Acurex Project 7385
STANDARDS SUPPORT PLAN FOR
ENVIRONMENTAL ASSESSMENT OF
CONVERSION OF BIOMASS TO
ENERGY GASOHOL
W. C. Kuby, N. L. Concion, G. R. Often, R. D. Shelton
Acurex Corporation
Energy & Environmental Division
485 Clyde Avenue
Mountain View, California 94042
February 1980
ACUREX DRAFT FINAL REPORT 80-44/EE
Prepared for
R. E. Mournighan Technical Project Monitor
Environmental Protection Agency
Industrial Environmental Research Laboratory
5555 Ridge Avenue
Cincinnati, Ohio 45268
Contract 68-03-2567
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Acurex Project 7385
STANDARDS SUPPORT PLAN FOR ENVIRONMENTAL ASSESSMENT
OF CONVERSION OF BIOMASS TO ENERGY GASOHOL
W. C. Kuby, N. L. Concion, G. R. Offen, R. D. Shelton
Acurex Corporation
Energy & Environmental Division
485 Clyde Avenue
Mountain View, California 94042
February 1980
Acurex Draft Final Report 80-44/EE
Prepared for
R. E. Mournighan Technical Project Monitor
Environmental Protection Agency
Industrial Environmental Research Laboratory
5555 Ridge Avenue
Cincinnati, Ohio 45268
Contract 68-03-2567
-------
TABLE OF CONTENTS
Section Page
1 INTRODUCTION 1-1
2 ALCOHOL FUELS PRODUCTION 2-1
2.1 Commercial-Scale Ethanol Production 2-2
2.1.1 Ethanol from Starches 2-2
2.1.2 Ethanol from Celluloses 2-7
2.1.3 Ethanol from Sugars 2-11
2.2 On-Farm Ethanol Production 2-15
2.2.1 Process Description 2-15
2.2.2 Emissions and Effluents 2-16
2.2.3 Pollution Control Systems 2-16
2.2.4 Liquid and Solid Waste Disposal 2-16
2.2.5 New and Emerging Technologies 2-16
2.3 Other Alcohol Fuels Production 2-17
2.3.1 Methanol Via Catalysis of Synthesis Gas .... 2-17
2.3.2 Butanol Production Via Biological Conversion . . 2-18
3 THE STANDARDS SUPPORT SCHEDULE . 3-1
3.1 Description of the Schedule 3-1
3.2 Program Schedule 3-2
3.3 Responsibilities and Working Interaction 3-12
4 DISCUSSION OF THE STANDARDS SUPPORT PLAN ELEMENTS ... 4-1
4.1 Alcohol Fuels Development 4-1
4.1.1 Potential Oil Savings from Alcohol Fuels .... 4-1
4.1.2 Supply and Demand 4-2
4.1.3 Biomass Availability 4-5
4.2 Regulatory Requirements and Plans 4-7
4.2.1 Bureau of Alcohol, Tobacco, and Firearms .... 4-7
4.2.2 Office of Air Quality Planning and Standards . . 4-11
4.2.3 Office of Water Planning and Standards 4-17
4.2.4 Office of Solid Waste 4-23
4.2.5 Office of Toxic Substances 4-25
4.2.6 Office of Enforcement 4-27
m
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SECTION 1
INTRODUCTION
Fuels containing non-petroleum-based alcohols can provide one
effective approach for limiting the increasing dependence by the United
States on foreign oil. Gasohol, a blend of 10 percent ethanol produced
from agricultural and waste feedstocks and 90 percent unleaded gasoline,
is the most promising, near-term application of alcohol fuels. Currently,
ethanol is the only commercially available alternate fuel and will remain
the only one available in significant quantities prior to 1985.
Production of ethanol fuel through 1985 will be limited by the capacity to
convert agricultural and waste materials to ethanol, rather than by the
availability of feedstock. Although alcohol fuels are not expected to
totally eliminate our nation's dependency on foreign oil sources, they
could become an important part of the national plan to stabilize our
energy balance.
The Environmental Protection Agency (EPA) is the Federal
organization with primary responsibility for controlling adverse
environmental effects of pollutant emissions. This Standards Support Plan
(SSP) shows how EPA's Office of Research and Development (ORD) plans to
support the media Program Offices in setting standards for the emission
effluents from fuel-grade alcohol production facilities. Since it is
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anticipated that ethanol will be the only alcohol produced in significant
quantities until 1985, this SSP is limited to ethanol production.
There are several aspects to the environment impact of gasohol
production and use, namely production of the feedstock; transportation;
transfer, storage, and blending of the alcohol with gasoline; and end-use
combustion in mobile sources. Although there could be significant
environmental problems in each of these areas, this study by ORD's
Industrial Environmental Research Laboratory at Cincinnati, Ohio (lERL-Ci)
is limited to fuel-grade alcohol production, from feedstock preparation to
the generation of 200-proof alcohol. Other emissions, including end-use
emissions, need to be reviewed by the ORD laboratories with direct
responsibilities in these areas of concern.
In this SSP, a detailed plan pertaining to the fuel-grade alcohol
industry is developed for activities over the next 2 years. This report
also projects a continuing activity resulting from the monitoring of
growth and development of other alcohol production technologies. The
purpose and content of this SSP are as follows:
To explain the Agency's standards development and supporting
R&D program, with special emphasis on sampling and analysis for
emission/effluent and treatability/control data at fuel-grade
ethanol plants
To show how the ORD/IERL-Ci component of this program is
integrated with the efforts being conducted by the media
Program Offices, namely, the Office of Air Quality Planning and
Standards (OAQPS), the Office of Solid Wastes (OSW), and the
Office of Water Planning and Standards (OWPS)
1-2
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To relate the overall data collection program to the media
offices' timelines for setting standards and the Regional
Offices' requirements for permitting new sources
To establish the various agency activities and the
responsibilities for each of those activities in terms of the
overall plan and timeline for occurance of various elements of
the studies
To present other information to allow the reader to gain a
knowledgeable perspective on the industry being studied and the
methodology of setting standards
Thus, this SSP is a practical working document. It presents the
Agency's program for determination of the emissions from gasohol
facilities and the approach necessary to define these emissions. In terms
of a sampling and analysis program, it details the test plan, including
the sites, number of samples to be collected, pollutants to be sampled,
and analyses to be performed. The results of this sampling and analysis
program, as well as other studies that will be done concurrently, are
coordinated with a schedule put forth by the Program Offices for
determining the appropriateness of standards and for setting those
standards required.
In order to facilitate the generation of a consensus plan leading
to a coordinated effort between the ORD study and each of the Program
Offices as they move toward the development of standards, a series of
meetings were held between lERL-Ci personnel and the staff members from
"the Effluent Guidelines Division (EGD) of OWPS, the Emission Standards and
Engineering Division (ESED) of OAQPS, and the Hazardous and Industrial
Waste Division (HIWD) of OSW. Since the major impetus for the interest in
1-3
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fuel-grade alcohol production came from an increase in permit requests in
Region VII for on-farm facilities, Region VII personnel also participated
in these meetings.
1-4
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SECTION 2
ALCOHOL FUELS PRODUCTION
The following section is a technical description of the commercial
and on-farm processes used for alcohol fuels production. The major
emphasis is on ethanol production facilities by biological conversion of
various feedstocks. However, two other alcohol fuel production
technologies, namely the production of methanol from synthesis gases and
butanol via biological conversion, are included. The discussion for each
technology provides specific examples of the emissions and effluents,
pollution control systems, liquid and solid wastes, and new technologies
for alcohol production facilities.
The first portion of the discussion describes both commercial-scale
and on-farm ethanol production technologies via biological conversion of
feedstocks. Three specific feedstocks were chosen because they are
typical of currently used or anticipated feedstocks for ethanol
production. These are:
0 Corn, a starch
Corn stover, a cellulose
t Cheese whey, a sugar
The methanol and butanol production processes are included as
technologies of the future.
2-1
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2.1 COMMERCIAL-SCALE ETHANOL PRODUCTION
Fuel-grade ethanol can be produced from a variety of carbohydrate
feedstocks via biological conversion. These feedstock materials can be
broadly classified as starches, celluloses and sugars. The following
items are discussed for each feedstock:
Process description
Emissions and effluents
t Pollution control systems
Liquid and solid waste disposal
New and emerging technologies
2.1.1 Ethanol from Starches
Starches (polysaccharides) are present in a wide variety of food
crops, such as rice, wheat, potatoes, and corn. This discussion uses corn
as a representative starch feedstock.
2.1.1.1 Process Description
Figure 2-1 is a flow diagram of a typical ethanol from corn
process. The process begins by grinding the grain in a milling process
(e.g., a hanmermi 11) and slurrying the grain with water to form a mash.
The mash is cooked by injecting steam (at approximately 150ฐC) to
solubilize the starches. The mash is then cooled and enzymes are added to
transform the complex starches into fermentable sugars.
These sugars are then introduced into the fermentation vessels with
yeast to be converted to alcohol and carbon dioxide by the metabolic
processes of the yeasts. The fermented mash (approximately 10 percent
alcohol) is then pumped to the alcohol stripping column. This
distillation column removes the solids and most of the water to produce a
2-2
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Preparation
fermentation
Distillation
flrhydraI inn
Corn
Flash
cooling
Steam Generation
ro
CO
ฉ-
Power
plant
Inputs and Discharges
T) Fugitive dust
><
ZJ Hater
3} Fuel
Combustion products including PM, NOX, SOX
Process steam
Captured particulates
7^ Hydrocarbon emissions
Enzymes
Enzymatic
saccharification
Fermontat. ion
Alcohol
stripping
Centrifugal
separation
Rotary
drying
Hyprodiict preparation
9J Yeast
C0;>, uncondensed hydrocarbon emissions
15) Uncondensed hydrocarbon emissions
Fuel
13} Combustion products, uncondensed
hydrocarbon emissions
Dried dist.H'er's grain
Fusel oils, aldehydes
Uncnndrnsed hydrocarbon omissions
vv Vny
Rer
Mastewater
treatment ^_
ydration
(??)
T
Chilled
separation
*
Benzene
recovery
JL 1 U-ZW53
Civ C^9
Treated wastewater
19) Sludge
Uncondensed hydrocarbon omissions
Ethanol
3) Benzene make-up
i<\\ Uncondensed hydrocarbon emissions
24)
Figure 2-1. Typical ethanol production from corn feedstock.
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stream containing 80 percent ethanol, 19 percent water, and about
1 percent impurities (fusel oils and aldehydes).
