Agriculture Regulations Engines CMPS and Permitting Fall

Agriculture Regulations – Engines, CMPS, and Permitting Fall 2009 Sheraz Gill Supervising Permit Services Air Quality Engineer San Joaquin Valley Air Pollution Control District 1

San Joaquin Valley • Hot, sunny summers • VOC, NOx • Ozone Problem • Cool, foggy winters • Particulate problem 2

What’s the problem? Valley air basin fails federal and state air quality standards. • Ozone: smog Serious health risks Nitrogen oxides (NOx) + volatile organic compounds (VOCs) + sunlight and heat. • Particulate matter: PM Serious health risks Sulfates, dust, soot, ash, salts and other pollutants 3

District Rule 4702 – Internal Combustion Engines • Goal of Rule: lower emissions from existing irrigation and other pump engines. • Applies to all stationary and transportable internal combustion (IC) engines greater than 50 bhp including emergency backup generators. 4

District Rule 4702 – Internal Combustion Engines • NOTE: This rule does not apply to mobile equipment that is self propelled (tractors, harvesters, etc. ), wind machines, and ag equipment that is towed or mounted on a vehicle and is continuously moved during its operation (sprayers, bailers, etc. ). 5

Emission Requirements Diesel Ag Engines • Replace Tier 0 with Tier 3 by January 1, 2010 – 50 -500 HP – 501 -750 hp but operate less than 1, 000 hrs • Replace Tier 0 with Tier 4 by January 1, 2011 – Greater than 750 hp but operate less than 1, 000 hrs • Replace Tier 1 and Tier 2 engines with Tier 4 by 2015 or a 12 years from installation date (but not later than 2018) – If Tier 4 is not available, Tier 3 can be installed without having to install Tier 4 in the future 6

Emission Requirements Diesel Ag Engines • Application due dates to replace Tier 0 – Permit applications due July 1, 2009 – Registration Applications due October 1, 2009 • For any new engine (non-replacement) – If subject to Permit, obtain Authority to Construct prior to installing engine – If subject to Registration, Submit registration application prior to operation 7

Emission Requirements Spark-Ignited Ag Engines • Rich-Burn: – 90 ppmvd NOx or 80% reduction – 2, 000 ppmvd CO – 250 ppmvd VOC • Lean-Burn: – 150 ppmvd NOx or 70% reduction – 2, 000 ppmvd CO – 750 ppmvd VOC • Compliance date: January 1, 2009 8

Options for Compliance Option 1 Remove and replace with electrical motor • • 9 No permit or registration to abide by, No permit or registration fees, No emission control equipment to maintain, & No periodic monitoring or testing of engine and it’s emissions

Options for Compliance Option 2 Replace with a Tier 3 (or latest-Tier) diesel certified engine • • • 10 Must emit less (on ppmvd basis) than existing engine For permitted farms, there may be some issues to increase engine size, talk to us Note: an ATC Permit is required prior to modification for permitted farms

Options for Compliance Option 3 Limit operation schedule of TIER 0 engine to no more than 200 hrs • Non-resettable time meter is required to ensure hours of operation • Records shall be kept on a monthly basis • Note: an ATC Permit is required prior to modification for permitted farms 11

Options for Compliance Spark-Ignited ONLY Replace/retrofit with lean-burn engine • Retrofits from natural gas rich-burn to lean -burn Note: an ATC Permit is required prior to modification for permitted farms 12

Options for Compliance Spark-Ignited ONLY Retrofit rich-burn engine with a 3 -way catalyst system • Unless certified you shall: – Monitor (Portable NOx analyzer once every 24 months), – Source test every 60 months – Operator perform monthly inspections • Note: an ATC Permit is required prior to modification for permitted farms 13

Monitoring/Recordkeeping • Monitor: – Operate and maintain per manufacturer – Monitor operational characteristics per manufacturer – Nonresettable operating time meter • Record: – Monthly operating log 14

Permit or Registration? • Permit is required for all engines that: – Are subject to 4702 (Stationary or transportable IC engines greater than 50 bhp), and – At farms that emit more than 12. 5 tons-NOx or VOC/year • Soon to be 5 tons-NOx or VOC/year (2010) 15

Permit or Registration? • Permit-Exempt Equipment Registration (PEER) is required for all engines that: – Are subject to requirements of 4702 (Stationary or transportable IC engines greater than 50 bhp), and – Do not need permits • Farm emits less than 12. 5 tons-NOx or VOC/year v. Soon to be 5 tons-NOx or VOC/year (2010) 16

Permit or Registration? • Subject to Registration if below the following: (based on 12. 5 tons-NOx/yr and assuming 2, 500 hours operation per year): – Tier 1 – 1, 000 total HP engine (65% load) – Tier 2 – 1, 235 total HP engine (65% load) – Tier 3 – 1, 985 total HP engine (65% load) 17

Upcoming Important Changes • Designation to Extreme Non-Attainment • EPA approval of District NSR Rule by March 2010 at latest – ½ major source goes from 12. 5 tons VOCs or NOx to 5 tons of VOC or NOx – Permit applications due 6 months after approval date 18

Upcoming Important Changes • Approximate HP exceeding the 5 tons of NOx/yr permitting threshold (assuming 2, 500 hours operation per year): – Tier 1 - 400 total HP engine (65% load) – Tier 2 - 495 total HP engine (65% load) – Tier 3 - 795 total HP engine (65% load) 19

