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Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-1 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 

## APPENDIX E

ANALYSIS OF CLASS TWO MITIGATION MEASURES FOR

AMENDED REVISED PROPOSED AMENDMENTS TO RULE 4570 (CONFINED ANIMAL FACILITIES)

October 21, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-2 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-3 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 APPENDIX E

COST ANALYSIS OF CLASS TWO MITIGATION MEASURES

I. INTRODUCTION

Rule 4570 contains options for facilities to implem ent certain “Class Two” mitigation measures that may have the potential to achieve inc reased emission reductions when compared to the required “Class One” mitigation mea sures. The Class Two mitigation measures are practices that are far beyond the requ irements of Best Available Retrofit Control Technology (BARCT). These measures were in cluded in the rule to give credit to operators who have made substantial investments in facilities and equipment that result in air quality benefits equivalent to or gre ater than those achieved by one of the Class One mitigation measures and to encourage oper ators to go beyond the basic rule requirements and implement innovative practices to further reduce emissions. However, these measures cannot be reasonably mandat ed because of a variety of concerns including animal health, technological fac tors, environmental factors, and economic feasibility. The technological and econom ic feasibility of various selected Class Two mitigation measures are analyzed below to more clearly illustrate that it is not currently feasible to require facilities to imp lement the Class Two mitigation

measures.

II. VENTING SILAGE TO A CONTROL DEVICE

The previous version of Rule 4570 contained the opt ions to enclose silage in a bag or weatherproof structure and vent the silage to a VOC control device as Class Two Mitigation Measures. At the time rule 4570 was bei ng developed, preliminary information indicated that dairy feed was an import ant source of VOC emissions at

dairies. More recent research has confirmed that f eed at dairies is a significant VOC emissions source. The options to vent silage to a VOC control device were included as potential means to reduce emissions from this impor tant source. The proposed controls were not based on any known installations but were based largely on technology transfer from composting operations, which were tho ught to involve a similar process. However, an examination of the processes required f or composting and creating silage

demonstrates that the fundamental differences in th e processes cause actively venting silage to a control device to be infeasible, theref ore these options have been removed

from the revised rule.

Composting is an aerobic process in which microbes decompose organic material in the presence of oxygen producing carbon dioxide and hea t. The end product is a humuslike product that can be used to increase the organ ic matter and porosity of soil. Because composting is an aerobic process, any air t hat is vented through the material being composted can speed or enhance the composting process and result in a more consistent end-product. Therefore, actively ventin g composting piles is feasible and may even be desirable. Production of silage is fun damentally different because it is an anaerobic process. The purpose of silage productio n is to move the ensiled plantSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-4 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 material from an aerobic phase to an anaerobic phas e as quickly as possible and achieve a rapid drop in pH that will hinder further microbial decomposition in order to preserve the nutritive value of the forage. The ra pid drop in pH is primarily caused by conversion of soluble carbohydrates to nonvolatile lactic acid. Oxygen, heat, and the production of carbon dioxide, which are desirable w hen producing compost, are undesirable when producing silage because this is i ndicative of lost dry matter and energy content. Preservation of dry matter and ene rgy content is the entire purpose of making silage because the nutrients and energy are used by cows to produce milk and maintain body weight. They are also used by the yo unger stock for growth. Aerobic deterioration and heating of silage in bunkers or p iles and when fed to animals in the total mixed ration (TMR) are well-known problems. Many steps are taken to prevent this loss of nutritive value. Active venting of si lage would introduce oxygen into the silage and result in the losses of nutritive value that producers are attempting to avoid. Therefore, this option is not feasible for producti on of silage.

Passive venting of silage to a control device may b e considered to be more feasible but this option is not currently reasonable. Because o f the need to maintain anaerobic conditions to preserve the nutritive value of the s ilage, silage piles are usually tightly compacted and covered with plastic to prevent air p enetration. Because most of the surface area of silage piles will usually have a co mpacted surface covered by plastic, the vast majority of emissions will be from the par t of the pile that is uncovered to allow removal of feed. Machinery must access this open p ortion of the silage pile at various times throughout the day to obtain feed for the ani mals; therefore, enclosing this portion of the pile to allow passive ventilation is not rea sonable. The District also considered including an option requiring that silage piles be re-covered after feed removal; however, this option also proved to be unreasonable because of safety concerns. The silage piles constructed in the San Joaquin Valley are extremely large. Producers will generally try to minimize the amount of work that i s performed on or near open silage piles because of the danger of the silage pile coll apsing, which can result in serious injury or death. The District consulted with exper ts in the field of silage production and they agreed that large silage piles are a safety co ncern and advised against including any measures that would require workers to spend ti me on or near open silage piles. These experts stated that silage piles are serious hazards and, unfortunately, injuries and/or deaths from silage pile avalanches probably occur every year 1 . Because of these important safety concerns, the option to have worke rs re-cover piles was not considered

further under the current rule revisions.

1 Recent incidents of silage piles collapsing on peo ple can be found at the following links (unfortunat ely, additional similar incidents can easily be found by a simple web search): http://hayandforage.com/hay/0201-surviving-silage-a valanche/ http://www.thaindian.com/newsportal/world/boy-dies- due-to-feed-pile-collapse_100354252.html http://www.agsafety.psu.edu/newsletters/MarApr07.pd fSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-5 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 III. ANALYSIS FOR MILK PARLORS VENTED TO A CONTROL DEVICE

Because the same control device could be used to co ntrol VOC emissions from the milk parlors and the cow housing, cost of the VOC emissi on reductions for an enclosed milk parlor was evaluated below in conjunction with the cost of VOC emissions from enclosed cow housing vented to a control device. S ince the emission factor from the milking parlors is much lower than the emission fac tor from the cow housing, this reduces the cost of emission reductions for venting the milking parlors to a control

device. The use of a biofilter as the control devi ce for VOCs is expected to result in much lower costs than other control options, such a s incineration; therefore, this option was analyzed below to determine the minimum cost of the emission reductions that could be achieved by venting an enclosed milk parlo r and enclosed freestall barns vented to a control device. Details of this analys is are given under Section C – Analysis for Confining Livestock in Enclosed Buildings and V enting Emissions to a Control

Device.

Description of a Milking Parlor

Milk parlors can be either naturally or mechanicall y ventilated. Mechanical ventilation can be easily applied to all areas of the milking p arlors, except the holding area. The mechanical ventilation system for the milking parlo r can be utilized to capture the gases emitted from the milking parlor; however in order t o capture all of the gases, and to keep an appropriate negative pressure throughout the sys tem, the holding area would also need to be entirely enclosed. No California facili ty that currently encloses the holding

area could be identified because cows are continuou sly going in and out of the barn throughout the day. The capital cost required to e nclose this large area would also be significant. Although the feasibility of such a te chnology is in question, it will be considered in the analysis below. If it is possibl e to overcome the significant obstacles to properly capturing the gases, it may be possible to vent them to a control device.

Description of Control Technology

A biofilter is a device for removing contaminants f rom a gas in which the gas is passed through a media that supports microbial activity by which pollutants are degraded by biological oxidation. During biofiltration exhaust air containing pollutants passes through a media that contains an established, diver se population of aerobic microorganisms. These microorganisms oxidize the g aseous organic contaminants, ammonia, and sulfur compounds in the exhaust air re sulting in carbon dioxide, nitrogen, water, salt, and biomass. Additional information o n biofiltration is given below in the analysis for enclosed animal housing vented to a co ntrol device.

Cost of VOC Emission Reductions

The analysis below for enclosed milk parlors and en closed freestall barns vented to a

biofilter demonstrates that the cost of the VOC red uctions would be greater than $205,081/ton. There are additional costs related to increased electricity use, andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-6 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 regulatory compliance and testing that have not bee n quantified for this analysis. Even without these costs, the cost of the VOC emission r eductions achieved far exceed the $17,500/ton cost effectiveness threshold of the Dis trict BACT policy. Therefore, this option would not be required as BACT and is beyond BARCT and any applicable RACT requirements.

IV. ANALYSIS FOR CONFINING LIVESTOCK IN ENCLOSED BU ILDINGS AND

VENTING EMISSIONS TO A CONTROL DEVICE

It has been periodically suggested that large VOC e mission reductions can be achieved by confining livestock in enclosed buildings and us ing mechanical ventilation to direct the emissions to a control device, such as an incin erator or biofilter. The District previously considered this option when the District originally adopted Rule 4570. The District determined that this option was beyond bot h Best Available Retrofit Control Technology (BARCT) and Best Available Control Techn ology (BACT) because it had not been achieved in practice at any facility and w ould have excessively high costs. Although the District considered this option to be a theoretical measure that was beyond BARCT and BACT, it was included in Rule 4570, like several other Class 2 measures, to encourage the development of innovation technolo gies that might possibly lead to greater emission reductions in the future.

In the BACT evaluations for several projects for ne w or modifying dairies, the District analyzed the cost of the VOC emission reductions fr om venting dairy barns to a control device. Although these abbreviated cost analyses o nly considered a small fraction of the total costs associated with this measure, they consistently resulted in costs of

emission reductions that exceeded the District’s co st effectiveness threshold for BACT for VOC. The District has repeatedly demonstrated that this measure is beyond BARCT and BACT, and certainly beyond the less stringent r equirements of Reasonably Available Control Technology (RACT). However, cert ain parties continue to suggest that, not just new or expanding dairies, but all ex isting dairies subject to Rule 4570 should be required to confine their herd in enclose d buildings vented to a control device.

This analysis does not quantify all of the costs or examine all of the potential issues that make requiring this option infeasible but it is int ended to be a more complete analysis that more accurately approaches the actual costs to implement this measure. The use of a biofilter as a control device for VOCs is expe cted to result in much lower costs than other control options, such as incineration. The U .S. Environmental Protection Agency (US EPA), Clean Air Technology Center (CATC) docume nt “Using Bioreactors to Control Air Pollution” states, “ The capital cost of a bioreaction installation is u sually just

a fraction of the cost of a traditional control dev ice installation. Operating costs are usually considerably less than the costs of traditi onal technology, too .” 2 Therefore, this

2 U.S. Environmental Protection Agency , The Clean A ir Technology Center (CATC), “Using Bioreactors to Control Air Pollution” EPA-456/R-03-003, (E143-0 3), September 2003, http://www.epa.gov/ttn/catc/dir1/fbiorect.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-7 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 analysis will evaluate the use of a biofilter to de termine the minimum cost of the emission reductions that would be achieved by venti ng enclosed animal housing to a

control device.

Description of Control Technology

A biofilter is a device for removing contaminants f rom a gas in which the gas is passed through a media that supports microbial activity by which pollutants are degraded by biological oxidation. During biofiltration, exhaus t air containing pollutants passes through a media that contains an established, diver se population of aerobic microorganisms. These microorganisms oxidize the g aseous organic contaminants, ammonia, and sulfur compounds in the exhaust air re sulting in carbon dioxide, nitrogen, water, salt, and biomass. The bacterial cultures ( microorganisms that typically consist of several species coexisting in a colony) that use oxygen to biodegrade organics are

called aerobic cultures. These aerobic cultures ar e usually supported by organic material contained in the biofilter, such as compos t, wood chips, soil, peat, etc. Biofilters must maintain sufficient porosity to all ow the contaminated air stream to pass through for treatment and to prevent anaerobic cond itions. The moisture content of biofilter beds must also be regulated to ensure tha t there is sufficient moisture to maintain the microorganisms needed for treatment wh ile avoiding excess moisture that can cause anaerobic conditions. A filtration syste m may be required upstream of the biofilter to remove particular matter which will cl og the biofilter over time. Biofilters must

be maintained free of rodents and weeds to avoid ch anneling of gases through the filter media and a loss of performance. The filter media of natural biofilters needs to be replaced periodically because of deterioration and loss of porosity.

Since biofilters rely on living organisms to functi on, a biofilter’s performance will be affected by several factors, including: ambient tem perature; temperature of the air stream being treated; the pollutant concentrations in the air stream; moisture content of the filter and air stream, and pH of the filter med ia. These parameters should be monitored to ensure optimum operating conditions fo r the biofilter.

Advantages and Disadvantages of Using a Biofilter

Some of the general advantages related to the use o f biofilters include: low installation costs for traditional biofilter designs; generally low operating costs in comparison to other control technologies; high control efficienci es for some compounds such as aldehydes, organic acids, hydrogen sulfide, and cer tain water-soluble organic compounds.

Some of the general disadvantages of the use of bio filters include: large land requirements for traditional biofilter designs; dif ficulty in determining the control efficiency for traditional open biofilter designs; for biofilters that use inexpensive natural bed media, the filter bed media must be replaced ev ery 2 to 5 years; biofilters usually require some time to reach optimum control efficien cy after initial startup and after periods of nonuse because of the need to establish or re-establish the microbialSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-8 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 population; and biofilters can also be a source of nitrous oxide emissions due to

denitrification.

Additional disadvantages specifically related to th e use of biofilters to control emissions from livestock include: animals that may currently have access to corrals or pasture for exercise would need to be confined in buildings to maximize emission reductions; facilities that currently use naturally ventilation would incur additional costs because of the need to convert to mechanical ventilation; faci lities that currently use mechanical ventilation systems may need to upgrade these syste ms to overcome the increased pressure drop across the biofiltration system; grea ter energy usage for all facilities to push air through the biofilter; few reported cases where a biofilter has been shown to be economically viable when applied to animal feeding operations 3 ; a very large biofilter system must be used to handle these huge flow rates while maintaining adequate contact time for treatment of emissions. Finally, because of the need to provide adequate ventilation for livestock it is not practi cal and may not be feasible to treat all of the air from large confined animal housing units. T he article “Hog Building Designs Help Mitigate Environmental, Energy Concerns” by Steve H off, an Iowa State University Agricultural Engineer, states “To be clear, however, mitigation of all animal hou sing ventilation air is impossible. Not only is it unrea listic in terms of biofiltration size requirements, but the sheer amount of ventilation a ir is too large to mitigate.” 4

Biofilter VOC Control Efficiency

It is assumed that 80% of the gasses emitted from t he enclosed animal housing will be captured by the mechanical ventilation system and t hat a properly functioning biofilter will eliminate 85% of the captured VOC emissions 5 ; therefore, the total control for VOCs from the enclosed animal housing = 0.80 x 0.85 = 68 %.

Cost Estimates for Biofilters

Several reference documents were consulted to deter mine the expected capital and operating costs of using a biofilter to control VOC emissions from enclosed animal housing. These references and the resulting cost i nformation are listed below. Additionally, several companies that specialize in building and supplying biofilters and

bio-scrubbers for the control of VOC emissions were contacted to request capital cost estimates for biofilter systems specifically for th e treatment of VOC emissions from dairy

3 U.S. Environmental Protection Agency, “Emissions f rom Animal Feeding Operations” (Draft), EPA Contract No. 68-D6-0011, August 15, 2001, pg. 9-20, http://www.epa.gov/ttn/chief/ap42/ch09/draft/drafta nimalfeed.pdf 4 Hoff, Steve - Agricultural Engineer, Iowa State U niversity , “Hog Building Designs Help Mitigate Environmental, Energy Concerns”, National HogFarmer , April 15, 2010, http://nationalhogfarmer.com/environmental-stewards hip/regulations/environmental-energy-buildingdesigns-0426/n

5 The SCAQMD Rule 1133.2 staff report (page 18) indi cates control efficiencies of 80-90% for VOC for existing biofilter composting applications and that a well-designed, well-operated, and well-maintaine d biofilter is capable of achieving 80 percent contro l efficiency for VOC, http://www.aqmd.gov/rules/doc/r1133/r1133_staffrepo rt.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-9 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 cows housed in enclosed barns. The dollar amounts of the estimates provided by these companies are also listed below.

Sources of Cost Estimates for Biofilters

U.S. Environmental Protection Agency, The Clean Air Technology Center (CATC), “Using Bioreactors to Control Air Pollution” EPA-45 6/R-03-003, (E143-03), September 2003, http://www.epa.gov/ttn/catc/dir1/fbiorect.pdf

Costs for a Biofilter Capital Cost for a Biofilter (~ 2000): $2.35-7.74/c fm (from Table 3 excluding higher costs for biofilters with a flow rate less than 50, 000 cfm; does not include the cost of ducting) Capital Cost Estimate for a Biofilter (2003): $5.42 /cfm (See Table 9) Capital Cost Estimate for a Biofilter (2010) 6 : $6.67/cfm

Operating Cost Estimate for a Biofilter (2003): $3. 31/cfm-yr (Based on Table 9) Operating Cost Estimate for a Biofilter (2010): $4. 07/cfm-yr

Costs for a Bio-trickling Filter Capital Cost for a Biotrickling Filter (~ 2000): $2 0.20-30.30/cfm (from Table 6 excluding higher costs for the research biotricklin g at the Hyperion WWTP) Capital Cost Estimate for a Biotrickling Filter (20 03): $27.11/cfm (See Table 9) Capital Cost Estimate for a Biotrickling Filter (20 10): $33.34/cfm

Operating Cost Estimate for a Biotrickling Filter ( 2003): $6.35/cfm-yr (Based on Table 9) Operating Cost Estimate for a Biotrickling Filter ( 2010): $7.81/cfm-yr

U.S. Environmental Protection Agency, “Emissions fr om Animal Feeding Operations” (Draft), EPA Contract No. 68-D6-0011, August 15, 20 01, Section 9.2.3 - Biofiltration of Confinement Housing Exhaust, http://www.epa.gov/ttn/chief/ap42/ch09/draft/drafta nimalfeed.pdf

Costs for a Biofilter Capital Cost for an open Biofilter (1991): $12.79-2 0.93/cfm Capital Cost for an enclosed Biofilter (1991): $20. 93-116.28/cfm (Both based on the cost per sq. ft values and a bio filter loading of 4.3 cfm per sq. ft; Cost per sq. ft from Leson, G. and A.M. Winer. 1991 . “Biofiltration: An Innovative Air Pollution Control Technology for VOC Emissions”. Jo urnal of the Air and Waste Management Association . 41(8):1045-54.) Capital Cost for an open Biofilter (2010): $22.43-3 6.70/cfm Capital Cost for an enclosed Biofilter (2010): $36. 70-203.90/cfm

6 Based on 3% annual inflationSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-10 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Operating Cost Estimate for a Biofilter (1998): $2- 14/cfm (from Boyette, R. A. 1998. “Getting Down to (Biofilter) Basics”. Biocycle 39(5):58-62) Operating Cost Estimate for a Biofilter (2010): $2. 85-19.96/cfm-yr

Bohn, Hinrich, “Biofilter Technology Offers Emissio ns Abatement Option”, Distillers Grain Quarterly , 3 rd Qtr 2008, http://www.ethanolproducer.com/dgq/artic leprint.jsp?article_id=1257

Capital Cost Estimate for a Biofilter (2008): $15/c fm (“for larger units”) Capital Cost Estimate for a Biofilter (2010): $15.9 1/cfm

Operating Cost Estimate for a Biofilter (2008): $2/ cfm-yr Operating Cost Estimate for a Biofilter (2010): $2. 12/cfm-yr

Delhoménie, Marie-Caroline; Heitz, Michèle, “Biofil tration of Air: A Review”, Critical Reviews in Biotechnology , 1549-7801, Volume 25, Issue 1, 2005, Pages 53 – 7 2

