SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT

Revised Proposed New Rule 4565

(Biosolids, Animal Manure, and Poultry Litter Operations)

March 30, 2007

Prepared by:		Sandra Lowe-Leseth, Air Quality Engineer 

Reviewed by:	Maria Stobbe, Planning Manager

George Heinen, Supervising Air Quality Engineer

Joven Nazareno, Senior Air Quality Engineer

Mike Buss, Senior Air Quality Engineer

Brian Clements, Senior Air Quality Engineer

Lucinda Roth, Senior Air Quality Specialist

Lori Sheriden, Air Quality Inspector

I.	SUMMARY

A.	Reasons for Rule Development and Implementation

In terms of state and federal standards, the California Air Resources
Board (ARB) and United States Environmental Protection Agency (EPA)
classified the San Joaquin Valley Air Basin (SJVAB) as a non-attainment
area for ozone.  The District is classified as a serious non-attainment
area for the federal 8-hour ozone National Ambient Air Quality Standards
(NAAQS).  It is anticipated that attainment of the eight-hour standard
will require the control measures cited in the District’s Extreme
Ozone Attainment Demonstration Plan (Ozone Plan), which includes a
control measure for composting/biosolids operations.  Since Rule 4565 is
a control measure in the District’s Ozone Plan, it is subject to
Federal Register, Clean Air Act (CAA), and California Health and Safety
Code (CH&SC) requirements.  Additionally, anti-backsliding provisions
commit the District to develop all control measures listed in the Ozone
Plan (Federal Register Volumes 69 and 70).  This rulemaking project is
intended to satisfy the attainment goal listed in the Ozone Plan. 
Additionally, the rulemaking project will seek to obtain as much VOC
emissions reduction from the source category as is expeditiously
practicable, technologically feasible, and economically reasonable, as
determined by the District's Governing Board.  Furthermore, the rule is
intended to satisfy the requirements identified in Table 1.

Table 1: Anti-backsliding and Ozone Plan Commitments

Subject	Reference	Requirement

Anti-backsliding	69 Federal Register 23955	Districts shall develop all
control measures listed in the Ozone Plan until the District is
designated as in attainment for the 8-hour NAAQS.

BACM	Federal Register 8/18/94	Provisions in attainment plans should
include the application of best available control measures (BACM) to
existing major stationary sources.

BARCT	CH&SC 40919(a)(3)	Ozone attainment plans should provide for best
available retrofit technology (BARCT) for existing permitted sources.  

Deadlines	Ozone Plan	Rule adoption by the 1st quarter of 2007.

All Feasible Controls	CH&SC 40914(a)(2)	Ozone attainment plans should
include "all feasible control measures."

RACT	Federal Clean Air Act (CAA) Sections 182(b)(2) and 182(f)	Ozone
attainment plans shall assure that reasonable available control
technology (RACT) for volatile organic compounds (VOC) is in use at
sources and on source categories at or above the RACT threshold.

RACT Threshold	70 Federal Register 30592-30596	The applicable RACT
threshold for control measures shall be the threshold in effect on June
15, 2004.  The Districts threshold on June 15, 2004 was 10 tons per year
(tpy) for VOC.  Therefore, 10 tpy is the RACT threshold for Proposed
Rule 4565.  

Reductions	Ozone Plan	The rule shall reduce VOC emissions by at least
14% from the baseline by 2010. Fourteen percent of the baseline used for
the Ozone Plan (0.7 tpd) is 0.1 tpd.

Timeline	CAA Section 172(c)(1)	Ozone attainment plans shall implement
control measures as expeditiously as practicable, and provide for
attainment.



B.	Description of the Project 

The main objective of this rulemaking project is to limit VOC emissions
from facilities that manage biosolids, animal manure or poultry litter. 
Biosolids are sewage sludge that has been treated to meet standards for
land application under Part 503 of the Clean Water Act.  Sewage sludge
is treated in the wastewater process, generally through aerobic or
anaerobic microbial activity for a specified time at a specified
temperature.  Sewage sludge requires treatment to ensure that its
release into the environment is protective of human health and the
environment as required by the Clean Water Act.  

