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The Next Challenge: New Air Quality Rules

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Title: The Next Challenge: New Air Quality Rules


1
The Next Challenge New Air Quality Rules
  • Saqib Mukhtar

Associate Prof. and Extension Agricultural
Engineer
Texas AM University, College Station
2
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

3
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)

4
  • 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)

5
National Ambient Air Quality Standards (NAAQS)
6
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.

7
Emissions, Gas/Dust
Sources
Dispersion
Property Line Concentration
Investigations are mostly complaint driven (dust
or odors)
8
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/)

9
Some States Directly Regulate Odors
  • State Regulators use olfactometry (human panels)
    or scentometers (Odor Instrument) to measure
    odors.

Olfactometry
10
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
11
Feedlot PM Issues
12
Not common to Dairies
13
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)

14
NH3 Emission Rates (45 days/Flock)
Ken Casey et al., 2005. Univ. of Kentucky
15
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.

16
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.
17
  • 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.

18
  • 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.

19
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.

20
  • 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.

21
  • 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.
22
Severe Serious Moderate
Nov., 2004
http//www.epa.gov/airprogm/oar/oaqps/greenbk/naa8
hclass.html, Accessed Jan 31, 2005.
23
Nov., 2004
http//www.epa.gov/airprogm/oar/oaqps/greenbk/mapp
m10.html, Accessed Jan 31, 2005.
24
(No Transcript)
25
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.

26
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

27
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.

28
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

29
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.

30
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.
31
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.
32
Air Quality Challenges (problems)
33
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.

34
Study Objective
  • Estimate real-time NH3 emissions from Low Level
    Area Sources (LLAS) using a flux chamber
    protocol.

35
Ammonia Measurement Equipment
36
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
37
Flux Chamber Analyzer Setup
38
Freestall Dairy LLAS
39
Open Lot Sampling
40
Freestall Sampling
41
Lagoon Sampling
Pontoon System
42
Seasonal NH3 Emission Rates (ER), Freestall dairy
43
Openlot Dairy
44
NH3 ER, Openlot Dairy, Summer-2004
45
  • 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.

46
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.

47
Questions?
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