Development Document for the Final Revisions to the 

National Pollutant Discharge Elimination System Regulation 

and the Effluent Guidelines for 

Concentrated Animal Feeding Operations 

Addendum 

Stephen L. Johnson 

Administrator 

Benjamin H. Grumbles 

Assistant Administrator, Office of Water 

Mary T. Smith 

Director, Engineering and Analysis Division 

Janet Goodwin 

Chief, Technology and Statistics Support Branch 

Paul H. Shriner 

Project Manager 

Engineering and Analysis Division 

Office of Science and Technology 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

June 2006 
ACKNOWLEDGMENTS AND DISCLAIMER 

This report has been reviewed and approved for publication by the Engineering and Analysis 

Division, Office of Science and Technology. This report was prepared with the support of 

Eastern Research Group, Inc. and Tetra Tech, Inc., under the direction and review of the Office 

of Science and Technology. Neither the United States government nor any of its employees, 

contractors, subcontractors, or other employees makes any warranty, expressed or implied, or 

assumes any legal liability or responsibility for any third party’s use of, or the results of such use 

of, any information, apparatus, product, or process discussed in this report, or represents that its 

use by such a third party would not infringe on privately owned rights. 

i 
Development Document for the Final Revisions to the 

National Pollutant Discharge Elimination System Regulation 

and the Effluent Guidelines for 

Concentrated Animal Feeding Operations 

Version Control 

Version EPA Publication 

Number 

Publication 

Date 

Description of Changes Author’s 

Initial 

1 EPA-821-R-03-001 December 2002 Initial Release PHS 

2 EPA-821-R-06-007 June 2006 Updated Introduction and 

Table of Contents; new 

subsections to Chapters 

2, 8, and 15; new 

Appendices 

PHS 

This document is an addendum to the Development Document for the Final Revisions to the 

National Pollutant Discharge Elimination System Regulation and the Effluent Guidelines for 

Concentrated Animal Feeding Operations (EPA-821-R-03-001), which was prepared in support 

of effluent limitations guidelines and standards for Concentrated Animal Feeding Operations 

(CAFOs), published February 12, 2003 (68 FR 7176). Please note that the section and page 

numbers in this document are numbered to be consistent with the original document. The section 

numbers either correspond to section numbers in the existing document, or are additions to the 

original document. The page numbers continue from the existing pages in the original 

document. 

ii 
CONTENTS

CHAPTER 1 INTRODUCTION .....................................................................................................1-7 

CHAPTER 2 SUMMARY AND SCOPE OF PROPOSED REGULATION ............................................2-17 

2.3 Summary of the Second Circuit Court Decision Concerning Remanded 

Issues......................................................................................................2-17 

2.3.1 Proposed Regulation of NSPS ...................................................2-17 

2.3.1.1 100-Year Storm Containment Structure ........................ 2-18 

2.3.1.2 Superior Alternative Performance Standards................. 2-18 

2.3.2 Proposed Regulation of BCT for Pathogen Control ..................2-18 

2.4 References..............................................................................................2-19 

CHAPTER 8 TREATMENT TECHNOLOGIES AND BEST MANAGEMENT PRACTICES .................8-232 

8.6 Treatment Technologies and Practices Evaluated for Pathogen 

Control .................................................................................................8-232 

8.6.1 Descriptions of Technology Options.......................................8-232 

8.6.1.1 Anaerobic Digestion .................................................... 8-233 

8.6.1.2 Lime Addition.............................................................. 8-234 

8.6.1.3 Composting of Poultry Manure or Litter ..................... 8-234 

8.6.1.4 Fluidized Bed Incineration........................................... 8-235 

8.6.1.5 Other Chemical Addition Technologies ...................... 8-236 

8.6.1.6 Deep Stacking of Poultry Litter ................................... 8-237 

8.6.2 Technology Cost Calculations.................................................8-237 

8.6.2.1 Anaerobic Digestion for Pathogen Reduction at Large 

Dairy Operations.......................................................... 8-240 

8.6.2.2 Anaerobic Digestion for Pathogen Reduction at Large 

Swine Operations......................................................... 8-245 

8.6.2.3 Lime Addition to Dairy Manure .................................. 8-247 

8.6.2.4 Composting of Poultry Manure or Litter ..................... 8-257 

8.6.3 Pollutant Load Calculations.....................................................8-265 

8.6.4 References................................................................................8-267 

CHAPTER 15 ADDITIONAL ANALYSES IN RESPONSE TO THE 2005 SECOND CIRCUIT COURT 

DECISION ............................................................................................................15-1 

15.1 New Source Performance Standards......................................................15-1 

15.1.1 100-Year Storm Containment Structure ....................................15-1 

15.2 Best Conventional Pollutant Control Technology .................................15-4 

15.2.1 Background of BCT Cost Test...................................................15-5 

15.2.1.1 BCT Cost Test Calculation Steps ............................. 15-6 

15.2.1.2 Data Sources Used in the BCT Cost Test 

Calculations.................................................................... 15-7 

15.2.2 Development of BCT Cost Test for FC.....................................15-8 

15.2.2.1 Calculation of POTW Benchmark for FC ................ 15-9 

15.2.2.2 Calculation of Industry Benchmark for FC ............ 15-12 

iii 
CONTENTS (CONTINUED) 

15.2.3 Results of BCT Cost Test ........................................................15-13 

15.2.3.1 BCT Cost Test for BOD and TSS Removals.......... 15-13 

15.2.3.2 BCT Cost Test for FC Removals............................ 15-16 

15.3 References............................................................................................15-19 

Appendix A: MODEL FARM RESULTS FOR MODIFIED OPTION 6 FOR SWINE 

Appendix B: CAFO POULTRY MODEL FARM COMPOSTING COST 

Appendix C: ADDITIONAL POLLUTANT DATA 

iv 
LIST OF FIGURES

Figure 8-16. Diagram of a Flush Dairy Lime Disinfection System........................................ 8-251 

Figure 8-17. Diagram of a Scrape Dairy Lime Disinfection System...................................... 8-252 

Figure 8-18. Poultry Composting System for Wet Layers ..................................................... 8-258 

Figure 8-19. Poultry Composting System for Dry Layers, Broilers, and Turkeys ................. 8-258 

v 
LIST OF TABLES

Table 1-1. Regulatory Options for CAFOs that EPA Considered for the 2003 Rule................. 1-8 

Table 8-28. Summary of Regulatory Options for CAFOs...................................................... 8-239 

Table 8-29. Animal Weights................................................................................................... 8-242 

Table 8-30. FarmWare Flush Dairy Results ........................................................................... 8-243 

Table 8-31. FarmWare Scrape Dairy Results ......................................................................... 8-243 

Table 8-32. U.S. Total NASS Large Dairy Farm Statistics.................................................... 8-244 

Table 8-33. Weighted Average FarmWare Capital and O&M Costs ..................................... 8-244 

Table 8-34. Total Annualized Model Farm Costs for Flush and Scrape Operations.............. 8-244 

Table 8-35. Digester Cost per Swine with Generator and Energy Recovery ......................... 8-246 

Table 8-36. Digester Cost per Swine without Generator or Energy Recovery....................... 8-247 

Table 8-37. Summary of Results for the Modified Option 6 for Swine ................................. 8-247 

Table 8-38. Model Dairy Waste Generation and Precipitation Collection............................. 8-249 

Table 8-39. Lime Disinfection System Design Parameters.................................................... 8-250 

Table 8-40. Lime Storage and Slaking System Design Parameters........................................ 8-253 

Table 8-41. Ammonia Scrubber System Design Parameters.................................................. 8-254 

Table 8-42. Estimated Capital Cost for Lime Disinfection of Dairy Waste........................... 8-255 

Table 8-43. Estimated Annual O&M Cost for Lime Disinfection of Dairy Waste ................ 8-256 

Table 8-44. Estimated Industry Cost for Lime Disinfection................................................... 8-257 

Table 8-45. Model Farms and Costs Presented in the Poultry Composting Report ............... 8-259 

Table 8-46. Storage Pond Volume and Costs ......................................................................... 8-261 

Table 8-47. Poultry Composting Costs Including Storage Ponds and Solids Separation....... 8-262 

Table 8-48. Poultry Industry Costs for Composting............................................................... 8-263 

Table 8-49. Compost Prices and Data Sources....................................................................... 8-264 

Table 8-50. Sediment Load Reductions from Large CAFOs in Millions of Pounds 

per Year............................................................................................................ 8-267 

Table 8-51. FC Load Reductions from Large CAFOs in 1019 Colony Forming Units........... 8-267 

Table 8-52. BOD Load Reductions from Large CAFOs in Millions of Pounds per Year ..... 8-267 

Table 15-1. Case Studies Using AWM and SPAW to Demonstrate No Discharge ................. 15-4 

Table 15-2. Model POTWs and Representative Flow Ranges from the 1986 FRN................. 15-6 

Table 15-3. Cost of Secondary Treatment .............................................................................. 15-11 

Table 15-4. Cost of Advanced Secondary Treatment............................................................. 15-11 

Table 15-5. Weighting Factors ............................................................................................... 15-12 

Table 15-6. POTW Benchmark for FC................................................................................... 15-12 

Table 15-7. Flow–weighted Cost of Secondary Treatment .................................................... 15-13 

Table 15-8. 2003 CAFO Rule BPT Costs and BOD & TSS Removals ................................. 15-14 

Table 15-9. Incremental Costs and BOD & TSS Removals of Candidate Technologies....... 15-14 

Table 15-10. BOD & TSS Cost Test Part One - POTW Test Results.................................... 15-15 

Table 15-11. BOD & TSS Cost Test Part Two – Industry Cost Test Results ........................ 15-16 

Table 15-12. 2003 CAFO Rule BPT Costs and FC Removals............................................... 15-17 

Table 15-13. Incremental Costs and FC Removals of Candidate Technologies .................... 15-17 

Table 15-14. Alternative Cost Test Part One - POTW Test Results ...................................... 15-18 

Table 15-15. Alternative Cost Test Part Two – Industry Cost Test Results........................... 15-18 

vi 
Chapter 1 

INTRODUCTION 

This document is an addendum to the Development Document for the Final Revisions to the 

National Pollutant Discharge Elimination System Regulation and the Effluent Guidelines for 

Concentrated Animal Feeding Operations (EPA-821-R-03-001), referred to as the Technical 

Development Document or TDD, which was prepared in support of effluent limitations 

guidelines and standards for Concentrated Animal Feeding Operations (CAFOs), published 

February 12, 2003 (68 FR 7176). On February 28, 2005, the Second Circuit Court of Appeal 

issued its decision to remand several elements of the 2003 CAFO rule related to new sources and 

Best Conventional Pollutant Control Technology (BCT) and directed EPA to further review and 

clarify these rules. This addendum summarizes EPA’s findings. 

The final regulations in the 2003 Effluent Limitations Guidelines and Standards include revisions 

of two regulations that ensure manure, litter, and other process wastewaters for CAFOs do not 

impair water quality. These two regulations are the National Pollutant Discharge Elimination 

System (NPDES) and the Effluent Limitations Guidelines and Standards (ELGs) for feedlots 

(beef, dairy, swine, poultry, and veal), which establish the technology-based standards that are 

applied to CAFOs. Both regulations were originally promulgated in the 1970s. EPA revised 

these regulations in 2003 to address changes that have occurred in the animal industry sectors 

over the last 25 years, to clarify and improve implementation of CAFO permit requirements, and 

to improve the environmental protection achieved under these rules by ensuring effective 

management of manure by primarily the largest CAFOs. EPA did not revise the ELG for the 

horse, sheep and lamb, or duck subcategories. In establishing these regulations, EPA evaluated 

several different technology options for implementation at CAFOs, which are summarized in 

Table 1-1. 

This document presents the methodology and calculations used to evaluate the court remanded 

issues of NSPS requirements and BCT standards for pathogens. The chapter, section, and page 

numbers of this TDD Addendum are designed to fold into and continue from the original TDD 

document. Section 2.3 is a continuation of Chapter 2 in the original TDD, which discusses the 

court decision and EPA’s proposed regulation for NSPS and BCT. Section 8.6 is a continuation 

of Chapter 8 in the original TDD, which discusses treatment technologies that were evaluated for 

pathogen control. Chapter 15 is a new chapter that describes the additional analyses that EPA 

conducted in response to the 2005 Second Circuit Court decision. 

1-7 
Table 1-1. Regulatory Options for CAFOs that EPA Considered for the 2003 Rule 

Option 

Number Description 

1 Zero discharge from a facility designed, maintained, and operated to hold manure, litter, and other process 

wastewater, including direct precipitation and runoff from a 25-year, 24-hour rainfall event. This option 

includes implementation of feedlot best management practices, including stormwater diversions; lagoon 

and pond depth markers; periodic inspections; nitrogen-based agronomic application rates; elimination of 

manure application within 100 feet of any surface water, tile drain inlet, or sinkhole; mortality handling, 

nutrient management planning, and recordkeeping guidelines. 

1A The same elements as Option 1, with the addition of storage capacity for the chronic storm event (10-year, 

10-day storm) above any capacity necessary to hold manure, litter, and other process wastewater, 

including direct participation and runoff from a 25-year, 24-hour rainfall event. 

2 The same elements as Option 1, except nitrogen-based agronomic application rates are replaced by 

phosphorus-based agronomic application rates when dictated by site-specific conditions. 

3A/3B The same elements as Option 2, plus Option 3A facility costs include an assessment of the ground water’s 

hydrologic link to surface water; Option 3B facility costs include ground water monitoring, concrete pads, 

synthetically lined lagoons and/or synthetically lined storage ponds. 

3C/3D The same elements as Option 2, plus permeability standards for lagoons and storage ponds, which may 

include costs for synthetically lined lagoons and ponds. 

4 The same elements as Option 2, plus costs for additional surface water monitoring. 

5 For swine, poultry, and veal operations only, the same elements as Option 2, but is based on zero 

discharge with no overflow under any circumstances (i.e., total confinement and covered storage). 

5A For beef, dairy, and heifer operations only, the same elements as Option 2, plus implementation of a drier 

manure management system (i.e., composting). 

6 For the Large swine and dairy operations only, the same elements as Option 2, plus implementation of 

anaerobic digestion with energy recovery. 

7 The same elements as Option 2, plus timing restrictions on land application of animal waste to frozen, 

snow-covered, or saturated ground. 

1-8 
Chapter 2 

SUMMARY AND SCOPE OF PROPOSED REGULATION 

The proposed regulations described in this document include revisions to the ELGs promulgated 

for CAFOs on February 12, 2003 (68 FR 7176). Section 2.3.1 describes the proposal related to 

NSPS and Section 2.3.2 describes the proposal related to BCT for the control of pathogens. 

2.3 Summary of the Second Circuit Court Decision Concerning Remanded Issues 

The Second Circuit Court of Appeals remanded several elements of the 2003 CAFO rule related 

to new sources. Specifically, the court directed EPA to clarify the basis for allowing subpart D 

CAFOs to comply with the NSPS requirements by either the 100-year storm standard or the 

alternative performance standards. With respect to the 100-year storm standard, the Court noted 

that while certain studies showed that the production area Best Management Practices (BMPs) 

adopted by the 2003 CAFO rule would have substantially prevented the production area 

discharges documented in the record, the court explicitly stated that substantially preventing 

discharges is not the same as prohibiting them outright. With respect to the alternative 

performance standards, the court held that EPA had not justified its decision to allow compliance 

with the no discharge standard through an alternative standard permitting production area 

discharges so long as the aggregate pollution to all media is equivalent to or lower than the 

baseline standards. The court further held that EPA did not provide adequate notice for either of 

these provisions under the CWA’s public participation requirements. See 33 U.S.C. § 1251(e) 

(“Public participation in the development, revision, and enforcement of any regulation, standard, 

effluent limitation, plan, or program established by the Administrator or any State under this Act 

shall be provided for, encouraged, and assisted by the Administrator and the States”). 

The Second Circuit Court of Appeal also remanded the 2003 CAFO rule’s BCT standard for 

pathogens. In the court’s view, the 2003 CAFO rule violated the CWA because EPA did not 

make an affirmative finding that the BCT-based ELGs adopted in the CAFO rule do in fact 

represent the best conventional pollutant control technology for reducing pathogens – 

specifically, fecal coliform bacteria (FC). The court noted that EPA may well determine that the 

ELGs otherwise adopted by the CAFO rule do in fact represent the best conventional pollutant 

control technology for reducing pathogens. The court further noted that EPA may determine, 

after considering all the relevant factors, that the ELGs otherwise adopted by the 2003 CAFO 

rule will directly – not just incidentally – reduce pathogens and do so better than any other 

pollutant control technology. 

2.3.1 Proposed Regulation of NSPS 

The CWA requires EPA to promulgate NSPS for new, as opposed to already existing, sources of 

pollution. See 33 U.S.C. § 1316. The Act provides that these standards must “reflect the 

greatest degree of effluent reduction which the Administrator determines to be achievable 

through application of the best available demonstrated control technology, processes, operating 

methods, or other alternatives, including, where practicable, a standard permitting no discharge 

of pollutants.” 33 U.S.C. § 1316(a)(1). The Act further requires that the EPA “take into 

2-17
consideration the cost of achieving such effluent reduction, and any non-water quality, 

environmental impact and energy requirements.” 33 U.S.C. § 1316(b)(1)(B). EPA is given 

considerable discretion to weigh and balance the various factors required by statute to set NSPS. 

Waterrkeeper Alliance, Inc., et al. v. EPA, 358 F. 3d 174, 195 (2d Cir. 2004). 

EPA proposed that the NSPS for the production areas of swine, poultry, and veal CAFOs include 

a total prohibition on production area discharges. In the Final Rule, however, the EPA changed 

course in several respects: (1) The NSPS still barred all production area discharges, but provided 

that a CAFO could comply with this requirement by designing, constructing, operating and 

maintaining production areas that could “contain all manure, litter, and process wastewater 

including the runoff and the direct precipitation from a 100-year, 24-hour rainfall event;” and (2) 

the NSPS empowered permitting authorities to establish alternative performance standards that 

allow production area discharges, so long as such discharges were accompanied by “an 

equivalent or greater reduction in the quantity of pollutants released to other media” by the 

CAFO. The court determined that there was not adequate support in the record for either of 

these decisions. This section discusses EPA’s analysis for the proposed changes to NSPS. 

2.3.1.1 100-Year Storm Containment Structure 

EPA proposes to delete 40 CFR 412.46(a)(1), the provision allowing CAFOs to meet the no 

discharge standard through the use of the 100-year, 24-hour rain event containment structure. By 

doing so, the production area requirements for new source swine, poultry, and veal calf 

operations sources would be no discharge of manure, litter, and process wastewater. The land 

application requirements would remain unchanged. EPA recognizes that a depth marker can be 

an excellent means of displaying how much storage a CAFO has, and whether it is time to pump 

down levels in the lagoon. Depth markers are a useful tool to help with the management of any 

facility. 

EPA proposes a compliance alternative for facilities with open manure storage structures to meet 

the no discharge requirements. Specifically, EPA is proposing a modeling approach by which 

facilities could demonstrate that their proposed system would comply with the no discharge 

requirements. If a facility complied with the specified site-specific design, construction, 

operation, and maintenance components of the modeled manure storage structure, it would be 

deemed to be in compliance with the no discharge requirement. 

2.3.1.2 Superior Alternative Performance Standards 

EPA proposes to delete 40 CFR 412.46(d) and remove the voluntary superior performance 

standards provision for new swine, poultry, and veal sources. The court ruling states that EPA 

cannot establish production area standards that substantially prevent discharges as equivalent to 

standards that prohibit discharges outright. In accordance with this ruling, EPA is proposing to 

withdraw this provision. 

2.3.2 Proposed Regulation of BCT for Pathogen Control 

EPA evaluated various candidate technologies to assess whether they are technologically feasible 

for all facilities in a subcategory and would achieve greater reductions of FC than the 

2-18
technologies selected as the basis for BPT in the 2003 rule. Specifically, EPA estimated 

pathogen reductions associated with technology Options 3, 5, 6 and 7, described in Table 1-1 and 

discussed in the 2003 docket. These regulatory options were evaluated despite EPA’s previous 

determinations of technical infeasibility, disproportionately high costs, and low affordability 

because these options may provide more reductions of pathogens than the option selected for the 

final 2003 CAFO ELGs. EPA did not consider Options 1 and 4 because they do not provide any 

further conventional pollutant reductions than the final selected Option 2. EPA also evaluated 

additional candidate technologies for pathogen reductions: fluidized bed incinerators; 

composting for poultry; chemical addition for disinfection; and additional storage to comply with 

national prohibitions of land application to frozen, saturated, or snow-covered ground (Option 7) 

for the swine industry (Option 7 for the beef and dairy industries was already presented in 2003). 

See Chapter 5 for a description and discussion of the evaluated technologies. 

EPA conducted the BCT cost-reasonableness test for those technology options determined to be 

feasible. EPA found that none of these candidate technologies would pass either part of the BCT 

cost test, noting the BCT cost test explicitly addresses the conventional pollutants TSS and BOD. 

See Chapter 4 for a description of the BCT cost test analysis. Therefore, EPA believes that any 

combination of these technologies developed into a regulatory option for a subcategory would 

also not pass the BCT cost test. For example, suppose technology A is practical for dry poultry 

facilities, but is not practical for wet poultry facilities. Technology B is practical for wet poultry 

facilities, but is not practical for dry poultry facilities. Both technologies are necessary to create a 

technology basis for the entire poultry category. If both technology A and technology B fail the 

BCT cost test, then a technology option developed for the poultry category comprised of 

technology A for dry facilities and technology B for wet facilities would also fail the BCT cost 

test. 

EPA also evaluated an alternative approach to conducting the two-part cost test that explicitly 

addresses FC. Section 15.2.3 presents the results of applying this alternative cost test to the 

candidate BCT technology options considered. None of the candidate technology options pass 

the alternative BCT cost test. 

2.4 References 

Waterkeeper Alliance, Inc. et al. v. EPA, 358 F. 3d 174, 195 (2d Cir. 2004). 

Waterkeeper Alliance, Inc. et al. v. EPA, 399 F. 3d 486 (2d Cir. 2005). 

2-19
Chapter 8 

TREATMENT TECHNOLOGIES AND BEST MANAGEMENT PRACTICES 

8.6 Treatment Technologies and Practices Evaluated for Pathogen Control 

This chapter provides a description of additional treatment technologies and best management 

practices (BMPs) specifically identified by EPA for the reduction of FC and other pathogens. 

These technologies, including digesters, fluidized bed incinerators, chemical addition for 

disinfection, composting, and deep stacking of poultry litter, were considered by EPA as the 

bases for BCT options in addition to the technology options evaluated for the 2003 CAFO rule 

(described in Table 1-1 of this document). 

Section 8.6.1 provides a description of each of the new technologies considered. Section 8.6.2 

presents the estimated engineering compliance costs associated with implementing the BCT 

regulatory options. More detailed information on the cost methodology used for options 

identified in the 2003 rule is contained in the Cost Report. 

