Air Quality Specialist

Technical Assistance: Jay Chen – Senior Air Quality Engineering Manager David Jones – Air Quality Analysis & Compliance Supervisor Charles Tupac – Air Quality Analysis & Compliance Supervisor Mike Garibay – Senior Air Quality Engineer Eric Padilla – Air Quality Engineer

Reviewed by: Tracy A. Goss, P.E. – Program Supervisor

Barbara Baird – District Counsel Veera Tyagi – Senior Depu ty District CounselSOUTH COAST AIR QUALIT Y MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: DR. WILLIAM A. BURKE Speaker of the Assembly Appointee

Vice Chairman: DENNIS YATES Mayor, Chino
Cities of San Bernardino
MEMBERS:

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

JOHN J. BENOIT Supervisor, Fourth District County of Riverside

MICHAEL A. CACCIOTTI Councilmember, South Pasadena Cities of Los Angeles County/Eastern Region

JANE W. CARNEY Senate Rules Appointee

JOSIE GONZALES Supervisor, Fifth District County of San Bernardino

RONALD O. LOVERIDGE Mayor, Riverside Cities of Riverside County

JOSEPH K. LYOU, Ph. D. Governor’s Appointee

JUDITH MITCHELL Councilmember, Rolling Hills Estates Cities of Los Angeles County/Western Region

SHAWN NELSON Supervisor, Fourth District County of Orange

JAN PERRY Councilmember, Ninth District City of Los Angeles

MIGUEL A. PULIDO Mayor, Santa Ana Cities of Orange County

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.

### TABLE OF CONTENTS

Executive Summary ...........................................................................................................1

Background .................................................................................................................... ....3

Public Process ................................................................................................................ .....7

Legal Authority ..................................................................................................................8

Control Methods ................................................................................................................8

Summary of Proposed Rules ...........................................................................................12

Emissions Inventory and Reductions .............................................................................21

Cost Effectiveness ............................................................................................................ .24

Incremental Cost Effectiveness .......................................................................................24

Environmental Assessment .............................................................................................25

Socioeconomic Assessment ..............................................................................................26

Comparative Analysis ......................................................................................................26

Conclusions ................................................................................................................... ....36

References .................................................................................................................... .....37

Appendix I – Composting Process

Appendix II – Emission Control Technology

Appendix III – Emission Reductions and Cost Effectiveness

Appendix IV – Public Comments and Responses

### List of Tables

Table 1. Estimated Number of Chipping and Grinding Facilities .....................................22

Table 2. Number and Throughput of Affect ed Greenwaste Composting Facilities ..........23

Table 3. Emissions Inventory and Emissi on Reductions for Existing Greenwaste

Composting Operations ......................................................................................24

Table 4. Greenwaste Composting Average Cost Effectiveness .........................................24

Table 5. Comparison of State Regula tion and District Proposed Rules ............................28

Table I-1. Commonly Used Raw Compost Materials ...................................................... I-3

Table I-2. Troubleshooting and Mana gement Guide for Composting

Conditions ....................................................................................................... I-5

Table III-1. Emission Tests Used to Devel op the Baseline Emission Factors .............. III-1

Table III-2. Composting Em ission Factors ................................................................... III-2

Table III-3. Greenwaste Composting Base line Emission Factors (EF) ........................ III-4

Table III-4. Greenwaste Composting Base line Emissions Inventory ........................... III-5

Table III-5. Weighted Average Control E fficiency for VOC and Ammonia ............... III-6

Table III-6. Greenwaste Composti ng Emission Reductions ......................................... III-8

Table III-7. Compliance Cost Estimates a nd Proposed Rule Requirement ................ III-10

Table III-8. Greenwaste Composting Averag e Cost Effectiveness (C-E) .................. III-10

### List of Figures

Figure I-1. Composting Process ........................................................................................ I-1

Figure I-2. Flow of Typical Green waste Composting Operation ..................................... I-1

Figure II-1. Covered Negative-pressure ASP with Biofilter System .............................. II-1

Figure II-2. GORE® Cover System Configuration ........................................................ II-3

Figure II-3. Covered Positive-pre ssurized MOR Compost Cover .................................. II-4

Figure III-1. VOC Emissions Profile for Greenwaste Composting .............................. III-3

Figure III-2. Ammonia Emissions Profile for Greenwaste Composting ...................... III-4Preface

On June 7, 2011, the Draft Staff Report and Proposed Amended Rule (PAR) 1133.1 – Chipping and Grinding Activities, and Proposed Rule (PR) 1133.3 – Greenwaste Composting Operations were released for a 30-day public review for a July 8, 2011 Public Hearing. This Final Staff Report co ntains staff’s current proposal for PAR 1133.1

and PR 1133.3 which are scheduled for a Ju ly 8, 2011 Public Hearing. Changes and

clarifications made to the rule since th e June release of the PAR 1133.1 and PR 1133.3 package are summarized below:

• Clarify that the non-putrescible materi als may be excluded in calculation of annual foodwaste throughput, provided th ey are quantified and records are maintained;

• Add 7 days maximum to the greenwas te holding time in PAR 1133.1 (d)(2). Also, remove the 48-hour timefra me from PR 1133.3 (d)(1)(A);

• Modify the time required to apply the fi nished compost cover from three hours to 24 hours of initial pile formation;

• Modify the time required to apply wate r from three hours to six hours before turning;

• Add official federal and st ate holidays to be excluded from the 48-hour timeframe in PAR 1133.1 (d)(2);

• Add allowance of turning a pile within 7 days of the finished compost cap to manage temperature of the pile in PR 1133.3 (d)(2)(D); and

• Make other minor clarifications.

Updates to the staff report to reflect thes e and other minor changes are presented in

strike-out/underline format.PAR 1133.1 and PR 1133.3 Final Staff Report



### EXECUTIVE SUMMARY

The South Coast Air Quality Management Dist rict (SCAQMD or the District) adopted a series of rules (Rules 1133, 1133.1 and 1133.2) in January 2003 covering chipping and grinding activities, and co-c omposting operations. Composting is a biological process in which organic material is decomposed by microorganisms under controlled conditions to produce compost that can be used to reintr oduce nutrients into the soils. Compost production operations have several benefits in developing a sustainable environment. To name a few, compost use enhances overall air quality by mitigating all forms of carbon and nitrogen emissions, volatile organic co mpounds (VOCs), methane, and renewable carbon dioxide (CO 2 ) versus non-renewable fossil fuel CO 2 , and enhances waste management by turning a material often put in to landfills to a beneficial use to enhance the sustainability of major industries, includin g agriculture, landscape and natural lands restoration and management. VOCs and a mmonia emissions still occur during this process, but can be reduced cost-effectively using simple management practices. Over 400,000 tons of greenwaste is composted in the District each year. Approximately 2.7 tons per day VOC and 0.4 tons per day ammonia are emitted from greenwaste composting in the District. If not done pr operly, greenwaste composting can also result in odor problems. Odor regul ation of composting is under the authority of the Local Enforcement Agencies, not the District (Ca lifornia Health and Safety Code Section 41705).

Proposed Rule (PR) 1133.3 woul d reduce 0.9 tons per day of VOC and 0.1 tons per day of ammonia from greenwaste composti ng operations. PR 1133.3 would implement Control Measure (CM) MCS-04 of the 2007 Ai r Quality Management Plan (AQMP) and seeks to establish operational best manage ment practices (BMPs) for greenwaste composting operations that produ ce active or finished compost from greenwaste-only or greenwaste in combination with manure or foodwaste. Amending Rule 1133.1 is proposed to better manage stockpile operatio ns associated with chipping and grinding activities, which is to be consistent with current greenwaste material processing requirements established in Title 14 of th e California Code of Regulations (CCR).

Proposed Amended Rule (PAR) 1133.1 covers approximately 70 facilities and would establish BMPs for chipping and grinding activ ities to produce materials other than active or finished compost. No emission reductions are quantified for this rule proposal because the rule incorporates existing state requi rements. PAR 1133.1 would also establish maximum holding times of greenwaste mate rial. PAR 1133.1 would apply to chipping and grinding activities not onl y occurring at a stand-alone ch ipping and grinding facility, but also occurring at a material recovery facility (MRF), a landfill using this material for alternative daily cover (ADC), a transfer station, a biomass energy production facility or a composting facility. PAR 1133.1 would establish requirements for processing greenwaste for other uses than composting. Under PAR 1133.1, gr eenwaste would be required to be chipped or ground and utilized or removed from the site within 48 hours of receipt, or up to seven days maximum with approval from the Local Enforcement Agency (LEA). Chipping and grinding facilities canno t take foodwaste, unle ss otherwise allowed by the LEA.

SCAQMD 1 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

PR 1133.3 would affect 17 facilities and w ould apply to greenwaste composting operations involving organic waste materials, including greenwaste, woodwaste, manure and foodwaste. Greenwaste composting includ ing greater than 20 percent manure is presently subject to Rule 1133.2 for co-composting operations. PR 1133.3 has requirements for the operator to process greenwaste for on-site composting as allowed by the LEA. Foodwaste is subjec t to a 48 hours processing tim e to initiate composting onsite, or would be required to be covered by finished compost until used. For composting operations of greenwaste-only or greenwaste mixed with up to 20 percent manure, by volume, or up to 5,000 tons per year of foodwaste throughput, operators would be required to cover each active ph ase pile with finished compos t within 24 hours of initial pile formation, such that the top is at least six inches thick and the pile is not turned for at least the first seven days of the active ph ase of composting. Operations would be required to apply water to a thr ee inch depth to the pile, prior to turning, during the first 15 days of the active phase of composting.

For greenwaste composting operations proc essing greater than 5,000 tons per year of foodwaste throughput, the operato r would be required to in stall an emission control device for all active phase compost piles c ontaining foodwaste content of 10 percent or more, by weight. An emission control device would need to be designed, operated and maintained with an overall system control efficiency of at least 80 percent, by weight, for VOC and ammonia emissions, respectively. None of the facilities are currently processing this amount of foodwaste.

PAR 1133.1 also has the 48 hours or up to seve n days material holding time requirement which is shorter than the previous hol ding time requirements of Rule 1133.1. The amended 48 hours or up to seven days maximum holding time requirement is to conform to that of the existing state regulation (T itle 14) which is currently enforced by the county-level LEAs. As the holding time requi rement has already been established and enforced by the LEA, no emission reductions ar e quantified relative to PAR 1133.1.

Costs associated with the implementa tion of PR 1133.3 involve operation and maintenance (O&M) costs to apply finished compost and additional watering to the compost piles before turning for the first 15 days of the active phase composting. These costs include water irrigation costs, including purchase of potable and/or reclaimed water and labor, and finished compost cover costs th at do not include the capital cost of the application equipment. Costs are proportional to the amount of greenwaste processed, which ranges from less than 5,000 tons to 200,000 tons per year per facility. Total annual O&M costs range from $700 to ~$200,000 per facility (facility annual average of $29,000 per year). Overall, for PR 1133.3, average cost effectiveness is estimated to be $1,340 per ton of VOC-only and $1,270 per ton ofVOC and ammonia combined. If addon emission controls were required due to foodwaste throughput above the aforementioned thresholds, incremental cost effectiveness would be $6,600 per ton of VOC-only and $5,700 per ton of VOC and ammoni a combined for a 50,000 tons per year operation, when compared to finished co mpost cover and watering application.

Several working group and other industry stakeh older meetings have been held to discuss rule concepts and draft rule language. A public workshop was held in February 2011.

SCAQMD 2 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Numerous facility meetings have also occurre d, as well as many site visits and phone calls. As a direct result of these meetings, rule language was refined. Staff will evaluate other uses of greenwaste for potential future rulemaking.



### BACKGROUND

AIR QUALITY

The SCAQMD is the regional government agency responsible for air quality in all of Orange County and the non-desert portions of Los Angeles, Riverside and San Bernardino counties. The District’s jurisd ictional boundaries include all of the South Coast Air Basin (Basin) and portions of th e Salton Sea Air Basin (SSAB). Although air quality in the Basin has remarkably improved in the past decades, the air still does not meet all federal and state air quality standard s. The U.S. EPA has designated the Basin

as “extreme” non-attainment for 8-hour ozone standard. The Basin has been designated

as non-attainment for PM 2.5 . The District is required to meet the federal annual PM 2.5 standard by 2015 and the federal 8-hour ozone standard by 2024, respectively.

Organic materials comprise about 40 percent of California’s waste stream. Diverting a high percentage of these materials is key to the state achieving and maintaining the diversion goals of the California Integr ated Waste Management Act (AB939, Sher, Chapter 1095, Statues of 1989 as amended [I WMA]). Pursuant to AB939, composting has been promoted statewide to achieve waste diversion goals. Composting is a good mitigation measure for greenhouse gas (GHG ) emissions reduction, as well. Much smaller quantities of methane are emitted from aerobic composting than from uncontrolled anaerobic decomposition. Good composting practices, which balance the carbon-to-nitrogen (C:N) ratio and provide adequate aeratio n and moisture, will minimize VOC, ammonia and GHG emissions.

Interest in foodwaste composting is also on the rise. Foodwaste, if not recycled via composting, is sent to landfills. More than six million tons of food scraps are generated each year in the state, which is about 15 pe rcent of landfill material. Composting is a beneficial way to recycle food scraps into reusable compost and reduce emissions of methane, a potent GHG. Currently, the vast majority of food sc raps are landfilled.

Greenwaste composting is a source of ammonia, a PM 2.5 precursor, and VOCs, an ozone precursor. Biogenic VOC also acts as a prec ursor gas to form secondary aerosols. Ammonia can be emitted from improperly managed composting piles and act as a precursor gas to form secondary aerosols. Annually, over 12 million tons of compostable organic materials, such as foodwaste and landscape trimmings, ar e sent to California landfills. In 2006, methane emissions from composting (primarily of greenwaste and food scraps from residential and commercial establishments) in the U.S. were estimated to be 75 gigagrams (Gg), which accounts for only 1.3 percent of 5,985 Gg of the landfill

methane emissions 1 . In the South Coast, gas recovery control systems have been required to be employed for decades. These systems effectively collect VOC and methane, as a result that landfill emissions are well controlled in the Basin. Therefore, diverting organic materials not only helps return valuable nutrients to the soil, improves

SCAQMD 3 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

plant productivity, and helps redu ce water usage, erosion, and chemical use, but it also

can reduce GHG emissions from landfills not equipped with gas control systems 2

.

Following is a brief description of the health and environmental concerns with air contaminants emitted from organic treatments, including greenwaste composting, that

contribute to the formation of PM 2.5 and ozone, and climate change. The management practices proposed in PAR 1133.1 and PR 1133.3 will reduce ammonia and VOC, precursors to PM 2.5 and ozone, as well as minimize PM 2.5 emissions.

Particulate Matter (PM 2.5 )

Most PM 2.5 in the Basin’s air is belie ved to be in the form of secondary aerosols, such as

ammonium sulfate and ammonium nitrate that are formed by reactions of ammonia with acidic gases, or such as secondary organi c aerosols formed from biogenic VOC. PM 2.5 is associated with adverse health effects. A great fraction of particles in this size range can penetrate and deposit deep in the lungs, damaging the airways of the lower respiratory

tract. It should be noted that PM emissions from material movement is, in general, controlled relative to complian ce with Rule 403 – Fugitive Dust.

Ozone

VOC is produced from greenwaste composting as a by-product of biological degradation of organic materials. Not only is VOC produced during aerobic co mposting of organic materials, but VOC is also produced in even greater quantity in an aerobic decomposition.

VOC contributes to the formation of ozone and organic aerosols in the atmosphere, contributing to higher PM 2.5 and lower visibility levels. Ozone is formed in the atmosphere through a photochemical reac tion of VOC and nitrogen oxides (NO

x ) by sunlight.

Ozone is a highly reactive compound and a st rong oxidizing agent. When ozone comes into contact with the respiratory tract, it can react with tissues a nd cause damage in the airways. Ozone is a deep lung irritant, causi ng the lung passages to become inflamed and swollen. Exposure to ozone produc es alterations in re spiration, the most characteristic of which is shallow, rapid breathing and a decrease in pulmonary performance.

Greenhouse Gases

Greenhouse gases, such as CO 2 , methane (CH 4 ), and nitrous oxide (N 2 O), are emitted to the atmosphere through natural processe s and human activities. These GHGs are associated with composting. All organic materials contain carbon. When organic materials are decomposed natu rally under aerobic conditions, CO 2 is emitted as part of

the natural short-term carbon cycle. When organic materi als are placed in an anaerobic environment, anaerobic decomposition will emit methane and some VOCs.

Methane is emitted from uncontrolled anaer obic decomposition of waste. Although landfill methane emissions are well controlled in the SCAB, landfills are the largest human-related source of methane in the U.S., accounting for 34 percent of all methane emissions. Methane is genera ted in landfills and open dumps as waste decomposes under anaerobic (without oxygen) c onditions. The amount of me thane created depends on the

SCAQMD 4 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

quantity and moisture content of the waste and the design and management practices at the site. Even though methane is formed in anaerobic sections at th e bottom of compost piles, it is oxidized to a large extent as it reaches more aerobic sections of the compost piles. Anaerobic sections are created in composting piles when there is excessive moisture and inadequate aeration of the piles. The estimated methane released into the atmosphere ranges from less than one percent to a few percent of the initial carbon content in the compost material 1 . The District has rules to capture methane and VOC emitted from landfills. Nitrogen-high organic ma terials, such as manure, grass clippings, and food scraps, under wet and oxygen-lim ited conditions, can also produce N 2 O during decomposition. The range of the estimated emissions varies from less than 0.5 percent to five percent of the initial nitrogen content of the material.

Regulatory Background

Following is a summary of the regulatory programs that are applicable or pertinent to the greenwaste composting operations industry.

Federal Programs

Resource Conservation and Recovery Act In 1976, Congress enacted the Resource Cons ervation and Recovery Act (RCRA), an amendment to the 1965 Solid Waste Disposal Act. RCRA calls for conservation of energy and natural resources, waste reduc tion, and environmentally sound waste management practices. In ad dition, RCRA encourages states to develop plans for nonhazardous industrial solid waste and munici pal solid waste (MSW) management, sets criteria for MSW landfills, as well as for other solid waste disposal facilities, and prohibits the open dumping of solid waste. Co ngress delegated authority to U.S. EPA to develop scientific regulations to implement the requirements of RCRA. Solid waste regulations have been promul gated in the Code of Federa l Regulations under Title 40, Chapter I, Subchapter I, Part s 240-282 (40 CFR Parts 240-282).

Sewage Sludge Disposal Standards U.S. 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. To qualify as Class A compost, Appendix B to Part 503 – Pathogen Treatment Process, genera lly requires processes to further reduce pathogens (PFRP). PFRP requires that open windrow composting maintain the temperature of the compost at 131 degrees Fahr enheit or higher for 15 days or longer, and during this time there must be a minimum of fi ve turnings of the windrows. For in-vessel or aerated static pile (ASP) composting, the RFRP requires the active pile temperature be at least 131 degrees Fahrenheit or higher fo r three days. This process assures that virtually all human pests and pathogens are destroyed. Since food residuals contain human pathogens, fungi and bacteria, this PFR P should be met when foodwaste is being mixed with greenwaste for composting.

State Programs

SCAQMD 5 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

California State Legislature: Californ ia Integrated Waste Management Act Recognizing landfill lim itations (i.e., capacity and siting) and the need for integrated waste management practices, in 1989, the Ca lifornia state legislat ure passed Assembly Bill (AB) 939 – California Integrated Wast e Management Act into law, which was incorporated into the California Public Res ources Code, Division 30. Cities and counties

were mandated to achieve a total waste dive rsion of 25 percent by 1995 and to meet a

total waste diversion of 50 percent every year.

California Department of Resources Recycling and Recovery (CalRecycle) In April 2003, the California Integrat ed Waste Management Board (CIWMB) promulgated a set of regulations governing composting operations and facilities. The CIWMB currently regulates approximately 115 composting facilities operating in

California in accordance with the Californi a Code of Regulations, Title 14, Division 7, Chapter 3.1 – Composting Operations Regulat ory Requirements (Chapter 3.1). Chapter 3.1 has requirements for handling compostabl e materials including, but not limited to,

material residence time at f acilities and temperature requirement to prevent inadvertent decomposition. This Chapter also has a path ogen reduction requirement that requires open windrow composting maintain the temperat ure of the pile at 131 degrees Fahrenheit or higher for at least 15 days or longer during which windrows must be turned at a minimum of five times. Depending on the type of composting materials and the throughput, affected facilities are required to obtain a Notification or a Full Solid Waste Facilities Permit (Full Permit) that are issued by LEAs, such as the environmental health departments. There are also requirements for green material composting operations and facilities, as well as an Odor Impact Mini mization Plan (OIMP). [Note: the CIWMB was formerly part of Cal-EPA, is now part of the Resources Agency, but many of the actions

referenced and discussed herein occurred before that time.]

2007 Strategic Directive 6.1 In 2007, the CIWMB adopted Strategic Directiv e 6.1, which in addition to the diversion required under AB 939, seeks an additional 50 percent of organi cs diverted from landfills by 2020, in accordance with the waste management hierarchy and in support of the California Global Warming Solutions Act of 2006. The CIWMB has estimated that meeting Strategic Directive 6.1 may require 50 to 100 new organics processing facilities (or equivalent expansion of existing facilities) that produ ce compost, biofuels, and/or bioenergy; increased development of produc t standards and increased procurement by private and public entities; and resoluti on of cross-agency regulatory issues.

Regional Water Quality Control Board The Regional Water Quality Control Board (RWQCB) issues and enforces National Pollutant Discharge Elimination System (NPDES) permits. In addition, the RWQCB focuses on wastewater generation, water de mand, the capacity of existing or planned stormwater drainage systems and potential ne w sources of polluted run-off, and potential depletion of groundwater supplie s or interference with groundwat er recharge. In the case of composting facilities, the RWQCB has required various com posting sites to be graded, paved, and surrounded by berms and other draina ge-related protections to prevent run-off and the leaching of chipped and gr ound materials into the groundwater.

SCAQMD 6 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Local Programs

There are several local requirements th at may apply to greenwaste composting operations. Specifically, these requirements focu s on air, land use and solid waste issues. The following is a summary of these requirements.

SCAQMD Rule Requirements Currently, operators of chippi ng/grinding operations at greenw aste composting facilities are required to comply with SCAQMD Rules 402 – Nuisance, 403 – Fugitive Dust, and 203 – Permit to Operate for equipment that require permits. In addition, greenwaste composting operations are required to comp ly with District Rules 1133 – General Administration, 1133.1 – Chipping and Gr inding, and 1133.2 – Emission Reductions from Co-Composting Operations involving mo re than 20 percent manure. However,

none of these rules establish specific control requirements to reduce VOC and ammonia emission from greenwaste-only composting operations.

Local Enforcement Agency Requirements There are several different local (i.e., city or county) enforcement agencies or LEAs that act as either the permitting or enforcemen t division of the CIWMB, depending on the throughput and type of compostable materials. For example, the local department of health services, on behalf of the CIWMB, issues Registration, Standardized, and Full Permits depending on the size of throughput and enforces the requ irements in these permits. For either type of permit scenar io, the LEAs are respons ible for handling and investigating complaints from composting a nd chipping/grinding operations. Pursuant to Health and Safety Code Section 41705, co mposting operations are exempt from SCAQMD odor regulations; SCAQMD must refer odor complaints to the LEA.

Local Governments Local government zoning ordinances determin e where composting activities can occur. In addition, local government grant conditional use permits if the jurisdiction has determined that special conditi ons and approvals are necessary.



### PUBLIC PROCESS

Staff invited environmental and commun ity group representatives, industry representatives, government staf f, consultants and individual s from affected industry to participate in a working group. The first working group meeting was held on June 8, 2010 and a subsequent follow-up conference call was held on June 18, 2010 to accommodate people who were not able to part icipate in the first working group meeting

due to technical difficulties with the conf erence call. A second working group meeting was held on August 27, 2010 with revised concepts and prelimin ary draft rule language. Three written comment letters were received from participants for initial concepts discussed at the first working group meeting and seven additional comment letters were received regarding the revised concepts and preliminary draft rule language. Staff has made many site visits and has met with indu stry representatives on several occasions to address key issues relative to proposed rule requirements. A public workshop was held on February 9, 2011 and 15 writte n comments were received. The rule proposal was

SCAQMD 7 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

revised based on those comments and the thir d working group meeti ng was held on May 10, 2011 with the revised rule proposal. Nine additional written comments were received as a result of the third working group meeting. Staff further revised the rule language and held another working group meeting on June 15, 2011. The revised rule proposal is

based on all the verbal and written comment s that were received since the Public Workshop and are responded to in Appendix IV. A Public Hearing is scheduled for July 8, 2011.



### LEGAL AUTHORITY

The SCAQMD obtains authority to adopt, amend, or repeal rules and regulations which control air pollution from Health and Safety Code §§ 39002, 40000, 40001, and 40440

.



### CONTROL METHODS

According to the District’s greenwaste co mposting industry survey conducted in 2007, the predominant method of greenwaste com posting is windrow composting. Composting is a biological process where organic mate rial is decomposed by microorganisms under controlled conditions in the pr esence of oxygen to produce a co mpost material that can be

used to reintroduce nutrients into the soils. Two com posting methods are commonly conducted: static pile composting and tu rned windrow composting. Static pile composting is characterized by infrequent turning, which is similar to backyard composting on a larger scale. The material is placed into piles where it decomposes over an extended period of time with no or little mixing during the composting process. Therefore, it is crucial to construct the pile to the appropriate size, with the material being thoroughly blended and having a moisture c ontent and porosity to allow adequate aeration through the composting process. In turned windrow composting, materials are

moved with a front-end loader into long piles called windrows. Aeration is achieved both by natural advection and mechan ically turning the piles w ith a front-end loader or a windrow turner, such as a Scarabs machine. Temperature, moisture content and oxygen concentration are maintained to optimize and hasten decomposition. After two to four months of composting in the piles or windrows, the material becomes finished compost.

