RE: 4 pm works for us - specifics of what we want to talk about are below

Ramon Norman to: Sona Chilingaryan, Nancy Levin 11/10/2011 04:47 PM

Cc: "Errol Villegas", "Sheraz Gill"

History: This message has been forwarded.

Sona,

As you requested in our conversation yesterday, I am sending a link to a sample recordkeeping form on 

the District’s website: 

http://www.valleyair.org/busind/comply/Forms/Copy%20of%20Draft%20Dairy%20recordkeeping%20check

list%20long%206-15-11%20(2).xls

As we discussed, as with many other District and EPA requirements, adequate recordkeeping is the main 

tool for demonstrating requirements with many of the measures required by District Rule 4570.

I also checked the and found that the estimate used for the open area of the silage piles and the area of 

TMR per cow, which was used to calculate emissions from the freestall barns, were within the range of

values given in the previous dairy emission studies performed by Dr. Schmidt and Dr. Krauter (see 

below). As we discussed, even if this were not the case and emissions from TMR were to be doubled, 

enclosed freestall barns vented to a biofilter still would not be cost effective since the District’s analysis 

indicated a minimum cost of $205,098/ton of VOC reduced.

Schmidt Studies

Dairy 1

2004 Measurements (2005 Report), www.epa.gov/ttnchie1/conference/ei14/session1/schmidt.pdf

Total Cows: 3,442; Total Area of TMR (m2): 1,923 + 153 = 2,076; TMR Area per total cows = 0.603 m2

/cow

 Estimated milk cows*: 2,939; Area of TMR for milk cows (m2): 1,923; TMR Area per milk cows = 

0.654 m2/cow

2005 Measurements (2006 Report), http://www.arb.ca.gov/ag/caf/SchmidtDairyEmissions2005.pdf

Total Cows: 3,412; Total Area of TMR (m2): 1,923 + 153 = 2,076; TMR Area per total cows = 0.608 m2

/cow

 Estimated milk cows*: 2,913; Area of TMR for milk cows (m2): 1,923; TMR Area per milk cows = 

0.660 m2/cow

2008 Measurements (2009 Report)

Total Cows: 3,558; Total Area of TMR (m2): 1,923 + 153 = 2,076; TMR Area per total cows = 0.583 m2

/cow

 Milk cows: 3,001; Area of TMR for milk cows (m2): 1,923; TMR Area per milk cows = 0.641 m2

/cow

 Open Area of Silage Pile: 250 m2 

Dairy 2

2005 Measurements (2006 Report),

Total Cows: 4,725; Total Area of TMR (m2): 2,009 + 223 = 2,232; TMR Area per total cows = 0.472 m2

/cow

 Estimated milk cows*: 2,382; Area of TMR for milk cows (m2): 2,009; TMR Area per milk cows = 

0.843 m2/cow

2008 Measurements (2009 Report)

Total Cows: 4,489; Total Area of TMR (m2): 2,009 + 223 = 2,232; TMR Area per total cows = 0.497 m2

/cow

 Milk cows: 2,249; Area of TMR for milk cows (m2): 2,009; TMR Area per milk cows = 0.893 m2
/cow

 Open Area of Silage Pile: 200 m2 

*milk cows estimated based on ratio of milk cows and total cows from 2008 Dairy Study

Krauter Studies

(2009 Report), www.arb.ca.gov/research/apr/past/04-343.pdf

The report does not list the area of the TMR for each dairy but for a hypothetical composite dairy with 

2,000 milk cows the report estimates that the total area of TMR would be 1,600 m2 (0.8 m2/cow).

Please let me know if you have any questions or need any additional information.

