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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010



## APPENDIX B

BASELINE EMISSI ON INVENTORY

AND EMISSION REDUCTION ANALYSIS

FOR REVISED PROPOSED RULE 4570 (CONFINED ANIMAL FACILITIES)

October 21, 2010

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

APPENDIX B

BASELINE EMISSION INVENTORY AND ESTIMATED EMISSION REDUCTIONS

I. SUMMARY

The purpose of this appendix is to detail the emission inventory and emission reduction analyses associated with the proposed amendment s to Rule 4570 (Confined Animal Facilities) (CAF). The rule applicability threshold has been lowe red for dairies and poultry (laying and broiling chi ckens) operations. The lowering of the threshold will make many previously exempted facilities subject to the requirements of the rule. Additional mitigation measures are also required for dairy operations. Although many measures have now been mandated in the proposed rule for all of the CAF categories, no additional emission reductions are expected fr om feedlot cattle, other cattle, swine, turkeys, goats, sheep, horses and other sm aller CAFs. Therefore, no analysis will be performed for these categories and this anal ysis will only calculate the emissions reductions from dairy, layer and broiler CAF categories.

A. Baseline Emission Inventory for Affected CAFs

The baseline emission inventory for CAF types affected by the amendments to this rule

is summarized in Table 1.

Table 1 - 2012 Population Estimate VOC Emission Inventory in tons per day Type of CAF 2008

current rule 

### 2012

without rule reductions 

### 2023

without rule reductions 

### Dairy 95.82 105.82 137.38 Poultry

Laying Chickens 0.26 0.26 0.26

Broiler Chickens 7.35 7.35 7.35

Total CAF Emissions 112.4 122.4 153.96

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

B. Estimated Emission Reductions

Table 2 summarizes the estimated emissi on reductions from each type of CAF.

Table 2 - Estimated Emission Reductions by CAF Type

Estimated Emission Reducti ons in tons per day Type of CAF 2012
(1 st full year of compliance) 

### 2023
(projected reductions) 

### Dairy 25.09 31.62 Poultry

Laying Chickens 0.01 0.01

Broiler Chickens 0.13 0.13

Total Estimated Reductions 25.23 31.76

II. EMISSION INVEN TORY METHODOLOGY

Emission inventories are calculated using an Emission Factor (EF) multiplied by a process rate. For CAFs, the EF is genera lly calculated on a per-animal basis, meaning that the EF is generally in pounds of emi ssions per head per year (lbs/hd-yr). The Emission Inventory can then be calculated by multiplying the EF by the number of animals at the facility. For dairies, recent studies have found feed (primarily from silage) to be a significant source of emissions. Si nce emissions from feed sources are based on an exposed surface area, the emissions are calculated by multiplying the area of the exposed feed surface and the EF in unit/area emitted. In order to calculate the emissions reductions, the emission inventory is multiplied by the control efficiency of each mitigation measure.

As a note, the reductions are only assessed fr om the facilities that exceed the Rule applicability levels. The remaining animals fo r each source are included in the inventory

as uncontrolled emissions.

A. Dairy Inventory

1) Dairy Population Estimation Method

The United States Department of Agriculture (USDA) National Agriculture Statistics Service (NASS) is one data source used to determine the number of animals within the District. NASS projects animal count s and livestock facility size distribution based a survey of a limited number of facilit ies. The most recent NASS information on CAF numbers is the 2007 Agriculture Census . The number of animals at dairies is reported in number of mature cows – wh ich means milking (lactating) cows plus dry adult cows. District staff disaggregated the number of mature cows into the number of milking cows and t he number of dry cows by using the District’s Permit

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

Services database of Permits to Operate. The permits list t he maximum number of milking cows, dry cows, lar ge, medium, and sma ll heifers and the number of calves for each facility. Using the overall rati os, the number of milking cows can be estimated by applying the ratio of milking co ws to the total of [milk cows plus dry cows] from the permits database to the number of dairy mature cows in the 2007 Agricultural Census.

Information from the Regional Water Board was also used to estimate the number of milking cows on dairies and dete rmine the various sizes.

The 2008 population estimate is shown in Table 3.