PR 1133.3 does not require a sp ecific type of composti ng, and thus any type of composting technique can be used for the process. PR 1133.3 requires two different levels of emission control methods to reduce gaseous emissions from greenwaste composting operations. The type of an emi ssion control method required is determined

based on the annual foodwaste th roughput on a facility-wide basi s. In order to comply with the requirements of PR 1133.3, new and existing greenwaste composting operations processing greenwaste by itself or operations with up to 20 percent manure, by volume, or with up to 5,000 tons per year of foodwas te throughput (source-sep arated or mixed) would require a combination of finished co mpost cover and additional water irrigation. The operator would need to apply finished co mpost cover to the to p of active greenwaste composting piles at least for the first seven days of the active phase of composting, and then apply water to the pile for the remaining days of the first 15 days of the active phase period of composting. The finished compost c over and water application is considered as a best management practice (BMP), not an emission control technology per se. If more

SCAQMD 8 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

than 5,000 tons per year of foodwaste thr oughput is composted, an emission control device would be required for any active phase composting pile containing a foodwaste content of 10 percent or more, by weight. If existing greenwaste composting facilities determine after rule adoption to process greater than 5,000 tons per year of foodwaste throughput and a foodwaste content of 10 pe rcent or more, by weight, an emission control technology achieving an 80 percent overall control efficiency would also be required.

Finished Compost Cover

PR 1133.3 would require applying either scre ened or unscreened, finished compost and/or compost overs to the top of greenwaste composting p iles at least during the first seven days of the active phase of composting so that the peak is six inches thick. Tests have shown that the emissions primarily escap e from the top one third of the pile. The proposal requires the compost cover such that the top is covered to a depth of six inches, and tapers off as it goes down the pilesides. Thus, the application is adequate to cover the top half of the pile where most emissions emanate. Finished compost is required to be applied to the active phase piles within 24 hours of initial pile construction and sit for a minimum of seven days with the piles unt urned. This so-called “pseudo-biofilter” approach is effective in reducing VOC emissi ons from composting piles. According to the recent greenwaste mitigation measure study 3 , the application of six inches finished compost to the surface of a greenwaste windro w resulted in a 53 percent reduction in VOC emissions for the 22-day active phase pe riod compared to the regular greenwaste windrow without finished compost on it. In the Modesto Emissions Study 4 , a 75 percent

reduction in VOC emissions was achieved with a six inches layer of finished compost

cover for the first two weeks of the active composting phase. Another recent emissions

research 5 using a compost cap made out of oversi zed materials screened from finished compost, known as “compost overs”, showed th at biofilter cap made out of overs reduced average measured ozone formation by 27 percen t in five days old piles and by 36 percent in 21 days old piles. Compost overs have been through the pathogen reduction process outlined in Title 14, Section 17868.3 of the Cali fornia Code of Regulations. Literature 6
shows that finished compost has also been used as a means to oxidize methane from landfills before it is released to the atmosphe re and has been used as biofilter media.

The emissions during the active phase period of composting surpass the emissions during the curing phase and account for the vast majority of the to tal emissions. Emissions for the first 15 days of the active phase period account for a majority (87 percent) of the total integrated VOC emissions. In addition, more VOC emissions occur during the first half of the 15 days period than dur ing the last half period.

The use of screened or unscreened finished compost and/or compost overs is considered a practical application since these materials are readily available at composting facilities. Compost overs do not decompose in a typical composting cycle anyway and are recycled back into the process by using it as a cover material. If fini shed compost is utilized as a cover material, it is initially recycled back into the proce ss by using it to cover windrows and it is also not consumed in the process. It cycles back to fini shed compost at the end of the composting process. PR 1133.3 require s only one time application of finished

SCAQMD 9 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

compost cover and/or compost overs and thus there would be one time (temporary) loss of product sale. Use of finish ed compost as a pseudo-biofi lter cover is a cost-effective emission mitigation measure to reduce VOC emi ssions from composting piles. Costs to apply finished compost cover mainly involve application time a nd a front-end loader operation cost.

Water Irrigation

PR 1133.3 would also require applying water to the surface of the compost piles so that three inches in depth of the pile is wet. According to the mitigation measure study 3

, water irrigation was tested on an active phase composting windrow and showed 24 percent reductions in VOC emissions during the 22 days active phase composting period. Since most compost piles are already wa tered for the composting process, water irrigation would not be difficult for most of the composting facility operators. Excess moisture is also evaporated while turning th e piles and will not lead to oversaturation and leaching issues. It should be noted that water is only required in amounts necessary to make the top three inches we t and does not require water a pplication indiscriminately. The costs of water irrigation involve the use of potable and/or reclaimed, well, or canal

water.

Emission Control Device

An emission control device would be requi red only for operations having greater than 5,000 tons per year of foodwas te throughput, either on a s ource-separated or mixed foodwaste basis, and a foodwaste content of 10 percent or more, by weight. PR 1133.3 does not propose any specific type of em ission control technology for greenwaste composting operations. However, an emi ssion control device should be designed, constructed, maintained, and ope rated to achieve overall system control efficiency of at least 80 percent, by weight, for VOC and ammonia emissions, respectively. Aerated static pile (ASP) venting to biofilter is one example of an emission control device. The material is placed on top of perforated pipes that are connected to blowers that either push or pull air through the piles

. ASP can be operated eith er under negative pressure or positive pressure. Negative-pressure ASP pulls air through the pile and vents the exhaust to an emission control device, such as a biof ilter, to remove air pollution gas emissions pulled from the compost pile before they ar e released to the atmosphere. Wood chips and compost can be used as biofilter media. Finished compost can be layered on the surface of the negative ASP to increase capture efficiency of gas emissions from the pile.

Biofiltration is a well-established emission control technology. In the United States, biofilters have been mainly utilized for the treatment of odors and VOC emissions in wastewater treatment plants . In the Basin since Dist rict Rule 1133.2 was adopted, biofiltration technology has been an emissi on control technology for co-composting VOC

and ammonia emissions. Based on the in formation collected on existing biofilter composting applications, overall control effici encies of about 80 to 90 percent for VOC and 70 to over 90 percent for ammonia have been achieved 7 . Due to technology advancement, a well-designed, well-operated, and well-maintained biofilter will be capable of achieving 80 percent control effici ency for both VOC and ammonia. Biofilter manufacturers also emphasize th at regular inspection and main tenance of the biofilter are

SCAQMD 10 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

key elements to achieve such control level. Based on source tests data from existing cocomposting operations (Inland Empire Regiona l Composting Facilities and City of Los Angeles Sanitation Bureau), properly de signed and maintained biofilters have demonstrated over 90 percent destruction efficiencies for both VOC and ammonia emissions. However, because of concerns over the continuous effectiveness of biofilters in reducing emissions beyond 80 percent, a mi nimum of 80 percent control efficiency would be required under the PR 1133.3.

Negative-pressure ASP is operated intermittentl y, typically with a blower turned on for one third of the operational time. If it is operated on a continuous basis, it will lose a significant portion of moisture content in th e pile because moistu re will be drawn together with the exhaust gas emissions, l eading to microorganisms entering a dormant

stage.

There are different ASP technologies utiliz ing a fabric cover or a tarp. These technologies are called covered ASP systems. A covered ASP system can be aerated positively or negatively, and uses an engineered fabric cover, instead of finished compost, as a cover material. One such syst em is covered negative-pressure ASP with

biofilter 8 . The compostable material is placed on a ventilation pipe and covered with a waterproof cover tarp, following the insert ion of monitoring probes. The pipe is connected to a blower that produces negative air pressure, pulling air into the pile from the outside through small holes in the tarp. As air is being dr awn through the piles, it is sent to a biofilter composed of moist wood chips and compost. Probes are linked to a computer to monitor temperature.

The other type of the covered ASP systems is covered positiv e-pressure ASP using triple layer membrane compost covers 9, 10 . This type of technology pus hes air into the pile, and

does not need a biofilter. The membrane cove rs selectively influen ce the process. They protect the composting material from the pe netration of rainwate r and yet allow carbon dioxide produced during the composting proc ess to escape. The compost cover keeps heat, odors, microorganisms, and some mois ture contained, while releasing oxygen and some moisture. Covered piles are controlledwith a blower fan, connected to either onfloor aeration pipes or in-floor aeration ducts, and controlled by means of either temperature and oxygen 9 or temperature only 10 . Further descriptio n of these covered forced ASP systems is given in Appendix II. These covered forced ASP systems would

cost from two million dollars to five million dollars, depending on vendors, for an operation with 100,000 tons throughput per year.

Another possible emission control technology is a positive-pressure ASP with finished compost as a cover material. Although staff expects that such cove red ASP systems will meet PR 1133.3 requirements, their overall control efficiencies will have to be demonstrated using approved source test me thods and protocols. Currently, there are only a few source tests that were conducted locally using the District Test Methods protocol.

SCAQMD 11 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report



### SUMMARY OF PROPOSED RULES

This section summarizes the requirements of the proposed and amended rules in the order of the major rule subdivisions: Purpose and Applicability, Requireme nts, Test Methods and Protocol, Recordkeeping, and Exemptions . Each section lis ts major proposed requirement elements followed by detailed descriptions.

Summary of Proposed Amended Rule 1133.1 – Chipping and Grinding

Activities

Purpose and Applicability

The purpose of PAR 1133.1 is to prevent in advertent decomposition occurring during chipping and grinding activities, including stoc kpile operations. This proposed amended rule applies to the operators of chipping and grinding ac tivities, including stockpile operations, to produce materials other than active or finish ed compost, unless otherwise exempted.

Greenwaste materials must first be chipped or ground before being further processed for composting, mulching, static pile for land appl ication, ADC at landfills, or biofuels at biomass facilities. Air emissions may occur ev en at a pre-chipping and grinding stage. However, once greenwaste materials are chip ped or ground, air emissi ons begin to occur immediately and spike within th ree to seven days of being chipped or ground. Tests have shown that extended stockpiling operations can cause extensive emissions of VOC and other trace air pollution gases (e.g., ammonia) to the atmosphere. In addition, chipping and grinding activities subject to Rule 1133.1 are also subject to the California Code of Regulations (CCR) Title 14 relative to com postable greenwaste material processing.

Therefore, based on the emission and Title 14, Rule 1133.1 is proposed for amendment to tighten requirements on stockpile operations and harmonize the rule with Title 14. It

should also be noted that the amendments add a pplicability of the rule to the operators of chipping and grinding activities, including stockpile operations, to produce materials other than active or finished compost, and ar e regulated under Title 14. Therefore, this amended rule would apply to the operators of chipping and grindi ng activities occurring not only at a stand-alone chipping and gr inding facility, but also at multi-operation facilities that handle multiple incoming material streams with separate operating areas for “chip and ship” operations (such as chip ping to produce mulch, biofuel, ADC or woodchips) within the same facility. Ch ipping and grinding activities to produce compost feedstock will be separately subjec t to the applicable PR 1133.3 and Title 14 requirements. It should furthe r be noted that as these facili ties are already subject to Title 14, amending Rule 1133.1 to strengthen the holding requirements does not cause any additional impact to the affected facilities.

Requirements

Foodwaste Management

Rule 1133.1 has been amended to state foodw aste cannot be accepted at chipping and grinding facilities, unless otherwise allowed by the LEA to handle foodwaste.

SCAQMD 12 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Stockpile Operations

Once greenwaste is received at the chippi ng and grinding facilit y, the operator shall chip or grind and utilize on-site or re move curbside, non-curbside or mixed greenwaste from the site with in 48 hours of receipt, exclud ing observance of official federal and state holidays, or up to seven days maximum, with approval from the LEA. This requirement harmonizes with Title 14, Division 7, Chapter 3.1, Section 17852 (a)(10)(A)(2) of the CCR. Chipped or ground material s shall not be stockpiled, but be “utilized” for other purpos es, including, but not limited to, daily landfill cover, land application, mulch and er osion control, or be removed from the site, such as being sent to a landfill fo r ADC use or to biomass power generation facility for biofuel consumption, within the applicable allotment of time.

Recordkeeping

All the operational records, as applicable, are required to be maintained for the prior five years of operation, with the most recent two years retained at the facility, which shall be immediately available upon request by the Executive Officer. The remaining three years of records shall be made available within one week of request.

Exemptions

Existing exemptions still apply to material derived and utilized on site, provided less than 1,000 cubic yards of materials per year are either sold or given away. Portable chipping and grinding, agricu ltural chipping and grinding, landclearing chipping and grinding, woodwaste chipping and grindi ng, and palm chipping and grinding activities continue to be exempt from the pr ovisions of the rule. In this amendment, the operator of a landfill or biomass power generation facility would be exempt from the requirements of maintaining operation-sp ecific records on-site, provided that the operator does not perform chipping and grinding of greenwaste on-site.

A biomass power generation facility or a f acility processing material as a biomass fuel for a biomass power generation facili ty would also be exempt from the 48 hours or up to seven days maximum holding time re quirement, provided that the material temperature is maintained at below 122 degr ees Fahrenheit or the moisture content is less than 30% and records of the temperature or moisture measurements are maintained on-site. With this exempti on, the definition of woodwaste has been modified such that the woody materials of screened or uns creened greenwaste, exceeding 2 inches in any dimension, such as tree trimmings, branches, tree trunks, stumps, and limbs, would be considered w oodwaste. Rule elements pertaining to moisture content of chipped and ground curbside greenwaste remain unchanged.

SCAQMD 13 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Summary of Proposed Rule 1133.3 – Emission Reductions from Greenwaste Composting Operations

Purpose and Applicability

The purpose of PR 1133.3 is to reduce f ugitive emissions of VOC and ammonia occurring during greenwaste composting opera tions. This proposed ru le would apply to all new and existing greenwaste composting op erations that produce active or finished compost from greenwaste by itself or green waste in combination with manure or foodwaste. If greenwaste material is ch ipped or ground to produce feedstock for composting, the chipping and grinding activi ties and associated ma terial holding would be subject to the PR 1133.3 requirements.

Certain exemptions may apply. Active compost means material that is in the process of being rapidly decomposed and is biologically unstable. Active compost is generating temperatures of at least 122 degrees Fahre nheit during decomposition. Pathogen-reduced mulch is included in active compost. Fini shed compost means a humus-like material and/or compost overs that result from the controlled biological decomposition of organic waste materials and is biologically stable. Both the active and curing phases of the greenwaste composting are required to achieve this finished compost product. Compost overs are defined as the oversized woody mate rials that do not decompose in a typical composting cycle and are screened out of fi nished product at the end of composting. Compost overs have been through the pat hogen reduction process outlined in the CCR, Title 14, Section 17868.3.

New greenwaste composting operations are de fined as greenwaste composting operations that have not started operations as of rule adoption. Existing greenwaste composting operations are defined as all greenwaste composting operations that have begun operations on or before rule adoption.

Requirements

The proposed rule would focus on stockpile operations and composting operations of greenwaste and/or foodwaste at all new and ex isting composting facilities that are either registered for a Notifica tion tier or permitted by the LEA to conduct composting operations. The level of requirements woul d depend on the annual foodwaste throughput on a facility-wide basis.

For all greenwaste composting operations:

Effective upon rule adoption, the operator of greenwast e composting operation is required to chip or grind, as necessary, and use greenwaste for on-site composting within 48 hours of receipt as allowed by th e LEA. This requirement is consistent with the requirement of the state regulation pursuant to th e CCR, Title 14, Division 7, Chapter 3.1, Section 17852 (a)(10)(A)(2). In addition, foodwaste should be used for on-site composting within 48 hours of receipt or covered with screened or unscreened finished compost until used.

SCAQMD 14 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

For operations processing greenwaste only, greenwaste with up to 20 percent manure, by volume, or up to 5,000 tons per year of foodwaste throughput:

Allowance of Manure or Foodwaste

For the purpose of this propos ed rule, up to 20 percent manure, by volume, integrated into greenwaste is considered greenwaste composting. This percent limit has been already established in District Rule 1133.2 – Emission Reductions from CoComposting Operations (adopted in Janua ry 2003), because it was difficult for agricultural farm composters to comple tely separate horse manure from horse bedding materials for composting. However, other kinds of animal manure would also be allowed up to 20 percent, by pile volume, under PR 1133.3. More than 20 percent manure, by volume, would not be considered as greenwaste composting, but would be subject to Rule 1133.2 for co-compos ting operations. Up to 5,000 tons per year of foodwaste throughput can be com posted without the ne ed to install an emission control device. This proposed foodwaste throughput is on a facility-wide basis, and either source-separated or mi xed foodwaste is counted. Mixed foodwaste contains compostable material (e.g., compos table plastic bags, f ood-soiled packaging, papers, or other biodegradable material) and/or non-compostable solid waste (e.g., glass, cans, napkins, plastics including bags , containers or styrofoam). The annual throughput calculation may exclude any non-pu trescible materials, including, but not limited to, paper, woody, other low-wate r, high cellulose materials, and noncompostable contaminants and greenwaste th at are separated either before or after composting and shipped off-site for dis posal, provided they are quantified and appropriate records are maintained.

Foodwaste means any pre- and post-consumer food residuals collected from the food service industry, grocery stor es, or residential food scrap collection. There is no restriction on the recipes of foodwaste-to-greenwaste ratio.

Mitigation Measures: Finished Compost Cover and Watering

Every active phase pile is required to be covered with finished compost within 24 hours of initial pile formation such that the top is six inches thick and the pile is not turned for the first seven days of the activ e phase period of composting. Tests have shown the emissions primarily escape from th e top one third of th e pile. Having a six inch compost cover at the top ensures that th e pile is adequately covered and tapers as it goes down the pilesides. Thus, the applica tion is adequate to cover the top half of the pile where most emissions emanate.

Tests have shown that a vast majority of VOC emissions are extensively produced during the first 15 day active phase period of composting. In partic ular, the emissions tend to spike within the first three to seven days of the active phase of composting

and then diminish with time. Acco rding to a mitigation measure study 3 , about 53 percent of VOC emission reductions were ac hieved with six inches of finished compost layer applied upon ini tial pile formation and each subsequent turning during the first 22 day active phase composting. VOC is a biodegradable chemical and is adsorbed on the finished compost layer, and is further broken down by the microbes

SCAQMD 15 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

living on the surface of the finished com post. To minimize facility impacts, the compost cover is only proposed for initial pi le formation and the pile is not to be turned for seven days unless needed to manage temperature or for pathogen

reduction.

Additional watering is also proposed as a subsequent mitigation measure following finished compost cover to reduce VOC and ammonia emissions from turned compost piles. For the first 15 days after initial pile formation for the active phase period of composting, water is to be applied as necessa ry to the surface area of all active phase piles within six hours before s ubsequent turning such that the pile is wet to a depth of three inches. When applying water to the pile , the top one half of the pile needs to be wet down to a three inch depth. Alterna tively, the operator may apply water during turning using a windrow turner equipped with water spraying technology during the entire windrow turning process.

According to the composting mitigation measure study 3 , the surface irrigation could help reduce VOC emissions from greenwa ste compost piles by 24 percent. VOCemitted from composting of organic wastes consists of biodegradable and watersoluble light alcohols to some extent. VOC entrapped inside the pile as a result of biological decomposition of organic material is emitted to the air when the pile is turned. As water is applied to the surface area, the water layer of the pile absorbs water-soluble VOC and emission reductions occur. Because only the top three inches of the pile irrigated becomes wet, th ere would be no water run-off problems associated with additional watering. Sta ff also expects that excess moisture is evaporated while turning the piles and w ill not lead to oversaturation and leaching issues, as well as anaerobic condition issues.

If a rain event occurs prior to watering th e pile within six hours before turning and the pile is wet to a depth of three inches, th e operator may turn the pile without adding

additional water. It is recommended that the operator conduct a ball test using hand pressure. At least three inches depth from the peak of a pile , if the compostable material contains enough moisture to fo rm a ball when compressed by hand, but may break when tapped, within six hours before turning, no additional watering would be required. If the ball crumbles upon release of the hand pressure test, additional water would be required to apply to the pile unt il requirements are met. This may also apply to a normal operating c ondition. If the pile is sufficiently wet down to a three inch depth within six hours before tu rning during non-rain, normal operations, additional watering may not be required. If the pile needs to be turned within the first seven days for maintaining temperature at or above 131 degrees Fahrenheit for pathogen reduction pursuant to Title 14, Division 7, Chapter 3.1, Section 17868.3 of the CCR, the operator does not need to re-apply the finished compost cover and should apply additional water to the p ile as described in this section.

An alternate mitigation measure may be implemented by the operator, provided that the measure will be based on a test protocol approved by the Executive Officer,

California Air Resources Boar d, and the United States Environmental Protection Agency, and demonstrate emission reductions by at least 40 percent, by weight, for

SCAQMD 16 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

VOC and by at least 20 percent, by weight, for ammonia for combined finished compost cover and water application.

For operations processing greater than 5,000 tons per year of foodwaste throughput:

Emission Control Device

For greenwaste composting incorporating greater than 5,000 tons per year of foodwaste throughput (source-separated or mi xed) on a facility wide basis, the operator would be required to install an emission control device for any active phase composting pile containing foodwaste amount of 10 percent or more, by weight. The emission control device would be required to have an overall system control efficiency of at least 80 percent, by weight, each for VOC and ammonia. Such equipment is required only for the 22 day active phase period of composting and not required for the curing phase. At the end of the first 22 day active phase composting, emissions are diminished over 90 percent 4, 11, 12 . Thus, requiring such control device for curing phase would not add significan t emission reductions but may increase operational costs. The operator may implement a control alterna tive, if approved by the Executive Officer, California Air Resour ces Board, and the U.S. EPA, to achieve VOC and ammonia emission reductions equivale nt to or greater than the required

reductions.

Any emission control device should be desi gned and operated such that an overall control efficiency of at least 80 pe rcent is achieved for VOC and ammonia, respectively, from the baseline emission factors or alternate baseline emission factors. The overall control efficiency counts on both the capture efficiency and destruction efficiency.

Even if the actual annual f acility foodwaste throughput exceeds 5,000 tons per year, but the composting mix (or recipe) is less than 10 percent foodwaste, by weight, an emission control device would not be required.

Baseline Emission Factors

For the purpose of this rule, baseline emi ssion factors are proposed to determine an overall control efficiency of 80 percent fo r an emission control device. Baseline

emission factors are the uncontrolled emi ssion factors for greenwaste composting operations for VOC and ammonia. Propos ed baseline emission factors are 4.25 pounds of VOC per ton of throughput a nd 0.46 pounds of ammonia per ton of throughput for the active phase of composti ng only. Staff developed the composite emission factors by using currently availa ble emissions data measured by various agencies, including the District, state and other air distri cts for greenwaste composting operations typical for the South Coast jurisdiction. The proposed emission factors reflect only emissions fr om windrow composti ng operations and exclude stockpile emissions. Procedures for developing the new baseline emission factors are explained in detail in Appe ndix III – Emission Reductions and Cost

Effectiveness.

SCAQMD 17 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Permit Application

A permit would be required for an emission control device for all new and existing greenwaste composting operations processi ng greater than 5,000 t ons per year of foodwaste throughput (source-separated or mixed) and a foodwaste content containing 10 percent or more, by wei ght. All new greenwaste composting operations would be require d to obtain a permit for such equipment before construction. Existing greenwaste composti ng operations that, as of rule adoption, process or plan to process greater th an the foodwaste throughput and content

thresholds would also have to file a permit application fo r an emission control device

within three months of rule adoption and fully implement such device within six months upon approval of the permit applica tion. However, based on the information provided by the composting operation, in resp onse to the survey conducted by staff, there are no existing operations currently that ar e in excess of 5,000 t ons of foodwaste

per year.

Depending on the configuration of the emi ssion control device, controls may be accomplished with or without the need of ve nting the exhaust air to a separate air pollution control device, such as a biofilter. The configuration of such equipment

should be described in detail in the permit application.

Windrow composting does not require a pe rmit. The AQMD permit requirements are specified in Rules 201 and 203, with perm it exemptions specified in Rule 219. Generally, turning of a pile or windrow using DMV-registered motor vehicles does not require a permit. On-site equipment, such as dedicated mobile grinders and screeners, are already subject to permit from the District or ARB, but that is for the equipment or engine emissions only, not co mposting emissions. If a pile is aerated, the mechanical aeration system and its a ssociated emission c ontrol device would require a separate permit for each.

It should also be noted that dependi ng on the circumstances, new and existing composting facilities modifying their opera tion may also be subject to New Source Review requirements of Regulation XIII, in cluding BACT and offsets. New facilities with control devices permitted would be required to provide offsets for their full potential to emit, i.e. maximum after cont rol of emissions up to levels allowed by their permit. If they keep their permitted levels of controlled emissions below the 4 tons per year VOC threshold in Rule 1304(d) , they will be exempt from the offset requirement. For existing facilities, no offsets would be required, provided no

modification causes an increase in emissions. Even if the modifi cation would result in an increase in emissions, the facility c ould take advantage of the small business exemption if its total emissions remain unde r the 4 tons per year threshold. Also, existing facilities are only required to offset the increase in emissions, or the amount in excess of the thresholds, if their pre-modification potential to emit was less than the amounts in Rule 1304(d). For purposes of this calculation, LEA permit limits on throughput will be considered to limit the s ource’s pre-modification potential to emit. Existing facilities required to install controls trigger the permit requirement, in which case they will be eligible for the offset ex emption in Rule 1304(c)(4), provided there

SCAQMD 18 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

is no increase in maximum rating as established in the facility’s LEA permit, otherwise only the net increase above the maximum rating need be offset.