Capital Cost Estimate for a Biofilter (2005): $16.9 9-118.93/cfm (Investment cost of $10-70 m 3 /hr) Capital Cost Estimate for a Biofilter (2010): $19.7 0-137.87/cfm

Operating Cost Estimate for a Biofilter (2005): $5. 10-16.99/cfm-yr (Operationt cost of $3-10 m 3 /hr) Operating Cost Estimate for a Biofilter (2010): $5. 91-19.70/cfm-yr

Boyette, R. Allen – E&A Environmental Consultants I nc., “Biofilter Economics and Performance”, 1996, http://www.p2pays.org/ref/12/11 505.pdf

Capital Cost Estimate for a Biofilter (1996): $2.50 -5.00/cfm (“for large biofilters treating more than 100,000 cfm of exhaust gas”) Capital Cost Estimate for a Biofilter (2010): $3.07 -6.15/cfm

Operating Cost Estimate for a Biofilter (1996): $2- 14/cfm-yr Operating Cost Estimate for a Biofilter (2010): $2. 46-17.22/cfm-yr

Govind

, Rakesh – PRD Tech Inc., White Paper - “Biofilteration: An Innovative Technology for the Future”, 1999, http://www.prdtechinc.com/PDF/PRDBIOFILTERR&DMAGAZI NEPAPER.pdf

Capital Cost Estimate for a Biotrickling Filter (19 99): $13.30-18/cfm (estimated from the Graphs in Figure 4) Capital Cost Estimate for a Biotrickling Filter (20 10): $18.41-24.92/cfm

Operating Cost Estimate for a Biotrickling Filter ( 1999): $3.33-6.67/cfm-yr (estimated from the Graphs in Figure 4)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-11 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Operating Cost Estimate for a Biotrickling Filter ( 2010): $4.61-9.23/cfm-yr

South Coast Air Quality Management District, “Techn ology Assessment for: Proposed Rule 1133: Emission Reductions from Composting and Related Operations”, March 22, 2002, http://www.aqmd.gov/rules/doc/r1133/r1133_tec hassessment.pdf

Capital Cost Estimate for a Biofilter (2002): $2.79 /cfm (based on the value given of $12/sq. ft and biofilter loading of 4.3 cfm per sq. ft) Capital Cost Estimate for a Biofilter (2010): $3.53 /cfm

Operating Cost Estimate for a Biofilter: 10% of cos t of enclosure and biofilter per

year

Schmidt, David. Janni, Kevin. Nicolai, Richard. “Bi ofilter Design Information”. Biosystems and Agricultural Engineering Update: BAE U-18, Revised March 2004. University of Minnesota Department of Biosystems an d Agricultural Engineering, College of Agricultural, Food and Environmental Sci ences, http://www.manure.umn.edu/assets/baeu18.pdf

Capital Cost Estimate for a Biofilter (2004): $0.15 -0.25/cfm Capital Cost Estimate for a Biofilter (2010): $0.25 -0.35/cfm 7

Operating Cost Estimate for a Biofilter (2004): $0. 005-0.015/cfm-yr Operating Cost Estimate for a Biofilter (2010): $0. 006-0.018/cfm-yr

Note: The capital cost estimate obtained from this source was ten times lower than the low-end of the cost estimates given in other so urces listed above and the estimates from biofilter suppliers presented below and the operating cost estimate

from this source was more than 100 times lower than the lowest the cost estimates given in the other sources listed above. Because o f this significant difference in costs, the design of this biofilter was evaluated t o determine if it would meet District

and EPA standards for an add-on VOC control device. This preliminary evaluation is

discussed below.

This document describes a biofilter designed to red uce odors not total VOCs. The document recommends that an open-bed biofilter used to control exhaust from animal housing have a depth of 10-18 inches and an empty bed contact time of 3-5 seconds. For an open-bed biofilter used for VOC co ntrol, the recommended depth and contact time are generally 3-5 feet and 30-60 s econds, respectively. The lower recommended depth is the result of limitations with typical exhaust fans used for ventilation in animal housing, which are not design ed for the larger pressure drops that would be caused by a deeper biofilter bed. It is likely that the much smaller

7 Based on a recent presentation on biofilters by th e University of Minnesota Extension: “Biofiltration
Basics”, 2009, https://umconnect.umn.edu/biofilter/SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-12 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 recommended contact time is related to the fact tha t the biofilter is only designed to reduce odors. Many odorous compounds are branched- chain volatile fatty acids (VFAs) that consist of large molecules with a stron g tendency to adhere to any surfaces that they contact; thus shortening the con tact time required to treat these compounds. Although VFAs are largely responsible f or objectionable odors from agricultural facilities, recent studies have shown that alcohols comprise the majority of VOC emissions. The biofilter design recommended in the document would not be as effective for reducing alcohols or other VOCs wh ich are more volatile and do not have a strong tendency to adhere to surfaces. The biofilter does not appear to be designed to handle the total flow rates from the an imal housing but is probably intended to handle smaller flow rates from high-odo r areas such as manure pits. Another limitation with the design is that there is no dedicated outlet to allow measurement and determination of control efficiency ; thus there isn’t any way to accurately assess if the biofilter is functioning p roperly. Because of the substantial deviation from established criteria for the design of biofilters for control of VOCs and the lack of information to support and quantify tot al VOC reductions from this particular design, the cost estimates associated wi th this design will be removed from further consideration. This design may be re- evaluated at a later time if the necessary information is provided or becomes availa ble.

Quotes/Estimates Received from Providers of Biofilt ers/Bio-Scrubbers for VOC Control

As stated above, several companies that supply biof ilters and bio-scrubbers for the control of VOC emissions were contacted to request capital cost estimates for biofilter systems capable of treating VOC emissions from dair y cows confined in enclosed barns. The companies that were contacted include: 1) Tri-Mer Corporation; 2) BioReaction Industries; 3) PRD Tech, inc.; 4) Sieme ns Water Technologies; 5) PPC Air Pollution Control Systems - PPC Biofilter; 6) Biore m/TEC Treatment Equipment Company; and 7) MEGTEC Systems, Inc.

The companies were provided information regarding t he type of VOCs that would be treated (mostly alcohols and VFAs) and were told th at the biofilter would need to be capable of treating airflow rates of 500,000 cfm or more. The estimates that were provided by these companies are listed below and ge nerally fell in the range of values given in the accepted sources listed above.

Estimate 1 Capital cost for units: $1.4-2.2 million Cost per cfm: $2.8-4.4/cfm Note: Two units required to handle 500,000 acfm; st ated control efficiency: 96%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-13 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Estimate 2 Capital cost: $8-10 million Cost per cfm: $16-20/cfm
Note: 100,000 ft 3 of media (one very large unit or several smaller u nits); stated control efficiency: 90%

Estimate 3 Capital cost: $7 million ± 20% Cost per cfm: $14/cfm ± 20% Note: cost of stack pad not included; Unit Size 90’ x 200‘ x 18’

Estimate 4 Capital cost: $20-25/cfm Note: multiple units required

Reduced Capital Cost from Economy of Scale

The potential for reduced dollar-per-cfm capital co sts was considered based on the large airflow rates that would be handled by biofil ters for confined animal facilities. Based on the information reviewed, it was determine d that there is not any additional cost reduction benefit related to economy of scale for biofilters handling such large flow

rates.

The information available indicates significant red uctions in biofilter costs per cfm as the

flow rate treated increases to a few thousand cfm b ut diminishing reductions in cost

after this until there is no further benefit. This is illustrated in the graph below. The graph shows no additional cost reductions benefits after approximately 50,000 cfm. Also, in a phone conversation with Jim Cash of MEGT EC Systems, Inc. he stated that economy of scale cost reductions for biofilter syst ems were insignificant after approximately 20,000 cfm. This was because multipl e individual units are generally required to treat flows greater than this and each unit would still cost about the same. Additionally, single units, and sometimes even mult iple units, handling such large flow rates would not be pre-fabricated but would have to be specially constructed on site, which can increase costs. This was also supported by the information provided by other biofilter suppliers. Therefore, any potential cost reduction benefits related to economy of scale have already been captured in the lower bi ofilter cost estimates given above

and no additional cost benefits will be realized at higher flow rates. As a result, the cost estimates for biofilters will be directly proportio nal to the airflow rate treated and the

number of animals housed.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-14 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Boyette, R. Allen – E&A Environmental Consultants I nc., “Biofilter Economics and Performance”, 1996

Cost Estimate for Biofilters for this Analysis

Based on the information above, the following biofi lter cost estimates will be used for this analysis. The cost estimate is conservatively low and is significantly lower than some of capitol cost estimates given in the referen ces listed above.

Capital Cost (2010): $3-35/cfm Operating Costs (2010): $2.12-20/cfm

A. Mechanically Ventilated Dairy Barns Vented to a Control Device

The following analysis is based on the cost of emis sion reductions for confining 1,000 milk cows in enclosed freestall buildings vented to a biofilter and venting the milking parlor to the same biofilter. Costs for larger dai ries would be linearly proportional.

Description of Dairy Housing

In a freestall barn, cows are grouped in large pens with free access to feed bunks, water, and stalls for resting. In the mild climate of the San Joaquin Valley, the typical freestall barn is an open structure (roof but no si des). The primary freestall design consists of a roof that provides shade with all sid es open to allow air to flow through, which keeps the cows cool. The open freestall barn s take advantage of natural summer winds in the San Joaquin Valley that are generally greater than four mph. The natural

winds result in an excellent summer ventilation rat e that is equivalent to 1000 cfm per cow more, which is why open dairy barns are general ly recommended in the SanSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-15 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Joaquin Valley. In colder climates enclosed or par tially enclosed barns may be utilized to protect cows from winter extremes. However, no enclosed freestall barns that were installed at a California dairy were identified.

Although the potential to enclose cows in a barn ma y exist, the feasibility of reasonably collecting the gas through a stack, chimney, or ven t remains in question considering the extremely large amounts of airflow going through th e barns needed to keep the cows cool. The airflow requirements would be even highe r in the San Joaquin valley, where temperatures can exceed 110 degrees in the hot summ er. If the barn exhaust can be properly captured it may be possible to vent it to a biofilter for VOC control. Some of the potential disadvantages related to the use of a bio filter to control emissions from

enclosed livestock barns were mentioned above. One of the disadvantages mentioned was the large space requirement for the traditional biofilter design. To further illustrate this, a low-cost natural bed biofilter designed to treat the VOC emissions from 1,000 milk cows and 180 dry cows with no support stock wo uld cover more than 5.4 acres and would need to be maintained free of pests and appro ved by the appropriate permitting agencies. To avoid such expansive land requirement s, the dairy would likely need to use much more expensive bio-trickling filters or bi o-scrubbers.

Even though questions remain about the reasonabilit y of requiring animals to be confined in buildings and venting the exhaust to a biofilter, it will be considered for purposes of this analysis.

Cost of Enclosed Freestall Barns

The sources listed below were consulted to determin e the expected capital and operating costs of mechanically ventilated freestal l barns.

Source of Cost Estimates for Enclosed Freestall Bar ns

Jones, Lawrence R., “Choosing a Freestall Barn Styl e”, June 18, 2002, http://www.milkproduction.com/Library/Articles/Choo sing_a_Freestall_Barn_Style.htm Capital Cost for traditional open freestall barn (2 002): $1,430.56-1,750.00/cow Capital Cost (2010) 8 : $1,812-2,217/cow

Quaife, Thomas, “Tunnel Ventilation: So far, so goo d”, Dairy Herd Management

, February 2006, http://www.dairyherd.com/directories .asp?pgID=724&ed_id=5169 Capital Cost (2006): $1,500/cow (25% more than conv entional open freestall barns) Capital Cost (2010): $1,688/cow

DiGuiseppe, Gary, “Cow Comfort Innovations in the b arn”, American Dairymen , Vol. 35, Number 3, March 2009, http://www.americandairymen.c om/articles/cow-comfortinnovations-barn Capital Cost (2009): $500/cow more than conventiona l open freestall barns

8 Based on 3% annual inflationSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-16 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Capital Cost (2010): $1,851-2,717/cow

Emails from Paul Martin of Western United Dairymen based on contacts in New York Capital Cost (2010): $2,000-2,700/cow (Estimate fro m 8/27/10 email) Capital Cost (2010): $2,500/cow (9/3/10 email based on recently constructed dairy in NY)

Gooch, Curt, “Dairy Freestall Barn Design – A North east Perspective”, Presented at the Ninth Annual Fall Dairy Conference - Cornell Univer sity College of Veterinary Medicine and Cornell PRO-DAIRY Program. November 12 -13, 200 8, http://www.ansci.cornell.edu/pdfs/pddairybarndesign .pdf Increased Operating Costs (2008): $127/cow more tha n conventional open freestall barns (based on operating costs given in Table 5 fo r a 4-row tunnel-ventilated barn) Increased Operating Costs (2010): $135/cow more

Dhuyvetter, Kevin C., Harner, Joe P., Smith, John F ., & Bradford, Barry J., Kansas State University Department of Agricultural Economi cs, “Economic Considerations of Low-Profile Cross-Ventilated Freestall Barns”, Pres ented at Dairy Housing of the Future, Sioux Falls, South Dakota. September 10-11, 2008, http://www.agmanager.info/dhuyvetter/presentations/ 2008/LPCV%20Conference(Sep2008). pdf Increased Operating Costs (2008): $69.95-92.23/cow more than conventional open freestall barns (See Page 11) Increased Operating Costs (2010): $74.21-97.85/cow more

Cost Estimates for Enclosed Freestall Barns for thi s Analysis

Based on the information above, the following cost estimates will be used for this analysis.

Capital Cost (2010): $1,700-2,700/cow Estimated Adjusted Capital Cost: $1,275-2,025/cow ( capital cost estimate reduced by 25% because it may be possible to use the existing concrete work and some of the existing freestall infrastructure with the new buil ding shell) Increased Operating Costs: $74-135/cow more

Capital Cost for Freestall Barn Enclosure for 1,000 milk cows

Low capital cost estimate: $1,275/cow x 1,000 cows = $1,275,000 High capital cost estimate: $2,025/cow x 1,000 cows = $2,025,000

Increased Operating Costs for Enclosed Freestall Ba rn for 1,000 milk cows

Low operating cost estimate: $74/cow-yr x 1,000 cow s = $74,000/yr High operating cost estimate: $135/cow-yr x 1,000 c ows = $135,000/yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-17 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Cost of Biofiltration

The cost estimates for biofiltration are based on t he references given above. The cost is largely dependent on the airflow rate that the biof ilter must handle. Biofilters used to

treat exhaust air should be sized to treat the maxi mum ventilation rate, which is typically the warm weather rate. The higher cost value is re presentative of a biotrickling filter, which may be necessary to handle the high air flow rates from the barns.

Capital Cost for a biofilter: $3-35/cfm Operating Costs for a biofilter: $2.12-20.00/cfm-yr

Required Airflow Rate of the Freestall Barns

In order to calculate the costs of this control opt ion, the airflow rate required for the freestall barns must be determined. The University of Minnesota’s publication “Improving Mechanical Ventilation in Dairy Barns”, gives minimum ventilation rates for dairy cattle, which are listed in the table below.

Minimum Ventilation Rates for Dairy Cows (cfm/cow)

Age Winter Mild Weather Summer

Baby Calf 15 50 100

Heifer (2-12 months) 20 60 130

Heifer (12-24 months) 30 80 180

Mature Cow 50 170 500 – 1,000

The minimum summer ventilation rate listed for matu re cows is 500 cfm per cow. However, according to the University of Minnesota p ublication and Cornell University’s publication “Natural or Tunnel Ventilation of Frees tall Structures: What is Right for Your Dairy Facility?”, the required airflow rate in the summer increases to 1,000 cfm per cow if tunnel ventilation is used to provide additional cooling. 9

The climate in the San Joaquin Valley is characteri zed by mild winters and hot summers. Because of the warmer climate, it is expe cted that tunnel ventilation or a similar system would need to be employed in an encl osed freestall barn to prevent excessive heat stress. Additionally, tunnel ventil ation systems are more representative of the types of systems that would be required to c apture and control emissions.

9 Improving Mechanical Ventilation in Dairy Barns, J .P. Chastain, http://www.milkproduction.com/Library/Articles/Impr oving_mechanical_ventilation.htm and Natural or

Tunnel Ventilation of Freestall Structures: What is Right for Your Dairy Facility?, C.A. Gooch, http://www.ansci.cornell.edu/pdfs/nattunnel.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-18 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Minimum Summer Air Requirements for freestall barns vented to a biofilter for 1,000

milk cows:

The minimum required summer airflow rate for housin g the 1,000 milk cows in enclosed

freestalls is calculated as follows:

Low Summer Ventilation Rate: 1,000 milk cows x 500 cfm/cow = 500,000 cfm High Summer Ventilation Rate: 1,000 milk cows x 1,0 00 cfm/cow = 1,000,000 cfm

Summer Ventilation Range for 1,000 milk cows: 500,0 00 – 1,000,000 cfm

Capital Cost of a Biofilter for 1,000 milk cows

The lower cost estimate does not include installati on of the required ductwork. As stated above, the estimated capital costs for a biofilter range of between $3.00 per cfm and $35.00 per cfm. The capital cost estimates of a bi ofilter for enclosed freestall barns housing 1,000 milk cows are calculated as follows:

Low capital cost estimate: $3.00/cfm x 500,000 cfm = $1,500,000 High capital cost estimate: $35.00/cfm x 1,000,000 cfm = $35,000,000

Operating Costs for a Biofilter for 1,000 milk cows

Low operating cost estimate: $2.12/cfm-yr x 500,000 cfm = $1,060,000/yr High operating cost estimate: $20.00/cfm-yr x 1,000 ,000 cfm = $20,000,000/yr

Annualized Capital Costs for Biofilter for 1,000 mi lk cows

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The cost for the purchase o f the enclosed freestall barn and biofilter will be spread over the expected life of the system using the capital recovery equation. Therefore, the expected life of the enti re system (enclosed barn, fans, media, plenum, etc) will be estimated at 10 years. A 10% interest rate is assumed in the equation and the assumption will be made that the e quipment has no salvage value at the end of the ten-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost P=Present Value (freestall enclosure and biofilter) I=Interest Rate (10%) N= Equipment Life (10 years)

Low Annualized Capital Cost Estimate = [($1,275,000 + $1,500,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $451,618/yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-19 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 High Annualized Capital Cost Estimate = [($2,025,000 + $35,000,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $6,025,648/year

Total Annual Cost Estimates

The total annualized capital costs and operating co sts for a freestall enclosure vented to a biofilter are given below. For the least expensi ve biofilters, the biofilter media (e.g., soil, compost, wood chips) must be replaced after 3 -5 years in order to remain effective. This may be an additional cost because it is unclea r if this cost was included in the least expensive operating cost estimates provided above.

Total annual cost estimate = (total annualized capi tal cost) + (increased operating cost for an enclosed freestall barn) + (operating c ost for a biofilter)

Low total annual cost estimate = ($451,618/yr) + ($74,000/yr) + ($1,060,000/yr) = $1,585,618/year

High total annual cost estimate = ($6,025,648/yr) + ($135,000/yr) + ($20,000,000/yr) = $26,160,648/year

Potential Income from Increased Milk Production

Cooling milk cows in enclosed freestall barns may r educe heat stress and result in increased milk production. Because dairy cows in C alifornia already have some of the highest milk production rates in the nation, it is questionable regarding whether enclosing the milk cows will result in any signific ant increases in milk production. This is because heat stress is related to both temperature and humidity and it is likely that the increased temperatures in California relative to ot her states are mitigated by the much lower humidity. Although questions remain about th e potential to increase milk production in the San Joaquin Valley by reducing he at stress, this potential benefit will be quantified for this analysis.

