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Ammonia Regulation –Are We Ready?

NADP Ammonia Workshop Washington, DCOctober 23, 2003

Dave MitchellPlanning Manager

San Joaquin Valley APCD

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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

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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

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San Joaquin Valley Air Quality Statusn Severe Nonattainment for federal 1-

hour ozone, Serious for 24-hour PM10, and annual PM10 standards

n Expect to be designated nonattainment for the federal 8-hour ozone and PM2.5 standards

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Regulatory Pressuresn 2003 PM10 Plan commitment to control

ammonia if research indicates it would expedite attainment

n PM2.5 attainment plan due in late 2007

n State mandated CAFO air regulations deadline for District adoption July 2005 (PM10 and precursors)

n California Environmental Quality Act Environmental Impact Reports

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What do elected boards need to help make decisions?

n Assurance that “sound science” was used to identify the cause of the problem

n Evidence that the proposed solution will be effective

n Knowledge that stakeholder concerns, including scientific ones, have been addressed

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What do Board members dislike about science in the regulatory process?n The time required to complete

research – results too laten Making decisions when substantial

uncertainty remainsn Worst case – faulty conclusions result

in adopting costly regulation that provides little or no benefits to public health (or the opposite)

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Extent of Ammonium Nitrate and Sulfate Jan 01 Episode

n Bakersfield 96 µg/m3 7 µg/m3

n Hanford 94 7n Fresno 74 4n Modesto 84 7n Nitrate high throughout the basin in

urban and rural areas

Nitrate Sulfate

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Winter PM10 Season

Valley Fog Conditions • Strong, low inversions for long periods

• Light winds

• Low temps

• Woodsmoke, ammonia and NOx abundant

• Fugitive dust if no precipitation

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SJVAB Ammonia Inventoryn Dairy 240 t/dn Poultry 46 t/dn Beef 40 t/dn Composting 15 t/dn Fertilizers 15 t/dn Soil – Natural and Ag 14 t/dn Other Livestock 9 t/dn Domestic 5 t/dn Motor Vehicles 5 t/dn Landfill 3 t/dn Other 6 t/d

o Total 397 t/d

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Dairy Ammonia Sources

Cow feeding and collection areas

Anaerobic lagoon

Manure Management

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CAFO Emission Issuesn Need process based emission factors

o Identify each emission point

o Identify processes and conditions allowing ammonia to volatize

o Identify environmental factors and management practices that cause emissions to vary

n Cross media impacts

o Ensure measures that reduce air emissions do not increase water contamination

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CAFO Control Issuesn Percentage of ammonia volatized

immediately after urine hits the groundn Does limiting nitrogen content of feed

impact animal productivity?

n Keeping ammonia in solution during cleanup of wet manure

n Lagoon water pH control – does this just delay release?

n Is indoor composting of manure really feasible on a large scale?

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Aerosol Modeling Issues

n Attempted UAM-Aero modeling for 2003 PM10 Plan

n Calif. Regional Particulate Air Quality Study (CRPAQS) data not available for modeling

n Used IMS-95 dataset with much lower PM10 and nitrate episodes than 2001

n Results were mixed

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PM on January 05, 1996

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PM on January 06, 1996

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Bakersfield – Van Horn School

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Kern Wildlife Refuge

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Fresno – Einstein Park

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Southwest of Chowchilla

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Findings based on UAM-Aeron O3 performance satisfactory except for

Bakersfield where we see an “O3 hole”n Nitrate performance satisfactory

n Over-prediction of sulfate and carbonaceous PM in urban areas but satisfactory in rural areas

n Severe under prediction of HNO3

n Performance for NH3, NO, and NO2 mixed

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Sensitivity of NitrateJan. 05, 1996

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Sensitivity of NitrateJan. 06, 1996

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Sensitivity Scenarios for Nitrate

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Major Features of Carrying Capacity Diagramsn Up to 50% precursor reductions

o Least responsive to VOC reductionso Rural sites are NOx limited

o Response is nearly linearn Beyond 50% precursor reductions

o Sites behave as expectedo Response not linear

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Is NH3 limitation at Bakersfield real?n Emissions

o Significant amount of NOxemissions in area

o No large sources of NH3(inventory not verified)

n Measurementso 0.25 to 0.3 µmole/m3 of excess

NH3

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Questions Raised by the Resultsn Is the ammonia inventory understating

emissions from a source in areas showing a deficiency?

n Is the model inaccurately depicting the atmospheric chemistry?

n Do both the inventory and model have critical flaws?

n What causes the non-linearity of NOx to nitrate formation?

n What happens at 100 µg/m3 nitrate?

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Resolutionn Ammonia measurements most convincing

evidence of excessn Weight of evidence supports NOx only

control strategyn Used 1.5/1 NOx/nitrate ratio in rollbackn CRPAQS final reports due in 2005n Ammonia inventory improvements for

CAFOs underwayn 2005 PM10 Plan update, PM2.5 and regional

haze plans will revisit this issuen Is the San Joaquin Valley ready for

ammonia control? - no

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Contact Information

o Dave MitchellSJVAPCD1990 E. Gettysburg Ave.Fresno, CA 93726

o 559-230-5800

o Email dave.mitchell@valleyair.org

San Joaquin Valley Air Pollution Control DistrictSan Joaquin Valley Air Pollution Control District