Source Testing

Under the proposed rule, all permitted emission control devices would be demonstrated through an approved source test for an overall contro l efficiency of at least 80 percent, by weight, for VOC and am monia emissions, respectively. Source

test needs to be conducted with in three months after start-up of the device, or within nine months of permit approval, whicheve r occurs sooner, and every three years thereafter. Existing device already tested would need to conduct future source tests every three years from the initial source test.

In the past, testing of biofilters has been re corded as costing several tens of thousands of dollars, but more recently there have also been full source tests performed for under $10,000. These tests have been su ccessfully approved by AQMD Source Testing and also successfully met the 80% requirements for VOC and ammonia. As an example of an acceptable test to demons trate and comply with PR 1133.3, a recent test on a biofilter for ammonia, VOC, as well as speciation testing by Method TO-15 and reporting was conducted for ~$10,000. Most of the past tests that have the higher

cost were research oriented tests that i nvolved several operating scenarios, were developing testing methods and technique s, were unique and difficult to test configurations, and/or included many sample s with no compositing done of any of the samples. As the testing firms gained experience with biofilter testing, and as more

testers have entered the market for co mpetition, the testing costs have gone down. Additionally, through experience in as sessing these processes, more effective methodologies have been developed fo r planning and executing testing.

Primary among the important f actors responsible for adequa te and lower cost testing is preliminary work to ensure representative samples, and the use of composite sampling. Biofilters tend, over time, to develop channeling and blockages to flow in

certain areas. In order to account for th ese phenomena and to ensure that higher concentration areas, as well as lower, are not excluded in testing, biofilter surface area is divided into imaginary grids. The EPA “Measurement of Gaseous Emission Rates from Land Surfaces Using an Emission Isolation Flux Chamber User’s Guide” provides equations that can be used to determine grid size and quantity of grid points. Using these points, screening is performed with a portable organi c vapor analyzer to determine the concentration profile of the biof ilter surface. Smoke testing can help to identify channeling also, though resolution is obviously more limited than organic analysis screening. With sc reening information, specific poi nts can be included in the actual testing to ensure that testing is representative. Often times, this screening can be used to reduce the number of sampling locations as would ot herwise be required by the EPA User’s Guide requirements. Compositing several sample points into one pair of sample canisters or impingers succeeds in reducing lab testing cost. Also, in

cases where biofilter in let ducting flow rate can be determined by a routine Method 1- 4 Pitot traverse, accuracy is increased while testing costs are decr eased by eliminating

SCAQMD 19 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

the need for flux chamber sweep gas. These measures, taken together, ensure not only a representative sampling, but also cost efficiency.

Operation and Maintenance

All permitted emission control devices should be installed, operated and maintained in accordance with the manufacturer’s ope ration and maintenance manual or other similar written materials supplied by the manufacturer or distributo r to ensure proper operating conditions.

Proper operation and maintenance would be required for an emission control system to ensure maximum emissions control. Installation, operation and maintenance should

be in accordance with the manufacturer’s operation and maintenance manual or other similar written guidelines supplied by the manufacturer or the distributor of an

emission control device to ensure that the control device remains in proper operating

condition.

Test Methods and Protocol

For operations subject to the requirements of an air pollution contro l device, the operator of a greenwaste composting operation would be required to conduct al l required source and laboratory tests using the Executive Offi cer approved test prot ocol developed in accordance with the guidelines provided in Attachment A of PR 1133.3. A District approved laboratory must be used for the associated tests.

Recordkeeping

All operational and informational records, including operation and maintenance of the aeration and control system and source tests, s hould be maintained for the prior five years of operation, with the most re cent two years retained at the facility, which shall be immediately available to the Executive Officer upon request. The remaining three years

of records shall be made available to the Executive Officer within one week of request.

Exemptions

• Composting facilities subject to Rule 1133.2 – Emission Reductions from CoComposting Operations, are exempt from the provisions of this rule.

• If the operator of any gr eenwaste composting operation voluntarily installs an emission control device, the provisions of additional irrigation and the finished compost cover and associated recordk eeping requirements do not apply.

• To be consistent with exemptions in Rule 1133 – Composting and Related Operations – General Administrative Requirements, the following type of facilities and operations are exempt fr om the provisions of PR 1133.3, provided that the operator is not subject to the Local Enforcement Agency Notification or Permit regulations pursuant to Title 14 Division 7, Chapter 3.1, Section 17857.1

of the CCR:

o Community composting

o Nursery composting

o Backyard composting

SCAQMD 20 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

o Recreational facility composting



### EMISSIONS INVENTORY AND REDUCTIONS

Affected Industry

Chipping and Grinding Industry Sector

For the purpose of PAR 1133.1, chipping and gri nding activity is defined as an activity that mechanically reduces the size of greenwaste, woodwaste, or foodwaste, using chippers and/or tub grinders . Chipping and grinding act ivities can be stand-alone operations, or part of multi-opera tion facilities, such as a tr ansfer station, a landfill, a material recovery operation, or a composti ng operation, that handle multiple incoming material streams with sepa rate operating areas within the same facility.

Chipping and grinding facilities process greenwaste, which is mostly collected from landscapers or from cities’ curbside collec tion programs. Curbside greenwaste is collected from receptacles designed for resi dential household greenwaste, and is mainly composed of grass clippings and weeds and may also contain other putrescible wastes (e.g., foodwaste). Non-curbside greenwaste is greenwaste that is not collected from curbside programs and mainly contains tr ee trimmings and other la ndscaping greenwaste. For the purpose of PAR 1133.1, the large woody material of tree trimmings exceeding two inches in any dimension is considered woodwaste.

District staff worked closely with stakehol ders and CalRecycle staff to estimate the

number of facilities that ha ve chipping and grinding oper ations. Table 1 shows the estimated number of chipping and grinding facilities. These facilities may be stand-alone facilities or co-located at MRFs, landfills or composting facilities.

There is a broad market for chipped or gr ound greenwaste where they can be used as mulch for landscaping, ADC at landfills, bi ofuels for energy production, feedstock for static pile or greenwaste composting opera tions, or bulking agents for manure and/or biosolids composting. All new and existing greenwaste chipping and grinding operations would be covered by PAR 1133.1. Agricultural chippi ng and grinding, woodwaste chipping and grinding, landcle aring chipping and grinding, palm chipping and grinding, and portable chipping and grinding activities would continue to be exempt from PAR

1133.1 and thus would not be affected.

Table 1. Estimated Number of Chipping and Grinding Facilities

County Number of

facilities Number of landfills (subset) Estimated landfill ADC throughput 1 (subset) (tons) Los Angeles 24 5 454,000 Orange 18 3 580,000

Riverside 17 3 103,000

San Bernardino 11 3 37,000

Total 70 14 1,174,000

1 2009 tons (source: Horowitz, CalRecycle).

SCAQMD 21 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Staff is appreciative of the input provided by the compost industry. Without adequate assistance from the compost industry stakeholde rs, staff would not be able to estimate or update the accurate greenwaste chipping and grinding throughput.

Greenwaste Composting Industry Sector

Staff developed an industry profile for the greenwaste composting operations based on

several resources. Those resources include the SWIS database, District Rule 1133 Registration/Annual Update database, the Dist rict’s Air Quality Notification Report, a District-wide composting survey (conducted in 2007), a supplemental questionnaire to augment the 2007 survey, site visits, phone ca lls/emails to the faci lity operators, and personal communications with CalRecycle and LEA staff.

Staff conducted a survey of greenwaste composting operations in the South Coast jurisdiction in 2007. The survey was conducted as a tool to update the inventory for the greenwaste composting industry relying on the extension of Rule 1133 Facility Registration. Initially, the survey focused on the facility total inco ming tonnage of green materials, along with operationa l practices (i.e., composting parameters). The surveyed facility total incoming throughput was 692,000 tons per year for 15 greenwaste composting facilities. The operational status of the facilities, the number of greenwaste composting facilities and act ual throughput for greenwaste composting operations was

refined for 2009–2010.

Currently, 17 facilities are identified as green waste composting facilities and their actual tons per year throughput for greenwaste composting are shown in Table 2. Actual greenwaste throughput for composting ope rations is about 416,300 tons for 2009–2010, which accounts for 58% of facility throughput tota ls for the same time period. About half of the 17 affected greenwaste composting facilities have multiple operations to produce materials other than compost, including, but not limited to, mulch, daily cover materials at landfills, biofuel for a biomass power generation facility, a nd palm feedstock.

Table 2. Number and Throughput of Aff ected Greenwaste Com posting Facilities

County Number of

facilities Facility throughput totals (tons/year) Throughput for composting (tons/year) Los Angeles 4 169,660 100,150 Orange 7 447,940 247,460

Riverside 4 93,220 60,830

San Bernardino 2 7,860 7,860

Totals 17 718,680 416,300

Emissions Inventory and Reductions

The emissions inventory for greenwaste com posting operations was developed based on the refined 2009–2010 activity data (i.e., act ual annual throughput of greenwaste processed for composting) and baseline em ission factors for windrow composting. The

baseline emission factors for both VOC and ammonia were developed based on the

SCAQMD 22 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

emission tests conducted by the District, ot her air districts, and CalRecycle for greenwaste windrow composting operations.

Windrow composting baseline (unc ontrolled) emissions are calc ulated for both the active and curing phases of composting, and thus emission factors used are 4.67 pounds per wet ton of throughput for VOC and 0.66 pounds pe r wet ton of throughput for ammonia, which includes emissions from the active and curing phases of composting. Total baseline emissions were then estimated by multiplying the total actual composting throughput by these emission factors. Howeve r, emission reductions were calculated only for the active phase of composting. Thus , emission factors for the active phase of composting are 4.25 pounds per wet ton for VOC and 0.46 pounds per wet ton for

ammonia. Emission reductions were calculated with the latter emission factors, as well as overall control efficiencies of mitigation measures.

Table 3 provides the emissions inventory fo r greenwaste composting operations, as well

as the emission reductions anticipated with the impl ementation of PR 1133.3. Calculation details are explained in Appe ndix III. As shown in Table 3, greenwaste composting operations generate significan t amount of VOC and fewer amounts of ammonia emissions in the Basin. Using th e baseline VOC emission factors and assumed percent emission reductions with the use of surface irrigation and finished compost cover during the 15 day active phase period of th e windrow composting process, 0.9 tons of VOC and 0.1 tons of ammonia are pr ojected to be reduced daily.

Table 3. Emissions Inventory and Emi ssion Reductions for Existing Greenwaste Composting Operations

VOC Ammonia Emissions Inventory (tons/day) 2.66 0.38 Proposed Requirements

Windrow composting operations (without emission control devices) 40% with compost cover and

water combined 20% with compost cover

and water combined Emissions Reduction (tons/day) 0.88 0.05



### COST EFFECTIVENESS

Cost effectiveness was analyzed, and is presented in Table 4, based on the total throughput of greenwaste processed for compos ting operations. Total compliance costs, being averaged per facility, are also presente d. The cost effectiveness would be $1,340 for ton of VOC-only emissions reduced and $1,270 for ton of VOC and ammonia

combined emissions reduced. This cost effectiveness was estimated based on the compliance costs calculated for finished compost cover and watering. According to the phone survey with the operators of affected composti ng facilities, some facilities use all potable water and the others us e all reclaimed or canal or we ll water. The different costs of potable or reclaimed, or other water use were reflected in the cost effectiveness

calculation. The total costs and assumptions used in this anal ysis are explained in detail in Appendix III. Costs are proportional to throughput of greenwaste processed and range from $700 to ~$200,000 per year depending on the facility. This figure is based on a compliance cost of $1.15 per ton of processed throughput.

SCAQMD 23 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Table 4. Greenwaste Composting Average Cost Effectiveness

Composting throughput (Tons/year) Number

of

facilities Mitigation

measure description Total annual compliance

costs (Avg. $/year) Cost

effectiveness for VOC only ($/ton) Cost

effectiveness for

VOC & NH 3 ($/ton)

416,300 17 Finished compost cover and watering

combined $29,000 $1,340 $1,270



### INCREMENTAL COST EFFECTIVENESS

Health and Safety Code Sect ion 40920.6 (a)(3) requir es the calculatio n of incremental cost effectiveness for potential control op tions, when the District adopts “rules or regulations to meet the requirements for best available retrofit control technology (BARCT) pursuant to Sections 40 918, 40919, 40920 and 40920.5, or for a feasible measure pursuant to Section 40914...” All of these referenced laws are contained in Chapter 10, which deals with district plans to “achieve and maintain state ambient air quality standards for ozone, carbon monoxide, su lfur dioxide and nitrogen dioxide...”

Incremental cost effectiveness is intended to measure the change in costs, in dollars per year, and emission reductions, in tons of VOC or ammoni a reduced per year, between two progressively more effec tive control technologies. In cremental cost effectiveness examines additional costs and emission reductions that can be achieved by adding a second level of control to the primary contro l. Because the incremental reductions from the controlled source operati ons are typically low, incr emental cost effectiveness produces a much higher cost-to- reduction ratio than the primary control and thus should not be compared to the cost effectiveness value. The use of an air pollution control device has long been concep tualized for composting invol ving foodwaste, but capital expenditures for low throughput facilities are co st-prohibitive. Therefore, staff proposes to require such controls for those facilities processing signif icant quantities of foodwaste (i.e., greater than 5,000 tons per year). No existing facility operati ons are expected to trigger this control re quirement, although it should be noted that two facilities are known presently to be in preparation to receive foodwaste in excess of 5,000 tons per year, but those facilities are already planning on air pollution control device installation.

Incremental costs and emission reductions were examined between the windrow composting with combined mitigation measures of finished compost cover and watering, and an emission control device required if th e facility receives more than 5,000 tons per year foodwaste and whose composting content exceeds 10 percent, by weight. A forced aeration system equipped with emission control is considered the t ypical emission control device for this comparison. The control device is assumed to have a lifetime of 10 years and an overall control efficiency of 80 pe rcent. Incremental costs and emission reductions were calculated for an operati on with 50,000 tons throughput per year.

Incremental costs were calculated to be $2,677,000 and incremental emission reductions were to be 420 tons (per 10 years) for VOC (480 tons for VOC and ammonia combined).

Incremental cost effectiveness was then ca lculated to be $6,600 per additional ton of VOC-only ($5,700 per additional ton of VOC and ammonia combined). As opposed to

SCAQMD 24 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

absolute cost effectiveness of using finish ed compost cover and watering for this 50,000 tons throughput operation, which was $1,340 per ton of VOC-only ($1,270 per ton of VOC and ammonia combined), incremental cost effectiveness was more than four times higher. High increases are caused by relativ ely high cost incremen ts, as opposed to the relatively small incremental emission reduc tions between the two control methods. Although $6,600 per ton incremental cost effectiv eness is in the range of other adopted rules, the operating margin for greenwaste com posting facilities is relatively low and with the seemingly high capital expenditure required fo r control equipment, the use of controls is not more widely proposed so as to not impact faci lity compliance/SB939 diversion goals.



### ENVIRONMENTAL ASSESSMENT

Pursuant to the California Environmental Quality Act (CEQA) and SCAQMD Rule 110, a Draft Environmental Assessment (DEA) has been prepared to analyze any potential adverse environmental impacts associated with PAR 1133.1 and PR 1133.3. The CEQA document was released for a 30 day public re view and comment on June 2, 2011, and is available at AQMD Headquarters, by calling the AQMD Public Information Center at (909) 396-2039, or by accessing AQMD’s CEQA website at: www.aqmd.gov/ceqa

. Close of the comment period is July 1, 2011.



### SOCIOECONOMIC ASSESSMENT

The Socioeconomic Analysis is being conducted and will be made ava ilable to the public at least 30 days prior to the Public Hearing.



### COMPARATIVE ANALYSIS

Health and Safety Code Section 40727.2 wa s added in 1997 as part of AB 1061 (Machado). The statute prescrib es the analysis that needs to be conducted to support a statutory mandated finding of non-duplication, which must be made by the district board prior to adopting, amending, or repealing a rule. The analys is requires an identification of “all existing federal air pol lution control requirements” including best available control technology (BACT) as well as “any existing or proposed [district] rules and regulations” that apply to the “same operations or source t ype” as proposed to be regulated by the rule. The District’s analysis must also examin e “all air pollution control requirements and guidelines” that the District is initially info rmed of by the public th at also apply to the same operations or source type.

AQMD Rule 403 – Fugitive Dust establishes the amount of PM entrained in the air as a result of man-made activity capable of generating fugitive dust. While PM emissions have not been measured from composting and related operations (e .g., chipping/grinding, screening, storing, etc.), gr eenwaste chipping and grinding operations subject to PAR 1133.1 and greenwaste composting operations s ubject to PR 1133.3 will also need to comply with Rule 403.

SCAQMD 25 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SCAQMD 26 July 2011 AQMD Rule 1133 – Greenwaste and Related Operations – General Administrative Requirement, is applied to chipping/grinding and composting faciliti es. It establishes one-time registration, along with one-tim e registration fee, and annual update requirements. Therefore, PAR 1133.1 and PR 1133.3 facilities continue to comply with

Rule 1133.

AQMD Rule 1133.1 – Chipping and Grinding Activities, establishes holding and processing time requirements for different t ypes of greenwaste and foodwaste to prevent inadvertent decomposition. Current Rule 1133. 1 currently allows holding times before being chipped or ground of 3 days for curbsi de, 14 days for non-curbside, and 7 days for mixed. However, the rule only requires thr ee-day retention time for curbside greenwaste after being chipped or ground, while there is no such holding time requirement for noncurbside and mixed chipped or ground gr eenwaste. PAR 1133.1 proposes to add the same 48 hours holding requirement all for cu rbside, non-curbside and mixed chipped and ground greenwaste.

AQMD Rule 1133.2 – Emission Reductions from Co-Composting Operations, is applied only to co-composting operations (biosolids an d/or manure mixed with bulking agents). It establishes control requirements for new and existing co-composting facilities. Rule 1133.2 facilities and operations are exempt from the requirements of PR 1133.3.

PR 1133.3 will add new requirements, and no conflict with existing requirements is anticipated.