Potential Increased Daily Milk Production: 4-6 lb/c ow-day (4570 Staff Report, June 2006) Potential Increased Annual Milk Production: 1,460-2 ,190 lb/cow-yr

Class 4b Price of milk 10 for August 2010: $14.39/cwt Income from increased milk production: $210.09-315. 14/cow-yr

Max Income from increased milk production for 1,000 milk cows: 1,000 milk cows x $315.14/cow-yr = $315,140/yr

Low total annual cost estimate – income from increa sed milk production = ($1,585,618/yr) - ($315,140/yr) = $1,270,478/year

10 http://www.cdfa.ca.gov/dairy/pdf/Prices_Grid.pdf ; The Class 4b milk price was because dairy industr y representatives state that increased production is purchased at the lowest price. Additionally, suffi cient increased production will cause the price to fallSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-20 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 VOC Emission Reductions for Biofiltration for 1,000 Milk Cows

The annual VOC Emission Reductions for enclosed fre estall barns for 1,000 milk cows

vented to a biofilter are calculated as follows:

[Number of cows] x [Cow Housing VOC EF (lb/cow-year )] x [Capture Efficiency] x [Biofilter Control Efficiency]

VOC Reductions from Milk Cows Housed in Enclosed Fr eestall Barns

Vented to a Biofilter (Cows, Stalls, & Lanes)

Emissions Source # of

cows x EF

(lb/cow-yr) x Capture

(%) x Control

(%) = lb-VOC/yr

Milk Cow (enteric)* 1,000 x 4.1 x 80% x 85% = 2,788

Stalls and Lanes 1,000 x 1.8 x 80% x 85% = 1,224
Milking Parlor Floor 1,000 x 0.03 x 80% x 85% = 20

Total (lb-VOC/yr) 4,032

*Includes emissions in the milk parlor(s)

VOC Reductions from TMR (Feed) for Milk Cows Housed in

Enclosed Freestall Barns Vented to a Biofilter

# of

cows EF (ug/m 2 -min) Feed area

per cow (m 2 ) min/yr lb/ug = Uncontrolled lb-VOC/yr x Capture

(%) x Control

(%) = lb-VOC/yr

1,000 16,119 0.658 525,600 2.20462E-09 = 12,290 x 80% x 85% = 8,357

Total Emission VOC Reduction from Milk Parlor, Cows , Stalls, Lanes, and Feed = 4,032 lb-VOC/yr + 8,357 lb-VOC/yr = 12,389 lb-VOC/y r

Cost of VOC Emission Reductions

Low Estimate 11 =($1,270,478/year)/[(12,389 lb-VOC/year)(1 ton/200 0 lb)]

= $205,098/ton of VOC reduced

High Estimate =($26,160,648/year)/[(12,389 lb-VOC/ year)(1 ton/2000 lb)]

= $4,223,206/ton of VOC reduced

As shown above, the costs for a freestall enclosure and biofilter would cause the cost of the VOC reductions to be greater than $205,098/ton. There are additional costs related to increased electricity use, and regulatory compli ance and testing that have not been quantified in this analysis. Even without these co sts, the cost of the VOC emission reductions achieved far exceed the $17,500/ton cost effectiveness threshold of the District BACT policy. Therefore, this option would not be required as BACT and is beyond BARCT and any applicable RACT requirements.

11 Includes reduction in overall annual costs because of potential additional revenue from maximum supposed increase in milk production.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-21 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 B. Mechanically Ventilated Poultry Houses Vented to a Control Device

The cost of the VOC emission reductions for venting a mechanically-ventilated poultry house to a control device is analyzed below. As st ated above, a biofilter is expected to be the least costly control device so it was chosen for purposes of this analysis.

Ventilation in a Poultry House

In poultry houses, ventilation is used to remove mo isture and ammonia from the houses during the winter season and to remove excess heat and ammonia from the houses during the summer season. Partially enclosed housi ng structures have open sidewalls with curtains that are opened and closed to control the house ventilation rate. In totally enclosed housing, mechanical ventilation is used. Mechanical ventilation is typically provided by an induced draft or negative-pressure s ystem. An induced draft system pulls fresh air into the house from one end and exh austs on the other. A negativepressure system draws fresh air into the house from side vents and out through the exhaust fan. Totally enclosed mechanically ventilat ed housing is known as tunnel-type housing or environmental housing. It may be possibl e to vent the exhaust from mechanically ventilated poultry houses to a control device; therefore, this option will be analyzed.

Cost of Biofiltration

The cost estimates for a biofiltration are based on the references given above. The cost is largely dependent on the airflow rate that the biof ilter must handle. Biofilters used to

treat exhaust air should be sized to treat the maxi mum ventilation rate, which is typically the warm weather rate. The higher cost value is re presentative of a biotrickling filter, which may be necessary to handle the high air flow rates from the houses.

Capital Cost for a biofilter: $3-35/cfm Operating Costs for a biofilter: $2.12-20.00/cfm-yr

Required Airflow Rate of the Poultry Houses

In order to calculate the costs of this control opt ion, the maximum airflow to be treated

from the houses house must be determined.

The MidWest Plan Service publication “Mechanical Ve ntilating Systems for Livestock Housing” (MWPS-32), gives minimum ventilation rates for poultry, which are listed in the

table below.

Minimum Ventilation Rates for Poultry (cfm/bird)

Animal Type Winter Mild Weather Summer

Broiler/Layer (5 lb) 0.5 2.5 5

Turkey (40 lb) 3.2 14 32SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-22 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Capital Cost of Biofilter for a Poultry House with 32,000 Broilers or Layers or 5,000 Turkeys

The lower cost estimate does not include installati on of the required ductwork. As stated above, the estimated capital costs for a biofilter range of between $3.00 per cfm and $35.00 per cfm. The capital cost estimates of a bi ofilter for mechanically ventilated poultry houses for 32,000 broilers or layers or 5,000 turke ys are calculated as follows:

Low capital cost estimate: $3.00/cfm x 160,000 cfm = $480,000 High capital cost estimate: $35.00/cfm x 160,000 cf m = $5,600,000

Operating Costs for a Biofilter for a Poultry House with 32,000 Broilers or Layers or 5,000 Turkeys

Low operating cost estimate: $2.12/cfm-yr x 160,000 cfm = $339,200/yr High operating cost estimate: $20.00/cfm-yr x 160,0 00 cfm = $3,200,000/yr

Annualized Capital Costs for Biofilter for 32,000 B roilers or Layers or 5,000 Turkeys

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The cost for the purchase o f the biofilter will be spread over the expected life of the system using the capital r ecovery equation. Therefore, the expected life of the entire system (fans, media, pl enum, etc) will be estimated at 10 years. A 10% interest rate is assumed in the equat ion and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost P=Present Value (biofilter) I=Interest Rate (10%) N= Equipment Life (10 years)

Low Annualized Capital Cost Estimate = [($480,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $78,118/year

High Annualized Capital Cost Estimate = [($5,600,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $911,374/year

Total Annual Cost Estimates

The total annualized capital costs and operating co sts for the biofilter are given below. For the least expensive biofilters, the biofilter m edia (e.g., soil, compost, wood chips) must be replaced after 3-5 years in order to remain effective and this may be an

additional cost. There would also be increased ele ctricity usage to overcome the pressure drop caused by the biofilter. This cost w as not quantified.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-23 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Total annual cost estimate = (total annualized capi tal cost) + (operating cost for a biofilter)

Low total annual cost estimate = ($78,118/yr) + ($ 339,200/yr) = $417,318/year

High total annual cost estimate = ($911,374/yr) + ($3,200,000/yr) = $4,111,374/year

VOC Emission Reductions for a Biofilter for 32,000 Broilers or Layers or 5,000 Turkeys

The annual VOC Emission Reductions for a mechanical ly-ventilated poultry house for 32,000 broilers or layers or 5,000 turkeys vented t o a biofilter are calculated as follows:

[Number of Birds] x [Poultry VOC EF (lb/bird-year)] x [Capture Efficiency] x [Biofilter Control Efficiency]

VOC Reductions from Enclosed Poultry Houses Vented to a Biofilter

Poultry Type # of Birds x EF (lb/bird-yr) x Capture

(%) x Control

(%) = lb-VOC/yr

Broiler 32,000 x 0.025 x 80% x 85% = 544

Layer 32,000 x 0.025 x 80% x 85% = 544

Turkey 5,000 x 0.1 x 80% x 85% = 340

Cost of VOC Emission Reductions

Broilers/Layers Low Estimate = ($417,318/year)/[(544 lb-VOC/year)( 1 ton/2000 lb)]

= $1,534,257/ton of VOC reduced

High Estimate = ($4,111,374/year)/[(544 lb-VOC/ye ar)(1 ton/2000 lb)]

= $15,115,346/ton of VOC reduced

Turkeys Low Estimate =($417,318/year)/[(340 lb-VOC/year)(1 ton/2000 lb)]

= $2,454,812/ton of VOC reduced

High Estimate =($4,111,374/year)/[(340 lb-VOC/yea r)(1 ton/2000 lb)]

= $24,184,553/ton of VOC reduced

As shown above, the costs for a biofilter for poult ry houses would cause the cost of the VOC reductions to be greater than $1,534,257/ton fo r broilers and layers and greater than $2,454,812/ton for turkeys. There are additio nal costs related to increased electricity use, and regulatory compliance and test ing that have not been quantified in this analysis. Even without these costs, the cost of the VOC emission reductions achieved far exceed the $17,500/ton cost effectiven ess threshold of the District BACTSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-24 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 policy. Therefore, this option would not be requir ed as BACT and is beyond BARCT and any applicable RACT requirements.

C. Mechanically Ventilated Swine Houses Vented to a Control Device

The cost of the VOC emission reductions for venting a mechanically-ventilated swine house to a control device is analyzed below. As st ated above, a biofilter is expected to be the least costly control device so it was chosen for purposes of this analysis.

Description of Ventilation in Swine Housing

Swine are typically housed in confinement buildings that are either totally enclosed or partially enclosed structures with open sidewalls w ith curtains. In totally enclosed housing, mechanical ventilation is used throughout the year. Mechanical ventilation is typically provided by an induced draft or negative- pressure system. An induced draft system pulls fresh air into the house from one end and exhausts on the other. A negative-pressure system draws fresh air into the h ouse from side vents and out through the exhaust fan. Partially enclosed swine housing uses natural ventilation the majority of the year. In these buildings the sidew all curtains are opened and closed to control the house ventilation rate. Partially encl osed swine housing may also use

mechanical ventilation when the curtains are closed due to weather conditions. Ventilation in swine housing is used to remove exce ss moisture, ammonia, and hydrogen sulfide from swine housing and to remove e xcess heat during the summer season. It may be possible to vent the exhaust fro m mechanically ventilated swine houses to a control device; therefore, this option will be analyzed.

Cost of Biofiltration

The cost estimates for a biofiltration are based on the references given above. The cost is largely dependent on the airflow rate that the biof ilter must handle. Biofilters used to

treat exhaust air should be sized to treat the maxi mum ventilation rate, which is typically the warm weather rate. The higher cost value is re presentative of a biotrickling filter, which may be necessary to handle the high air flow rates from the houses.

Capital Cost for a biofilter: $3-35/cfm Operating Costs for a biofilter: $2.12-20.00/cfm-yr

Required Airflow Rate of the Swine Houses

In order to calculate the costs of this control opt ion, the maximum airflow to be treated from the houses the swine housing building must be determined.

The MidWest Plan Service publication “Mechanical Ve ntilating Systems for Livestock Housing” (MWPS-32), gives minimum ventilation rates for finishing swine, which are

listed in the table below.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-25 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Minimum Ventilation Rates for Finishing Swine (cfm/ head)

Animal Type Winter Mild Weather Summer

Finishing Swine 10 35 120

Minimum Summer Air Requirements for Swine Housing f or 3,000 Finishing Head:

The minimum required summer airflow rate for housin g the 3,000 head of swine in enclosed housing is calculated as follows:

Summer Ventilation Rate: 3,000 head x 120 cfm/head = 360,000 cfm

Capital Cost of Biofilter for Swine Housing with 3, 000 Finishing Head

The lower cost estimate does not include installati on of the required ductwork. As stated above, the estimated capital costs for a biofilter range of between $3.00 per cfm and $35.00 per cfm. The capital cost estimates of a bi ofilter for mechanically ventilated swine housing with 3,000 finishing head are calculated as follows:

Low capital cost estimate: $3.00/cfm x 360,000 cfm = $1,080,000 High capital cost estimate: $35.00/cfm x 360,000 cf m = $12,600,000

Operating Costs for Biofilter for Swine Housing wit h 3,000 Finishing Head

Low operating cost estimate: $2.12/cfm-yr x 360,000 cfm = $763,200/yr High operating cost estimate: $20.00/cfm-yr x 360,0 00 cfm = $7,200,000/yr

Annualized Capital Costs for Biofilter for Swine Ho using with 3,000 Finishing Head

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The cost for the purchase o f the biofilter will be spread over the expected life of the system using the capital r ecovery equation. Therefore, the expected life of the entire system (fans, media, pl enum, etc) will be estimated at 10 years. A 10% interest rate is assumed in the equat ion and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost P=Present Value (biofilter) I=Interest Rate (10%) N= Equipment Life (10 years)

Low Annualized Capital Cost Estimate = [($1,080,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $175,765/year

High Annualized Capital Cost Estimate =SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-26 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 [($12,600,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $2,050,592/year

Total Annual Cost Estimates

The total annualized capital costs and operating co sts for the biofilter are given below. For the least expensive biofilters, the biofilter m edia (e.g., soil, compost, wood chips) must be replaced after 3-5 years in order to remain effective and this may be an

additional cost. There would also be increased ele ctricity usage to overcome the pressure drop caused by the biofilter. This cost w as not quantified.

Total annual cost estimate = (total annualized capi tal cost) + (operating cost for a biofilter)

Low total annual cost estimate = ($175,765/yr) + ( $763,200/yr) = $938,965/year

High total annual cost estimate = ($2,050,592/yr) + ($7,200,000/yr) = $9,250,592/year

VOC Emission Reductions for Biofilter for Swine Hou sing with 3,000 Finishing Head

The annual VOC Emission Reductions for mechanically -ventilated swine housing for 3,000 finishing head vented to a biofilter are calc ulated as follows:

[Number of Head] x [Poultry VOC EF (lb/head-year)] x [Capture Efficiency] x [Biofilter Control Efficiency]

VOC Reductions from Enclosed Swine House Vented to a Biofilter

Animal # of

Head x EF*

(lb/head-yr) x Capture

(%) x Control

(%) = lb-VOC/yr

Finishing Swine 3,000 x 4.2 x 80% x 85% = 8,568

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from housing

barns and 9% of VOC emissions are assumed to be fro m lagoons 12

Cost of VOC Emission Reductions

Low Estimate = ($938,965/year)/[(8,568 lb-VOC/year) (1 ton/2000 lb)]

= $219,180/ton of VOC reduced

High Estimate = ($9,250,592/year)/[(8,568 lb-VOC/ye ar)(1 ton/2000 lb)]

= $2,159,335/ton of VOC reduced

As shown above, the costs for a biofilter for swine housing would cause the cost of the VOC reductions to be greater than $219,180/ton. Th ere are additional costs related to

12 Rumsey, I. C., “Characterizing Reduced Sulfur Comp ounds and Non-Methane Volatile Organic Compounds Emissions from a Swine Concentrated Anima l Feeding Operation” (2010) – PhD dissertation submitted to the Graduate Faculty of North Carolina State UniversitySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-27 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 increased electricity use, and regulatory complianc e and testing that have not been quantified in this analysis. Even without these co sts, the cost of the VOC emission reductions achieved far exceed the $17,500/ton cost effectiveness threshold of the District BACT policy. Therefore, this option would not be required as BACT and is beyond BARCT and any applicable RACT requirements.

D. Mechanically Ventilated Poultry Houses

The analysis evaluates replacing naturally ventilat ed animal housing with mechanically ventilated housing. The effectiveness of this meas ure is related to rapidly reducing the

moisture in the manure and the associated microbial activity that produces emissions. Because of this, this measure is only applicable wh en animals are housed inside a building and the animals produce manure that does n ot contain excessive amounts of moisture; therefore this analysis will evaluate thi s option only for poultry facilities because other types of animals are generally housed outside (e.g. feedlot cattle) or produce manure that is handled as a liquid (e.g. sw ine). The cost of the VOC emission reductions for replacing a naturally ventilated pou ltry house with a mechanically ventilated poultry house is analyzed below. The an alysis will look at the costs for both turkeys and broilers. Because both broilers and la ying hens have the same VOC emissions on a per bird basis and the overall costs of mechanically-ventilated housing for broilers is expected to be much less than mecha nically-ventilated housing for laying hens because of the need for additional equipment f or collection of eggs, the lower cost associated with mechanically-ventilated housing for broilers will also provide the minimum cost of VOC reductions when applying this m easure to laying hens. The following analysis is based on typical broiler and turkey operations in California and demonstrates that replacing naturally ventilated po ultry houses with mechanically

ventilated houses is not cost-effective for existin g facilities. The analysis of the VOC

reductions for broiler houses also shows that the V OC emission reductions would not be cost effective for layers because mechanically vent ilated houses for laying hens would have higher costs.

Process Description for Typical Broiler and Turkey Houses in the San Joaquin Valley

Broilers and turkeys are produced to meet specific requirements of the customer, which can be a retail grocery store, fast-food chain, or an institutional buyer. The production cycle of broilers and turkeys is divided into two p hases: brooding and grow-out. The brooding phase begins when freshly hatched chicks f rom local hatcheries are delivered and placed in a heated section of a poultry house k nown as the brood chamber. The brood chamber of the house is kept warm for newly h atched chicks. In a typical poultry house in the San Joaquin Valley about 20,000 - 35,0 00 broiler chicks or 8,500 turkey poults are released into each house at the beginnin g of each grow-out period. During the birds’ first few weeks of growth, the temperatu re is gradually decreased. After completion of the grow-out phase the broilers and t urkeys are transported to a nearby processing plant. The length of the grow-out phase for broiler chickens is approximatelySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-28 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 45 days, resulting in an average weight of 4.5 to 5 .5 pounds. Turkey hens are usually grown for 14 to 16 weeks and turkey toms are usuall y grown for 17 to 21 weeks.

In poultry houses, ventilation is used to remove mo isture and ammonia from the houses during the winter season and to remove excess heat and ammonia from the houses during the summer season. Partially enclosed housi ng structures have open sidewalls with curtains that are opened and closed to control the house ventilation rate. In totally enclosed housing, mechanical ventilation is used. Mechanical ventilation is typically provided by an induced draft or negative-pressure s ystem. An induced draft system pulls fresh air into the house from one end and exh austs on the other. A negativepressure system draws fresh air into the house from side vents and out through the exhaust fan. Totally enclosed mechanically ventilat ed housing is known as tunnel-type housing or environmental housing.