Section 8.6.3 presents an estimation of the pollutant load reductions associated with the 

implementation of each option. EPA’s assessment incorporated pollutant loadings from feedlots 

and manure storage structures, representing discharges from AFO production areas. These 

discharges generally include runoff from the feedlot or manure storage areas due to precipitation 

events, but also include, where actual discharge data was available, a limited number of 

discharges attributed to storage system failures and improper management. The loadings also 

include edge-of-field pollutant loadings from cropland where animal manure, litter, and process 

wastewater is applied. More detailed information on the loads methodology used for options 

identified in the 2003 rule is contained in the Pollutant Loading Reductions for the Revised 

Effluent Limitations Guidelines for Concentrated Animal Feeding Operations (2002) (i.e., 

“Loads Report”). 

8.6.1 Descriptions of Technology Options 

This section provides a description of the new technology options EPA considered for BCT as 

part of this proposed rule. EPA also evaluated Options 3, 5, 5A, 6, and 7 for the control of 

conventional pollutants. These options, identified in the 2003 rule and described in Table 1-1, 

potentially provide pathogen reduction beyond that of the BPT option (Option 2). 

In support of this proposed rule, EPA reevaluated Option 6 (anaerobic digestion) to focus on a 

technology basis and design that would optimize pathogen removal, specifically mesophilic 

digestion. EPA identified the design basis for this technology, and estimated the cost to 

implement the technology, and the expected load reductions. 

EPA also evaluated two new technology options not previously considered as BPT candidate 

technologies, but considered here because of their potential in reducing pathogens: lime addition 

to dairy manure, and composting of poultry litter. To be thorough, EPA evaluated the costs and 

8-232 
load reductions associated with these technologies, despite EPA’s previous determinations of 

their technical infeasibility, disproportionately high costs, and low affordability. 

Finally, EPA reviewed several other technologies that were determined to not be viable 

technology options: fluidized bed incinerators, chemical addition for disinfection (including 

chlorine, calcium hypochlorite, sodium hypochlorite, and ozone), and deep stacking of poultry 

litter. These technologies are described in this section, but were not included in the cost or loads 

calculations because they are not technically feasible for this industry. 

8.6.1.1 Anaerobic Digestion 

EPA included a digester option in the BCT cost test for those species where the technology is 

most likely to be feasible - Large dairy and swine facilities (see the AgSTAR handbook for more 

information, EPA Docket OW-2005-0037, DCN 1-01215). Sections 8.6.2.1 and 8.6.2.2 present 

the cost calculation methodologies used to represent this option. The option includes 

construction of a mesophilic digester (either a heated covered-lagoon digester, plug flow, or 

complete mix digester, with biogas recovery) prior to manure storage. Treated manure is stored 

in the CAFO’s existing manure storage facility. Treated manure is assumed to be land applied 

consistent with the BPT requirements of 40 CFR 412. 

There are three basic temperature regimes for anaerobic digestion: psychrophilic, mesophilic, 

and thermophilic. Psychrophilic, or low-temperature, digestion is a natural decomposition 

process at temperatures typically found in lagoons. The hydraulic retention time for stable 

operation varies from 30 days to 90 days depending on temperature. Mesophilic digestion 

reduces the retention period to 12 to 20 days. In some limited cases digesters were shown to 

reduce FC by as much as 99 percent, particularly by thermophilic (higher temperatures in the 

range of 135 to 155 degrees Fahrenheit) digestion, but regrowth of both FC and other pathogens 

was shown to occur during effluent storage. (68 FR 7217) EPA did not receive any public 

comments or data during the 2003 rulemaking process that provided a reliable means of 

quantifying this regrowth. Most importantly, a digester does not eliminate the need for the 

CAFO to have liquid impoundments for process wastewater, treated wastewater, and storm water 

runoff. 

EPA assumes a mesophilic (heated) digester system will reduce FC of the stored manure by 99 

percent (a 2 log-order reduction). EPA’s digester option costs include cost-offsets due to biogas 

recovery and energy recovery, and a new storage pond for effluent storage if the CAFO did not 

already utilize liquid storage structures. The resources for a mesophilic digester designed to 

target pathogen reduction are expected to be higher than a digester designed to stabilize manure 

and produce biogas. In particular, CAFO operators are highly unlikely to have the experience 

and technical expertise for start-up, troubleshooting, and routine diagnostics to ensure the 

digester is operating as intended. Therefore EPA’s costs also include annual technical 

consultation and services necessary to assure effective digester system operation, optimal biogas 

generation, and energy recovery. The total incremental costs and pollutant reductions of this 

option are presented in Tables 15-8 and 15-12. 

Digesters do not reduce the total nutrients in animal wastes. Most of the phosphorus removed 

from the effluent is concentrated in the digested solids, which are still subject to land application 

8-233 
requirements. Other data show that changes in pollutant composition, particularly the soluble 

forms of nitrogen, could result in increased discharges of pollutants following land application of 

digested manure, specifically ammonia releases and other emissions. Similarly, metals are not 

reduced and remain in the digester effluent and solids. 

Digestion may also be conducted aerobically, but this variation is rarely seen at CAFOs due to 

process problems, design challenges, high energy requirements, and disproportionately high 

costs (See Table 8-14 of the TDD for a list of aerobic digestion and activated sludge processes). 

8.6.1.2 Lime Addition 

Lime addition may be used as a disinfectant for barn and milking parlors and other animal 

wastes. Lime addition is a proven treatment technology for Class A and Class B biosolids 

standards. To meet Class B requirements using lime stabilization, the pH of the biosolids must 

be elevated to more than 12 for 2 hours and subsequently maintained at more than 11.5 for 22 

hours. The material also needs to be kept at high temperature (70 Celsius) for at least 30 

minutes, which would require outside heating of the material to be treated. 

Section 8.6.2.3 presents a cost estimate for lime treatment of dairy manure. Data presented in 

Section 8.6.2.3 demonstrate that the capital costs for holding tanks, dosage tanks, mixing 

equipment, and neutralization tanks necessary for retrofitting this technology at CAFOs are high. 

The addition of lime results in an increase in sludge volume, although lime stabilization 

generally requires less space than treatment alternatives such as composting. Most highmoisture CAFO wastes would require some sort of digestion and/or dewatering prior to 

stabilization. EPA believes additional costs for operator training, safety controls, chemical 

purchases, and increased volume of materials that must be hauled and land applied may be 

another reason the technology has not been adopted by CAFOs given the successful application 

of lime addition to biosolids. The addition of lime to organic wastes in general has been shown 

to accelerate ammonia emissions. 

8.6.1.3 Composting of Poultry Manure or Litter 

Composting is used at animal feeding operations to biologically stabilize and dry waste for use 

as a fertilizer or soil amendment. Composting is an aerobic process in which microorganisms 

decompose organic matter into heat, water, carbon dioxide, and a more stable form of organic 

matter—resulting in a relatively uniform, dry, odorless end product that can be used as a soil 

amendment. The elevated temperature in the interior of a properly operated compost pile kills 

weed seeds, pathogens, and fly larvae. Because composting is an aerobic process, a continuous 

supply of oxygen must be available for the microorganisms to break down the organic matter. 

Composting time and efficiency are affected by the amount of oxygen, the balance of carbon and 

nitrogen in the raw materials, the moisture content, and the particle size and the porosity of the 

materials. Five basic approaches to composting are (1) the passive pile approach, (2) windrow 

composting using a loader for turning, (3) windrow composting using specialized windrow 

turners, (4) aerated static pile systems, and (5) in-vessel systems. 

The effectiveness of the technology is weather dependent, and for Large CAFOs generating 

substantial quantities of manure, the technology requires a large amount of land, requires 

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additional runoff controls and wastewater storage, and imposes a much operating higher cost on 

CAFOs. (TDD, p. 8-102 to 8-110; Cost Report, Section 5.12) However, windrow composting is 

applicable at a much wider range of CAFOs, and was included in technology Option 5A for beef 

and dairy operations in the 2003 rule. Composting is also a practical technology for incremental 

pathogen removals at most poultry operations. 

EPA evaluated a windrow composting option for poultry manure/litter in the BCT cost test. 

Similar to the digesters option, EPA conservatively estimates that composting reduces FC by 99 

percent. Costs for the poultry composting option include: 

y Planning; 

y Compost amendments (including water); 

y Land rental for the composting area; 

y Equipment for windrow turning (capital and operation & maintenance) and compost 

monitoring; 

y Labor for windrow turning and monitoring (temperature and moisture content); 

y Solids separation equipment for wet layer operations; and 

y Storage pond installation and irrigation costs for dry layer, broiler, and turkey operations. 

Section 8.6.2.4 provides a detailed explanation of the windrow composting option and 

methodology used to calculate costs for applying composting technology to poultry operations. 

8.6.1.4 Fluidized Bed Incineration 

Fluidized bed incineration is a proven technology for reducing waste volume and for converting 

the waste to useful products (e.g., energy, nutrient enriched ash), and is being used at municipal 

waste disposal facilities. However, even at municipal operations, incineration can be a costly 

method of disposal and frequently requires co-combustion with other feedstocks. 

In addition, incinerators are not widely used in the United States to manage animal manure 

because it is generally not affordable to individual CAFOs. Application of this technology has 

been attempted by a beef feedlot in the U.S., but failed because the incinerator thermal output 

could not be sustained (TDD, page 8-93 to 8-95). Fluidized bed incinerators are also sensitive to 

moisture content and fuel particle size, limiting incinerator effectiveness to those wastes that 

have a more consistent composition and contain no more than 15-20 percent moisture. 

EPA has not been able to identify cattle or swine CAFOs that have successfully implemented the 

technology. Individual poultry CAFOs in the U.S. do not currently use incineration as a method 

of handling excess poultry litter, although centralized incinerator projects have been successfully 

developed in the European Union in selected geographic areas with a high density of poultry 

operations, and several similar systems have been proposed in the U.S. These centralized 

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incinerators reduce pathogens in the litter. However, large-scale, centralized incineration plants 

have not yet successfully translated into feasible, smaller-scale units for individual CAFO use. 

(See Chapter 8 of the TDD.) 

It is also possible to gasify manure solids on-farm, but this technology is still in the pilot stage. 

EPA is aware of a demonstration project that heats the manure in a refractory oven, and where 

the gasses are used to replace propane in a mortality handling system. EPA is not aware of any 

individual CAFOs using incineration due to fuel costs, the high capital costs of the incineration 

unit, and the inability to sustain the technology for most animal manures. EPA therefore rejects 

this technology as practical for individual CAFOs. 

8.6.1.5 Other Chemical Addition Technologies 

Methods of disinfection include chemical addition, heat, mechanical methods, and radiation. 

Various types of chemical addition for the purpose of disinfection were reviewed but not selected 

as part of a technology option in the 2003 CAFO rule. (See Chapter 8 of the TDD for more 

information). Commonly used disinfection technologies in the U.S. include the addition of 

chemicals such as chlorine, calcium hypochlorite, sodium hypochlorite, lime, and ozone. 

Chlorination has a history of select pathogen destruction effectiveness and is relatively 

inexpensive when used as a polishing step for final incremental removal of pathogens. However, 

organic compounds present in typical CAFO wastewater can combine with chlorine to form 

chloroform (a documented animal carcinogen), monochloramines, and other toxic chloro-organic 

compounds. Accordingly, the Occupational Safety and Health Administration (OSHA) 

established intensive training and safety measures for chlorine use (EPA Docket OW-2005-0037, 

DCN 1-01198). Chlorine dioxide is widely used as an alternative bactericide, but requires 

expensive generating equipment, and produces chlorate and chlorite as potentially undesirable 

by-products. Chemical addition is not commonly practiced in the United States for treatment of 

animal wastes. In order for chlorination to be optimally effective and to minimize the generation 

of chlorinated by-products, the treated wastewater should have low levels of suspended solidsgenerally 30 to 50 mg/l or less. Therefore, to implement chlorine-based disinfection, animal 

wastewater would require primary and/or biological treatment prior to disinfection. Storage 

tanks, dosage control equipment, and mixing equipment would need to be retrofitted. The 

capital investment to modify a typical CAFO’s existing manure management system will be 

costly and clearly requires higher levels of maintenance and operator skill. 

Ozone is a highly effective germicide against a wide range of pathogenic organisms, including 

bacteria, protozoa, and viruses. Ozone use in U.S. wastewater treatment is limited due to high 

capital and operating costs and intensive energy requirements. Ozonation, like chlorination, 

requires a wastewater that has relatively low levels of solids to avoid regrowth of 

microorganisms after disinfection and reduce added cost associated with oxidizing oxygen 

demanding solids. Ozone disinfection technology is not commonly practiced in the United 

States for treatment of animal wastes. The processes are costly and require higher levels of 

maintenance and operator skill. Ozone disinfection efficiency depends on a pH 6-10 and 

temperature of at least 36 degrees Fahrenheit. (TDD, p. 8-117) To implement this technology, 

animal wastewater would require primary and/or biological treatment prior to disinfection (EPA 

Docket OW-2005-0037, DCN 1-01198). Therefore, EPA rejected ozonation as practical due to 

undesirable disinfection by-products, high operation and maintenance requirements, high 

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operator skill, considerable worker safety concerns, and overall high costs. For the above 

reasons, EPA finds that all of these chemical addition technologies are not practical for 

individual CAFOs. 

8.6.1.6 Deep Stacking of Poultry Litter 

Deep stacking consists simply of piling litter in a conical pile or stack after it is removed from a 

poultry house and raising the temperature to a maximum of 140 Fahrenheit (60 Celsius) by 

microbes. As with anaerobic digestion, incineration, and in some cases chemical addition, the 

heat (high temperature) reduces pathogens. Although the practice of deep stacking poultry litter 

enhances its potential value as a feedstuff for ruminants by reducing concern about possible 

pathogen transmission, the poultry litter cannot be considered pathogen free. The stacked litter is 

not mixed out of concern that re-aeration will create the potential for excessive heating. Thus, 

outer regions of the deep stacked litter do not reach the temperatures necessary for pathogen 

destruction. 

In practice, deep stacking may be considered a specialized approach to composting in which 

oxygen availability limits the overall temperature and the degree to which dry matter (“volatile 

solids” or “VS”) are destroyed. (TDD, p. 8-131 to 8-132) Due to the lack of reliable data on the 

overall effectiveness of the technology in reducing FC, the operational similarities to windrow 

composting (an option already evaluated; see Section 8.6.1.3), and limited applications to limited 

types of poultry CAFOs, EPA rejects deep stacking as practical for consideration as a BCT 

candidate. 

8.6.2 Technology Cost Calculations 

EPA estimated industry costs for Options 2, 3, 5, 5A, and 7, based on costs developed for the 

2003 CAFO rule using the methodology presented in the Cost Report. Estimation of these costs 

began by identifying the practices and technologies that could be used to meet a particular set of 

regulatory requirements. The Agency then developed a cost model to estimate costs for their 

implementation. 

EPA used the following approach to estimate compliance costs for the CAFOs industry: 

EPA collected data from published research, meetings with industry organizations, discussions 

with USDA cooperative extension agencies, review of USDA’s Census of Agriculture data, and 

site visits to swine, poultry, beef, veal, and dairy CAFOs. These data were used to define model 

farms and to determine waste generation and nutrient concentration, current waste and nutrient 

practices, and the viability of waste management technologies for the model farms. 

EPA identified candidate waste and nutrient management practices and grouped appropriate 

technologies into regulatory options. These regulatory options serve as the bases of compliance 

cost and pollutant loading calculations. 

EPA developed technology frequency factors to estimate the percentage of the industry that 

already implements certain operations or practices required by the regulatory options (i.e., 

baseline conditions). 

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EPA differentiated between the top 25 percent and bottom 25 percent of performers. This is 

identified as “Performance Needs” and receives a value of low, medium, or high (L, M, or H). 

This part of the costing methodology addresses the concern that all CAFOs are average 

performers and all incur an average cost. This methodology, when combined with frequency 

factors, results in some CAFOs having little or no costs, some CAFOs having high or full costs, 

and some CAFOs incurring moderate costs. 

EPA developed cost equations for estimating capital costs, initial fixed costs, and 3-year 

recurring costs, 5-year recurring costs, and annual O&M costs for the implementation and use of 

the different waste and nutrient practices targeted under the regulatory options. Cost equations 

were developed from information collected during the site visits, published information, vendor 

contacts, and engineering judgment. 

EPA developed and used computer cost models to estimate compliance costs and nutrient loads 

for each regulatory option. 

EPA used output from the cost model to estimate total annualized costs and the economic impact 

of each regulatory option on the CAFOs industry (presented in the Economic Analysis). 

Table 8-28 presents the regulatory options and the waste and nutrient management components 

that make up each option. 

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Table 8-28. Summary of Regulatory Options for CAFOs 

Technology or Practice 

Options 

1 1A 2 

3A/ 

3B 

3C/ 

3D 4 5 5A 6 7(d) 

Feedlot best management practices (BMPs), including 

storm water diversions, lagoon/pond depth markers, • • • • • • • • • • 

periodic inspections, and records 

Mortality handling requirements (e.g., rendering, 

composting) (a) • • • • • • • • • • 

Nutrient management planning and recordkeeping (sample 

soils once every 3 years, sample manure twice per year) • • • • • • • • • • 

Land application limited to nitrogen-based agronomic 

application rates 

• • 

Land application limited to phosphorus-based agronomic 

application rates where dictated by site-specific conditions, • • • • • • • • 

and nitrogen-based application elsewhere 

No manure application within 100 feet of any surface 

water, tile drain inlet, or sinkhole 

• • • • • • • • • • 

Ground water requirements, including assessment of 

hydrologic link, monitoring wells (four per facility), 

impermeable pads under storage, impermeable • 

lagoon/pond liners, and temporary/modified storage during 

upgrade 

Ground water requirements including performance based • standards for lagoons 

Additional capacity for 10-year, 10-day chronic storm • 

event 

Surface water monitoring requirement, including four total 

grab samples upstream and downstream of both feedlot 

and land application areas, 12 times per year. One • 

composite sample collected once per year at stockpile and 

surface impoundments. Samples are analyzed for nitrogen, 

phosphorus, and total suspended solids. 

Drier manure technology basis (b)(c) • • 

Anaerobic digestion • 

Timing requirements for land application (resulting in • regional variation in storage periods) 

(a) There are no additional compliance costs expected for beef and dairy operations related to mortality handling 

requirements. 

(b) Option 5 mandates “drier waste management.” For beef feedlots and dairies, this technology basis is composting. 

For swine, poultry and veal operations, drier systems include covered lagoons. 

(c) Option 5A mandates “no overflow” systems. For swine operations, the technology basis is high-rise housing for 

hogs, and for poultry operations the technology basis is dry systems. 

(d) EPA modified the cost estimations for Option 7 costs to 12 month storage for northern facilities 

EPA additionally estimated industry costs for lime disinfection at Large dairy operations, 

anaerobic digestion optimized for pathogen reduction at Large swine and dairy operations (i.e. 

recalculated Option 6), and windrow composting at Large poultry operations (Option 5A for 

poultry). Section 8.6.2 describes the cost estimating methodology EPA used for each of these 

technology options. 

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8.6.2.1 Anaerobic Digestion for Pathogen Reduction at Large Dairy Operations 

EPA investigated the technical applicability, costs, and FC reductions associated with anaerobic 

digestion with a focus on pathogen reduction at Large dairy operations. Some anaerobic digester 

systems are capable of treating CAFO wastes at elevated temperatures, resulting in a decrease in 

pathogenic microorganism numbers, while converting the volatile solids into reusable energy. 

Section 8.6.2.1 provides a description of two model dairy CAFOs with different manure removal 

methods (flush and scrape) and the associated wastes (manure, wash water, flush water, runoff, 

etc) used to size and cost an anaerobic digester system, the cost calculation methodology and 

total costs to the industry, and FC loads associated with this technology. 

Model Farms 

EPA developed two model farms to represent Large dairy operations in the United States: a flush 

dairy and a scrape dairy. Scrape and flush dairies were previously costed for anaerobic digestion 

for the final CAFO regulation as described in EPA’s Cost Report. EPA’s previous costing 

efforts assumed that flush dairies use a covered lagoon system following a settling basin, and 

scrape dairies use a complete mix digester following a settling basin. However, these 

assumptions were based on the optimal influent solids content of each digester rather than their 

pathogen reduction capability. A covered lagoon system is not heated and is therefore not 

considered a technology that adequately reduces pathogen levels. The complete mix and plug 

flow digester systems are heated and are best suited for pathogen reduction. To account for 

pathogen reduction, EPA assumed that flush dairies use a complete mix digester and scrape 

dairies use a plug flow digester. 

For costing purposes, the representative location used for the Large dairy farms is Tulare County, 

California. The costs of digester systems for scrape and flush dairies were calculated for a range 

of farms containing 850, 1500 and 2500 dairy cows. Each farm is assumed to have both calves 

and heifers. Based on data and assumptions previously presented in the Cost Report: 

y The number of calves and heifers on site was assumed to equal 60 percent of the dairy 

cows, with each animal accounting for 30 percent; 

y The dairy cows spend 4 hours in the milking parlor and 20 hours in the free stall barn; 

and 

y The heifers and calves spend the entire time in a dry lot. 

Cost Methodology 

During the development of the CAFOs effluent guidelines, several regulatory options were 

considered. Regulatory Option 6 stated that “for Large swine and dairy operations only, the 

same elements as Option 2, plus implementation of anaerobic digestion with energy recovery” 

should be evaluated. Therefore, Option 6 costs will be evaluated as the cost of the digester 

systems plus the costs to implement Option 2. The cost of implementation of anaerobic 

digestion without energy recovery will also be evaluated for comparison. There is no concern of 

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double counting lagoon costs because lagoons costs are not included in Option 2 costs for Large 

Dairy farms as described in the Cost Report. 

To estimate the total industry cost of dairy anaerobic digestion, EPA performed the following 

steps: 

1. EPA estimated the anaerobic digestion costs for scrape and flush dairies with 850, 1500, 

and 2500 head using FarmWare Version 2. This is the same version of FarmWare that 

was used for EPA’s previous costing efforts. The anaerobic digestion costs were 

estimated for two different scenarios: with energy recovery and without energy recovery. 

The costs were estimated on an annual basis. 

2. Operation and maintenance costs were estimated for anaerobic digestion for both scrape 

and flush dairies by calculating a weighted average of the different size operations. 

3. The weighted average FarmWare costs were then annualized. 

4. EPA then added the annualized anaerobic digestion costs to the Option 2 annualized 

costs, which were calculated during the original rule development. 

The following sections describe the steps taken by EPA to calculate the total cost to industry for 

the implementation of anaerobic digester systems for Large dairy operations with and without 

energy recovery under regulatory Option 6. 

FarmWare 

EPA input data into FarmWare Version 2 to model three different sizes of scrape and flush 

dairies. The FarmWare program was developed by the AgSTAR Program (www.epa.gov/agstar) 

as a screening-level model to support decision making on whether a methane recovery facility 

could be integrated into an existing facility. FarmWare Version 2 is available publicly at: 

http://www.epa.gov/agstar/resources/handbook.html (and is also in EPA Docket OW-2005-0037, 

DCN 1-01203). The following list is a screen-by-screen summary of the inputs used to calculate 

the capital costs of anaerobic digestion using FarmWare. 

Site Location and Climate: FarmWare contains a database of the average monthly temperature 

and rainfall for every county in the US. Tulare County, California was selected from this 

database. This region of the country represents more large dairies than any other region in the 

country. The actual farm level costs may be lower or higher depending on average temperature 

and rainfall, but this approach is intended to provide an average national cost, not a facility 

specific cost. 