II.	CURRENT REGULATIONS

Currently, the District does not have any prohibitory rules that
specifically regulate VOC emissions from facilities that manage
biosolids, animal manure, and poultry litter.  However, some composting
facilities may already be subject to permit requirements as a new or
modified source or as a source emitting significant air emissions under
District Rule 2010 (Permits Required) and District Rule 2201 (New and
Modified Stationary Source Review Rule).  

III.	DISCUSSION

Biosolids, animal manure, and poultry litter are commonly managed in one
of three ways:  buried in landfill, applied to land to enrich the soil,
or composted either alone or with other materials to make a soil
amendment.  When biosolids, animal manure, or poultry litter are
composted with other materials like greenwaste or bedding, it is called
co-composting.  Looking at biosolids specifically, the California
Association of Sanitation Agencies (CASA) surveyed facilities that
generate biosolids.  The 750,000 dry tons per year of biosolids in
California are managed in the following ways:

 4% surface disposed

 5% incinerated or stored in temporary storage

 6% disposed of in landfills

12% used as alternative daily cover (ADC) at landfills

54% land applied

16% composted

Rule 4565 would address VOC emissions from landfill, land application,
composting, and co-composting operations.  

A.	Section 1.0 Purpose/Section 2.0 Applicability

The purpose of the rule is to limit volatile organic compound (VOC)
emissions from operations that manage biosolids, animal manure, or
poultry litter.  The rule applies to any facility that landfills,
land-applies, composts, or co-composts material containing one or more
of the following:  biosolids, animal manure, or poultry litter.  Sewage
treatment plants or other wastewater treatment facilities are not
subject to this rule unless the operator landfills, land applies,
composts, or co-composts the treated material (biosolids) on site.

B.	Section 3.0 Definitions

This section lists definitions that pertain to the rule.  During the
course of rule development, adding and modifying definitions have
improved rule clarity.  The rule has changed the carbon dioxide
respiration end points and the Solvita Maturity Index numbers for
active, curing, and finished compost to match Test Methods for the
Examination of Composting and Compost by the US Composting Council
Research and Education Foundation (TMECC) Table 05.08-1 guidelines. 
Language was also added to the biosolids definition to clarify that
biosolids that have completed the composting process are considered
finished compost for purposes of this rule.  This distinction was of
concern to some landfill operators who may choose to use composted
material as an alternative daily cover (ADC).  

C.	Section 4.0 Exemptions

Except for records that verify the exemption, this section delineates
the facilities that are not subject to rule.  The types of exempt
facilities include:

Facilities subject to District Rule 4570 (Confined Animal Facilities) or
specifically exempt under Rule 4570; 

Composting/co-composting facilities whose throughput includes a total of
less than 100 wet tons per year of biosolids, animal manure, and poultry
litter; 

Facilities that land apply less than 10,000 tons per year of biosolids,
animal manure, or poultry litter; and 

Operations that bag un-composted biosolids, animal manure, or poultry
litter for sale.

As required under federal and state mandates with respect to districts
that are in non-attainment of established air quality standards, any
rule project seeks to obtain as much VOC emissions reduction from the
source category as is expeditiously practicable, technologically
feasible, and economically reasonable, as determined by the District's
Governing Board.  Therefore, any source subject to District Rule 4570 is
already subject to VOC limits for its operations, including any
landfill, land application, or composting/co-composting operations. 
Facilities that are specifically exempt from Rule 4570 are smaller
operations whose emissions are not significant, as determined during the
rule project.  

The exempted compost/co-compost facilities are operations for which
there is no established “best practices.”  Providing an exemption
for these facilities prevents the inclusion of facilities that accept
small amounts of biosolids, but may be accepting large amounts of
greenwaste, which will be addressed later as a separate rule project.

District staff used two concepts to determine the maximum amount of
material that could be land applied at a given facility before
mitigation measures would be required.  The concepts are the
District’s RACT emission level and the research done by South Coast
Air Quality Management District (SCAQMD) staff for Rule 1133.2 (Emission
Reductions from Co-Composting Operations).  Since there is no
peer-reviewed data about biosolids and land application, the
co-composting emission factor was used as a surrogate.  

