3Amend Rule 1133.1 – Chipping and Grinding Activities, and Adopt ...

BOARD MEETING DATE: July 8, 2011 AGENDA NO. 37 

PROPOSAL: Amend Rule 1133.1 – Chipping and Grinding Activities, and 

Adopt Rule 1133.3 – Emission Reductions from Greenwaste 

Composting Operations 

SYNOPSIS: Proposed Rule 1133.3 will implement 2007 AQMP Control 

Measure MCS-04 by establishing best management practices to 

reduce VOC and ammonia emissions from greenwaste composting 

operations. 

COMMITTEE: Stationary Source, April 15 and June 17, 2011, Reviewed 

RECOMMENDED ACTIONS: 

Adopt the attached resolution: 

1. Certifying the CEQA Final Environmental Assessment for Proposed Amended Rule 

1133.1 and Proposed Rule 1133.3; and 

2. Amending Rule 1133.1 and Adopting Rule 1133.3. 

EC:LT:JW:TG:JHL 

Barry R. Wallerstein, D.Env. 

Executive Officer 

Background 

Proposed Amended Rule 1133.1 (PAR 1133.1) will update the rule to be consistent with 

state requirements for greenwaste that is chipped and ground. Proposed Rule (PR) 

1133.3 would implement Control Measure MCS-04 in the 2007 Air Quality 

Management Plan (AQMP). 

PAR 1133.1 covers approximately 70 facilities and would establish best management 

practices (BMPs) for chipping and grinding of greenwaste to produce materials other 

than compost material. Amending Rule 1133.1 is proposed to better manage stockpile 

operations associated with chipping and grinding activities, which will be consistent 

with current greenwaste processing requirements established in the state regulation Title 

14 of the California Code of Regulations (CCR). No emission reductions are quantified 

for this rule amendment.

PR 1133.3 would implement Control Measure (CM) MCS-04 of the 2007 AQMP and 

seeks to establish operational BMPs for greenwaste composting operations that produce 

compost material. PR 1133.3 would affect 17 facilities and would apply to greenwaste 

composting operations involving greenwaste, woodwaste, manure, or foodwaste. PR 

1133.3 would reduce 0.9 ton of volatile organic compounds (VOCs) per day and 0.1 ton 

of ammonia per day from greenwaste composting operations. Cost effectiveness is 

$1,340 per ton of VOC and $1,270 per ton of VOC and ammonia combined. 

Ensuring operational BMPs for chipping/grinding and composting operations is 

important because the South Coast Air Basin (Basin) has not yet attained the state or 

federal ambient air quality standards for fine particulate matter (PM2.5) and 8-hour 

ozone. This proposal will help reduce VOC and ammonia emissions from inadvertent 

decomposition from greenwaste composting operations. 

Emissions from composting result from the decomposition of material after it is preprocessed 

by grinding the material and forming it into piles. Piles are managed by 

adding moisture and turning to maintain aerobic conditions. The 17 identified facilities 

compost approximately 416,000 tons of greenwaste material per year based on recent 

data and emit approximately 2.7 and 0.4 tons per day VOC and ammonia, respectively. 

It is likely that composting-related emissions will grow in the future, provided that 

composting continues to be a desirable waste diversion and resource conservation 

practice. The largest composting facility has VOC emissions comparable to a refinery. 

Staff worked extensively with industry stakeholders to develop a proposal that reduces 

emissions, but keeps the industry viable, as a valuable resource. After adoption, staff 

will continue to work with stakeholders to evaluate other greenwaste uses. 

Proposal 

Proposed Amended Rule 1133.1 

Amendments to Rule 1133.1 align the rule with current requirements in place by the 

Local Enforcement Agency (LEA). Specifically, greenwaste would be required to be 

chipped or ground and utilized on-site or removed from the site within 48 hours of 

receipt, excluding official federal and state holidays, or up to seven days maximum, 

with approval from the LEA. Chipping and grinding facilities cannot take foodwaste, 

unless otherwise allowed by the LEA to handle foodwaste. The amended 48 hours or 

seven days maximum holding time requirement is to conform to Title 14, Division 7, 

Chapter 3.1 of the CCR, which is currently enforced by the county-level LEAs, and is 

more stringent than the previous holding time requirement of Rule 1133.1. 

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. A biomass 

power generation facility or a facility processing material as a biomass fuel for a 

biomass power generation facility would be exempt from the holding time requirement, 

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provided that the material temperature is maintained at below 122 degrees Fahrenheit or 

the moisture content is less than 30 percent and records of the temperature or moisture 

measurements are maintained on-site. With this exemption, the definition of 

woodwaste has been modified to include the woody materials of greenwaste that exceed 

2 inches in any dimension into woodwaste. 

Proposed Rule 1133.3 

PR 1133.3 would require the operator to chip or grind, as necessary, and use greenwaste 

for on-site composting as allowed by the LEA. This requirement is consistent with the 

state regulation. PR 1133.3 requires the operator to implement BMPs to minimize 

emissions during the composting process. 

The proposed BMPs are covering each initial active phase compost pile with finished 

compost and/or compost overs within 24 hours of formation for each composting cycle 

such that the top is at least six inches thick. The pile shall not be turned for the first 

seven days of the active phase of composting. For the first 15 days of active phase of 

composting, water would be required to be applied to the compost pile, as necessary, 

within six hours before turning such that the top half of the pile is wet to a depth of 

three inches. If the compost pile needs to be turned within the first seven days for 

managing temperature or for pathogen reduction purposes, the operator would not need 

to re-apply the compost cover and would need to apply water for the balance of the rest 

of the 15 days of the active phase. 

PR 1133.3 allows up to 20 percent manure, by volume to be considered as greenwaste 

composting. More than 20 percent manure, by volume, would be considered as cocomposting 

and subject to Rule 1133.2. Foodwaste would also be considered for 

greenwaste composting, and the level of emission control is determined based on the 

annual facility-wide foodwaste throughput. Foodwaste would be required to be used for 

on-site composting within 48 hours of receipt or covered with screened or unscreened 

finished compost until used, unless otherwise required by the LEA. 

Up to 5,000 tons per year of foodwaste throughput can be composted without the need 

to install an emission control device and would require BMPs. The annual throughput 

calculation may exclude any non-putrescible materials and greenwaste that are 

separated either before or after composting and shipped off-site for disposal, provided 

they are quantified and appropriate records are maintained. 

For operations with annual foodwaste throughput of greater than 5,000 tons per year, an 

emission control device would be required to be installed on any active phase 

composting pile containing more than 10 percent foodwaste, by weight. The emission 

control device would be required to have at least 80 percent overall system control 

efficiency for VOC and ammonia, respectively. If a control device is used, the compost 

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cover and watering requirements do not apply. Currently, none of the 17 facilities 

process more than 2,500 tons of foodwaste per year. 

Community composting, nursery composting, backyard composting and recreational 

facility composting are exempt from the requirements of this rule, provided that the 

operation is not subject to the LEA Notification or Permit regulations. 

Public Input 

During the development of PAR 1133.1 and PR 1133.3, staff worked with a Working 

Group and invited participation from environmental and community group 

representatives, representatives from industry associations and potentially affected 

facilities, government (US EPA, CARB and CalRecycle) staff, and consultants. District 

staff also worked closely with San Joaquin Valley Air Pollution Control District 

(APCD) staff for this rulemaking process as they are in the process of developing a 

similar rule. Four Working Group meetings were held. District staff made several site 

visits and met with industry representatives numerous times to address issues related to 

the proposed rule requirements. A Public Workshop was held on February 9, 2011 with 

approximately 70 people attending. Twenty-four comment letters were received for this 

rulemaking process since the Public Workshop. 

Key Issues 

Several key issues were raised and addressed during the rule development process. 

Attachment B provides additional information. 

Several changes have been made to the rule since the February 9, 2011 Public 

Workshop, based on the comments received. These revisions were released June 7, 

2011 for a subsequent 30-day public notice and review period in advance of the July 8, 

2011 Public Hearing. Key issues resolved for the June 7, 2011 version of the rule for 

the Set Public Hearing are: 

• One time finished compost and subsequent watering during the first 15 days of 

active phase would be required as low-cost BMPs; 

• Greenwaste material holding time requirement harmonized with the state 

regulation; and 

• Non-putrescible materials may be excluded in calculating annual foodwaste 

throughput. 

Since the Set Hearing documents were made available, industry representatives met 

with staff regarding 5 key remaining issues/questions. These included modification to 

the foodwaste definition, greenwaste holding times, compost cover application time, 

water application time, and blending operations. Staff was able to address four of the 

five issues within the rule, which are discussed in Attachment B in more detail. These 

changes do not significantly affect the meaning of the proposed rule or affect the 

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conclusions in the CEQA document. Staff and stakeholders agreed to work together 

during rule implementation to address the question regarding blending operations. 

The Resolution contains commitments to form a working group for implementation and 

for staff to report back to the Stationary Source Committee on working group activities 

within one year of rule implementation. Additionally, staff will continue to evaluate 

emissions and potential emission reduction measures, and to develop future rule or 

control measure requirements for organic waste, as necessary, for the Board’s 

consideration in the future. 

California Environmental Quality Act (CEQA) 

Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, 

the AQMD has prepared a Draft Environmental Assessment (EA) for the proposed 

amendment of Rule 1133.1 and proposed adoption of Rule 1133.3. The Draft EA was 

released for a 30-day public review and comment period from June 2, 2011 to July 1, 

2011. The Draft EA concluded that no impacts would occur due to the implementation 

of the proposed amendment of Rule 1133.1 which establishes BMPs for chipping and 

grinding activities consistent with LEA enforcement of Title 14. The Draft EA also 

concluded that all environmental impacts, including air quality impacts are less than 

significant due to the implementation of Proposed Rule 1133.3. 

Since the release of the Draft EA, minor modifications have been made to the 

document. However, none of the modifications alter any conclusions reached in the 

Draft EA, nor provide new information of substantial importance relative to the draft 

document. As a result, these minor revisions do not require recirculation of the Draft 

EA pursuant to CEQA Guidelines § 15073.5. Therefore, the Draft EA is now a Final 

EA and is included as an attachment to this Governing Board package. 

Socioeconomic Analysis 

There are no costs associated with the proposed amendments to Rule 1133.1 because 

they align with the existing requirements in Title 14. 

Costs associated with implementation of Proposed Rule 1133.3 include finished 

compost cover for newly formed compost piles, the application of water prior to 

turning, and recordkeeping. These costs are based on existing facilities and their 

throughput. Since no facilities are processing near the 5,000 ton per year foodwaste, no 

costs for add-on controls were assumed for this analysis. The total average annual 

compliance cost from 2011 to 2025 is projected to be $31,000 per facility or $0.53 

million for all the affected facilities. Costs are proportional to throughput and range 

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jobs in the four-country region, could be forgone annually, on average, between 2011 

and 2025. This is within the noise (uncertainty) of the model. 

AQMP and Legal Mandates 

There is no legal mandate for PR 1133.1. However, this rule would harmonize the 

requirements for chipping and grinding operations with state regulation, Title 14, 

Division 7, Chapter 3.1 of the CCR. Proposed Rule 1133.3 is a greenwaste composting 

rule that would implement control measure MCS-04 of the AQMP. 

Implementation Plan 

Existing AQMD resources will be sufficient to implement the amended and new rules. 

Attachments 

A. Summary of Proposal 

B. Key Issues and Responses 

C. Rule Development Process 

D. Key Contacts List 

E. Resolution 

F. Proposed Amended Rule 1133.1 

G. Proposed Rule 1133.3 

H. Final Staff Report 

I. Final Socioeconomic Assessment of Proposed Amended Rule 1133.1 and 


J. Final EA for Proposed Amended Rule 1133.1 and Proposed Rule 1133.3 

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ATTACHMENT A 

SUMMARY OF PROPOSAL 

Proposed Amended Rule 1133.1 – Chipping and Grinding Activities, and Proposed 

Rule 1133.3 – Greenwaste Composting Operations 

PAR 1133.1 

• Greenwaste needs to be chipped or ground and utilized on-site or removed from the site 

within 48 hours of receipt, excluding official federal and state holidays, or up to 7 days 

maximum, with approval from the LEA. 

• Taking foodwaste is not allowed at chipping and grinding facilities, unless otherwise 

allowed by the LEA. 

• Amended/additional exemption provisions: 

o Chipping and grinding activities of greenwaste derived from the site and utilized onsite, 

provided less than 1,000 cubic yards of materials are either sold or given away. 

o A biomass power generation facility or a facility processing material as a fuel for a 

biomass power generation facility provided the material temperature is maintained at 

below 122 degrees Fahrenheit or the moisture content is less than 30% and the 

temperature or moisture content measurements are maintained on-site. 

o The operator of a landfill or biomass power generation facility, provided that chipping 

and grinding of greenwaste is not performed on-site. 

PR 1133.3 

• Greenwaste shall be chipped or ground, as necessary, and used for on-site composting as 


• Effective upon start-up for new greenwaste composting operations and effective (4 months 

after date of adoption) for existing operations, the operator processing greenwaste only or 

up to 20 percent manure, by volume, or up to 5,000 tons per year of foodwaste throughput 

needs to cover each active phase compost pile with screened or unscreened finished 

compost and/or compost overs within 24 hours of initial pile formation such that the top is 

at least six inches thick and the pile is not turned for the first seven days of the active phase 

of composting.



• For the first 15 days inclusive of the initial pile formation for the active phase period, the 

operator is required to apply water as necessary to the surface area of the top half of each 

active phase composting pile within six hours prior to turning such that the top half of the 

pile is wet to a depth of three inches. Alternatively, the operator may apply water during 

turning using a windrow turner which is equipped with water spraying technology during 

the entire windrow turning process. 

• If the pile needs to be turned within the first seven days for managing temperature or 

pathogen reduction, the operator does not need to re-apply the finished compost cover but 

needs to apply water for the first 15 days of the active phase. 

• Foodwaste needs to be used for on-site composting within 48 hours of receipt or covered 

with screened or unscreened finished compost until used, unless otherwise required by the 

LEA. 

• Effective (date of adoption), the operator processing greater than 5,000 tons per year of 

foodwaste throughput is required to install an emission control device with an overall 

system control efficiency of at least 80 percent, by weight, on any active phase composting 

pile containing more than 10 percent foodwaste, by weight. 

• PR 1133.3 also includes exemptions for: 

o Composting facilities subject to Rule 1133.2 – Emission Reductions from Co- 

Composting Operations. 

o The operator of any greenwaste composting operation who voluntarily installs an 

emission control device from the mitigation measures application. 

o Community composting, nursery composting, backyard composting, and recreational 

facility composting, provided the operation is not subject to the LEA Notification or 

Permit regulations.

ATTACHMENT B 

KEY ISSUES AND RESPONSES 



• Issue: Composting is beneficial to reducing carbon emissions compared to uncontrolled 

natural decay and the proposed rule should develop cost effective emission control 

measures to keep industry viable. 

Response: Staff appreciates the benefits of composting and has worked with industry to 

develop low-cost BMPs. Add-on controls would be required for operations processing 

greater than 5,000 tons per year of foodwaste throughput and more than 10% foodwaste, 

by weight. Currently, none of the existing composting operations process more than about 

half of this amount. 

• Issue: Other uses of greenwaste in the District should also be evaluated and controlled. 

Response: Staff has worked with industry and CalRecycle staff to evaluate other uses of 

greenwaste and is appreciative of the input provided. Staff recognizes that more work 

would be required to better evaluate the uses of greenwaste materials in the District and 

develop potential emission control measures. Staff has committed to this work for potential 

future rules or control measures. 

• Issue: There are remaining issues/questions, including foodwaste definition, holding times, 

compost cover and water application times, and blending operations. 

Response: Staff addressed four of five remaining issues. Specifically, the definition of 

foodwaste was modified to exclude non-putrescible materials from the definition. 

Greenwaste holding times were modified to 48 hours of receipt, excluding official federal 

and state holidays, or up to 7 days maximum, with approval from the LEA which is 

consistent with the state regulation. Time to apply finished compost was modified from 3 

hours to 24 hours inclusive of forming the pile and the time to apply water was modified 

from 3 hours to 6 hours before turning. Staff committed to continuing to work with 

stakeholders through an implementation working group and to address any issues as they 

may arise during rule implementation, including the blending-related issues/questions.

ATTACHMENT C 

RULE DEVELOPMENT PROCESS 

Proposed Amended Rule 1133.1 – Chipping and Grinding Activities, and 

Proposed Rule 1133.3 – Greenwaste Composting Operations 

Public Workshop, Board Committee Meetings, and 

Working Group, Industry, and Public Meetings 

Industry Survey conducted to identify universe of sources (2007) 

Four Working Group Meetings held 

Numerous Industry Meetings held, including site visits 

About 850 Notices Mailed for Workshop 

Public Workshop held February 9, 2011 

Stationary Source Committee Briefings held April 15 and June 17, 2011 

CEQA Document 

Draft Environmental Assessment (EA) with no significant adverse impacts was prepared and 

circulated for a 30-day public review and comment period, which ends July 1, 2011. Final 

EA will be prepared and will contain responses to any comments received. 

Socioeconomic Assessment 

A socioeconomic assessment was conducted and provided in the Set Hearing package 

A final socioeconomic assessment has been prepared for the Public Hearing package 

Set Hearing: June 3, 2011 

Draft documents noticed and released for 30-day 

notice June 7, 2011 

Public Hearing: July 8, 2011 

Sixteen (16) months spent in rule development.

ATTACHMENT D 

KEY CONTACTS LIST 

Rule 1133 Working Group 

California Compost Coalition 

Integrated Waste Management Consulting, LLC 

Association of Compost Producers 

Inland Empire Disposal Association 

City of Los Angeles Solid Resource Processing/Construction Division 

Los Angeles County Sanitation Districts 

Riverside County Waste Management Department 

Orange County Waste and Recycling

ATTACHMENT E 

RESOLUTION NO. 11-_____ 

A Resolution of the Governing Board of the South Coast Air 

Quality Management District (AQMD) certifying the Final Environmental 

Assessment for Proposed Amended Rule 1133.1 – Chipping and Grinding 

Activities and Proposed Rule 1133.3 – Emission Reductions from Greenwaste 

Composting Operations. 

A Resolution of the Governing Board of the South Coast AQMD 

amending Rule 1133.1 – Chipping and Grinding Activities and adopting 

Proposed Rule 1133.3 – Emission Reductions from Greenwaste Composting 

Operations. 

WHEREAS, the AQMD Governing Board approved the final Air 

Quality Management Plan in June 2007, which included Control Measure MCS-04 

to ensure best management practices for greenwaste composting; and 

WHEREAS, volatile organic compounds and ammonia are 

precursors to ozone (O3) and particulate matter (PM) which the U.S. 

Environmental Protection Agency (EPA) has identified as an air contaminant and 

has set criteria air pollutant national ambient air quality standards for ozone and 

fine and coarse particulate matter (O3, PM2.5 and PM10), respectively, and the 

South Coast Air Basin has not yet attained these air quality standards and is 

exceeding the corresponding state standards by an even greater margin; and 

WHEREAS, the AQMD staff conducted a public workshop 

regarding Proposed Amended Rule 1133.1 and Proposed Rule 1133.3; and 

WHEREAS, the South Coast Air Quality Management District 

(AQMD) Governing Board finds and determines that Proposed Amended Rule 

1133.1 and Proposed Rule 1133.3, are considered a "project" pursuant to the 

California Environmental Quality Act (CEQA); and 

WHEREAS, the AQMD has had its regulatory program certified 

pursuant to California Public Resources Code Section 21080.5 and has conducted 

CEQA review and analysis pursuant to such program (Rule 110); and 

WHEREAS, AQMD staff has prepared a Draft Environmental 

Assessment (EA) pursuant to its certified regulatory program and state CEQA 

Guidelines Section 15252, setting forth the potential environmental consequences 

of Proposed Amended Rule 1133.1 and Proposed Rule 1133.3; and

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WHEREAS, the Draft EA concluded environmental impacts from 

the proposed project are not significant; and 

WHEREAS, the Draft EA was circulated for a 30-day public review 

and comment period, no comments were received (subject to change), and the 

Draft EA will be revised to include responses to comments received such that it 

will be a Final EA; and 

WHEREAS, a statement of findings and a statement of overriding 

considerations were not prepared because the environmental impacts are not 

significant and thus, not required; and 

WHEREAS, a Mitigation Monitoring Plan pursuant to Public 

Resources Code Section 21081.6, has not been prepared since no mitigation 

measures are necessary; and 

WHEREAS, the AQMD Governing Board voting on Proposed 

Amended Rule 1133.1 and Proposed Rule 1133.3, has reviewed and considered, 

and hereby certifies the Final EA; and 

WHEREAS, the AQMD Governing Board finds and determines, 

taking into consideration the factors in Section (d)(4)(D) of the Governing Board 

Procedures, that the modifications adopted which have been made to Proposed 

Amended Rule 1133.1 and Proposed Rule 1133.3, since notice of public hearing 

was published do not significantly change the meaning of the proposed rule within 

the meaning of Health and Safety Code Section 40726 and would not constitute 

significant new information requiring recirculation of the Draft EA pursuant to 

CEQA Guidelines Section 15073.5; and 

WHEREAS, California Health and Safety Code Section 40727 

requires that prior to adopting, amending or repealing a rule or regulation, the 

AQMD Governing Board shall make findings of necessity, authority, clarity, 

consistency, non-duplication, and reference based on relevant information 

presented at the public hearing and in the staff report; 

WHEREAS, the AQMD Governing Board has determined that a 

need exists to adopt Proposed Amended Rule 1133.1 and Proposed Rule 1133.3 to 

ensure best management practices to prevent inadvertent decomposition during 

operations related to greenwaste material handling, including chipping and 

grinding activities, and to reduce emissions occurring from composting, including 

ozone and PM precursors; and

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WHEREAS, the AQMD Governing Board has authority to adopt 

Proposed Amended Rule 1133.1 and Proposed Rule 1133.3 pursuant to the 

California Health and Safety Code Sections 39614, 40000, 40001, 40440, 40441, 

and 40702, and 

WHEREAS, the AQMD Governing Board has determined that 

Proposed Amended Rule 1133.1 and Proposed Rule 1133.3 is written and 

displayed so that the meaning can be easily understood by persons directly 

affected by it; and 


Rules 1133.1 and 1133.3, as proposed, are in harmony with, and not in conflict 

with, or contradictory to, existing statutes, court decisions, or state or federal 

regulations; and 


Rules 1133.1 and 1133.3, as proposed, do not impose the same requirement as any 

existing state or federal regulation, except to the extent they are necessary and 

proper to execute the powers and duties granted to, and imposed upon, the 

AQMD; and 

WHEREAS, by adopting Proposed Amended Rule 1133.1 and 

Proposed Rule 1133.3, the AQMD Governing Board will be implementing, 

interpreting or making specific the provisions of the California Health and Safety 

Code Section 40001 (rules to achieve ambient air quality standards), 40440(a) 

(rules to carry out the AQMP), 40440 (c) (cost-effectiveness), and Federal Clean 

Air Act Section 172 (c)(1) (RACT); and 

WHEREAS, adoption of Proposed Amended Rule 1133.1 and 

Proposed Rule 1133.3 will alleviate a problem, that is harmonizing greenwaste 

material handling with Title 14 of the California Code of Regulations, Division 7, 

Chapter 3.1 and preventing emissions from composting operations through the use 

of best management practices; and 

WHEREAS, Proposed Rule 1133.3 was listed as a VOC and PM 2.5 

control measure in the 2007 Air Quality Management Plan (AQMP) and thus is 

not subject to California Health and Safety Code Section 40922 and thus, was not 

ranked by cost-effectiveness relative to other AQMP control measures in the 2007 

AQMP and further, that cost-effectiveness in terms of dollars per ton of pollutant 

reduced could not be calculated because emission reductions could not be 

quantified at the time of control measure development, but now emission 

reductions have been quantified and cost-effectiveness is presented in the staff 

report; and

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WHEREAS, the AQMD Governing Board has determined that the 

Socioeconomic Impact Assessment of Proposed Amended Rule 1133.1 and 

Proposed Rule 1133.3 is consistent with the March 17, 1989 and October 14, 1994 

Governing Board Socioeconomic Resolutions for rule adoption; and 


Socioeconomic Impact Assessment is consistent with the provisions of the 

California Health and Safety Code Sections 40440.8, 40728.5, 40920.6; and 


Proposed Amended Rule 1133.1 and Proposed Rule 1133.3 will result in increased 

costs to the industry, yet are considered to be reasonable, with a total annualized 

cost as specified in the Final Socioeconomic Impact Assessment; and 

WHEREAS, the AQMD Governing Board has actively considered 

the Socioeconomic Impact Assessment and has made a good faith effort to 

minimize such impacts; and 

WHEREAS, the AQMD specifies the Manager of Rules 1133.1 and 

1133.3 as the custodian of the documents or other materials which constitute the 

record of proceedings upon which the adoption of this proposed rule is based, 

which are located at the South Coast Air Quality Management District, 21865 E. 

Copley Drive, Diamond Bar, California; and 

WHEREAS, a public hearing has been properly noticed in 

accordance with all provisions of Health and Safety Code Section 40725; and 

WHEREAS, the AQMD Governing Board has held a public hearing 

in accordance with all provisions of law, inclusive of Health and Safety Code 

Section 40726; and 

WHEREAS, the AQMD Governing Board voting on Proposed 

Amended Rule 1133.1 and Proposed Rule 1133.3 has reviewed and considered the 

information contained in the Final Environmental Assessment for Proposed 

Amended Rule 1133.1 and Proposed Rule 1133.3, and has determined that the 

document is adequate and has been completed in compliance with CEQA. 

WHEREAS, the AQMD Governing Board has determined that staff 

should continue to work with stakeholders on implementation of the proposed 

rules and that efforts should also continue to possible future consideration of 

regulatory requirements for organic waste material handling; and 

NOW, THEREFORE BE IT RESOLVED, that the AQMD 

Governing Board hereby certifies, pursuant to the authority granted by law, the

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Final Environmental Assessment for Proposed Amended Rule 1133.1 and 

Proposed Rule 1133.3; and 

BE IT FURTHER RESOLVED, that because no significant 

adverse environmental impacts were identified as a result of implementing 

Proposed Amended Rule 1133.1 and Proposed Rule 1133.3, a Statement of 

Findings, a Statement of Overriding Considerations, and a Mitigation Monitoring 

Plan are not required; and 

BE IT FURTHER RESOLVED, that the AQMD Governing Board 

does hereby adopt, pursuant to the authority granted by law, Proposed Amended 

Rule 1133.1 and Proposed Rule 1133.3, as set forth in the attached, and 

incorporated herein by reference; and 


does hereby direct staff to form an implementation working group comprised of 

key stakeholders and other interested parties and to provide the Stationary Source 

Committee with periodic status reports on working group activities beginning no 

later than March 2012; and 


does hereby direct staff to continue efforts to evaluate emissions, potential 

emission reduction measures, and to develop future rule or control measure 

requirements for organic waste, as necessary, for the Board’s consideration in the 

future. 

DATE: _________________ _________________________________ 

CLERK OF THE BOARDS

PAR 1133.1-1 

(Adopted January 10, 2003)PAR 1133.1ef 

June 7July 8, 2011 

PROPOSED AMENDED RULE 1133.1 CHIPPING AND GRINDING 

ACTIVITIES 

(a) Purpose 

The purpose of this rule is to prevent inadvertent decomposition occurring during 

chipping and grinding activities, including stockpile operations. 

(b) Applicability 

This rule applies to operators of chipping and grinding activities to produce 

materials other than active or finished compost, unless otherwise exempted under 

subdivision (f) of this rule. The requirements of Rule 403 – Fugitive Dust, also 

apply to these activities. 

(c) Definitions 

For the purposes of this rule, the following definitions shall apply: 

(1) ACTIVE COMPOST is material that is in the process of being rapidly 

decomposed and is biologically unstable. Active compost is generating 

temperatures of at least 122 degrees Fahrenheit during decomposition. 

Active compost includes, but is not limited to, pathogen-reduced mulch. 

(1)(2) AGRICULTURAL CHIPPING AND GRINDING is any chipping and 

grinding activity conducted at an agricultural site where organic waste 

material is generated on-site by the production and/or processing of farm 

products, and the chipped and ground organic waste material is used onsite. 

(23) CALENDAR DAYS refer to any days of the year, excluding official 

federal and state holidays. 

(33) CHIPPING AND GRINDING is any activity that mechanically reduces 

the size of greenwaste, woodwaste, and/or foodwaste. 

(44) COMPOSTING is a process in which solid organic waste materials are 

decomposed in the presence of oxygen under controlled conditions 

through the action of bacteria and other microorganisms. 

(5) COMPOST OVERS are the oversized woody materials that do not 

decompose in a typical composting cycle and are screened out of finished 

product at the end of composting. Compost overs have been through the

Proposed Amended Rule 1133.1 (cont.) (Adopted January 10, 2003) 

pathogen reduction process outlined in Title 14, Section 17868.3 of the 

California Code of Regulations. 

(6) CURBSIDE GREENWASTE is greenwaste that is collected from 

receptacles designated for residential household greenwaste. Curbside 

greenwaste also includes screened curbside greenwaste containing only 

grass clippings, leaves, and/or twigs that is not considered non-curbside 

greenwaste as defined in paragraph (c)(1113). 

(7) FINISHED COMPOST is a humus-like material and/or compost overs 

that result from the controlled biological decomposition of organic waste 

materials and is biologically stable. 

(8) FOODWASTE is any food scraps collected from the food service 

industry, grocery stores, or residential food scrap collection. Foodwaste 

also includes foodwaste food scraps that is are chipped and ground. 

Foodwaste mixed with greenwaste is considered foodwaste. 

(9) GREENWASTE is 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. It includes 

curbside, non-curbside, and mixed greenwaste. 

(10) INADVERTENT DECOMPOSITION is decomposition of greenwaste 

and/or foodwaste associated with stockpiling greenwaste and/or foodwaste 

for an extended period of time, and is not considered part of normal 

chipping and grinding operations. 

(11) LANDCLEARING is an activity where trees and plants grown at the site 

are cut, then chipped or ground and removed from the site to clear the site. 

(12) MIXED GREENWASTE is curbside greenwaste that is mixed with noncurbside 

greenwaste. 

(13) NON-CURBSIDE GREENWASTE is any greenwaste that is not collected 

from receptacles designated for residential household greenwaste. 

Curbside greenwaste or mixed greenwaste that is screened and contains 

only large woody materials (larger than 3 inches in any dimension) such as 

tree trimmings and branches, is also considered to be non-curbside 

greenwaste. 

(14) PALM CHIPPING AND GRINDING is any activity that mechanically 

reduces the size of palm trees waste. 

PAR 1133.1 - 2


(15) PORTABLE CHIPPING AND GRINDING is chipping and grinding 

utilizing equipment with a manufacturer's rating of 170 brake horsepower 

or less. 

(16) RAINY DAY is any day with at least 0.05 inches of rain reported by the 

National Weather Service or a cooperative weather reporting station for 

the site closest to where the chipping and grinding activity occurs. 

(17) STOCKPILE is a supply of raw material tipped and stored prior to being 

utilized on-site or removed from the site. Raw materials before and after 

chipping and grinding are also included. 

(18) WET WEATHER CONDITIONS are weather conditions following a 

rainy day not to exceed 10 days. 

(18)(19) WOODWASTE is lumber, and the woody material portion of 

mixed demolition wastes and mixed construction wastes. Woodwaste also 

includes large wood materials of curbside greenwaste or mixed 

greenwaste that is screened or unscreened, such as tree trimmings, 

branches, tree trunks, stumps, and limbs exceeding 2 inches in any 

dimension. 

(d) Requirements 

Effective July 1, 2003, the The operator of a chipping and grinding activity shall 

comply with the following requirements: 

(1) Remove foodwaste from the site or use foodwaste for on-site composting 

within 2 calendar days of receiptFoodwaste shall not be taken at the 

facility, unless otherwise allowed by the Local Enforcement Agency to 

handle foodwaste. 

(2) Chip or grind, or use and utilize on-site, or remove curbside, non-curbside, 

or mixed greenwaste from the site within 3 calendar days 48 hours of 

receipt, excluding observance of official federal and state holidays, or up 

to seven days maximum, with approval from unless otherwise allowed by 

the Local Enforcement Agency to hold materials for a longer period of 

time. 

(3) Chip or grind or remove non-curbside greenwaste from the site within 14 

calendar days of receipt. 

(4) Chip or grind, or use on-site, or remove mixed greenwaste from the site 

within 7 calendar days of receipt. 



(5)(3) Remove chipped or ground curbside greenwaste from the site or use 

chipped or ground curbside greenwaste on-site within 3 calendar days of 

being chipped or groundMaintain all the operational records 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 to the Executive Officer within one week of request. 

(6)(4) Maintain the following records, as applicable, on-site for two years: 

(A) A copy of the facility’s AQMD registration and annual updates 

submitted in compliance with Rule 1133; and, 

(B) Records of date, type, and amount of greenwaste and/or foodwaste 

received; and, 

(C) Records of date, type, amount of greenwaste and/or foodwaste 

removed from the site, and location where they are transferred to.; 

(D) Records of dates of rainy days and wet weather conditions and 

description of specific conditions that limited normal operations.; 

(E) Records of temperature or moisture content measurements.; and 

(F) Records of dates and amount of curbside greenwaste chipped and 

ground. 

(7)(5) The time requirements specified in paragraphs (d)(1), (d)(2), (d)(3), (d)(4), 

and (d)(5) may be extended by the number of rainy days and wet weather 

conditions that impede normal chipping and grinding operations provided 

that records are maintained in accordance with subparagraph (d)(64)(D). 

(e) Moisture Content Measurement 

Moisture content will be determined by collecting at least 10 samples of chipped 

and ground greenwaste from various locations of the pile at a depth of at least 12 

inches below pile surface. The samples shall then be mixed thoroughly and 

analyzed for moisture content by ASTM method D4442 (December 2007), ASTM 

method D4444 (May 2008) or ASTM method E871-82 (December 2006). 

(f) Exemptions 

(1) Chipping and grinding activities of greenwaste derived from the site and 

used utilized on-site shall be exempt from the requirements of paragraphs 

(d)(2), (d)(3), and (d)(4), (d)(5), and (d)(6), provided less than 1,000 cubic 

yards of materials are either sold or given away. 



(2) Portable chipping and grinding, agricultural chipping and grinding, land 

clearing chipping and grinding, woodwaste chipping and grinding, and 

palm chipping and grinding activities shall be exempt from the 

requirements of paragraphs (d)(2), (d)(3), and (d)(4), (d)(5), and (d)(6). 

(3) Chipped and ground curbside greenwaste shall be exempt from the 

requirements of paragraph (d)(52) provided that the moisture content is 

less than 30%, measured in accordance with subdivision (e) and the 

temperature or moisture content measurements are maintained on-site in 

accordance with subparagraph (d)(64)(E). 

(4) A biomass power generation facility or a facility processing material as a 

biomass fuel for a biomass power generation facility shall be exempt from 

the requirements of paragraph (d)(2) provided that the material 

temperature is maintained at below 122 degrees Fahrenheit or the moisture 

content is less than 30%, measured in accordance with subdivision (e) and 

the temperature or moisture content measurements are maintained on-site 

in accordance with subparagraph (d)(4)(E). This exemption shall not 

apply to material processed for purposes other than biomass fuel. 

(5) The operator of a landfill or biomass power generation facility shall be 

exempt from the requirements of paragraph (d)(4), provided that the 

operator does not perform chipping and grinding of greenwaste on-site. 


PR 1133.3 - 1 

PR 1133.3ef 


PROPOSED RULE 1133.3 EMISSION REDUCTIONS FROM GREENWASTE 

COMPOSTING OPERATIONS 

(a) Purpose 

The purpose of this rule is to reduce fugitive emissions of volatile organic compounds 

(VOC) and ammonia occurring during greenwaste composting operations. 


This rule applies to the operator of all new and existing greenwaste composting 

operations that produce active or finished compost from greenwaste by itself or 

greenwaste in combination with manure or foodwaste, unless otherwise exempted under 

subdivision (g) of this rule. 



(1) ACTIVE COMPOST means material that is in the process of being rapidly 


temperatures of at least 122 degrees Fahrenheit during decomposition. Active 

compost includes, but is not limited to, pathogen-reduced mulch. 

(2) ACTIVE PHASE means the phase of the greenwaste composting process that 

begins when organic waste materials are mixed together for composting and lasts 

a minimum of 22 days under controlled conditions or until the compost has a 

Solvita Maturity Index of five or greater measured pursuant to subparagraph 

(e)(4)(A). 

(3) BACKYARD COMPOSTING means composting conducted by a household 

including, but not limited to, single family residences, condominiums, duplexes, 

or apartment buildings. 

(4) BASELINE EMISSION FACTORS mean the uncontrolled emission factors for 

greenwaste composting operations for VOC and ammonia. 

(5) COMMUNITY COMPOSTING means composting conducted by a residential 

neighborhood association using feedstock generated within the residential 

neighborhood to produce compost for the neighborhood’s use.

PR 1133.3 - 2 


(6) COMPOSTING means a process in which solid organic waste materials are 

decomposed in the presence of oxygen through the action of bacteria and other 

microorganisms. 

(7) COMPOST OVERS mean the oversized woody materials that do not decompose 

in a typical composting cycle and are screened out of finished product at the end 

of composting. Compost overs have been through the pathogen reduction process 

outlined in Title 14, Section 17868.3 of the California Code of Regulations. 

(8) CURING PHASE means the phase of the greenwaste composting process that 

begins immediately after the end of the active phase of composting and lasts a 

minimum of 40 days or until the compost has a Solvita Maturity Index of seven or 

the product respiration rate is below ten milligrams of oxygen consumed per gram 

of volatile solids per day as measured by direct respirometry, pursuant to 

subparagraph (e)(4)(B). 

(9) EXISTING GREENWASTE COMPOSTING OPERATIONS mean all 

(10) 

greenwaste composting operations that have begun operations on or before (date 

of adoption). 

FINISHED 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 product. 

(11) FOODWASTE means any pre- or post-consumer food scraps collected from the 

food service industry, grocery stores, or residential food scrap collection. 

Foodwaste also includes food scraps that are chipped and ground. Any non-food 

material that is not separated from food scraps is considered foodwaste for the 

purpose of calculating throughput, including but not limited to compostable 

plastic bags and food-soiled packaging, papers or other biodegradable material, or 

non-compostable solid waste, such as napkins, cans, glass, plastics including bags, 

containers and styrofoam. 

(12) GREENWASTE means 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. 

(13) GREENWASTE COMPOSTING means composting of greenwaste by itself or a 

mixture with foodwaste, or with up to 20 percent manure, per pile volume basis. 

(14) NEW GREENWASTE COMPOSTING OPERATIONS mean greenwaste 

composting operations that have not started operations as of (date of adoption).

PR 1133.3 - 3 


(15) NURSERY COMPOSTING means composting conducted at a nursery to produce 

compost for on-site use. 

(16) ORGANIC WASTE means any organic waste material that includes foodwaste, 

greenwaste, woodwaste, or manure, or a mixture thereof. 

(17) OPERATOR means any person that operates a greenwaste composting operation. 

(18) PILE means compostable material that is heaped together. 

(19) RECREATIONAL FACILITY COMPOSTING means composting conducted at 

parks, arboretums and other recreational facilities using feedstock generated on- 

site to produce compost for on-site use. 

(20) SOLVITA MATURITY INDEX means an index that defines the stage where 

compost exhibits resistance to further decomposition, as tested by the Solvita 

Maturity Test ® . 

(21) START-UP means the first day of active greenwaste composting operations at the 

facility. 

(22) THROUGHPUT means the mass of manure, foodwaste, or greenwaste in tons per 

year as received by the facility and processed through composting, excluding 

recycled materials. 

(23) TMECC means Test Methods for the Examination of Composting and Compost 

published by the US Composting Council Research and Education Foundation. 

(24) WOODWASTE means lumber, and the woody material portion of mixed 

demolition and construction wastes. Woodwaste also includes large wood 

materials of curbside greenwaste or mixed greenwaste that is screened or 

unscreened, such as tree trimmings, branches, tree trunks, stumps, and limbs 

exceeding two inches in any dimension. 


(1) Effective (date of adoption), the operator of greenwaste composting operations 

shall comply with the following requirements: 

(A) Chip or grind, as necessary, and use greenwaste for on-site composting 

within 48 hours of receipt, unless otherwise as allowed by the Local 

Enforcement Agency to hold for a longer period of time. 

(B) Use foodwaste for on-site composting within 48 hours of receipt or cover 

foodwaste with screened or unscreened finished compost until used, unless 

otherwise required by the Local Enforcement Agency. 

(2) Effective upon start-up for new greenwaste composting operations and effective 

(4 months after date of adoption) for existing greenwaste composting operations,

PR 1133.3 - 4 


the operator of greenwaste composting operations processing greenwaste only or 

up to 20 percent manure, by volume, or up to 5,000 tons per year of foodwaste 

throughput shall comply with the following requirements: 

(A) Cover each active phase pile with screened or unscreened finished 

compost within three twenty-four hours of initial pile formation such that 

the top is at least six inches thick and the pile shall not be turned for the 

first seven days of the active phase of composting, unless subparagraph 

(d)(2)(D) applies. 

(B) For the first fifteen days after initial pile formation for the active phase 

period of composting, within three six hours before turning, apply water as 

necessary to the surface area of each active phase pile such that the top 

one half of the pile is wet to a depth of three inches. Alternatively, the 

operator may apply water during turning using a windrow turner which is 

equipped with water spraying technology during the entire windrow 

turning process. 

(C) If a rain event occurs prior to watering the pile within three six hours 

before turning and the pile is wet to a depth of three inches, the operator 

may turn the pile without adding additional water. If the top half of the 

pile is dry at any level to the three inch depth, apply additional water to the 

pile pursuant to subparagraph (d)(2)(B). 

(D) If the pile needs to be turned within the first seven days for maintaining 

managing temperature at or above 131 degrees Fahrenheit for pathogen 

reduction pursuant to Title 14 Division 7, Chapter 3.1, Section 17868.3 of 

the California Code of Regulations, the operator does not need to re-apply 

the screened or unscreened finished compost cover and shall apply water 

pursuant to subparagraph (d)(2)(B) for the first fifteen days of the active 

phase. 

(E) The operator may implement an alternate mitigation measure that will be 

based on a test protocol approved by the Executive Officer, California Air 

Resources Board, and the United States Environmental Protection Agency 

and that demonstrates emission reductions by at least 40 percent, by 

weight, for VOC and emission reductions by at least 20 percent, by 

weight, for ammonia for combined screened or unscreened finished 

compost cover and water application.

PR 1133.3 - 5 



processing greater than 5,000 tons per year of foodwaste throughput shall comply 

with the following requirements, for the purpose of regulatory compliance: 

(A) Any active phase of composting containing more than 10% foodwaste, by 

weight, shall be conducted using an emission control device designed and 

operated with an overall system control efficiency of at least 80 percent, 

by weight, each for VOC and ammonia emissions. 

(B) The operator may implement a control alternative if the alternative is 

approved by the Executive Officer, California Air Resources Board, and 

the United States Environmental Protection Agency, to achieve VOC and 

ammonia reductions that are greater than or equal to the reductions 

required pursuant to subparagraph (d)(3)(A). 

(C) For new greenwaste composting operations that intend to compost greater 

than 5,000 tons per year of foodwaste throughput, a permit shall be 

obtained for an emission control device, as specified in subparagraph 

(d)(3)(A) or (d)(3)(B), prior to construction. 

The annual throughput calculation may exclude any non-putrescible materials, 

including, but not limited to paper, woody, other low-water, high cellulose 

materials, and non-compostable contaminants and green waste that are separated 

either before or after composting and shipped off-site for disposal provided they 

are quantified and appropriate records are maintained for. 

(4) No later than (3 months after date of adoption), for existing greenwaste 

composting operations that, as of (date of adoption), process or plan to process 

greater than 5,000 tons per year of foodwaste throughput, the operator shall file a 

permit application for an emission control device and fully implement the 

emission control device in accordance with subparagraphs (d)(3)(A) or (d)(3)(B) 

within six months upon approval of the permit application. 

(5) The overall control efficiency required in subparagraph (d)(3)(A) shall be 

demonstrated by a source test within three months after implementation of the 

emission control device, or within nine months of permit approval, whichever 

occurs sooner, and every three years thereafter. For the purpose of this rule, the 

baseline emission factors to be used shall be 4.25 pounds of VOC per ton of 

throughput and 0.46 pounds of ammonia per ton of throughput for the active 

phase of composting only. The Executive Officer may approve the use of 

alternate baseline emission factors, if the operator demonstrates through the

PR 1133.3 - 6 


approved source test that alternate baseline emission factors are representative of 

uncontrolled operations for that facility 

(6) All emission control devices shall be installed, operated, and maintained in 

accordance with the manufacturer’s operation and maintenance manual or other 

similar written materials supplied by the manufacturer or distributor of such 

equipment to ensure that the system remains in proper operating conditions. Such 

documentation shall be made available to the Executive Officer upon request. 

(7) All records, including application of screened or unscreened finished compost and 

water, operation and maintenance of an emission control device, and source tests, 

shall be kept and maintained at the facility pursuant to subdivision (f). 