Table 3 - 2008 Population Estimate

County Population

Estimate Fresno Kern Kings Madera Merced San Joaquin Stanislaus Tulare Totals



### Milk Cows 94,889 140,181 144,106 60,184 211,644 91,183 150,721 384,772 1,277,678



### Dry Cows 23,711 29,319 31,394 15,116 46,556 17,817 32,679 87,928 284,522



### Large Heifers 33,444 50,621 43,877 20,338 45,920 19,660 42,579 113,806 370,246



### Medium Heifers 31,385 36,263 32,336 18,445 38,986 18,241 35,759 97,262 308,677



### Small Heifers 15,388 20,345 18,863 12,203 26,348 12,454 26,353 65,835 197,789



### Calves 10,967 17,636 14,673 18,178 42,015 11,051 17,755 67,526 199,802



### Totals 209,785 294,365 285,249 144,464 411,46 9 170,406 305,846 817,129 2,638,714



### The rule only looks to control emissions from dairy operations with ≥ 500 milk cows, however, the population estimates provided in Table 2 were disaggregated into the following categories: <300, ≥ 300<500, ≥ 500<1,000, and ≥ 1000 milk cows since the EFs for each of these categories vary, specifically for the silage piles. Silage piles sizes vary with the size of the dairy. The smaller dairi es will generally have smaller piles than the larger dairies. The categories suggested he re allow for a more accurate emissions inventory and emission reduction calculations.

Using the herd information fr om the Regional Water B oard, the dairy population breakdown by category type is shown in Table 4.

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

Table 4 - 2008 Dairy Cow Population Summary by Category

Category Milk Cows Dry Cows Large

Heifers Medium

Heifers Small

Heifers Calves Totals

< 300 34,303 7,517 8,926 7,679 5,594 5,240 69,260



### >= 300 88,602 19,433 23,807 20,184 12,410 13,107 177,542



### >= 500 260,158 57,618 72,327 61,081 38,644 39,142 528,968



### >= 1000 894,616 199,954 265,187 219,73 4 141,141 142,313 1,862,945



### Totals 1,277,678 284,522 370,246 308,67 7 197,789 199,802 2,638,714



### In order to determine the emissions reducti on effect of the rule in 2012 and 2023, population estimates for those years were also created. Data provided by the California Department of Food and Agriculture (CDFA) indicates that the average milk cow population in the last 7 years has grown approximately 3% per year. The District used this information to grow the 2008 estimate by 3% percent each year to derive the population estimate in Table 5 and 7. T he same methodology noted for Table 4 above was used to speciate the data into each ca tegory and animal type. The results are

shown in Tables 6 and 8.

Table 5 - 2012 Dairy Cow Population Estimate

County Population

Estimate Fresno Kern Kings Madera Merced San Joaquin Stanislaus Tulare Totals



### Milk Cows 106,798 157,775 162,192 67,737 238,207 102,627 169,638 433,064 1,438,038



### Dry Cows 26,687 32,999 35,334 17,013 52,399 20,053 36,781 98,964 320,232



### Large Heifers 37,642 56,974 49,384 22,891 51,684 22,128 47,923 128,089 416,715



### Medium

Heifers 35,325 40,815 36,394 20,760 43,879 20,530 40,247 109,469 347,419



### Small Heifers 17,319 22,899 21,231 13,734 29,655 14,017 29,661 74,098 222,613



### Calves 12,344 19,850 16,515 20,459 47,288 12,438 19,983 76,001 224,879



### Totals 236,115 331,311 321,050 162,596 463,11 2 191,794 344,232 919,686 2,969,896



### Table 6 - 2012 Dairy Cow Population Summary by Category

Category Milk Cows Dry Cows Large

Heifers Medium

Heifers Small

Heifers Calves Totals

< 300 38,609 8,460 10,046 8,643 6,296 5,898 77,952



### >= 300 99,722 21,872 26,795 22,717 13,968 14,752 199,825



### >= 500 292,810 64,849 81,404 68,747 43,494 44,054 595,358



### >= 1000 1,006,898 225,050 298,470 247,312 158,856 160,175 2,096,761



### Totals 1,438,038 320,232 416,715 347,419 222,613 224,879 2,969,896



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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

Table 7 - 2023 Dairy Cow Population Estimate

County Population

Estimate Fresno Kern Kings Madera Merced San Joaquin Stanislaus Tulare Totals



### Milk Cows 147,834 218,397 224,512 93,764 329,734 142,060 234,818 599,462 1,990,581



### Dry Cows 36,941 45,679 48,911 23,551 72,533 27,759 50,913 136,989 443,276



### Large Heifers 52,105 78,866 68,359 31,687 71,542 30,630 66,337 177,306 576,832



### Medium

Heifers 48,897 56,497 50,378 28,737 60,739 28,419 55,711 151,531 480,909



### Small Heifers 23,974 31,697 29,388 19,011 41,050 19,403 41,058 102,569 308,149



### Calves 17,087 27,477 22,861 28,320 65,458 17,218 27,662 105,203 311,285

Totals 326,838 458,612 444,409 225,071 641,056 265,488 476,498 1,273,060 4,111,031



