SAN JOAQUIN VALLEY
AIR POLLUTION CONTROL DISTRICT
Approved by: SIGNED Date: 09/09/09David Warner
Director of Permit Services
I.Purpose:
This policy is to provide guidance regarding the permitting of existing organic waste processing operations within the District. Organic waste processing operations includes greenwaste composting, food waste composting, co-composting, processing of organic waste materials at landfills, and land application of organic waste materials.
II.Applicability:
This policy applies to the processing of In-House Permit(s) to Operate (PTOs) applications for existing organic waste processing operations. Organic waste material screening and grinding operations that may be conducted at thesefacilities are not covered by this policy.
III.Background:
Organic waste materials are generally managed by disposal in landfills, applied to land to enrich the soil, or composted. These operations are significant sources of volatile organic compounds (VOC), ammonia (NH3), and odor emissions due to the decomposition of the organic materials. In addition, fugitive particulate matter emissions may also be emitted due to the handling and processing of the organic materials. Organic waste processing consists of the following types of operations:
Green Waste Composting:
Green waste composting is the controlled biological decomposition of green waste material by microorganisms under controlled conditions to convert the material into a soil-like substance called compost. Green waste is defined as any organic waste material generated from gardening, agriculture, or landscaping activities including, but not limited to, grass clippings, leaves, tree and shrub trimmings, and plant remains. The manufactured compost is utilized as a soil amendment for landscaping and agriculture purposes.
Food Waste Composting:
Food waste composting is the controlled biological decomposition of food waste material by microorganisms under controlled conditions to convert the material into compost. Food waste is defined as any food scraps from the food service industry, grocery stores, or residential food scrap collection. Food waste material is generally mixed with green waste to produce compost, which is used as a soil amendment for landscaping and agriculture purposes.
Co-Composting:
Co-composting is where biosolids, animal manure, and/or poultry litter are mixed with other materials (typically green waste) to produce compost. Per District Rule 4565, composting is defined as the controlled biological decomposition of organic material, such as sewage sludge, animal manures, or crop residues, under aerobic (with air) or anaerobic (without air) conditions to form a humus-like material. Biosolids is defined as organic material resulting from the treatment of sewage sludge or wastewater. Animal manure is defined as non-human animal excretions and waste, including, but not limited to, dried solids and urine from cows, cattle, or swine. Poultry litter is defined as poultry excretions and waste, including, but not limited to, driedsolids and urine from chickens, turkeys, geese, or ducks. The manufactured compost is utilized as a soil amendment for landscaping and agriculture purposes.
Processing of Organic Waste Materials at Landfills:
Green waste, biosolids, animal manure, and poultry litter received at landfills are for final disposal where the material is spread and compacted and a daily cover is applied. Landfill operators are currently allowed to accept organic waste as a recycled material for use as an alternative daily cover (ADC). Therefore, at some landfills the green waste, biosolids, animal manure, and poultry litter are composted or co-composted to use as an ADC. This policy will only address the permitting of an existing composting or co-composting operation at a landfill. The emissions from the disposal of organic waste materials at a landfill is beyond the scope of this policy and will addressed under the facility’s permit for their landfill gas collection and control system.
Land Application of Organic Waste Materials:
Another method to manage and utilize green waste, biosolids, animal manure, and/or poultry litter is direct application of these materials onto open land to enrich the soil. The received or site-produced organic waste materials are land incorporated by tilling, injecting, or plowing the organic waste materials into the soil. This is a common method used for the disposal of biosolids at sewage treatment plants and to provide the needed organic matter in low quality soils for the growing of feed crops on farmland.
IV.Permit Requirement:
Based on past and recent source testing at existing organic waste processing operations, these facilities can be significant sources of volatile organic compounds (VOC), ammonia (NH3), and particulate matter (PM) emissions. Based on these recent findings, emissions from these types of operations may exceed the permit exemption limits of District Rule 2020, Sections 3.7 and 6.19. for low emitting units.
