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
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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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
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
-------
DISCLAIMER
This report has been reviewed by the Industrial Environmental Research
Laboratory, U.S. Environmental Protection Agency, and approved for
publication. Approval does not signify that the contents necessarily reflect
the views and policies of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement or
recommendation for use.
-------
ABSTRACT
Fuels containing non-petroleum-based alcohols, such as gasohol, can
provide one effective approach for limiting the increasing dependence by the
United states on foreign oil. Currently, ethanol is the only comnercially
available alternate fuel and will remain the only one available in significant
quantities prior to 1985. 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 and the Regional Offices in setting
standards for the emission effluents from fuel-grade alcohol production
facilities. Since it is 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 environmental impact of gasohol
production and use, namely the production of the feedstock; transportation;
transfer, storage, and blending of the alcohol with gasoline; and end-use
combustion in mobile sources. This study by ORD's Industrial Environmental
Research Laboratory at Cincinnati, Ohio (IERL-Ci) is limited to fuel-grade
alochol production, from feedstock preparation to the generation of 200-proof
alcohol. Other aspects need to be reviewed by other cognizant ORD laboratories.
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. 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. The studies planned are to be done
concurrently and in coordination with a schedule put forth by the Program
Offices for determining the appropriateness of standards and for setting those
standards required; as such it represents a consensus plan between the ORD
study and each of the Program Offices.
Region VII personnel have also participated in formulating the plan.
The programs developed in cooperation with Region VII will serve as a model
for the other regions and will be adapted where there is an interest and a
need.
iii
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CONTENTS
Foreword iii
Abstract iv
1. Introduction 1
2. Alcohol Fuels Production 3
2.1 Commercial-Scale Ethanol Production 3
2.1.1 Ethanol from Starches 4
2.1.2 Ethanol from Celluloses . . . 7
2.1.3 Ethanol from Sugars 11
2.2 On-Farm Ethanol Production 14
2.2.1 Process Description 14
2.2.2 Emissions and Effluents 14
2.2.3 Pollution Control Systems 14
2.2.4 Liquid and Solid Waste Disposal 14
2.2.5 New and Emerging Technologies 14
2.3 Other Alcohol Fuels Production 15
2.3.1 Methanol Via Catalysis of Synthesis Gas 15
2.3.2 Butanol Production Via Biological Conversion .... 16
3. The Standards Support Schedule 17
3.1 Description of the Schedule 17
3.2 Program Schedule 17
3.3 Responsibilities and Working Interaction 26
4. Discussion of the Standards Support Plan Elements 29
4.1 Alcohol Fuels Development 29
4.1.1 Potential Oil Savings from Alcohol Fuels 29
4.1.2 Supply and Demand 30
4.1.3 Biomass Availability 31
4.2 Regulatory Requirements and Plans,
Bureau of Alcohol, Tobacco, and Firearms 33
iv
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SECTION 1
INTRODUCTION
Fuels containing nonpetroleum-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
and the Regional Offices in setting standards for the emission effluents from
fuel-grade alcohol production facilities. Since it is 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 environmental impact of gasohol
production and use, namely the 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 (IERL-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
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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)
• 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.
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 IERL-Ci personnel and 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 fuel-grade alcohol production came
from an increase in permit requests in Region VII for on-farm facilities,
Region VII personnel have also participated in formulating the plan. The
programs developed in cooperation with Region VII will serve as a model for
the other regions and will be adapted where there is an interest and a need.
2
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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 by biological conversion of various feedstocks. However,
two other alcohol fuel production technologies, namely the production of
methanol from synthesis gases (carbon monoxide and hydrogen) and butanol via
biological conversion, are included. The discussion for each technology
provides specific examples of the air emissions and liquid and solid
effluents, pollution control systems, disposal of wastes from air, liquid and
solid streams, and new technologies for alcohol production facilities. In
each instance, the description will focus on current practices used in
operating facilities. A salient goal of the EPA Gasohol Program is, however,
to develop in-plant strategies that minimize potential environmental concerns
and, therefore, minimize the need for sophisticated and expensive control
systems.