The product stream is purified in a rectification column, producing
a 95 percent ethanol, 5 percent water azeotrope. The fusel oil and
aldehyde impurities are separated and removed in a side stream. These can
be combined with the final ethanol fuel product.
Dehydration of the ethanol-water azeotrope is necessary to produce
an anhydrous product. A dehydrating agent (benzene) is added to the
azeotrope in the dehydration column. The column produces a stream of
anhydrous ethanol and a stream containing benzene, ethanol, and water.
This latter stream is treated in a chilled separator. The separator
produces an ethanol/benzene-rich stream that is recycled to the
dehydration column. An ethanol/water-rich stream is also produced in the
separator. Ethanol and trace benzene are recovered from this stream in
the benzene recovery column and are returned to the dehydration column.
The separated water is sent to the wastewater treatment facility.
Typically, the byproduct still age from the alcohol stripping column
is treated to recover the solids, rather than used directly or processed
in wastewater treatment. Water is removed from the stream using
centrifugation and evaporation. The water from centrifugation is recycled
to the cooker or evaporated. The solid product contains proteins and dead
yeast and is used as a cattle feed supplement, dried distillers grain
(DD6). The DDG drying operation may be fueled by oil or gas. Process
steam is produced on-site by a boiler, typically oil- or coal-fired.
2.1.1.2 Emissions and Effluents
The majority of the air pollutants from this process are produced
by fuel combustion in the boiler and rotary dryer (see streams 5 and 13 in
2-4
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Figure 2-1) and consist mainly of particulates, SO , and NO .
f\ A
Fugitive hydrocarbon (gaseous and condensed) emissions are produced by
flash cooling, fermentation, alcohol stripping, rectification, -
dehydration, chilled separation, benzene recovery, wastewater treatment,
and rotary drying process (streams 7, 10, 11, 13, 15, 17, 20, 22, and 24).
Fugitive particulates are produced by corn shelling and grinding
(stream 1).
All liquid effluent leaving the plant exits after wastewater
treatment (stream 18). The cooling tower blowdown contributes to the
wastewater. The rectification and benzene recovery columns also produce
wastewater. Equipment washes periodically produce wastewater. Solid
wastes include collected coal dust flyash from the coal-fired boiler,
sludge from wastewater treatment (stream 19), and collected grain dust
from the grinding process (stream 1).
2.1.1.3 Pollution Control Systems
Mechanical particulate collectors or wet scrubbers for flue gas
cleaning are used at the boiler and rotary dryer. Mechanical collectors
are also used to capture and recycle dust emissions from milling.
Condenser vents are used to reduce hydrocarbon emissions from the
fermentation tank, columns, and separator. Condensates from the vents are
returned to the associated processes. Based on measurements at
distilleries, these emissions are minimal and of little concern.
The wastewater treatment system employed is an extended aeration
activated sludge unit. This technology was selected primarily because it
"reflects current operating practices in the beverage-grade alcohol
industry. Mean cell residence times of 20 to 30 days (hydraulic retention
2-5
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time of 18 to 36 hours) are typical for this type of unit with a
biochemical oxidation demand (BOD) removal efficiency of 75 to 79 percent.
2.1.1.4 Liquid and Solid Haste Disposal
The liquid effluent from wastewater treatment is discharged to a
waterway. As stated earlier, the DDG can be used as a cattle feed
supplement. In addition, the collected grain dust from milling can be
added to th DDG. The remaining process solid wastes, coal dust, flyash,
and wastewater sludge, must be disposed of via landfilling or land
spreading.
2.1.1.5 New and Emerging Technologies
It is not possible to fully assess the impacts of new and emerging
technologies on emissions and effluents. However, there are several new
process technologies that could affect the efficiencies and yields of the
ethanol fermentation process and should be noted. For instance, gasoline
has been substituted for benzene as the dehydrating agent and other
dehydrating chemicals are also under investigation. Use of these
alternatives could remove the potential for emissions of benzene, a
hazardous pollutant. Alternate alcohol/solids/water separation
technologies, such as selective adsorption, membrane separation, and
supercritical fluid extraction, are being investigated to replace the
distillation step.
Continuous fermentation with yeast recycle is possible. In
addition, vacuum distillation can be coupled to the process, permitting
continuous alcohol removal from the fermenter. New strains of yeasts and
better saccharification enzymes are being developed to increase yields.
Finally, anaerobic digestion of the still age can be implemented.
This eliminates drier energy consumption and produces methane that can be
2-6
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burned for process steam generation. The still age can also be used
without drying as a feed supplement, further reducing energy consumption
and related emissions. However, the wet still age must be used .immediately
since even short-term storage causes the material to become rancid.
2.1.2 Ethanol from Celluloses
Cellulose is the structural fiber in trees, herbaceous plants, and
paper products. This discussion focuses on corn stover as a
representative cellulosic feedstock.
2.1.2.1 Process Description
Figure 2-2 is a conceptual flow diagram for a typical ethanol from
corn stover process. The process begins by reducing the stover size and
breaking down the cellulose into fermentable simple sugars by acid
hydrolysis. Dilute sulfuric acid (_< 5 percent) is contacted with the
stover to transform the cellulose. This produces furfural and simple
sugars. The solubilized products are separated in a flash distillation
step. The sugars are neutralized to remove the contaminants (lignin,
etc.) and to alter the pH to provide a proper environment for the
fermentation yeast.
The simple sugars are then converted to alcohol and carbon dioxide
by the metabolic processes of the yeasts. The fermented mash
(approximately 10 percent alcohol) is then pumped to the alcohol stripping
column. This distillation column removes the solids and most of the water
to produce a stream containing 80 percent ethanol, 19 percent water, and
about 1 percent impurities (fusel oils and aldehydes).
The product stream is purified in a rectification column, producing
a 95 percent ethanol, 5 percent water azeotrope. The fusel oil and
2-7
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Preparation
s-
Fermentation
-v S~\ /-"\
Distillation
X-N X >.
Dehydration
x~N
Corn I fc
stover
ro
oo
Acid
diiestion
Flash
dfstfllation
Power
plant
3team generation
Inputs and
1 ) Fugitive particulates
2} Dilute sulfuric acid
Coal
Combustion products Including
PH, NOX, SOX
Steam
Captured particulars
Furfural
Yeast
00ฎ
10]
[17
Furfural
distillation
Sludge
clarification
.13)
* Fermentation
Centrifugal
separation
ฉ
Rotary
ป dryer
__^ Alcohol
stripping
Byproduct preparation
9] CO?, uncondensed hydrocarbon emissions
Uncondensed hydrncarbon emissions
II1) Lime
12^ Lime sludge, lignln, iinrescted cellulose,
decomposed suqars
131 Fuel oil
S^
fa ) Uncondensed hydrocarbon emissions
(15J Dried still age
r\T\KO) Uncondensed hydrocarbon emissions
Rectification .
Wastewater
treatment
4
Dehydration
i
(20) *~
Chilled
separation
Benzene
strtnpinq
[21]
MB) Ethanol
M9 Fusel oil. aldehydes
Benzene
Uncondpnsed h^drocar-bon emissions
Treated wastewater
Sludge
ar
V)
3T
H
Figure 2-2. Typical ethanol production from corn stover cellulosic feedstock.
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aldehyde impurities are separated and removed in a side stream. These can
be combined with the final ethanol fuel product.
Dehydration of the ethanol-water azeotrope is necessary to produce
an anhydrous product. A dehydrating agent (benzene) is added to the
azeotrope in the dehydration column. The column produces a stream of
.anhydrous ethanol and a stream containing benzene, ethanol, and water.
This latter stream is treated in a chilled separator. The separator
produces an ethanol/benzene-rich stream that is recycled to the
dehydration column. An ethanol/water-rich stream is also produced in the
separator. Ethanol and trace benzene are recovered from this stream in
the benzene recovery column and are returned to the dehydration column.
The separated water is sent to the wastewater treatment facility.
Typically, the byproduct still age from the alcohol stripping column
is treated to recover the solids, rather than used directly or processed
in wastewater treatment. Water is removed from the stream using
centrifugation and evaporation. The water from centrifugation is recycled
to the fermentation tank or evaporated. The solid product contains
unconverted materials and dead yeast. The solids are relatively low in
nutrient value and are not typically used as a food supplement. The
drying operation may be fueled by oil or gas. Process steam is produced
on-site by a boiler, typically oil- or coal-fired.
2.1.2.2 Emissions and Effluents
The majority of the air pollutants from this process are produced
by fuel combustion in the boiler and rotary dryer (streams 4, 19) and
.consist mainly of particulates, SO , and NO . Fugitive hydrocarbon
^ /\
(gaseous and condensed) emissions are produced by flash cooling,
fermentation, alcohol stripping, rectification, dehydration, chilled
2-9
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separation, benzene recovery, wastewater treatment, and rotary drying
(process streams 9, 10, 16, 17, 19, 20, 22, and 25). Fugitive
participates are produced by stover preparation (stream 1).
All liquid effluent leaving the plant exits after wastewater
treatment. The cooling tower blowdown contributes to the major volume of
wastewater. The rectification and benzene recovery columns and equipment
washes and blowdown from a scrubber also contribute to wastewater. The
distilled furfural can be sold (stream 7). Solid wastes include collected
coal dust flyash from the coal-fired boiler, sludge from wastewater
treatment, and collected stover dust from the preparation process. Sludge
is produced from the neutralization of the hydrolyzed cellulose
(stream 12).
2.1.2.3 Pollution Control Systems
Mechanical particulate collectors and wet scrubbers for flue gas
cleaning are used at the boiler and rotary dryer. Mechanical collectors
are also used to capture and recycle dust emissions from stover
preparation. Condenser vents are used to reduce hydrocarbon emissions
from the columns, fermentation tank, and separator. Condensates from the
vents are returned to the associated processes. Lime addition and sludge
clarification are used to capture the unusable fraction of the hydrolyzed
wood.
The wastewater treatment system employed is an extended aeration
activated sludge unit. This technology was selected primarily because it
reflects current operating practices in the beverage-grade alcohol
industry. Mean cell residence times of 20 to 30 days (hydraulic retention
time of 18 to 36 hours) are typical for this type of unit with a BOD
removal efficiency of 75 to 79 percent.
2-10
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2.1.2.4 Liquid and Solid Waste Disposal
The liquid effluent from wastewater treatment is discharged to a
waterway. The remaining process solid wastes, coal and stover-dust,
flyash, lime sludge, still age, and wastewater sludge (streams 1, 12, 15,
and 24), must be disposed of via landfilling or land spreading.