(e) Test Methods and Protocol 

(1) For a greenwaste composting operation subject to paragraphs (d)(3) through 

(d)(5), the operator shall conduct all required source and laboratory tests in 

accordance with an Executive Officer approved test protocol developed in 

accordance with the guidelines provided in Attachment A of this rule. 


(d)(5), the operator shall use a District approved laboratory in accordance with the 

Attachment A of this rule. 

(3) The following methods shall be used to determine compliance with this rule: 

(A) SCAQMD Method 207.1 – Determination of Ammonia Emissions from 

Stationary Sources. 

(B) SCAQMD Method 25.3 – Determination of Low Concentration Non- 

Methane Non-Ethane Organic Compound Emissions from Clean Fueled 

Combustion Sources. 

(C) SCAQMD Method 1.1 – Sample and Velocity Traverses for Stationary 

Sources. 

(D) SCAQMD Method 1.2 – Sample and Velocity Traverses for Stationary 

Sources with Small Stacks and Ducts. 

(E) SCAQMD Method 2.1 – Determination of Stack Gas Velocity and 

Volumetric Flow Rate (S-Type Pitot Tube). 

(F) SCAQMD Method 2.2 – Direct Measurement of Gas Volume through 

Pipes and Small Ducts. 

(G) SCAQMD Method 2.3 – Determination of Gas Velocity and Volumetric 

Flow Rate from Small Stacks or Ducts.

PR 1133.3 - 7 


(H) SCAQMD Method 4.1 – Determination of Moisture Content in Stack 

Gases. 

(4) Triplicate samples shall be taken for the following test methods: 

(f) Recordkeeping 

(A) TMECC 05.08-E – Solvita Maturity Index (April 7, 2002). 

(B) TMECC 05.08-A – Specific Oxygen Uptake Rate (April 7, 2002). 

Records shall be kept in a format approved by the Executive Officer. All operational 

records and information recorded pursuant to the provisions of this rule shall 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 to the Executive Officer 

within one week of request. 

(g) Exemptions 

(1) Composting facilities subject to Rule 1133.2 – Emission Reductions from Co- 

Composting Operations, are exempt from the provisions of this rule. 

(2) If the operator of any greenwaste composting operation installs an emission 

control device, in accordance with paragraphs (d)(3) through (d)(6), the 

provisions of paragraph (d)(2) do not apply. 

(3) The following types of facilities and operations are exempt from the requirements 

of this rule, 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: 

(A) Community composting; 

(B) Nursery composting; 

(C) Backyard composting; and 

(D) Recreational facility composting.

ATTACHMENT A 

PR 1133.3 - 8 


GUIDELINES FOR THE DEVELOPMENT OF SOURCE TEST PROTOCOLS 

FOR VOC AND AMMONIA EMISSIONS FROM GREENWASTE 


Source test protocols are to consist of testing plans to measure VOC and ammonia emissions due 

to the composting process. When used for determining the control device efficiency requirement 

specified for new and existing facilities, the measurements shall consist of lb/hr measurements at 

the inlet and exhaust of the control device and are subject to the applicable requirements that 

follow. When used for determining the overall emission reduction requirements as compared to 

the baseline emissions factors, emissions are to be reported as % reductions for the active phase 

composting in terms of pounds of emissions per ton of throughput (total raw material as 

received) and are subject to the applicable requirements that follow. The following are general 

requirements for all testing as well as specific requirements for the rule sections for each facilityspecific 

protocol which must be prepared by the source test contractor and approved by the 

SCAQMD prior to testing. 

1. Alternative Test Methods 

The reference test methods for ammonia, VOC, and flow rate cited in this guideline shall 

be used to determine compliance with this rule. Alternative test methods may be used if 

they are determined to be equivalent and approved in writing by the Executive Officer, 

the California Air Resources Board, and the U.S. Environmental Protection Agency. For 

the source test protocols, as defined as the manner in which the reference test methods are 

employed to obtain a measurement of the emissions, alternatives to the procedures cited 

in this guidelines may be used if they are determined to be equivalent and approved in 

writing by the Executive Officer. 

2. LAP Requirements 

The sampling, analysis, and reporting shall be conducted by a laboratory/source test firm 

that has been approved under the SCAQMD Laboratory Approval Program (LAP) for the 

cited SCAQMD reference test methods, where LAP approval is available. For SCAQMD 

reference test methods for which no LAP program is available, the LAP approval 

requirement shall become effective one year after the date that the LAP program becomes 

available for that SCAQMD reference test method. 

3. Operating Conditions 

The testing must be conducted under representative operating conditions with respect to 

seasonal conditions, compost composition, process throughput, processing of the

PR 1133.3 - 9 


materials, and pile geometries. The following operating parameters shall be recorded 

during testing and reported with the test results: 

a) A thorough description of the composting process and process diagram of each 

processing area and including residence times in each of the composting process 

areas. 

b) Process throughput as determined by facility’s billing scales or other calibrated 

measuring device that represents the tons of the material as received that is present at 

the facility during the time of the testing. When using the District Baseline Emission 

Factors, the process throughput is to include all of the raw organic materials that are 

composted excluding material that is recycled from previous similar processing. 

Several throughputs may be necessary if applicable to the different processing areas 

or pile ages. 

c) Compost composition (percent and type of materials i.e. manure, greenwaste, 

foodwaste, etc…). 

d) Age of all piles that were tested and all piles present at the facility during testing. 

e) Detailed dimensions of all piles or the biofilter so that a surface area for each pile 

type can be calculated. 

f) A description of the biofilter system, including a process diagram and type of biofilter 

media. 

g) Age of the biofilter media. 

h) A thorough description of the humidification and moisture maintenance system for 

the biofilter. 

i) Identification of peripheral monitoring equipment, such as moisture or temperature 

sensors, and data from them during testing. 

4. Ammonia Sampling 

SCAQMD Method 207.1 shall be used to obtain the ammonia samples from each source 

of emissions to be tested. When sampling from a flux chamber, a sample line of minimal 

length should be connected to a midget sampling train consisting of; two midget 

impingers each filled with 15 ml of 0.1N Sulfuric Acid, an empty bubbler, and a bubbler 

filled with tared silica gel. The samples shall be analyzed for ammonium content as 

ammonia by ion chromatography or ion selective electrode. 

5. VOC Sampling 

Duplicate integrated gas samples shall be taken from each source of emissions to be 

tested using SCAQMD Method 25.3. The Method 25.3 apparatus should be connected to 

sample directly inside the flux chamber or duct as applicable. Compost emissions are 

considered as water soluble sources where the 50 ppm applicability limit of Method 25.3 

does not apply.

PR 1133.3 - 10 


6. Specific Requirements for Testing Greenwaste Composting Operations Control 

Equipment Performance 

For surface types of emissions, such as with open faced biofilter exhausts, the exhaust 

emission rate shall be determined as in the following Section (8). 

For a control device inlet or exhaust that is vented through a testable duct, the gas 

velocity within the duct shall be measured according to SCAQMD Methods 1.1, 2.1, and 

3.1. The flow rate shall also be corrected to dry standard conditions using the moisture 

content as determined by SCAQMD Method 4.1. This flow rate may then be used to 

determine mass emission rates. 

The overall destruction efficiency is calculated as follows: 

Where: 

ODE = 100 x (1 – (E / I)) (Equation 1) 

ODE = Overall Destruction Efficiency (%) 

E = Total Exhaust Emission Rate (lb/hr) 

I = Total Inlet Emission Rate to Control Device (lb/hr) 

7. Specific Requirements for Existing Greenwaste Composting Operations and New 

Greenwaste Composting Operations (Overall Emissions Reduction) 

A proposed measurement from the active greenwaste composting process, including but 

not limited to surface emissions of all piles where the materials are composted, and 

outlets (vents or surfaces) of control devices must be included in the protocol. If the 

emissions are vented to atmosphere from a vent stack such as from an otherwise 

uncontrolled aerated static pile or other vent to atmosphere, then the stack concentration, 

determined using methods specified in Sections (4) and (5) and flow rate measurements 

as specified in the previous Section (6) are required. From all surface types of emissions 

such as from compost piles and biofilter surfaces, the procedure for measuring surface 

emissions as in Section (8) is required. A measurement for fugitive emissions from 

aerated static pile surfaces must also be included. 

Each type of pile must be tested. If the facility includes several identical piles, then only 

the largest pile need be tested. If the facility has more than three different age piles that 

are otherwise identical in processing and composition, then at a minimum three ages can 

be tested including newer, older, and middle aged piles. In any case, the surface area of 

all piles at the facility must be included in the determination of pile dimensions as 

recorded in Section (3). 

If the facility elects to use an alternative to the District’s baseline emissions factors, then 

a separate test must be conducted to establish this baseline on the uncontrolled 

composting operation (e.g., windrow method) with the same compost mix. Following the

PR 1133.3 - 11 


source test to determine an alternative baseline, facilities would have the option to use the 

District’s baseline emissions factors or the alternative baseline emissions factors. 

Reduction of emissions shall be calculated as follows: 

Where: 

% Reduction = 100 x (1-TE/B) (Equation 2) 

TE = Total Active and Curing Phase Emissions (lb/ton throughput) 

B = District Baseline Emissions or Alternative Baseline Emissions if Tested 

(lb/ton throughput) 

8. Procedure for Measuring Surface Emissions 

The procedure for measuring surface emissions such as the compost pile and biofilter 

surfaces that cannot be tested by conventional methods through a stack or duct, is a 

modified form of the procedures found in the US Environmental Protection Agency’s 

(EPA) Measurement of Gaseous Emission Rates from Land Surfaces Using an Emission 

Isolation Flux Chamber User’s Guide (EPA Guide). The modification to the procedures 

in the EPA Guide is specified in the following requirements. 

The flux chamber encompasses a fixed surface area of 1.4 ft 2 and contains a sweep air 

system to obtain a homogeneous air sample by employing a mixing fan and sweep gas 

(10% He in air at 5 liters/min recommended). The sweep gas must contain a non reactive 

and non-present tracer such as the aforementioned 10% helium so that a correction for the 

contribution of the surface flow rate can be calculated. 

A minimum of ten (10) sample locations or a sufficient number at each pile/surface tested 

must be obtained in order to achieve a representative sample of the surface emissions. 

These locations can be composited for each pile/surface to reduce testing costs. For 

example, for one hour sampling, ten (10) random positions on the pile should be tested 

for 6 minutes each. Alternatively, a lesser number of sample locations may be sampled 

provided that an evaluation of spatial variation demonstrates that the number of sample 

locations is sufficient. 

The emissions must be reported in units of lb/hr-ft 2 , lb/hr and lb/ton of throughput. The 

following calculations shall apply to the test results: 

Where: 

Surface Flow Correction Factor = Ct / Cs (Equation 3) 

Ct = Concentration of Tracer in Sweep Gas 

Cs = Concentration of Sweep Gas in Flux Chamber Sample

Where: 

Corrected Flux Chamber Results (lb/hr-ft 2 ) = UFC x SFCF (Equation 4) 

UFC = Uncorrected Flux Chamber Results (lb/hr-ft 2 ) 

SFCF = Surface Flow Correction Factor 

Where: 

Where: 

lb/hr = lb/hr-ft 2 x Total Compost Surface Area in Category (Equation 5) 

lb/ton throughput = lb/hr x (24 hr/day) /PT (Equation 6) 

PT = Process Throughput (total ton/day as received) 

Total Emissions (lb/ton throughput) = ∑ P (Equation 7) 

PR 1133.3 - 12 


P = Active and curing sources of the Facility Compost Emissions (lb/ton throughput) 

For a facility where not every age of pile was tested, the surface areas from each pile in 

the facility must be included and sorted into appropriate age and emissions categories 

from those that were measured.

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

DRAFT FINAL STAFF REPORT 

PROPOSED AMENDED RULE 1133.1 – CHIPPING AND GRINDING 

ACTIVITIES 

PROPOSED RULE 1133.3 – EMISSION REDUCTIONS FROM GREENWASTE 


June July 2011 

Planning, Rule Development, and Area Sources 

Deputy Executive Officer 

Planning, Rule Development and Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 


Laki Tisopulos, Ph.D., P.E. 


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 Deputy District Counsel 

ATTACHMENT H


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 


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 


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 .........................................................................2021 

Cost Effectiveness.........................................................................................................2324 

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

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

Socioeconomic Assessment ..........................................................................................2526 

Comparative Analysis ..................................................................................................2526 

Draft Findings under the California Health and Safety Code .....................................34 

Conclusions ...................................................................................................................3536 

References .....................................................................................................................3637 

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 .................................2122 

Table 2. Number and Throughput of Affected Greenwaste Composting Facilities ......2223 

Table 3. Emissions Inventory and Emission Reductions for Existing Greenwaste 

Composting Operations ..................................................................................2324 

Table 4. Greenwaste Composting Average Cost Effectiveness .....................................2324 

Table 5. Comparison of State Regulation and District Proposed Rules ........................2728 

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

Table I-2. Troubleshooting and Management Guide for Composting 

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

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

Table III-2. Composting Emission Factors ................................................................... III-2 

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

Table III-4. Greenwaste Composting Baseline Emissions Inventory ........................... III-5 

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

Table III-6. Greenwaste Composting Emission Reductions ......................................... III-8 

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

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

List of Figures 

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

Figure I-2. Flow of Typical Greenwaste 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-pressurized 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-4

Preface 

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 contains staff’s current proposal for PAR 1133.1 

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

clarifications made to the rule since the June release of the PAR 1133.1 and PR 1133.3 

package are summarized below: 

Clarify that the non-putrescible materials may be excluded in calculation of 

annual foodwaste throughput, provided they are quantified and records are 

maintained; 

Add 7 days maximum to the greenwaste holding time in PAR 1133.1 (d)(2). 

Also, remove the 48-hour timeframe from PR 1133.3 (d)(1)(A); 

Modify the time required to apply the finished compost cover from three hours to 

24 hours of initial pile formation; 

Modify the time required to apply water from three hours to six hours before 

turning; 

Add official federal and state 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 these and other minor changes are presented in 

strike-out/underline format.

PAR 1133.1 and PR 1133.3 Draft Final Staff Report 

EXECUTIVE SUMMARY 

The South Coast Air Quality Management District (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-composting 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 reintroduce 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 of, volatile organic compounds (VOCs), methane, and renewable 

carbon dioxide (CO2) versus non-renewable fossil fuel CO2, and enhances waste 

management by turning a material often put into landfills to a beneficial use to enhance 

the sustainability of major industries, including agriculture, landscape and natural lands 

restoration and management. VOCs and ammonia 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 properly, greenwaste composting can also result 

in odor problems. Odor regulation of composting is under the authority of the Local 

Enforcement Agencies, not the District (California Health and Safety Code Section 

41705). 

Proposed Rule (PR) 1133.3 would reduce 0.9 tons per day of VOC and 0.1 tons per day 

of ammonia from greenwaste composting operations. PR 1133.3 would implement 

Control Measure (CM) MCS-04 of the 2007 Air Quality Management Plan (AQMP) and 

seeks to establish operational best management practices (BMPs) for greenwaste 

composting operations that produce 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 operations associated with chipping and grinding 

activities, which is to be consistent with current greenwaste material processing 

requirements established in Title 14 of the California Code of Regulations (CCR). 

Proposed Amended Rule (PAR) 1133.1 covers approximately 70 facilities and would 

establish BMPs for chipping and grinding activities to produce materials other than active 

or finished compost. No emission reductions are quantified for this rule proposal because 

the rule incorporates existing state requirements. PAR 1133.1 would also establish 

maximum holding times of greenwaste material. PAR 1133.1 would apply to chipping 

and grinding activities not only occurring at a stand-alone chipping 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, greenwaste 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 unless otherwise allowed by 

the Local Enforcement Agency (LEA) to be held for a longer period of time. Chipping 

and grinding facilities cannot take foodwaste, unless otherwise allowed by the LEA. 

SCAQMD 1 June July 2011


PR 1133.3 would affect 17 facilities and would apply to greenwaste composting 

operations involving organic waste materials, including greenwaste, woodwaste, manure 

and foodwaste. Greenwaste composting including 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 within 48 

hours of receipt, unless otherwiseas allowed by the LEA to hold for a longer period of 

time. Foodwaste is also subject to the a 48 hours processing time to initiate composting 

on-site, 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 phase pile with finished compost within three 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 phase of composting. Operations 

would be required to apply water to a three inch depth to the pile, prior to turning, during 

the first 15 days of the active phase of composting. 

For greenwaste composting operations processing greater than 5,000 tons per year of 

foodwaste throughput, the operator would be required to install an emission control 

device for all active phase compost piles containing 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 seven days material holding time requirement 

which is shorter than the previous holding 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 (Title 14) which is currently enforced by the 

county-level LEAs. As the 48 hoursholding time requirement has already been 

established and enforced by the LEA, no emission reductions are quantified relative to 

PAR 1133.1. 

Costs associated with the implementation 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 that 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 of VOC 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 ammonia combined for a 50,000 tons per year 

operation, when compared to finished compost cover and watering application. 



Several working group and other industry stakeholder meetings have been held to discuss 

rule concepts and draft rule language. A public workshop was held in February 2011. 

Numerous facility meetings have also occurred, 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 jurisdictional boundaries include all of the South 

Coast Air Basin (Basin) and portions of the 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 standards. 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 PM2.5. The District is required to meet the federal annual PM2.5 

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 Integrated Waste Management Act (AB939, Sher, 

Chapter 1095, Statues of 1989 as amended [IWMA]). 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 aeration 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 percent 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 scraps are landfilled. 

Greenwaste composting is a source of ammonia, a PM2.5 precursor, and VOCs, an ozone 

precursor. Biogenic VOC also acts as a precursor 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, are 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 SCABBasin. 

Therefore, diverting organic materials not only helps return valuable nutrients to the soil, 

improves plant productivity, and helps reduce 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 anaerobic organic treatments, including greenwaste 

composting, that contribute to the formation of PM2.5 and ozone, and climate change. 

The management practices proposed in PAR 1133.1 and PR 1133.3 will reduce ammonia 

and VOC, precursors to PM2.5 and ozone, as well as minimize PM2.5 emissions. 

Particulate Matter (PM2.5) 

Most PM2.5 in the Basin’s air is believed 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 organic aerosols formed from biogenic VOC. PM2.5 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 compliance 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 composting of organic 

materials, but VOC is also produced in even greater quantity in anaerobic decomposition. 

VOC contributes to the formation of ozone and organic aerosols in the atmosphere, 

contributing to higher PM2.5 and lower visibility levels. Ozone is formed in the 

atmosphere through a photochemical reaction of VOC and nitrogen oxides (NOx) by 

sunlight. 

Ozone is a highly reactive compound and a strong oxidizing agent. When ozone comes 

into contact with the respiratory tract, it can react with tissues and cause damage in the 

airways. Ozone is a deep lung irritant, causing the lung passages to become inflamed and 

swollen. Exposure to ozone produces alterations in respiration, the most characteristic of 

which is shallow, rapid breathing and a decrease in pulmonary performance. 

Greenhouse Gases 

Greenhouse gases, such as CO2, methane (CH4), and nitrous oxide (N2O), are emitted to 

the atmosphere through natural processes and human activities. These GHGs are 

associated with composting. All organic materials contain carbon. When organic 

materials are decomposed naturally under aerobic conditions, CO2 is emitted as part of 

the natural short-term carbon cycle. When organic materials are placed in an anaerobic 

environment, anaerobic decomposition will emit methane and some VOCs. 

Methane is emitted from uncontrolled anaerobic 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 generated in landfills and open dumps as waste decomposes under 

anaerobic (without oxygen) conditions. The amount of methane created depends on the 

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 the 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 materials, such as manure, grass clippings, 

and food scraps, under wet and oxygen-limited conditions, can also produce N2O 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 Conservation and Recovery Act (RCRA), an 

amendment to the 1965 Solid Waste Disposal Act. RCRA calls for conservation of 

energy and natural resources, waste reduction, and environmentally sound waste 

management practices. In addition, RCRA encourages states to develop plans for nonhazardous 

industrial solid waste and municipal 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. Congress delegated authority to U.S. EPA to 

develop scientific regulations to implement the requirements of RCRA. Solid waste 

regulations have been promulgated in the Code of Federal Regulations under Title 40, 

Chapter I, Subchapter I, Parts 240-282 (40 CRF 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, generally requires processes to further reduce 

pathogens (PFRP). PFRP requires that open windrow composting maintain the 

temperature of the compost at 131 degrees Fahrenheit or higher for 15 days or longer, and 

during this time there must be a minimum of five 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 for three days. This process assures that 

virtually all human pests and pathogens are destroyed. Since food residuals contain 

human pathogens, fungi and bacteria, this PFRP should be met when foodwaste is being 

mixed with greenwaste for composting. 



State Programs 

California State Legislature: California Integrated Waste Management Act 

Recognizing landfill limitations (i.e., capacity and siting) and the need for integrated 

waste management practices, in 1989, the California state legislature passed Assembly 

Bill (AB) 939 – California Integrated Waste Management Act into law, which was 

incorporated into the California Public Resources Code, Division 30. Cities and counties 

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

total waste diversion of 50 percent every year. 

California Integrated Waste Management BoardDepartment of Resources Recycling and 

Recovery (CalRecycle) 

In April 2003, the California Integrated Waste Management Board (CIWMB) 

promulgated a set of regulations governing composting operations and facilities. The 

CIWMB currently regulates approximately 87 115 composting facilities operating in 

California in accordance with the California Code of Regulations, Title 14, Division 7, 

Chapter 3.1 – Composting Operations Regulatory Requirements (Chapter 3.1). The 

Chapter 3.1 has requirements of for handling compostable materials including, but not 

limited to, material residence time at facilities, and temperature requirement to prevent 

inadvertent decomposition. This Chapter also has a pathogen reduction requirement that 

requires open windrow composting maintain the temperature 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 Registration Permit, a Standardized 

Composting Permit,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 Minimization Plan (OIMP). [Note: the CIWMB was recently put under the 

officesformerly part of Cal-EPA, and is currently known as CalRecyclenow 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 Directive 6.1, which in addition to the diversion 

required under AB 939, seeks an additional 50 percent of organics 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 produce compost, biofuels, and/or 

bioenergy; increased development of product standards and increased procurement by 

private and public entities; and resolution of cross-agency regulatory issues. 

Regional Water Quality Control Board 

The Regional Water Quality Control Board (RWQCB) issues and enforces EPA-issued 

National Pollutant Discharge Elimination System (NPDES) permits. In addition, the 

RWQCB focuses on wastewater generation, water demand, the capacity of existing or 



planned stormwater drainage systems and potential new sources of polluted run-off, and 

potential depletion of groundwater supplies or interference with groundwater recharge. 

In the case of composting facilities, the RWQCB has required various composting sites to 

be graded, paved, and surrounded by berms and other drainage-related protections to 

prevent run-off and the leaching of chipped and ground materials into the groundwater. 

Local Programs 

There are several local requirements that may apply to greenwaste composting 

operations. Specifically, these requirements focus on air, land use and solid waste issues. 

The following is a summary of these requirements. 

SCAQMD Rule Requirements 

Currently, operators of chipping/grinding operations at greenwaste 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 comply with District Rules 1133 – General 

Administration, 1133.1 – Chipping and Grinding, and 1133.2 – Emission Reductions 

from Co-Composting Operations involving more 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 enforcement 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 requirements in these 

permits. For either type of permit scenario, the LEAs are responsible for handling and 

investigating complaints from composting and chipping/grinding operations. Pursuant to 

Health and Safety Code Section 41705, composting operations are exempt from 

SCAQMD odor regulations; SCAQMD must refer odor complaints to the LEA. 

Local Governments 

Local government zoning ordinances determine where composting activities can occur. 

In addition, local government grant conditional use permits if the jurisdiction has 

determined that special conditions and approvals are necessary. 

PUBLIC PROCESS 

Staff invited environmental and community group representatives, industry 

representatives, government staff, consultants and individuals 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 participate in the first working group meeting 

due to technical difficulties with the conference call. A second working group meeting 

was held on August 27, 2010 with revised concepts and preliminary 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 industry representatives on several occasions to 

address key issues relative to proposed rule requirements. A public workshop was held 

on February 9, 2011 and 15 written comments were received. The rule proposal was 

revised based on those comments and the third working group meeting 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 

has scheduledheld another working group meeting on June 15, 2011. The revised rule 

proposal is based on all the verbal and written comments 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 composting industry survey conducted in 2007, 

the predominant method of greenwaste composting is windrow composting. Composting 

is a biological process where organic material is decomposed by microorganisms under 

controlled conditions in the presence of oxygen to produce a compost material that can be 

used to reintroduce nutrients into the soils. Two composting methods are commonly 

conducted: static pile composting and turned 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 content 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 mechanically turning the piles with 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 specify specific type of composting, 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 emission control method required is determined 

based on the annual foodwaste throughput on a facility-wide basis. 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 foodwaste throughput (source-separated or mixed) 



would require a combination of finished compost cover and additional water irrigation. 

The operator would need to apply finished compost cover to the top 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 cover and water application is considered as 

a best management practice (BMP), not an emission control technology per se. If more 

than 5,000 tons per year of foodwaste throughput 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 percent 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 screened or unscreened, finished compost 

and/or compost overs to the top of greenwaste composting piles 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 escape 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 three 24 hours of initial pile construction and 

sit for a minimum of seven days with the piles unturned. This so-called “pseudobiofilter” 

approach is effective in reducing VOC emissions 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 windrow resulted in a 53 percent 

reduction in VOC emissions for the 22-day active phase period 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 oversized materials screened from 

finished compost, known as “compost overs”, showed that biofilter cap made out of overs 

reduced average measured ozone formation by 27 percent 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 California 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 atmosphere and has been used as biofilter media. 

The emissions during the active phase period of composting surpass the emissions during 

the curing phase and accounts for the vast majority of the total 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 during 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 finished compost is utilized as a 

cover material, it is initially recycled back into the process by using it to cover windrows 

and it is also not consumed in the process. It cycles back to finished compost at the end 

of the composting process. PR 1133.3 requires only one time application of finished 

compost cover and/or compost overs and thus there would be one time (temporary) loss 

of product sale. Use of finished compost as a pseudo-biofilter cover is a cost-effective 

emission mitigation measure to reduce VOC emissions from composting piles. Costs to 

apply finished compost cover mainly involve application time and 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 watered for the composting process, water 

irrigation would not be difficult for most of the composting facility operators. Excess 

moisture is also evaporated while turning the 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 wet and does not require water application 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 required only for operations having greater than 

5,000 tons per year of foodwaste throughput, either on a source-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 emission control technology for greenwaste 

composting operations. However, an emission control device should be designed, 

constructed, maintained, and operated 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 either 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 biofilter, to remove air pollution gas emissions 

pulled from the compost pile before they are 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 District Rule 1133.2 was adopted, 



biofiltration technology has been an emission control technology for co-composting VOC 

and ammonia emissions. Based on the information collected on existing biofilter 

composting applications, overall control efficiencies 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 efficiency for both VOC and ammonia. Biofilter 

manufacturers also emphasize that regular inspection and maintenance of the biofilter are 

key elements to achieve such control level. Based on source tests data from existing cocomposting 

operations (Inland Empire Regional Composting Facilities and City of Los 

Angeles Sanitation Bureau), properly designed 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 minimum of 80 percent control efficiency 

would be required under the PR 1133.3. 

Negative-pressure ASP is operated intermittently, 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 the pile because moisture will be drawn 

together with the exhaust gas emissions, leading to microorganisms entering a dormant 

stage. 

There are different ASP technologies utilizing 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 system 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 insertion 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 drawn 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 positive-pressure ASP using triple 

layer membrane compost covers 9, 10 . This type of technology pushes air into the pile, and 

does not need a biofilter. The membrane covers selectively influence the process. They 

protect the composting material from the penetration of rainwater and yet allow carbon 

dioxide produced during the composting process to escape. The compost cover keeps 

heat, odors, microorganisms, and some moisture contained, while releasing oxygen and 

some moisture. Covered piles are controlled with 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 description 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 covered ASP systems will 



meet PR 1133.3 requirements, their overall control efficiencies will have to be 

demonstrated using approved source test methods and protocols. Currently, there are 

only a few source tests that were conducted locally using the District Test Methods 

protocol. 

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, Requirements, Test Methods 

and Protocol, Recordkeeping, and Exemptions. Each section lists 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 inadvertent decomposition occurring during 

chipping and grinding activities, including stockpile operations. This proposed amended 

rule applies to the operators of chipping and grinding activities, including stockpile 

operations, to produce materials other than active or finished compost, unless otherwise 

exempted. 

Greenwaste materials must first be chipped or ground before being further processed for 

composting, mulching, static pile for land application, ADC at landfills, or biofuels at 

biomass refuse-to-energy facilities. Air emissions may occur even at a pre-chipping and 

grinding stage. However, once greenwaste materials are chipped or ground, air emissions 

begin to occur immediately and spike within three 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 compostable 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 applicability of the rule to the operators of 

chipping and grinding activities, including stockpile operations, to produce materials 

other than active or finished compost, and are regulated under Title 14. Therefore, this 

amended rule would apply to the operators of chipping and grinding activities occurring 

not only at a stand-alone chipping and grinding facility, but also at multi-operation 

facilities that handle multiple incoming material streams with separate operating areas for 

“chip and ship” operations (such as chipping to produce mulch, biofuel, ADC or 

woodchips) within the same facility. Chipping and grinding activities to produce 

compost feedstock will be separately subject to the applicable PR 1133.3 and Title 14 

requirements. It should further be noted that as these facilities 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 foodwaste cannot be accepted at chipping and 

grinding facilities, unless otherwise allowed by the LEA to handle foodwaste. 

Stockpile Operations 

Once greenwaste is received at the chipping and grinding facility, the operator shall 

chip or grind and utilize on-site or remove curbside, non-curbside or mixed 

greenwaste from the site within 48 hours of receipt, excluding observance of official 

federal and state holidays, or up to seven days maximum, with approval fromunless 

otherwise allowed by the LEA to hold for a longer period of time. This requirement 

harmonizes with Title 14, Division 7, Chapter 3.1, Section 17852 (a)(10)(A)(2) of the 

CCR. Chipped or ground materials shall not be stockpiled, but be “utilized” for other 

purposes, including, but not limited to, daily landfill cover, land application, mulch 

and erosion control, or be removed from the site, such as being sent to a landfill for 

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, agricultural chipping and grinding, landclearing chipping and 

grinding, woodwaste chipping and grinding, and palm chipping and grinding 

activities continue to be exempt from the provisions 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-specific records on-site, provided that the 


A biomass power generation facility or a facility processing material as a biomass 

fuel for a biomass power generation facility would also be exempt from the 48 hours 

or up to seven days maximum holding time requirement, provided that the material 

temperature is maintained at below 122 degrees Fahrenheit or the moisture content is 

less than 30% and records of the temperature or moisture measurements are 

maintained on-site. With this exemption, the definition of woodwaste has been 

modified such that the woody materials of screened or unscreened greenwaste, 

exceeding 2 inches in any dimension, such as tree trimmings, branches, tree trunks, 

stumps, and limbs, would be considered woodwaste. Rule elements pertaining to 

moisture content of chipped and ground curbside greenwaste remain unchanged. 



Summary of Proposed Rule 1133.3 – Emission Reductions from Greenwaste 


Purpose and Applicability 

The purpose of PR 1133.3 is to reduce fugitive emissions of VOC and ammonia 

occurring during greenwaste composting operations. This proposed rule would apply to 

all new and existing greenwaste composting operations that produce active or finished 

compost from greenwaste by itself or greenwaste in combination with manure or 

foodwaste. If greenwaste material is chipped or ground to produce feedstock for 

composting, the chipping and grinding activities and associated material 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 Fahrenheit during decomposition. Pathogen-reduced 

mulch is included in active compost. Finished 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 materials that do not decompose in a typical 

composting cycle and are screened out of finished product at the end of composting. 

Compost overs have been through the pathogen reduction process outlined in the CCR, 

Title 14, Section 17868.3. 

New greenwaste composting operations are defined 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 existing composting facilities that are either 

registered for a Notification tier or permitted by the LEA to conduct composting 

operations. The level of requirements would depend on the annual foodwaste throughput 

on a facility-wide basis. 

For all greenwaste composting operations: 

Effective upon rule adoption, the operator of greenwaste composting operation is 

required to chip or grind, as necessary, and use greenwaste for on-site composting 

within 48 hours of receipt, unless otherwise as allowed by the LEA to hold for a 

longer period of time. This requirement is consistent with the requirement of PAR 

1133.1, pursuant to paragraph (d)(2) and is conforming to the state regulation 

pursuant to the 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. 



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 proposed 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 Co- 

Composting Operations (adopted in January 2003), because it was difficult for 

agricultural farm composters to completely 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-composting operations. Up to 5,000 tons per 

year of foodwaste throughput can be composted without the need to install an 

emission control device. This proposed foodwaste throughput is on a facility-wide 

basis, and either source-separated or mixed foodwaste is counted. Mixed foodwaste 

contains compostable material (e.g., compostable plastic bags, food-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-putrescible materials, including, but not 

limited to, paper, woody, other low-water, high cellulose materials, and noncompostable 

contaminants and greenwaste that are separated either before or after 

composting and shipped off-site for disposal, 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 stores, or residential food scrap collection. Any non-food 

material that is not separated from food scraps is also considered foodwaste for the 

purpose of calculating throughput, including, but not limited to, compostable 

materials (e.g., plastic bags, food-soiled packaging, papers or other biodegradable 

material) or non-compostable solid waste (e.g., napkins, cans, glass, plastics, 

containers, and Styrofoam). There is no restriction on the recipes of foodwaste-togreenwaste 

ratio. 

Mitigation Measures: Finished Compost Cover and Watering 

Every active phase pile is required to be covered with finished compost within three 

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 active phase period of composting. Tests 

have shown the emissions primarily escape from the top one third of the pile. Having 

a six inch compost cover at the top ensures that the pile is adequately covered and 

tapers as it goes down the pilesides. Thus, the application 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 

from during the first 15 day active phase period of composting. In particular, the 

emissions tend to spike within the first three to seven days of the active phase of 



composting and then diminish by with time. According to a mitigation measure 

study 3 , about 53 percent of VOC emission reductions were achieved with six inches 

of finished compost layer applied upon initial 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 living on the surface of the finished compost. To minimize facility 

impacts, the compost cover is only proposed for initial pile 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 necessary to the surface area of all active phase 

piles within three six hours before subsequent 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. Alternatively, 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 greenwaste compost piles by 24 percent. VOC 

emitted 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, there would be no water run-off problems 

associated with additional watering. Staff also expects that excess moisture is 

evaporated while turning the piles and will not lead to oversaturation and leaching 

issues, as well as anaerobic condition issues. 

If a rain event occurs prior to watering the pile within three six hours before turning 

and the pile is wet to a depth of three inches, the 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 form a ball when compressed by hand, but may 

break when tapped, within three 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 until requirements are met. 

This may also apply to a normal operating condition. If the pile is sufficiently wet 

down to a three inch depth within three six hours before turning 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 pile 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 Board, and the United States Environmental Protection 

Agency, and demonstrate emission reductions by at least 40 percent, by weight, for 

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 mixed) 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 significant emission reductions but may increase 

operational costs. The operator may implement a control alternative, if approved by 

the Executive Officer, California Air Resources Board, and the U.S. EPA, to achieve 

VOC and ammonia emission reductions equivalent to or greater than the required 

reductions. 

Any emission control device should be designed and operated such that an overall 

control efficiency of at least 80 percent 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 facility 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 emission factors are proposed to determine an 

overall control efficiency of 80 percent for an emission control device. Baseline 

emission factors are the uncontrolled emission factors for greenwaste composting 

operations for VOC and ammonia. Proposed baseline emission factors are 4.25 

pounds of VOC per ton of throughput and 0.46 pounds of ammonia per ton of 

throughput for the active phase of composting only. Staff developed the composite 

emission factors by using currently available emissions data measured by various 



agencies, including the District, state and other air districts for greenwaste 

composting operations typical for the South Coast jurisdiction. The proposed 

emission factors reflect only emissions from windrow composting operations and 

exclude stockpile emissions. Procedures for developing the new baseline emission 

factors are explained in detail in Appendix III – Emission Reductions and Cost 

Effectiveness. 

Permit Application 

A permit would be required for an emission control device for all new and existing 

greenwaste composting operations processing greater than 5,000 tons per year of 

foodwaste throughput (source-separated or mixed) and a foodwaste content 

containing 10 percent or more, by weight. All new greenwaste composting 

operations would be required to obtain a permit for such equipment before 

construction. Existing greenwaste composting operations that, as of rule adoption, 

process or plan to process greater than the foodwaste throughput and content 

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

within three months of rule adoption and fully implement such device within six 

months upon approval of the permit application. However, based on the information 

provided by the composting operation, in response to the survey conducted by staff, 

there are no existing operations currently that are in excess of 5,000 tons of feedstock 

foodwaste per year. 

Depending on the configuration of the emission control device, controls may be 

accomplished with or without the need of venting 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 permit, with or without food. Finished 

compost cover is seen more as a BMP as opposed to a control technology, and thus 

does not require a permit nor trigger BACT. New facilities required to obtain a 

permit will be subject to New Source Review including BACT requirements. This 

being the case, ASP composting with appropriate emission control devices may be 

considered BACT. If the post-control VOC emissions exceed 22 lbs per day at a 

facility, offsets would be required. This is part of the existing permit system. 

Existing facilities that are currently doing windrow composting and that modify to 

ASP composting solely to comply with this new rule would likely meet BACT and 

not require offsets, provided that they operate at the current facility throughput. Such 

permitting would be reviewed and evaluated on a case-by-case basis. 

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 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 

composting emissions. If a pile is aerated, the mechanical aeration system and its 

associated emission control device would require a separate permit for each. 



It should also be noted that depending on the circumstances, new and existing 

composting facilities modifying their operation may also be subject to New Source 

Review requirements of Regulation XIII, including 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 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 causes an increase in emissions. Even if the modification would result 

in an increase in emissions, the facility could take advantage of the small business 

exemption if its total emissions remain under 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 source’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 exemption in Rule 1304(c)(4), provided there 

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 control efficiency of at 

least 80 percent, by weight, for VOC and ammonia emissions, respectively. Source 

test needs to be conducted within three months after start-up of the device, or within 

nine months of permit approval, whichever 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 recorded 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 successfully approved by AQMD Source 

Testing and also successfully met the 80% requirements for VOC and ammonia. As 

an example of an acceptable test to demonstrate 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 involved several operating scenarios, were 

developing testing methods and techniques, were unique and difficult to test 

configurations, and/or included many samples 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 competition, the testing costs have gone 

down. Additionally, through experience in assessing these processes, more effective 

methodologies have been developed for planning and executing testing. 

Primary among the important factors responsible for adequate 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 these 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 organic vapor analyzer to 

determine the concentration profile of the biofilter surface. Smoke testing can help to 

identify channeling also, though resolution is obviously more limited than organic 

analysis screening. With screening information, specific points 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 otherwise 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 inlet ducting flow rate can be determined by a routine Method 1- 

4 Pitot traverse, accuracy is increased while testing costs are decreased by eliminating 

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 operation and maintenance manual or other 

similar written materials supplied by the manufacturer or distributor 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 control device, the operator 

of a greenwaste composting operation would be required to conduct all required source 

and laboratory tests using the Executive Officer approved test protocol 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, should be maintained for the prior five years 

of operation, with the most recent 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 Co- 


If the operator of any greenwaste composting operation voluntarily installs an 

emission control device, the provisions of additional irrigation and the finished 

compost cover and associated recordkeeping 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 from 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 

o Recreational facility composting 

EMISSIONS INVENTORY AND REDUCTIONS 

Affected Industry 

Chipping and Grinding Industry Sector 

For the purpose of PAR 1133.1, chipping and grinding 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 activities can be stand-alone 

operations, or part of multi-operation facilities, such as a transfer station, a landfill, a 

material recovery operation, or a composting operation, that handle multiple incoming 

material streams with separate operating areas within the same facility. 

Chipping and grinding facilities process greenwaste, which is mostly, collected from 

landscapers or from cities’ curbside collection programs. Curbside greenwaste is 

collected from receptacles designed for residential 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 tree trimmings and other landscaping 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 stakeholders and CalRecycle staff to estimate the 

number of facilities that have chipping and grinding operations. 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 ground greenwaste where they can be used as 

mulch for landscaping, ADC at landfills, biofuels for energy production, feedstock for 



static pile or greenwaste composting operations, 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 chipping and grinding, woodwaste 

chipping and grinding, landclearing 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 Number of Estimated landfill ADC 

facilities landfills (subset) 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). 

Staff is appreciative of the input provided by the compost industry. Without adequate 

assistance from the compost industry stakeholders, 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 District’s Air Quality Notification Report, a 

District-wide composting survey (conducted in 2007), a supplemental questionnaire to 

augment the 2007 survey, site visits, phone calls/emails to the facility 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 incoming tonnage of green 

materials, along with operational 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 actual throughput for greenwaste composting operations was 

refined for 2009–2010. 

Currently, 17 facilities are identified as greenwaste composting facilities and their actual 

tons per year throughput for greenwaste composting are shown in Table 2. Actual 

greenwaste throughput for composting operations is about 416,300 tons for 2009–2010, 

which accounts for 58% of facility throughput totals 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, and palm feedstock. 



Table 2. Number and Throughput of Affected Greenwaste Composting Facilities 

County Number of Facility throughput totals Throughput for 

facilities 

(tons/year) 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 composting operations was developed based on 

the refined 2009–2010 activity data (i.e., actual annual throughput of greenwaste 

processed for composting) and baseline emission factors for windrow composting. The 

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

emission tests conducted by the District, other air districts, and CalRecycle for 

greenwaste windrow composting operations. 

Windrow composting baseline (uncontrolled) emissions are calculated 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 per 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. However, 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 for greenwaste composting operations, as well 

as the emission reductions anticipated with the implementation of PR 1133.3. 

Calculation details are explained in Appendix III. As shown in Table 3, greenwaste 

composting operations generate significant amount of VOC and fewer amounts of 

ammonia emissions in the Basin. Using the 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 the windrow composting process, 0.9 tons of 

VOC and 0.1 tons of ammonia are projected to be reduced daily. 



Table 3. Emissions Inventory and Emission Reductions for Existing Greenwaste 


VOC Ammonia 

Emissions Inventory (tons/day) 2.66 0.38 

Proposed Requirements 

Windrow composting operations 

40% with compost cover and 20% with compost cover 

(without emission control devices) water combined 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 composting operations. Total compliance costs, 

being averaged per facility, are also presented. 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 composting facilities, some facilities use all 

potable water and the others use all reclaimed or canal or well 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 analysis 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. 

Composting 

throughput 

(Tons/year) 

Table 4. Greenwaste Composting Average Cost Effectiveness 

Number 

of 

facilities 

416,300 17 

Mitigation 

measure 

description 

Finished compost 

cover and watering 

combined 

Total annual 

compliance 

costs 

(Avg. $/year) 

INCREMENTAL COST EFFECTIVENESS 

Cost 

effectiveness 

for VOC only 

($/ton) 

Cost 

effectiveness for 

VOC & NH3 

($/ton) 

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

Health and Safety Code Section 40920.6 (a)(3) requires the calculation of incremental 

cost effectiveness for potential control options, when the District adopts “rules or 

regulations to meet the requirements for best available retrofit control technology 

(BARCT) pursuant to Sections 40918, 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, sulfur 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 ammonia reduced per year, between 



two progressively more effective control technologies. Incremental cost effectiveness 

examines additional costs and emission reductions that can be achieved by adding a 

second level of control to the primary control. Because the incremental reductions from 

the controlled source operations are typically low, incremental 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 conceptualized for composting involving foodwaste, but capital 

expenditures for low throughput facilities are cost-prohibitive. Therefore, staff proposes 

to require such controls for those facilities processing significant quantities of foodwaste 

(i.e., greater than 5,000 tons per year). No existing facility operations are expected to 

trigger this control requirement, 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 the 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 typical 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 percent. Incremental costs and emission 

reductions were calculated for an operation 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 calculated to be $6,600 per additional ton of 

VOC-only ($5,700 per additional ton of VOC and ammonia combined). As opposed to 

absolute cost effectiveness of using finished 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 relatively high cost increments, as opposed to the 

relatively small incremental emission reductions between the two control methods. 

Although $6,600 per ton incremental cost effectiveness is in the range of other adopted 

rules, the operating margin for greenwaste composting facilities is relatively low and with 

the seemingly high capital expenditure required for control equipment, the use of controls 

is not more widely proposed so as to not impact facility 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 review and comment on June 2, 2011, and 

will beis 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 available to the public 

at least 30 days prior to the Public Hearing. 

COMPARATIVE ANALYSIS 

Health and Safety Code Section 40727.2 was added in 1997 as part of AB 1061 

(Machado). The statute prescribes 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 analysis requires an identification 

of “all existing federal air pollution 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 type” as proposed to be regulated by the rule. 

The District’s analysis must also examine “all air pollution control requirements and 

guidelines” that the District is initially informed of by the public that 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.), greenwaste chipping and grinding operations subject to PAR 

1133.1 and greenwaste composting operations subject to PR 1133.3 will also need to 

comply with Rule 403. 

AQMD Rule 1133 – Greenwaste and Related Operations – General Administrative 

Requirement, is applied to chipping/grinding and composting facilities. It establishes 

one-time registration, along with one-time 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 types 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 curbside, 14 days for non-curbside, and 7 days for 

mixed. However, the rule only requires three-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 greenwaste. PAR 1133.1 proposes to add the 

same 48 hours holding requirement all for curbside, 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 and/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. 