Description of Control Technology

The mechanically ventilated environmental houses wi ll have advanced environmental control system that uses thermostats, sensors, and timers to more effectively control their exhaust fans. Environmental conditions (e.g. temperature, humidity, ventilation, and lighting) within the houses are usually control led by a computer system and monitored by staff. The conditions in the houses a re controlled in a manner to optimize animal growth, maintain animal health, minimize fee d spoilage and waste, and reduce moisture and undesirable microorganisms in the hous es. This tight control of environmental conditions has a positive impact on o verall air quality. It is conservatively assumed that mechanically-ventilated environmental housing will reduce VOC emissions from poultry houses by 15%.

Capital Cost of a Mechanically Ventilated Poultry H ouses

The cost estimate for a mechanically ventilated pou ltry house is based on information taken from the University of California Cooperative Extension Poultry Fact Sheet No. 20

“Chicken Meat Production in California” 13 (June 1995). This publication gives an initial capital cost estimate of $115,000 for a broiler hou se for a 40 ft x 500 ft (20,000 sq. ft.) mechanically ventilated broiler house for 22,200 bi rds. Because this estimate is 15 years old, this cost will be updated to 2010 dollars assu ming a 3% annual inflation rate. The cost

estimate in 2010 dollars is calculated as follows:

2010 Capital Cost Estimate = $115,000 x 1.03 (2010-1995) = $179,166

Although this cost will be used for purposes of thi s analysis, some producers have provided more recent information indicating that th e cost for mechanically ventilated environmental poultry houses is significantly highe r.

13 “Chicken Meat Production in California” University of California Cooperative Extension Poultry Fact S heet No. 20 Ernst, Ralph A. (June 1995) http://animalscience.ucdavis.edu/avian/pfs20.htmSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-29 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Turkey operations use the same housing structures a s broilers but have fewer birds per house. The University of California Cooperative Ex tension, California Poultry Workgroup publication “Animal Care Series: Turkey Care Practi ces” 14 (May 1998) states that “Approximately 10,000 hens or 7,000 toms are placed in the typical 50 by 500 foot barn.” This results in an average of 8,500 turkeys per 25,000 sq. ft. house. Therefore, it will be assumed that the 20,000 sq. ft. broiler house described above can house 6,800 turkeys (8,500 birds x 20,000 sq. ft./25,000 sq. ft .).

Annualized Capital Cost a Mechanically Ventilated P oultry House for 22,200 Broilers or 6,800 Turkeys

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The cost for the initial co st of the poultry house will be spread over the expected life of the system using the capi tal recovery equation. The expected life of the entire system will be estimated at 10 y ears. A 10% interest rate is assumed in the equation and the assumption will be made that t he equipment has no salvage value at the end of the ten-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost

P=Present Value I=Interest Rate (10%) N= Equipment Life (10 years)

Annualized Capital Cost Estimate = [$179,166 x 0.1( 1.1) 10 ]/[(1.1) 10 -1] = $29,158/year

VOC Emission Reductions for a Mechanically Ventilat ed Poultry House for 22,200 Broilers or 6,800 Turkeys

The annual VOC Emission Reductions for a mechanical ly-ventilated poultry house for 22,200 broilers and 6,800 turkeys are calculated as follows:

[Number of Birds] x [Poultry VOC EF (lb/bird-year)] x [Mechanical Ventilation Control Efficiency]

Broilers = (0.025 lb-VOC/bird-year) (22,200 bird/house) (0.1 5) = 83 lb-VOC/house-year

Turkeys = (0.1 lb-VOC/bird-year) (6,800 bird/house) (0.15) = 102 lb-VOC/house-year

Cost of VOC Emission Reductions

14 “Animal Care Series: Turkey Care Practices” Univer sity of California Cooperative Extension California Poultry Workgroup (May 1998) http://www.vetmed.ucdavis.edu/vetext/INF-PO_TurkeyC arePrax.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-30 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Broilers/Layers Cost Estimate = ($29,158/year)/[(83 lb-VOC/year)(1 ton/2000 lb)]

= $702,602/ton of VOC reduced

Turkeys Cost Estimate =($29,158/year)/[(102 lb-VOC/year)(1 ton/2000 lb)]

= $571,725/ton of VOC reduced

As shown above, the capital cost alone for mechanic ally ventilated poultry housing would cause the cost of the VOC reductions to be gr eater than $700,072/ton for broilers and layers and greater than $571,725/ton for turkey s. This cost does not include the costs of demolition of the existing naturally venti lated poultry house. Even without these costs, the cost of the VOC emission reductions achi eved exceed the $17,500/ton cost effectiveness threshold of the District BACT policy . Therefore, this option would not be required as BACT and is beyond BARCT and any applic able RACT requirements.

V. ANALYSES FOR MANURE HANDLING SYSTEMS

A. Poultry House with a Belt Manure Removal System

The cost of the VOC emission reductions for convert ing an existing poultry house to a manure-belt poultry house is analyzed below. The u se of manure-belt houses is only applicable to birds that are housed in cages and wo uld not be applicable to birds that are housed directly on litter, which is the case fo r most broilers and turkeys; therefore, this analysis will be based on layer operations. I n addition, forced drying of poultry manure inside poultry houses and forced drying of p oultry manure that is directly removed from the houses on a frequent basis will ge nerally require use of some type of manure belt handling system. Therefore, this analy sis also serves to establish the minimum cost of VOC reductions for using an in-hous e poultry manure drying system.

Description of Housing in a Typical Laying Hen Oper ation

Laying hens maintained for table egg production are usually confined in cages. This allows automation of feed distribution and egg coll ection. Most confinement facilities for laying hens are mechanically ventilated to remove t he moisture and carbon dioxide produced by respiration. Exhaust fans draw air int o the building through slots located along the perimeter of the roof. There are several types of cage systems including full and modified stair-step systems. With modified sta ir-step cage systems, upper cages are partially offset with a baffle diverting manure from upper cages away from lower cages. There are also cage systems that stack cage s without any offset to maximize the number of birds per unit floor area. In single story buildings, full or modified stair systems are located over shallow manure collection pits that may be cleaned either by scraping or flushing. With stacked cage systems, a belt system under the cages can be

used to collect and remove manureSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-31 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Description of Control Technology

Belt systems can be used to handle manure generated by poultry confined in cages. Manure in manure-belt poultry houses drops onto bel ts beneath cages and is frequently removed from the house, usually several times per w eek. This is in contrast to deep-pit

houses in which manure can accumulate in houses for several months to a year. The manure that falls on the belts begins to dry. A fo rced-air drying system can also be

used to further reduce the moisture content of the manure. The manure removed from the houses by the belt system can be transported an d stored in separate manure storage areas, applied directly to land, or compost ed. Manure-belt houses facilitate rapid drying of manure, which reduces the time avai lable in which biological activity in the manure can produce emissions of air contaminant s. A number of studies have shown that overall emissions of odorous compounds a nd ammonia from poultry houses using belt manure removal systems are much lower th an poultry houses using in-house pit storage of manure. It is conservatively assume d that manure-belt housing will reduce VOC emissions from poultry houses by 10%.

Cost of a Manure-Belt House

The cost estimate for manure-belt poultry housing i s based on information taken from the report “Economics of Controlling Ammonia Emission f rom Commercial Layer Farms” 15

(1998). This publication gives an initial capital cost estimate of $1.75 per bird and an annual maintenance cost of 3% of the initial capito l cost for conversion of an existing poultry house to a manure-belt house. Because the capitol cost estimate is 12 years old, this cost will be updated to 2010 dollars assuming a 3% annual inflation rate. The cost

estimate in 2010 dollars is calculated as follows:

2010 Capital Cost Estimate = $1.75/bird x 1.03 (2010-1998) = $2.495/bird

The capital cost and annual maintenance costs for c onverting an existing 20,000 bird house to a manure-belt house are given as follows:

Capitol Cost = 20,000 birds x $2.495/bird = $49,900

Annual Maintenance Costs = $49,900 x 0.03 = $1,497/ year

Annualized Capital Cost of a Manure-Belt House for 20,000 birds

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The cost for the initial co st of converting to a manure-belt house will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system w ill be estimated at 10 years. A 10%

15 van Horne P. L. M., Brake J., Williams, C. M., “E conomics of Controlling Ammonia Emission from Commercial Layer Farms”, Journal of Applied Poultr y Science 1998. 7:61-68 http://japr.fass.org/cgi/reprint/7/1/61.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-32 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 interest rate is assumed in the equation and the as sumption will be made that the equipment has no salvage value at the end of the te n-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost

P=Present Value I=Interest Rate (10%) N= Equipment Life (10 years)

Annualized Capital Cost Estimate = [$49,900 x 0.1(1 .1) 10 ]/[(1.1) 10 -1] = $8,121/year

Total Annual Cost Estimate

The total annualized capital costs and operating co sts for converting an existing poultry house for 20,000 birds to a manure-belt house are g iven below.

Total annual cost estimate = (total annualized capi tal cost) + (increased operating cost)

Total annual cost = ($8,121/yr) + ($1,497/yr) = $9, 618/year

VOC Emission Reductions for a Manure-Belt House for 20,000 birds

The annual VOC Emission Reductions for a manure-bel t poultry house for 20,000 birds

are calculated as follows:

[Number of Birds] x [Layer VOC EF (lb/bird-year)] x [Manure-Belt Control Efficiency]

= (20,000 bird/house) x (0.025 lb-VOC/bird-year) x (0.10) = 50 lb-VOC/house-year

Cost of VOC Emission Reductions

Cost Estimate =($9,618/year)/[(50 lb-VOC/year)(1 t on/2000 lb)]

= $384,720/ton of VOC reduced

As shown above, the costs for converting existing p oultry housing to manure-belt housing would cause the cost of the VOC reductions to be greater than $384,720/ton. This may not include the costs of additional energy required to run the belt and any associated drying equipment. The cost of the VOC e mission reductions achieved far exceeds the $17,500/ton cost effectiveness threshol d of the District BACT policy. Therefore, this option would not be required as BAC T and is beyond BARCT and any applicable RACT requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-33 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 B. Composting or Storing Manure Removed Animal Hous ing in an Aerated Static Pile (ASP) or Enclosure Vented to a Control Device

The costs associated with composting or storing the solid manure produced by livestock in an aerated static pile (ASP) vented to a control device or an enclosure vented to a control device are analyzed below. This practice i s only applicable to manure that is handled in solid form; therefore this analysis will evaluate this option only for dairy cattle, beef cattle, and poultry because these conf ined animal facilities can handle

manure in solid form. Manure from swine facilities must be handled as a liquid or slurry unless significant amounts of bedding are added to allow handling as a semi-solid. The cost of these options was previously evaluated in t he final staff report for District Rule 4565 - Biosolids, Animal Manure, and Poultry Litter Operations (May 30, 2007). The

relevant cost information will be taken from this s taff report. The staff report for District Rule 4565 found that use of ASPs and in-vessel comp osting would have unreasonably high costs for existing composting facilities that have a throughput of less than 100,000 wet tons per year. The vast majority of confined a nimal facilities produce much less manure than this; therefore, this option is not exp ected to be cost-effective for confined animal facilities. Although this option is not exp ected to be reasonably cost-effective, it

will be evaluated below.

Description of Control Technology

It may be possible to reduce emissions from solid m anure by using an ASP or enclosure to compost or store the solid manure. ASPs are use d in composting systems to speed up the compost process by forcing or drawing air th rough the material being composted. The material in an ASP is placed over perforated pi pes that are connected to a blower to draw air from the pile. The air that is drawn f rom the pile can be sent to a VOC control device to reduce emissions. Large composti ng facilities can also use in-vessel composting systems, in which the composting process occurs in a building or other

enclosure. The emissions from solid manure that is composted or stored in an

enclosure can also be sent to a VOC control device. A complete enclosure is more expensive than an ASP but results in higher capture efficiency for emissions.

As noted in the staff report for District Rule 4565 , biofilters are the most commonly used VOC emission control device at composting facilitie s. This is because biofilters are significantly less expensive than other options use d for the control of VOCs. A biofilter is a device for removing contaminants from a gas in which the gas is passed through a media that supports microbial activity by which pol lutants are degraded by biological oxidation. During biofiltration exhaust air contai ning pollutants passes through a media that contains an established, diverse population of aerobic microorganisms. These microorganisms oxidize the gaseous organic contamin ants, ammonia, and sulfur compounds in the exhaust air resulting in carbon di oxide, nitrogen, water, salt, and

biomass.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-34 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 It must be noted that although it may be possible t o reduce VOC emissions from solid manure using an ASP or enclosure vented to a biofil ter or other control device, recent studies at dairies and poultry facilities have indi cated that VOC emissions are very low from stored solid manure and poultry litter while o ther studies have indicated that large composting operations can have high VOC emissions i f they are not properly controlled. Therefore, if composting is performed additional mo nitoring of the composting system

and control device would be needed to ensure that V OC emissions are reduced compared to storage of solid manure.

Cost of an ASP or Enclosure vented to a Control Dev ice:

The following costs are taken from the final staff report for District Rule 4565 - Biosolids, Animal Manure, and Poultry Litter Operations (May 3 0, 2007). 16 The cost information is based on a large composting facility with a through put of 200,000 wet tons per year. On a per ton basis the costs for smaller composting fa cilities would be higher since there would not be the economies of scale for building an d operations created by large composting facilities.

Low Cost Scenario: ASP & Biofilter (200,000 wet to n/yr)

Total Capital Cost $7,775,000

Annualized capital cost (10% interest - 10 years) $1,265,345

Total Annual O & M Cost $124,305

Total Annualized Cost - ASP & Biofilter (Low-Estimate of Annual Costs) ($/yr/facility) $1,389,650

High Cost Scenario: In-Vessel and RTO (200,000 wet ton/yr)

Total Capital Cost $21,185,000

Annualized capital cost (10% interest - 10 years) $3,447,761

Total Annual O & M Cost $285,910

Total Annualized Cost - In-Vessel & RTO (High-Estimate of Annual Costs) ($/yr/facility) $3,733,671

As stated above, the final staff report for Distric t Rule 4565 stated that the use of ASPs and in-vessel composting would have unreasonably hi gh costs for facilities that have a throughput of less than 100,000 wet tons per year. The costs given above are for a

16 The capitol and operation costs for ASP and in-ves sel composting given in the final staff report were

taken from: United States Environmental Protection Agency, “Biosolids Technology Fact Sheet: Use of Composting for Biosolids Management” EPA 832-F-02-0 24, September 2002, http://water.epa.gov/scitech/wastetech/upload/2002_ 10_15_mtb_combioman.pdf . These costs were not adjusted for inflationSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-35 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 facility with a throughput of 200,000 wet tons per year. It will conservatively be assumed that the cost for a facility with a through put of 100,000 wet tons per year will be half of the values given above. Therefore, the cost estimates for a facility with a throughput of 100,000 is as follows:

Low Annual Capital Cost Estimate (100,000 wet ton/y r) = $1,389,650/yr x 0.5 = $694,825/year

High Annual Capital Cost Estimate (100,000 wet ton/ yr) = $3,733,671/yr x 0.5 = $1,866,836/year

C. ASP or In-Vessel Enclosure for Solid Cow Manure Removed from Housing

The cost of the emission reductions achieved by com posting or storing solid manure removed from dairy cow housing in an ASP or enclosu re vented to a control device are analyzed below. Because it has been determined tha t this practice would not be costeffective for a facility with a throughput of less than 100,000 tons per year, this analysis will be based on a dairy facility that can produce 100,000 tons of solid manure per year.

Number of Cows to Produce 100,000 ton/yr of Solid M anure

According to the United States Department of Agricu lture (USDA) Natural Resources Conservation Service (NRCS) Agricultural Waste Mana gement Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteris tics 17 (March 2008), dairy cows in scraped open corrals produce approximately 77 lb pe r day of solid manure that can be removed and transferred for storage or composting. The amount of solid manure removed for dairy cows housed in corrals or freesta ll barns with a flush system would be much less. The number of cows needed to produce 10 0,000 ton/year of solid manure is

calculated as follows:

(100,000 ton/year x 2,000 lb/ton) ÷ (77 lb/cow-day x 365 day/yr) = 7,116 cows

VOC Emission Reductions from an ASP or Enclosure Ha ndling Solid Manure from 7,116 Milk Cows:

The annual VOC Emission Reductions for ASP or in-ve ssel enclosure handling the solid manure from 7,116 milk cows are calculated as follo ws and shown in the table below:

[Number of cows] x [Solid Manure VOC EF (lb/cow-yea r)] x [ASP/In-Vessel Capture Efficiency] x [Control Device VOC Control Efficienc y]

17 United States Department of Agriculture (USDA) Nat ural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH ), http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-36 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 VOC Reductions for Solid Manure in ASP or In-Vessel Enclosure Vented to Control Device

Type of Animal # of

cows x Solid Manure

EF (lb/cow-yr) x Capture (%)* x Control

(%) = lb-VOC/yr

Milk Cow 7,116 x 0.15 x 50% x 85% = 454

* The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for compostin g facilities, which would result in lower emission re ductions.

Cost of VOC Emission Reductions

Low Estimate = ($694,825/year)/[(454 lb-VOC/year)(1 ton/2000 lb)]

= $3,060,903/ton of VOC reduced

High Estimate = ($1,866,836/year)/[(454 lb-VOC/yea r)(1 ton/2000 lb)]

= $8,223,947/ton of VOC reduced

As shown above, the cost an ASP or in-vessel enclos ure to handle the solid manure at a dairy would cause the cost of the VOC reductions to be greater than $3,060,903/ton. The excessively high costs of this option make it i mpractical for most confined animal

facilities.

D. ASP or In-Vessel Enclosure for Feedlot Cattle So lid Manure Removed from Housing

The cost of the emission reductions achieved by com posting or storing solid manure removed from feedlot cattle pens in an ASP or enclo sure vented to a control device are analyzed below. Because it has been determined tha t this practice would not be costeffective for a facility with a throughput of less than 100,000 tons per year, this analysis will be based on a feedlot facility that can produc e 100,000 tons of solid manure per

year.

Number of Feedlot Cattle to Produce 100,000 ton/yr of Solid Manure

According to the United States Department of Agricu lture (USDA) Natural Resources Conservation Service (NRCS) Agricultural Waste Mana gement Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteris tics 17 (March 2008), feedlot cattle in earthen lots produce approximately 17 lb per day of solid manure that can be removed and transferred for storage or composting. The number of feedlot cattle needed to produce 100,000 ton/year of solid manure is calculated as follows:

(100,000 ton/year x 2,000 lb/ton) ÷ (17 lb/head-day x 365 day/yr) = 32,232 headSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-37 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 VOC Emission Reductions from an ASP or Enclosure Ha ndling Solid Manure from 32,232 Feedlot Cattle:

The annual VOC Emission Reductions for ASP or in-ve ssel enclosure handling the solid manure from 32,232 feedlot cattle are calculated as follows and shown in the table

below:

[Number of Feedlot Cattle] x [Solid Manure VOC EF ( lb/head-year)] x [ASP/In-Vessel Capture Efficiency] x [Control Device VOC Control E fficiency]

VOC Reductions for Solid Manure in ASP or In-Vessel Enclosure Vented to Control Device

Type of Animal # of

head x Solid Manure EF

(lb/head-yr)* x Capture (%)** x Control

(%) = lb-VOC/yr

Feedlot Cattle 32,232 x 0.09 x 50% x 85% = 1,233

*Feedlot Cattle Solid manure EF estimated by scalin g down the draft Dairy solid manure EF of 0.15 lb/h dyr based on current dairy and feedlot cattle VOC em ission factors of 19.3 lb/hd-yr and 11.1 lb/hd-yr ** The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for compostin g facilities, which would result in lower emission re ductions.