2.1.2.5 New and Emerging Technologies
There are several new and developing technologies for increasing
the yields and efficiencies of conversion of cellulose to ethanol. For
example, there are many different types of hydrolysis, including weak acid
pretreatment, strong acid hydrolysis, and enzymatic hydrolysis. An
explosive defioration technique to thermo-mechanically break down the
cellulose from its contaminants (lignin) is under development. In
addition, solvent removal of lignin prior to acid digestion is being
investigated. Improved fermentation and alcohol separation technologies
that are applicable to starch feedstocks are also applicable to cellulosic
alcohol production.
2.1.3 Ethanol from Sugars
Sugars (mono- and disaccharides) are present in many foods,
including fruits, sugar beets, sugar cane, and milk. Most sugars can be
converted directly to ethanol by yeast. This discussion focuses on
lactose from the industrial waste cheese whey as a representative sugar
feedstock.
2.1.3.1 Process Description
Figure 2-3 is a flow diagram for an ethanol from cheese whey
"process. The process begins with raw cheese whey, which is a waste
product of the cheese industry. Typical cheese whey consists of water,
lactose, and small amounts of proteins and fats. The fats and proteins
2-11
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ro
i
ro
I
Cheese whey
Powerplant
Inputs and Discharges
Proteins, fats
(T\ Coal
Preparation
Precipitation
3 } Combustion products Including
^ PH, NOX, SOX
1-) Collected partfculates
ฉ
Steam
Frrmrntation
Coolinq
Distillation
Fermentation
Alcohol
Stripping
tj Yeast
j CO?, unconriensed hydrocarbon emissions
9 ) llncondensed hydrocarbon emissions
Gasohol product
Fusel oils, aldehydes
0?1 Uncondensed hydrocarbon emissions
Dehydrnt.ion
Rectification
Wastewater
Dehydration
U?
T
Chilled
separation
Benzene
strippinn
Benzene
HI ) llncondensed hydrocarbon emissions
s Treated wastewster
Sludqe
l ? J Uncondensed hydrocarbon emissions
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are precipitated from the lactose solution by controlled heating and pH
adjustment. This eliminates the need for solids removal in the
distillation operations. The lactose soultion is cooled and sent to the
fermentation tank where it is converted to alcohol and carbon dioxide by
added yeast.
The fermented product (approximately 10 percent alcohol) is then
pumped to the alcohol stripping column. This distillation column removes
the solids and most of the water, producing 80 percent ethanol, 19 percent
water, and about 1 percent impurities (fusel oils and aldehydes).
The product stream is purified in a rectification column, producing
a 95 percent ethanol, 5 percent water azeotrope. The fusel oil and
aldehyde impurities are separated and removed in a side stream. These can
be combined with the final ethanol fuel product.
Dehydration of the ethanol-water azeotrope is necessary to produce
an anhydrous product. A dehydrating agent (benzene) is added to the
azeotrope in the dehydration column. The column produces a stream of
anhydrous ethanol and a stream containing benzene, ethanol, and water.
This latter stream is treated in a chilled separator. The separator
produces an ethanol/benzene-rich stream that is recycled to the
dehydration column. An ethanol/water-rich stream is also produced in the
separator. Ethanol and trace benzene are recovered from this stream in
the benzene recovery column and are returned to the dehydration column.
The separated water is sent for wastewater treatment. Process steam is
produced on-site by a boiler, typically oil- or coal-fired.
-2.1.3.2 Emissions and Effluents
The majority of the air pollutants from this process are produced
by fuel combustion in the boiler (stream 3) and consist mainly of
2-13
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particulates, SO , and NO . Fugitive hydrocarbon emissions are
A ^
produced by flash cooling, fermentation, alcohol stripping, rectification,
dehydration, chilled separation, benzene recovery and wastewater treatment
(streams 7, 8, 9, 12, 14, and 17).
All liquid effluent leaving the plant exits after wastewater
treatment. The cooling tower blowdown contributes to the major volume of
wastewater. The rectification and benzene recovery columns also produce
wastewater. Equipment washes periodically produce wastewater.
Solid wastes include collected coal dust, flyash from the
coal-fired boiler, sludge from wastewater treatment, and precipitated
proteins and fats from the whey (streams 1, 3, and 16).
2.1.3.3 Pollution Control Systems
This process includes the use of mechanical particulate collectors
or wet scrubbers for flue gas cleaning at the boiler. Condenser vents are
used to reduce hydrocarbon emissions from the fermentation tank, columns,
and separator. Condensates from the vents are returned to the associated
processes.
The wastewater treatment system employed is an extended aeration
activated sludge unit. This technology was selected primarily because it
reflects current operating practices in the beverage-grade alcohol
industry. Mean cell residence times of 20 to 30 days (hydraulic retention
time of 18 to 36 hours) are typical for this type of unit with a BOD
removal efficiency of 75 to 79 percent.
2.1.3.4 Liquid and Solid Waste Disposal
The liquid effluent from wastewater treatment is discharged to a
waterway. The remaining solid wastes, coal dust, flyash, and wastewater
2-14
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sludge, must be disposed of via landfilling or land spreading. The
precipitated fats and proteins are also landfilled.
2.1.3.5 New and Emerging Technologies
It is not possible to fully assess the impacts of new and emerging
technologies on emissions and effluents. However, there are several new
process technologies that could affect the efficiencies and yields of the
ethanol fermentation process and should be noted. For instance, gasoline
has been substituted for benzene as the dehydrating agent. Other
dehydrating chemicals are also under investigation. Alternate chemicals
could remove the potential for benzene emissions. Alternate
alcohol/solids/water separation technologies, such as selective
adsorption, membrane separation, and supercritical fluid extraction, are
being investigated to replace the distillation steps.
Continuous fermentation with yeast recycle is possible. In
addition, vacuum distillation can be coupled to the process, permitting
continuous alcohol removal from the fermenter. New strains of yeasts and
better saccharification enzymes are being developed to increase yields.
2.2 ON-FARM ETHANOL PRODUCTION
In general, on-farm ethanol production will use technologies
identical to those used in commercial-scale production. However, the
smaller size of the on-farm process causes some notable differences,
especially in regard to pollution control equipment.
2.2.1 Process Description
In the near-term, on-farm ethanol production will use corn as a
.-feedstock. The process will be identical to the commercial process,
except for the following:
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1. A low-pressure boiler (firetube) will be used to allow easy
operation by a farmer. It will be oil-, gas-, or waste-fired in
most cases.
2. If corn is used as the feedstock, the still age from the alcohol
stripping column will not be dried. It will be used directly as
a cattle feed supplement. This neccesitates immediate usage
since even short-term storage will cause the still age to become
rancid.
3. Wastewater and still age will not be treated on-site.
2.2.2 Emissions and Effluents
The emissions and effluents from the on-farm process will be the same
as in commercial production, except that there will be no drier emissions.
2.2.3 Pollution Control Systems
The on-farm system will be very small and will have few pollution
control systems. The boiler will be uncontrolled because of its small
size. There will not be any condenser vents on the fermentation tank and
distillation/dehydration columns. Also, no dust collection devices will
be used. The wastewater will be discharged to an existing wastewater
system. On-site wastewater treatment will not be available.
2.2.4 Liquid and Solid Waste Disposal
The stillage, although undried, will be disposed of as on-site
cattle feed if feasible. Wastewater will be discharged and not treated
on-site.
2.2.5 New and Emerging Technologies
The new technologies potentially affecting on-farm ethanol
production are the same as those in commercial application, with the
exception of supercritical fluid extraction of ethanol. This process is
2-16
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not applicable to on-farm processes because of its complexity and cost.
Increased automatic control (especially with a continuous fermentation
system) would be a major improvement, but this would not alter the process
or effluents.
2.3 OTHER ALCOHOL FUELS PRODUCTION
The production of methanol and butanol fuels is technically
feasible, although the technologies are not as ready for commercialization
as ethanol production technologies. This section describes the production
of methanol via catalysis of synthesis gas and the production of butanol
via biological conversion.
2.3.1 Methanol Via Catalysis of Synthesis Gas
Methanol is produced by the catalytic reaction of hydrogen and
carbon monoxide at a temperature of approximately 315ฐC and a pressure
of 105 to 350 kg/cm (2H2 + CO"^~^.CH3OH). The hydrogen and carbon
monoxide precursors can be generated in several fashions. The gases are
available from industrial off-gases or from the gasification of
carbonaceous feedstocks. These carbonaceous feedstocks include coal,
lignite, peat, and the celluloses, wood, refuse-derived fuel, and biomass.
The gasification of these feedstocks can occur at different
temperatures and pressures. This discussion concerns itself with
atmospheric pressure, air-fed gasifiers, which have been demonstrated with
all of the carbonaceous feedstocks. The gasifiers reform the carbonaceous
feedstock into a crude gas, consisting mainly of hydrogen, carbon
monoxide, and carbon dioxide. The crude gas is scrubbed to remove
2
.organics and then compressed to approximately 10 kg/cm . The gas is
subsequently passed through a hot potassium carbonate scrubber and a
monoethanolamine scrubber to remove the carbon monoxide.
2-17
-------
The CCL-free gas is treated cryogenically to remove methane,
hydrocarbons, and nitrogen. The gas is compressed to approximately
2
30 kg/cm and reacted over an iron shift catalyst. Water vapor and
carbon monoxide are reacted to form hydrogen. Enough gas is reacted until
the requisite hydrogen-carbon monoxide ratio is reached (2:1).
The COp produced during this shift catalysis is removed in
another potassium carbonate scrubber. The synthesis gas is compressed to
2
approximately 175 kg/cm and fed to the nickel chrome catalytic
reactor. These reactor products are distilled in two columns to remove
the light ends and higher alcohols from the methanol product.
The major effluent from this process is the solid residue from the
feedstock gasification, which contains feedstock inerts and some carbon.
This is disposed of by landfill. The major source of wastewater is from
the hydrocarbon scrubber just downstream of the gasifier. This water
contains particulates as well as hydrocarbons and requires appropriate
wastewater treatment.
There will be fugitive hydrocarbon emissions from the distillation
columns and scrubbers. Condenser vents will be used to control these.
2.3.2 Butanol Production Via Biological Conversion
Butanol can be produced biologically from pentoses in a process
similar to ethanol fermentation. This process is still under evaluation
and development, and only a short discussion of it is possible at this
time.
Pentoses are produced via hydrolysis of pentosans found in
cellulosic wastes or grain. These simple sugars are fermented with a
select strain of yeast that enzymatically converts the five-carbon sugar
into butanol and carbon dioxide. Subsequent process steps refine the
2-18
-------
alcohol and remove the water, solids, and other hydrocarbons. Fuel-grade
butanol is the final product.
