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Protecting the Quality of Our Nation's Air
EPA Targets Air Pollution From Ethanol Facilities:
VOC Emissions Higher Than Previously Believed
The UjaitedJStatesJBnvkonmental
Protection Agency (EPA), work-
ing closely with several state; agen-
cies, recently determined that etha-
nol facilities emit some air pollutants
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in greater quantities than previously
reported. These emission tests con-
ducted by Minnesota, Indiana, and Il-
linois sources triggered concern be-
cause emissions of several criteria
pollutants were much higher than per-
mitted by those states and EPA. For
example;, volatile organic compound
(VOC) omissions were found to be
approximately 10 times higher than the
limits in the facilities' permits and in-
cluded at least 2 previously unidenti-
fied hazardous air pollutants (HAPs),
acroleurand acetaldehyde. In addi-
tion, a recent test conducted by an
Illinois source showed that carbon
monoxide (CO) emissions were even
higher than the VOC emissions. This
led EPA to believe that ethanol facili-
ties were failing to accurately esti-
- mate emissions from hundreds of pro-
cess units and constructing or expand-
ing other units without the installation
of air pollution control technology re-
quired under the Clean Air Act
(CAA).; Originally, ethanol facilities
were permitted with limits based on
the emission characterizations of only
ethanol and methanol; it was not until
odor problems were identified by
some state regulators that total vola-
tile organic compounds (VOCs) were
measured and analyzed.
Industry-wide, these uncontrolled
facilities are "major sources" of air
pollution and are, therefore, subject to
the CAA's New Source Review/Pre-
vention of Significant Deterioration
(NSR/PSD) requirements. In addition,
certain New Source Performance
Standards (NSPS) under the CAA
apply. As such, the ethanol facilities
should have applied for appropriate
preconstruction and operating permits
at the time they were constructed and
they should have installed the required
equipment to reduce emissions of air
tr -rv . ... . fj
g a material, mostcommonlyj
iiaa^^
irecent years, ethanol has
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y I^y^j|^^^J™~™~°
onFage j/ Htnanol rrocess
-------
Enforcement Alerti
pollutants.
Recent EPA Enforce-
ment Settlements With
Ethanol Facilities
12 Minnesota Dry Mills
Once EPA determined that air
emissions were not permitted, the
Agency approached a number of
ethanol producers to resolve these-
alleged violations. During the sum-
mer of 2002,12 ethanol facilities in
Minnesota entered into negotiations
with EPARegion 5 and the U.S. De-
partment of Justice (DOJ). Consent
decrees for all 12 facilities were
lodged on October 2, 2002. The
settlement terms for the Minnesota
facilities require that every facility in-
stall Best Available Control Technol-
ogy (B ACT) and meet B ACT-level
emission limits. As part of the settle-
ment, each facility was allowed to
decide whether it wanted to continue
to be a major source or whether it
wanted to take an emissions cap that
would keep;it at "synthetic minor"
source levels. Regardless of the
facility's decision, the facility was re-
quired to install B ACT. Of the 12
Minnesota facilities, 2 chose to re-
main major Sources and will submit
PSD permit applications under the
terms of the consent decree. The 10
remaining facilities believe that with
BACT-level controls they will be
.abletojeniainundersynthetic minor.
source emission thresholds. All 12
will limit their HAP emissions under
\
major source levels of 10 tons per
year (tpy) for each pollutant and 24
tpy combined. All 12 sources cur-
rently have installed, or are in the pro-
cess of installing, the required con-
trol equipment. These settlements
will result in emission reductions of
2,400 tpy of VOCs (includes 250
tpy of HAPs); 2,000 tpy of CO; 180
tpy nitrogen oxides (NOx); and 240
tpy particula :e matter (PM) and PM-
10. Each facility also paid a civil
penalty ranging from $18,000 to
$42,000.
Archer Daniels Midland
Archer Daniels Midland Company
(ADM) is the largest producer of etha-
nol in the United States supplying 50
percent of the market. ADM also pro-
duces other corn products including
sweeteners, starch, oil, and meal from
its 7 corn mills. ADM is thought to be
the largest producer of domestic veg-
etable oils with 28 plants,' wKere it
employs a solvent extraction process
to separate oils from soybeans, sun-
flowers, cottonseeds, peanuts, and
canola. On April 9,2003, DOJ, along
with state and local government co-
plaintiffs, and EPA, announced a
landmark settlement with ADM that
will cover operations at 52 facilities
in 16 states. The settlement is the
result of an unprecedented joint fed-
eral and state enforcement effort with
Proper Emissions Sampling from Ethanol Facilities
Industry, previous testing was typically done using EPAMethods 18 or 308. These methods are used exclusively to
[quantify the emissions of specific VOCs. |
Because of the complex nature of their organic compound emissions, ethanol facilities began using tests such as EPA
Method 25 to quantify the emissions of all organic compounds. However, such methods only quantify the total mass of
the carbon in the VOCs being emitted. Additional analysis is needed to convert that number to the total mass of VOCs
being emitted. ;
EPA's Headquarters, Regions 5 and 7, and the Office of Air Quality Planning and Standards, in conjunction with
[companies experienced in stack testing for VOCs, created a method to quantify the average molecular weight-to-
[carbon weight ratio for each dryer tested. This method, now called the Midwest Scaling Method, involves the use of
[EPAMethod 18 as well as portions of National Council ofthe Paper Industry for Air and Stream Improvement (NCASI)
{Methods 94.02 and 98.01. In addition, EPA simplified this method by identifying a handful of compounds deemed to
have the most significant effect on the average molecular weight-to-carbon weight ratio. This ratio can be applied to the
[results of tests that quantify the emissions of organic calrbon to yield the total VOC emission rate.
