SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-1 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 

## APPENDIX E

ANALYSIS OF CLASS TWO MITIGATION MEASURES FOR

REVISED PROPOSED AMENDMENTS TO RULE 4570 (CONFINED ANIMAL FACILITIES)

October 21, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-2 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-3 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 APPENDIX E

COST ANALYSIS OF CLASS TWO MITIGATION MEASURES

I. INTRODUCTION

Rule 4570 contains options for facilities to implement certain “Class Two” mitigation measures that may have the potential to achieve increased emission reductions when compared to the required “Cla ss One” mitigation measures. The Class Two mitigation measures are practices that are far beyond t he requirements of Best Available Retrofit Control Technology (BARCT). T hese measures were included in the rule to give credit to operators who have made substantial invest ments in facilities and equipment that result in air quality benefits equivalent to or greater than those achieved by one of the Class One mitigation measures and to encour age operators to go beyond the basic rule requirements and implement innovative prac tices to further reduce emissions. However, these measures cannot be reas onably mandated because of a variety of concerns including animal health, technologi cal factors, environm ental factors, and economic feasibility. The technological and economic feasibility of various selected Class Two mitigation measures are analyzed below to more clearly illustrate that it is not currently feasible to require facilit ies to implement the Class Two mitigation

measures.

II. VENTING SILAGE TO A CONTROL DEVICE

The previous version of Rule 4570 containe d the options to enclose silage in a bag or weatherproof structure and vent the silage to a VOC control device as Class Two Mitigation Measures. At the time Rule 4570 was being developed, preliminary information indicated that dairy feed was an important source of VOC emissions at

dairies. More recent research has confirme d that feed at dairies is a significant VOC emissions source. The options to vent silage to a VOC control device were included as potential means to reduce emissi ons from this important source. The proposed controls were not based on any known installations but were based largely on technology transfer from composting operations, which were thought to involve a similar process. However, an examination of the processes required for co mposting and creating silage

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

from the revised rule.

Composting is an aerobic process in which microbes decompose organic material in the presence of oxygen producing carbon dioxid e and heat. The end product is a humuslike product that can be used to increase the organic matter and por osity of soil. Because composting is an aerobic process, any air that is vented through the material being composted can speed or enhance the composting process and result in a more consistent end-product. Therefore, actively venting composting piles is feasible and may even be desirable. Production of silage is fundamentally different because it is an anaerobic process. The purpose of silage pr oduction is to move the ensiled plantSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-4 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 material from an aerobic phase to an anaerobic phase as quickly as possible and achieve a rapid drop in pH that will hinder fu rther microbial decomposition in order to preserve the nutritive value of the forage. The rapid drop in pH is primarily caused by conversion of soluble carbohydrates to nonv olatile lactic acid. Oxygen, heat, and the production of carbon dioxide, which ar e desirable when producing compost, are undesirable when producing sila ge because this is indicative of lost dry matter and energy content. Preservation of dry matter and energy content is the entire purpose of making silage because the nutrients and energy are used by cows to produce milk and maintain body weight. They are also us ed by the younger stock for growth. Aerobic deterioration and heating of silage in bunker s or piles and when fed to animals in the total mixed ration (TMR) are well-known prob lems. Many steps are taken to prevent

this loss of nutritive value. Active vent ing of silage would introduce oxygen into the silage and result in the losses of nutritive val ue that producers are a ttempting to avoid. Therefore, this option is not feas ible for production of silage.

Passive venting of silage to a control devic e may be considered to be more feasible but this option is not currently reasonable. Be cause of the need to maintain anaerobic conditions to preserve the nutritive value of the silage, silage piles are usually tightly compacted and covered with plastic to prevent air penetration. Because most of the surface area of silage piles will usually hav e a compacted surface covered by plastic, the vast majority of emissions will be from the part of the pile that is uncovered to allow removal of feed. Machinery must access th is open portion of the silage pile at various times throughout the day to obt ain feed for the animals; theref ore, enclosing this portion of the pile to allow passive ventilation is not reasonable. The District also considered including an option requiring that silage piles be re-covered after feed removal; however, this option also proved to be unreas onable because of safety concerns. The silage piles constructed in the San Joaquin Valley are extremely large. Producers will generally try to minimize the amount of wo rk that is performed on or near open silage piles because of the danger of the silage pile collapsing, which can result in serious injury or death. The District consulted wit h experts in the field of silage production and they agreed that large silage piles are a safety concern and advised against including any measures that would require workers to spend time on or near open silage piles. These experts stated that sil age piles are serious hazards and, unfortunately, injuries and/or deaths from silage pile av alanches probably occur every year 1 . Because of these important safety concerns, the option to have workers re-cover piles was not considered

further under the current rule revisions.

1 Recent incidents of silage piles collapsing on peopl e can be found at the following links (unfortunately, additional similar incidents can easily be found by a simple web search): http://hayandforage.com/hay/0201- surviving-silage-avalanche/ http://www.thaindian.com/newsportal/world/boy -dies-due-to-feed-pile-collapse_100354252.html http://www.agsafety.psu.edu/newsletters/MarApr07.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-5 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 III. MILK PARLORS VENTED TO A CONTROL DEVICE

Because the same control device could be used to control VOC emissions from the milk parlors and the cow housing, cost of the VOC emission reductions for an enclosed milk parlor was evaluated below in conjunction wi th the cost of VOC emissions from enclosed cow housing vented to a control devic e. Since the emission factor from the milking parlors is much lower than the em ission factor from the cow housing, this

reduces the cost of emission reductions fo r venting the milking parlors to a control

device. The use of a biofilter as the control device for VOCs is expected to result in

much lower costs than other cont rol options, such as incinerati on; therefore, this option was analyzed below to determine the minimum cost of the emission reductions that could be achieved by venting an enclosed milk parlor and enclosed freestall barns

vented to a control device. Details of this analysis are given under Section IV – Analysis for Confining Livestock in Encl osed Buildings and Venting Emissions to a

Control Device.

Description of a Milking Parlor

Milk parlors can be either naturally or mech anically ventilated. Mechanical ventilation can be easily applied to all areas of the milk ing parlors, except t he holding area. The mechanical ventilation system for the milking parlor can be utilized to capture the gases

emitted from the milki ng parlor; however in order to capture all of the gases, and to keep an appropriate negative pressure throughout t he system, the holding area would also need to be entirely enclosed. No California fa cility that currently encloses the holding

area could be identified becaus e cows are continuously going in and out of the barn throughout the day. The capital cost required to enclose this large area would also be significant. Although the feasibility of su ch a technology is in question, it will be considered in the analysis below. If it is po ssible to overcome the significant obstacles to properly capturing the gases, it may be possible to vent t hem to a control device.

Description of C ontrol Technology

A biofilter is a device for removing contami nants from a gas in which the gas is passed through a media that supports microbial activity by which pollutants are degraded by biological oxidation. Duri ng biofiltration microorganisms oxidize the gaseous organic contaminants, ammonia, and sulfur compounds in the exhaust air resulting in carbon dioxide, nitrogen, water, salt , and biomass. Additional in formation on biofiltration is given below in the analysis for enclosed an imal housing vented to a control device.

Cost of VOC Em ission Reductions

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

biofilter demonstrates that the cost of the VOC reduc tions would be greater than $205,081/ton. There are additional costs rela ted to increased electricity use, and regulatory compliance and testing that have not been quantified for this analysis. EvenSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-6 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 without these costs, it is cl ear that the cost of the VO C emission reductions achieved are far beyond BARCT and any appl icable RACT requirements.

IV. ANALYSIS FOR CONFINING LIVESTOCK IN ENCLOSED BUILDINGS AND

VENTING EMISSIONS TO A CONTROL DEVICE

It has been periodically suggested that large VOC emission reductions can be achieved by confining livestock in enclosed buildings and using mechanical ventilation to direct the emissions to a control device, such as an incinerator or biofilter. The District previously considered this option when the Di strict originally adopted Rule 4570. The District determined that this option was beyo nd both Best Available Retrofit Control Technology (BARCT) and Best Available Control Technology ( BACT) because it had not been achieved in practice at any facilit y and would have excessively high costs. Although the District considered this option to be a theoretical measure that was beyond BARCT and BACT, it was included in Rule 4570, like several other Class 2 measures, to encourage the development of innovation te chnologies that might possibly lead to greater emission reductions in the future.

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

emission reductions that exc eeded the District’s cost effectiveness threshold for BACT for VOC. The District has repeatedly demonst rated that this measure is beyond BARCT and BACT, and certainly beyond the less st ringent requirement s of Reasonably Available Control Technology (RACT). Howe ver, certain parties continue to suggest that, not just new or expanding dairies, but all existing dairies subject to Rule 4570 should be required to confine their herd in enclos ed buildings vented to a control device.

This analysis does not quantify all of the costs or examine all of the potential issues that make requiring this option infeasible but it is intended to be a more complete analysis that more accurately approaches the actual co sts to implement this measure. The use

of a biofilter as a control device for VOCs is expected to result in much lower costs than other control options, such as incineration. The U.S. Environmental Protection Agency (US EPA), Clean Air Technology Center (CATC) document “Using Bioreactors to Control Air Pollution” states, “ The capital cost of a bioreacti on installation is usually just

a fraction of the cost of a traditional control device instal lation. Operating costs are usually considerably less than the costs of traditional technology, too .” 2 Therefore, this analysis will evaluate the use of a biofilter to determine the minimum cost of the

emission reductions that would be achieved by venting enclosed animal housing to a

control device.

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-7 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 A. Biofilter Information

Description of C ontrol Technology

A biofilter is a device for removing contami nants from a gas in which the gas is passed through a media that supports microbial activity by which pollutants are degraded by biological oxidation. During biofiltration, exhaust air containing pollutants passes through a media that contai ns an established, di verse population of aerobic microorganisms. These microorganisms oxid ize the gaseous organic contaminants, ammonia, and sulfur compounds in the exhaust air resulting in carbon dioxide, nitrogen, water, salt, and biomass. T he bacterial cultures (microor ganisms that typically consist of several species coexisting in a colony) that use oxygen to biodegrade organics are

called aerobic cultures. These aerobic cult ures are usually supported by organic material contained in the biofilter, such as compost, wood chips, soil, peat, etc. Biofilters must maintain sufficient porosity to allow the contaminated air stream to pass through for treatment and to pr event anaerobic conditions. The moisture content of biofilter beds must also be regulated to ens ure that there is su fficient moisture to maintain the microorganisms needed for treatment while avoiding excess moisture that

can cause anaerobic conditions. A filtrati on system may be requir ed upstream of the biofilter to remove particular matter which will clog the biofilter over time. Biofilters must

be maintained free of rodents and weeds to avoi d channeling of gases through the filter media and a loss of performance. The filter media of nat ural biofilters needs to be replaced periodically because of deter ioration and loss of porosity.

Since biofilters rely on livi ng organisms to function, a biofilter’s performance will be affected by several factors, including: ambi ent temperature; tem perature of the air stream being treated; the pollutant concentrations in the ai r stream; moisture content of the filter and air stream, and pH of the filter media. These parameters should be monitored to ensure optimum operating conditions for the biofilter.

Advantages and Disadvantages of Using a Biofilter to Control Emissions

Some of the general advantages related to the use of biofilters incl ude: low installation

costs for traditional biofilter designs; generally low operating costs in comparison to other control technologies; high control e fficiencies for some compounds such as aldehydes, organic acids, hydrogen sulfide, and certain water-soluble organic compounds.

Some of the general disadvantages of t he use of biofilters include: large land requirements for traditional biofilter designs; difficulty in determining the control efficiency for traditional open biofilter designs; for biofilters that use inexpensive natural bed media, the filter bed media must be repl aced every 2 to 5 years; biofilters usually require some time to reach optimum control efficiency afte r initial startup and after periods of nonuse because of the need to es tablish or re-establish the microbialSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-8 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 population; and biofilters can also be a source of nitrous oxide emissions due to

denitrification.

Additional disadvantages specifically related to the use of biofilters to control emissions

from livestock include: animals that may currently have access to corrals or pasture for

exercise would need to be confined in build ings to maximize emission reductions; facilities that currently use natural ventilati on would incur additional costs because of the need to convert to mechanical ventilation; fa cilities that currently use mechanical ventilation systems may need to upgrade these systems to overcome the increased pressure drop across the biofiltration system; greater energy usage for all facilities to push air through the biofilter; few reported cases where a bi ofilter has been shown to be economically viable when applied to animal feeding operations 3 ; a very large biofilter system must be used to handle these huge fl ow rates while maintaining adequate

contact time for treatment of emissions. Fi nally, because of the extremely large airflow rates needed to provide adequate ventilation for liv estock it is not practical and may not

be feasible to treat all of the ventilation ai r from large confined animal housing units.

Biofilter VOC Control Efficiency

It is assumed that 80% of the gasses emitt ed from the enclosed ani mal housing will be captured by the mechanical vent ilation system and that a prop erly functioning biofilter

will eliminate 85% of t he captured VOC emissions 4 ; therefore, the tota l control for VOCs

from the enclosed animal housing = 0.80 x 0.85 = 68%.

Cost Estimates for Biofilters

Several reference documents were consul ted to determine the expected capital and operating costs of using a biofilter to c ontrol VOC emissions fr om enclosed animal housing. These references and the result ing cost informati on are listed below. Additionally, several companies that specia lize in building and supplying biofilters and

bio-scrubbers for the c ontrol of VOC emissions were contacted to request capital cost estimates for biofilter systems specifically fo r the treatment of VOC emissions from dairy

cows housed in enclosed barns. The dollar am ounts of the estimates provided by these companies are also listed below.

Sources of Cost Estimates for Biofilters

Table 1 summarizes the cost information fo r biofilters found in literature. The

references follow the table.

