In California, local air pollution districts set operational rules and limitations for businesses that emit “criteria pollutants.” In many rural areas, district boundaries follow county lines. In other areas, districts are multi-county entities that address air problems regionally. Local air pollution districts are led by their own executive boards, typically comprised of county supervisors and city council members. They are supervised by the U.S. Environmental Protection Agency. Under the federal Clean Air Act, local air quality districts must produce and implement plans for cleaning up any pollutant that exceeds federal standards.
Local air districts are not able to enact rules that restrict “mobile sources” including cars, trucks, locomotives, and other vehicles. Only “stationary sources” of air pollution fall under their control. Mobile sources are regulated by the California Air Resources Board.
Stationary sources include industrial sources. As obvious sources of pollution–like power plants or refineries–reduce their emissions, local air pollution districts increasingly look toward less obvious sites–such as organic recycling operations–as potential places to reduce emissions of either criteria pollutants or their precursor chemicals, which are also subject to regulation. Actively composting piles of organic feedstocks emit volatile organic compounds (VOC), which can react in the atmosphere with oxides of nitrogen (NOx) to make ground-level ozone, a criteria pollutant. VOCs can also react with ammonia (NH 3) to create fine particulates (alternatively referred to as particulate matter (PM 2.5), another criteria pollutant). VOCs are a class of more than 1,000 chemicals with greatly varying degrees of reactivity and toxicity. Some VOCs may be considered desirable, such as the ones which give off the scent of lemons, pine, or an expensive perfume. Others, like cadaverine, are extremely offensive. Common VOCs that are actually quite dangerous include benzene and formaldehyde.
The amount of VOCs or greenhouse gas (GHG) emissions released during composting appears to be highly variable, and is influenced by feedstocks, management practices, and even climate. The relationships between the types of gases being emitted at any one time are complicated and remain poorly understood.
Compost White Paper
Composting White Paper-Discussion of air quality permitting and regulatory issues for expanding composting infrastructure
California law contains ambitious goals to divert an increasing percentage of compostable organic wastes from landfills. To meet those goals, CalRecycle convened a working group including the California Air Resources Board (CARB), the California Air Pollution Control Officers Association (CAPCOA), and representatives from the 35 air districts represented by CAPCOA, to identify and pursue potential solutions to challenges currently faced by composting facilities when applying for air permits. In August 2018, this group released a discussion paper entitled “Composting in California: Addressing Air Quality Permitting and Regulatory Issues for Expanding Infrastructure.” The working group conducted two workshops in October 2018 to receive comments from the public and stakeholders. This updated paper includes feedback from those workshops:
Compost White Paper: Coming Soon
CARB, CAPCOA, and CalRecycle are continuing to collaborate on potential solutions and next steps. If you would like to receive announcements on this process, please sign up for the Organic Materials Management listserv to be kept up-to-date on developments!
Air District Rules
South Coast Air Quality Management District (AQMD)
The South Coast AQMD is comprised of all of Orange County, Los Angeles County except for the high desert, the urbanized southwest corner of San Bernardino County, and Riverside County except for the area near the Nevada border. Formed by legislative action in 1976, the district has executed one of the most aggressive anti-smog campaigns in history. Because of these actions, the air in the Los Angeles basin, particularly inland valleys directly to the east of downtown has improved dramatically. Despite these efforts, the estimated 16 million people living within the AQMD still breathe air that ranks at or near the very worst in the annual U.S. air quality rankings.
- Rule 1133: The District adopted the first in this series of rules in 2003. The greenwaste composting rule was adopted in 2011. Composting And Related Operations–General Administrative Requirements
- Rule 1133.1: Chipping and Grinding Activities
- Rule 1133.2: Emission Reductions From Co-Composting Operations
- Rule 1133.3: Emissions Reductions from Greenwaste Composting Operations
San Joaquin Valley Unified Air Pollution Control District
The district, known as Valley Air, is comprised of eight counties: San Joaquin, Stanislaus, Merced, Madera, Fresno, Kings, Tulare, and the western half of Kern. This is California’s agricultural heartland, and air pollution resulting from agricultural operations has proven both difficult to quantify and difficult to regulate. The district is spanned by two major north-south highways with heavy diesel truck traffic that the district cannot regulate. Years of effort have improved air quality, but not as dramatically as the in Los Angeles basin. Theoretically, the district could shut down every stationary source within its boundaries and still not attain U.S. ozone standards. All of the district’s major metropolitan areas, and several of its smaller ones, regularly rank among the U.S. cities with the worst air.