Farm Design: All farms were assumed to be freestall dairy farms. This assumption is consistent 

with the data presented in the Cost Report for Large CAFOs, as opposed to the farm design for 

AFOs or small farms. The manure collection method pick list was used to specify whether the 

farm was a flush or scrape barn. To specify a flush barn the “Flush Everything” option was 

selected and to specify a scrape barn the “Flush Parlor and Scrape Rest” option was selected. In 

order to select a digester system, the manure treatment/storage system must be specified as 

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“Methane Recovery Lagoon.” A settling basin was specified for both complete mix and plug 

flow digester systems. 

Livestock: Table 8-29lists the default animal weights used to calculate the manure and volatile 

solids (VS). 

Table 8-29. Animal Weights 

Animal Type Animal Weight (lbs) 

Lactating Cows 1,350 

Heifers 550 

Calf 350 

Facilities: The amount of time each animal type spends in each housing type as discussed earlier 

was applied in this FarmWare screen. 

Manure Management Train: For the flush dairy, process water is used for the parlor and the free 

stall barn. The amount of water used in each facility was calculated using the following 

equations and values from the Cost Report: 

Parlor Wastewater (gal/day) = 477.5 gal/day + (30 gal/cow-day × Number of Dairy Cattle) 

Barn Wastewater (gal/day) = 100 gal/day-cow × Number of Dairy Cattle 

The calculated wastewater values were input into the model and a flush frequency of two was 

specified. A flush frequency of 2.5 was established as representative of the industry but 

FarmWare only recognizes whole numbers (EPA, 2002). This may result in underestimating the 

facility design (size), and may therefore understate capital costs. As the drylot is scraped, a 

mechanical scraper was specified for the manure collection. 

For the scrape dairy, process water is only used for the parlor. The amount of water used to flush 

the parlor was calculated using the following equation: 

Parlor Wastewater (gal/day) = 477.5 gal/day + (0.625 gal/cow-day × Number of Dairy Cattle) 

The same flush frequency of 2 was specified for scrape barns. A mechanical separator was 

selected for the free stall barn and the drylot. 

Both farms required an electric generator to recover the energy from the biogas produced. The 

unit was assumed to be running 90 percent of the time. This is the default value in FarmWare. 

EPA included additional O&M costs for a consultant who assists in maintaining the system at 

optimal levels throughout the system’s life. 

Energy Usage and Payments: To calculate the cost of electricity recovered each month, the 

national average unit price for electricity of 7.4 cents per kilowatt hour (kWh) and 90 cents per 

gallon of propane were used (USDOE, 1998). The maximum fraction of propane expenses that 

could be offset was assumed to be 90, which is the model default. 

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Anaerobic Digestion Costs for Large Dairy Operations 

Tables 8-30 and 8-31 present the output of the FarmWare model for the flush and scrape model 

dairies using the inputs described above. 

Table 8-30. FarmWare Flush Dairy Results 

Dairy Calf Heifer Capital Cost Annual Energy Benefit 

850 255 255 $746,585 $50,910 

1,500 450 450 $1,204,852 $87,780 

2,500 750 750 $1,896,021 $144,178 

Table 8-31. FarmWare Scrape Dairy Results 

Dairy Calf Heifer Capital Cost 

Annual Energy 

Benefit 

850 255 255 $323,495 $53,072 

1,500 450 450 $485,435 $89,939 

2,500 750 750 $728,269 $146,657 

Weighted Average of FarmWare Output 

In order to calculate one cost for Large scrape dairies and one cost for Large flush dairies, EPA 

calculated a weighted average of the costs with and without the energy benefits calculated in 

FarmWare. First, EPA estimated total operating and maintenance costs. FarmWare calculates 

an annual O&M cost for operating the generator but not maintaining the digester system as a 

whole. Based on a memorandum from the CAFO docket (EPA Docket OW-2002-0037, DCN 

00815), EPA assumed that the annual cost would equal 10 percent of the total capital cost. To 

account for the need for the farm operator to obtain on-going consulting support to operate the 

digester system at optimal levels, a special maintenance cost for technical consulting was added 

to the annual O&M cost. A 60-dollar per hour consulting fee was assessed for 6 hours per month 

(EPA Docket OW-2005-0037, DCN 1-02002). These operating and maintenance costs we used 

to calculate the total annual O&M costs with and without energy recovery using the following 

equations: 

Annual O&M costs ($/yr) with Energy Recovery = Operating Costs + Consulting Fees – Energy Benefit 

Annual O&M costs ($/yr) without Energy Recovery = Operating Costs + Consulting Fees 

To calculate one set of costs for Large scrape dairies and one set of costs for Large flush dairies, 

EPA used statistics from the United States Department of Agriculture (USDA) National 

Agricultural Statistics Service (NASS) to calculate weighted average farm sizes and counts. 

These data are listed in Table 8-32. 

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Table 8-32. U.S. Total NASS Large Dairy Farm Statistics 

Farm Size (# of head) Representative Size Number of Farms Percent of Farms 

700-999 850 1,020 48% 

1000-1999 1,500 770 36% 

2000+ 2,500 325 15% 

Total 2,115 100% 

By applying the percentage of representative farms to the costs calculated in FarmWare, the 

weighted average capital and O&M costs for flush and scrape dairy operations for the entire 

Large dairy category were calculated, as shown in Table 8-33. 

Table 8-33. Weighted Average FarmWare Capital and O&M Costs 

Farm Type Capital 

Annual O&M with 

Energy Recovery 

Annual O&M without 

Energy Recovery 

Flush $ 1,090,052 $ 36,424 $ 111,089 

Scrape $ 444,651 $ (34,326) $ 46,549 

Annualized Anaerobic Digestion Costs 

With the capital costs calculated in FarmWare and the O&M costs estimated as described above, 

the net present value (NPV) of the proposed project was calculated. The NPV was then used to 

calculate the total annualized cost of each model farm. The annualized costs for flush and 

scrape model farms are summarized in Table 8-34. The annualized costs were calculated based 

on the same annualization model used in the 2002 rule, which is documented in Section 2.2.4 of 

the Economic Analysis of the Final Revisions to the National Pollutant Discharge Elimination 

System Regulation and the Effluent Guidelines for Concentrated Animal Feeding Operations 

(EPA-821-R-03-002). The model uses a real discount/interest rate of 7 percent, as recommended 

by the Office of Management and Budget (OMB, 1992), which does not have to be adjusted for 

inflation. The life expectancy of the asset depends on the serviceable life of the structure as well 

as on the depreciable life, which affects what portion of a capital cost can be used each year to 

reduce taxable income. The Internal Revenue Service (IRS) rules govern the designation of 

depreciable life, which is assigned on the basis of serviceable life. Most of the types of capital 

investments required under these regulations are typically depreciated over 10 years (IRS, 

1999c). The cost annualization model thus incorporates a 10-year annualization period to 

compute annual costs. 

Table 8-34. Total Annualized Model Farm Costs for Flush and Scrape Operations 

Farm 

Annualized Cost w/ Energy 

Recovery 

Annualized Cost w/o Energy 

Recovery 

Flush $ 271,154 $ 345,418 

Scrape $ 51,329 $ 102,624 

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Industry Total Costs 

To obtain industry costs for Option 6, the annualized anaerobic digestion costs were added to the 

model farm costs for Option 2. (Option 2 costs totaled $128 million, as presented in Table 15-7.) 

The resulting model farms costs were multiplied by the number of facilities represented by each 

model farm and summed to obtain a total cost for Option 6 for the entire industry. EPA 

estimates that the total industry cost for the implementation of anaerobic digester systems at 

Large Dairy farms under Regulatory Option 6 will be $511 million with energy recovery and 

$619 million without energy recovery. 

8.6.2.2 Anaerobic Digestion for Pathogen Reduction at Large Swine Operations 

EPA calculated an anaerobic digester option for swine assuming no (zero) energy recovery or 

sales to represent a potential upper bound cost of this option. This scenario assumes the 

installation of a flare instead of the generator and therefore no energy recovery. (EPA Docket 

OW-2005-0037, DCN 1-02001) 

EPA used FarmWare v.2 to calculate anaerobic digestion costs for model farm Large swine 

operations from the 2003 final CAFO rule (68 FR 7243). These model farms were run in 

FarmWare with the following assumptions and modifications: 

y Used Sampson County, North Carolina as the representative MidAtlantic farm, Blue 

Earth, Minnesota as the Midwest farm, and Beaver County, Utah as the Central farm. 

y Assumed “flush everything” as the existing manure management system for liquid 

manure and evaporative ponds and “Pull Plug or Cascade Dam” for pit. 

y Reduced flush water to twice per day (33 percent reduction in flush water use) 

y Precipitation is diverted away from the digester, no runoff from lot areas is generated, 

and direct precipitation into the open (uncovered) effluent storage lagoon is captured 

y Used model default of $.06 per kWh (1999 U.S. average of 4.5 cents industrial use, 7.43 

cents commercial, and 8.27 cents residential) 

y Engineering costs of $25 thousand (FarmWare model default) was used for grow-finish 

facilities. Engineering costs for farrow-to-finish operations were increased to $40 

thousand to account for the increased complexity of the site that could affect digester 

construction and design (such as multiple confinement buildings, different building 

designs for each stage of animal, different waste generation rates and manure 

composition at each site) 

y Deep pit housing systems do not have a storage lagoon, so additional capital costs on the 

order of $30-50 thousand are incurred to construct an effluent holding structure, for an 

additional estimated $4,500 annual expense 

y Digester Cover Material: High Durability was selected in the FarmWare pulldown menu 

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y Generator cost was oversized by 10 KW, for an additional cost of $10,500 per CAFO 

(Farmware cost of generator is $1,050/KW) (See Cost report for the basis for this design) 

y Capital costs include a contingency factor of 5 percent to reflect site specific variations of 

the assumed digester design described above 

See Table 5.13.3-1 of the Cost Report for additional information. The results are presented in 

Table 8-35. 

Table 8-35. Digester Cost per Swine with Generator and Energy Recovery 

Manure Type Operation Type Region 

Total Cost 

($ per head) 

Annual Cost 

($ per head) 

Pit GF MA 47.99 (4.81) 

Pit GF MW 55.10 (4.21) 

Pit FF MA 47.79 (1.61) 

Pit FF MW 53.36 (1.70) 

Liquid GF MA 41.04 (4.77) 

Liquid GF MW 51.77 (4.20) 

Liquid FF MA 40.30 (1.62) 

Liquid FF MW 48.63 (1.71) 

Evaporative GF CE 40.20 (4.47) 

Evaporative FF CE 39.18 (2.00) 

These results were re-evaluated assuming no energy recovery and including a flare ($2,500 per 

CAFO; see Cost Report) instead of a generator. The results of this analysis are presented in 

Table 8-36. Costs include the compliance costs from Option 2 for land application, 

recordkeeping, reporting, and other costs incurred as a result of the 2003 rule. Cost offsets for 

energy recovery can be readily determined by comparing the costs presented in Tables 8-35 and 

8-36. 

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Table 8-36. Digester Cost per Swine without Generator or Energy Recovery 

Manure Type Operation Type Region 

Total Cost 

($ per head) 

Annual Cost 

($ per head) 

Pit GF MA 31.28 1.71 

Pit GF MW 38.64 1.50 

Pit FF MA 33.38 1.36 

Pit FF MW 39.13 1.21 

Liquid GF MA 24.42 1.69 

Liquid GF MW 35.34 1.50 

Liquid FF MA 25.95 1.35 

Liquid FF MW 34.42 1.21 

Evaporative GF CE 24.53 1.19 

Evaporative FF CE 25.69 0.90 

The next step was to estimate the total cost under Option 6 for the new scenario (no energy 

recovery and a flare) by multiplying model farm costs by the number of farms. Table 8-37 

shows a summary of the results and Appendix A has the detailed model farm results. These costs 

include consultation fees for dairies (as described in EPA Docket OW-2005-0037, DCN 1­

01128). 

Table 8-37. Summary of Results for the Modified Option 6 for Swine 

Animal 

Type 

Manure 

Type 

Operation 

Type Capital Annual Fixed 

3-Year 

Recurring 5-Year Recurring 

Chic Liquid LW $13,973,304 $1,463,489 $138,625 $21,729 $90,529 

Chic Solid BR $84,021,646 $3,406,773 $1,864,429 $71,074 $958,713 

Chic Solid LA $32,320,857 $1,896,668 $324,297 $46,202 $219,660 

Swine Evapor FF $31,883,745 $1,801,689 $128,481 $8,947 $79,291 

Swine Evapor GF $31,241,133 $2,215,633 $131,848 $9,180 $81,339 

Swine Liquid FF $213,681,593 $14,002,802 $821,738 $72,010 $6,479,157 

Swine Liquid GF $159,459,230 $12,421,397 $605,426 $54,106 $5,023,542 

Swine Pit FF $206,321,208 $23,085,413 $829,828 $66,532 $552,418 

Swine Pit GF $270,568,974 $34,886,081 $1,091,786 $88,524 $724,830 

Turk Solid SL $30,569,896 $2,767,751 $783,724 $33,539 $556,494 

Note: Values in the highlighted cells were forced to be the same as Option 2. 

8.6.2.3 Lime Addition to Dairy Manure 

Lime treatment increases both the pH and temperature of CAFO wastes, resulting in a decrease 

in pathogenic microorganism numbers, while converting a portion of the soluble phosphorous in 

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the waste stream to an insoluble calcium phosphate. Section 8.6.2.3 provides a description of 

two model dairy CAFOs with different manure removal methods (flush and scrape). These two 

models have different volumes of wastes (manure, wash water, flush water, runoff, etc) that are 

used to size and cost a lime disinfection system. For each model farm, this section provides a 

description of the necessary lime treatment system equipment, and the costs for each of the major 

lime disinfection system components. 

Model Dairy CAFO Description 

EPA developed two model farms to represent Large dairy operations in the United States: a flush 

dairy and a scrape dairy. The Large dairy lime disinfection models are assumed to be in the 

Midwest, since this region receives an average amount of rainfall as compared to other regions of 

the United States. Using an area of the country with average rainfall allows for a moderately 

sized reaction tank because the tank is sized to allow for manure and runoff from rainfall. Also, 

the soils in the Midwest area have typical curve numbers. This means that the soils have an 

average runoff potential which also allows for a moderately sized reaction tank. 

EPA’s Large Dairy model farm has 1,430 milk cows assumed to be housed in three free-stall 

barns. The model dairies are assumed to have a hospital barn, a milking parlor, and an earthen 

dry lot for heifers and calves. For one model dairy, EPA assumed the free-stall barn alleys are 

flushed three times per day. For another model dairy, EPA assumed the free-stall barn and alleys 

are scraped three times per day. Sawdust is used for bedding in the barns. Feed is brought into 

the barns and spread along a center drive-through alley. For milking, the herd is moved from the 

barn or dry lot into a covered holding area where they are washed, then into the milking parlor, 

and back out into the barn or lot three times each day. 

For the dairy with a flush system, EPA estimated wastewater is generated at a rate of 130 gallons 

per day per cow1. EPA assumed that all flush water from the free-stall barns, parlor, and staging 

areas is discharged to a liquid lime treatment system. 

For the scrape system, only wash water from the parlor is discharged to the liquid lime treatment 

system. EPA estimated wastewater generation in the parlor to be 0.96 gallons per day per cow. 

Only 15 percent of the total daily manure generation from the scraped dairy enters the liquid lime 

system. The remainder of manure is collected and stockpiled during scraping. Stockpiled 

manure is treated through a pug-mill with solid lime. 

EPA also assumed that runoff from the dry lots and free-stall barn areas for both the flush dairy 

and scrape dairy enter the liquid lime treatment system for disinfection. To estimate the amount 

of runoff that will be treated by the liquid lime treatment system at both the flush and scrape 

dairies, EPA used data contained in Table 4.7.3-2 of the CAFO Cost Report. Table 4.7.3-2 

includes runoff amounts by model farm and by region. According to this table, the runoff 

volume from a Large Midwest dairy from a 25-year, 24-hour storm event is 111,004 ft3 (830,300 

gallons). Therefore, the lime treatment systems must be sized to handle 830,300 gallons of 

runoff per day, plus manure, flush water (flush system), parlor water, and any wash waters. 

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Table 8-38 shows the number of head selected for each model dairy, estimated manure and 

nutrient generation, and the estimated amount of runoff that will be captured and treated by the 

lime disinfection system. 

Table 8-38. Model Dairy Waste Generation and Precipitation Collection 

Model Dairy CAFO Design Flush System Scrape System 

Lactating dairy cows (a) 1,430 1,430 

Heifers (a) 429 429 

Calves (a) 429 429 

Dairy cow manure generation (lbs/day as excreted) 161,200 161,200 

Flush water and wash water volume (gal/day) (a) 186,400 1,373 

Ammonia nitrogen generation (lbs/day) (b) 837 837 

Phosphorous generation (lbs/day) (b) 130 130 

Captured runoff volume (gal/day) 830,300 830,300 

(a) Cost Report 

(b) TDD 

Lime Disinfection System Description 

The lime disinfection systems requires a quick-lime (calcium oxide) storage and slaking system, 

a reaction tank to allow for contact between the lime and liquid CAFO waste, a pug mill for 

contact between scraped manure and lime (scrape dairy only) and a scrubber system to capture 

gaseous ammonia emissions from the liquid reaction tank. Figure 8-1 is a conceptual diagram 

showing the primary pieces of equipment included in the lime disinfection system for a flush 

dairy. Figure 8-2 is a conceptual diagram showing the primary pieces of equipment included in 

the lime disinfection system for a scrape dairy. For all the flush dairy waste, and the parlor waste 

from the scrape dairy, the conceptual design assumes that quick lime is diluted in water to 

approximately a 12 percent (w/w) slurry and metered into the dairy waste using a pH meter and 

controller to raise the pH to approximately 10. The dairy waste/lime mixture is agitated to 

promote mixing, and is held in the reaction tank for approximately 8 hours. For both the model 

farms (flush and scrape), EPA estimated the lime slurry addition to the liquid treatment tank to 

be 0.5 lbs per pound of manure solids (Eric Males, EPA Docket OW-2002-0025, DCN 40267). 

Dry lime addition to the pug mill is also based on 0.5 lbs per pound of manure solids. Table 8-39 

shows the design parameters for the lime disinfection systems. 

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Table 8-39. Lime Disinfection System Design Parameters 

Design Parameter Flush System Scrape System 

Lime disinfection tank volume (ft3) 92,100 61,900 

Lime disinfection tank shape Square Square 

Lime disinfection tank materials In-ground, epoxy-coated, 

concrete, covered with vent 

to scrubber 

In-ground, epoxy-coated, 

concrete, covered with vent to 

scrubber 

Lime disinfection tank depth (ft) 14 14 

Lime disinfection tank width and length (ft) 107 88 

Pug mill size (tons/hour) NA 80 

Pug mill and manure pad size (sq feet) NA 1,280 

Lime requirements (lbs/day) 

 Liquid system 

Pug mill scrape manure 

9,700 

NA 

1,570 

8,130 

Tank head space blower size (cfm) 100 100 

Manure pump/agitator size (HP) 50 50 

Number of manure pump/agitator assemblies 12 8 

Lime-manure pump out rate at max flow (gpm) 18,000 12,000 

NA: Not applicable for flush dairy model farm 

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Figure 8-16. Diagram of a Flush Dairy Lime Disinfection System 
8-252 

Figure 8-17. Diagram of a Scrape Dairy Lime Disinfection System 
To size the liquid lime disinfection tanks, EPA assumed that two-thirds of the tank volume 

would be removed during each batch, leaving one-third of the tank contents (manure plus 

residual lime) to react with the incoming raw waste. EPA also sized the manure pump and 

agitator assemblies to transfer the contents of the lime disinfection tank to an existing on-site 

lagoon in 30 minutes. Vendor information on the pumping and agitation units is provided in the 

CAFO record (EPA Docket OW-2005-0037, DCN 1-01218). Addition of lime to the dairy waste 

will generate heat (up to 70°C) that will aid in the disinfection process. To maintain the 

temperature of the disinfection tank during winter months, EPA assumed the tank was in-ground. 

The size of the pug mill needed to mix lime and scraped manure is based on the amount of 

manure collected in the free-stall barn and yard areas. Vendor information on the pug mill is 

also included in the CAFO record (EPA Docket OW-2005-0037, DCN 1-01205). 

Another important unit process associated with the lime disinfection system is the bulk quicklime storage and slaking system. For the quick-lime storage silo sizing requirements, EPA 

assumed 7 days of bulk lime storage. EPA notes in remote locations or locations subject to 

extended periods of heavy snow, this storage period may be inadequate and the costs may 

therefore be understated. The liquid disinfection systems operate by metering dry quick-lime into 

a 2,000-gallon mixed slurry tank and diluting with water to generate a 12 percent (w/w) lime 

slurry that is then metered into the manure disinfection tank. The pug mill system used for 

scraped manure operates by metering (by weight) dry quick-lime from the storage silo to the pug 

mill for contact with manure. Table 8-40 shows the design parameters used to size and cost the 

lime storage and slaking system. 

Table 8-40. Lime Storage and Slaking System Design Parameters 

Design Parameter Flush System Scrape System 

Dry Lime storage capacity (ft3) 1,100 1,100 

Lime storage capacity (days) 7 7 

Lime slurry tank volume (gal) 2,000 500 

Lime slurry concentration (%) 12 12 

Lime slurry tank mixer size (HP) 1.3 0.5 

Lime slurry metering pump size (HP) 0.5 0.5 

Number of lime slurry metering pumps 3 2 

The disinfection tank is covered to prevent the loss of gaseous ammonia due to the increase in 

pH when quick lime is added. Literature information indicates between 10 and 40 percent of the 

ammonia nitrogen in manure is converted to gaseous ammonia when lime is added during 

disinfection. For the model dairy CAFOs, EPA assumed 25 percent of the ammonia nitrogen in 

the raw dairy waste entering the liquid manure disinfection tank is converted to gaseous 

ammonia nitrogen and is transferred from the head-space above the disinfection tank to a wet 

scrubber using a 100 cfm blower. For the pug mill system used for scraped manure, gaseous 

ammonia emissions are uncontrolled. 

The wet scrubber selected for the flush and scrape dairy conceptual design is a pre-fabricated 

system that allows for counter-current contact between the ammonia rich gas and a dilute sulfuric 

acid liquid stream. Information on the ammonia scrubber requirements were provided by the 

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scrubber vendor, Advanced Air Technologies (EPA Docket OW-2005-0037, DCN 1-01219). 

The ammonia scrubber converts gaseous ammonia to a concentrated ammonium sulfate solution 

that can be used as on-site fertilizer. Table 8-41 shows the design parameters for the ammonia 

scrubber systems. 