### Table 8 - 2023 Dairy Cow Population Summary by Category

Category Milk Cows Dry Cows Large

Heifers Medium

Heifers Small

Heifers Calves Totals

< 300 53,444 11,711 13,906 11,964 8,715 8,164 107,904



### >= 300 138,038 30,275 37,091 31,446 19,334 20,420 276,605



### >= 500 405,317 89,766 112,682 95,162 60,206 60,981 824,115



### >= 1000 1,393,782 311,523 413,152 342,33 8 219,894 221,719 2,902,407



### Totals 1,990,581 443,276 576,832 480,90 9 308,149 311,285 4,111,031



### 2) Number of Dairies in the Valley

It has been estimated that ther e are approximately 1,331 dairies in the San Joaquin Valley. In order to calculate the silage emissions appropriately, the total dairies in the valley must be speciated into the fo llowing categories (<300, >= 300, >=500, and >=1000 milk cows) as discussed above. T he data provided by the Regional Water Board was used to develop the percent of dairies and the number of dairy facilities for each category, as shown in Table 9.

Table 9 - Estimated Dairies By Category

Category < 300 (SCAF) >= 300 (SCAF) >= 500 (CAF) >= 1000 (LCAF) 

### Total

# Dairies 

### 180 242 419 490 1331

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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

3) Silage Surface Area Estimation

The emission factors for total mixed rati ons (TMR) and for silage are based on the total amount of surface area exposed. In meetings with dairy industry representatives, stakeholders provided an average exposed area for both TMR and silage piles at dairies of various sizes. The following surface area, in square meters ( m 2 

### ), will be used to calculate the emissions from TMR and silage on a per-dairy

basis.

Table 10 - Estimated Size of Pile (m 2 

### ) Based on Size of Dairy

Size of Dairy >1,000 Milk Cows 300 to 999 Milk Cows <300 Milk Cows Size of Pile (m 2 

### ) 225 102 44.59 Size of Pile (m 2 

### ) 24 24 0 Size of Pile (m 2 

### ) 225 102 0



### B. Layer and Broiler Inventory

The population of animals in this category wa s estimated based on information from the USDA Agricultural Census and t he District’s Permit/CMP database.

District staff is expecting that these sect ors will not change sign ificantly between now

and 2023.

Table 11 - Laying and Broiler Chicken Inventory

Animal Type Number of Animals # of birds subject

to Current Rule Additional birds brought into proposed Rule 1



### Laying Chickens 9,565,825 5,548,179 1,050,000

Broiler Chickens 287,565,325 178,290,502 9,450,000



### III. EMISSION FACTORS

A. Dairy Emission Factors

The current uncontrolled Emission Factor (EF) being used by the District in the permitting of dairies is 19.3 lbs/hd-yr wh ich was based on a report released by the District on August 1, 2005, entitled “ Air Pollution Control Office r’s (APCO) Determination

of VOC Emission Factors for Dairies ” 2 

### . The report was based on the best available

science at the time and also outlined areas and sources which needed further studying. The District and other stakeholders developed mult iple studies which were tailored to fill

1 Based on information provided by industry, due to t he lowering of the applicability threshold for layers and broiler, 2 additional layer operations and 18 additional broiler operations will now be brought into the

Rule. It will be estimated that each of these operations has an average of 525,000 birds each

2 http://www.valleyair.org/busind/pto/dpag/APC O%20Determination%20of %20EF_August%201_.pdf



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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

in the information gaps identified in the previous work. These studies were performed in California to capture the conditions found on local dairies. Upon completion of these studies, the District undertook a very detailed analysis to revise the dairy VOC Emission Factor. This new analysis includes updates to the existing dairy emission sources that were documented in the 2005 report for the fo llowing sources: enteric emissions, milk parlor, freestall barns, corrals, lagoon/storage, and separated solid piles. The revised analysis also includes a great deal of data that strengthens the emission quantification

for other sources at dairies. These s ources are as follows: liquid and solid land application, manure piles, s ilage piles, and Total Mixed Ra tion (TMR). The revised analysis was released as a draft report (w hich can be found in Appendix I) for comment to the public on January 21, 2010, with the commenting date expiring on February 22,

2010.The District has reviewed all comm ents received, and does not expect any significant changes to the emission factor.

