The Next Challenge: New Air Quality Rules

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The Next Challenge New Air Quality Rules

• Saqib Mukhtar

Associate Prof. and Extension Agricultural
Engineer
Texas AM University, College Station
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Content

• History of National Ambient Air Quality Standards
• Air Quality Regulated at National and State
  Levels
• CERCLA/EPCRA Reporting
• The New EPA AFO Consent Agreement
• Whats up with California
• The Ammonia Challenge

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Federal Legislation and Regulation

• Air Pollution Control Act of 1955
• Provided fund for research and technical
  assistance NOT control activities.
• Clean Air Act (CAA) of 1963
• Federal Authority to address interstate air
  pollution problems.
• CAA Amendments of 1970 and National Environmental
  Protection Policy Act (provided Authority to
  create the EPA)

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• The CAAA of 1977 (PSD-prevention of significant
  deterioration of air quality in clean regions)
• The CAAA of 1990 (Over 750 pages and 11 titles)
• Federal Standards Established for 6 Criteria
  Pollutants
• List of Air Toxics (Hazardous Air Pollutants 188
  HAPs in the original list. H2S and NH3 are NOT
  included)

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National Ambient Air Quality Standards (NAAQS)
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EPAs Definition of Primary and Secondary Standards

• Primary These Standards Set limits to protect
  public health, including the health of
  "sensitive" populations such as asthmatics,
  children, and the elderly.
• Secondary standards set limits to protect public
  welfare, including protection against decreased
  visibility, damage to animals, crops, vegetation,
  and buildings.

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Emissions, Gas/Dust
Sources
Dispersion
Property Line Concentration
Investigations are mostly complaint driven (dust
or odors)
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Odors

• No Federal Standards
• Regulated Under Nuisance Laws (any condition that
  interferes with the normal use and enjoyment of
  property )
• A 1610 British Court Ruling Hog producer Must
  Remove his pigs because their presence infringed
  on his neighbors right to wholesome air.
• (Source National Hog Farmer. Accessed on the
  web, Jan 31, 2005. http//nationalhogfarmer.com/ma
  g/farming_states_regulate_odors/)

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Some States Directly Regulate Odors

• State Regulators use olfactometry (human panels)
  or scentometers (Odor Instrument) to measure
  odors.

Olfactometry
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Colorado Example

• Scentometer measurements greater than 7 DT
  (dilutions to threshold Number of clean air
  dilutions needed for odorous air sample so that
  the odor is undetectable ) at the property line
  mean odor violation.

Scentometer
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Feedlot PM Issues
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Not common to Dairies
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CERCLA and EPCRA

• Comprehensive Environmental Response,
  Compensation and Liability Act (CERCLA section
  103)
• Emergency Planning and Community Right-to-Know
  Act (EPCRA section 304)
• Both acts require reporting of NH3 and H2S (plus
  numerous other hazardous substances) emissions
  from sources including AFOs
• One hundred pounds of Either Pollutants released
  per 24 hours must be reported.
• Idaho Conservation League forced Desert Rose
  Farms dairy to report NH3 emissions and They did
  (Assoc. Press, Jan., 21, 2004)

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NH3 Emission Rates (45 days/Flock)
Ken Casey et al., 2005. Univ. of Kentucky
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EPA Animal Feeding Operations Consent Agreement
and Final Order, Jan 21, 2005.

• Nationwide Monitoring Program
• Twenty Eight farms (Swine, poultry and dairy)
  will be selected for monitoring of pollutants
  that include PM (TSP, PM10 and PM2.5), H2S, VOCs,
  NH3 and NOx.
• Monitoring will occur at the selected lagoons and
  barns for approximately 24 months.

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Key Provisions in the Air Quality Compliance
Agreement

• Participating AFOs will be required to
• Pay a civil penalty, ranging from 200 to
  100,000, depending on the size and number of
  AFOs.
• Pay nearly 2,500 into a fund for emissions
  monitoring program.
• Apply for air permits and comply with permit
  conditions.
• Install Best Available Control Technology (BACT)
  or control technology meeting the Lowest
  Achievable Emission Rate (LAER) on all sources
  that exceed the major source threshold for
  their area.
• Report releases of NH3 and H2S per CERCLA/EPCRA

http//www.epa.gov/compliance/resources/agreements
/caa/cafo-agr-0501.html, accessed Jan 31, 2005.
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• What EPA Offers In Return
• A covenant not to sue for past violations of
• Permitting requirements by federal and state
  clean air acts to control emissions of NOx, H2S,
  VOCs, or PM from AFO confinement structures and
  lagoons.
• CERCLA /EPCRA reporting of NH3 and H2S from
  confinement structures and lagoons.

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• Conditions and limits of the covenant not to sue
  
• Exclude AFOs that present an imminent and
  substantial endangerment to human health.
• The covenant terminates shortly after the
  monitoring program.
• Only cover violations from agricultural livestock
  and waste.
• The covenant does not cover emissions from other
  operations on the farm (generators and
  bio-digesters etc.)
• Does not affect permits required for new
  construction or modification of existing AFOs.

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Conditions and Limits.

• The covenant not to sue will be nullified if AFOs
  fail to comply with state nuisance final orders
  relating to air emissions.
• AFOs that are subject to federal or state Clean
  Air Act, CERCLA /EPCRA enforcement actions may
  not be eligible to enter into the Agreement.
• EPA will continue to prosecute cases that may
  present an imminent and substantial endangerment
  to human health.

