Ammonia Regulation Are We Ready NADP Ammonia Workshop

Ammonia Regulation – Are We Ready? NADP Ammonia Workshop Washington, DC October 23, 2003 Dave Mitchell Planning Manager San Joaquin Valley APCD 1

California Air Basins • California has 15 air basins • SJV Air District largest in state • 25, 000 sq. mi. • 250 mi by 80 mi • 3. 3 million people • Nation’s no. 1 ag region 2

Importance of Agriculture to the San Joaquin Valley • 250 commodities • $13 billion/year • 15% US veg prod. • 38% US fruit prod. • No. 1 Dairy County in US – Tulare, No. 2 Merced, No. 3 Stanislaus 3

San Joaquin Valley Air Quality Status Severe Nonattainment for federal 1 hour ozone, Serious for 24 -hour PM 10, and annual PM 10 standards n Expect to be designated nonattainment for the federal 8 -hour ozone and PM 2. 5 standards n 4

Regulatory Pressures n n 5 2003 PM 10 Plan commitment to control ammonia if research indicates it would expedite attainment PM 2. 5 attainment plan due in late 2007 State mandated CAFO air regulations deadline for District adoption July 2005 (PM 10 and precursors) California Environmental Quality Act Environmental Impact Reports

What do elected boards need to help make decisions? n n n 6 Assurance that “sound science” was used to identify the cause of the problem Evidence that the proposed solution will be effective Knowledge that stakeholder concerns, including scientific ones, have been addressed

What do Board members dislike about science in the regulatory process? n n n 7 The time required to complete research – results too late Making decisions when substantial uncertainty remains Worst case – faulty conclusions result in adopting costly regulation that provides little or no benefits to public health (or the opposite)

Extent of Ammonium Nitrate and Sulfate Jan 01 Episode Nitrate Sulfate Bakersfield 96 µg/m 3 7 µg/m 3 n Hanford 94 7 n Fresno 74 4 n Modesto 84 7 n Nitrate high throughout the basin in urban and rural areas n 8

Winter PM 10 Season Valley Fog Conditions • Strong, low inversions for long periods • Light winds • Low temps • Woodsmoke, ammonia and NOx abundant • Fugitive dust if no precipitation 9

SJVAB Ammonia Inventory n n n 1 0 Dairy Poultry Beef Composting Fertilizers Soil – Natural and Ag Other Livestock Domestic Motor Vehicles Landfill Other o Total 240 t/d 46 t/d 40 t/d 15 t/d 14 t/d 9 t/d 5 t/d 3 t/d 6 t/d 397 t/d

Dairy Ammonia Sources Manure Management Anaerobic lagoon 1 1 Cow feeding and collection areas

CAFO Emission Issues n Need process based emission factors o Identify processes and conditions allowing ammonia to volatize o Identify environmental factors and management practices that cause emissions to vary Cross media impacts o Ensure measures that reduce air emissions do not increase water contamination o n 1 2 Identify each emission point

CAFO Control Issues n n n 1 3 Percentage of ammonia volatized immediately after urine hits the ground Does limiting nitrogen content of feed impact animal productivity? Keeping ammonia in solution during cleanup of wet manure Lagoon water p. H control – does this just delay release? Is indoor composting of manure really feasible on a large scale?

Aerosol Modeling Issues n n 1 4 Attempted UAM-Aero modeling for 2003 PM 10 Plan Calif. Regional Particulate Air Quality Study (CRPAQS) data not available for modeling Used IMS-95 dataset with much lower PM 10 and nitrate episodes than 2001 Results were mixed

PM on January 05, 1996 1 5

PM on January 06, 1996 1 6

Bakersfield – Van Horn School 1 7

Kern Wildlife Refuge 1 8

Fresno – Einstein Park 1 9

Southwest of Chowchilla 2 0

Findings based on UAMAero n n n 2 1 O 3 performance satisfactory except for Bakersfield where we see an “O 3 hole” Nitrate performance satisfactory Over-prediction of sulfate and carbonaceous PM in urban areas but satisfactory in rural areas Severe under prediction of HNO 3 Performance for NH 3, NO, and NO 2 mixed

Sensitivity of Nitrate Jan. 05, 1996 2 2

Sensitivity of Nitrate Jan. 06, 1996 2 3

Sensitivity Scenarios for Nitrate 2 4

2 5

2 6

2 7

Major Features of Carrying Capacity Diagrams n Up to 50% precursor reductions o Rural sites are NOx limited o Response is nearly linear Beyond 50% precursor reductions o Sites behave as expected o Response not linear o n 2 8 Least responsive to VOC reductions

Is NH 3 limitation at Bakersfield real? n n 2 9 Emissions o Significant amount of NOx emissions in area o No large sources of NH 3 (inventory not verified) Measurements 3 o 0. 25 to 0. 3 mole/m of excess NH 3

Questions Raised by the Results n n n 3 0 Is the ammonia inventory understating emissions from a source in areas showing a deficiency? Is the model inaccurately depicting the atmospheric chemistry? Do both the inventory and model have critical flaws? What causes the non-linearity of NOx to nitrate formation? What happens at 100 µg/m 3 nitrate?

Resolution n n n 3 1 Ammonia measurements most convincing evidence of excess Weight of evidence supports NOx only control strategy Used 1. 5/1 NOx/nitrate ratio in rollback CRPAQS final reports due in 2005 Ammonia inventory improvements for CAFOs underway 2005 PM 10 Plan update, PM 2. 5 and regional haze plans will revisit this issue Is the San Joaquin Valley ready for ammonia control? - no

Contact Information o o o 3 2 Dave Mitchell SJVAPCD 1990 E. Gettysburg Ave. Fresno, CA 93726 559 -230 -5800 Email dave. mitchell@valleyair. org San Joaquin Valley Air Pollution Control District