Table 8-41. Ammonia Scrubber System Design Parameters 

Design Parameters Flush System Scrape System 

Gas flow rate (cfm) 100 100 

Scrubber column height (feet) 9.2 9.2 

Scrubber column diameter (inches) 13.5 13.5 

Scrubber water flow rate (gpm) 3 3 

Daily ammonia nitrogen load to scrubber (lbs/day) 170 26 

Sulfuric acid requirement (lbs/day) 600 80 

Ammonium sulfate production (lbs/day) 800 100 

Ammonium sulfate solution concentration (%) 43 43 

Ammonium sulfate solution storage tank (gal) 500 100 

In addition to the ammonia scrubber, a concentrated sulfuric acid (98 percent w/w) storage and 

delivery system is required. For the flush dairy, the sulfuric acid storage system includes a 

2,500-gallon fiberglass tank with secondary containment, two corrosion resistant metering 

pumps, a pH meter/controller, and corrosion resistant piping to transfer the concentrated acid 

from the storage tank to the ammonia scrubbers liquid recycle system. For the scrape dairy, the 

sulfuric acid storage system requires only a 150-gallon acid storage tank and a 100-gallon 

ammonium sulfate solution storage tank due to smaller amount of manure and ammonia nitrogen 

entering the liquid system. 

Lime Treatment System Costs 

EPA estimated installed capital, operating and maintenance (O&M), and annualized costs 

(2001$) for the model flush and scrape dairy CAFOs described above. Installed capital costs 

were estimated by applying design factors for items such as plumbing and electrical to 

equipment purchased costs and published cost data for specific construction activities (EPA 

Docket OW-2005-0037, DCN 1-01206). O&M costs were estimated based on published 

chemical cost data and from electrical requirements for motors associated with pumps and 

mixers used in the disinfection system (EPA Docket OW-2005-0037, DCNs 1-01207, 1-01209, 

1-01221, and 1-01016A1) Labor requirements (hours per year) for the system were based on 

engineering judgment. 

The annualized cost (capital and O&M) for the flush dairy lime disinfection system is 

approximately $335,300 per year based on an 11-year depreciation schedule and a 7 percent 

interest rate (2001$). Annualized costs for the scrape dairy CAFO is approximately $343,000 

per year (2001$). Detailed costs for both capital and O&M items are described below. 

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Capital Cost Estimate 

Capital costs for the lime disinfection system at the model dairy CAFO are summarized in Table 

8-42. EPA estimated the total installed capital cost for the flush dairy lime disinfection system to 

be approximately $1,046,000 (2001$). EPA estimated the total installed capital costs for the 

scrape dairy lime disinfection system to be approximately $925,000 (2001$). Costs do not 

include engineering or contingency since these costs are highly variable and site-specific. 

Table 8-42. Estimated Capital Cost for Lime Disinfection of Dairy Waste 

Equipment 

Flush System Capital Cost 

(2001 $) 

Scrape System Capital 

Cost (2001$) 

Quick lime storage and delivery system $129,000 $129,000 

Corrosion resistant lime disinfection tank and 

associated pumps, mixers, and controllers. 

$851,000 $604,000 

Pug mill system for contact of scraped manure 

with quick lime 

NA $142,000 

Ammonia scrubber/ammonium sulfate generation 

system. 

$43,000 $38,000 

Concentrated sulfuric acid delivery and 

containment system 

$23,000 $12,000 

Total capital cost: $1,046,000 $925,000 

Annual Operating and Maintenance Costs 

Annual operating and maintenance (O&M) costs for the lime disinfection systems at the model 

dairy CAFOs are summarized in Table 8-43. EPA estimated the annual O&M costs for the flush 

dairy to be $227,200 (2001$) and have included a cost credit for the value of ammonium sulfate 

generated by the capture and scrubbing of ammonia from the lime disinfection system. 

Estimated annual O&M costs for the scrape dairy are estimated to be $252,300. Electrical costs 

for both systems have been adjusted to account for periods when no precipitation is being treated 

in the liquid lime treatment tank. Annual O&M costs for the scrape dairy are higher than the 

flush system due to the added labor needed to operate the pug mill system, and the lower amount 

of recoverable ammonium sulfate due to the loss of ammonia in the pug mill. 

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Table 8-43. Estimated Annual O&M Cost for Lime Disinfection of Dairy Waste 

O&M Item 

Flush System Annual O&M 

Cost (2001 $/yr) 

Scrape Annual O&M Cost 

(2001 $) 

Chemicals 

 Lime

 Sulfuric Acid

 Ammonium Sulfate 

$192,000 

$8,300 

($28,000) 

$192,000 

$1,300 

($4,000) 

Electrical $38,000 $32,000 

Labor $16,900 $31,500 

Total annual O&M: $227,200/yr $252,300/yr 

Lime Treatment System Conclusions 

The annual costs for the flush and scrape model dairy lime disinfection systems are 

approximately $335,300 per year and $343,000 per year, respectively. This cost estimate is 

based only on the equipment, electricity, chemical, and labor costs; this estimate does not include 

the cost of solids separation and is in addition to the costs associated with nutrient management 

planning, land application costs, and other best management practices. 

To appropriately extrapolate the model lime disinfection system cost to the entire dairy industry, 

EPA would need to estimate the additional costs associated with solids separation and the costs 

that would be required for each model dairy to meet BPT. However, a rough estimate of the 

minimum dairy industry costs for lime disinfection can be calculated by multiplying the model 

system cost by the number of dairies in the Large category using either a flush or scrape system. 

Table 8-44 shows the estimated cost for the entire industry. The numbers of Large dairy farms 

by region were determined from the Cost Report. This calculation produces an estimate of 

$489,359,000. Even without taking into account the additional costs of solids separation and 

BPT requirements, the cost for lime disinfection is more expensive than any other regulatory 

option for dairy (other option costs are presented in Section 15.2.3). 

Because of the extremely high costs associated with lime disinfection, EPA does not consider 

this technology to be a viable option. As stated in Section 8.6.2.3, costs do not include 

engineering and contingency, and lime storage costs may be understated for many locations. 

Less expensive technologies can potentially reduce FC by 99 percent. Therefore, even though 

this technology could remove an estimated 99 percent of FC, the high cost renders the FC 

pollution reductions irrelevant. Accordingly, FC loads for this technology option were not 

calculated. 

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Table 8-44. Estimated Industry Cost for Lime Disinfection 

Region 

Number of 

Large Dairies 

Percent 

Flush 

Percent 

Scrape 

Flush Dairy 

Annualized 

Cost 

(2001$) 

Scrape System 

Annualized Cost 

(2001$) 

Central 401 75 25 $100,841,000 $34,386,000 

Mid-Atlantic 104 50 50 $17,436,000 $17,836,000 

Midwest 95 50 50 $15,927,000 $16,292,000 

Pacific 759 75 25 $190,870,000 $65,084,000 

South 91 75 25 $22,884,000 $7,803,000 

Totals: 1,450 $347,958,000 $141,401,000 

8.6.2.4 Composting of Poultry Manure or Litter 

EPA investigated the technical applicability and costs for composting of poultry manure or litter. 

Section 8.6.2.4 describes the methodology and resources used to calculate costs for applying 

composting technology to poultry operations. 

Figures 8-3 and 8-4 present the components of poultry composting systems for wet layers and 

other poultry operations. EPA used a step-wise process to calculate composting costs for the 

poultry industry. 

1. Estimate poultry manure/litter composting costs using the Methodology for Estimating 

the Costs of Composting Swine and Poultry Manure (referred to as the Poultry 

Composting Report, EPA Docket OW-2002-0025, DCN 120039) 

2. Add costs for storage ponds to collect runoff from the composting area at broiler, dry 

layer, and turkey operations. Add costs for solids separation technology at wet layer 

operations. 

3. Apply the dollar per bird composting costs (including storage ponds and solids 

separation) from the Poultry Composting Report to the model farms developed for the 

CAFO rulemaking process. 

4. Add irrigation costs to apply pond water to land application areas. 

5. Sum CAFO model farm costs to calculate a total industry cost for a poultry composting 

option. 

These steps and the resulting costs are explained in detail in the remainder of Section 8.6.2.4. 

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Compost Amendments 

Manure 

Flush Solid Land Solid-Liquid Water Application 

Windrow 

Solids Composting 

Liquid Runoff 

Storage Pond Liquid Land 

Application 

Figure 8-18. Poultry Composting System for Wet Layers 

Compost Amendments 

Dry Layer Manure 

Broiler Litter Solid Land 

Turkey Litter Application 

Windrow 

Composting 

Storage Pond Liquid Land 

Application 

Runoff 

Figure 8-19. Poultry Composting System for Dry Layers, Broilers, and Turkeys 

Poultry Composting Report Model Farms and Composting Costs 

The Poultry Composting Report presents the model poultry farms and calculated costs for 

composting at each model farm. The report presents windrow composting costs in dollars 

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(1997$) per ton of manure/litter for model farms with wet and dry layers, broilers, and turkeys, 

using two different types of compost amendments. The characteristics of these model farms are 

specific to the Poultry Composting Report and are different from the model farm characteristics 

developed for the final CAFO rule and presented in the Cost Report. This change was necessary 

to more accurately reflect the costs of composting to various types of poultry facilities. (See the 

“Application of Table 8-47 Costs to Model Farms Developed for the CAFO Rule 

” section below for a description of how these two sets of model farms are correlated.) The total 

cost for each model farm in the Poultry Composting Report includes the following components: 

y Planning; 

y Compost amendments (including water); 

y Land rental for the composting area; 

y Equipment for windrow turning (capital and operation & maintenance) and compost 

monitoring; and 

y Labor for windrow turning and monitoring (temperature and moisture content). 

Costs for solids separation of liquid waste, storage ponds to collect runoff from the composting 

areas, or irrigation from the storage ponds are not included in this step. Revenue from compost 

sales are presented in Section 8.6.2.4. Table 8-45 summarizes the model farm characteristics and 

final composting costs from the Poultry Composting Report. 

Table 8-45. Model Farms and Costs Presented in the Poultry Composting Report 

Sector Region 

Number 

of Birds 

Annual Manure 

Production per 

Model Farm 

(tons) 

Compost 

Amendments 

Windrow 

Area 

(acres) 

Total 

Annualized 

Cost (1997$/ton 

manure) 

Layer: Wet South 3,654 149 Wheat straw & 

Sawdust 

0.0928 $36.51 

Layer: Wet Sawdust South 3,654 149 Sawdust 0.0715 $18.63 

Layer: Dry South 884,291 6,838 Wheat straw 24.0815 $229.79 

Layer: Dry Sawdust South 884,291 6,838 Sawdust 11.1950 $49.30 

Broiler Mid-Atlantic 36,796 587 Wheat straw 1.0045 $91.65 

Broiler Sawdust Mid-Atlantic 36,796 587 Sawdust 0.5306 $19.81 

Turkey Mid-West 158,365 9,691 Wheat straw 10.7043 $46.34 

Turkey Sawdust Mid-West 158,365 9,691 Sawdust 7.1424 $11.05 

The total annualized costs in Table 8-45 provide the starting point for EPA’s other cost 

calculations, which incorporate additional costs for runoff storage ponds, solid-liquid separation 

of manure, and irrigation into a $/bird poultry composting cost. 

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Runoff Storage Pond Costs 

For dry layer, broiler, and turkey model farms, where poultry waste is handled as a dry 

substance, EPA added the cost of storage ponds to collect runoff from the composting area. The 

process described in Chapter 5.5 of the Cost Report was used to calculate the cost of storage 

ponds. The storage pond calculations from the Cost Report were originally developed for beef 

feedlot runoff, so EPA modified some elements to reflect poultry composting runoff as described 

below. 

First, EPA determined the necessary pond volume using the following equation. 

Pond Volume = Sludge Volume + Runoff (normal and peak) + Net Precipitation + Design Storm + Freeboard 

Where: 

y Sludge Volume: The sludge volume calculation uses an animal-specific sludge 

accumulation ratio to determine sludge volume. However, the Cost Report only 

presented this ratio for beef cattle. EPA consulted the USDA Agricultural Waste 

Management Field Handbook to identify sludge accumulation ratios for layers and 

broilers. Sludge accumulation ratios for layers and broilers are 0.0295 and 0.455 cubic 

feet per pound, respectively. The sludge accumulation ratio for turkeys was assumed to 

be the same as broilers, since both use a litter-based manure management system. 

y Runoff: The amount of runoff entering the pond is determined from the net precipitation, 

composting area size, and number of days of storage. Runoff estimates reflect 

precipitation values for each region using the same climate data used for beef cattle 

model farms. Peak precipitation represents a 25-year 24-hour storm. The composting 

area size for each model farm is provided in the Poultry Composting Report, and Option 

5A requires 180 days of storage capacity. The runoff contribution to the pond is reduced 

by the amount of water retained by the solids that settle out in the basin. For the purposes 

of estimating solids entering the runoff pond, EPA assumed that poultry compost runoff 

and settling in storage ponds would have similar characteristics to beef feedlot runoff and 

settling. Therefore, EPA used a value of 1.5 percent solids in runoff, while the solids 

entering the pond are 50 percent of the basin solids. 

y Net Precipitation and Design Storm: The pond depth is increased to allow for direct net 

precipitation (average precipitation minus average evaporation) plus the design storm 

(24-hour, 25-year storm). Again, regional climate data corresponding to beef cattle 

model farms for the same location was used. 

y Freeboard: A minimum of 1 foot of freeboard is added to the depth. 

After determining an appropriate volume for the storage pond, EPA used equations from the 

Cost Report to calculate the best-fit dimensions for ponds at each model farm based on the 

required volume. Because the storage pond volumes for poultry operations are smaller than the 

beef feedlots described in Chapter 5.5 of the Cost Report, EPA used an initial pond depth of 9 

feet (instead of 10 feet, recommended in the Cost Report), and a final pond depth of 10 feet when 

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calculating pond dimensions. EPA also assumed that embankments surround the ponds would 

be the same size as berms that surround feedlots, 6 feet wide at the base and 3 feet tall. 

Next, EPA calculated the pond surface area and excavation and embankment volumes. Using 

these data, along with equations and unit cost data from Table 5.5.3-1 in the Cost Report, EPA 

calculated capital and annual costs for constructing storage ponds. 

Capital Cost = Mobilization + Excavation + Compaction + Conveyance 

Annual Cost = 5% × Capital Cost 

EPA annualized these costs, using the 11-year, 7 percent amortization rate from the Cost Report. 

EPA then calculated the $/ton manure cost by dividing the annualized cost by the annual tons of 

manure at each model farm (from Table 8-45). Table 8-46 presents these storage pond costs. 

Table 8-46. Storage Pond Volume and Costs 

Sector 

Total Pond 

Volume (cu ft) Capital Cost 

Operation & 

Maintenance 

Annualized 

Cost (1997$) $/ton manure 

Layer: Dry 1,962,953 $481,136 $23,675 $81,415 $11.91 

Layer: Dry Sawdust 919,073 $229,879 $11,112 $38,718 $5.66 

Broiler 91,554 $30,357 $1,136 $4,812 $8.20 

Broiler Sawdust 49,726 $20,219 $629 $3,090 $5.26 

Turkey 551,652 $141,375 $6,687 $23,678 $2.44 

Turkey Sawdust 369,221 $97,400 $4,488 $16,205 $1.67 

Solid-Liquid Separation Costs for Wet Layer Waste 

Liquid manure from wet layer operations has a moisture content of 75 percent. In comparison, 

the respective moisture contents of dry layer manure, broiler litter, and turkey litter are 40 

percent, 25 percent, and 35 percent (Poultry Composting Report, p. 6). Solid-liquid separation 

must be performed on wet layer waste before it can be composted. 

EPA used the process described in Chapter 5.7 of the Cost Report to calculate the cost of 

installing and operating screen solid-liquid separation equipment at wet layer operations. The 

solids content of separated solids is assumed to be 23 percent and the separation efficiency is 

assumed to be 30 percent (based on Poultry Composting Report). Capital costs are determined 

by the following equation, and annual costs are estimated to be 2 percent of the capital costs. 

Separation Capital Cost = (Solids volume generated over 6 months × safety factor × Storage tank cost) + 

Separator device + (Pipe length × Pipe cost) + (Installation labor × Labor rate) 

EPA calculated the solids volume generated over a 6-month period using the following equation. 

6-mo. Solids Volume = (Annual manure generation [gallons] × % Solids in manure × % Efficiency of separation) 

2 

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EPA calculated capital and annual operation and maintenance (O&M) costs for wet layers, then 

annualized the costs. The resulting annualized cost for solid-liquid separation at wet layer model 

farms is $4,117 (regardless of compost amendment type). EPA calculated the $/ton manure cost 

by dividing the annualized cost by the annual tons of manure at each model farm (from Table 8­

45). The solid-liquid separation cost is $27.58 per ton of manure. 

Composting Costs Including Storage Ponds and Solids Separation 

EPA added the $/ton manure storage pond or solids separation costs from Table 8-46 to the $/ton 

manure composting cost at model farms presented in Table 8-45. Costs were converted from 

1997$ to 2001$ using RS Means Historical Cost Indices so they can be compared or added to 

other estimated industry costs. EPA calculated $/bird composting costs from the $/ton manure 

costs using data from Table 8-45 in the following equation. 

Annual Cost per Bird = Cost of Composting with Pond/Solid Sep. × Annual Manure Production

 # Birds 

Based on the Poultry Composting Report, EPA assumed that both types of compost amendments 

(wheat stalks and sawdust) are equally available, and farmers would choose the least expensive 

amendment option. The least expensive compost amendment option for all poultry types is 

sawdust, so EPA selected the sawdust option to represent the layer, broiler, and turkey sector 

composting costs. Table 8-47 presents the $/ton manure and $/bird composting cost data. 

Table 8-47. Poultry Composting Costs Including Storage Ponds and Solids Separation 

Sector 

Composting Cost 

from Table 8-45 

($/ton) 

Annual Cost of 

Pond or Solids 

Sep. per Ton 

Manure 

($/ton) 

Total Cost of 

Composting 

with Pond or 

Solids Sep. 

(1997$/ton) 

Total Cost of 

Composting with 

Pond or Solids 

Sep. 

(2001$/ton) 

Total Cost of 

Composting with 

Pond or Solids 

Sep. 

(2001$/bird) 

Layer: Wet 

Sawdust $18.63 $27.58 $46.21 $49.89 $2.04 

Layer: Dry 

Sawdust $49.30 $5.66 $54.96 $59.35 $0.46 

Broiler Sawdust $19.81 $5.26 $25.07 $27.07 $0.43 

Turkey Sawdust $11.05 $1.67 $12.72 $13.74 $0.84 

Application of Table 8-47 Costs to Model Farms Developed for the CAFO Rule 

The poultry composting costs presented through Table 8-47 have been based on the model farms 

described in the Poultry Composting Report. The $/bird costs from these four model farms used 

in the Poultry Composting Report need to be correlated and applied to the ninety-nine “Large” 

poultry model farms that were the basis for the final CAFO rule. 

EPA matched model farms from the Poultry Composting Report to the CAFO Cost Report model 

farms by animal type and operation. Then, EPA multiplied Table 8-47$/bird costs by the 

number of animals at “Large1” and “Large2” model farms to estimate a composting cost for each 

8-262
model farm. Table 8-48 presents these poultry composting costs for CAFO Cost Report model 

farms. 

Irrigation Costs 

Next, EPA calculated capital and annual costs for irrigation systems in all CAFO Cost Report 

model poultry farms. Irrigation costs were set to zero for wet layer operations where storage 

ponds and irrigation systems would already be in place. Irrigation costs for dry layers, broilers, 

and turkeys were calculated using the process described in Chapter 5.8 of the Cost Report. 

Although Chapter 5.8 describes beef and dairy irrigation costs, no changes were needed to 

translate the methodology to poultry costs. The only variable used to determine irrigation costs 

is the total number of irrigated acres. 

Using the capital and annual cost equations from Table 5.8.3-1 in the Cost Report, costs for 

traveling gun irrigation were calculated for model farms with less than 30 acres of cropland and 

costs for center pivot irrigation were calculated for model farms with greater than 30 acres of 

cropland. EPA then annualized the irrigation costs and added the irrigation costs to other 

composting costs at model farms. Appendix B presents the irrigation costs for model farms. 

Poultry Composting Industry Cost 

EPA summed the model farm costs presented in Table 8-47 to obtain industry-level costs for 

composting. Table 8-48 presents these composting costs for the poultry industry. 

Table 8-48. Poultry Industry Costs for Composting 

Operation # of Large Facilities Total Cost of Composting (2001$) 

Wet Layers 383 $114,220,000 

Dry Layers 729 $137,260,000 

Broilers 1,632 $166,540,0000 

Turkeys 388 $48,610,000 

ALL 3,132 $466,600,000 

The costs in Table 8-48 represent only the composting portion (plus irrigation) for CAFO 

Regulatory Option 5A. To calculate the entire cost of Option 5A for the poultry industry, these 

additional costs must be added: 

y Production area and land application best management practices; 

y Mortality-handling requirements; 

y Nutrient management planning and recordkeeping; and 

y Transport of manure or litter to other farms. 

EPA believes that the poultry industry cost for Option 5A could be estimated by adding the 

composting costs (from Table 8-48) to Option 2 costs ($41 million, from Table 15-8). However, 

there is some uncertainty in this estimation. Depending on what components the original 

Option 2 costs include, there may be double counting or omission of some costs. 

8-263
Assuming that Option 5A costs can be calculated by adding composting costs and Option 2 costs 

and there are no cost offsets for compost sale revenue, the total industry cost will be $508 

million. 

Revenue and Cost Offsets from Compost Sales 

A portion of the industry costs for composting could be offset by selling the finished compost 

product. The Poultry Composting Report estimates revenue from compost sales at each of the 

model farms. These costs are based on two assumptions: 1) 80 percent volume reduction of the 

manure and amendments composted, and 2) a compost sale price of $6 per cubic yard. EPA 

examined these assumptions and found that the compost volume reduction is reasonable, but 

$6/cubic yard seems to be a low price estimate for poultry compost in today’s market. EPA 

researched current compost prices and determined that a more reasonable price estimate for 

poultry compost is $20/cubic yard. Table 8-49 presents the data sources that EPA consulted. 

Table 8-49. Compost Prices and Data Sources 

Compost Sale Price 

($/cubic yard) Type of Compost Data Source 

$30.00 Mix of layer manure and broiler litter Biocycle, Aug. 2001 

$30.00 Layer manure Biocycle, Aug. 2001 

$25.40 Buffalo chip Cheyenne Composting Facility 

$11.50 Manure Whatcom County Manure Compost Marketing 

Guide 

$10.00 General - bulk Biocycle, Dec. 2004 

$15.00 General - bulk Biocycle, Oct. 2004 

$6.00 - $15.00 Yard waste North Carolina Department of Environment and 

Natural Resources 

To estimate compost sale revenues for the poultry CAFO industry, EPA calculated a dollar per 

bird ($/bird) revenue for wet and dry layer, broiler, and turkey operations using data from the 

Poultry Composting Report and the price estimate of $20/cubic yard in the following equation: 

Dollar per Bird Revenue = Compost Sale Price per Cubic Yard × Cubic Yards of Compost per Model Farm 

# Bird per Model Farm 

EPA applied this $/bird value to model farms used in the CAFO rule-making process. The 

CAFO model farm revenues were summed to determine industry revenue from compost sales. 

Assuming a price of $20 per cubic yard of compost, the industry revenue from compost sales 

will be $252,630,000. When this revenue is subtracted from the industry composting costs, the 

Option 5A cost is $255 million. The sales price of compost may decrease or increase depending 

on availability of bulking materials and market demand. For example, if all Large poultry 

CAFOs composted manure, in some areas an influx of compost may flood the market, driving 

the sales price down or even eliminating the positive dollar value. 

