In a precedent-setting ruling that ultimately could send shock waves throughout the industry, the nation's first air emission control regulations for compost operations recently were approved in southern California.

By Jack Beardwood

While industry professionals agree the immediate impact will be an increase in the cost of doing business in the Los Angeles area, experts expressed a wide variety of views on what could be a new era in composting. Some say the rules could be the first step toward more costly regulations gradually spreading throughout the nation.

Rule 1133 requires co-composting and chipping and grinding facilities to register and provide throughput information. With the information they receive, the South Coast Air Quality Management District (SCAQMD) intends to create a database on composting operations. Facilities also will have to provide annual updates on their operations.

Rule 1133.1 establishes holding or processing time limits for chipping and grinding activities in order to prevent inadvertent decomposition associated with stockpiling greenwaste or foodwaste.

Perhaps the most expensive hit for the industry is contained within 1133.2. Co-composters will be required to enclose their operations (unless they can come up with an approved alternative plan) and allow for the aeration of materials and venting of emissions to a control system or a biofilter. New facilities will be required to provide a control efficiency of 80% for volatile organic compounds (VOCs) and ammonia emissions for both active and curing phases, while existing plants will have to prove a 70% efficiency.

According to a socioeconomic report prepared by SCAQMD staff, the cost of co-composting biosolids could increase as much as $22/ton. One company estimated the cost of retrofitting their operation at $40 million to $50 million.

While most experts agreed that the co-composting rules were by far the more stringent, some believe the chipping and grinding standards could make survival difficult for the smaller operator.

Paul Ryan, owner of P.F. Ryan and Associates, an industry consultant in Norco, CA, says new chipping and grinding rules will cost one of his clients tens of thousands of dollars.

The cost of registering, as well as the need to process materials within three days, could have a significant effect on what he described as a small operation. "If you can't store stuff on-site, then you have to have the market outlets to get rid of it or you have to cut back on your operations," states Ryan. "Chippers and grinders have never had to come under that kind of scrutiny before. It will have a tremendous impact on the industry because if you are a small marginal operator, you've got some big issues that you have to deal with."

Ryan says there will be more processing outside of the air basin. "In some jurisdictions [where] greenwaste is collected, it's chipped and ground locally and taken to the [California's] Central Valley or the Imperial Valley to be made into compost." The result of added expenses could be more materials going to landfill, he says.

Ryan's suggestions: "Get organized with trade associations or industry groups. Help fight the regulations. I don't believe in just sitting there playing stupid, laying around, and just watching the regulators do what they're going to do. It's important to participate in the regulatory process to make sure the regulators understand what they're doing to you."

For the time being, strictly greenwaste facilities are exempt, even though they reportedly are a significant source of VOC emissions. Cost analysis indicates that the control options are so expensive they might have "adverse impacts" on the industry. Plans are to create new standards for greenwaste operations within two years.

The new rules are seen as part of the solution to help one of the smoggiest regions in the nation meet federal air-quality standards.

According to Barry Wallerstein, executive officer of the SCAQMD, the 75 affected compost facilities emit 6.8 tons of VOCs and 4.7 tpd of ammonia. In comparison, all southland oil refineries emit a total of about 9 tpd of VOCs.

A Question of Fairness

"I'm feeling that the composting industry is being picked on here," remarks Jim McNelly, owner of Renewable Carbon Management LLC in Saint Cloud, MN. "I don't think it's fair. The amount of VOCs coming out of landfills is so much greater than what's coming out of composting sites. I'm thinking, ŒMy gosh, here we're reducing so much and keeping so many other VOCs out of landfills and now they're picking on this? Part of me wants to throw my hands up and say, ŒWhat's next?' We've got a herd of stampeding elephants [landfills] in terms of the impact on air quality, and they're talking about the mice [composting sites]. Part of me would like to say this is a conspiracy. Lightening up on landfills and cracking down on composting. What's wrong with this picture?"

McNelly says the industry is fully capable of managing air missions, but they don't have the cost infrastructure to support the effort. "What composters are getting paid isn't enough for us to meet these rules, at least in California. I don't see the economic effect being taken into consideration, especially while the rules are being lessened on landfills, almost eliminated. There are basically two solutions. One is to fight these new rules as being unfair and protective of the landfill operators. The second approach is to upgrade. They won't be able to upgrade unless they are paid more. This could result in maybe even doubling the cost of composting over windrows."