3 U.S. Environmental Protection Agency, “Emissio ns from Animal Feeding Operations” (Draft), EPA Contract No. 68-D6-0011, August 15, 2001, pg. 9-20, http://www.epa.gov/ttn/chief/ap42/ ch09/draft/draftanimalfeed.pdf

4 The SCAQMD Rule 1133.2 staff report (page 18) indicates control efficiencies of 80-90% for VOC for existing biofilter composting applications and that a well-designed, well-operated, and well-maintained biofilter is capable of achieving 80 percent control efficiency for VOC, http://www.aqmd.gov/rules/doc/r1133/r1133_staffreport.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-9 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Table 1 – Biofilter Co sts from Literature

Article

Number Year published Capital Cost Range ($/cfm) Adj 2010 Capital Cost ($/cfm) Operating Cost Range ($/cfm/yr) Adj 2010 Operating Cost ($/yr)

1 2003 $2.35 - $7.74

biofilter $6.67 $3.31

biofilter $4.07

2 2003 $20.20 - 30.30 biotrickling filter $33.34 $6.35 biotrickling filter $7.81

3 1991 $12.79 - $20.93 open biofilter $22.43 - $36.70

4 1991 $20.93 - $116.28

enclosed biofilter $36.70 - $203.90

5 1998 - - $2 - $14 $2.85 - $19.96

6 2008 $15 $15.91 $2 $2.12

7 2005 $16.99 - $118.93 $19.70 - $137.87 $5.10 - $16.99 $5.91 - $19.70

8 1996 $2.50 - $5.00 $3.07 - $6.15 $'2 - $14 $2.46 - $17.22

9 1999 $13.30 - $18 $18.401 - $24.92 $3.33 - $6.67 $4.61 - $9.23

10 2002 $2.79 $3.53 10% of capital cost

11 2004 $0.15 - $0.25 $0.25 - $0.35 $0.005 -$ 0.015 $0.006 - $0.018

1 & 2. U.S. Environmental Protection Agency, The Clean Air Technology Center (CATC), “Using Bioreactors to Control Ai r Pollution” EPA-456/R-03-003, (E143-03), September 2003, http://www.epa.gov/ttn/catc/dir1/fbiorect.pdf

3. U.S. Environmental Protection Agency, “Emissions from Animal Feeding Operations” (Draft), EPA Contract No. 68-D6-0011, August 15, 2001, Section 9.2.3 - Biofiltration of Confinement Housing Exhaust, http://www.epa.gov/ttn/chief/ap42/ ch09/draft/draftanimalfeed.pdf

4. Leson, G. and A.M. Winer. 1991. “Biofiltration: An Innovat ive Air Pollution Control Technology for VOC Emissions”. Jour nal of the Air and Waste Management Association. 41(8):1045-54.)

5. Operating Cost Estimate for a Biofilter (1998): $2-14/cfm (from Boyette, R. A. 1998. “Getting Down to (Biofilter) Basics”. Biocycle 39(5):58-62)

6. Bohn, Hinrich, “Biofilter Technology Offe rs Emissions Abatement Option”, Distillers Grain Quarterly , 3 rd Qtr 2008, http://www.ethanolproducer.com/dgq/articleprint.jsp?article_id=1257SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-10 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 7. Delhoménie, Marie-Caroline; Heitz, Michèle, “Biofiltration of Air: A Review”, Critical Reviews in Biotechnology , 1549-7801, Volume 25, Issue 1, 2005, Pages 53 – 72

8. Boyette, R. Allen – E&A Environmental Consultants Inc., “Biofilter Economics and Performance”, 1996, http://www.p2pays.org/ref/12/11505.pdf

9. Govind, Rakesh – PRD Tech Inc., Whit e Paper - “Biofilterat ion: An Innovative Technology for the Future”, 1999, http://www.prdtechinc.com/PDF/P RDBIOFILTERR&DMAGAZINEPAPER.pdf

10. South Coast Air Quality Management District, “Technology Assessment for: Proposed Rule 1133: Emission Reductions fr om Composting and Related Operations”, March 22, 2002, http://www.aqmd.gov/rules/ doc/r1133/r1133_techassessment.pdf

11. Schmidt, David. Janni, Kevin. Nicolai, Richard. “Biofilter Design Information”. Biosystems and Agricultural Engineering Update: BAEU-18, Revised March 2004. University of Minnesota Department of Bi osystems and Agricultur al Engineering, College of Agricultural, Food and Environmental Sciences, http://www.manure.um n.edu/assets/baeu18.pdf

Note: The capital cost estimate obtained from this source was ten times lower than the low-end of the cost estimates giv en in other sources listed above and the estimates from biofilter suppliers present ed below and the operating cost estimate

from this source was more than 100 times lower than the lowest the cost estimates given in the other sources listed above. Because of this significant difference in costs, the design of this biof ilter was evaluated to determi ne if it would meet District

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

discussed below.

Reference #11 describes a biofilter designe d to reduce odors not total VOCs. The

document recommends that an open-bed biofilter used to c ontrol exhaust from animal housing have a depth of 10-18 inches and an em pty bed contact time of 3-5 seconds. For an open-bed biofilter used for VOC c ontrol, the recommended depth and contact time are generally 3-5 feet and 30-60 second s, respectively. The lower recommended depth is the result of limitations with typica l exhaust fans used for ventilation in animal housing, which are not designed for the larger pressure drops that would be caused by a deeper biofilter bed. It is likely that the much smaller recommended contact time is

related to the fact that t he biofilter is only designed to reduce odors. Many odorous compounds are branched-chain volatile fatty acids (VFAs) that consist of large molecules with a strong tendency to adhere to any surfaces that they contact; thus shortening the contact time required to treat these compounds. Although VFAs are largely responsible for objectionable odors from agricultural facilities, recent studies have shown that alcohols comprise the majority of VOC emissions. The biofilter design

recommended in the document would not be as e ffective for reducing alcohols or other VOCs which are more volatile and do not have a strong tendency to adhere to surfaces.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-11 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 The biofilter does not appear to be designed to handle the total flow rates from the animal housing but is probably intended to handl e smaller flow rate s from high-odor areas such as manure pits. Another limitation wit h the design is that there is no

dedicated outlet to allow meas urement and determination of control efficiency; thus there isn’t any way to accurately assess if th e biofilter is functioni ng properly. Because

of the substantial deviation from established criteria for the design of biofilters for control

of VOCs and the lack of information to s upport and quantify total VOC reductions from this particular design, the cost estimate s associated with this design will be removed from further consideration. This design may be re-evaluated at a later time if the necessary information is provided or becomes available.

Quotes/Estimates Received from Providers of Biof ilters/Bio-Scrubber s for VOC Control

As stated above, several companies that supply biofilters and bio-scrubbers for the

control of VOC emissions were contacted to request capital cost es timates for biofilter systems capable of treating VOC emissions from dairy cows confined in enclosed barns. The companies that were contact ed include: 1) Tri-Mer Corporation; 2) BioReaction Industries; 3) PRD Tech, inc.; 4) Siemens Water Technologies; 5) PPC Air Pollution Control Systems - PPC Biofilter; 6) Biorem /TEC Treatment Equipment Company; and 7) MEGTEC Systems, Inc.

Four vendors responded to the District’s r equest for cost information. They are identified as Vendors A, B, C, and D in Table 2. The companies were provided information regarding the type of VOCs t hat would be treated (mostly alcohols and VFAs) and were told that the biofilter would need to be capable of treating airflow rates of 500,000 cfm or more. The estimates that were provided by these companies are listed below and generally fell in the range of values giv en in the accepted sources

listed above.

Table 2 – Summary of Vendor Cost Information

Vendor Capital Cost ($) Operating Cost ($/cfm)

A $1.4 - $2.2 m illion $2.8 - $4.4

B $8 - $10 million $16 - $18

C $7 million ± 20% $14 ± 20%

D - $20 - $25

Reduced Capital Cost from Economy of Scale

The potential for reduced dollar-per-cfm c apital costs was considered based on the large airflow rates that would be handled by bi ofilters for confined animal facilities. Based on the information reviewed, it was det ermined that there is not any additional

cost reduction benefit related to economy of scale for biofilt ers handling such large flow

rates.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-12 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 The information available indicates significant reductions in biofilter costs per cfm as the flow rate treated increases to a few thousand cfm but diminishing reductions in cost

after this until there is no further benefit. This is illustrated in the graph below. The graph shows no additional cost reductions benefits after approximately 50,000 cfm. Also, in a phone conversation with Jim Cash of MEGTEC Systems, Inc. he stated that economy of scale cost reductions for biof ilter systems were insignificant after approximately 20,000 cfm. This was because multiple i ndividual units are generally required to treat flows greater than this and each unit would still cost about the same. Additionally, single units, and sometimes even multiple units, handling such large flow rates would not be pre-fabricated but would have to be specially constructed on site, which can increase costs. This was also sup ported by the information provided by other biofilter suppliers. Theref ore, any potential co st reduction benefits related to economy of scale have already been captured in the lo wer biofilter cost estimates given above

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

number of animals housed.

Boyette, R. Allen – E&A Environmental Consultants In c., “Biofilter Economics and Performance”, 1996

Cost Estimate for Biofilters for this Analysis

For purposes of this report, t he following biofilt er cost estimates will be used. The cost estimates are conservative and are significa ntly lower than some of capitol cost estimates given in the refe rences listed above.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-13 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Capital Cost (2010): $3-35/cfm Operating Costs (2010): $2.12-20/cfm

B. Analysis of Enclosed Dairy Barns Vented to a Control Device

The following analysis is based on the cost of emission reductions for confining 1,000 milk cows in enclosed freestall buildings v ented to a biofilter and venting the milking parlor to the same biofilter. Costs for la rger dairies would be linearly proportional.

Description of Dairy Housing

In a freestall barn, cows are grouped in large pens with free access to feed bunks, water, and stalls for resting. In the mild climate of the San Joaquin Valley, the typical freestall barn is an open structure (roof but no sides). The primary freestall design consists of a roof that prov ides shade with all sides open to allow air to flow through, which keeps the cows cool. The open freestall barns take advantage of natural summer winds in the San Joaquin Valley that are gener ally greater than four mph. The natural winds result in an excellent summer ventilation rate that is equiva lent to 1,000 cfm per cow more, which is why open dairy barns are generally recommended in the San Joaquin Valley. In colder climates enclos ed or partially enclosed barns may be utilized to protect cows from winter extremes. Ho wever, no completely enclosed freestall barns

that were installed at a Califor nia dairy were identified.

Although the potential to enclose cows in a barn may exist, the feas ibility of reasonably collecting the gas through a sta ck, chimney, or vent remains in question considering the extremely large amounts of airflow going through the barns needed to keep the cows cool. The airflow requirements would be ev en higher in the San Joaquin valley, where temperatures can exceed 110° F in the hot summer. If the barn exhaust can be properly captured it may be possible to vent it to a biofilter for VOC control. Some of the potential disadvantages related to the use of a biofilter to control emissions from

enclosed livestock barns were mentioned a bove. One of the disadvantages mentioned was the large space requirement for the traditi onal biofilter design. To further illustrate this, a low-cost natural bed biofilter designe d to treat the VOC em issions from 1,000 milk cows and 180 dry cows with no support st ock would cover more than 5.4 acres and would need to be maintained free of pests and approved by the appropriate permitting agencies. To avoid such expansive land re quirements, the dairy would likely need to use much more expensive bio-tri ckling filters or bio-scrubbers.

Even though questions remain about the re asonability of requiring animals to be confined in buildings and venting the exhaus t to a biofilter, it will be considered for purposes of this analysis.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-14 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Source of Cost Estimates for Enclosed Freestall Barns

Table 3 – Cost Estimates fo r Enclosed Freestall Barns

Article

Number Year published Capital Cost Range ($/cow) Adj 2010 Capital Cost ($/cow) Operating Cost Range

($/cow/yr) Adj 2010 Operating

Cost ($/cow/yr)

1 2002 $1,430 - $1.750 $1,812 - $2,217

2 2006 $1,500 $1,688

3 2009 +$500 than

conventional $1,851 - $2,717

4 2010 $2,000 - $2,700 $2,000 - $2,700

5 2008 - - +$127/cow

more than

conventional +$135/cow

6 2008 - - $69.95 - $92.23 $74.21 - $97.85

1. Jones, Lawrence R., “Choosing a Fr eestall Barn Style”, June 18, 2002, http://www.milkproduction.com/Library/Arti cles/Choosing_a_Freestall_Barn_Style.htm

2. Quaife, Thomas, “Tunnel Ventilation: So far, so good”, Dairy Herd Management

, February 2006, http://www.dairyherd.com/dire ctories.asp?pgID=724&ed_id=5169

3. DiGuiseppe, Gary, “Cow Comfort Innovations in t he barn”, American Dairymen , Vol. 35, Number 3, March 2009, http://www.americandairymen.co m/articles/cow-comfortinnovations-barn

4. Emails from Paul Martin of Wester n United Dairymen based on contacts in New

York

5. Gooch, Curt, “Dairy Freestall Barn De sign – A Northeast Perspective”, Presented at the Ninth Annual Fall Dairy Conference - Co rnell University College of Veterinary

Medicine and Cornell PRO-DAIRY Pr ogram. November 12 -13, 2008, http://www.ansci.cornell. edu/pdfs/pddairybarndesign.pdf

6. Dhuyvetter, Kevin C., Harner, Joe P., Sm ith, John F., & Bradfor d, Barry J., Kansas State University Department of Agricultural Economics, “Economic Considerations of

Low-Profile Cross-Ventilated Freestall Barn s”, Presented at Dairy Housing of the Future, Sioux Falls, South Da kota. September 10-11, 2008, http://www.agmanager.info/dhuyvetter/presen tations/2008/LPCV%20Conference(Sep20 08).pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-15 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Cost Estimates for Enclosed Free stall Barns for this Analysis

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

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

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

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

Increased Operating Costs for Enclosed Freestall Barn for 1,000 milk cows

Low operating cost estimate: $74/cow-yr x 1,000 cows = $74,000/yr High operating cost estimate: $13 5/cow-yr x 1,000 cows = $135,000/yr

Cost of Biofiltration

The cost estimates for biofiltration are based on the references given above. The cost is largely dependent on the airflow ra te that the biofilter must handle. Biofilters used to

treat exhaust air should be sized to treat the maximum ventilati on rate, which is typically the warm weather rate. The higher cost value is representative of a biotrickling filter, which may be necessary to handle the high air flow rates from the barns.

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

Required Airflow Rate of the Freestall Barns

In order to calculate the cost s of this control option, the airflow rate required for the

freestall barns must be determined. The University of Mi nnesota’s publication “Improving Mechanical Ventilation in Dairy Ba rns”, gives minimum v entilation rates for dairy cattle, which are listed in the table below.