V.District Organic Waste Processing Operations Prohibitory Rules:
The following are District prohibitory rules which may apply to existing organic waste processing operations:
Rule 4565 (Biosolids, Animal Manure, and Poultry Litter Operations):
This rule was adopted on March 15, 2007 and applies to allfacilities whose throughput consists entirely or in part of biosolids, animal manure, or poultry litter and to operators who landfill, land apply, compost, or co-compost these materials. This rule does not apply to facilities that only process green waste or food waste.
Per Section 4.0 of Rule 4565 (except for the applicable recordkeeping requirements of Section 6.6.1) the following Table 1lists the exemptionsof this rule.
Table 1 –Summary of Rule 4565 ExemptionsRule Section / Exemptions
4.1 / Facilities subject to Rule 4570 (Confined Animal Facilities) or specifically exempt under Section 4.0 of Rule 4570.
4.2 / Composting/Co-Composting facilities with throughput of biosolids, animal manure, and poultry litter of 100 wet tons/year.
4.3 / Operators who land apply any combination of biosolids, animal manure or poultry litter and that meet all of the following criteria:
4.3.1 -Receive a total of 10,000 wet tons/year of any combination of biosolids, animal manure, or poultry litter; and
4.3.2 -Are not intentionally conducting pathogen reduction on any biosolids, animal manure, or poultry litter; and
4.3.3 -Are not subject to the regulations of the California Integrated Waste Management Board pertaining to solid waste transfer/processing or disposal; and
4.3.4 -Do not receive or collect tipping fees.
Table 1 –Summary of Rule 4565 Exemptions (Continued)
Rule Section / Exemptions
4.4 / Facilities that place all material containing un-composted biosolids, animal manure, or poultry litter in air tight bags or packages for sale or sell materialscontaining biosolids, animal manure, or poultry litter as a soil amendment or fertilizer. Within 15 days of receipt, the biosolids, animal manure, or poultry litter must be placed in airtight bags or removed from the facility.
If the existing facility is subject to the requirements of this rule and is not exempt per Table 1 above, then the facility will need to identify and implement method(s) to comply with the applicable requirements of Section 5.0 based on the compliance schedule as indicated in Section 7.0 of the rule. For the source category requirements please refer to Section 5.0 of this rule. Table 2 below lists the compliance schedule based on the source categories.
Table 2 – Summary of Rule 4565 Compliance ScheduleSource Category / ATC Application Submission Date / Full Compliance Date
Landfills / --- / March 15, 2008
Land Application
100,000 wet tons/year / --- / March 15, 2008
Land Application
>100,000 wet tons/year / --- / September 15, 2008
Composting/Co-composting
<100,000 wet tons/year / --- / September 15, 2008
Composting/Co-composting
100,000 wet tons/year / --- / March 15, 2010
Composting/Co-Composting
100,000 wet tons/year and converting to energy generation / March 15, 2008 / Implement four (4) Class One mitigation measures by September 15, 2008
Implement three (3) Class One mitigation measures and operate in-vessel composting by
September 15, 2012
Rule 4566 (Organic Waste Operations):
This rule is currently under development and is proposed for adoption during the Forth Quarter of 2010. This rule will apply to all facilities whose throughput consists primarily of organic waste, as defined in the rule, and the operators who compost, chip or grind, landfill, land apply, store or stockpile these materials, including operators who processes these materials for direct feed or dehydration. Organic waste, for the purposes of this rule, is any organic waste material that includes food processing by-products, food waste, green waste, and wood waste, or a mixture thereof, and does not include biosolids, animal manure, and poultry litter material. This rule will not apply to facilities which are subject to or exempt from Rule 4565.
VI.Organic Waste Processing Operations Permit Exemption Dates:
The following dates in Table 3 are to be used to determine if an existing organic waste processing operation qualifies for an In-House PTO(s) through loss of exemption under District Rule 2020. The notification date is the date the District sent mailers to existing facilities, which may be subject to District permit requirements. The In-House PTO cut-off date is the date utilized to determine if an In-House PTO will be issued for the existing operation. Any organic waste processing operation installed after the In-House PTO cut-off date will require an application for an Authority to Construct (ATC) permit and will be subject to the requirements of District Rule 2201.