The exact process characteristics of this alcohol production
technology are not certain. The process is very similar to ethanol
fermentation from cellulosic feedstocks. Based on this, it is expected
that the emissions and effluents, control technologies, and disposal
characteristics will be similar.
2-19
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SECTION 3
THE STANDARDS SUPPORT SCHEDULE
3.1 DESCRIPTION OF THE SCHEDULE
The heart of an SSP is the schedule showing the temporal
relationships among the various activities required to develop standards
for a source category. Specifically, the schedule shows how lERL-Ci will
support the development of standards by indicating the laboratory's
commitment to carry on various research activities prior to and concurrent
with Program Office dates for the development of standards. As a result
of these efforts, several reports will be prepared and a sampling and
analysis (S&A) program on fuel-grade alcohol production facilities will be
carried out. The timeline for the various studies and the content of each
of the activities are discussed in Section 3.2. Section 3.3 explains the
responsibilities and working interactions between lERL-Ci, Region VII, and
the various Program Offices.
As indicated previously, this SSP was developed with the consensus
of the cognizant Program Offices: OWPS/EGD, OAQPS/ESED, and OSW/HIWD.
Since the original impetus for such a study came from an increase in
requests for permits for fuel-grade alcohol production facilities on the
^farms in Region VII, representatives of Region VII also participated in
the development of the plan. Through a series of meetings the salient
elements and requirements of the research study in terms of Program Office
3-1
-------
needs were discussed. Based on these discussions, the time framework for
the various studies and an S&A program were developed for both commercial
and on-farm fuel-grade alcohol producing facilities. Additionally,
responsibilities for certain elements of the plan were delegated. The
specific details of the time framework of and responsibilities within the
lERL-Ci research program are discussed in Section 3.2.
3.2 PROGRAM SCHEDULE
As a result of a series of meetings among lERL-Ci, the Program
Offices, and Region VII, a program schedule evolved for the research
effort required to establish the need and/or basis for environmental
standards applied to fuel-grade alcohol production. Initially, the
production of ethanol, methanol, and butanol was considered; however, the
current plan has been limited to ethanol production, which will dominate
in the near term. As will be discussed, future consideration will be
given to the other two alcohol fuels.
There are four important phases to this research: (1) information
surveys of the processes, (2) engineering analysis, (3) environmental data
acquisition, and (4) documentation including a Pollution Control Guidance
Document (PCGD), a Health and Ecology Effects Report, and an Environmental
Assessment Report (EAR). Based on the above, the Program Offices will
determine the appropriate standards as required. Figure 3-1 shows the
schedule for the various activities and the relationship agreed upon by
the agency offices.
The activities discussed in this SSP are limited to the production
of ethanol; they focus on processes using grain as a feedstock, but also
include those which use industrial waste stocks, such as cheese whey and
cellulosic materials as inputs. The program distinguishes between
3-2
-------
1979
1980
1981
1982
FMAMJJASONo'jFMAHJJASONB.JFM
00
OJ
I Kansas City Htg. 1 Transcripts
Overview
Starting In 10/78 Distillery Survey
SSP II
3-cL
RegionVII Activities
BATF
Coordinate
Oept. Agr./Ed.
Ext. Program
On-Farn Manual
lERL/Program Office/Region VII Mtgs.
S1A at Midwest Solvents
a Nov 14 Htg.
b Dec 5 Mtg.
e Dec 20 Mtg.
SiA IERL On-Farm
S1A IERL Comnercial
Program Office
Comnercial SAA
EGO Std. Dev./OSW/OAQPS
Std. Eval.
JปSOND.JFMAMJJASON
(see Fig. 3-2)
SSP 12
ICRL/Prog. Oft.
Htus.
ion Control
ce Document
IERL SSA Program | Qฐ]J"JJฐn
Health t Ecology
Effects Report
Environmental
Assessment Report 1
Control
?Qi;i/ment
Health ft Ecology!
Effects Report I
}
Environmental Assessment Report 1
Figure 3-1. IERL program schedule for gasohol.
-------
commercial production and on-farm production for private use by an
individual farmer. The latter appears to be increasingly important as
more farmers are turning to alcohol fuel to ensure an adequate energy
supply for their needs.
The following briefly describes each of the elements of the Gasohol
program shown in Figure 3-1.
Information Surveys
The Gasohol Overview Report is an update of similar
overview reports by the Office of Technology Assessments
(OTA) and the Department of Energy (DOE), but from an EPA
perspective. This report focuses on an examination of the
state-of-the-art technology, the economics, environmental
issues, impediments to wide-spread use, and Federal
initiatives to promote gasohol's use.
~ A review of major existing ethanol production facilities,
listing the major U.S. producers of ethanol, whether the
product is used for fuel or not (i.e., includes some
distilleries), and the salient information about each
operation.
The transcript of a meeting at Region VII, Kansas City,
presents an overall discussion and information transfer on
the subject of gasohol, including environmental, economic,
and energy issues.
Engineering Analyses
IERL has previously supported a study at Midwest Solvents
(MWS) plant. Information developed in that study was the
basis for the analysis to determine the extent of the
3-4
-------
potential environmental problems associated with fuel-grade
alcohol production and the media specific priorities and
analytical detail required in continued research directed
toward these facilities.
-- Based on the review of major existing ethanol production
facilities, the important characteristics of near-term
technologies and feedstocks were determined and typical
facilities identified for continued study.
Environmental Data Acquisition
An S&A program has been planned for each of the three
media: water, solid, and air discharges. The IERL S&A
program was developed in consensus with the three Program
Offices and Region VII. The data provided by this program
will be used in the preparation of a PCGD see below
and will be of assistance in permit writing and standards
development. The choice of commercial facilities resulted
from a review of the existing facilities listed in the
ethanol production survey. The facilities selected by IERL
and the Program Offices are shown in Table 3-1. It should
be noted that the MWS plant had previously been studied by
IERL, except for trace metals. Additional samples will be
obtained by Region VII and analyzed for trace metals by
EGD. Two on-farm facilities will be investigated in
addition to the commercial plants. Table 3-2 lists agency
office responsibilities by activity and agency office. The
test matrix is shown in Table 3-3. The bases for this
matrix are the results obtained at MWS.
3-5
-------
TABLE 3-1. SUMMARY OF S&A INTEREST IN ALCOHOL PRODUCTION PLANTS BY
PROGRAM OFFICES/ORD
Plant
Midwest Solvents
Georgia-Pacific
American Distilling
Milbrew
Muscati ne
Natick
On-Farm (2)
Program Office/ORD Involvement3
OWPS/EGD
C*
I
I
I
I
I
OSW/HIWD
C
NI
I
I
I
I
OAQPS/ESED
C
NI
C
I
I
NI
ORD/IERL
C*
I
I
I
I
I
I
aLegend
I Interested
NI No interest
C Sufficient testing completed
* Need trace metal analysis for completion; to be
sampled by Region VII and analyzed by EGD
3-6
-------
TABLE 3-2. AGENCY OFFICE RESPONSIBILITIES
Activity
Responsible Agency Office
Overview Report
Alcohol Production Survey
Information Transfer Meeting at Kansas City
S&A Study at MWS
SSP for Ethanol Production
(Meeting of Agency Offices)
S&A On-Farm Facilities
S&A Commercial Facilities (Air)
S&A Commercial Facilities (Water & Solids)
Standards Development
Regional Enforcement Model
Environmental Operation Manual
PCGD
EAR (with Health and Ecology Effects Report)
Continued Research
ORD/IERL-Ci
ORD/IERL-Ci
ORD/IERL-Ci & Region VII
ORD/IERL-Ci
ORD/IERL-Ci
ORD/IERL-Ci & Region VII
ORD/IERL-Ci
OWPS/EGD
Program Offices
Region VII
ORD/IERL-Ci & Region VII
ORD/IERL-Ci
ORD/IERL-Ci
ORD/IERL-Ci
3-7
-------
TABLE 3-3. SAMPLING AND ANALYSIS PROGRAM MATRIX
I. On-Site Sampling/Analysis*
Solids: Two locations -- dryer waste, coal
Sample dryer waste five times/day for 3 days, therefore,
15 samples or three daily composites
Sample one coal /test
Liquids: Four locations -- influent, effluent, sludge, makeup
Each location sampled five times/day for 3 days,
therefore,
five samples/day x 3 days/plant x four locations =
60 samples or three daily composites at each location
Air: Two locations (i.e., dryer vent and grain handling)
Test each location once/day for 3 days
Test Type Method
Parti cu late EPA Method-5
NOX EPA Method-7
EPA Method-6
CO, C02, 02 EPA Method-3
Hydrocarbons GC w/FID
II. Laboratory Analysis
Solid Streams: Phenols, Cyanides, Ammonia Sulfate, Sulfites,
Nitrates, 22 Metals, Including Solid Extraction
Organ ics by GC/MS, Acid Fraction, Base Neutral
Fraction, Pesticides
Liquid Stream: Biological Oxygen Demand (BOD), Chemical Oxygen
Demand (COD), Total Organic Carbon (TOC), Total
Suspended Solids (TSS), Phenols, Cyanides, Ammonia
Nitrates, Sulfates, Sulfites, 22 Metals
Organics by GC/MS, Volatile Organic Analysis (VOA),
Acid Fraction, Base Neutral Fraction, Pesticides
Air Stream: Particulate Sulfates, Nitrates
*The sample frequency is site specific; the above is only typical of the
level of effort.
3-8
-------
-- The sampling and analysis will be coordinated with the
Program Office efforts. Figure 3-2 shows a schedule for
effluent guidelines development leading to the -
establishment of water effluent standards, if warranted.
OSW will establish priorities based on this S&A program
regarding future standards that may be enforced through
their permitting system. OAQPS will use the results to
establish the need for developing a New Source Performance
Standard (NSPS) for ethanol production. At present,
however, they do not anticipate a need for an NSPS for air
emissions.
Documentation
The PCGD report will define the processes currently in use
(both commercial and on-farm), characterize the process
flow and emission streams, identify options for management
and control of waste streams, and provide information on
expected environmental control costs. The PCGD will be
based on the results of the S&A program and the engineering
analyses. As shown in Figure 3-2, EGD plans to publish a
draft Development Document (DD) based on their standards
development activities prior to the planned start of the
PCGD. Before actually starting the PCGD, the DD will be
reviewed to determine its adequacy in replacing
(eliminating the need for) the PCGD.