Table 4 - Minimum Ventilation Ra tes for Dairy Cows (cfm/cow)

Age Winter Mild Weather Summer

Baby Calf 15 50 100

Heifer (2-12 months) 20 60 130

Heifer (12-24 months) 30 80 180

Mature Cow 50 170 500 – 1,000SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-16 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 The minimum summer ventilation rate listed for mature cows is 500 cfm per cow. However, according to the University of Minnesota publication and Cornell University’s publication “Natural or Tunnel Ventilation of Freestall Structures: What is Right for Your Dairy Facility?”, the required airflow rate in the summer increases to 1,000 cfm per cow

if tunnel ventilation is used to provide additional cooling. 5

The climate in the San Joaquin Valley is characterized by mild winters and hot summers. Because of the warmer climate, it is expected that tunnel ventilation or a similar system would need to be employed in an enclosed freestall barn to prevent

excessive heat stress. Additi onally, tunnel ventilation system s are more representative of the types of systems that would be requi red to capture and control emissions.

Minimum Summer Air Requirements for freesta ll barns vented to a biofilter for 1,000

milk cows:

The minimum required summer ai rflow rate for housing the 1,000 milk cows in enclosed

freestalls is calculated as follows:

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

Capital Cost of a Biofilter for 1,000 milk cows

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

Low capital cost estimate: $3.00/cfm x 500,000 cfm = $1,500,000 High capital cost estimate: $35. 00/cfm x 1,000,000 cfm = $35,000,000

Operating Costs for a Biofilter for 1,000 milk cows

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

Annualized Capital Costs for Biofilter for 1,000 milk cows

The annualized capital cost estimates will be calculated below. The cost for the purchase of the enclosed freestall barn and biof ilter will be spread over the expected life of the system using the capital recovery equati on. Therefore, the expected life of the entire system (enclosed barn, fans, media, pl enum, etc) will be estima ted at 10 years.

A 10% interest rate is assumed in t he equation and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

5 Improving Mechanical Ventilation in Dairy Barns, J.P. Chastain, http://www.milkproduction.com/Library/Arti cles/Improving_mechanical_ventilation.htm and Natural or

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-17 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 A = [P x I(I+1) n ]/[(I+1) n -1]

Where:

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

Low Annualized Capital Cost Estimate = [($1,275,000 + $1,500, 000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $451,618/year

High Annualized Capital Cost Estimate = [($2,025,000 + $35,000, 000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $6,025,648/year

Total Annual Cost Estimates

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

Total annual cost estimate = (total annua lized capital cost) + (increased operating cost for an enclosed freestall barn) + (biofilter operating cost)

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

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

Potential Income from In creased Milk Production

Cooling milk cows in enclosed freestall barns may reduce heat stress and result in increased milk production. Because dairy cows in California already have some of the highest milk production rates in the nation, it is questionable regarding whether enclosing the milk cows will result in any signifi cant increases in milk production. This is because heat stress is related to both temper ature and humidity and it is likely that the increased temperatures in California relative to other states are mitigated by the much lower humidity. Although questions remain about the potential to increase milk production in the San Joaquin Valley by reduci ng heat stress, this potential benefit will be quantified for this analysis.

Potential Increased Daily Milk Production: 4-6 lb/cow-day (District 4570 Staff Report, June 2006)

Potential Increased Annual Milk Production: 1,460-2,190 lb/cow-yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-18 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Class 4b Price of milk 6 for August 2010: $14.39/cwt Income from increased milk production: $210.09-315.14/cow-yr

Max Income from increased milk production for 1,000 milk cows: 1,000 milk cows x $315. 14/cow-yr = $315,140/yr

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

VOC Emission Reductions for Biofiltration for 1,000 Milk Cows

The annual VOC Emission Reductions for encl osed freestall barns for 1,000 milk cows

vented to a biofilter are calculated as follows:

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

Table 5 - VOC Reductions from Milk Cows Housed in Enclosed Freestall Barns Vented to a Biofilter (Cows, Stalls, & Lanes)

Emissions Source # of

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

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

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

Total (lb-VOC/yr) 4,032

*Includes emissions in the milk parlor(s)

Table 6 - VOC Reductions from TMR (Feed) for Milk Cows Housed in

Enclosed Freestall Barns Vented to a Biofilter

# of

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

per cow

(m 2 ) min/yr lb/ug = Uncontrolled lb-VOC/yr x Capture (%) x Control (%) = lb-VOC/yr

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

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

Cost of VOC Em ission Reductions

Low Estimate 7 =($1,270,478/year)/[(12,389 lb-VOC/year)(1 ton/2000 lb)]

= $205,098/ton of VOC reduced

6 http://www.cdfa.ca.gov/dairy/pdf/Prices_Grid.pdf ; The Class 4b milk price was because dairy industry representatives state that increased production is pu rchased at the lowest price. Additionally, sufficient increased production will cause the price to fall

7 Includes reduction in overall annual costs becau se of potential additional revenue from maximum supposed increase in milk production.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-19 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 High Estimate =($26,160,6 48/year)/[(12,389 lb-VOC/year)(1 ton/2000 lb)]

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

As shown above, the costs for a freestall enclosu re and biofilter would cause the cost of the VOC reductions to be great er than $205,098/ton. There are additional costs related to increased electricity use, and regulatory compliance and testing that have not been quantified in this analysis. Even without these cost s, it is clear that the cost of the VOC

emission reductions achieved are far beyond BARCT and any applicable RACT requirements.

C. Mechanically Ventilated Swine H ousing Vented to a Control Device

The cost of the VOC emission reductions for venting a mechanica lly-ventilated swine house to a control device is analyzed below. As stated above, a biofilt er is expected to be the least costly control device so it wa s chosen for purposes of this analysis.

Description of Ventilation in Swine Housing

Swine are typically housed in confinement build ings that are either totally enclosed or partially enclosed structures with open sidewalls with curt ains. In totally enclosed housing, mechanical ventilation is used thr oughout the year. Mechani cal ventilation is typically provided by an induced draft or negative-pressure system. An induced draft system pulls fresh air into the house fr om one end and exhausts on the other. A negative-pressure system draws fresh air into the house from side vents and out through the exhaust fan. Partially enclosed swine housing uses nat ural ventilation the majority of the year. In these buildings t he sidewall curtains are opened and closed to

control the house ventilation rate. Partia lly enclosed swine housing may also use

mechanical ventilation when the curtains are closed due to weather conditions. Ventilation in swine housing is used to remove excess mois ture, ammonia, and hydrogen sulfide from swine housing and to remove excess heat during the summer season. It may be possible to vent the ex haust from mechanica lly ventilated swine houses to a control device; theref ore, this opti on will be analyzed.

Cost of Biofiltration

The cost estimates for biofiltration are based on the references given above. The cost is largely dependent on the airflow ra te that the biofilter must handle. Biofilters used to

treat exhaust air should be sized to treat the maximum ventilati on rate, which is typically the warm weather rate. The higher cost value is representative of a biotrickling filter, which may be necessary to handle the high air flow rates from the houses.

Capital Cost for a biofilter: $3-35/cfm Operating Costs for a biof ilter: $2.12-20.00/cfm-yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-20 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Required Airflow Rate of the Swine Houses

In order to calculate the cost s of this control option, the maximum airflow to be treated

from the houses the swine hous ing building must be determined.

The MidWest Plan Service publication “Mechani cal Ventilating Systems for Livestock Housing” (MWPS-32), gives minimum ventilati on rates for finishing swine, which are

listed in the table below.

Table 7 - Minimum Ventilation Rat es for Finishing Swine (cfm/head)

Animal Type Winter Mild Weather Summer
Finishing Swine 10 35 120

Minimum Summer Air Requirements for Sw ine Housing for 3,000 Finishing Head:

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

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

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

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

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

Operating Costs for Biofilter for S wine Housing with 3,000 Finishing Head

Low operating cost estimate: $2.12 /cfm-yr x 360,000 cfm = $763,200/yr High operating cost estimate: $20. 00/cfm-yr x 360,000 cf m = $7,200,000/yr

Annualized Capital Costs for Biofilter fo r Swine Housing with 3,000 Finishing Head

The annualized capital cost estimates will be calculated below. The cost for the purchase of the biofilter will be spread over the expected life of the system using the capital recovery equation. Therefore, t he expected life of t he entire system (fans, media, plenum, etc) wil l be estimated at 10 years. A 10% interest rate is assumed in the equation and the assumption will be made t hat the equipment has no salvage value

at the end of the ten-year cycle.

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

Low Annualized Capital Cost Estimate = [($1,080,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $175,765/yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-21 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 High Annualized Capital Cost Estimate = [($12,600,000) x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $2,050,592/year

Total Annual Cost Estimates

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

additional cost. There would also be in creased electricity usage to overcome the pressure drop caused by the biofilte r. This cost was not quantified.

Total annual cost estimate = (total annualized capital cost) + (biofilter operating cost)

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

= $938,965/year

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

= $9,250,592/year

VOC Emission Reductions for Biofilter fo r Swine Housing with 3,000 Finishing Head

The annual VOC Emission Reductions for me chanically-ventilated swine housing for 3,000 finishing head vented to a biof ilter are calculated as follows:

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

Table 8 - VOC Reductions from Enclosed Swine House Vented to a Biofilter

Animal # of

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

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

* Based on a study by Rumsey, 91% of swine fac ility VOC emissions are assumed to be from housing barns and 9% of VOC emissions are assumed to be from lagoons 8

Cost of VOC Em ission Reductions

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

= $219,180/ton of VOC reduced

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

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

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

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-22 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 increased electricity use, and regulatory compliance and testing that have not been quantified in this analysis. Even without these cost s, it is clear that the cost of the VOC

emission reductions achieved are far beyond BARCT and any applicable RACT requirements.

D. Mechanically Ventilated Poultry Houses Vented to a Control Device

The cost of the VOC emission reductions for venting a mechanica lly-ventilated poultry house to a control device is analyzed below. As stated above, a biofilt er is expected to be the least costly control device so it wa s chosen for purposes of this analysis.

Ventilation in a Poultry House

In poultry houses, ventilation is used to re move moisture and ammonia from the houses during the winter season and to remove excess heat and ammonia from the houses during the summer season. Partially enclo sed housing structures have open sidewalls with curtains that are opened and cl osed to control the house ventilation rate. In totally enclosed housing, mechanical ve ntilation is used. Mechanica l ventilation is typically provided by an induced draft or negative-pr essure system. An induced draft system pulls fresh air into the house from one end and exhausts on the other. A negativepressure system draws fresh air into the house from side vents and out through the exhaust fan. Totally enclosed mechanically ventilated housi ng is known as tunnel-type housing or environmental housing. It may be possible to vent the exhaust from mechanically ventilated poultry houses to a cont rol device; therefore, this option will be analyzed.

Cost of Biofiltration

The cost estimates for a biofil tration are based on the references given above. The cost is largely dependent on the airflow ra te that the biofilter must handle. Biofilters used to

treat exhaust air should be sized to treat the maximum ventilati on rate, which is typically the warm weather rate. The higher cost value is representative of a biotrickling filter, which may be necessary to handle the high air flow rates from the houses.

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

Required Airflow Rate of the Poultry Houses

In order to calculate the cost s of this control option, the maximum airflow to be treated

from the houses house must be determined.

The MidWest Plan Service publication “Mechani cal Ventilating Systems for Livestock Housing” (MWPS-32), gives minimum ventilation rates for poultry, whic h are listed in the

table below.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-23 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Table 9 - Minimum Ventilation Rates for Poultry (cfm/bird)

Animal Type Winter Mild Weather Summer
Broiler/Layer (5 lb) 0.5 2.5 5 Turkey (40 lb) 3.2 14 32

Capital Cost of Biofilter for a Poultry House with 32,000 Broilers or Layers or 5,000 Turkeys

The lower cost estimate does not include inst allation of the required ductwork. As stated above, the estimated capital costs for a biofilter range of between $3.00 per cfm and $35.00 per cfm. The capital cost estimates of a biofilter for mechanically ventilated poultry
houses for 32,000 br oilers or layers or 5,000 turk eys are calculated as follows:

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

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

Low operating cost estimate: $2.12 /cfm-yr x 160,000 cfm = $339,200/yr High operating cost estimate: $20. 00/cfm-yr x 160,000 cf m = $3,200,000/yr

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

The annualized capital cost estimates will be calculated below. The cost for the purchase of the biofilter will be spread over the expected life of the system using the capital recovery equation. Therefore, t he expected life of t he entire system (fans, media, plenum, etc) wil l be estimated at 10 years. A 10% interest rate is assumed in the equation and the assumption will be made t hat the equipment has no salvage value

at the end of the ten-year cycle.

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

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

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

Total Annual Cost Estimates

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

additional cost. There would also be in creased electricity usage to overcome the pressure drop caused by the biofilte r. This cost was not quantified.

Total annual cost estimate = (total annualized capital cost) + (biofilter operating cost)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-24 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Low total annual cost estimate = ($78,118/yr) + ($339,200/yr)

= $417,318/year

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

= $4,111,374/year

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

The annual VOC Emission Reductions for a mechanically-ventilated poultry house for 32,000 broilers or layers or 5,000 turkeys vent ed to a biofilter are calculated as follows:

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

Table 10 - VOC Reductions from Enclosed Poultry Houses Vented to a Biofilter

Poultry Type # of Birds x EF (lb/bird-yr) x Capture (%) x Control (%) = lb-VOC/yr

Broiler 32,000 x 0.025 x 80% x 85% = 544
Layer 32,000 x 0.025 x 80% x 85% = 544
Turkey 5,000 x 0.1 x 80% x 85% = 340

Cost of VOC Em ission Reductions

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

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

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

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

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

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

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

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

As shown above, the costs for a biofilter for poultry houses w ould cause the cost of the VOC reductions to be greater than $1,534,257 /ton for broilers and layers and greater than $2,454,812/ton for turkeys. There ar e additional costs related to increased electricity use, and regulatory compliance and testing that have not been quantified in this analysis. Even without these costs, it is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-25 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 V. MECHANICALLY VENTILATED POULTRY HOUSES

The analysis evaluates replacing naturally ventilated animal hous ing with mechanically ventilated housing. The effectiveness of this measure is related to rapidly reducing the

moisture in the manure and the associated micr obial activity that produces emissions. Because of this, this measure is only applicable when animals are housed inside a building and the animals produce manure that does not contain excessive amounts of moisture; therefore this analysis will evalua te this option only for poultry facilities because other types of animals are generally housed outside (e.g. feedlot cattle) or produce manure that is handled as a liquid (e.g. swine). The cost of the VOC emission reductions for replacing a naturally v entilated poultry house with a mechanically ventilated poultry house is analyzed below. T he analysis will look at the costs for both turkeys and broilers. Because both broilers and laying hens have the same VOC emissions on a per bird basis and the over all costs of mechanically-ventilated housing for broilers is expected to be much less than mechanically-ventilated housing for laying

hens because of the need for addi tional equipment for collecti on of eggs, the lower cost associated with mechanically-ventilated hous ing for broilers will also provide the minimum cost of VOC reductions when applying this measure to laying hens. The following analysis is based on typical broi ler and turkey operations in California and demonstrates that replacing naturally v entilated poultry houses with mechanically

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

reductions for broiler houses also shows t hat the VOC emission reductions would not be cost effective for layers because mechanically ventilated houses for laying hens would have higher costs.