Other federal, state and local requirements have been summarized on pages 5–7 of this staff report. Table 5 compares PAR 1133.1 and PR 1133.3 with the most relevant requirements of CCR Title 14.PAR 1133.1 and PR 1133.3Final Staff ReportTable 5. Comparison of State Regulation and District Proposed RulesTitle 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 1.GeneralSubdivisions(a) Purpose, (b) Applicability & (c) DefinitionsSubdivisions(a) Purpose, (b) Applicability & (c) DefinitionsSection17850Scope(c)Establishes standards andregulatory requirements forintentional and inadvertent composting resulting from thehandling of compostable materials, IBNLT feedstock,compost, or chipped and ground materialsPurpose(a)Prevent inadvertent decomposition occurringduring chipping andgrinding activities,including stockpile operationsPurpose(a)Reduce fugitive emissions of VOC andammonia occurring during greenwastecomposting operationApplicability(b)Operators of chippingand grinding activitiesto produce materials other than active orfinished compostApplicability(b)Operators of all new and existing greenwasteCST operations that produce active orfinished compost from greenwaste only orgreenwaste in combination with manure orfoodwasteDefinitionsSection17852Activecompost(a)(1)Compost feedstock:•Generating T at≥122 deg F; or•Releasing CO2≥15 mg/g compost/day, or theequivalent of O2 uptakeDefinitions:Activecompost(c)(1)•Material in the process of being rapidlydecomposed and is biologically unstable•Generates T at≥122 deg F•IBNLT pathogen-reduced mulchDefinitions:Activecompost(c)(1)•Material in the process of being rapidlydecomposed and is biologically unstable•Generates T at≥122 deg F•IBNLT pathogen-reduced mulchChippingand grindingoperationsand facilities(a)(10)An operation or facility that:•Donotproduce compost; or•Mechanically reduces the size; or otherwise•Engages in the handling ofcompostable materialChippingand grinding(c)(3)Any activity that mechanically reduces thesize of greenwaste, woodwaste, and/orfoodwasteActive phase(c)(2)Phase of the greenwaste CST process that:•Begins when organic waste materials aremixed together for composting; and•Lasts at least 22 days under controlledconditions, or•Until the compost has a SMI of 5 or higher(a)(10)(A)1.Handles only material, excluding manure, allowed at agreen material composting op. or fac. set forth in17852(a)(22)N/AN/A(a)(10)(A)2.•Each load of green material is removed from the sitewithin 48 hrs of receipt•The EA may allow a site tokeep it on-site for up to 7daysRefer to PAR 1133.1 RequirementsRefer to PR 1133.3 Requirements(a)(10)(B)If the contaminant limits in 17852(a)(21) are exceeded,shall be regulated as set forth transfer/processingrequirementsN/AN/A(a)(10)(C)If green material remains on-site for >48 hrs, shall beregulated as a compostable material handling operation orfacilityN/AN/ACompostablematerial(a)(11)Any organic material that when accumulated will becomeactive compostGreenwastecomposting(c)(13)•Composting of greenwaste by itself; or•Mixture with foodwaste or with up to 20%manure, by volumeCompostablematerialhandlingoperation orfacility(a)(12)An operation or facility that:•Processes, transfers, or stores compostable material,resulting in controlled biological decomposition•Handling includes composting, screening, chipping andgrinding, and storage activities related to the productionof compost, compost feedstocks, and chipped and groundmaterialsComposting(c)(6)A process that solid organic waste materialsare decomposed in the presence of oxygenthrough the action of bacteria and othermicroorganismsSCAQMD 28 July2011PAR 1133.1 and PR 1133.3Final Staff ReportTable 5. Comparison of State Regulationand District Proposed Rules (continued)Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 1.General (cont’d)Subdivision(c) DefinitionsSubdivision(C) DefinitionsDefinitionsSection17852Curing(a)(13)Final stage of the composting process:•Occurs after compost has undergone pathogen reduction& after most of the readily metabolized material has beendecomposed and stabilizedFinishedcompost(c)(7)Humus-like material that results from thecontrolled biological decomposition oforganic waste materials and is biologicallystableFinishedcompost(c)(10)•Humus-like material that results from thecontrolled biological decomposition oforganic waste materials and is biologicallystable•Both active and curing phases are requiredDisposal(a)(15)(A)Stockpiling of:•Compostable material onto land for a combined period oftime > 6 mos., or agricultural and green material for 12mos. on prime agricultural landN/ACuring phase(c)(7)Phase of the greenwaste CST process that:•Begins immediately after the end of theactive phase of composting; and•Lasts at least 40 days; or•Until the compost has a SMI of 7; or•Product respiration rate is < 10 mg of O2consumed per g of VS per day asmeasured by direct respirometry(a)(15)(B)Doesnotinclude the use of compostable material for ADCat a solid waste landfill (Title 27, section 20680)N/AN/A(a)(15)(C)Does not include land application of compostable organicmaterialLand application – application of compostable material(excl. food or mixed solid waste)to forest, agricultural, andrange land, I/A/W CDFA requirements for beneficial usesN/AN/AFeedstock(a)(19)•Any compostable material used in the production ofcompost or chipped and ground material IBNLTagricultural material, greenmaterial, food material,biosolids, and mixed solid waste•Additives or amendments arenot considered feedstocksStockpile(c)(17)•A supply of raw material tipped and storedprior to be utilized on-site or removedfrom the site•Raw materials before and after chippingand grinding are also includedN/AFoodmaterial(a)(20)Any material that:•Was acquired for animal or human consumption•Is separated from the municipal solid waste stream•Does not meet the definition of “agricultural material”•May include material from food facilities [H&SC113785], grocery stores, institutional cafeterias orresidential food scrap collectionFoodwaste(c)(8)•Any food scraps collected from the foodservice industry, grocery stores, orresidential food scrap collection•Includes food scraps that are chipped andgroundFoodwaste(c)(11)•Any pre- & post-consumer food scrapscollected from the food service industry,grocery stores, or residential food scrapcollection•Includes chipped and ground food scraps•SCAQMD 29 July2011PAR 1133.1 and PR 1133.3Final Staff ReportTable 5. Comparison of State Regulationand District Proposed Rules (continued)Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 1.General (cont’d)Subdivision(c) DefinitionsSubdivision(C) DefinitionsGreenmaterial(a)(21)Any plant material that is:•Separated at the point of generation•Contains no greater than 1% of physical contaminations,Wt.•IBNLT yard trimmings, untreated wood wastes, naturalfiber products, and C&D wood waste•Doesnotinclude food material, biosolids, mixed solidwaste, material processed from commingled collection,wood containing lead-based paint or wood preservative,mixed construction or mixed demolition debrisCurbsidegreenwaste(c)(5)•Collected from receptacles designated forresidential household greenwaste•Screened curbside greenwaste containingonly grass clippings, leaves, and/or twigsthat is not considered non-curbsidegreenwaste as defined in paragraph (c)(11)Mixedgreenwaste(c)(10)Curbside greenwaste comingled with noncurbsideNoncurbsidegreenwaste(c)(11)•Any greenwastenotcollected fromreceptacles designated for residentsCompostovers(c)(5)•Oversized woody materials that do notdecompose in a typical composting cycleand are screened out of finished product atthe end of composting•Have been through pathogen reductionprocess outlined in the Title 14, Section17868.3Compostovers(c)(7)•Oversized woody materials that do notdecompose in a typical composting cycleand are screened out of finished product atthe end of composting•Have been through pathogen reductionprocess outlined in the Title 14, Section17868.3Greenmaterialcompostingop. or fac.(a)(22)An operation or facility that:•Composts green material, additives, and/or amendments•May also handle manure or paper productsN/AN/AWoodwaste(a)(42)Solid waste consisting of wood pieces generated from:manufacturing or production ofwood products, harvesting,processing or storage of raw wood materials, or C&DactivitiesWoodwaste(c)(16)Lumber, and the woody material portion (> 2inches) of mixed demolition and constructionwastes, tree trimmings, branches, tree trunks,stumps, and limbsWoodwaste(c)(25)Lumber, and the woody material portion (> 2inches) of mixed demolition and constructionwastes, tree trimmings, branches, tree trunks,stumps, and limbsYardtrimmings(a)(43)Any wastes generated from themaintenance or alteration ofpublic, commercial or residential landscapes IBNLTyard clippings, leaves, tree trimmings, prunings, brush, andweedsGreenwaste(c)(7)•Any organic waste material generatedfrom gardening, agriculture, orlandscaping activities IBNLT grassclippings, leaves, tree and shrubtrimmings, and plant remains•Includes curbside, non-curbside, andmixed greenwasteGreenwaste(c)(12)Any organic waste material generated fromgardening, agriculture, or landscapingactivities IBNLT grass clippings, leaves, treeand shrub trimmings, and plant remainsSCAQMD 30 July2011PAR 1133.1 and PR 1133.3Final Staff ReportTable 5. Comparison of State Regulationand District Proposed Rules (continued)Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 2.Regulatory Tiers for Composting Operations and FacilitiesSubdivisions(f) ExemptionsSubdivisions(g) ExemptionsSection17854CompostingmaterialshandlingfacilitypermitAll compostable materials handling activities shall obtain aCompostable Materials Handling Facility PermitN/AN/ASection17855Excludedactivities•Agricultural material derived on-site and used on-site•Vermicomposting•Mushroom farming•Handling of green material, feedstock, additives,amendments, compost, or chipped and ground material,if:o≤500 cy is on-site at any one time;oCompostable materials* are generated on-site; ando≤1,000 cy of materials are either sold or given awayannually* Compostable material may include up to 10% food, vol.•Handling of compostable materials, if:oThe activity is co-located at a facility (i.e. landfill ortransfer/processing facility)that has a tiered or fullpermit as defined section 18101; etc.•Non-commercial composting with < 1 cy food materialgenerated and used on-site•Storage of bagged products (≤5 cy) from compostablematerial•Within-vessel compostingprocess < 50 cy capacity•Beneficial use of compostable materials IBNLT:oSlope stabilization, weed suppression, ADC, andsimilar uses, determined by the LEAoLand application [Food & Ag. Code 14501]oReclamation projects [Public Resrc. Code 2770]Exemptions(f)•Exempt from (d)(2) through (d)(4):oC/G activities of greenwaste derivedfrom the site and utilized on-site,provided < 1,000 cy of material is soldor given awayoPortable, agricultural, landclearing,woodwaste, and palm C/G activities•Chipped and ground curbside greenwaste:Exempt from the requirements ofparagraph (d)(2) provided that the MC is <30%, measured I/A/W subdivision (e) andthe MC measurements are maintained onsite in accordance with subparagraph(d)(4)(E)•The operator of a landfill or biomasspower generation facility: Exempt fromthe requirements of paragraph (d)(6),provided that the operator does notperform C/G of greenwaste on-site•The operator of a biomass powergeneration facility or a facility to producebiofuel for a biomass power generationfacility: Exempt from (d)(2), provided T is< 122 deg F. or MC is < 30%, measuredI/A/W subdivision (e) and the MCmeasurements are maintained on-site inaccordance with subparagraph (d)(4)(E)Exemptions(g)•Co-composting facilities (Rule 1133.2)•If the operator of any greenwastecomposting operation installs a forcedaeration system including an emissioncontrol device, I/A/W paragraphs (d)(3)through (d)(6), the provisions of paragraph(d)(2) do not apply•The following types of facilities andoperations, provided that the operationsare not subject to the LEA Notification orPermit regulations pursuant to Title 14Section 17851.1:oCommunity composting;oNursery composting;oBackyard composting; andoRecreational facility compostingSCAQMD 31 July2011PAR 1133.1 and PR 1133.3Final Staff ReportTable 5. Comparison of State Regulation and District Proposed Rules (continued)Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 2.Regulatory Tiers for CompostingOperations and Facilities (cont’d)Subdivision(d) RequirementsSubdivision(d) RequirementsSection17857.1Greenmaterialcompostingoperationsand facilities•EA Notification requirements:oHas > 12,500 cy of feedstock on-site at any one timeoInspection at least once every 3-months•Compostable Materials Handling Facility Permit:oHas > 12,500 cy of feedstock on-site at any one timeN/AN/AFoodmaterialMust have a composting operation or a transfer stationpermit to receive food material (per Horowitz,CalRecycle)N/AN/AFoodwaste(d)(1)Cannot take it unless allowed by the LEA tohandle foodwasteFoodwaste(d)(1)(B)•Use foodwaste for on-site compostingwithin 48 hours of receipt, or•Covered with screened or unscreenedfinished compos until used, unlessotherwise required by the LEASection17862.1Chippingand grindingoperationsand facilities•EA Notification requirements:oReceives up to 200 tpd•Registration Permit:oReceives > 200 tpd and up to 500 tpd•Compostable Materials Handling Facility Permit:oReceives > 500 tpd•A chip/grind operation isnotsubject to 17868.1 through3•If a chip/grind operation exceeds 1% contaminationlimits, it shall be regulated as set forth inTransfer/Processing Regulatory requirements•If a chip/grind operation stores material for > 48 hrs, thesite shall be regulated as a green material handlingoperation or facilityCurbside,noncurbside, andmixedgreenwaste(d)(2)Chip or grind and utilize on-site, or removefrom the site within 48 hours of receipt,excluding observance of official federal andstate holidays, or up to 7 days maximum,with approval from the LEAGreenwaste(d)(1)(A)Chip or grind, as necessary, and use for onsite composting as allowed by the LEASCAQMD 32 July2011PAR 1133.1 and PR 1133.3Final Staff ReportTable 5. Comparison of State Regulation and District Proposed Rules (continued)Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 8Composting Operation and FacilityRecordsSubdivisions(d) Requirements and (e) Moisture ContentSubdivision(f) RecordkeepingSection17869GeneralrecordkeepingrequirementsAll compostable materials handling operations andfacilities shall record the following:•Any special occurrences encountered during operationand methods used to resolve problems•Any public complaints, including:oThe nature of the complaint;oThe date the complaint was received;oThe name, address, and ph.# of the complainer; andoAny actions taken to respond to the complaint•The quantity and type of feedstock received and quantityof compost and chipped/ground material produced•Keep all records in one location and accessible for 5years and available for inspection by authorizedrepresentatives during normal working hours•The number of load checks and loads rejected•All test results IBNLT metal contaminations, fecalcoliforms/Salmonella sp. Densities, T measurements, &dates of windrow turningsoRetain records detailingpathogen reduction methods•Any serious injury to the public occurring on-site andany complaint of adverse health effects to the publicattributed to operationsRecordkeeping(d)(3)•Maintain all the operational records for theprior 5 yrs. of operation, with the mostrecent 2 yrs. retained at the facility, whichshall be immediately available uponrequest by the EO•Remaining 3 yrs. of records shall be madeavailable to the EO within 1 week ofrequestRecordkeeping(f)•Keep in a format approved by the EO•Maintain all operational records andinformation for the prior 5 years – themost recent 2 yrs. on-site and theremaining 3 yrs. available within 1 weekof requestRecords(d)(4)Maintain the following on-site for 2 years:•(A) AQMD registration and annualupdates•(B) Date, type, andamount of greenwasteand/or foodwaste received•(C) Date, type, amount of greenwasteand/or foodwaste removed from the sitelocation where they are transferred to•(D) Dates of rainy days and wet weatherconditions and description of specificconditions that limited normal operations•(E) T or MC measurements•(F) Dates and amount of curbsidegreenwaste chipped and groundN/ARainy daysand wetweatherconditions(d)(5)Time requirements in paragraph (d)(2) maybe extended by the number of rainy days andwet weather conditions that impede normalchipping and grinding operations providedthat records are maintained in accordancewith subparagraph (d)(4)(D)N/AMoisturecontentmeasurement(e)•Determine by collecting at least 10samples of chipped and ground greenwastefrom various locations of the pile•At a depth of at least 12 inches below pilesurface•Mix thoroughly and analyze for moisturecontent by ASTM method D4442, ASTMmethod D4444 or ASTM method E871-82SCAQMD 33 July2011PAR 1133.1 and PR 1133.3Final Staff ReportSCAQMD 34 July2011Table 5. Comparison of State Regulationand District Proposed Rules (continued)Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory RequirementsPAR 1133.1PR 1133.3Article 6.Composting Operation StandardsSection17867Generalrequirements•Random road checks;•Traffic flow and human access control;•Post legible signs at public entrances;•Fire prevention and control measures;•Ventilation of enclosed operations and facilities;•Leachate control;•Attendant on duty during business hours/open to public;•Prevent human injury, etc.N/AN/AArticle 7.Environmental Health StandardsSection17868.3Pathogenreduction•Operators that produce compost shall ensure thefollowing:oEnclosed or within-vessel, active compost:–Maintain T at≥131 deg F for 3 daysoWindrow composting, active compost:–Maintain T at≥131 deg F for 15 days or longer–Minimum of 5 turningsoAerated static pile, active compost:–Cover with 6–12 inches ofinsulating material–Maintain T at≥131 deg F for 3 days or longer•Alternative, equivalentpathogen reduction method•Monitoring during the pathogen reduction period:oEach day, at least one T reading per every 150 ftwindrow, or for every 200 cy of active compost–12–24 inches below the pile surface for windrowcomposting–12–18 inches below the point where the insulationcover meets the active compost for aerated staticpileN/AN/AAcronyms:ADC: alternative daily coverI/A/W: in accordance withCCR: California Code of RegulationsIBNLT: includes, butis not limited to; or including, but not limited toCDFA: California Department of Food andAgricultureLEA: Local Enforcement AgencyC&D: construction and demolitionMC: moisture contentCDI: construction, demolition, andinertPAR: Proposed Amended RuleC/G: chipping and grindingPR: Proposed RuleCST: compostingSMI: Solvita Maturity Index®EO: Executive OfficerT: temperaturePAR 1133.1 and PR 1133.3 Final Staff Report



### CONCLUSIONS

The proposed rules reflect reasonable, cost-eff ective mitigation measures for reductions in VOC and ammonia emissions from chipping and grinding, and greenwaste composting operations.

The proposed amendments to Rule 1133.1 would generate negligible compliance costs because they reflect existing requirements in Title 14 of the CCR. Although the proposed

amendments are more restrictiv e than existing Rule 1133.1, there would be no impacts, as the changes codify what the operators are doing now to comply with CCR, Title 14 requirements as enforced by the LEA.

Compliance costs associated with the implementation of PR 1133.3 would include the O&M costs for applying one-time fini shed compost and additional wa tering to compost piles during the first 15 days of th e active phase of composting. Costs for potable and reclaimed water, and labor were considered. Capital cost for the equipment to apply finished compost cover was not considered as such equipment already exists at the faciliti es. Total annual O&M costs range from $700 per facil ity to $200,000 per facility with a facility average of $29,000 per year. The compliance cost per ton of throughput is $1.15 per ton for adding an initial finished compost cover and watering before each turning.

Implementation of PR 1133.3 is estimated to reduce 0.9 tons of VOC and 0.1 tons of ammonia per day from 17 existi ng greenwaste composting facilitie s. Overall average cost effectiveness would be approximately $1,270 per ton of VOC and ammonia combined emissions reduced (or $1,340 per ton of VOC-only emissions reduced).

SCAQMD 35 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SCAQMD 36 July 2011 

### REFERENCES

1

. USEPA, 2008. Inventory of US Greenhouse Gas Emissions and Sinks: 1990–2006, EPA Report 430-R-08-005, U.S. Environmental Protection Agency, April 2008.

2. Brown, M.R, 2007. California links organics r ecycling to sustainabl e future. BioCycle, 48, 20–22.

3. SJVAPCD, 2010a. Comparison of Mitigation Measures for Reduction of Emissions Resulting from Greenwaste Composting, Pr oject 09-01 CCOS Draft Final Report.

4. CIWMB, 2007. Emissions Testing of Vola tile Organic Compounds from Greenwaste Composting at the Modesto Compost Facility in the San Joaquin Valley, Contractor’s Report to the California Integrated Waste Management Board, October 31, 2007.

5. CalRecycle, 2010. An Investigation of the Potential for Ground-Level Ozone Formation Resulting from Compost Facility Emissions, Contractor’s Report to the California Department of Resources Recycling and Recovery, December 2010.

6. Govind, R, 2009. Biofiltration: An Innovative Technology for the Future, PRD Tech, Inc. White Paper.

7. SCAQMD, 2003. Final Staff Report for Proposed Rule s1133, 1133.1 and 1133.2, South Air Quality Management District, January 2003.

8. Engineered Compost Systems (ECS), www.compostsystems.com/ac_composter.html

, accessed in 2010.

9. GORE® Cover, www.gore.com/en_xx/products/fabrics/swt/index.html , accessed in

2010.

10

. Managed Organic Recycling, Inc., www.odorfreecompost.com/topics/technology

, accessed in 2010.

11. SJVAPCD, 2010b. Compost VOC Emi ssion Factors, San Joaquin Valley Air Pollution Control District, September 15, 2010.

12. NorCal Waste Systems, 2006. Emissions Eval uation of Complete Compost Cycle VOC and Ammonia Emissions, Air Emissi ons Source Test Report, May 2006.PAR 1133.1 and PR 1133.3 Final Staff Report



### APPENDIX I – COMPOSTING PROCESS

This appendix describes basic steps and mana gement requirements for greenwaste composting operations. This part of the document includes discussion on the defini tion of composting, the typical greenwaste composting operation, and operating paramete rs of composting conditions taken into consideration for efficient composting operation.

Composting is a biological process where micr oorganisms decompose organic materials under

controlled environments. The readily available nutrients of the feedstock materials are consumed by microorganisms. Microorganis ms use carbon for energy and growth while nitrogen is essential for protein and reproduc tion. As a result of the decomposition by the microorganisms, the feedstock is reduced to about one-half of the original volume. Figure I-1 describes the composting process. In order for the microorganisms to function properly, enough moisture and oxygen are required, as well as a balance of nutrients.

Figure I-1. Composting Process 1

Greenwaste composting consists of three stag es: preprocessing, processing and postprocessing. Figure I-2 presents the flow of a t ypical greenwaste composting process.

Figure I-2. Flow of Typical Gr eenwaste Composting Operation 2

SCAQMD I-1 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

The preprocessing stage involves sorting and shredding (grinding and chipping) greenwaste

collected and unloaded. Af ter being preprocessed, greenwa ste undergoes active composting during which thermophilic microorganisms (or thermophiles) decompose the readily available nutrients. The curing stage takes place when materi als are stable, and the remaining nutrients are further degraded by mesophilic microorganisms (o r mesophiles) that are still present. The finished compost may be screen ed again before use as a soil amendment or conditioner during the postprocessing stage.

Preprocessing Stage

1. T he green materials should be first screened to get rid of uncompostable materials, such as plastic bags, and shredded to allow a la rge surface area on which the microorganisms can consume nutrients quickly and easily. The size of the shredded materials, however, should be large enough so as not to pack the materials too tightly, which limits the movement of air through the pile and thus may result in anaerobic conditions 2 . Although the material size varies, it generally ranges from 0.125 inch to 3.0 inches.

2. Once screened and shredded, water is added to the greenwaste to obtain the preferred

moisture content of 40% – 60% 2-7 . If the pile is too wet, dry materials are added to

decrease the moisture content or aeration is provided to evaporate excess water that may

result in anaerobic conditions.

Processing Stage

3. The feedstock is formed into windrows (for the turned windrow system). The ideal height of the windrow is 5–6 feet to allow the composting materials to be insulated properly but to prevent the buildup of excessive heat inside the pile. Windrow heights vary, however, based on the feedstock, the season, the region where the composting operation is being conducted, th e tendency of the materials to compact, and the turning equipment used 2 . Thus, windrows with leav es and tree trimmings te nd to have la rger pile dimensions than windrows of grass clippings with leaves. Windrow widths are generally twice the height of the pile.

4. Once windrows are formed, the active com posting begins. Active composting is characterized by high temperature, high level of oxygen demand and high evaporation rates due to temperature. There are several f actors that need to be controlled to optimize rapid, efficient microbial d ecomposition of greenwaste.

a. Temperature . During the active composting, ther mophiles play a dominant role in decomposing organic materials, which results in heating within the windrow. When the internal windrow temperatures exceed above 150 degrees Fahrenheit, most thermophiles will die and the rate of decomposition decreases. Thus, it is necessary to maintain temperatures between 110 a nd 150 degrees Fahrenheit for microbial activities by turning the windrows to remove excess heat. Maintaining temperatures between 120 and 140 degrees Fahrenheit is generally preferred. According to

literature 2, 8, 9 , the interior of composting windro ws should be maintained at 131

SCAQMD I-2 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

degrees Fahrenheit for at least three days for pathogen destruction and to kill weed seeds. The California Integrated Wast e Management Board (CIWMB) Regulations Title 14, Division 7, Chapter 3.1, Secti on 17868.3 (Pathogen Reduction) requires temperatures during active composting to be maintained at 131 de grees Fahrenheit or higher for 15 consecutive days for pathogen reduction.

b. Nutrients . The balance of the nutrients should be properly maintained for optimum composting. Too much grass clippings (i.e., high nitrogen content) tend to cause an anaerobic composting conditi on because of its high demand for oxygen, which results in greatly reducing the composting rate. The excess nitrogen may evolve as ammonia gas, leading to odor problems and loss of n itrogen in the compost. As a result, the internal windrow temperatures do not rise high enough, composting slows down, and uncompleted compost can be produced. If there are too little grass clippings but much woody materials (i.e., high carbon cont ent), the composting process also slows down due to lack of adequate nitrogen. Th erefore, it is nece ssary to balance the carbon and nitrogen. A carbon to nitrogen (C:N) ratio rang ing from 25:1 to 40:1 is reasonable for initial conditions, with a r ecommended C:N ratio of 30:1 for active composting 1, 3, 5, 9, 11 . C:N ratio decreases as decom position proceeds and the ratio in the finished compost is below 20:1.

Table I

- 1 lists some materials commonly used in making compost. A mix of one part grass to three parts leaves by volume is generally recomm ended for rapid composting. A volumetric ratio of one part wood chip: two parts leaves: one part grass is also good.

Table I-1. Commonly Used Raw Compost Materials 1, 8, 10-14

Material Characteristic C:N Ratio Bulking Agents

- W ood Chips • Low Moisture 700:1

- Sawdust • High Porosity 500:1

- Wheat Straw • Low Nitrogen 100-150:1

- Corn Stalks 60:1

- Leaves (Dry), Grass Hay 80:1 Energy Materials

- Grass Clippings • High Moisture 12-20:1

- Fresh Dairy, Chicken Manure • Low Porosity 15-18:1

- Garden Trimmings • High Nitrogen 19:1

Balanced Raw Materials

- Ground Tree and Shrub Trimmings • Low to Medium Moisture 16-53:1

- Horse Manure and Bedding • Medium Porosity 25-50:1

- Deciduous Leaves • Medium Nitrogen 40:1

- Legume Hay 25:1

c

. Oxygen . The feedstock should be maintained with a reasonable oxygen concentration for optimized microbial decomposition. Volatile organic compounds (VOCs) and ammonia (NH 3 ) are produced during the anaerobic decomposition of greenwaste. To

SCAQMD I-3 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

maintain aerobic composting conditions, windrows are turned with a front-end loader or a Scarab. The frequency of turning is determined by the wi ndrow size, feedstock composition, stage of decomposition and moisture content, and is adjusted so aerobic conditions are maintained, not providing t oo much aeration, which can dry out the pile and impede composting. The suggested range of oxygen content is generally above 5 percent.

d. Acidity/Alkalinity . It is common for the pH of th e feedstock materials to become slightly acidic (i.e., down to 5.0) during th e early stage of com posting due to organic acid formation. The pH then begins to rise to near neutral conditions (6.5–8.0), and the composting process is relatively insensitiv e to pH within this range. If the pH reaches 9, nitrogen is converted to ammoni a and becomes unavailable to organisms, resulting in a decomposition pr ocess that is too slow.

e. Moisture . According to several composting manuals 2-7, 9 , 40–60 percent of moisture content is reasonable for the optimum composting conditions throughout the process. If the moisture level drops below about 40%, the nutrients are no longer in an aqueous medium and are not easily available to the microorganisms. Their microbial activity then decreases, and the composting process slows. For very dry leaves, 20 gallons of water is required for each cubic ya rd of leaves. At a moisture level greater than 60 percent, porosity of the windrow decreases and air movement through void spaces will be impeded, which results in anaerobic conditions.

f. Material Size . Since decomposition occurs on material surfaces, degradability can be improved by reducing the material size (whi ch increases surface area) as long as porosity is not a problem. Good results are usually obtained when the material sizes range from 0.5 inch to 2.0 inches on average diameter.

5. The windrows are turned as frequently as required responding to the conditions within the composting windrows, and water is a dded when needed. Infrequent and prescheduled turning can develop odor problems. Internal windrow temperatures should be monitored daily, and windrows need to be turned when temperatures reach a predetermined point. Turning the piles incr eases the rate of d ecomposition by mixing materials and exposing new surface areas. The active composting phase should last at least 22 days. Completely processing greenwast e with frequent turning may take two to

four months. Based on the Dist rict staff report for Rule 1133.2 9 , 80 percent of VOC and 50 percent of NH 3 emissions are released during the 22-day active composting phase.

6. Once the greenwaste has been composted, curi ng should take place and the windrow no longer heats when being turned. During the curing stage, compost is stabilized as the remaining available nutrients are metaboli zed by the microorganisms that are still present, and the need for oxyge n and the evaporation rates decrease. While the curing stage may take another several weeks, it shou ld last at least 40 days during which 20 percent of VOC and 50 percent of NH 3 emissions are released 9

.

SCAQMD I-4 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Postprocessing Stage

7. Compost may be analyzed to ensure the stab ilization is complete. Compost also can be tested for chemical or pathogen contaminatio n and tested to dete rmine nutrient levels, cleansed of unwanted materials, sorted by size, size-reduced, blended with other materials, stored, and/or bagged.

Table I-2 summarizes troubleshooting and mana gement guide for greenwaste composting.

Table I-2. Troubleshooting and Manageme nt Guide for Composting Conditions 6

Condition Possible reason Other clues Remedy

Windrow fails to heat Materials too dry

Materials too wet

Not enough nitrogen

Poor structure

Cold weather and small pile

size

pH excessively low Cannot squeeze water from

material

Moisture content greater than

60%

C:N ratio greater than 50:1

Pile settles quickly

Windrow height less than

3.5 feet

pH less than 5.5 Add water

Add dry amendment

or remix

Add high-nitrogen ingredients

Add bulking agent

Enlarge or combine windrows; add highly degradable ingredients

Add lime or wood

ash and remix Temperature falls consistently over several days Low oxygen

Low moisture Temperature declines gradually

Cannot squeeze water from

material Turn windrow

Add water

Uneven temperatures or varying odors in windrow Poorly mixed materials

Uneven airflow

Materials at different stages of maturity Visible differences in the pile

moisture

Visible differences in the pile

moisture

Temperature varies along the pile length Turn or remix

windrow

Remix windrow

None required

Pile does not reheat after turning Composting nearing completion

Low moisture Approaching expected composting time period; adequate moisture level;

C:N ratio less than 20:1

Cannot squeeze water from

materials None required

Add water and remix

SCAQMD I-5 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Table I-2. Troubleshooting and Ma nagement Guide (continued)

Condition Possible reason Other clues Remedy
Pile overheating (temperature greater than 150 oF) Insufficient aeration for

heat removal

Moderate to low moisture

Pile is too large Pile is moist

Pile feels damp

Height great than 8 feet Turn pile

Add water

Decrease the pile size Extremely high temperature (greater than 170 oF in pile) Spontaneous combustion Low moisture content; pile

interior looks or smells charred Decrease pile size; maintain proper moisture content; add

water to charred sections; break down pile, combine with other piles High temperature or odors in curing or storage pile Compost is not stable

Piles are too large Short active composting period; temperature and odor change after mixing

Height greater than 8 feet; width greater than 20 feet Manage pile for temperature and odor control; turn piles as needed; limit pile

size

Decrease pile size

Ammonia odor coming from composting piles High nitrogen level

High pH

Slowly available carbon

source C:N ratio less than 20:1

pH greater than 8.0

Large woody particles; C:N

ratio less than 30:1 Add high carbon

amendments

Avoid alkaline ingredients

Increase the carbon proportion Odors generated only after turning Odorous raw materials

Insufficient aeration;

anaerobic interior High temperatures

Falling temperatures Frequent turnings; increase porosity; add odor-adsorbing

amendment

Shorten time interval between turnings; increase porosity Foul odor coming from composting piles continually Anaerobic conditions

Materials too wet

Poor structure

Pile compacted

Insufficient aeration

Anaerobic conditions Pile too large

Airflow uneven or short circuiting Low temperature

High temperature Add dry amendments

Add bulking agent

Remix pile and add bulking agent if

necessary

Turn pile more frequently

Decrease the pile size

Remix pile; change recipe

SCAQMD I-6 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Table I-2. Troubleshooting and Ma nagement Guide (continued)

Condition Possible reason Other clues Remedy
Fly or mosquito problems F lies breeding on compost piles

Flies breeding in raw

materials

Mosquito breeding in

stagnant water Flies hover around piles

Wet raw materials stored on site more than 4 days

Standing puddles of water Turn piles every 4 to 7 days

Handle raw materials promptly

Grade site properly

Compost contains clumps of materials and large particles; texture is not

uniform Poor mixing of materials or insufficient turning

Airflow uneven

Raw materials contain largeparticles and nondegradable or slowly degradable materials

Active composting not complete Original raw materials discernible in compost

Wet clumps of compost

Large, often woody, particles in

compost

Curing piles heat or develop

odors Screen compost; improve initial mixing

Screen or shred

compost

Screen compost; grind and/or sort raw

materials

Lengthen composting time or improve composting

conditions

Summary

Greenwaste composting is defined by an aer obic decomposition of green material by microorganisms. Temperature, moisture content, and oxygen level are key parameters that need to be controlled throughout the composting process to prevent anaerobic decomposition, which may result in emissions of NH 3 and VOCs that play an importa nt role in forming secondary particulate matter and ozone in the atmosphere.

