Maria Bowen Suzan Pankenier April 11, 2019

Covered Aerated Static Pile Air

Permitting

Presentation Summary

• Composting needs in California

• General CASP operation

• Permitting in various Air Districts

• Additional information requested by Air Districts while permitting

• Keys for successful permitting

• What to expect in CASP air permits

Permitting in California – SB 1383 and AB 1826

• SB 1383:

▪ 50% reduction in the level of statewide disposal of organic waste

from the 2014 level by 2020

▪ 75% reduction by 2025

Outcome: Demand on landfill operators to look to composing operations

to meet requirements

• AB 1826:

▪ Beginning April 1, 2016, required businesses to recycle their organic

waste depending on the amount of waste they generate per week

– As of January 2019, businesses that generate four cubic yards or more of commercial solid waste per week shall arrange for organic recycling services

Composting White Paper

• In August 2018, the California Air Resources Board (CARB), California Air

Pollution Control Officers Association (CAPCOA) and CalRecycle issued a

White Paper addressing the permitting and regulatory issues related to

composting operations in California

• Findings:

▪ Due to variety of locations, types, size etc. of composting projects it

is difficult for air districts to establish a “one size fits all” method of

permitting for general composting

▪ Concern around the impact of volatile organic compound (VOC)

emissions, composting projects require VOC emissions

– Will the diversion of organics to composting reduce the VOCs from Landfills? Will there be enough to offset the composting operations?

– CalRecycle is preparing for and studying the potential VOC ERC shortage

Composting White Paper

• Areas which still need research:

▪ Additional VOC data

▪ Simplifying a Source Test Protocol method

▪ More in-depth testing of feedstocks and curing piles for VOC

emissions

▪ Modeling NOx emissions from transportation of the organic waste

materials to processing facilities

▪ Quantifying the compost application air quality benefits from the use

of the final compost from operations

▪ Cal Poly SLO in the process of completing a LFG study and the

effects of LFG on VOC Emissions

• The White Paper does identify Aerated Static Piles (ASPs) as the Best

Achievable Control Technology(BACT) for composting operations

CASP Operation Basics

• Grind and mix feedstock for a

homogenous pile material

• Moisture condition feedstock to

40-60%

Material Processing

• Finished compost biofilter

• Positive or negative aeration

• Static – do not turn piles

• Aerate for approximately 21-28

days

• Process to Further Reduce

Pathogens (PFRP): pile

temperatures must be 131

degrees F or above for 72

consecutive hours

Active Aeration

• After active aeration

• Fungal breakdown and degradation of

more complex molecules (lignin)

• The pile further matures to a quality

desired by the seller

• Duration may vary due to quality of

compost desired

▪ Can range from 4 to 8 week or up

to 6 months

Curing

Compost Handling Permit

• Ensure the site has a composting handling permit

▪ In California this entails an application to CalRecycle including the

following:

– Report of Compost Site Information (RCSI)

– Odor Impact Minimization Plan (OIMP)

– Odor Best Management Practice Feasibility Report (may be required)

– Existing compost handling permit may need updating of reports/plans listed above

Permitted Facilities

Site 1 Site 2 Site 3

Daily Acceptance 1,134 tons 75 tons 700 tons

Annual Acceptance 130,000 tons 23,400 tons 160,680 tons

Type of CASP Positive Positive Positive

Air District BAAQMD SCAQMD BAAQMD

Previous

Composting Onsite

Yes, CASP to

replace Windrow

Yes, Windrow

(CASP to operate

concurrently with

Windrows)

Yes, CASP to

replace Windrow

Air Permitting – General Guidelines

• ATC/PTO application

▪ Narrative describing project

▪ Calculation of project emissions and determination of emissions

▪ Flow diagram

▪ Equipment specifications

– Such as pile designs

▪ Applicable forms (varies per Air District’s requirements)

• Note! Minor permit revision if a composting operation exists onsite, the

items above would need to be addressed to the modifications that would

be reflected onsite from the change in operations.