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• Additional Protections and Benefits
• AFOs that install waste-to-energy systems in
  compliance with all applicable permitting and
  control requirements will get additional time
  (180 days) to apply for air permits for their
  emissions from agricultural livestock and
  livestock waste.
• The Agreement will complement ongoing state and
  local efforts to promote research into AFO air
  emissions and to improve air quality.

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• Whats Up With California?
• Ozone and PM-10 Non-attainment
• Large CAF definition for VOCs Emissions
• Best Available Control Technology implementation

Source Dr. Frank Mitloehner (UC Davis)
Presentation available at the California Air
Resources Board webpage. http//www.arb.ca.gov/ag/
agadvisory/lersymp.htm, Accessed Jan. 30, 2005.
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Severe Serious Moderate
Nov., 2004
http//www.epa.gov/airprogm/oar/oaqps/greenbk/naa8
hclass.html, Accessed Jan 31, 2005.
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Nov., 2004
http//www.epa.gov/airprogm/oar/oaqps/greenbk/mapp
m10.html, Accessed Jan 31, 2005.
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(No Transcript)
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California Senate Bill 700 Requires Volatile
Organic Compounds (VOCs) Reductions and
definition of a Large Confined Animal Facility
(CAF)

• The Large CAF for VOCs must be defined by July 1,
  2005
• VOC means any compound of carbon, excluding
  carbon monoxide, carbon dioxide, carbonic acid,
  metallic carbides or carbonates, and ammonium
  carbonate, which participates in atmospheric
  photochemical reactions.

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California Air Resources Boards Reactive Organic
Gases (ROG) Emission Factor Development. How it
all started?

• 1938 Actual measurement of methane (CH4 )
  emission from cattle was conducted (Ritzman and
  Benedict, 1938)
• Result 200 g CH4 emitted in 24 hrs
• (From observation of 10 adult cows.)
• 200g/24 hr(lb/454 g)(24hr/d)365d/yr
• Equivalent to 160 lb CH4/HD/year

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What happened in 1978?

• The methane number incorrectly began being
  reported as Total Organic Gases (TOG) instead of
  just purely methane
• Thus, 160 lbs CH4/HD/year began being reported as
  160 lbs TOG/HD/year.

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Conclusion of Livestock TOG Speciation Study?

• 8 of TOG component is reactive ROG)
• Ethyl alcohol (2)
• Isopropyl alcohol (2)
• Propyl acetate (2)
• Ethyl amine (1)
• Trimethyl amine (1)
• 92 considered non-reactive

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Emission Factor (EF) Calculation

• Current ROG EF is
• 160 0.08 12.8 lbs ROG/HD/year
• EF is conservative due to error
• San Joaquin Valley Air Pollution District has
  used this number to estimate which dairies are
  above the 12.5 ton per year ROG threshold.
• This number (12.8 lb) challenged by the dairy
  industry. Agreement to present a science-based
  EF is in place.

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New Studies to Determine VOCs from Dairies in CA.
Source Dr. Frank Mitloehner (UC Davis)
Presentation available at the California Air
Resources Board webpage. http//www.arb.ca.gov/ag/
agadvisory/lersymp.htm, Accessed Jan. 30, 2005.
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Cow Study Yields Surprises About Source, Amount
of Dairy Air Pollution Preliminary findings
indicate that cows and their waste produce about
6.4 pounds of volatile organic compounds (VOCs)
per year. Furthermore, Mitloehner found that
about 2.5 pounds of the total 6.4 pounds, or only
about 40 percent, comes from excreta.
UC Davis News and Information, January 26, 2005.
http//www.news.ucdavis.edu/search/printable_news.
lasso?id7263tablenews Accessed, Jan 31, 2005.
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Air Quality Challenges (problems)
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Why Ammonia?

• AFOs and Fertilizer applications contribute large
  amount of NH3 to atmosphere.
• NH3 is a precursor to PM2.5
• Need to quantify NH3 emissions from low level
  area source (LLAS).
• CERCLA/EPCRA reporting requirements.
• NH3 emissions may be regulated in future.

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Study Objective

• Estimate real-time NH3 emissions from Low Level
  Area Sources (LLAS) using a flux chamber
  protocol.

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Ammonia Measurement Equipment
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Flux Chamber
Sampling Equipment
Sampling port
T probe
Vent port
Hemispherical dome
Dome Height16.5cm
Sweep air inlet
Rubber Gasket
Cylinder Height22.9cm
Cylindrical Skirt
D49.5cm
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Flux Chamber Analyzer Setup
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Freestall Dairy LLAS
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Open Lot Sampling
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Freestall Sampling
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Lagoon Sampling
Pontoon System
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Seasonal NH3 Emission Rates (ER), Freestall dairy
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Openlot Dairy
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NH3 ER, Openlot Dairy, Summer-2004
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• Freestall Dairy
• Winter Compost and free-stall contributed
  77 to overall NH3 emission.
• Summer Two lagoons contributed 65 to
  overall NH3 emission.
• Openlot Dairy
• Summer Two Lagoons and Openlots
  contributed 97 to the Overall NH3
  emission.

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Conclusions

• NH3 emissions may vary due to
• 1- Seasonal variations in temperatures,
• 2- Dairy waste loading rates,
• 3- Moisture and Biological activity of LLAS.
• Long-term studies needed to examine impact of
  BMPs on reducing NH3 emissions from AFOs.

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Questions?