SCAQMD I-7 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SCAQMD I-8 July 2011 References

1. Evanylo, G.K. et al. The Virginia Yard-Waste Management Manual . Virginia Polytechnic Institute and State University Virginia Cooperative Extension. 2003.

2. United States Environmental Protection Agency. Composting Yard Trimmings and Municipal Solid Waste . 1994.

3. Alberta Environment. Leaf and Yard Waste Composting Manual . 1999.

4. Alberta Environment. Mid-Scale Composting Manual . 1999.

5. Forgie, D.J.L., Sasser, L.W., and Neger, M.K. Compost Facility Requirements Guideline: How to Comply with Part 5 of th e Organic Matter Recycling Regulation . British Columbia.

2004.

6. Rynk, R. et al. On-Farm Composting Handbook . Northeast Regional Agricultural Engineering Service Cooperative Extension. 1992.

7. Gannet Fleming. Municipal Yard Waste Composting F acility Operator’s Reference Guide

and Handbook . Borough of Philipsburg, Centre County, Pennsylvania. 2001.

8. DSM. Yard Waste Composting: Operator Training Manual . DSM Environmental Services,

Inc. 2004.

9. SCAQMD. Final Staff Report for Proposed Rules 1133, 1133.1, and 1133.2 . South Coast Air Quality Management District. 2003.

10

. Cogger, C.G. and Sullivan, D.M. Backyard Composting . Washington State University Cooperative Extension. 2001.

11. Schneider, R.M. et al. Kentucky Composting Manual . Kentucky Department of

Environmental Protection Divi sion of Waste Management. 2001.

12. Washington State Department of Ecology. On-Farm Composting of Livestock Mortalities

. 2005.

13. Christian, A.H., Evanylo, G.K., and Pease, J.W. On-Farm Composting: A Guide to Principles, Planning and Operations . Virginia Polytechnic Inst itute and State University Virginia Cooperative Extension. 1997.

14. Canadian Organic Growers. Organic Field Crop Handbook . 2001.PAR 1133.1 and PR 1133.3 Final Staff Report



### APPENDIX II – EMISSION CONTROL TECHNOLOGY

This section summarizes advanced emission c ontrol technologies that are associated with requirements of PR 1133.3. Advanced emission control technologies ar e engineered control methods that include a covered aerated static pi le (ASP) composting system. These systems are commercially available and can be deployed by ve ndors. Brief descriptions of each system are given below. Inclusion of these vendors in this report does not im ply or serve as an endorsement of any vendor or product by the District.

Negative ASP System wi th Emission Controls

One of the covered ASP systems is the AC ComposterTM and CompDogTM (pipe-less aeration system) 1 , a covered negative-pressure ASP with bi ofilter provided by Engineered Compost Systems (ECS). A brief operational principle of this system follows. Once the feedstock mix is ready for placement in a windrow, an inflatable t ube is laid down where middle of the pile will be located. The mixed feedstock is then placed over the tube using a wheeled front-end loader,

allowed to settle around the tube for 12 to 24 hours, and covered with a waterproof tarp following the insertion of monito ring probes. The probes are linke d to a computer to monitor temperature and do not have moisture sensors on th em. The computer is capable of adjusting the air pressure to maintain proper aerobic composting conditions. After the compost settles, the

inflatable tube is deflated and removed from the pile, creating a ventilation tunnel through the pile. The tunnel is then closed at one end by filling it with feedstock from the pile and a ventilation pipe is inserted into the other end. The pi pe is connected to a blower that produces a negative air pressure, pulling air into the pile from the outside through sma ll holes in the tarp. As air is being drawn through the piles, it is sent to a biofilter composed of moist wood chips and compost. Pulled air is mixed with ambient air to reduce the temper ature of the exhaust air. As the air rises through the biofilter, it removes contaminants and odors through microbial action prior to releasing back to the atmosphere. Fi gure II-1 shows an encl osed negative ASP with biofilter composting system.

Figure II-1. Covered Negative-pressure ASP with Biofilter System

While the active composting process has three phases of approximately two-week period, the duration of each phase could be flexible. The first pile will compost for two weeks. At that end,

SCAQMD II-1 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

the tarp is removed and the pile is turned us ing a wheeled front-end load er into a new zone. Once the first pile is moved to the second zone, th e tarp and probes are placed again. This action occurs every two weeks over a si x-week period. When the com posting process is completed at the end of the sixth week, the fi nished compost may be relocated to a designated area for curing, as appropriate, for an additional four to eight we eks. All phases are covered and aerated, and the

exhaust air is vented to the biofilter.

Positive ASP System without Biofilter

The other type of covered ASP systems is the c overed positive-pressure AS P using a triple layer membrane compost cover. Since this type of technology pushes air into the pi le, it does not need

a biofilter. One kind of this covered, pos itive-pressure ASP t echnology is W.L. GORE & Associates’ GORE® Cover composting system 2 . The GORE® Cover utilizes composting with forced aeration coupled with a semi permeable membrane cover over the compostable pile. The piles are the same size in each of the three Phas es. GORE® Covers are used only in Phase I and II and are optional for Phase III. Each pile may have a concrete head wall to retain the material in each pile on the compost pad. Two aeration trenches are under each pile. These trenches serve as ducts to provide air to the pile and also to collect leachate coming from the pile. Each pile has a blower to provide air to the comp osting material via the aeration trenches. The trenches are cast in concrete to provide a solid impervious surface. The entire compost pad consists of a concrete slab or asphalt, which allows for the collection and separation of all storm

water and leachate.

The total composting process take s approximately eight (8) weeks. The compost pad is divided into three sections: Phase I (high rate com posting), Phase II (maturation) and Phase III (finishing). Material remains in the Phase I section for 4 weeks, followed by 2 weeks in the

Phase II section and 2 weeks in the Phase III sec tion. As the composting process proceeds, the

volume of material and mass of material is reduced through composting losses.

After a pile is built, the GORE® Cover is placed over the entire pile. A mobile winding machine

for installation and removal of the cover is availabl e. Once the cover is installed and secured in place, a weighting system (sand or water filled pipes) are placed at the edge of the cover and fixed in position to make an en closed system. Stainless stee l temperature and oxygen probes are installed through the co ver into the composting material. The blowers are controlled by a Programmable Logic Controller (PLC) to optimi ze the composting process using readings from temperature and oxygen sensor s under the cover. All data is collected in real time for monitoring and reporting purposes. Figure II-2 shows the general configuration of the GORE® Cover

compost system.

The GORE® Cover membrane is laminated betw een two polyester laye rs that selectively influence the treatment process. The membrane laminate tec hnology protects the compostable material from the penetration of rainwater a nd yet allows naturally occurring carbon dioxide produced during the composting process to escape. In addition, a fine film of condensation develops on the inside of the tarp covers dur ing the composting process, suppressing odors and other gaseous emissions. These gases are partly di ssolved in the film of water and drop back into the compostable material where they continue to be broken down by beneficial bacteria. The micro-porous structure of the GORE® Cover prevents the final product from being too wet, yet

SCAQMD II-2 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

at the same time ensures that there is sufficient moisture retained to allow the material to be decomposed.

Figure II-2. GORE® Cove r System Configuration

Another kind of this covered, positive-pressure ASP technologies is Managed Organic Recycling (MOR) composting cover system 3 . The MOR compost cover keeps odor, heat, microorganisms and some moisture contained, while releasing oxygen, bits of carbon monoxide and some moisture. This complex cover material allows th e covered piles to be c ontrolled with a blower fan, connected to a ventilated air hose snaking be neath the pile. The fan is necessary since the pile should never be cooler than 110 or warmer than 160 degrees Fahrenheit. The MOR compost

cover allows airflow to be decrea sed if the pile is not hot enough or increased if the pile begins getting too warm. This is done by adjusting the fan output using a torque timer. A torque timer can be set so the fan blows air throughout the pile every ten minutes and then stays off for ten minutes before turning on again. The timer can be adjusted to the setting that works best for the pile. The pile size, ingredients used, weather and life of the pile will di ctate the most suitable settings for a specific pile. Fi gure II-3 presents an example of MOR compost cover system.

SCAQMD II-3 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Figure II-3. Covered Positive-pr essurized MOR Compost Cover

References

1. Engineered Compost Systems (ECS), www.compostsystems.com/ac_composter.html

, accessed in 2010.

2. GORE® Cover, www.gore.com/en_xx/products/fabrics/swt/index.html , accessed in 2010.

3. Managed Organic Recycling, Inc., www.morcompost.com , accessed in 2010.

SCAQMD II-4 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report



### APPENDIX III – EMISSION REDUCT IONS AND COST EFFECTIVENESS

Emission Factors

Baseline emission factors were developed based on the emissions source tests c onducted by the SCAQMD, the state and other air district s from 2001 to 2009 for greenwaste composting windrows. The following emissions test results we re used in developing the baseline emission

factors.

Table III-1. Emission Tests Used to Develop the Baseline Emission Factors

Test facility Location Season samples taken Test

year Jurisdiction

Inland Empire Composting Facility Colton Fall 2001 SCAQMD Inland Empire Composting Facility Colton Winter 2001 SCAQMD Jepson Prairie Organics (JPO) Compost Facility Vacaville Summer 2005 Yolo-Solano (YS) AQMD Modesto Compost Facility Modesto Fall 2006 CIWMB

Site X Central Valley Spring 2008 SJVAPCD Zamora Compost Facility Zamora Spring 2009 YSAQMD

Staff reviewed the emissions source test results in Table III-1, and recommended as many of the emissions test results as possible to be included in developing the baseline composting emission factors that represent the types of composting that takes place in the South Coast jurisdiction.

Prior District emission factors included emissi ons from stockpiles, st atic piles and windrow composting combined. For PR 1133.3, VOC and ammonia emissions only from static pile and windrow composting operations were considered in developing baseline emission factors to calculate the emissions inventory. Static pile composting is a composting technique that is characterized by the absence of turning. The mate rial is placed into p iles where it decomposes over an extended period of time with no or little mixing. Oxyge n supply is passive; warm air leaving the pile at the top is re placed by air entering from the outsi de of the pile at the bottom. Composting is slow in static piles, and is often used to kill weed seeds prior to a land application, such as spreading on agricultural land.

Table III-2 shows windrow compos ting emission factors calculated from various emissions test data. Two Inland (SCAQMD) tests data were measured over the static and windrow phase compost piles, and other test data were measured over the active and curi ng phase compost piles.

Note that there are differences between the In land data and other air districts’ data. The

District’s Inland tests data can be considered as a snap shot of emissions because the calculation

is based on tests conducte d on specific days of the composti ng period. Other air districts’ test data were also measured on specific days during a full composting cycle and then total cumulative emissions were calculated for the full cycle period (days not sampled were interpolated). The Inland data has been included as it is relevant lo cal data. Using daily composting throughput, emission factors were weight ed to calculate composite emission factors.

SCAQMD III-1 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Table III-2. Composting Emission Factors

Site Sampling age of

material Season samples

taken Throughput (tons/day) VOC (lbs/wet ton) Ammonia (lbs/wet ton)

Inland Over the static and windrow phase Winter 307 1.56 0.26

Inland Fall 350 2.25 0.63

Modesto Over the active and curing phase (days not sampled were interpolated) Fall 103 0.85 Not Available

Site X Spring 200 6.30 2.34

JPO Summer 163 5.65 0.24

Zamora Spring 319 10.03 0.445 Weighted average emission factors 4.67 0.66

VOC emissions profiles were examined for greenwaste emission source tests conducted at Modesto, Zamora and JPO greenwaste compost facili ties. Emission source tests have shown that a vast majority (~90 percent) of VOC emissions are produced during the first 22 days of greenwaste composting (i.e., active phase) and a bout 70 percent of ammonia emissions emanate from the active phase period of greenwaste composting. VOC emissions tend to increase immediately after greenwaste is chipped or gr ound, typically with peaks during three to seven days, and then decrease sharply over time. Such emissions profiles are shown in Figures III-1

and III-2. Based on the cumulative emissions of VOC and ammonia during the active phase, it is assumed that VOC emissions during the active composting phase account for 91 percent of total cumulative emissions and ammonia emissions account for 70 percent of total cumulative emissions, respectively. Overall, the Distri ct’s proposed greenwaste composting operations

emission factors are shown in Table III-3. Fo r PR 1133.3, the total composting emission factors during the active and curing phase were used to refine the baseline ( uncontrolled) emissions inventory. However, emission reduc tions and cost effectiveness we re calculated using the active phase emission factors only, since the proposed m itigation measures are required only for the first 15 days of the active phase period of composting.

SCAQMD III-2 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Figure III-1. VOC Emissions Profile for Greenwaste Composting.

SCAQMD III-3 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Figure III-2. Ammonia Emissions Pr ofile for Greenwaste Composting.

Table III-3. Greenwaste Composting Baseline Emission Factors (EF)

Windrow composting EF (lbs/wet ton) Total composting EF

Active phase Curing phase (lbs/wet ton)

VOC 4.25 0.42 4.67

Ammonia 0.46 0.20 0.66

Emissions Inventory

Emissions can occur during chipping and grindi ng activities, stockpiling of chipped or ground greenwaste, and composting of chipped or grou nd greenwaste. Emissions during chipping and grinding have not been quantifie d as no data are available. Emissions during stockpiling are quantifiable, but are not quantified for the purpose of this rulemaking. PR 1133.3 requires removing the material from the site within 48 h ours of receipt or up to seven days maximum, with approval from the LEA, which is consistent with the Title 14 requirement. Staff determined

that there would be no emission reductions fr om stockpiling operations because the proposed

SCAQMD III-4 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

holding time requirement has already been esta blished in the state regulation. Composting emissions of chipped or ground greenwaste at facilities solely su bject to PR 1133.3 are quantifiable using composting throughput and the composite emission factors estimated in the previous section.

Initially 15 facilities were identified from a survey for greenwaste co mposting industry staff conducted in 2007 in the South Coast region. Operational status has been updated for 2009–

2010. Two facilities were found to be out of business and four facili ties were added. Seventeen facilities have been identified as subject to PR 1133.3. Baseline emissions inventory was developed using the baseline emission factors (i .e., total composting EF in Table III-3) and actual throughput of greenwaste processed for composting operatio ns for these 17 facilities. Table III-4 shows the baseline emissions inventory profile for these facilities.

As a whole, based on 365 days per year, the greenwaste composting operations produce approximately 2.66 tons of VOC em issions per day and 0.38 tons of ammonia emissions per day.

Table III-4. Greenwaste Composti ng Baseline Emissions Inventory

Total throughput (tons/year) Composting emission factor (lbs/wet ton) Baseline composting emissions (tons/year)

VOC Ammonia VOC Ammonia
416,300 4.67 0.66 972 137 Total emissions in tons per day 2.66 0.38

Among the existing 17 greenwaste composting facilities, 12 facilit ies produce annual VOC emissions from windrow composting operations exceed ing the ten tons per year potential-to-emit threshold for major sources as defined in District Rule 3001 relative to Clean Air Act, Title V, requirements. However, as windrow composting is not permitted and emissions are fugitive in nature, Title V does not apply in this case. The largest greenwaste composting facility is estimated to emit ~450 tons of VOC per ye ar from windrow composting operations.

Emission Reductions

PR 1133.3 would require mitigation measures, su ch as finished compost cover and water irrigation during the first 15 days of the activ e phase composting. The SJVAPCD contracted with San Diego State University for a study i nvestigating mitigation measures for compost

emissions reduction. The San Diego State University team conducted tests at the Tulare Composting and Biomass Facility in Tulare, CA . Mitigation measures tested included water irrigation and finished compost cover. Wate r irrigation was test ed on an active phase composting windrow and showed 24 percent reduc tions in VOC emissions during the 22 days active phase composting period. Another greenwas te pile was tested with finished compost cover. Finished compost was applied to the pile such that the top is six inches thick, after initial pile formation and after each turning during th e active phase composting, and showed 53 percent

reductions in VOC emissions. In an earlier Modesto compost study, about 75 percent VOC

reductions were achieved with six inches of finished compost cover. However, unlike the Tulare mitigation measure study in which the finished compost cover was applied repeatedly after turning during the 22 days active phase composti ng, finished compost cover was applied after

SCAQMD III-5 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

the initial pile formation and after the first turning only for the first 14 days of the active phase composting in the Modesto study. Therefore, Dist rict staff concluded that the SJVAPCD’s test results of control efficiency (i.e., 53 percent) would be more reflective of the control over the active phase composting period involving multiple turnings.

PR 1133.3 would require the operator to apply finished compost cover to the peak of the pile so that the top is six inches thick during the first seve n days after initial pile is formed, and then to apply water to the top half of the pile so that the top three inches of the pile is wet during the following eight days, which constitutes a total of the first 15 days of the active phase of composting. VOC emissions during the first 15 days of the active phase composting accounted for the majority (~87 percent) of total VOC emissions from composting. Weighted average control efficiency was calculated by multiplying cumulative emissions and control efficiencies of mitigation measures, as shown in Table III-5. The three different VOC emissions profiles shown in Figure III-1 and the two different ammonia emissions profiles shown in Figure III-2 were used in calculating the weighted average control efficiency.

Table III-5. Weighted Average Contro l Efficiency for VOC and Ammonia

Active phase VOC emissions rate (%) Control efficiency composting Modesto Zamora JPO Average Mitigation measures Composite - VOC First 7 days 61 59 89 70 53% - compost cover 41%* Following 8 days 24 24 4 17 24% - watering 15 days total 85 83 93 87 * Compost cover for the first 3 days and watering for the following 12 days yield 31% efficiency.

Active phase Ammonia emissions rate (%) Control efficiency composting Modesto Zamora JPO Average Mitigation measures Composite - NH 3 First 7 days N/A 36 26 31 53% - compost cover 23% ^ Following 8 days N/A 28 28 28 24% - watering 15 days total N/A 64 54 59

^ Compost cover for the first 3 days and watering for the following 12 days yield 17% efficiency.

Staff obtained site-specific information about the pathogen reduction process from greenwaste composting facilities. About half of the co mposting throughput begins the pathogen reduction process immediately after the initial pile is fo rmed. Composite control efficiency for VOC and

ammonia was calculated to be 31 and 17 percent, respectivel y. The site-specific control efficiency data were also used in calculating emission reductions that are shown in Table III-6.

In summary, the following facts and assumptions were made to calcula te emission reductions:

1. The existing facilities have open composting pile or windrow operations which have no emissions control device;

2. The VOC emissions factor for the active phase of the composting process is 4.25 lbs/ton of greenwaste throughput;

3. The VOC emissions factor for the curing phase of the composting process is 0.42 lbs/ton of greenwaste throughput;

4. The ammonia emission factor for the activ e phase of the composting process is 0.46 lbs/ton of greenwaste throughput;

SCAQMD III-6 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

5. The ammonia emission factor for the curing phase of the composting process is 0.20 lbs/ton of greenwaste throughput;

6. The VOC emissions during the first seven days of the active phase period of composting process account for 70 percent of total cumu lative emissions during the full composting cycle;

7. The VOC emissions during the following eigh t days of the active phase period account for 17 percent of total cumulative emissi ons during the full composting cycle;

8. The ammonia emissions during the first seve n days of the active phase period of composting process account for 31 percent of total cumulative emissions during the full composting cycle;

9. The ammonia emissions during the following eight days of the active phase period account for 28 percent of total cumulative em issions during the full composting cycle;

10

. The control efficiency of finished compost cover applied to the top of the active phase compost pile is 53 percent for VOC emissions based on the SJVAPCD’s mitigation measure study;

11. The control efficiency of water irrigation on the active phase compost pile is 24 percent for VOC emissions, based on the SJVAPCD’s mitigation measure study; and

12. The same control efficiencies of 24 percen t with water irrigation and 53 percent with finished compost cover as for VOC emissi ons can be applied for ammonia emissions.

With regard to Assumption #12, the control efficien cy with water irrigation and finished compost

cover was not evaluated for am monia in the original mitiga tion measures study. However, historically, District biofilter emissions test re sults have shown greater controls in ammonia emissions than VOC emissions. Finished compost is used as an element of biofilter media. Conservatively, finished compos t cover was assumed to have th e same 53 percent control for ammonia as was shown for VOCs. The 24 percen t control with water irrigation was achieved with multiple water irrigation. Considering a mmonia is a highly water-soluble gas, it was conservatively assumed that the water irrigati on had the equivalent control efficiency for

ammonia.

Staff calculated reductions based on 53 and 24 pe rcent control efficiencies with the proposed applications in PR 1133.3. Emission reductions (ER) are calculated by multiplying baseline (uncontrolled) emissions by an overall contro l efficiency using the following equation. Uncontrolled emissions are calculated by multip lying the amount of composting throughout by an emission factor (EF).

,

where EF is an emission factor for VOC or ammonia and control efficiency is an overall composite control efficiency. Since PR 1133.3 re quires that the finished compost cover and watering are applied only for the first 15 days of the active phase period of composting process, the reductions during the cu ring phase of composting are considered to be zero.

Table III-6 presents that with the implementa tion of PR 1133.3, 0.9 tons of VOC and 0.1 tons of ammonia are anticipated to be reduced per day from the existing 17 greenwaste composting facility operations.

SCAQMD III-7 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Table III-6. Greenwaste Com posting Emission Reductions

Mitigation measures (Active phase only) Throughput (tons/year) Number

of

facilities Baseline emissions (tons/day) Composite control efficiency (%) Emission reductions (tons/day)

VOC Ammonia VOC Ammonia VOC Ammonia Finished compost

cover and water 1 208,300 16 1.33 0.19 41% 23% 0.50 0.03

Finished compost

cover and water 2 208,000 1 1.33 0.19 31% 17% 0.38 0.02

Total 416,300 17 2.66 0.38 0.88 0.05

1 7 day retention prior to turning.

2 3 day retention prior to turning for pathogen reduction.

Compliance Costs

Compliance costs of PR 1133.3 were estimated base d on the proposed requirements of the rule. Under PR 1133.3, the operator of any greenwast e composting operation would be required to hold greenwaste materials as allowed by the LEA. This requirement is to harmonize the holding time requirement of the state regulation. Sinc e the removal requirement has already been established in the state regulati on, there would be no compliance cost s incurred with this material holding time requirement of PR 1133.3.

Compliance costs consist of one-time purchase costs of equipment and annual operation and maintenance (O&M) costs involv ing water irrigation and finish ed compost cover. PR 1133.3 requires only one time application of finished co mpost cover after an initial compost pile is formed. This can be done by existing equipment, such as a front-end loader or a skit loader, at the facility. Since facilities ar e assumed to already have turni ng machines for their composting operations, such as a wheeled front-end loader, additional purchase of such equipment is unnecessary and thus this equipment costs were excluded from this estimation. Therefore, compliance costs only involve annual operational co sts for water irrigation and finished compost cover. For the worst case, it was assumed that water is applied five ti mes to the compost pile.

Annual O&M costs would be incurred with the following proposed requirements:

• Si x inches of finished compost cover to th e top of the active phase compost piles; and

• Three inches watering to the top half of the active phase compost piles.

To estimate the annual O&M costs for each faci lity, the following assumptions were made:

1

. Compost pile:

a. Is trapezoidal in shape

b. Is 16 feet wide, 7 feet high and 200 feet long

c. Has four cubic yards per ton pile density

2. The unit cost of the potable water irrigation is assumed to be $0.40 per ton of throughput

and the unit cost of the reclaimed water ir rigation is assumed to be $0.29 per ton of throughput with the following assumptions;

a. Water use:

SCAQMD III-8 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

i. Pile management at 50 percent moistu re content corresponds to 45 percent average free air space

ii

. Wet piles assumed to be 75 percent moisture content, which corresponds to 23 percent average free air space, therefore the change in free air space of 22 percent

iii

. Amount of water applied for the worst cas e day to fill the free air space for a 3 inches pile depth corresponds to 19 gallons of water per ton throughput

iv. T otal volume of annual water use for 5 times watering is approximately 37 million gallons for 17 existing greenwaste composting facilities

b. P otable water for non-residential/landscap e purposes at a rate of $793 per acrefoot water (reclaimed water for irrigation is at a rate of $427 per acre-foot water)

c. 20 minutes are taken to irri gate 100 tons of windrow

d. Five turning events during the active phase

e. $10 per hour labor rate for irrigati on to a depth of three inches

3. The unit cost of the finished compost cover application is assumed to be $0.79 per ton of throughput from the Modesto/Bakersfield study with the following assumptions;

a. 15 minutes application time pe r 110 feet length of windrow

b. $180 per hour for equipment and oper ator with 50 percent overhead

c. One time application during the active phase

d. Four cubic yards per ton density

Staff calculated the potential water use associated with the requirement for water application to windrows before turning. Using the Science of Composting (E. Epstein, CRC Press, 1997), staff

was able to derive the free air space in a composting pile relative to moisture content. Based on the data provided in the reference, staff identified that average composting moisture content of 50% has an average free air space of 45%. Unde r PR 1133.3, the piles are to have water applied to make the piles “wet” before turning. Base d on comments received, “wet” material would have a moisture content of about 75%. According to the reference, this moisture content would have a free space of 23%. Assuming the material itself is saturated, the amount of water to be applied to make the material “wet” is repres ented by the difference in the moisture content (22%), thereby filling the free air space. Using the prescribed compost pile parameters, the maximum amount of water to be used in one year is approximately 37 million gallons. Using site specific information obtained from the 17 a ffected facilities, the worst case one-day water use would be about 106,000 gallons, of which ~55,400 gallons is potable and ~50,900 gallons is

reclaimed or untreated well or canal water. It should be noted that the facilities currently use more than 50 million gallons of water and th e operations may very well be adjusting the application times to accommodate the rule requirem ents. For example, watering the piles before turning as opposed to after could be employed th ereby minimize additional water use. It should also be pointed out that watering is only required to the extent the top 3 inches is wet, which may not require water application at all depending on the time of year and climatic conditions.