Air Permitting – Application

• Narrative

▪ Description of proposed facility

▪ Discussions on following topics:

• Emissions

– Receiving materials and stockpiling

– Material handling

– Negative/positive aeration

– Vehicle traffic

Note! If the facility already had composting onsite sources may only

need to be modified in the application.

Air Permitting – Attachments

• Site layout drawing

• Engineering drawings of aeration system (# of piles, dimensions, blower

specifications)

• Public notification (if applicable)

• Application forms (vary by Air District)

• Health Risk Screening Analysis

• Compared to windrowing:

▪ Can expect lower POC and

NH3 emissions

▪ Lower PM emissions because

piles are not being turned

• Aeration system and biofilter can

decrease emissions by

approximately 70-80%

▪ Biofilter typically consists of

cured compost

Air Permitting – Actual Impacts on Air Quality

Air District Responses to Applications

• Information requests

▪ Understanding of processes/phases

▪ Feedstock materials and handling of materials

▪ Proposed vehicle miles broken up by process

• Clarification on monitoring parameters

▪ Oxygen, temperature, moisture, pH

– When and how to measure for these for operations/air quality

Active Piles:

▪ Temperature

▪ Moisture

▪ Oxygen

▪ Air Flow

Curing piles:

▪ Temperature

▪ pH

Monitoring for Operations vs. Permitted Requirements

To maintain proper operations of your CASP you will need to monitor the

following:

The Air District is likely to have requirements of monitoring the parameters

listed above (and possibly more), so it is best if the frequency and required

ranges are consistent with planned CASP operations.

• Open communication with the Air

District

• Be prepared to train/provide

educational resources

• Time consuming

• Include information on the

process as a whole in the initial

application

▪ Many Air District’s have never

seen a CASP application, or

have processed very few

Keys to Successful Permitting

Receiving Final Issued Air Permit

• Once your Air District issues the ATC it is likely to include:

▪ Monitoring requirements

– Temperature

– Oxygen

– Moisture

– pH

– Materials tracking

– Amount received, piles material incorporated into

– Tonnage and vehicle miles limits

Receiving Final Issued Air Permit Cont.

• Once your Air District issues the ATC it is likely to include:

▪ Timeline for incorporating materials into an active pile

▪ Maximum Dimensions of Active and Curing Piles

▪ Source test (typically within specified number of days following

startup)

▪ PTO issued after source test results are received/reviewed

▪ Type of aeration (positive or negative)

Anticipated Permit Requirements

• Temperature, moisture, oxygen, and pH ranges for feedstock, active and

curing piles and biofilter

• Tracking: feedstock receipt date, active/curing pile

construction/deconstruction dates

• Tonnage of feedstock received, tonnage of compost sold/used onsite

• Vehicle miles travelled

• Visual and odor observations/inspections

• Frequency of monitoring and resources

required

• Time of monitoring

▪ pH

• Are required ranges/limits achievable?

• Do the requirements allow for biological

processes to occur?

▪ Temporary temperature increase

when moving from active to curing

piles

Requirements – Are they Achievable?

Consider the following when reviewing draft ATCs and final PTOs:

BMPs

• Key for operating CASP – ideal for operations whether a requirement of

the air district or not

• Include management practices to:

▪ Maintain Composting progression through:

– Temperature ranges

– Oxygen levels

– Moisture levels

▪ Minimize:

– Odors

– Dust emissions

Lessons Learned/to be Learned

• White Paper Concerns as Realities

▪ Limited availability and access to ERCS

▪ Source Testing

– Inconsistencies of test protocols

– Inconsistencies in test requirements

▪ Not all air districts have specific regulations and/or rules directed to

composting operations

Questions?

Contact Information

Maria Bowen

maria.bowen@tetratech.com

Suzan Pankenier

suzan.pankenier@tetratech.com