Misconceptions

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

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

3. 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

4. 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.”

5. 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.

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

7. “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

8. Hazardous Air Pollutants • HAPs have different thresholds with respect to major status. • Individual HAPs ≥ 10 tons per yearor • 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

9. 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???

10. 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

11. 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.

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

14. Wastewater • Unavoidable wastewater generation. • Must be collected, treated, & disposed of properly. • Wastewater discharge to waterbody • Requires an NPDES Permit. • Anti-Degradation Study • Discharge MayNot be acceptable. • Site specific Federal Permit. • Requires site inspection &/or water quality stream modeling. • Typical permitting actions take 180-270 days.

15. 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

16. 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.

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

18. 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

19. 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.

20. 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

21. Recap Purpose: To give a general idea of the MDEQ permitting requirements that are typically required in biodiesel production. Questions? Contact: Chad Winter (601) 961-5601 chad_winter@deq.state.ms.us