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

Broilers and turkeys are produced to meet s pecific requirements of the customer, which can be a retail grocery store, fast-food chain, or an institutional buyer. The production cycle of broilers and turkeys is divided in to two phases: brooding and grow-out. The brooding phase begins when freshly hatched ch icks from local hatcheries are delivered and placed in a heated section of a poultry h ouse known as the brood chamber. The brood chamber of the house is kept warm for ne wly hatched chicks. In a typical poultry house in the San Joaquin Valley about 20,000 - 35,000 broiler chicks or 8,500 turkey poults are released into each house at the b eginning of each grow-out period. During the birds’ first few weeks of growth, the temperature is gradually decreased. After completion of the grow-out phase the broilers and turkeys are transported to a nearby processing plant. The length of the grow-out phase for broiler chickens is approximately 45 days, resulting in an average weight of 4.5 to 5.5 pounds. Turkey hens are usually grown for 14 to 16 weeks and turkey toms are usually grown for 17 to 21 weeks.

As discussed above, ventilation in poultry houses is used to remove moisture and ammonia from the houses during the winte r season and to remove excess heat and ammonia from the houses during the summer season. In totally enclosed housing, mechanical ventilation is provided by an i nduced draft or negative-pressure system.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-26 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Description of C ontrol Technology

The mechanically ventilated environmental houses will have advanced environmental control system that uses thermostats, sensor s, and timers to more effectively control their exhaust fans. Environmental conditions (e.g. temperature, hu midity, ventilation, and lighting) within the houses are usually controlled by a computer system and monitored by staff. The conditions in the houses are controlled in a manner to optimize animal growth, maintain animal health, mini mize feed spoilage and waste, and reduce moisture and undesirable microorganisms in the houses. This tight control of environmental conditions has a positive impact on ov erall air quality. It is conservatively assumed that mechanically-ventilated environmental housing will reduce VOC emissions from poultry houses by 15%.

Capital Cost of a Mechanica lly Ventilated Poultry Houses

The cost estimate for a mec hanically ventilated poultry hou se is based on information taken from the University of California Cooperative Extens ion Poultry Fact Sheet No. 20

“Chicken Meat Product ion in California” 9 (June 1995). This public ation gives an initial capital cost estima te of $115,000 for a broiler hous e for a 40 ft x 500 ft (20,000 sq. ft.) mechanically ventilated broiler hou se for 22,200 birds. Because this estimate is 15 years old, this cost will be updated to 2010 dollars assuming a 3% an nual inflation rate. The cost

estimate in 2010 dollars is calculated as follows:

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

Although this cost will be us ed for purposes of this analysis, so me producers have provided more recent informati on indicating that the cost for mechanically ventilated environmental poultry houses is significantly higher.

Turkey operations use the same housing struct ures as broilers but have fewer birds per house. The University of Ca lifornia Cooperative Extension, California P oultry Workgroup publication “Animal Care Seri es: Turkey Care Practices” 10 (May 1998) states that “Approximately 10,000 hens or 7,000 toms are placed in the typical 50 by 500 foot barn.” This results in an average of 8,500 tu rkeys per 25,000 sq. ft. house. Therefore, it will be assumed that the 20, 000 sq. ft. broiler house described above can house 6,800 turkeys (8,500 bird s x 20,000 sq. ft ./25,000 sq. ft.).

Annualized Capital Cost a Mec hanically Ventilated Poultry House for 22,200 Broilers or 6,800 Turkeys

The annualized capital cost estimates will be calculated below. The cost for the initial cost of the poultry house wil l be spread over the expected life of the system using the

9 “Chicken Meat Production in California” University of California Cooperative Extension Poultry Fact Sheet No. 20 Ernst, Ralph A. (June 1995) http://animalscience.ucdavis.edu/avian/pfs20.htm

10 “Animal Care Series: Turkey Care Practices” University of California Cooperative Extension California Poultry Workgroup (May 1998) http://www.vetmed.ucdavis.edu/v etext/INF-PO_TurkeyCarePrax.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-27 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 capital recovery equation. The expected life of the entire system will be estimated at 10 years. A 10% interest rate is assum ed in the equation and the assumption will be made that the equipment has no salvage val ue at the end of the ten-year cycle.

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

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

VOC Emission Reductions for a Mechanica lly Ventilated Poultry House for 22,200 Broilers or 6,800 Turkeys

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

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

Broilers = (0.025 lb-VOC/bird-year) (22,200 bird /house) (0.15) = 83 lb-VOC/house-year

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

Cost of VOC Em ission Reductions

Broilers/Layers Cost Estimate = ($29,158/year)/[(83 lb-VOC/year)(1 ton/2000 lb)]

= $702,602/ton of VOC reduced

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

= $571,725/ton of VOC reduced

As shown above, the capital cost alone for mechanically ventilated poultry housing

would cause the cost of t he VOC reductions to be greater than $700,072/ton for broilers and layers and greater than $571,725/ton for turk eys. This cost does not include the

costs of demolition of the ex isting naturally vent ilated poultry house. Even without these costs, it is clear that t he cost of the VOC emission re ductions achieved are far beyond BARCT and any applicable RACT requirements.

VI. ANALYSES FOR MANURE HANDLING SYSTEMS

A. Poultry House with a Be lt Manure Removal System

The cost of the VOC emission reductions for converting an existing poultry house to a manure-belt poultry house is analyzed below. The use of manure-belt houses is only applicable to birds that are housed in cages and would not be applicable to birds thatSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-28 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 are housed directly on litter, which is the case for most broilers and turkeys; therefore, this analysis will be based on layer operations. In addition, forced drying of poultry manure inside poultry houses and forced drying of poultry manure that is directly removed from the houses on a frequent basis wil l generally require use of some type of manure belt handling system. Th erefore, this analysis also serves to establish the

minimum cost of VOC reductions for usi ng an in-house poultry manure drying system.

Description of Housing in a Typical Laying Hen Operation

Laying hens maintained for table egg produc tion are usually confined in cages. This

allows automation of feed distri bution and egg collection. Most confinement facilities for laying hens are mechanically ventilated to remove the moisture and carbon dioxide produced by respiration. Exhaust fans draw air into the building through slots located along the perimeter of the roof. There are several types of cage systems including full and modified stair-step systems. With modi fied stair-step cage systems, upper cages are partially offset with a baffle diverting manure from upper cages away from lower cages. There are also cage systems that st ack cages without any offset to maximize the number of birds per unit floor area. In single story buildings, full or modified stair systems are located over shallow manure collect ion pits that may be cleaned either by scraping or flushing. With stacked cage systems, a belt system under the cages can be

used to collect and remove manure

Description of C ontrol Technology

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

houses in which manure can accumulate in hous es for several months to a year. Using belts to handle manure facilitates drying of t he manure that falls on the belts. A forcedair drying system can also be used to furt her reduce the moisture content of the

manure. The manure removed from the houses by the belt system can be transported and stored in separate manure storage areas, appli ed directly to land, or composted.

Manure-belt houses facilitate r apid drying of manure, which reduces the time available in which biological activity in the manure can produce emissions of air contaminants. A

number of studies have s hown that overall emissi ons of odorous compounds and ammonia from poultry houses using belt m anure removal systems are much lower than poultry houses using in-house pit storage of manure. It is conservatively assumed that manure-belt housing will reduc e VOC emissions from poultry houses by 10%.

Cost of a Manure-Belt House

The cost estimate for manure-bel t poultry housing is based on information taken from the report “Economics of Cont rolling Ammonia Emission from Commercial Layer Farms” 11

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-29 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 (1998). This publication gives an initial capital cost estima te of $1.75 per bird and an

annual maintenance co st of 3% of the initial capitol co st for conversion of an existing poultry house to a manure-belt house . Because the capitol cost estimate is 12 years old, this cost will be updated to 2010 dollars assuming a 3% annual inflation rate . The cost

estimate in 2010 dollars is calculated as follows:

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

The capital cost and annual ma intenance costs for converting an existing 20,000 bird

house to a manure-belt hous e are given as follows:

Capitol Cost = 20 ,000 birds x $2.4 95/bird = $49,900

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

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

The annualized capital cost estimates will be calculated below. The cost for the initial cost of converting to a manure-belt house will be spread over the ex pected life of the system using the capital recovery equation. The expected life of the entire system will be estimated at 10 years. A 10% interest rate is assumed in the equation and the assumption will be made that the equipment has no salvage value at the end of the tenyear cycle.

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

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

Total Annual Cost Estimate

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

Total annual cost estimate = (total annua lized capital cost) + (increased operating cost)

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

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

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

are calculated as follows:

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

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

Cost of VOC Em ission Reductions

Cost Estimate =($9,618/year)/[(50 lb-VOC/year)(1 ton/2000 lb)]SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-30 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 = $384,720/ton of VOC reduced

As shown above, the costs for converti ng existing poultry housing to manure-belt housing would cause the cost of the VOC reductions to be greater than $384,720/ton. This may not include the costs of additional energy required to run the belt and any associated drying equipment. It is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirements.

B. Composting or Storing Manure Removed Animal Housing in an Aerated Static Pile (ASP) or Enclosur e Vented to a Control Device

The costs associated with composting or st oring the solid manure produced by livestock in an aerated static pile (ASP) vented to a control device or an enclosure vented to a control device are analyzed below. This prac tice is only applicable to manure that is handled in solid form; t herefore this analysis will evaluate this option only for dairy cattle, beef cattle, and poultry because thes e confined animal facilities can handle

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

relevant cost information will be taken from th is staff report. The st aff report for District

Rule 4565 found that use of ASPs and in-v essel composting would have unreasonably high costs for existing composting facilitie s that have a throughput of less than 100,000 wet tons per year. The vast majority of confined animal facilities produce much less manure than this; therefore, th is option is not expected to be cost-effective for confined animal facilities. Although this option is not expected to be reasonably cost-effective, it

will be evaluated below.

Description of C ontrol Technology

It may be possible to reduce emissions from solid manure by using an ASP or enclosure to compost or store the solid manure. ASPs are used in com posting systems to speed up the compost process by forcing or drawing air through the material being composted. The material in an ASP is placed over perfo rated pipes that are connected to a blower to draw air from the pile. The air that is drawn from t he pile can be sent to a VOC control device to reduce emissions. Large co mposting facilities can also use in-vessel composting systems, in which the composti ng process occurs in a building or other

enclosure. The emissions from solid manur e that is composted or stored in an enclosure can also be sent to a VOC control device. A complete enclosure is more expensive than an ASP but results in higher c apture efficiency for emissions. As noted in the staff report for Distri ct Rule 4565, biofilters are the most commonly used VOC emission control device at composting fac ilities. This is because biofilters are significantly less expensive than other opti ons used for the control of VOCs. As discussed above, biofilters utilize microbial ac tivity to remove contaminants from a gas through biological oxidation.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-31 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 It must be noted that although it may be possible to reduce VOC emissions from solid manure using an ASP or enclosure vented to a bi ofilter or other control device, recent studies at dairies and poultry facilities have i ndicated that VOC emissions from stored solid manure and poultry litter are very low wh ile other studies have indicated that large composting operations can have high VOC emissions if they ar e not properly controlled. Therefore, if composting is performed addi tional monitoring of the composting system

and control device would be needed to ensur e that VOC emissions are reduced compared to storage of solid manure.

Cost of an ASP or Enclosure vented to a Control Device:

The following costs are taken from the final st aff report for District Ru le 4565 - Biosolids, Animal Manure, and Poultry Li tter Operations (May 30, 2007). 12 The cost information is based on a large composting facility with a th roughput of 200,000 wet tons per year. On a per ton basis the costs for smaller compos ting facilities would be higher since there

would not be the economies of scale for bui lding and operations created by large composting facilities.

Table 11 - Low Cost Scenario: A SP & Biofilter (200,000 wet ton/yr)

Total Capital Cost $7,775,000

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

Total Annual O & M Cost $124,305

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

Table 12 - High Cost Scenario: In-Vessel and RTO (200,000 wet ton/yr)

Total Capital Cost $21,185,000

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

Total Annual O & M Cost $285,910

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

As stated above, the final staff report for Dis trict Rule 4565 stated that the use of ASPs and in-vessel composting would have unreasonably high costs for faci lities that have a

12 The capitol and operation co sts for ASP and in-vessel composting giv en in the final staff report were

taken from: United States Environmen tal Protection Agency, “Biosolids Technology Fact Sheet: Use of Composting for Biosolids Managemen t” EPA 832-F-02-024, September 2002, http://water.epa.gov/scite ch/wastetech/upload/200 2_10_15_mtb_combioman.pdf . These costs were not adjusted for inflationSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-32 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 throughput of less than 100,000 wet tons per year. The costs given above are for a facility with a throughput of 200,000 wet tons per year. It will conservatively be

assumed that the cost for a facility with a throughput of 100,000 wet tons per year will be half of the values given above. Therefor e, the cost estimates for a facility with a throughput of 100,000 are as follows:

Low Annual Capital Cost Estimate (100,000 wet ton/yr) = $694,825/year

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

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

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

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

According to the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Agricultur al Waste Management Field Handbook (AWMFH), Chapter 4 - Agricult ural Waste Characteristics 13 (March 2008), dairy cows in scraped open corrals produce approximately 77 lb per day of solid manure that can be removed and transferred for storage or composting. The amount of solid manure removed for dairy cows housed in corrals or freestall barns with a flush system would be much less. The number of cows needed to pr oduce 100,000 ton/year of solid manure is

calculated as follows:

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

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

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

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

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-33 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Table 13 - VOC Reductions for Dairy Solid Manure in ASP or Enclosure Vented to a Biofilter

Type of Animal # of

cows x Solid Manure EF (lb/cow-yr) x Capture (%)* x Control (%) = lb-VOC/yr

Milk Cow 7,116 x 0.15 x 50% x 85% = 454
* The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for composting facilities, which would result in lower emission reductions.