Table 5. Comparison of State Regulation and District Proposed Rules 

Title 14, CCR, Chapter 3.1 – Composting Operations Regulatory Requirements PAR 1133.1 PR 1133.3 

Article 1. General Subdivisions (a) Purpose, (b) Applicability & (c) Definitions Subdivisions (a) Purpose, (b) Applicability & (c) Definitions 

Section 

17850 

Definitions 

Section 

17852 

Scope 

(c) 

Active 

compost 

(a)(1) 

Chipping 

and grinding 

operations 

and facilities 

(a)(10) 

Establishes standards and regulatory requirements for 

intentional and inadvertent composting resulting from the 

handling of compostable materials, IBNLT feedstock, 

compost, or chipped and ground materials 

Compost feedstock: 

Generating T at ≥ 122 deg F; or 

Releasing CO2 ≥ 15 mg/g compost/day, or the 

equivalent of O2 uptake 

An operation or facility that: 

Do not produce compost; or 

Mechanically reduces the size; or otherwise 

Engages in the handling of compostable material 

(a)(10)(A)1. Handles only material, excluding manure, allowed at a 

green material composting op. or fac. set forth in 

17852(a)(22) 

(a)(10)(A)2. Each load of green material is removed from the site 

within 48 hrs of receipt 

The EA may allow a site to keep it on-site for up to 7 

days 

(a)(10)(B) If the contaminant limits in 17852(a)(21) are exceeded, 

shall be regulated as set forth transfer/processing 

requirements 

(a)(10)(C) If green material remains on-site for >48 hrs, shall be 

regulated as a compostable material handling operation or 

Compostable 

material 

(a)(11) 

Compostable 

material 

handling 

operation or 

facility 

(a)(12) 

facility 

Any organic material that when accumulated will become 

active compost 


Processes, transfers, or stores compostable material, 

resulting in controlled biological decomposition 

Handling includes composting, screening, chipping and 

grinding, and storage activities related to the production 

of compost, compost feedstocks, and chipped and ground 

materials 

Purpose 

(a) 

Applicability 

(b) 

Definitions: 

Active 

compost 

(c)(1) 



(c)(3) 

Prevent inadvertent decomposition occurring 

during chipping and grinding activities, 

including stockpile operations 

Operators of chipping and grinding activities 

to produce materials other than active or 

finished compost 

Material in the process of being rapidly 

decomposed and is biologically unstable 

Generates T at ≥ 122 deg F 

IBNLT pathogen-reduced mulch 

Any activity that mechanically reduces the 

size of greenwaste, woodwaste, and/or 

foodwaste 

SCAQMD 28 June July 2011 

N/A 

Purpose 

(a) 

Applicability 

(b) 

Definitions: 

Active 

compost 

(c)(1) 

Active phase 

(c)(2) 

Reduce fugitive emissions of VOC and 

ammonia occurring during greenwaste 

composting operation 

Operators of all new and existing greenwaste 

CST operations that produce active or 

finished compost from greenwaste only or 

greenwaste in combination with manure or 

foodwaste 

Material in the process of being rapidly 

decomposed and is biologically unstable 

Generates T at ≥ 122 deg F 

IBNLT pathogen-reduced mulch 

Phase of the greenwaste CST process that: 

Begins when organic waste materials are 

mixed together for composting; and 

Lasts at least 22 days under controlled 

conditions, or 

Until the compost has a SMI of 5 or higher 

Refer to PAR 1133.1 Requirements Refer to PR 1133.3 Requirements 

N/A 

N/A 

Greenwaste 

composting 

(c)(13) 

Composting 

(c)(6) 

N/A 

N/A 

N/A 

Composting of greenwaste by itself; or 

Mixture with foodwaste or with up to 20% 

manure, by volume 

A process that solid organic waste materials 

are decomposed in the presence of oxygen 

through the action of bacteria and other 

microorganisms


Table 5. Comparison of State Regulation and District Proposed Rules (continued) 


Article 1. General (cont’d) Subdivision (c) Definitions Subdivision (C) Definitions 

Definitions Curing Final stage of the composting process: 

Finished Humus-like material that results from the Finished Humus-like material that results from the 

Section (a)(13) Occurs after compost has undergone pathogen reduction compost controlled biological decomposition of compost controlled biological decomposition of 

17852 

& after most of the readily metabolized material has been (c)(7) organic waste materials and is biologically (c)(10) organic waste materials and is biologically 

decomposed and stabilized 

stable 

stable 

Both active and curing phases are required 

Disposal Stockpiling of: 

Curing phase Phase of the greenwaste CST process that: 

(a)(15)(A) Compostable material onto land for a combined period of 

(c)(7) Begins immediately after the end of the 

time > 6 mos., or agricultural and green material for 12 

active phase of composting; and 

mos. on prime agricultural land 

N/A 

Lasts at least 40 days; or 

Until the compost has a SMI of 7; or 

Product respiration rate is < 10 mg of O2 

consumed per g of VS per day as 

measured by direct respirometry 

(a)(15)(B) Does not include the use of compostable material for ADC 

at a solid waste landfill (Title 27, section 20680) 

N/A 

N/A 

(a)(15)(C) Does not include land application of compostable organic 

material 

Land application – application of compostable material 

(excl. food or mixed solid waste) to forest, agricultural, and 

range land, I/A/W CDFA requirements for beneficial uses 

N/A 

N/A 

Feedstock Any compostable material used in the production of Stockpile A supply of raw material tipped and stored 

(a)(19) compost or chipped and ground material IBNLT 

(c)(17) prior to be utilized on-site or removed 

agricultural material, green material, food material, 

from the site 

N/A 

biosolids, and mixed solid waste 

Raw materials before and after chipping 

Additives or amendments are not considered feedstocks 

and grinding are also included 

Food Any material that: 

Foodwaste Any food scraps collected from the food Foodwaste Any pre- & post-consumer food scraps 

material Was acquired for animal or human consumption 

(c)(8) 

service industry, grocery stores, or (c)(11) collected from the food service industry, 

(a)(20) Is separated from the municipal solid waste stream 

residential food scrap collection 

grocery stores, or residential food scrap 

Does not meet the definition of “agricultural material” 

Includes food scraps that are chipped and 

collection 

May include material from food facilities [H&SC 

ground 

Includes chipped and ground food scraps 

113785], grocery stores, institutional cafeterias or 

Non-food materials (either compostable or 

residential food scrap collection 

non-compostable) are considered 

foodwaste for calculating throughput, if 

not separated from food scraps 





Article 1. General (cont’d) Subdivision (c) Definitions Subdivision (C) Definitions 

Green 

material 

(a)(21) 

Green 

material 

composting 

op. or fac. 

(a)(22) 

Wood waste 

(a)(42) 

Yard 

trimmings 

(a)(43) 

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, natural 

fiber products, and C&D wood waste 

Does not include food material, biosolids, mixed solid 

waste, material processed from commingled collection, 

wood containing lead-based paint or wood preservative, 

mixed construction or mixed demolition debris 


Composts green material, additives, and/or amendments 

May also handle manure or paper products 

Solid waste consisting of wood pieces generated from: 

manufacturing or production of wood products, harvesting, 

processing or storage of raw wood materials, or C&D 

activities 

Any wastes generated from the maintenance or alteration of 

public, commercial or residential landscapes IBNLT 

yard clippings, leaves, tree trimmings, prunings, brush, and 

weeds 

Curbside 

greenwaste 

(c)(5) 

Mixed 

greenwaste 

(c)(10) 

Noncurbside 

greenwaste 

(c)(11) 

Compost 

overs 

(c)(5) 

Woodwaste 

(c)(16) 

Greenwaste 

(c)(7) 

Collected from receptacles designated for 

residential household greenwaste 

Screened curbside greenwaste containing 

only grass clippings, leaves, and/or twigs 

that is not considered non-curbside 

greenwaste as defined in paragraph (c)(11) 

Curbside greenwaste comingled with noncurbside 

Any greenwaste not collected from 

receptacles designated for residents 

Oversized woody materials that do not 

decompose in a typical composting cycle 

and are screened out of finished product at 

the end of composting 

Have been through pathogen reduction 

process outlined in the Title 14, Section 

17868.3 


N/A 

Lumber, and the woody material portion (> 2 

inches) of mixed demolition and construction 

wastes, tree trimmings, branches, tree trunks, 

stumps, and limbs 

Any organic waste material generated 

from gardening, agriculture, or 

landscaping activities IBNLT grass 

clippings, leaves, tree and shrub 

trimmings, and plant remains 

Includes curbside, non-curbside, and 

mixed greenwaste 

Compost 

overs 

(c)(7) 

Woodwaste 

(c)(25) 

Greenwaste 

(c)(12) 

Oversized woody materials that do not 

decompose in a typical composting cycle 

and are screened out of finished product at 

the end of composting 

Have been through pathogen reduction 

process outlined in the Title 14, Section 

17868.3 

N/A 

Lumber, and the woody material portion (> 2 

inches) of mixed demolition and construction 

wastes, tree trimmings, branches, tree trunks, 

stumps, and limbs 

Any organic waste material generated from 

gardening, agriculture, or landscaping 

activities IBNLT grass clippings, leaves, tree 

and shrub trimmings, and plant remains




Article 2. Regulatory Tiers for Composting Operations and Facilities Subdivisions (f) Exemptions Subdivisions (g) Exemptions 

Section 

17854 

Section 

17855 

Composting 

materials 

handling 

facility 

permit 

Excluded 

activities 

All compostable materials handling activities shall obtain a 

Compostable Materials Handling Facility Permit 

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; 

o Compostable materials* are generated on-site; and 

o ≤ 1,000 cy of materials are either sold or given away 

annually 

* Compostable material may include up to 10% food, vol. 

Handling of compostable materials, if: 

o The activity is co-located at a facility (i.e. landfill or 

transfer/processing facility) that has a tiered or full 

permit as defined section 18101; etc. 

Non-commercial composting with < 1 cy food material 

generated and used on-site 

Storage of bagged products (≤ 5 cy) from compostable 

material 

Within-vessel composting process < 50 cy capacity 

Beneficial use of compostable materials IBNLT: 

o Slope stabilization, weed suppression, ADC, and 

similar uses, determined by the LEA 

o Land application [Food & Ag. Code 14501] 

o Reclamation projects [Public Resrc. Code 2770] 

Exemptions 

(f) 


N/A 

Exempt from (d)(2) through (d)(4): 

o C/G activities of greenwaste derived 

from the site and utilized on-site, 

provided < 1,000 cy of material is sold 

or given away 

o Portable, agricultural, landclearing, 

woodwaste, and palm C/G activities 

Chipped and ground curbside greenwaste: 

Exempt from the requirements of 

paragraph (d)(2) provided that the MC is < 

30%, measured I/A/W subdivision (e) and 

the MC measurements are maintained onsite 

in accordance with subparagraph 

(d)(4)(E) 

The operator of a landfill or biomass 

power generation facility: Exempt from 

the requirements of paragraph (d)(6), 

provided that the operator does not 

perform C/G of greenwaste on-site 

The operator of a biomass power 

generation facility or a facility to produce 

biofuel for a biomass power generation 

facility: Exempt from (d)(2), provided T is 

< 122 deg F. or MC is < 30%, measured 

I/A/W subdivision (e) and the MC 

measurements are maintained on-site in 

accordance with subparagraph (d)(4)(E) 

Exemptions 

(g) 

N/A 

Co-composting facilities (Rule 1133.2) 

If the operator of any greenwaste 

composting operation installs a forced 

aeration system including an emission 

control device, I/A/W paragraphs (d)(3) 

through (d)(6), the provisions of paragraph 

(d)(2) do not apply 

The following types of facilities and 

operations, provided that the operations 

are not subject to the LEA Notification or 

Permit regulations pursuant to Title 14 

Section 17851.1: 

o Community composting; 

o Nursery composting; 

o Backyard composting; and 

o Recreational facility composting




Article 2. Regulatory Tiers for Composting Operations and Facilities (cont’d) Subdivision (d) Requirements Subdivision (d) Requirements 

Section 

17857.1 

Section 

17862.1 

Green 

material 

composting 

operations 


Food 

material 



operations 


EA Notification requirements: 

o Has > 12,500 cy of feedstock on-site at any one time 

o Inspection at least once every 3-months 

Compostable Materials Handling Facility Permit: 

o Has > 12,500 cy of feedstock on-site at any one time 

Must have a composting operation or a transfer station 

permit to receive food material (per Horowitz, 

CalRecycle) 

EA Notification requirements: 

o Receives up to 200 tpd 

Registration Permit: 

o Receives > 200 tpd and up to 500 tpd 

Compostable Materials Handling Facility Permit: 

o Receives > 500 tpd 

A chip/grind operation is not subject to 17868.1 through 

3 

If a chip/grind operation exceeds 1% contamination 

limits, it shall be regulated as set forth in 

Transfer/Processing Regulatory requirements 

If a chip/grind operation stores material for > 48 hrs, the 

site shall be regulated as a green material handling 

operation or facility 

Foodwaste 

(d)(1) 

Curbside, 

noncurbside, 

and 

mixed 

greenwaste 

(d)(2) 

N/A N/A 

N/A N/A 

Cannot take it unless allowed by the LEA to 

handle foodwaste 

Chip or grind and utilize on-site, or remove 

from the site within 48 hours of receipt, 

unless otherwise allowed by the LEA to hold 

for a longer period of timeexcluding 

observance of official federal and state 

holidays, or up to 7 days maximum, with 

approval from the LEA 

Foodwaste 

(d)(1)(B) 

Greenwaste 

(d)(1)(A) 

Use foodwaste for on-site composting 

within 48 hours of receipt, or 

Covered with screened or unscreened 

finished compos until used, unless 

otherwise required by the LEA 

Chip or grind, as necessary, and use for onsite 

composting within 48 hours of receipt, 

unless otherwiseas allowed by the LEA to 

hold for a longer period of time 





Article 8 Composting Operation and Facility Records Subdivisions (d) Requirements and (e) Moisture Content Subdivision (f) Recordkeeping 

Section 

17869 

General 

record 

keeping 

requirements 

All compostable materials handling operations and 

facilities shall record the following: 

Any special occurrences encountered during operation 

and methods used to resolve problems 

Any public complaints, including: 

o The nature of the complaint; 

o The date the complaint was received; 

o The name, address, and ph.# of the complainer; and 

o Any actions taken to respond to the complaint 

The quantity and type of feedstock received and quantity 

of compost and chipped/ground material produced 

Keep all records in one location and accessible for 5 

years and available for inspection by authorized 

representatives during normal working hours 

The number of load checks and loads rejected 

All test results IBNLT metal contaminations, fecal 

coliforms/Salmonella sp. Densities, T measurements, & 

dates of windrow turnings 

o Retain records detailing pathogen reduction methods 

Any serious injury to the public occurring on-site and 

any complaint of adverse health effects to the public 

attributed to operations 

N/A 

N/A 

Recordkeeping 

(d)(3) 

Records 

(d)(4) 

Rainy days 

and wet 

weather 

conditions 

(d)(5) 

Moisture 

content 

measurement 

(e) 

Maintain all the operational records for the 

prior 5 yrs. of operation, with the most 

recent 2 yrs. retained at the facility, which 

shall be immediately available upon 

request by the EO 

Remaining 3 yrs. of records shall be made 

available to the EO within 1 week of 


request 

Maintain the following on-site for 2 years: 

(A) AQMD registration and annual 

updates 

(B) Date, type, and amount of greenwaste 

and/or foodwaste received 

(C) Date, type, amount of greenwaste 

and/or foodwaste removed from the site 

location where they are transferred to 

(D) Dates of rainy days and wet weather 

conditions and description of specific 

conditions that limited normal operations 

(E) T or MC measurements 

(F) Dates and amount of curbside 

greenwaste chipped and ground 

Time requirements in paragraph (d)(2) may 

be extended by the number of rainy days and 

wet weather conditions that impede normal 

chipping and grinding operations provided 

that records are maintained in accordance 

with subparagraph (d)(4)(D) 

Determine by collecting at least 10 

samples of chipped and ground greenwaste 

from various locations of the pile 

At a depth of at least 12 inches below pile 

surface 

Mix thoroughly and analyze for moisture 

content by ASTM method D4442, ASTM 

method D4444 or ASTM method E871-82 

Recordkeeping 

(f) 

Keep in a format approved by the EO 

Maintain all operational records and 

information for the prior 5 years – the 

most recent 2 yrs. on-site and the 

remaining 3 yrs. available within 1 week 

of request




Article 6. Composting Operation Standards 

Section 

17867 

General 

requirements 

Article 7. Environmental Health Standards 

Section 

17868.3 

Pathogen 

reduction 

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. 

Operators that produce compost shall ensure the 

following: 

o Enclosed or within-vessel, active compost: 

– Maintain T at ≥ 131 deg F for 3 days 

o Windrow composting, active compost: 

– Maintain T at ≥ 131 deg F for 15 days or longer 

– Minimum of 5 turnings 

o Aerated static pile, active compost: 

– Cover with 6–12 inches of insulating material 

– Maintain T at ≥ 131 deg F for 3 days or longer 

Alternative, equivalent pathogen reduction method 

Monitoring during the pathogen reduction period: 

o Each day, at least one T reading per every 150 ft 

windrow, or for every 200 cy of active compost 

– 12–24 inches below the pile surface for windrow 

composting 

– 12–18 inches below the point where the insulation 

cover meets the active compost for aerated static 

pile 

Acronyms: 

ADC: alternative daily cover I/A/W: in accordance with 

CCR: California Code of Regulations IBNLT: includes, but is not limited to; or including, but not limited to 

CDFA: California Department of Food and Agriculture LEA: Local Enforcement Agency 

C&D: construction and demolition MC: moisture content 

CDI: construction, demolition, and inert PAR: Proposed Amended Rule 

C/G: chipping and grinding PR: Proposed Rule 

CST: composting SMI: Solvita Maturity Index® 

EO: Executive Officer T: temperature 


N/A 

N/A 

N/A 

N/A


DRAFT FINDINGS UNDER THE CALIFORNIA HEALTH AND 

SAFETY CODE 

Before adopting, amending or repealing a rule, the California Health and Safety Code 

requires SCAQMD to adopt written findings of necessity, authority, clarity, consistency, 

non-duplication, reference, and problem, as defined in Health and Safety Code §§ 40727 and 

to promote the attainment or maintenance of state or federal ambient air quality standards 

pursuant to Health and Safety Code Section 40001(c). The draft findings are as follows: 

Necessity – The SCAQMD Governing Board has determined that a need exists to adopt 

Proposed Amended Rule 1133.1 – Chipping and Grinding Activities, and Proposed Rule 

1133.3 – Greenwaste Composting, to ensure best management practices to prevent 

inadvertent decomposition during operations related to greenwaste material handling, 

including chipping and grinding, and to reduce emissions occurring from composting, 

including ozone and PM precursors. 

Authority – The SCAQMD Governing Board obtains its authority to adopt, amend, or repeal 

rules and regulations from Health and Safety Code §§ 39002, 40000, 40001, 40440, 40702, 

40725 through 40728. 

Clarity – The SCAQMD Governing Board has determined that Proposed Amended Rule 

1133.1 – Chipping and Grinding Activities, and Proposed Rule 1133.3 – Greenwaste 

Composting, is written and displayed so that the meaning can be easily understood by 

persons directly affected by it. 

Consistency – The SCAQMD Governing Board has determined that Proposed Amended 

Rule 1133.1 – Chipping and Grinding Activities, and Proposed Rule 1133.3 – Greenwaste 

Composting, is in harmony with, and not in conflict with or contradictory to, existing statues, 

court decisions, federal or state regulations. 

Non-duplication – The SCAQMD Governing Board has determined that Proposed Amended 

Rule 1133.1 – Chipping and Grinding Activities, and Proposed Rule 1133.3 – Greenwaste 

Composting, does not impose the same requirements as any existing state or federal 

regulation, and the proposed rule is necessary and proper to execute the powers and duties 

granted to, and imposed upon, the SCAQMD. 

Reference – In adopting this proposed rule, the SCAQMD Governing Board references the 

following statues which the SCAQMD hereby implements, interprets or makes specific: 

Health and Safety Code Sections 40001 (rules to achieve ambient air quality standards); and 

40440(a) (rules to carry out the AQMP); 40440(c) (cost-effectiveness). 

Problem – The SCAQMD Governing Board has determined that, pursuant to Health and 

Safety Code Section 40001(c), there is a problem that Proposed Amended Rule 1133.1 – 

Chipping and Grinding Activities, and Proposed Rule 1133.3 – Greenwaste Composting, will 

alleviate, that is harmonizing greenwaste material handling with that of the California Code 

of Regulations, Title 14, and preventing emissions from composting operations through the 

use of best management practices. 



CONCLUSIONS 

The proposed rules reflect reasonable, cost-effective 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 restrictive 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 finished compost and additional watering to compost piles during 

the first 15 days of the 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 facilities. Total annual O&M 

costs range from $700 per facility 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 existing greenwaste composting facilities. 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). 



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 recycling to sustainable future. BioCycle, 

48, 20–22. 

3. SJVAPCD, 2010a. Comparison of Mitigation Measures for Reduction of Emissions 

Resulting from Greenwaste Composting, Project 09-01 CCOS Draft Final Report. 

4. CIWMB, 2007. Emissions Testing of Volatile 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, 


11. SJVAPCD, 2010b. Compost VOC Emission Factors, San Joaquin Valley Air Pollution 

Control District, September 15, 2010. 

12. NorCal Waste Systems, 2006. Emissions Evaluation of Complete Compost Cycle VOC 

and Ammonia Emissions, Air Emissions Source Test Report, May 2006. 



APPENDIX I – COMPOSTING PROCESS 

This appendix describes basic steps and management requirements for greenwaste composting 

operations. This part of the document includes discussion on the definition of composting, the 

typical greenwaste composting operation, and operating parameters of composting conditions 

taken into consideration for efficient composting operation. 

Composting is a biological process where microorganisms decompose organic materials under 

controlled environments. The readily available nutrients of the feedstock materials are 

consumed by microorganisms. Microorganisms use carbon for energy and growth while 

nitrogen is essential for protein and reproduction. 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 stages: preprocessing, processing and postprocessing. 

Figure I-2 presents the flow of a typical greenwaste composting process. 

Figure I-2. Flow of Typical Greenwaste Composting Operation 2 

SCAQMD I-1 June July 2011


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

collected and unloaded. After being preprocessed, greenwaste undergoes active composting 

during which thermophilic microorganisms (or thermophiles) decompose the readily available 

nutrients. The curing stage takes place when materials are stable, and the remaining nutrients are 

further degraded by mesophilic microorganisms (or mesophiles) that are still present. The 

finished compost may be screened again before use as a soil amendment or conditioner during 

the postprocessing stage. 

Preprocessing Stage 

1. The green materials should be first screened to get rid of uncompostable materials, such 

as plastic bags, and shredded to allow a large 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, the tendency of the materials to compact, and the turning 

equipment used 2 . Thus, windrows with leaves and tree trimmings tend to have larger 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 composting begins. Active composting is 

characterized by high temperature, high level of oxygen demand and high evaporation 

rates due to temperature. There are several factors that need to be controlled to optimize 

rapid, efficient microbial decomposition of greenwaste. 

a. Temperature. During the active composting, thermophiles 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 and 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 windrows should be maintained at 131 



degrees Fahrenheit for at least three days for pathogen destruction and to kill weed 

seeds. The California Integrated Waste Management Board (CIWMB) Regulations 

Title 14, Division 7, Chapter 3.1, Section 17868.3 (Pathogen Reduction) requires 

temperatures during active composting to be maintained at 131 degrees 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 condition 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 nitrogen 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 content), the composting process also slows 

down due to lack of adequate nitrogen. Therefore, it is necessary to balance the 

carbon and nitrogen. A carbon to nitrogen (C:N) ratio ranging from 25:1 to 40:1 is 

reasonable for initial conditions, with a recommended C:N ratio of 30:1 for active 

composting 1, 3, 5, 9, 11 . C:N ratio decreases as decomposition 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 recommended for rapid composting. A 

volumetric ratio of one part wood chip: two parts leaves: one part grass is also good. 

1, 8, 10-14 

Table I-1. Commonly Used Raw Compost Materials 

Material 

Bulking Agents 

Characteristic C:N Ratio 

- Wood 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 (NH3) are produced during the anaerobic decomposition of greenwaste. To 



maintain aerobic composting conditions, windrows are turned with a front-end loader 

or a Scarab. The frequency of turning is determined by the windrow size, feedstock 

composition, stage of decomposition and moisture content, and is adjusted so aerobic 

conditions are maintained, not providing too 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 the feedstock materials to become 

slightly acidic (i.e., down to 5.0) during the early stage of composting 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 insensitive to pH within this range. If the pH 

reaches 9, nitrogen is converted to ammonia and becomes unavailable to organisms, 

resulting in a decomposition process 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 yard 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 (which 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 added 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 increases the rate of decomposition by mixing 

materials and exposing new surface areas. The active composting phase should last at 

least 22 days. Completely processing greenwaste with frequent turning may take two to 

four months. Based on the District staff report for Rule 1133.2 9 , 80 percent of VOC and 

50 percent of NH3 emissions are released during the 22-day active composting phase. 

6. Once the greenwaste has been composted, curing 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 metabolized by the microorganisms that are still 

present, and the need for oxygen and the evaporation rates decrease. While the curing 

stage may take another several weeks, it should last at least 40 days during which 20 

percent of VOC and 50 percent of NH3 emissions are released 9 . 



Postprocessing Stage 

7. Compost may be analyzed to ensure the stabilization is complete. Compost also can be 

tested for chemical or pathogen contamination and tested to determine 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 management guide for greenwaste composting. 

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

Condition Possible reason Other clues Remedy 

Windrow fails to heat Materials too dry 

Cannot squeeze water from 

material 

Add water 

Temperature falls 

consistently over several 

days 

Uneven temperatures or 

varying odors in windrow 

Pile does not reheat after 

turning 

Materials too wet 

Not enough nitrogen 

Poor structure 

Cold weather and small pile 

size 

pH excessively low 

Low oxygen 

Low moisture 

Poorly mixed materials 

Uneven airflow 

Materials at different stages 

of maturity 

Composting nearing 

completion 

Low moisture 

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 

Temperature declines gradually 


material 

Visible differences in the pile 

moisture 

Visible differences in the pile 

moisture 

Temperature varies along the 

pile length 

Approaching expected 

composting time period; 

adequate moisture level; 

C:N ratio less than 20:1 


materials 

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 

Turn windrow 

Add water 

Turn or remix 

windrow 

Remix windrow 

None required 

None required 

Add water and remix 



Table I-2. Troubleshooting and Management Guide (continued) 


Pile overheating 

Insufficient aeration for Pile is moist 

Turn pile 

(temperature greater than 

150 ºF) 

heat removal 

Moderate to low moisture Pile feels damp 

Add water 

Extremely high 

temperature (greater than 

170 ºF in pile) 

High temperature or 

odors in curing or storage 

pile 

Ammonia odor coming 

from composting piles 

Odors generated only 

after turning 

Foul odor coming from 

composting piles 

continually 

Pile is too large 

Height great than 8 feet 

Spontaneous combustion Low moisture content; pile 

interior looks or smells charred 

Compost is not stable 

Piles are too large 

High nitrogen level 

High pH 

Slowly available carbon 

source 

Odorous raw materials 

Insufficient aeration; 

anaerobic interior 

Anaerobic conditions 

Materials too wet 

Poor structure 

Pile compacted 

Insufficient aeration 

Anaerobic conditions 

Pile too large 

Airflow uneven or short 

circuiting 

Short active composting period; 

temperature and odor change 

after mixing 

Height greater than 8 feet; 

width greater than 20 feet 

C:N ratio less than 20:1 

pH greater than 8.0 

Large woody particles; C:N 

ratio less than 30:1 

High temperatures 

Falling temperatures 

Low temperature 

High temperature 

Decrease the pile size 

Decrease pile size; 

maintain proper 

moisture content; add 

water to charred 

sections; break down 

pile, combine with 

other piles 

Manage pile for 

temperature and odor 

control; turn piles as 

needed; limit pile 

size 

Decrease pile size 

Add high carbon 

amendments 

Avoid alkaline 

ingredients 

Increase the carbon 

proportion 

Frequent turnings; 

increase porosity; 

add odor-adsorbing 

amendment 

Shorten time interval 

between turnings; 

increase porosity 

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 



Table I-2. Troubleshooting and Management Guide (continued) 


Fly or mosquito problems Flies breeding on compost Flies hover around piles Turn piles every 4 to 

piles 

7 days 

Compost contains clumps 

of materials and large 

particles; texture is not 

uniform 

Summary 

Flies breeding in raw 

materials 

Mosquito breeding in 

stagnant water 

Poor mixing of materials or 

insufficient turning 

Airflow uneven 

Raw materials contain large 

particles and nondegradable 

or slowly 

degradable materials 

Active composting not 

complete 

Wet raw materials stored on 

site more than 4 days 

Standing puddles of water 

Original raw materials 

discernible in compost 

Wet clumps of compost 

Large, often woody, particles in 

compost 

Curing piles heat or develop 

odors 

Handle raw materials 

promptly 

Grade site properly 

Screen compost; 

improve initial 

mixing 

Screen or shred 

compost 

Screen compost; 

grind and/or sort raw 

materials 

Lengthen composting 

time or improve 

composting 

conditions 

Greenwaste composting is defined by an aerobic 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 NH3 and VOCs that play an important role in forming secondary 

particulate matter and ozone in the atmosphere. 



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 the 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 Facility 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 Division 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 Institute and State University 

Virginia Cooperative Extension. 1997. 

14. Canadian Organic Growers. Organic Field Crop Handbook. 2001. 



APPENDIX II – EMISSION CONTROL TECHNOLOGY 

This section summarizes advanced emission control technologies that are associated with 

requirements of PR 1133.3. Advanced emission control technologies are engineered control 

methods that include a covered aerated static pile (ASP) composting system. These systems are 

commercially available and can be deployed by vendors. Brief descriptions of each system are 

given below. Inclusion of these vendors in this report does not imply or serve as an endorsement 

of any vendor or product by the District. 

Negative ASP System with Emission Controls 

One of the covered ASP systems is the AC Composter and CompDog (pipe-less aeration 

system) 1 , a covered negative-pressure ASP with biofilter 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 tube 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 monitoring probes. The probes are linked to a computer to monitor 

temperature and do not have moisture sensors on them. 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 pipe is connected to a blower that produces a 

negative air pressure, pulling air into the pile from the outside through small 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 temperature 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. Figure II-1 shows an enclosed 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, 

the tarp is removed and the pile is turned using a wheeled front-end loader into a new zone. 

SCAQMD II-1 June July 2011


Once the first pile is moved to the second zone, the tarp and probes are placed again. This action 

occurs every two weeks over a six-week period. When the composting process is completed at 

the end of the sixth week, the finished compost may be relocated to a designated area for curing, 

as appropriate, for an additional four to eight weeks. 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 covered positive-pressure ASP using a triple layer 

membrane compost cover. Since this type of technology pushes air into the pile, it does not need 

a biofilter. One kind of this covered, positive-pressure ASP technology 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 Phases. 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 composting 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 takes approximately eight (8) weeks. The compost pad is divided 

into three sections: Phase I (high rate composting), 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 section. 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 available. 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 enclosed system. Stainless steel temperature and oxygen probes are 

installed through the cover into the composting material. The blowers are controlled by a 

Programmable Logic Controller (PLC) to optimize the composting process using readings from 

temperature and oxygen sensors 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 between two polyester layers that selectively 

influence the treatment process. The membrane laminate technology protects the compostable 

material from the penetration of rainwater and 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 during the composting process, suppressing odors and 

other gaseous emissions. These gases are partly dissolved 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 



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

decomposed. 

Figure II-2. GORE® Cover 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 the covered piles to be controlled with a blower 

fan, connected to a ventilated air hose snaking beneath 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 decreased 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 dictate the most suitable 

settings for a specific pile. Figure II-3 presents an example of MOR compost cover system. 



References 

Figure II-3. Covered Positive-pressurized MOR Compost Cover 

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


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. 



APPENDIX III – EMISSION REDUCTIONS AND COST EFFECTIVENESS 

Emission Factors 

Baseline emission factors were developed based on the emissions source tests conducted by the 

SCAQMD, the state and other air districts from 2001 to 2009 for greenwaste composting 

windrows. The following emissions test results were used in developing the baseline emission 

factors. 

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

Test facility Location Season Test Jurisdiction 

samples taken year 

Inland Empire Composting Facility Colton Fall 2001 SCAQMD 

Inland Empire Composting Facility Colton Winter 2001 SCAQMD 

Jepson Prairie Organics (JPO) Vacaville Summer 2005 Yolo-Solano (YS) 

Compost Facility 

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 emissions from stockpiles, static 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 material is placed into piles where it decomposes 

over an extended period of time with no or little mixing. Oxygen supply is passive; warm air 

leaving the pile at the top is replaced by air entering from the outside 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 composting 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 curing phase compost piles. 

Note that there are differences between the Inland 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 conducted on specific days of the composting 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 local data. Using daily 

composting throughput, emission factors were weighted to calculate composite emission factors. 

SCAQMD III-1 June July 2011


Table III-2. Composting Emission Factors 

Site Sampling age of Season samples Throughput VOC Ammonia 

material 

taken (tons/day) (lbs/wet ton) (lbs/wet ton) 

Inland Over the static and Winter 307 1.56 0.26 

Inland windrow phase Fall 350 2.25 0.63 

Modesto Over the active and Fall 103 0.85 Not Available 

Site X curing phase (days Spring 200 6.30 2.34 

JPO not sampled were Summer 163 5.65 0.24 

Zamora interpolated) 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 facilities. 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 about 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 ground, 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 District’s proposed greenwaste composting operations 

emission factors are shown in Table III-3. For 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 reductions and cost effectiveness were calculated using the active 

phase emission factors only, since the proposed mitigation measures are required only for the 

first 15 days of the active phase period of composting. 



Figure III-21. VOC Emissions Profile for Greenwaste Composting. 



Figure III-32. Ammonia Emissions Profile 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 grinding activities, stockpiling of chipped or ground 

greenwaste, and composting of chipped or ground greenwaste. Emissions during chipping and 

grinding have not been quantified 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 hours of receipt, or up to seven days maximum, 

with approval from unless otherwise allowed by the LEA to hold for a longer period of time, 

which is consistent with the Title 14 requirement. Staff determined that there would be no 



emission reductions from stockpiling operations because the proposed holding time requirement 

has already been established in the state regulation. Composting emissions of chipped or ground 

greenwaste at facilities solely subject 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 composting 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 facilities 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 operations 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 emissions per day and 0.38 tons of ammonia emissions per day. 

Table III-4. Greenwaste Composting Baseline Emissions Inventory 

Total Composting emission factor 

Baseline composting emissions 

throughput 

(tons/year) 

(lbs/wet ton) 

VOC Ammonia VOC 

(tons/year) 

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 facilities produce annual VOC 

emissions from windrow composting operations exceeding 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 year from windrow composting operations. 

Emission Reductions 

PR 1133.3 would require mitigation measures, such as finished compost cover and water 

irrigation during the first 15 days of the active phase composting. The SJVAPCD contracted 

with San Diego State University for a study investigating 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. 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. Another greenwaste 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 the 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 composting, finished compost cover was applied after 



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, District 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 seven 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 Control Efficiency for VOC and Ammonia 

Active phase VOC emissions rate (%) Control efficiency 

composting Modesto Zamora JPO Average Mitigation measures Composite - VOC 

First 7 days 

Following 8 days 

61 

24 

59 

24 

89 

4 

70 

17 

53% - compost cover 

24% - watering 

41%* 

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 - NH3 

First 7 days N/A 36 26 31 53% - compost cover 

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 composting throughput begins the pathogen reduction 

process immediately after the initial pile is formed. Composite control efficiency for VOC and 

ammonia was calculated to be 31 and 17 percent, respectively. The site-specific control 

efficiency data were also used in calculating emission reductions that are shown in Table III-6. 

23% ^ 

In summary, the following facts and assumptions were made to calculate 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 active phase of the composting process is 0.46 

lbs/ton of greenwaste throughput; 



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 cumulative emissions during the full composting 

cycle; 

7. The VOC emissions during the following eight days of the active phase period account 

for 17 percent of total cumulative emissions during the full composting cycle; 

8. The ammonia emissions during the first seven 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 emissions 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 percent with water irrigation and 53 percent with 

finished compost cover as for VOC emissions can be applied for ammonia emissions. 

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

cover was not evaluated for ammonia in the original mitigation measures study. However, 

historically, District biofilter emissions test results have shown greater controls in ammonia 

emissions than VOC emissions. Finished compost is used as an element of biofilter media. 

Conservatively, finished compost cover was assumed to have the same 53 percent control for 

ammonia as was shown for VOCs. The 24 percent control with water irrigation was achieved 

with multiple water irrigation. Considering ammonia is a highly water-soluble gas, it was 

conservatively assumed that the water irrigation had the equivalent control efficiency for 

ammonia. 

Staff calculated reductions based on 53 and 24 percent control efficiencies with the proposed 

applications in PR 1133.3. Emission reductions (ER) are calculated by multiplying baseline 

(uncontrolled) emissions by an overall control efficiency using the following equation. 

Uncontrolled emissions are calculated by multiplying 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 requires 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 curing phase of composting are considered to be zero. 

Table III-6 presents that with the implementation 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 June July 2011 

,


Mitigation measures 

(Active phase only) 

Table III-6. Greenwaste Composting Emission Reductions 

Throughput 

(tons/year) 

Number 

of 

facilities 

Baseline emissions 

(tons/day) 

Composite control 

efficiency (%) 

Emission reductions 

(tons/day) 

VOC Ammonia VOC Ammonia VOC Ammonia 


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


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 based on the proposed requirements of the rule. 

Under PR 1133.3, the operator of any greenwaste composting operation would be required to 

hold greenwaste materials no longer than 48 hours of receipt at the facility, unless otherwiseas 

allowed by the LEA to hold for a longer period of time. This requirement is to harmonize the 

holding time requirement of the state regulation, as well as to be consistent with PAR 1133.1, to 

prevent inadvertent decomposition occurring during an extended period of stockpile operation. 

Since the 48 hours removal requirement has already been established in the state regulation, 

there would be no compliance costs 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 involving water irrigation and finished compost cover. PR 1133.3 

requires only one time application of finished compost 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 are assumed to already have turning 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 costs for water irrigation and finished compost 

cover. For the worst case, it was assumed that water is applied five times to the compost pile. 

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

Six inches of finished compost cover to the 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 facility, 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 irrigation is assumed to be $0.29 per ton of 

throughput with the following assumptions; 

a. Water use: 

i. Pile management at 50 percent moisture 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 case day to fill the free air space for 

a 3 inches pile depth corresponds to 19 gallons of water per ton throughput 

iv. Total volume of annual water use for 5 times watering is approximately 37 

million gallons for 17 existing greenwaste composting facilities 

b. Potable water for non-residential/landscape 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 irrigate 100 tons of windrow 

d. Five turning events during the active phase 

e. $10 per hour labor rate for irrigation 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 per 110 feet length of windrow 

b. $180 per hour for equipment and operator 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%. Under PR 1133.3, the piles are to have water applied 

to make the piles “wet” before turning. Based 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 represented 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 affected 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 the operations may very well be adjusting the 

application times to accommodate the rule requirements. For example, watering the piles before 

turning as opposed to after could be employed thereby 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 throughput, annual compliance costs are estimated as 

shown in Table III-7. Annual compliance cost and total annual cost are the costs averaged over 

all 17 affected facilities. Total annual compliance costs range from $700 per facility to $215,800 

per facility with a facility average of $29,000 per year. It should be noted that the compliance 

cost-to-throughput ratio for each affected facility is calculated to be up to $1.15 per ton of 

throughput for adding an initial finished compost cover and watering before each turning (based 

on weighted water source cost of $0.36 per ton 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 Number Annual compliance Proposed rule requirement Total annual 

(tons/year) of 

costs 

costs 

facilities (Avg. $/year) 

(Avg. $/year) 

416,300 17 

$8,400 

$20,600 

Finished compost cover 

Water irrigation 

$29,000 

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 greenwaste 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. 

Throughput 

(tons/year) 

416,300 

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

Mitigation 

measures 

(Active phase only) 

Finished compost cover 

and water combined 

Total annual costs 

(Avg. $/year) 

Average C-E 

for VOC only 

($/ton) 

Average C-E 

for VOC & Ammonia 

($/ton) 

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



APPENDIX IV – PUBLIC COMMENTS AND RESPONSES 

This section summarizes comments received during 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 received, 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 individual 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 environmental impact analysis for the PR 1133.3 include 

consideration of: 1) groundwater 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 facilities already apply water to their 

compost piles to maintain moisture level and additional watering only applies to 

the first three inches of the pile depth before turning. Therefore, the impact of 

watering on the groundwater would be negligible. The finished compost cover 

would only be required one time 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 are 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 further limited by specifying the procedures 

that will be used to verify compliance with this section or by specifying that 

alternative mitigation measures will be based on a test protocol that is approved 

AQMD, CARB “and” EPA. 

Response #3: Staff revised the rule language as recommended. 

Comment #4: PR 1133.1 requires maintaining records on-site for two years. To improve 

enforceability and greater consistency with Title V requirements, EPA 

recommends requiring that operators maintain these records for five years. 

SCAQMD IV-1 June July 2011


Response #4: Staff revised rule language that the prior two year records should be maintained 

on-site and the remaining three year records would be available within one 

week of request (i.e., five years total). 

Comment #5: Please remove or better justify the 40-day limits in the definition of the curing 

phase of composting in PR 1133.3. California, for example, defines curing 

composting only by pathogen reduction, as described in California Code of 

Regulations (CCR) Section 17868.3, and after most of the readily metabolized 

material has been decomposed and stabilized. See CCR, Title 14, Section 

17852(a)(13). 

Response #5: Definitions of the 22-day active composting and 40-day curing have already 

been established in District Rule 1133.2. These limits were supported by 

information found in EPA 503 regulations and other studies found in the 

literature of the Technology Assessment Report for Proposed Rule 1133 (dated 

March 22, 2002). Specifically, the 22- and 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 conflict with the meaning 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 foodwaste (as defined in this section) and 

waste from food material. 

Response #6: The definition of foodwaste has been modified. The sentence 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 including 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 requirement. 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 proposed rule. Rather, 

reference is made to temperature monitoring per CCR, Title 14. 

Comment #9: Please clarify the basis of source testing every two years in lieu of more 

frequent testing that is required 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 every two years to every three years. This would be 

consistent with existing permitting practice. 



Comment #10: Please clarify whether Attachment A of Rule 1133.2 is to be included in the 

State Implementation Plan (SIP). We believe 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 been modified specific to PR 1133.3 and is 

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

Comment #11: Please list the applicable dates of those TMECC test methods for PR 1133.3. 

Please clarify the number of replicate samples needed for these test methods. 

We recommend averaging the results of three samples. 

Response #11: The applicable dates of those TMECC test methods are listed as recommended 

in the revised rule language. Staff added the requirement of triplicate samples 

needed for the TMECC test methods. 

Comment #12: Please consider adding size thresholds 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 addressed here that are very large. 

Response #12: Staff added conditions to the exemption for the community composting – 

provided that the operation is not subject to the Local Enforcement Agency 

Notification or Permit regulations pursuant 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 sources pursuant to paragraph (f)(3). 

Please clarify whether there are additional instances that moisture content 

measurements are needed. Please clarify the frequency and time during the 

composting cycle when composting measurements will be taken. 

Response #13: Moisture content measurement requirements are also presented as a monitoring 

parameter to exempt a biomass power generation facility or a facility processing 

material as a biomass fuel for a biomass power generation facility from the 48 

hours holding time. The alternative parameter that the material temperature is 

below 122 degrees Fahrenheit is also provided. Composting monitoring 

measurements are not taken into consideration in PAR 1133.1. When moisture 

content measurements are taken, at least 10 samples of chipped and ground 

greenwaste shall be taken from various locations of the pile on a given day. 

Comment #14: Please indicate the rule version, 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 Method for Direct Moisture Content 

Measurement of Wood and Wood-Base Materials) is the method that is used as 

the reference for calibrating and standardizing a hand-held 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 the two methods differ in their results, 

D4442 takes precedence. 



CARB Comments 

Comment #1: Table IV-2 of Appendix IV to the Preliminary Draft Staff Report mentioned that 

the average emission factors were determined 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 the 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 emission 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 factor. We recommend more calculations 

be added to improve clarity. 

Response #2: The reader is referred 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 logic behind using a 

statewide average emission factor rather than the only data from the South 

Coast region. 

Response #3: The emission factor from the Inland Empire Composting Facility does not 

represent typical greenwaste composting operations currently being conducted 

in the South Coast region. Other air districts also did not consider using this 

emission factor because they thought that 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 currently available set of data that are 

considered to represent greenwaste composting operations in the South Coast 

District. Therefore, the weighted emission factor considers these four tests, 

along with the Inland Empire results. 



CalRecycle Comments 

Comment #1: PAR 1133.1(d)(1)(A): 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 acceptable material for 

landfill alternative cover or erosion control. Therefore, please delete this 

section or clarify that the chip or grind facility must have a transfer station 

permit in order to receive foodwaste. 

Response #1: The rule language has been revised such that foodwaste cannot be accepted at 

chipping and grinding facilities, unless otherwise allowed by the LEA. 

