SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT OFFICE MEMO

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1 DATE: April 12, 2006 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT OFFICE MEMO TO: FROM: SUBJECT: Permit Services Staff Sheraz Gill Dairy and Feedlot PM 10 Emissions Factors Purpose: The purpose of this memo is to outline the PM 10 emission factors from dairy and feedlot operations, to be used for permitting purposes. These factors are subject to change. Data: Five sources were evaluated in the determination of a feedlot and dairy emission factor. These sources and their emission factors are shown in the table below. Each source is also analyzed in detail below with a summary of the methodology of arriving at the final emission factors. Source Year Location EF (lbs-pm 10 /hd-yr) 1 USDA Report UC Davis April 2001 Tulare and Kern Feedlot Cattle Dairy Cows ASAE Texas Jul 28 Jul Relatively dry A&M Univ 1 31, 2002 West Texas dairy Milk cows ASAE Texas A&M Univ 2 July Relatively dry West Texas dairy Box (total herd) 2.17 ISC Total herd 2.39 ISC Freestalls with exercise pens ASAE Texas A&M Phone Conv w/ Barry Goodrich 5 ASAE Texas A&M Univ ARB Livestock Emissions inventory Summary of 2002 and 2003 study August 1-4, Relatively dry West Texas dairy ISC Open Corrals 5.46 Freestall 3.77 Open Corrals 7.1 Texas Cattle 2004 Feed yard ISC Total Herd 2.4 May 2004 All Dairy Cattle 2.46 (ASAE 2002) Feedlot Cattle (USDA 2001) 1 Shade structures were provided for cows in the open corrals during this study 2 There were no shade structures in the open corrals during this study 1

2 Analysis: 1. This study was performed by UC Davis for USDA and involved extensive testing for many agricultural sources, including field crops, orchard crops, and livestock. The dairy and feedlot studies were performed in Kern and Tulare County from using a series of models (Block Profile Model, Logarithmic Profile Model, and Box Model). The studies resulted in an emission factor of lbs-hd-yr for feedlot cattle and lbs/hd-yr for dairy cattle. 2. This study was performed by Texas A&M University in 2002 at a Texas dairy with the majority of milk cows housed in freestalls with exercise pens and the remaining milk cows housed in open corrals. No support stock was present during the testing. A Box Model approach was used to estimate the emissions from this study. The emission factor reported did not differentiate the emissions for the type of housing (freestall or open corral). The daily average was reported as 1.6 lbs/hd-yr. During the sampling period, the dairy was harvesting silage. This process involves cutting and chopping the silage in the field and transporting it to the storage pits with large trucks. The trucks were traveling on unpaved roads, which generated significant emissions of PM. Road dust could not be avoided and the data was not corrected to account for this source of PM. 3. This study was a continuation of the 2002 Texas A&M Study at the same Texas dairy. The testing was performed a year later, from July 27-July 30, This study added the Industrial Source Complex (ISC) model in addition to the Box Model in order to differentiate the emissions from the different types of housing and to evaluate the performance of the models. Using the Box Model, a total dairy herd emission factor of 2.17 lbs/hd-yr was reported. The total dairy herd EF using the ISC model resulted in an emission factor of 2.39 lbs/hd-yr, and the emission factor broken down by the types of housing resulted in 1.37 lbs/hd-yr from the freestalls and 5.46 lbs/hd-yr from the open corrals. 4. I spoke with Barry Goodrich, one of the researchers for the 2002 and 2003 ASAE (studies listed under #2 and #3) dairy PM 10 emission study in order to better understand the two studies. Barry Goodrich stated that he is currently writing a thesis paper, which will sum up the two studies outlining a revised emission factor. He mentioned that the Box Model is not the best method to calculate emissions and that data obtained in the 2002 study was re-run using ISC-STv3. Barry stated that the new numbers would be included in a new report, which will be released sometime in May-June He did provide me with his draft revised emission factors in his report, 3.77 lbs/hd-yr was attributed to milk cows housed in freestalls and 7.1 lbs/hd-yr for milk cows housed in open corrals. Barry also mentioned that these numbers remained uncorrected for the unpaved road and silage harvesting emissions (from the factors highlighted in the 2002 study). 2