Cost of VOC Em ission Reductions

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

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

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

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

As shown above, the cost an ASP or in-vesse l enclosure to handle the solid manure at a dairy would cause the cost of the VOC r eductions to be greater than $3,060,903/ton. The excessively high costs of this option make it impracti cal for most confined animal

facilities.

b. ASP or In-Vessel Enclosure for Feed lot Cattle Solid Manure Removed from Housing

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

year.

Number of Feedlot Catt le to Produce 10 0,000 ton/yr of Solid Manure

According to the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Agricultur al Waste Management Field Handbook (AWMFH), Chapter 4 - Agricult ural Waste Characteristics (March 2008), feedlot cattle in earthen lots produce approximately 17 lb per day of solid manure that can be removed and transferred for storage or composting. The number of feedlot cattle needed to produce 100,000 ton/year of solid m anure is calculated as follows:

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-34 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 VOC Emission Reductions from an ASP or Enclosure Handling Solid Manure from 32,232 Feedlot Cattle:

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

below:

[Number of Feedlot Cattle] x [Solid Manur e VOC EF (lb/head-year)] x [ASP/In-Vessel Capture Efficiency] x [Control De vice VOC Control Efficiency]

Table 14 - VOC Reductions for Feedlot Solid Manure in ASP or Enclosure Vented to a Biofilter

Type of Animal # of

head x Solid Manure EF (lb/head-yr)* x Capture (%)** x Control (%) = lb-VOC/yr

Feedlot Cattle 32,232 x 0.09 x 50% x 85% = 1,233
*Feedlot Cattle Solid manure EF estimated by scaling down the draft Dairy solid manure EF of 0.15 lb/hdyr based on current dairy and feedlot cattle VOC em ission factors of 19.3 lb/hd-yr and 11.1 lb/hd-yr ** The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for composting facilities, which would result in lower emission reductions.

Cost of VOC Em ission Reductions

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

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

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

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

As shown above, the cost an ASP or in-vesse l enclosure to handle the solid manure at

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

facilities.

c. ASP or In-Vessel Enclosure for Litt er/Solid Manure Removed from Poultry Housing

The cost of the emission reductions achiev ed by composting or storing litter/solid manure removed from poultry houses in an ASP or enclosure vented to a control device are analyzed below. Because it has been dete rmined that this practice would not be cost-effective for a facility with a throughput of less than 100,000 tons per year, this analysis will be based on a broiler or turkey fa cility that can produc e 100,000 tons of litter per year. However, it is thought that there are no single poultr y facilities that are this large because of bio-security concerns and the impracticality of having such a large

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-35 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Number of Broilers or Turkeys to Produce 100,000 ton/yr of Litter

According to the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Agricultur al Waste Management Field Handbook (AWMFH), Chapter 4 - Agricult ural Waste Characteristics (March 2008), the amount of litter removed from poultry houses that can be transferred for storage or composting is approximately 0.044 lb per day for broile rs and approximately 0.24 lb per day for turkeys. The number of broilers or turk eys needed to produce 100,000 ton/year of solid

manure is calculated as follows:

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

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

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

that are this size is evaluated below.

VOC Emission Reductions from an ASP or En closure Handling Litter/Solid Manure from 12,453,300 Broilers or 2,283,105 Turkeys:

The annual VOC Emission Reductions for ASP or in-vessel enclosure handling the litter/solid manure from 12,453,300 broilers or 2,283,105 turkeys are calculated as

follows and shown in the table below:

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

Table 15 - VOC Reductions for Poultry Solid Manure/Li tter in ASP or Enclosure Vented to a Biofilter

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

Broiler/Layer 12,453,300 x 0.0025 x 50% x 85% = 13,232
Turkey 2,283,105 x 0.01 x 50% x 85% = 9,703

* CARB source test results for California broiler ho uses indicated near negligible VOC emissions from

litter when birds were not in the house. 14 Based on the information from this study VOC emissions from poultry litter/solid manure removed from the house ar e very conservatively estimated to be 10% of the total VOC emission factor for poultry. ** The capture efficiency is conservatively assumed to be 50%. The technical assessment of SCAQMD Rule 1133.2 and the staff report for District Rule 4565 give a capture efficiency of 33% for composting facilities, which would result in lower emission reductions.

14 “Quantification of Gaseous Emissions from Califor nia Broiler Production Houses” - Source tests on mechanically ventilated broiler houses during the spri ng and fall of 2004. Participants included: AIRx Testing; California Air Resources B oard; California Department of Food an d Agriculture; California Poultry Federation; Foster Farms; & Univ ersity of California, Davis. http://www.arb.ca.gov/ ag/caf/poulemisrpt.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-36 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Cost of VOC Em ission Reductions

Broilers/Layers

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

= $105,022/ton of VOC reduced

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

= $282,170/ton of VOC reduced

Turkeys

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

= $143,219/ton of VOC reduced

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

= $384,796/ton of VOC reduced

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

ASP or in-vessel enclosure to handle the litter/solid manure to be cost effective. If there were any such facilities the cost of the VOC reductions w ould be greater than $105,022/ton for broilers and greater than $143, 219/ton for turkeys. The excessively high costs of this option make it imprac tical for most confined animal facilities

C. Sending Solid Manure Removed from An imal Housing to a Digester with a

VOC Control Device

The costs associated with treat ing the solid manure produced by livestock in a digester vented to a control device are analyzed below. This practice is only applicable to

manure that is handled in solid form; therefore this cost anal ysis will evaluate this option only for dairy cattle, beef cattle, and poultry because these confined animal facilities can

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

content and fibrous material in cattle manure allows the manure to be effectively pushed through the digester. EPA’s AgSTAR anaerobi c digester database lists a number of digesters utilizing dairy manure but only two digesters using beef cattle manure and three using poultry manure. 15 This is because manure from beef cattle and broilers is usually mixed with large amount of bedding or earth and cannot be easily collected and separated for use in a digester.

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-37 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Description of C ontrol Technology

An anaerobic digester is an enclosed basin or tank that is designed to facilitate the decomposition of wastewater by microbes in the absence of oxygen. The process of anaerobic decomposition results in the c onversion of organic compounds in the wastewater into methane (CH 4 ), carbon dioxide (CO 2 ), and water rather than intermediate Volatile Organic Compounds (VOC s). The gas generated by this process is known as biogas, waste gas, or digester gas. Biogas may also include trace amounts of VOCs that remain from incomplete digesti on of the volatile solids in the incoming wastewater. The undigested solid s that remain after diges tion are removed from the digester as sludge. Because biogas is mo stly composed of methane, the main component of natural gas, the gas produced in the digester can be cleaned to remove

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

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

a. Digester for Solid Manure from Dairy Cows

The costs associated with treat ing the solid manure removed from milk cow housing in a plug flow digester vented to a control devic e are analyzed below. Because it may be possible to generate power from the system to offset some of the costs associated with installation, this potential benefit is incl uded in the analysis below. The following analysis is based on the treatment of solid manure from 1,000 milk cows in a plug flow digester with power generation.

Capital Cost for Insta llation of a Plug Flow Digester for Dairy Cows

The capital cost estimates for installation of a plug flow digester ar e based on information from the United States EPA AgSTAR publication “Anaerobic Digestion Capital Costs for Dairy Farms” (May 2010) 16 and the California Energy Commi ssion (CEC) Public Interest Energy Research (PIER) Program Dairy Methane Digester System Program Evaluation Report (Feb 2009) 17 . The formula in the AgSTAR publicat ion results in a capitol cost of $1,192 per cow for a plug flow anaerobic dige ster treating manure from 1,000 cows.

This estimate excludes costs of solids separation after digestion, hydrogen sulfide

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

17 “Dairy Power Production Program – Dairy Met hane System Program Evaluation Report” (February 2009). Western United Resource Development, Inc prepared for the California Energy Commission (CEC) Public Interest Energy Research Program. (CEC-500-2009-009) http://www.energy.ca.gov/2009publications/C EC-500-2009-009/CEC-500-2009-009.PDFSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-38 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 removal, and utility charges including line up grades and interconnection costs and fees.

Based on information from installations in California, the CEC PIER Dairy Methane Digester Program Evaluation Report give s an average cost of $1,042 per cow for installation of plug flow anaerobi c digesters (see Table 9 - Total Project Costs and Cost per Cow and per kW). Theref ore, for purposes of this a nalysis the capital cost for installation of a plug flow digester system for 1,000 cows will be assumed to be between $1,042 and $1,192 per cow. The capital cost estimates of a plug flow digester treating
the manure of 1,000 milk cows are shown below:

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

The annualized capital cost estimates will be calculated below. The capital cost for the installation of the plug flow digester will be spread over the expected life of the system using the capital recovery equation. T he expected life of t he entire system will be estimated at 10 years though the cover may r equire replacement during this period. A 10% interest rate is assumed in the equat ion and the assumption wil l be made that the equipment has no salvage value at the end of the t en-year cycle.

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

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

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

Potential Production of Electric ity from a Plug Flow Digeste r Treating Solid Manure from 1,000 Milk Cows:

It may be possible to offset some of the in stallation costs of an anaerobic digester with revenue from generation of electricity. Bas ed on the information given in the CEC PIER Dairy Methane Digester Program Evaluation Report, Table 7 – Actual Generation per Cow Comparisons, California dair ies that used a plug flow digester to produce electricity generated between 426.5 and 1,013.2 kW-hr/yr per lactating cow with a overall per facility average generation rate of 632.8 kW-hr/ yr per lactating cow. This average annual generation rate is actually higher than all the facilities included in the average except one that had a very high generation rate. In addition, this average may overestimate the per-cow generation potent ial because the contributions of support stock to the digesters were not accounted for. However, for more conservative calculations, this average will be used to ca lculate the potential annual savings in electricity costs. The potential production of el ectricity from a plug flow digester treating solid manure from 1,000 milk cows is calculated as follows:

Electrical Production: 632.8 kW-hr/(m ilk cow-yr) x 1,000 milk cows = 632,800 kW-hr/yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-39 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Potential Cost Savings from Production of El ectricity from a Plug Flow Digester Treating

Solid Manure from 1,000 Milk Cows:

The value of the electricit y generated will be based upon the average price for industrial electricity in California for the year 2010, as taken from the Energy Information Administration (EIA) Website: ( http://www.eia.doe.gov/cneaf/e lectricity/epm/table5_6_b.html )

Average Cost for electricity = $0.0999/kW-hr

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

632,800 kW-hr/yr x $0.0999/ kW-hr = $63,217/yr

Annualized Capital Cost for a Plug Flow Dige ster Treating Solid M anure from 1,000 Milk Cows minus Potential Savings fr om Generation of Electricity:

Low Annual Capital Cost Estimate mi nus Savings from Po tential Generation = $169,581/yr - $63,217/yr = $106,364/year

High Annual Capital Cost Estimate mi nus Savings from Potential Generation = $193,993/yr - $63,217/yr = $130,776/year

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

The annual VOC Emission Reductions for plug fl ow anaerobic digester treating the solid manure from 1,000 milk cows are calculated as follows and shown in the table below:

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

Table 16 - VOC Reductions for a Digester for Solid Manure Vented to Control Device

Type of Cow # of

cows x Solid Manure EF (lb/cow-yr) x Control (%) = lb-VOC/yr

Milk Cow (freestall) 1,000 x 0.15 x 80% = 120

Cost of VOC Em ission Reductions

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

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

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

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

As shown above, the capital cost alone for a di gester to treat the solid manure at a dairy

would cause the cost of t he VOC reductions to be greater than $1,772,733/ton. ThisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-40 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 cost includes the potential revenue generated by electrical production but does not

include the additional maintenan ce required for the system. Even without these costs, it is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, which may offset any reductions in VOCs.

b. Digester for Solid Manure from Feedlot Cattle

The costs associated with treat ing the solid manure removed from feedlot cattle housing in a plug flow digester vented to a control device are analyzed below. Because it may be possible to generate power from the system to offset some of th e costs associated with installation, this potentia l benefit is included in the analysis below. The following analysis is based on the treatment of solid manure from 3,500 feedlot cattle in a plug flow digester with power generation.

Capital Cost for In stallation of a Plug flow Digester for Feedlot Cattle

On an animal weight basis, the capital cost esti mates for installa tion of a plug flow digester

for beef feedlot cattle are assumed to be the same as the costs for installation of a plug flow digester at a dairy. Ba sed on the information given above, the capital cost of installation of a plug flow digester at a dairy is between $1,042 and $1,1 92 per cow. A typical milk cow weighs approximately 1,400 lb and the average weight of feedlot steers is

assumed to be 950 lb. The es timated capital cost of a plug flow digester for beef feedlot

cattle is estimated by adjusting by weight as follows:

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

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

Low capital cost estimate : 3,500 head x $707/head = $2,474,500 High capital cost estimate: 3,500 head x $809/head = $2,831,500

The annualized capital cost estimates will be calculated below. The capital cost for the installation of the plug flow digester will be spread over the expected life of the system using the capital recovery equation. T he expected life of t he entire system will be estimated at 10 years though the cover may r equire replacement during this period. A 10% interest rate is assumed in the equat ion and the assumption wil l be made that the equipment has no salvage value at the end of the t en-year cycle.