Appendix B contains data tables presenting the costs per model farm for poultry composting. 

8-264
8.6.3 Pollutant Load Calculations 

EPA applied the estimated pollutant loads generated for the Options 2, 3 and 5 in 2003 rule to 

this BCT cost test. For Option 5a, 6 and 7 EPA updated the models’ assumptions and recreated 

(or in some cases generated for the first time) the loads estimations (EPA Docket OW-2005-0037 

DCN 1-02000). The updated assumptions for each of the modified options were: 

y Option 5A for beef, dairy, and heifer operations has the same elements as Option 2, plus 

implementation of a drier manure management system (i.e., composting). To estimate the 

loads from Option 5a it was assumed that the bacteria levels were reduced by 99 percent 

prior to land application. In addition, the loads from the overflows were reduced by the 

efficiencies reported for solids separation in the TDD (BOD: 40%, TS: 57%, TN: 58%, 

TP: 50%, Bacteria: 57%). Sediment discharges from cropland were assumed to equal 

those previously estimated for Option 2. 

y Option 6 has the same elements as Option 2 plus implementation of anaerobic digestion 

with energy recovery for the large swine and dairy operations only. (Note heifer 

operation would not have to install digesters, but they are presented under the general 

DAIRY category). To estimate the loads from Option 6 it was assumed that the bacteria 

levels were reduced by 99 percent prior to land application. In addition, the loads from 

the lagoon overflows were reduced by the efficiencies reported for anaerobic digesters in 

the TDD (BOD: 85%, TS: 30%, TN: 65%, TP: 85%, Bacteria: 99%). These reductions 

were applied to large swine and dairy operations only. As noted above there were no 

changes to the pollutants in the overflows from heifer operations. 

y Option 7 has the same elements as Option 2, plus timing restrictions on land application 

of animal waste to frozen, snow-covered, or saturated ground. To estimate the loads from 

Option 7 it was assumed that model facilities that incurred costs for additional storage 

would also eliminate any lagoon overflows. Under Option 7, the costs model had costs 

for swine facilities in the MA and MW. It was assumed that beef and dairy facilities in 

the MA and MW would also conservatively eliminate all lagoon overflows under this 

option. 

The models available for simulating pollutant reductions from land application practices 

(GLEAMS, EPIC, and BASINS) do not measure BOD, and EPA was not able to quantify BOD 

from land application in the 2003 final CAFO rule. BOD in runoff from land application areas 

contains BOD from manure and process wastewaters, but it also contains BOD from organic 

matter including background soil organic materials and crop residues. In contrast to crop 

residues, degradation of manure BOD is highly sensitive to moisture and aerobic conditions, and 

quickly forms inorganic materials and nutrients after land application, as evidenced by 

significant off-gassing (odor) as the manure decomposes immediately following land application 

(EPA Docket OW-2005-0037, DCN 1-01230). BOD deliveries to surface water are also highly 

variable, but current literature suggests the timing of land application in relation to future rainfall 

events is a key parameter. 

8-265
Since the 2003 CAFO rule, models including WAM (Watershed Assessment Model) and WMM 

(Watershed Management Model) were developed that have some watershed level BOD modeling 

capability (for example, see “TMDLs for Nutrient, DO, and BOD for Delaney Creek,” March 

2005, EPA Docket OW-2005-0037, DCN 1-01222). The data required for the WMM model 

includes: area of all the land use categories and the area served by septic tanks; percent 

impervious area of each land category; event mean concentration of runoff (EMC) from land use 

for each pollutant type and land use category; percent EMC of each pollutant type that is in 

suspended form; and annual precipitation. The lack of data/literature to support estimation of 

national BOD loadings from land applied manure is a significant issue. EPA concludes the 

capability is still not available to more accurately model BOD runoff. 

The 2003 CAFO rule prohibits dry weather discharges from land application areas, and EPA 

further believes the BPT land application requirements (including technical standards for timing, 

form, and rate of application, as well as the required vegetated buffer, setback, or equivalent 

practices) already minimize discharges of BOD from land application areas. For all of these 

reasons, EPA believes the reductions in BOD in runoff from land application areas, specifically 

the BOD attributable to manure and process wastewater, are minimal in comparison to 

production area discharges of BOD. Therefore EPA’s load reductions for BOD include 

production area discharges (overflows and runoff from manure storage), but do not include land 

application. 

Runoff of land applied manure was simulated using the Groundwater Loading Effects of 

Agricultural Management Systems (GLEAMS) models EPA developed for the 2003 CAFO rule 

(See III-19 of Loads Report). GLEAMS is a field-scale model that simulates hydrologic 

transport, erosion, biochemical processes such as chemical transformation and plant uptake, and 

nutrient losses in surface runoff, sediment, and groundwater leachate and is described in the 

Loads Report. The National Water Pollution Control Assessment Model (NWPCAM) is a 

national surface-water quality model designed to characterize water quality for the nation's 

network of rivers, streams, and lakes. In the 2003 final CAFO rule analysis, NWPCAM 

simulations predict that, on average nationwide, 75 percent of FC, 88 percent of BOD, and 79 

percent of TSS that reach the edge-of-field will reach surface waters (all calculated at the RF3 

level). EPA summed the reduced discharges of conventional pollutants from modeled overflows 

(See Loads Report for more information) with the land application edge-of-field load analyses 

(the GLEAMS simulations followed by attenuation in the NWPCAM model) to quantify 

reductions in conventional pollutant discharges from both the production area and the land 

application area. 

Tables 8-50, 8-51, and 8-52 summarize the pollutant loads data as they were calculated and used 

for the EPA CAFO rulemaking process and BCT cost test. Appendix C presents additional 

pollutant loads data. 

8-266
Table 8-50. Sediment Load Reductions from Large CAFOs in Millions of Pounds per Year 

Sector Option 1 Option 2 Option 3 Option 5a Option 5 Option 6 Option 7 

Cattle 1200.8 1200.8 1200.8 1225.6 N/A 1200.8 1200.9 

Dairy 99.3 99.4 99.4 106.6 N/A 108.2 106.7 

Swine 0.0 112.8 112.8 N/A 113.4 113.3 113.4 

Poultry 31.2 172.4 172.4 172.4 N/A 172.4 172.4 

Poultry (wet) 0.0 8.5 8.5 N/A 98.0 8.5 8.5 

Total 1331.4 1594.0 1594.0 1504.5 211.4 1603.3 1601.8 

Table 8-51. FC Load Reductions from Large CAFOs in 1019 Colony Forming Units 

Sector Option 1 Option 2 Option 3 Option 5a Option 5 Option 6 Option 7 

Cattle 10.5 10.6 10.6 260.4 N/A 10.6 11.1 

Dairy 1.0 1.0 1.0 31.4 N/A 34.3 23.9 

Swine 0.4 0.4 0.4 N/A 137.8 137.4 136.5 

Poultry 6.7 6.7 6.7 7.2 N/A 6.7 6.7 

Poultry (wet) 0.0 0.0 0.0 N/A 56.5 0.0 0.0 

Total 18.7 18.7 18.7 299.0 194.3 189.0 178.2 

Table 8-52. BOD Load Reductions from Large CAFOs in Millions of Pounds per Year 

Sector Option 1 Option 2 Option 3 Option 5a Option 5 Option 6 Option 7 

Cattle 0.0 0.0 0.0 2.9 N/A 0.0 0.0 

Dairy 0.0 0.0 0.0 1.2 N/A 2.2 1.8 

Swine 0.0 0.0 0.0 N/A 7.4 6.3 7.2 

Poultry 6.0 6.0 6.0 6.0 N/A 6.0 6.0 

Poultry (wet) 0.0 0.0 0.0 N/A 13.3 0.0 0.0 

Total 6.0 6.0 6.0 10.1 20.7 14.5 15.0 

8.6.4 References 

Alexander, Ron, Rod Tyler, and Nora Goldstein. Increasing Dollar Value for Compost Products. 

Biocycle. 45(10), 48. October 2004. EPA Docket OW-2005-0037, DCN 1-01008. 

Brazy, Amy. ERG Inc. Memorandum: Methodology to Calculate Dairy Anaerobic Digestion 

Costs. 15 December 2000. EPA Docket OW-2002-0025, Section 6, DCN 00815. 

Bundy, Dwaine & Gary Greene. Evaluation of Alkaline By-Products for the Control of Swine 

Odor in Manure Storage. International Livestock Odor Conference, 1995. Email to Ron 

Jordan USEPA from Eric Males, National Lime Association. June 30, 2000, EPA 

Docket OW-2002-0025, W-00-27, Section 4.5, DCN 40267. 

8-267
City of Cheyenne Solid Waste Division. Cheyenne Composting Facility (website). Available 

online at http://www.cheyennecity.org/compost.htm, accessed 30 November 2005. EPA 

Docket OW-2005-0037, DCN 1-01009. 

Coker, Craig and Nora Goldstein. Characterizing the Composting Industry. Biocycle. 45(12), 

20. December 2004. EPA Docket OW-2005-0037, DCN 1-01010. 

Cramer, Allen. Whatcom County Manure Compost Marketing Guide. Whatcom Conservation 

District, Washington State University Cooperative Extension, Washington State 

Department of Ecology Centennial Clean Water Fund. 1998 (or more recent). Available 

online at http://whatcom.wsu.edu/ag/compost/pdfs/Marketing%20Guide.PDF, accessed 

30 November 2005. EPA Docket OW-2005-0037, DCN 1-01011. 

Energy Information Administration. Residential Electricity Prices: A Consumer's Guide . U.S. 

Department of Energy, National Energy Information Center. Available online at 

http://www.eia.doe.gov/neic/brochure/electricity/electricity.html. 2005. EPA Docket 

OW-2005-0037, DCN 1-01221. 

Faucette, Britt. Georgia Builds Poultry Litter Composting Infrastructure. Biocycle. 42(8), 23-26. 

August 2001. EPA Docket OW-2005-0037, DCN 1-01012 

Males, Eric. Fraser River Action Plan, Biosolids Stabilization Demonstration Project (DOE 

FRAP 1998-06). Environment Canada. March 1998. Email to Ron Jordan USEPA from 

Eric Males, National Lime Association. June 30, 2000. EPA Docket OW-2002-0025, 

W-00-27, Section 4.5, DCN 40267. 

Males, Eric. National Lime Association, email to Paul Shriner, USEPA. September 22, 2000, 

EPA Docket OW-2002-0025, W00-27, Section 4.5, DCN 40295. 

McLanahan Corporation. Pug Mill Mixers. Available online at 

http://www.mclanahan.com/pdf/bcr_pugmill.pdf. 2006. EPA Docket OW-2005-0037, 

DCN 1-01205. 

Metcalf and Eddy, Inc. Wastewater Engineering (3rd Edition). 1991. EPA Docket OW-2005­

0037, DCN 1-01002. 

Minnesota Department of Administration, Office of Geographic and Demographic Analysis, 

Environmental Quality Board. Generic Environmental Impact Statement (GEIS) on 

Animal Agriculture. Available online at: http://www.eqb.state.mn.us/geis/, accessed 30 

November 2005. EPA Docket OW-2005-0037, DCN 1-01230. 

National Research Council. Managing Wastewaters in Coastal Urban Areas. National Academy 

Press. 1993. EPA Docket OW-2005-0037, DCN 1-01198. 

North Carolina Department of Environment and Natural Resources: Division of Pollution 

Prevention and Environmental Assistance. Organics: Yard Wastes Commodity Profile. 

8-268
1998. Available online at http://www.p2pays.org/ref/02/0162216.pdf, accessed 30 

November 2005. EPA Docket OW-2005-0037, DCN 1-01013. 

R.S. Means. Mossman, Melville (Ed.). Mechanical Cost Data: 24th Annual Edition (p. 577), 

2001. EPA Docket OW-2005-0037, DCN 1-01003. 

RS Means. Construction and Building Cost Data. 2001. EPA Docket OW-2005-0037, 

 DCN 1-01206. 

Skousen, Jeff; Jenkins, Mike. Acid Mine Drainage Treatment Costs with Calcium Dioxide and 

the Aquafix Machine. West Virginia University Extension Service, Agricultural and 

Natural Resources Development. Available online at 

http://www.wvu.edu/~agexten/landrec/aquafix.htm. 1993. EPA Docket OW-2005-0037, 

DCN 1-01207. 

Slogan Systems. Hydrated Lime Slurry System. EPA Docket OW-2002-0025, W-00-27, Section 

4.5, DCN 40264. 

Tetra-Tech, Inc. Memo: Labor Rate for Technical Consultation for Digester Operation. 

November 2005. EPA Docket OW-2005-0037, DCN 1-02002. 

Tetra-Tech, Inc. Memo: CAFOs Costs for Digesters with No Energy Recovery. December 2005. 

EPA Docket OW-2005-0037, DCN 1-02001. 

Tetra-Tech, Inc. Memo: Cost and Load General Assumptions. November 2005. EPA Docket 

OW-2005-0037, DCN 1-02000. 

Tetra-Tech, Inc. Methodology for Estimating the Costs of Composting Swine and Poultry 

Manure. September 2001. EPA Docket OW-2002-0025, DCN 120039. 

USDA NASS. Available online at http://www.nass.usda.gov/QuickStats, accessed November 

2005. 

USDA NRCS. Agricultural Waste Management Field Handbook. 1992. Available online at 

http://ianrpubs.unl.edu/wastemgt/g1371.htm, accessed 15 November 2005. 

USDOD. Secondary Use of Acids and Alkalis for Wastewater Treatment. NAVY/MARINES 

Joint Services PPO Handbook. Available online p2library.nfesc.navy.mil/ 

P2_Opportunity_Handbook/9-I-1.html. 2004. EPA Docket OW-2005-0037, DCN 1­

01209. 

USDOE. 1998. United States Department of Energy (DOE): Monthly Electric Utility Sales and 

Revenue Report with State Distributions. Energy Information Administration, Form EIA826. 

8-269
USEPA. AgSTAR FarmWare Model. Version 2.0. February 1997. EPA Docket OW-2005­

0037, DCN 1-01203. 

USEPA. Better Assessment Science Integrating Point and Nonpoint Sources (BASINS) (EPA823-B-01-001). U.S. Environmental Protection Agency, Office of Water, Washington, 

DC. 2001. 

USEPA. Cost Methodology for the Final Revisions to the National Pollutant Discharge 

Elimination System Regulation and the Effluent Guidelines for Concentrated Animal 

Feeding Operations (EPA-821-R-03-004). December 2002. 

USEPA. Development Document for the Final Revisions to the National Pollutant Discharge 

Elimination System Regulation and the Effluent Guidelines for Concentrated Animal 

Feeding Operations (EPA-821-R-03-001). December 2002. 

USEPA. National Water Pollution Control Assessment Model (NWPCAM). Available online at 

http://iaspub.epa.gov/edr/edr_proc_qry.navigate?P_LIST_OPTION_CD=CSDIS&P_RE 

G_AUTH_IDENTIFIER=1&P_DATA_IDENTIFIER=89813&P_VERSION=1. 

USEPA. Pollutant Loading Reductions for the Effluent Limitations Guidelines for Concentrated 

Animal Feeding Operations (EPA-821-R-03-007). December 2002. 

USEPA. Watershed Assessment Model. Available online at 

http://www.epa.gov/ATHENS/wwqtsc/WAMView.pdf. 

Knisel, W.G., F.M. Davis, R.A. Leonard, and A.D. Nicks. 1993. GLEAMS: Groundwater 

Loading Effects of Agricultural Management Systems, Version 2.10. 

Sharpley, A.N., and J.R. Williams. 1990. EPIC-Erosion/Productivity Impact Calculator: 1. 

Model Documentation. USDA Tech. Bull. No. 1786. U.S. Department of Agriculture, 

Washington, DC. 

8-270
Chapter 15 

ADDITIONAL ANALYSES IN RESPONSE TO THE 2005 SECOND CIRCUIT 

COURT DECISION 

Chapter 15 presents the additional analyses that EPA performed in response to the 2005 Second 

Circuit Court decision. EPA reexamined the New Source Performance Standards (NSPS) and 

developed an alternative BCT cost test for fecal coliform. EPA performed the conventional BCT 

cost test for BOD and TSS and the alternative fecal coliform cost test for candidate technologies. 

15.1 New Source Performance Standards 

Section 15.1 presents the information supporting the proposed regulations for NSPS, including 

the 100-year storm containment structure and superior alternative performance standards. 

15.1.1 100-Year Storm Containment Structure 

EPA proposed to remove the provision allowing CAFOs to meet the no discharge standard 

through the use of the 100-year, 24-hour rain event containment structure. Facilities with open 

manure storage structures may demonstrate the no discharge requirements using site-specific 

design, construction, operation, and maintenance components and the U.S. Department of 

Agriculture Natural Resources Conservation Service Animal Waste Management (AWM) model. 

While one mechanism to prevent discharge from an open system is to provide ‘adequate’ storage 

of manure and wastewater during critical periods, EPA believes it is much more complex than 

that. In fact, the capacity for any specified storm event (such as a 100-year, 24-hour rainfall) is a 

small component in determining overall storage capacity. Adequate storage is based on a sitespecific evaluation of the CAFO’s entire waste handling system. Factors such as rainy seasons 

and storage capacity for the winter are readily factored into the proper design and construction of 

any storage facility. Adequate storage has to be defined in terms of climate-specific variables 

that define the appropriate storage volume, but of equal importance are the nutrient management 

plan and other management decisions that dictate when and how the storage can be emptied. 

The link between adequate storage and land application practices is one of the most critical 

considerations in developing and implementing a site-specific nutrient management plan. For 

example, the amount of land available for application, the hydraulic limitations (ability of the 

land to handle additional water without the occurrence of runoff), geology, and soil properties of 

the available land base can play an important role. See Chapter 2 of EPA’s technical guidance 

for CAFOs “Managing Manure Nutrients at Concentrated Animal Feeding Operations” (EPA821-B-04-00) for more information. 

Given these concerns, EPA has developed a set of procedures with the expectation that a system 

designed in accordance with such procedures can be reasonably expected to meet the no 

discharge requirements. They are: 

15-1 
1. Gather information about the specific operation to be analyzed and the regulatory 

framework in which it operates. 

2. Design the storage facility using design procedures in the NRCS “Agricultural Waste 

Management Field Handbook,” NEH-651. 

3. Evaluate the adequacy of the AWM designed storage facility using the Soil Plant Air 

Water (SPAW) Hydrology Tool. 

This three-step procedure to design and then evaluate a manure storage facility can be applied to 

any given location (a manure treatment lagoon that has a storage component is essentially a 

manure storage facility for this discussion). The process in general was previously described in 

two papers delivered to the American Society of Agricultural Engineers, Moffitt et al, 2003 and 

Moffitt and B. Wilson, 2004 (EPA Docket OW-2005-0037, DCNs 1-01223 and 1-01224). 

The first step in the process is to gather information about the specific operation to be analyzed 

and the regulatory framework in which it operates. The regulatory framework could include: 

state requirements for minimum storage periods for rainy seasons or winter or additional 

minimum capacity requirements for chronic rainfalls; technical standards that prohibit or 

otherwise limit land application to frozen, saturated, or snow-covered ground; standards that 

further limit land application where there is a high risk of nutrient transport; increased storage 

capacity with the intent to transfer the manure to another recipient at a later time; and any other 

special requirements that would impact the size of the storage facility. The operator’s 

management options and needs are to be included in the design and evaluation, as discussed 

below. For example, frequent dewatering for continuous grasses is quite different from seasonal 

applications to a given crop rotation. 

The second step is the design of the storage facility using design procedures in the NRCS 

“Agricultural Waste Management Field Handbook,” NEH-651. This can be accomplished using 

Animal Waste Management (AWM) software, which is NRCS’s manure storage/treatment 

planning/design software tool for animal feeding operations that can be used to estimate the 

production of manure, bedding, and process water and to determine the size of storage/treatment 

facilities. The Common Computing Environment (CCE) version of AWM 2.10 is currently 

available on the web, and planned software updates in the near future are not expected to change 

the general form of the tool. Site-specific input to AWM includes climate data for 30 years 

consisting of historical average monthly precipitation obtained from local weather stations, and 

evaporation values obtained from the National Oceanic and Atmospheric Administration 

(NOAA). Additional inputs include animal numbers and typical animal sizes/weights, added 

water and bedding (if any), and the size and condition of outside areas exposed to rainfall and 

contributing runoff to the storage facility. AWM allows the user to specify a storage period 

(months), and the software will design for the series of months with the most rainfall. The 

program will not design a system in excess of 12 months, as such designs are not recommended. 

As an alternative, the user can designate months when the storage pond can be emptied, and 

AWM sizes the pond based on the months with the most precipitation between pumping events. 

The output of this step is the design of a waste storage facility. AWM provides a series of 

reports describing the storage facility and providing a listing of the related specifications 

15-2 
including the dimensions of the storage facility, daily manure and wastewater additions, the size 

and characteristics of the fields, and other management assumptions such as storage period. 

The third step is an evaluation of the adequacy of the AWM designed storage facility using the 

Soil Plant Air Water (SPAW) Hydrology Tool. The current version of SPAW is 6.1. SPAW is a 

field-level tool that uses a modified Soil Conservation Service Curve Number Method to develop 

water budgets for agricultural fields. Water budget processes are evaluated by making daily 

adjustments to crop canopy cover and antecedent soil moisture. Field water budgets can be used 

for evaluating runoff and infiltration from precipitation events. SPAW also provides an 

integrated pond module to develop pond water budgets that is ideal for evaluation purposes. 

Input to SPAW includes daily precipitation, temperature, and evaporation data; storage facility 

dimensions and manure related quantities extracted from AWM; and the strategies for managing 

the storage facility. For each user-specified soil profile and crop rotation, SPAW simulates 

possible runoff from fields as well as the irrigation water needs of fields receiving the storage 

effluent. Hydrologic groups are used to rate soils for potential to release excess water down 

grade. 

EPA notes that where AWM software is used for design and SPAW is used for evaluation, 

additional software for nutrient management planning may be appropriately linked and the NMP 

data can then be imported. For example, see p. 6-12 of Managing Manure Nutrients at 

Concentrated Animal Feeding Operations (EPA-821-B-04-009) for a discussion of “Manure 

Management Planner” or “MMP,” a comprehensive Windows-based planning tool for manure 

management. 

SPAW is then run with the site-specific historic rainfall records to see if the open containment 

system (referred to as a pond in SPAW) and associated management and land application are 

adequate to eliminate any discharge. EPA believes that a historical look at 100 years is an 

adequate timeframe to support a finding of no discharge. However, EPA is aware that 100 years 

of continuous rainfall data may not be available for many CAFOs. The SPAW model can be run 

using actual rainfall data where available, and then simulated with a confidence interval analysis 

over a period of 100 years. The SPAW model shows not only that the storage facility does not 

discharge, but also that there is no runoff of wastewater from fields during land application 

activities, a necessary step in meeting the hydraulic limitations of the land application area. In 

practice, if the SPAW evaluation indicated any level of discharge or any spillway flow, the pond 

design volume could be increased in size in AWM, the new dimensions converted to SPAW 

input, and the simulation done again. This iterative procedure could continue until the pond 

simulation predicts no discharge. If the facility shows no discharge over the 100-year 

simulation, then the requirement of no discharge has been achieved. 

