Final Staff Report and Recommendations on Agricultural Burning



## Chapter 8

Air Quality Impacts of Continued Open Burning and AlternativesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

Final Staff Report and Recommendations on Agricultural Burning This page intentionally blank



## .San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-1 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning 

### Chapter 8: Air Quality Impacts of Continued Open Burning & Alternatives

8.1 SMOKE MANAGEMENT SYSTEM

Open burning of agricultural crops and materials is managed by the District’s Smoke Management System (SMS). The SMS uses a comb ination of real-time meteorological information and computer modeling to determine the allowable amount and location of agricultural burning. Under the SMS, the amount of burning allowed to take place on any given day woul d be based on several factors such as the local meteorology, the air qual ity conditions, the atmospheric holding capacity, the amount of burning already app roved in a given area, and the potential impacts on downwind populations. The District’s use of the SMS is

intended to limit emissions to levels below the fed eral ambient air quality standards and to better distribute emissions tempor ally and spatially for flexibility of burn days for growers while minimizing the impac t on the public.

Under the SMS, the SJVAB is classified into three r egions (north, central, and south), the number of which will be determined by t he topographical, geological and meteorological conditions in the San Joaquin Va lley Air Basin (SJVAB). Burning is allocated by region, depending upon each region’s carrying capacity for smoke on each day. Not every burner who wants t o burn on a given day may

be able to do so. Therefore, the District establish ed a system for prioritizing burning within each region. The SMS analyzes the d aily impact of open burning on air quality in 103 zones in the SJVAB.

Because of the general locations where agricultural and prescribed burning activities tend to occur, combined with the topogra phy, geology, and weather conditions in the SJVAB, it is expected that the re gions will fall into three categories: (a) regions where only prescribed burni ng will occur; (b) regions where only agricultural burning will occur; and (c) regions where both prescribed and agricultural burning will occur. In regions wh ere only agricultural burning will

occur, the allocation will be on a first come, firs t served basis. However, burners who do not receive an allocation on a particular da y will be placed on a waiting list for the following day(s). The District has est ablished a procedure whereby burners on the waiting list receive notification wh en their allocation is going to be available. Properly managed burning allocation s under the existing District SMS ensures that air quality and health impacts of open burning of agricultural materials, prescribed burning, and hazard reduction burning are minimized to the

fullest extent.San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-2 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning Figure 8-2 shows the burn allocation zones in each of the eight counties in the

SJVAB

Figure 8-2 Smoke Management System Burn Allocation ZonesSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-3 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning 8.2 2007 OZONE PLAN

Air monitoring data in the San Joaquin Valley Air B asin (SJVAB) indicates ozone levels that exceed the eight-hour ozone National Am bient Air Quality Standards (NAAQS) set by the federal government to protect pu blic health and welfare. As a result, the United States Environmental Protectio n Agency (EPA) has classified the Valley as serious nonattainment. In accordance with the requirements of the federal Clean Air Act, nonattainment areas must dev elop plans to achieve attainment of the NAAQS. Consequently, the San Joaq uin Valley Unified Air Pollution Control District (District), adopted the 2007 Ozone Plan. The Ozone Plan contains a comprehensive and exhaustive list o f regulatory and incentivebased measures to reduce emissions of ozone and par ticulate matter precursors throughout the Valley. Additionally, the Plan call s for major advancements in pollution control technologies for mobile and stati onary sources of air pollution, and a significant increase in state and federal fun ding for incentive-based measures to create adequate reductions in emissions to bring the entire Valley

into attainment with the federal ozone standard.

In preparing the Ozone Plan, consistent with the Di strict’s guiding principle, the control strategy in the Plan is developed with the utmost consideration to future

needs for the PM2.5 Attainment Plan discussed below . Both Plans’ focus is based on NOx reduction strategy. Consequently, the control strategy to attain the federal 8-hour ozone standard produces NOx emis sions reductions that are

close to what is needed for attainment of the 1997 PM2.5 standards by the maximum statutory attainment date of April 15, 2015 . This suggests that the ozone strategy will provide most – if not all – of the reductions needed to attain the PM2.5 annual standard, based on simple modeling exercises. There is a possibility that that some additional NOx emissions reductions from incentivebased measures may be needed to demonstrate attainm ent of the 19977 annual

PM2.5 standard.