As noted in Table 1 above, the RACT threshold for the District is 10
tons per year.  SCAQMD Rule 1133.2 uses 1.78 pounds VOC per wet ton of
material as an uncontrolled emission factor.  During the background
research for its rule, SCAQMD staff measured emissions as high as 2.36
pounds VOC per wet ton at a co-composting facility within the
District’s boundaries.  To calculate the amount of material
corresponding to 10 tons VOC emissions per year, the 10 tons per year
RACT limit was divided by the emission factor.  Using the 1.78 figure
yields about 11,200 wet tons of material per year and using the 2.36
figure yields about 8,470 wet tons per year.  District staff rounded the
calculated amount of material land applied to 10,000 tons per year,
which is equivalent to an emission factor of 2.0.

Some facilities bag un-composted animal manure or poultry litter for
sale.  District staff expects that emission from such facilities would
be minimal, since, within 15 days of receipt, the material is placed in
airtight bags or removed from the site.  The facilities are not
deliberately composting the material, so emissions from “incidental”
composting would be minimal.

D.	Section 5.0 Requirements

Section 5.0 of the rule addresses the specific requirements for landfill
operations, land application operations, and composting/co-composting
operations.  This section also includes provisions for VOC control
equipment and source testing.  The paragraphs below outline the main
rule requirements.

1.	Landfill Operations

Within 24 hours of receipt, biosolids, animal manure, or poultry litter
are required to be covered with either six inches of soil, six inches of
finished compost, a waterproof covering, or any other alternative daily
cover (ADC) that landfills are allowed to use under CH&SC Section 20690.
 In addition to covering the biosolids, landfill operators may choose an
alternative mitigation measure that provides at least 10% VOC emission
reduction.  The District and EPA must approve this alternative
mitigation measure.  The procedure for approval is outlined in Section
6.3 of the rule.  

Under California rules for solid waste management, landfills must cover
waste at the end of each working day, so this provision will not affect
these operations.  Although the state rule allows 24 hours, waste
arriving at landfills is always moving.  Once material arrives at the
landfill site, within a short time, other wastes are piled on top of the
material or the material moved from the working face and compacted. 
Even the very last truckload of material received on a given day would
be covered within a short amount of time, since, under California Code
of Regulations (CCR) for solid waste management, the landfill operator
is required to cover all landfilled material at the end of each
operating day.  This cover is called daily cover.  In addition to
certain materials used at specified depth, the CCR has a list of
allowable alternative materials and depths that can be used as daily
cover.  This is “alternative daily cover” or ADC.

The CCR allows biosolids as ADC, meaning that biosolids can be used as
the cover over the working face of the landfill required at the end of
the working day.  In a 1998 survey, the California Association of
Sanitation Agencies (CASA) estimated that 12% of all biosolids generated
in California are used as ADC.  All of the landfills that reported using
biosolids as ADC are located outside the District boundaries.  This
means that instituting this rule provision will not affect current
landfill operations.  The rule specifically limits the use of biosolids
or biosolids-derived material as ADC.  Operators must notify the
District before using these materials.  In approving biosolids as ADC,
District staff must consider the use of the covers specified in Sections
5.1.1.1 through 5.1.1.4 compared with using biosolids or
biosolids-derived material as well as other available controls.  The
notification by operators may also trigger Rule 2201 (New and Modified
Stationary Source Review Rule) Best Available Control Technology (BACT),
emission offsets, and public notification requirements.

Publicly owned treatment works (POTWs), i.e., sewage treatment plants,
generate biosolids on-site and could conceivably landfill those
biosolids on-site and therefore, the phrase “received at the
facility” would have no meaning in this case.  The January 4, 2007
version of the rule mentions “movement from location of generation.”
 The phrase caused more confusion than clarification, so it was removed
from the requirements in the revised proposed rule.