The district adopted its bio-solids co-composting rule in 2007 and its greenwaste composting rule in 2011.
Composting Emissions and Data Research
ARB Emissions Inventory Methodology for Composting Facilities
A summary of air emission researchPDF download specific to composting operations that was completed by the year 2015.
Solar-Powered Aerated Static Piles (ASP) With Compost Cap
Reaching the 75 percent recycling and composting goals of California’s Mandatory Commercial Recycling law will require new ways of managing organic materials, which make up the largest share of materials still going to landfills. In 2012 CalRecycle partnered with the Association of Compost Producers, the City of Bakersfield, O2 Compost and emissions consultants Chuck Schmidt and Tom Card to test the potential emissions reductions and sustainability enhancements from using a small-horsepower positive aeration system hooked to a photovoltaic power system, coupled with a biofilter compost cap for emissions control. The project was funded by the San Joaquin Valley Air Pollution Control District through its Technology Advancement Program. The project was hosted by Harvest Power at its Tulare location. An electric conveyor system was designed and built by Kevin Barnes, compost site manager for the City of Bakersfield, to move feedstocks directly from the grinder to the pile without the use of diesel power.
The project showed VOC emissions reductions of nearly 99 percent for the aerated system, along with significant reductions in ammonia (NH3) and greenhouse gas (GHG) emissions, when compared to windrows made out of the same materials on the same day (see table ES-1). Diesel use in pile construction and active-phase management was reduced by 87 percent compared to typical windrows. Water savings from the aerated static pile system averaged around 20 percent, and the footprint needed for the ASP system is some 55 percent smaller than that required by windrows. Compost produced through the ASP system was similar in quality and maturity to the product from normally managed windrows after 30 days.
Ozone Formation Potential Study
CalRecycle partnered with the School of Civil and Environmental Engineering at UC Davis to perform the first-ever assessment of the ozone formation potential of composting emissions. The initial research was funded by a combination of composters and public agencies, and the results from that work were published in the peer-reviewed journal, Atmospheric Environment, in March 2011. The second half of the study expanded on the first round of research and also tested the impact of an emissions reduction practice on ozone formation. In both studies, traditional VOC measurement techniques were combined with the use of a mobile ozone formation chamber to ensure that no major ozone-forming emissions were ignored.
- Peer-reviewed article in Atmospheric Environment: “Volatile Organic Compound Emissions from Green Waste Composting: Characterization and Ozone Formation“
- CalRecycle publication: An Investigation of the Potential for Ground Level Ozone Formation Resulting from Compost Facility Emissions
Subsequent work to investigate the ozone formation potential of biosolids co-compostPDF download was funded by members of the California Association of Sanitation Agencies. Whether or not the addition of food waste to composting feedstocks would influence the types of VOCs emitted from piles is a missing piece of this puzzle. Funding is being sought to complete this work.
Nitrous Oxide (N2O) Study
This report presents the results of research on greenhouse gas emissions of methane, nitrous oxide, and carbon dioxide associated with the composting process and application of composted green materials to agricultural lands. UC Davis researchers studied emissions from traditional open windrow and aerated static pile composting, as well as those associated with the application of compost to tomato fields and almond orchards.
The Modesto Study
CalRecycle, then known as the California Integrated Waste Management Board (CIWMB), collected and analyzed 100 emissions samples from four compost windrows built and managed at the city of Modesto’s composting facility. The study calculates a life-cycle VOC emissions factor for greenwaste and food waste windrows, and also tests the emissions-reducing potential of two best management practices.
- Emissions Testing of Volatile Organic Compounds from Greenwaste Composting at the Modesto Compost Facility in the San Joaquin Valley, available on CalRecycle’s Publications Catalog webpage.
- Article about the Modesto Study, “Measuring and Controlling Composting Emissions,” published in BioCycle magazine.