-- The Environmental Operations Manual will provide guidance
to the BATF on what environmental questions should be
examined when issuing their permit for a still and
3-9
-------
Task order
awarded
Plan
approval
Profile
(1/2/80) -(1/18/80) (2/7/80)
Sampling Completion of
plant Sampling sampling S
selection initiated analyses
(3/1/80) \ (3/21/80)(6/15/RO) \
Technology
selection
(2/21/BO)
u>
Subcategory
selection/
paragraph/
BCT test 8J
\ Field
\ Assessment
/ of technology
/ (hinlnflical )
(3/21/80)
In-plant
. treatment
\ assessment
A\ U/ JU/ '"J > \
Review'
i.uii^nn.c i Draft bv
innvrnd DD D0
(6/15/BOJJ(7/21/BOj (8/21/fl0)
, (.1/21/80) II
\ 308 data / /
, \ collection / I
\ (4/15/80)
\ Initiation
\ of cost
I manual
1 Final
/ Site cost
J verification report
I
Final
[)[) RMP
(11/30/80)
(3/21/ftO)
(6/2/r,n)
Approximately 10 plants will be sampled.
One project officer full time is required.
Figure 3-2. Gasohol effluent guidelines development.
-------
practical advice to the farmers on how to manage wastes
from their on-farm processes. As part of this activity,
Region VII will establish a liaison with the Department of
Agriculture/Educational Extension to develop a program
assuring farmer awareness of the environmental impacts and
proper operational practices to acceptably minimize these
impacts. It is also planned to monitor the initial on-farm
installation through a cooperative effort by the BATF, who
inspects facilities before start-up as part of their permit
process. The manual and protocol established by Region VII
will be used as a model for other Regions.
~ The results of the IERL program will form the basis for the
preparation of a Health and Ecology Effects Report which is
one of the essential elements of an EAR. Environmental
Assessment Reports are designed to provide a comprehensive
overview for a given technology. An EAR dealing with
alternative modules that comprise a given system within a
given technology is prepared by drawing together technical,
economic, and environmental impact data for that system.
The major topics addressed are process description,
characterization of input materials, products and waste
streams, performance and cost of control alternatives,
analysis of regulatory requirements, and environmental
impacts.
As a result of the meetings between lERL-Ci, the Program Offices,
and Region VII, responsibilities for the various activities identified in
this SSP were assigned. E6D will carry out the solid and liquid waste S&A
3-11
-------
program for the commercial units. Two of the commercial units will be
sampled for air emissions, and a complete sampling program for solid,
liquid, and air effluents will be carried out at two on-farm facilities.
Responsibility for these tests lies with lERL-Ci. A manual will be
produced to serve as a guideline to the farmers who construct or install
fuel-grade alcohol production facilities and to the Bureau of Alcohol,
Tobacco and Firearms (BATF) who issues permits with respect to BATF
regulations. The preparation of this manual will be the responsibility of
IERL in conjunction with Region VII. Region VII is also responsible for
developing cooperation between the Department of Agriculture/Educational
Extension and the BATF. Through the establishment of these contacts and
the development of a regulatory procedure, Region VII will serve as a
model region with respect to the control of on-farm facilities.
As stated previously, the IERL program has focused on current
technology for the production of ethanol. As the alcohol fuels industry
progresses, additional technologies and feedstocks will be developed for
ethanol production, and other alcohols, e.g. methanol and butanol, may
become more important. For these reasons, the IERL program will continue
beyond that currently planned in the SSP. Since several of the
developments indicated are expected to be, at least, in pilot-plant stage
by 1981-1982, it is recommended that a second SSP on fuel-grade alcohol
production be prepared in April 1981, followed by a second PCGD presenting
an engineering analysis of emerging production capabilities.
3.3 RESPONSIBILITIES AND WORKING INTERACTIONS
The responsibilities and working interactions that have been
developed under this SSP stem from the overall mission of each group
involved. These are shown in Table 3-3. ORD's role is to respond to the
3-12
-------
needs of the Program Offices to obtain the data necessary for those
offices to establish appropriate standards. In addition, they are to
provide guidance to the users of alcohol facilities, the Regions, and the
Program Offices to quantify effects beyond those required by the Program
Offices in order to fully understand the environmental impact of the
facilities under study. The responsibilities developed during the
organization meetings clearly respond to these missions.
lERL-Ci is responsible for the generation of the background data
and the appropriate S&A program, both of which will lead to the generation
of a PC6D and an EAR. Additionally, at the termination of the current
SSP, IERL will be involved in looking at the emerging technologies for
fuel-grade alcohol production. Should these appear important, more SSP's
and/or PCGD's will be generated.
The Program Offices are required to establish the appropriateness
of emissions standards to assure that no significant environmental damage
will result from the facilities under study. They also must develop data
of a type and quality needed for legally defensible standards and to
ultimately promulgate the standards required. Since OAQPS does not
anticipate needing standards in this area, their responsibilities to the
program are minimal. However, for solid and liquid wastes, EGD will
assume the responsibility for carrying out a portion of the ORD/IERL-Ci
S&A program. These activities, occurring at the commercial facilities
identified, result from general interest in promoting the new development
of these sources and the immediacy of obtaining data to assess their
impact.
3-13
-------
The Regions have the responsibility of enforcing the standards,
normally through permits (such as under the National Pollution Discharge
Elimination Systems, or NPDES, for sources discharging a liquid), and
putting into place mechanisms to alert the EPA to potential problems due
to the proliferation of fuel-alcohol facilities. As part of this role,
they are developing liaisons with both the Agricultural Department/
Educational Extension and the BATF, assisting with the development of the
Environmental Operations Manual, and identifying the on-farm facilities to
be studied. These liaisons and the resulting mechanisms developed in
Region VII will serve as a model for other regions dealing with the
buildup of fuel-grade alcohol facilities on the farm.
The organizational units involved in this study have designated
individuals as principal contacts for the program. Table 3-4 lists the
organizational unit, the responsible person, and the address and phone
number for that person.
3-14
-------
TABLE 3-4. ALCOHOL FUEL/ENERGY COORDINATORS/CONTACTS
ORD/IERL-Ci
OAQPS/ESED
OWPS/EGD
OSW/HIWD
ORD/EPD
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Robert Mournigham
Dave Markwordt
John Lum
Yvonne Carbe
David Berg
Dick Keppler
Paul Pruchan
Bernard Purinski
Frank Redmond
Jim Phillips/Cliff Risley
John Accardi
Charles Hajinian
Terry Thoem
Carl Kohnert
George Hofer
(513) 684-4334
(919) 629-5371
(202) 426-2707
(202) 755-9190
(202) 755-0205
(617) 223-3477
(212) 264-7665
(215) 597-9944
(404) 257-3004
(213) 886-6054
(214) 729-2650
(816) 758-2921
(303) 327-5914
(415) 556-7858
(206) 399-1125
3-15
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SECTION 4
DISCUSSION OF THE STANDARDS SUPPORT PLAN ELEMENTS
To provide a perspective on the future importance and potential
environmental impact of this source category, the status and projected
development of the alcohol-for-fuels industry is described in
Section 4.1. Regulatory requirements for EPA and the Bureau of Alcohol,
Tobacco and Firearms (BATF) that could apply to these sources under
existing statutes are discussed in Section 4.2, as are the responses of
these agencies to these legislative mandates.
4.1 ALCOHOL FUELS DEVELOPMENT
Alcohol fuels represent an important source of domestic renewable
energy. The use of alcohol in motor vehicles is not a new technology.
The Model T Ford was designed to run on alcohol, gasoline, or any mixture
of the two fuels. However, as gasoline became relatively inexpensive and
plentiful, the market for alcohol fuels diminished. The recent increases
in the price of petroleum products and the planned reduction of United
States dependency on foreign sources of energy has led to an increase in
the demand for alcohol fuels. (For Section 4.1, see References 4-1, 4-2,
and 4-3.)
-4.1.1 Potential Oil Savings from Alcohol Fuels
The amount of oil that alcohol fuels can displace is equal to the
amount of oil they save or replace in combustion processes minus any
4-1
-------
difference in the amount of oil used to produce each fuel. Two alcohol
fuels, ethanol and methanol, are commercially available today. In the
near term (1980 to 1985), ethanol will be the alcohol fuel available in
significant quantity for use in the commercial fuel market. A mixture of
10 percent ethanol and 90 percent gasoline, called gasohol, can be used in
motor vehicles without engine modifications.
Ethanol used in gasohol not only extends gasoline supplies by
replacing 1 gallon of gasoline for every 10 gallons of fuel consumed, but
also acts as an octane enhancer. Since the presence of alcohol in gasohol
increases the octane rating, the reforming requirements for the production
of the unleaded fuel are reduced. This reduction increases the production
yield and decreases the amount of heating oil required in the reforming
process. The combined effect of these two savings further increases
alcohol's value relative to gasoline. Industry estimates that these
effects merit a premium of roughly $0.10 per gallon of alcohol.*
4.1.2 Supply and Demand
Current demand for gasohol is increasing. The National Gasohol
Commission estimates that the number of retail outlets selling gasohol
have increased from 500 in March 1979 to about 2,000 in October 1979.
Three factors contribute to the increase in demand for gasohol. These are:
t Driver perceived improved vehicle performance from higher
octane ratings than those of unleaded gasolines
Consumer preference (particularly by residents of farm states)
for vehicle fuels derived from renewable agricultural products
*At 1979 prices.
4-2
-------
Lower selling price at the pumps than higher octane unleaded
gasolines because the $0.04 Federal tax is not applied to
gasohol
Government incentives including eligibility of alcohol fuels
for DOE entitlements worth approximately 2 to 3 cents per
gallon. U.S. Department of Agriculture has made loan
guarantees available for alcohol pilot plants.
The U.S. is currently producing 80 million gallons of ethanol for
fuel use per year (4,000 barrels per day). By 1982 ethanol production is
expected to reach 300 million gallons per year (20,000 barrels per day).
Increased ethanol production will come primarily from excess distillery
capacity and expansions in currently operating facilities. By 1985, if the
proposed Federal incentives materialize, ethanol production could reach 500
to 600 million gallons per year. This level of production is beyond the
capacity of existing facilities and would occur only with the construction
of new facilities. The design, construction, and startup of a new ethanol
facility can take 1 to 3 years, depending on the size of the plant.
Wine producers throughout the United States are currently
investigating the feasibility of producing fuel-grade alcohol. At this
time, it is not possible to accurately project what impact these facilities
would have on the alcohol fuels industry. However, a number of refineries
have the capacity to produce 100 million gallons of alcohol per year.