Cost of VOC Emission Reductions

Low Estimate = ($694,825/year)/[(1,233 lb-VOC/year) (1 ton/2000 lb)]

= $1,127,048/ton of VOC reduced

High Estimate = ($1,866,836/year)/[(1,233 lb-VOC/y ear)(1 ton/2000 lb)]

= $3,028,120/ton of VOC reduced

As shown above, the cost an ASP or in-vessel enclos ure to handle the solid manure at

a feedlot would cause the cost of the VOC reduction s to be greater than $1,127,048/ton. The excessively high costs of this option make it i mpractical for most confined animal

facilities.

E. ASP or In-Vessel Enclosure for Litter/Solid Manu re Removed from Poultry Housing

The cost of the emission reductions achieved by com posting or storing litter/solid manure removed from poultry houses in an ASP or enc losure vented to a control device are analyzed below. Because it has been determined that this practice would not be cost-effective for a facility with a throughput of less than 100,000 tons per year, this analysis will be based on a broiler or turkey facil ity that can produce 100,000 tons of litter per year. However, it is thought that there are no single poultry facilities that are this large because of bio-security concerns and the impracticality of having such a large

number of birds at one location.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-38 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Number of Broilers or Turkeys to Produce 100,000 to n/yr of Litter

According to the United States Department of Agricu lture (USDA) Natural Resources Conservation Service (NRCS) Agricultural Waste Mana gement Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteris tics 17 (March 2008), the amount of litter removed from poultry houses that can be tran sferred for storage or composting is approximately 0.044 lb per day for broilers and app roximately 0.24 lb per day for turkeys. The number of broilers or turkeys needed to produce 100,000 ton/year of solid

manure is calculated as follows:

Broilers (100,000 ton/year x 2,000 lb/ton) ÷ (0.044 lb/bird- day x 365 day/yr) = 12,453,300 birds

Turkeys (100,000 ton/year x 2,000 lb/ton) ÷ (0.24 lb/bird-d ay x 365 day/yr) = 2,283,105 birds

As mentioned above, it is thought that there actual ly no poultry facilities with this number of broilers or turkeys at one location. The refore, this option is not expected to be cost effective for any poultry facilities. The cost effectiveness for any poultry facilities

that are this size is evaluated below.

VOC Emission Reductions from an ASP or Enclosure Ha ndling Litter/Solid Manure from 12,453,300 Broilers or 2,283,105 Turkeys:

The annual VOC Emission Reductions for ASP or in-ve ssel enclosure handling the litter/solid manure from 12,453,300 broilers or 2,2 83,105 turkeys are calculated as

follows and shown in the table below:

[Number of Birds] x [Solid Manure VOC EF (lb/bird-y ear)] x [ASP/In-Vessel Capture Efficiency] x [Control Device VOC Control Efficienc y]

VOC Reductions for Solid Manure in ASP or In-Vessel Enclosure Vented to Control Device

Type of

Animal # of Birds x Solid Manure EF (lb/bird-yr)* x Capture (%)** x Control

(%) = lb-VOC/yr

Broiler/Layer 12,453,300 x 0.0025 x 50% x 85% = 13,232

Turkey 2,283,105 x 0.01 x 50% x 85% = 9,703

* CARB source test results for California broiler h ouses indicated near negligible VOC emissions from

litter when birds were not in the house. 18 Based on the information from this study VOC emis sions from poultry litter/solid manure removed from the house are very conservatively estimated to be 10% of the total VOC emission factor for poultry. ** The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for compostin g facilities, which would result in lower emission re ductions.

18 “Quantification of Gaseous Emissions from Californ ia Broiler Production Houses” - Source tests on mechanically ventilated broiler houses during the s pring and fall of 2004. Participants included: AI Rx Testing; California Air Resources Board; California Department of Food and Agriculture; California Pou ltry Federation; Foster Farms; & University of Californi a, Davis. http://www.arb.ca.gov/ag/caf/poulemisrpt.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-39 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Cost of VOC Emission Reductions

Broilers/Layers Low Estimate = ($694,825/year)/[(13,232 lb-VOC/year )(1 ton/2000 lb)]

= $105,022/ton of VOC reduced

High Estimate = ($1,866,836/year)/[(13,232 lb-VOC/ year)(1 ton/2000 lb)]

= $282,170/ton of VOC reduced

Turkeys Low Estimate = ($694,825/year)/[(9,703 lb-VOC/year) (1 ton/2000 lb)]

= $143,219/ton of VOC reduced

High Estimate =($1,866,836/year)/[(9,703 lb-VOC/ye ar)(1 ton/2000 lb)]

= $384,796/ton of VOC reduced

As shown above, there are no known poultry faciliti es that are large enough for use of

ASP or in-vessel enclosure to handle the litter/sol id manure to be cost effective. If there were any such facilities the cost of the VOC reduct ions would be greater than $105,022/ton for broilers and greater than $143,219 /ton for turkeys. The excessively high costs of this option make it impractical for m ost confined animal facilities

F. Sending Solid Manure Removed from Animal Housing to a Digester with a

VOC Control Device

The costs associated with treating the solid manure produced by livestock in a digester vented to a control device are analyzed below. Thi s practice is only applicable to manure that is handled in solid form; therefore thi s cost analysis will evaluate this option only for dairy cattle, beef cattle, and poultry bec ause these confined animal facilities can

handle manure in solid form. Manure from swine fac ilities must be handled as a liquid or slurry unless significant amounts of bedding is added, which would preclude effective use of a digester. For solid manure, complete-mix and plug flow digesters can be used. Plug flow digesters are primarily used with cattle manure because the high solids

content and fibrous material in cattle manure allow s the manure to be effectively pushed through the digester. EPA’s AgSTAR anaerobic diges ter database lists a number of digesters utilizing dairy manure but only two diges ters using beef cattle manure and three using poultry manure. 19 This is because manure from beef cattle and broil ers is usually mixed with large amount of bedding or earth and cannot be easily collected and separated for use in a digester.

19 US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Digester Database (updated April 2010), http://www.epa.gov/agstar/operational.htmlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-40 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Description of Control Technology

An anaerobic digester is an enclosed basin or tank that is designed to facilitate the decomposition of wastewater by microbes in the abse nce of oxygen. The process of anaerobic decomposition results in the conversion o f organic compounds in the wastewater into methane (CH 4 ), carbon dioxide (CO 2 ), and water rather than intermediate Volatile Organic Compounds (VOCs). Th e gas generated by this process is known as biogas, waste gas, or digester gas. Bio gas may also include trace amounts of VOCs that remain from incomplete digestion of th e volatile solids in the incoming wastewater. The undigested solids that remain after digestion are removed from the digester as sludge. Because biogas is mostly compos ed of methane, the main component of natural gas, the gas produced in the d igester can be cleaned to remove

H 2 S and other impurities and used as fuel. The captur ed biogas can be combusted in a flare or may be sent to a boiler or engine, where t he gas can be used to generate useful heat or electrical energy.

As stated above, the gas generated from the solid m anure sent to an anaerobic digester can be captured and then sent to a suitable combust ion device. During combustion, gaseous hydrocarbons are oxidized to form CO 2 and water. For this analysis, the overall control efficiency is assumed to be 80% of the emissions that would have been emitted from the solid manure piles.

G. Digester for Solid Manure from Dairy Cows

The costs associated with treating the solid manure removed from milk cow housing in a plug flow digester vented to a control device are a nalyzed below. Because it may be possible to generate power from the system to offse t some of the costs associated with installation, this potential benefit is included in the analysis below. The following analysis is based on the treatment of solid manure from 1,000 milk cows in a plug flow digester with power generation.

Capital Cost for Installation of a Plug Flow Digest er for Dairy Cows

The capital cost estimates for installation of a pl ug flow digester are based on information from the United States EPA AgSTAR publication “Anae robic Digestion Capital Costs for Dairy Farms” (May 2010) 20 and the California Energy Commission (CEC) Public Interest Energy Research (PIER) Program Dairy Methane Digest er System Program Evaluation Report (Feb 2009) 21 . The formula in the AgSTAR publication results in a capitol cost of $$1,192 per cow for a plug flow anaerobic digester treating manure from 1,000 cows. This estimate excludes costs of solids separation a fter digestion, hydrogen sulfide

20 “Anaerobic Digestion Capital Costs for Dairy Farms ” (May 2010), EPA AgSTAR http://www.epa.gov/agstar/pdf/digester_cost_fs.pdf

21 “Dairy Power Production Program – Dairy Methane Sy stem Program Evaluation Report” (February 2009). Western United Resource Development, Inc pre pared for the California Energy Commission (CEC) Public Interest Energy Research Program. (CEC-500-2 009-009) http://www.energy.ca.gov/2009publications/CEC-500-2 009-009/CEC-500-2009-009.PDFSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-41 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 removal, and utility charges including line upgrade s and interconnection costs and fees.

Based on information from installations in Californ ia, the CEC PIER Dairy Methane Digester Program Evaluation Report gives an average cost of $1,042 per cow for installation of plug flow anaerobic digesters (see Table 9 - Total Project Costs and Cost per Cow and per kW). Therefore, for purposes of th is analysis the capital cost for installation of a plug flow digester system for 1,0 00 cows will be assumed to be between $1,042 and $1,192 per cow. The capital cost estima tes of a plug flow digester treating the manure of 1,000 milk cows are shown below:

Low capital cost estimate: $1,042/cow x 1,000 cows = $1,042,000 High capital cost estimate: $1,192/cow x 1,000 cows = $1,192,000

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The capital cost for the in stallation of the plug flow digester will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system will be esti mated at 10 years though the cover may require replacement during this period. A 10% interest rate is assumed in the equation and the assumption will be made that the e quipment has no salvage value at the end of the ten-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost

P=Present Value I=Interest Rate (10%) N= Equipment Life (10 years)

Low Annual Capital Cost Estimate = [$1,042,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $169,581/year

High Annual Capital Cost Estimate = [$1,192,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $193,993/year

Potential Production of Electricity from a Plug Flo w Digester Treating Solid Manure from 1,000 Milk Cows:

It may be possible to offset some of the installati on costs of an anaerobic digester with revenue from generation of electricity. Based on t he information given in the CEC PIER Dairy Methane Digester Program Evaluation Report, T able 7 – Actual Generation per Cow Comparisons, California dairies that used a plu g flow digester to produce electricity generated between 426.5 and 1,013.2 kW-hr/yr per la ctating cow with a overall per facility average generation rate of 632.8 kW-hr/yr per lactating cow. This average annual generation rate is actually higher than all the facilities included in the average except one that had a very high generation rate. I n addition, this average may overestimate the per-cow generation potential becau se the contributions of supportSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-42 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 stock to the digesters were not accounted for. How ever, for more conservative calculations, this average will be used to calculat e the potential annual savings in electricity costs. The potential production of elec tricity from a plug flow digester treating solid manure from 1,000 milk cows is calculated as follows:

Electrical Production: 632.8 kW-hr/(milk cow-yr) x 1,000 milk cows = 632,800 kW-hr/yr

Potential Cost Savings from Production of Electrici ty from a Plug Flow Digester Treating Solid Manure from 1,000 Milk Cows:

The value of the electricity generated will be base d upon the average price for industrial electricity in California for the year 2010, as tak en from the Energy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table 5_6_b.html )

Average Cost for electricity = $0.0999/kW-hr

The potential annual cost savings from electricity generation from a plug flow digester treating manure from 1,000 milk cows is calculated as follows:

Potential Annual Cost Savings from Electrical Produ ction: 632,800 kW-hr/yr x $0.0999/kW-hr = $63,217/yr

Annualized Capital Cost for a Plug Flow Digester Tr eating Solid Manure from 1,000 Milk Cows minus Potential Savings from Generation of Ele ctricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation = $169,581/yr - $63,217/yr = $106,364/year

High Annual Capital Cost Estimate minus Savings fro m Potential Generation = $193,993/yr - $63,217/yr = $130,776/year

VOC Emission Reductions from a Plug Flow Anaerobic Digester Treating Solid Manure from 1,000 Milk Cows:

The annual VOC Emission Reductions for plug flow an aerobic digester treating the solid manure from 1,000 milk cows are calculated as follo ws and shown in the table below:

[Number of cows] x [Solid Manure VOC EF (lb/cow-yea r)] x [Digester Control Efficiency for Solid Manure]

VOC Reductions for a Digester for Solid Manure Vent ed to Control Device

Type of Cow # of

cows x Solid Manure EF

(lb/cow-yr) x Control (%) = lb-VOC/yr

Milk Cow (freestall) 1,000 x 0.15 x 80% = 120SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-43 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Cost of VOC Emission Reductions

Low Estimate = ($106,364/year)/[(120 lb-VOC/year)(1 ton/2000 lb)]

= $1,772,733/ton of VOC reduced

High Estimate = ($130,776/year)/[(120 lb-VOC/year) (1 ton/2000 lb)]

= $2,179,600/ton of VOC reduced

As shown above, the capital cost alone for a digest er to treat the solid manure at a dairy would cause the cost of the VOC reductions to be gr eater than $1,772,733/ton. This cost includes the potential revenue generated by el ectrical production but does not include the additional maintenance required for the system. Even without these costs,

the cost of the VOC emission reductions achieved ex ceed the $17,500/ton cost effectiveness threshold of the District BACT policy . Therefore, this option would not be required as BACT and is beyond BARCT and any applic able RACT requirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, wh ich may offset any reductions in

VOCs.

H. Digester for Solid Manure from Feedlot Cattle

The costs associated with treating the solid manure removed from feedlot cattle housing in a plug flow digester vented to a control device are analyzed below. Because it may be possible to generate power from the system to of fset some of the costs associated with installation, this potential benefit is includ ed in the analysis below. The following analysis is based on the treatment of solid manure from 3,500 feedlot cattle in a plug flow digester with power generation.

Capital Cost for Installation of a Plug flow Digest er for Feedlot Cattle

On an animal weight basis, the capital cost estimat es for installation of a plug flow digester

for beef feedlot cattle are assumed to be the same as the costs for installation of a plug flow digester at a dairy. Based on the information given above, the capital cost of installation of a plug flow digester at a dairy is between $1,042 and $1,192 per cow. A typical milk cow weighs approximately 1,400 lb and the average weight of feedlot steers is assumed to be 950 lb. The estimated capital cost o f a plug flow digester for beef feedlot cattle is estimated by adjusting by weight as follo ws:

Low capital cost estimate: $1,042/cow x 950 lb/head /(1,400 lb/cow) = $707/head High capital cost estimate: $1,192/cow x 950 lb/hea d/(1,400 lb/cow) = $809/head

The estimated capital cost of a plug flow digester treating the solid manure from 3,500 finishing steers is calculated as follows:

Low capital cost estimate: 3,500 head x $707/head = $2,474,500 High capital cost estimate: 3,500 head x $809/head = $2,831,500SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-44 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The capital cost for the in stallation of the plug flow digester will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system will be esti mated at 10 years though the cover may require replacement during this period. A 10% interest rate is assumed in the equation and the assumption will be made that the e quipment has no salvage value at the end of the ten-year cycle.

A=[P x I(I+1) n ]/[(I+1) n -1]

Where:

A=Annual Cost

P=Present Value I=Interest Rate (10%) N= Equipment Life (10 years)

Low Annual Capital Cost Estimate = [$2,474,500 x 0 .1(1.1) 10 ]/[(1.1) 10 -1]

= $402,713/year

High Annual Capital Cost Estimate = [$2,831,500 x 0.1(1.1) 10 ]/[(1.1) 10 -1]

= $460,814/year

Potential Production of Electricity from a Plug flo w Digester Treating Solid Manure from 3,500 Beef Feedlot Cattle:

It may be possible to offset some of the installati on costs of a plug flow anaerobic digester with revenue from generation of electricit y. Production of electricity from digester gas from feedlot cattle manure has not bee n common because of the difficulty in collecting fresh manure for a digester. Because there is limited information available regarding production of electricity from digester g as from feedlot cattle manure, the potential for production of electricity will be est imated based on the information given above for production of electricity from plug flow digesters at dairy facilities. It will be assumed that the potential for production of digest er gas and electricity from dairy cows and beef cattle will be proportional to the amount of volatile solids excreted in the manure. According to the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Ch aracteristics 22 (March 2008), a lactating dairy cow excretes an average of approxim ately 17 lb/day of volatile solids and feedlot cattle excrete an average of approximately 9.35 lb/day of volatile solids per 1,000-lb AU. Based on the information given above, a plug flow anaerobic digester at a dairy is estimated to produce 670.3 kW-hr per milk cow per year. Assuming that the amount of electricity produced is proportional to t he amount of volatile solids sent to the

22 United States Department of Agriculture (USDA) Nat ural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH ), http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-45 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 plug flow, the potential for electricity generation by a plug flow anaerobic digester at a beef cattle facility is estimated as follows:

(0.95 AU/head x 9.35 lb VS/AU)/(17 lb-VS/milk cow) x 632.8 kW-hr/(milk cow-yr) = 330.6 kW-hr/(head-yr)

The potential production of electricity from a plug flow digester treating solid manure from 3,500 beef feedlot cattle is calculated as follows:

Electrical Production: 330.6 kW-hr/(head-yr) x 3,50 0 head = 1,157,100 kW-hr/yr

Potential Cost Savings from Production of Electrici ty from a Plug Flow Digester Treating Solid Manure from 3,500 Feedlot Cattle:

The value of the electricity generated will be base d upon the average price for industrial electricity in California for the year 2010, as tak en from the Energy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table 5_6_b.html )

Average Cost for electricity = $0.0999/kW-hr

The potential annual cost savings from electricity generation from a plug flow digester treating manure from 3,500 feedlot cattle is calcul ated as follows:

Potential Annual Cost Savings from Electrical Produ ction: 1,157,100 kW-hr/yr x $0.0999/kW-hr = $115,594/yr

Annualized Capital Cost for a Plug flow Digester Tr eating Solid Manure from 3,500 Feedlot Cattle minus Potential Savings from Generat ion of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation = $402,713/yr

- $115,594/yr = $287,119/year

High Annual Capital Cost Estimate minus Savings fro m Potential Generation = $460,814/yr - $115,594/yr = $345,220/year

VOC Emission Reductions from a Plug flow Anaerobic Digester Treating Solid Manure from 3,500 Feedlot Cattle:

The annual VOC Emission Reductions for plug flow an aerobic digester treating the manure from 3,500 feedlot cattle are calculated as follows and shown in the table

below:

[Number of Feedlot Cattle] x [Solid Manure VOC EF ( lb/cow-year)] x [Digester Control Efficiency for Solid Manure]SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-46 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 VOC Reductions for a Plug Flow Digester Vented to C ontrol Device

Type of Animal # of

head x Solid Manure EF

(lb/head-yr) x Control (%) = lb-VOC/yr

Feedlot Cattle 3,500 x 0.09 x 80% = 252

* Based on scaling down draft dairy emission factor for solid manure using current dairy and feedlot cattle VOC emission factors of 19.3 lb/hd-yr and 11 .1 lb/hd-yr

Cost of VOC Emission Reductions

Low Estimate = ($287,119/year)/[(252 lb-VOC/year)(1 ton/2000 lb)]

= $2,278,722/ton of VOC reduced

High Estimate = ($345,220/year)/[(252 lb-VOC/year) (1 ton/2000 lb)]

= $2,739,841/ton of VOC reduced

As shown above, the capital cost alone for a digest er to treat the solid manure at a beef

feedlot would cause the cost of the VOC reductions to be greater than $2,278,722/ton. This cost includes the potential revenue generated by electrical production but does not include the additional maintenance required for the system. Even without these costs,

the cost of the VOC emission reductions achieved ex ceed the $17,500/ton cost effectiveness threshold of the District BACT policy . Therefore, this option would not be required as BACT and is beyond BARCT and any applic able RACT requirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, wh ich may offset any reductions in

VOCs.