2.	Land Application

As noted at the beginning of Discussion section, the CASA survey found
that 54% of all biosolids were land applied.  This is the single largest
use of biosolids and dwarfs the next three uses combined.  Individual
counties may prohibit or regulate land application of biosolids.  More
specifically, The Strategic County-wide Biosolids Plan for Santa Barbara
noted that, in general:

San Joaquin, Stanislaus, and Tulare counties ban land application of
biosolids,

Fresno, Kings, and Kern counties ban land application of Class B
biosolids, and

Madera County has significant regulations for land application of
biosolids.

According to a report by the Iowa State University and the University of
Iowa Study Group, the following odor reductions were documented for land
application:

Injection with full soil coverage – 85%-90%

Surface applied, incorporated immediately by plowing – 50%

Surface applied, incorporation delayed by 3 hours – 0 – 10%

Surface applied, incorporation delayed by 6 hours – 0 – 5%

Surface applied, incorporation delayed by 12 hours – 0 – 5%

Surface applied, incorporation delayed by 24 hours – 0 – 5%

In the same report, the study group found that covering liquid manure
lagoons with chopped-straw has 75% odor reduction.  Several of the
components of odor are VOCs, and therefore, District staff has equated
odor reduction to VOC emission reduction.  

In Rule 4565, operators who land-apply biosolids, animal manure, or
poultry litter would be required to either inject the material at least
three inches below the soil surface, or to apply the material and then
incorporate it within three hours.  Immediate incorporation may not
always be practical.  For example, when there has been significant
rainfall in a short amount of time, it may not be possible to work the
ground on that day.  For those situations when the material cannot be
injected or land-incorporated within the 3-hour timeframe, operators
would be required to cover the material until the material could be
injected or land incorporated.  The three-hour timeframe was chosen to
have at least a 10% emission reduction of the emissions released before
direct injection/land incorporation.  In addition, some facilities
receive materials before daybreak to reduce traffic during the day.  A
special provision has been included to address this situation.  The
provision allows materials received after 6 pm to be incorporated by
12:00 pm (noon) the following day due to safety issues that otherwise
would occur when land incorporating at night.

Publicly owned treatment works (POTWs), i.e., sewage treatment plants,
generate biosolids on-site and could conceivably land apply those
biosolids on-site and therefore, the phrase “received at the
facility” would have no meaning in this case.  The January 4, 2007
version of the rule mentions “movement of material from point of
generation.”  The phrase caused more confusion than clarification, so
it was removed from the requirements of the rule.

3.	Composting/Co-composting Facilities

Recognizing that there is no such thing as a typical composting
facility, and not all options are feasible for all facilities, staff
developed a menu approach for these facilities.  Operators of composting
facilities are required to choose a specified number of practices and
technology from a list, which staff believes satisfies the CH&SC Code
40919(a)(3) requirement for BARCT and Federal Registry 8/18/94
requirement for BACM.  In each case, facilities can use mitigation
measures listed in the rule or develop mitigation measures of their own
to comply with the rule requirements.  The options in the rule include
both management practice options (e.g., managing moisture content;
covering piles with finished compost between turnings) and technology
options (e.g., use of aerated static piles and in-vessel composting
systems).  

Furthermore, in order to acknowledge that some VOC mitigation measures
are only cost-effective for larger facilities, staff developed the
concept of Class One and Class Two mitigation measures.  Class One
mitigation measures are considered BARCT and cost-effective options for
all facilities, regardless of size.  These measures are management
practices found to be best practices for all composting operations. 
Class Two mitigation measures are the technology options and achieve
reductions greater than Class One mitigation measures, however they are
not cost effective for facilities with throughputs of less than 100,000
wet tons per year.  The estimated cost effectiveness of implementing
Class Two mitigation measures for facilities with throughputs of at
least 100,000 wet tons per year is about $9,800 to $41,300 per ton of
VOC reduced.  On the other hand, for facilities with throughputs less
than 100,000 wet tons per year, the estimated cost effectiveness of
implementing Class Two mitigation measures is between $48,000 to
$860,000 per ton of VOC reduced.  Appendix C of the Final Draft Staff
Report details the costs and cost effectiveness analysis.