EPA has developed several case studies using this approach. Case studies of swine facilities 

using this approach are presented in Table 15-1. More detailed information on the inputs to 

SPAW as well as the SPAW outputs may be found in a separate memo to the record (EPA 

Docket OW-2005-0037, DCNs 1-01225 and 1-01226). 

15-3 
Table 15-1. Case Studies Using AWM and SPAW to Demonstrate No Discharge 

Location 

Number 

of Head 

Storage 

Period 

(months) 

Modeled 

Dewatering 

Frequency 

Do the manure levels 

reach the maximum 

operating level? 

Any 

predicted 

overflows?? 

North Carolina 5000 6 months Pumpout every 6 

months 

Yes No 

Iowa 5000 6 months Pumpout every 6 

months 

Yes No 

Georgia 2454 6 months Continuous irrigation No No 

Pumpout every 6 

months 

Yes No 

Nebraska 1600 5 months Pumpout 3 times per 

year 

No No 

South Carolina 3520 5 months Spring followed by 

seasonal irrigation 

No No 

If the AWM design does not provide the result of no predicted overflows, the CAFO could 

evaluate different designs and management options (such as different storage periods and 

dewatering schedules consistent with the CAFO’s NMP) that do not result in any predicted 

discharges, or the CAFO could conclude an open system is not appropriate for the particular site 

being evaluated. 

The demonstration requires certain information regarding design, operation, and maintenance of 

the system that would be included in the CAFO’s NMP under 40 CFR 122.42(e)(1). This 

information includes the key user-defined inputs and model system parameters. The site-specific 

design, construction, operation, and maintenance measures would then become enforceable 

requirements in the CAFO’s permit. As long as the CAFO complies with these requirements, the 

CAFO would presumptively meet no discharge even if it actually did discharge during extreme 

weather conditions. As with the “Voluntary alternative performance standards” provision for 

existing sources, the burden is on the CAFO to demonstrate any open system they employ meets 

the new source standard. EPA believes that this would provide a clear and enforceable element 

for the CAFO as well as provide assurance to the public that the proposed system would comply 

with the no discharge requirements. 

15.2 Best Conventional Pollutant Control Technology 

Section 15.2 presents a summary of the proposed BCT methodology, including the incorporation 

of FC removals into the two-part cost-reasonableness test, and presents the results of the BCT 

cost test. 

In considering whether to propose revised BCT limits for the Subpart C and D subcategories, 

EPA considered whether technologies are available that achieve greater removals of 

conventional pollutants than the current BPT effluent limitations guidelines. See Chapter 8 for a 

description of these technologies. EPA also considered whether those technologies are costreasonable according to the BCT cost test, which compares the incremental removals and costs 

associated with BCT limitations to a baseline associated with BPT. The candidate BCT 

15-4 
technologies do not pass the BCT cost test. Therefore, EPA is not proposing more stringent BCT 

limitations for Subparts C and D of this industry category. 

15.2.1 Background of BCT Cost Test 

The CWA Amendments that created BCT also specify that the cost associated with BCT effluent 

limitations be “reasonable” with respect to the effluent reductions. Accordingly, the “BCT 

Methodology” was developed to answer the question of whether it is “cost-reasonable” for 

industry to control conventional pollutants at a level more stringent than already required by BPT 

effluent limitations. The BCT methodology was originally published on August 29, 1979 along 

with the promulgation of BCT ELGs for 41 subcategories of the secondary industries (44 FR 

50732). The crux of the methodology was a comparison of the costs of removing conventional 

pollutants for an average-sized publicly owned treatment works (POTW). The Fourth Circuit 

Court remanded the regulation, and directed EPA to develop an industry cost test in addition to 

the POTW test. EPA proposed a revised BCT methodology in 1982 (47 FR 49176) that 

addressed the industry cost test. EPA proposed to base the POTW benchmark on model plant 

costs in a 1984 notice (49 FR 37046). 

The final BCT methodology was published on July 9, 1986 (51 FR 24974), maintaining the basic 

approach of the 1982 proposed BCT methodology and adopting the use of the new model POTW 

data. These guidelines state that the BCT cost analysis “...answers the question of whether it is 

‘cost reasonable’ for industry to control conventional pollutants at a level more stringent than 

BPT effluent limitations already require.” Conventional pollutants are five-day biological 

oxygen demand (BOD), total suspended solids (TSS), oil and grease, FC, and pH. 

The 1986 BCT methodology analysis incorporates two cost tests to establish cost reasonableness: 

the POTW Test and the Industry Cost Test. Each of these tests are compared with established 

benchmarks. The POTW benchmark used in the 1986 FRN is $0.25 per pound (in 1976 dollars) 

for industries where cost per pound is based on long-term performance data. This benchmark 

was developed using only BOD and TSS pollutant removals. (See 51 FR 24974 for more 

information on these two cost tests and benchmarks.) 

The 1986 FRN notes that FC is not included in the POTW Test calculations because control of 

that pollutant is not measurable as “pounds removed” (FC is typically measured in colony 

forming units (CFUs)1

, but offers no alternative means for addressing FC in BCT cost analyses. 

As such, the established cost test benchmarks do not incorporate FC removals. However, the 

1986 FRN also notes that in the case where there is a lack of comparable industry data, a strict 

comparison to the benchmark may undermine Congress’ intent on cost reasonableness. 

Therefore, EPA can develop appropriate industry-specific procedures to evaluate cost 

reasonableness. (51 FR 24976) For CAFOs, EPA developed procedures for evaluating cost 

reasonableness of BCT controls for FC. 

1

A colony forming unit is actually a single bacterium. The “CFU” term is derived from the test method where 

sample water is applied to a controlled medium (such as a Petri dish) and individual bacteria cells multiply until they 

form colonies, which can be easily recognized and counted. 

15-5 
15.2.1.1 BCT Cost Test Calculation Steps 

Establishing BCT effluent limitations for an industrial category or subcategory begins by 

identifying technology options that provide additional conventional pollutant control beyond that 

provided by application of BPT effluent limitations. EPA evaluates the candidate technologies 

by applying the two-part BCT cost test. 

The first part of the BCT cost test is the POTW test. To “pass” the POTW test, the cost per 

pound of conventional pollutant discharges removed in upgrading from BPT to the candidate 

BCT must be less than the cost per pound of conventional pollutant removed in upgrading 

POTWs from secondary treatment to advanced secondary treatment. 

The second part of the test that the “candidate” BCT technology must pass is the industry cost 

test. In this test the ratio of incremental costs to upgrade from BPT to BCT over the incremental 

costs to upgrade from no treatment to BPT is compared to the ratio of incremental costs for a 

POTW to upgrade from secondary treatment to advanced treatment over the incremental costs 

for a POTW to upgrade from no treatment to secondary treatment. 

Historically, EPA has evaluated the cost-reasonableness of each technology option on a 

subcategory basis. However, the candidate technologies being evaluated for BCT vary in costs 

and feasibility among species within a subcategory of CAFOs. The candidate technologies are 

also not likely to be applicable across an entire subcategory of CAFOs. For this reason, the 

historical approach will provide results that are less meaningful for the CAFO rule. Therefore 

EPA has evaluated each candidate technology based on a species-specific basis (the animal 

species for which the technology is believed to be feasible) rather than based on the subcategory 

as a whole. This approach eliminates the need to consider subcategories as a factor in the overall 

BCT methodology as applied to the CAFO industry. 

EPA reviewed the POTW cost estimate methodology in the 1986 FRN. Five model POTWs 

were established to represent five different flow ranges of POTWs, as shown in Table 15-2. 

Costs were developed by multiple engineering firms for each of the model POTWs. The costs 

represent the construction and operation costs of a secondary POTW, and the total annual cost to 

upgrade to advanced secondary treatment (i.e., polymer addition). The costs include chlorination 

(see 51 FR 24982, 2nd column, last paragraph). 

Table 15-2. Model POTWs and Representative Flow Ranges from the 1986 FRN 

Model POTW Representative Flow Range 

0.052 MGD 0 - 0.105 MGD 

0.38 MGD 0.106 - 1.05 MGD 

3.3 MGD 1.06 - 10.5 MGD 

25 MGD 10.0 - 50.2 MGD 

140 MGD >50.2 MGD 

The average model POTW costs were extrapolated to represent the entire industry by 

multiplying the average model POTW cost by a weighting factor. The weighting factors 

15-6 
represent the flow ranges of the model POTW, and were determined by dividing the amount of 

POTW industry flow in each flow range by the national POTW industry total flow. 

Historically, the two conventional pollutants used in calculating the POTW pollutant removal are 

BOD and TSS. In the first part of the BCT cost test, the POTW upgrade cost, or POTW 

benchmark, is compared to the upgrade cost to industry. The POTW benchmark from the 1986 

FRN was $0.25 (1976$) per pound BOD and TSS removed. EPA used cost index data from RS 

Means Historical Cost Indices to update this POTW benchmark to 2001$ according to the 

following equation: 

Index for 2001 

×Cost in 1976$ = Cost in 2001$ 

Index for 1976 

121.8 

×$0.25 = $0.65 

46.9 

EPA then calculated incremental costs per pound of BOD and TSS removed ($/lb) for each 

candidate technology. The upgrade cost to industry must be less than the POTW benchmark of 

$0.65 per pound (in 2001 dollars). If any candidate technology option passes the first part of the 

BCT cost test, the technology is further evaluated in the second part of the test. 

To pass the second part of the BCT cost test, the industry cost test, EPA computes a ratio of two 

incremental costs. The first incremental cost is the cost per pound removed by the candidate 

technology relative to BPT. The second incremental cost is the cost per pound removed by BPT 

relative to no treatment (i.e., raw wasteload). As in the POTW test, the ratio of the first cost 

divided by the second cost is compared to an industry cost benchmark. The industry cost 

benchmark is the ratio of two incremental costs: the cost per pound to upgrade a POTW from 

secondary treatment to advanced secondary treatment is divided by the cost per pound to initially 

achieve secondary treatment. If the industry ratio is lower than the benchmark, then the 

candidate technology passes the cost test. The industry cost benchmark is 1.29 (i.e., the cost 

increase must be less than 29 percent) (see 51 FR 24974; also see the pulp and paper final rule 

Technical Development Document, EPA-821-R-97-011). 

15.2.1.2 Data Sources Used in the BCT Cost Test Calculations 

EPA evaluated numerous sources of data on CAFO manure management systems, including 

treatment technologies and best management practices (BMPs) for pollution prevention, as well 

as for the handling, storage, treatment, and land application of wastes. These data sources 

include available technical literature, over 11,000 comments submitted by industry and other 

public commenters, and insights gained from conducting over 116 site visits to CAFOs. 

For this BCT cost test analysis, EPA calculated POTW costs and FC reductions to represent 

current POTW performance. EPA also calculated or revisited costs and FC reductions for lime 

treatment of dairy manure, anaerobic digestion of swine and dairy manure for pathogen 

reduction, and composting of poultry manure/litter. A variety of data sources were used in these 

analyses, including EPA data from the 2004 Clean Watersheds Needs Survey and Permit 

Compliance System database, items from the CAFO rule docket (OW-2002-0025), and new 

15-7 
sources relating to technology costs and performance in the CAFO industry. Chapter 5 discusses 

how EPA calculated costs and loads for the technology options evaluated in the BCT cost test. 

Section 15.3 presents the references used for the BCT cost test. 

EPA estimated costs, baseline conventional pollutant loads, and conventional pollutant 

reductions based on the Cost Methodology for the Final Revision to the National Pollutant 

Discharge Elimination System Regulation and the Effluent Guidelines for Concentrated Animal 

Feeding Operations, December 2002 (i.e., “Cost Report”), and Pollutant Loading Reductions for 

the Effluent Limitations Guidelines for Concentrated Animal Feeding Operations, December 

2002 (i.e., “Loads Report”). In general, EPA assumed an upper bound of 99 percent FC 

reductions are achieved by each production area technology considered. The literature suggests 

such high removals are not likely to be achieved. However, EPA notes if no technology passes 

the cost test at the upper bound 99 percent FC removals, then any technology of similar cost will 

also not pass the cost test. Chapter 5 presents a description of each technology option’s costs and 

pollutant loads. 

15.2.2 Development of BCT Cost Test for FC 

Although FC is not typically evaluated in the BCT cost test, EPA’s BCT methodology 

specifically contemplated that in certain instances, EPA would need to develop appropriate 

procedures to evaluate cost-reasonableness on an industry-specific basis. (51 FR 24976) 

Moreover, CWA Section 304(b)(4)(B) authorizes EPA to consider other appropriate factors in 

establishing BCT. Therefore, Section 15.2.2 presents an alternative approach to conducting the 

cost-reasonableness test that directly accounts for pathogens by specifically looking at FC, the 

only conventional pollutant that is a possible pathogen. The approach is identical to the two-part 

cost-reasonableness test described in Section 15.2.1.1, except pounds of BOD and TSS are 

replaced by colony forming units (CFU) of FC. EPA’s methodology to perform the BCT cost 

test for FC employed the following steps. 

1. Calculate a POTW cost test benchmark for FC reduction ($/trillion CFU of FC removed). 

2. Calculate an industry cost test benchmark, which is the ratio of the POTW secondary to 

advanced incremental cost/unit of FC removed to the POTW raw to secondary 

cost/trillion CFU of FC removed. 

3. Obtain industry costs from regulatory options explored in the original rulemaking and 

calculate industry costs for newly explored technologies ($/trillion CFU of FC removed). 

4. Perform the first part of the BCT cost test (the POTW test) by comparing the industry 

option cost to the POTW benchmark cost. 

5. Perform the second part of the BCT cost test (the industry cost test) by comparing the 

POTW cost ratio to the candidate technology industry cost ratio. 

The remainder of this section describes the development of the POTW and industry benchmarks 

for FC removal. Section 15.2.3 presents the results of the BCT cost tests. 

15-8 
15.2.2.1 Calculation of POTW Benchmark for FC 

EPA developed a new benchmark to use for the POTW test, which estimates the cost to reduce 

FC bacteria at a POTW. Because the 1986 FRN costs include biological treatment and 

disinfection, EPA assumed that no additional treatment would be needed to remove FC, and the 

costs from the 1986 FRN could be used as the starting point for the analysis. EPA updated the 

1986 FRN annual costs for each model POTW from 1976$ to 2001$, using the RS Means 

Historical Cost Indices. (See Tables 15-3 and 15-4.) 

EPA then calculated annual influent and effluent FC loads. EPA estimated the FC concentration 

in untreated wastewater using accepted engineering design manuals, (EPA Docket OW-2005­

0037, DCNs 1-01001, 1-01002 and 1-01220). Domestic wastewater typically contains FC 

concentrations between 1 and 10 million CFU/100mL. EPA compared this range of FC 

concentrations with other data sources and considers this to be a good estimate.2 EPA used the 

mid-point of this range (5,000,000 CFU/ 100 mL) as the influent FC concentration for all model 

POTWs (secondary and advanced secondary). EPA considered using measured POTW data 

from EPA’s Permit Compliance System (PCS) data, but there were insufficient data reported in 

PCS for influent3 FC concentrations at POTWs. 

Secondary treatment does not require FC reductions. Therefore, EPA estimated the final effluent 

FC concentration from POTWs with secondary treatment to be 200 CFU/100mL, which is the 

standard water quality criterion for FC according to EPA’s Ambient Water Quality Criteria for 

Bacteria. EPA multiplied the effluent and influent FC concentrations by the annual flow at each 

model POTW to calculate influent and effluent FC loads. EPA estimated FC removals by 

subtracting effluent loads from influent loads for each model POTW. The removal cost was 

calculated by dividing the annual cost of operation by the trillions of CFUs removed. Table 15-3 

shows EPA’s estimated costs of secondary treatment and FC removal at each model POTW. 

EPA estimated costs and loads at POTWs with advanced secondary treatment using the same 

process as secondary treatment at POTWs, with the exception of the effluent FC concentration. 

For advanced secondary POTWs, EPA used Permit Compliance System (PCS) data to determine 

the effluent FC concentrations that POTWs are actually achieving. Based on the median point of 

all POTWs that report to PCS, EPA used an effluent FC concentration of 21 CFU/100 mL for 

advanced secondary POTWs. Table 15-4 shows EPA’s estimated costs of advanced secondary 

treatment and FC removal at each model POTW. 

EPA determined the incremental cost per trillion CFU removed between secondary and advanced 

secondary treatment for each model POTW, and applied a flow weighting factor to determine an 

incremental cost per trillion CFU removed for the entire POTW industry. EPA created updated 

weighting factors, following the same methodology as the 1986 FRN and using the flow data 

from the 2004 Clean Watersheds Needs Survey (CWNS). EPA divided the total flow in each 

POTW size category by the sum of all POTW flows. Table 15-5 presents the data used to 

calculate the flow weighting factors. 

2

Other FC data sources include EPA’s Meat & Poultry Processing Final Rule, Onsite Wastewater Treatment 

Systems Manual, and Small and Decentralized Wastewater Management Systems (Crites & Tchobanoglous). 3

Both influent and effluent data are needed to calculate FC reductions. 

15-9 
EPA multiplied the incremental costs for each model POTW by the flow weighting factor and 

summed the results to get a flow weighted cost. The resulting incremental cost is the POTW 

benchmark value for FC. The benchmark was determined to be $0.33 per trillion CFU removed 

(in 2001$). Table 15-6 presents these incremental costs used to calculate the POTW benchmark. 

15-10
Table 15-3. Cost of Secondary Treatment 

15-11 

BCT POTW Flow Ranges 

and Model POTW Flows 

(MGD) (a) 

Annual Cost of Model 

POTW Operation 

(1976$) (b) 

Annual Cost of 

Model POTW 

Operation (2001$) 

Influent FC Load 

(trillion CFU/year) 

(c) 

Effluent FC Load 

(trillion 

CFU/year) (d) 

FC R

(tri

CFU

0 - 0.105 (Model=0.052) $40,000 $103,881 3.5923E+15 1.4369E+11 3.5920.106 - 1.05 (Model=0.38) $156,000 $405,134 2.6252E+16 1.0501E+12 2.6251.06 - 10.5 (Model=3.3) $1,351,000 $3,508,567 2.2798E+17 9.1190E+12 2.27910.6 - 50.2 (Model=25) $5,456,000 $14,169,313 1.7271E+18 6.9084E+13 1.727> 50.2 (Model=140) $20,151,000 $52,332,448 9.6717E+18 3.8687E+14 9.671

(a) 51 FR 24974 Table 2, page 24983. (b) 51 FR 24974 Table 4, page 24983. (c) Based on influent FC concentration of 5,000,000 CFU/100mL. (c) Based on effluent FC concentration of 200 CFU/100mL. 

Table 15-4. Cost of Advanced Secondary Treatment 

BCT POTW Flow Ranges 

and Model POTW Flows 

(MGD) 

Annual Cost of Model 

POTW Operation 

(1976$) 

Annual Cost of 

Model POTW 

Operation 

(2001$) 

Influent FC Load 

(trillion CFU/year) 

(c) 

Effluent FC Load 

(trillion 

CFU/year) (d) 

FC R

(tri

CFU

0 - 0.105 (Model=0.052) $40,000 $103,881 3.5923E+15 1.5088E+10 3.5920.106 - 1.05 (Model=0.38) $156,000 $405,134 2.6252E+16 1.1026E+11 2.6251.06 - 10.5 (Model=3.3) $1,398,000 $3,630,627 2.2798E+17 9.5750E+11 2.27910.6 - 50.2 (Model=25) $5,696,000 $14,792,567 1.7271E+18 7.2538E+12 1.727> 50.2 (Model=140) $20,034,000 $54,625,612 9.6717E+18 4.0621E+13 9.671

(a) 51 FR 24974 Table 2, page 24983. (b) 51 FR 24974 Table 4, page 24983. (c) Based on influent FC concentration of 5,000,000 CFU/100mL. (c) Based on effluent FC concentration of 21 CFU/100mL. 
Table 15-5. Weighting Factors 

Size of Model POTW 

(MGD) 

Representative Flow Range 

(MGD) 

Total Flow for All POTWs 

(MGD) (a) Weighting Factor 

0.052 0 - 0.105 303 0.0091 

0.38 0.106 - 1.05 2395 0.0720 

3.3 1.06 - 10.5 8983 0.2701 

25 10.6 - 50.2 8644 0.2599 

140 > 50.2 12939 0.3890 

ALL ALL 33264 1 

(a) The total flow for all POTWs column reflects CWNS data. 

Table 15-6. POTW Benchmark for FC 

Size of POTW (MGD) Weighting Factor 

Annual Incremental Cost 

per Trillion CFUs Removed from Secondary 

Treatment to Advanced Secondary Treatment 

0.052 0.0091 $0.00 

0.38 0.0720 $0.00 

3.3 0.2701 $0.53 

25 0.2599 $0.36 

140 0.3890 $0.24 

Flow-weighted Incremental Cost ($/trillion CFU): $0.33 

15.2.2.2 Calculation of Industry Benchmark for FC 

The second test that the candidate BCT technology must pass to be considered cost-reasonable is 

the industry cost test. As described previously, to pass the industry cost test, EPA computes a 

ratio of two incremental costs. In the alternative cost test, the FC reductions are used in lieu of 

pounds TSS and BOD. The first incremental cost is therefore the cost per CFU removed by the 

candidate technology relative to BPT. The second incremental cost is the cost per CFU removed 

by BPT relative to no treatment (i.e., raw wasteload). The industry cost benchmark is the ratio of 

two incremental costs: the cost per CFU to upgrade a POTW from secondary treatment to 

advanced secondary treatment (the POTW benchmark) is divided by the cost per CFU to initially 

achieve secondary treatment. If the industry ratio is lower than the benchmark, then the 

candidate technology passes the cost test. 

The cost per CFU to initially achieve secondary treatment is presented for each model POTW in 

Table 15-4. Table 15-7 presents the flow-weighted cost of secondary treatment for the entire 

POTW industry. 

15-12
Table 15-7. Flow–weighted Cost of Secondary Treatment 

Size of 

POTW 

(MGD) 

Upgrade Cost from Raw 

Waste to Secondary 

($/trillion CFU) 

Upgrade Cost from 

Secondary to Advanced 

(Incremental $/trillion 

CFU) 

Cost 

Ratio 

Weighting 

Factor 

Weighted 

Ratio 

0 - 0.105 $28.92 $0.00 0.0000 0.0090 0.00 

0.106 - 1.05 $15.43 $0.00 0.0000 0.0712 0.00 

1.06 - 10.5 $15.39 $0.53 0.0348 0.2677 0.01 

10.6 - 50.2 $8.20 $0.36 0.0440 0.2619 0.01 

> 50.2 $5.41 $0.24 0.0438 0.3901 0.02 

Flow-weighted Industry Cost Benchmark: 0.04 

The cost ratio is calculated for each POTW size using the following equation: 

Cost per trillion CFU to upgrade to secondary treatment to advanced secondary treatment

Cost per trillion CFU to initially achieve secondary treatment

The cost ratio for each POTW size is multiplied by a flow weighting factor and the weighted 

ratios are summed to determine the flow-weighted industry cost benchmark. For this BCT cost 

test, the industry cost benchmark is 0.04. 

