Local Enforcement Agency Compostable Organic Materials Regulatory Initiative

Scope of Work

Compostable Organic Materials Processing Contract Addressing Public Health And Nuisance Concerns

Composting and mulching have long been an accepted and practiced means of processing organic materials into products used in agriculture, erosion control, landscaping and other end uses. In California over 30 percent of the waste stream is comprised of compostable organic material. Currently there are over 175 regulated composting sites in California, along with an unknown number of chipping and grinding operations; many more are planned to assist in meeting solid waste diversion goals. Increased public scrutiny based on nuisance factors, as well as perceived health risk, continues to raise issues related to siting of composting facilities near or close to residential areas. Nuisances such as odors and odor complaints, interfere with siting and permitting of organic operations, limiting the amounts of organics able to be diverted from disposal and ultimately preventing jurisdictions from meeting their diversion goals.

The contract will assist the Board in achieving three of its four strategic plan goals:

1. To ensure compliance with waste management statues and regulations while maximizing protection of public health and safety and the environment.
2. To support the diversion of compostable organic material from landfills.
3. To aid jurisdictions in achieving AB 939 diversion mandates.

This contract will address issues related to public health and nuisance concerns from compostable organic materials processing. The contract will provide for the development of a resource guide for use by organic material site operators and enforcement agencies in methods and mitigation measures specific to composting and other organic material processing sites operating under California’s conditions. The contract will provide for the development and implementation of a research study that will investigate airborne bioaerosol levels from composting and other organic materials processing. The contract will provide for the development and implementation of a statewide study that will gather accurate and unbiased information on odor occurrences in California and successful operations, mitigation and or prevention methods which have been successful at California sites. Pertinent information from the study will be incorporated into the resource guide. In addition, the study will gather information on which odor measurement devices were found effective for monitoring operations and complaint investigation. The projects listed above will provide valuable information to State and local officials and other stakeholders on issues related to this California industry. Provided below is more specific information:

Development of this resource guide is to provide information on operational and mitigation measures that affect composting and other organic material handling operations. The resource guide will provide methods that may be used at a site to assist in evaluation for the protection of public health and the environment. The resource guide will also provide common sense strategies currently used in well-managed operations and possible future practices that will mitigate or control emission of bioaerosol from composting facilities. The guide will include not only standard and best management composting practices but address those practices that are unique to California’s industry. Highlighted topics within this guide will include design, siting, maintenance, operational and employee exposure issues. Special emphasis will be placed on addressing potential problems at the source by control methods such as, operational, engineering, design or administrative. The information provided is intended to aid the user by providing guidance when interacting with composting site operators and to assist in professional decision-making. The format of the guide should include question/answer and provide examples through scenarios. The document shall incorporate applicable statutory mandates as required by the California Code of Regulations (CCR). The reduction or control of any particulate emissions or nuisance factors using the best available demonstrated methodology or technology is considered the best way to lessen exposure and protect the health of compost workers and the neighboring communities.

Topics Covered in the Resource Guide

• Overview of Composting Process
  
• Potential Problems Associated with Composting Facilities (health risk, fire and aesthetic)
  
• Facility Siting Issues

• Location of Facility (area, proximity to residences and public facilities, visibility, drainage, and runoff control)
• Facility Size – Processing amounts
• Meteorological/Topographical Conditions (potential for air-inversions)
• Air Quality (dust and odor considerations)
• Traffic (vehicle entry)
• Site Near Sensitive Receptors (schools, hospitals, and nursing homes)
• Vectors/Sanitation

• Design and Construction Issues

• Processing Layout (New Facility)

• Feedstock or raw material unloading and storage
• Composting area (composting pad layout)
• Screening area
• Equipment area (type and number of equipment for size of operation)
• Conveying
• Storage bins
• Throughput capacity
• Final product storage, packaging, and distribution

• Existing Facility Expansion

• Facility Operational Practices/Control Methods

Best Management Practices-Operations Plan

• Feedstock
  
  • Type and quality
  • Screening loads
  • Preparation
  • Storage

• Active Composting
  
  • Particle size and aeration
  • Adding amendments or bulking agents
  • Nutrient balance
  • Pathogen Reduction: temperature and oxygen controls
  • Windrow configuration or pile geometry
  • Curing time and stabilization

• Control Methods

• Moisture control (water spraying)
• Odor control (feedstock & pile management, odor measurement devices and odor masking and/or preventing agents)
• Dust control (mechanical ventilation: bio-filters, chemical scrubbers, electrostatic precipitators, dry bag house)
• pH control
• Oxygen control
• Facility housekeeping
• Vehicular traffic control
• Total operation enclosure

• Employee Exposure

• Engineering Controls
• Administrative Control
• Personal Protective Equipment

Item 2 –Provide training/workshops on the Operational and Mitigation Measures Resource Guide for Compostable Organic Materials Processing Sites

This is a one-day training/workshop that will review the contents of the Operational and Mitigation Measures Resource Guide for Compostable Organic Materials Processing Sites. The information provided shall consist of practical hands on training exercises, workshops and case studies related to the information provide in this guide. All material shall emphasize best management practices associated with organic material processing sites.

Emphasis shall be placed on interactive teaching between participants and the instructor. The course will be offered to Board personnel and Local Enforcement Agencies (LEAs), operators and other stakeholders with a wide range of background and specialized training in composting operations. The class size shall be no more than 30 students with no less than four (4) class presentations; one in Sacramento, one in the Bay area, one in the Central Valley and one in Southern California (additional venues may be scheduled if needed and funding exists). Board staff will approve training/workshop agenda, format and venues.