3 5. This study was performed by Texas A&M University in the summer of 2004 (August 1-4) on a Texas cattle feedlot. The analysis was performed using Dispersion Modeling ISCST3. This study included emissions from the unpaved roads adjacent to the feedyard. It was reported, that these roads were heavily traveled during the daytime by passenger vehicles, feed trucks, large machinery, and other maintenance vehicles. This created a sizeable dust plume. In order to calculate an emission factor for the feedlot, the unpaved road emissions were subtracted from the average daily emission factor. The difference in the daytime and nighttime emission factors were attributed ALL to road dust emissions. The emission factors presented in the report are as follows: Time weighted daytime average = 23.4 Time weighted nighttime average = hour weighted average = 15.3 From this, 12.8 lbs/hd-yr was attributed to road dust emissions and 2.4 lbs/hd-yr was attributed to emissions from the corrals. As a note, the pen surface conditions at the feed yard were moist due to a rain event that occurred 7 days before the first test. The pen surfaces remained moist during the 4-day sampling period. However, the unpaved roads were reported as being dry throughout. Other Agency Emission Factors The California Air Resources Board uses the following PM 10 emission factors: 2.46 lbs/hd-yr for all dairy cattle (this includes milk cows and support stock) and lbs/hdyr for feedlot cattle. The dairy emission factor was developed using the 2002 ASAE Texas A&M study and multiplying that number by a scaling factor. The scaling factor was used to try to make the results more consistent with California geographic conditions. The USDA reported dairy emission factor of lbs/hd-yr was excluded by ARB since it did not seem reasonable to have higher emissions from a dairy when compared to the reported emission factor for feedlots. The feedlot emission factor was developed using data from the USDA report (discussed in item #1). Summary and Conclusions Feedlot Emission Factor: ARB adopted an emission factor of lbs/hd-yr for feedlot cattle, which was based on the USDA study (listed in item #1). The only other study that evaluated a feedlot emission factor was the 2004 Texas A&M study (#5). This study raises questions about the reported feedlot emission factor due to some externalities at the feedlot. A rain event occurred at the feed yard seven days prior to the test, which kept the pen surfaces moist during the 4- day sampling period. The unpaved roads, however, were dry throughout the entire period. These roads were heavily traveled during the daytime by passenger vehicles, feed trucks, large machinery, and other maintenance vehicles, which created a sizeable dust plume. All of the emissions generated during the daytime beyond the amount created by the cows at night were attributed to the unpaved roads. Generally, cows tend to be more active in the daytime hours, resulting in higher emissions. However, this was not considered in 3

4 developing the emission factor outlined in this study. Therefore, until better data becomes available, the emission factor of lbs/hd-yr, currently used by ARB, will be used for feedlot cattle operations. The following table outlines the emission factor for feedlot cattle. Feedlot PM 10 Emission Factor Emission Factor Type of Cow Type of Housing Source (lbs/hd-yr) Feedlot Cattle Open Corral USDA - ARB Summary and Conclusions Dairy Emission Factor: ARB adopted an emission factor of 2.46 lbs-hd-yr for all dairy cattle, which was derived from the 2002 Texas ASAE study (Discussed on page 2) and multiplying by a scaling factor. The scaling factor was based on the ratio of the California Feedlot PM 10 emission factor to a Texas feedlot PM 10 EF. This Feedlot EF was referenced in the 2002 ASAE Texas A&M study. The scaling factor was applied to adjust for climate conditions in California. There are a few concerns with the use of this emission factor, as follows: The 2.46 lbs/hd-yr EF cannot be applied to all dairy cattle, since the only cows tested during the study were milk cows. This emission factor does not differentiate between emissions from open corral housing and freestall housing even though there is a significant difference in emissions from the two. This emission factor includes emissions from silage harvesting and unpaved road emissions. There is no reason to assume a scaling factor in developing this emission factor. The climate in Texas and California is fairly similar in the summer months and therefore, will result in similar emissions. Additionally, a direct correlation between the various geographic conditions cannot be established. Therefore, the scaling factor will be considered arbitrary, further raising doubt to this EF. The subsequent study performed by Texas A&M in 2003, however, does a better job at refining the dairy emission factor. No contamination from any other source was reported for the measurements from the freestalls and corrals. The study was also designed to evaluate emissions from the different types of housing. The freestall emission factor with exercise pens was reported as 1.37 lbs/hd-yr and the emission factor from the open corral was reported as 5.46 lbs/hd-yr. The only other source for dairy emissions reported was based on a phone conversation with Barry Goodrich, one of the researchers for the 2002 and 2003 ASAE study. Barry Goodrich stated that significantly more work had gone into this research since the two 3 This emission factor takes an average of March samples (when ground surface was relatively wet) and during July. In July, water trucks were used for dust control in all of the animal enclosures and on the unpaved portions of roads surrounding the feedlot. 4