Using the above assumptions and actual throug hput, annual compliance costs are estimated as shown in Table III-7. Annual comp liance cost and total annual co st are the costs averaged over

all 17 affected facilities. Total annual compliance costs ra nge from $700 per facility to $215,800 per facility with a facility av erage of $29,000 per year. It shoul d be noted that the compliance cost-to-throughput ratio for each a ffected facility is calculated to be up to $1.15 per ton of

SCAQMD III-9 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SCAQMD III-10 July 2011 throughput for adding an initial finished compost cover and watering before each turning (based on weighted water source cost of $0.36 per t on and $0.79 per ton of throughput for adding one time finished compost cover).

Table III-7. Compliance Cost Estimates and Proposed Rule Requirement

Throughput (tons/year) Number

of

facilities Annual compliance

costs (Avg. $/year) Proposed rule requirement Total annual

costs (Avg. $/year)

416,300 17 $8,400 Finished compost cover $29,000 $20,600 Water irrigation

Cost Effectiveness

Cost effectiveness was calculated based on both VOC and ammonia combined emission reductions, and VOC-only emission reductions for windrow composting with finished compost cover followed by water irrigation.

Table III-8 summarizes greenwast e composting average cost effectiveness for VOC-only and for VOC and ammonia combined. Average cost effectiveness was estimated to be about $1,340 for ton of VOC-only emissions reduced and about $1,270 for ton of VOC and ammonia combined

emissions reduced.

Table III-8. Greenwaste Composting Av erage Cost Effectiveness (C-E)

Throughput (tons/year) Mitigation

measures (Active phase only) Total annual costs (Avg. $/year) Average C-E for VOC only ($/ton) Average C-E

for VOC & Ammonia ($/ton)

416,300 Finished compost cover

and water combined $29,000 $1,340 $1,270PAR 1133.1 and PR 1133.3 Final Staff Report



### APPENDIX IV – PUBLIC COMMENTS AND RESPONSES

This section summarizes comments received dur ing the public comment period ending February 23, 2011 associated with a Public Workshop and California Environmental Quality Act (CEQA) Scoping Session for Proposed Amended Rule (PAR) 1133.1 and Proposed Rule (PR) 1133.3 that was held on February 9, 2011. 15 comment letters were receive d, including U.S. EPA, CARB, and CalRecycle. These comments were reflected in the revised rule proposal for which another working group meeting was held on May 10, 2011, after which nine additional comment letters were received. Staff response to verbal and written comments, including e-mails, are summarized below by proposed rule subdivisions to which indi vidual comments are related. Similar comments on the same rule element were integrated into one single comment.



### February 23 rd 

### Public Workshop Comments (January 25, 2011 version of the rules)

US EPA Comments

Comment #1: We recommend the environmenta l impact analysis for the PR 1133.3 include consideration of: 1) groundw ater impacts where sprinkler irrigation is used; and 2) NOx and PM emissions that result from control measures.

Response #1: Groundwater impacts and NOx and PM emissions by proposed control

measures will be considered in the environmental impact analysis. The proposed rule would require mitigation measures using water irrigation and finished compost cover. Composting f acilities already apply water to their compost piles to maintain moisture level and additional watering only applies to

the first three inches of th e pile depth before turning. Therefore, the impact of watering on the groundwater would be neg ligible. The finished compost cover would only be required one tim e after the initial pile is formed. According to staff analysis of diesel emissions, NOx and PM emissions, as well as water use from this rule implementation ar e under the CEQA daily threshold.

Comment #2: Add a definition of the undefined term “finished compost.”

Response #2: Definition of finished compost has been added.

Comment #3: National policy discourages State Implementation Plan (SIP) provisions that allow AQMD discretion to independently modify SIP requirements (e.g., Clean Air Act Section 110(i), the Little Bluebook and 52 FR 45109, 11/24/87). EPA

recommends that the discretion be furt her limited by specifying the procedures that will be used to verify compliance with this section or by specifying that alternative mitigation measures will be base d on a test protocol that is approved AQMD, CARB “and” EPA.

Response #3: Staff revised the ru le language as recommended.

Comment #4: PR 1133.1 requires maintaining reco rds on-site for two years. To improve enforceability and greater consistency with Title V requirements, EPA recommends requiring that operators main tain these records for five years.

SCAQMD IV-1 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #4: Staff revised rule language that th e prior two year record s should be maintained on-site and the remaining three year r ecords would be available within one week of request (i.e., five years total).

Comment #5: Please remove or better justify th e 40-day limits in the definition of the curing phase of composting in PR 1133.3. Calif ornia, for example, defines curing composting only by pathogen reduction, as described in California Code of Regulations (CCR) Section 17868.3, and afte r most of the readily metabolized material has been decomposed and st abilized. See CCR, Title 14, Section 17852(a)(13).

Response #5: Definitions of the 22-day activ e composting and 40-day curing have already been established in District Rule 1133.2. These limits were supported by information found in EPA 503 regulati ons and other studies found in the literature of the Technology Assessment Report for Proposed Rule 1133 (dated March 22, 2002). Specifically, the 22- a nd 40-day limits are based on the

source test conducted for odor emissions.

Comment #6: In paragraph (c)(9) of PR 1133.3, foodwaste mixed with greenwaste is

considered foodwaste. This seems to c onflict with the meani ng of foodwaste in (d)(1) and (d)(2). For example, if any mixture of greenwaste and foodwaste is considered foodwaste as indicated in (c)( 9), then theoretically , “10% foodwaste, by weight” in (d)(1) and/or (d)(2) could contain up to 99% greenwaste. It may be helpful to distinguish between foodwas te (as defined in this section) and

waste from food material.

Response #6: The definition of foodwaste has be en modified. The sent ence that “Foodwaste mixed with greenwaste is considered foodwaste.” has been deleted.

Comment #7: Please consider clarifying the term “periodic basis.” Also, per California state law, it would appear that the minimum turns needed during the composting cycle is five. Please consider incl uding this requirement in the rule.

Response #7: The term “turned windrow” has been removed from this rule and thus

clarification is not needed. This rule no longer requires a specific type of composting system as a minimum requireme nt. The five times turning in the CCR is relative to pathogen reduction and may occur any time during the active or curing phase.

Comment #8: Please specify in the rule the specific temperature parameters that will be used.

Response #8: Temperature measurement is no longer required in this pr oposed rule. Rather, reference is made to temperature monitoring per CCR, Title 14.

Comment #9: Please clarify the basis of source testing every two year s in lieu of more frequent testing that is re quired of many other sources.

Response #9: Although the cost of source testing is not as expensive as commented from the public, considering those comments on the source testing frequency, staff revised the frequency from ev ery two years to every three years. This would be consistent with existing permitting practice.

SCAQMD IV-2 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Comment #10: Please clarify wh ether Attachment A of Rule 1133.2 is to be included in the State Implementation Plan (SIP). We be lieve it is appropriate to include this

attachment in Rule 1133.3.

Response #10: Attachment A of existing Rule 1133.2 has been previously approved into the SIP. However, this attachment has b een modified specific to PR 1133.3 and is

included within the rule. The attachme nt will be part of the SIP submittal.

Comment #11: Please list the applicable date s of those TMECC test methods for PR 1133.3. Please clarify the number of replicate sa mples needed for these test methods. We recommend averaging the results of three samples.

Response #11: The applicable dates of those TM ECC test methods are listed as recommended in the revised rule language. Staff a dded the requirement of triplicate samples

needed for the TMECC test methods.

Comment #12: Please consider adding size th resholds to the exemptions of Rule 1133.3, specifically community composting. It may be appropriate to apply some or all

of PR 1133.3 to facilities addres sed here that are very large.

Response #12: Staff added conditions to the exemption for the community composting – provided that the operati on is not subject to the Local Enforcement Agency Notification or Permit regulations pur suant to the CCR Title 14 Division 7, Chapter 3.1, Section 17857.1.

Comment #13: It is not clear why moisture content measurement requirements are needed relative to Rule 1133.1, except to exempt s ources pursuant to paragraph (f)(3). Please clarify whether there are additi onal instances that moisture content

measurements are needed. Please clarify the fre quency and time during the composting cycle when composting measurements will be taken.

Response #13: Moisture content measurement requ irements are also presented as a monitoring parameter to exempt a biomass power genera tion facility or a facility processing material as a biomass fuel for a biomass power generation facility from the holding time. The alternative parameter that the material temperature is below 122 degrees Fahrenheit is also provide d. Composting monitoring measurements

are not taken into consideration in PAR 1133.1. When moisture content measurements are taken, at least 10 sa mples of chipped and ground greenwaste

shall be taken from various locati ons of the pile on a given day.

Comment #14: Please indicate the rule vers ion, by year, of ASTM methods D4442 and D4444 that are cited in PAR 1133.1(e), and how the District would handle a situation

where the two moisture content test methods produce different results.

Response #14: The rule version of ASTM methods was indicated in the rule as recommended. ASTM method D4442 (Standard Test Me thod for Direct Moisture Content

Measurement of Wood and Wood-Base Materi als) is the method that is used as the reference for calibrating and standardizing a hand-he ld moisture meter (with D4444). A hand-held moisture meter can be used to measure moisture content, but since the meter produces relative readings, it should be calibrated by the method D4442. This being the case, if th e two methods differ in their results, D4442 takes precedence.

SCAQMD IV-3 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

CARB Comments

Comment #1: Table IV-2 of Appendix IV to the Preliminary Draft Staff Report mentioned that the average emission factors were determ ined by weighting the values based on greenwaste throughput. However, upon further evaluation of the document, the throughput values used to weigh the data are not included in the Appendix. We suggest including the throughputs for each composting operation so the reader can follow the calculation more clearly.

Response #1: As staff attempted to harmonize th e material holding time with the Title 14 requirement (i.e., to remove within 48 hours of receipt or up to seven days maximum), there would be no emission reductions quantified from the PAR 1133.1 requirements. Thus, staff decided to remove sections for stockpile baseline emissions and stockpile emi ssion reductions from the staff report.

Comment #2: In Table IV-2, it is not clear how the composite emission factor was calculated based on the average lbs/wet ton/day fact or. We recommend more calculations be added to improve clarity.

Response #2: The reader is referre d to Response #1 of this section.

Comment #3: The five facilities averaged together to obtain the stockpile and windrow emission factors are from throughout the state. Using the statewide average may artificially inflate the baseline for the South Coast because the South Coast values used in the average are on the low end for both the stockpiles and greenwaste. Is the assumption that the other greenwaste facilities in the South Coast region are less clean (from a VOC perspective) than the Inland Empire Composting Facility? We recommend that you explain the l ogic behind using a statewide average emission factor rather than the only data from the South Coast region.

Response #3: The emission factor from the In land Empire Composting Facility does not represent typical greenwaste composting operations currently being conducted in the South Coast region. Other air dist ricts also did not consider using this emission factor because they thought th at the emissions test was lacking in representing full life cycle emissions of VOC. The emission factors for the four (except Inland Empire) facilities are the cu rrently available set of data that are considered to represent greenwaste co mposting operations in the South Coast District. Therefore, the weighted emi ssion factor considers these four tests, along with the Inland Empire results.

SCAQMD IV-4 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

CalRecycle Comments

Comment #1: PAR 1133.1(d)(1)(A): Under existing state regulat ion, chip and grind sites which are not associated with a perm itted composting operation or transfer station may not accept foodwaste. Foodwaste is not an accept able material for landfill alternative cover or erosion control. Therefore, please delete this section or clarify that the chip or gri nd facility must have a transfer station permit in order to receive foodwaste.

Response #1: The rule language has been revise d such that foodwaste cannot be accepted at chipping and grinding facilities, unl ess otherwise allowed by the LEA.

Comment #2: PAR 1133.1(d)(1)(E): This section conflic ts with state regulation. Please

delete.

Response #2: Staff deleted this subparagraph as suggested.

Comment #3: PAR 1133.1(d)(3)(D): Records of ra iny days and wet weather conditions should only pertain to composting facilities.

Response #3: Although chipping and grinding operations can occur on rainy days, the original intention of this requirement was to allow additional time for chipping operations, if the normal operations are impeded by rain events and the operator cannot effectively remove the material w ithin 48 hours of receipt or up to seven days maximum, with approval from the LEA.

Comment #4: PAR 1133.1(d)(3)(E): Records of moisture content shou ld only pertain to biomass power generation facil ity stockpiles, as those fa cilities are exempt from Title 14 Division 4 Chapter 3.1 Section 17852 of the CCR. For stand-alone chip and grind facilities, there is no ex emption for moisture content in existing state regulations. For CD I facilities, the materials must remain under 122 degrees Fahrenheit at all times.

Response #4: An exclusion from material hol ding requirements has been added for biomass fuel material. The existing moisture content exemption relative to curbside greenwaste (i.e., grass and leaves) is not proposed for or within the scope of the

amendment.

Comment #5: PAR 1133.1(d)(4): Wet weather co nditions should not apply to non-compost facilities, as Title 14 Division 7 Chap ter 3.1 Section 17852(a)(10)(ii) of the CCR does not contain an exemption beyond 7 days for wet weather.

Response #5: This element is ne cessary for landfill operations.

Comment #6: PAR 1133.1(e): Moisture content measurement section should only apply to biomass power generation facility stockpiles.

Response #6: The reader is referre d to Response #4 of this section.

Comment #7: Why is foodwaste measured by we ight but manure measured by volume? It

would make sense to use the same sta ndard. Weight is straightforward to measure and less subjective.

SCAQMD IV-5 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #7: Manure measured by volume has b een established in District Rule 1133.2 relative to co-composting. The definition should be on a consistent basis with

that in Rule 1133.2 and Rule 1133.3.

Comment #8: There may be circumstances where a passively aerated static pile, such as one that has large pipes embedde d in it, could provide su fficient aeration to avoid

anaerobic conditions. Please consider al lowing passively aerated static piles when covered a pseudo-biofilter and pur suant to the approval of the APCO.

Response #8: Staff revised the proposed rule la nguage such that a minimum requirement for composting system design is no longer incl uded. That is, there is no limitation in the composting system. Operators can continue with their respective techniques for composting.

Comment #9: While 5% oxygen content is consid ered ideal, it is diffi cult to achieve in practice, particularly in actively deco mposing piles, where microbes consume oxygen rapidly. 5% oxygen will be nearly impossible to maintain without very frequent turning which probably result in huge increases in diesel and particulate matter (PM) emissions, and co sts from the turning operation. More likely, achieving 5% oxygen content will be impossible when a pile is covered with a 6 inch layer of finished compost. At a minimum, please remove the oxygen requirement during the time when a compost cap is app lied. We prefer you make the oxygen testing for informati onal purpose only, until such as time as we can be certain the instruments are reliable and an applicable standard can

be deduced.

Response #9: Staff agrees and has removed th is requirement from the proposed rule.

Comment #10: Please make an exception for opera tors who apply water during turning using a turner which is equipped with wa ter spraying technology. This best management practice wets the composting feedstock evenly and is expected to reduce emissions during turning. It also represents efficient water and diesel

fuel use.

Response #10: Staff added this suggestion to the rule.

Comment #11: Too many re-applic ations of the compost cap ar e impractical. Regulation does

not mandate Process to Further Reduce Pa thogens (PFRP) occu r during the first 22 days, but many operators prefer to doc ument their pathogen reduction early in the process, because the materials may not get hot enough later on. Applications of a thick blanket of mate rial could compromise operators’ ability to maintain sufficient temperatures during the legally required pathogen reduction period. Therefore, we recommend the following scheme:

1) Applying a 6 inch cap of overs if available and finished compost if overs are not available to initial windrow;

2) At the first turn, applying water for th e next five turns, if operator has begun pathogen reduction. If the ope rator turns but has not begun pathogen reduction, then they should re-apply the cap. Operators are already required to maintain a log of when pathogen reduction begins and ends; and

SCAQMD IV-6 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

3) When pathogen reduction is finished, the operator may apply one more cap of unscreened finished material s for additional clean air benefits.

Response #11: Staff is proposing to place the fini shed compost cover on the top of initial pile for the first seven days of the active pha se composting, during which the pile is to not be turned, and watering afterward to the surface of the pile within six hours before the initial and subsequent turnings during the remaining active phase period of composting. Please re fer to subparagraph (d)(2)(B) of the

revised PR 1133.3.

Comment #12: Please add a re quirement which suspends cap ping during the ozone season (from May 1 to October 1). The cappi ng operations are substantial, and the diesel equipment needed for these operations will result in NOx emissions. The ozone season coincides with periods of intense sunlight, hence ozone exceedences are very rare during the winter months.

Response #12: The revised rule no longer requires repeated capping of finished compost. Therefore, the requirement suggested for the ozone season is not needed.

Comment #13: Source testing for a large bi ofilter costs around $100,000 per occurrence; a twoyear frequency is not cost effective fo r an engineered system. Two reasonable methods for ensuring the efficacy of an in stalled biofilter are to place a limit on the shrinkage of the filter medium, or to conduct a smoke test every two years. With these suggestions in place, it would be reasonable to extend the time frame between source tests to 5 years or more.

Response #13: While there have been tests that ha ve cost as much as the amounts stated, most

of the tests conducted that cost that mu ch were research oriented tests that involved several operating scenarios, deve loping site-specifi c testing methods and techniques, or were unique and diffi cult to test configurations. As the testers gained experience with biofilter testing, and as more testers have entered the market for competition, testing costs have gone down. A test that recently took place on a greenwaste and foodwaste composting facility with a biofilter, was conducted for ~$10,000, including source testing and reporting. It is likely that this lower testing cost is more repres entative of those that will be available in the future, unless further competition drives that cost lower. In the PR 1133.3, staff revised the source testing frequency from every two years to every three years.

SCAQMD IV-7 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Public Comments on PAR 1133.1

(a ) Purpose

Comment #1: The primary goal of PAR 1133.1 shoul d match with that of PR 1133.3, which is reducing VOC and ammonia emissions from the regulated facilities. Activities permitted in this rule that do not promote emission reductions include the continuation of alternative daily cover (ADC) without restri ctions, and other practices in conflict with PR 1133.3 and other regulations.

Response #1: At landfills located in the South Coast jurisdicti on, ADC is placed as a cover

material onto the surface of a landfill each day, and is generally not stockpiled for longer than 48 hours. Their material holding time is consistent with the holding time required in PAR 1133.1 and state regulation, Title 14.

(c) Definition

Comment #1: Please add a definition of th e undetermined term “finished compost.”

Response #1: Staff added a definition of finished compost as suggested.

Comment #2: Chipping and grindi ng definitions, holding times, and foodwaste parameters

need to be consistent with PR 1133.3 and Title 14.

Response #2: Staff made some of the definitio ns and requirements consistent with PR 1133.3 and Title 14, such as “active compost” and “material holding time.”

Comment #3: Definition of “static pile” has no m eaning relative to “active compost” (in Title 14) which is defined by temperature in the pile, not processing method.

Response #3: Staff removed the term “static p ile” from the rule and refers to composting generically.

(d) Requirements

Holding Times

Comment #1: Stand alone chipping and grinding facilities (those not co-located at MRFs, transfer stations and/or landfills) are not allowed to handle source-separated food scraps without additional permitting. The requirements in PAR 1133.1 need to be consistent with, and at a minimum, not contradict with existing requirements for these types of facilities under Title 14.

Response #1: Staff modified the requirement such that foodwaste cannot be accepted at chipping and grinding facilities, unl ess otherwise allowed by the LEA.

Comment #2: Holding time requirements shou ld be made consistent between PAR 1133.1 and

PR 1133.3.

Response #2: Staff made holding time re quirements consistent as recommended.

SCAQMD IV-8 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Comment #3: Holding time requirement differs ba sed on the source of greenwaste. It should

be based on actual material moisture and nitrogen rather than on “source.”

Response #3: The rule no longer requires di fferent holding times based on the source of greenwaste, rather it requires the same 48 hours or up to seven days maximum holding time on any type of greenwaste, with approval from the LEA.

Comment #4: Rule should better de fine “used on site.” It should be clearly defined to mean

“utilized on site” and not “sto ckpiled.” If this rule is to reduce VOC emissions, the District should regulate how the material is handl ed once it arrives at its

destination within the District.

Response #4: Staff changed the rule language from “used on site” to “utilized on site.”

Comment #5: Under existing state regulation, chip and grind sites which are not associated with a permitted composting operation or transfer station may not accept foodwaste. Foodwaste is not an accepta ble material for landfill ADC or erosion control. Therefore, please delete this section or clarify that the chip and grind must have a transfer station permit in order to receive foodwaste.

Response #5: Staff made changes to the rule so that chip and gr ind sites cannot take foodwaste, unless otherwise allowed by the LEA.

Comment #6: The current rule allows various holding times based on the origin of green materials, which conflicts with existing state regulation requiring removal of materials from the site within 48 hours of receipt.

Response #6: Revised rule language is now ha rmonized with state regulation Title 14. Regardless of origin, greenwaste needs to be processed and removed within 48 hours of receipt or up to seven days ma ximum, with approval from the LEA.

Comment #7: Holding time for composters should be listed in PR 1133.3 for ease of understanding.

Response #7: Staff has specified the holding ti me requirement for composters as suggested.

Static Piles/Stockpile Operations

Comment #8: Under the current proposed rule, stockpiling green material effectively allows static pile composting at a non-permitted chipping and grinding facility, which conflicts with state regulations. Unde r Title 14, static pile composting would require a composting permit. Chipping a nd grinding operations are required to keep materials below 122 degrees Fahre nheit. Any green material achieving this temperature at a facility is c onsidered active composting and thus the facility would be required to obt ain a composting facility permit.

Response #8: Specification of stoc kpiling and static pile requirements were removed from the proposed rule provisions. This revise d proposed rule esse ntially applies to chipping and grinding activ ities to produce materials other than active or finished compost by means of any type of composting methods.

Comment #9: Static pile is a legitimate co mposting method, as decomposition of organic materials in the piles can reach the te mperature of composting allowed for under

SCAQMD IV-9 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Title 14, Section 17868.3. Therefore, it should be part of Rule 1133.3 and not

Rule 1133.1. PR 1133.3 should allow it to be used as a “partial composting” process with a broader range of retention times (for example, from 14-21 days) without the regulatory burdens of the full composting process.

Response #9: Static pile composting require ment was removed from PAR 1133.1. The PR 1133.3 no longer requires specific type of composting method and specifies BMPs for the active phase only.

Comment #10: Adding finished compost to a p ile of freshly ground material will assuredly cause the pile temperature to rise ab ove 122 degrees Fahren heit as the compost

will inoculate the new materials with additional microbes.

Response #10: Adding finished compost to a freshly ground green ma terial is no longer required under PAR 1133.1. Mitigation m easure requirements were deleted.

Comment #11: Stockpile operations for composters should be moved to PR 1133.3.

Response #11: The reader is referre d to Response #7 of this section.

Comment #12: The finished compost cover on ch ipped or ground greenwaste should be deleted and compost that is cured (low moisture ) should be allowed to remain on-site for as long as necessary.

Response #12: The finished compost cover requi rement was deleted and is no longer proposed in the revised PAR 1133.1. Stockpiling cu red compost on-site is out of scope

for PAR 1133.1 and PR 1133.3 does not lim it storage of finished (cured) compost as the process is complete.

Recordkeeping

Comment #13: Assuming that the landfill does not perform the chipping and grinding or composting onsite, rather the chipped gr eenwaste is brought to the landfill:

o Wi ll landfills be required to register and provide annual updates per Rule

1133? The intent of Rule 1133 reads to establish a registration process and database for composting and chippi ng and grinding facilities that are in the business of producing compost. It is suggested that landfills are exempt from this requirement since we are simply the end users of a product that is manufactur ed by other entities.

o The greenwaste is applied to the working face the day it is received. We

do not take moisture content measuremen ts. If the greenwaste is applied the day it is received, we are not sure what value these measurements would have. We suggest exempting this requirement for landfills that do not exceed the 3 day maximum storage time.

o At landfills, we are simply the customers receiving shipments of chipped greenwaste. We do not have informa tion as to whether the shipment of greenwaste originated from curbside , non-curbside, or mixed greenwaste

sources. That information would need to come from the product

manufacturer.

SCAQMD IV-10 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #13: Staff revised the language such that the operator of a landfill or biomass power generation facility would be exempt from the requirements of recordkeeping, provided that the operator does not perf orm chipping and grinding operations

on-site.

Wet Weather Conditions

Comment #14: Wet weather exclusions should be removed because chipping and grinding can be and is conducted during rainy periods , and Title 14 does not contain an exemption for wet weather.

Response #14: The reader is referred to Re sponses #3 and #5 of the CalRecycle Comments

section.

Moisture Content Measurement

Comment #15: Instead of ASTM tests of moistu re content, please allo w in-situ monitoring of moisture in the chipped and ground greenwaste pile using a soil moisture monitor probe.

Response #15: ASTM methods D4444 is the sta ndard test method for standardizing and calibrating hand-held moisture meter. A hand-held moisture meter should be calibrated by the method D4442. Therefor e, hand-held moisture meters are already allowed for use in the rule. The reader is also referred to Response #14

of the US EPA Comments section.

Comment #16: Further studies should be performed to determine if 30% is an appropriate value to retard decomposition and is achievable under cu rrent operation.