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

Low Annual Capital Cost Esti mate = [$2,474,500 x 0.1(1.1) 10 ]/[(1.1) 10 -1]

= $402,713/yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-41 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 High Annual Capital Cost Esti mate = [$2,831,500 x 0.1(1.1) 10 ]/[(1.1) 10 -1]

= $460,814/year

Potential Production of Electric ity from a Plug flow Digeste r Treating Solid Manure from 3,500 Beef Feedlot Cattle:

It may be possible to offset some of the installation costs of a plug flow anaerobic digester with revenue from generation of electricity. Production of electricity from digester gas from feedlot cattle manure has not been common because of the difficulty in collecting fresh manure for a digester. Because there is limited information available regarding production of electric ity from digester gas from feedlot cattle manure, the potential for production of electricity will be estimated based on the information given above for production of electricity from plug flow digesters at dairy facilities. It will be assumed that the potential for production of di gester gas and electricity from dairy cows and beef cattle will be proportional to the amount of volatile solids excreted in the manure. According to the United States Department of Agricult ure (USDA) Natural Resources Conservation Service (NRCS) Agricultural Waste Management Field Handbook (AWMFH), Chapter 4 - Agri cultural Waste Characteristics 18 (March 2008), a lactating dairy cow excretes an average of approximately 17 lb/d ay of volatile solids and feedlot cattle excrete an average of approximately 9.35 lb/day of volatile solids per 1,000-lb AU. Based on the information given above, a plug flow anaerobic digester at a dairy is estimated to produce 670.3 kW-hr per milk cow per year. Assuming that the amount of electricity produced is proportional to the amount of vo latile solids sent to the plug flow digester, the potential for elec tricity generation by a plug flow anaerobic digester at a beef cattle facility is estimated as follows:

(0.95 AU/head x 9.35 lb VS/AU)/ (17 lb-VS/milk cow) x 6 32.8 kW-hr/(milk cow-yr) = 330.6 kW-hr/(head-yr)

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

Electrical Production: 330.6 kW-hr/( head-yr) x 3,500 head = 1,157,100 kW-hr/yr

Potential Cost Savings from Production of El ectricity from a Plug Flow Digester Treating

Solid Manure from 3,500 Feedlot Cattle:

Based on the reference given above, the value of electricity used for this analysis will be = $0.0999/kW-hr

The potential annual cost savings from electric ity generation from a pl ug flow digester treating manure from 3,500 feedlot cattle is calculated as follows:

1,157,100 kW-hr/yr x $0. 0999/kW-hr = $115,594/yr

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-42 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Annualized Capital Cost for a Plug flow Dig ester Treating Solid Manure from 3,500 Feedlot Cattle minus Potential Savings from Generation of Electricity:

Low Annual Capital Cost Estimate mi nus Savings from Po tential Generation = $402,713/yr

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

High Annual Capital Cost Estimate mi nus Savings from Potential Generation = $460,814/yr - $115,594/yr = $345,220/year

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

The annual VOC Emission Reductions for pl ug flow anaerobic dige ster treating the manure from 3,500 feedlot cattle are calcul ated as follows and shown in the table

below:

[Number of Feedlot Cattle] x [Solid Manure VOC EF (lb/cow-year)] x [Digester Control Efficiency for Solid Manure]

Table 17 - VOC Reductions for a Plug Flow Digester Vented to Control Device

Type of Animal # of

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

Feedlot Cattle 3,500 x 0.09 x 80% = 252
* Based on scaling down draft dairy emission factor for solid manure using current dairy and feedlot cattle VOC emission factors of 19.3 lb/hd-yr and 11.1 lb/hd-yr

Cost of VOC Em ission Reductions

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

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

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

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

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

feedlot would cause the cost of the VOC r eductions to be greater than $2,278,722/ton. This cost includes the potential revenue gener ated by electrical production but does not

include the additional maintenan ce required for the system. Even without these costs, it is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, which may offset any reductions in VOCs.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-43 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 c. Digester for Solid Manure from Poultry

Although treating the manure excreted by poultry in a digester is not a common practice 19 , the costs associated with treating the so lid manure excreted by laying hens in a digester are analyzed below. Because it may be possible to generate power from the system to offset some of the costs associated with insta llation, this potential benefit is included in the analysis below. The following analysis is based on the treatment of manure from 500,000 laying hens in an anae robic digester with power generation.

Capital Cost for Insta llation of a Digester for Poultry Solid Manure

On an animal weight basis, the capital cost esti mates for insta llation of a digester treating solid manure from poultry are assumed to be the sa me as the costs for installation of a plug flow digester at a dairy. Based on the information give n above, the capital cost of installation of a plug flow digester at a dairy is between $1,042 and $1,1 92 per cow. A typical milk cow weighs approximately 1,400 lb and the average weight of a laying hen is

assumed to be 4 lb. The estima ted capital cost of a digester for solid poultry manure is estimated by adjusting by weight as follows:

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

The estimated capital cost of a plug flow di gester treating the solid manure from 500,000 laying hens is calcul ated as follows:

Low capital cost estimate: 500,000 birds x $2.98/bird = $1,490,000 High capital cost estimate: 500,000 birds x $3.41/bird = $1,705,000

The annualized capital cost estimates will be calculated below. The capital cost for the installation of the digester will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system will be estimated at 10 years though the cover may require replacement during this period. A 10% interest rate is assumed in the equation and the assumpti on will be made that the equipment has no salvage value at the end of the ten-year cycle.

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

Low Annual Capital Cost Esti mate = [$1,490,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1]

= $242,491/year

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

= $277,481/year

19 The US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Dige ster Database (updated April 2010) lists only three poultry digesters, http://www.epa.gov/agstar/operational.htmlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-44 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Potential Production of Electr icity from an Anaerobic Dige ster Treating Solid Manure from 500,000 Laying Hens:

It may be possible to offset some of the in stallation costs of an anaerobic digester with revenue from generation of electricity. Bec ause only a very small number of digesters have been installed at poultry facilities and there is limited information available regarding production of electric ity from digester gas from poultry manure, the potential for production of electricity will be estima ted based on the information given above for production of electricity from plug-flow digeste rs at dairy facilities. It will be assumed that the potential for production of digeste r gas and electricity from dairy cows and poultry will be proportional to the amount of volatile solids excreted in the manure. According to the USDA NRCS Agricultur al Waste Management Field Handbook (AWMFH), Chapter 4 - Agricult ural Waste Characteristics (March 2008), a lactating dairy cow excretes an average of approximatel y 17 lb/day of volatile solids and a laying hen excretes approximately 0.036 lb/day of vo latile solids. Based on the information given above, an anaerobic digester treating solid manure at a dairy is estimated to produce 632.8 kW-hr per milk cow per year. Assuming that the amount of electricity produced is proportional to the amount of vola tile solids sent to the plug flow, the potential for electricity generat ion by an anaerobic digester fo r solid manure at a poultry facility is estimated as follows:

(0.036 lb-VS/bird)/(17 lb- VS/milk cow) x 632.8 kW-hr/ (milk cow-yr) = 1.34 kWhr/(bird-yr)

The potential product ion of electricity from a digester treating solid manure from 500,000 laying hens is calculat ed as follows:

Electrical Production: 1.34 kW-hr/(bir d-yr) x 500,000 birds = 670,000 kW-hr/yr

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

Based on the reference given above, the value of electricity used for this analysis will be = $0.0999/kW-hr

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

670,000 kW-hr/yr x $0.0999/ kW-hr = $66,933/yr

Annualized Capital Cost for a Digester Treat ing Solid Manure from 500,000 Birds minus Potential Savings from G eneration of Electricity:

Low Annual Capital Cost Estimate mi nus Savings from Po tential Generation = $242,491//yr - $66,933/yr = $175,558/year

High Annual Capital Cost Estimate mi nus Savings from Potential Generation = $277,481/yr - $66,933/ yr = $210,548/yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-45 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 VOC Emission Reductions from an Anaerobic Digester Treating So lid Manure from 500,000 Birds:

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

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

Table 18 - VOC Reductions for a Digester for Solid Manure Vented to Control Device

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

Laying Hens 500,000 x 0.0025 x 80% = 1,000

* CARB source test results for California broiler ho uses indicated near negligible VOC emissions from

litter when birds were not in the house. 20 Based on the information from this study VOC emissions from poultry litter/solid manure removed from the house ar e very conservatively estimated to be 10% of the total VOC emission factor for poultry.

Cost of VOC Em ission Reductions

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

= $351,116/ton of VOC reduced

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

= $421,096/ton of VOC reduced

As shown above, the capital cost alone for an anaerobic digester for solid manure from poultry would cause the cost of the VOC r eductions to be greater than $351,116/ton. This cost includes the potential revenue gener ated by electrical production but does not

include the additional maintenan ce required for the system. Even without these costs, it is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirements. This analysis did not consider the additional pollution that would be generated by any combustion equipment that would utilize the gas, which may offset any reductions in VOCs . In general, this option would not likely be considered economically feasible for any facility without the project receiving

substantial subsidies to offset the extremely high costs of installation.

20 “Quantification of Gaseous Emissions from Califor nia Broiler Production Houses” - Source tests on mechanically ventilated broiler houses during the spri ng and fall of 2004. Participants included: AIRx Testing; California Air Resources B oard; California Department of Food an d Agriculture; California Poultry Federation; Foster Farms; & Univ ersity of California, Davis. http://www.arb.ca.gov/ ag/caf/poulemisrpt.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-46 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 D. Aerobic Treatment Lagoon or a Mech anically Aerated to Treat Manure Liquid Manure Produced by Livestock

The feasibility of treating the manure produced by livestock in an aerobic lagoon is evaluated below. This practice is only app licable to manure that is handled in liquid form; therefore this option will only be eval uated for dairy cattle, swine, and layers

because these confined animal facilities frequently handle manure in liquid form, whereas feedlot cattle, broilers and turkeys al most exclusively handle manure or litter as a solid. As defined in the current and pr oposed versions of District Rule 4570, an aerobic lagoon is “ a lagoon designed, constructed, maintained, and operated in accordance with the applicable standards for aerobic lagoons in the Natural Resource Conservation Service (NRCS) California Fiel d Office Technical Guide Conservation Practice Standard Code 359 or other app licable standards approved by the APCO, ARB, and EPA. ” NRCS Practice Standard Code 359 contains criter ia for both naturally aerobic lagoons and mechanically aerated lagoons. Because it is clear that the very large land requirements to treat the manure from confined animal facilities subject to this rule in a naturally aerobic lagoon ar e beyond what could reasonably be required, a complete cost analysis will not performed for th is option. However, a complete cost analysis will be performed for a me chanically aerated lagoon.

Description of C ontrol Technology

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

In completely aerated lagoons sufficient oxygen must be provided to sustain the aerobic microorganisms. NRCS Practice Standard C ode 359 specifies that naturally aerobic lagoons have a minimum surface area det ermined by regional climate and daily Biological Oxygen Demand (BOD 5 ) and requires the depth of naturally aerobic lagoons have a maximum depth no greater than five f eet. For mechanically aerated lagoons

NRCS Practice Standard Code 359 specifies that t he aeration equipment shall provide a minimum of 1 pound of oxygen for each pound of daily BOD 5 loading. The mechanical aerators that provi de the required oxygen may float on the lagoon surface or be submerged in the lagoon. Aeration can also be performed by injection of tiny air bubbles into the lagoon water, mixing of the lagoon water, or spraying of the water into the air. According to Dr. Ruihong Zhang, a res earcher at the University of California, Davis, at least 95% VOC control can be achieved if the dissolved oxygen (DO) concentration of the liquid manure is 2. 0 mg/L or more. However, the DO concentrations achieved in mechanically aer ated lagoons treating manure are typicallySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-47 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 much less than this and will therefore have lower control efficiencies. A major disadvantage of completely aerated lagoons is the enormous cost of the energy required to run the aerators continuously. Because of this, it has generally been determined that completely aerated lagoons ar e not cost effective options for confined animal facilities at the present time.

a. Aerobic Lagoon Treating Liqui d Manure from Dairy Cows

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

Space Requirement for a Naturally Aer obic Lagoon Treating Manure from 1,000 Dairy

Cows

The following brief analysis will demonstrate that the very lar ge land requirements needed to treat the manure from dairies subject to this rule in a naturally aerobic lagoon would be beyond what could reasonably be requi red. Therefore, there is no need to perform a detailed analysis that would consider all of the addi tional costs, such as the costs of purchasing additional land, constr ucting and lining the lagoon(s), and additional costs for control of mosquito larvae.

NRCS Practice Standard Code 359 requires that naturally aerobi c lagoons be designed

to have a minimum treatment surface area as determined on the basis of daily BOD 5 loading per unit of lagoon surface. The st andard specifies that the maximum loading rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the NRCS Agricultural Waste Managem ent Field Handbook (AWMFH) 21 or the maximum loading rate according to state regulatory requirements, whichever is more stringent. According to Figure 10-30 (August 2009) of the latest version of the AWMFH, the maximum aerobic lagoon loadin g rate for the San Joaqui n Valley is 45 - 55 lbBOD 5 /acre-day. According to Table 4-5 (March 2008) of the NRCS AWMFH, the total daily manure produced by a m ilk cow will have 2.9 lb-BOD 5 /day. Assuming that 80% of the manure will be flushed to the lagoon syst em, the minimum lagoon surface area required for a naturally aerobi c lagoon treating manure from 1,000 milk cows in the San Joaquin Valley can be ca lculated as follows:

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

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum loading rate of 55 lb-BOD 5 /acre-day = 2,320 lb-BOD 5 /day ÷ 55 lb-BOD 5 /acre-day = 42.2 acres

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-48 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum loading rate of 45 lb-BOD 5 /acre-day = 2,320 lb-BOD 5 /day ÷ 45 lb-BOD 5 /acre-day = 51.6 acres

As shown above the minimum surface ar ea required for a naturally aerobic lagoon treating manure from 1,000 milk cows in the San Joaquin Valley would range from approximately 42.2 to 51.6 acres. This does not include the additional surface area that would be required to treat manure from s upport stock onsite. Based on the space requirements alone it is clear that this option cannot reasonably be required and no further analysis is needed.

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

As discussed above, the very large space requirements for naturally aerobic lagoons cause this option to be infeasible for most confined animal facilities. Mechanically aerating a lagoon can achieve so me of the benefits of a naturally aerobic lagoon without the large space requirements. However, the costs of energy for complete aeration have also caused this option to be infeasible. The amount of energy required for aeration is

based on the amount of volatile solids excret ed by animals that must be treated; thus, this cost will be directly proportional to the number of animals at a site. The following analysis will determine the cost of emission reductions that can be achieved from a mechanically aerated lagoon treating manur e from 1,000 milk cows.