 

In general, aerobic composting conditions result in less VOC emissions
than anaerobic composting conditions.  Based on this premise, the
Southwest Clean Air Agency (SWCAA) identified in their Hanaford Farm
Best Available Control Technology Determination several composting
parameters that minimize emissions by promoting aerobic composting
conditions.  These include:

Scraping/cleaning of process areas—SWCAA stated that scraping or
sweeping clean all process areas of compostable material each day is
required to prevent material from being compacted.  These compacted
materials often give off offensive odors thus, presumably, are decaying
anaerobically;

Maintaining a minimum oxygen concentration of at least 5%, by volume, in
the free air space of composting material and turn piles if low oxygen
levels are detected;

Maintaining a compost moisture content no greater than 70%-- SWCAA
stated that when compost moisture exceeds 70%, the amount of free air
space may be reduced to the point where anaerobic conditions are likely
to develop.  In addition, excessive amounts of water surrounding
composting material can slow oxygen transfer to the point that anaerobic
conditions develop on the surface of the material even when adequate
oxygen exists within the free air space; and

Maintaining carbon to nitrogen ratios of piles of at least 20:1.  

Additionally, staff believes that rapid processing or covering of
organic waste material will minimize VOC emissions.  This is based on
discussions by the Dairy Permitting Advisory Group and Rule 4651 (Soil
Decontamination).  Staff believes that the same principals that suggest
minimizing exposed surface area of manure and contaminated soil results
in minimization of VOC emissions would apply to compost piles.

For the Class Two mitigation measures, the rule contains supplementary
requirements for the process.  VOC emissions would be measured on the
fourth day after initial pile formation for aerated static piles (ASPs)
and in-vessel composting.  The capture efficiency of an ASP or in-vessel
process cannot be easily quantified, so the purpose of the testing is to
assure that the process is capturing as much of the VOC generated by the
process as possible.

4.	VOC Emission Control Systems

The most commonly used VOC emission control device at composting
facilities are biofilters.  Currently, biofilters are used at over 200
composting facilities in Europe, over twenty composting facilities in
the United States of America, and at least five composting facilities in
California. 

The typical biofilter design consists of fans, ducts, media support (a
bed liner), an air plenum, and the media (typically a blend of finished
compost, soil, and/or wood chips).  Wall ventilation and pit fans blow
air from the building and pit through ducts into an air plenum below the
biofilter media.  The air passes through the media, where microorganisms
treat the air before it is released to the atmosphere.  A schematic of a
biofilter is shown in Figure 1 below.

Figure 1- Sample Biofilter Design

As shown above, biofilters are technologically simple yet effective VOC
controls.  At Las Virgenes composting facility in Calabasas, CA, the
biofilter routinely removes over 80% of the VOC (Peters).  This is
similar to results found by other researchers.  Rule 4565 requires
operators to monitor the biofilter for five parameters:  temperature,
moisture, pH, appearance (visual inspection), and fugitive VOCs.  Since
the control over a biofilter is less direct than for thermal oxidizers,
monitoring these parameters would allow the operator to determine that
the biofilter is within the most optimal range for VOC removal.

While it is most likely that operators at composting facilities would
choose biofilters as their VOC control device, Rule 4565 does allow for
operational flexibility by also addressing controls for non-biofilters. 
Additionally, both biofilters and non-biofilters would be required to
prove their control efficiency through source test every two years.

E.	Section 6.0 Administrative Requirements

Section 6.0 has been designed to match the administrative requirements
with requirements in other sections of the rule.  For example, records
required are in Section 6.1, test methods are in Section 6.2, etc. 
Furthermore, the records for exempt facilities are in Section 6.1.1,
records for landfills are in Section 6.1.2, and so forth.  Section 6.3
outlines the procedure for operators wishing to implement an alternative
mitigation measure.  This procedure mirrors the one in SCAQMD Rule
1133.2.  Based on conversations with EPA Region IX staff, approval of
the alternative mitigation measure would include EPA approval in
addition to the APCO approval.