Table 3 – Permit Exemption DatesProcess Type / Notification Date / In-House PTO Cut-off Date
Composting or Co-Composting with Biosolids / August 1, 2002 / August 1, 2002
Composting or Co-Composting with Animal Manure and Poultry Litter / November 16, 2007 / November 16, 2007
Processing of Biosolids, Animal Manure, Poultry Litter, Green Waste, Food Waste, and Wood Waste by Land Application / November 16, 2007 / November 16, 2007
Green Waste Composting / November 16, 2007 / November 16, 2007
Food Waste Composting / November 16, 2007 / November 16, 2007
VII.Land Use Authorizations/Permits for Existing Organic Waste Processing Operations:
This policy only applies to an existing organic waste processing operation, which qualifies for an In-House PTO as determined in Section VI. of this document. Since these are existing facilities,it will be assumed that all required land use authorities/permits have been obtained. In addition, the District does not have the authority to enforce other local, state, or federal agency requirements. The issuance of a District permit does not authorize the existing facility to operate in violation of any established requirements fromany local, state, or federal agency. The following condition will be included in their District permit to address thisissue.
- - This permit does not authorize the facility to operate without the required permits from other local, state, or federal agency and does not authorize the violation of any conditions established for this facility in the Conditional Use Permit (CUP), Special Use Permit (SUP), Site Approval, Site Plan Review (SPR), or other approval documents issued by a local, state, or federal agency. [District Rules 2070 and 2080]
VllI.Fugitive Emissions:
Pursuant to District Rule 2201 (New and Modified Stationary Source Review Rule), Section 3.18, Fugitive Emissions is defined as, “emissions that could not reasonably pass through a vent, chimney, stack, or other functionally equivalent opening. Emissions that are not vented through a stack but can reasonably be captured and vented through a stack are not considered fugitive.” Because these existing organic waste processing operations utilize large open windrow piles and/or open fields for processing, the emissions from these operations do not reasonably lend themselves to capture and venting through an exhaust stack. Since these are existing operations, which are currently not subject to the requirements of District Rule 2201, then these emissions will be considered to be fugitive until such time that the operation is modified and become subject to the requirements of Rule 2201.
IX.Organic Waste Processing Operations Emission Factors:
The District is currently in the process of establishing emissions factors for organic waste processing operations. The following emission factors will only be used for the processing of these In-House PTO(s) to establish a baseline emissions leveland will be revised once more appropriate emission factors are determined through on-going research and testing. These emission factors are based on the current available emission factors and will be updated when appropriate pursuant to District Policy APR 1110 (Use of Revised Generally Accepted Emission Factors).
Green Waste Emission Factors:
Based on the District’s preliminary Green Waste Compost Report, the following emission factors will be utilized for green waste composting as presented below in Table 4.
Table 4 – Emission Factors for Green Waste CompostingActivity / Emission Factors (lb/wet ton)
VOC / NH3
Stockpiles / 5.36 / 0.06
Windrows / 4.27 / 1.44
Facility Total / 9.63 / 1.50
Food Waste Emission Factors:
The District has not been able to identify an emission factor for uncontrolled food waste composting. Source tests from controlled composting operations have yielded emission factors ranging from 3.4 lb VOC per ton food waste composted (micropore cover) to 37.1 lb VOC per ton food waste composted (Ag Bag). In addition to the wide range of values observed, it is also unlikely that emissions from a covered system would accurately represent emissions from the open windrow commonly used by facilities in the District. This is because covered systems offer many process control advantages including weather protection and water retention. For these reasons, the District will use the green waste composting emission factor to represent this feed stock until a more representative emission factor can be identified.
Pomace Emission Factors:
The District has not been able to identify an emission factor for pomace composting. The District will use the green waste composting emission factor to represent this feed stock until a more representative emission factor can be identified.
Biosolids and Animal Manure Emission Factors:
Biosolids and animal manure composting emission factors were taken from source tests conducted by the South Coast Air Quality Management District (SCAQMD) in support of their Rule 1133 (Emission Reductions from Composting and Related Operations). These emission factors were calculated as an average of emissions from three co-composting facilities (SCAQMD, 2002) as presented in the Table 5 below.