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

delete. 

Response #2: Staff deleted this subparagraph as suggested. 

Comment #3: PAR 1133.1(d)(3)(D): Records of rainy 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 within 48 hours of receipt or up to seven 

days maximum, with approval from . However, as written in the revised 

proposed rule, the operator may hold the material for a longer period of time, if 


Comment #4: PAR 1133.1(d)(3)(E): Records of moisture content should only pertain to 

biomass power generation facility stockpiles, as those facilities 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 exemption for moisture content in existing 

state regulations. For CDI facilities, the materials must remain under 122 

degrees Fahrenheit at all times. 

Response #4: An exclusion from material holding 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 conditions should not apply to non-compost 

facilities, as Title 14 Division 7 Chapter 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 necessary for landfill operations. 

Comment #6: PAR 1133.1(e): Moisture content measurement section should only apply to 

biomass power generation facility stockpiles. 




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

would make sense to use the same standard. Weight is straightforward to 

measure and less subjective. 

Response #7: Manure measured by volume has been 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 embedded in it, could provide sufficient aeration to avoid 

anaerobic conditions. Please consider allowing passively aerated static piles 

when covered a pseudo-biofilter and pursuant to the approval of the APCO. 

Response #8: Staff revised the proposed rule language such that a minimum requirement for 

composting system design is no longer included. 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 considered ideal, it is difficult to achieve in 

practice, particularly in actively decomposing 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 costs 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 applied. We prefer 

you make the oxygen testing for informational 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 this requirement from the proposed rule. 

Comment #10: Please make an exception for operators who apply water during turning using a 

turner which is equipped with water 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-applications of the compost cap are impractical. Regulation does 

not mandate Process to Further Reduce Pathogens (PFRP) occur during the first 

22 days, but many operators prefer to document their pathogen reduction early 

in the process, because the materials may not get hot enough later on. 

Applications of a thick blanket of material 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 the next five turns, if operator has 

begun pathogen reduction. If the operator 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 

3) When pathogen reduction is finished, the operator may apply one more 

cap of unscreened finished materials for additional clean air benefits. 

Response #11: Staff is proposing to place the finished compost cover on the top of initial pile 

for the first seven days of the active phase composting, during which the pile is 

to not be turned, and watering afterward to the surface of the pile within three 

six hours before the initial and subsequent turnings during the remaining active 

phase period of composting. Please refer to subparagraph (d)(2)(B) of the 

revised PR 1133.3. 

Comment #12: Please add a requirement which suspends capping during the ozone season 

(from May 1 to October 1). The capping 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 biofilter costs around $100,000 per occurrence; a twoyear 

frequency is not cost effective for an engineered system. Two reasonable 

methods for ensuring the efficacy of an installed 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 have cost as much as the amounts stated, most 

of the tests conducted that cost that much were research oriented tests that 

involved several operating scenarios, developing site-specific testing methods 

and techniques, or were unique and difficult 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 representative 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. 



(a) Purpose 

Public Comments on PAR 1133.1 

Comment #1: The primary goal of PAR 1133.1 should 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 restrictions, and other 

practices in conflict with PR 1133.3 and other regulations. 

Response #1: At landfills located in the South Coast jurisdiction, 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 the undetermined term “finished compost.” 

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

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

need to be consistent with PR 1133.3 and Title 14. 

Response #2: Staff made some of the definitions 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 meaning 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 pile” from the rule and refers to composting 

generically. 


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, unless otherwise allowed by the LEA. 

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

PR 1133.3. 

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



Comment #3: Holding time requirement differs based 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 different 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, unless otherwise allowed bywith 

approval from the LEA. 

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

“utilized on site” and not “stockpiled.” If this rule is to reduce VOC emissions, 

the District should regulate how the material is handled 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 acceptable 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 grind 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 harmonized 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 maximum, unless otherwise allowed bywith 

approval from the LEA to hold for a longer period of time. 

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

understanding. 

Response #7: Staff has specified the holding time 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. Under Title 14, static pile composting would 

require a composting permit. Chipping and grinding operations are required to 

keep materials below 122 degrees Fahrenheit. Any green material achieving 

this temperature at a facility is considered active composting and thus the 

facility would be required to obtain a composting facility permit. 

Response #8: Specification of stockpiling and static pile requirements were removed from the 

proposed rule provisions. This revised proposed rule essentially applies to 

chipping and grinding activities to produce materials other than active or 

finished compost by means of any type of composting methods. 



Comment #9: Static pile is a legitimate composting method, as decomposition of organic 

materials in the piles can reach the temperature of composting allowed for under 

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 requirement 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 pile of freshly ground material will assuredly 

cause the pile temperature to rise above 122 degrees Fahrenheit as the compost 

will inoculate the new materials with additional microbes. 

Response #10: Adding finished compost to a freshly ground green material is no longer 

required under PAR 1133.1. Mitigation measure requirements were deleted. 

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


Comment #12: The finished compost cover on chipped 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 requirement was deleted and is no longer proposed 

in the revised PAR 1133.1. Stockpiling cured compost on-site is out of scope 

for PAR 1133.1 and PR 1133.3 does not limit 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 greenwaste is brought to the landfill: 

o Will 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 chipping 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 manufactured by other entities. 

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

do not take moisture content measurements. 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 information 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. 

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 perform 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 Responses #3 and #5 of the CalRecycle Comments 

section. 

Moisture Content Measurement 

Comment #15: Instead of ASTM tests of moisture content, please allow 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 standard test method for standardizing and 

calibrating hand-held moisture meter. A hand-held moisture meter should be 

calibrated by the method D4442. Therefore, 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 current 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 biomass fuel is maintained at less than 30 

percent to avoid decomposition. 

Miscellaneous 

Comment #17: What if the chipping/grinding operation is conducted 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 chipping/grinding equipment on-site, and are therefore 

responsible for handling of the chipped and/or ground material. The only 

exception is if the equipment meets the definition of portable equipment, that is 

equipment with a manufacturer’s rating of 170 brake hp or less, which is 

exempt under the rule. 



General Comments 

Public Comments on PR 1133.3 

Comment #1: Explain the physical and time boundaries that were assumed when determining 

the centralized organics processing adverse impacts to the atmosphere, 

including all the transformations and exchanges that take place in the soil, 

terrestrial vegetation, and atmosphere over the life of the materials. 

Response #1: Relative to the rule proposal, emissions baseline 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 impact of this regulation on the carbon cycle. One benefit of 

composting is that it enriches the soil with carbon, increase 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 regulation. Although composting is an 

environmentally favorable treatment method of recycling organic waste, it is 

also true that composting operations emit VOCs and ammonia that partake in 

the formation of ozone and fine particulates. 

Comment #3: The District should promote alternative 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 existing exemptions for backyard composting. 

Comment #4: We expect to see, in the socio-economic analysis, a comprehensive whole 

systems analysis of costs and benefits, which includes economic assessments of 

soil amendment, fertilizer, energy production and landfill uses of organics, 

using competitive tipping fees, competitive prices of products, and all current 

and proposed rule requirements affecting: processing, operational, analytical 

testing, storage and marketing costs. 

Response #4: The suggested micro systemic analysis 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 existing 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 facilities and the entire 

economy in the four-county region. 

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

material. 





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

Response #1: Staff disagrees. Greenwaste means organic waste material generated from 

gardening, agriculture, or landscaping activities. 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 greenwaste for the purpose of greenwaste 

composting because it is difficult to completely 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 percent 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. 


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 windrow composters to continue with their 

respective techniques as there are few enough of both in the South Coast. 

Response #1: The reader is referred to Response #2 8 of the CalRecycle Comments section. 

Comment #2: There is no basis for the exclusion of “passive pile” composting (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 composting should be 

allowed under PR 1133.3. 

Response #2: The reader is referred to Response #2 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 facilities, 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 

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 money. In addition, having a 5% oxygen 

level has not been shown to reduce emissions 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 should be perceived as mitigation and the basis 

of reduction should be from non-composted 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 such 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 chippers 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 “level playing field” for 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 practice, potentially leading to anaerobic 

conditions. Additionally, conformance with Water Board regulations may 

preclude or limit over application of water at compost sites. 

Response #8: Staff added an exception for water application relative to a rain event in which 

the aim is to ensure wet material before turning without indiscreminant 

indiscriminate water application. 



Comment #9: We support the surface water application as mitigation, but are concerned that 

the basis for the threshold being applied (that is, based on throughput) is 

inappropriate. Please explain. 

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 throughout the active phase process, the District 

Rule will necessitate the multiple handling 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 the finished compost cover is required to apply 

to initial active piles only for the first seven days of the active phase, and 

watering is required thereafter for the remaining 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 emissions to control after the first two weeks, 

there should be no further reason to cap the pile, and this will also lead the 

composters to believe that they are not being put at an economic disadvantage 

to the shredders. 


Comment #12: Records already include pile moisture content for water. By adding 

“applications of water” makes the recordkeeping redundant. 

Response #12: Revised rule language no longer requires 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 forced 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 pollution control device. However, staff 

decided to pursue a modified threshold that combines the percent limit of 

foodwaste with a facility-wide annual throughput. 

Comment #14: It is not clear why the aerated static pile composting process is required for 10% 

or more of foodwaste in the system. It would be helpful 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 biodegradable and volatile 

material than greenwaste, composting 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 

without foodwaste. In addition to VOC emissions, decomposing putrescible 

foodwaste can cause odor problems. 

Staff carefully investigated the current foodwaste composting operations and 

decided to augment the 10 percent, by weight, foodwaste limit with actual 

annual foodwaste threshold. Therefore, in the revised rule language, an 

emission control technology meeting 80 percent control would be required for 

any active phase pile containing foodwaste of 10 percent or more, if an operator 

intends to (or does) process greater than 5,000 tons per year of foodwaste 

throughput (source-separated or mixed). Up to this throughput threshold, there 

is no percent restriction of containing foodwaste in the greenwaste composting 

operations. 

Comment #15: Compost emission factors are operation specific, and 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 emissions 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 operations in the South Coast District. 

Comment #16: The mandated emission factor is set so high that virtually 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/day threshold as the 

maximum mitigated VOC emissions, 80% mitigation efficiency of the required 

forced aeration system, and the mandated uncontrolled baseline emission factor 

of 4.67 lbs/ton, virtually no greenwaste composting facility will be able to have 

a throughput of greater than 60 tons per day without preparing an 

Environmental Impact Report under CEQA. 

Response #16: The baseline emission factor of 4.67 lbs/ton for VOC is determined from 

emissions test data that are currently available from respective greenwaste 

composting operations that are representative of local operations. For the 

purpose of this rule effort, an emission factor of 4.25 lbs VOC/ton throughput 

for the active phase only of composting would be considered. It should be 

noted that this factor is for uncontrolled emissions in the absence of site-specific 

source tests. Source testing under the rule relative to the emission control 

device will provide a more site-specific 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 operations. Since these operations have the 

potential to emit lower VOC and ammonia 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. 

Recent source tests conducted for biosolids composting operations showed 

much higher control efficiencies than the required 80%. 

Comment #18: The requirement of an 80% overall system control efficiency for VOC and 

ammonia seems high given the lack of operational 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 performance of ASP and biofilter system for green 

material with food scraps is available. A commercial application 1 achieved 

90% reduction in VOC emissions (as total hydrocarbon) for ASP and biofilter 

system composting 25% food scrap and 75% greenwaste. A different 

commercial application 2 of a forced aeration system using a fabric membrane 

cover has multiple data sets from demonstration 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 composting is on the 

rise, staff expects additional emissions data to be collected on the performance 

of an emission control system for foodwaste windrow mixed with greenwaste in 

the future. 

Source Testing 

Comment #19: The current methodology for source testing, flux chamber testing, is very 

expensive and not warranted for aerated static 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 cost 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 start of operation. If at this time, or at 

any other time that a portable flux chamber is given, the TNMNEHC is over 

100 ppmv, a source test will be required. The portable flux chamber test can be 

required if nuisance complaints demonstrate obvious neglect or negligence by 

not adhering to best management practices. 

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

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

1 ECS, 2011. Comparison of Air Emissions from the ECS AC Composter 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. 



Response #20: The flux chamber test method, modified by the District, has been used to 

determine emissions from compost piles and biofilter controls. A new source 

test method is not required for compost operations, but staff will work with the 

industry if there are suggestions for new methods in the future. 


Comment #1: “Municipal composting” or “centralized composting” should be exempted. We 

believe that the benefit of centralized composting to soil, water, and air are 

much more preferable to the alternatives. Our mulch give-away program 

recycles organic residuals (25% of the City green residuals and 75% by 

contractors) through giveaways to residents 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 composting or centralized composting collects curbside and noncurbside 

greenwaste which are main components of greenwaste composting 

feedstock. Although the compost product is given away to the local 

communities for free, the magnitude of the centralized composting would 

typically be large. Thus, staff did not add an exemption for centralized 

composting to PR 1133.3. 

Comment #2: The type of community composting needs 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 solids anaerobic digestion (HSAD) would be 

classified as a pre-processing step for composting facilities. The organic 

material waste is digested in an enclosed unit. The resulting material (a 

combination of green and food) can be transferred to a compost 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, anaerobic digestion (AD) is not being 

considered as an option of composting organic materials. Considering growing 

interest to the AD system, however, staff may examine the AD system as a preprocessing 

technology for composting processes. 



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 installation. 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 recovery 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 available in all places, and many composters may be 

reluctant to use it because it generally contains higher levels of salt. Salt build 

up is a concern, particularly in foodwaste and manure composting, but also with 

greenwaste. Furthermore, once compost 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, some facilities use all 

potable water and others use all reclaimed or canal water. Salt content has not 

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

Comment #3: CalRecycle recently completed emissions research using “overs” (by-product of 

finished compost screening) as a pseudo-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 compost” 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 proposed 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 depth of piles are wet. Staff expects excess 

moisture is also evaporated while turning 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 compost 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 application and amount of materials and labor 

needed to apply it. 

Response #5: 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. 

Comment #6: The highest costs to apply the cover involve the lost sales of materials used for 

the compost cover and the potential loss 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 apply a compost cover. The amount of 

increased loader activity – in addition to other equipment to handle the compost 

cover application materials – will produce 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 finished 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 completed in 2006 by the CIWMB, the use of 

two compost inoculants reduced VOC emissions 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 mixed 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 measure in your rule, and to allow additive 

manufacturers to submit research demonstrating 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 misinterpreted, and Table 1 is misleading. The most 

recent CIWMB survey of the compost and mulch infrastructure statewide 

estimates about 9.3 million tons of compostable materials are handled statewide. 

Significant portions of these materials are handled in the Central Valley and in 

the Bay Area. 17 million tons in the four-county SCAQMD area is not 

plausible. We believe the District has the data, through Rule 1133, to formulate 

a more reasonable estimate. 

Response #8: Staff agrees that the initial estimated chipping and grinding throughput needs 

more work and attempted to update the throughput number. Furthermore, staff 

requested industry stakeholders and CalRecycle assistance to provide countylevel 

aggregated chipping and grinding throughput data. Although CalRecycle 

approved sharing county-specific data, confidentiality concerns prevented 



transmittal of the information. Staff will continue to work to refine this 

information. 

Comment #9: The Preliminary Draft Staff Report fails to adequately analyzed the importance 

of the chip and grind process as a first step in quantifying air pollutants and 

reducing emissions during the initial first 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 staff 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 having 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 stakeholders to discuss 

the above-mentioned issues. With input from 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 could continue to be exempted. 

Response #10: The operator of any greenwaste chipping and grinding would be subject to PAR 

1133.1. If chipping and grinding takes place at a composting facility or colocated 

landfill or material recovery facility, the operator would be subject to 

PAR 1133.1, provided that the chipped materials are used for purposes other 

than composting. Woodwaste chipping and 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 as 

ADC 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 numbers of greenwaste composting should 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 composting operators who participated 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 material have peaks immediately after 



grinding, trailing off over time. It is unfair putting the bulk of the compliance 

burden on greenwaste composters. 

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 48 hourslimited removal requirement intends to prevent 

inadvertent decomposition of green material during stockpiling that may result 

in VOC peaks after chipping. PR 1133.3 would require the same similar 

holding time, unless otherwiseas allowed by the LEA to hold for a longer period 

of time, and finished compost cover and water application to reduce emissions 

for the first 15 days 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 sales 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 could not afford to stay in business 

adding $5.30 per ton to product cost, based on the $53,000 annual cost. 

Response #14: The compliance costs and cost effectiveness 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 would 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 Modesto 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 first 22 days. Normal compost 

windrow operations do five turnings in the first 15 days. Therefore, one would 

expect five cover applications. Using 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 life 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 provided. With only one time application of 

compost cover, $0.79 per ton is the revised calculated cost (as compared to 

$1.15 per ton of throughput for adding an initial compost 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 loader to apply finished compost cover 

on the initial pile for that cycle. 

Comment #16: Using an average diesel consumption rate of five gallons per hour per truck or 

machine, our Bakersfield exercise indicates it will take one gallon of diesel fuel 

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 using 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 the 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 and grinding rule) is tightening 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 chipping and grinding industry sector. 

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

information about the establishment of 5% oxygen concentration is important to 

the emission rates. The accuracy of annual composting throughput is also 

doubtful. 

Response #18: Appendix I of the Preliminary Draft 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 confusion, staff has removed the 2007 survey 

results in the Draft Staff Report. 

Miscellaneous 

Comment #19: It would be helpful if copies of all comments 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 assessment documents. Those comments are 

public information and available on request. 



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 PAR 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 holding requirements of the existing Rule 1133.1 

and thus would not relax the 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 foodwaste, 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 material 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 that is allowed to chip foodwaste 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 staff report should include the expected 

emission reductions based on the latest proposed version of the rule. 

Response #3: The expected emission reductions with 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. Finished 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 describe 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 that the term “finished compost” includes 

unscreened finished compost which still includes oversized materials that will 



be screened out in final processing. Adding a new definition of “overs” is also 

recommended. 

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): The 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 large 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 provision in Title 14 that would prohibit the 

LEA from allowing an operator to hold materials up to 7 days “provided that the 

materials are not chipped or ground.” We believe that clause can be removed 

without changing the intent of the section. 

Response #4: That particular clause was removed. To effectively harmonize with Title 14, 

paragraph (d)(2) was modified to “… remove from the site within 48 hours of 

receipt, except observance of official federal and state holidays, or up to seven 

days maximum, unless otherwise allowed bywith approval from the Local 

Enforcement Agency to hold materials for a longer period of time.” 

Comment #5: PAR 1133.1 (d)(3): The 24 hour holding time proposed to a biomass power 

generation facility might cause biomass plant operators to stop accepting 

greenwaste completely, further reducing markets for these materials. Biomass 

plants are currently exempt from Title 14 feedstock holding 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 Construction, Demolition, and Inert (CDI) 

facilities primarily handle woodwaste, some do handle greenwaste. This section 

appears to open a loophole in the rule. In the interests of a level playing field, 

you may wish to require these facilities to handle greenwaste the same as other 

chip and grind facilities. You may also wish to expand the definition of 

woodwaste, per our Comment #3 of this section. 

Response #6: Paragraph (d)(4) was completely removed 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 foodwaste 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 believe your intent is to limit this provision to 

curbside materials only. Please strike the word “curbside” from the first line. 

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 future 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 reference to direct respirometry really a 

reference to the Solvita test? Since Solvita is already referenced, why change 

now? 

Response #9: This definition of “curing phase” has already been established in the District’s 

earlier Rule 1133.2 (co-composting 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 blended into the compost pile, overs reduce 

bulk density and increase penetration of air 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 allowing 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 allow 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 source 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 entities such as the Climate Action Reserve, which 

requires foodwaste composters to actually 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 requirements with regard to foodwaste composting 

operations. The definition of “foodwaste” has been modified to address nonfood 

materials, and a threshold of annual foodwaste throughput on a facility 

basis is proposed. 

Some greenwaste composting facilities in the South Coast 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 



Applicability 

windrow recipes without the need of an add-on emission control device. There 

are only a few facilities handling this food material in the South Coast, but 

significant interest increases on this activity. Existing composting facilities use 

foodwaste recipes of 1 part foodwaste to 2 or 4 parts greenwaste. Therefore, 

staff has set a new threshold of 5,000 tons per year of foodwaste throughput, 

above which an emission control device meeting at least 80% control efficiency 

for VOC and ammonia would be required for active phase piles or windrows 

containing foodwaste of 10 percent or more, by weight. By this revision, the 

rule proposes that up to 5,000 tons per year of foodwaste throughput, either on a 

source-separated or mixed basis, be decomposed without an add-on control 

device. 

Public Comments 

Comment #1: Please clarify applicability of PAR 1133.1 to chipping and grinding activities at 

multi-operation facilities that handle multiple incoming material streams with 

separate operating areas for chip and ship and composting operations within the 

same facility. 

Response #1: Staff clarified applicability of PAR 1133.1 to “chipping and grinding 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 grinding activities as part of composting 

operations to produce active or finished compost within the same facility would 

be subject to the provision 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 utilization of materials in PAR 1133.1(d)(3). The new 

utilization time limits may cause power plants to delay acceptance of materials 

from greenwaste facilities, causing a backlog that would shut down operations. 

Response #2: The reader is referred to Response #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 pile basis. By changing the definition 

to a “per facility” basis allows greater flexibility in absorbing fluctuating input 

streams and lessens the need for stockpiling that will lower emissions. We feel 

that the “per pile” term should be changed to “per facility” in the definition of 

greenwaste composting and the word “waste” should be taken out of all the rule 

language altogether. 

Response #3: The definition of greenwaste composting 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 would 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 defined as co-composting and thus the 

operator would need to meet the requirements of Rule 1133.2. 

Comment #4: Residuals derived from food production 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 portion (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 determined for feedstock coming into the 

entire facility, not just one pile or windrow. 

Response #4: Staff re-defined the term “foodwaste” to be “any pre- or post-consumer food 

scraps collected from the food service industry, grocery stores, or residential 

food scrap collection. Any non-food material that is not separated from food 

scraps is considered foodwaste for the purpose of calculating throughput, which 

includes both compostable and non-compostable waste.” The proposed 

threshold that would require 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 throughput calculation may exclude any non-putrescible materials, noncompostable 

contaminants, and greenwaste that are separated before or after 

composting and shipped off-site for disposal, provided they are quantified 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 greenwaste than food. 

Response #5: As it pertains to chipping and grinding operations, staff does not feel that any 

modification is needed to this definition as the suggestion would require 

separation and characterization of the material which would be unnecessarily 

burdensome. 

Comment #6: Under PAR 1133.1, so-called “greenwaste” is not entirely composted of “leafy 

green” material, the putrescible portion, and the primary VOC producing 

component. For this reason, for the purpose of this rule, green material should 

be specifically defined as the VOC-producing portion of those materials as per 

Title 14. 

Response #6: Staff disagrees. The definition of greenwaste has been established in earlier 

District’s rules and modifying this definition could cause confusion to the 

readers. The large woody materials of greenwaste exceeding 2 inches in 

diameter are now considered woodwaste 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 degrading “bulking agent” to more putrescible 



materials. Alternatively, it is used for “wood chips” or sent to biomass burn 

facilities for fuel. It is recommended that woody material portion of green 

material is considered wood material. 


Comment #8: Composting and compost are already defined in other regulations as time and 

temperature for pathogen reduction. It is recommended that the rule defines 

“active compost” as in Title 14, and includes “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 definition 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 within 24 hours of receipt. It appears 

that the rule considers a landfill application 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 manner. Attempting to operate with 24 

hours or less of inventory is not feasible or practiced anywhere in the biomass 

industry. In addition, the definition of “greenwaste” 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 from the rule, and the same 48 hours or up to 

seven days maximum removal requirement would be applied to all facilities, 

unless otherwise allowed bywith approval from the LEA to hold for a longer 

period of time. Staff also proposes an exemption for a biomass power 

generation facility or a facility processing material as a biomass fuel for a 

biomass power generation facility from the requirement of material removal 

within 48 hours of receiptthe allotted times, provided that the material 


content is less 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 revised to allow greater storage time for woody 

materials. 

Response #10: The reader is referred to Response #6 of the CalRecycle Comment section under 

the May 10 th Working Group Comments. 

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. 

Foodwaste Limit 

Comment #13: While I understand foodwaste can be a big contributor to VOCs, it is important 

to understand the foodwaste collection programs that are currently in place in 

various municipalities and institutions. 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 processing is required to 

remove contaminants from compost. In most cases, it is rare to receive clean 

pure foodwaste. Depending on the source (either pre- or post-consumer 

foodwaste), the percentage of non-food packaging can vary. A flat 10% 

maximum by weight is not conducive to the much needed foodwaste programs 

currently in effect. 


Emissions Control and Alternative 

Comment #14: Forced aeration systems and windrow composting are two very different forms 

of composting and will require specifically defined language for each. While 

there are many common requirements, there 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 required. However, the rule would still 

require an emission control device meeting 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 allow 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 technologies to achieve the 

overall system control efficiency of at least 80%. For example, Rule 1133.2 

provides a similar condition without specifying 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-biofilter) could also be 

utilized to achieve the desired control efficiency. 

Response #15: The language has been revised to reflect this suggestion. 

Comment #16: PR 1133.3 would require 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 emission control methods by greenwaste 

composting operators. This will involve three levels of time-consuming 

government review. It is our opinion that the Executive Officer (EO) of the 

AQMD is sufficiently qualified to consider and approve alternative BMPs and 



alternative emission control methods. Therefore, it is our recommendation that 

the EO of the AQMD be the sole authority in the consideration and approval of 

alternative BMPs for emission reduction and alternative emission control 

methods proposed by greenwaste composting operators. 

Response #16: The reader is referred to Response #3 of the US EPA Comments section under 

the February 23 rd Public Workshop Comments. As the rule will be submitted to 

CARB and US EPA as a part of SIP, approval 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 Control Technology (BACT) for windrow 

composting vs. aerated static pile (ASP) composting for food material. 

Additionally, the percentage targets for BACT are not clearly defined. 

Response #17: Windrow composting does not require a permit, with or without food. Finished 

compost cover is seen more as a BMP as opposed to a control technology, and 

thus does not require a permit nor trigger BACT. Depending on the 

circumstances, new and existing composting facilities modifying their operation 

may also be subject to New Source Review requirements of Regulation XIII, 

including BACT and offsets. ASP composting with appropriate emission 

control devices 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 causes an increase in emissions. Even if the modification would 

result in an increase in emissions, the facility could take advantage of the small 

business exemption if its total emissions remain under 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 

source’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 exemption in Rule 1304(c)(4), provided there is no increase in 

maximum rating as established in the facility’s LEA permit.New facilities 

required to obtain a permit will be subject to New Source Review including 

BACT requirements. This being the case, ASP composting with appropriate 

emission control devices may be considered BACT. If the post-control VOC 

emissions exceed 22 lbs per day at a facility, offsets would be required. This is 

part of the existing permit system. Existing facilities that are currently doing 

windrow composting and that modify to ASP composting solely to comply with 



this new rule would likely meet BACT and not require offsets, provided that 

they operate at the current facility throughput. 

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 vehicles 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 emissions. If a pile is aerated, the 

mechanical aeration system and its associated emission control device would 

require a separate permit for each. 

Exemptions 

Comment #19: PAR 1133.1(f)(3) should apply to all greenwaste, instead of curbside 

greenwaste as drafted. 


Comment #20: As waste conversion technologies rapidly advance, greenwaste by itself or in 

combination with other organic materials may be composted at landfill sites via 

anaerobic processes in the near future. 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 applied to greenwaste composting on its own (i.e., 

voluntarily by the facility operator), the 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 sure that we set a new precedent of socio-economic analysis for 

our industry, which is fundamentally based on the new sustainable economiesof-scope 

as applied to renewable carbon 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 industry is unique, and strategically positioned, 

compared to any other industry, in helping society move to a sustainable, 

renewable carbon society. Since carbon is central to all life and economics, this 

industry is core to the emerging sustainable economy. For these reasons, the 



compost industry should be given new, and unique, analysis considerations. We 

suggest the District staff work with the 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. Would this not impact their viability? 

Response #23: The cost, which is driven by the cost of the water application BMP, is a worst 

case scenario. The facility has informed staff that this element of the rule is 

workable and has indicated that total water use may not be that high as the 

increased water use will be minimized to the extent feasible by altering the 

water application timing. 



Written comments were submitted by: 

Andrew Steckel, US EPA Region IX (2) 

Alex Krichevsky, Air Resources Board (ARB) 

Howard Levenson, Department of Resources Recycling 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 Waste Management Department (2) 

Linda Novick, Harvest Power 

David Rothbart, Los Angeles County Sanitation Districts (2) 

Kevin Barnes, City of Bakersfield Solid Waste Division (2) 

David Tieu, Orange County Waste and Recycling 

Chuck Tobin, Burrtec Waste Industries 

Matt Cotton, Integrated Waste Management Consulting, LLC and on behalf of: 

Agromin; 

Aguinaga Green; 

Alameda County Waste Management Authority 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 Management 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. 



Socioeconomic Assessment for 

Proposed Amended Rule 1133.1—Chipping and Grinding Activities—and 

Proposed Rule 1133.3—Emission Reductions from Greenwaste Composting 

Operations 

July 2011 


Planning, Rule Development & Area Sources 



Planning, Rule Development & Area Sources 




Jill Whynot 

ATTACHMENT I 

Author: Greg Hunter, Ph.D., Air Quality Specialist 

Reviewed By: Sue Lieu, Program Supervisor 

Tracy A. Goss, P.E., Program Supervisor 

Veera Tyagi, Deputy District Counsel 

Jong Hoon Lee, Ph.D., Air Quality Specialist


GOVERNING BOARD 

Chairman: WILLIAM A. BURKE, Ed.D. 



Mayor, City of Chino 

Cities of San Bernardino County Representative 

MEMBERS: 








Mayor Pro Tem, South Pasadena 








Mayor, City of Riverside 


JOSEPH K. LYOU, PH.D. 

Governor's Appointee 




SHAWN NELSON 



JAN PERRY 

Councilmember, 9 th District 

City of Los Angeles Representative 






PAR 1133.1 and PR 1133.3 Socioeconomic Report 

EXECUTIVE SUMMARY 

A socioeconomic analysis was conducted to assess the impacts of Proposed Amended Rule 

(PAR) 1133.1–Chipping and Grinding Activities & Proposed Rule (PR) 1133.3—Emission 

Reductions from Greenwaste Composting Operations. A summary of the analysis and findings 

is presented below. 

Elements of Proposed Rule 

and Proposed Amendments 

Affected Facilities and 

Industries 

Assumptions of Analysis 

Proposed Amended Rule (PAR) 1133.1 harmonizes 

AQMD’s requirements for chipping and grinding operations 

with the Code of California Regulations Title 14 Division 7 

Chapter 3.1. 

Proposed Rule (PR) 1133.3 would require greenwaste 

composting operations to limit greenwaste and foodwaste 

compost feedstock holding times to less than 48 hours from 

the date of receipt, unless otherwise allowed by or up to 

seven days maximum with approval from the local 

enforcement agency. PR 1133.3 would also require 

greenwaste composting operations with up to 20 percent 

manure, by volume, or processing up to 5,000 tons of 

foodwaste, by weight, to cover each newly formed compost 

pile with finished compost and apply water prior to pile 

turning. Greenwaste composting operations processing 

greater than 5,000 tons, by weight, and compost that 

includes more than 10 percent foodwaste, would be required 

to reduce VOC and ammonia emissions by an overall 

control efficiency of at least 80 percent. 

PAR 1133.1 is not expected to affect any facilities in the 

AQMD. 

PR 1133.3 would affect facilities in the chemical 

manufacturing and waste management sector of the South 

Coast’s regional economy. Of the 17 affected facilities, 

approximately 80 percent are in the chemical manufacturing 

sector. Affected facilities are concentrated in the fertilizer 

(mixing only) manufacturing (North American Industry 

Classification System [NAICS] 325314) and materials 

recovery facilities (NAICS 562920) industries. Facilities 

processing greenwaste in the District range from less than 

1,000 tons of throughput per year to 200,000 tons per year. 

No existing facilities currently process more than 5,000 tons 

of foodwaste per year. As a result, no facility would be 

required to install a forced aeration, or other similar, 

emissions control device. It is also assumed that 17 facilities 

would modify their best management practices to meet the 

proposed rule requirements. These facilities would cover 

SCAQMD i July 2011


Assumptions of Analysis 

(continued) 

Compliance Costs 

newly-formed compost piles with finished compost, apply 

water to compost piles prior to turning, and perform 

additional recordkeeping. As such, these facilities would 

incur additional costs of water usage, front-loader wear and 

tear, diesel fuel, and labor associated with these activities. 

PR 1133.3 provisions requiring a finished compost cover for 

newly formed compost piles, the application of water prior 

to compost pile turning, and recordkeeping are expected to 

generate total annual compliance costs of approximately 

$31,000 per facility. The annual compliance costs per 

facility depend on facility throughput. The range of annual 

compliance costs is from approximately $2,600 (< 1,000 

tons) to $240,000 (200,000 tons). 

The average annual total cost of Proposed Amended Rule 

(PAR) 1133.1 is assumed to be negligible because the 

proposed amendments align AQMD’s requirements for 

chipping and grinding operations with existing requirements 

in the Code of California Regulations. 

The average annual cost of PR 1133.3 is projected to be 

$0.53 million from 2011 to 2025, of which the costs of 

covering newly formed piles with finished compost, 

watering piles prior to turning, and recordkeeping are, 

respectively, $0.34 million (63 percent), $0.16 million (31 

percent), and $0.03 million (6 percent). 

The chemical manufacturing industry would incur 94 

percent of the cost and the rest would be incurred by the 

waste management and remediation services industry. 

Employment Impacts Overall, 4 jobs, which is 0.00004 percent of total jobs in the 

four county region, could be forgone annually, on average, 

between 2011 and 2025. Job impacts are within the noise 

uncertaintylevel of the REMI economic model. 

Competitiveness Adoption of the proposed rule is expected to cause very few 

changes in the relative costs of production and prices of 

goods in the local economy. On a per ton of throughput 

basis, the compliance costs are approximately $1.30. Based 

on these compliance costs, no significant changes in the 

location or distribution of greenwaste facilities in the 

District are anticipated. 

SCAQMD ii July 2011


INTRODUCTION 

Proposed Amended Rule (PAR) 1133.1 harmonizes AQMD’s requirements for chipping and 

grinding operations with the Code of California Regulations Title 14 Division 7 Chapter 3.1. 

Proposed Rule (PR) 1133.3 would require greenwaste composting operations to limit greenwaste 

and foodwaste compost feedstock holding times to less than 48 hours from the date of receipt, 

unless otherwise allowed by or up to seven days maximum with approval from the local 

enforcement agency. Within four months of the adoption date, PR 1133.3 would require that 

greenwaste composting operations with up to 20 percent manure, by volume, or processing up to 

5,000 tons of foodwaste, by weight, cover each newly formed compost pile with finished 

compost and apply water prior to pile turning. Upon the date of adoption, greenwaste composting 

operations processing greater than 5,000 tons, by weight, and compost that includes more than 

10 percent foodwaste, would be required to reduce VOC and ammonia emissions to an overall 

control efficiency of at least 80 percent. 

The socioeconomic assessment herein analyzes the impacts of the proposed rule and proposed 

amendments on affected facilities and the entire economy in the four-county region. 

LEGISLATIVE MANDATES 

The socioeconomic assessments at the AQMD have evolved over time to reflect the benefits and 

costs of regulations. The legal mandates directly related to the assessment of the proposed rule 

and the proposed amendments include the AQMD Governing Board resolutions and various 

sections of the California Health & Safety Code (H&SC). 

AQMD Governing Board Resolutions 

On March 17, 1989 the AQMD Governing Board adopted a resolution that calls for preparing an 

economic analysis of each proposed rule for the following elements: 

Affected Industries 

Range of Control Costs 

Cost Effectiveness 

Public Health Benefits (see staff report) 

On October 14, 1994, the Board passed a resolution which directed staff to address whether the 

rules or amendments brought to the Board for adoption are in the order of cost effectiveness as 

defined in the AQMP. The intent was to bring forth those rules that are cost effective first. 

Health & Safety Code Requirements 

The state legislature adopted legislation that reinforces and expands the Governing Board 

resolutions for socioeconomic assessments. H&SC Sections 40440.8(a) and (b), which became 

effective on January 1, 1991, require that a socioeconomic analysis be prepared for any proposed 

rule or rule amendment that "will significantly affect air quality or emissions limitations." 

Specifically, the scope of the analysis should include: 

SCAQMD 1 July 2011


Type of Affected Industries 

Impact on Employment and the Economy of the District 

Range of Probable Costs, Including Those to Industries 

Emission Reduction Potential 

Necessity of Adopting, Amending or Repealing the Rule in Order to Attain State and Federal 

Ambient Air Quality Standards 

Availability and Cost Effectiveness of Alternatives to the Rule 

For emission reduction potential, necessity of rule adoption and cost effectiveness of alternatives 

to the proposed rule, please refer to the Staff Report for PAR 1133.1 and PR 1133.3. 

Additionally, the AQMD is required to actively consider the socioeconomic impacts of 

regulations and make a good faith effort to minimize adverse socioeconomic impacts. H&SC 

Section 40728.5, which became effective on January 1, 1992, requires the AQMD to: 

Examine the type of industries affected, including small businesses; and 

Consider socioeconomic impacts in rule adoption 

H&SC Section 40920.6, which became effective on January 1, 1996, requires that incremental 

cost effectiveness be performed for a proposed rule or proposed amendments related to ozone, 

carbon monoxide (CO), oxides of sulfur (SOx), oxides of nitrogen (NOx), and their precursors. 

Incremental cost effectiveness is defined as the difference in costs divided by the difference in 

emission reductions between one level of control and the next more stringent control. 

Incremental cost effectiveness for this proposed rule is addressed in the Staff Report for PAR 

1133.1 and PR 1133.3. 

AFFECTED FACILITIES 

PAR 1133.1 will not affect any facilities in the four-county region because facilities already 

comply with the proposed amendments. PR 1133.3 will affect 17 facilities operating in the 

District. The affected facilities belong to the industries of Waste Management and Remediation 

Services [North American Industry Classification System (NAICS) code 562] and Chemical 

Manufacturing (NAICS 325). Approximately 23 percent of affected facilities are in Los Angeles 

County, 42 percent are in Orange Country, 23 percent are in Riverside County, and 12 percent 

are in San Bernardino County. 

Small Businesses 

The AQMD defines a "small business" in Rule 102 as one which employs 10 or fewer persons 

and earns less than $500,000 in gross annual receipts. In addition to the AQMD's definition of a 

small business, the federal Small Business Administration (SBA), the federal Clean Air Act 

Amendments (CAAA) of 1990, and the California Department of Health Services (DHS) also 

provide definitions of a small business. 

The SBA's definition of a small business uses the criteria of gross annual receipts (ranging from 

$0.75 million to $35.5 million), number of employees (ranging from 50 to 1,500), megawatt 

hours generated (4 million), or assets ($175 million), depending on industry type (US SBA, 

2010). The SBA definitions of small businesses vary by 6-digit NAICS code. For example, in 

SCAQMD 2 July 2011


the Fertilizer (Mixing Only) Manufacturing (NAICS 325314) industry, a business with 500 or 

fewer employees is considered “small.” In the Material Recovery Facilities (NAICS 562920) 

industry, a business with gross annual receipts of $12.5 million or less is considered “small.” 

The CAAA classifies a facility as a "small business stationary source" if it: (1) employs 100 or 

fewer employees, (2) does not emit more than 10 tons per year of either VOC or NOx, and (3) is 

a small business as defined by SBA. 

Of the 17 facilities examined, Dunn and Bradstreet data on gross annual receipts and employees 

were available for 16 facilities. 1 Data on emissions of VOC and NOx were only available for 

one facility. Applying the small business criteria to the facilities with adequate data for 

evaluation revealed that 14 facilities meet the SBA criteria for small business designation. Under 

the AQMD criterion for small businesses, 3 affected facilities would be categorized as small 

businesses. No facility would meet the CAAA small business criterion. 

COMPLIANCE COST 

There would be no additional compliance cost for chipping and grinding facilities under PAR 

1133.1 because the proposed amendments reflect existing requirements in the Code of California 

Regulations. The 17 affected facilities under PR 1133.3 would be required to cover newlyformed 

compost piles with finished compost, apply water to compost piles prior to turning, and 

perform additional recordkeeping. No existing facility would be required to install a forced 

aeration, or similar, emissions control device because no facilities currently process more than 

5,000 tons of foodwaste. The effective date for all the requirements is from the date of adoption. 

Table 1 summarizes the cost assumptions for PR1133.3. 

Table 1 

Cost Assumptions for PR 1133.3 

Requirement 

Compost Covering 

Unit Cost 

Total Units Per Ton 

of Throughout or Per 

Facility 

Labor $30/hr 0.0044 hr/ton 

Wear/Tear $150/hr 0.0044 hr/ton 

Diesel Fuel 

Watering 

$3.50/gal 0.022 gal/ton 

Labor $10/hr 0.0165 hr/ton 

Water 

Recordkeeping 

$0.0024/gal 95 gals/ton 

Labor $25/hr 78 hrs per facility 

A survey by District staff showed that approximately 416,000 tons of greenwaste throughput is 

processed at affected facilities annually. Industry cost studies were used by staff to estimate the 

cost of compliance activities associated with each of the proposed requirements using the volume 

(132 tons) of throughput in a pile of typical dimensions (200 feet long, 16 feet wide, and 7 feet 

1 Data for some of the affected facilities was obtained from Manta.com, which specifies a range for facility 

employment and gross annual receipts. The lower end value in the data range given by Manta.com was used for 

small business status classification. 

SCAQMD 3 July 2011


high). Covering a newly-formed pile would require finished compost material, a front-end 

loader, and additional labor. The finished compost used for covering can be recovered from piles 

when composting is completed and is thus assumed to generate no additional cost to composting 

facilities. Applying the finished compost cover would require approximately 35 minutes of 

front-end loader time for a pile of typical dimensions. On a per ton of throughput basis, 0.0044 

hours of front-end loader time is needed to apply the compost cover. The wear and tear 

associated with operation of a front-end loader (excluding fuel) is assumed to be $150 per hour. 

Diesel fuel for front-end loader operation is assumed to cost $3.50 per gallon. The wage rate for 

operating a front-end loader is assumed to be $30 per hour. 

The cost of applying water to compost piles prior to turning includes the cost of increased water 

usage and labor for its application. Each ton of composting throughput is assumed to require five 

applications at 19 gallons of water per application prior to each turning to satisfy the proposed 

wet depth requirement. Water is assumed to cost $0.0024 per gallon. The analysis herein 

assumes that affected facilities use potable water, which is significantly more costly than the 

non-potable water that is often used in composting operations. Approximately, 25 minutes of 

labor are assumed to be needed in each application of water to a pile of typical dimensions. On a 

per ton of throughput basis, 0.0165 hours of labor are needed. The assumed wage rate for labor is 

$10 per hour. 

PR 1133.3 also would require that additional labor be devoted to documenting compliance 

activities at affected facilities. The analysis assumes that approximately one additional hour per 

week of recordkeeping will be necessary at each affected facility. Recordkeeping labor is 

assumed to have a wage of $25 per hour. 

The average annual cost of PR 1133.3 is estimated to be $0.53 million from 2011 to 2025. Table 

2 shows the cost of compliance by industry and requirement. The majority of the cost is incurred 

in the chemical manufacturing sector. The compost covering requirement has 64 percent of the 

total compliance cost of PR 1133.3. 

Table 2 

Average Annual Cost by Industry (2011-2025) in Millions of Dollars 

Industry (NAICS) Compost Covering Watering Recordkeeping Total 

Chemical Manufacturing (325) $0.333 $0.163 $0.006 $0.50 

Waste Management and Remediation Services (562) $0.003 $0.001 $0.027 $0.03 

Total $0.34 $0.16 $0.03 $0.53 

On a per ton of throughput basis, the compliance costs of PR 1133.3 are approximately $1.30. 

Based on these compliance costs, no significant changes in the location or distribution of 

greenwaste facilities in the District are anticipated. 

TOTAL IMPACTS 

The REMI PI + model (version 1.2.7) is used to assess the total socioeconomic impacts of a 

policy change. The model links the economic activities in the counties of Los Angeles, Orange, 

Riverside, and San Bernardino. The REMI model for each county is comprised of a five block 

SCAQMD 4 July 2011


structure that includes (1) output and demand, (2) labor and capital, (3) population and labor 

force, (4) wages, prices and costs, and (5) market shares. These five blocks are interrelated. 

Within each county, producers are made up of 165 private non-farm industries, three government 

sectors, and a farm sector. Trade flows are captured between sectors and borders as well as 

across counties and the rest of U.S. Market shares of industries are dependent upon their product 

prices, access to production inputs, and local infrastructure. The demographic/migration 

component has 160 ages/gender/race/ethnicity cohorts and captures population changes in births, 

deaths, and migration. 

The assessment herein is performed relative to a baseline without the implementation of PR 

1133.3. Direct effects of the policy change (the proposed rule) have to be estimated and used as 

inputs to the REMI model in order for the model to assess secondary and induced impacts for all 

the actors in the four-county economy on an annual basis and across a user-defined horizon 

(2011 to 2025). Direct effects of PR 1133.3 include additional costs to the affected industries 

and additional sales of control devices or services by local vendors at the county (or finer) level 

and by industry. 

