Rule 217 Staff Repor t Appendix A

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# STAFF REPORT
APPENDIX A

EMISSION REDUCTION ANALYSIS FOR PROPOSED AMENDED
RULE 217 ( Large Confined Animal Facili ti es Permits Required )

I. SUMMARY

This staff report appendix A details the estimated emission reductions generated by implementation of Propo sed Amended Rule 217

, Large Confined Animal Facilities Permits Required. Currently there are 26 beef feedlots and 1 dair y under the Imperial County Air Pollution Control District’s (Air District) jurisdiction

. The Imperial County does not currently house any poultry farms or egg ranches. Therefore, this document evaluates only emissions produced by dairy and beef
feedlot facilities. Table 1 summarizes the results of the detailed calculations,
which are fully displayed in later sections of this document. Based on the data analyzed herein , th e practices listed within proposed Rule 217 would produce an
esti mated reduction of 452.7 tons of VOC per year.

Table 1: Summary of Reductions

Pollutant VOC Emissions Dairy Beef
Feedlot Uncontrolled Emissions (ton s/day) 0.08 5.39 Controlled Emissions (tons/day) 0. 0 6 4.15 Reductions from Proposed Control Requirements (tons/day) 0.02 1. 24

Reductions from Proposed Control Requirements (tons/year) 6.9 452.7

II. INTRODUCTION

The proposed amended rule would req uire dairy and beef feedlot facilities above the exemption threshold to implement multiple mitigation measures to offset VOC
emissions. The California Air Resources B oard’s (CARB) definition of a L arge Confined Animal Facility ( L CAF) was used as the appli cability threshold to satisfy state and federal requirements. Air District staff performed a preliminary VOC emissions reduction analysis for proposed amended Rule 217 based on the information that is currently readily available. This evaluation is based on San Joaquin Valley Unified Air Pollution Control District’s ( San Joaquin APCD ) permitting emission factors for dairy and beef feed lot operations. Table 2 presents a list of mitigation measures proposed by Rule 217 to reduce VOC
emission for each emiss ion unit at dairy and beef feedlot facilities

.Rule 217 Staff Repor t Appendix A

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- Table 2 : Amount of Mandatory Mitigation Measures from each Emission
Unit for Dairy and Beef Feedlot Facilities

Beef Feedlot Dairy

Feed 2 of 4 5 of 8 Silage 1 of 3 1 of 3

Milk Parlor 0 of 0 1 of 2

Frees tall Barns 0 of 0 3 of 6 Housing 5 of 7 7 of 10

Solid Manure 1 of 2 1 of 3 Liquid Manure 1 of 5 1 of 5 Land Application 2 of 2 2 of 2

TOTAL 1 2 of 2 3 2 1 of 39

III. EMISSION REDUCTION ANALYSIS

A. Background

In performing the emission reduction an a lysis, several assumptions were made
to reflect conservative emission reduction results. These include:

• All mitigation measures achieve creditable VOC reductions from all facilities that use the mitigation measures. Although many of these mitigation measures are currently being implemented, it is assumed a
future reduction of VOC emissions would be accomplished due to the mitigation options regardless of whether or not they were in practice prior to rule adoption. This assumption is made due to the f act that without the presence of proposed Rule 217, the se facilities could cease the usage of the mitigation measures at any time. Thus, the rule achieves reductions by prohibiting the owner/operator from suspending the implementation of
VOC mitigation me asures

.

• In some cases, no data could be found in the literature search on how to base a control efficiency factor for these practices. The Air District has conservatively assumed a minimal 10% control eff iciency . As information becomes available, it will be added to this methodology.

• B ased on the information provided by our Technical Advisory Committee (TAC)

, an assumption is made to the effect that no single dairy in Imperial County has freestalls installed within its facilities. In additi on, d uring the workshop, stakeholders mentioned that f eedlots and dairies in Imperial County feed dry grains which do not include silage. Therefore, emissions from the feed from feedlot and calf operations are assumed negligible.Rule 217 Staff Repor t Appendix A

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- Based on the three major assumptions above, the Air D istrict analyzed the efficiency of the least expensive mitigation measures options that owners/operators would more than likely choose for adoption

.