Task 2 - Develop and Conduct a Comprehensive Study of Past Odor Occurrences in California of Composting and Other Organic Materials Processing Operations

Odor is one of the primary nuisances at organic material processing sites. There is very little available information on California specific odor mitigation measures. A study/survey is needed to collect data on odor occurrences and successful odor prevention and mitigation methods in California. The results of the survey would be used to provide guidance to operators and local enforcement agencies to ensure a comprehensive, consistent, and effective approach to odor control at compost sites in California. With passage of SB 675 in October 1997, local enforcement agencies and CIWMB are responsible for conducting investigations of odor complaints involving composting sites while ensuring the protection of public health, safety, and the environment.

This proposal is to solicit a contractor to develop and conduct a survey of California composters and other organic material processing site operators, air boards and districts and local enforcement agencies to gather information on past odor events and effective odor control.

Methodology

The contractor shall develop and conduct a telephonic/written survey of all organic material processing operators, air boards and districts and local enforcement agencies to gather information on odor events and odor complaint investigations in California. The survey will be retrospective from 1995 to present. At a minimum the survey should obtain the following type of data related to odor occurrences and odor complaint investigations:

1. date of complaint, if the complaint was verified, who complained
2. number of complaints for the site
3. name of company and operation
4. type and size of operation
5. SWFP (solid waste facility permit) number or tier
6. feedstock type and storage
7. proximity to receptors
8. odor control plan in operation at time of the incident(s)
9. evaluation of efficacy of odor detection equipment used, including detection limits
10. evaluation of efficacy of odor masking/preventing agents used, including type of product used
11. modifications to the odor control plan after the incident
12. odor prevention and control methods or products used, successfully and unsuccessfully
13. name of any odor training courses taken
14. enforcement action taken
15. number of odor events at site without complaints
16. any illness complaints associated with odors
17. symptoms of illness associated with odor complaints

The contractor will summarize all the results of the survey in a report and recommend odor prevention and mitigation methods based on the results of the study.

Task 3 - Development and implementation of a research study that will investigate airborne bioaerosol levels from composting and other organic materials processing facilities

Review of current literature indicates that there is little research data on dispersal patterns of bioaerosols from composting sites to the surrounding environment. To date, there is no conclusive evidence that bioaerosols associated with the operation of solid waste composting facilities endanger the health of the general public and environment. There is, however, information that links individual occupational exposure in settings such as mushroom production, timber processing, and cotton processing to verified health effects from continuous high concentrations to various bioaerosols. Milner et.al., concluded that more environmental monitoring data are needed to assist in evaluating potential health risks associated with organic materials processing operations.

This proposal is to solicit a contractor to develop and begin implementation of a research study that will investigate airborne bioaerosol levels from composting and other organic materials processing. The study would attempt to answer the following question:

How do bioaerosol (i.e., Aspergillus fumigatus) levels in neighborhoods surrounding selected composting and other organic materials processing operations compare to background levels, and are changes in these levels related to the operations? [Note: bioaerosols are defined as airborne particles composed of or derived from living organisms]¹

This environmental monitoring study will be designed to quantify bioaerosols levels in the environment at and near selected organic materials processing facilities. Sampling methodology will require state-of-the-art testing protocols, may include bulk samples to characterize bioaerosol type, perform sampling and analysis to quantify emissions, and report findings for emissions from various facilities statewide.

Methodology

The contractor shall propose methodology for development and implementation for environmental monitoring of airborne bioaerosols from selected organic materials processing facilities. This methodology shall consider all aspects related to the study's attempt to answer the question: "How do bioaerosol (i.e., Aspergillus fumigatus) levels in neighborhoods surrounding selected composting and other organic materials processing operations compare to background levels, and are changes in these levels related to the operations?"

The environmental monitoring study must be designed to quantify bioaerosols levels in the environment at and near selected organic materials processing facilities. As a minimum sampling methodology shall consider all of the following:

• State-of-the-art testing protocols.
• Bulk samples to speciate characterize bioaerosol type.
• Sampling methodology.
• Analysis to quantify.

The contractor shall develop an air-sampling program based on a well-considered strategy that takes into consideration the hypotheses stated above and must yield representative data results. The sampling plan must consider outdoor sampling protocol for bioaerosols such as bioaerosol generation by a wider variety of sources, collection during a variety of weather conditions, bioaerosol suspension in moving rather than still air, and changes due to relative humidity, ultraviolet radiation, and exposure to air pollutants. The air-sampling plan must consider as a minimum:

1. Possible sampling locations.
2. Number of samples to collect.
3. Bioaerosol concentration and seasonal and temporal variations in the concentrations of different biological agents.
4. Consideration of factors which may influence temporal (and spatial) variation including diurnal variation and seasonal cycles for the bioaerosol collected.
5. Meteorology and effects on particle transport.
6. Temperature and wind speed (or turbulence).
7. Volume of air to collect.
8. Sampling time required to collect a give volume of air.
9. Limitation of applicable assay systems [reference ACGIH: Bioaerosols: Assessment and Control. 2nd edition. JM Macher, HM Ammann, et.al., ACGIH, Cincinnati, OH].

The methods to be employed by the contractor to accomplish the project objectives must be described in sufficient detail to allow the Board to evaluate that method.

Last updated: April 18, 2008