Table 5 – Summary of Co-Composting Emission Factors Developed by SCAQMDLocation / Emission Factors (lb/wet ton)
VOC / NH3
RECYC Inc / 0.53 / 2.70
EKO Systems / 1.70 / 3.28
San Joaquin Composting / 3.12 / 2.81
Average / 1.78 / 2.93
PoultryLitter Emission Factors:
The District has not been able to identify an emission factor for poultry litter composting. The District will use the biosolids composting emission factor to represent this feed stock until a more representative emission factor can be identified.
Summary of Emission Factors:
Table 6 below summarizes the emission factors to be utilized for these In-House PTO applications until more representative emission factorsare determined.
Table 6 – Summary of Organic Waste Processing Operation Emission FactorsProcess Type / Emission Factor / Source of
Emission Factors
Composting or Co-Composting with Biosolids (Windrows) / 1.78 lb-VOC/wet ton
2.93 lb-NH3/wet ton / SCAQMD Staff Report for Rule 1133
Composting or Co-Composting with Animal Manure and Poultry Litter (Windrows) / 1.78 lb-VOC/wet ton
2.93 lb-NH3/wet ton / SCAQMD Staff Report for Rule 1133
Processing of Biosolids, Animal Manure, Poultry Litterby Land Application / 1.78 lb-VOC/wet ton
2.93 lb-NH3/wet ton / SCAQMD Staff Report for Rule 1133
Green Waste Composting
(VOC Emissions) / 5.36 lb-VOC/wet ton (Stockpiles)
4.27 lb-VOC/wet ton (Windrows) / District Green Waste Composting Emission Factor Report
Green Waste Composting
(NH3 Emissions) / 0.06 lb-NH3/wet ton (Stockpiles)
1.44 lb-NH3/wet ton (Windrows) / District Green Waste Composting Emission Factor Report
Food Waste Composting
(VOC Emissions) / 5.36 lb-VOC/wet ton (Stockpiles)
4.27 lb-VOC/wet ton (Windrows) / District Green Waste Composting Emission Factor Report
Food Waste Composting
(NH3 Emissions) / 0.06 lb-NH3/wet ton (Stockpiles)
1.44 lb-NH3/wet ton (Windrows) / District Green Waste Composting Emission Factor Report
Table 6 – Summary of Organic Waste Processing Operation Emission Factors (Continued)
Process Type / Emission Factor / Source of
Emission Factors
Processing of Green Waste, Food Waste, and Wood Waste by Land Application(VOC Emissions) / 5.36 lb-VOC/wet ton (Stockpiles)
4.27 lb-VOC/wet ton (Windrows) / District Green Waste Composting Emission Factor Report
Processing of Green Waste, Food Waste, and Wood Waste by Land Application(NH3 Emissions) / 0.06 lb-NH3/wet ton (Stockpiles)
1.44 lb-NH3/wet ton (Windrows) / District Green Waste Composting Emission Factor Report
X.Permit Application Processing Procedures:
Step 1:Determine if the existing organic waste processing operation will be exempt from District permitting requirements as a low emitting unit per District Rule 2020, Section 6.19.
(a).Utilizing the appropriate emission factors from Table 6 above for the process type, determine if the uncontrolled emissions from each pollutant are less than 2 lb/day.
(b).Submit a Risk Management Review (RMR) request to determine if the operation will trigger Toxic Best Available Control Technology (T-BACT).
Based on the above results, if the operation is exempt from District permits, notify the facility of their exemption and cancel the application. If the operation is not exempt from District permits continue on to Step 2.
Step 2:Determine if the existing organic waste processing operation qualifies for an In-House PTO(s).
(a).Determine whether the operation was installed prior to the cut-off date as indicated in Table 3 above for the process type.
(b).Except for land application operations, determine whether the facility was issued a solid waste transfer, processing,or disposal permit from the California Integrated Waste Management District (CIWMB) prior to the cut-off date indicated in Table 3 above for the process type.
If the operation was installed prior to the applicable cut-off date with a CIWMB permit, then the operation will be issued an In-House PTO utilizing the appropriate In-House PTO application review. Otherwise, notify the facility that their operation does not qualify for an In-House PTO and their application will be processed under District Rule 2201 (New and Modified Stationary Source Review) for issuance of Authority to Construct (ATC) permits.