Proposed Rule 1133.3 would create additional demand for water utilities (NAICS 221) due to the 

requirement to wet compost piles prior to turning. PR 1133.3 would also create an additional 

demand for diesel fuel for front-loader operation, resulting additional sales of diesel fuel by 

gasoline stations in the retail sector (NAICS 447). The increased use of front-loaders will 

modestly increase equipment depreciation and create a small additional demand in the 

construction machinery manufacturing industry (NAICS 333). 

The additional costs to affected facilities include the annualized costs for water, fuel, and 

equipment depreciation. In addition, facilities complying with the watering and covering 

requirements in PR 1133.3 will also use additional labor for the compost covering, watering, and 

recordkeeping. The additional labor cost will modestly reduce worker productivity at affected 

facilities. 

Overall, 4 jobs could be forgone annually, on average, between 2011 and 2025 in the local 

economy. Of the 4 jobs forgone, the chemical manufacturing and retail trade sectors each would 

forgo one job. The two other jobs forgone are due to secondary and induced impacts on the 

demand for labor across all other sectors in the regional economy. Under the baseline forecast, 

the four county region will average 10 million jobs annually from 2011 to 2025. The forecasted 

decline of 4 jobs represents 0.00004 percent of total jobs in the four county region, and is within 

the noise uncertainty of the model. 

The relative cost of production in the chemical manufacturing sector is estimated to rise by 0.001 

percent in 2011 and by 0.002 percent from 2012 to 2025. For the waste management and 

remediation services sector, which includes materials recovery facilities affected by the rule, the 

cost of production is estimated to rise by less than 0.001 percent from 2011 to 2025. The 

chemical manufacturing sector also is projected to experience an increase of 0.001 percent in the 

cost of production from 2012 to 2025. All other sectors would experience an increase in the cost 

of production of less than 0.001 percent. 

SCAQMD 5 July 2011


The average price of a good at the place of use reflects prices of the good produced locally and 

imported elsewhere. The proposed rule is projected to result in increases in delivered prices in all 

sectors by less than 0.001 percent. 

RULE ADOPTION RELATIVE TO THE COST EFFECTIVENESS 

SCHEDULE 

On October 14, 1994, the Governing Board adopted a resolution that requires staff to address 

whether rules being proposed for adoption are considered in the order of cost-effectiveness. The 

2007 Air Quality Management Plan (AQMP) ranked, in the order of cost-effectiveness, all of the 

proposed control measures for which costs were quantified. It is generally recommended that the 

most cost-effective actions be taken first. 

Proposed Rule 1133.3 implements control measure MCS-04—Emissions Reduction from 

Greenwaste Composting. MCS-04 is not ranked for overall cost-effectiveness among competing 

stationary source control measures listed in the 2007 AQMP. The estimated cost effectiveness of 

PR 1133.3 was not determined for the 2007 AQMP because emissions reductions were difficult 

to estimate. 

SCAQMD 6 July 2011


REFERENCES 

EIA. Spot Prices [Data File]. Retrieved from http://www.eia.gov/dnav/pet/hist/ 

Manta.com. Business Profile [Data File]. Retrieved from http://manta.com 

Regional Economic Modeling Inc. (REMI). PI + for the South Coast Region (169 sector model). 

Version 1.2.7. 

South Coast Air Quality Management District (SCAQMD). Proposed Amended Rule 1133.1— 

Chipping and Grinding Activities. June 2011. 

South Coast Air Quality Management District (SCAQMD). Proposed Rule 1133.3—Emission 

Reductions from Greenwaste Composting Operations. June 2011. 

South Coast Air Quality Management District (SCAQMD). Draft Staff Report for Proposed 

Amended Rule 1133.1—Chipping and Grinding Activities—and Proposed Rule 1133.3— 

Emission Reductions from Greenwaste Composting Operations. June 2011. 

South Coast Air Quality Management District (SCAQMD). 2007 Air Quality Management Plan. 

June 2007. 

San Diego State University Research Foundation. (2007). Emissions Testing of Volatile 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. 

San Joaquin Valley Air Pollution Control District (SJVAPCD). (2010) Comparison of Mitigation 

Measures for Reduction of Emissions Resulting from Greenwaste Composting, Project 09-01 

CCOS Draft Final Report. 

U.S. Small Business Administration (US SBA). Small Business Size Standards. November 

2010. 

SCAQMD 7 July 2011

SOUTH COAST AIR QUALITY MAAGEMET DISTRICT 

Draft Final Environmental Assessment: 

Proposed Amended Rule 1133.1 – Chipping and Grinding Activities and 

Proposed Rule 1133.3 – Emission Reductions from 

Greenwaste Composting Operations 

June July 2011 

SCAQMD o. 110518JI 

Executive Officer 

Barry R. Wallerstein, D. Env. 





Planning, Rules, and Area Sources 


Planning and Rules Manager 

Susan Nakamura 

Author: Jeffrey Inabinet Air Quality Specialist 

Technical 

Assistance: Jong Hoon Lee, Ph.D. Air Quality Specialist 

Reviewed By: Tracy A. Goss, P.E. Program Supervisor 

Jill Whynot Assistant Deputy Executive Officer, 


Veera Tyagi Deputy District Counsel II 

Barbara Baird District Counsel

SOUTH COAST AIR QUALITY MAAGEMET DISTRICT 

GOVERIG BOARD 

Chairman: DR. WILLIAM A. BURKE 



Mayor, Chino 

Cities of San Bernardino 

MEMBERS: 








Councilmember, South Pasadena 








Mayor, Riverside 


JOSEPH K. LYOU, Ph. D. 

Governor’s Appointee 




SHAWN NELSON 



JAN PERRY 

Councilmember, Ninth District 

City of Los Angeles 






TABLE OF COTETS 

CHAPTER 1 - PROJECT DESCRIPTION 

Introduction ............................................................................................................................ 1-1 

California Environmental Quality Act ................................................................................... 1-2 

Project Location ..................................................................................................................... 1-3 

Project Objective .................................................................................................................... 1-3 

Emission Effects of PAR 1133.1 and PAR 1133.3 ................................................................ 1-4 

Project Background ................................................................................................................ 1-4 

Project Description................................................................................................................. 1-7 

CHAPTER 2 - ENVIRONMENTAL CHECKLIST 

Introduction ............................................................................................................................ 2-1 

General Information ............................................................................................................... 2-1 

Environmental Factors Potentially Affected .......................................................................... 2-3 

Determination ........................................................................................................................ 2-4 

Environmental Checklist and Discussion .............................................................................. 2-5 

Figures 

Figure 1-1 - Boundaries of the South Coast Air Quality Management District .................... 1-3 

Tables 

Table 2-1 – Air Quality Significance Thresholds .................................................................. 2-10 

Table 2-2 – Peak Construction Emissions Due to Installation of an Emission Control Device and 

Associated Concrete Pad .................................................................................... 2-12 

Table 2-3 – Peak Operational Emissions Due to Incremental Increased Loader Usage to Place 

Finished Compost Cover .................................................................................... 2-15 

Table 2-4 – Overall CO2 Equivalent Increases Due to Construction Activities ................... 2-15 

Table 2-5 – Overall CO2 Equivalent Increases Due to Operational Activities ..................... 2-15 

Table 2-6 – Typical Construction Noise Sources .................................................................. 2-35 

APPENDIX A – Proposed Amended Rule 1133.1 

APPENDIX B – Proposed Amended Rule 1133.3 

APPENDIX C – Construction Emission Calculations 

APPENDIX D – Operational Emission Calculations 

APPENDIX E – Comments Received and Responses to Comments

PREFACE 

This document constitutes the Final Environmental Assessment (EA) for Proposed Amended 

Rule 1133.1 – Chipping and Grinding Activities and Proposed Rule 1133.3 – Emission 

Reductions from Greenwaste Composting Operations. The Draft EA was released for a 30-day 

public review and comment period from June 2, 2011 to July 1, 2011. One comment letter was 

received, as well as several verbal comments from a working group meeting. These comments 

and responses to the comments are provided in Appendix E. The environmental analysis in the 

Draft EA concluded that Proposed Amended Rule 1133.1 and Proposed Rule 1133.3 would not 

generate any significant adverse environmental impacts. 

Minor modifications were made to the Draft EA. To facilitate identifying modifications to the 

document, added and/or modified text is underlined. None of the modifications alter any 

conclusions reached in the Draft EA, nor provide new information of substantial importance 

relative to the draft document. As a result, these minor revisions do not require recirculation of 

the document pursuant to CEQA Guidelines §15088.5. Therefore, this document now 

constitutes the Final EA for Proposed Amended Rule 1133.1 and Proposed Rule 1133.3.

C H A P T E R 1 - P R O J E C T D E S C R I P T I O 

Introduction 

California Environmental Quality Act 

Project Location 

Project Objective 

Emission Effects of PAR 1133.1 and PR 1133.3 

Project Background 

Project Description

Draft Final Environmental Assessment: Chapter 1 

ITRODUCTIO 

The California Legislature created the South Coast Air Quality Management District 

(SCAQMD) in 1977 1 as the agency responsible for developing and enforcing air pollution 

control rules and regulations in the South Coast Air Basin (Basin) and portions of the Salton Sea 

Air Basin and Mojave Desert Air Basin (collectively known as the “district”). By statute, the 

SCAQMD is required to adopt an air quality management plan (AQMP) demonstrating 

attainment of all federal and state ambient air quality standards for the district. Furthermore, the 

SCAQMD must adopt rules and regulations that carry out the AQMP 2 . The 2007 AQMP 

concluded that major reductions in emissions of volatile organic compounds (VOCs) and oxides 

of nitrogen (NOx) are necessary to attain the state and national ambient air quality standards for 

ozone, particulate matter with an aerodynamic diameter of 10 microns or less (PM10) and 

particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5). Ozone, a 

criteria pollutant, is formed when VOCs react in the presence of light with NOx in the 

atmosphere and has been shown to adversely affect human health. VOC emissions also 

contribute to the formation of PM10 and PM2.5. The federal one-hour and eight-hour ozone 

standards were exceeded in all four counties and in the Salton Sea Air Basin in 2008. The 

Central San Bernardino Mountain area recorded the greatest number of exceedences of the onehour 

state standard (79 days), eight-hour state standard (115 days), eight-hour federal standard 

(97 days), as well as, health advisory days (two days). Altogether, in 2008, the South Coast Air 

Basin exceeded the federal eight-hour standard on 120 days, the state one-hour standard on 102 

days, and the state eight-hour standard on 140 days. 

SCAQMD adopted a series of rules (Rules 1133, 1133.1 and 1133.2) in January 2003 covering 

composting operations. Composting is a biological process in which organic material is 

decomposed by microorganisms under controlled conditions to generate compost that can be 

used to reintroduce nutrients into the soils. VOC and ammonia emissions occur during this 

process, but can be reduced cost-effectively. 

Proposed Amended Rule (PAR) 1133.1 would establish best management practices (BMPs) for 

chipping and grinding operations taking place at facilities that accept greenwaste consistent with 

Title 14 California Code of Regulations and that produce materials other than active or finished 

compost, unless otherwise allowed by the local enforcement agency (LEA), pursuant to Title 14 

California Code of Regulations. for a longer period of time. PAR 1133.1 would also establish 

maximum holding time of raw greenwaste material. PAR 1133.1 would apply not only to any 

stand-alone facility receiving greenwaste material for chipping and grinding, but also to any 

facility co-located at a material recovery facility (MRF), a landfill using this material for 

alternative daily cover (ADC), a transfer station, or a biomass energy production facility. PAR 

1133.1 would establish requirements for processing greenwaste for other uses but composting. 

Under PAR 1133.1, foodwaste is not to be taken by the facility for chipping and grinding unless 

otherwise allowed by the LEA. In addition, raw greenwaste would be required to be chipped or 

ground and utilized or removed from the site within 48 hours of receipt, excluding official 

federal and state holidays, or up to seven days maximum with approval from unless otherwise 


1 The Lewis-Presley Air Quality Management Act, 1976 Cal. Stats., ch 324 (codified at Health & Safety Code, 

§§40400-40540). 

2 Health & Safety Code, §40440 (a). 

PAR 1133.1 and PR 1133.3 1-1 May July 2011


Proposed Rule (PR) 1133.3 would apply to greenwaste composting operations involving organic 

waste materials, including greenwaste, woodwaste, manure and foodwaste. PR 1133.3 has 

requirements for the operator to process greenwaste for on-site composting within 48 hours of 

receipt unless otherwise as allowed by the LEA. to be held for a longer period of time. 

Foodwaste is also subject to the 48 hour processing time to initiate composting on-site or 

covered with finished compost until used, unless otherwise required by the LEA. 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 the initial active phase pile with finished compost within three hours of formation, such 

that the top is at least six inches thick and the pile is not turned for the first seven days of the 

active phase of composting, which is followed by additional watering to a three inch depth to the 

top half of the pile, prior to turning, during the first 15 days of the active phase composting 

period. 

For greenwaste composting operations processing greenwaste mixed with greater than 5,000 tons 

per year of foodwaste throughput, the operator would be required to install an emission control 

device achieving a minimum 80 percent control efficiency for all active phase compost piles 

processing foodwaste. It should be noted that greenwaste composting including greater than 20 

percent manure is presently subject to Rule 1133.2 for co-composting operations. 

Approximately 70 existing greenwaste chipping and grinding operations or facilities would be 

subject to the requirements of PAR 1133.1 Based on the assumption that most of these facilities 

are already in compliance with the proposed amendments to Rule 1133.1, no emission reduction 

is assumed. PR 1133.3 is applicable to 17 existing greenwaste composting facilities. Based on 

the emissions inventory compiled for greenwaste compost facilities in the SCAQMD, the total 

emissions reduction associated with the PR 1133.3 is estimated to be 0.9 tons of VOC and 0.1 

tons of ammonia per day. 

CALIFORIA EVIROMETAL QUALITY ACT 

PAR 1133.1 and PR 1133.3 are discretionary actions, which have the potential for resulting in 

direct or indirect changes to the environment and, therefore, are considered a “project” as defined 

by the California Environmental Quality Act (CEQA). SCAQMD is the lead agency for the 

proposed project and has prepared this Draft Final Environmental Assessment (EA) with no 

significant adverse impacts pursuant to its Certified Regulatory Program and SCAQMD Rule 

1110. California Public Resources Code §21080.5 allows public agencies with regulatory 

programs to prepare a plan or other written document in lieu of an environmental impact report 

or negative declaration once the Secretary of the Resources Agency has certified the regulatory 

program. SCAQMD's regulatory program was certified by the Secretary of the Resources 

Agency on March 1, 1989, and is codified as SCAQMD Rule 110. 

CEQA and Rule 110 require that potential adverse environmental impacts of proposed projects 

be evaluated and that feasible methods to reduce or avoid significant adverse environmental 

impacts of these projects be identified. To fulfill the purpose and intent of CEQA, the SCAQMD 

has prepared this Draft Final EA to address the potential adverse environmental impacts 

associated with the proposed project. The Draft Final EA is a public disclosure document 

intended to: (a) provide the lead agency, responsible agencies, decision makers and the general 

PAR 1133.1 and PR 1133.3 1-2 MayJuly 2011


public with information on the environmental effects of the proposed project; and, (b) be used as 

a tool by decision makers to facilitate decision making on the proposed project. 

SCAQMD’s review of the proposed project shows that the proposed project would not have a 

significant adverse effect on the environment. Therefore, pursuant to CEQA Guidelines §15252, 

no alternatives or mitigation measures are required to be included in this Draft Final EA. The 

analysis in Chapter 2 supports the conclusion of no significant adverse environmental impacts. 

Comments received on the Draft Final EA during the public comment period will be addressed 

in the Final EA. 

PROJECT LOCATIO 

PAR 1133.1 and PR 1133.3 would affect greenwaste chipping and grinding operations and 

greenwaste composting operations in the District. The SCAQMD has jurisdiction over an area 

of 10,473 square miles, consisting of the four-county South Coast Air Basin (Basin) and the 

Riverside County portions of the Salton Sea Air Basin (SSAB) and the Mojave Desert Air Basin 

(MDAB) referred to hereafter as the district. The Basin, which is a subarea of the district, is 

bounded by the Pacific Ocean to the west and the San Gabriel, San Bernardino, and San Jacinto 

Mountains to the north and east. The 6,745 square-mile Basin includes all of Orange County and 

the non-desert portions of Los Angeles, Riverside, and San Bernardino counties. The Riverside 

County portion of the SSAB and MDAB is bounded by the San Jacinto Mountains in the west 

and spans eastward up to the Palo Verde Valley. The federal non-attainment area (known as the 

Coachella Valley Planning Area) is a subregion of both Riverside County and the SSAB and is 

bounded by the San Jacinto Mountains to the west and the eastern boundary of the Coachella 

Valley to the east (Figure 1-1). 

S a n ta 

B a r b a r a 

C o u n ty 

S o u th C o a s t 

A ir Q u a lity M a n a g e m e n t D is tric t 

S C A Q M D J u ris d ic tio n 

S a n J o a q u in 

V a lle y 

A ir B a s in 

S o u th 

C e n tra l 

C o a s t A ir B a s in 

V e n tu r a 

C o u n ty 

K e r n C o u n ty S a n B e r n a r d in o C o u n ty 

L o s A n g e le s 

C o u n ty 

S o u th C o a s t 

A ir B a s in 

O r a n g e 

C o u n ty 

M o ja v e D e s e rt 

A ir B a s in 

R iv e rs id e C o u n ty 

S a n D ie g o 

A ir B a s in 

S a n D ie g o C o u n ty 

S a lto n S e a 

A ir B a s in 

I m p e r ia l C o u n ty 

Figure 1-1 

Boundaries of the South Coast Air Quality Management District 



PROJECT OBJECTIVE 

The main objective of PAR 1133.1 and PR 1133.3 is to achieve further emission reductions of 

VOCs and ammonia from greenwaste chipping and grinding operations and greenwaste 

composting operations. PAR 1133.1 would establish best management practices (BMPs) to 

better manage stockpile operations associated with chipping and grinding activities, which is 

consistent with current greenwaste material processing requirements established in Title 14 of 

the California Code of Regulations (CCR). PAR 1133.3 would implement Control Measure 

(CM) MCS-04 of the 2007 Air Quality Management Plan (AQMP) and would seek to establish 

operational BMPs for greenwaste composting operations that produce active or finished compost 

material from greenwaste-only or greenwaste in combination with manure or foodwaste. 

Facilities processing large volumes of foodwaste would be required to install controls capable of 

reducing VOC and ammonia emissions by 80 percent or more. 

EMISSIO EFFECTS OF PAR 1133.1 AD PR 1133.3 

Using baseline emission factors for greenwaste composting operations for the 17 existing 

greenwaste composting facilities, the total actual throughput, the proposed 48 hour retention 

time, and estimated emission reductions for finished compost cover and water irrigation, up to 

0.9 tons of VOC and 0.1 tons of ammonia per day would be reduced with the implementation of 

PR 1133.3. PAR 1133.1 also has the 48 hour material holding time requirement, which is tighter 

than the previous holding time requirements of Rule 1133.1. The amended 48 hour holding 

requirement is to conform to that of the existing state regulation (Title 14) which is currently 

enforced by the county-level Local Enforcement Agency (LEA). As the 48 hour requirement is 

already enforced by the LEA, no emission reductions are quantified relative to PAR 1133.1. 

PROJECT BACKGROUD 

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 Integrated Waste Management Act (AB939, Sher, Chapter 1095, Statutes of 1989 

as amended [IWMA]). 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 aeration and moisture, 

will minimize VOC, ammonia, and GHG emissions. 

Greenwaste composting is a source of ammonia, a PM2.5 precursor, and VOCs, an ozone 

precursor. Biogenic VOCs also act as a precursor 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, are 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. In the South Coast, gas recovery control 

systems have been required to be employed for decades at landfills. These systems effectively 

collect VOC and methane emissions. As a result, landfill emissions are well controlled in the 



SCAB. Diverting organic materials helps return valuable nutrients to the soil, improves plant 

productivity, and helps reduce water usage, erosion, and chemical use. 

The following is a summary of the regulatory programs that are applicable or pertinent to the 

greenwaste composting industry. 

Federal Programs 

Resource Conservation and Recovery Act 

In 1976, Congress enacted the Resource Conservation and Recovery Act (RCRA), an 

amendment to the 1965 Solid Waste Disposal Act. RCRA calls for conservation of energy and 

natural resources, waste reduction, and environmentally sound waste management practices. In 

addition, RCRA encourages states to develop plans for non-hazardous industrial solid waste and 

municipal 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. Congress 

delegated authority to U.S. EPA to develop scientific regulations to implement the requirements 

of RCRA. Solid waste regulations have been promulgated in the Code of Federal Regulations 

under Title 40, Chapter I, Subchapter I, Parts 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, generally requires processes to further reduce pathogens (PFRP). PFRP 

requires that open windrow composting maintain the temperature of the compost at 131 degrees 

Fahrenheit or higher for 15 days or longer, and during this time there must be a minimum of five 

turnings of the windrows. For in-vessel or aerated static pile (ASP) composting, the PFRP 

requires the active pile temperature be at least 131 degrees Fahrenheit or higher for three days. 

This process assures that virtually all human pests and pathogens are destroyed. Since food 

residuals contain human pathogens, fungi and bacteria, this PFRP should be met when foodwaste 

is being mixed with greenwaste for composting. 

State Programs 

California State Legislature: California Integrated Waste Management Act 

Recognizing landfill limitations (i.e., capacity and siting) and the need for integrated waste 

management practices, in 1989, the California state legislature passed Assembly Bill (AB) 939 – 

California Integrated Waste Management Act into law, which was incorporated into the 

California Public Resources Code, Division 30. Cities and counties were mandated to achieve a 

total waste diversion of 25 percent by 1995 and to meet a total waste diversion of 50 percent 

every year. 

CalRecycle (formerly California Integrated Waste Management Board, CIWMB) 

In April 2003, the then CIWMB promulgated a set of regulations governing composting 

operations and facilities. The CIWMB currently regulates approximately 87 composting 

facilities operating in California in accordance with the California Code of Regulations, Title 14, 

Division 7, Chapter 3.1 – Composting Operations Regulatory Requirements (Chapter 3.1). The 



Chapter 3.1 has requirements of handling compostable materials including, but not limited to, 

material residence time at facilities, temperature requirement to prevent inadvertent 

decomposition. This Chapter also has a pathogen reduction requirement that requires open 

windrow composting maintain the temperature 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 Registration Permit, a Standardized Composting Permit, Notification or a 

Full Solid Waste Facilities Permit (Full Permit) that are issued by local enforcement agencies 

(LEAs), such as the environmental health departments. There are also requirements for green 

material composting operations and facilities, as well as an Odor Impact Minimization Plan 

(OIMP). 

2007 Strategic Directive 6.1 

In 2007, the CIWMB adopted Strategic Directive 6.1, which in addition to the diversion required 

under AB 939, seeks an additional 50 percent of organics 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 produce compost, biofuels, and/or bioenergy; increased development of product 

standards and increased procurement by private and public entities; and resolution of crossagency 

regulatory issues. 

Regional Water Quality Control Board 

The Regional Water Quality Control Board (RWQCB) enforces EPA-issued National Pollutant 

Discharge Elimination System (NPDES) permits. In addition, the RWQCB focuses on 

wastewater generation, water demand, the capacity of existing or planned stormwater drainage 

systems and potential new sources of polluted run-off, and potential depletion of groundwater 

supplies or interference with groundwater recharge. In the case of composting facilities, the 

RWQCB has required various composting sites to be graded, paved, and surrounded by berms 

and other drainage-related protections to prevent run-off and the leaching of chipped and ground 

materials into the groundwater. 

Local Programs 

There are several local requirements that may apply to greenwaste composting operations. 

Specifically, these requirements focus on air, land use and solid waste issues. The following is a 

summary of these requirements. 

SCAQMD Rule Requirements 

Currently, operators of chipping/grinding operations at greenwaste 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 comply with District Rules 1133 – General Administration, and 1133.1 – 

Chipping and Grinding. However, none of these rules establish specific control requirements to 

reduce VOC and ammonia emissions from greenwaste 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 enforcement division of the CIWMB (now known as CalRecycle), 

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 requirements in these permits. 

For either type of permit scenario, the LEAs are responsible for handling and investigating 

complaints from composting and chipping/grinding operations. Pursuant to Health and Safety 

Code Section 41705, composting operations are exempt from SCAQMD odor regulations; 

SCAQMD must refer odor complaints to the LEA. 

Local Governments 

Local government zoning ordinances determine where composting activities can occur. In 

addition, local governments grant conditional use permits if the jurisdiction has determined that 

special conditions and approvals are necessary. 

PROJECT DESCRIPTIO 

Proposed Amended Rule 1133.1 

PAR 1133.1 would establish best management practices (BMPs) to better manage stockpile 

operations associated with chipping and grinding activities, which is consistent with current 

greenwaste material processing requirements established in Title 14 of the California Code of 

Regulations (CCR). This proposed amended rule applies to the operators of chipping and 

grinding activities, including stockpile operations, taking place at facilities that accept 

greenwaste and do not to produce material other than active or finished compost, unless 

otherwise exempted. 

Foodwaste Management 

Rule 1133.1 is proposed to be amended to clarify that foodwaste cannot be accepted at chipping 

and grinding facilities unless facilities are allowed by the LEA to handle foodwaste. All 

conditions and requirements should be described on the facility permit issued by the LEA. 

Stockpile Operations 

Under PR 1133.3, once greenwaste is received at the chipping and grinding facility, the operator 

shall chip or grind and utilize on-site or remove curbside, non-curbside or mixed greenwaste 

from the site within 48 hours of receipt, excluding official federal and state holidays, or up to 

seven days maximum with approval from the LEA. , unless permitted by the LEA to hold the 

material for a longer period of time. This requirement harmonizes the rule provisions with Title 

14, Division 7, Chapter 3.1, Section 17852 (a)(10)(A)(2) of the CCR. Chipped or ground 

materials shall not be stockpiled, but be “utilized” for other purposes, including, but not limited 

to, daily landfill cover, land application, mulch and erosion control, or be removed from the site, 

such as for landfill ADC, within the applicable allotment of time. 

Recordkeeping 

All the operational records 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. 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, as well as portable 

chipping and grinding, agricultural chipping and grinding, landclearing chipping and grinding, 

woodwaste chipping and grinding, and palm chipping and grinding activities. In this 

amendment, the operator of a landfill or biomass power generation facility would be exempt 

from the requirements of maintaining operation-specific records on-site, provided that the 

operator does not perform chipping and grinding of greenwaste on-site. Rule elements 

pertaining to moisture content remain unchanged. 


PAR 1133.3 would implement CM MCS-04 of the 2007 AQMP and would seek to establish 

operational BMPs for greenwaste composting operations that produce active or finished compost 

material from greenwaste-only or greenwaste in combination with manure or foodwaste. The 

proposed rule would focus on stockpile and composting operations of greenwaste and/or 

foodwaste at all new and existing composting facilities that are either registered for a notification 

tier or permitted by the LEA to conduct composting operations. The level of requirements would 

depend on the annual amount of foodwaste being composted. 

Operations Processing Greenwaste and/or Foodwaste 

Effective upon rule adoption, the operator of greenwaste composting operations would be 

required to chip or grind and use greenwaste for on-site composting or remove greenwaste from 

the site within 48 hours of receipt, unless otherwise as allowed by the LEA. for a longer period 

of time. This requirement is consistent with the requirement of PAR 1133.1, pursuant to 

paragraph (d)(2) and conforming to the state regulation pursuant to Title 14 Division 7, Chapter 

3.1, Section 17852 (a)(10)(A)(2) of the CCR. In addition, foodwaste should be used for on-site 

composting within 48 hours of receipt or cover the foodwaste with screened or unscreened 

finished compost until used, unless otherwise required by the LEA. 

Operations Processing Greenwaste Only, Greenwaste with up to 20 Percent Manure by Volume, 

or Greenwaste with up to 5,000 Tons per Year of Foodwaste 

• Allowance of Manure or Foodwaste 

Up to 20 percent manure by volume, or up to 5,000 tons per year of foodwaste, would be 

allowed to be integrated into greenwaste composting. Installing an emission control 

device is not required below these levels. 

For the purpose of this proposed rule, up to 20 percent manure, by volume, integrated 

into greenwaste is considered greenwaste composting. This percent limit is already 

allowed in Rule 1133.2 – Emission Reductions from Co-Composting Operations 

(adopted in January 2003), because it was difficult for agricultural farm composters to 

completely separate horse manure from horse bedding materials for composting. 

However, other kinds of animal manure would also be allowed under PR 1133.3. More 

than 20 percent manure, by volume, would not be considered as greenwaste composting. 

It would be considered as co-composting and such operations would be subject to Rule 



1133.2. Up to 5,000 tons per year of foodwaste can be integrated for greenwaste 

composting as well. The amount of foodwaste to be included is based on an annual 

facility tonnage throughput basis, while the amount of manure is based on a pile volume 

basis. 

• Rule Requirements: Finished Compost Cover and Watering 

Every initial (or first formation of) an active phase pile is required to be covered with 

finished compost within three 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 active phase period of 

composting. Tests have shown the emissions primarily escape from the top one third of 

the pile. Having a six inch compost cover at the top ensures the pile is adequately 

covered. 

Tests have shown that a vast majority of VOC emissions (80 percent) are produced 

during the first 15 day active phase period of composting. In particular, the emissions 

tend to spike within the first three to seven days of the active phase of composting and 

then diminish over time. According to a San Joaquin APCD study 3 , about 53 percent of 

VOC emission reductions were achieved with six inches of finished compost layer 

applied upon initial 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 living on the surface 

of the finished compost. To minimize facility impacts, the compost cover is only 

proposed for initial pile formation and the pile is not to be turned for seven days unless 

needed to manage temperature or for pathogen reduction. 

Additional watering is proposed as a subsequent requirement 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 necessary to the surface area of all active phase piles within three hours before 

subsequent turning such that the pile is wet to a depth of three inches. The top one half of 

the pile must always be wet down to a three inch depth. Alternatively, the operator may 

apply water during turning using a windrow turner equipped with water spraying 

technology during the entire windrow turning process. 

According to a composting mitigation measure study 4 , the surface irrigation could help 

reduce VOC emissions from greenwaste compost piles by 24 percent. VOC emitted from 

composting of organic wastes consists of biodegradable and water-soluble 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, 

there would be no water run-off problems associated with additional watering. 

3 SJVAPCD, 2010a. Comparison of Mitigation Measures for Reduction of Emissions Resulting from Greenwaste Composting, 

Project 09-01 CCOS Draft Final Report. 



If a rain event occurs prior to watering the pile and the pile is wet to a depth of three 

inches, the operator may turn the pile without adding additional water. 

It is recommended that the operator conduct a ball test using hand pressure to evaluate if 

the pile is “wet” enough before turning. No additional watering would be required if the 

compostable material contains enough moisture to form a ball when compressed by hand, 

but may break when tapped, at least three inches depth from the peak of a pile. If the ball 

crumbles upon release of the hand pressure test, additional water would be required to 

apply to the pile until the requirement is met. This may also apply to a normal operating 

condition. If the pile is sufficiently wet down to a three inch depth within three hours 

before turning 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 pile as 

described in this section. 

An alternate method may be implemented by the operator, provided that the measure is 

approved by the Executive Officer, California Air Resources Board, and the United 

States Environmental Protection Agency, and it is demonstrated that equivalent or greater 

emission reductions are achieved of at least 40 percent, by weight, for VOC and of 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 by Weight 

• Emission Control Device Achieving Overall Control Efficiency Greater than or Equal to 

80 Percent 

For a facility that accepts greater than 5,000 tons per year of foodwaste, the operator 

would be required for all composting including foodwaste to install an emission control 

device with an overall system control efficiency of at least 80 percent by weight, each for 

VOC and ammonia, for all active phase compost piles processing foodwaste. 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, 5 . Thus, requiring such equipment for curing 

phase would not add significant emission reductions but may increase operational costs. 

The operator may implement a control alternative, if approved by the Executive Officer, 

California Air Resources Board, and the U.S. EPA, to achieve VOC and ammonia 

emission reductions equivalent to or greater than the required reductions. It should be 

4 SJVAPCD, 2010b. Compost VOC Emission Factors, San Joaquin Valley Air Pollution Control District, September 15, 

2010. 

5 NorCal Waste Systems, 2006. Emissions Evaluation of Complete Compost Cycle VOC and Ammonia Emissions, Air 

Emissions Source Test Report, May 2006. 



noted that a facility need not control composting of greenwaste only, but rather any 

composting involving foodwaste. 

Any emission control system, such as forced aeration with biofilter, should be designed 

and operated such that an overall control efficiency of at least 80 percent is achieved for 

VOC and ammonia, respectively, from the baseline emission factors or alternate baseline 

emission factors. The overall control efficiency includes both the capture efficiency and 

destruction efficiency. 

• Permit Application 

A permit would be required for an emission control device for any new or existing 

greenwaste composting operations processing greater than 5,000 tons per year of 

foodwaste. All new greenwaste composting operations would be required to obtain a 

permit for such equipment before construction. Existing greenwaste composting 

operations that plan to process greater than 5,000 tons per year of foodwaste would also 

have to obtain a permit for the equipment before processing greater than that amount. 

Existing greenwaste composting operations that currently process greater than 5,000 tons 

per year of foodwaste would be required to file a permit application within three months 

of rule adoption and implement such equipment within six months upon approval of the 

permit application. However, based on staff research of greenwaste composting facilities 

located within the District, no existing facilities are expected to be required to install an 

emission control device based on their current operations. 

Any aeration system and its associated emission control device would need a separate 

permit for each. Any aeration system or emission control device would be integrated to 

the same permit. Depending on the configuration of an emission control system, 

emission controls may be accomplished without the need of venting 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. 

• Source Testing 

Under the proposed rule, all permitted emission control devices would be demonstrated 

through an approved source test for an overall control efficiency of at least 80 percent by 

weight for VOC and ammonia emissions, respectively. The source test needs to be 

conducted within three months after start-up of the equipment, or within nine months of 

permit approval, whichever occurs sooner, and every three years thereafter. Existing 

equipment already tested would need to conduct future source tests every three years 

from the initial source test. 

• Operation and Maintenance 

Proper operation and maintenance would be required for an installed emission control 

system to ensure maximum emissions control. All permitted equipment should be 

installed, operated and maintained in accordance with the manufacturer’s operation and 

maintenance manual or other similar written materials supplied by the manufacturer or 

distributor to ensure proper operating conditions. 



Test Methods and Protocol 

For operations subject to the requirements of an air pollution control device, the operator would 

be required to conduct all required source and laboratory tests using the Executive Officer 

approved test protocol 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 control 

system and source tests, should be maintained for the prior five years of operation, with the most 

recent 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 Co- 


• If the operator of any greenwaste composting operation voluntarily installs an emission 

control device, the provisions of additional irrigation and the finished compost cover and 

associated recordkeeping 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 from 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 

o Recreational facility composting 


C H A P T E R 2 - E V I R O M E T A L C H E C K L I S T 

Introduction 

General Information 

Environmental Factors Potentially Affected 

Determination 

Environmental Checklist and Discussion


ITRODUCTIO 

The environmental checklist provides a standard evaluation tool to identify a project's potential adverse environmental impacts. 

This checklist identifies and evaluates potential adverse environmental impacts that may be created by the proposed project. 

GEERAL IFORMATIO 

Project Title: Draft Final Environmental Assessment (EA) for Proposed Amended Rule 

(PAR) 1133.1 – Chipping and Grinding Activities and Proposed Rule (PR) 

1133.3 – Emission Reductions from Greenwaste Composting Operations 

Lead Agency Name: South Coast Air Quality Management District 

Lead Agency Address: 21865 Copley Drive 

Diamond Bar, CA 91765 

CEQA Contact Person: Mr. Jeffrey Inabinet (909) 396-2453 

PARs 1162 and 1132 Contact Person: Dr. Jong Hoon Lee (909) 396-3903 

Project Sponsor's Name: South Coast Air Quality Management District 

Project Sponsor's Address: 21865 Copley Drive 

Diamond Bar, CA 91765 

General Plan Designation: Not applicable 

Zoning: Not applicable 

PAR 1133.1 would establish the best management practices (BMPs) for 

Description of Project: 

chipping and grinding activities, including stockpile operations, to produce 

materials other than active or finished compost material. PAR 1133.1 would 

establish requirements for processing, utilizing or removing greenwaste from 

the site within 48 hours of receipt, unless otherwise allowed by the Local 

Enforcement Agency to hold for a longer period of time. PAR 1133.1 would 

apply to any chipping and grinding activities to produce materials other than 

active or finished compost, occurring at a chipping and grinding facility, a 

material recovery facility (MRF), a landfill using this material for alternative 

daily cover (ADC), a transfer station, a biomass power generation facility, or a 

composting facility. PR 1133.3 would implement Control Measure (CM) 

MCS-04 of the 2007 Air Quality Management Plan (AQMP) and seeks to 

establish operational BMPs for greenwaste composting operations that 

produce active or finished compost material from greenwaste-only or 

greenwaste in combination with manure or foodwaste. Operators of a 

greenwaste composting operations would be required to apply finished 

compost cover after the initial pile is formed and up to the minimum of seven 

days and water irrigation within a specified time before turning the material 

for all active phase piles. Additionally, for greenwaste composting operations 

processing greenwaste mixed with greater than 5,000 tons per year of 

foodwaste throughput, the operator would be required to install an emission 

control device for all active phase compost piles containing foodwaste content 

of 10% or more by weight. PR 1133.3 would apply to greenwaste composting 

operations involving organic waste materials, including greenwaste, 

woodwaste, manure, or foodwaste. 

Surrounding Land Uses and Setting: Not applicable 

Other Public Agencies Whose 

Approval is Required: 

Not applicable 



EVIROMETAL FACTORS POTETIALLY AFFECTED 

The following environmental impact areas have been assessed to determine their potential to be 

affected by the proposed project. As indicated by the checklist on the following pages, 

environmental topics marked with an "" may be adversely affected by the proposed project. 

An explanation relative to the determination of impacts can be found following the checklist for 

each area. 

Aesthetics Agriculture Resources Air Quality 

Biological Resources Cultural Resources Energy 

Geology/Soils Hazards & Hazardous 

Materials 

Hydrology/ 

Water Quality 

Land Use/Planning Mineral Resources Noise 

Population/Housing Public Services Recreation 

Solid/Hazardous Waste Transportation/ 

Traffic 

Mandatory 

Findings of 

Significance 



DETERMIATIO 

On the basis of this initial evaluation: 

I find the proposed project, in accordance with those findings made pursuant to 

CEQA Guideline §15252, COULD NOT have a significant effect on the 

environment, and that an ENVIRONMENTAL ASSESSMENT with no 

significant impacts will be prepared. 

I find that although the proposed project could have a significant effect on the 

environment, there will NOT be significant effects in this case because 

revisions in the project have been made by or agreed to by the project 

proponent. An ENVIRONMENTAL ASSESSMENT with no significant 

impacts will be prepared. 

I find that the proposed project MAY have a significant effect(s) on the 

environment, and an ENVIRONMENTAL ASSESSMENT will be prepared. 

I find that the proposed project MAY have a "potentially significant impact" on 

the environment, but at least one effect 1) has been adequately analyzed in an 

earlier document pursuant to applicable legal standards, and 2) has been 

addressed by mitigation measures based on the earlier analysis as described on 

attached sheets. An ENVIRONMENTAL ASSESSMENT is required, but it 

must analyze only the effects that remain to be addressed. 

I find that although the proposed project could have a significant effect on the 

environment, because all potentially significant effects (a) have been analyzed 

adequately in an earlier ENVIRONMENTAL ASSESSMENT pursuant to 

applicable standards, and (b) have been avoided or mitigated pursuant to that 

earlier ENVIRONMENTAL ASSESSMENT, including revisions or mitigation 

measures that are imposed upon the proposed project, nothing further is 

required. 

Date: June 1 July 8, 2011 Signature: 

Steve Smith, Ph.D. 

Program Supervisor 



EVIROMETAL CHECKLIST AD DISCUSSIO 

As discussed in Chapter 1, PAR 1133.1 would establish BMPs for chipping and grinding 

operations taking place at facilities that accept greenwaste consistent with Title 14 and produce 

materials other than active or finished compost, unless otherwise allowed by the local 

enforcement agency (LEA), pursuant to Title 14, for a longer period of time. PAR 1133.1 would 

also establish maximum holding time of raw greenwaste material. PAR 1133.1 would apply not 

only to any stand-alone facility receiving greenwaste material for chipping and grinding, but also 

to any facility co-located at a material recovery facility (MRF), a landfill using this material for 

alternative daily cover (ADC), a transfer station, or a biomass energy production facility. PAR 

1133.1 would establish requirements for processing greenwaste for other uses but composting. 

Under PAR 1133.1, foodwaste is not to be taken by the facility for chipping and grinding unless 

otherwise allowed by the LEA. In addition, raw greenwaste 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 unless otherwise allowed by the LEA. 

PR 1133.3 would apply to greenwaste composting operations involving organic waste materials, 

including greenwaste, woodwaste, manure and foodwaste. PR 1133.3 has requirements for the 

operator to process greenwaste for on-site composting within 48 hours of receipt unless 

otherwise as allowed by the LEA. to be held for a longer period of time. Foodwaste is also 

subject to the 48 hour processing time to initiate composting on-site or covered with finished 

compost until used, unless otherwise required by the LEA. 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 the initial active 

phase pile with finished compost within three 24 hours of formation, such that the top is at least 

six inches thick and the pile is not turned for the first seven days of the active phase of 

composting, which is followed by additional watering to a three inch depth to the top half of the 

pile, prior to turning, during the first 15 days of the active phase composting period. 

For greenwaste composting operations processing greenwaste mixed with greater than 5,000 tons 

per year of foodwaste throughput, the operator would be required to install an emission control 

device achieving a minimum 80 percent control efficiency for all active phase compost piles 

processing foodwaste. It should be noted that greenwaste composting including greater than 20 

percent manure is presently subject to Rule 1133.2 for co-composting operations. 


subject to the requirements of PAR 1133.1. Based on the assumption that most of these facilities 

are already in compliance with the proposed amendments to Rule 1133.1, no emission reduction 

is assumed. PR 1133.3 is applicable to 17 existing greenwaste composting facilities. Based on 

the emissions inventory compiled for greenwaste compost facilities in the SCAQMD, the total 

emissions reduction associated with the PR 1133.3 is estimated to be 0.9 tons of VOC and 0.1 

tons of ammonia per day. 



I. AESTHETICS. Would the project: 

a) Have a substantial adverse effect on a 

scenic vista? 

b) Substantially damage scenic resources, 

including, but not limited to, trees, 

rock outcroppings, and historic 

buildings 

highway? 

within a state scenic 

c) Substantially degrade the existing 

visual character or quality of the site 

and its surroundings? 

d) Create a new source of substantial 

light or glare which would adversely 

affect day or nighttime views in the 

area? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 

Significance Criteria 

The proposed project impacts on aesthetics will be considered significant if: 

- The project will block views from a scenic highway or corridor. 

- The project will adversely affect the visual continuity of the surrounding area. 

- The impacts on light and glare will be considered significant if the project adds lighting 

which would add glare to residential areas or sensitive receptors. 

Discussion 

I. a), b), c) & d) PAR 1133.1 or PR 1133.3 is not expected to require any new development or 

require modifications to buildings or other structures to comply with the new BMPs for chipping 

and grinding operations and the new requirements for greenwaste composting. It is expected that 

PAR 1133.1 and PR 1133.3 would not significantly change existing operations at any of the 

affected facilities. Further, since all of the affected activities already occur within existing 

facilities, there would be no change to the visual character of the existing setting at any of the 

existing affected facilities. For the same reason, PAR 1133.1 and PR 1133.3 are not expected to 

adversely affect scenic vistas or substantially damage scenic resources. 

PR 1133.3 may include some construction activities, should the facilities be required to or 

choose to install control equipment. However, based on current throughput at facilities located 

within the District, no currently existing facilities would be required to install air pollution 

control equipment. Such construction activity would not be expected to adversely affect 

aesthetics. 

Additional light or glare would not be created which would adversely affect day or nighttime 

views in the area since no light generating equipment would be required to comply with the new 

BMPs for chipping and grinding operations and the new requirements for greenwaste 



composting. Similarly, the proposed amended rule does not require nighttime activities at 

affected facilities. 

Based upon these considerations, significant adverse aesthetics impacts are not anticipated and 

will not be further analyzed in this Draft Final EA. Since no significant adverse aesthetics 

impacts were identified, no mitigation measures are necessary or required. 

II. AGRICULTURE AD FOREST 

RESOURCES. Would the project: 

a) Convert Prime Farmland, Unique 

b) 

Farmland, or Farmland of Statewide 

Importance (Farmland), as shown on 

the maps prepared pursuant to the 

Farmland mapping and Monitoring 

Program of the California Resources 

Agency, to non- agricultural use? 

Conflict with existing zoning for 

agricultural use, or a Williamson Act 

contract? 

c) Conflict with existing zoning for, or 

cause rezoning of, forest land (as 

defined in Public Resources Code 

§12220(g)), timberland (as defined by 

Public Resources Code §4526), or 

timberland zoned Timberland 

d) 

Production (as defined by Government 

Code §51104 (g))? 

Result in the loss of forest land or 

conversion of forest land to non-forest 

use? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 


Project-related impacts on agriculture and forest resources will be considered significant if any 

of the following conditions are met: 

- The proposed project conflicts with existing zoning or agricultural use or Williamson Act 

contracts. 