Conservation Management Practices (CMP) Plans - Rule 4550 • Purpose of Rule to limit fugitive dust emissions from farms • The District definition of a Stationary Source still applies, i. e. contiguous and adjacent property. – This means a farmer with multiple sites will have to submit a Conservation Management Practices (CMP) plan for each site. 20

Conservation Management Practices (CMP) Plans - Rule 4550 • Applicability: – Greater than 100 acres of crops – Dairies with over 500 mature Cows (Milk and Dry cows) – Feedlot Cattle with over 190 head – Other CAFs • CMP Apps were due on Dec. 31, 2004 21

Conservation Management Practices Categories • • • 22 Land Preparation/Cultivation (Cropland) Harvest (Cropland) Other (Cropland) Unpaved Roads Unpaved Vehicle/Equipment Traffic Areas CAFO Manure Handling and Storage

CMP Forms • • • Alfalfa Citrus Corn, Grain, and Silage Cotton Dry Beans, Cereal Grains, Safflower, Wheat, and Barley • Grapes • Nut Crops • Onions and Garlic 23 • Sugar Beets • Tree Fruit • Vegetables, Tomatoes, Melons, and Other • Dairy • Feedlot • Poultry • Unpaved Roads & Unpaved Vehicle/Equipment Areas

Examples of CMPs Chemigation/Fertigation • Application of chemicals thru an irrigation system • Benefits – Reduces the need to travel in-field for application purposes – Reduces # of passes & soil disturbance – Increases efficiency for application • Examples – Addition of herbicide or fertilizer through water application – Aerial application 24

Examples of CMPs Combined Operations • Combination of equipment to perform several operations during one pass • Benefits – Reduces # of passes necessary to cultivate the land – Reduction of soil compaction & time to prepare fields • Examples – Combining cane cutting, discing, and flat-furrowing in a single pass for vineyards – Use of one-pass till equipment in ground preparation or crop tillage, cultivation & fertilization of field crop in a single pass 25

Examples of CMPs Conservation Irrigation • Conservation of the quantity of water used • Benefits – Conserves water – Reduces weed population • Examples – Use of drip or buried line systems – Water flow meters or soil monitoring devices to avoid overirrigation 26

Examples of CMPs Night Farming & Harvesting • Operation at night where practical when moisture content levels are higher and winds are lighter • Benefits – Decreases concentration of PM during day – Increase in ambient humidity • Examples – Farm during night time, when it’s dark – Increased humidity may increase soil surface moisture thereby helping contain PM emissions from tillage. 27

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Modifications to CMPS • A CMP modification application need to be submitted for any changes not covered by the current CMP for the following: – Change in crop type – Addition/subtraction of crop acreage – Change in Conservation Management Practice (CMP) • There is no fee to make changes to your CMP plan 29

CMP Recordkeeping • The owner/operator of the farm must keep a copy of all approved CMP plans for five years. • Conversely, if a farm is exempt from the CMP Rule, all necessary information to show exemption from the Rule must be maintained. 30

Compliance • The District is committed to assisting growers in complying with these rules and regulations. • Non-compliance with these rules and regulations may lead to enforcement action with the potential for a penalty. 31

FEES: Permits vs Registration (PEER) Filing Fee Hourly Process fee Permits $71 app fee due up front PEER 32 $24 or $85 Annual Fee Pre. Construction BACT? Permits? 51 -99 bhp = $80 100 -199 bhp = $117 200 -399 bhp = $240 400 -799 bhp = $479 800 -999 bhp = $602 1, 000 -4, 999 bhp = $749 Yes $23 or $57 No No

CMP Fees • The initial plan fee varies from $74 to $294. 00 (depending on the number of animals). • The initial plan fee varies from $141. 00 to $642. 00 (depending on the acreage of the farm). • There is a renewal fee of $117 every two years. • There is NO CMP fee, if facility has a permit for any equipment. 33

District Grant Funding • Heavy-Duty Engine Program – Agricultural Irrigation Pumps • Received over 8, 000 applications • Contracted over $91 million – Agricultural Off-Road Vehicles • Received over 2, 900 applications • Contracted over $12 million 34

Current Funding Opportunities • Stationary and portable Ag irrigation pumps – Engine repower (non-Tier 0 engines) – New electric motor purchase • Mobile off-road Ag vehicles – Repower & retrofit • Forklifts – New electric forklift purchase – Retrofit of LSI forklifts 35

District Resources • Small Business Assistance – Modesto (209) 557 -6446 – Fresno (559) 230 -5888 – Bakersfield (661) 392 -5665 • Emission Reduction Incentive Program (ERIP) – (559) 230 -5800 • Ag website (www. valleyair. org) – Automated emission calculations – Application Forms 36

Contacts/References Sheraz Gill (559) 230 -5900 SJVAPCD www. valleyair. org 37

Ag Workshops • Tuesday, 10/27 – 9 am – San Joaquin Farm Bureau – Stockton – 1: 30 pm - Stanislaus Ag Center - Modesto – 6 pm - Merced County Farm Bureau - Merced • Thursday, 10/29 – 9 am - Madera Fairgrounds - Madera – 1: 30 pm - Kerman Community Center - Kerman • Tuesday, 11/3 – 9 am - Tulare County Farm Bureau - Visalia – 1: 30 pm - Reedley Community Center - Reedley • Wednesday, 11/4 – 9 am - UCCE Conference Room -Bakersfield – 1: 30 pm - Kings Fairgrounds - Hanford 38