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Agriculture Regulations – Engines, CMPS, and Permitting

Fall 2009

Sheraz GillSupervising Permit Services Air Quality EngineerSan Joaquin Valley Air Pollution Control District

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San Joaquin Valley

•Hot, sunny summers•VOC, NOx•Ozone Problem

•Cool, foggy winters•Particulate problem

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What’s the problem?Valley air basin fails federal and state air quality standards.

• Ozone: smogSerious health risksNitrogen oxides (NOx) + volatile organic compounds (VOCs) + sunlight and heat.

• Particulate matter: PMSerious health risksSulfates, dust, soot, ash, salts and other pollutants

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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 back-up generators.

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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.).

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Emission RequirementsDiesel 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

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Emission RequirementsDiesel 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

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Emission RequirementsSpark-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

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Options for ComplianceOption 1

Remove and replace with electrical motor

• 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

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Options for Compliance Option 2

Replace with a Tier 3 (or latest-Tier) diesel certified engine

• 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

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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

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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

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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

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Monitoring/Recordkeeping

• Monitor:– Operate and maintain per manufacturer– Monitor operational characteristics per

manufacturer– Nonresettable operating time meter

• Record:– Monthly operating log

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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)

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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/yearSoon to be 5 tons-NOx or VOC/year (2010)

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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)

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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

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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)

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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.

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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

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Conservation Management Practices Categories

• Land Preparation/Cultivation (Cropland)

• Harvest (Cropland)

• Other (Cropland)

• Unpaved Roads

• Unpaved Vehicle/Equipment Traffic Areas

• CAFO Manure Handling and Storage

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CMP Forms• Alfalfa• Citrus• Corn, Grain, and Silage• Cotton• Dry Beans, Cereal

Grains, Safflower, Wheat, and Barley

• Grapes• Nut Crops• Onions and Garlic

• Sugar Beets• Tree Fruit• Vegetables, Tomatoes,

Melons, and Other• Dairy• Feedlot• Poultry• Unpaved Roads &

Unpaved Vehicle/Equipment Areas

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Examples of CMPsChemigation/Fertigation

• Application of chemicals thru an irrigation system

• Examples– Addition of herbicide or fertilizer

through water application– Aerial application

• Benefits– Reduces the need to travel in-field for application purposes– Reduces # of passes & soil disturbance – Increases efficiency for application

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Examples of CMPs Combined Operations

• Combination of equipment to perform several operations during one pass

• 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

• Benefits– Reduces # of passes necessary to cultivate the land – Reduction of soil compaction & time to prepare fields

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Examples of CMPs Conservation Irrigation

• Conservation of the quantity of water used

• Examples– Use of drip or buried line systems– Water flow meters or soil

monitoring devices to avoid over-irrigation

• Benefits– Conserves water– Reduces weed population

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Examples of CMPs Night Farming & Harvesting

• Examples– Farm during night time, when it’s dark– Increased humidity may increase soil surface

moisture thereby helping contain PM emissions from tillage.

• 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

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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

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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.

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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.

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FEES: Permits vs Registration (PEER)

Filing Fee Annual FeePre-

Construction Permits?

BACT?

Permits

Hourly Process

fee

$71 app fee due up front

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 Yes

PEER$24 or

$85$23 or $57 No No

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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.

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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

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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

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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

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Contacts/References

Sheraz Gill (559) 230-5900

SJVAPCD

www.valleyair.org

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Ag Workshops• Tuesday, 10/27

– 9am – 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