15.2.3 Results of BCT Cost Test 

EPA identified several technology options that potentially provide additional control of some 

conventional pollutants beyond that provided by BPT. (See Chapter 5 for more details.) From 

these technology options, EPA identified five options that are technologically feasible at CAFOs: 

y Groundwater controls (Option 3); 

y No discharge (Option 5); 

y Composting (Option 5A); 

y Anaerobic digestion (Option 6); and 

y Land application timing restrictions (Option 7). 

In the BCT cost test, EPA evaluates various candidate technologies to assess whether they are 

“practical” (technologically feasible for all facilities in a subcategory) and would achieve greater 

reductions of FC than the technologies selected as the basis for BPT in the 2003 rule. EPA finds 

that none of these candidate technologies would pass both parts of the BCT cost test. 

This section provides the results of EPA’s BCT cost-reasonableness test for these options. EPA 

evaluated cost reasonableness for both BOD and TSS removals (the traditional cost 

reasonableness test, see Section 15.2.3.1), as well as FC removals (alternative cost 

reasonableness test, see Section 15.2.3.2). 

15.2.3.1 BCT Cost Test for BOD and TSS Removals 

In the traditional BCT cost test evaluation of BOD and TSS, EPA calculated incremental 

industry costs for all candidate BCT technologies compared to the BCT option. Table 15-8 

15-13
provides a summary of the costs and BOD and TSS reductions of the 2003 CAFO rule BPT. 

Pollutant removals were determined using the 2003 final CAFO rule methodology, as described 

in Section 8.6.3. Table 15-9 provides incremental costs and incremental pollutant removals of 

candidate technologies in relation to BPT. Incremental costs are the costs of the technology 

option minus the BPT costs from Table 15-8. Incremental load reductions are the pounds 

removed by the technology option minus the BPT load reductions from Table 15-8. Total 

incremental reductions include the summation of BOD and TSS removals. EPA has evaluated 

the candidate technologies on a species-specific basis rather than on a subcategory wide basis. 

Table 15-8. 2003 CAFO Rule BPT Costs and BOD & TSS Removals 

Sector 

Annualized costs 

($2001, millions, 

pre-tax) 

BOD removed 

(million pounds) 

TSS removed 

(million pounds 

sediment) 

Total pounds 

removed (million 

pounds) 

Beef 86 0 1201 1201 

Dairy 128 0 99 99 

Swine 25 0 113 113 

Poultry 41 6 181 187 

Table 15-9. Incremental Costs and BOD & TSS Removals of Candidate Technologies 

Candidate 

Technology 

Animal 

Sector 

Annualized Costs 

of Candidate 

Technology 

Option 

($2001, millions, 

pre-tax) 

Incremental 

Costs 

($2001, 

millions, pretax) 

Incremental 

BOD 

Removed 

(million 

pounds) 

Incremental 

TSS Removed 

(million 

pounds 

sediment) 

Total 

Incremental 

Reductions 

(million 

pounds) 

Ground water 

Controls a 

Beef 231 145 NC (a) NC NC 

Dairy 316 188 NC NC NC 

Swine 61 36 NC NC NC 

No Discharge Swine 133 108 7 0 7 

Composting Beef 1,367 1281 3 25 28 

Dairy 277 149 1 7 8 

Poultry 508 467 0 ND (b) ND 

Anaerobic 

Digestion 

Dairy 505 377 2 9 11 

Swine 79 54 6 0.5 7 

Land 

Application 

Timing 

Restrictions 

Beef 112 26 0.01 0.06 0.08 

Dairy 318 190 2 7 9 

Swine 37 12 7 1 8 

(a) NC Values were not calculated because no additional pollutant removal was expected for these options. 

(b) ND -

 Values were non-zero, but too small to report in the indicated units 

The POTW upgrade cost is referred to as the POTW benchmark; its derivation is described in the 

1986 final BCT methodology notice (51 FR 24974). The upgrade cost to industry must be less 

than the POTW benchmark of $0.25 per pound (in 1976 dollars) or $0.65 per pound (in 2001 

15-14 
dollars). Table 15-10 provides the cost per pound of conventional pollutants (BOD and TSS) 

removed by the candidate technology and the results of the first part of the BCT cost test. 

Table 15-10. BOD & TSS Cost Test Part One - POTW Test Results 

Candidate Technology Animal Sector 

Incremental cost per pound 

removed by technology 

($/lb) POTW Test Result 

Ground water controls Beef NC (a) Fail 

Dairy NC Fail 

Swine NC Fail 

No discharge Swine 13.55 Fail 

Composting Beef 46.39 Fail 

Dairy 17.84 Fail 

Poultry NC Fail 

Anaerobic Digestion Dairy 34.15 Fail 

Swine 7.89 Fail 

Land Application Timing Restrictions Beef 366.65 Fail 

Dairy 20.90 Fail 

Swine 1.55 Fail 

(a) NC Values were not calculated because no additional BOD or TSS removal was expected for these options. 

In all cases, the POTW benchmark is lower than the cost per pound of conventional pollutants 

removed by the candidate technology. Since the candidate technologies all fail the POTW cost 

test, the candidate technologies are not cost-reasonable. EPA notes even though a candidate 

technology may be affordable for a subcategory, the candidate technologies must be costreasonable to be further considered as a basis for BCT. 

EPA believes that since all candidate technologies fail the POTW test for each species evaluated, 

any technology option developed for subcategories C or D utilizing a combination of these 

candidate technologies also fails the POTW test. For example, for subcategory C CAFOs (beef 

and dairy facilities), no technology option passes the cost test for either beef or dairy operations, 

therefore no combination of technology options can be constructed for subcategory C (beef and 

dairy facilities) that will pass the cost test. 

EPA is applying the results presented here for dairy, swine, and poultry operations to veal calf 

facilities because they are typically total confinement operations with similar waste management 

systems. Similarly, the results for beef cattle operations may be applied to heifer operations 

which use waste management technologies identical to those used by beef feedlots. EPA notes 

veal calf and heifer operations reflect approximately 2 percent of all Large CAFOs. 

The second test that the candidate BCT technology must pass to be considered cost-reasonable is 

the industry cost test. (See Section 15.2.1.1.) The industry cost benchmark is 1.29 (i.e., the cost 

increase must be less than 29 percent) (see 51 FR 24974; also see the pulp and paper final rule 

Technical Development Document, EPA-821-R-97-011). Table 15-11 shows the ratio of the 

15-15
incremental costs for the candidate technology options and the results of the second part of the 

BCT cost test. 

Table 15-11. BOD & TSS Cost Test Part Two – Industry Cost Test Results 

Candidate Technology Animal Sector 

Candidate 

Technology Cost 

Ratio 

Industry Cost 

Benchmark 

Industry Cost 

Test Result 

Ground water controls Beef NC (a) 1.29 Fail 

Dairy NC 1.29 Fail 

Swine NC 1.29 Fail 

No discharge Swine 61.15 1.29 Fail 

Composting Beef 647.70 1.29 Fail 

Dairy 13.86 1.29 Fail 

Poultry NC 1.29 Fail 

Anaerobic digestion Dairy 26.52 1.29 Fail 

Swine 35.63 1.29 Fail 

Land Application Timing 

Restrictions 

Beef 5,119.52 1.29 Fail 

Dairy 16.23 1.29 Fail 

Swine 6.99 1.29 Fail 

(a) NC—Values were not calculated because no additional pollutant removal was expected for these options. 

In all cases, the industry cost ratio is higher than the industry cost benchmark. Even if a 

candidate technology was to pass the POTW cost test, none of the candidate technologies pass 

the industry cost test. EPA believes that since all candidate technologies fail the industry cost 

test for each species evaluated, any technology option developed for subcategories C or D 

utilizing a combination of these candidate technologies also fails the industry cost test. 

15.2.3.2 BCT Cost Test for FC Removals 

In the alternative BCT cost test for FC, EPA calculated incremental industry costs for all 

candidate BCT technologies compared to the BCT option. Table 15-12 presents the costs and 

FC removals of the 2003 CAFO rule (BPT). Table 15-13 provides incremental costs and 

incremental FC removals of candidate technologies in relation to BPT. FC removals were 

determined using the 2003 final CAFO rule methodology. In this alternative analysis, EPA has 

again evaluated the candidate technologies on a species-specific basis rather than on a 

subcategory basis. 

15-16
Table 15-12. 2003 CAFO Rule BPT Costs and FC Removals 

Sector 

Annualized costs 

($2001, millions, pre-tax) 

FC Removed 

(million CFU) 

Beef 86 10.56 × 10 13 

Dairy 128 0.97 × 10 13 

Swine 25 0.42 × 10 13 

Poultry (wet and dry) 41 6.74 × 10 13 

Table 15-13. Incremental Costs and FC Removals of Candidate Technologies 

Candidate Technology Animal Sector 

Incremental Annualized 

Cost ($2001, millions, 

pre-tax) 

Incremental FC 

Removed (million 

CFU) 

Ground water controls a Beef 145 NC (a) 

Dairy 188 NC 

Swine 36 NC 

No discharge Swine 108 137.4x 1013 

Composting Beef 1281 249.9 x 1013 

Dairy 149 30.4 x 1013 

Poultry 467 0.460 x 1013 

Anaerobic digestion Dairy 377 33.3x 1013 

Swine 54 170.3x 1013 

Land Application Timing Restrictions Beef 26 0.557 x 1013 

Dairy 190 22.9 x 1013 

Swine 12 136.1 x 1013 

(a) NC Values were not calculated because no additional pollutant removal was expected for these options. 

EPA developed a new benchmark to use for this alternative POTW test, which reflects the cost to 

reduce FC at a POTW. The resulting incremental cost per trillion CFU removed was $0.33 

($2001). Table 15-14 shows the POTW test result using the alternative POTW benchmark for 

conducting part one of the cost-reasonableness test. 

15-17
Table 15-14. Alternative Cost Test Part One - POTW Test Results 

Candidate Technology Animal Sector 

Cost per trillion CFU 

removed by technology POTW Test Result 

Ground water controls Beef NC Fail 

Dairy NC Fail 

Swine NC Fail 

No discharge Swine 1.46 Fail 

Composting Beef 0.51 Fail 

Dairy 0.49 Fail 

Poultry 101.44 Fail 

Anaerobic digestion Dairy 1.64 Fail 

Swine 0.04 Pass 

Land Application Timing Restrictions Beef 4.58 Fail 

Dairy 0.83 Fail 

Swine 0.01 Pass 

In some cases, the alternate POTW benchmark is lower than the cost per pound of conventional 

pollutants removed by the candidate technology. In these cases, EPA believes the candidate 

technologies fail the alternate POTW test. The remaining candidate technologies pass the 

POTW test and move on to the second cost test. 

The second test that the candidate BCT technology must pass to be considered cost-reasonable is 

the industry cost test. As described previously, to pass the industry cost test, EPA computes a 

ratio of two incremental costs. In the alternative cost test, the FC reductions are used in lieu of 

pounds TSS and BOD. The first incremental cost is therefore the cost per CFU removed by the 

candidate technology relative to BPT. The second incremental cost is the cost per CFU removed 

by BPT relative to no treatment (i.e., raw wasteload). The industry cost benchmark is the ratio of 

two incremental costs: the cost per CFU to upgrade a POTW from secondary treatment to 

advanced secondary treatment is divided by the cost per CFU to initially achieve secondary 

treatment. If the industry ratio is lower than the benchmark, then the candidate technology 

passes the cost test. The industry cost benchmark is 0.04. Table 15-15 shows the ratio of the 

incremental costs for the candidate technology options and the results of the second part of the 

BCT cost test. 

Table 15-15. Alternative Cost Test Part Two – Industry Cost Test Results 

Candidate Technology Animal Sector 

Candidate 

Technology Cost 

Ratio 

Industry Cost 

Benchmark 

Industry Cost 

Test Result 

Anaerobic digestion Swine 6.63 0.04 Fail 

Land Application Timing 

Restrictions 

Swine 1.48 0.04 Fail 

All candidate technologies passing the POTW test fail the industry cost test. In all cases, the 

industry cost ratio is several orders of magnitude higher than the industry cost benchmark. As 

discussed in 4.1.2, EPA assumed 99 percent FC reductions were achieved by any candidate 

15-18 
production area technology. Lower FC reductions result in higher industry cost ratios, and 

would result in failing the industry cost test by an even higher margin. Since all candidate 

technologies fail the cost-reasonableness test for each species evaluated, any technology option 

developed for subcategories C or D utilizing a combination of these candidate technologies also 

fails the cost test. 

15.3 References 

Baker, James C. Design Criteria for Swine Waste Flushing Systems. March 1996. Available 

online at 

http://www5.bae.ncsu.edu/programs/extension/publicat/wqwm/ebae080_81.html. EPA 

Docket OW-2005-0037, DCN 1-01216. 

Crites and Tchobanoglous, Eds. Small and Decentralized Wastewater Management Systems. 

(McGraw-Hill), 1998. EPA Docket OW-2005-0037, DCN 1-01001. 

Great Lakes-Upper Mississippi River Board of State and Provincial Public Health and 

Environmental Managers. Recommended Standards for Wastewater Facilities (i.e., TenState Standards), 2004 Edition. EPA Docket OW-2005-0037, DCN 1-01220. 

Metcalf and Eddy, Inc. Wastewater Engineering (3rd Edition), 1991. EPA Docket OW-2005­

0037, DCN 1-01002. 

Moffitt, David, C., et. al. Evaluating the Design and Management of Waste Storage Ponds 

Receiving Lot Runoff. Presented at the ASAE International Meeting 2003 in Las Vegas, 

Nevada. ASAE paper number 034129. July, 2003. EPA Docket OW-2005-0037, DCN 

1-01223. 

Moffitt, David, C. and Wilson, Bruce. Evaluating the Design and Management of Waste Storage 

Ponds-Part II. Presented at the 2004 ASAE/CSAE Annual International Meeting 2004, 

Ottawa, Ontario, Canada. ASAE paper number 044072. 2004. EPA Docket OW-2005­

0037, DCN 1-01224. 

NRCS Conservation Practice Standard (313) Waste Storage Facility. October 2003. Available 

online at ftp://ftp-fc.sc.egov.usda.gov/NHQ/practice-standards/standards/313.doc. EPA 

Docket OW-2005-0037, DCN 1-01217 

R.S. Means. Mossman, Melville (Ed.). Mechanical Cost Data: 24th Annual Edition (p. 577), 

2001. EPA Docket OW-2005-0037, DCN 1-01003 

U.S. Department of Agriculture. A SPAW Evaluation of Five AWM Designed Swine Manure 

Storage Facilities. EPA Docket OW-2005-0037, DCN 1-01225. 

U.S. Department of Agriculture. Case Studies on AWM and SPAW. EPA Docket OW-2005­

0037, DCN 1-01226. 

15-19
U.S. Department of Agriculture Natural Resources Conservation Service (NRCS). Agricultural 

Waste Management Field Handbook. National Engineering Handbook Part 651. June 

1999. Available online at http://www.wcc.nrcs.usda.gov/awm. 

U.S. Department of Agriculture Natural Resources Conservation Service (NRCS). Animal 

Waste Management (AWM). NRCS design tool that is based on the design procedures in 

the NRCS Animal Waste Management Field Handbook. Available online at 

http://www.wcc.nrcs.usda.gov/awm/awm.html. EPA Docket OW-2005-0037, DCN 1­

01196. 

USEPA. Ambient Water Quality Criteria for Bacteria (EPA 440/5-84-002). January 1986. EPA 

Docket OW-2005-0037, DCN 1-01004. 

USEPA. BCT Benchmarks: Methodology, Analysis, and Results. May 1986. EPA Docket OW2005-0037, DCN 1-01014. 

USEPA. Clean Watersheds Needs Survey. 2004. EPA Docket OW-2005-0037, 

 DCN 1-01005A1. 

USEPA. Cost Methodology for the Final Revisions to the National Pollutant Discharge 

Elimination System Regulation and the Effluent Guidelines for Concentrated Animal 

Feeding Operations (EPA-821-R-03-004). December 2002. 

USEPA. Meat & Poultry Processing Final Rule, Technical Development Document (EPA-821­

R-04-011), Table 6-3. July 2004. Available online at 

http://www.epa.gov/guide/mpp/tdd/vol1.pdf. 

USEPA. Managing Manure Nutrients at Concentrated Animal Feeding Operations (EPA-821­

B-04-009). December 2004. 

USEPA. Onsite Wastewater Treatment Systems Manual (EPA-625-R-00-008). February 2002. 

EPA Docket OW-2005-0037, DCN 1-01006 

USEPA. Permit Compliance System. Available online at 

http://www.epa.gov/enviro/html/pcs/�pcs_query_java.html. EPA Docket OW-2005­

0037, DCN 1-01005A1. 

USEPA. Pollutant Loading Reductions for the Effluent Limitations Guidelines for Concentrated 

Animal Feeding Operations (EPA-821-R-03-007). December 2002. 

USEPA. Pulp and Paper Rulemaking, Technical Support Document. (EPA-821-R-97-011). 

October 1997. 

15-20
Appendix A 

MODEL FARM RESULTS FOR MODIFIED OPTION 6 FOR SWINE
Table A-1. Model Farm Results for Modified Option 6 for Swine 

A-20 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Evapor FF Large2 CE 1 H 3.1 $526,268 $8,783 $346 Swine Evapor FF Large1 CE 1 H 4.3 $295,703 $7,408 $336 Swine Pit FF Large2 MA 1 H 1.8 $461,407 $8,052 $286 Swine Pit FF Large1 MA 1 H 2.5 $229,107 $5,647 $226 Swine Liquid FF Large2 MA 1 H 5.6 $1,126,858 $21,636 $876 Swine Liquid FF Large1 MA 1 H 7.8 $567,108 $16,002 $706 Swine Pit FF Large2 MW 1 H 25.0 $5,594,708 $84,367 $3066 Swine Pit FF Large1 MW 1 H 34.8 $3,549,031 $73,412 $2956 Swine Liquid FF Large2 MW 1 H 19.3 $3,826,609 $61,008 $2366 Swine Liquid FF Large1 MW 1 H 26.9 $2,443,068 $54,324 $2286 Swine Evapor GF Large2 CE 1 H 3.2 $519,232 $9,066 $416 Swine Evapor GF Large1 CE 1 H 4.4 $289,629 $7,580 $376 Swine Pit GF Large2 MA 1 H 2.8 $673,250 $12,525 $516 Swine Pit GF Large1 MA 1 H 3.9 $335,727 $8,810 $386 Swine Liquid GF Large2 MA 1 H 4.7 $890,941 $18,159 $856 Swine Liquid GF Large1 MA 1 H 6.6 $452,934 $13,540 $656 Swine Pit GF Large2 MW 1 H 32.1 $7,094,895 $108,328 $4466 Swine Pit GF Large1 MW 1 H 44.7 $4,503,298 $94,297 $4136 Swine Liquid GF Large2 MW 1 H 13.3 $2,706,030 $42,042 $1846 Swine Liquid GF Large1 MW 1 H 18.5 $1,723,222 $37,361 $1716 Swine Evapor FF Large2 CE 2 H 7.0 $1,909,420 $26,010 $1036 Swine Evapor FF Large1 CE 2 H 9.7 $907,645 $18,239 $83

1 
Table A-1 (Continued) 

A-2 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Pit FF Large2 MA 2 H 10.3 $4,485,065 $31,167 $9816 Swine Pit FF Large1 MA 2 H 14.3 $2,108,966 $23,601 $5076 Swine Liquid FF Large2 MA 2 H 32.7 $11,633,933 $98,949 $7556 Swine Liquid FF Large1 MA 2 H 45.6 $5,611,505 $75,260 $5196 Swine Pit FF Large2 MW 2 H 24.9 $9,717,679 $118,333 $6966 Swine Pit FF Large1 MW 2 H 34.7 $4,220,445 $75,164 $4226 Swine Liquid FF Large2 MW 2 H 19.2 $6,857,692 $91,245 $3386 Swine Liquid FF Large1 MW 2 H 26.8 $3,042,013 $58,052 $2476 Swine Evapor GF Large2 CE 2 H 7.2 $1,876,410 $26,753 $1286 Swine Evapor GF Large1 CE 2 H 10.0 $895,090 $18,803 $966 Swine Pit GF Large2 MA 2 H 16.5 $6,737,094 $49,928 $1,666 Swine Pit GF Large1 MA 2 H 23.0 $3,183,561 $37,960 $8616 Swine Liquid GF Large2 MA 2 H 27.5 $9,236,237 $83,214 $7556 Swine Liquid GF Large1 MA 2 H 38.4 $4,470,018 $63,376 $4936 Swine Pit GF Large2 MW 2 H 32.0 $12,333,453 $152,075 $1,026 Swine Pit GF Large1 MW 2 H 44.6 $5,358,333 $96,609 $6006 Swine Liquid GF Large2 MW 2 H 13.2 $4,834,862 $62,731 $2706 Swine Liquid GF Large1 MW 2 H 18.5 $2,151,490 $40,073 $1866 Swine Evapor FF Large2 CE 3 H 4.0 $3,648,880 $- $1476 Swine Evapor FF Large1 CE 3 H 5.5 $733,749 $- $546 Swine Pit FF Large2 MA 3 H 3.0 $1,517,530 $- $3686 Swine Pit FF Large1 MA 3 H 4.2 $637,081 $- $1696 Swine Liquid FF Large2 MA 3 H 9.6 $3,797,478 $- $245
Table A-1 (Continued) 

A-3 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Liquid FF Large1 MA 3 H 13.3 $1,589,050 $- $1526 Swine Pit FF Large2 MW 3 H 20.9 $13,908,052 $- $1,386 Swine Pit FF Large1 MW 3 H 29.1 $5,251,387 $- $6326 Swine Liquid FF Large2 MW 3 H 16.1 $9,456,666 $- $4146 Swine Liquid FF Large1 MW 3 H 22.5 $3,600,023 $- $2456 Swine Evapor GF Large2 CE 3 H 4.1 $3,571,413 $- $1936 Swine Evapor GF Large1 CE 3 H 5.7 $726,881 $- $656 Swine Pit GF Large2 MA 3 H 4.8 $2,276,425 $- $6146 Swine Pit GF Large1 MA 3 H 6.7 $953,577 $- $2796 Swine Liquid GF Large2 MA 3 H 8.1 $3,016,338 $- $2486 Swine Liquid GF Large1 MA 3 H 11.2 $1,261,200 $- $1456 Swine Pit GF Large2 MW 3 H 26.8 $17,611,766 $- $1,906 Swine Pit GF Large1 MW 3 H 37.4 $6,665,873 $- $8626 Swine Liquid GF Large2 MW 3 H 11.1 $6,692,901 $- $3406 Swine Liquid GF Large1 MW 3 H 15.5 $2,544,888 $- $1896 Swine Evapor FF Large2 CE 1 L 3.1 $520,421 $- $336 Swine Evapor FF Large1 CE 1 L 4.3 $289,699 $- $316 Swine Pit FF Large2 MA 1 L 1.8 $460,262 $- $276 Swine Pit FF Large1 MA 1 L 2.5 $227,683 $- $216 Swine Liquid FF Large2 MA 1 L 5.6 $1,116,502 $- $856 Swine Liquid FF Large1 MA 1 L 7.8 $556,683 $- $676 Swine Pit FF Large2 MW 1 L 25.0 $5,579,646 $- $2966 Swine Pit FF Large1 MW 1 L 34.8 $3,529,388 $- $282
Table A-1 (Continued) 