Response #16: The 30% level of moisture content has already been established in the previous rulemaking based on staff research. Decomposition of chipped green material is

retarded at below 30% moisture content. As an example, the moisture content of chipped green materials used as bioma ss fuel is maintained at less than 30 percent to avoid decomposition.

Miscellaneous

Comment #17: What if the ch ipping/grinding operation is co nducted on-site by an outside contractor that brings the equipment on site as needed; does the rule apply to the contractor operating the equipment or the facility operator at the site receiving the greenwaste?

Response #17: The facility operator is responsible for compliance with the rule holding time and processing requirements as they are receiving the material, contracting with those that bring the chi pping/grinding equipment on- site, and are therefore responsible for handling of the chi pped and/or ground material. The only exception is if the equipment meets the defi nition of portable equipment, that is equipment with a manufacturer’s rating of 170 brake hp or less, which is exempt under the rule.

SCAQMD IV-11 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Public Comments on PR 1133.3

General Comments

Comment #1: Explain the physical and time boundari es that were assumed when determining the centralized organics processing adverse impacts to the atmosphere, including all the transformations and ex changes that take place in the soil, terrestrial vegetation, and atmosphere over the life of the materials.

Response #1: Relative to the ru le proposal, emissions baselin e and reductions factored in emission profiles developed were based on full cycle composting. Conducting a life cycle analysis, as suggested, is outside the scope of analysis for this rule development effort.

Comment #2: Evaluate the imp act of this regulation on the carbon cycle. One benefit of composting is that it enriches the so il with carbon, increa se the soil’s carbon reserve, decreasing carbon available in the atmosphere.

Response #2: Evaluating the impact of this regulation on the carbon cycle is beyond the purpose and scope of this regula tion. Although composting is an environmentally favorable treatment met hod of recycling organic waste, it is also true that composting operations em it VOCs and ammonia that partake in the formation of ozone and fine particulates.

Comment #3: The District should promote altern ative organic residual processes such as backyard composting since it conserves and reduces energy and emissions by eliminating transportation and processing operations.

Response #3: The proposal does not alter exis ting exemptions for backyard composting.

Comment #4: We expect to see, in the so cio-economic analysis, a comprehensive whole systems analysis of costs and benefits , which includes economic assessments of soil amendment, fertilizer, energy produc tion and landfill uses of organics, using competitive tipping fees, competitive prices of products, and all current and proposed rule requirements affectin g: processing, operational, analytical testing, storage and marketing costs.

Response #4: The suggested micro systemic analys is requires tedious and costly construction of individual elements, which is beyond the scope of analysis the District staff performs in support of rule development. That being said, the data necessary or economic model for such micro analysis is not available and the suggested level of analysis cannot be done. Additional costs and benefits associated with the proposed rule relative to the existi ng four-county economy are assessed through the Regional Economy Modeling Inc. (REMI) PI + model for the total socioeconomic impacts of the proposed rule on affected fac ilities and the entire economy in the four-county region.

Comment #5: Consider composting as a VOC reduction technology for non-composted

material.

Response #5: The reader is referre d to Response #2 of this section.

SCAQMD IV-12 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

( c) Definitions

Comment #1: Greenwaste mixed with up to 20% manure is still defined as greenwaste.

Response #1: Staff disagrees. Greenwaste mean s organic waste material generated from gardening, agriculture, or landscaping ac tivities. Manure means excrement of animals, such as barnyard or stable dung, often with discarded animal bedding, and cannot be defined as green material . Up to 20 percent manure, by volume, is allowed to be composted with green waste for the purpose of greenwaste composting because it is difficult to co mpletely separate manure from animal bedding. This 20 percent allowance was already established in existing Rule 1133.2 – Emission Reductions from Co-Composting Operations.

Comment #2: Increase percent manure to 49 pe rcent for the greenwaste composting operations

to be more flexible.

Response #2: Requirements for greater than 20 percent manure, by volume, are already established as co-composting under Rule 1133.2.

(d) Requirements

Composting System

Comment #1: Static pile is another composting technique, just like a windrow. It must meet the same time and temperature requirements to make a compost product. The rule should allow both static pile and wi ndrow composters to continue with their respective techniques as there are fe w enough of both in the South Coast.

Response #1: The reader is referred to Res ponse #8 of the CalRecycle Comments section.

Comment #2: There is no basis for the exclusion of “passive pile” com posting (which is more commonly referred to as “static pile”). Static pile composting (which has limited turning) would not include these VOC releases and may in fact have

lower VOC emissions overall. Unless the District can provide research that shows that passive pile composting (not stockpiling) has larger uncontrolled emissions than windrows, passive pile or static pile co mposting should be

allowed under PR 1133.3.

Response #2: The reader is referred to Res ponse #8 of the CalRecycle Comments section.

Windrow Management

Comment #3: PR 1133.3 should not refer back to requirements in PAR 1133.1. If there are required holding times for composting faci lities, they can be listed in PR

1133.3.

Response #3: Staff revised rule language to list required holding times for composting facilities in PR 1133.3, not referring to PAR 1133.1.

Comment #4: Moisture meters currently on the market are generally developed for soil moisture and have limited utility with compost. The Rule should allow flexibility in how moisture is measured, such as the “squeeze test” used by

SCAQMD IV-13 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SJVAPCD in their Proposed Rule 4566 or using a Koster Moisture Tester without separate Executive Officer approval.

Response #4: Staff has concluded there is a lack of evidence that emissions will be negatively impacted if moisture falls below 40%. Thus, the moisture measurement is removed and no longer required in PR 1133.3.

Comment #5: Effective windrow compost operations have a track record of turning frequently enough to maintain adequate oxygen levels and to avoid anaerobic conditions. In fact, operators have an incentive to do so, since failing to do so would slow production and waste mone y. In addition, having a 5% oxygen

level has not been shown to reduce em issions and may be impractical to maintain without very frequent turning. Therefore, it seems unnecessary to add an oxygen monitoring requirement.

Response #5: The requirement has been deleted from PR 1133.3.

Mitigation Measures: Water Irrigation and Finished Compost Cover

Comment #6: The whole composting process shoul d be perceived as mitigation and the basis

of reduction should be from non-co mposted material processes.

Response #6: Staff agrees that composting is a process turning organic waste into a useful product. However, composting is still an emissive process. Those emissions may be inevitable, but staff believes su ch emissions could be reduced further with appropriate mitigation measures. Therefore, the reductions are measured from an uncontrolled composting pile as opposed to natural degradation.

Comment #7: The use of a finished compost cap should be encouraged when the material is available, but at the minimum both chi ppers and composters should be required to use water irrigation on the pile in the initial period after the greenwaste is first ground. This will lead to a “lev el playing field” fo r both chippers and composters and also control emissions at their most critical period.

Response #7: Requirements for both chippers and grinders will be handled separately in Rule 1133.1. The revised rule proposal has more stringent requirements for material holding time than the earlier version of the rule and conforms to the Title 14 state regulation.

Comment #8: There is no discussion present of the requirements for water application following rain events. Oversaturation of the materials has been previously identified as a poor management practi ce, potentially leading to anaerobic conditions. Additionally, conformance with Water Board regulations may preclude or limit over applicati on of water at compost sites.

Response #8: Staff added an excep tion for water application relati ve to a rain event in which the aim is to ensure wet material before turning without in discriminate water application.

Comment #9: We support the surface water applic ation as mitigation, but are concerned that the basis for the threshold being app lied (that is, based on throughput) is inappropriate. Please explain.

SCAQMD IV-14 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #9: Staff revised the rule language so that no threshold is imposed for the surface water application and water applies to every facility regardless of size.

Comment #10: By requiring the compost cap thro ughout the active phase process, the District Rule will necessitate the multiple handli ng of the same material. This will require an operator to emit more criteria pollutants from mobile sources. This practice could also have significant GHG impacts from the increased use of diesel fuel. We suggest the compost cap be removed from this rule until such

time as the District can demonstrate its cost-effectiveness as mitigation and that its use will not have an additive emission impact in other criteria pollutants such as particulate, GHG, and/or NOx.

Response #10: Staff revised the rule such that th e finished compost cover is required to apply to initial active piles only for the fi rst seven days of the active phase, and watering is required thereafter for the rema ining duration of the first 15 days of active phase composting. NOx and PM Emissions for finished compost cover are under the CEQA daily threshold.

Comment #11: Because there are relatively few em issions to control after the first two weeks, there should be no further reason to cap th e pile, and this w ill also lead the composters to believe that they are not being put at an economic disadvantage

to the shredders.

Response #11: The reader is referre d to Response #10 of this section.

Comment #12: Records already include pile moisture content for water. By adding “applications of water” make s the recordkeeping redundant.

Response #12: Revised rule language no longer requi res pile moisture content measurement. Applications of water to the active phase piles would be required the recordkeeping.

Forced Aeration System

Comment #13: We agree with the use of the fo rced aeration system in regards to the 10% foodwaste, by weight.

Response #13: Staff appreciates your support to the amount of foodwaste, by weight, to be composted with addition of an air pollu tion control device. However, staff decided to pursue a modified threshol d that combines the percent limit of

foodwaste with a facili ty-wide annual throughput.

Comment #14: It is not clear w hy the aerated static pile compos ting process is required for 10%

or more of foodwaste in th e system. It would be help ful to equate this to the

amount of VOCs are increased by the addition of foodwaste.

Response #14: Since food scraps contain a larger fraction of easily biode gradable and volatile material than greenwaste, composti ng foodwaste emits more VOC than composting greenwaste alone. In the Modesto study published by the CalRecycle in 2007, composting of 15% foodwaste windrow emitted as two-tothree times higher VOC emissions as composting of a greenwaste windrow

SCAQMD IV-15 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

without foodwaste. In addition to VOC emissions, decomposing putrescible foodwaste can cause odor problems.

Staff carefully investigated the curre nt foodwaste composting operations and decided to augment the 10 percent, by weight, foodwaste limit with actual

annual foodwaste threshold. Therefore, in the re vised rule language, an emission control technology meeting 80 pe rcent control would be required for any active phase pile containing foodwaste of 10 percent or mo re, if an operator intends to (or does) pro cess greater than 5,000 tons per year of foodwaste throughput (source-separated or mixed). Up to this throughput threshold, there is no percent restric tion of containing foodwaste in the greenwaste composting operations.

Comment #15: Compost emission factors are operation specific, a nd thus inappropriate to apply a universal emission factor to all operations.

Response #15: Staff agrees that emissions can vary. However, consistent testing on like operations can be conducted. Compost em issions can vary by conditions (e.g., feedstock) even for the same operation. This is why composite emission factors are developed from currently available emission tests conducted at respective composting facilities with similar oper ations in the South Coast District.

Comment #16: The mandated emission factor is set so high that vi rtually all of the 16 affected composting facilities’ and, particularly, future new composting facilities’ composting VOC emissions will certainly exceed the District’s significance threshold of 55 lbs/day. For instance, using the 55 lbs/da y threshold as the maximum mitigated VOC emissions, 80% mi tigation efficiency of the required forced aeration system, and the mandate d uncontrolled baseline emission factor of 4.67 lbs/ton, virtually no greenwaste com posting facility will be able to have a throughput of greater than 60 t ons per day without preparing an Environmental Impact Report under CEQA.

Response #16: The baseline emissi on factor of 4.67 lbs/ton fo r VOC is determined from emissions test data that are currently available from respective greenwaste composting operations that are represen tative of local operations. For the purpose of this rule effort, an emi ssion factor of 4.25 lbs VOC/ton throughput for the active phase only of composti ng would be consider ed. It should be

noted that this factor is for uncontrolled emissions in the absence of site-specific source tests. Source testing under the ru le relative to the emission control device will provide a more site-specifi c emission characterization. CEQA will not be triggered unless the facility makes a modification requiring a discretionary approval from a government agency.

Comment #17: The control efficiency of 80% by weight for VOC and ammonia emissions is not viable for biosolids composting operati ons. Since these operations have the potential to emit lower VOC and ammoni a emissions, a more reasonable and achievable control efficiency is 75%.

Response #17: Greenwaste composting operations have the potential to emit higher VOC

emissions and lower ammonia emissions than biosolids composting operations.

SCAQMD IV-16 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SCAQMD IV-17 July 2011 Recent source tests conducted for bios olids composting operations showed much higher control efficienci es than the required 80%.

Comment #18: The requirement of an 80% ove rall system control efficiency for VOC and ammonia seems high given the lack of ope rational data on the performance of aerated static pile (ASP) and biofilter systems for green material with more than 10% food scraps. Please provide more evidence that this is achievable in commercial application on the proposed regulated feedstocks (i.e., not biosolids).

Response #18: Emissions test data on the perfor mance of ASP and biofilter system for green material with food scraps is ava ilable. A commerc ial application 1 achieved 90% reduction in VOC emissions (as total hydrocarbon) for ASP and biofilter system composting 25% food scrap a nd 75% greenwaste. A different commercial application 2 of a forced aeration system using a fabric membrane cover has multiple data sets from demons tration projects and existing facilities showing more than 95% reduction in VOC and ammonia emissions from mix recipes up to 45% foodwaste by weight compost pile without the need for a

biofilter. As public and regulatory interest on foodwaste com posting is on the rise, staff expects additional emissions da ta to be collected on the performance of an emission control system for foodwas te windrow mixed with greenwaste in

the future.

Source Testing

Comment #19: The current methodology for s ource testing, flux chamber testing, is very expensive and not warranted for aerated st atic pile composting biofilters. The test costs between $50,000 and $100,000 per test. Testing at the initial

construction of the biofilter in addition to every two years is co st prohibitive. If an operator is adhering to best management practices as required in paragraph (d)(2)(H), and the equipment installation, maintenance and best management practices are documented, the testing will be redundant. Our recommendation

is that the District conduct a test with a portable flux chamber on the surface of

the biofilter within three months of the star t of operation. If at this time, or at any other time that a portable flux chamber is given, th e TNMNEHC is over 100 ppmv, a source test will be required. The portable flux chamber test can be required if nuisance complain ts demonstrate obvious ne glect or negligence by not adhering to best management practices.

Response #19: The reader is referred to Res ponse #13 of the CalRecycle Comments section.

Comment #20: Provide new source te st method for compost operations.

Response #20: The flux chamber test method, modi fied by the District, has been used to determine emissions from compost piles and biofilter controls. A new source

1 ECS, 2011. Comparison of Air Emissions from the ECS AC ComposterTM and Turned Windrow during Composting of a Food Waste and Green Waste Mixture. White Paper ACC-2.

2 Data available for GORE ® Cover can be requested by contacting W. L. Gore & Associates.PAR 1133.1 and PR 1133.3 Final Staff Report

test method is not required for compost operations, but staff will work with the industry if there are suggestions fo r new methods in the future.

(g) Exemptions

Comment #1: “Municipal composting” or “central ized composting” should be exempted. We believe that the benefit of centralized composting to soil, water, and air are much more preferable to the altern atives. Our mulch give-away program recycles organic residuals (25% of the City green residuals and 75% by contractors) through giveaways to resident s and farms. We operate at a fiscal deficit and any additional costs would make it more difficult to maintain our operations. Our vision is to increase our give-away program and recycle more

residuals back into the local communities.

Response #1: Municipal compos ting or centralized composti ng collects curbside and noncurbside greenwaste which are main components of greenwaste composting feedstock. Although the compost prod uct is given away to the local communities for free, the magnitude of the centralized composting would typically be large. T hus, staff did not add an exemption for centralized composting to PR 1133.3.

Comment #2: The type of community composting n eeds to be more fully defined in order to determine at what volume level they should be exempted from in this rulemaking.

Response #2: The proposed rule has been revised such that composting facilities as listed in paragraph (g)(3) are exempt, provided that the operation is not subject to the Local Enforcement Agency Notification or Permit regulations pursuant to Title 14 Division 7, Chapter 3.1, Section 17857.1 of the California Code of Regulations.

Miscellaneous

Comment #1: It is recommended that high so lids anaerobic diges tion (HSAD) would be classified as a pre-processing step fo r composting facilities. The organic material waste is digested in an enclosed unit. The resulting material (a combination of green and food) can be tr ansferred to a compos t facility. These units are enclosed, and are also designed to include enclosure for the delivery of undigested materials.

Response #1: Under this proposed rule, composting is limited to be aerobic decomposition of organic waste material. Currently, an aerobic digestion (AD) is not being considered as an option of composting or ganic materials. Considering growing interest to the AD system, however, sta ff may examine the AD system as a preprocessing technology for composting processes.

SCAQMD IV-18 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Comments on Preliminary Draft Staff Report

Comment #1: Landfill gas recovery systems (in the remaining states) have little impact on

VOC emissions from ADC or beneficial reuse, mainly due to the lag time between the disposal time and their in stallation. Additionally, the lengthy residence time allowed for processed organic materials at landfills in this draft rule is inadequate given that over twice as much material is used for ADC as is composted in the Basin.

Response #1: The statement of the landfill gas r ecovery systems in the remaining states was

deleted. Landfills in South Coast have been controlled for VOCs and methane for decades. In addition, ADC materials must be applied to the landfill surface at the end of the operating day pursuant to Title 27 of California Code of Regulations.

Comment #2: Recycled water is not availabl e in all places, and many composters may be reluctant to use it because it generally co ntains higher levels of salt. Salt build up is a concern, particularly in foodwaste and manure composting, but also with greenwaste. Furthermore, once com post has passed the pathogen reduction stage, untreated surface water cannot be used for irrigation of piles.

Response #2: According to the existing composting facility operators, so me facilities use all potable water and others use all reclaimed or canal water. Salt content has not

been raised as a relevant local issu e, as it pertains the watering BMP.

Comment #3: CalRecycle recently completed emissions research using “overs” (by-product of finished compost screening) as a ps eudo-biofilter compost cap. Overs are similar to biofilter material, and were effective in reducing ozone formation from composting emissions.

Response #3: The definition of “finished compos t” has been revised so that “compost overs” are included. Finished compost can be screened or unscreened, humus-like material and/or compost overs that have gone through pathogen-reduction period.

Comment #4: Both the finished compost cap and irrigation measures propos ed will impact the potential air movement and moisture content and increase the potential for anaerobic sections to exist, thus generating increased GHGs.

Response #4: A finished compost cap is now required to be applied only one time after initial pile formation for the first seven days of the active phase. Irrigation is only required so that the three inches in dept h of piles are wet. Staff expects excess moisture is also evaporated while tu rning the piles and will not lead to oversaturation and leaching issues. Thus , both measures would not increase the potential for anaerobic sections to develop.

Comment #5: The application of finished com post was evaluated to the top surface of the windrow only. A more robust description of the compost cover requirement is needed to evaluate the proper applica tion and amount of materials and labor needed to apply it.

SCAQMD IV-19 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #5: The proposal requires the compost cove r such that the top is covered to a depth of six inches, and ta pers off as it goes down the pile sides. Thus, the application is adequate to cover the top half of the pile where most emissions emanate.

Comment #6: The highest costs to apply the cover involve the lost sales of materials used for the compost cover and the potential lo ss of operating space between windrows

in order to allow the use of a front-end loader to access the windrows. Windrow composting operations generally have 8 to 10 feet spacing between windrows; a

loader would need more than twice that spacing in order to effectively

maneuver between windrows in order to a pply a compost cover. The amount of increased loader activity – in addition to other equipment to handle the compost cover application materials – will produ ce significant increase NOx emissions.

These increased NOx emissions have not been assessed.

Response #6: The proposed rule has been revised in response to this comment. The revised rule language only requires one-time finish ed compost cover application which, based on the staff assessment, would not produce significant increased NOx emissions, loss of production, or loss of operating space.

Comment #7: In the Modesto Compost Study co mpleted in 2006 by the CIWMB, the use of two compost inoculants reduced VOC em issions by 42% in the first week and 14% for the first two weeks, but one of the additives was not re-applied in the second week. The specific products used in the Modesto study were GOC technologies formulas ASC 2500 and ASC 2600 . The former is a topical spray applied to windrows. The latter is mi xed into a new batch of materials. Because there are many makers of inoculants and other compost “starters,” and because rapid composting is beneficial for air quality, we urge you to include additives as a potential mitigation measur e in your rule, and to allow additive

manufacturers to submit research demons trating the efficacy of their products.

Response #7: Studies of the control efficiency of the chemical additives are limited and thus more research is needed for the efficacy prior to being considered as a VOC emissions mitigation measure under PR 1133.3.

Comment #8: Data from SWIS is often misinter preted, and Table 1 is misleading. The most recent CIWMB survey of the compost and mulch infrastructure statewide estimates about 9.3 million tons of composta ble materials are handled statewide. Significant portions of these materials ar e handled in the Central Valley and in the Bay Area. 17 million tons in the four-county SCAQMD area is not plausible. We believe th e District has the data, th rough Rule 1133, to formulate

a more reasonable estimate.

Response #8: Staff agrees that the initial es timated chipping and grinding throughput needs more work and attempted to update the throughput number. Furthermore, staff requested industry stakeholders and Ca lRecycle assistance to provide countylevel aggregated chipping and grindi ng throughput data. Although CalRecycle approved sharing county-specific data, confidentiality concerns prevented

transmittal of the information. Staff w ill continue to work to refine this

information.

SCAQMD IV-20 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Comment #9: The Preliminary Draft Staff Report fails to adequately analyzed the importance of the chip and grind process as a firs t step in quantifying air pollutants and reducing emissions during the initial firs t few days of organics processing. About 10% of the greenwaste processed is used for compost, and remaining 90% is used for mulches, boiler-fuel, ADC, and other end product application. It seems important for the District sta ff to first consider focusing on chip and grind processing to achieve the highest level of emission reductions before any attempt is made to reduce air quality emissions from composting. We would like to assist the District staff by ha ving meetings with staff to discuss an accurate baseline inventory, appropriate emission reduction measures and strategies, permitting, source testing, etc.

Response #9: Staff appreciated the opportunity to meet with industry st akeholders to discuss the above-mentioned issues. With input fr om the stakeholders, staff was able to improve rule language and data, but even industry representative had difficulty obtaining facility throughput data. Staff’s efforts in this area will continue after Board consideration of the existing proposal.

Comment #10: All facilities receiving greenwaste should be included within PAR 1133.1, even

where woodwaste is the dominant share. The greenwaste fraction at these chipping and grinding facilities should be managed according to the adopted rules, while the woodwaste coul d continue to be exempted.

Response #10: The operator of any greenwaste ch ipping and grinding would be subject to PAR 1133.1. If chipping and grinding takes pl ace at a composting facility or colocated landfill or material recovery facility, the operator would be subject to PAR 1133.1, provided that the chipped ma terials are used for purposes other than composting. Woodwaste chipping a nd grinding continues to be exempt

from PAR 1133.1.

Comment #11: The throughput numbers of landfills are inaccurate and should be revised. CalRecycle website reports show that less than 1,000,000 tons were used asADC at landfills within the District. We estimate that quite a bit less than onehalf of that amosunt is being composted.

Response #11: Staff revised the throughput numbers for landfills.

Comment #12: Throughput number s of greenwaste composting s hould be revised to reflect

accurate totals.

Response #12: Throughput numbers of greenwaste composting have been revised based on a supplemental questionnaire to reflect more current information. Staff appreciates all the greenwaste composti ng operators who part icipated in the supplemental survey.

Comment #13: Greenwaste being composted is a minor source of VOC emissions versus the vast majority of VOC resulting from green materials being processed in the District. VOC emissions from green ma terial have peaks immediately after grinding, trailing off over time. It is unfair putting the bulk of the compliance burden on greenwaste composters.

SCAQMD IV-21 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #13: PAR 1133.1 has been revised such that the operator of chipping and grinding

needs to move material within 48 hours of receipt or up to seven days maximum, with approval from the LEA, which harmonizes with state regulation Title 14. This limited removal requireme nt intends to prevent inadvertent decomposition of green material duri ng stockpiling that may result in VOC peaks after chipping. PR 1133.3 would require the similar holding time, as allowed by the LEA, and finished com post cover and water application to

reduce emissions for the first 15 da ys of active phase composting. The compliance costs have been revised with additional information staff received from greenwaste composting operators.

Comment #14: This cost effectiveness appears to be underestimated by a significant measure. There is no accounting for the loss of sa les and the potential volume reductions at the compost sites due to the logistics of applying the compost cover. Even at these low estimates, a 10,000 ton facility co uld not afford to stay in business adding $5.30 per ton to product co st, based on the $53,000 annual cost.

Response #14: The compliance costs and cost eff ectiveness have been revised to reflect the current proposed mitigation measures, based on the revised composting throughput, emission reductions, and cost data. The revised dollar amount of compliance cost per ton for adding a finished compost cover initially and watering before each turning woul d be approximately $1.15 per ton of throughput (as compared to $0.79 per ton of throughput for adding one time finished compost cover).

Comment #15: The staff report indicates a facility cost of $0.62 per ton for the compost cover system to be used, based on the Modest o Study. However, a review of that study indicates that the study windrow was not turned and re-covered repeatedly, as a real production scenario would require. The draft rule defines the active compost phase as the fi rst 22 days. Normal compost windrow operations do five tu rnings in the first 15 da ys. Therefore, one would expect five cover applications. Us ing the Modesto Study’s numbers, we calculated the cost to be $2.76 per ton for applying five sets of compost covers. However, this is too optimistic, because the Modesto example

further lacks resemblance to a real lif e production scenario. The loader was able to maneuver freely in open space next to the test windrow, without other windrows cramping the operation. This is important, because almost all

facilities have narrow drive aisles between windrows.

Response #15: Staff revised the cost estimates for compost cover using the Bakersfield experiment data the commenter provide d. With only one time application of compost cover, $0.79 per ton is the revi sed calculated cost (as compared to $1.15 per ton of throughput fo r adding an initial com post cover and watering before turning). If there is enough space for a loader to turn the windrow, there should be little problem to maneuver the lo ader to apply finished compost cover on the initial pile for that cycle.