5 studies were completed. The subsequent work found that the Box Model used in 2002 and 2003 was inadequate for the complicated source configuration on the dairy. Therefore, all samples were consequently analyzed using ISC-STv3. The emission factors provided over the phone (3.77 lbs/hd-yr for freestalls and 7.1 lbs/hd-yr from open corrals) were a result of the analysis of all the numbers (from both the 2002 and 2003 study) solely using ISC and not the result from the Box Model. The results of this analysis are scheduled to be released sometime in May or July This paper will need to be carefully evaluated before this new data can be used. These emission factors are not consistent with the reported values in the 2002 and 2003 studies. Based on my phone conversation with Barry Goodrich, these values also include emissions from silage harvesting and unpaved roads. Until this paper becomes available and is carefully reviewed to see if the road and harvest emissions can be identified. These emission factors will not be used in the development of a dairy PM 10 emission factor. Emission Factor for calves Currently, there is no emission factor established for calves, nor have there been any studies undertaken to develop one. Therefore, this memo will attempt to devise a calf emission factor using the best available data from the studies presented in this memo. This memo will develop a worst-case emission factor based on the type of housing that has the potential of creating the most PM 10 emissions. A control efficiency can be applied to this emission factor if better calf housing are used. Baby calves weigh less than 200 pounds, are generally fed a liquid diet, and are generally housed in hutches or small individual pens. Hutches are usually small-enclosed houses with an opening in the front and large enough for baby calves to lie down. There are several types of hutches/individual pens at a dairy. Individual pens are similar to an open corral type housing, with the exception of the size and that amount of cows held per pen. Calves hutches can either be placed directly on the ground with bedding or on grates, where the manure falls onto a concrete lane so that it can be flushed. Based on the type of housing discussed above, it would appear that the worst-case emissions would most likely be generated from individual pens, which are open to the elements. Due to the type of confinement of these calves, the emissions would resemble an emissions profile similar to cows housed in freestalls (1.37 lbs/hd-yr). Keeping in mind that the emissions would likely be lower for calves due to the difference in weight and activity between milk cows and calves, an emission factor of 1.37 lbs/hd-yr would be far better than the current factor of 2.46 lbs/hd-yr used by ARB and would be considered a very conservative estimate considering no data is available. As mentioned earlier, further reductions can be obtained by installing different types of calve housing systems (Refer to Dairy/Feedlot PM 10 Mitigation Practices and their Control efficiencies document). Therefore, in order to be conservative, an emission factor of 1.37 lbs/hd-yr will be used for calves. 5

6 Based on the above analysis, the 2003 ASAE Texas A&M study will be used in establishing the dairy PM 10 emission factor. The following table outlines the emissions factors for dairies: Dairy PM 10 Emission Factor Type of Cow Type of Housing Emission Factor (lbs/hd-yr) Source Milk & Dry cow Freestall with exercise Pens ASAE Texas A&M Milk & Dry cow Open Corrals with no shade structure ASAE Texas A&M Heifers 4 Open Corrals with no shade USDA structure Calves Individual Pens 1.37 SJVAPCD 4 It will be assumed that heifers at a dairy are as active as feedlot cattle. 6

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