B

. Emission Factors for Dairies and Beef Feedlots

The Air Resources Board has develop ed emission factors to estimate TOG and ROG emission from dairy and beef feedlot facilities. The s e emission factors are
not based on recent numbers or California specific test data. Therefore, the Air
D istrict has opted to use for this evaluation the current emission factors used in San Joaquin APCD . The Air District chose to use S an Joaquin’s APCD emission
factors due to the following reasons : (a) they are accepted by the Air Resources
Board

, and (b) they are divided into emission units which fa cilitates VOC
emission evaluation. T he values in Table 3 for: manure & feed in housing; enteric emissions in housing; enteric emissions in milking center; manure emissions in milking center; liquid manure handling; and land application subtotal the current
emission factors used for permitting purposes in San Joaquin APCD

. According to the Emission Reduction Analysis for Proposed Rule 4570 (Confined Animal Facilities), Appendix B, the emission factors used by San Joaquin APCD did not
include all emission s ources. Two sources in wh ich emissions were not counted

we re the solid bedding storage piles and the feed piles outside of the animal housing. Since there is research documenting emission s these sources and the various VOC control options

, San Joaquin APC D staff estimated the emissions from these sources by using data from Schmidt's research. These emission factors are only used for calculating reductions from mitigation measures that control VOC emissions from solid bedding or feed storage piles.

A cc ording to the information obtained from our Technical Advisory Committee, none of the dairies in Imperial County have ins talled f reestalls . Th erefore, within
this evaluation it is ass umed that dairies operate without the usage of freestalls. In addition, d uring the workshop, stakeholders mentioned that f eedlots and
dairies in Imperial County feed dry grains which do not include silage. Therefore, emissions from the feed from feedlot and calf operations are assumed negligible.
E missions for dairies are show n in the subsequent chart below, T able 3 . These
factors were used to calculate the control factors for dairy control measures.

T he Air D istrict also use d San Joaquin APCD permitting emission factors to evaluate emissions from dairy and beef feedlots . Ba se d on American Society of Agricultural and Biological Engineers (ASAE) Publication D384.1, manure from beef cattle in confinement (adult and growing cattle) contains 68% of the amount
of volatile solids found in a mature dairy cow (lactating and dry cattl e). Since the
amount of volatile solids in the manur e is a function of diet and amount of manure, emission factors for dairy cattle were multiplied by 0.68 to estimate the
emissions for beef cattle and are shown in Table 3 . These factors were used to
cal culate the control factors for beef feedlot control measures.Rule 217 Staff Repor t Appendix A

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- The calculations for dairies and beef feedlots are based on the following
breakdown of the emi ssion factor by source category:

Table 3 : Emission Factors for Dairies and Beef Feedlots
Emission Unit Dairy Emission Factors (Dairies
without Freestalls) Beef Feedlots
Emission

Factors

Enteric Emissions in Housing 4.1 lb/hd

- yr 5.2 lb/hd

- yr Milk Parlor(s) 0.03 lb/hd

- yr 0. 0 lb/hd

- yr Corral/Pens 6.6 lb/hd

- yr 3.3 lb/hd

- yr Lagoons, Storage Ponds 1.3 lb /hd

- yr 0.0 lb/hd

- yr Liquid Manure Land Application 1.4 lb/hd

- yr 0. 0 lb/hd

- yr Solid Manure Land Application 0.3 lb/hd

- yr 0.0 lb/hd

- yr Separated Solid Piles 0.06 lb/hd

- yr 0.0 lb/hd

- yr Solid Manure Storage 0.15 lb/hd

- yr 2.5 lb/hd

- yr Total 13.94 lb/hd

- y r 11.0 lb/hd

- yr

C

. Control Efficienc y Calculation for Dairies

1. ENTERIC EMISSIONS

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize the excess nutrients fed to the animals at
the site . Based on research suggesting that nitrogen content in feed is directly proportional to nitrogen content in manure, the Air D istrict believes that feeding according to the NRC guidelines