I. Digester for Solid Manure from Poultry

Although treating the manure excreted by poultry in a digester is not a common practice 23 , the costs associated with treating the solid manu re excreted by laying hens in a digester are analyzed below. Because it may b e possible to generate power from the system to offset some of the costs associated w ith installation, this potential benefit is included in the analysis below. The following a nalysis is based on the treatment of manure from 500,000 laying hens in an anaerobic dig ester with power generation.

Capital Cost for Installation of a Digester for Pou ltry Solid Manure

On an animal weight basis, the capital cost estimat es for installation of a digester treating solid manure from poultry are assumed to be the sam e as the costs for installation of a plug flow digester at a dairy. Based on the inform ation given above, the capital cost of installation of a plug flow digester at a dairy is between $1,042 and $1,192 per cow. A typical milk cow weighs approximately 1,400 lb and the average weight of a laying hen is

23 The US EPA AgSTAR Program Guide to Anaerobic Diges ters – Anaerobic Digester Database (updated April 2010) lists only three poultry digesters, http://www.epa.gov/agstar/operational.htmlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-47 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 assumed to be 4 lb. The estimated capital cost of a digester for solid poultry manure is estimated by adjusting by weight as follows:

Low capital cost estimate: $1,042/cow x 4 lb/bird/( 1,400 lb/cow) = $2.98/bird High capital cost estimate: $1,192/cow x 4 lb/bird/ (1,400 lb/cow) = $3.41/bird

The estimated capital cost of a plug flow digester treating the solid manure from 500,000 laying hens is calculated as follows:

Low capital cost estimate: 500,000 birds x $2.98/bi rd = $1,490,000 High capital cost estimate: 500,000 birds x $3.41/b ird = $1,705,000

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The capital cost for the in stallation of the digester will be spread over the expected life of the system using t he capital recovery equation. The expected life of the entire system will be estimate d at 10 years though the cover may require replacement during this period. A 10% inte rest rate is assumed in the equation and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

Low Annual Capital Cost Estimate = [$1,490,000 x 0 .1(1.1) 10 ]/[(1.1) 10 -1]

= $242,491/year

High Annual Capital Cost Estimate = [$1,705,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1]

= $277,481/year

Potential Production of Electricity from an Anaerob ic Digester Treating Solid Manure from 500,000 Laying Hens:

It may be possible to offset some of the installati on costs of an anaerobic digester with revenue from generation of electricity. Because on ly a very small number of digesters have been installed at poultry facilities and there is limited information available regarding production of electricity from digester g as from poultry manure, the potential for production of electricity will be estimated bas ed on the information given above for production of electricity from plug-flow digesters at dairy facilities. It will be assumed that the potential for production of digester gas a nd electricity from dairy cows and poultry will be proportional to the amount of volat ile solids excreted in the manure. According to the USDA NRCS Agricultural Waste Manag ement Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteris tics 22 (March 2008), a lactating dairy cow excretes an average of approximately 17 l b/day of volatile solids and a laying hen excretes approximately 0.036 lb/day of volatile solids. Based on the information given above, an anaerobic digester treating solid m anure at a dairy is estimated to produce 632.8 kW-hr per milk cow per year. Assumin g that the amount of electricity produced is proportional to the amount of volatile solids sent to the plug flow, the potential for electricity generation by an anaerobi c digester for solid manure at a poultry facility is estimated as follows:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-48 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 (0.036 lb-VS/bird)/(17 lb-VS/milk cow) x 632.8 kW-h r/(milk cow-yr) = 1.34 kWhr/(bird-yr)

The potential production of electricity from a dige ster treating solid manure from 500,000 laying hens is calculated as follows:

Electrical Production: 1.34 kW-hr/(bird-yr) x 500,0 00 birds = 670,000 kW-hr/yr

Potential Cost Savings from Production of Electrici ty from a Digester Treating Solid Manure from 500,000 Laying Hens:

The value of the electricity generated will be base d upon the average price for industrial electricity in California for the year 2010, as tak en from the Energy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table 5_6_b.html )

Average Cost for electricity = $0.0999/kW-hr

The potential annual cost savings from electricity generation from a digester treating solid manure from 500,000 laying hens is calculated as follows:

Potential Annual Cost Savings from Electrical Produ ction: 670,000 kW-hr/yr x $0.0999/kW-hr = $66,933/yr

Annualized Capital Cost for a Digester Treating Sol id Manure from 500,000 Birds minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation = $242,491//yr - $66,933/yr = $175,558/year

High Annual Capital Cost Estimate minus Savings fro m Potential Generation = $277,481/yr - $66,933/yr = $210,548/year

VOC Emission Reductions from an Anaerobic Digester Treating Solid Manure from
500,000 Birds:

The annual VOC Emission Reductions for an anaerobic digester treating the solid manure from 500,000 birds are calculated as follows and shown in the table below:

[Number of Birds] x [Solid Manure VOC EF (lb/cow-ye ar)] x [Digester Control Efficiency for Solid Manure]

VOC Reductions for a Digester for Solid Manure Vent ed to Control Device

Animal # of Birds x Lagoon EF (lb/Bird-yr)* x Control (%) = lb-VOC/yr

Laying Hens 500,000 x 0.0025 x 80% = 1,000SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-49 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 * CARB source test results for California broiler h ouses indicated near negligible VOC emissions from

litter when birds were not in the house. 24 Based on the information from this study VOC emis sions from poultry litter/solid manure removed from the h ouse are very conservatively estimated to be 10% of the total VOC emission factor for poultry.

Cost of VOC Emission Reductions

Low Estimate = ($175,558/year)/[(1,000 lb-VOC/year) (1 ton/2000 lb)]

= $351,116/ton of VOC reduced

High Estimate =($210,548/year)/[(1,000 lb-VOC/year )(1 ton/2000 lb)]

= $421,096/ton of VOC reduced

As shown above, the capital cost alone for an anaer obic digester for solid manure from poultry would cause the cost of the VOC reductions to be greater than $351,116/ton. This cost includes the potential revenue generated by electrical production but does not include the additional maintenance required for the system. Even without these costs,

the cost of the VOC emission reductions achieved ex ceed the $17,500/ton cost effectiveness threshold of the District BACT policy . Therefore, this option would not be required as BACT and is beyond BARCT and any applic able RACT requirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, wh ich may offset any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substant ial subsidies to offset the extremely high costs of installation.

J. Aerobic Treatment Lagoon or a Mechanically Aerat ed to Treat Manure Liquid Manure Produced by Livestock

The feasibility of treating the manure produced by livestock in an aerobic lagoon is evaluated below. This practice is only applicable to manure that is handled in liquid form; therefore this option will only be evaluated for dairy cattle, swine, and layers because these confined animal facilities frequently handle manure in liquid form, whereas feedlot cattle, broilers and turkeys almost exclusively handle manure or litter as a solid. As defined in the current and proposed ve rsions of District Rule 4570, an aerobic lagoon is “ a lagoon designed, constructed, maintained, and ope rated in accordance with the applicable standards for aerobi c lagoons in the Natural Resource Conservation Service (NRCS) California Field Office Technical Guide Conservation Practice Standard Code 359 or other applicable stan dards approved by the APCO, ARB, and EPA. ” NRCS Practice Standard Code 359 contains criteria for both naturally aerobic lagoons and mechanically aerated lagoons. Because it is clear that the very large land requirements to treat the manure from co nfined animal facilities subject to

24 “Quantification of Gaseous Emissions from Californ ia Broiler Production Houses” - Source tests on mechanically ventilated broiler houses during the s pring and fall of 2004. Participants included: AI Rx Testing; California Air Resources Board; California Department of Food and Agriculture; California Pou ltry Federation; Foster Farms; & University of Californi a, Davis. http://www.arb.ca.gov/ag/caf/poulemisrpt.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-50 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 this rule in a naturally aerobic lagoon are beyond what could reasonably be required, a complete cost analysis will not performed for this option. However, a complete cost analysis will be performed for a mechanically aerat ed lagoon.

Description of Control Technology

An aerobic lagoon is a waste treatment lagoon that is designed to facilitate the decomposition of wastewater by microbes in the pres ence of oxygen (O 2 ). The process of aerobic decomposition results in the conversion of organic compounds in the wastewater into carbon dioxide (CO 2 ), and (H 2 O), nitrates, sulfates, and inert biomass (sludge). The process of aerobic digestion is some times referred to as nitrification (especially when discussing NH 3 transformation). Complete aerobic digestion (100% aeration) removes nearly all malodors and also virt ually eliminates VOCs, H 2 S, and NH 3 emissions from liquid waste.

In completely aerated lagoons sufficient oxygen mus t be provided to sustain the aerobic microorganisms. NRCS Practice Standard Code 359 sp ecifies that naturally aerobic lagoons have a minimum surface area determined by r egional climate and daily Biological Oxygen Demand (BOD 5 ) and requires the depth of naturally aerobic lagoo ns have a maximum depth no greater than five feet. Fo r mechanically aerated lagoons NRCS Practice Standard Code 359 specifies that the aeration equipment shall provide a minimum of 1 pound of oxygen for each pound of da ily BOD 5 loading. The mechanical aerators that provide the required oxyge n may float on the lagoon surface or be submerged in the lagoon. Aeration can also be p erformed by injection of tiny air bubbles into the lagoon water, mixing of the lagoon water, or spraying of the water into the air. According to Dr. Ruihong Zhang, a research er at the University of California, Davis, at least 95% VOC control can be achieved if the dissolved oxygen (DO) concentration of the liquid manure is 2.0 mg/L or m ore. However, the DO concentrations achieved in mechanically aerated lag oons treating manure are typically

much less than this and will therefore have lower c ontrol efficiencies. A major disadvantage of completely aerated lagoons is the e normous cost of the energy required to run the aerators continuously. Because of this, it has generally been determined that completely aerated lagoons are not cost effective options for confined animal facilities at the present time.

K. Aerobic Lagoon Treating Liquid Manure from Dairy Cows

The following analyses are based on the treatment o f manure from 1,000 milk cows in naturally aerobic lagoons and mechanically aerated lagoons.

Space Requirement for a Naturally Aerobic Lagoon Tr eating Manure from 1,000 Dairy

Cows

The following brief analysis will demonstrate that the very large land requirements needed to treat the manure from dairies subject to this rule in a naturally aerobic lagoon would be beyond what could reasonably be required. Therefore, there is no need toSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-51 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 perform a detailed analysis that would consider all of the additional costs, such as the costs of purchasing additional land, constructing a nd lining the lagoon(s), and additional costs for control of mosquito larvae.

NRCS Practice Standard Code 359 requires that natur ally aerobic lagoons be designed

to have a minimum treatment surface area as determi ned on the basis of daily BOD 5 loading per unit of lagoon surface. The standard s pecifies that the maximum loading rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the NRCS Agricultural Waste Management Field Handbook ( AWMFH) 25 or the maximum loading rate according to state regulatory requirem ents, whichever is more stringent. According to Figure 10-30 (August 2009) of the late st version of the AWMFH, the maximum aerobic lagoon loading rate for the San Joa quin Valley is 45 - 55 lbBOD 5 /acre-day. According to Table 4-5 (March 2008) of the NRCS AWMFH, the total daily manure produced by a milk cow will have 2.9 l b-BOD 5 /day. Assuming that 80% of the manure will be flushed to the lagoon system, th e minimum lagoon surface area required for a naturally aerobic lagoon treating ma nure from 1,000 milk cows in the San Joaquin Valley can be calculated as follows:

BOD 5 loading (lb/day) = 1,000 milk cows x 2.9 lb-BOD 5 /cow-day x 0.80 = 2,320 lb-BOD 5 /day

Minimum Surface (acres) in areas with a maximum loa ding rate of 55 lb-BOD 5 /acreday = 2,320 lb-BOD 5 /day ÷ 55 lb-BOD 5 /acre-day = 42.2 acres

Minimum Surface (acres) in areas with a maximum loa ding rate of 45 lb-BOD 5 /acreday = 2,320 lb-BOD 5 /day ÷ 45 lb-BOD 5 /acre-day = 51.6 acres

As shown above the minimum surface area required fo r a naturally aerobic lagoon treating manure from 1,000 milk cows in the San Joa quin Valley would range from approximately 42.2 to 51.6 acres. This does not in clude the additional surface area that would be required to treat manure from support stoc k onsite. Based on the space requirements alone it is clear that this option can not reasonably be required and no further analysis is needed.

Analysis for a Mechanically Aerated Lagoon Treating Manure from 1,000 Dairy Cows

As discussed above, the very large space requiremen ts for naturally aerobic lagoons cause this option to be infeasible for most confine d animal facilities. Mechanically aerating a lagoon can achieve some of the benefits of a naturally aerobic lagoon without the large space requirements. However, the costs o f energy for complete aeration have also caused this option to be infeasible. The amou nt of energy required for aeration is based on the amount of volatile solids excreted by animals that must be treated; thus,

25 United States Department of Agriculture (USDA) Nat ural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH ), http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-52 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 this cost will be directly proportional to the numb er of animals at a site. The following analysis will determine the cost of emission reduct ions that can be achieved from a mechanically aerated lagoon treating manure from 1, 000 milk cows.

Biological Oxygen Demand (BOD 5 )

In order to effectively calculate the costs of this control option, the energy requirement for complete aeration must be determined. It should be noted that approximately 1.5 to 2.5 pounds of oxygen is required to digest 1 pound of Biological Oxygen Demand (BOD 5 ) with additional oxygen required for conversion of ammonia to nitrate (nitrification). 26 It is generally accepted that at least twice the B OD should be provided for complete aeration. 27 According to Dr. Ruihong Zhang of the University of California, Davis, 2.4 lbs (1.1 kg) of oxygen (O 2 ) per cow must be provided each day for removal of BOD and an additional 3 lbs (1.4 kg) per cow for ox idation of 70% of the nitrogen. 28

The proposed rule specifies that an aerobic lagoon be designed and operated in

accordance with NRCS Practice Standard Code 359. N RCS Practice Standard Code 359 requires that mechanically aerated lagoons use aeration equipment that provides a minimum of one pound of oxygen for each pound of da ily BOD 5 loading. As discussed above, the total daily manure produced by a milk co w will have a BOD 5 of 2.9 lb/day and a lagoon handling flushed manure from 1,000 mil k cows will have a loading rate of approximately 2,320 lb-BOD 5 /day (1,052 kg-BOD 5 /day).

Energy Requirement a Mechanically Aerated Lagoon Tr eating Manure from 1,000 Milk

cows:

Based on the data gathered in a UC Davis study on a erator performance for wastewater lagoons, aeration efficiencies for mechanical aerat ors ranged from 0.10 to 0.68 kg of oxygen provided per kW-hr of energy utilized. 29 The most efficient aerator tested that had been installed in dairy lagoons had an aeration efficiency of 0.49 kg-O 2 /kW-hr. These efficiency tests were performed in clean wate r and lower aeration efficiencies are expected in liquid manure because of the significan t amount of solids that it contains. The yearly energy requirement mechanically aerated lagoon treating flushed manure from 1,000 milk cows is calculated as follows:

High Efficiency Aerator 1,052 kg-BOD 5 /day ÷ (0.68 kg-O 2 /kW-hr) x (365 day/year) = 564,676 kW-hr/year

Low Efficiency Aerator

26 An Assessment of Technologies for Management and T reatment of Dairy Manure in California’s San Joaquin Valley, December 2005, page 34 ( http://www.arb.ca.gov/ag/caf/dairypnl/dmtfaprprt.pd f )

27 See http://www.extension.org/faq/27574 and http://www.omafra.gov.on.ca/english/engineer/facts/ 04-

033.htm

28 An Assessment of Technologies for Management and T reatment of Dairy Manure in California’s San Joaquin Valley, December 2005, page 35 ( http://www.arb.ca.gov/ag/caf/dairypnl/dmtfaprprt.pd f )

29 Aerator Performance for Wastewater Lagoon Applicat ion, September 2007, UC Davis, R.H. Zhang ( http://asae.frymulti.com/abstract.asp?aid=23832&t=2 )SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-53 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 1,052 kg-BOD 5 /day ÷ (0.10 kg-O 2 /kW-hr) x (365 day/year) = 3,839,800kW-hr/year

Cost of Electricity for a Mechanically Aerated Lago on Treating Manure from 1,000 Milk

cows:

The cost for electricity will be based upon the ave rage price for industrial electricity in California for the year 2010, as taken from the Ene rgy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/ epm/table5_6_b.html )

Average Cost for electricity = $0.0999/kW-hr

The electricity costs for complete aeration are cal culated as follows:

Low Cost Estimate (High Efficiency Aerator) 564,676 kW-hr/year x $0.0999/kW-hr = $56,411/year

High Cost Estimate (Low Efficiency Aerator) 3,839,800 kW-hr/year x $0.0999/kW-hr = $383,596/yea r

VOC Emission Reductions from a Mechanically Aerated Lagoon Treating Manure from 1,000 Milk Cows:

It will be conservatively assumed that a mechanical ly aerated lagoon providing 1 lb of oxygen for every 1 lb of BOD 5 loading will control 90% of the VOC emissions from the lagoon/storage pond. However, as noted above, it i s generally accepted that the oxygen provided should be twice the BOD 5 loading rate for complete aeration; therefore, the actual control from providing 1 lb o f oxygen for every 1 lb of BOD 5 loading is probably closer to 50%.

The annual VOC Emission Reductions for mechanically aerated lagoon treating the manure from 1,000 milk cows are calculated as follo ws and shown in the table below:

[Number of cows] x [Lagoon/Storage Pond VOC EF (lb/ cow-year)] x [Complete Aeration Control Efficiency for Lagoon/Storage Pond]

VOC Reductions for a Mechanically Aerated Lagoon

Type of Animal # of

cows x Lagoon EF

(lb/cow-yr) x Control

(%) = lb-VOC/yr

Milk Cow (freestall) 1,000 x 1.3 x 90% = 1,170

Cost of VOC Emission Reductions

Low Estimate = ($56,411/year)/[(1,170 lb-VOC/year)( 1 ton/2000 lb)]

= $96,429/ton of VOC reduced

High Estimate =($383,596/year)/[(1,170 lb-VOC/year )(1 ton/2000 lb)]

= $655,720/ton of VOC reducedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-54 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 As shown above, the electricity cost alone for a me chanically aerated lagoon would cause the cost of the VOC reductions to be greater than $96,429/ton. This cost does not include the additional electricity cost for nit rification that would naturally occur as the lagoons were aerated or equipment costs. Even with out this cost, the cost of the VOC emission reductions achieved exceed the $17,500/ton cost effectiveness threshold of the District BACT policy. Therefore, this option w ould not be required as BACT and is beyond BARCT and any applicable RACT requirements.

