Maricopa County recently held a second stakeholder workshop regarding the creation of the proposed Rule 327. The newly drafted rule regulates stockpiles and composting of organic material. This rule is meant to limit volatile organic compounds (VOCs) and ammonia emissions from these source types as well as addressing potential fire dangers associated with organic material handling activities.

Background:

Maricopa County Air Quality District (MCAQD) has been working to correct deficiencies in its regulation of volatile organic compounds (VOCs), which is a precursor for ozone. Maricopa County was recently redesignated as serious nonattainment for the 2015 Ozone National Ambient Air Quality Standard (NAAQS), prompting MCAQD to review and enact additional regulations on emission sources. In review of emission sources, MCAQD has determined the need to regulate and control VOC emissions from organic material processing, necessitating Rule 327. If adopted, Rule 327 would be included into the Arizona State Implementation Plan (SIP) for moderate ozone nonattainment.
In addition to regulating emissions from organic material processing sources, Rule 327 strives to limit potential fire danger from these activities as well. Large piles of organic material can self-generate heat causing spontaneous combustion. With proper control, these events can be properly deterred, increasing facility-wide safety. 

Facility Applicability:

The proposed language of the rule cites sources that produce 200 or more wet tons of any of the following material to be subject to the rule:

• Green material
• Food material
• Less than or equal to 75 percent animal manure or poultry litter

The rule also proposes exemptions for facilities that process organic material and do not sell to outside organizations, as well as residential and community composting. From the language in the draft rule, affected facilities will be commercial composting and organic material processing sites.
The new language added in this version of the rule includes tiered emission control requirements. The threshold to determine the applicability of the stricter, larger source regulations is held at 10,000 tons per year of organic material throughput.

Emission Controls:

The necessitated controls for affected facilities are the following: 

• Watering Systems: Watering is required for all applicable organic material handling facilities during the active phase. Rule 327 gives facilities two watering options: an independent watering system waters the surface area of the stockpile before turning and mixing the pile, or integrated watering systems in which water as the organic material is mixed and turned.
• Finished compost cover: A cover of organic material piles is required for all applicable facilities. The cover must be at least six inches in height over a third of organic material stockpiles. Initial covers are required, as well as after each turning for sites processing greater than 10,000 tons of material per year.

While the rule provides details into required controls for organic material stockpiles, testing and monitoring of the required emission controls to ensure compliance is also detailed in the new rule. Moisture testing serves as the primary compliance test. MCAQD has proposed three different moisture testing procedures in this draft of the rule.

Fire Prevention:

In addition to the sections covering air quality, Rule 327 provides regulations covering fire prevention practices to limit fire danger from organic material processing sources. Composting of organic material generates heat as material is broken down. Without proper controls, spontaneous combustion may occur causing hazards to the facility. The proposed rule covers best practices and standards to ensure fire hazards associated with organic material processing are properly addressed by facilities in Maricopa County. These standards include pile layout specifications and require specific material handling equipment. 
In addition, recordkeeping and monitoring is regulated in the new rule. Required monitoring and reporting activities include internal temperature measurements, smoke and smoldering monitoring, and fire reports. These new regulations would add new responsibilities and due diligence to composting facilities.

Conclusion

This proposed rule provides standards for a previously unregulated source in Maricopa County as the county tries to regain ozone nonattainment. The full draft language of the rule provides full specifics divulging into the new requirements MCAQD will enforce. 
This proposed rule is subject to change as it goes through the regulatory process; however, the current draft language provides a good picture of how a finalized rule may affect organic material handling processing sources. Prior to the second stakeholder meeting, the proposed rule went through a previous Stakeholder workshop meeting and has been reviewed in a Board of Health meeting to initiate the change. Rule 327 will go through a second review from the Board of Health and a public hearing with the Board of Supervisors before implementation.
If you would like to discuss Rule 327 and how it may impact your facility, please contact Trinity’s Phoenix office or call 602.274.2900.