F.	Section 7.0 Compliance Schedule

Landfill operations would be required to comply with all rule provisions
within twelve (12) months of rule adoption.  Land application facilities
have a two tier approach based on amount of material incorporated. 
Facilities utilizing less than 100,000 wet tons per year would have 12
months to come into full compliance.  Large facilities, meaning
facilities that handle more than 100,000 wet tons per year of biosolids,
animal manure, or poultry litter would most likely require more
equipment to meet the proposed land application requirements.  For these
largest facilities, the operator would be in full compliance within 18
months of rule adoption.

Operators of compost facilities with throughputs of less than 100,000
wet tons per year would comply within eighteen (18) months of rule
adoption; operators of compost/co-compost facilities with throughputs of
at least 100,000 wet tons per year would comply within thirty-six (36)
months of rule adoption.  For those facilities that plan to convert
compost/co-compost operations to energy generation operations, extended
compliance schedule is allowed if the operator meets specific provisions
within defined timeframes.  Composting/co-composting operations not part
of the energy generation operation would be required to meet the same
compliance schedule as if they were not part of an energy generation
conversion.  A composting/co-composting operation originally planned for
energy generation operation that does not become part of the energy
generation operation would be in-vessel operation with 90% control of
VOC emissions.

IV.	COMPARISON BETWEEN PROPOSED NEW RULE 4565 and SCAQMD RULE 1133.2

Staff noted that there are some significant differences between District
Rule 4565 and SCAQMD Rule 1133.2.  This should not be interpreted to
mean that one rule is more stringent than the other but due, instead, to
the following factors:

Technology has changed significantly since SCAQMD Rule 1133.2 was
adopted;

Additional research projects regarding mitigation measures have been
completed since SCAQMD Rule 1133.2 was adopted; and 

The socioeconomic climate of the SCAQMD is significantly different from
that of the San Joaquin Valley Unified Air Pollution Control District.

Table 2 summarizes the significant differences between SCAQMD Rule
1133.2 and SJVUAPCD Rule 4565.  Please note staff only included the
significant differences, not all of the differences, between the two
rules.

Table 2: Significant Differences

	SCAQMD Rule 1133.2	SJVUAPCD Rule 4565	Reason

Facilities Other Than Co-Composting	Rule does not apply to these
operations	Management practices for facilities that landfill and land
apply.

Management practices and control technology for large composting
facilities; management practices only for other composting facilities
Knowledge of VOC control options has increased since Rule 1133.2
adoption and staff believes that cost-effective methods of controlling
VOC emissions from these facilities exist.

Co-Composting Threshold for Applicability	Facilities with at least 1,000
to 3,000 tpy throughput	Facilities that handle 100 tpy or more of
biosolids, animal manure, or poultry litter	Staff believes that there
are reasonable, cost effective options for facilities with throughputs
of at (100 tpy that would not impose an undue burden on operators.

Control Requirements	In-vessel composting with 70 – 80% VOC control
efficiency	VOC control efficiency 10% -80% depending on type of
operation and facility throughput	Management practices (mitigation
measures) are effective, reasonable, and have been achieved in practice
for smaller facilities.

In-vessel composting is not cost-effective for smaller or medium
facilities and there are no known, unsubsidized facilities in the SCAQMD
that would comply with such rule requirements.



V.	VOC EMISSION REDUCTION ANALYSIS

District staff estimates that current VOC emissions from land
application and composting of biosolids, animal manure, and poultry
litter is over 3,500 tons of VOC per year with estimated emission
reduction of 1,430 tons per year when the rule is fully implemented. 
This represents about a 40% reduction in the baseline VOC emissions for
this source category.  The VOC emission reduction analysis is included
in Appendix B of the Final Staff Report.

VI.	COSTS AND COST EFFECTIVENESS ANALYSIS

The California Health and Safety Code 40920.6(a) requires the San
Joaquin Valley Unified Air Pollution Control District to conduct a cost
effectiveness analysis of available emission control options before
adopting each BARCT rule. The purpose of conducting a cost effectiveness
analysis is to evaluate the economic reasonableness of the pollution
control measure or rule.  The analysis also serves as a guideline in
developing the control requirements listed in a rule.

District staff has evaluated costs and cost effectiveness for sources
affected by Revised Proposed New Rule 4565.  