Summary of Dairy Emissions 3



### In summary, the table below shows t he APCO’s recommended revised EF for each

source or constituent:

Table 12 - Per Cow Dairy Emissions Factor

Process or Constituent Emissions (lb/hd-yr)

1. Enteric Emissions from Cows 4.1

2. Milking Parlor(s) 0.03

3. Freestall Barns 1.8

4. Corrals/Pens 6.6

5. Liquid Manure Handling (Lagoons, Storage Ponds, Basins) 1.3

6. Liquid Manure Land Application 1.4

7. Solid Manure Land Application 0.33

8. Separated Solids Piles 0.06

9. Solid Manure Storage 0.15

12. Composting & Manure

Disturbance TBD, >0

3 All milk cow Emission Factors discussed in this re port have been adjusted for all of the other support stock at a dairy which includes dry cows, heifers, an d calves. The adjustment is made by taking the ratio between the milk cow manure output to the other sup port stock and multiplying by the milk cow EF.



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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

Table 12 - Per Cow Dairy Emissions Factor

Process or Constituent Emissions (lb/hd-yr)

Total not including Feed 15.8



### Table 12a - Silage Pile VOC Emissions Flux

10. Silage Piles Emissions Flux (μg/m 2 

### -min)

1. Corn Silage 34,681

2. Alfalfa Silage 17,458

3. Wheat silage 43,844

Table 12b - Average TMR VOC Emissions Flux

11. TMR Emissions Flux (μg/m 2 

### -min)

Average 13,056

The above emission factors have been determined to include the mitigation measures

from the current version of Rule 4570 (adopted in 2006) based on the mitigation measures that were in place on the dai ries when the studies were performed. Therefore, the above emission factors will be used to calculate the baseline emissions inventory for dairies with greater than 1,000 m ilk cows (the current regulatory threshold for Rule 4570).

Dairies with less than 1,000 milk cows ar e expected to have no control as those facilities were not required to have any miti gation measures in place. In order to

determine the uncontrolled emissi on factor, the mitigation meas ures that were in place when the studies were performed need to be adj usted. The controlled EF of 15.8 lbs/hd-yr and the associated silage and TMR EFs will therefore be adj usted accordingly

to consider the control meas ures that were in place at the time the emission measurements took place. The following control measures were determined to be in place at the dairies where the em ission measurements were taken:

• Feed according to the NRC guidelines 4



### • Feed or dispose of rations within 48 hours of grinding and mixing rations

• Cover the horizontal surface of silage pi les, except for the area where feed is removed from the pile.

4 5% control efficiency will be used for this measure since one of the two dairies that were sampled did not include this measure when the testing was perform ed. Therefore, the aver age for the two dairies was taken (10%/2=5%).



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• Flush or hose milk parlor immediately pr ior to, after, or during each milking

• Clean corrals at least once between Apr il and July and at least once between

October and December

• Manage corrals such that the depth of animal waste in the corral does not exceed 12” at any point or time , except for in -corral mounding 4



### • Maintain corrals to ensure proper drainage

• Inspect water pipes and troughs and repair leaks at least once every 14 days 4



### • Install shades uphill of the corrals 4



### • Remove solids from the waste system wit h a solids separator system, prior to the waste entering the lagoon

• Land incorporate all solid manure within 72 hours of applying to land

• Do not allow liquid manure to sta nd in fields for more than 24 hours

Dairy emissions research indicates that the proposed mitigation measures will achieve significant emissions reductions. Based on this science, and in an effort to be
conservative, the District has assessed a 10% minimum control efficiency to the majority of mitigation measures, which the District believes may underestimate the

emissions benefits of t he proposed rule. The majority of the VOC emission reductions achieved by the proposed rule are expected to come from the meas ures for silage and the total mixed ration (TMR) prepared from t he silage. These practices are likely to

exceed the District conservative control efficiency estimates as discussed below. 5



### Increased Density & Proper Management of Silage Piles The proposed rule requires best management practices that will reduce dry matter loss and emissions of VOCs. Chapter 40, “Silage Production”, of Forages - The Science of Grassland Agriculture 6 

### indicates that dry matter loss in silage piles can be as high as 35% but proper management of the silage can reduce this loss to 15% or less, a 57% reduction in dry matter loss. While some of the dry matter loss is the result of reduced CO2 production; a large reduction in weight lo ss is also attributable to a large reduction

in VOC emissions.