Jack Broadbent, a spokesman for the United States Environmental Protection Agency, believes SCAQMD should be congratulated for its efforts and the federal government will be monitoring operations to see if similar standards should be imposed in other areas.

"We're going to allow a lot of latitudes to the industry and the South Coast district as they move ahead and implement this rule," he points out. "We're looking to monitor it closely and see if other areas with similar operations should adopt a similar rule. We at EPA believe the South Coast [district] has established essentially a model for other areas.

"The rules are adopted, the deadlines are firm. The sources need to comply because there are some significant penalties if they do not, but more importantly, the rule represents another step that will help clean up the air in the greater Los Angeles region."

"It has been a long and difficult process, but in the end I guess it will be something we can live with," remarks Matt Cotton, owner of Integrated Waste Management Consulting in Nevada City, CA. "It's a long battle, and I think everybody learned a little bit from it, but overall it's probably consistent with the trend in composting, which is more regulation all the time. I wish there were a little bit more science and a little more time. As long as it's applied fairly, people will be able to live with it."

Cotton says it is too soon to tell what the impacts will be. "Some facilities are going to make the tough choice to either close or move out of the district. I'm certain of that for smaller facilities. It will be very tough for small facilities."

While he sees the standards eventually spreading throughout the state of California, Cotton says he doubts that they will be enacted in other states unless they have similar air pollution problems.

John Gundlach, manager of biosolids for the Inland Empire Utilities Agency (IEUA) in western San Bernardino County, CA, agrees with Cotton that the new standards might result in smaller facilities going the way of the dinosaur. "It will be so expensive to build them, to get the technology needed for the air requirements, and if you don't have the volume of material, it's just going to be difficult for anybody to have it pencil out to build a composting facility.

"What the air board did here was they looked at a model technology," says Gundlach. "They took it a little bit beyond, because most of these facilities where you are doing aerated static pile composting, you don't have to be fully enclosed to capture all of your emissions. That's the difference. In some of these locations, they are partially enclosed and are capturing emissions using a biofilter. What's really happening with our air board is they're saying, ŒHey, biofilters work on treatment of the air. Aerated static piles is a way to make sure you're capturing as much of the emissions as you can.'"

Looking at the bright side, he says the new rules might stimulate new creative technologies that will create new products out of wastes. "There's a lot of things being done in Europe. Maybe through economies of scale and technological advances we can do a lot more to recycle our foodwaste and solid waste."

IEUA is looking at the possibility of utilizing anaerobic digestion to generate methane gas as a renewable energy, he says. "It's getting a lot of attention in Europe, and it's getting a lot of attention here. That's what our big focus is."

IEUA is joining forces with the Sanitation Districts of Los Angeles County (SDLAC) to build a new facility at Rancho Cucamonga. Gundlach says the enclosed facility, which will incorporate aerated static-pile composting and use a very large biofilter, will exceed requirements. "I guess we are alarmed in as we certainly had to put some expense into the facility related to the new standards," Gundlach comments.

"Basically what they're [the air control district] trying to do here is avoid open-air outdoor composting operations, particularly windrow type, that are being practiced now in southern California," points out Eliot Epstein, a chief environmental scientist for Tetra Tech and a member of the board of directors for the US Composting Council. "I think it could cause significant hardships and increase the cost of composting for communities in the Los Angeles area."

Epstein says the requirement that compliance plans be submitted at least one year prior to the startup for new facilities creates unnecessary hardship by delaying their opening date, especially for small firms. "Small operators can purchase containerized systems or construct enclosed systems in less than 12 months. I think that could make it very hard on small operations. It will be more costly and lengthier in time. Time is money."

He also was critical of the 22-day active composting cycle requirement for co-composting. "The number of days of [active] composting depends on the type of feedstock. The longer one has to process material, the more expensive it is. It takes more space, more materials handling, and more capital - pavement and buildings. Rule 1133.2 is concerned with VOCs and ammonia. For most feedstocks, these compounds are at a low level in 10 to 14 days."

Epstein also questions the need for a required 40-day curing period. "Obviously the longer one needs to cure, the more expensive the operation. The rule should not have any time constraint but be based strictly on the condition of the compost."