Beyond 1985 ethanol production will depend on:
The availability of inexpensive feedstocks
New technological developments that decrease capital and energy
requirements and, therefore, the cost of conversion
ง The relative cost of competing fuels
4-3
-------
Methanol derived from coal is also an attractive alternative for
extending U.S. supplies of high quality liquid fuels. However, it is
unlikely that methanol will be used extensively before 1990, when new
conversion facilities should be operating. At present economies of scale,
profitable plants must be large, producing 20,000 to 50,000 barrels per
day. A plant of this size requires an investment of $500 million to
$1 billion and can take up to 4 years to build. Once such facilities are
in operation, methanol could be produced more economically and in larger
quantities than ethanol.
Originally methanol was made from wood, hence the common name wood
alcohol. Today methanol is made almost entirely from natural gas and
oil. In 1976 the U.S. produced 1.2 billion gallons of methanol, primarily
from these fossil fuels. In the future production of methanol will most
likely come from coal, wood, and agricultural residues.*
Methanol has essentially the same octane enhancing characteristics
as ethanol. However, the use of methanol in quantities greater than
several percent requires modifications to existing engines.
In the long term (late 1980's and beyond) methanol is being
considered for use in gas turbines and may also be used as a petrochemical
feedstock. Diesel engines, boilers, and utility fuel cells may be
potential future uses for methanol, but additional research and
development are required.
*Methanol produced by the liquefaction of coal and gasoline produced from
such coal-derived methanol are under investigation by EPA as part of the
Indirect Liquefaction Program. These processes will be the subject of
separate PCGD's and EAR'S.
4-4
-------
If adapting motor vehicles and/or distribution systems to
accommodate methanol proves to be difficult, it may be converted directly
to high quality gasoline or MTBE, which is chemically closer to
petroleum. Methanol/ethanol/gasoline blends are also under consideration;
however, at this point it is impossible to project what the proportions of
each fuel might be and what the market penetration will be in 1985 and
beyond.
4.1.3 Biomass Availability
Approximately 800 million dry tons of biomass are available
annually for alcohol production. By the year 2000 it is projected that
over 1.1 billion tons will be available. Available feedstocks are
generally those feedstocks that are noncompetitive. For example,
"available wood" does not include wood that would be used for lumber or
paper. Available grain crops are residues and grains not needed for
projected demands of food, feed, or for export. A breakdown of the
projected biomass resource availability is shown in Table 4-1.
In order to estimate the amount of alcohol fuels that could be
produced from available feedstocks, it is necessary to consider the
conversion processes currently demonstrated, those expected to be
demonstrated in the future, and the resulting conversion efficiencies of
each process.
Conversion of all grains, sugar crops, and food processing wastes
could yield a maximum of 4.4 billion gallons of ethanol per year by 1980,
rising to 12.2 billion gallons in the year 2000. Ethanol production
potential could be greatly increased by conversion of wood, agricultural
residues, and municipal solid waste (MSW) to ethanol. In 1980 ethanol
4-5
-------
TABLE 4-1. PROJECTED MAXIMUM U.S. BIOMASS AVAILABLE FOR ALCOHOL PRODUCTION
(million dry tons per year)
en
Blomass Source
Wood a
Agricultural
residues
Grains^
Sugars'*
Municipal solid
waste (MSW)
Food processing
wastes
Total
1980
Quantity
499
193
38
86
6
822
Percent
61
23
5
--
10
1
100
1985
Quantity
464
220
38
8
92
7
829
Percent
56
26
5
1
11
1
100
1990
Quantity
429
240
28
69
99
8
873
Percent
49
28
3
8
11
1
100
2000
Quantity
549
278
23
172
116
10
1,148
Percent
48
24
2
15
10
1
100
aAssumes wood from s1v1cultura1 energy farms starting in 1995
''Estimates for grains and sugars assume development program to establish sweet sorghum as a cash crop
-------
production could reach 39.2 billion gallons per year, rising to
54.0 billion gallons per year by 2000.
Table 4-2 shows the projected maximum alcohol production from U.S.
biomass resources. It is important to note that the ethanol and methanol
quantities cannot be added because the same feedstock resources are
assumed to be used for one or the other. Conversion of wood, agricultural
residues, and MSW could produce 128.3 billion gallons of methanol by
1980. However, due to the lack of existing facilities, it is highly
unlikely that there will be significant methanol production before 1990.
In the year 2000 sufficient biomass could be available to produce either
54.0 billion gallons of ethanol or 154.7 billion gallons of methanol.
These figures represent a physical ~ though not necessarily economic
possibility of alcohol fuels production. Actual alcohol fuels production
will be considerably less than physical capacity.
4.2 REGULATORY REQUIREMENTS AND PLANS
4.2.1 Bureau of Alcohol, Tobacco, and Firearms
The BATF is responsible for administering the laws in the Internal
Revenue Code relating to distilled spirits (alcohol). The code
(26 U.S.C., Section 5002) defines distilled spirits as those substances
known as ethyl alcohol, ethanol, or spirits of wine, including all
dilutions and mixtures thereof, from whatever source, by whatever process
produced. Although these laws relate primarily to the beverage alcohol
industry, all producers of alcohol must comply with them. The primary
responsiblity of BATF is to protect revenue. (For Section 4.2.1, see
References 4-4 and 4-5.)
There are two types of distilled spirits plants (DSP's) currently
authorized by law: commercial DSP's and experimental DSP's. Under the
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TABLE 4-2. PROJECTED MAXIMUM ALCOHOL PRODUCTION FROM U.S. BIOMASS RESOURCES
(billion gallons per year)
oo
Blomass Source
Wood a
Agricultural
residues
MSW
Subtotal
Sugars
Grains
Food processing
wastes
Subtotal
Total
1980
Ethanol
23.5
9.1
2.2
34.8
3.9
0.5
4.4
39.2
Methanol
86.3
33.4
8.6
128.3
--
128.3
1985
Ethanol
21.8
10.3
2.3
34.4
0.4
3.8
0.6
4.8
39.2
Methanol
80.2
38.1
9.2
127.5
--
127.5
1990
Ethanol
20.2
11.3
2.5
34.0
3.7
2.8
0.7
7.2
41.2
Methanol
74.2
41.5
9.9
125.6
125.6
2000
Ethanol
25.8
13.1
2.9
41.8
9.0
2.3
0.7
12.2
54.0
Methanol
95.0
48.1
11.6
154.7
154.7
-------
law, a commercial facility can produce beverage or industrial alcohol.
Qualification as a commercial facility requires registering the plant,
obtaining an operating permit, filing a bond, having a continuous and
closed distilling system, and providing adequate facilities for all
operations including production, warehousing, denaturation, and bottling.
Extensive requirements also govern the location, construction,
arrangement, and protection of the facility. These commercial facilities
are areas under direct onsite supervision by BATF inspectors. The law
also requires that in order for alcohol to be removed from the facility
free of tax, it must be denatured; this denaturation renders the alcohol
unfit for beverage use.
The second type of DSP, the experimental facility, is authorized by
law to produce alcohol for experimental or developmental purposes only; no
alcohol may be sold or given away. Generally the duration of the
operating permit is 2 years. Because of these limitations, the
experimental DSP is not subject to the extensive controls and requirements
mandated for a commercial facility.
In the first 7 months of 1979, BATF received over 2,000
applications for experimental DSP's. All of these applications were for
production of fuel-grade alcohol, and most were by individuals who wanted
to produce fuel-grade alcohol for their personal use. Although it is not
clear if the use of the experimental provision was intended for the
production of fuel-grade alcohol, BATF has moved to approve these
applications since there is no other provision under current law, and they
do not wish to hinder the production of fuel-grade ethanol.
In an effort to provide a long-term solution to regulation of the
production of fuel-grade alcohol, BATF has presented to Congress changes
4-9
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to the Internal Revenue Code. The submitted proposal will provide BATF
with the flexibility required to meet the needs of the alcohol fuels
industry. The proposed changes establish a third type of DSP, the fuel
producer.
Under the proposed plan, the fuel producer will be regulated in
direct proportion to the danger of loss of revenue, based on production.
There will be three categories, or sizes, of producers. They are:
Small producers ~ producing less than 5,000 (100 proof)
gallons of alcohol per year
Medium producers producing less than 100,000 (100 proof)
gallons of alcohol per year
t Large producers ~ producing over 100,000 (100 proof) gallons
of alcohol per year
While specific regulatory controls will vary at each level of
production, all fuel alcohol plants will be required to: file a
simplified application; denature their alcohol; maintain security
necessary to prevent diversion of alcohol to uses other than fuel; and
maintain limited records with respect to production and disposition of the
alcohol. The small producer would not be required to file a surety bond,
but the medium and large producers will.
Commercial distillers are currently required to denature alcohol
using specified formulae requiring substances such as gasoline, kerosene,
and other chemicals. Denaturation must be conducted under the direct
supervision of BATF inspectors or through metered systems. Under the
proposal, BATF will work with the fuel producer to develop an acceptable
formula that will meet the needs of the individual producer.
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As previously mentioned, the primary responsibility of BATF is to
protect revenues. However, BATF has certain responsibilities under the
National Environmental Policy Act (NEPA) of 1969, the Federal Water
Pollution Control Act of 1972 (FWPCA) as amended in 1977, and the National
Historic Preservation Act (NHPA) of 1966 as amended. BATF has published a
handbook on environmental protection that serves as a guideline for BATF
personnel to ensure compliance with the above mentioned laws. The IERL
program for gasohol calls for publication of an Environmental Operations
Manual to guide BATF as to what environmental questions to examine when
issuing permits for a DSP. In practice it will also serve as a guide to
farmers on how to manage wastes from their on-farm processes. This manual
will be a cooperative effort between BATF and EPA.
4.2.2 Office of Air Quality Planning and Standards
The Clean Air Act (CAA) as amended in 1977 is the legal authority
for the air pollution control program. The OAQPS is responsible for
administering the provisions of the CAA for control of air pollutants from
stationary sources. The objective of the CAA is to achieve and maintain
air quality sufficient to protect public health and welfare, including the
maintenance of low pollutant concentrations in currently "clean" areas.
The enactment of the act provided the basis for a series of national,
state, and local actions designed to protect air quality and limit the
emissions of certain air pollutants. In addition to any regulations
developed independently by state and local authorities, the following
federally mandated regulations could apply to the alcohol fuels industry:
National Ambient Air Quality Standards (NAAQS)
t State Implementation Plans (SIP's)
New Source Performance Standards (NSPS)
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Nonattainment New Source Review (NSR)
Prevention of Significant Deterioration (PSD)
(For Section 4.2.2, see Reference 4-6.)