, which minimizes excess nutrients in the diet,
would reduce VOC emissions. Following San Joaquin ’s APCD rule evaluation , a 5% reduction is assumed. Given that this practice reduces the content of VOC

precursors fed to the animal (entering the animal)

, it will reduce the VOC

precur sors exiting the animal and those being treated in each animal waste

sys tem. In addition, reductions will occur from feed in the housing and stockpiles because there will be less VOC precursors in the feed, which could eventually decompose. As a result , the 5 % reduction figure again was applied to the facility
wide emission factors. This is expected to be used by all facilities since
reductions in excess nutrients in feed, such as protein, would not increase costs significantly. Any further labor employed to determine what feed formulations would meet NRC guidelines would l ikely be offset by lower costs for feed due to
lower nutrient content. The reduction calculations are:

The b aseline is 4.1 lb/hr/yr. yet there are fewer emissions due to the use of the NRC feed guidelines. The reduction per measure is:

Reductions = 4.1 l b/hd

- yr x 9 5 % (emissions remaining after implementing OptionRule 217 Staff Repor t Appendix A

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- 1) = 3.90 lb/hd

- yr

Option 2 , 3 and 4 : T hree mitigation measures for cleaning feed from housing

These measures are intended to minimize moisture, surface area for VOCs to
move from the feed to t he atmosphere, and anaerobic digestion due to wet conditions and thick depths of animal waste. Data suggests that these practices
would minimize VOC emissions; however there are no peer

- reviewed articles that quantify this. Therefore, the Air District as sumed a default reduction of 5 %
for each measure. Yet

, this assumption only affects the emissions from feed and these emissions were already reduced by Option 1.

2. MILK PARLOR PRACTICES

Flush/clean milk parlor after each milking

Withi n the studies performed for the determination of the emission factor for this option, this practice was already being carried out . Therefore, the baseline assumes that all facilities implement this practice. Thus, no reduction from the baseline is anticipated. This me asure was included to ensure all current and future facilities implement practices accounted for in the baseline emission
estimate. Following San Joaquin APCD rule evaluation, the baseline is 0.03
lb/hd

- yr

.

Reductions = 0.03 lb/hd

- yr x 9 5 % (emissions rem aining after implementing Option 1) = 0.03 lb/hd

- yr

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. FREESTALL PRACTICES

None of the dairies in Imperial County is constructed with feestalls ; consequently

, no reductions are anticipated by freestall practices. However, Rule 217 includes mitigation me asures for facilities constructed with feestalls with the anticipat i on that future facilities may construct feestalls at their site.

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. CORRAL PRACTICES

Option 1 through 6 : All housing measures to clean corals, manage manure depth, and minimize moisture are now mandatory

. These measures are intended to minimize moisture and anaerobic digestion due to wet conditions or thick depths of manure that prevents the manure from drying completely and oxygen continuing to come in contact with all animal waste in th e pens and corrals. Data suggests that this would minimize VOC emissions

. Following San Joaquin’s
APCD rule evaluation, a baseline emissions factor of 6.6 lb/hd

- yr and a 2 7 .3%
reduction is assumed (Corrals 22.3% + 5% Feed NRC)

. The reduction per theseRule 217 Staff Repor t Appendix A

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- measure s is:

Corral emissions = 6.6 lb/hd

- yr x 27. 3% (emissions from corrals)