A-4 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Liquid FF Large2 MW 1 L 19.3 $3,794,309 $- $2286 Swine Liquid FF Large1 MW 1 L 26.9 $2,407,573 $- $2186 Swine Evapor GF Large2 CE 1 L 3.2 $513,196 $- $406 Swine Evapor GF Large1 CE 1 L 4.4 $283,485 $- $356 Swine Pit GF Large2 MA 1 L 2.8 $671,469 $- $506 Swine Pit GF Large1 MA 1 L 3.9 $333,506 $- $376 Swine Liquid GF Large2 MA 1 L 4.7 $882,249 $- $836 Swine Liquid GF Large1 MA 1 L 6.6 $444,113 $- $626 Swine Pit GF Large2 MW 1 L 32.1 $7,075,555 $- $4336 Swine Pit GF Large1 MW 1 L 44.7 $4,478,068 $- $3966 Swine Liquid GF Large2 MW 1 L 13.3 $2,683,772 $- $1796 Swine Liquid GF Large1 MW 1 L 18.5 $1,698,811 $- $1636 Swine Evapor FF Large2 CE 2 L 7.0 $1,893,694 $- $1006 Swine Evapor FF Large1 CE 2 L 9.7 $892,754 $- $796 Swine Pit FF Large2 MA 2 L 10.3 $4,478,968 $- $9726 Swine Pit FF Large1 MA 2 L 14.3 $2,101,096 $- $4996 Swine Liquid FF Large2 MA 2 L 32.7 $11,649,550 $- $7436 Swine Liquid FF Large1 MA 2 L 45.6 $5,615,828 $- $5036 Swine Pit FF Large2 MW 2 L 24.9 $9,701,644 $- $6866 Swine Pit FF Large1 MW 2 L 34.7 $4,200,794 $- $4096 Swine Liquid FF Large2 MW 2 L 19.2 $6,863,569 $- $3306 Swine Liquid FF Large1 MW 2 L 26.8 $3,040,848 $- $2376 Swine Evapor GF Large2 CE 2 L 7.2 $1,860,236 $- $125
Table A-1 (Continued) 

A-5 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Evapor GF Large1 CE 2 L 10.0 $879,738 $- $926 Swine Pit GF Large2 MA 2 L 16.5 $6,727,328 $- $1,656 Swine Pit GF Large1 MA 2 L 23.0 $3,170,904 $- $8486 Swine Liquid GF Large2 MA 2 L 27.5 $9,249,370 $- $7456 Swine Liquid GF Large1 MA 2 L 38.4 $4,473,658 $- $4806 Swine Pit GF Large2 MW 2 L 32.0 $12,312,846 $- $1,016 Swine Pit GF Large1 MW 2 L 44.6 $5,333,075 $- $5836 Swine Liquid GF Large2 MW 2 L 13.2 $4,838,903 $- $2656 Swine Liquid GF Large1 MW 2 L 18.5 $2,150,686 $- $1806 Swine Evapor FF Large2 CE 3 L 4.0 $3,636,998 $- $1456 Swine Evapor FF Large1 CE 3 L 5.5 $727,199 $- $526 Swine Pit FF Large2 MA 3 L 3.0 $1,517,440 $- $3676 Swine Pit FF Large1 MA 3 L 4.2 $636,955 $- $1676 Swine Liquid FF Large2 MA 3 L 9.6 $3,780,947 $- $2426 Swine Liquid FF Large1 MA 3 L 13.3 $1,575,723 $- $1476 Swine Pit FF Large2 MW 3 L 20.9 $13,907,425 $- $1,376 Swine Pit FF Large1 MW 3 L 29.1 $5,250,514 $- $6226 Swine Liquid FF Large2 MW 3 L 16.1 $9,427,416 $- $4076 Swine Liquid FF Large1 MW 3 L 22.5 $3,577,320 $- $2366 Swine Evapor GF Large2 CE 3 L 4.1 $3,559,234 $- $1916 Swine Evapor GF Large1 CE 3 L 5.7 $720,093 $- $636 Swine Pit GF Large2 MA 3 L 4.8 $2,276,281 $- $6136 Swine Pit GF Large1 MA 3 L 6.7 $953,376 $- $277
Table A-1 (Continued) 

A-6 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Liquid GF Large2 MA 3 L 8.1 $3,002,390 $- $2456 Swine Liquid GF Large1 MA 3 L 11.2 $1,249,977 $- $1406 Swine Pit GF Large2 MW 3 L 26.8 $17,610,962 $- $1,896 Swine Pit GF Large1 MW 3 L 37.4 $6,664,751 $- $8496 Swine Liquid GF Large2 MW 3 L 11.1 $6,672,735 $- $3356 Swine Liquid GF Large1 MW 3 L 15.5 $2,529,248 $- $1836 Swine Evapor FF Large2 CE 1 M 6.2 $1,045,073 $9,874 $686 Swine Evapor FF Large1 CE 1 M 8.6 $583,303 $8,326 $656 Swine Pit FF Large2 MA 1 M 3.5 $895,070 $1,754 $546 Swine Pit FF Large1 MA 1 M 4.9 $446,421 $1,238 $436 Swine Liquid FF Large2 MA 1 M 11.2 $2,240,265 $4,851 $1736 Swine Liquid FF Large1 MA 1 M 15.6 $1,119,911 $3,579 $1386 Swine Pit FF Large2 MW 1 M 50.0 $11,160,942 $94,844 $6046 Swine Pit FF Large1 MW 1 M 69.6 $7,061,074 $82,539 $5826 Swine Liquid FF Large2 MW 1 M 38.6 $7,610,651 $68,585 $4666 Swine Liquid FF Large1 MW 1 M 53.8 $4,837,258 $61,078 $4506 Swine Evapor GF Large2 CE 1 M 6.3 $1,014,654 $10,033 $816 Swine Evapor GF Large1 CE 1 M 8.9 $577,453 $8,616 $746 Swine Pit GF Large2 MA 1 M 5.7 $1,367,107 $2,857 $1036 Swine Pit GF Large1 MA 1 M 7.9 $675,824 $1,996 $776 Swine Liquid GF Large2 MA 1 M 9.4 $1,770,593 $4,071 $1696 Swine Liquid GF Large1 MA 1 M 13.1 $886,993 $3,005 $1286 Swine Pit GF Large2 MW 1 M 64.1 $14,131,183 $121,590 $880
Table A-1 (Continued) 

A-7 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Pit GF Large1 MW 1 M 89.4 $8,959,085 $106,020 $8146 Swine Liquid GF Large2 MW 1 M 26.6 $5,382,726 $47,263 $3656 Swine Liquid GF Large1 MW 1 M 37.1 $3,422,054 $42,119 $3376 Swine Evapor FF Large2 CE 2 M 14.0 $3,799,281 $29,234 $2046 Swine Evapor FF Large1 CE 2 M 19.5 $1,804,878 $20,608 $1646 Swine Pit FF Large2 MA 2 M 20.5 $8,915,128 $6,941 $1,946 Swine Pit FF Large1 MA 2 M 28.6 $4,203,137 $5,278 $1,006 Swine Liquid FF Large2 MA 2 M 65.4 $23,188,517 $22,143 $1,506 Swine Liquid FF Large1 MA 2 M 91.2 $11,139,166 $16,829 $1,026 Swine Pit FF Large2 MW 2 M 49.8 $19,404,930 $133,005 $1,386 Swine Pit FF Large1 MW 2 M 69.4 $8,403,879 $84,485 $8356 Swine Liquid FF Large2 MW 2 M 38.5 $13,705,324 $102,825 $6706 Swine Liquid FF Large1 MW 2 M 53.7 $6,048,228 $65,372 $4876 Swine Evapor GF Large2 CE 2 M 14.3 $3,706,782 $29,861 $2526 Swine Evapor GF Large1 CE 2 M 20.0 $1,769,902 $21,136 $1896 Swine Pit GF Large2 MA 2 M 33.0 $13,455,745 $11,173 $3,316 Swine Pit GF Large1 MA 2 M 46.0 $6,343,325 $8,488 $1,706 Swine Liquid GF Large2 MA 2 M 55.0 $18,405,743 $18,622 $1,506 Swine Liquid GF Large1 MA 2 M 76.7 $8,857,881 $14,153 $9756 Swine Pit GF Large2 MW 2 M 63.9 $24,589,323 $170,663 $2,046 Swine Pit GF Large1 MW 2 M 89.1 $10,657,133 $108,467 $1,186 Swine Liquid GF Large2 MW 2 M 26.5 $9,674,844 $70,776 $5376 Swine Liquid GF Large1 MW 2 M 36.9 $4,258,952 $44,921 $367
Table A-1 (Continued) 

A-8 

Option Animal 

Farm 

Type 

Manure 

Type 

Size 

Class Region Category 

Performance 

Needs 

Number 

of 

Facilities 

Capital 

Costs 

Fixed 

Costs 

Ann

O&M 

6 Swine Evapor FF Large2 CE 3 M 7.9 $7,194,696 $- $2896 Swine Evapor FF Large1 CE 3 M 11.1 $1,474,080 $- $1096 Swine Pit FF Large2 MA 3 M 6.0 $3,034,892 $- $7366 Swine Pit FF Large1 MA 3 M 8.4 $1,273,927 $- $3376 Swine Liquid FF Large2 MA 3 M 19.1 $7,538,686 $- $4866 Swine Liquid FF Large1 MA 3 M 26.7 $3,176,297 $- $3026 Swine Pit FF Large2 MW 3 M 41.7 $27,748,391 $- $2,756 Swine Pit FF Large1 MW 3 M 58.2 $10,501,144 $- $1,256 Swine Liquid FF Large2 MW 3 M 32.3 $18,942,283 $- $8266 Swine Liquid FF Large1 MW 3 M 45.0 $7,176,735 $- $4856 Swine Evapor GF Large2 CE 3 M 8.1 $7,043,577 $- $3806 Swine Evapor GF Large1 CE 3 M 11.3 $1,434,129 $- $1276 Swine Pit GF Large2 MA 3 M 9.7 $4,600,005 $- $1,246 Swine Pit GF Large1 MA 3 M 13.5 $1,921,008 $- $5626 Swine Liquid GF Large2 MA 3 M 16.1 $5,981,350 $- $4926 Swine Liquid GF Large1 MA 3 M 22.5 $2,522,073 $- $2886 Swine Pit GF Large2 MW 3 M 53.6 $35,222,032 $- $3,806 Swine Pit GF Large1 MW 3 M 74.7 $13,311,831 $- $1,716 Swine Liquid GF Large2 MW 3 M 22.2 $13,365,329 $- $6776 Swine Liquid GF Large1 MW 3 M 31.0 $5,073,717 $- $375
Appendix B 

CAFO POULTRY MODEL FARM COMPOSTING COST
Table B-1. CAFO Poultry Model Farm Composting Costs 

B-20 

Operation Region Size ID Category 

Performance 

Needs # Facilities 

Number of 

Birds 

Cropland 

(acres) 

Model Farm 

Composting 

Cost (a) 

Model Farm 

Irrigation 

Cost 

F

Broiler Mid-Atlantic Large1 1 H 4 125,000 493 $53,988 $25,806 Broiler Mid-Atlantic Large1 1 L 4 125,000 493 $53,988 $25,806 Broiler Mid-Atlantic Large1 1 M 7 125,000 493 $53,988 $25,806 Broiler Mid-Atlantic Large1 2 H 54 132,969 173 $57,430 $15,324 Broiler Mid-Atlantic Large1 2 L 54 132,969 173 $57,430 $15,324 Broiler Mid-Atlantic Large1 2 M 108 132,969 173 $57,430 $15,324 Broiler Mid-Atlantic Large1 3 H 27 150,049 0 $64,807 $6,803 Broiler Mid-Atlantic Large1 3 L 27 150,049 0 $64,807 $6,803 Broiler Mid-Atlantic Large1 3 M 53 150,049 0 $64,807 $6,803 Broiler Mid-Atlantic Large2 1 H 2 263,625 1,007 $113,861 $48,034 Broiler Mid-Atlantic Large2 1 L 2 263,625 1,007 $113,861 $48,034 Broiler Mid-Atlantic Large2 1 M 4 263,625 1,007 $113,861 $48,034 Broiler Mid-Atlantic Large2 2 H 31 327,459 297 $141,431 $19,377 Broiler Mid-Atlantic Large2 2 L 31 327,459 297 $141,431 $19,377 Broiler Mid-Atlantic Large2 2 M 62 327,459 297 $141,431 $19,377 Broiler Mid-Atlantic Large2 3 H 15 383,846 0 $165,784 $6,803 Broiler Mid-Atlantic Large2 3 L 15 383,846 0 $165,784 $6,803 Broiler Mid-Atlantic Large2 3 M 31 383,846 0 $165,784 $6,803 Broiler South Large1 1 H 3 125,000 853 $53,988 $40,387 Broiler South Large1 1 L 3 125,000 853 $53,988 $40,387 Broiler South Large1 1 M 6 125,000 853 $53,988 $40,387 Broiler South Large1 2 H 126 134,989 129 $58,302 $13,674 Broiler South Large1 2 L 126 134,989 129 $58,302 $13,674 Broiler South Large1 2 M 252 134,989 129 $58,302 $13,674 
Table B-1 (Continued) 

B-2 

Operation Region Size ID Category 

Performance 

Needs # Facilities 

Number of 

Birds 

Cropland 

(acres) 

Model Farm 

Composting 

Cost (a) 

Model Farm 

Irrigation 

Cost 

F

Broiler South Large1 3 H 46 132,017 0 $57,019 $6,803 Broiler South Large1 3 L 46 132,017 0 $57,019 $6,803 Broiler South Large1 3 M 91 132,017 0 $57,019 $6,803 Broiler South Large2 1 H 2 242,608 1,591 $104,783 $85,305 Broiler South Large2 1 L 2 242,608 1,591 $104,783 $85,305 Broiler South Large2 1 M 3 242,608 1,591 $104,783 $85,305 Broiler South Large2 2 H 73 313,353 213 $135,338 $16,686 Broiler South Large2 2 L 73 313,353 213 $135,338 $16,686 Broiler South Large2 2 M 146 313,353 213 $135,338 $16,686 Broiler South Large2 3 H 26 325,838 0 $140,731 $6,803 Broiler South Large2 3 L 26 325,838 0 $140,731 $6,803 Broiler South Large2 3 M 53 325,838 0 $140,731 $6,803 

Layer: Dry Mid-West Large1 1 H 8 291,153 2,100 $133,616 $128,773 Layer: Dry Mid-West Large1 1 L 8 291,153 2,100 $133,616 $128,773 Layer: Dry Mid-West Large1 1 M 15 291,153 2,100 $133,616 $128,773 Layer: Dry Mid-West Large1 2 H 46 291,153 62 $133,616 $10,308 Layer: Dry Mid-West Large1 2 L 46 291,153 62 $133,616 $10,308 Layer: Dry Mid-West Large1 2 M 91 291,153 62 $133,616 $10,308 Layer: Dry Mid-West Large1 3 H 49 291,153 0 $133,616 $6,803 Layer: Dry Mid-West Large1 3 L 49 291,153 0 $133,616 $6,803 Layer: Dry Mid-West Large1 3 M 97 291,153 0 $133,616 $6,803 Layer: Dry Mid-West Large2 1 H 1 856,368 6,177 $393,003 $860,156 Layer: Dry Mid-West Large2 1 L 1 856,368 6,177 $393,003 $860,156 Layer: Dry Mid-West Large2 1 M 2 856,368 6,177 $393,003 $860,156 Layer: Dry Mid-West Large2 2 H 7 856,368 80 $393,003 $11,404 
Table B-1 (Continued) 

B-3 

Operation Region Size ID Category 

Performance 

Needs # Facilities 

Number of 

Birds 

Cropland 

(acres) 

Model Farm 

Composting 

Cost (a) 

Model Farm 

Irrigation 

Cost 

F

Layer: Dry Mid-West Large2 2 L 7 856,368 80 $393,003 $11,404 Layer: Dry Mid-West Large2 2 M 14 856,368 80 $393,003 $11,404 Layer: Dry Mid-West Large2 3 H 7 856,368 0 $393,003 $6,803 Layer: Dry Mid-West Large2 3 L 7 856,368 0 $393,003 $6,803 Layer: Dry Mid-West Large2 3 M 15 856,368 0 $393,003 $6,803 Layer: Dry South Large1 1 H 3 291,153 2,424 $133,616 $162,021 Layer: Dry South Large1 1 L 3 291,153 2,424 $133,616 $162,021 Layer: Dry South Large1 1 M 7 291,153 2,424 $133,616 $162,021 Layer: Dry South Large1 2 H 27 291,153 62 $133,616 $10,308 Layer: Dry South Large1 2 L 27 291,153 62 $133,616 $10,308 Layer: Dry South Large1 2 M 55 291,153 62 $133,616 $10,308 Layer: Dry South Large1 3 H 28 291,153 0 $133,616 $6,803 Layer: Dry South Large1 3 L 28 291,153 0 $133,616 $6,803 Layer: Dry South Large1 3 M 56 291,153 0 $133,616 $6,803 Layer: Dry South Large2 1 H 0 856,368 7,131 $393,003 $1,130,489 Layer: Dry South Large2 1 L 0 856,368 7,131 $393,003 $1,130,489 Layer: Dry South Large2 1 M 1 856,368 7,131 $393,003 $1,130,489 Layer: Dry South Large2 2 H 3 856,368 80 $393,003 $11,404 Layer: Dry South Large2 2 L 3 856,368 80 $393,003 $11,404 Layer: Dry South Large2 2 M 6 856,368 80 $393,003 $11,404 Layer: Dry South Large2 3 H 3 856,368 0 $393,003 $6,803 Layer: Dry South Large2 3 L 3 856,368 0 $393,003 $6,803 Layer: Dry South Large2 3 M 6 856,368 0 $393,003 $6,803 

Layer: Wet South Large1 1 H 7 146,426 980 $298,477 $0 Layer: Wet South Large1 1 L 7 146,426 980 $298,477 $0 
Table B-1 (Continued) 

B-4 

Operation Region Size ID Category 

Performance 

Needs # Facilities 

Number of 

Birds 

Cropland 

(acres) 

Model Farm 

Composting 

Cost (a) 

Model Farm 

Irrigation 

Cost 

F

Layer: Wet South Large1 1 M 14 146,426 980 $298,477 $0 Layer: Wet South Large1 2 H 43 146,426 260 $298,477 $0 Layer: Wet South Large1 2 L 43 146,426 260 $298,477 $0 Layer: Wet South Large1 2 M 86 146,426 260 $298,477 $0 Layer: Wet South Large1 3 H 46 146,426 0 $298,477 $0 Layer: Wet South Large1 3 L 46 146,426 0 $298,477 $0 Layer: Wet South Large1 3 M 91 146,426 0 $298,477 $0 

Turkey Mid-Atlantic Large1 1 H 1 127,396 1,233 $107,095 $60,852 Turkey Mid-Atlantic Large1 1 L 1 127,396 1,233 $107,095 $60,852 Turkey Mid-Atlantic Large1 1 M 2 127,396 1,233 $107,095 $60,852 Turkey Mid-Atlantic Large1 2 H 24 127,396 437 $107,095 $23,895 Turkey Mid-Atlantic Large1 2 L 24 127,396 437 $107,095 $23,895 Turkey Mid-Atlantic Large1 2 M 48 127,396 437 $107,095 $23,895 Turkey Mid-Atlantic Large1 3 H 16 127,396 0 $107,095 $6,803 Turkey Mid-Atlantic Large1 3 L 16 127,396 0 $107,095 $6,803 Turkey Mid-Atlantic Large1 3 M 32 127,396 0 $107,095 $6,803 Turkey Mid-West Large1 1 H 2 127,396 1,023 $107,095 $48,864 Turkey Mid-West Large1 1 L 2 127,396 1,023 $107,095 $48,864 Turkey Mid-West Large1 1 M 3 127,396 1,023 $107,095 $48,864 Turkey Mid-West Large1 2 H 33 127,396 437 $107,095 $23,895 Turkey Mid-West Large1 2 L 33 127,396 437 $107,095 $23,895 Turkey Mid-West Large1 2 M 66 127,396 437 $107,095 $23,895 Turkey Mid-West Large1 3 H 22 127,396 0 $107,095 $6,803 Turkey Mid-West Large1 3 L 22 127,396 0 $107,095 $6,803 Turkey Mid-West Large1 3 M 43 127,396 0 $107,095 $6,803 
Appendix C 

ADDITIONAL POLLUTANT LOADS DATA
Table C-1. BOD Loads from Large CAFOs (in millions of pounds per year) 

C-20 

Sector Baseline Option 1 Option 2 Option 3 Option 5a Option 5 Option 

Cattle 7 7 7 7 4 N/A Dairy 3 3 3 3 2 N/A Swine 7 7 7 7 N/A 0 Poultry 6 0 0 0 0 N/A Poultry (wet) 13 13 13 13 N/A 0 Total 37 31 31 31 6 0 

Table C-2. Sediment Loads from Large CAFOs (in millions of pounds per year) 

Sector Baseline Option 1 Option 2 Option 3 Option 5a Option 5 Option 

Cattle 11339 10138 10138 10138 10113 N/A Dairy 1856 1757 1757 1757 1749 N/A Swine 2937 2937 2824 2824 N/A 2823 Poultry 10996 10965 10824 10824 10824 N/A Poultry (wet) 885 885 877 877 N/A 787 Total 28013 26682 26419 26419 22686 3611 

Table C-3. FC Loads from Large CAFOs in 1019 Colony Forming Units 

Sector Baseline Option 1 Option 2 Option 3 Option 5a Option 5 Option 

Cattle 422 412 411 411 162 N/A Dairy 54 53 53 53 22 N/A Swine 139 138 138 138 N/A 1 Poultry 7 0 0 0 0 N/A Poultry (wet) 57 56 56 56 N/A 0 Total 678 659 659 659 184 1 
Table C-4. Incremental Pollutant Reductions 

OPTION 3 BOD TSS FC 

Cattle 0.0 0.0 0.0 

Dairy 0.0 0.0 0.0 

Swine 0.0 0.0 0.0 

Poultry 0.0 0.0 0.0 

Poultry (wet) 0.0 0.0 0.0 

Poultry total 0.0 0.0 0.0 

OPTION 5a BOD TSS FC 

Cattle 2.9 24.7 249.9 

Dairy 1.2 7.2 30.4 

Swine N/A N/A N/A 

Poultry 0.0 0.0 0.5 

Poultry (wet) N/A N/A N/A 

OPTION 5 BOD TSS FC 

Cattle N/A N/A N/A 

Dairy N/A N/A N/A 

Swine 7.4 0.6 137.4 

Poultry N/A N/A N/A 

Poultry (wet) 13.3 89.6 56.4 

OPTION 6 BOD TSS FC 

Dairy 2.2 8.8 33.3 

Swine 6.3 0.5 137.0 

OPTION 7 BOD TSS FC 

Cattle 0.0 0.1 0.6 

Dairy 1.8 7.3 22.9 

Swine 7.2 0.5 136.1 

Poultry 0.0 0.0 0.0 

Poultry (wet) 0.0 0.0 0.0 

C-2