4.2.2.1 National Ambient Air Quality Standards and State Implementation
Plans
National Ambient Air Quality Standards are intended to protect
health and welfare by specifying maximum allowable ambient pollutant
concentrations. To date NAAQS have been promulgated for sulfur oxides,
particulate matter, carbon monoxide, photochemical oxidant, lead,
hydrocarbons, and nitrogen oxides. Each state must then develop an
implementation plan outlining the state's strategy for attaining and
maintaining the NAAQS. The SIP for a particular pollutant includes
regulations as needed on new and/or existing sources to achieve sufficient
emission reductions to attain and maintain the NAAQS. It is, therefore, a
plan for implementation, maintenance, and enforcement of emission
limitations and other measures for particular sources.
4.2.2.2 New Source Performance Standards
Under Section 111 of the CAA, EPA is directed to establish NSPS for
new and modified stationary sources deemed to have a significant impact on
health and welfare. These standards are nationally applicable direct
emission limitations for specific source categories (e.g.,
fossil-fuel-fired steam generators). NSPS regulations require emission
reductions achievable through application of the best demonstrated
continuous control technologies taking into account non-air quality
factors such as energy requirements and the cost of achieving such
reductions.
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By 1982 NSPS are to be established for all categories of major
sources sources with the potential to emit more than 91 Mg (100 tons)
per year. EPA may, however, develop standards for sources emitting less
than that amount, especially for certain minor sources that together
represent a large quantity of emissions.
4.2.2.3 National Emission Standards for Hazardous Air Pollutants
Section 112 of the CAA requires EPA to establish National Emission
Standards for Hazardous Air Pollutants (NESHAP's}. NESHAP's are specific
emission limitations applicable to any new source or modified existing
source. A hazardous air pollutant is defined as a pollutant for which no
ambient air quality standard has been set, but which may cause or
contribute to an increase in mortality or serious illness. NESHAP's have
been established for asbestos, beryllium, mercury, and vinyl chloride. By
February 1980 the proposed NESHAP for benzene will be complete.
4.2.2.4 Nonattainment and New Source Review
A major new source planning to build a facility or modify an
existing one in a region where an ambient standard is being exceeded
(called a nonattainment area) must obtain a New Source Review (NSR)
permit. To issue the NSR permit, the state must show that the total
emissions from all sources in the area, including the proposed new one,
will be sufficiently less than the total emissions due to all existing
sources. In addition the new source must use controls that reduce
emissions as much as required by the most stringent limitation in any SIP
or as obtained in practice called Lowest Achievable Emission Rate
(LAER). LAER determinations do not take cost into account as in NSPS and
BACT (see Section 4.2.2.5).
4-13
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4.2.2.5 Prevention of Significant Deterioration and Best Available Control
Technology
While the purposes of nonattainment provisions and the SIP are to
attain and maintain standards, the objective of PSD is to prevent
significant deterioration of air that is already cleaner than NAAQS.
Under PSD, all areas in the U.S. meeting air quality standards are
classified Class I, Class II, or Class III, with varying limits on
increased pollutant levels.
Increases in pollution are restricted by numerical limitations
called increments. Each increment is a numerical definition of the amount
of additional pollution allowed through the combined effects of all new
growth in a particular area.
At the present time EPA is considering alternatives to the
increments approach used to control emissions of SO^ and particulate
matter. It is expected that PSD regulations for other criteria pollutants
will be promulgated in 1981.
A new source entering a PSD area must use the Best Available
Control Technology (BACT) in order to minimize air quality impact. BACT
determinations, which include cost and energy trade-offs, are made by the
states on a case-by-case basis. If an NSPS exists for a source category,
the BACT emission level must not exceed the NSPS limit.
4.2.2.6 Regulatory Decision Making Process
Figure 4-1 shows the analysis and decision making process used by
EPA in selecting the preferred regulatory approach for air emissions from
stationary sources. The initial decision is based on health and
ecological effects, requiring that atmospheric emissions data be known.
4-14
-------
Prob1 em
Assessment
Preferred
Regulatory
Approach
Are in.) )or sutlorury
v>ut i t"i controlI
life -HIM' u* (.ontrot of
Oilier uu||ut.int*?
Can |>ruU'iti(in
of ht>dlth be justified
under Section II??
Figure 4-1. Preferred standards path analysis flow chart for
air quality programs.
-------
If these emissions are found to cause adverse affects, a branching chain
of possible actions based on specific questions follows. Information is
also needed on available control technologies (if known) and their
performance.
4.2.2.7 Current Regulations
The major potential sources of air pollution from alcohol fuel
production are discussed in Section 2. There are no federal or state air
regulations that specifically address these emissions. Although federal
regulations do exist for particulate, SCL, and NO emissions from
Lm Ab
boilers greater than 73 MW (250 x 10 Btu/hr) heat input, the boiler in
a typical alcohol plant producing 20 million gallons is less than half
that size. In the future, emissions from industrial boilers, whether they
are fossil-fuel-fired and smaller than 73 MW (250 x 106 Btu/hr) heat
input or non-fossil-fuel-fired and of any size, will be covered by NSPS
requirements currently being generated by EPA. There are also federal
opacity standards for dryers, grain elevators, truck or railcar loading,
and other grain handling operations that might apply to alcohol fuels
production. A number of states have emission standards for particulates
from industrial incinerators, dryers, and steam generating equipment.
If the fugitive emissions of benzene from the benzene dehydration
process are found to be significant, other processes such as using ethyl
ether and hexane can be implemented. The EPA is currently working on a
NESHAP standard for benzene; it is unclear at this time what effect this
standard will have on the use of benzene to produce alcohol.
Although none of these regulations apply specifically to the
alcohol fuels industry, regulations governing specific emissions from a
4-16
-------
particular piece of equipment would probably be applied to such equipment
as it is used in alcohol fuels production.
4.2.2.8 Regulatory Plans
At this time OAQPS does not foresee any new regulatory actions
directed specifically toward controlling air emissions from facilities
producing fuel grade alcohol. OAQPS will participate in a sampling
program coordinated by IERL. OAQPS will use the results of this program
in the analysis scheme depicted in Figure 4-1 to establish if there is a
need to institute the NSPS process of alcohol fuels production.
4.2.3 Office of Water Planning and Standards
The FWPCA of 1972, as amended* provides the statutory authority for
the regulatory programs of OWPS. The major objective of the CWA is to
restore and maintain the chemical, physical, and biological integrity of
the Nation's waters.
The regulatory mechanisms authorized by the CWA that could be
applied to control effluents from alcohol fuels production are as
follows. (For Section 4.2.3, see References 4-7 and 4-8.)
4.2.3.1 Effluent Limitations
Section 301 provides for the establishment of nationally applicable
effluent limitations on an industry-by-industry basis. These effluent
limitations, with minor exceptions, establish a nationwide base level of
treatment for existing direct discharge sources in every significant
industrial category. These limitations are to be accomplished in phases.
*The Federal Water Pollution Control Act Amendments of 1972, (PL 92-500)
further extended the scope of the FWCPA of 1965, as previously amended
in 1966 and 1970. New anmendements to this legislation, the Clean Water
Act (CWA) of 1977 (PL-92-217) were signed into law in December 1977.
4-17
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The first phase of treatment requires application of the Best Practicable
Technology (BPT). BPT has been defined as "the average of the best
existing performance by well operated plants within each industrial
category or subcategory." In developing BPT, impacts on industry and
economy as a whole are taken into account.
Section 301 provides for three categories of pollutants for the
next phase of cleanup: toxic, conventional and non-conventional. By
July 1, 1980 EPA must issue effluent limitations for 65 toxic substances.
These effluent limitations will require applications of BAT by July 1,
1984. For any chemical added to the toxic list, EPA must promulgate BAT
regulations as soon as practicable. Industry must comply with BAT not
later than 3 years after the standard is set. EPA must identify
conventional pollutants; these include suspended solids, certain bacteria,
pollutants affecting BOD and alkalinity-acidity. Discharges of
conventional pollutants are required to install Best Control Technology
(BCT) by July 1, 1984. BCT is defined as a technology that is considered
to be economically reasonable for an industry, that is, at least as
stringent as the base level or BPT and less than or as stringent as the
Best Available Technology (BAT). BAT is defined as the "very best control
treatment measures that have been or are capable of being achieved"
considering the cost impact of the industry.
For all conventional pollutants (pollutants other than toxic or
conventional) industry must comply with BAT by July 1, 1987. EPA may
modify the BAT requirements however if a facility has compiled with BPT
and is meeting water quality standards, if no additional burden on other
dischargers will result, and if no public health or environmental risk is
anticipated.
4-18
-------
Thus, BAT is applicable to both toxic and nonconventional
pollutants, though the deadlines differ depending on the type of discharge
being regulated. Industries may propose to meet BAT by replacing existing
production processes with an innovative process or control technique
resulting in significant effluent reduction or lower costs and that may
have industry-wide application. These industries will have the longest
timetable available.
In addition to setting effluent limitations, EPA must now publish
regulations to contol plant site runoff, leaks, waste disposal, spillage,
and drainage from raw material storage of toxic and hazardous pollutants
associated with an industrial manufacturing or treatment process. Called
Best Management Practices (BMP's), these controls must be included in any
permit issued under Section 402.
Under Section 306 of the CWA, EPA is directed to establish national
standards of performance for new sources. The general approach to the
establishment of NSPS is similar to that established for existing sources,
with some distinct differences. A standard of performance is defined as a
standard for the control of discharge of pollutants reflecting the
greatest degree of reduction. This reduction can be achieved through
application of the best available demonstrated control technology,
processes, operating methods, or other alternatives including, where
practicable, standards permitting no discharge of pollutants. The primary
differences between this criteria and BPT or BAT is that under Section 306
EPA is specifically required to consider not only pollution control and
abatement processes and techniques, but also various alternative
production processes, operating methods, in-plant control procedures,
4-19
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etc. In addition, NSPS do not require detailed consideration of economic
and technological factors, but Section 304 does.
4.2.3.2 Pretreatment Regulations
The primary intent of the pretreatment regulation is to protect the
operation of publicly owned treatment works (POTW) and to prevent
inadequate treatment of discharged pollutants. The discharge limits are
based on best available technology economically achievable for industrial
uses of both new and existing sources.