Biological Oxygen Demand (BOD 5 )

In order to effectively calcul ate the costs of this control option, the energy requirement for complete aeration must be determined. It should be noted that approximately 1.5 to 2.5 pounds of oxygen is required to di gest 1 pound of Biological Oxygen Demand (BOD 5 ) with additional oxygen required for conversion of ammonia to nitrate (nitrification). 22 It is generally accepted that at l east twice the BOD should be provided for complete aeration. 23 According to Dr. Ruihong Zhang of the University of California, Davis, 2.4 lbs (1.1 kg) of oxygen (O 2 ) per cow must be provided each day for removal of BOD and an additional 3 lbs (1.4 kg) per co w for oxidation of 70% of the nitrogen. 22

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

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

22 An Assessment of Technologies for Management an d Treatment of Dairy Manure in California’s San

Joaquin Valley, December 2005, pages 34 & 35 ( http://www.arb.ca.gov/ag/caf/dairypnl/dmtfaprprt.pdf )

23 See http://www.extension.org/faq/27574 and http://www.omafra.gov.on.ca/e nglish/engineer/facts/04-

033.htmSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-49 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Energy Requirement a Mechanically Aera ted Lagoon Treating Manure from 1,000 Milk

cows:

Based on the data gathered in a UC Davis study on aerator performance for wastewater lagoons, aeration efficiencies for mechanical aerators ranged from 0.10 to 0.68 kg of oxygen provided per kW-hr of energy utilized. 24 The most efficient aerator tested that had been installed in dairy lagoons had an aeration efficiency of 0.49 kg-O 2 /kW-hr. These efficiency tests were performed in clea n water and lower aeration efficiencies are expected in liquid manure because of the significant amount of solids that it contains. The yearly energy requirement mechani cally aerated lagoon treating flushed manure from 1,000 milk cows is calculated as follows:

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

Low Efficiency Aerator 1,052 kg-BOD 5 /day ÷ (0.10 kg-O 2 /kW-hr) x (365 day/year) = 3,839,800kW-hr/year

Cost of Electricity for a Mechanically Ae rated Lagoon Treating Manure from 1,000 Milk

cows:

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

Average Cost for electricity = $0.0999/kW-hr

The electricity costs for complete aeration are calculated as follows:

Low Cost Estimate ( High Efficiency Aerator) 564,676 kW-hr/year x $0. 0999/kW-hr = $56,411/year

High Cost Estimate (L ow Efficiency Aerator) 3,839,800 kW-hr/year x $0. 0999/kW-hr = $383,596/year

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

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

24 Aerator Performance for Wastewater Lagoon App lication, September 2007, UC Davis, R.H. Zhang

( http://asae.frymulti.com/a bstract.asp?aid=23832&t=2 )SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-50 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 The annual VOC Emission Reductions for me chanically aerated lagoon treating the manure from 1,000 milk cows are calculated as follows and shown in the table below:

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

Table 19 - VOC Reductions for a Mechanically Aerated Lagoon

Type of Animal # of

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

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

Cost of VOC Em ission Reductions

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

= $96,429/ton of VOC reduced

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

= $655,720/ton of VOC reduced

As shown above, the electricity cost al one for a mechanically aerated lagoon would

cause the cost of the VOC r eductions to be greater than $96, 429/ton. This cost does

not include the additional electric ity cost for nitrification that would naturally occur as the lagoons were aerated or equipmen t costs. Even without these costs, it is clear that the

cost of the VOC emissi on reductions achieved are far beyond BARCT and any applicable RACT requ irements.

b. Aerobic Lagoon Treating Liquid Manure from Swine

The following analyses are based on the treatm ent of manure from 3,000 finishing swine in naturally aerobic lagoons and mechanically aerated lagoons.

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

The following brief analysis will demonstrate that the very lar ge land requirements

needed to treat the manure from s wine facilities subject to this rule in a naturally aerobic lagoon would be beyond what could reasonabl y be required. Therefore, there is no need to perform a detailed analysis that would c onsider all of the additional costs, such as the costs of purchasing additional land, constructi ng and lining the lagoon(s), and additional costs for control of mosquito larvae.

NRCS Practice Standard Code 359 requires that naturally aerobic lagoons be designed

to have a minimum treatment surface area as determined on the basis of daily BOD 5 loading per unit of lagoon surface. The st andard specifies that the maximum loading rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the NRCS Agricultural Waste Managem ent Field Handbook (AWMFH) or the maximumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-51 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 loading rate according to stat e regulatory requirements, whichev er is more stringent. As discussed above, the maximum aerobic lagoon la ding rate for the San Joaquin Valley is

45 - 55 lb-BOD 5 /acre-day. According to Table 4-5 (March 2008) of the NRCS AWMFH, finishing swine produce approximately 2.1 lb-BOD 5 /day per 1,000 lb Animal Unit (AU). It will be assumed that the average weight of fini shing swine is 150 lb (0.15 AU) and that

100% of the manure will be flushed to the lagoon system. The minimum lagoon surface area required for a naturally aerobic lagoon treating manure from 3,000 finishing swine in the San Joaquin Valley c an be calculated as follows:

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

= 945 lb-BOD 5 /day

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum loading rate of 55 lb-BOD 5 /acre-day =

945 lb-BOD 5 /day ÷ 55 lb-BOD 5 /acre-day = 17.2 acres

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum loading rate of 45 lb-BOD 5 /acre-day =

945 lb-BOD 5 /day ÷ 45 lb-BOD 5 /acre-day = 21.0 acres

As shown above the minimum surface ar ea required for a naturally aerobic lagoon treating manure from 3,000 finishing swine in the San Joaquin Valley would range from approximately 17.2 to 21.0 acres. Based on the space requirements alone it is clear that this option is cannot reasonably be r equired and no further analysis is needed.

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

Swine

As discussed above, the very large space requirements for naturally aerobic lagoons cause this option to be infeasible for most confined animal facilities. Mechanically aerating a lagoon can achieve so me of the benefits of a naturally aerobic lagoon without the large space requirements. However, t he costs of energy for complete aeration have also caused this option to be infeasible. The amount of energy required for aeration is

based on the amount of volatile solids excret ed by animals that must be treated; thus, this cost will be directly proportional to the number of animals at a site. The following analysis will determine the cost of emission reductions that can be achieved from a mechanically aerated lagoon treating manur e from 3,000 finishing swine.

Biological Oxygen Demand (BOD 5 )

In order to effectively calcul ate the costs of this control option, the energy requirement for complete aeration must be determined. It should be noted that approximately 1.5 to 2.5 pounds of oxygen is required to di gest 1 pound of Biological Oxygen Demand (BOD 5 ) with additional oxygen required for conversion of ammonia to nitrate (nitrification). It is generally accepted that at leas t twice the BOD should be provided for complete aeration. Additional oxygen would need to be provided for nitrification.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-52 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 The proposed rule specifies that an aer obic lagoon be designed and operated in

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

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

As mentioned above, in a UC Davis study on the performance of mechanical aerators for wastewater lagoons, measur ed aeration efficiencies ranged from 0.10 to 0.68 kg of oxygen provided per kW-hr of energy utilized. These efficiency tests were performed in

clean water and lower aeration efficiencies ar e expected in liquid manure because of the significant amount of solids that it contains. The yearly energy requirement mechanically aerated lagoon treating flushed manure from 3,000 fi nishing swine is

calculated as follows:

High Efficiency Aerator 429 kg-BOD 5 /day ÷ (0.68 kg-O 2 /kW-hr) x (365 day/year) = 230,272 kW-hr/year

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

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

Based on the reference given above, the cost of electricity used for this analysis will be = $0.0999/kW-hr

The electricity costs for complete aeration are calculated as follows:

Low Cost Estimate ( High Efficiency Aerator) 230,272 kW-hr/year x $0. 0999/kW-hr = $23,004/year

High Cost Estimate (L ow Efficiency Aerator) 1,565,850 kW-hr/year x $0. 0999/kW-hr = $156,428/year

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

It will be conservatively assumed that a mec hanically aerated lagoon providing 1 lb of oxygen for every 1 lb of BOD 5 loading will control 90% of the VOC emissions from the lagoon/storage pond. However, as noted above, it is generally accepted that the oxygen provided should be twice the BOD 5 loading rate for complete aeration;SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-53 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 therefore, the actual contro l from providing 1 lb of ox ygen for every 1 lb of BOD 5 loading is probably closer to 50%.

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

below:

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

Table 20 - VOC Reductions for a Mechanically Aerated Lagoon

Type of Animal # of

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

Finishing Swine 3,000 x 0.4 x 90% = 1,080

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from housing barns and 9% of VOC emissions are assumed to be from lagoons 25

Cost of VOC Em ission Reductions

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

= $42,600/ton of VOC reduced

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

= $289,681/ton of VOC reduced

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

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

This cost does not include the additional electr icity cost for nitrification that would naturally occur as the lagoons were aerat ed or equipment costs. Even without these costs, it is clear that t he cost of the VOC emission re ductions achieved are far beyond BARCT and any applicable RACT requirements.

c. Aerobic Lagoon Treating Li quid Manure from Poultry

The following analyses are based on the treatm ent of manure from 400,000 laying hens in naturally aerobic lagoons and mechanically aerated lagoons.

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

The following brief analysis will demonstrate that the very lar ge land requirements

needed to treat the manure from poultry facilities subject to this rule in a naturally aerobic lagoon would be beyond what could reasonably be required. Therefore, there is

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-54 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 no need to perform a detailed analysis that woul d consider all of the additional costs, such as the costs of purchasing additional land, constructing and lining the lagoon(s),

and additional costs for cont rol of mosquito larvae.

NRCS Practice Standard Code 359 requires that naturally aerobic lagoons be designed

to have a minimum treatment surface area as determined on the basis of daily BOD 5 loading per unit of lagoon surface. The st andard specifies that the maximum loading rate of naturally aerobic lagoons shall not exceed the loading rate indicated by the NRCS Agricultural Waste Managem ent Field Handbook (AWMFH) or the maximum loading rate according to stat e regulatory requirements, whichev er is more stringent. As discussed above,, the maximum aerobic lagoon lading rate for the San Joaquin Valley

is 45 - 55 lb-BOD 5 /acre-day. According to Table 4-5 (March 2008) of the NRCS AWMFH, the total manure produced by a laying hens results in 0.011 lb-BOD 5 /day. Assuming that all of the manure will be flushed to t he lagoon system, the minimum lagoon surface area required for a natura lly aerobic lagoon tr eating manure from 400,000 laying hens in the San Joaquin Va lley can be calculated as follows:

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

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum loading rate of 55 lb-BOD 5 /acre-day = 4,400 lb-BOD 5 /day ÷ 55 lb-BOD 5 /acre-day = 80.0 acres

Minimum Surface Area (acres) in areas of the San Joaquin Valley with a maximum loading rate of 45 lb-BOD 5 /acre-day = 4,400 lb-BOD 5 /day ÷ 45 lb-BOD 5 /acre-day = 97.8 acres

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

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

Hens

As discussed above, the very large space requirements for naturally aerobic lagoons cause this option to be infeasible for most confined animal facilities. Mechanically aerating a lagoon can achieve so me of the benefits of a naturally aerobic lagoon without the large space requirements. However, the costs of energy for complete aeration have also caused this option to be infeasible. The amount of energy required for aeration is

based on the amount of volatile solids excret ed by animals that must be treated; thus, this cost will be directly proportional to the number of animals at a site. The following analysis will determine the cost of emission reductions that can be achieved from a mechanically aerated lagoon treating manure from 400,000 laying hens.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-55 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Biological Oxygen Demand (BOD 5 )

In order to effectively calcul ate the costs of this control option, the energy requirement for complete aeration must be determined. It should be noted that approximately 1.5 to 2.5 pounds of oxygen is required to di gest 1 pound of Biological Oxygen Demand (BOD 5 ) with additional oxygen required for conversion of ammonia to nitrate (nitrification). It is generally accepted that at leas t twice the BOD should be provided for complete aeration. Additional oxygen would need to be provided for nitrification.

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

accordance with NRCS Practice Standard Code 359. NRCS Practice Standard Code 359 requires that mechanically aerated lagoons use aeration equipment that provides a minimum of one pound of oxygen for each pound of daily BOD 5 loading. As discussed above, a lagoon handling flushed manure from 400,000 laying hens will have a loading rate of approximately 4,400 lb-BOD 5 /day (1,996 kg-BOD 5 /day).

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

As mentioned above, in a UC Davis study on the performance of mechanical aerators for wastewater lagoons, measur ed aeration efficiencies ranged from 0.10 to 0.68 kg of oxygen provided per kW-hr of energy utilized. These efficiency tests were performed in

clean water and lower aeration efficiencies ar e expected in liquid manure because of the significant amount of solids that it contains. The yearly energy requirement mechanically aerated lagoon treating flushed manure from 400,000 laying hens is

calculated as follows:

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

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

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

Based on the reference given above, the cost of electricity used for this analysis will be = $0.0999/kW-hr

The electricity costs for complete aeration are calculated as follows:

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

High Cost Estimate (L ow Efficiency Aerator) 7,285,400 kW-hr/year x $0. 0999/kW-hr = $727,811/yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-56 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 VOC Emission Reductions from a Mechani cally Aerated Lagoon Treating Manure from 400,000 Laying Hens

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

The annual VOC Emission Reductions for me chanically aerated lagoon treating the manure from 400,000 laying hens are calculat ed as follows and shown in the table

below:

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

Table 21 - VOC Reductions for a Mechanically Aerated Lagoon

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

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

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

9% of the total emission factor

Cost of VOC Em ission Reductions

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

= $264,274/ton of VOC reduced

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

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

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

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

This cost does not include the additional electr icity cost for nitrification that would naturally occur as the lagoons were aerat ed or equipment costs. Even without these costs, it is clear that t he cost of the VOC emission re ductions achieved are far beyond BARCT and any applicable RACT requirements.

E. Covered Lagoon Digester Vented to a Control Device to Treat Liquid Manure Produced by Livestock

The costs associated with treat ing the liquid manure produced by livestock in a covered lagoon digester vented to a control device are analyzed below. This practice is only applicable to manure that is handled in liquid form; theref ore this cost analysis will evaluate this option only for dairy cattle, swine, and layers because these confined animal facilities frequently handle manure in liquid form. EPA’s AgSTAR anaerobicSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-57 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 digester database indicates that covered lagoon anaerobic digesters are currently used at dairy and swine facilities with a greater num ber currently used at dairy facilities. The database does not list any covered lagoon diges ters currently used at poultry or beef

cattle facilities. 26

Description of C ontrol Technology

Covered treatment lagoons are one type of anaerobic digester. As discussed above, an anaerobic digester is an enclosed basin or t ank that is designed to facilitate the decomposition of wastewater by microbes in the absence of oxygen. The process of anaerobic decomposition results in the c onversion of organic compounds in the wastewater into methane (CH 4 ), carbon dioxide (CO 2 ), and water rather than intermediate Volatile Organic Compounds (V OCs). Because the gas produced by the digester is mostly composed of methane, t he main component of natural gas, the gas produced in the digester can be cleaned to remove H 2 S and other impurities and used

as fuel.