Additionally, Dr. Charles Kraut er of California State Univ ersity, Fresno measured VOC emissions from silage and feed while per forming a study on dairy emissions. Information from his completed study has shown that silage wit h higher density emits significantly less total VOC emissions from both the silage piles and the TMR. This

information indicates that ethanol emissions from two silage piles with the lowest

5 Section XVIII “References” of the Staff Report, Appendix A of the Da iry Emission Factor Report, and the previous Rule 4570 staff report identifies additional studies that support the District’s analysis.

6 "Silage Production" ( Forages - The Science of Grassland Agriculture , Chapter 40, December 2006) by Richard E. Muck, Agricultural Engineer, US Dair y Forage Research Center, Agricultural Research Service, USDA, Madison, WI and Limin Kung, Jr., Prof essor of Animal and Food Sciences, University of
Delaware, Newark, DE http://ddr.nal.usda.gov/bitst ream/10113/9224/1/IND43941281.pdf



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Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

densities were more than twice as great as the average ethanol emissions from all other remaining piles.

Although the expected reduction in dry matt er loss from proper management of silage piles can be as high as 57% and informati on from Dr. Krauter’s study showed that adequate density could potentiall y reduce ethanol emissions by as much as 50%, the District conservatively applied a 25% c ontrol efficiency for this measure.

Inoculation with Ho molactic Bacteria In a study by Filya 7 

### , inoculation with homolactic lactic acid bacteria (L. plantarum) resulted in an average reduction in ethanol conc entration of 12.1% in the corn silages that were studied compared to the control wit h no inoculation. The study also found that

inoculation with homolactic lactic acid bacte ria reduced weight loss in corn silage by an average of 43.2% compared to the control wit h no inoculation. Similar to the study above, a large reduction in weight loss is also attributable to a large reduction in VOC emissions. Although this study found an average reduction in ethanol concentration greater than 10% and an average reduction in weight loss much greater than 10%, the District conservatively applied a 10% c ontrol efficiency for this measure.

Antifungal Chemical Additives Another study showed that t he addition of sodium benzoate and a potassium sorbate

additive reduced ethanol concentrations in corn silage by 73.2% and 79.7%, respectively compared to the control. The study also found that these additives reduced dry matter loss by more than 85.7%. 8 

### While this study found reductions in ethanol concentration and dry matter loss much greate r than 10% the District conservatively applied a 10% control efficiency for this measure.

Although the District believes that the VOC emission reduct ions achieved by several measures included in the proposed rule may be underestimated, the District will continue to seek out and support research that further enhances its understanding of CAF emissions and potentia l mitigation measures.

Applying the above assumptions to the proposed EF of 15.8 lbs/hd-yr and the associated silage and TMR EFs results in a corrected uncontrolled EF of 20 lbs/hd-yr. The 20 lbs/hd-yr is consistent with the unc ontrolled EF of 19.3 lbs/hd-yr that was established in the 2005 APCO VOC report 2 

### . The 20 lbs/hd-yr EF and the associated

7 Filya, I., 2003. The effect of Lactobacillus buchneri and Lactobacillus plantarum on the fermentation, aerobic stability and ruminal degradability of low dry ma tter corn and sorghum silages. J. Dairy Sci., 86:

3575-3581.

8 Kleinschmit, D. H., Schmidt, R. J., and L. Kung, Jr . 2005. The effects of various antifungal additives on the fermentation and aerobic stability of co rn silage. J. Dairy Sci. 88:2130-2139.



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B-13 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 

### adjusted silage and TMR EFs wil l therefore be used as the uncontrolled baseline EF for
dairies with less than 1,000 milk cows.

Table 13 shows the breakdown of the emission calculations. A sample calculation for

Enteric Emissions demonstrates how the calculations were conducted:

Enteric Emissions = 4.1 lbs/hd-yr ÷ (1 - Control Efficiency Feed to NRC Guideline 

