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

2. 2 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

3. 3 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

4. 4 San Joaquin Valley Air Quality Status Severe Nonattainment for federal 1- hour ozone, Serious for 24-hour PM10, and annual PM10 standards Expect to be designated nonattainment for the federal 8-hour ozone and PM2.5 standards

5. 5 Regulatory Pressures 2003 PM10 Plan commitment to control ammonia if research indicates it would expedite attainment PM2.5 attainment plan due in late 2007 State mandated CAFO air regulations deadline for District adoption July 2005 (PM10 and precursors) California Environmental Quality Act Environmental Impact Reports

6. 6 What do elected boards need to help make decisions? 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

7. 7 What do Board members dislike about science in the regulatory process? 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)

8. 8 Extent of Ammonium Nitrate and Sulfate Jan 01 Episode Bakersfield96 µg/m 3 7 µg/m 3 Hanford94 7 Fresno74 4 Modesto84 7 Nitrate high throughout the basin in urban and rural areas NitrateSulfate

9. 9 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

10. 1010 SJVAB Ammonia Inventory Dairy240 t/d Poultry46 t/d Beef40 t/d Composting15 t/d Fertilizers15 t/d Soil – Natural and Ag14 t/d Other Livestock9 t/d Domestic5 t/d Motor Vehicles5 t/d Landfill3 t/d Other6 t/d  Total397 t/d

11. 1 Dairy Ammonia Sources Cow feeding and collection areas Anaerobic lagoon Manure Management

12. 1212 CAFO Emission Issues Need process based emission factors  Identify each emission point  Identify processes and conditions allowing ammonia to volatize  Identify environmental factors and management practices that cause emissions to vary Cross media impacts  Ensure measures that reduce air emissions do not increase water contamination

13. 1313 CAFO Control Issues 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 pH control – does this just delay release? Is indoor composting of manure really feasible on a large scale?

14. 1414 Aerosol Modeling Issues Attempted UAM-Aero modeling for 2003 PM10 Plan Calif. Regional Particulate Air Quality Study (CRPAQS) data not available for modeling Used IMS-95 dataset with much lower PM10 and nitrate episodes than 2001 Results were mixed

15. 1515 PM on January 05, 1996

16. 1616 PM on January 06, 1996

17. 1717 Bakersfield – Van Horn School

18. 1818 Kern Wildlife Refuge

19. 1919 Fresno – Einstein Park

20. 2020 Southwest of Chowchilla

21. 2121 Findings based on UAM- Aero 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

22. 2 Sensitivity of Nitrate Jan. 05, 1996

23. 2323 Sensitivity of Nitrate Jan. 06, 1996

24. 2424 Sensitivity Scenarios for Nitrate

25. 2525

26. 2626

27. 2727

28. 2828 Major Features of Carrying Capacity Diagrams Up to 50% precursor reductions  Least responsive to VOC reductions  Rural sites are NO x limited  Response is nearly linear Beyond 50% precursor reductions  Sites behave as expected  Response not linear

29. 2929 Is NH 3 limitation at Bakersfield real? Emissions  Significant amount of NO x emissions in area  No large sources of NH 3 (inventory not verified) Measurements  0.25 to 0.3  mole/m 3 of excess NH 3

30. 3030 Questions Raised by the Results 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?

31. 3131 Resolution 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 PM10 Plan update, PM2.5 and regional haze plans will revisit this issue Is the San Joaquin Valley ready for ammonia control? - no

32. 3232 Contact Information  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