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

be 80% of the emissions that would hav e been emitted from the lagoon system.

a. Covered Lagoon Digester for Li quid Manure from Dairy Cows

The costs associated with treat ing the manure excreted by milk cows in a covered lagoon digester vented to a control dev ice are analyzed below. Because it may be possible to generate power from the system to offset some of the costs associated with installation, this potential benefit is incl uded in the analysis below. The following analysis is based on the treatme nt of manure from 1,000 milk cows in a covered lagoon anaerobic digester with pow er generation.

Capital Cost for Installa tion of a Covered Lagoo n Digester for Dairy Cows

The capital cost estimates for installation of a covered lagoon di gester are based on

information from the United States EPA AgSTAR publication “Anaerobic Digestion Capital Costs for Dairy Farms” (May 2010) and the California Energy Commission (CEC) Public Interest Energy Research (PIER) Program Dairy Met hane Digester System Program Evaluation Report (Feb 2009) . The formula in the AgSTAR publication results in a capitol cost of $1,032 per cow for a cover ed lagoon anaerobic digest er treating manure from 1,000 cows. This estimate excludes costs of solids separation after digestion,

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-58 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 hydrogen sulfide removal, and utilit y charges including line upgrades and

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

estimates of a covere d lagoon digester treati ng the manure of 1,000 milk cows is

calculated as follows:

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

The annualized capital cost estimates will be calculated below. The capital cost for the

installation of the covered l agoon digester will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system will be estimated at 10 years though the cover may require replacement during this period.

A 10% interest rate is assumed in t he equation and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

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

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

High Annual Capital Cost Esti mate = [$1,032,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $167,953/year

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

It may be possible to offset some of the inst allation costs of a covered lagoon anaerobic digester with revenue from generation of electr icity. Based on the information given in the CEC PIER Dairy Methane Digester Program Evaluation Report, Table 7 – Actual Generation per Cow Comparisons, California dairies that used a covered lagoon digester to produce electr icity generated between 429.1 a nd 1,031.8 kW-hr/yr per lactating cow with a overall per facility aver age generation rate of 670.3 kW-hr/yr per lactating cow. This aver age annual generation rate is actually higher than all the facilities included in the average except one that had a very high generation rate. In addition, this average may overestimate the per-cow generation potential because the contributions of support stock to the digeste rs were not accounted for. However, for more conservative calculations, this aver age will be used to calculate the potential annual savings in electricity costs. The potential production of electricity from a covered lagoon digester trea ting manure from 1,000 milk cows is calc ulated as follows:

Electrical Production: 670.3 kW-hr/(milk cow-yr) x 1,000 milk cows = 670,300 kWhr/yrSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-59 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Potential Cost Savings from Production of Electricity from a Covered Lagoon Digester Treating Manure from 1,000 Milk Cows:

Based on the reference given above, the value of electricity used for this analysis will be = $0.0999/kW-hr

The potential annual cost savings from el ectricity generation fr om a covered lagoon digester treating manure from 1,000 m ilk cows is calculated as follows:

Potential Annual Cost Savings from Electrical Production: 670,300 kW-hr/yr x $0. 0999/kW-hr = $66,963/yr

Annualized Capital Cost for a Covered Lagoon Digester Treati ng Manure from 1,000 Milk Cows minus Potential Saving s from Generation of Electricity:

Low Annual Capital Cost Estimate mi nus Savings from Po tential Generation = $95,206/yr - $66,963/yr = $28,243/year

High Annual Capital Cost Estimate mi nus Savings from Potential Generation = $167,953/yr - $66,963/yr = $100,990/year

VOC Emission Reductions from a Cover ed Lagoon Anaerobic Digester Treating Manure from 1,000 Milk Cows:

The annual VOC Emission Reductions for cove red lagoon anaerobic digester treating the manure from 1,000 milk cows are calcul ated as follows and shown in the table

below:

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

Table 22 - VOC Reductions for a Covered Lagoon Vented to Control Device

Type of Cow # of

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

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

Cost of VOC Em ission Reductions

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

= $54,313/ton of VOC reduced

High Estimate = ($167,953/year)/[(1,040 lb-VOC/year)(1 ton/2000 lb)]

= $322,987/ton of VOC reduced

As shown above, the capital cost alone for a covered lagoon digester for a dairy would

cause the cost of the VOC reductions to be greater than $54,313 /ton. This cost includes the potential revenue generated by electrical production but does not include the additional maintenance requir ed for the system. Even without these costs, it is clearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-60 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirem ents. This analysis did not consider the additional pollution that would be generated by any combustion equi pment that would utilize the gas, which may offset any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substantial subsidies to offset the extremely high costs of installation.

b. Covered Lagoon Digester for Swine Manure

The costs associated with treat ing the manure excreted by fi nishing swine in a covered lagoon digester vented to a control dev ice are analyzed below. Because it may be possible to generate power from the system to offset some of the costs associated with installation, this potential benefit is incl uded in the analysis below. The following analysis is based on the treatme nt of manure from 5,000 fi nishing swine in a covered lagoon anaerobic digester with power generation.

Capital Cost for Installation of a Covered Lagoon Dig ester for Swine

On an animal weight basis, the capital cost es timates for installation of a covered lagoon digester for finishing swine are assumed to be the same as th e costs for installation of a covered lagoon digester at a da iry. Based on the informatio n given above, the capital cost

of installation of a co vered lagoon digester at a dairy is between $585 and $1,032 per cow. A typical milk cow weighs approximately 1, 400 lb and the average weight of finishing swine is assumed to be 150 lb. The estimated capital cost of a covered lagoon digester for finishing swine is es timated by adjusting by weight as follows:

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

The estimated capital cost of a covered lag oon digester treating the liquid manure from 5,000 finishing swine is calculated as follows:

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

The annualized capital cost estimates will be calculated below. The capital cost for the

installation of the covered l agoon digester will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system will be estimated at 10 years though the cover may require replacement during this period.

A 10% interest rate is assumed in t he equation and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

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

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

High Annual Capital Cost Es timate = [$555,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $90,324/yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-61 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Potential Production of Electricity from a Covered Lagoon Digester Treating Manure from 5,000 Finishing Swine:

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

furnace. Because there is limited info rmation available regar ding production of electricity from digester gas from swine manu re, the potential for production of electricity will be estimated based on the information given above for production of electricity from covered lagoon digesters at dairy facilities. It will be assumed that the potential for production of digester gas and electricity fr om dairy cows and swine will be proportional

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

Waste Characteristics 27 (March 2008), a lactating dairy cow excretes an average of approximately 17 lb/day of volatile solids and finishing swine excr ete approximately 5.4 lb/day of volatile solids per 1,000-lb AU . Based on the information given above, a covered lagoon anaerobic digester at a dairy is estimated to produce 670.3 kW-hr per milk cow per year. Assuming that the amount of electric ity produced is proportional to

the amount of volatile solids sent to the covered lagoon, the potential production of electricity from a covered lagoon anaerobic di gester at a finishing swine facility is

estimated as follows:

(0.15 AU/swine x 5.4 lb VS/AU )/(17 lb-VS/milk cow) x 6 70.3 kW-hr/(milk cow-yr) = 31.9 kW-hr/(swine-yr)

The potential product ion of electricity from a covered l agoon digester treati ng manure from 5,000 finishing swine is ca lculated as follows:

Electrical Production: 31.9 kW-hr/(swi ne-yr) x 5,000 swine = 159,500 kW-hr/yr

Potential Cost Savings from Production of Electricity from a Covered Lagoon Digester Treating Manure fr om 5,000 Swine:

Based on the reference given above, the value of electricity used for this analysis will be = $0.0999/kW-hr

The potential annual cost savings from el ectricity generation fr om a covered lagoon digester treating manure from 5,000 swine is calculated as follows:

159,500 kW-hr/yr x $0.0999/ kW-hr = $15,934/yr

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-62 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 Annualized Capital Cost for a Covered Lagoo n Digester Treating Manure from 5,000 Swine minus Potential Savings from Generation of Electricity:

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

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

High Annual Capital Cost Estimate mi nus Savings from Potential Generation = $90,324/yr - $15,934/yr = $74,390/year

VOC Emission Reductions from a Cover ed Lagoon Anaerobic Digester Treating Manure from 5,000 Finishing Swine:

The annual VOC Emission Reductions for cove red lagoon anaerobic digester treating the manure from 5,000 swine ar e calculated as follows and shown in the table below:

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

Table 23 - VOC Reductions for a Covered Lagoon Vented to Control Device

Animal # of

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

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

* Based on a study by Rumsey, 91% of swine facility VOC emissions are assumed to be from housing barns and 9% of VOC emissions are assumed to be from lagoons 28

Cost of VOC Em ission Reductions

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

= $44,164/ton of VOC reduced

High Estimate = ($74,390/year)/[( 1,600 lb-VOC/year)(1 ton/2000 lb)]

= $92,988/ton of VOC reduced

As shown above, the capital cost alone for a covered lagoon digester for swine would

cause the cost of the VOC reductions to be greater than $44,164 /ton. This cost includes the potential revenue generated by electrical production but does not include the additional maintenance requir ed for the system. Even without these costs, it is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirem ents. This analysis did not consider the additional pollution that would be generated by any combustion equi pment that would utilize the gas, which may offset any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substantial subsidies to offset the extremely high costs of installation.

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

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-63 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 c. Covered Lagoon Digester for Poultry Manure

Although treating the manure excreted by laying hens in a covered lagoon digester appears to be very uncommon, the costs associated with treating the manure excreted by laying hens in a covered lagoon digeste r are analyzed below. Because it may be possible to generate power from the system to offset some of the costs associated with installation, this potential benefit is incl uded in the analysis below. The following analysis is based on the treat ment of manure from 500,000 laying hens in a covered lagoon anaerobic digester with power generation.

Capital Cost for Installation of a Covered Lagoon Dig ester for Poultry

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

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

The estimated capital cost of a covered lag oon digester treating the liquid manure from 500,000 laying hens is calculated as follows:

Low capital cost estimate: 500, 000 birds x $1.67/bird = $835,000 High capital cost estimate: 500,000 birds x $2.95/bird = $1,475,000

The annualized capital cost estimates will be calculated below. The capital cost for the

installation of the covered l agoon digester will be spread over the expected life of the system using the capital recovery equation. The expected life of the entire system will be estimated at 10 years though the cover may require replacement during this period.

A 10% interest rate is assumed in the equation and the assumption will be made that the equipment has no salvage value at the end of the ten-year cycle.

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

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

High Annual Capital Cost Esti mate = [$1,475,000 x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $240,049/year

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

It may be possible to offset some of the in stallation costs of a covered lagoon anaerobic digester with revenue from generation of electr icity. Only a very small number ofSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-64 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 digesters have been installed at poultry facilities and there was no information available on any covered lagoon digesters at poultry facilities. 29 Because there is limited information available regarding production of el ectricity from digester gas from poultry manure, the potential for production of el ectricity will be estimated based on the information given above for production of elec tricity from covered lagoon digesters at dairy facilities. It will be assu med that the potentia l for production of digester gas and electricity from dairy cows and poultry will be proportional to the amount of volatile

solids excreted in the manure. Accordi ng to the USDA NRCS Agricultural Waste Management Field Handbook (AWMFH), Chapter 4 - Agricultural Waste Characteristics (March 2008), a lactating dairy cow excretes an average of approximately 17 lb/day of volatile solids and a laying hen excretes approx imately 0.036 lb/day of volatile solids. Based on the information given above, a cove red lagoon anaerobic digester at a dairy is estimated to produce 670.3 kW-hr per milk cow per year. Assuming t hat the amount of electricity produced is proportiona l to the amount of volatile solids sent to the covered lagoon, the potential production of electric ity from a covered lagoon anaerobic digester at a poultry facility is estimated as follows:

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

The potential product ion of electricity from a covered l agoon digester treati ng manure from 500,000 laying hens is calculated as follows:

Electrical Production: 1.42 kW-hr/(bir d-yr) x 500,000 birds = 710,000 kW-hr/yr

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

Based on the reference given above, the value of electricity used for this analysis will be = $0.0999/kW-hr

The potential annual cost savings from el ectricity generation fr om a covered lagoon digester treating manure from 500,000 la ying hens is calculated as follows:

710,000 kW-hr/yr x $0.0999/ kW-hr = $70,929/yr

Annualized Capital Cost for a Covered Lagoo n Digester Treating Manure from 500,000 Birds minus Potential Savings fr om Generation of Electricity:

Low Annual Capital Cost Estimate mi nus Savings from Po tential Generation = $135,892/yr

- $70,929/yr = $64,963/year

High Annual Capital Cost Estimate mi nus Savings from Potential Generation = $240,049/yr - $70,929/yr = $169,120/year

29 The US EPA AgSTAR Program Guide to Anaerobic Digesters – Anaerobic Dige ster Database (updated April 2010) lists only three poultry digesters, http://www.epa.gov/agstar/operational.htmlSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

E-65 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4570 VOC Emission Reductions from a Cover ed Lagoon Anaerobic Digester Treating Manure from 500,000 Birds:

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

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

Table 24 - VOC Reductions for a Covered Lagoon Vented to Control Device

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

Laying Hens 500,000 x 0.00225 x 80% = 900

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

9% of the total emission factor

Cost of VOC Em ission Reductions

Low Estimate = ($64,963/ year)/[(900 lb-VOC/year)(1 ton/2000 lb)]

= $144,362/ton of VOC reduced

High Estimate = ( $169,120/year)/[( 900 lb-VOC/year)(1 ton/2000 lb)]

= $375,822/ton of VOC reduced

As shown above, the capital cost alone for a covered lagoon digester for poultry would

cause the cost of the VOC reductions to be greater than $144,362 /ton. This cost includes the potential revenue generated by electrical production but does not include the additional maintenance requir ed for the system. Even without these costs, it is clear that the cost of the VOC emission reductions achieved are far beyond BARCT and any applicable RACT requirem ents. This analysis did not co nsider the additional pollution that would be generated by any combustion equi pment that would utilize the gas, which may offset any reductions in VOCs. In general, this option would not likely be considered economically feasible for any facility without the project receiving substantial

subsidies to offset the extrem ely high costs of installation.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Class Two Measures Anal ysis for Rule 4570 October 21, 2010

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