- The proposed project will convert prime farmland, unique farmland or farmland of statewide 

importance as shown on the maps prepared pursuant to the farmland mapping and monitoring 

program of the California Resources Agency, to non-agricultural use. 

- The proposed project conflicts with existing zoning for, or causes rezoning of, forest land (as 

defined in Public Resources Code §12220(g)), timberland (as defined in Public Resources 



Code §4526), or timberland zoned Timberland Production (as defined by Government Code 

§ 51104 (g)). 

- The proposed project would involve changes in the existing environment, which due to their 

location or nature, could result in conversion of farmland to non-agricultural use or 

conversion of forest land to non-forest use. 

Discussion 

II. a), b), c) & d) PAR 1133.1 and PR 1133.3 would not require any new development or 

require modifications to existing buildings or other structures to comply with the new BMPs for 

chipping and grinding operations and the new requirements for greenwaste composting. All of 

the affected operations occur within existing facilities, so new land use designations, including 

agricultural designations, are not expected to be altered by the proposed project. Therefore, 

since PAR 1133.1 and PR 1133.3 affects operations at existing facilities located only in already 

zoned areas, it is not expected to convert any classification of farmland to non-agricultural use or 

conflict with zoning for agricultural use or a Williamson Act contract. The proposed project is 

not expected to result in the loss of forest land or conversion of forest land to non-forest use. 

Based upon these considerations, significant agricultural resource impacts are not anticipated and 

will not be further analyzed in this Draft Final EA. Since no significant adverse agriculture 

resources impacts were identified, no mitigation measures are necessary or required. 

III. AIR QUALITY AD 

GREEHOUSE GAS EMISSIOS. 

Would the project: 

a) Conflict with or obstruct implementation 

of the applicable air quality plan? 

b) Violate any air quality standard or 

contribute to an existing or projected air 

quality violation? 

c) Result in a cumulatively considerable 

net increase of any criteria pollutant for 

which the project region is nonattainment 

under an applicable federal 

or state ambient air quality standard 

(including releasing emissions that 

exceed quantitative thresholds for ozone 

precursors)? 

d) Expose sensitive receptors to substantial 

pollutant concentrations? 

e) Create objectionable odors affecting a 

substantial number of people? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 

 



f) Diminish an existing air quality rule or 

future compliance requirement resulting 

in a significant increase in air 

pollutant(s)? 

g) Generate greenhouse gas emissions, 

either directly or indirectly, that may 

have a significant impact on the 

environment? 

h) Conflict with an applicable plan, policy 

or regulation adopted for the purpose of 

reducing the emissions of greenhouse 

gases? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 


To determine whether or not air quality impacts from the proposed project may be significant, 

impacts will be evaluated and compared to the criteria in Table 2-1. If impacts exceed any of the 

criteria in Table 2-1, they will be considered further in the Draft Final EA. If necessary, all 

feasible mitigation measures will be identified in the Draft Final EA and implemented to reduce 

significant impacts to the maximum extent feasible. 

To determine whether or not greenhouse gas emissions from the proposed project may be 

significant, impacts will be evaluated and compared to the 10,000 MT CO2/year threshold for 

industrial sources. 

Discussion 

III. a) PAR 1133.1 and PR 1133.3 are intended to benefit air quality and be consistent with, 

rather than conflict with, or obstruct, the implementation of the SCAQMD's AQMP. The three 

primary categories of composting operations (e.g. co-composting, greenwaste composting, and 

chipping and grinding) contribute to a sizeable amount of VOC and ammonia emissions in the 

District. VOC and ammonia are precursors to ozone and PM2.5 emissions, respectively, for 

which ambient air quality standards are currently exceeded in the South Coast Air Basin. The 

proposed project is intended to reduce VOC and ammonia emissions from greenwaste 

composting and minimize VOC and ammonia emissions from inadvertent decomposition 

associated with stockpiling at chipping and grinding facilities. PR 1133.3 would implement 

Control Measure MCS-04 of the 2007 AQMP and seeks to establish operational BMPs for 

greenwaste composting operations that produce finished compost material from greenwaste-only 

or greenwaste in combination with manure or foodwaste. If a facility chooses to compost large 

amounts of foodwaste (greater than 5,000 tons per year), an emission control device would be 

required to be installed. Therefore, the proposed project is consistent with the SCAQMD’s air 

quality goals and objectives for the region. 



III. b), c), d) & f) For a discussion of these items, refer to the following analysis. 

Air Quality Significance Criteria 

To determine whether or not air quality impacts from adopting the proposed rule or amendments 

are significant, impacts will be evaluated and compared to the criteria in Table 2-1. If impacts 

equal or exceed any of the criteria in Table 2-1, air quality impacts will be considered significant. 

All feasible mitigation measures will be identified and implemented to reduce significant impacts 

to the maximum extent feasible. 

Table 2-1 

Air Quality Significance Thresholds 6 

Mass Daily Thresholds 

Pollutant Construction Operation 

NOx 100 lbs/day 55 lbs/day 

VOC 75 lbs/day 55 lbs/day 

PM10 150 lbs/day 150 lbs/day 

PM2.5 55 lbs/day 55 lbs/day 

SOx 150 lbs/day 150 lbs/day 

CO 550 lbs/day 550 lbs/day 

Lead 3 lbs/day 3 lbs/day 

Toxic Air Contaminants (TACs) 

Accidental Release of Acutely 

Hazardous Materials (AHMs) 

Toxic Air Contaminants and Odor Thresholds 

MICR > 10 in 1 million ; HI > 1.0 (project increment) 

CAA §112® threshold quantities 

Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402 

Ambient Air Quality for Criteria Pollutants (a) 

NO2 

1-hour average 

annual average 

PM10 


annual geometric average 

annual arithmetic mean 

PM2.5 


Sulfate 


CO 



SCAQMD is in attainment; project is significant if it causes or 

contributes to an exceedance of the following attainment standards: 

0.25 ppm (state) 

0.053 ppm (federal) 

10.4 µg/m 3 (construction) (b) & 2.5 µg/m 3 (operation) 

1.0 µg/m 3 

20 µg/m 3 

10.4 µg/m 3 (construction) (b) & 2.5 µg/m 3 (operation) 

1 µg/m 3 

SCAQMD is in attainment; project is significant if it causes or 

contributes to an exceedance of the following attainment standards: 

20 ppm (state) 

9.0 ppm (state/federal) 

6 CEQA Air Quality Handbook, SCAQMD, www.aqmd.gov/ceqa/hdbk.html. 



(a) Ambient air quality thresholds for criteria pollutants based on SCAQMD Rule 1303, Table A-2 unless otherwise stated. 

(b) Ambient air quality threshold based on SCAQMD Rule 403. 

KEY: MICR = maximum individual cancer risk HI = Hazard Index 

µg/m 3 = microgram per cubic meter ppm = parts per million 

AHM = acutely hazardous material; TAC = toxic air contaminant 

Greenhouse Gases Significance Thresholds 

SCAQMD’s adopted interim greenhouse gases (GHG) significance threshold proposal uses a 

tiered approach to determining significance. Tier 1 consists of evaluating whether or not the 

project qualifies for any applicable exemption under CEQA. Tier 2 consists of determining 

whether or not the project is consistent with a GHG reduction plan that may be part of a local 

general plan, for example. Tier 3 establishes a screening significance threshold level to 

determine significance using a 90 percent emission capture rate approach, which corresponds to 

10,000 metric tons of CO2 equivalent emissions per year (MTCO2eq/yr). Tier 4 consists of a 

decision tree approach that allows the lead agency to choose one of three compliance options 

based on performance standards, but was not recommended for approval at this time. Under Tier 

5 the project proponent would implement offsite mitigation (GHG reduction projects) to reduce 

GHG emission impacts to less than the proposed screening level. To determine whether or not 

greenhouse gas emissions from the proposed project may be significant, impacts will be 

evaluated and compared to the 10,000 MT CO2/year threshold for industrial sources. 

Rule Objective and Facility Applicability 

The objectives of PAR 1133.1 and PR 1133.3 are generally to implement maximum holding and 

processing time requirements for greenwaste chipping and grinding activities in order to 

minimize ammonia and VOC emissions from inadvertent decomposition associated with 

stockpiling and to establish new requirements for greenwaste composting. 


affected by the requirements of PAR 1133.1. Based on the assumption that most of these 

affected facilities are already in compliance with the proposed amendments to Rule 1133.1, no 

emission reduction is assumed. PR 1133.3 is applicable to 17 existing greenwaste composting 

facilities. Based on the emissions inventory compiled for greenwaste compost facilities in the 

SCAQMD, The total emissions reduction associated with the PR 1133.3 is estimated to be 0.9 

tons of VOC and 0.1 tons of ammonia per day. 

Construction Air Quality Impacts – Criteria Pollutants 

PAR 1133.1 and 1133.3 would incorporate new BMPs for chipping and grinding operations and 

the new requirements for greenwaste composting. For greenwaste composting operations 

processing greenwaste mixed with greater than 5,000 tons per year of foodwaste, the operator 

would be required to install an emission control device for all active phase compost piles 

processing foodwaste. Based on staff research and industry input from greenwaste composting 

facilities located within the District, two facilities currently compost with foodwaste. However, 

these facilities compost less than half of the threshold amount. Therefore, no existing facilities 

are expected to be required to install an emission control device without significant increases of 

foodwaste throughput on an annual basis. However, as a worst case scenario, construction 

emission calculations were conducted for the installation of emission control equipment and an 

associated concrete pad at all 17 affected facilities. Based on information obtained from 

emission control system vendors, the systems would most likely consist of pre-fabricated 



equipment that would be delivered to the facility. Therefore, the construction impacts analyzed 

include: 

• Delivery of the pre-fabricated control equipment to the facility 

• Placement of pre-fabricated control equipment into place at the facility 

• Compaction and surfacing of 150-foot by 150-foot concrete pad for composting 

operations 

• Supply concrete for pad, two concrete walls/berms and footings for blowers 

Table 2-2 summarizes the peak construction emissions due to construction of an emission control 

system and associated concrete pad at the affected facilities. Construction air quality impacts do 

not exceed any applicable significance thresholds. Therefore, construction air quality impacts 

are concluded to be less than significant. 

Table 2-2 

Peak Construction Emissions Due to Installation of an Emission Control System and 

Associated Concrete Pad 

VOC CO Ox SOx PM10 PM2.5 

PEAK COSTRUCTIO lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day 

Total Emissions 2.41 11.25 15.57 0.02 0.95 0.91 

SIGNIFICANCE THRESHOLD 75 550 100 150 150 55 

SIGNIFICANT? NO NO NO NO NO NO 

A detailed construction emissions spreadsheet including construction estimates and assumptions 

is located in Appendix C. 

Operational Air Quality Impacts - Criteria Pollutants 

PAR 1133.1 and PR 1133.3 would incorporate new BMPs for chipping and grinding operations 

and the new requirements for greenwaste composting. No operational air quality impacts are 

expected to occur as a result of the implementation of PAR 1133.1 BMPs that are not already 

occurring. Per PR 1133.3, 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, operators 

would be required to cover each initial active phase pile with finished compost within three 24 

hours of initial pile formation, such that the top is at least six inches thick and the pile is not 

turned for the first seven days of the active phase of composting, which is followed by additional 

watering on the top half of the pile to a three inch depth to the pile, prior to turning, during the 15 

days of the active phase of composting. 

Operational emission calculations were conducted for the incremental increase in loader usage to 

place the finished compost cover on the initial active phase compost piles at the affected 

facilities. As a worst case scenario, it was assumed that all 17 affected facilities would be 

starting a new composting cycle on the same day and placing the finished compost cover on their 

piles. 

Table 2-3 summarizes the peak operational emissions due to the incremental increase of loader 

usage in order to place the finished compost cover at the affected facilities. Operational air 

quality impacts do not exceed any applicable significance thresholds. Therefore, operational air 

quality impacts are concluded to be less than significant. 



Table 2-3 

Peak Operational Emissions Due to Incremental Increased Loader Usage to Place Finished 

Compost Cover 

VOC CO Ox SOx PM10 PM2.5 

PEAK COSTRUCTIO lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day 

Total Emissions 2.98 130 23.7 0.03 1.34 1.34 

SIGNIFICANCE THRESHOLD 75 550 55 150 150 55 

SIGNIFICANT? NO NO NO NO NO NO 

A detailed operational emissions spreadsheet including loader usage estimates and assumptions 

is located in Appendix D. 

The proposed project is intended to reduce VOC and ammonia emissions from greenwaste 

composting and minimize VOC and ammonia emissions from inadvertent decomposition 

associated with stockpiling at chipping and grinding facilities. Any operational modifications or 

site changes initiated to comply with PAR 1133.1 or PR 1133.3 will occur within the boundaries 

of an existing facility. Throughput at affected facilities is not expected to change from current 

operational levels in the near future, but with landfill closures and increased demand in the 

coming years, throughput may increase. However, based on the operational emission 

calculations, the amount of throughput could nearly double before NOx levels would exceed the 

significance threshold. As a result, no operational criteria pollutant air quality impacts are 

expected to occur from the proposed project. Therefore, potential criteria pollutant air quality 

impacts will not be considered further in this Draft Final EA. 

Operational Air Quality Impacts - Toxic Air Contaminants 

In assessing potential impacts from the adoption of proposed rule and amendments, SCAQMD 

staff not only evaluates the potential air quality benefits, but also determines potential health 

risks associated with implementation of the proposed amendments. 

As stated previously, PAR 1133.1 and PR 1133.3 would incorporate new BMPs for chipping and 

grinding operations and new requirements for greenwaste composting. No change in the current 

waste streams that the affected facilities are currently accepting is expected to occur (with the 

possible exception of a potential slight increase in food waste at several of the affected facilities). 

Therefore, no changes in toxicity are expected. As a result, there will be no increase in toxic air 

contaminant emissions from the affected facilities due to the proposed rule or amendments. 

Conclusion 

Based on staff research of greenwaste composting facilities located within the District, no 

existing facilities are expected to be required to install an emission control device. The two 

facilities currently composting with foodwaste would have to more than double their existing 

annual throughput to exceed the 5,000 tons per year threshold level. However, as a worst case 

scenario, construction emission calculations were conducted for the installation of emission 

control equipment and an associated concrete pad at each of the 17 facilities. Based on this 



analysis, construction air quality impacts do not exceed any applicable significance thresholds. 

As a result, no construction air quality impacts are expected to occur from the proposed project. 

Since operators would be required to cover each active phase pile with finished compost within 

three hours of initial pile formation, operational emission calculations were conducted for the 

incremental increase in loader usage at the affected facilities. Based on this analysis, which 

includes all facilities starting a new composting cycle on the same day, operational air quality 

impacts do not exceed any applicable significance thresholds. Therefore, operational air quality 

impacts are concluded to be less than significant. Additionally, no change in the current waste 

streams that the affected facilities are currently accepting is expected to occur (with the possible 

exception of a potential slight increase in food waste at several of the affected facilities, based on 

future city contracts relative to diversion goals). As a result, no operational criteria pollutant or 

toxic air contaminant air quality impacts are expected to occur from the proposed project. 

Significant adverse air quality impacts to sensitive receptors are not expected from implementing 

PAR 1133.1 and PR 1133.3. 

III. e) Historically, the SCAQMD has enforced odor nuisance complaints through SCAQMD 

Rule 402 - Nuisance. The proposed project requires operational modifications to reduce VOC 

and ammonia emissions from greenwaste composting facilities and maximum holding and 

processing time requirements for greenwaste chipping and grinding activities in order to 

minimize ammonia and VOC emissions from inadvertent decomposition associated with 

stockpiling. The overall intent of the proposed rules is to improve air quality by controlling 

VOC and ammonia emissions, which are ozone and PM2.5 precursor pollutants. Controlling 

emissions from decomposition will also reduce odors. The proposed project will not expose 

sensitive receptors to substantial pollutant concentrations or create objectionable odors affecting 

a number of people. Odors are enforced by the LEAs per state law. 

III. g) & h) Significant changes in global climate patterns have recently been associated with 

global warming, an average increase in the temperature of the atmosphere near the Earth’s 

surface, attributed to accumulation of GHG emissions in the atmosphere. GHGs trap heat in the 

atmosphere, which in turn heats the surface of the Earth. Some GHGs occur naturally and are 

emitted to the atmosphere through natural processes, while others are created and emitted solely 

through human activities. The emission of GHGs through the combustion of fossil fuels (i.e., 

fuels containing carbon) in conjunction with other human activities, appears to be closely 

associated with global warming. State law defines GHG to include CO2, CH4, N2O, HFCs, 

PFCs, and SF6. The most common GHG that results from human activity is CO2, followed by 

CH4 and N2O. The combustion processes affected by the proposed project by the off-road 

equipment and on-road vehicles during the construction phase of the project will generate GHG 

emissions, primarily CO2 and CH4, which are evaluated in the following paragraphs. Other 

GHGs cannot be analyzed at this time because emission factors are not currently available or 

they are not associated with construction or boiler combustion emissions. Specifically, the 

following analysis focuses on directly emitted CO2 and CH4 emissions because these are the 

primary GHG pollutants emitted during the combustion process and are the GHG pollutants for 

which emission factors are most readily available. CO2 and CH4 emissions were estimated using 

emission factors from CARB EMFAC2007 and Off-Road 2007 models and EPA’s AP-42. The 

GWP was applied to the CH4 emissions to provide equivalent CO2 emissions so they can be 

added and presented as CO2E emissions. The CO2 and CH4 emission factors and calculations can 

be found in the emission calculation spreadsheets in Appendices C and D . 



The analysis of GHGs is a much different analysis than the analysis of criteria pollutants for the 

following reasons. For criteria pollutants, significance thresholds are based on daily emissions 

because attainment or non-attainment is based on daily exceedances of applicable ambient air 

quality standards. Further, several ambient air quality standards are based on relatively shortterm 

exposure effects on human health, e.g., one-hour and eight-hour, etc. Since the atmospheric 

life of CO2 is approximately 100 years, for example, the effects of GHGs are longer-term, 

affecting global climate over a relatively long time frame. As a result, the SCAQMD’s current 

approach is to evaluate GHG effects over a longer timeframe than a single day. 

As previously discussed, based on staff research of greenwaste composting facilities located 

within the District, no existing facilities are expected to be required to install an emission control 

device. However, as a worst case scenario, construction emission calculations were conducted 

for the installation of emission control equipment and an associated concrete pad. Table 2-4 

provides the total construction CO2E emissions that could occur from the installation of emission 

control equipment and an associated concrete pad at all 17 affected facilities. As shown in Table 

2-4, GHG emissions generated by construction activities are expected to be relatively small and, 

therefore, not significant. 

Table 2-4 

Overall CO2 Equivalent (eq) Increases Due to Construction Activities (metric tons/year) 1 

CO2 CH4 CO2eq 

Annual CO2eq Emission Increases Due to: lb/day lb/day MT/year 

Installing Emission Control System 2,057 .20 17 

1 1 metric ton = 2,205 pounds 

Since operators would be required to cover each active phase pile with finished compost within 

three hours of initial pile formation, operational emission calculations were conducted for the 

incremental increase in loader usage at the affected facilities. Table 2-5 provides the total 

operational CO2E emissions that could occur from the increased loader usage at all 17 affected 

facilities. As shown in Table 2-5, GHG emissions generated by operational activities are 

expected to be relatively small and, therefore, not significant. 

Table 2-5 

Overall CO2 Equivalent (eq) Increases Due to Operational Activities (metric tons/year) 1 

CO2 CH4 CO2eq 

Annual CO2eq Emission Increases Due to: lb/day lb/day MT/year 

Incremental Increase of Loader Usage to Cover 

Active Phase Piles with Finished Compost Cover 

1 1 metric ton = 2,205 pounds 

2,389 0.3 960 

Since GHG emissions are considered cumulative impacts, and the GHG emission increases from 

construction activities associated with the proposed project are considerably below the 10,000 

MT CO2E per year SCAQMD interim significance threshold for industrial projects, significant 



adverse cumulative GHG impacts from the proposed project are not considered significant and, 

as a result, are not expected to contribute appreciably to climate change. Thus, potential GHG 

emission impacts from the proposed project will not be a significant contributor to the current 

global warming or climate change setting. 

Therefore, the proposed project is not expected to result in a significant GHG impact on the 

environment or possibly conflict with an applicable plan, policy, or regulation of an agency 

adopted for the purpose of reducing the emissions of GHG. Since there are no significant 

adverse impacts, no mitigation measures are required. 

Conclusion 

Based on the preceding discussions, PAR 1133.1 and PR 1133.3 are expected to reduce VOC 

and ammonia emissions, which is an air quality benefit. The proposal has no provision that 

would cause a violation of any air quality standard or directly contribute to an existing or 

projected air quality violation. The lower VOC and ammonia emissions would assist in reducing 

overall VOC, PM, and ozone concentrations throughout the District. Since VOC and ammonia 

air quality effects from implementing PAR 1133.1 and PR 1133.3 are seen as benefits, and PAR 

1133.1 and 1133.3 would not cause an exceedance of any of the air quality significance 

thresholds in Table 2-1, air quality impacts are not considered to be cumulatively considerable as 

defined in CEQA Guidelines §15065(h)(1). The analysis of GHGs also concluded that PAR 

1133.1 and PR 1133.3 would not generate significant adverse cumulative GHG impacts. 

Therefore, the proposed project is not expected to result in significant adverse cumulative 

impacts for any criteria or GHG pollutant. 

Thus, PAR 1133.1 and PR 1133.3 are not expected to result in significant adverse air quality 

impacts, and mitigation measures are not required. 

IV. BIOLOGICAL RESOURCES. 


a) Have a substantial adverse effect, 

either directly or through habitat 

modifications, on any species 

identified as a candidate, sensitive, or 

special status species in local or 

regional plans, policies, or regulations, 

or by the California Department of 

Fish and Game or U.S. Fish and 

Wildlife Service? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 



b) Have a substantial adverse effect on 

any riparian habitat or other sensitive 

natural community identified in local 

or regional plans, policies, or 

regulations, or by the California 

Department of Fish and Game or U.S. 

Fish and Wildlife Service? 

c) Have a substantial adverse effect on 

federally protected wetlands as 

defined by §404 of the Clean Water 

Act (including, but not limited to, 

marsh, vernal pool, coastal, etc.) 

through direct removal, filling, 

hydrological interruption, or other 

means? 

d) Interfere substantially with the 

movement of any native resident or 

migratory fish or wildlife species or 

with established native resident or 

migratory wildlife corridors, or 

e) 

impede the use of native wildlife 

nursery sites? 

Conflicting with any local policies or 

ordinances protecting biological 

f) 

resources, such as a tree preservation 

policy or ordinance? 

Conflict with the provisions of an 

adopted Habitat Conservation plan, 

Natural Community Conservation 

Plan, or other approved local, regional, 

or state habitat conservation plan? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 

 


Impacts on biological resources will be considered significant if any of the following criteria 

apply: 

- The project results in a loss of plant communities or animal habitat considered to be rare, 

threatened or endangered by federal, state or local agencies. 

- The project interferes substantially with the movement of any resident or migratory wildlife 

species. 

- The project adversely affects aquatic communities through construction or operation of the 

project. 



Discussion 

IV.a), b), c), & d) PAR 1133.1 and PR 1133.3 would not require any new development or 


and grinding operations and the new requirements for greenwaste composting. As a result, PARs 

PAR 1133.1 and PR 1133.3 would not directly or indirectly affect any species identified as a 

candidate, sensitive or special status species, riparian habitat, federally protected wetlands, or 

migratory corridors. For these same reasons, PAR 1133.1 and PR 1133.3 are not expected to 

adversely affect special status plants, animals, or natural communities. 

IV.e) & f) PAR 1133.1 and PR 1133.3 would not conflict with local policies or ordinances 

protecting biological resources or local, regional, or state conservation plans because they would 

not cause new development. Additionally, PAR 1133.1 and PR 1133.3 would not conflict with 

any Habitat Conservation Plan, Natural Community Conservation Plan, or any other relevant 

habitat conservation plan for the same reason identified in Item IV. a), b), c), and d) above. 

Likewise, the rules would not in any way impact wildlife or wildlife habitat. 

The SCAQMD, as the Lead Agency for the proposed project, has found that, when considering 

the record as a whole, there is no evidence that the proposed project will have potential for any 

new adverse effects on wildlife resources or the habitat upon which wildlife depends. 

Accordingly, based upon the preceding information, the SCAQMD has, on the basis of 

substantial evidence, rebutted the presumption of adverse effect contained in §753.5 (d), Title 14 

of the California Code of Regulations. 

Based upon these considerations, significant adverse biological resources impacts are not 

anticipated and will not be further analyzed in this Draft Final EA. Since no significant adverse 

biological resources impacts were identified, no mitigation measures are necessary or required. 

V. CULTURAL RESOURCES. Would 

the project: 

a) Cause a substantial adverse change in 

the significance of a historical 

b) 

resource as defined in §15064.5? 

Cause a substantial adverse change in 

the significance of an archaeological 

resource as defined in §15064.5? 

c) Directly or indirectly destroy a unique 

paleontological 

feature? 

resource, site, or 

d) Disturb any human remains, including 

those interred outside formal 

cemeteries? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 




Impacts to cultural resources will be considered significant if: 

- The project results in the disturbance of a significant prehistoric or historic archaeological 

site or a property of historic or cultural significance to a community or ethnic or social group. 

- Unique paleontological resources are present that could be disturbed by construction of the 

proposed project. 

- The project would disturb human remains. 

Discussion 

V. a), b), c), & d) PAR 1133.1 and PR 1133.3 would not require any new development or 


and grinding operations and the new requirements for greenwaste composting. All of the 

affected activities occur within existing facilities. No construction is expected for any currently 

existing facility to meet the requirements of PAR 1133.1 and PR 1133.3. As a result, no impacts 

to historical resources are anticipated to occur as a result of implementing the proposed project. 

PAR 1133.1 and PR 1133.3 are not expected to require physical changes to the environment, 

which may disturb historical, paleontological or archaeological resources. Since there is no 

expected construction on previously undisturbed areas related to PAR 1133.1 and PR 1133.3, the 

proposed project is not expected to disturb any human remains. 

Based on staff research of greenwaste composting facilities located within the District, no 

existing facilities are expected to be required to install an emission control device. However, as 

a worst case scenario, construction emission calculations were conducted for the installation of 

emission control equipment and an associated concrete pad. These construction emissions are 

further discussed in Section III. b), c), d) & f). The installation of a concrete pad may disturb 

immediate surficial soils due to limited grading/leveling activities. However, these activities are 

expected to be taking place at an already existing greenwaste composting facility where soils 

have already been disturbed due to initial development activities. Therefore, it is unlikely that 

any cultural resources would be uncovered or disturbed as the result of the installation of an 

emission control system. 

Based upon these considerations, significant adverse cultural resources impacts are not expected 

from the implementing PAR 1133.1 and PR 1133.3 and will not be further assessed in this Draft 

Final EA. Since no significant adverse cultural resources impacts were identified, no mitigation 

measures are necessary or required. 

VI. EERGY. Would the project: 

a) Conflict with adopted energy 

conservation plans? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 



b) Result in the need for new or 

substantially altered power or natural 

gas utility systems? 

c) Create any significant effects on local 

or regional energy supplies and on 

requirements for additional energy? 

d) Create any significant effects on peak 

and base period demands for 

electricity and other forms of energy? 

e) Comply 

standards? 

with existing energy 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 


Impacts to energy and mineral resources will be considered significant if any of the following 

criteria are met: 

- The project conflicts with adopted energy conservation plans or standards. 

- The project results in substantial depletion of existing energy resource supplies. 

- An increase in demand for utilities impacts the current capacities of the electric and natural 

gas utilities. 

- The project uses non-renewable resources in a wasteful and/or inefficient manner. 

Discussion 

VI. a) & e) The proposed project is intended to reduce VOC and ammonia emissions from 

greenwaste composting and minimize VOC and ammonia emissions from inadvertent 

decomposition associated with stockpiling at chipping and grinding facilities. PAR 1133.1 

would require new BMPs for chipping and grinding operations and PR 1133.3 includes new 

requirements for greenwaste composting. The proposed rule and amendments are not expected to 

create any additional demand for energy at any of the affected facilities. Since it is unlikely that 

the affected facilities would require new equipment or modifications, it is unlikely that energy 

demand requirements would change. As a result, PAR 1133.1 and PR 1133.3 would not conflict 

with energy conservation plans, use non-renewable resources in a wasteful manner, or result in 

the need for new or substantially altered power or natural gas systems. Since PAR 1133.1 and 

PR 1133.3 would affect primarily existing facilities, it will not conflict with adopted energy 

conservation plans because existing facilities would be expected to continue implementing any 

existing energy conservation plans. Additionally, operators of affected facilities are expected to 

implement existing energy conservation plans or comply with energy standards to minimize 

operating costs. Accordingly these impact issues will not be further analyzed in the draft Final 

EA. 

VI. b), c) & d) PAR 1133.1 and PR 1133.3 would require new BMPs for chipping and grinding 

operations and PR 1133.3 includes new requirements for greenwaste composting. The proposed 



amendments are not expected to increase any electricity or natural gas demand in any way and 

would not create any significant effects on peak and base period demands for electricity and 

other forms of energy. If a facility is required or chooses to install an emission control device, 

the associated increased energy usage is expected to be minimal. 

PAR 1133.1 and PR 1133.3 are not expected to generate significant adverse energy resources 

impacts and will not be discussed further in this Draft Final EA. Since no significant energy 

impacts were identified, no mitigation measures are necessary or required. 

VII. GEOLOGY AD SOILS. Would 

the project: 

a) Expose people or structures to 

potential substantial adverse effects, 

including the risk of loss, injury, or 

death involving: 

• Rupture of a known earthquake 

fault, as delineated on the most 

recent Alquist-Priolo Earthquake 

Fault Zoning Map issued by the 

State Geologist for the area or 

based on other substantial 

evidence of a known fault? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

• Strong seismic ground shaking? 

• Seismic–related ground failure, 

including liquefaction? 

 

b) Result in substantial soil erosion or the 

loss of topsoil? 

 

c) Be located on a geologic unit or soil 

that is unstable or that would become 

unstable as a result of the project, and 

potentially result in on- or off-site 

landslide, lateral spreading, 

d) 

subsidence, liquefaction or collapse? 

Be located on expansive soil, as 

defined in Table 18-1-B of the 

Uniform Building Code (1994), 

creating substantial risks to life or 

property? 

 

 



e) Have soils incapable of adequately 

supporting the use of septic tanks or 

alternative wastewater disposal 

systems where sewers are not 

available for the disposal of 

wastewater? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 


Impacts on the geological environment will be considered significant if any of the following 

criteria apply: 

- Topographic alterations would result in significant changes, disruptions, displacement, 

excavation, compaction or over covering of large amounts of soil. 

- Unique geological resources (paleontological resources or unique outcrops) are present that 

could be disturbed by the construction of the proposed project. 

- Exposure of people or structures to major geologic hazards such as earthquake surface 

rupture, ground shaking, liquefaction or landslides. 

- Secondary seismic effects could occur which could damage facility structures, e.g., 

liquefaction. 

- Other geological hazards exist which could adversely affect the facility, e.g., landslides, 

mudslides. 

Discussion 

VII. a) Southern California is an area of known seismic activity. Structures must be designed to 

comply with the Uniform Building Code Zone 4 requirements if they are located in a seismically 

active area. The local city or county is responsible for assuring that a proposed project complies 

with the Uniform Building Code as part of the issuance of the building permits and can conduct 

inspections to ensure compliance. The Uniform Building Code is considered to be a standard 

safeguard against major structural failures and loss of life. The goal of the code is to provide 

structures that will: 1) resist minor earthquakes without damage; 2) resist moderate earthquakes 

without structural damage but with some non-structural damage; and 3) resist major earthquakes 

without collapse but with some structural and non-structural damage. 

The Uniform Building Code bases seismic design on minimum lateral seismic forces (“ground 

shaking”). The Uniform Building Code requirements operate on the principle that providing 

appropriate foundations, among other aspects, helps to protect buildings from failure during 

earthquakes. The basic formulas used for the Uniform Building Code seismic design require 

determination of the seismic zone and site coefficient, which represent the foundation conditions 

at the site. Accordingly, buildings and equipment at existing affected facilities are likely to 

conform with the Uniform Building Code and all other applicable state codes in effect at the time 

they were constructed. 



No new buildings or structures are expected to be constructed in response to the proposed 

project. Additionally, no modification to existing equipment would be necessary. Therefore, 

PAR 1133.1 and PR 1133.3 are not expected to affect a facility’s ability to continue to comply 

with any applicable Uniform Building Code requirements. Consequently, PAR 1133.1 and PR 

1133.3 are not expected to expose persons or property to geological hazards such as earthquakes, 

landslides, mudslides, ground failure, or other natural hazards. As a result, substantial exposure 

of people or structure to the risk of loss, injury, or death involving seismic-related activities is 

not anticipated and will not be further analyzed in this draft Final EA. 

VII. b), c), d) & e) Since PAR 1133.1 and PR 1133.3 would affect primarily existing facilities, 

it is expected that the soil types present at the affected facilities that are susceptible to expansion 

or liquefaction would be considered part of the existing setting. New subsidence impacts are not 

anticipated since no excavation, grading, or fill activities will occur at affected facilities. 

Further, the proposed project does not involve drilling or removal of underground products (e.g., 

water, crude oil, et cetera) that could produce new, or make worse existing subsidence effects. 

Additionally, the affected areas are not envisioned to be prone to new risks from landslides or 

have unique geologic features, since the affected facilities are located in industrial or commercial 

areas where such features have already been altered or removed. Finally, since adoption of PAR 

1133.1 and PR 1133.3 would be expected to affect operations at primarily existing facilities, the 

proposed project is not expected to alter or make worse any existing potential for subsidence, 

liquefaction, etc. 

Based on the above discussion, the proposed project is not expected to have an adverse impact 

on geology or soils. Since no significant adverse impacts are anticipated, this environmental 

topic will not be further analyzed in the draft Final EA. No mitigation measures are necessary or 

required. 

VIII. HAZARDS AD HAZARDOUS 

MATERIALS. Would the project: 

a) Create a significant hazard to the 

public or the environment through the 

routine transport, use, and disposal of 

hazardous materials? 

b) Create a significant hazard to the 

public or the environment through 

reasonably foreseeable upset 

conditions involving the release of 

hazardous 

environment? 

materials into the 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 



c) Emit hazardous emissions, or handle 

hazardous or acutely hazardous 

d) 

materials, substances, or waste within 

one-quarter mile of an existing or 

proposed school? 

Be located on a site which is included 

on a list of hazardous materials sites 

compiled pursuant to Government 

Code §65962.5 and, as a result, would 

create a significant hazard to the 

public or the environment? 

e) For a project located within an airport 

land use plan or, where such a plan has 

not been adopted, within two miles of 

a public use airport or a private 

airstrip, would the project result in a 

safety hazard for people residing or 

working in the project area? 

f) Impair implementation of or 

physically interfere with an adopted 

emergency response plan or 

g) 

emergency evacuation plan? 

Expose people or structures to a 

significant risk of loss, injury or death 

involving wildland fires, including 

where wildlands are adjacent to 

h) 

urbanized areas or where residences 

are intermixed with wildlands? 

Significantly increased fire hazard in 

areas with flammable materials? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 

 

 


Impacts associated with hazards will be considered significant if any of the following occur: 

- Non-compliance with any applicable design code or regulation. 

- Non-conformance to National Fire Protection Association standards. 

- Non-conformance to regulations or generally accepted industry practices related to operating 

policy and procedures concerning the design, construction, security, leak detection, spill 

containment or fire protection. 

- Exposure to hazardous chemicals in concentrations equal to or greater than the Emergency 

Response Planning Guideline (ERPG) 2 levels. 



Discussion 

VIII. a, b) & c) The proposed project will not create a significant hazard to the public or the 

environment through the routine transport, use, and disposal of hazardous materials, due to the 

fact that the proposed rules do not require the transport, use, and disposal of hazardous materials. 

The reason for this conclusion is that chipping and grinding and composting facilities do not 

typically use hazardous materials or produce hazardous waste as part of their operating process 

or procedures. Further, based on the fact that the proposed rules do not require the transport, use 

and disposal of hazardous materials, PAR 1133.1 and PR 1133.3 will not create a significant 

hazard to the public or environment through a reasonably foreseeable release of these materials 

into the environment. 

Based on the above facts, there is little likelihood that affected facilities will emit hazardous 

emissions or handle hazardous materials, substances or waste within one-quarter mile of an 

existing or proposed school as a result of implementing the proposed rules. Chipping and 

grinding and greenwaste composting facilities are typically located in light industrial or 

commercial areas. Further, PAR 1133.1 and PR 1133.3 are intended to reduce overall VOC and 

ammonia emissions in the district. It is expected that the proposed rules would improve air 

quality, visibility and reduce odors surrounding existing facilities and, would do likewise for any 

existing or proposed schools within one-quarter mile of affected facilities. 

VIII. d) Government Code §65962.5 typically refers to a list of facilities that may be subject to 

Resource Conservation and Recovery Act (RCRA) permits. Most facilities affected by PAR 

1133.1 or PR 1133.3 are not expected to be on this list, and would not typically handle hazardous 

materials or generate large quantities of hazardous waste. For any facilities affected by the 

proposed rule that are on the Government Code §65962.5 list, it is anticipated that they would 

continue to manage any and all hazardous materials and hazardous waste, in accordance with 

federal, state and local regulations. 

VIII. e) Since PAR 1133.1 and PR 1133.3 would incorporate the new BMPs for chipping and 

grinding operations and the new requirements for greenwaste composting, implementation of 

PAR 1133.1 and PR 1133.3 is not expected to increase or create any new hazardous emissions in 

general, which could adversely affect public/private airports located in close proximity to the 

affected sites. Implementation of PAR 1133.1 and PR 1133.3 is not expected to create any 

additional safety hazards for people residing or working in the project area. 

VIII. f) The proposed project will not impair implementation of, or physically interfere with any 

adopted emergency response plan or emergency evacuation plan. Any existing commercial or 

light industrial facilities affected by the proposed project will typically have their own 

emergency response plans. Any new facilities will be required to prepare emergency response 

and evacuation plans as part of the land use permit review and approval process conducted by 

local jurisdictions for new development. Emergency response plans are typically prepared in 

coordination with the local city or county emergency plans to ensure the safety of not only the 

public (surrounding local communities), but the facility employees as well. Since the proposed 

project does not involve the use of hazardous materials, or generate hazardous waste, no changes 

to emergency response plans are anticipated. 

Health and Safety Code §25506 specifically requires all businesses handling hazardous materials 

to submit a business emergency response plan to assist local administering agencies in the 



emergency release or threatened release of a hazardous material. Business emergency response 

plans generally require the following: 

1. Identification of individuals who are responsible for various actions, including reporting, 

assisting emergency response personnel and establishing an emergency response team; 

2. Procedures to notify the administering agency, the appropriate local emergency rescue 

personnel, and the California Office of Emergency Services; 

3. Procedures to mitigate a release or threatened release to minimize any potential harm or 

damage to persons, property or the environment; 

4. Procedures to notify the necessary persons who can respond to an emergency within the 

facility; 

5. Details of evacuation plans and procedures; 

6. Descriptions of the emergency equipment available in the facility; 

7. Identification of local emergency medical assistance; and 

8. Training (initial and refresher) programs for employees in: 

a. The safe handling of hazardous materials used by the business; 

b. Methods of working with the local public emergency response agencies; 

c. The use of emergency response resources under control of the handler; and 

d. Other procedures and resources that will increase public safety and prevent or 

mitigate a release of hazardous materials. 

In general, every county or city and all facilities using a minimum amount of hazardous materials 

are required to formulate detailed contingency plans to eliminate, or at least minimize, the 

possibility and effect of fires, explosion, or spills. In conjunction with the California Office of 

Emergency Services, local jurisdictions have enacted ordinances that set standards for area and 

business emergency response plans. These requirements include immediate notification, 

mitigation of an actual or threatened release of a hazardous material, and evacuation of the 

emergency area. Adopting PAR 1133.1 and 1133.3 is not expected to hinder in any way with the 

above business emergency response plan requirements. 

VIII. g) Since the affected facilities are located in industrial or commercial areas where 

wildlands are typically not prevalent, risk of loss or injury associated with wildland fires is not 

expected as a result of implementing PAR 1133.1 and PR 1133.3. 

VIII. h) Chipping and grinding and greenwaste composting facilities must comply with all local 

and county requirements for fire prevention and safety. The proposed project does not require 

any activities which would be in conflict with fire prevention and safety requirements, and thus 

would not create or increase fire hazards at these existing facilities. Further, facilities affected by 

the proposed rules do not typically include the routine use of flammable materials in their daily 

operations. As a result, the proposed project is not expected to increase fire hazards at facilities 

subject to the provisions of the proposed rules 



PAR 1133.1 and PR 1133.3 are intended to reduce VOC and ammonia emissions from 

greenwaste composting and minimize VOC and ammonia emissions from inadvertent 

decomposition associated with stockpiling at chipping and grinding facilities. Typically these 

facilities do not use or store flammable materials. The process of decomposition of materials in 

a compost pile creates heat, which may create a fire potential, if not properly managed. Pursuant 

to local and county fire prevention and safety requirements, facilities are required to maintain 

appropriate site management practices to prevent fire hazards. PAR 1131.1 and PR 1133.3 will 

not interfere with fire prevention practices. 

In conclusion, potentially significant adverse hazard or hazardous material impacts resulting 

from adopting and implementing PAR 1133.1 and 1133.3 are not expected and will not be 

considered further. No mitigation measures are necessary or required. 

IX. HYDROLOGY AD WATER 

QUALITY. Would the project: 

a) Violate any water quality standards, 

waste discharge requirements, exceed 

wastewater treatment requirements of 

the applicable Regional Water Quality 

Control Board, or otherwise 

substantially degrade water quality? 

b) Substantially deplete groundwater 

supplies or interfere substantially with 

groundwater recharge such that there 

would be a net deficit in aquifer 

volume or a lowering of the local 

groundwater table level (e.g. the 

production rate of pre-existing nearby 

wells would drop to a level which 

would not support existing land uses 

or planned uses for which permits 

have been granted)? 

c) Substantially alter the existing 

drainage pattern of the site or area, 

including through alteration of the 

course of a stream or river, or 

substantially increase the rate or 

amount of surface runoff in a manner 

that would result in substantial erosion 

or siltation on- or off-site or flooding 

on- or off-site? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 



d) Create or contribute runoff water 

which would exceed the capacity of 

existing or planned storm water 

drainage systems or provide 

substantial additional sources of 

e) 

polluted runoff? 

Place housing or other structures 

within a 100-year flood hazard area as 

mapped on a federal Flood Hazard 

Boundary or Flood Insurance Rate 

Map or other flood hazard delineation 

map, which would impede or redirect 

flood flows? 

f) Expose people or structures to a 

significant risk of loss, injury or death 

involving flooding, including flooding 

as a result of the failure of a levee or 

dam, or inundation by seiche, tsunami, 

or mudflow? 

g) Require or result in the construction of 

new water or wastewater treatment 

facilities or new storm water drainage 

facilities, or expansion of existing 

facilities, the construction of which 

could cause significant environmental 

effects? 

h) Have sufficient water supplies 

available to serve the project from 

existing entitlements and resources, or 

are new or expanded entitlements 

needed? 

i) Result in a determination by the 

wastewater treatment provider which 

serves or may serve the project that it 

has adequate capacity to serve the 

project’s projected demand in addition 

to the provider’s existing 

commitments? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 

 

 




Potential impacts on water resources will be considered significant if any of the following 

criteria apply: 

Water Demand: 

- The existing water supply does not have the capacity to meet the increased demands of the 

project, or the project would use more than 262,820 gallons per day of potable water. 

- The project increases demand for total water by more than five million gallons per day. 

Water Quality: 

- The project will cause degradation or depletion of ground water resources substantially 

affecting current or future uses. 

- The project will cause the degradation of surface water substantially affecting current or 

future uses. 

- The project will result in a violation of National Pollutant Discharge Elimination System 

(NPDES) permit requirements. 

- The capacities of existing or proposed wastewater treatment facilities and the sanitary sewer 

system are not sufficient to meet the needs of the project. 

- The project results in substantial increases in the area of impervious surfaces, such that 

interference with groundwater recharge efforts occurs. 

- The project results in alterations to the course or flow of floodwaters. 

Discussion 

IX. a), b), c), d) & g) If adopted, PAR 1133.1 and PR 1133.3 would incorporate new BMPs for 

chipping and grinding operations and new requirements for greenwaste composting. PR 1133.3 

would require applying water to the surface of the compost piles so that three inches in depth of 

the pile is wet. Since most compost piles are already watered for the composting process, the 

additional irrigation would not be difficult for most of the composting facility operators. 

Staff calculated the worst case 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%. Under PR 1133.3, the piles are to 

have water applied to make the piles “wet” before turning. Based on comments received from 

the composting industry, “wet” material would have a moisture content of about 75%. 

According to the reference, this moisture content would have a free air space of 23%. Assuming 

the material itself is saturated, the amount of water to be applied to make the material “wet” is 

represented by the difference in the moisture content (22%), thereby filling the free air space. 