4.2.3.3 Water Quality Criteria
As mentioned previously, the technology based effluent limitations
function primarily as a nationwide base level of treatment. Section 302
of the CWA makes specific provisions for the establishment of effluent
criteria. These criteria can be more stringent than the BAT guidelines,
when necessary, to attain or maintain water quality that assures
protection of public water supplies, agricultural and industrial uses, and
fish and wildlife. These criteria may require that an industrial facility,
located either in areas of heavy discharge concentration or near waters
where very stringent water quality standards have been established,
provide a level of treatment considerably higher than the base level
established by the technology related effluent limitations.
4.2.3.4 National Pollutant Discharge Elimination System
The primary enforcement mechanism for the federal effluent
limitations, NSPS, and pretreatment requirements is a nationwide permit
program, called NPDES, established under Section 402 of the Act. Under
this program, every point source is issued a permit by EPA or the state.
These permits specify maximum permissible levels of each pollutant that
can be discharged, a compliance schedule for reaching these limits, and
4-20
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requirements for monitoring and reporting discharges to the states and
EPA. These guidelines and standards are technology based (as opposed to
being based on meeting specific water quality or health goals). These
guidelines and standards do not require that specific control technology
be used; the level of control, however, is based on physical/chemical
treatment of the effluent, process modifications, best management
practices, or even transferring the discharge to an industrial waste
disposal company.
4.2.3.5 Regulatory Decision Making Process
Figure 4-2 shows the analysis used by OWPS in determining the
regulatory approach to be used. First, the amount of effluents from the
particular source must be known, followed by a determination of the
potential adverse effects of the effluent on water quality. If these
effects are determined to pose a problem of national or statewide concern,
a standard for control is established.
4.2.3.6 Current Regulations
No specific regulations govern the waste stream effluents from
alcohol fuels production. Standards on other processes, such as sugar
mills and grain mills, which will require secondary treatment may also
apply to alcohol fuels production. In addition, general water quality
standards for BOD and suspended solids must be maintained. More stringent
standards can be found at the state and local levels for pH, organic
materials, and other effluents that cannot be discharged into POTW.
Notwithstanding any of the above regulations, the EPA Administrator
can establish effluent limitations for a source or sources interfering
with the attainment or maintenance of any promulgated water quality
standard.
4-21
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ro
r\>
Problem Assessment
OMCrnlM ซffIttWt
quality fi<< ou'ntlly
Supporting
Information
Development
Develop Industry (ปoUu'
-------
4.2.3.7 Regulatory Plans
The OWPS/EGD prepares and publishes a development document for each
industrial category for which the Agency intends to promulgate an effluent
guideline. These documents present the data base supporting the Agency's
findings on uncontrolled discharges, the availability of control
technologies for these discharges, the reductions achievable through the
use of control techniques, and the cost, energy consumption and other
nonwater quality aspects resulting from the use of these controls. OWPS
plans to publish a development document on gasohol by November 1980.
4.2.4 Office of Solid Waste
The program for environmentally safe disposal of solid waste is
administered by OSW under the statutory authority of the Resource
Conservation and Recovery Act (RCRA). The objectives of RCRA are to
protect health and the environment and to conserve valuable material and
energy resources. To date no specific regulations have been developed by
OSW. The following paragraphs describe the provisions contained in RCRA
that could apply to the alcohol fuels industry (see Reference 4-9).
Subtitle C contains the primary enforcement and program
authorizations. The content of Subtitle C is to enable a program
providing for identification of those waste substances (primarily
industrial) that may be hazardous and tracking of them from their
generation through transportation and storage to ultimate disposal in an
environmentally acceptable manner.
Under RCRA, a distinction is made between hazardous and
nonhazardous solid wastes. OSW is currently planning to promulgate
standards in 1980 for the criteria and test procedures to be used in
4-23
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determining whether or not a solid waste is hazardous. Among the criteria
under consideration are flammability, corrosivity, reactivity,
radioactivity, toxicity, and potential for bioaccumulation, persistence,
and causing disease. By April 1980 it is expected that OSW will have
published a list of hazardous waste substances. In addition to the EPA
listing, RCRA allows the governor of any state to petition EPA to identify
or list additional substances.
Regulations for a federal permit system applicable to owners and
operators of hazardous waste treatment, storage, or disposal systems have
also been developed by OSW and should be promulgated by Febuary 1980.
Further, by 1980 OSW plans to have promulgated guidelines to assist the
states in developing hazardous waste programs. State or regional plans
for the management of nonhazardous wastes are administered under
Subtitle D of RCRA. OSW guidelines for state plans and criteria for
sanitary landfills are also expected to be published in 1980.
4.2.4.1 Current Regulations
There are no federal or state regulations dealing specifically with
the solid wastes generated from alcohol fuels production. In general,
state regulations require that wastes be handled by a licensed waste
hauler and disposed of in a licensed disposal facility.
It is believed that most alcohol fuel producers will dispose of
less than 100 kilograms (220 pounds) per month of hazardous wastes
(including benzene and pesticides), if any at all. In the event they do
dispose of hazardous wastes up to 100 kilograms per month, they must
comply with Section 250.29 (persons who dispose of less than 100 kilograms
per month of hazardous waste; retailers; and farmers) of the proposed RCRA
4-24
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regulations. In general, this provision requires that any hazardous waste
generated, no matter how small the quantity, be disposed of either in:
0 A solid waste facility that has been permitted or otherwise
certified by the state as meeting the criteria pursuant to
Section 4004 (Criteria for Sanitary Landfills) of RCRA
A treatment, storage, or disposal facility permitted by the
Administrator pursuant to the requirements of Section 3005
(Permits for Treatment, Storage and Disposal of Hazardous
Wates), or permitted by an authorized state program pursuant to
Section 3006 (Guidelines for Authorized State Hazardous Waste
Programs) of RCRA
4.2.4.2 Regulatory Plans
At present OSW does not plan to develop regulations for the
disposal of solid wastes from the production of alcohol fuels because
preliminary tests indicated that these wastes were not hazardous. The
OSW, however, will participate in the sampling and analysis program to be
conducted by OWPS and lERL-Ci to ensure that these are, in fact, not
hazardous.
4.2.5 Office of Toxic Substances
The Toxic Substances Control Act (TSCA) of 1976 is administered by
the Office of Toxic Substances (OTS). TSCA has two main goals: the
acquisition of sufficient information to identify and evaluate potential
hazards from chemical substances and the regulation of production, use,
distribution, and disposal of these substances (see Reference 4-10).
Under TSCA, manufacturers or processors of potentially harmful
chemicals may be required to conduct tests on the chemicals at their own
4-25
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expense. Testing may be necessary to evaluate a chemical's health or
ecological effects.
Manufacturers of new chemical substances must notify the EPA
90 days before the chemical is manufactured for commercial purposes. On
June 1, 1979 EPA published an inventory of existing chemicals. Any
chemical not on this list is considered new for the purposes of the
premarket notice requirement. In addition, the EPA Administrator may
designate a use of an existing chemical as a signficant new use. Anyone
who intends to manufacture a chemical for such a significant new use also
must report this information 90 days before marketing.
TSCA authorizes EPA to issue an order or seek an injunction, if
necessary, to keep a new chemical off the market. In addition, the EPA
Administrator may prohibit or limit the manufacture, use, or disposal of a
chemical substance or mixture if these activities present an unreasonable
risk to health or the environment.
4.2.5.1 Current Regulations
The EPA is now in the process of developing programs to fully
implement the authorities of TSCA. Intially, more emphasis is being
placed on obtaining and analyzing information than on writing specific
control regulations. In 1980 the agency will concentrate on devising a
premarket notification system. By the end of 1980, all aspects of the
TSCA program are planned to be operational.
4.2.5.2 Regulatory Plans
Under the provisions of TSCA, ethanol is not considered toxic.
Hence, OTS does not have any plans at this time to require premarket
notification or special handling of ethanol. If any of the byproducts of
alcohol fuels production are found to be toxic as a result of the sampling
4-26
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and analysis program described in this plan, it is expected that
regulation of these substances will be handled by the appropriate media
office.
4.2.6 Office of Enforcement
4.2.6.1 Current Regulations
The Office of Enforcement, in cooperation with Regional Offices,
has the authority to enforce compliance with federal regulations. In
general, day-to-day enforcement activities are the primary responsibility
of the states; however, when a state fails to adequately administer its
SIP, NPDES, hazardous waste, or other federally mandated environmental
program, EPA has the authority to assume this function.
The Office of General Enforcement, Stationary Source Enforcement
Division, provides support to the EPA Regional Offices and state
environmental control authorities as needed to maintain and enforce the
regulations and provisions under the CAA.
The Office of Water Enforcement, Enforcement Division, enforces
compliance with water quality standards and effluent limitations in
cooperation with state authorities and the EPA regional offices. The Permits
Division works with the states to issue discharge permits in an advisory
capacity and, for those states not authorized to issue permits (20 out of
50), has the responsibility of application review and permit issuance.
4.2.6.2 Regulatory Plans
The Office of Enforcement needs reliable information on pollutant
emission rates and control methods to aid in their guidance for permitting
of stationary sources. The information derived from the sampling and
analysis program to be conducted by IERL will assist the Office in their
permitting, should permitting be necessary in the future.
4-27
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REFERENCES FOR SECTION 4
4-1. U.S. Department of Energy, "The Report of the Alcohol Fuels Policy
Review," June 1979.
4-2. Congress of the United States, Office of Technology Assessment,
"Gasohol, a Technical Memorandum," 1979.
4-3. Brochure, National Gasohol Commission, Inc., Lincoln, Nebraska.
4-4. Department of the Treasury, Bureau of Alcohol, Tobacco, and
Firearms, "Informational Brochure Ethyl Alcohol for Fuel Use,"
ATF P 5000.1, July 1978.
4-5. G. R. Dickerson, Statement presented to the Senate Agricultural
Research and General Legislation Subcommittee of the Committee on
Agriculture, Nutrition, and Forestry of the United States Senate,
July 23, 1979.
4-6. The Clean Air Act Amendments of 1977, P.L. 95-95, 91 Stat. 685; and
P.L. 95-190, 91 Stat. 1393.
4-7. Research Triangle Institute, "Standard Support Plan for
Technologies for Producing Synthetic Fuels from Coal," Draft,
January 1979.
4-8. Federal Water Pollution Control Act of 1972, 33 U.S.C. Section 1251
and P.L. 95-217, 91 Stat. 1566, December 27, 1977.
4-9. Resource Conservation and Recovery Act of 1976, P.L. 94-580,
90 Stat. 2795.
4-10. Toxic Substances Control Act of 1976, P.L. 94-469, 71 Stat. 850.
4-28
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