For landfill operations and land application operations, no additional
costs are expected as a result of following the rule requirements.  

For composting facilities, the cost of instituting the Class One
mitigation measures is estimated to have no cost impact, since the
mitigation measures represent best practices for
composting/co-composting operations.  

For the largest composting facilities, meaning those that have
throughput of at least 100,000 wet tons per year, total annualized costs
range from about $5.8 million to $24 million for all facilities to
implement the Class Two mitigation measures.  With estimated emission
reductions of 595 tons VOC per year, District staff estimates that the
cost effectiveness would range between $9,800 per ton VOC reduced and
$41,000 per ton VOC reduced.  

For composting facilities with throughput less than 100,000 wet tons per
year, the cost effectiveness value ranges from $48,000 to $856,000. 
Therefore, District staff believes that it is not cost effective to
require facilities with throughputs less than 100,000 wet tons per year
to implement Class Two mitigation measures.  It should be noted,
however, that the rule provides operators of small composting facilities
with the flexibility to comply by implementing Class One measures only
or a combination of a specified number of Class One and Class Two
measures. 

 

Details of the analysis are in Appendix C of this staff report.

VII.	SOCIOECONOMIC IMPACT ANALYSIS

Pursuant to state law, District staff is required to analyze the
socioeconomic impacts of any proposed rule or rule amendment that
significantly affects air quality or strengthens an emission limitation.
 During the first workshop, District staff solicited volunteers from
stakeholders, and manufacturers and vendors of control devices to
participate as members of the socioeconomic focus group for the rule. 
District staff worked closely with the focus group to determine direct
compliance costs of the proposed rule provisions.  The District’s
independent consultant participated with the focus group to identify and
analyze the socioeconomic impacts of the proposed rule.  District staff
considered the socioeconomic analysis to further refine the proposed
rule.  The socioeconomic impact analysis report is attached to this
staff report as Appendix D.  A draft of the socioeconomic impact
analysis report was posted for comment to interested parties on February
8, 2007.  The final socioeconomic report was presented to the District
Governing Board at the public hearing for the rule in order to disclose
any expected economic impacts.

VIII.	ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Act (CEQA), District
staff has investigated the likely environmental impacts of Rule 4565. 
Based on the lack of evidence to the contrary, District staff has
concluded that the revised proposed rule will not have any significant
adverse effects on the environment.  Staff recommends filing a Notice of
Exemption under the provisions of Public Resource Code 15061 (b)(3).

IX.	RULE CONSISTENCY ANALYSIS

Pursuant to state Health and Safety Code, Section 40272.2, District
staff has prepared a rule consistency analysis.  The rule provisions are
consistent with EPA policy and guidelines for sources subject to Rule
4565.  Details of the rule consistency analysis are attached as Appendix
E to this staff report.

X.	Rule Development Process

As part of the rule development process, District staff conducted public
scoping meetings in March 2005 and public workshops in October 2006 and
January 2007.  Staff has conducted a socioeconomic focus group meeting
in order to present, discuss, and solicit comments on the compliance
costs and impact to businesses as part of the socioeconomic impact
analysis.  The proposed socioeconomic impact analysis was posted for
written comment February 8, 2007.  

In addition to the workshops, staff has met with stakeholders to receive
comments on the technical aspects and compliance costs of the proposed
rule. The comments received from the public, affected sources,
California Air Resources Board, and United States Environmental
Protection Agency during the public workshop process and technical
consultation meetings have been incorporated into the proposed rule as
appropriate.  Appendix A of the Final Staff Report outlines the
significant comments received and the responses of District staff to the
February 15, 2007 version of the rule.

Proposed New Rule 4565 and the Final Draft Staff Report, including the
analyses mandated by CH&SC, were published before the public hearing for
the District Governing Board to consider the adoption of the proposed
rule.  The notice of the public hearing for this rule project was
published in a general circulation newspaper in each of the eight San
Joaquin Valley counties, and was mailed to affected sources and
interested parties.  The public notice solicited written comments and
identified the name and telephone numbers of the District staff who
answered questions and responded to comments.  The adoption schedule
allowed the District meet the Ozone Plan commitment to adopt a rule by
first quarter of 2007.  