July 2003
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14 states and counties joining EPA
to resolve these violations. This is
the first major NSR/PSD settlement
involving the grain and oilseed pro-
cessing industry. Under the settle-
ment, ADM will implement broad-
sweeping environmental improve-
ments at its facilities nationwide that
will result in a total reduction of air
pollutants of at least 63,000 tpy, in-
cluding: 21,000 tpy of VOCs; 23,000
tpy of CO; 1 1,000 tpy of S02; 7,000
tpy of NOX; and 1,000 tpy of PM.
ADM will instaUBACT-level controls
onalarge number of units, shutdown
some of the oldest, dirtiest units, and
take stringent emission limits on other
units. ADM will pay a civil penalty
of $4.6 million, and implement an
additional $6.3 million worth of
Supplemental Environmental
Projects.
EPA Resolves to
Noncompliance in the
Ethanol Industry
On June 3, 2002, EPAReglon 5
hosted a meeting for ethanol facilities
_located_in EPA Regions 5, 7, and 8.
In addition to owners and operators
of ethanol facilities, participants in-
cluded management from the air pro-
gram offices of the 3 EPARegions,
representatives from state program
offices, an ethanol industry group, the
Renewable Fuels Association, EPA's
Office of Enforcement and Compli-
ance Assurance, and DOJ. At the
meeting, Region 5's Regional Admin-
istrator Tom Skinner outlined the is-
sues of concern for ethanol facilities
related to the proper characterization
July 2003 _________
EPA has recently
settled a number of
VOC emission
\ cases.
of emissions. The
Regional Adminis-
trator ialso de-
scribed EPA's ap-
proach for resolving
violations at ethanol
_ faciMe§!thajLw,ould,
voluntarily ap-
proach EPA soon
after the meeting.
Although the mes-
sage was delivered
in Region 5, the in-
dustry-wide ap-
proach was coordinated with the af- ~ -
fected Regions and EPA Headquar-
ters and,|as such, represented a na-
tional EPAundertaking.
Following that meeting, the Min-
Ethanol Process/Fromip.1
- - - A
Usually dedicated to producing ethanol and i
- "? generally smaller than wet mills, which;
^ -EL-tuji:i~~i_ui1 .-i/i'...".1..1.*,,,;•,' L .I"! :,-,, , •" "".i,,™,;,: »iiu jmiui-a !,".• .'*,.„„ »;',,a
Scally produce products in addition to •
gthanol. The ethanol production process
nesota settlements were the firstLnJ^brokend^nintothreemainproj
settlements reached, and the settle.^^. feed preparation, fermentation,3
ment with ADM_followed shortlyO purification
thereafter. EPAand the states conJF. During the fermentation process, left-*:
tame to negotiate with other ethanol^g- so^s ^ generauy processed further1
facilitiesf rossthecountry. EPAwm|^product ^ to make anima] feed;
ensure that environmental benefits arep^j. e^ssions can contain nitrogen ox-"
achieve^by requiring that the etha- ^cartxin monoxide, particulate matter,*
nolindustry come into compliancep^ a^^^y Qf VOCs such as ethanol^
with the CAA as quickly as possible,fcpetaidehyde; methanol, acrolein, acetic^
and will ensure that there is consis-fej a^Jactis; acid In addition the VOCs1
tencyandalevelplaying field acrossp|^d g^ ^^s can contajn up tQ 4(^
)ercentHAPs; It is these dryer emissions"
^tt^ehistor^ally been underestimated*
ifthe ethanol industry.
the ethanol industry.
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&EPA
United States
Environmental Protection Agency
Office of Regulatory Enforcement
(2241 A)
Washington, D.C. 20460
Official Business
Penalty for Private Use $300
'Enforcement Alert' newsletter
Assistance Resources
orcementand Compliance
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Air Enforcement Division:
emnt Agreemen
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