Ramon Norman

Air Quality Engineer

San Joaquin Valley Air Pollution Control District

1990 E. Gettysburg Ave

Fresno, CA 93726-0244

Phone: (559) 230-5909

FAX: (559) 230-6061

From: Chilingaryan.Sona@epamail.epa.gov [mailto:Chilingaryan.Sona@epamail.epa.gov] 

Sent: Wednesday, November 09, 2011 11:46 AM

To: Sheraz Gill

Cc: Errol Villegas; Levin.Nancy@epamail.epa.gov; Ramon Norman

Subject: 4 pm works for us - specifics of what we want to talk about are below 

Yep, 4 works for us. Let's talk then. We can use the same call in number: (712) 432-1438, access code: 

757585# 

We really appreciate your time and want to make this as quick as possible. There are only three 

paragraphs from the comment letter I sent earlier (attached again directly below) that I think we need to 

talk about. I'm pasting the relevant paragraphs below to help focus our discussion. 

l Furthermore, there is no data in the record demonstrating the methodology of estimating,

or confirming the accuracy of, the total area of TMR exposure in feed lanes. The exposed TMR 

area is large and is estimated by Howard to equal 1,650 square meters for a 1,200 cow dairy.13

The District staff report only estimates emissions based on an feed area of 225 square meters for 

a dairy greater than 1,000 cows.14 Elsewhere, the District low-balled emissions estimates for 

TMR by assuming only 0.658 square meters of feed area per cow.15 On a per cow basis, Howard 

estimated emissions at 1.375 square meters per cow, or more than double that which the District 

used when dismissing the feasibility of enclosed barns. (from pg. 6) 

l Another example is Menu 4.1(A)(2) that requires the TMR to be within 3 feet of a

feedlane fence. This measure supposedly reduces the surface area from which VOC would be 

emitted from the highest VOC source in the Valley. There is no evidence to demonstrate that 
standard industry practice is to allow the feed to go beyond three feet or that dairy operators don’t 

already “push up” the feed to ensure that the cows can actually reach and eat the feed; a cow’s 

head can only protrude a given distance from the feed stanchion so why would a profit-conscious 

dairy business allow expensive feed to lay beyond the reach of the cows that the operator wants 

to feed? Moreover, the measure assumes that cows aren’t continually consuming the feed, 

thereby exposing previously covered feed containing VOC to air flow and evaporation. Finally, 

the baseline emissions inventory measures emissions from feed in the feedlane at 31⁄2 feet. Staff 

contends that this six-inch reduction would reduce the surface area and the flux rate of the feed 

significantly. However, the District’s method does not yield a decrease in flux rate, only exposed 

surface area. (from pg. 7) 

l Significantly, there is no required monitoring for pushing up TMR in the feed lanes, the

most significant source of VOC emissions at dairy LCAFs and a required Rule 4570 measure. 

See sections 6 and 7. This is a fundamental failure because no monitoring is required to 

demonstrate compliance, and only the general mandate for an operator to maintain records 

applies. With respect to lagoon emissions, the rule leaves required monitoring at the discretion 

of the “the APCO and EPA.” Section 6.1. (from pg. 8) 

I know you all have a copy of the Howard article mentioned in the first paragraph above, but I'm also 

attaching the article directly below so we can look at it together at 4 o'clock. The relevant page is 2313. 

Thanks and talk to you at 4, 

s. 

From: "Sheraz Gill" <Sheraz.Gill@valleyair.org>

To: Sona Chilingaryan/R9/USEPA/US@EPA, "Ramon Norman" <Ramon.Norman@valleyair.org>

Cc: Nancy Levin/R9/USEPA/US@EPA, "Errol Villegas" <errol.villegas@valleyair.org>

Date: 11/09/2011 11:31 AM

Subject: RE: tomorrow at 2 pm for discussing 4570 comments works for us

Sona,

Errol has a conflicting meeting at 2. Can we have a call at 4 instead?

Sheraz Gill

Supervising Air Quality Engineer

San Joaquin Valley APCD

Phone: (559) 230-5908
Fax: (559) 230-6061

sheraz.gill@valleyair.org

From: Chilingaryan.Sona@epamail.epa.gov [mailto:Chilingaryan.Sona@epamail.epa.gov] 

Sent: Tuesday, November 08, 2011 4:40 PM

To: Sheraz Gill; Ramon Norman

Cc: Levin.Nancy@epamail.epa.gov

Subject: tomorrow at 2 pm for discussing 4570 comments works for us 

 

Here's a call in number: (712) 432-1438, access code: 757585# 

If you have issues connecting, please call my cell (510-684-8100). 

I think it'll just be Nancy and me from our end. 

Thanks so much for your time and talk to you tomorrow at 2! 

s.