### ) = 4.1 lbs/hd-yr ÷ (1 - 0.05) = 4.32 lbs/hd-yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Baseline Emission Inventoryand Emission ReductionsOctober 21, 2010B-14Final Staff Report with Appendices ForRevised Proposed Amendments to Rule 4570Table 13 - Correcting Dairy Emission Baseline SummaryFeedSilageParlorCorralsLiquidLand AppSource Proposed Revised Draft EF Feed to NRC Guidelines feed/dispose rations 48 hrs Silage pile cover flush parlor after each milking remove manure April to July depth of waste not exceed 12 " in corral ensure d ra i nage - slope surface - harrow/rake Inspect Water pipes Install Shades uphill remove solids w/ separator incorporation not let water stand in field > 24 hrs Corrected Baseline EF1. Enteric Emissions4.15%4.322. Milking Parlor(s)0.035%10%0.043. Freestalls (lanes)0.85%0.84Freestall beds1.05%1.054. Corrals/Pens6.65%10%5%10%5%5%10.005. Liquid ManureHandling (Lagoons,Storage Ponds)1.35%10%1.526. Liquid ManureLand Application1.45%10%1.647. Solid ManureLand Application0.335%10%0.398. Separated SolidsPiles0.065%0.069. Solid ManureStorage0.155%0.16Total not includingFeed15.820.010. Silage Piles(μg/m2-min)Corn Silage34,68110%38,534Alfalfa Silage17,45810%19,39848,716Wheat silage43,84410%11. TMR13,05610%14,507

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

Emission Factors for Dairies wit h greater than 1,000 milk cows (large dairies) with proposed Rule 4570 mitiga tion measures in place

As indicated above, the baseline emission factor for dairies with milk cows greater than 1,000 milk cows is 15.8 lbs/hd-yr. T he proposed rule includes many mandated measures in addition to requiring additio nal mitigation measures. The control efficiencies of the additional mitigation meas ures will be applied to the baseline EF of 15.8 lbs/hd-yr which will result in a further controlled EF.

All of the mitigation measures and assumpti ons are listed below for an example dairy:

Example dairy with the proposed rule mitigation measures:

• Feed according to the NRC guidelines

• Feed steam-flaked, dry rolled, cracked or ground corn or other steam-flaked, dry rolled, cracked or ground cereal grains

• Begin feeding or disposing of total mix ed rations within two (2) hours of grinding and mixing rations.

• Store grain in a weatherproof stor age structure from October to May

• Push feed to within three (3 ) feet of feed bunk fenceline

• Cover the surface of silage piles, except for the area where feed is removed from the pile.

• Silage Inoculation

• Manage multiple silage piles such that t he total exposed surface area of all silage piles is less than 4,300 square feet

• Incorporate the following practi ces when creating a silage pile: 9



### o Harvest silage crop at: ≥ 65% moisture for corn; and ≥ 60% moisture for alfalfa/wheat/grass using TM BBB.

o Set chop particle length to 1/2 inch or less for unprocessed silage

material.

o Manage silage material delivery such that no more than six (6) inches of material are uncompact ed on top of the pile.

o Cover silage pile within 72 hours of la st delivery of mate rial to the pile.

• Flush or hose milk parlor immediately pr ior to, after, or during each milking

• Flush, scrape, or vacuum freestall flus h lanes immediately prior to, immediately after, or during each milking

• Rake, harrow, scrape, or grade bedding in freestalls at least once every 14 days

• Clean corrals at least once between Apr il and July and at least once between September and December.

9 All these practices result in reduced porosity, whic h in turn reduces ethanol production. A significant

amount of emission reductions can be achieved throu gh this practice, however to be conservative, a 25% control efficiency will be applied. These management practices will also have a reduction in emissions from the TMR. To be conservative, only a 10% cont rol efficiency will be applied at this time, although emissions reductions could be significantly greater.



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B-16 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 

### • Scrape, vacuum, or flush concrete lanes in corrals at least once every day for mature cows and every sev en (7) days for support stock

• Inspect water pipes and troughs and repair leaks at least once every seven (7) days.

• Maintain corrals to ensure drainage and prevent water from standing more than

48 hours after a storm

• Install shade structures such that they are constr ucted with a light permeable roofing material

• Manage corrals such that the depth of animal waste in the corral does not exceed 12” at any point or time, except for in-co rral mounding. Manure depth may exceed 12 inches when corrals becom e inaccessible due to rain events. The facility must resume management of the manure depth of 12 inches or lower immediately upon the corral becoming accessible.

• Cover dry animal waste piles outside the pens with a weatherproof covering from October to May, except for times, not to exceed 24 hours per event, when wind events remove the covering

• Remove solids with a solids separator system, prior to t he manure entering the lagoon

• Apply no solid manure with a moistu re content of greater than 50%

• Allow liquid animal waste to stand in the fields no more than 24 hours after irrigation

Applying the above mitigation measures and the associated control efficiency to the 15.8 lbs/hd-yr and the associ ated silage and TMR baseline EFs results in an Revised Proposed Rule 4570 control EF of 13.5 lbs/hd-yr for th e manure and a significant change (decrease) for the silage and TMR EFs. These EFs will be used towards developing the Revised Propos ed Rule 4570 emissions inv entory and will serve as the basis for the reductions for this proposed ru le for the greater than 1,000 milk cow category.