He says he does not believe the new standards will result in less composting due to the increased cost of doing business. "I think composting still is going to continue to go well, particularly in biosolids. Many states prohibit biosolids from going to the landfill because of the high moisture content. EPA and most states are looking toward beneficial use of biosolids. We look at it as a resource. I think biosolids products are going to be much more acceptable to the public. I think we'll see a rise in composting biosolids, especially since a lot of counties in California - Kern County, Kings County, and others - are banning land application of biosolids, so the next least costly beneficial alternative is composting."

Added Costs

John Goodwin, general manager of the Corona co-composting facility owned by Synagro Composting Company of California, says they had proposed building a new plant - which would have met all air standards - but could not generate the needed support to make it fly due to a number of issues, including the large increase in the service cost resulting from the requirements of the new rule.

Philosophically, Synagro supports any new rules when they are based on sound data and economic analysis, he says. "However, the added costs of doing business in compliance with the new rule will likely curtail composting in the district. It is limiting business by requiring controls and facilities that are so costly compared with current rates that alternative residuals management options that are less expensive, such as trucking materials out of the district, are more likely."

"They built some flexibility into the rules to allow for different types of control measures, other than just enclosing facilities," notes Stuart Buckner, executive director of the US Composting Council. "That will allow various management measures to be implemented - such as feedstock preparation, materials handling, process management measures - to minimize emissions, particularly ammonia. These types of measures should be more cost-effective than going to full-scale buildings and enclosures. It is essentially too premature to even guess at what the impact may be. There's going to be some cost factor involved, there's no doubt about that, but hopefully with the various agencies and groups working on developing best management practices, that will minimize the financial impact."

California's Integrated Waste Management Board (CIWMB), which has been pressing local governments to meet the state's 50% waste diversion goal, is concerned that the net effect of the new rule will be to roll back progress on diversion rates. Steve Jones, the board's industry representation, says because CIWMB and SCAQMD worked together, the rules adopted in January were much better than the ones originally proposed. He does feel, however, that the cost of compliance will still need to be monitored.

"Local government and the private sector have invested millions of dollars in new collection and processing facilities to divert materials from disposal," reports Jones. "In 2002 the statewide diversion rate reached 48% and our composting and mulching industry is very much part of the success. Roughly 40% of our wastestream is green material, so the strength and vitality of the organics diversion infrastructure is critical."

Brenda Smyth, senior integrated waste management specialist for CIWMB, says it remains to be seen whether alternative strategies will succeed in attaining compliance. "We feel good about them entertaining flexible or alternative compliance strategies. In a practical sense, however, it remains to be seen how it's going to play out with these compliance plans. I don't know how difficult an alternative compliance strategy will be to get approved. The other thing that needs more work is the biofilter performance. Will they be able to maintain that efficiency level over the long term, and how expensive will that be?"

She notes that the new rules are among the most expensive ever imposed by the district. "I know that ultimately this is going to cost maybe $40 million to $50 million per facility to do the enclosure, negative aerated static pile, and biofilter. My concern is how expensive is it going to be, how practical are the plans going to be, so that we can get the best companies continuing to operate and to cover their expenses. And, as with all rules, there may be some casualties involved."

Smyth says CIWMB is testing best management practices at greenwaste facilities to seek operational alternatives that will reduce emissions. It is hoped that what they learn will also help co-composters. Much of their study centers on changing variables, such as feedstock blends or aeration techniques. "You could also test moisture content or pH and temperature - different variables that are a little more passive than a building with [aerated static pile] and blowers and biofilters and all of that - to see if we can operate in the best way possible. We're hoping that this will show some results, but I don't really know whether we can achieve 80% reduction by doing that. I think we can come a long way to reducing the emissions with just some pretty passive measures."

She suggests a closer examination of the carbon-to-nitrogen ratio in the feedstock. "If you blend more woody stock - leaves and branches and grass clippings - into the mix, you can increase your carbon and nitrogen ratio and decrease the odors, which are an indication of emissions."

They also are testing aeration. "Some composters put their materials into a windrow and kind of let them cook on their own for a given amount of time. Others turn their windrows and aerate them. We're trying to look at some very low aerated, naturally vented windrows versus windrows that are aerated with mechanical turning to see if that improves the composting process."