L. Aerobic Lagoon Treating Liquid Manure from Swine

The following analyses are based on the treatment o f manure from 3,000 finishing swine in naturally aerobic lagoons and mechanically aerated lagoons.

Space Requirement for a Naturally Aerobic Lagoon Tr eating Manure from 3,000 Finishing Swine

The following brief analysis will demonstrate that the very large land requirements

needed to treat the manure from swine facilities su bject to this rule in a naturally aerobic lagoon would be beyond what could reasonably be req uired. Therefore, there is no need to perform a detailed analysis that would cons ider all of the additional costs, such as the costs of purchasing additional land, constru cting and lining the lagoon(s), and additional costs for control of mosquito larvae.

NRCS Practice Standard Code 359 requires that natur ally aerobic lagoons be designed

to have a minimum treatment surface area as determi ned on the basis of daily BOD 5 loading per unit of lagoon surface. The standard s pecifies that the maximum loading rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the NRCS Agricultural Waste Management Field Handbook ( AWMFH) 25 or the maximum loading rate according to state regulatory requirem ents, whichever is more stringent. According to Figure 10-30 (August 2009) of the late st version of the AWMFH, the maximum aerobic lagoon lading rate for the San Joaq uin Valley is 45 - 55 lb-BOD 5 /acreday. According to Table 4-5 (March 2008) of the NR CS AWMFH, finishing swine produce approximately 2.1 lb-BOD 5 /day per 1,000 lb Animal Unit (AU). It will be assumed that the average weight of finishing swine is 150 lb (0.15 AU) and that 100% of the manure will be flushed to the lagoon system. The minimum lagoon surface area required for a naturally aerobic lagoon treating ma nure from 3,000 finishing swine in the San Joaquin Valley can be calculated as follows:

BOD 5 loading (lb/day) = 3,000 head x 0.15 AU/head x 2.1 lb-BOD 5 /AU-day x 1.00 =

= 945 lb-BOD 5 /day

Minimum Surface (acres) in areas with a maximum loa ding rate of 55 lb-BOD 5 /acreday = 945 lb-BOD 5 /day ÷ 55 lb-BOD 5 /acre-day = 17.2 acres

Minimum Surface (acres) in areas with a maximum loa ding rate of 45 lb-BOD 5 /acreday = 945 lb-BOD 5 /day ÷ 45 lb-BOD 5 /acre-day = 21.0 acresSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-55 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 As shown above the minimum surface area required fo r a naturally aerobic lagoon treating manure from 3,000 finishing swine in the S an Joaquin Valley would range from approximately 17.2 to 21.0 acres. Based on the spa ce requirements alone it is clear that this option is cannot reasonably be required a nd no further analysis is needed.

Analysis for a Mechanically Aerated Lagoon Treating Manure from 3,000 Finishing

Swine

As discussed above, the very large space requiremen ts for naturally aerobic lagoons cause this option to be infeasible for most confine d animal facilities. Mechanically aerating a lagoon can achieve some of the benefits of a naturally aerobic lagoon without the large space requirements. However, the costs o f energy for complete aeration have also caused this option to be infeasible. The amou nt of energy required for aeration is based on the amount of volatile solids excreted by animals that must be treated; thus, this cost will be directly proportional to the numb er of animals at a site. The following analysis will determine the cost of emission reduct ions that can be achieved from a mechanically aerated lagoon treating manure from 3, 000 finishing swine.

Biological Oxygen Demand (BOD 5 )

In order to effectively calculate the costs of this control option, the energy requirement for complete aeration must be determined. It should be noted that approximately 1.5 to 2.5 pounds of oxygen is required to digest 1 pound of Biological Oxygen Demand (BOD 5 ) with additional oxygen required for conversion of ammonia to nitrate (nitrification). 26 It is generally accepted that at least twice the B OD should be provided for complete aeration. 27 Additional oxygen would need to be provided for n itrification.

The proposed rule specifies that an aerobic lagoon be designed and operated in

accordance with NRCS Practice Standard Code 359. N RCS Practice Standard Code 359 requires that mechanically aerated lagoons use aeration equipment that provides a minimum of one pound of oxygen for each pound of da ily BOD 5 loading. As discussed above, a lagoon handling flushed manure from 3,000 finishing swine will have a loading rate of approximately 945 lb-BOD 5 /day (429 kg-BOD 5 /day).

Energy Requirement a Mechanically Aerated Lagoon Tr eating Manure from 3,000 Finishing Swine

Based on the data gathered in a UC Davis study on a erator performance for wastewater lagoons, aeration efficiencies for mechanical aerat ors ranged from 0.10 to 0.68 kg of oxygen provided per kW-hr of energy utilized. 29 The most efficient aerator tested that had been installed in dairy lagoons had an aeration efficiency of 0.49 kg-O 2 /kW-hr. These efficiency tests were performed in clean wate r and lower aeration efficiencies are expected in liquid manure because of the significan t amount of solids that it contains. The yearly energy requirement mechanically aerated lagoon treating flushed manure from 3,000 finishing swine is calculated as follows :SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-56 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 High Efficiency Aerator 429 kg-BOD 5 /day ÷ (0.68 kg-O 2 /kW-hr) x (365 day/year) = 230,272 kW-hr/year

Low Efficiency Aerator 429 kg-BOD 5 /day ÷ (0.10 kg-O 2 /kW-hr) x (365 day/year) = 1,565,850 kW-hr/year

Cost of Electricity for a Mechanically Aerated Lago on Treating Manure from 3,000 Finishing Swine:

The cost for electricity will be based upon the ave rage price for industrial electricity in California for the year 2010, as taken from the Ene rgy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/ epm/table5_6_b.html ).

Average Cost for electricity = $0.0999/kW-hr

The electricity costs for complete aeration are cal culated as follows:

Low Cost Estimate (High Efficiency Aerator) 230,272 kW-hr/year x $0.0999/kW-hr = $23,004/year

High Cost Estimate (Low Efficiency Aerator) 1,565,850 kW-hr/year x $0.0999/kW-hr = $156,428/yea r

VOC Emission Reductions from a Mechanically Aerated Lagoon Treating Manure from 3,000 Finishing Swine:

It will be conservatively assumed that a mechanical ly aerated lagoon providing 1 lb of oxygen for every 1 lb of BOD 5 loading will control 90% of the VOC emissions from the lagoon/storage pond. However, as noted above, it i s generally accepted that the oxygen provided should be twice the BOD 5 loading rate for complete aeration; therefore, the actual control from providing 1 lb o f oxygen for every 1 lb of BOD 5 loading is probably closer to 50%.

The annual VOC Emission Reductions for mechanically aerated lagoon treating the manure from 3,000 finishing swine are calculated as follows and shown in the table

below:

[Number of Head] x [Lagoon/Storage Pond VOC EF (lb/ head-year)] x [Complete Aeration Control Efficiency for Lagoon/Storage Pond ]

VOC Reductions for a Mechanically Aerated Lagoon

Type of Animal # of

Head x Lagoon EF

(lb/head-yr)* x Control (%) = lb-VOC/yr

Finishing Swine 3,000 x 0.4 x 90% = 1,080SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-57 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 * Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from housing barns and 9% of VOC emissions are assumed t o be from lagoons 30

Cost of VOC Emission Reductions

Low Estimate = ($23,004/year)/[(1,080 lb-VOC/year)( 1 ton/2000 lb)]

= $42,600/ton of VOC reduced

High Estimate = ($156,428/year)/[(1,080 lb-VOC/yea r)(1 ton/2000 lb)]

= $289,681/ton of VOC reduced

As shown above, the electricity cost alone for a me chanically aerated lagoon for swine

manure would cause the cost of the VOC reductions t o be greater than $42,600/ton.

This cost does not include the additional electrici ty cost for nitrification that would naturally occur as the lagoons were aerated or equi pment costs. Even without this cost,

the cost of the VOC emission reductions achieved ex ceed the $17,500/ton cost effectiveness threshold of the District BACT policy . Therefore, this option would not be required as BACT and is beyond BARCT and any applic able RACT requirements.

M. Aerobic Lagoon Treating Liquid Manure from Poult ry

The following analyses are based on the treatment o f manure from 400,000 laying hens in naturally aerobic lagoons and mechanically aerat ed lagoons.

Space Requirement for a Naturally Aerobic Lagoon Tr eating Manure from 400,000 Laying Hens

The following brief analysis will demonstrate that the very large land requirements needed to treat the manure from poultry facilities subject to this rule in a naturally aerobic lagoon would be beyond what could reasonabl y be required. Therefore, there is no need to perform a detailed analysis that would c onsider all of the additional costs, such as the costs of purchasing additional land, co nstructing and lining the lagoon(s), and additional costs for control of mosquito larvae

.

NRCS Practice Standard Code 359 requires that natur ally aerobic lagoons be designed

to have a minimum treatment surface area as determi ned on the basis of daily BOD 5 loading per unit of lagoon surface. The standard s pecifies that the maximum loading rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the NRCS Agricultural Waste Management Field Handbook ( AWMFH) 25 or the maximum loading rate according to state regulatory requirem ents, whichever is more stringent. According to Figure 10-30 (August 2009) of the late st version of the AWMFH, the maximum aerobic lagoon lading rate for the San Joaq uin Valley is 45 - 55 lb-BOD 5 /acreday. According to Table 4-5 (March 2008) of the NR CS AWMFH, the total manure

30 Rumsey, I. C., “Characterizing Reduced Sulfur Comp ounds and Non-Methane Volatile Organic Compounds Emissions from a Swine Concentrated Anima l Feeding Operation” (2010) – PhD dissertation submitted to the Graduate Faculty of North Carolina State UniversitySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-58 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 produced by a laying hens results in 0.011 lb-BOD 5 /day. Assuming that all of the manure will be flushed to the lagoon system, the mi nimum lagoon surface area required for a naturally aerobic lagoon treating manure from 400,000 laying hens in the San Joaquin Valley can be calculated as follows:

BOD 5 loading (lb/day) = 400,000 birds x 0.011 lb-BOD 5 /bird-day x 1 = 4,400 lbBOD 5 /day

Minimum Surface (acres) in areas with a maximum loa ding rate of 55 lb-BOD 5 /acreday = 4,400 lb-BOD 5 /day ÷ 55 lb-BOD 5 /acre-day = 80.0 acres

Minimum Surface (acres) in areas with a maximum loa ding rate of 45 lb-BOD 5 /acreday = 4,400 lb-BOD 5 /day ÷ 45 lb-BOD 5 /acre-day = 97.8 acres

As shown above the minimum surface area required fo r a naturally aerobic lagoon treating manure from 400,000 laying hens in the San Joaquin Valley would range from approximately 80.0 to 97.8 acres. Based on the spa ce requirements alone it is clear that this option is cannot reasonably be required a nd no further analysis is needed.

Analysis for a Mechanically Aerated Lagoon Treating Manure from 400,000 Laying

Hens

As discussed above, the very large space requiremen ts for naturally aerobic lagoons cause this option to be infeasible for most confine d animal facilities. Mechanically aerating a lagoon can achieve some of the benefits of a naturally aerobic lagoon without the large space requirements. However, the costs o f energy for complete aeration have also caused this option to be infeasible. The amou nt of energy required for aeration is based on the amount of volatile solids excreted by animals that must be treated; thus, this cost will be directly proportional to the numb er of animals at a site. The following analysis will determine the cost of emission reduct ions that can be achieved from a mechanically aerated lagoon treating manure from 40 0,000 laying hens.

Biological Oxygen Demand (BOD 5 )

In order to effectively calculate the costs of this control option, the energy requirement for complete aeration must be determined. It should be noted that approximately 1.5 to 2.5 pounds of oxygen is required to digest 1 pound of Biological Oxygen Demand (BOD 5 ) with additional oxygen required for conversion of ammonia to nitrate (nitrification). 26 It is generally accepted that at least twice the B OD should be provided for complete aeration. 27 Additional oxygen would need to be provided for n itrification.

The proposed rule specifies that an aerobic lagoon be designed and operated in

accordance with NRCS Practice Standard Code 359. N RCS Practice Standard Code 359 requires that mechanically aerated lagoons use aeration equipment that provides a minimum of one pound of oxygen for each pound of da ily BOD 5 loading. As discussedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-59 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 above, a lagoon handling flushed manure from 400,00 0 laying hens will have a loading rate of approximately 4,400 lb-BOD 5 /day (1,996 kg-BOD 5 /day).

Energy Requirement a Mechanically Aerated Lagoon Tr eating Manure from 400,000 Laying Hens

Based on the data gathered in a UC Davis study on a erator performance for wastewater lagoons, aeration efficiencies for mechanical aerat ors ranged from 0.10 to 0.68 kg of oxygen provided per kW-hr of energy utilized. 29 The most efficient aerator tested that had been installed in dairy lagoons had an aeration efficiency of 0.49 kg-O 2 /kW-hr. These efficiency tests were performed in clean wate r and lower aeration efficiencies are expected in liquid manure because of the significan t amount of solids that it contains. The yearly energy requirement mechanically aerated lagoon treating flushed manure from 400,000 laying hens is calculated as follows:

High Efficiency Aerator 1,996 kg-BOD 5 /day ÷ (0.68 kg-O 2 /kW-hr) x (365 day/year) = 1,071,382 kW-hr/year

Low Efficiency Aerator 1,996 kg-BOD 5 /day ÷ (0.10 kg-O 2 /kW-hr) x (365 day/year) = 7,285,400 kW-hr/year

Cost of Electricity for a Mechanically Aerated Lago on Treating Manure from 400,000 Laying Hens

The cost for electricity will be based upon the ave rage price for industrial electricity in California for the year 2010, as taken from the Ene rgy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/ epm/table5_6_b.html ).

Average Cost for electricity = $0.0999/kW-hr

The electricity costs for complete aeration are cal culated as follows:

Low Cost Estimate (High Efficiency Aerator) 1,071,382 kW-hr/year x $0.0999/kW-hr = $107,031/yea r

High Cost Estimate (Low Efficiency Aerator) 7,285,400 kW-hr/year x $0.0999/kW-hr = $727,811/yea r

VOC Emission Reductions from a Mechanically Aerated Lagoon Treating Manure from 400,000 Laying Hens

It will be conservatively assumed that a mechanical ly aerated lagoon providing 1 lb of oxygen for every 1 lb of BOD 5 loading will control 90% of the VOC emissions from the lagoon/storage pond. However, as noted above, it i s generally accepted that the oxygen provided should be twice the BOD 5 loading rate for complete aeration; therefore, the actual control from providing 1 lb o f oxygen for every 1 lb of BOD 5 loading is probably closer to 50%.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-60 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 The annual VOC Emission Reductions for mechanically aerated lagoon treating the manure from 400,000 laying hens are calculated as f ollows and shown in the table

below:

[Number of Birds] x [Lagoon/Storage Pond VOC EF (lb /bird-year)] x [Complete Aeration Control Efficiency for Lagoon/Storage Pond]

VOC Reductions for a Mechanically Aerated Lagoon

Type of Animal # of Birds x Lagoon EF (lb/Bird-yr)* x Control (%) = lb-VOC/yr

Laying Hens 400,000 x 0.00225 x 90% = 810

* Based on information for dairy and swine, the lag oon emission factor for poultry is assumed to be

9% of the total emission factor

Cost of VOC Emission Reductions

Low Estimate = ($107,031/year)/[(810 lb-VOC/year)(1 ton/2000 lb)]

= $264,274/ton of VOC reduced

High Estimate = ($727,811/year)/[(810 lb-VOC/year) (1 ton/2000 lb)]

= $1,797,064/ton of VOC reduced

As shown above, the electricity cost alone for a me chanically aerated lagoon for poultry

manure would cause the cost of the VOC reductions t o be greater than $264,274/ton.

This cost does not include the additional electrici ty cost for nitrification that would naturally occur as the lagoons were aerated or equi pment costs. Even without these costs, the cost of the VOC emission reductions achi eved exceed the $17,500/ton cost effectiveness threshold of the District BACT policy . Therefore, this option would not be required as BACT and is beyond BARCT and any applic able RACT requirements.

N. Covered Lagoon Digester Vented to a Control Devi ce to Treat Liquid Manure Produced by Livestock

The costs associated with treating the liquid manur e produced by livestock in a covered lagoon digester vented to a control device are anal yzed below. This practice is only applicable to manure that is handled in liquid form ; therefore this cost analysis will evaluate this option only for dairy cattle, swine, and layers because these confined animal facilities frequently handle manure in liqui d form. EPA’s AgSTAR anaerobic digester database indicates that covered lagoon ana erobic digesters are currently used at dairy and swine facilities with a greater number currently used at dairy facilities. The database does not list any covered lagoon digesters currently used at poultry or beef

cattle facilities. 31

31 US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Digester Database (updated April 2010), http://www.epa.gov/agstar/operational.htmlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-61 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Description of Control Technology

Covered treatment lagoons are one type of anaerobic digester. An anaerobic digester is an enclosed basin or tank that is designed to fa cilitate the decomposition of wastewater by microbes in the absence of oxygen. Th e process of anaerobic decomposition results in the conversion of organic compounds in the wastewater into methane (CH 4 ), carbon dioxide (CO 2 ), and water rather than intermediate Volatile Organic Compounds (VOCs). The gas generated by thi s process is known as biogas, waste gas, or digester gas. Biogas may also include trace amounts of VOCs that remain from incomplete digestion of the volatile solids in the incoming wastewater. The undigested solids that remain after digestion are r emoved from the digester as sludge. Because biogas is mostly composed of methane, the m ain component of natural gas, the gas produced in the digester can be cleaned to remove H 2 S and other impurities and used as fuel. The captured biogas can be combus ted in a flare or may be sent to a boiler or engine, where the gas can be used to gene rate useful heat or electrical energy.

As stated above, the gas generated in the covered l agoon anaerobic digester can be captured and then sent to a suitable combustion dev ice. During combustion, gaseous hydrocarbons are oxidized to form CO 2 and water. Although the control efficiency of the gas captured from the primary lagoon is expected to be very high, the overall control efficiency is expected to be less since VOCs will a lso be emitted from the storage pond and as fugitive emissions. For this analysis, the o verall control efficiency is assumed to

be 80% of the emissions that would have been emitte d from the lagoon system.

O. Covered Lagoon Digester for Liquid Manure from D airy Cows

The costs associated with treating the manure excre ted by milk cows in a covered lagoon digester vented to a control device are anal yzed below. Because it may be possible to generate power from the system to offse t some of the costs associated with installation, this potential benefit is included in the analysis below. The following analysis is based on the treatment of manure from 1 ,000 milk cows in a covered lagoon anaerobic digester with power generation.