Table 14 summarizes the calculations of the emission factors.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Baseline EmissionInventory and Emission Reductions October21,2010Table 14 - Dairy Emission Factor after applying current R4570 requirementsFeed MitigationSilageParlorFreestallsCorralsSolidliquidLand appSource Baseline EF Feed to NRC Guidelines** Push feed within 3 feet feed/dispose rations 2 hrs* feed high moisture corn store grain weatherproof cover silage pile cover* Density Smooth Face Inoculation flush parlor after milking* Rake, harrow scrape or grade flush more frequently Remove manure from corrals** clean lanes not exceed 12" - clean lanes 1-7 days Inspect water troughs for leaks** slope surface/ensure drainage/harrow-scrape* Shades*** depth in corral less than 12** Cover Piles certain periods* remove solids w/ separator* Solid Incorporation allow liquid animal waste to stand no more than 24 hrs* EF with current Rule 4570 CE1. EntericEmissions4.15%3.902. MilkingParlor(s)0.035%0.033a. FreestallLanes0.85%10%0.683b. FreestallBeds1.05%10%0.864. Corrals/Pens6.65%10%5%2.3%5%4.985. Lagoons,StoragePonds1.35%1.246. LiquidManure LandApplication1.45%1.337. SolidManure LandApplication0.35%0.318. SeparatedSolids Piles0.065%0.069. SolidManureStorage0.155%10%0.13Total notincludingFeed15.813.5B-17Final Staff Report with Appendices ForRevised Proposed Amendments to Rule 4570SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Baseline Emission Inventoryand Emission ReductionsOctober 21, 2010B-18Final Staff Report with Appendices ForRevised Proposed Amendments to Rule 4570Table 14 - Dairy Emission Factor after applying current R4570 requirementsFeed MitigationSilageParlor FreestallsCorralsSolid liquidLand appSource Baseline EF Feed to NRC Guidelines** Push feed within 3 feet feed/dispose rations 2 hrs* feed high moisture corn store grain weatherproof cover silage pile cover* Density Smooth Face Inoculation flush parlor after milking* Rake, harrow scrape or grade flush more frequently Remove manure from corrals** clean lanes not exceed 12" - clean lanes 1-7 days Inspect water troughs for leaks** slope surface/ensure drainage/harrow-scrape* Shades*** depth in corral less than 12** Cover Piles certain periods* remove solids w/ separator* Solid Incorporation allow liquid animal waste to stand no more than 24 hrs* EF with current Rule 4570 CE10. SilagePiles (μg/m2-min)Corn Silage34,68125%10%10%21,069Alfalfa Silage17,45825%10%10%10,606Wheat silage43,84425%10%10%26,63511. TMR13,05610%10%-10%9,518*Estimated to be included in the revised EF of 15.8 lbs/hd-yr and the associated silage and feed EF.**Estimated to be partially included in the revised EFof 15.8 lbs/hd-yr and the associated silage and feed EF.***Estimated to be partially included in the revised EF of 15.8 lbs/hd-yr and expecting 50% of dairies will select the measure.-Emission reductions not quantified from this measure since no EF is available for this measure

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission In ventory and Emission Reductions October 21, 2010

Emission Factors for Dairies between 50 0 to 999 milk cows (Medium dairies)

This source category was previously not required to perform any of the mitigation

measures from the current rule (adopted 2006). The proposed rule now requires these facilities to adopt mitigation measures consis tent with dairies with > 1,000 milk cows. The number of measures require d for the medium si ze dairies are the same as those for large dairies, with the except ion of one less measure from the solid manure category. The emissions from the solid manure categor y is extremely low, adjustments to the calculation will not change any of the above numbers, therefor e, the resulting controlled

EF will be the same as calculated for the lar ge dairies in the above ta ble. Therefore, the 13.5 lbs/hd-yr and the associ ated silage and TMR EFs will be used as the controlled EFs for this category as well.

These EFs will be used towards developing the emissions inventory and will serve as the basis for the reductions for this proposed rule for the 500-999 milk cow category.

B. Layer and Broiler Emission Factors

The layer and broiler Emission Factors are summarized in the table below.

