Biodiesel: Environmental Permitting Issues for Production in Mississippi Emerging Fuels Workshop December 5-6, 2006 Chad Winter MDEQ-OPC Environmental Permits Division

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Biodiesel Environmental Permitting Issues for
Production in MississippiEmerging Fuels
WorkshopDecember 5-6, 2006Chad
WinterMDEQ-OPCEnvironmental Permits Division
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Misconceptions

• Certification of biodiesel quality resolves
  permitting issues - FALSE
• There are no MDEQ requirements relating to
  biodiesel production FALSE
• Lack of information

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Causes for Misconceptions

• Biodiesel production is relatively new to MS
• Many unaware of MDEQ role
• Miscommunication of information re state
  federal requirements
• Federal State regulations vary depending on
• Type of operation
• Chemicals used
• Type of control equipment
• Amount of biodiesel produced

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Permit To Construct (PTC)

• New Source Review (NSR)
• Minor Source State PTC per State Implementation
  Plan (SIP)
• Major Source PSD federal construction permit
• Grants permission to build air emissions
  equipment and may contain specific limits and
  standards for each piece of equipment used in the
  process
• Applicants must complete the Application for Air
  Pollution Control Permit to Construct and/or
  Operate Air Emissions Equipment.

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Potential to Emit (PTE)

• To determine the type of air operating permit a
  facility requires, the facility must calculate
  their potential to emit (PTE).
• Worst case scenario - 8,760 hpy w/o controls.
• Applicable federally enforceable standards.
• Federally enforceable permit limit/restriction.
• NSPS exceptions.
• If the PTE is below the major status threshold,
  then the facility is a True Minor Source.

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PTE continued

• True Minor Source does not require an air permit
  to operate.
• Otherwise
• Title V Operating Permit Program.
• Synthetic Minor Operating Permit.

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Typical Pollutant Thresholds

• The threshold crossed to become a major source is
  determined by pollutant.
• Sulfur dioxide (SO2)
• Boilers, burners, etc.
• VOCs
• Ethanol-use plants
• Particulate matter
• When burning glycerin distillation bottoms
• HAPs
• Methanol-use plants

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Hazardous Air Pollutants

• HAPs have different thresholds with respect to
  major status.
• Individual HAPs 10 tons per year or
• Combined HAPs 25 tons per year
• Methanol (most common) is a HAP.
• Ethanol (less common) is a VOC.
• Threshold is 100 tpy before reaching Major Source
  Status
• Title V PSD

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NSPS

• New Source Performance Standards found in 40 CFR
  Part 60.
• Address the synthetic organic chemical
  manufacturing industry (SOCMI) specifically as it
  applies to biodiesel production.
• Subpart(s) NNN, RRR, VV.
• Batch Production
• Exempted from NNN RRR.
• Subpart VV applies regardless of batch or
  continuous operation.
• Other exemptions to these subparts???

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Typical Review/Limits

• Methanol Recovery units, cited as inherent
  process equipment
• Thus lowering HAPs PTE
• Condensors (less expensive)
• Distillation Columns (more expensive)
• Cease production if/when control equipment
  (scrubbers, etc.) fail.
• HAP 9.9 tpy
• Leaks, valves, fittings, etc.
• VOC 99 tpy
• Sulfur Restrictions

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Disclaimer

• MDEQ cannot advise, in any means, on what
  chemical to use to produce biodiesel.
• MDEQ cannot consult in the economic /or
  technical aspects of biodiesel production
• MDEQ can only assist in the environmental
  regulations that pertain to the facility.

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• Applications (11) submitted to MDEQ for proposed
  production facilities
• More applications expected to be submitted to
  MDEQ for proposed production facilities

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Facility Alcohol MG / Yr Location
Mound Bayou Refineries, Inc. Methanol 20 Mound Bayou
Tri States Petroleum, LLC. Ethanol 14 Houston
CFC Transportation, Inc. Methanol 1.2 Columbus
Delta Agri-Fuels, LLC Methanol --- Natchez
Three Rivers Biofuels Methanol 36 Burnsville
World Biodiesel Methanol 55 West Point
North MS Biodiesel Methanol 35 New Albany
Biodiesel of MS Ethanol --- Nettleton
Biodiesel Fuels of MS Methanol --- Meridian
Ming Farms Methanol 0.765 Shelby
Scott Petroleum Methanol 20 Greenville
TOTAL 181.2
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Wastewater

• Unavoidable wastewater generation.
• Must be collected, treated, disposed of
  properly.
• Wastewater discharge to waterbody
• Requires an NPDES Permit.
• Anti-Degradation Study
• Discharge May Not be acceptable.
• Site specific Federal Permit.
• Requires site inspection /or water quality
  stream modeling.
• Typical permitting actions take 180-270 days.

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Wastewater continued

• Land application of wastewater on-site
• Adequate acreage
• Requires a State Operating (No Discharge) Permit
• Connection to a municipal collection/treatment
  system.
• Discuss with the city to determine feasibility
• Pre-treatment permit from MDEQ will be required

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Baseline Coverage

• Methanol is a Section 313 Water Priority Chemical
• Regulations for SARA Title III apply to most
  biodiesel facilities.
• Emergency Planning Community Right-To-Know Act
• Incorporated into the Baseline Storm Water
  General Permit.
• Largely addresses containment specific
  reporting requirements relating to spills.
• Covers activities associated with industrial
  processes in regards of eliminating preventing
  contaminated storm water.

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Baseline Documents

• Baseline General Permit
• Baseline Notice of Intent
• Guidance manual for industrial activities

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Toxic Release Inventory (TRI)

• Section 313 of Title III of the Superfund
  Amendments and Reauthorization Act of 1986
  (SARA./Title III)
• Industrial facilities required to submit reports
  to EPA.
• Reports concern storage, release, use, and
  disposal of toxic, hazardous, and extremely
  hazardous substances.
• TRI is a reporting mechanism for activity, usage,
  and releases of toxic substances, in addition to,
  but regardless of, other permits.
• epa.gov/tri

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Glycerin What to do with it?

• Not an option
• Dc Landfills
• Sewer Systems
• Discharge
• So, what then?????
• Large-scale Refineries
• Small-scale Trucking companies, etc.

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Glycerin

• 1st MSU Biodiesel Workshop
• Holcim
• BIF (Boiler Industrial Furnace)
• Energy recovery vs. destruction
• Only BIF in MS
• DRE goes to 99.99999 (CO2 water)
• 8,000 9,000 Btu / lb
• Holcim desires 12,000 Btu / lb

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Recap

• Purpose To give a general idea of the MDEQ
  permitting requirements that are typically
  required in biodiesel production.
• Questions?
• Contact Chad Winter
• [phone]
• chad_winter_at_deq.state.ms.us