XI.	REFERENCES

Anit, Selvi, Artuz, Robert, Biofiltration of Air,
http://www.rpi.edu/dept/chem.-eng/Biotech-Environ/MISC/biofilt/biofiltra
tion.htm.

Bartlett, Jerry Vice President Cedar Grove Composting Facility, e-mail
correspondence.

California Air Resources Board 2005 Almanac, available through links at
http://www.arb.ca.gov/app/emsinv/emseic_query.php?F_YR=2004&F_DIV=-4&F_S
EASON=A&SP=2005&SPN=2005_Almanac&F_AREA=CA&F_EICSUM=199.

California Air Resources Board 2003 Almanac, available through links at
http://www.arb.ca.gov/app/emsinv/emssumcat_query.php?F_DIV=0&F_DD=Y&F_YR
+2002&F-SESON+A&SP=2003f&F_AREA=CO&F_CO=2003.

California Code of Regulations, Title 14 Division 7 available at
http://www.ciwmb.ca.gov/Regulations/Title14.

CIWMB, SWIS database; Conversion Technologies for Municipal Residuals
May 3, 2001; Best Management Practices for Greenwaste Composting
Operations July 29, 2003; and Second Assessment of California's Compost
and Mulch Producing Infrastructure May 2004, available through links at
http://www.ciwmb.ca.gov.

Fondahl, Lauren, Biosolids Coordinator, EPA Region 9, e-mail
correspondence 10/14/04.

Garcia, Elizabeth Legislative and Regulatory Coordinator for Norcal
e-mail correspondence and Norcal website at
http://www.sunsetscavenger.com/jepson_prairie_organics.htm.

Iowa State University and The University of Iowa Study Group,
Concentrated Animal Feeding Operations Air Quality Study, February 2002;
available on-line at
http://www.public-health.uiowa.edu/ehsrc/CAFOstudy.htm

Peters, Deborah, Communications and Media Coordinator Las Virgenes MWD,
e-mail correspondence.

San Joaquin Valley Unified Air Pollution Control District Co-composting
Operation BACT Project #S-1032219, Application S-4212.

Sercu, Bram, Kristof Demeestere, et al, Degradation of Isobutanal at
High Loading Rates in a Compost Biofilter, Journal of the Air and Waste
Management Association, 2005, 55:1217-1227.  ISSN 1047-3289.

Schmidt, David, Janni, Kevin, Nicolai, Richard, Biofilter Design
Information, Biosystems and Agricultural Engineering Update, 2004,
BAEU-18, http://www.manure.umn.edu/assets.

Sonoma Technology Inc (STI) Contract 903340 available through links at
http://www.valleyair.org/Workshops/public_workshops_past.htm#Rule%204565
%20(Composting/Biosolids%20Operations).

South Coast Air Quality Management District Rule 1133, Rule 1133
Technical Report, and Source Tests available through links at
http://www.valleyair.org/Workshops/public_workshops_past.htm#Rule%204565
%20(Composting/Biosolids%20Operations).

Southwest Clean Air Agency, Technical Support Document Little Hanaford
Farms, SWCAA ID: 2228, April 19, 2005.  

van Lith, Chris, Leson, Gero, Michelsen, Richard, Evaluating Design
Options for Biofilters, Journal of the AIr and Waste Management
Association, 1997, 47:37-48.  ISSN 1047-3289.

Wallace, Z, How to Interpret Compost Analysis, 2005, available at
http://www.wallacez.freeserve.ca.uk/analysis.

Wheeler, PA, Stewart, I, Dumitrean, P, Donavan, B, Health Effects of
Composting, 2001, ISBN 1 857 05680 9, available through
publications@wrcplc.co.uk.



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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report for Rule 4565	March 30, 2007

 PAGE   12 

Final Staff Report for Rule 4565

Final Staff Report for Rule 4565

Biofilter Set-Up

Fan

Vent

Media

Air Plenum

Air Duct

Pit

Enclosure with Compost

Scrubbed

Exhaust Air