Appendix I of the Ozone Plan listed the Control Mea sures that are needed to

achieve attainment of the standards. One of these Control Measures is S-AGR-1 Open Burning, which addressed the phased-down prohi bitions of burning agricultural materials mandated by the state Health and Safety Code Sections 41855.5 and 41855.6. District Rule 4103 (Open Burn ing) in conjunction with the District’s “Staff Report and Recommendations on Agr icultural Burning” is the mechanism by which the District is implementing the agricultural materials open burn prohibition.

8.3 2008 PM2.5 PLAN

In 1997, EPA sets two PM2.5 standards: a 24-hour st andard (65 μg/m 3 ) to protect short term health impacts, and a 12-month ( annual) standard (15 μg/m 3 )San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-4 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning to protect against long-term impacts. The San Joaq uin complied with the 24- hour standard, based on data from 2004 through 2006 . In 2006, EPA revised the 24-hour standard to lower the standard (35 μg/m 3 ). It is estimated that that attainment plans for this new standard may be requi red by 2012 or 2013.

EPA has designated the San Joaquin Valley Air Basin as nonattainment of the federal PM2.5 standards. In April 2008, the Distri ct Governing Board adopted the PM2.5 Plan that demonstrates the strategies the District will pursue in order

to achieve attainment of the federal PM2.5 standard s. The 2008 PM2.5 Plan builds upon the comprehensive strategy adopted in t he District’s 2007 Ozone Plan to bring the San Joaquin Valley Air Basin into attainment of the federal PM2.5 standards. In preparing the 2007 Ozone Plan, the control strategy was developed with utmost consideration to future needs for the PM2.5 attainment plan. An evaluation of the District’s ozone contro l strategy to attain the federal 8- hour ozone standard has determined that the ozone p lan included NOx

emissions reductions that are close to what is need ed for attainment of the 1997 PM2.5 standards by the maximum statutory date attai nment date of April 5, 2015. Based on simplified modeling exercises performed at the time of the ozone plan was completed, the ozone control strategy was deter mined to have a design value that would provide most – if not all – of the reductions needed to attain the

PM2.5 annual standard.

Appendix I of the PM2.5 Plan listed the Control Mea sures that are needed to

achieve attainment of the standards. One of these Control Measures is S-AGR-1 Open Burning, which addressed the phased-down prohi bitions of burning agricultural materials mandated by the California H ealth and Safety Code (CH&SC) Sections 41855.5 and 41855.6. District Rul e 4103 (Open Burning) in conjunction with the District’s “Staff Report and R ecommendations on Agricultural Burning” is the mechanism by which the District is implementing the agricultural materials open burn prohibition.

8.3.1 Annual PM2.5 Standard

As discussed in the District 2008 PM2.5 Plan, attai nment of the annual standard is projected by 2014 by the regional photochemical model and all receptor evaluations. The predicted value is within one mic rogram of the standard; therefore, a weight of evidence evaluation is appro priate. The predictions of these models are compared, along with air monitorin g data, trends and other technical information, to establish a weight of evi dence assurance that attainment will be achieved. The weight of evidence evaluatio n supports acceptance of the regional and receptor modeling predictions. Evalua tion of the receptor modeling identifies that attainment will not occur by 2009 w ith the expected achievable reductions and will require the extensive NOx reduc tions proposed by ARB for 2014. Reductions achieved by the District and curr ent ARB efforts for all directlySan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-5 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning emitted and secondary particulate sources are impor tant to achieving attainment. The proposed NOx reductions for 2014 would not be s ufficient to achieve

attainment without these other reductions. The str ategy for attainment includes reduction of directly emitted PM2.5 (geologic, mobi le, organic carbon and vegetative burning) as well as reductions from SOx and NOx as precursors to ammonium sulfate and ammonium nitrate. Secondary o rganic aerosol particulate formation is also included in the model ing evaluation of motor vehicle and organic carbon contributions.

8.3.2 24-Hour PM2.5 Standard

As discussed in the District 2008 PM2.5 Plan, attai nment of the prior 24-hour 65 microgram standard is projected to occur prior to 2 014 and with much less reductions required than are needed to attain the a nnual standard. This means

that the annual standard identifies the amount of r eductions needed to achieve attainment. ARB used the regional model to evaluat e the top 25% of days modeled to provide the annual analysis. Based on d esign values for 2005, ARB projected a 2014 value of 45 micrograms or less at all sites. Due to concerns that the last two years have experienced slightly higher 24-hour values, the District also performed a screening assessment with estimate d design values for 2007 (based on incomplete and uncertified data). Evalua tion by the District projected a 2014 value of 53 micrograms. Both of these proje ctions are well below the 65 microgram standard and do not require a weight of e vidence evaluation.