Capital Cost for Installation of a Covered Lagoon D igester for Dairy Cows

The capital cost estimates for installation of a co vered lagoon digester are based on information from the United States EPA AgSTAR publi cation “Anaerobic Digestion Capital Costs for Dairy Farms” (May 2010) 32 and the California Energy Commission (CEC) Public Interest Energy Research (PIER) Program Dair y Methane Digester System Program Evaluation Report (Feb 2009) 33 . The formula in the AgSTAR publication

32 “Anaerobic Digestion Capital Costs for Dairy Farms ” (May 2010), EPA AgSTAR http://www.epa.gov/agstar/pdf/digester_cost_fs.pdf

33 “Dairy Power Production Program – Dairy Methane Sy stem Program Evaluation Report” (February 2009). Western United Resource Development, Inc pre pared for the California Energy Commission (CEC) Public Interest Energy Research Program. (CEC-500-2 009-009) http://www.energy.ca.gov/2009publications/CEC-500-2 009-009/CEC-500-2009-009.PDFSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-62 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 results in a capitol cost of $1,032 per cow for a c overed lagoon anaerobic digester treating manure from 1,000 cows. This estimate exc ludes costs of solids separation after digestion, hydrogen sulfide removal, and util ity charges including line upgrades

and interconnection costs and fees. Based on infor mation from installations in California, the CEC PIER Dairy Methane Digester Pro gram Evaluation Report gives an average cost of $585 per cow for installation of co vered lagoon anaerobic digesters (see Table 9 - Total Project Costs and Cost per Cow and per kW). Therefore, for purposes of this analysis the capital cost for inst allation of a covered lagoon digester system for 1,000 cows will be assumed to be between $585/cow and $1,032/cow. The capital cost estimates of a covered lagoon digester treating the manure of 1,000 milk cows

is calculated as follows:

Low capital cost estimate: $585/cow x 1,000 cows = $585,000 High capital cost estimate: $1,032/cow x 1,000 cows = $1,032,000

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The capital cost for the in stallation of the covered lagoon digester will be spread over the expected life of t he system using the capital recovery equation. The expected life of the entire system w ill be estimated at 10 years though the cover may require replacement during this perio d. A 10% interest rate is assumed in the equation and the assumption will be made tha t the equipment has no salvage value at the end of the ten-year cycle.

Low Annual Capital Cost Estimate = [$585,000 x 0.1 (1.1) 10 ]/[(1.1) 10 -1] = $95,206/year

High Annual Capital Cost Estimate = [$1,032,000 x 0 .1(1.1) 10 ]/[(1.1) 10 -1] = $167,953/year

Potential Production of Electricity from a Covered Lagoon Digester Treating Manure from 1,000 Milk Cows:

It may be possible to offset some of the installati on costs of a covered lagoon anaerobic digester with revenue from generation of electricit y. Based on the information given in the CEC PIER Dairy Methane Digester Program Evaluat ion Report, Table 7 – Actual Generation per Cow Comparisons, California dairies that used a covered lagoon digester to produce electricity generated between 4 29.1 and 1,031.8 kW-hr/yr per lactating cow with a overall per facility average g eneration rate of 670.3 kW-hr/yr per lactating cow. This average annual generation rate is actually higher than all the facilities included in the average except one that had a very high generation rate. In addition, this average may overestimate the per-cow generation potential because the contributions of support stock to the digesters wer e not accounted for. However, for more conservative calculations, this average will b e used to calculate the potential annual savings in electricity costs. The potential production of electricity from a covered lagoon digester treating manure from 1,000 milk cow s is calculated as follows:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-63 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Electrical Production: 670.3 kW-hr/(milk cow-yr) x 1,000 milk cows = 670,300 kWhr/yr

Potential Cost Savings from Production of Electrici ty from a Covered Lagoon Digester Treating Manure from 1,000 Milk Cows:

The value of the electricity generated will be base d upon the average price for industrial electricity in California for the year 2010, as tak en from the Energy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table 5_6_b.html ).

Average Cost for electricity = $0.0999/kW-hr

The potential annual cost savings from electricity generation from a covered lagoon digester treating manure from 1,000 milk cows is ca lculated as follows:

Potential Annual Cost Savings from Electrical Produ ction: 670,300 kW-hr/yr x $0.0999/kW-hr = $66,963/yr

Annualized Capital Cost for a Covered Lagoon Digest er Treating Manure from 1,000 Milk Cows minus Potential Savings from Generation o f Electricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation = $95,206/yr - $66,963/yr = $28,243/year

High Annual Capital Cost Estimate minus Savings fro m Potential Generation = $167,953/yr - $66,963/yr = $100,990/year

VOC Emission Reductions from a Covered Lagoon Anaer obic Digester Treating Manure from 1,000 Milk Cows:

The annual VOC Emission Reductions for covered lago on anaerobic digester treating the manure from 1,000 milk cows are calculated as f ollows and shown in the table

below:

[Number of cows] x [Lagoon/Storage Pond VOC EF (lb/ cow-year)] x [Covered Lagoon Digester Control Efficiency for Lagoon/Storage Pond ]

VOC Reductions for a Covered Lagoon Vented to Contr ol Device

Type of Cow # of

cows x Lagoon EF

(lb/cow-yr) x Control

(%) = lb-VOC/yr

Milk Cow (freestall) 1,000 x 1.3 x 80% = 1,040

Cost of VOC Emission Reductions

Low Estimate = ($28,243/year)/[(1,040 lb-VOC/year)( 1 ton/2000 lb)]

= $54,313/ton of VOC reducedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-64 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 High Estimate = ($167,953/year)/[(1,040 lb-VOC/yea r)(1 ton/2000 lb)]

= $322,987/ton of VOC reduced

As shown above, the capital cost alone for a covere d lagoon digester for a dairy would cause the cost of the VOC reductions to be greater than $54,313/ton. This cost includes the potential revenue generated by electri cal production but does not include the additional maintenance required for the system. Even without these costs, the cost

of the VOC emission reductions achieved exceed the $17,500/ton cost effectiveness threshold of the District BACT policy. Therefore, this option would not be required as BACT and is beyond BARCT and any applicable RACT re quirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, which may off set any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substantial subsidies to offset the extremely high costs of

installation.

P. Covered Lagoon Digester for Swine Manure

The costs associated with treating the manure excre ted by finishing swine in a covered lagoon digester vented to a control device are anal yzed below. Because it may be possible to generate power from the system to offse t some of the costs associated with installation, this potential benefit is included in the analysis below. The following analysis is based on the treatment of manure from 5 ,000 finishing swine in a covered lagoon anaerobic digester with power generation.

Capital Cost for Installation of a Covered Lagoon D igester for Swine

On an animal weight basis, the capital cost estimat es for installation of a covered lagoon digester for finishing swine are assumed to be the same as the costs for installation of a covered lagoon digester at a dairy. Based on the i nformation given above, the capital cost of installation of a covered lagoon digester at a d airy is between $585 and $1,032 per cow. A typical milk cow weighs approximately 1,400 lb an d the average weight of finishing swine is assumed to be 150 lb. The estimated capit al cost of a covered lagoon digester for finishing swine is estimated by adjusting by we ight as follows:

Low capital cost estimate: $585/cow x 150 lb/head/( 1,400 lb/cow) = $63/head High capital cost estimate: $1,032/cow x 150 lb/hea d/(1,400 lb/cow) = $111/head

The estimated capital cost of a covered lagoon dige ster treating the liquid manure from 5,000 finishing swine is calculated as follows:

Low capital cost estimate: 5,000 head x $63/head = $315,000 High capital cost estimate: 5,000 head x $111/head = $555,000

The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The capital cost for the in stallation of the covered lagoonSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-65 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 digester will be spread over the expected life of t he system using the capital recovery equation. The expected life of the entire system w ill be estimated at 10 years though the cover may require replacement during this perio d. A 10% interest rate is assumed in the equation and the assumption will be made tha t the equipment has no salvage value at the end of the ten-year cycle.

Low Annual Capital Cost Estimate = [$315,000 x 0.1 (1.1) 10 ]/[(1.1) 10 -1] = $51,265/year

High Annual Capital Cost Estimate = [$555,000 x 0.1 (1.1) 10 ]/[(1.1) 10 -1] = $90,324/year

Potential Production of Electricity from a Covered Lagoon Digester Treating Manure from 5,000 Finishing Swine:

It may be possible to offset some of the installati on costs of a covered lagoon anaerobic digester with revenue from generation of electricit y. Production of electricity from digester gas from swine manure generally requires a very large facility to be economically attractive; therefore it has been more common to flare the gas from covered lagoons at swine facilities for abatement o f odors or to use the gas in a boiler or

furnace. Because there is limited information avai lable regarding production of electricity from digester gas from swine manure, th e potential for production of electricity will be estimated based on the information given ab ove for production of electricity from covered lagoon digesters at dairy facilities. It w ill be assumed that the potential for production of digester gas and electricity from dai ry cows and swine will be proportional

to the amount of volatile solids excreted in the ma nure. According to the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH ), Chapter 4 - Agricultural

Waste Characteristics 34 (March 2008), a lactating dairy cow excretes an av erage of approximately 17 lb/day of volatile solids and fini shing swine excrete approximately 5.4 lb/day of volatile solids per 1,000-lb AU. Based o n the information given above, a covered lagoon anaerobic digester at a dairy is est imated to produce 670.3 kW-hr per milk cow per year. Assuming that the amount of ele ctricity produced is proportional to

the amount of volatile solids sent to the covered l agoon, the potential production of electricity from a covered lagoon anaerobic digeste r at a finishing swine facility is

estimated as follows:

(0.15 AU/swine x 5.4 lb VS/AU)/(17 lb-VS/milk cow) x 670.3 kW-hr/(milk cow-yr) = 31.9 kW-hr/(swine-yr)

The potential production of electricity from a cove red lagoon digester treating manure from 5,000 finishing swine is calculated as follows:

Electrical Production: 31.9 kW-hr/(swine-yr) x 5,00 0 swine = 159,500 kW-hr/yr

34 United States Department of Agriculture (USDA) Nat ural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH ), http://policy.nrcs.usda.gov/viewerFS.aspx?hid=21430SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-66 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 Potential Cost Savings from Production of Electrici ty from a Covered Lagoon Digester Treating Manure from 5,000 Swine:

The value of the electricity generated will be base d upon the average price for industrial electricity in California for the year 2010, as tak en from the Energy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table 5_6_b.html ).

Average Cost for electricity = $0.0999/kW-hr

The potential annual cost savings from electricity generation from a covered lagoon digester treating manure from 5,000 swine is calcul ated as follows:

Potential Annual Cost Savings from Electrical Produ ction: 159,500 kW-hr/yr x $0.0999/kW-hr = $15,934/yr

Annualized Capital Cost for a Covered Lagoon Digest er Treating Manure from 5,000 Swine minus Potential Savings from Generation of El ectricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation = $51,265/yr

- $15,934/yr = $35,331/year

High Annual Capital Cost Estimate minus Savings fro m Potential Generation = $90,324/yr - $15,934/yr = $74,390/year

VOC Emission Reductions from a Covered Lagoon Anaer obic Digester Treating Manure from 5,000 Finishing Swine:

The annual VOC Emission Reductions for covered lago on anaerobic digester treating the manure from 5,000 swine are calculated as follo ws and shown in the table below:

[Number of swine] x [Lagoon/Storage Pond VOC EF (lb /cow-year)] x [Covered Lagoon Digester Control Efficiency for Lagoon/Storage Pond ]

VOC Reductions for a Covered Lagoon Vented to Contr ol Device

Animal # of

Head x Lagoon EF

(lb/head-yr)* x Control (%) = lb-VOC/yr

Finishing Swine 5,000 x 0.4 x 80% = 1,600

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from housing barns and 9% of VOC emissions are assumed t o be from lagoons 35

Cost of VOC Emission Reductions

Low Estimate = ($35,331/year)/[(1,600 lb-VOC/year)( 1 ton/2000 lb)]

= $44,164/ton of VOC reduced

35 Rumsey, I. C., “Characterizing Reduced Sulfur Comp ounds and Non-Methane Volatile Organic Compounds Emissions from a Swine Concentrated Anima l Feeding Operation” (2010) – PhD dissertation submitted to the Graduate Faculty of North Carolina State UniversitySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-67 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 High Estimate = ($74,390/year)/[(1,600 lb-VOC/year )(1 ton/2000 lb)]

= $92,988/ton of VOC reduced

As shown above, the capital cost alone for a covere d lagoon digester for swine would cause the cost of the VOC reductions to be greater than $44,164/ton. This cost includes the potential revenue generated by electri cal production but does not include the additional maintenance required for the system. Even without these costs, the cost

of the VOC emission reductions achieved exceed the $17,500/ton cost effectiveness threshold of the District BACT policy. Therefore, this option would not be required as BACT and is beyond BARCT and any applicable RACT re quirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, which may off set any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substantial subsidies to offset the extremely high costs of

installation.

Q. Covered Lagoon Digester for Poultry Manure

Although treating the manure excreted by laying hen s in a covered lagoon digester appears to be very uncommon, the costs associated w ith treating the manure excreted by laying hens in a covered lagoon digester are ana lyzed below. Because it may be possible to generate power from the system to offse t some of the costs associated with installation, this potential benefit is included in the analysis below. The following analysis is based on the treatment of manure from 5 00,000 laying hens in a covered lagoon anaerobic digester with power generation.

Capital Cost for Installation of a Covered Lagoon D igester for Poultry

On an animal weight basis, the capital cost estimat es for installation of a covered lagoon digester for poultry are assumed to be the same as the costs for installation of a covered lagoon digester at a dairy. Based on the informati on given above, the capital cost of installation of a covered lagoon digester at a dair y is between $585 and $1,032 per cow. A typical milk cow weighs approximately 1,400 lb an d the average weight of a laying hen is assumed to be 4 lb. The estimated capital cost of a covered lagoon digester for poultry is estimated by adjusting by weight as follows:

Low capital cost estimate: $585/cow x 4 lb/bird/(1, 400 lb/cow) = $1.67/bird High capital cost estimate: $1,032/cow x 4 lb/bird/ (1,400 lb/cow) = $2.95/bird

The estimated capital cost of a covered lagoon dige ster treating the liquid manure from 500,000 laying hens is calculated as follows:

Low capital cost estimate: 500,000 birds x $1.67/bi rd = $835,000 High capital cost estimate: 500,000 birds x $2.95/b ird = $1,475,000SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-68 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 The annualized capital cost estimates will be calcu lated in accordance with the District’s BACT Policy, APR 1305. The capital cost for the in stallation of the covered lagoon digester will be spread over the expected life of t he system using the capital recovery equation. The expected life of the entire system w ill be estimated at 10 years though the cover may require replacement during this perio d. A 10% interest rate is assumed in the equation and the assumption will be made tha t the equipment has no salvage value at the end of the ten-year cycle.

Low Annual Capital Cost Estimate = [$835,000 x 0.1 (1.1) 10 ]/[(1.1) 10 -1] = $135,892/year

High Annual Capital Cost Estimate = [$1,475,000 x 0 .1(1.1) 10 ]/[(1.1) 10 -1] = $240,049/year

Potential Production of Electricity from a Covered Lagoon Digester Treating Manure from 500,000 Laying Hens:

It may be possible to offset some of the installati on costs of a covered lagoon anaerobic digester with revenue from generation of electricit y. Only a very small number of digesters have been installed at poultry facilities and there was no information available on any covered lagoon digesters at poultry faciliti es. 36 Because there is limited information available regarding production of elect ricity from digester gas from poultry manure, the potential for production of electricity will be estimated based on the information given above for production of electrici ty from covered lagoon digesters at dairy facilities. It will be assumed that the pote ntial for production of digester gas and electricity from dairy cows and poultry will be pro portional to the amount of volatile solids excreted in the manure. According to the US DA NRCS Agricultural Waste Management Field Handbook (AWMFH), Chapter 4 - Agri cultural Waste

Characteristics 22 (March 2008), a lactating dairy cow excretes an av erage of approximately 17 lb/day of volatile solids and a la ying hen excretes approximately 0.036 lb/day of volatile solids. Based on the informatio n given above, a covered lagoon anaerobic digester at a dairy is estimated to produ ce 670.3 kW-hr per milk cow per year. Assuming that the amount of electricity prod uced is proportional to the amount of volatile solids sent to the covered lagoon, the pot ential production of electricity from a covered lagoon anaerobic digester at a poultry faci lity is estimated as follows:

(0.036 lb-VS/bird)/(17 lb-VS/milk cow) x 670.3 kW-h r/(milk cow-yr) = 1.42 kWhr/(bird-yr)

The potential production of electricity from a cove red lagoon digester treating manure from 500,000 laying hens is calculated as follows:

Electrical Production: 1.42 kW-hr/(bird-yr) x 500,0 00 birds = 710,000 kW-hr/yr

Potential Cost Savings from Production of Electrici ty from a Covered Lagoon Digester Treating Manure from 500,000 Laying Hens:

36 The US EPA AgSTAR Program Guide to Anaerobic Diges ters – Anaerobic Digester Database (updated April 2010) lists only three poultry digesters, http://www.epa.gov/agstar/operational.htmlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-69 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 The value of the electricity generated will be base d upon the average price for industrial electricity in California for the year 2010, as tak en from the Energy Information Administration (EIA) Website: (http://www.eia.doe.gov/cneaf/electricity/epm/table 5_6_b.html ).

Average Cost for electricity = $0.0999/kW-hr

The potential annual cost savings from electricity generation from a covered lagoon digester treating manure from 500,000 laying hens i s calculated as follows:

Potential Annual Cost Savings from Electrical Produ ction: 710,000 kW-hr/yr x $0.0999/kW-hr = $70,929/yr

Annualized Capital Cost for a Covered Lagoon Digest er Treating Manure from 500,000 Birds minus Potential Savings from Generation of El ectricity:

Low Annual Capital Cost Estimate minus Savings from Potential Generation = $135,892/yr

- $70,929/yr = $64,963/year

High Annual Capital Cost Estimate minus Savings fro m Potential Generation = $240,049/yr - $70,929/yr = $169,120/year

VOC Emission Reductions from a Covered Lagoon Anaer obic Digester Treating Manure from 500,000 Birds:

The annual VOC Emission Reductions for covered lago on anaerobic digester treating the manure from 500,000 birds are calculated as fol lows and shown in the table below:

[Number of Birds] x [Lagoon/Storage Pond VOC EF (lb /cow-year)] x [Covered Lagoon Digester Control Efficiency for Lagoon/Storage Pond ]

VOC Reductions for a Covered Lagoon Vented to Contr ol Device

Animal # of Birds x Lagoon EF (lb/Bird-yr)* x Control (%) = lb-VOC/yr

Laying Hens 500,000 x 0.00225 x 80% = 900

* Based on information for dairy and swine, the lag oon emission factor for poultry is assumed to be

9% of the total emission factor

Cost of VOC Emission Reductions

Low Estimate = ($64,963/year)/[(900 lb-VOC/year)(1 ton/2000 lb)]

= $144,362/ton of VOC reduced

High Estimate = ($169,120/year)/[(900 lb-VOC/year) (1 ton/2000 lb)]

= $375,822/ton of VOC reduced

As shown above, the capital cost alone for a covere d lagoon digester for poultry would cause the cost of the VOC reductions to be greater than $144,362/ton. This costSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix E: Class Two Measures Analysis for Rule 4 570 October 21, 2010

E-70 Final Draft Staff Report with Appendices For Amended Revised Proposed Amendments to Rule 457 0 includes the potential revenue generated by electri cal production but does not include the additional maintenance required for the system. Even without these costs, the cost

of the VOC emission reductions achieved exceed the $17,500/ton cost effectiveness threshold of the District BACT policy. Therefore, this option would not be required as BACT and is beyond BARCT and any applicable RACT re quirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, which may off set any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substantial subsidies to offset the extremely high costs of

installation.