Using standardized 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 

affected facilities, the worst case one-day water use would be about 106,000 gallons, of which 

approximately 55,4000 gallons is potable and approximately 510,9000 gallons is reclaimed or 

untreated well or canal water. These amounts fall below the significance levels of water use for 

CEQA of 262,820 gallons of potable water or five million gallons total water per day, and 

represent worst case consumption. It should be noted that the facilities currently use more than 



50 million gallons of water per year and the operations may adjust the application times to 

accommodate the rule requirements. For example, watering the piles before turning as opposed 

to after. 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. 

Based on the above staff calculations, only a small amount of increased water usage is expected 

due to the proposed rule. Additionally, affected facilities are already required to water stockpiles 

during turning activities per AQMD Rule 403 – Fugitive Dust. 

Because only the top three inches of the pile irrigated becomes wet, there would be no water runoff 

problems associated with additional watering. No additional wastewater generation is 

expected to result from the proposed project. Further, PAR 1133.1 and PR 1133.3 have no 

provision that would require the construction of additional water resource facilities, increase the 

need for new or expanded water entitlements, or alter existing drainage patterns. The proposed 

project would not substantially deplete groundwater supplies or interfere substantially with 

groundwater recharge. PAR 1133.1 and PR 1133.3 would not create or contribute runoff water 

that would exceed the capacity of existing or planned stormwater drainage systems or provide 

substantial additional sources of polluted runoff. Further, the adoption of PAR 1133.1 and PR 

1133.3 would not create a change in the current volume of existing wastewater streams from the 

affected facilities. In addition, the proposed amended rules are not expected to require additional 

wastewater disposal capacity, violate any water quality standard or wastewater discharge 

requirements, or otherwise substantially degrade water quality. 

Adoption of PAR 1133.1 and PR 1133.3 could affect future operations at existing facilities that 

are typically located in industrial or commercial areas that are paved and already have drainage 

infrastructures in place. Based on the current greenwaste composting facility inventory in the 

District, implementation of PAR 1133.1 and PR 1133.3 is not expected to involve major 

construction activities including site preparation, grading, etc., so no changes to storm water 

runoff, drainage patterns, groundwater characteristics, or flow are expected. Therefore, these 

impact areas are not expected to be affected by PAR 1133.1 and PR 1133.3. 

PAR 1133.1 and PR 1133.3 are not expected to have significant adverse water demand or water 

quality impacts for the following reasons: 

• The proposed project does not increase demand for water by more than 5,000,000 

gallons per day. 

• The proposed project does not require construction of new water conveyance 

infrastructure. 

• The proposed project does not create a substantial increase in mass inflow of 

effluents to public wastewater treatment facilities. 

• The proposed project does not result in a substantial degradation of surface water 

or groundwater quality. 

• The proposed project does not result in substantial increases in the area of 

impervious surfaces, such that interference with groundwater recharge efforts 

occurs. 



• The proposed project does not result in alterations to the course or flow of 

floodwaters. 

IX. i) The proposed project is not expected to change existing operations at affected facilities, 

nor would it result in the generation of increased volumes of wastewater, because only a small 

amount of increased water usage if any is expected due to the proposed rule. As a result, there 

are no potential changes in wastewater volume expected from facilities as a result of the adoption 

of PAR 1133.1 and PR 1133.3. It is expected that facilities and operations will continue to 

handle wastewater generated in a similar manner and with the same equipment as the wastewater 

that is currently generated. Further, PAR 1133.1 and PR 1133.3 are not expected to cause 

affected facilities to violate any water quality standard or wastewater discharge requirements 

since there would be no additional wastewater volumes generated as a result of adopting PAR 

1133.1 and PR 1133.3. 

IX. e), f) & h) The proposed project would incorporate new BMPs for chipping and grinding 

operations and the new requirements for greenwaste composting. As a result, PAR 1133.1 and 

PR 1133.3 would not require construction of new housing, contribute to the construction of new 

building structures, or require modifications or changes to existing structures. Further, PAR 

1133.1 and PR 1133.3 are not expected to require additional workers at affected facilities 

because the proposed project does not affect how equipment is operated. Therefore, PAR 1133.1 

and PR 1133.3 are not expected to generate construction of any new structures in 100-year flood 

areas as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other 

flood delineation map. As a result, PAR 1133.1 and PR 1133.3 are not expected to expose 

people or structures to significant new flooding risks, or make worse any existing flooding risks. 

Because PAR 1133.1 and PR 1133.3 would not require construction of new structures or the 

addition of new employees, PAR 1133.1 and PR 1133.3 will not affect in any way any potential 

flood hazards inundation by seiche, tsunami, or mud flow that may already exist relative to 

existing facilities or create new hazards at existing facilities. Additionally, since PAR 1133.1 

and PR 1133.3 do not require additional water usage or demand, sufficient water supplies are 

expected to be available to serve the project from existing entitlements and resources, and no 

new or expanded entitlements would be needed. 

Based upon these considerations, significant hydrology and water quality impacts are not 

expected from the adoption of PAR 1133.1 and PR 1133.3 and will not be further analyzed in 

this draft Final EA. Since no significant hydrology and water quality impacts were identified, no 

mitigation measures are necessary or required. 



X. LAD USE AD PLAIG. 


a) Physically divide an established 

b) 

community? 

Conflict with any applicable land use 

plan, policy, or regulation of an 

agency with jurisdiction over the 

project (including, but not limited to 

the general plan, specific plan, local 

coastal program or zoning ordinance) 

adopted for the purpose of avoiding or 

mitigating an environmental effect? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 


Land use and planning impacts will be considered significant if the project conflicts with the 

land use and zoning designations established by local jurisdictions. 

Discussion 

X. a) PAR 1133.1 and PR 1133.3 would not require any new development or require 

modifications to buildings or other structures to comply with the new BMPs for chipping and 

grinding operations and the new requirements for greenwaste composting at any of the currently 

existing facilities. Therefore, PAR 1133.1 and PR 1133.3 do not include any components that 

would require physically dividing an established community. 

X. b) There are no provisions in PAR 1133.1 and PR 1133.3 that would affect land use plans, 

policies, or regulations. Land use and other planning considerations are determined by local 

governments and no land use or planning requirements would be altered by the new BMPs for 

chipping and grinding operations and the new requirements for greenwaste composting. 

Therefore, as already noted in the discussion under “Biological Resources,” PAR 1133.1 and PR 

1133.3 would not affect in any habitat conservation or natural community conservation plans, 

agricultural resources or operations, and would not create divisions in any existing communities. 

Present or planned land uses in the region would not be significantly adversely affected as a 

result of implementing the proposed amended rules. 

Based upon these considerations, significant adverse land use and planning impacts are not 

expected from the implementation of PAR 1133.1 and PR 1133.3 and will not be further 

analyzed in this Draft Final EA. Since no significant land use and planning impacts were 

identified, no mitigation measures are necessary or required. 



XI. MIERAL RESOURCES. Would 

the project: 

a) Result in the loss of availability of a 

known mineral resource that would be 

of value to the region and the residents 

of the state? 

b) Result in the loss of availability of a 

locally-important mineral resource 

recovery site delineated on a local 

general plan, specific plan or other 

land use plan? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 


Project-related impacts on mineral resources will be considered significant if any of the 

following conditions are met: 

- The project would result in the loss of availability of a known mineral resource that would be 

of value to the region and the residents of the state. 

- The proposed project results in the loss of availability of a locally-important mineral resource 

recovery site delineated on a local general plan, specific plan or other land use plan. 

Discussion 

XI. a) & b) There are no provisions in PAR 1133.1 and PR 1133.3 that would result in the loss 

of availability of a known mineral resource of value to the region and the residents of the state, 

or of a locally-important mineral resource recovery site delineated on a local general plan, 

specific plan or other land use plan because compliance with PAR 1133.1 and PR 1133.3 does 

not require mineral resources such as sand, gravel, etc. 

Based upon the above considerations, significant adverse mineral resources impacts are not 

expected from the implementation of PAR 1133.1 and PR 1133.3 and will not be further 

analyzed in this Draft Final EA. Since no significant mineral resources impacts were identified, 

no mitigation measures are necessary or required. 



XII. OISE. Would the project result in: 

a) Exposure of persons to or generation 

of permanent noise levels in excess of 

standards established in the local 

general plan or noise ordinance, or 

applicable standards of other agencies? 

b) Exposure of persons to or generation 

of excessive groundborne vibration or 

groundborne noise levels? 

c) A substantial temporary or periodic 

increase in ambient noise levels in the 

project vicinity above levels existing 

without the project? 

d) For a project located within an airport 

land use plan or, where such a plan has 

not been adopted, within two miles of 

a public use airport or private airstrip, 

would the project expose people 

residing or working in the project area 

to excessive noise levels? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 


Impacts on noise will be considered significant if: 

- Construction noise levels exceed the local noise ordinances or, if the noise threshold is 

currently exceeded, project noise sources increase ambient noise levels by more than three 

decibels (dBA) at the site boundary. Construction noise levels will be considered significant 

if they exceed federal Occupational Safety and Health Administration (OSHA) noise 

standards for workers. 

- The proposed project operational noise levels exceed any of the local noise ordinances at the 

site boundary or, if the noise threshold is currently exceeded, project noise sources increase 

ambient noise levels by more than three dBA at the site boundary. 

Discussion 

XII. a) PAR 1133.1 and PR 1133.1 would incorporate new BMPs for chipping and grinding 

operations and the new requirements for greenwaste composting. PAR 1133.1 and PR 1133.3 

would not require any new development or require modifications to buildings or other structures 

to comply with the proposed amended rules at any of the currently existing facilities. All of the 

affected activities occur within existing facilities. Compliance with the new BMPs for chipping 

and grinding operations and the new requirements for greenwaste composting are not expected to 

adversely affect operations at affected facilities. Thus, the proposed project is not expected to 

expose persons to the generation of excessive noise levels above current facility levels. It is 

expected that any facility affected by PAR 1133.1 and PR 1133.3 would continue complying 

with all existing local noise control laws or ordinances. 



In commercial environments, Occupational Safety and Health Administration (OSHA) and 

California-OSHA have established noise standards to protect worker health. It is expected that 

operators at affected facilities will continue complying with applicable OSHA or Cal/OSHA 

noise standards, which would limit noise impacts to workers, patrons and neighbors. 

XII. b) PAR 1133.1 and PR 1133.3 are not anticipated to expose people to, or generate 

excessive groundborne vibration or groundborne noise levels since complying with PAR 1133.1 

and PR 1133.3 is not expected to alter operations at affected facilities. Therefore, any existing 

noise or vibration levels at affected facilities are not expected to change as a result of 

implementing PAR 1133.1 and PR 1133.3. Since existing operations are not expected to 

generate excessive groundborne vibration or noise levels, and PAR 1133.1 and PR 1133.3 are 

not expected to alter physical operations, no groundborne vibrations or noise levels are expected 

from the proposed amended rules. 

XII. c) A permanent increase in ambient noise levels at the existing affected facilities above 

existing levels as a result of implementing the proposed project is unlikely to occur because the 

physical operations are not expected to change at affected facilities. The existing noise levels are 

unlikely to change and raise ambient noise levels in the vicinities of the existing facilities to 

above a level of significance, because implementation of new BMPs for chipping and grinding 

operations and the new requirements for greenwaste composting is not expected to generate 

higher noise levels than are already occurring. 

No increase in periodic or temporary ambient noise levels in the vicinity of affected facilities 

above levels existing prior to PAR 1133.1 and PR 1133.3 is anticipated because the proposed 

project would not require substantial changes to any of the currently existing facilities. As 

indicated earlier, operational noise levels are expected to be equivalent to existing noise levels. 

PR 1133.3 may include some construction activities, should the facilities be required or choose 

to install control equipment. Sources which may be expected to generate noise during temporary 

construction activities might include earth-moving equipment, cement trucks, work-crew 

vehicular traffic, compressors and generators. Table 2-6 presents a range of noise levels for 

various types of equipment that may be used at a typical construction site. Because of the nature 

of this activity, the types, numbers, periods of operation, loudness of equipment, and distance to 

the closest sensitive receptor/residence, will vary with each construction phase and the size of the 

composting project. 

TABLE 2-6 

Typical Construction oise Sources 

Equipment Type Typical Range (decibels) 

Tractors/Crawlers/Dozers (up to 450 hp) 78 to 82 

Grader (300 hp) 80 

Diesel Trucks (100 to 400 hp) 72 to 81 

Backhoe (85 hp) 76 

Forklift (40 hp) 75 

Air Compressor (25 hp or 230 hp) 75 or 80 

Generator (22 hp or 550 hp) 73 or 85 



These construction activities (as well as operational activities for the initial covering) will 

increase noise levels for a short duration, but will cease once activities are complete. Further, 

co-composting facilities are typically located in light industrial or rural areas, removed from 

residential communities. Based on current throughput at facilities located within the District, no 

currently existing facilities would be required to install air pollution control equipment. 

Therefore, none of the construction noise referred to above is expected to occur. 

XII. d) Even if an affected facility is located near a public/private airport, there are no new noise 

impacts expected from any of the existing facilities as a result of complying with the proposed 

project. Similarly, any existing noise levels at affected facilities are not expected to increase 

appreciably. Thus, PAR 1133.1 and PR 1133.3 are not expected to expose people residing or 

working in the vicinities of public airports to excessive noise levels. 

Based upon these considerations, significant adverse noise impacts are not expected from the 

implementation of PAR 1133.1 and PR 1133.3 and are not further evaluated in this Draft Final 

EA. Since no significant noise impacts were identified, no mitigation measures are necessary or 

required. 

XIII. POPULATIO AD HOUSIG. 


a) Induce substantial growth in an area 

either directly (for example, by 

proposing new homes and businesses) 

or indirectly (e.g. through extension of 

roads or other infrastructure)? 

b) Displace substantial numbers of 

people or existing housing, 

necessitating the construction of 

replacement housing elsewhere? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 


Impacts of the proposed project on population and housing will be considered significant if the 

following criteria are exceeded: 

- The demand for temporary or permanent housing exceeds the existing supply. 

- The proposed project produces additional population, housing or employment inconsistent 

with adopted plans either in terms of overall amount or location. 

Discussion 

XIII. a) The proposed project is not anticipated to generate any significant adverse effects, 

either direct or indirect, on the district's population or population distribution as no additional 



workers are anticipated to be required for affected facilities to comply with the proposed 

amendments. Human population within the jurisdiction of the SCAQMD is anticipated to grow 

regardless of implementing PAR 1133.1 and PR 1133.3. As such, PAR 1133.1 and PR 1133.3 

would not result in changes in population densities or induce significant growth in population. 

XIII. b) Because the proposed project affects chipping and grinding and greenwaste composting 

facilities, PAR 1133.1 and PR 1133.3 are not expected to result in the creation of any industry 

that would affect population growth, directly or indirectly, induce the construction of single- or 

multiple-family units, or require the displacement of people elsewhere. 

Based upon these considerations, significant adverse population and housing impacts are not 

expected from the implementation of PAR 1133.1 and PR 1133.3 and are not further evaluated in 

this Draft Final EA. Since no significant population and housing impacts were identified, no 

mitigation measures are necessary or required. 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

XIV. PUBLIC SERVICES. Would the 

proposal result in substantial adverse 

physical impacts associated with the 

provision of new or physically altered 

governmental facilities, need for new 

or physically altered government 

facilities, the construction of which 

could cause significant environmental 

impacts, in order to maintain 

acceptable service ratios, response 

times or other performance objectives 

for any of the following public 

services: 

a) Fire protection? 

b) Police protection? 

c) Schools? 

d) Other public facilities? 


Impacts on public services will be considered significant if the project results in substantial 

adverse physical impacts associated with the provision of new or physically altered 

governmental facilities, or the need for new or physically altered government facilities, the 

construction of which could cause significant environmental impacts, in order to maintain 

acceptable service ratios, response time or other performance objectives. 



Discussion 

XIV. a) & b) PAR 1133.1 and PR 1133.3 would implement new BMPs for chipping and 

grinding operations and the new requirements for greenwaste composting. The proposed project 

does not require any action which would alter and, thereby, adversely affect existing public 

services, or require an increase in governmental facilities or services to support the affected 

existing facilities. Current fire, police and emergency services are adequate to serve existing 

facilities, and the proposed project will not result in the need for new or physically altered 

government facilities in order to maintain acceptable service ratios, response times, or other 

performance objectives. 

Because the proposed project does not require or involve the use of hazardous materials or 

hazardous waste, it will not generate an emergency situation that would require additional fire or 

police protection, or impact acceptable service ratios or response times. 

XIV. c) & d) As indicated in discussion under item XIII. Population and Housing, 

implementing PAR 1133.1 and PR 1133.3 would not induce population growth or dispersion 

because no additional workers are expected to be needed at the existing affected facilities. 

Therefore, with no increase in local population anticipated as a result of adopting and 

implementing PAR 1133.1 and PR 1133.3, additional demand for new or expanded schools or 

parks is also not anticipated. As a result, no significant adverse impacts are expected to local 

schools or parks. 

Based upon these considerations, significant adverse public services impacts are not expected 

from the implementation of PAR 1133.1 and PR 1133.3 and are not further evaluated in this 

Draft Final EA. Since no significant public services impacts were identified, no mitigation 


XV. RECREATIO. 

a) Would the project increase the use of 

existing neighborhood and regional 

parks or other recreational facilities 

such that substantial physical 

b) 

deterioration of the facility would 

occur or be accelerated? 

Does the project include recreational 

facilities or require the construction or 

expansion of recreational facilities that 

might have an adverse physical effect 

on the environment or recreational 

services? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 




Impacts to recreation will be considered significant if: 

- The project results in an increased demand for neighborhood or regional parks or other 

recreational facilities. 

- The project adversely affects existing recreational opportunities. 

Discussion 

XV. a) & b) As discussed under “Land Use and Planning” above, there are no provisions in 

PAR 1133.1 and PR 1133.3 that would affect land use plans, policies, or regulations. Land use 

and other planning considerations are determined by local governments and no land use or 

planning requirements will be altered by the proposed amended rules. The proposed project 

would not increase the demand for, or use of existing neighborhood and regional parks or other 

recreational facilities or require the construction of new or expansion of existing recreational 

facilities that might create an adverse physical effect on the environment because it will not 

directly or indirectly increase or redistribute population. 

Based upon these considerations, significant recreation impacts are not expected from the 

implementation of PAR 1133.1 and PR 1133.3 and are not further evaluated in this Draft Final EA. 

Since no significant recreation impacts were identified, no mitigation measures are necessary or 

required. 

XVI. SOLID/HAZARDOUS WASTE. 


a) Be served by a landfill with sufficient 

permitted capacity to accommodate 

the project’s solid waste disposal 

needs? 

b) Comply with federal, state, and local 

statutes and regulations related to solid 

and hazardous waste? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 


The proposed project impacts on solid/hazardous waste will be considered significant if the 

following occurs: 

- The generation and disposal of hazardous and non-hazardous waste exceeds the capacity of 

designated landfills. 



Discussion 

XVI. a) Landfills are permitted by the local enforcement agencies with concurrence from 

CalRecycle, formerly the California Integrated Waste Management Board (CIWMB). Local 

agencies establish the maximum amount of solid waste which can be received by a landfill each 

day and the operational life of a landfill. 

There are three Class I landfills in California: Chemical Waste Management Kettleman Hills in 

Kettleman City, CA; Clean Harbors Buttonwillow in Buttonwillow, CA, and Clean Harbors 

Westmorland in Westemorland, CA. Chemical Waste Management Kettleman Hills has a 

remaining capacity of 7,360,000 cubic yards with an estimated closure date of 2037. Clean 

Harbors Buttonwillow and Westmorland have a remaining capacity of 12,731,000 cubic yards 

with an estimated closure date of 2036. 

Chipping and grinding activities are considered to be a component of the solid waste industry. 

The objective of PAR 1133.1 is to harmonize the rule BMPs for chipping and grinding 

operations in order to minimize VOC and ammonia emissions from inadvertent decomposition 

associated with stockpiling. Some landfills include a chipping and grinding operation onsite, 

which reduces the size of wood and brush, so that the material can be used as alternative daily 

cover (ADC). These operations at landfills would be subject to the requirements of PAR 1133.1. 

As a result, this proposed rule is not expected to adversely impact landfill operations or landfill 

capacity because activities regulated by PAR 1133.1 are already part of the current practices of 

affected chipping and grinding facilities. 

PAR 1133.1 will not require the addition of any costly equipment, building enclosures, or 

generate additional solid waste requiring disposal in local landfills, or transportation out of the 

district. Further, PAR 1133.1 does not include or affect any requirements that would generate, 

store, transport or dispose of hazardous waste and, therefore, will not pose a hazardous waste 

impact. 

Greenwaste composting activities are also considered to be a component of the solid waste 

industry, and a sub-set of the composting industry. PR 1133.3 is intended to reduce VOC and 

ammonia emissions, precursors to PM2.5 and ozone. The requirement for emission reductions at 

existing composting facilities is not expected to impact landfill capacity. The proposed rule 

provides substantial flexibility regarding compliance with the emissions control requirements. 

For this reason, the proposed project is not expected to cause existing facilities to close or divert 

composting feedstock to landfills. Consequently, no significant adverse impacts to landfills are 

expected. 

XVI. b) Existing chipping and grinding and greenwaste composting facilities must currently 

comply with applicable federal, state and local regulations governing solid waste operations. 

The provisions of PAR 1133.1 and PR 1133.3 will not alter, or reduce, the compliance 

requirements for these types of operations. These facilities are typically considered a nonhazardous 

operation and permitted by the CalRecycle and/or a local enforcement agency. 

Additionally, facilities must also comply with Title 14 as permitted and enforced by the LEAs. 

AB939, known as the California Integrated Waste Management Act of 1989 (California Public 

Resources Code Section 40050-40063) was initiated to promote and maximize integrated waste 

management options. The impetus for AB939 was to encourage innovative waste disposal 



practices and reduce the reliance on, and assumption that, the only method for solid waste 

disposal was by landfill. PAR 1133.1 and PR 1133.3 will not have a significant adverse impact 

on the goals and objectives of AB 939. The proposed rules are intended to reduce air pollutant 

emissions, not cause the diversion of feedstock typically sent to composting and related facilities, 

nor cause these activities to cease operations. 

PAR 1133.1 and PR 1133.3 are not expected to increase the volume of solid or hazardous wastes 

from affected facilities, require additional waste disposal capacity, or generate waste that does 

not meet applicable local, state, or federal regulations. With regard to potential wastewater 

impacts, please see the discussion under item IX., “Hydrology and Water Quality.” Since no 

solid/hazardous waste impacts were identified, no mitigation measures are necessary or required. 

XVII. TRASPORTATIO/TRAFFIC. 


a) Conflict with an applicable plan, 

ordinance or policy establishing 

measures of effectiveness for the 

performance of the circulation system, 

taking into account all modes of 

transportation including mass transit 

and non-motorized travel and relevant 

components of the circulation system, 

including but not limited to 

intersections, streets, highways and 

freeways, pedestrian and bicycle 

b) 

paths, and mass transit? 

Conflict with an applicable congestion 

management program, including but 

not limited to level of service 

standards and travel demand measures, 

or other standards established by the 

county congestion management 

agency for designated roads or 

c) 

highways? 

Result in a change in air traffic 

patterns, including either an increase 

in traffic levels or a change in location 

that results in substantial safety risks? 

d) Substantially increase hazards due to a 

design feature (e.g. sharp curves or 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

 



dangerous intersections) or 

incompatible uses (e.g. farm 

equipment)? 

e) Result 

access? 

in inadequate emergency 

f) Conflict with adopted policies, plans, 

or programs regarding public transit, 

bicycle, or pedestrian facilities, or 

otherwise decrease the performance or 

safety of such facilities? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 


Impacts on transportation/traffic will be considered significant if any of the following criteria 

apply: 

- Peak period levels on major arterials are disrupted to a point where level of service (LOS) is 

reduced to D, E or F for more than one month. 

- An intersection’s volume to capacity ratio increase by 0.02 (two percent) or more when the 

LOS is already D, E or F. 

- A major roadway is closed to all through traffic, and no alternate route is available. 

- The project conflicts with applicable policies, plans or programs establishing measures of 

effectiveness, thereby decreasing the performance or safety of any mode of transportation. 

- There is an increase in traffic that is substantial in relation to the existing traffic load and 

capacity of the street system. 

- The demand for parking facilities is substantially increased. 

- Water borne, rail car or air traffic is substantially altered. 

- Traffic hazards to motor vehicles, bicyclists or pedestrians are substantially increased. 

- The need for more than 350 employees 

- An increase in heavy-duty transport truck traffic to and/or from the facility by more than 350 

truck round trips per day 

- Increase customer traffic by more than 700 visits per day. 

Discussion 

XVII. a) & b) PAR 1133.1 is not expected to cause an increase in traffic that is substantial in 

relation to the existing traffic load and capacity of the street system. If chipped and ground 

material is used onsite there will be no increase in trips leaving the site. If chipped and ground 

material is currently removed from the site, the net effect of PAR 1133.1 could be that the 

material would be removed sooner, but not as an additional trip. Further, existing affected 

facilities are located throughout the entire district. It is unlikely that truck trips leaving two or 

more facilities will affect the level of service (or volume-to-capacity ratio) at a single intersection 

at the same time. 



PR 1133.3 is also not expected to cause an increase in traffic that is substantial in relation to the 

existing traffic load and capacity of the street system. Assuming the facility chooses to install an 

emission control device, traffic may increase on a temporary basis during construction activities. 

However, based on current throughput at facilities located within the District, no currently 

existing facilities would be required to install air pollution control equipment. Based on the 

construction assumptions discussed in Appendix B, there would be a traffic increase of 26 trips 

per day during the installation of an emission control system and associated components. PAR 

1133.3 does not, however, require site modifications which would require the hiring of additional 

permanent employees, or require an increase in heavy-duty transport truck traffic to and/or from 

the facility by more than the SCAQMD significance threshold of 350 truck round-trips per day. 

Further, existing affected facilities are located throughout the entire district. It is unlikely that 

truck trips from two or more facilities will affect the level of service (or volume-to-capacity 

ratio) at a single intersection at the same time. Therefore, because the number of construction 

vehicle trips from construction is so low, the proposed project is not expected to impact the 

existing traffic load and capacity of the street system, or exceed the level of service standard 

established by the county congestion management agency for designated roads or highways. 

The proposed project sets forth requirements to control VOC and ammonia emissions primarily 

from existing facilities, and includes a variety of options for operators to comply with the 

proposed rules. Facilities are not expected to cease operations. As a result, additional trips to 

divert chipping and grinding and compost feedstock materials to a location out of the district or 

out of state, are not expected. 

XVII. c) PAR 1133.1 and PR 1133.3 will not require operators of existing facilities to construct 

buildings or other structures or change the height and appearance of the existing structures, such 

that they could interfere with flight patterns. Therefore, adoption of PAR 1133.1 and PR 1133.3 

are not expected to adversely affect air traffic patterns. Further, PAR 1133.1 and PR 1133.3 will 

not affect in any way air traffic in the region because it will not require transport of any materials 

by air. 

XVII. d) The proposed project does not require or include any facility modifications which 

would necessitate hazardous design features either onsite, or offsite; or necessitate incompatible 

vehicular uses (e.g. farm equipment). The siting of a new facility will undergo a review of the 

site plan and other documents by the local land use authority to also ensure no hazardous design 

features are incorporated into the development application. 

XVII. e) The proposed project does not require any changes to an existing facility which would 

impact emergency access, parking capacity, or conflict with alternative transportation policies, 

plans or programs already in place. The siting of a new facility would undergo a review of the 

site plan and other documents to ensure adequate emergency access, parking capacity and 

consistency with alternative transportation policies, plans or programs. 

XVII. f) Since PAR 1133.1 and PR 1133.3 only implements BMPs for chipping and grinding 

operations and the new requirements for greenwaste composting, the implementation of PAR 

1133.1 and PR 1133.3 would not result in conflict with adopted policies, plans, or programs 

regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance 

or safety of such facilities. 



Based upon these considerations, PARs 1133.1 and PR 1133.3 are not expected to generate 

significant adverse transportation/traffic impacts and, therefore, this topic will not be considered 

further. Since no significant transportation/traffic impacts were identified, no mitigation 


XVIII. MADATORY FIDIGS OF 

SIGIFICACE. 

a) Does the project have the potential to 

degrade the quality of the 

environment, substantially reduce the 

habitat of a fish or wildlife species, 

cause a fish or wildlife population to 

drop below self-sustaining levels, 

threaten to eliminate a plant or animal 

community, reduce the number or 

restrict the range of a rare or 

endangered plant or animal or 

eliminate important examples of the 

major periods of California history or 

prehistory? 

b) Does the project have impacts that are 

individually limited, but cumulatively 

considerable? ("Cumulatively 

considerable" means that the 

incremental effects of a project are 

considerable when viewed in 

c) 

connection with the effects of past 

projects, the effects of other current 

projects, and the effects of probable 

future projects) 

Does the project have environmental 

effects that will cause substantial 

adverse effects on human beings, 

either directly or indirectly? 

Potentially 

Significant 

Impact 

Less Than 

Significant 

With 

Mitigation 

Less Than 

Significant 

Impact 

o Impact 

 

 

 

Discussion 

XVIII. a) As discussed in the “Biological Resources” section, PAR 1133.1 and PR 1133.3 are 

not expected to significantly adversely affect plant or animal species or the habitat on which they 

rely because PAR 1133.1 and PR 1133.3 implement BMPs for chipping and grinding operations 



and new requirements for greenwaste composting, which will primarily be conducted at existing 

affected facilities. All of the currently affected facilities are located at sites that have already 

been greatly disturbed and that currently do not support such habitats. PAR 1133.1 and PR 

1133.3 are not expected to induce construction of any new land use projects that could affect 

biological resources. 

XVIII. b) Based on the foregoing analyses, cumulative impacts in conjunction with other 

projects that may occur concurrently with or subsequent to the proposed project are not expected 

to adversely impact any environmental topic. Related projects to the currently proposed project 

include existing and proposed amended rules and regulations, as well as AQMP control 

measures, which produce emission reductions from most industrial and commercial sectors. 

Furthermore, because PAR 1133.1 and PR 1133.3 do not generate project-specific impacts, 

cumulative impacts are not considered to be "cumulatively considerable” as defined by CEQA 

guidelines §15065(a)(3). For example, the environmental topics checked ‘No Impact’ (e.g., 

aesthetics, agriculture resources, air quality, biological resources, cultural resources energy, 

geology and soils, hazards and hazardous materials, hydrology and water quality, land use and 

planning, mineral resources, noise, population and housing, public services, recreation, 

solid/hazardous waste and transportation and traffic) would not be expected to make any 

contribution to potential cumulative impacts whatsoever. Also, in the case of air quality impacts, 

the net effect of implementing the proposed project with other proposed amended rules and 

regulations, and AQMP control measures is an overall reduction in district-wide emissions, thus, 

contributing to the attainment of state and national ambient air quality standards. Therefore, it is 

concluded that PAR 1133.1 and PR 1133.3 have no potential for significant cumulative or 

cumulatively considerable impacts in any environmental areas. 

XVIII.c) Based on the foregoing analyses, PAR 1133.1 and PR 1133.3 are not expected to cause 

significant adverse effects to human beings. Significant adverse air quality impacts are not 

expected from the implementation of PAR 1133.1 and PR 1133.3. Based on the preceding 

analyses, no significant adverse impacts to aesthetics, agriculture resources, biological resources, 

cultural resources, energy, geology and soils, hazards and hazardous materials, hydrology and 

water quality, land use and planning, mineral resources, noise, population and housing, public 

services, recreation, solid/hazardous waste and transportation and traffic are expected as a result 

of the implementation of PAR 1133.1 and PR 1133.3. 

As discussed in items I through XVIII above, the proposed project would have no potential to 

cause significant adverse environmental effects. 


A P P E D I X A 

P R O P O S E D A M E D E D R U L E 1 1 3 3 . 1

PAR 1133.1-1 

(Adopted January 10, 2003)PAR 1133.1ef 


PROPOSED AMENDED RULE 1133.1 CHIPPING AND GRINDING 

ACTIVITIES 

(a) Purpose 

The purpose of this rule is to prevent inadvertent decomposition occurring during 

chipping and grinding activities, including stockpile operations. 


This rule applies to operators of chipping and grinding activities to produce 

materials other than active or finished compost, unless otherwise exempted under 

subdivision (f) of this rule. The requirements of Rule 403 – Fugitive Dust, also 

apply to these activities. 



(1) ACTIVE COMPOST is material that is in the process of being rapidly 


temperatures of at least 122 degrees Fahrenheit during decomposition. 

Active compost includes, but is not limited to, pathogen-reduced mulch. 

(1)(2) AGRICULTURAL CHIPPING AND GRINDING is any chipping and 

grinding activity conducted at an agricultural site where organic waste 

material is generated on-site by the production and/or processing of farm 

products, and the chipped and ground organic waste material is used onsite. 

(23) CALENDAR DAYS refer to any days of the year, excluding official 

federal and state holidays. 

(33) CHIPPING AND GRINDING is any activity that mechanically reduces 

the size of greenwaste, woodwaste, and/or foodwaste. 

(44) COMPOSTING is a process in which solid organic waste materials are 

decomposed in the presence of oxygen under controlled conditions 

through the action of bacteria and other microorganisms. 

(5) COMPOST OVERS are the oversized woody materials that do not 

decompose in a typical composting cycle and are screened out of finished 

product at the end of composting. Compost overs have been through the


pathogen reduction process outlined in Title 14, Section 17868.3 of the 

California Code of Regulations. 

(6) CURBSIDE GREENWASTE is greenwaste that is collected from 

receptacles designated for residential household greenwaste. Curbside 

greenwaste also includes screened curbside greenwaste containing only 

grass clippings, leaves, and/or twigs that is not considered non-curbside 

greenwaste as defined in paragraph (c)(1113). 

(7) FINISHED COMPOST is a humus-like material and/or compost overs 

that result from the controlled biological decomposition of organic waste 

materials and is biologically stable. 

(8) FOODWASTE is any food scraps collected from the food service 

industry, grocery stores, or residential food scrap collection. Foodwaste 

also includes foodwaste food scraps that is are chipped and ground. 

Foodwaste mixed with greenwaste is considered foodwaste. 

(9) GREENWASTE is 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. It includes 

curbside, non-curbside, and mixed greenwaste. 

(10) INADVERTENT DECOMPOSITION is decomposition of greenwaste 

and/or foodwaste associated with stockpiling greenwaste and/or foodwaste 

for an extended period of time, and is not considered part of normal 

chipping and grinding operations. 

(11) LANDCLEARING is an activity where trees and plants grown at the site 

are cut, then chipped or ground and removed from the site to clear the site. 

(12) MIXED GREENWASTE is curbside greenwaste that is mixed with noncurbside 

greenwaste. 

(13) NON-CURBSIDE GREENWASTE is any greenwaste that is not collected 

from receptacles designated for residential household greenwaste. 

Curbside greenwaste or mixed greenwaste that is screened and contains 

only large woody materials (larger than 3 inches in any dimension) such as 

tree trimmings and branches, is also considered to be non-curbside 

greenwaste. 

(14) PALM CHIPPING AND GRINDING is any activity that mechanically 

reduces the size of palm trees waste. 



(15) PORTABLE CHIPPING AND GRINDING is chipping and grinding 

utilizing equipment with a manufacturer's rating of 170 brake horsepower 

or less. 

(16) RAINY DAY is any day with at least 0.05 inches of rain reported by the 

National Weather Service or a cooperative weather reporting station for 

the site closest to where the chipping and grinding activity occurs. 

(17) STOCKPILE is a supply of raw material tipped and stored prior to being 

utilized on-site or removed from the site. Raw materials before and after 

chipping and grinding are also included. 

(18) WET WEATHER CONDITIONS are weather conditions following a 

rainy day not to exceed 10 days. 

(18)(19) WOODWASTE is lumber, and the woody material portion of 

mixed demolition wastes and mixed construction wastes. Woodwaste also 

includes large wood materials of curbside greenwaste or mixed 

greenwaste that is screened or unscreened, such as tree trimmings, 

branches, tree trunks, stumps, and limbs exceeding 2 inches in any 

dimension. 


Effective July 1, 2003, the The operator of a chipping and grinding activity shall 

comply with the following requirements: 

(1) Remove foodwaste from the site or use foodwaste for on-site composting 

within 2 calendar days of receiptFoodwaste shall not be taken at the 

facility, unless otherwise allowed by the Local Enforcement Agency to 

handle foodwaste. 

(2) Chip or grind, or use and utilize on-site, or remove curbside, non-curbside, 

or mixed greenwaste from the site within 3 calendar days 48 hours of 

receipt, excluding observance of official federal and state holidays, or up 

to seven days maximum, with approval from unless otherwise allowed by 

the Local Enforcement Agency to hold materials for a longer period of 

time. 

(3) Chip or grind or remove non-curbside greenwaste from the site within 14 

calendar days of receipt. 

(4) Chip or grind, or use on-site, or remove mixed greenwaste from the site 

within 7 calendar days of receipt. 



(5)(3) Remove chipped or ground curbside greenwaste from the site or use 

chipped or ground curbside greenwaste on-site within 3 calendar days of 

being chipped or groundMaintain all the operational records 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 to the Executive Officer within one week of request. 

(6)(4) Maintain the following records, as applicable, on-site for two years: 

(A) A copy of the facility’s AQMD registration and annual updates 

submitted in compliance with Rule 1133; and, 

(B) Records of date, type, and amount of greenwaste and/or foodwaste 

received; and, 

(C) Records of date, type, amount of greenwaste and/or foodwaste 

removed from the site, and location where they are transferred to.; 

(D) Records of dates of rainy days and wet weather conditions and 

description of specific conditions that limited normal operations.; 

(E) Records of temperature or moisture content measurements.; and 

(F) Records of dates and amount of curbside greenwaste chipped and 

ground. 

(7)(5) The time requirements specified in paragraphs (d)(1), (d)(2), (d)(3), (d)(4), 

and (d)(5) may be extended by the number of rainy days and wet weather 

conditions that impede normal chipping and grinding operations provided 

that records are maintained in accordance with subparagraph (d)(64)(D). 

(e) Moisture Content Measurement 

Moisture content will be determined by collecting at least 10 samples of chipped 

and ground greenwaste from various locations of the pile at a depth of at least 12 

inches below pile surface. The samples shall then be mixed thoroughly and 

analyzed for moisture content by ASTM method D4442 (December 2007), ASTM 

method D4444 (May 2008) or ASTM method E871-82 (December 2006). 

(f) Exemptions 

(1) Chipping and grinding activities of greenwaste derived from the site and 

used utilized on-site shall be exempt from the requirements of paragraphs 

(d)(2), (d)(3), and (d)(4), (d)(5), and (d)(6), provided less than 1,000 cubic 

yards of materials are either sold or given away. 



(2) Portable chipping and grinding, agricultural chipping and grinding, land 

clearing chipping and grinding, woodwaste chipping and grinding, and 

palm chipping and grinding activities shall be exempt from the 

requirements of paragraphs (d)(2), (d)(3), and (d)(4), (d)(5), and (d)(6). 

(3) Chipped and ground curbside greenwaste shall be exempt from the 

requirements of paragraph (d)(52) provided that the moisture content is 

less than 30%, measured in accordance with subdivision (e) and the 

temperature or moisture content measurements are maintained on-site in 

accordance with subparagraph (d)(64)(E). 

(4) A biomass power generation facility or a facility processing material as a 

biomass fuel for a biomass power generation facility shall be exempt from 

the requirements of paragraph (d)(2) provided that the material 


content is less than 30%, measured in accordance with subdivision (e) and 

the temperature or moisture content measurements are maintained on-site 

in accordance with subparagraph (d)(4)(E). This exemption shall not 

apply to material processed for purposes other than biomass fuel. 

(5) The operator of a landfill or biomass power generation facility shall be 

exempt from the requirements of paragraph (d)(4), provided that the 



A P P E D I X B 

P R O P O S E D R U L E 1 1 3 3 . 3

PR 1133.3 - 1 

PR 1133.3ef 


PROPOSED RULE 1133.3 EMISSION REDUCTIONS FROM GREENWASTE 


(a) Purpose 

The purpose of this rule is to reduce fugitive emissions of volatile organic compounds 

(VOC) and ammonia occurring during greenwaste composting operations. 


This rule applies to the operator of all new and existing greenwaste composting 

operations that produce active or finished compost from greenwaste by itself or 

greenwaste in combination with manure or foodwaste, unless otherwise exempted under 

subdivision (g) of this rule. 



(1) ACTIVE COMPOST means material that is in the process of being rapidly 


temperatures of at least 122 degrees Fahrenheit during decomposition. Active 

compost includes, but is not limited to, pathogen-reduced mulch. 

(2) ACTIVE PHASE means the phase of the greenwaste composting process that 

begins when organic waste materials are mixed together for composting and lasts 

a minimum of 22 days under controlled conditions or until the compost has a 

Solvita Maturity Index of five or greater measured pursuant to subparagraph 

(e)(4)(A). 

(3) BACKYARD COMPOSTING means composting conducted by a household 

including, but not limited to, single family residences, condominiums, duplexes, 

or apartment buildings. 

(4) BASELINE EMISSION FACTORS mean the uncontrolled emission factors for 

greenwaste composting operations for VOC and ammonia. 

(5) COMMUNITY COMPOSTING means composting conducted by a residential 

neighborhood association using feedstock generated within the residential 

neighborhood to produce compost for the neighborhood’s use.

PR 1133.3 - 2 


(6) COMPOSTING means a process in which solid organic waste materials are 

decomposed in the presence of oxygen through the action of bacteria and other 

microorganisms. 

(7) COMPOST OVERS mean the oversized woody materials that do not decompose 

in a typical composting cycle and are screened out of finished product at the end 

of composting. Compost overs have been through the pathogen reduction process 

outlined in Title 14, Section 17868.3 of the California Code of Regulations. 

(8) CURING PHASE means the phase of the greenwaste composting process that 

begins immediately after the end of the active phase of composting and lasts a 

minimum of 40 days or until the compost has a Solvita Maturity Index of seven or 

the product respiration rate is below ten milligrams of oxygen consumed per gram 

of volatile solids per day as measured by direct respirometry, pursuant to 

subparagraph (e)(4)(B). 

(9) EXISTING GREENWASTE COMPOSTING OPERATIONS mean all 

(10) 

greenwaste composting operations that have begun operations on or before (date 

of adoption). 

FINISHED 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 product. 

(11) FOODWASTE means any pre- or post-consumer food scraps collected from the 

food service industry, grocery stores, or residential food scrap collection. 

Foodwaste also includes food scraps that are chipped and ground. Any non-food 

material that is not separated from food scraps is considered foodwaste for the 

purpose of calculating throughput, including but not limited to compostable 

plastic bags and food-soiled packaging, papers or other biodegradable material, or 

non-compostable solid waste, such as napkins, cans, glass, plastics including bags, 

containers and styrofoam. 

(12) GREENWASTE means 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. 

(13) GREENWASTE COMPOSTING means composting of greenwaste by itself or a 

mixture with foodwaste, or with up to 20 percent manure, per pile volume basis. 

(14) NEW GREENWASTE COMPOSTING OPERATIONS mean greenwaste 

composting operations that have not started operations as of (date of adoption).

PR 1133.3 - 3 


(15) NURSERY COMPOSTING means composting conducted at a nursery to produce 

compost for on-site use. 

(16) ORGANIC WASTE means any organic waste material that includes foodwaste, 

greenwaste, woodwaste, or manure, or a mixture thereof. 

(17) OPERATOR means any person that operates a greenwaste composting operation. 

(18) PILE means compostable material that is heaped together. 

(19) RECREATIONAL FACILITY COMPOSTING means composting conducted at 

parks, arboretums and other recreational facilities using feedstock generated on- 

site to produce compost for on-site use. 

(20) SOLVITA MATURITY INDEX means an index that defines the stage where 

compost exhibits resistance to further decomposition, as tested by the Solvita 

Maturity Test ® . 

(21) START-UP means the first day of active greenwaste composting operations at the 

facility. 

(22) THROUGHPUT means the mass of manure, foodwaste, or greenwaste in tons per 

year as received by the facility and processed through composting, excluding 

recycled materials. 

(23) TMECC means Test Methods for the Examination of Composting and Compost 

published by the US Composting Council Research and Education Foundation. 

(24) WOODWASTE means lumber, and the woody material portion of mixed 

demolition and construction wastes. Woodwaste also includes large wood 

materials of curbside greenwaste or mixed greenwaste that is screened or 

unscreened, such as tree trimmings, branches, tree trunks, stumps, and limbs 

exceeding two inches in any dimension. 



shall comply with the following requirements: 

(A) Chip or grind, as necessary, and use greenwaste for on-site composting 

within 48 hours of receipt, unless otherwise as allowed by the Local 

Enforcement Agency to hold for a longer period of time. 

(B) Use foodwaste for on-site composting within 48 hours of receipt or cover 

foodwaste with screened or unscreened finished compost until used, unless 

otherwise required by the Local Enforcement Agency. 

(2) Effective upon start-up for new greenwaste composting operations and effective 

(4 months after date of adoption) for existing greenwaste composting operations,

PR 1133.3 - 4 


the operator of greenwaste composting operations processing greenwaste only or 

up to 20 percent manure, by volume, or up to 5,000 tons per year of foodwaste 

throughput shall comply with the following requirements: 

(A) Cover each active phase pile with screened or unscreened finished 

compost within three twenty-four hours of initial pile formation such that 

the top is at least six inches thick and the pile shall not be turned for the 

first seven days of the active phase of composting, unless subparagraph 

(d)(2)(D) applies. 