Smyth says there are several variables that good composters use. "They use feedstock controls, they use aeration techniques, they use moisture. They spray water on their piles. Some of them use pH as a variable. Most certainly are monitoring temperature. They don't want them too cold; they don't want them too hot. And they change these variables to control their temperature to stay in the right range. That gives them the most optimum composting environment. Moisture can be a temperature control. Turning probably is one of the best temperature controls when you aerate the pile, but it also has to be the right moisture content because the bacteria that actually biodegrade the material want to have the right moisture content as well. You don't want it too wet or the bacteria can't breath and they drown - and you don't want it too dry. So they have kind of a watering frequency."

Greg Adams, assistant department engineer for air-quality engineering with SDLAC, remarks that the new rules are unnecessarily complicated. One of the issues is the 22-day active compost cycle. Their planned Rancho Cucamonga plant has a 21-day active composting cycle. As a result, just because of that one day of difference, they will have to traverse the district's more "uncertain" alternative process.

"By not having the 22 days, we can't take advantage of the quicker compliance route that's offered in the rule," notes Adams, who also serves as vice chairman of the air committee of the Southern California Alliance of Publicly Owned Treatment Works (SCAP). "We presented information that we didn't think their 22 days was correctly calculated, but by that time they had already made up their minds."

As a result, Adams says every public facility within the air district likely will file under the alternative provisions of the rule. "Everybody has to go through these substantially more complicated, more approval-requiring hurdles to come up with these alternative schemes. You have to submit plans to the SCAQMD staff, you have to build the facilities, you have to do additional testing, you have to come up with additional documentation. We have no choice, even though that particular facility is going to have the cure phase completely covered and the rule does not require that. The alternative compliance route fundamentally is a problem because EPA doesn't like alternative compliance schemes, and traditionally EPA likes a rule to be very hard and fast. They like a stipulated technology where they know they are going to get a percent reduction. But if there is an alternative compliance strategy, then it has to be done almost on a case-by-case basis."

Adams's agency has the responsibility of disposing of some 600,000 tpy of biosolids. He relates that SCAP is concerned that the new rules will hinder the recycling of biosolids. "We're very guarded. We believe recycling of biosolids is a good thing. Fundamentally, anything that makes recycling more expensive or more difficult to do thwarts our goal of beneficial recycling."

He says SCAP is concerned that other counties - possible outlets for recycling of biosolids produced in southern California - will approve similar rules. "If all the counties up and down California adopt the rule, new facilities one way or another will have to come up with an 80% control efficiency, and that's a tremendous cost."

Change in Emissions

Adams states that ammonia emissions can be virtually eliminated without too much difficulty. VOCs are what can be more of a problem.

If you have a low-pH water stream, you can install a scrubber to remove the ammonia, he says. If you don't have low-pH water, you can reduce ammonia by not producing it in the first place. By varying the ratio of biosolids, you can dramatically reduce the ammonia level.

In tests that took place at Griffith Park (which cost a handful of agencies more than $300,000), they attained a ratio of biosolids that was 62.2% by weight of the entire mixture. "The city normally operates a biosolids mixture that is 38.8% by weight of the total mixture. We know at that level [62.2], it hardly produces any ammonia at all. It's really a drastic change in emissions."

That alone might get you the 80% ammonia reduction that is needed, he says. In addition, using a biofilter, an aeration system that reaches the entire pile, and several other alternatives that are listed in the rules should do the trick.

Adams observes that VOCs are more difficult to reduce, mainly because the performance of biofilters can be unpredictable. "We think that a well-operated new biofilter is going to be very effective on ammonia. But we do have a problem with VOCs. At the very last moment the [SC]AQMD staff agreed to work with us to look at the long-term efficacy of biofilters on VOC removal and also to work with us in coming up with some surrogate testing methods that allow us to quickly analyze the effectiveness of our biofilter and our control techniques."

One way to help reduce VOCs is to create more efficient piles, according to Adams. For instance, a trapezoidal pile allows for the aeration system to reach the entire pile, as opposed to a very, very tall triangular pile where the aeration system cannot reach the top of a 10- or 12-ft. pile. Such a design with continuous aeration could reduce total VOCs dramatically.