= 4.8 lb/hd

- yr from corrals

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. LIQUID MANURE PRACTICES

All of the lagoon control options

AEM, 3/03, Vol 69, pg 1710

- 1720, indicates a 80

- 93% decrease in emissions
from sw ine phototrophic lagoons; ILOC, 1995, pg 80

- 85, DiSpirito, found the same in swine lagoons; and JFB, 70:39

- 44, Hiraishi, found the same in sewage wastewater lagoons. The loading rate contributing to a phototrophic are typically found in lagoons utilizing a solid separator, NRCS guidelines for anaerobic lagoon design, and microaerobic nutrient management. However, these studies were for swine and not cattle. Based on AP42 by U.S. EPA, swine emit 63.5% of the volatile solids that cattle do. Therefore, in o rder to be conservative, staff assumed that cattle lagoons are 63.5% as efficient as swine lagoons (63.5% x 80% = 50%). According to San Joaquin APCD rule evaluation, t he b aseline is 1.3 lb/hr/yr. yet there are fewer emissions due to the use of the NRC fee d guidelines. The reduction per measure is:

Reductions = 1.3 lb/hd

- yr x 9 5 % (emissions remaining after implementing Option 1) = 1. 24 lb/hd

- yr

6. SOLID MANURE STORAGE /SEPARATED SOLIDS PRACTICES

Cover piles outside the pens

Th is measure is intended to mi nimize moisture and anaerobic digestion due to wet conditions. There is no data regarding the amount of emissions from the manure storage piles, therefore staff conservatively estimated the separated solids and the manure piles emit approximately the same amount of VOC. Since there is little data regarding reductions

, staff assumed a default reduction of 10%
for cover piles mitigation measure. The reduction per measure is:

Separated solid Practice Piles = 0.06 lb/hd

- yr x 9 5 % (emissions remaining after implementing Option 1) = 0.06 lb/hd

- yr Solid Manure Storage = 0.15 lb/hd

- yr (piles) x 85 % ( 10% emissions remaining after implementing Cover Piles Measure + 5% Option 1) = 0. 13 lb/hd

- yr reductions.

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. SOLID MANURE LAND APPLICATION PRACTICES

These practi ces are intended to rapidly land incorporate the manure or wasteRule 217 Staff Repor t Appendix A

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- water. The soil is expected to act as a biofilter since it is an organic media with significant microbial populations and airflow. Research suggests biofilters range in efficiency from 10% t o 90% depending on how they are maintained. Conservatively staff assumed 50% control. The baseline emissions from crop application are 0.3 lb/hd

- yr.

The reduction per measure is = 0.3 lb/hd/year x 9 5 % (emissions remaining after implementing Option 1 ) = 0.3 lb/hd

- yr

8. TOTAL REDUCTIONS

The total percent reductions can be calculated by a ssuming the percent reductions for each mitigation measure above.

Controlled Emission Factor = 10.46 lb/hd

- yr

The total percent reduction = ( (13.94

– 10.46)/13.94 ) x 100

The total percent reduction = 25 %

D . Control Efficienc y Calculation for Beef Feedlots

1. ENTERIC EMISSIONS

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize the excess nutrients fed to the animals at
the si te . Based on research suggesting that nitrogen content in feed is directly proportional to nitrogen content in manure, the Air D istrict believes that feeding according to the NRC guidelines

, which minimizes excess nutrients in the diet,
would reduce VOC e missions. Following San Joaquin APCD rule evaluation, a 5% reduction is assumed. Given that this practice reduces the content of VOC

precursors fed to the animal (entering the animal)

, it will reduce the VOC

precur sors exiting the animal and those being treated in each animal waste system. In addition, reductions will occur from feed in the housing and stockpiles because there will be less VOC precursors in the feed, which could eventually decompose. As a result , the 5 % reduction figure again was applie d to the facility wide emission factors. This is expected to be used by all facilities since
reductions in excess nutrients in feed, such as protein, would not increase costs significantly. Any further labor employed to determine what feed formulations

w ould meet NRC guidelines would likely be offset by lower costs for feed due to
lower nutrient content. The reduction calculations are:

The b aseline is 5.2 lb/hr/yr. yet there are fewer emissions due to the use of the NRC feed guidelines. The reduction per measure is:Rule 217 Staff Repor t Appendix A

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- Reductions = 5.2 lb/hd

- yr x 9 5 % (emissions remaining after implementing Option 1) = 4.94 lb/hd

- yr

Option 2, 3 and 4 : T hree mitigation measures for cleaning feed from housing

These measures are intended to minimize moisture, surface area for VOCs to move from the feed to the atmosphere, and anaerobic digestion due to wet conditions and thick depths of animal waste. Data suggests that these practices would minimize VOC emissions; however there are no peer

- reviewed articles that quantify this. Therefore, the Air District assumed a default reduction of 5 % for each measure. Yet, this assumption only affects the emissions from feed and these emissions were already reduced by Option 1.