Comment #16: Using an average diesel consumpti on rate of five gallons per hour per truck or machine, our Bakersfield exercise indicates it will take one gallon of diesel fuel

SCAQMD IV-22 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

to apply every 100 feet of compost cover (each time). If our facility had to apply five covers to each of the 132,000 linear feet of windrow we handle each year, it would take 6,600 extra gallons of diesel fuel per year.

Response #16: Compost cover cost was calculated using an average diesel consumption rate of five gallons per hour per machine usi ng the same data as provided in the

Bakersfield exercise. The proposed rule now requires only one time covering of the pile with finished compost and th e calculated diesel use has been revised accordingly.

Comment #17: The largest source of emissions in the industry sector was ignored by disproportionately placing the burden of emission reductions on composters.

Response #17: PAR 1133.1 (chipping a nd grinding rule) is tighteni ng a green material holding time in existing Rule 1133.1 such that the material must be processed or removed within 48 hours of receipt, or up to seven days maximum, with approval from the LEA, to reduce inadvertent decomposition during stockpiling. This amended requirement is to harmonize with the state regulation that has already been required under Title 14. Therefore, the proposed amendment would minimize unnecessary emissions, but no emission reductions would be quantified for the chippi ng and grinding industry sector.

Comment #18: Appendix I of the Preliminar y Draft Staff Report does not provide enough

information about the establishment of 5% oxygen concentrati on is important to the emission rates. The accuracy of annual composting throughput is also

doubtful.

Response #18: Appendix I of the Preliminary Dr aft Staff Report summarizes results from a 2007 survey that the District staff conducted to understand greenwaste composting operations in the South Coast. Although the information in the Appendix I still informative, some of the data (e.g., the list of existing facilities and annual composting throughput) have been updated elsewhere in the staff report. To avoid unnecessary confus ion, staff has removed the 2007 survey results in the Draft Staff Report.

Miscellaneous

Comment #19: It would be he lpful if copies of all comme nts were included with the information provided at the public meetings.

Response #19: All comments received in regard to rules and staff report are summarized in this appendix of this staff report. Copies of all comments to the CEQA document will be included in the respective asse ssment documents. Those comments are public information and available on request.

SCAQMD IV-23 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report



### May 10 th 

### Working Group Comments (May 3, 2011 version of the rules)

US EPA Comments

Comment #1: In order for EPA to approve a PA R 1133.1 amendment to the SIP, the District’s staff report should demonstrate that any relaxation of current SIP requirements

is consistent with Clean Air Act (CAA) Section 110(l) requirements.

Response #1: PAR 1133.1 tightens material hold ing requirements of the existing Rule 1133.1

and thus would not relax th e current SIP requirements.

Comment #2: Under the PAR 1133.1, facilities that chip and grind greenwaste and foodwaste would be no longer subject to Rule 1133.1, unless they are permitted by the

LEA to handle foodwaste. The District’s staff report should explain how this is consistent with CAA Section 110(l) if: (a) the LEA permit requirements are less stringent than the current rule requirements for f oodwaste, and (b) there are chipping and grinding facilities in the District that are allowed to chip foodwaste without an LEA permit.

Response #2: Under Title 14, the LEA permit for chipping and grinding facilities does not allow receiving food materi al at the facility and PAR 1133.1 is to harmonize with Title 14 regulation for foodwaste. Staff understands that a chipping and grinding permit is issued by the LEA and thus, there is no chipping and grinding facility in the District th at is allowed to chip foodw aste without an LEA permit, which has been more stringent in general than existing Rule 1133.1.

Comment #3: The rule requirements of PR 1133.3 have been changed since the January 25, 2011 Workshop version. The District’s st aff report should include the expected

emission reductions based on the late st proposed version of the rule.

Response #3: The expected emission reductions w ith the latest proposed version of the PR 1133.3 are included in the staff report.

CalRecycle Comments

Comment #1: PAR 1133.1 (c)(1): The new term “composted mulch derived from partially composted greenwaste” is puzzling. Fi nished compost may be used as mulch, and oversized materials may be screened out of finished compost and used as mulch. If you are attempting to descri be as partially composted mulch product which has been through a complete pathogen reduction process, the term “pathogen-reduced mulch” is preferred.

Response #1: Staff revised the definition of “active compost” by deleting the term, and by adding the preferred term “pathogen -reduced mulch” as recommended.

Comment #2: PAR 1133.1 (c)(7): We recommend th at the term “finished compost” includes unscreened finished compost which still in cludes oversized materials that will be screened out in final processing. A dding a new definition of “overs” is also

recommended.

SCAQMD IV-24 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #2: Staff revised the definition of “finished compost” by including “compost overs” as part of finished compost. The new term “compost overs” has been defined in

the rule.

Comment #3: PAR 1133.1 (c)(19): Th e definition of “woodwaste” is overly restrictive. Might

woodwaste also include tree trunks, stumps, and limbs exceeding 2 inches in

diameter?

Response #3: The definition of “woodwaste” has been modified as recommended. Woodwaste now includes larg e wood materials of curbside or mixed greenwaste that is screened or unscreened, such as tree trimmings, branches, tree trunks, stumps, and limbs exceeding 2 inches in any dimension.

Comment #4: PAR 1133.1 (d)(2): There is no prov ision in Title 14 that would prohibit the LEA from allowing an operator to hold ma terials up to 7 days “provided that the materials are not chipped or ground.” We believe that clause can be removed without changing the inte nt of the section.

Response #4: That particular clause was removed. To effectively harmonize with Title 14, paragraph (d)(2) was modified to “... rem ove from the site w ithin 48 hours of receipt, except observance of official fe deral and state holiday s, or up to seven days maximum, with approval from the Local Enforcement Agency.”

Comment #5: PAR 1133.1 (d)(3): The 24 hour ho lding time proposed to a biomass power generation facility might cause bioma ss plant operators to stop accepting greenwaste completely, further reducing markets for these materials. Biomass plants are currently exempt from T itle 14 feedstock hold ing times. Might biomass power plants be permitted to hold chipped greenwaste longer than 24 hours so long as the moisture content is below 30%?

Response #5: Due to changes to paragraph (d)(2 ), this requirement is no longer needed and

has been removed.

Comment #6: PAR 1133.1 (d)(4): Although C onstruction, Demolition, and Inert (CDI) facilities primarily handle woodwaste, some do handle greenwaste. This section appears to open a loophole in the rule. In th e interests of a le vel playing field, you may wish to require these facilities to handle greenwaste the same as other chip and grind facilities. You may al so wish to expand the definition of woodwaste, per our Comment #3 of this section.

Response #6: Paragraph (d)(4) was completely re moved from the rule to avoid confusion and as it is already required by paragraph (d)(2) of the revised PAR 1133.1. For the definition of woodwaste, the reader is referred to Response #3 of this section.

Comment #7: PAR 1133.1 (d)(6)(B) & (C): Strike the words “foodwaste” from here, as these facilities are not permitted to handle foodw aste unless they are also a permitted

transfer station.

Response #7: Staff removed the words as recommended.

Comment #8: PAR 1133.1 (f)(3): We do not believ e your intent is to limit this provision to curbside materials only. Please strike the word “curbside” from the first line.

SCAQMD IV-25 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Response #8: This exemption is existing rule language and its modification is outside the scope of these amendments. Staff plans to continue to work on this chipping and grinding sector in the near fu ture and may revisit this issue.

Comment #9: PR 1133.3 (c)(7): The term defined here is no longer used in the rule. Is the definition needed? If so, is the refere nce to direct respirometry really a

reference to the Solvita test? Since So lvita is already referenced, why change

now?

Response #9: This definition of “curing phase” ha s already been establis hed in the District’s earlier Rule 1133.2 (co-composti ng rule). This term is still needed and used in the definition of “finished compost.”

Comment #10: PR 1133.3 (d)(2)(A): Recent research by CalRecycle showed that overs were effective as a compost cap. When ble nded into the compost pile, overs reduce bulk density and increase penetration of ai r deep into the pile, helping maintain aerobic conditions. Overs typically contain beneficial microbes left over from the composting process, which helps inoculate the pile with and speeds decomposition. Please strongly consider al lowing the use of overs as a compost cap material or provide your rationale as to why this should not be allowed.

Response #10: The rule has been modified to allo w the use of overs as a compost cap material by adding it to the new definition of “finished compost” (PR 1133.3 (c)(10)). Furthermore, the rule is now allowing screened or unscreened finished compost (including compost overs) as a cover material.

Comment #11: PR 1133.3 (d)(2)(B): The word “subsequent” is confusing and probably

unnecessary.

Response #11: Staff removed the word as recommended.

Comment #12: PR 1133.3 (d)(3): It would be helpful to define the method for calculating foodwaste percentage. What is the s ource of the 10% foodwaste figure? Foodwaste, even when source separated and not mixed with greenwaste, typically contains a high percentage of non-food materials, such as cardboard. This is recognized by en tities such as the Climate Action Reserve, which requires foodwaste composters to actuall y measure the percentage of food in

their waste streams in order to claim GHG credits. Even when collected separately from restaurants and institutions, the percentage of actual food in

foodwaste is less than 100%.

Response #12: Staff has revised the rule require ments with regard to foodwaste composting operations. The definition of “foodwas te” has been modified to address nonfood materials, and a threshold of a nnual foodwaste throu ghput on a facility basis is proposed.

Some greenwaste composting facilities in the South Coas t region currently accept foodwaste less than 10%, by weight, on a facility throughput basis, but actually more than 10% food scraps, by weight, are being composted in windrow recipes without the need of an add-on emission control device. There are only a few facilities handling this f ood material in the South Coast, but significant interest increases on this activity. Existing composting facilities use

SCAQMD IV-26 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

foodwaste recipes of 1 part foodwaste to 2 or 4 part s greenwaste. Therefore, staff has set a new threshold of 5,000 tons per year of foodwaste throughput,

above which an emission control device m eeting at least 80% control efficiency for VOC and ammonia would be require d for active phase piles or windrows containing foodwaste of 10 percent or mo re, by weight. By this revision, the rule proposes that up to 5,000 tons pe r year of foodwas te throughput be decomposed without an add-on control device.

Public Comments

Applicability

Comment #1: Please clarify applicability of PA R 1133.1 to chipping and grinding activities at multi-operation facilities that handle multip le incoming material streams with separate operating areas for chip and ship and composting operations within the same facility.

Response #1: Staff clarified a pplicability of PAR 1133.1 to “ch ipping and grindi ng activities to produce materials other than active or finished compost, unless otherwise exempted.” Separate operations for chip and ship or chipping to produce biofuel or ADC within the same facility would be subject to the provisions of PAR 1133.1. However, chipping and grindi ng activities as part of composting operations to produce active or finished compost within the same facility would be subject to the provisio n of PR 1133.3(d)(1)(A).

Comment #2: PAR 1133.1 does not list landfills or power plants for applicability, but they are given a time limit for utiliz ation of materials in PA R 1133.1(d)(3). The new

utilization time limits ma y cause power plants to delay acceptance of materials from greenwaste facilities, causing a b acklog that would shut down operations.

Response #2: The reader is referred to Res ponse #4 of the CalRecycle Comments section and Response #9 of this section.

Definitions

Comment #3: PR 1133.3(c)(12) adds a “per pile” requirement to the definition. We currently operate one of our greenwaste facilities with less than 20% manure, but may go over this minimum amount on a pile by p ile basis. By changing the definition to a “per facility” basis allows greater flexibility in absorbing fluctuating input streams and lessens the need for stockpili ng that will lower emissions. We feel that the “per pile” term should be change d to “per facility” in the definition of greenwaste composting and the word “wast e” should be taken out of all the rule language altogether.

Response #3: The definition of greenwaste com posting with up to 20% manure, by volume, is to be consistent with District’s co-composting Rule 1133.2. Changing the definition to a “per facility” basis woul d conflict with Rule 1133.2. Under Rule 1133.2, composting of greater than 20% manure, by volume would no longer be defined as greenwaste composting, but de fined as co-composting and thus the operator would need to meet the requirements of Rule 1133.2.

SCAQMD IV-27 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Comment #4: Residuals derived from food producti on and storage enterprises are typically not exclusively food waste. They typically include a lot of non-food, wrapping and container material (paper & plastic). For this reason when the rule says 10% foodwaste (e.g., 1133.3(d)(2)), it contains a significant porti on (greater than 50% by weight, depending on the source) of non-putrescible material. It is suggested that PR 1133.3 should delete “foodwaste” and define “food material” as the portion of the compostable material feedstock that is directly derived from vegetable or animal matter, which is consistent with the Title 14 term. The percent of food material will be de termined for feedstock coming into the entire facility, not just one pile or windrow.

Response #4: Staff re-defined the term “foodwas te” to be “any pre- or post-consumer food scraps collected from the food service industry, grocery stores, or residential food scrap collection.” The proposed thre shold that would re quire installation

of an emission control device has been modified to 5,000 tons per year of foodwaste throughput per facility and 10 percent foodwaste, by weight. Staff revised the rule language such that the annual th roughput calculation may exclude any non-putrescible materials, non-compostable contaminants, and greenwaste that are separated before or after composting and shipped off-site for disposal, provided they are quan tified and appropriate records are

maintained.

Comment #5: PAR 1133.1(c)(8) should exclude compostable food packaging materials which, being derived from plant fibers, are more like green waste than food.

Response #5: As it pertains to chipping and gr inding operations, staff doe s not feel that any

modification is needed to this defi nition as the suggestion would require separation and characterizat ion of the material whic h would be unnecessarily

burdensome.

Comment #6: Under PAR 1133.1, so-called “greenwa ste” is not entirely composted of “leafy green” material, the putrescible por tion, and the primary VOC producing component. For this reason, for the purpos e of this rule, green material should be specifically defined as the VOC-produc ing portion of those materials as per

Title 14.

Response #6: Staff disagrees. The definition of greenwaste has been es tablished in earlier

District’s rules and modi fying this definition coul d cause confusion to the readers. The large woody materials of greenwaste exceeding 2 inches in

diameter are now considered woodw aste for the purpose of PAR 1133.1.

Comment #7: Woody material, while compostable, typically is used in chipped or ground fashion to provide a very slow degradi ng “bulking agent” to more putrescible materials. Alternatively, it is used for “wood chips” or sent to biomass burn

facilities for fuel. It is recommende d that woody material portion of green

material is considered wood material.

Response #7: The reader is referred to Res ponse #3 of the CalRecycle Comments section.

Comment #8: Composting and compost are alread y defined in other regulations as time and temperature for pathogen reduction. It is recommended that the rule defines

SCAQMD IV-28 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

“active compost” as in Title 14, and incl udes “compost overs” in the definition of “finished compost.”

Response #8: Staff included temperature requirement as part of definition of “active compost” and included “compost overs” in the de finition of “finished compost” as

recommended.

Greenwaste Processing and Stockpiling

Comment #9: PAR 1133.1(d)(3) requires a landfill or “biomass power generation facility” to utilize the chipped or ground greenwaste w ithin 24 hours of receipt. It appears that the rule considers a landfill applica tion of ADC or erosion control the same as stockpiling greenwaste for fuel to produce energy. The applications are entirely different and the greenwaste at the plant does not remain on site or get buried, but is consumed in a timely ma nner. Attempting to operate with 24 hours or less of inventory is not feasible or practiced anywhere in the biomass industry. In addition, th e definition of “greenwa ste” includes any organic material whereas Colmac’s greenwaste definition does not include grass, palm

or succulents such as found at a landfill.

Response #9: Staff removed that paragraph fr om the rule, and the same 48 hours or up to seven days maximum removal requirement would be applied to all facilities, with approval from the LEA. Staff al so proposes an exemption for a biomass power generation facility or a facility pro cessing material as a biomass fuel for a biomass power generation facility from the requirement of material removal within the allotted times, provided that th e material temperature is maintained at below 122 degrees Fahrenheit or the mois ture content is le ss than 30%. In addition, the definition of “non-curbside greenwaste” has been modified to include the large (exceeding 2 inches) woody material of greenwaste into the

definition of “woodwaste.”

Comment #10: PAR 1133.1(d)(4) should be revise d to allow greater storage time for woody

materials.

Response #10: The reader is referred to Res ponse #6 of the CalRecycle Comment section.

Comment #11: PAR 1133.1(d)(2) and (d)(3) should be revised to mimic Title 14, Section 17852(a)(10), which requires greenwaste to be “...removed from the site within 48 hours of receipt.” Such a provision will allow facilities that do not operate 24/7 adequate time to manage greenwaste, especially for materials received at the end of the regular business week.

Response #11: Staff revised this requirement as recommended.

Comment #12: For consistency, PAR 1133.1(d) (2)/(d)(3) and PR 1133.3(d)(1)(C) should contain the same processing and storage requirements.

Response #12: Staff revised the processing and storage requirements such that they are

consistent between the two rules.

SCAQMD IV-29 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Foodwaste Limit

Comment #13: While I understand foodwaste can be a big contributor to VOCs, it is important to understand the foodwaste collection pr ograms that are currently in place in various municipalities and in stitutions. 10% foodwaste by weight can be very deceiving. Foodwaste typically arrives in packages on pallets. As long as the packaging is organic and bio-degradable , no additional proces sing is required to remove contaminants from compost. In most cases, it is rare to receive clean pure foodwaste. Depending on the sour ce (either pre- or post-consumer foodwaste), the percentage of non-f ood packaging can vary. A flat 10% maximum by weight is not conducive to the much needed foodwaste programs currently in effect.

Response #13: The reader is referred to Re sponse #12 of the CalRecycle Comments section.

Emissions Control and Alternative

Comment #14: Forced aeration systems and windrow composting are two very different forms of composting and will require specifi cally defined language for each. While there are many common requirements, th ere are many differing methods in production that need to be considered.

Response #14: Staff revised the rule language such that a specific composting technology (such as a force aeration system) is no longer re quired. However, the rule would still require an emission control device meetin g at least 80% reductions in VOC and ammonia emissions if greater than 5,000 tons per year of foodwaste throughput is decomposed. This revision is to al low various technologies that may achieve the overall system control efficiency of at least 80%.

Comment #15: PR 1133.3 should be revised to allow various t echnologies to achieve the overall system control efficiency of at least 80%. For example, Rule 1133.2 provides a similar condition without spec ifying the control technology to be used employed. It is our experience that positive aeration systems and other technologies or approaches (e.g., ASP with pseudo-bi ofilter) could also be utilized to achieve the desired control efficiency.

Response #15: The language has been re vised to reflect this suggestion.

Comment #16: PR 1133.3 would requi re approvals from the AQMD, CARB, as well as the US EPA to allow for adoption of alternative best management practices (BMPs) for

emission reduction and alternative em ission control methods by greenwaste composting operators. This will involve three levels of time-consuming government review. It is our opinion th at the Executive Officer (EO) of the AQMD is sufficiently qualified to consider and approve alternative BMPs and

alternative emission control methods. Th erefore, it is our recommendation that the EO of the AQMD be the sole authority in the consideration and approval of

alternative BMPs for emission reducti on and alternative emission control methods proposed by greenwas te composting operators.

Response #16: The reader is referred to Respons e #3 of the US EPA Comments section under the February 23 rd Public Workshop Comments. As the rule will be submitted to

SCAQMD IV-30 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

CARB and US EPA as a part of SIP, a pproval by all agencies is required to limit agency-specific discretion. In addition, this requirement is typical of other AQMD rules that include compliance alternatives. Staff will work to expedite such requests.

Permitting/Offsets/BACT

Comment #17: Compost producers need to have a better understanding of how the District staff plans to address Best Available C ontrol Technology (BACT) for windrow composting vs. aerated static pile (ASP) composting for food material. Additionally, the percenta ge targets for BACT are not clearly defined.

Response #17: Windrow composting do es not require a permit. Fini shed compost c over is seen more as a BMP as opposed to a control technology, and thus does not require a permit. Depending on the circumstances, new and existing composting facilities modifying their operation may al so be subject to New Source Review requirements of Regulation XIII, includi ng BACT and offsets. ASP composting with appropriate emission control devi ces may be considered BACT. New facilities with control devices permitted would be required to provide offsets for their full potential to emit, i.e. maximum after control of emissions up to levels allowed by their permit. If they keep their permitted levels of controlled emissions below the 4 tons per year VOC threshold in Rule 1304(d), they will be exempt from the offset requirement. For existing facilities, no offsets would be required, provided no modification cause s an increase in emissions. Even if

the modification would result in an increas e in emissions, the facility could take advantage of the small business exempti on if its total emissions remain under the 4 tons per year threshold. Also, exis ting facilities are only required to offset the increase in emissions, or the amount in excess of the thresholds, if their premodification potential to em it was less than the amount s in Rule 1304(d). For purposes of this calculation, LEA permit limits on throughput will be considered to limit the source’s pre-modification potential to emit. Existing facilities required to install controls tr igger the permit requirement, in which case they will be eligible for the offset exemption in Rule 1304(c)(4), provided there is no increase in maximum rating as established in the facility’s LEA permit.

Comment #18: It is not clear if permitting would be required if you have a trammel screen or other pieces of equipment or control device that is listed in the permitting rules. Please clarify what constitutes triggering of an 1133.1 permit, based on equipment on any given site.

Response #18: The AQMD permit requirements are specified in Rules 201 and 203, with permit exemptions specified in Rule 219. Generally, turning of a pile or windrow using DMV-registered motor vehi cles does not require a permit. Onsite equipment, such as dedicated mobile grinders and screeners, are already subject to permit from the District or ARB, but that is for the equipment or engine emissions only, not composting em issions. If a pile is aerated, the mechanical aeration system and its a ssociated emission control device would require a separate permit for each.

SCAQMD IV-31 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

Exemptions

Comment #19: PAR 1133.1(f)(3) should apply to all greenwaste, instead of curbside greenwaste as drafted.

Response #19: The reader is referred to Res ponse #8 of the CalRecycle Comments section.

Comment #20: As waste convers ion technologies rapidly advan ce, greenwaste by itself or in combination with other organic materials may be composted at landfill sites via anaerobic processes in the near futu re. These landfill-based greenwaste composting operations will clearly not fit well with the regulatory framework of

PR 1133.3. It is recommended that landfill-based anaerobic greenwaste composting operations be specifically exempt from PR 1133.3.

Response #20: If anaerobic digestion is applie d to greenwaste compos ting on its own (i.e., voluntarily by the facility operator), th e composting would be exempt pursuant to PR 1133.3(g)(2), provided that an overall 80% control efficiency is

demonstrated.

Miscellaneous

Comment #21: We want to be su re that we set a new precedent of socio-economic analysis for our industry, which is fundamentally ba sed on the new sustainable economiesof-scope as applied to renewable ca rbon management. While we understand that this is beyond the scope of the current , prescribed methods of the District’s socio-economic analysis, we believe that we have a unique opportunity to use this rulemaking process to introduce an evolutionary change in this process.

Response #21: As discussed at the working group meeting, such an analysis is beyond the scope of these proposed rules.

Comment #22: We believe that the compost i ndustry is unique, and strategically positioned, compared to any other industry, in help ing society move to a sustainable, renewable carbon society. Since carbon is central to all life and economics, this industry is core to the emerging sustai nable economy. For these reasons, the compost industry should be given new, and unique, analysis c onsiderations. We suggest the District staff work with th e compost industry closely to craft a new socio-economic analysis that adequately articulates and demonstrates the importance of this relatively small industry within the larger context of renewable carbon management.

Response #22: Staff appreciates the environmental benefits that composting provides. However, the analysis requested is beyond the scope of this rule proposal.

Socioeconomic Analysis

Comment #23: Relative to the analysis of impacts to the largest facility, a $240,000 annual compliance cost is very high. Woul d this not impact their viability?

Response #23: The cost, which is driven by the co st of the water application BMP, is a worst case scenario. The facility has informed st aff that this element of the rule is

workable and has indicated that total wa ter use may not be that high as the

SCAQMD IV-32 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

increased water use will be minimized to the extent feasible by altering the water application timing.

SCAQMD IV-33 July 2011PAR 1133.1 and PR 1133.3 Final Staff Report

SCAQMD IV-34 July 2011 Written comments were submitted by:

Andrew Steckel, US EPA Region IX (2) Alex Krichevsky, Air Resources Board (ARB) Howard Levenson, Department of Resources Re cycling and Recovery (CalRecycle) (2) Khalil M. Gharios, City of Los Angeles Solid Resource Processing/Construction Division (2) Neil Edgar, California Compost Coalition Hans Kernkamp, Riverside County Wa ste Management Department (2) Linda Novick, Harvest Power David Rothbart, Los Angeles C ounty Sanitation Districts (2) Kevin Barnes, City of Bakers field Solid Waste Division (2) David Tieu, Orange County Waste and Recycling Chuck Tobin, Burrtec Waste Industries Matt Cotton, Integrated Waste Manageme nt Consulting, LLC and on behalf of: Agromin; Aguinaga Green; Alameda County Waste Management Authorit y and Alameda County Source Reduction and Recycling Board as one Public Agency – StopWaste.org; Association of Compost Producers; Athens Services; American Organics; Burrtec Waste Industries; California Bio-Mass; California Against Waste; City of Bakersfield Solid Waste Division; Community Recycling and Resource Recovery; CR&R Incorporated;
Harvest Power; Integrated Waste Management Consulting, LLC; and Recology Dan Noble, Association of Compost Producers (2) Paul Ryan, Inland Empire Disposal Association and on behalf of: California Refuse Recycling Council – Southern District; Inland Empire Disposal Association; Los Angeles County Waste Mana gement Association; and Solid Waste Association of Orange County Brian Fuchs, W.L. Gore & Associates, Inc. Dean Johnson, American Organics James Russell Huffman, Colmac Energy, Inc.