Becky Smith, marketing specialist for Peterson Pacific, a manufacturer of heavy equipment for the recycling and reprocessing industry located in Eugene, OR, says she views the new rules as a survival-of-the-fittest situation. Companies that meet the challenges will thrive. "It looks like there are very few of our customers who will be directly affected," she notes, "but we're keeping it on the radar screen because we want to offer our customers the best solutions out there. I would be surprised if in 10 or 15 years this isn't something that a lot of our customers face. California always seems to be one of the first states to enact stricter environmental policies."

Initially the new regulations will result in some reductions in recycling as a result of increasing recycling prices, Smith points out. It also will result in scaring off people from entering the business. "It's unfortunate that the district would institute those barriers, but it's just like everything else in business; you have to find your way around it. It may turn out that the folks that learn how to do this best will actually create bigger profits for themselves. That's where we see ourselves, helping customers out with that sort of strategy. If it were national, I would be a lot more concerned, but at this point we're looking at this as a test case. We're sort of taking a wait-and-see approach. I think the people who are processing those types of materials will have to get better. And that's part of what happens when a market develops and matures. The legislation creates new needs to become more efficient."

Tim O'Neill, president of Engineered Compost Systems in Seattle, WA, says the new standards likely will result in more technologies being developed. "There's a lot of organic wastestreams that could be composted that are not. A lot of them end up in landfills, which is, in many ways, just pushing the cost off until later because downstream there's problems associated with aging landfills. I think that people are going to have to take a look around and see what their options are. I'm sure that investigating the cost performance of in-vessel systems will be one of the first things they will look at."

Engineered Compost Systems produces vessel composting facilities that are as small as 40 yd.³ - based on a rolloff container technology - to large concrete vessels that are as large as 300 yd.³

"Generally we feel that high-rate composting in buildings is problematic," he states. "When you have really active composting in a building, the atmosphere inside tends to be very hard on the building and very hard on the workers, quite unpleasant to be in. There are some exceptions to that. There are facilities that manage a lot of things - air changes - but then you end up with other technical problems of huge biofilters, having to add lots and lots of moisture to material. We're proponents of what we call low-head-space composting, where there's very little atmosphere above the composting bed and we control the volume very well and not expose workers or the building to that compost environment."

O'Neill says the benefits of his systems are very limited worker exposure, minimized air-handling requirements by the compost environment, prevention of corrosion and degradation of the building, minimized need for a larger biofilter, better uniformity provided through the biomass that is being composted, better process control, and better environmental control.

In addition, in-vessel material doesn't dry out, so you don't have to re-add water, he says. "It keeps the composting active. The vessels themselves are insulated so during colder parts of the year it makes it easier for them to meet their temperature profiles, plus they don't have to cover the pile with an insulating material so it lessens material handling. Then there's the issue of odor control. Quite a few facilities in North America have been shut down due to odor problems, many lawsuits. An in-vessel system pretty much takes care of that problem if the operators practice good housekeeping."

According to O'Neill, one of the big issues is the use of a bulking agent. "When you go in-vessel, you can often get away with less bulking agent - that is a richer mix - than you can in a static aerated pile. That is sometimes helpful. Some of the sites we have looked at in southern California [are] finding [that] a reasonable source of amendment has been a challenge."

Bulking agents might include sawdust, wood chips, or even agricultural products, such as rice hulls. "They add carbon and porosity and absorb moisture for biosolids," he notes.

Debbie Linder, director of operations for Ag-Bag International Ltd. in Warrenton, OR, claims that their system will help composters comply with the new rules. "Basically it's an in-vessel system where we fill the bags with any kind of organic material and perforated pipe is laid down inside the bags. When the bags are filled, they are hooked up to a blower system, so we're able to control the oxygen, control the moisture, and have a system that is controlling odor and providing a more efficient system for the microbes to work because we have consistent moisture, consistent oxygen, consistent temperatures within our enclosed system."

She points out that it can be used for all kinds of organic materials. The best part is it doesn't require constructing a building. "Our system is a low-tech way to have an in-vessel system without the capital expenses of building a building."

Linder says southern California's emission standards have the composting industry abuzz nationwide. "There are opinions in the field that these regulations will affect how others do composting in other areas. There is a lot of speculation that other parts of California and other states might look to South Coast as maybe a way of the future as far as regulations. We've been doing a lot of [research and development] on sites already, and we feel comfortable with the regulations."

Writer Jack Beardwood has more than 20 years of professional experience working with newspapers and magazines.

MSW - July/August 2003