2. CORRAL PRACTICES

Option 1 through 4 : All housing mea sures to clean co r rals, manage manu re depth, and minimize moisture. These are intended to minimize moisture and anaerobic digestion due to wet conditions or thick depths of manure that prevents the manure from drying completely and oxygen continuing to com e in contact
with all animal waste in the pens and corrals. Data suggests that this would
minimize VOC emissions . A baseline emission factor of 3.3 lb/hd

- yr is assumed. Following San Joaquin APCD rule evaluation, a 27.3% reduction is assumed (Corrals 22.3 % + 5% Feed NRC). The reduction per these measure s is:

Corral emissions = 3.3 lb/hd

- yr x 27.3% (emissions from corrals) = 3.3 lb/hd

- yr x (1

- 0.273) = 2.4 lb/hd

- yr

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. SOLID MANURE LAND APPLICATION PRACTICES

Option 9 & 1 0 : All methods for crop applicat ion.

These practices are intended to rapidly land incorporate the manure or waste water. The soil is expected to act as a biofilter, since both biofilters and soil are organic media with significant microbial populations and airflow. Research suggests bi ofilters range in efficiency from 10% to 90% depending on how they are maintained. Conservatively

, staff assumed 50% control. The baseline emission from crop application is 2.5 lb/hd

- yr. The seven moisture minimization practices utilized as mitigation me asures for animal housing means there is less
moisture in the manure and therefore less poten tial for VOC emissions. There
also lies less potential for VOC emissions due to the implementation of a NRC
diet. T hus

, the baseline emissions should also be redu ced by 10%, which is the control efficiency of having a diet based on the NRC guidelines. The reduction per measure is:

Options 9 & 1 0 Reductions = 2.5 lb/hd/year x 90% (emissions remaining after implementing Option 1) x 50% (control efficiency) = 1.13 l b/hd

- yrRule 217 Staff Repor t Appendix A

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. TOTAL REDUCTIONS

Controlled Emission Factor = 8.47 lb/hd/year

The total percent reductions can be calculated by summing the percent reductions for each mitigation measure above.

The total percent reduction = ((11

– 8.47)/11) x 100

The t otal percent reduction = 23 %

E

. Rule 217 Emissions and Reductions

As previously stated, 26 beef feedlots and 1 dair y operate within the jurisdiction
of the Air District , with a total cattle population , as of 20 13

, of 361,888 heads.
This figure, along with San Joaquin APCD emission factors and control efficiency, formed the basis for estimating total VOC reductions in Imperial County due to the implementation of the various mitigation measures found
within proposed Rule 217. Based on this information, it is estimated that a VOC
reduction from dairies will be 6.96 tons per year, whereas beef feedlots will see a
reduction of 452.7 tons per year. Table 4 summarize s the emission reduction
calculations from the control measures included in the rule :

Table 4 Cattle

- Related VOC Emission Reductions Source Category Dairy Cattle Beef Feedlot

20 13 Cattle Population 4,000 357,888
Uncontrolled Emission Factor (lbs VOC/head/year) 13.94 11.0

Uncontrolled VOC Emissions (ton/day) 0. 08 5.39

Control Efficiency of Mi tigation
Measures 25 % 23 %

Controlled Emission Factor (lbs VOC/head/day) 10.46 8.47

Controlled VOC Emissions (tons/day) 0.06 4.15

VOC Reductions (tons/day) 0.02 1.24

VOC Reductions (tons/year) 6.9 452.7