Unmonitored area evaluation for the year 2014 was c onducted by ARB and provides confirming evidence for the attainment dem onstration. The unmonitored area evaluation requires examination of regional modeling results for the entire Valley. ARB has provided a screenin g assessment produced from the regional model results for the year 2014 to det ermine if any portion of the modeling domain predicts concentrations greater tha n the monitored locations. This initial analysis did not identify any grid squ ares that have higher values.

ARB has committed to conduct further evaluation in accordance with EPA guidance should this be determined to be necessary; however, the screening assessment indicates that it is unlikely that any a reas will be identified that require subsequent evaluation or temporary monitori ng. The District and ARB

will confer with EPA to ensure that the unmonitored area evaluation provides

sufficient confirmation for the attainment demonstr ation.

8.4 OPEN BURNING EMISSIONS INVENTORY

The prohibition of open burning of certain material s has been implemented by adopting Rule 4103 in June 1992. The rule was subs equently amended in December 1992, December 1993, June 2001, September 2004, May 2005, and May 2007. The emissions inventory from the 2007 Ozone Plan and the 2008San Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-6 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning PM2.5 Plan

for Control Measure S-AGR-1 (Open Burning) are sho wn in Table 1 below. The projected emission reductions and actua l estimated emissions reductions for the 2010 burn prohibition schedule a re presented in Table 2 and Table 3 below. Both of the plans did not include t he projected emissions reduction from 2007 and 2010 burn prohibition deadl ines.

Since District’s implementation of the open burning prohibitions of agricultural materials pursuant to the state law requirements, e mission of NOx, PM, and VOC from this source category has significantly been re duced. The emissions

reductions achieved so far are more than the estima ted amount indicated in the

PM2.5 Plan

and Ozone Plan . In addition to fulfilling the CH&SC 2010 burn prohibition deadline and the requirements from Rule 4103, the District has also met the State Implementation Plan commitments for t his source category.

Table 8 – 1 Emissions Inventory from the PM2.5 and Ozone Plans for Open Burning

NOx PM2.5 VOC SO 2 Emissions Inventory for Open Burning (S-AGR-1) (tpd) (tpd) (tpd) (tpd)

PM2.5 Plan : Emissions Inventory by 2010 5.27 6.94 n/a 0.13

Ozone Plan : Emissions Inventory by 2008 1 4.8 n/a 5.7 n/a

1. The Ozone Plan does not show projected reduction s for 2010.

Table 8 – 2 PM2.5 Plan Projected Emissions Reduction for Open Burning

NOx PM2.5 VOC SO 2 PM2.5 Plan : Emissions Reduction (tpd) (tpd) (tpd) (tpd)

PM2.5 Plan : Projected Annual Average Reductions for the Open Burning Control Measure by 2010 1 1.95 2.57 n/a 0.05

PM2.5 Plan : Estimated Reductions from 2007 Burn Prohibition Deadline (Annual) 3.54 4.57 n/a 0.09

PM2.5 Plan : Estimated Reductions from 2010 Burn Prohibition Deadline (Annual) 0.54 1.79 n/a 0.03

District’s Total Estimated Reductions for Open Burning 4.08 6.36 n/a 0.12

1. The projected reductions include emissions from the rulemaking projects from the 2007 and

2010 CH&SC deadlines. *tpd: tons per day; N/A: not applicable to the PlanSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

8-7 Chapter 8: Air Quality Impacts of Continued Open Burning and Alternatives

Final Staff Report and Recommendations on Agricultural Burning Table 8 – 3 Ozone Plan Projected Emissions Reduction for Open Burning

NOx PM2.5 VOC SO 2 Ozone Plan : Emissions Reduction (tpd) (tpd) (tpd) (tpd)

Ozone Plan : Projected Annual Average Reductions for the Open Burning Control Measure by 2008 1 1.1 n/a 1.3 n/a

Ozone Plan : Estimated Reductions from 2007 Burn Prohibition Deadline (Annual) 3.2 n/a 3.7 n/a

Ozone Plan : Estimated Reductions from 2010 Burn Prohibition Deadline (Annual) 0.5 n/a 1.5 n/a

District’s Total Estimated Reductions for Open Burning 3.7 n/a 5.2 n/a

1. The projected reductions include emissions from the rulemaking projects from the 2007 and

2010 CH&SC deadlines. *tpd: tons per day; N/A: not applicable to the PlanSan Joaquin Valley Unified Air Pollution Control Di strict May 20, 2010 Revised July 21, 2010

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