(B) For the first fifteen days after initial pile formation for the active phase 

period of composting, within three six hours before turning, apply water as 

necessary to the surface area of each active phase pile such that the top 

one half of the pile is wet to a depth of three inches. Alternatively, the 

operator may apply water during turning using a windrow turner which is 

equipped with water spraying technology during the entire windrow 

turning process. 

(C) If a rain event occurs prior to watering the pile within three six hours 

before turning and the pile is wet to a depth of three inches, the operator 

may turn the pile without adding additional water. If the top half of the 

pile is dry at any level to the three inch depth, apply additional water to the 

pile pursuant to subparagraph (d)(2)(B). 

(D) If the pile needs to be turned within the first seven days for maintaining 

managing temperature at or above 131 degrees Fahrenheit for pathogen 

reduction pursuant to Title 14 Division 7, Chapter 3.1, Section 17868.3 of 

the California Code of Regulations, the operator does not need to re-apply 

the screened or unscreened finished compost cover and shall apply water 

pursuant to subparagraph (d)(2)(B) for the first fifteen days of the active 

phase. 

(E) The operator may implement an alternate mitigation measure that will be 

based on a test protocol approved by the Executive Officer, California Air 

Resources Board, and the United States Environmental Protection Agency 

and that demonstrates emission reductions by at least 40 percent, by 

weight, for VOC and emission reductions by at least 20 percent, by 

weight, for ammonia for combined screened or unscreened finished 

compost cover and water application.

PR 1133.3 - 5 



processing greater than 5,000 tons per year of foodwaste throughput shall comply 

with the following requirements, for the purpose of regulatory compliance: 

(A) Any active phase of composting containing more than 10% foodwaste, by 

weight, shall be conducted using an emission control device designed and 

operated with an overall system control efficiency of at least 80 percent, 

by weight, each for VOC and ammonia emissions. 

(B) The operator may implement a control alternative if the alternative is 

approved by the Executive Officer, California Air Resources Board, and 

the United States Environmental Protection Agency, to achieve VOC and 

ammonia reductions that are greater than or equal to the reductions 

required pursuant to subparagraph (d)(3)(A). 

(C) For new greenwaste composting operations that intend to compost greater 

than 5,000 tons per year of foodwaste throughput, a permit shall be 

obtained for an emission control device, as specified in subparagraph 

(d)(3)(A) or (d)(3)(B), prior to construction. 

The annual throughput calculation may exclude any non-putrescible materials, 

including, but not limited to paper, woody, other low-water, high cellulose 

materials, and non-compostable contaminants and green waste that are separated 

either before or after composting and shipped off-site for disposal provided they 

are quantified and appropriate records are maintained for. 

(4) No later than (3 months after date of adoption), for existing greenwaste 

composting operations that, as of (date of adoption), process or plan to process 

greater than 5,000 tons per year of foodwaste throughput, the operator shall file a 

permit application for an emission control device and fully implement the 

emission control device in accordance with subparagraphs (d)(3)(A) or (d)(3)(B) 

within six months upon approval of the permit application. 

(5) The overall control efficiency required in subparagraph (d)(3)(A) shall be 

demonstrated by a source test within three months after implementation of the 

emission control device, or within nine months of permit approval, whichever 

occurs sooner, and every three years thereafter. For the purpose of this rule, the 

baseline emission factors to be used shall be 4.25 pounds of VOC per ton of 

throughput and 0.46 pounds of ammonia per ton of throughput for the active 

phase of composting only. The Executive Officer may approve the use of 

alternate baseline emission factors, if the operator demonstrates through the

PR 1133.3 - 6 


approved source test that alternate baseline emission factors are representative of 

uncontrolled operations for that facility 

(6) All emission control devices shall be installed, operated, and maintained in 

accordance with the manufacturer’s operation and maintenance manual or other 

similar written materials supplied by the manufacturer or distributor of such 

equipment to ensure that the system remains in proper operating conditions. Such 

documentation shall be made available to the Executive Officer upon request. 

(7) All records, including application of screened or unscreened finished compost and 

water, operation and maintenance of an emission control device, and source tests, 

shall be kept and maintained at the facility pursuant to subdivision (f). 

(e) Test Methods and Protocol 


(d)(5), the operator shall conduct all required source and laboratory tests in 

accordance with an Executive Officer approved test protocol developed in 

accordance with the guidelines provided in Attachment A of this rule. 


(d)(5), the operator shall use a District approved laboratory in accordance with the 

Attachment A of this rule. 

(3) The following methods shall be used to determine compliance with this rule: 

(A) SCAQMD Method 207.1 – Determination of Ammonia Emissions from 

Stationary Sources. 

(B) SCAQMD Method 25.3 – Determination of Low Concentration Non- 

Methane Non-Ethane Organic Compound Emissions from Clean Fueled 

Combustion Sources. 

(C) SCAQMD Method 1.1 – Sample and Velocity Traverses for Stationary 

Sources. 

(D) SCAQMD Method 1.2 – Sample and Velocity Traverses for Stationary 

Sources with Small Stacks and Ducts. 

(E) SCAQMD Method 2.1 – Determination of Stack Gas Velocity and 

Volumetric Flow Rate (S-Type Pitot Tube). 

(F) SCAQMD Method 2.2 – Direct Measurement of Gas Volume through 

Pipes and Small Ducts. 

(G) SCAQMD Method 2.3 – Determination of Gas Velocity and Volumetric 

Flow Rate from Small Stacks or Ducts.

PR 1133.3 - 7 


(H) SCAQMD Method 4.1 – Determination of Moisture Content in Stack 

Gases. 

(4) Triplicate samples shall be taken for the following test methods: 

(f) Recordkeeping 

(A) TMECC 05.08-E – Solvita Maturity Index (April 7, 2002). 

(B) TMECC 05.08-A – Specific Oxygen Uptake Rate (April 7, 2002). 

Records shall be kept in a format approved by the Executive Officer. All operational 

records and information recorded pursuant to the provisions of this rule shall 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 to the Executive Officer 

within one week of request. 


(1) Composting facilities subject to Rule 1133.2 – Emission Reductions from Co- 


(2) If the operator of any greenwaste composting operation installs an emission 

control device, in accordance with paragraphs (d)(3) through (d)(6), the 

provisions of paragraph (d)(2) do not apply. 

(3) The following types of facilities and operations are exempt from the requirements 

of this rule, 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: 

(A) Community composting; 

(B) Nursery composting; 

(C) Backyard composting; and 

(D) Recreational facility composting.

ATTACHMENT A 

PR 1133.3 - 8 


GUIDELINES FOR THE DEVELOPMENT OF SOURCE TEST PROTOCOLS 

FOR VOC AND AMMONIA EMISSIONS FROM GREENWASTE 


Source test protocols are to consist of testing plans to measure VOC and ammonia emissions due 

to the composting process. When used for determining the control device efficiency requirement 

specified for new and existing facilities, the measurements shall consist of lb/hr measurements at 

the inlet and exhaust of the control device and are subject to the applicable requirements that 

follow. When used for determining the overall emission reduction requirements as compared to 

the baseline emissions factors, emissions are to be reported as % reductions for the active phase 

composting in terms of pounds of emissions per ton of throughput (total raw material as 

received) and are subject to the applicable requirements that follow. The following are general 

requirements for all testing as well as specific requirements for the rule sections for each facilityspecific 

protocol which must be prepared by the source test contractor and approved by the 

SCAQMD prior to testing. 

1. Alternative Test Methods 

The reference test methods for ammonia, VOC, and flow rate cited in this guideline shall 

be used to determine compliance with this rule. Alternative test methods may be used if 

they are determined to be equivalent and approved in writing by the Executive Officer, 

the California Air Resources Board, and the U.S. Environmental Protection Agency. For 

the source test protocols, as defined as the manner in which the reference test methods are 

employed to obtain a measurement of the emissions, alternatives to the procedures cited 

in this guidelines may be used if they are determined to be equivalent and approved in 

writing by the Executive Officer. 

2. LAP Requirements 

The sampling, analysis, and reporting shall be conducted by a laboratory/source test firm 

that has been approved under the SCAQMD Laboratory Approval Program (LAP) for the 

cited SCAQMD reference test methods, where LAP approval is available. For SCAQMD 

reference test methods for which no LAP program is available, the LAP approval 

requirement shall become effective one year after the date that the LAP program becomes 

available for that SCAQMD reference test method. 

3. Operating Conditions 

The testing must be conducted under representative operating conditions with respect to 

seasonal conditions, compost composition, process throughput, processing of the 

materials, and pile geometries. The following operating parameters shall be recorded 

during testing and reported with the test results:

PR 1133.3 - 9 


a) A thorough description of the composting process and process diagram of each 

processing area and including residence times in each of the composting process 

areas. 

b) Process throughput as determined by facility’s billing scales or other calibrated 

measuring device that represents the tons of the material as received that is present at 

the facility during the time of the testing. When using the District Baseline Emission 

Factors, the process throughput is to include all of the raw organic materials that are 

composted excluding material that is recycled from previous similar processing. 

Several throughputs may be necessary if applicable to the different processing areas 

or pile ages. 

c) Compost composition (percent and type of materials i.e. manure, greenwaste, 

foodwaste, etc…). 

d) Age of all piles that were tested and all piles present at the facility during testing. 

e) Detailed dimensions of all piles or the biofilter so that a surface area for each pile 

type can be calculated. 

f) A description of the biofilter system, including a process diagram and type of biofilter 

media. 

g) Age of the biofilter media. 

h) A thorough description of the humidification and moisture maintenance system for 

the biofilter. 

i) Identification of peripheral monitoring equipment, such as moisture or temperature 

sensors, and data from them during testing. 

4. Ammonia Sampling 

SCAQMD Method 207.1 shall be used to obtain the ammonia samples from each source 

of emissions to be tested. When sampling from a flux chamber, a sample line of minimal 

length should be connected to a midget sampling train consisting of; two midget 

impingers each filled with 15 ml of 0.1N Sulfuric Acid, an empty bubbler, and a bubbler 

filled with tared silica gel. The samples shall be analyzed for ammonium content as 

ammonia by ion chromatography or ion selective electrode. 

5. VOC Sampling 

Duplicate integrated gas samples shall be taken from each source of emissions to be 

tested using SCAQMD Method 25.3. The Method 25.3 apparatus should be connected to 

sample directly inside the flux chamber or duct as applicable. Compost emissions are 

considered as water soluble sources where the 50 ppm applicability limit of Method 25.3 

does not apply.

PR 1133.3 - 10 


6. Specific Requirements for Testing Greenwaste Composting Operations Control 

Equipment Performance 

For surface types of emissions, such as with open faced biofilter exhausts, the exhaust 

emission rate shall be determined as in the following Section (8). 

For a control device inlet or exhaust that is vented through a testable duct, the gas 

velocity within the duct shall be measured according to SCAQMD Methods 1.1, 2.1, and 

3.1. The flow rate shall also be corrected to dry standard conditions using the moisture 

content as determined by SCAQMD Method 4.1. This flow rate may then be used to 

determine mass emission rates. 

The overall destruction efficiency is calculated as follows: 

Where: 

ODE = 100 x (1 – (E / I)) (Equation 1) 

ODE = Overall Destruction Efficiency (%) 

E = Total Exhaust Emission Rate (lb/hr) 

I = Total Inlet Emission Rate to Control Device (lb/hr) 

7. Specific Requirements for Existing Greenwaste Composting Operations and New 

Greenwaste Composting Operations (Overall Emissions Reduction) 

A proposed measurement from the active greenwaste composting process, including but 

not limited to surface emissions of all piles where the materials are composted, and 

outlets (vents or surfaces) of control devices must be included in the protocol. If the 

emissions are vented to atmosphere from a vent stack such as from an otherwise 

uncontrolled aerated static pile or other vent to atmosphere, then the stack concentration, 

determined using methods specified in Sections (4) and (5) and flow rate measurements 

as specified in the previous Section (6) are required. From all surface types of emissions 

such as from compost piles and biofilter surfaces, the procedure for measuring surface 

emissions as in Section (8) is required. A measurement for fugitive emissions from 

aerated static pile surfaces must also be included. 

Each type of pile must be tested. If the facility includes several identical piles, then only 

the largest pile need be tested. If the facility has more than three different age piles that 

are otherwise identical in processing and composition, then at a minimum three ages can 

be tested including newer, older, and middle aged piles. In any case, the surface area of 

all piles at the facility must be included in the determination of pile dimensions as 

recorded in Section (3). 

If the facility elects to use an alternative to the District’s baseline emissions factors, then 

a separate test must be conducted to establish this baseline on the uncontrolled 

composting operation (e.g., windrow method) with the same compost mix. Following the

PR 1133.3 - 11 


source test to determine an alternative baseline, facilities would have the option to use the 

District’s baseline emissions factors or the alternative baseline emissions factors. 

Reduction of emissions shall be calculated as follows: 

Where: 

% Reduction = 100 x (1-TE/B) (Equation 2) 

TE = Total Active and Curing Phase Emissions (lb/ton throughput) 

B = District Baseline Emissions or Alternative Baseline Emissions if Tested 

(lb/ton throughput) 

8. Procedure for Measuring Surface Emissions 

The procedure for measuring surface emissions such as the compost pile and biofilter 

surfaces that cannot be tested by conventional methods through a stack or duct, is a 

modified form of the procedures found in the US Environmental Protection Agency’s 

(EPA) Measurement of Gaseous Emission Rates from Land Surfaces Using an Emission 

Isolation Flux Chamber User’s Guide (EPA Guide). The modification to the procedures 

in the EPA Guide is specified in the following requirements. 

The flux chamber encompasses a fixed surface area of 1.4 ft 2 and contains a sweep air 

system to obtain a homogeneous air sample by employing a mixing fan and sweep gas 

(10% He in air at 5 liters/min recommended). The sweep gas must contain a non reactive 

and non-present tracer such as the aforementioned 10% helium so that a correction for the 

contribution of the surface flow rate can be calculated. 

A minimum of ten (10) sample locations or a sufficient number at each pile/surface tested 

must be obtained in order to achieve a representative sample of the surface emissions. 

These locations can be composited for each pile/surface to reduce testing costs. For 

example, for one hour sampling, ten (10) random positions on the pile should be tested 

for 6 minutes each. Alternatively, a lesser number of sample locations may be sampled 

provided that an evaluation of spatial variation demonstrates that the number of sample 

locations is sufficient. 

The emissions must be reported in units of lb/hr-ft 2 , lb/hr and lb/ton of throughput. The 

following calculations shall apply to the test results: 

Where: 

Surface Flow Correction Factor = Ct / Cs (Equation 3) 

Ct = Concentration of Tracer in Sweep Gas 

Cs = Concentration of Sweep Gas in Flux Chamber Sample

Where: 

Corrected Flux Chamber Results (lb/hr-ft 2 ) = UFC x SFCF (Equation 4) 

UFC = Uncorrected Flux Chamber Results (lb/hr-ft 2 ) 

SFCF = Surface Flow Correction Factor 

Where: 

Where: 

lb/hr = lb/hr-ft 2 x Total Compost Surface Area in Category (Equation 5) 

lb/ton throughput = lb/hr x (24 hr/day) /PT (Equation 6) 

PT = Process Throughput (total ton/day as received) 

Total Emissions (lb/ton throughput) = ∑ P (Equation 7) 

PR 1133.3 - 12 


P = Active and curing sources of the Facility Compost Emissions (lb/ton throughput) 

For a facility where not every age of pile was tested, the surface areas from each pile in 

the facility must be included and sorted into appropriate age and emissions categories 

from those that were measured.

A P P E D I X C 

C O S T R U C T I O E M I S S I O C A L C U L A T I O S

Installation of Air Pollution Control Devices (APCDs) 

Construction Emissions - APCD Installation 

Installation of APCDs at Affected 

Greenwaste Composting Facilities Construction Activity 

Installing 17 APCD Units at Affected Greenwaste Composting Facilities 

Over a 6 Month Period 

Construction Schedule - "Worst-case" Complete APCD Installation at 1 location/week (overall 17 installations; avg less than 1/wk) 

Activity Equipment Type No. of Equipment Hrs/day Crew Size 

Off-Road Mobile Source Operations Forklift 1 8 1 – Place prefabricated control equipment into place 

Off-Road Mobile Source Operations Roller 1 8 1 

Off-Road Mobile Source Operations Cement Mixer 2 8 2 

PR 1133.3 B - 1 

– Compact and surface 150' x 150' concrete pad for 

composting operations 

– Supply concrete for pad, two concrete walls/berms 

and footings for blowers 

On-Road Mobile Source Operations Delivery Truck 1 - 1 – Deliver the control equipment 

On-Road Mobile Source Operations Worker Vehicle 10 - 18 

2010 Construction Equipment Emission 

Factors 

VOC CO NOx SOx PM10 PM2.5 CO2 CH4 

Equipment Type* lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr 

Forklift (composite) 0.0686 0.2319 0.5161 0.0006 0.0281 0.0281 54.4 0.0062 

Roller (composite) 0.1176 0.4212 0.7749 0.0008 0.0547 0.0547 67.1 0.0106 

Cement Mixer (composite) 

*Equipment is assumed to be diesel fueled. 

0.0101 0.0434 0.0599 0.0001 0.0035 0.0035 7.2 0.0009 

Source: CARB's Off-Road Mobile Source Emission Factors for Scenario Year 2011 http://www.aqmd.gov/ceqa/handbook/offroad/offroadEF07_25.xls 

Construction Vehicle (Mobile Source) 

Emission Factors for Years 2010 

VOC CO NOx SOx PM10 PM2.5 CO2 CH4 

Construction Related Activity lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile lb/mile 

Offsite (Construction Worker Vehicle) 0.00091399 0.00826276 0.00091814 0.00001077 0.00008698 0.00005478 1.09568235 0.00008146 

Offsite (Equipment Delivery Truck - HHDT) 0.00304157 0.01195456 0.03822102 0.00004131 0.00183062 0.00160083 4.21120578 0.00014201 

Source: EMFAC 2007 (v2.3) Emission Factors (On-Road Vehicles, Scenario Year 2011) 

Composite Emission Factors for Passenger Vehicle and Heavy-Heavy Duty Trucks for Scenario Year 2011 

http://www.aqmd.gov/ceqa/handbook/onroad/onroadEF07_26.xls and http://www.aqmd.gov/ceqa/handbook/onroad/onroadEFHHDT07_26.xls 

September 2010

Construction Worker Number of Trips and Trip Length 

Vehicle 

No. of One-Way 

Trips/Day 


Trip Length 

(miles) 

Offsite (Construction Worker) 20 25 

Offsite (Cement Mixer) 4 50 

Offsite (Delivery/Haul Truck - HHDT) 2 50 

Incremental Increase in Onsite Combustion Emissions from Construction Equipment 

Equation: Emission Factor (lb/hr) x No. of Equipment x Work Day (hr/day) = Onsite Construction Emissions (lbs/day) 

Equipment Type VOC CO NOx SOx PM10 PM2.5 CO2 CH4 

lb/day lb/day lb/day lb/day lb/day lb/day lb/day lb/day 

Forklift (composite) 0.55 1.86 4.13 0.00 0.22 0.22 435.17 0.05 

Roller (composite) 0.94 3.37 6.20 0.01 0.44 0.44 536.42 0.08 

Cement Mixer (composite) 0.16 0.69 0.96 0.00 0.06 0.06 115.97 0.01 

Construction Equip TOTAL 1.65 5.92 11.29 0.01 0.72 0.72 1087.56 0.15 

Incremental Increase in Offsite Combustion Emissions from Construction Vehicles 

Equation: Emission Factor (lb/mile) x No. of One-Way Trips/Day x Number of workers x Trip length (mile) = Offsite Construction Emissions (lbs/day) 

Vehicle VOC CO NOx SOx PM10 PM2.5 CO2 CH4 

lb/day lb/d lb/day ay lb/d lb/day ay lb/d lb/day ay lb/d lb/day ay lb/d lb/day ay lb/d lb/day ay lb/d lb/day ay 

Offsite (Construction Worker Vehicle) 0.46 4.13 0.46 0.01 0.04 0.03 547.84 0.04 

Offsite (Delivery/Haul HHDT) 0.30 1.20 3.82 0.00 0.18 0.16 421.12 0.01 

Vehicle TOTAL 0.76 5.33 4.28 0.01 0.23 0.19 968.96 0.05 

Total Incremental Combustion Emissions from Construction Activities (Construction Equipment, Trucks and Workers' Vehicles) 

VOC CO NOx SOx PM10 PM2.5 CO2 CH4 CO2eq 

lb/day lb/day lb/day lb/day lb/day lb/day lb/day lb/day MT/year 

TOTAL 2.41 11.25 15.57 0.02 0.95 0.91 2056.52 0.20 16.86 

Significant Threshold 75 550 100 150 150 55 n/a n/a 10,000 

Exceed Significance? NO NO NO NO NO NO n/a n/a NO 

PR 1133.3 B - 2 

September 2010

Total Increase in Fuel Usage From Construction Equipment and Workers' Vehicles 


Off-Road 

Total Diesel 

Total 

Gasoline 

Total Project 

Hours of 

Fuel Fuel Use Fuel Use 

Overall Construction Activity 

Operation 

Equipment Type (gal/hr)* 

(gallons) (gals) 

Operation of Off-Road Equipment 30 Forklift 2.47 1259.70 N/A 

Operation of Off-Road Equipment 30 Roller 3.07 1565.70 N/A 

Operation of Off-Road Equipment 60 Cement Mixer 0.33 336.60 N/A 

Workers' Vehicles** - Commuting N/A Mixed Passenger 

Heavy-Heavy 

Duty 

N/A N/A 400.00 

Offsite Delivery Trucks*** N/A Delivery 

Truck 

N/A 113.33 N/A 

TOTAL 3275.33 400.00 

*Based on CARB's Off-Road Model (Version 2.0) for Equipment Year 2010. 

**Assume that construction workers' commute vehicles use gasoline and get 20 mi/gal and round trip length is 50 miles/phase. 

***Assume that delivery trucks use diesel and get 15 miles/gallon traveling 100 miles roundtrip; 17 locations 

PR 1133.3 B - 3 

September 2010

A P P E D I X D 

O P E R A T I O A L E M I S S I O C A L C U L A T I O S

Operational Emissions from Finished Compost Cover Control Measure 

Placement of Finished Compost Cover on Active 

Greenwaste Windrows as VOC Control Measure 

Operational Activity: 

Operation of Front-end Loader to Place Finished Compost Cover 

Operational Schedule -"Worst-case" Scenario: Initial Covering of Windrows at 17 Composting Facilities on Same Day in SCAQMD Basin 

(based on yearly processing volume) 

Equipment No. of 

Activity Type 

Rubber 

Tired 

Equipment 

Hrs/day Crew Size 

Off-Road Mobile Source Operations Loader 

Rubber 

Tired 

1 6 1 – Place finished compost over windrows 

Off-Road Mobile Source Operations Loader 16 1 16 

*Assumes one loader would be utilized per day at each of the 17 facilities. 

*Assumes facilities will start a new composting cycle each week on the same day / 52 cycles per year. 

*Based on time estimate for application of compost cap of 0.0031 hours per ton obtained from the Modesto/Bakersfield study. 

2011 Operational Equipment Emission Factors VOC CO NOx SOx PM10 PM2.5 CO2 CH4 

Equipment Type* lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr 

Rubber Tired Loader (composite) 0.1354 0.4959 1.0771 0.0012 0.0608 0.0608 109 0.0122 

*Equipment is assumed to be diesel fueled. 

Source: CARB's Off-Road Mobile Source Emission Factors for Scenario Year 2011 http://www.aqmd.gov/ceqa/handbook/offroad/offroad.html 

Total Incremental Increase in Onsite Combustion Emissions from Operational Equipment 

Equation: Emission Factor (lb/hr) x No. of Equipment x Work Day (hr/day) = Onsite Operational Emissions (lbs/day) 

Equipment Type VOC CO NOx SOx PM10 PM2.5 CO2 CH4 

lb/day lb/day lb/day lb/day lb/day lb/day lb/day lb/day 

Rubber Tired Loader (composite) 2.98 129.93 23.70 0.03 1.34 1.34 2389.48 0.27 

Operational Equipment TOTAL 2.98 129.93 23.70 0.03 1.34 1.34 2389.48 0.27 

Significant Threshold 55 550 55 150 150 55 n/a n/a 10,000MT/Y 

Exceed Significance? NO NO NO NO NO NO n/a n/a NO 

Total Increase in Fuel Usage From Operational Equipment (per covering day for 17 facilities) 

Overall Activity 

Total Project 

Hours 

of 

Operation 

Operation of Off-Road Equipment 22 

Rubber Tired 

Loader 5.05 1888.70 N/A 

*Based on CARB's Off-Road Model (Version 2.0) for Equipment Year 2011. 

Equipment 

Type 

Off-Road 

Fuel 

(gal/hr)* 

Total Diesel 

Fuel Use 

(gallons) 

Total 

Gasoline 

Fuel Use 

(gals) 

TOTAL 1888.70 0.00

A P P E N D I X E 

C O M M E N T S R E C E I V E D A N D R E S P O N S E S T O C O M M E N T S

E-mail received from City of San Diego on July 1, 2011 

Dear Mr. Inabinet: 

Thank you for the opportunity to review proposed amended rule 1133.1 and rule 1133.3 and the 

draft Environmental Assessment (dEA) prepared for these regulations. The City of San Diego 

operates a 690 ton-per-day commercial composting facility, the Miramar Greenery, located at the 

West Miramar Landfill. City recycling staff design and implement organic recycling programs 

to divert material from the landfill to the Greenery. The City plans to continue developing 

organic diversion programs and promotes the development of new organic diversion facilities. 

The following comments are provided on the dEA. 

Page 1-4 

On page 1-4 the dEA states that ozone is formed when VOCs react in the presence of light with 

NOx. However, a recent study done by the California Department of Resources Recycling and 

Recovery (CalRecycle), concluded that VOCs from composting windrows produce ozone at 

lower rates than other types of VOCs (An Investigation of the Potential for Ground-Level Ozone 

Formation Resulting from Compost Facility Emissions, 

http://www.calrecycle.ca.gov/Publications/default.asp?pubid=1369). The dEA does not address 

this difference. 

SCAQMD Response 

The CEQA analysis conducted in the dEA assumes a worst-case scenario. By assuming that 

ozone is formed when VOCs react in the presence of light with NOx, the dEA is taking a more 

conservative approach than assuming that VOCs from composting windrows produce ozone at 

lower rates than other types of VOCs. Please also be aware that while lesser reactive VOCs may 

contribute to ozone formation at lower rates, they often contribute to the formation of secondary 

aerosols at rates higher than those of more reactive VOCs, resulting in exacerbation of fine 

particulate pollution, for which our Basin population faces the highest exposure burden in the 

nation. 

With regard to reactivity, the attainment demonstration for the Basin and air quality modeling 

analyses embedded in the Air Quality Management Plan does account for varying levels of 

reactivity from VOC species emitted from different emission sources to the extent that such 

information is available. However, in 2006, in meetings with CARB, air districts and the U.S. 

EPA, air districts expressed concerns that implementing a reactivity-based rule would require 

detailed chemical formulation data, air district staff would need to identify the appropriate 

maximum incremental reactivity (MIR) value for each of these ingredients before the overall 

reactivity could be calculated for the product, and concerns were expressed regarding the ability 

to enforce a reactivity-based control approach. Nevertheless, the SCAQMD is committed to 

continue to work with all stakeholders to further explore the feasibility of implementing a 

reactivity-based approach if and when such an approach becomes available.

Page 2-9 

On page 2-9 the dEA does not address potential conflicts with the Scoping Plan developed 

pursuant to AB32. The AB32 Scoping Plan is an adopted plan for addressing greenhouse gas 

emissions. It addresses recycling and other waste diversion measures including composting. The 

dEA may also conflict with local plans to divert waste and reduce green house gas emissions, 

such as a jurisdictions [sic] Source Reduction and Recycling Element (SRRE), Non-Disposal 

Facility Element (NDFE), and Siting Plans. 


The proposed rule and amendments are not in conflict with any of the measures in AB32. 

Neither the commenter nor other industry representatives have explained the basis for this 

assertion nor have they provided data or other information that supports this assertion. It is 

assumed that this assumption is based on the incorrect notion that the proposed rule and 

amendments would be too onerous to comply with and, therefore, would cause affected facilities 

to close down, thus, requiring composting materials to be transported out of the district. This 

assertion is incorrect for the following reasons. PAR 1133.1 would establish best management 

practices (BMPs) to better manage stockpile operations associated with chipping and grinding 

activities. Affected facilities are already subject to the same greenwaste material processing 

requirements established in Title 14, Division 7, Chapter 3.1 of the California Code of 

Regulations (CCR). Approximately 70 existing greenwaste chipping and grinding operations or 

facilities would be affected by the requirements of PAR 1133.1. Based on staff evaluation of the 

effects of PAR 1133.1 for existing facilities, including a number of site visits, most of these 

affected facilities are already in compliance with the proposed amendments to Rule 1133.1, so 

there would be no reason to expect that facilities would be unable to comply with the proposed 

BMP requirements and there is no reason to expect that facilities would close down or that 

somehow fewer facilities would be built in the future. As a result, it is not expected that there 

would be a shift in the delivery of materials for composting from these facilities to alternative 

facilities located outside of the district. 

PR 1133.3 would establish operational BMPs for greenwaste composting operations that produce 

active or finished compost material from greenwaste-only or greenwaste in combination with 

manure or foodwaste. PR 1133.3 is applicable to 17 existing greenwaste composting facilities. 

Based on staff research and industry input from greenwaste composting facilities located within 

the district, it is expected that the current facilities would comply with PR 1133.3 by making 

minor adjustments (adding finished compost cover to initial compost piles, adjust watering 

schedules, etc.) in their current operational BMPs. Based on industry input, it is expected that 

affected facilities would be able to make the necessary minor adjustments in their operational 

BMPs at a relatively low cost, further supporting the conclusion that composting facilities would 

not be adversely affected by the proposed rule or that composting materials would be diverted 

out of the district. This view is supported by the socioeconomic impact analysis prepared for the 

proposed project, which showed that the primary economic effects of the proposed project are 

the loss of four new jobs in the affected industry in the future. Potential adverse environmental 

impacts associated with these minor adjustments (e.g., increased usage of existing loaders for 

compost cover) were analyzed in the dEA. Additionally, no existing facilities are expected to be 

required to install an emission control device without significant increases of foodwaste 

throughput on an annual basis (i.e., to 5,000 tons per year or more). If the commenter is 

referring to diversion from the closure of the Puente Hills landfill in 2013, that diversion is in no

way related to the currently proposed rule and amendments. According to a PowerPoint 

presentation titled “Green Waste Management After Closure of Puente Hills Landfill,” prepared 

by the County Sanitation Districts of Los Angeles County, diversion of composting material 

from the closure of the Puente Hills landfill is already expected to occur to other facilities within 

the district and to areas outside the district. Few, if any, facilities subject to Rule 1133.3 are 

expected to exceed 5,000 tons per year. Based on staff research, two facilities had plans to add 

controls because they were planning to process more than 5,000 tons per year of foodwaste. 

Finally, the primary intent of the proposed rule and amendments is to reduce criteria pollutant 

emissions, which are precursors to ozone and fine particulates. Furthermore, the proposed BMPs 

are intended to prevent anaerobic decomposition of greenwaste and alleviate adverse GHG and 

criteria pollutant emission impacts resulting from such conditions. Therefore, based on the 

information above and the emission reduction effects of the proposed project, it is not expected 

that the proposed rule and amendments would conflict with AB32. While the goal of the state 

program is to reduce GHG emissions, it is not intended to be at the expense of criteria pollutant 

control efforts. 

Page 2-9 (cont.) 

The proposed rule would make it more difficult to obtain facility permits and could decrease the 

number of new composting operations in the region. Any tonnage expansion of an existing 

facility OR permitting a new facility would trigger New Source Review and dramatically 

increase the costs addressed in the AQMD Staff Report and Socioeconomic Assessment. Fewer 

compost facilities in the region could lead to more green waste being disposed in landfills. 

Additionally, direct land application of green waste will likely increase. Both of these alternative 

methods for handling green waste impact public service and could have potential environmental 

impacts including: ground water contamination, methane generation and emissions, increased 

emissions due to longer hauling distances between generator and facility, spread of imported 

pests outside quarantine areas, reduced stewardship of soil resources, increased erosion, and 

increased water use in landscaping. These effects might cause substantial adverse effects either 

directly or indirectly. 


The comment provides no information or supporting data to support the assertion that the 

proposed project would make it more difficult for affected facilities to obtain permits. In fact, 

the proposed rule and amendments do not make it more difficult to obtain facility permits for the 

following reasons. It is not true that any tonnage expansion of a facility would trigger New 

Source Review, as permitting would only be required if the facility composts more than 5,000 

tons per year of foodwaste and/or composting materials with a foodwaste content greater than 10 

percent by weight. Composting in windrow fashion does not require a permit in the South Coast 

Air Quality Management District. If aerating or controlling or voluntarily installing equipment 

to control emissions through mechanical means is used because of an increase in the foodwaste 

component of the composting material, then composting in these situations would require 

permits. As such, covering an active windrow with finished compost cover is a BMP and does 

not require a permit within the SCAQMD’s jurisdiction. Therefore, the assertion that the 

proposed project would lead to increased landfill disposal or greater land application of green 

waste materials is not justified as the handling of such material is largely unaffected by 

permitting. For example, the largest windrow composting facility in the region processes more

than 200,000 tons per year of greenwaste, but would not require a composting permit from the 

SCAQMD because it does not process more than 5,000 tons per year of foodwaste. As a result, 

the environmental impacts associated with more greenwaste being disposed in landfills that the 

commenter listed are not likely to occur. 

Permitting a new facility would only occur if the facility intends to compost 5,000 tons per year 

of foodwastes or the facility voluntarily installs controls for other reasons, such as odor control to 

deal with LEA requirements. If pollution controls are installed, e.g., venting a compost pile to a 

control device such as biofilter, which would likely be considered BACT, there would be costs 

involved. Similarly, offsets may be required, but this will depend on the specific type of 

operation and the actual permitted emissions. In many cases, facilities may be eligible for an 

offset exemption. Although there could be costs involved for some types of operations, 

according to the socioeconomic impact analysis for the proposed rule and amendments, these 

costs would not be expected to be so onerous that it would be more difficult to obtain facility 

permits. 

As demonstrated in the paragraphs above, it is not anticipated that the proposed project would 

reduce the number of existing and future composting operations in the region. Consequently, 

the potential impacts associated with reducing the number of composting facilities in the district, 

e.g., ground water contamination, methane generation and emissions, increased emissions due to 

longer hauling distances between generator and facility, spread of imported pests outside 

quarantine areas, reduced stewardship of soil resources, increased erosion, and increased water 

use in landscaping, would not be expected to occur. 

Page 2-28 

On page 2-28 of the dEA, no impact to wastewater facilities is identified. However, by 

discouraging the siting of new composting facilities, opportunities to send food waste and other 

organic material to beneficial use will be more limited than what would be expected without the 

proposed restrictions. Therefore the amount of material requiring processing, with its attendant 

impacts, would be greater than the amount expected if additional facilities were more likely to 

come online. As pointed out on page 1-6 of the dEA, CalRecycle is planning on 50 to 100 new 

or expanded organic materials-diverting facilities, but these facilities would be discouraged by 

the proposed rule.


Neither the commenter nor other industry representatives have explained the basis for the 

assertion nor have they provided data or other information that the proposed rule and 

amendments would divert foodwaste to wastewater facilities, presumably by somehow reducing 

the number of or limiting affected facilities in the future. Please refer to the response to the 

comment on Page 2-9 above for the rationale explaining why it is not anticipated that the 

proposed project would reduce the number of existing or future facilities. These same reasons 

apply to facilities under consideration by CalRecycle. Further, it is very unlikely that the 50 to 

100 new or expanded organic materials-diverting facilities that CalRecycle is planning will be 

handling the quantities of foodwaste to require an air pollution control device, and CalRecycle 

has not indicated otherwise. Only two facilities/one operator surveyed has indicated that they 

would reach this level and have already agreed to install applicable controls. As a result, the 

proposed rule and amendments are not expected to impact wastewater facilities. 

Consequently, foodwaste is not likely to be diverted to wastewater facilities because that process 

requires considerable expense, such as through the creation of material delivery systems and 

potential modifications to increase capacity. Furthermore, only foodwaste greater 5,000 tons per 

year and 10 percent by weight would require control of emissions. An increase of foodwaste of 

that quantity would also likely require substantial expansion to wastewater processing facility 

systems. 

Page 2-40, 2-41 

The dEA concludes that the proposed rule provides flexibility regarding compliance. While it 

may be that existing facilities would not be forced to close, new facilities are less likely to be 

developed in the future because of increased permitting costs. Because the regulation would 

discourage new facilities, it is reasonable to conclude that tonnages entering the landfill would be 

higher than the rates that would be disposed in landfills without this regulation. Thus, there 

could be an impact on landfill capacity. 


The comment appears to concur with staff’s assertion that the proposed project would not 

“force” existing facilities to close. However, the comment provides no information or data to 

support the opinion that the proposed rule and amendments would discourage future facilities 

because of permitting costs. SCAQMD staff disagrees with the assertion that new facilities are 

less likely to be developed in the future because of permitting costs. Please refer to the response 

to comment “Page 2-9” for a comprehensive discussion of why costs are not expected to be so 

onerous that future facilities would not be developed. 

Thank you for your consideration of these comments. If you have any questions, please contact 

Renee Robertson at (858) 627-3308. 

Sincerely, 

Ken Prue 

************************************************************** 

Ken Prue

Recycling Program Manager 

City of San Diego 

Environmental Services Department 

9601 Ridgehaven Ct., Suite 320 

San Diego, CA 92123 

(858) 492-5085 (phone) 

(858) 518-3568 (cell) 

(858) 492-5089 (fax) 

kprue@sandiego.gov 

Please consider the environment before printing this e-mail

Response to Verbal Comments at Working Group Meeting 

Comment #1: SCAQMD’s proposed rule and amendments would drive composting materials 

out of the District. 

The proposed rule and amendments are not in conflict with any of the measures in AB32. 

Neither the commenter nor other industry representatives have explained the basis for this 

assertion nor have they provided data or other information that supports this assertion. It is 

assumed that this assumption is based on the incorrect notion that the proposed rule and 

amendments would be too onerous to comply with and, therefore, would cause affected facilities 

to close down, thus, requiring composting materials to be transported out of the district. This 

assertion is incorrect for the following reasons. PAR 1133.1 would establish best management 

practices (BMPs) to better manage stockpile operations associated with chipping and grinding 

activities. Affected facilities are already subject to the same greenwaste material processing 

requirements established in Title 14, Division 7, Chapter 3.1 of the California Code of 

Regulations (CCR). Approximately 70 existing greenwaste chipping and grinding operations or 

facilities would be affected by the requirements of PAR 1133.1. Based on staff evaluation of the 

effects of PAR 1133.1 for existing facilities, including a number of site visits, most of these 

affected facilities are already in compliance with the proposed amendments to Rule 1133.1, so 

there would be no reason to expect that facilities would be unable to comply with the proposed 

BMP requirements and there is no reason to expect that facilities would close down or that 

somehow fewer facilities would be built in the future. As a result, it is not expected that there 

would be a shift in the delivery of materials for composting from these facilities to alternative 

facilities located outside of the district. 

PR 1133.3 would establish operational BMPs for greenwaste composting operations that produce 

active or finished compost material from greenwaste-only or greenwaste in combination with 

manure or foodwaste. PR 1133.3 is applicable to 17 existing greenwaste composting facilities. 

Based on staff research and industry input from greenwaste composting facilities located within 

the district, it is expected that the current facilities would comply with PR 1133.3 by making 

minor adjustments (adding finished compost cover to initial compost piles, adjust watering 

schedules, etc.) in their current operational BMPs. Based on industry input, it is expected that 

affected facilities would be able to make the necessary minor adjustments in their operational 

BMPs at a relatively low cost, further supporting the conclusion that composting facilities would 

not be adversely affected by the proposed rule or that composting materials would be diverted 

out of the district. This view is supported by the socioeconomic impact analysis prepared for the 

proposed project, which showed that the primary economic effects of the proposed project are 

the loss of four new jobs in the affected industry in the future. Potential adverse environmental 

impacts associated with these minor adjustments (e.g., increased usage of existing loaders for 

compost cover) were analyzed in the dEA. Additionally, no existing facilities are expected to be

equired to install an emission control device without significant increases of foodwaste 

throughput on an annual basis (i.e., to 5,000 tons per year or more). If the commenter is 

referring to diversion from the closure of the Puente Hills landfill in 2013, that diversion is in no 

way related to the currently proposed rule and amendments. According to a PowerPoint 

presentation titled “Green Waste Management After Closure of Puente Hills Landfill,” prepared 

by the County Sanitation Districts of Los Angeles County, diversion of composting material 

from the closure of the Puente Hills landfill is already expected to occur to other facilities within 

the district and to areas outside the district. Few, if any, facilities subject to Rule 1133.3 are 

expected to exceed 5,000 tons per year except two facilities that are already planning on using 

these controls. 

Comment #2: If composting materials are spread to surrounding counties due to SCAQMD’s 

proposed rule and amendments, PAR 1133.1 and PR 1133.3 would cause the spreading of 

imported pests. 

Neither the commenter nor other industry representatives have explained the basis for their 

assertion or provided data or other information that the proposed rule and amendments would 

drive composting materials out of the district, presumably by somehow reducing the number of 

or limiting affected facilities in the future. Please refer to response to Comment #1 above for 

rationale indicating there would be no reason to expect that fewer facilities would be built or 

existing facilities would be unable to comply with the proposed rule and amendments. 

Therefore, there is no evidence to support that the implementation of the proposed rule and 

amendments would facilitate the spreading of imported pests. 

Comment #3: The proposed rule and amendments do not take into consideration the goals of 

AB32. 

The comment does not provide any information or data supporting the opinion that the proposed 

rule and amendments would conflict with any of the measures in AB32. It is assumed that this 

comment is based on the notion that the proposed rule and amendments would result in the 

closure of existing and future facilities. Please refer to response to Comment #1 above for 

rationale indicating there would be no reason to expect that fewer facilities would be built or 

existing facilities would be unable to comply with the proposed amendments. The primary intent 

of the proposed rule and amendments is to reduce criteria pollutant emissions, which are 

precursors to ozone and fine particulates. Furthermore, the proposed BMPs are intended to 

prevent anaerobic decomposition of greenwaste and alleviate adverse GHG and criteria pollutant 

emission impacts resulting from such conditions. Therefore, based on the information above and 

the emission reduction effects of the proposed project, it is not expected that the proposed rule 

and amendments would conflict with AB32. While the goal of the state program is to reduce 

GHG emissions, it is not intended to be at the expense of criteria pollutant control efforts.

Errata 

July 8, 2011 

Agenda Item No. 37 

Proposed Amendments to Rule 1133.1 – Chipping and Grinding Activities 

And 

Proposed Rule 1133.3 – Emission Reductions from Greenwaste Composting Operations 

Please amend page 2 of the Resolution in Attachment E of the Board letter, as follows: 

Second paragraph: 

WHEREAS, the Draft EA was circulated for a 30-day public review and comment 

period, no one comments letter and verbal comments were received from stakeholders, responses to 

written and verbal comments have been prepared and included in Appendix E of the Draft EA were 

received (subject to change), and the Draft EA will be revised to include responses to comments 

received such that it will beis now a Final EA; and 

and, fifth paragraph: 

WHEREAS, the AQMD Governing Board voting on Proposed Amended Rule 1133.1 

and Proposed Rule 1133.3, has reviewed and considered the Final EA, including responses to comments, 

and hereby certifies the Final EA; and 

Please add the following as the fourth paragraph to page 5 of the Resolution in Attachment E to the 

Board letter, as follows: 

BE IT FURTHER RESOLVED, that the AQMD Governing Board does hereby direct 

staff to work with stakeholders and other interested parties to explore the feasibility of utilizing a 

moisture meter as an alternative to the squeeze ball test included in Proposed Rule 1133.3 for the 

purpose of determining the moisture content of the compostable material before pile turning; and 

Please also amend Proposed Rule 1133.3, subparagraph (d)(2)(B), as follows: 

(B) For the first fifteen days after initial pile formation for the active phase period of composting, 

within threesix hours before turning, apply water as necessary to the surface area of each active 

phase pile such that the top one half of the pile is wet toat a depth of at least three inches. 

Alternatively, the operator may apply water during turning using a windrow turner which is 

equipped with water spraying technology during the entire windrow turning process. 

(i) For the purpose of this subparagraph, “wet” shall be determined by means of a squeeze 

ball test or an alternative approved by the Executive Officer, California Air Resources 

Board, and the United States Environmental Protection Agency. The ball test shall be 

conducted by taking a sample of the compostable material from the top half of the pile, at 

least three inches below the outer surface. The material should be squeezed into a ball 

using hand pressure and wearing a protective glove. There should be at least enough 

water to form a ball when compressed, but the ball may break when tapped. If the ball 

crumbles upon release of the hand pressure, apply additional water to the windrow prior 

to turning until the material passes the ball test.

-2-

3Amend Rule 1133.1 – Chipping and Grinding Activities, and Adopt ...

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