Table 15 - Layer and Br oiler Emission Factors

Animal Type 10 

### VOC Uncontrolled Emission

Factor Manure (lb/hd-yr) VOC Controlled Emission

Factor Manure (lb/hd-yr) 11



### Laying Chickens 0.025 0.0164

Broiler Chickens 0.025 0.0148

10 Based on the 2005 California Department of Food and Agriculture source test of a chicken broiler facility, results have been transferred over to layer operations – EFs are also approved the California Air Resources Board (CARB)

11 Applying the 10% control efficiency for mitigation me asures, the overall control efficiency for layer and broiler ranches is 34% and 41%, respectively, result ing in controlled EFs of 0.0164 lbs/hd-yr and 0.0148 lbs/hd-yr respectively.



### B-19 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission In ventory and Emission Reductions October 21, 2010

IV. BASELINE EMISSION INVENTORY

A. Dairy

The dairy baseline emissions inventory for 2008 and the project 2012 and 2023 is

summarized in the table below.

Table 16 - Dairy Baseline Emission Inventory

Source 2008

Emissions (tons/day) 2012

Emissions (tons/day) 2023

Emissions (tons/day)

Cows 43.38 48.82 67.58

Silage <300 0.49 0.49 0.49

Silage >300<500 3.44 3.44 3.44

Silage >500<1000 5.96 5.96 5.96
Silage >1000 13.78 13.78 13.78

TMR 28.77 33.33 46.13

Total 95.82 105.82 137.38

B. Broiler and Layer Baseline Emission Inventory

The broiler and layer baseline emissions inventory is summarized in the table below.

Table 17 - Boiler and Layer Baseline Emission Inventory Type Inventory (tons/day) Layers 0.26

Broilers 7.35

Total 7.61

B-20 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission In ventory and Emission Reductions October 21, 2010

V. EMISSION REDUCTIONS FROM PROPOSED RULE

A. Reductions from Dairy CAFs

Based on the estimated population, the EFs stated above and the controls proposed by the proposed rule, the District estimates that by 2012 and 2023 the overall emissions reduction from the proposed rule will be 25.09 tons/day and 31.62 tons/day, respectively, as shown in Tables 18 and 19, below:

Table 18 - Dairy 2012 Emission Reductions

Type W/out proposed Rule (tons/day) With Proposed

Rule (tons/day) Emission

Reductions (tons/day)



### Cows 48.82 40.46 8.36 Silage

>500<1000 5.96 3.26 2.70

Silage >1000 13.78 8.39 5.39

TMR 33.33 24.68 8.64

Total 105.82 80.73 25.09

Table 19 - Dairy 2023 Emission Reductions

Type W/out proposed Rule (tons/day) With Proposed

Rule (tons/day) Emission

Reductions (tons/day)



### Cows 67.58 56.01 11.57

Silage

>500<1000 5.96 3.26 2.70
Silage >1000 13.78 8.39 5.39

TMR 46.13 34.17 11.96

Total 137.38 105.76 31.62

B. Reductions from Poultry CAFs

As shown in the inventory section above, because the regulatory threshold for broiler CAFs and layer CAFs is being lowered, addit ional poultry CAFs will be subject to the

control measures in the revised rule. T he emission reductions are calculated in the following table:

B-21 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emission Inventory and Emission Reductions October 21, 2010

B-22 Final Staff Report with Appendices For 

### Table 20 - Poultry Emission Reductions

Type Additional

birds Uncontrolled EF (lbs/hd-yr) Controlled EF (lbs/hd-yr) Total Reductions (tons/day) Laying Chickens 1,050,000 0.025 0.0164 0.012

Broiler Chickens 9,450,000 0.025 0.0148 0.132

Total Emission Reductions 0.144

Sample Calculation Total Reduction = (1,050,000 birds x (0.025 lbs/ hd-yr-0.0164 lbs/hd-yr))/(2,000tons x 365 days/yr ) = 0.012 tons/day



### C. CAFs with No Emission Reducti ons from Proposed Amendments

There are certain CAFs that will not be affe cted by the revised proposed amendments

to the rule. The main reason is that ther e are no facilities that would become newly subject to the rule. District staff has exam ined information about the number of animals

at these CAFs and has determined that there are no existing facilities that are large enough to become subject to the ru le. These categories are:

• Beef Feedlots

• Other Cattle

• Swine

• Sheep/Goats

• Horses

• Other CAFs not elsewhere listed.

Revised Proposed Amendments to Rule 4570