Compost vs. Biogenic Emissions
CalRecycle funded research at San Diego State University to determine whether emissions from the decay of organic materials vary based on whether the materials are composted or allowed to decay in an uncontrolled environment. The study concluded that VOCs are “very likely to be biodegraded within the composting matrix, and thus result in lower emissions when composted than if the materials were to be handled differently.” This research was first published in Compost Science and Utilization.
- Biogenic Emissions from Green Waste and Comparison to Emissions from Composting. An article in the Compost Science and Utilization journal focusing on compost process management techniques. If you require special accommodation to access this document pursuant to the Americans with Disabilities Act, please contact the Office of Public Affairs at (916) 341-6300 or firstname.lastname@example.org.
Best Management Practices
The most cost-effective way to reduce emissions from compost operations may be to carefully control operational variables in order to provide the best possible environment for the aerobic organisms which power composting. Most composters do these things purposefully; others may do it unwittingly, inconsistently, or not at all. It’s known that poorly managed piles smell bad and attract bugs; it is also likely they produce more pollution than well-managed piles, and in doing so may lose some of the nutrients which benefit the compost end user.
Even well-managed piles can have sections which go “anaerobic.” That means a lack of oxygen has depleted the desirable microbes which break down organic wastes, and has allowed other microorganisms which operate without the presence of oxygen to take their place. Emissions of methane, ammonia and other VOCs like cadaverine or putrescine seem to be related to anaerobic conditions.
While the types and amounts of emissions may be closely related to actual feedstocks (which vary seasonally), it is thought that the following variables influence emissions, and that optimizing these variables may significantly reduce composting emissions.
- Initial carbon-nitrogen ratio: Piles which have too much nitrogen may lose nitrogen to the atmosphere in gaseous form. Excessive carbon may slow or halt decomposition.
- Moisture content: Piles which are too wet may go anaerobic. Piles which are too dry may not compost well or may get too hot. In California, composters generally add water to piles during the warm months and when aerating. In other sections of the country, piles must be protected from excessive rain.
- Temperature: Piles which are too hot kill valuable micro-organisms and may volatize more compounds than is optimal. Cold temperatures may indicate an anaerobic pile. Composters are required to maintain pile temperatures greater than 131ºF for 15 days in order to kill pathogens.
- Oxygen content: Lack of oxygen impedes or kills aerobic organisms, leading to anaerobic conditions. Blowers inject oxygen deep into the pile. Windrow turners fluff up the pile, allowing oxygen to penetrate. Lowering the bulk density of composting feedstocks generally improves oxygen content. Oxygen penetration into actively composting piles can be enhanced by blending in large particles, such as oversized materials screened out at the end of the compost process.
CalRecycle Research on Best Management Practices
CalRecycle (then CIWMB) completed emissions tests on greenwaste composting designed to evaluate emission reductions that could be achieved by controlling feedstock mixtures and aeration techniques. Two blends of feedstock were used: a woody blend (high carbon-to-nitrogen ratio) and a grassy blend (low carbon-to-nitrogen ratio). Two levels of aeration were evaluated as well: static windrows (natural convection only) and mechanically turned windrows. The tests were conducted at Tierra Verde Industries in Irvine, in Southern California. Test results indicated that ammonia emissions were extremely low and should not be a concern for greenwaste composting. The emissions from the woody blend were lower than the grassy blend. And, changing the aeration techniques altered the emission profiles over time. However, it is difficult to conclude whether aeration techniques lowered the total emissions.
- Best Management Practices for Greenwaste Composting Operations: Air Emissions Tests vs. Feedstock Controls & Aeration Techniques
Emissions-reducing best management practices tested at Modesto included a “pseudo-biofilter compost cap,” and a pair of commercial inoculants blended into and sprayed upon a windrow. The compost cap, a 4-to-6-inch layer of finished compost covering the newly formed windrow, acts as a biofilter to destroy emissions. The inoculants stimulated beneficial microbes and helped form a crust on the active compost pile. Both practices resulted in emissions reductions during the initial two weeks of composting. However, the pseudo-biofilter was more effective, reducing emissions by about 75 percent during the first two weeks. This is significant because the Modesto study suggests that roughly 80 percent of all emissions occur during the first two weeks of composting.
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