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 and are
representative of the types used in the production facilities to be studied in
the sampling and analysis portion of this plan. These are:
• Corn, a starch
• Corn stover, a cellulose
• Cheese whey, a sugar
The methanol and butanol production processes are included as
technologies of the future.
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
3
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broadly classified as starches, celluloses and sugars. The following items
are discussed for each feedstock:
• Process description
• Air emissions and liquid and solid effluents
• Pollution control systems
« Disposal of wastes from air, liquid and solid streams
• 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.
Production begins by grinding the grain in a milling process (e.g., a
harnmermill) and slurrying the grain with water to form a mash. The mash is
cooked by injecting steam (at approximately 150°c) to solubilize the
starches. After the mash is cooled, enzymes are added to transform the
complex starches into fermentable sugars.
When the mash enters the fermentation vessels, yeast converts the
sugars to alcohol and carbon dioxide. 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, producing a
stream that contains 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, separated and removed in a side stream, 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 two streams: one of anhydrous
ethanol and one containing benzene, ethanol, and water. The latter is treated
in a chilled separator, producing an ethanol/benzene-rich stream that is
recycled to the dehydration column and an ethanol/water-rich stream. Ethanol
and trace benzene are recovered from the ethanol/water-rich stream in the
benzene recovery column, then returned to the dehydration column (stream E).
The separated water is sent to the wastewater treatment facility.
Typically, the byproduct still age (stream A) from the alcohol stripping
column is treated to recover the solids (stream C), rather than used directly
4
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en
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-------
or processed in wastewater treatment. Water is removed from the stream using
centrifugation and evaporation. The water from centrifligation is recycled to
the cooker (stream B) or evaporated. The solid product, containing proteins
and dead yeast, is used as a cattle feed supplement, e.g., dried distillers
grain (DDG). 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 Air Emissions and Liquid and Solid 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
Figure 2-1) and consist mainly of particulates, S0X, and N0X. 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 effluents from the plant pass through wastewater treatment
(stream 18) before being discharged to a waterway. The cooling tower blowdown
and the rectification and benzene recovery columns produce most of the
wastewater. Equipment washes also periodically add to the wastewater. The
treated water may be recycled and used in the process again if it is
sufficiently cleansed of contaminants to the emzymes and yeasts. Recycling
lowers the fresh water input to the process (stream 2).
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 on the boiler and rotary dryer. Mechanical collectors are
also used to capture and recycle dust emissions from milling operations.
Condensers are placed on the vents to reduce hydrocarbon emissions from the
fermentation tank, columns, and separator. Condensates from these vents are
returned to the associated processes. Based on measurements at distilleries,
these hydrocarbon 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 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. The wastewater can be
recycled to the process if it has been sufficiently cleansed of contaminants.
2.1.1.4 Disposal of Wastes from Air, Liquid and Solid Streams
The liquid effluent from wastewater treatment can be discharged to a
waterway or, if sufficiently uncontaminated, recycled to the.process. As
6
/
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stated earlier, the sti11 age can be used as a cattle feed supplement. In
addition, the collected grain dust from milling can be added to the stillage
to improve the nutrient value of the supplement or returned to the feed
stream. The wastewater sludge must be disposed of via landfilling or land
spreading.
The treatment of air streams produces two solid wastes: captured flue
gas particulates (flyash) and coal dust collected from coal storage and
handling. Both are disposed of via landfills.
2.1.1.5 New and Emerging Technologies
It is not possible to fully assess the impacts of new and emerging
technologies on air emissions and liquid and solid effluents. However, there
are several new technologies that could affect the efficiencies and yields of
the ethanol fermentation process. 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 stillage can be implemented,
eliminating drier energy consumption and producing methane that can be burned
for process steam generation. Anaerobic digestion of stillage is not a common
industry practice, but it is a well understood technology that could be easily
adapted to the alcohol production process. The stillage from the alcohol
stripper can also be used without drying as a feed supplement, further
reducing energy consumption and related emissions. However, wet stillage 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 first step is to reduce the stover size and break down
cellulose into fermentable simple sugars by acid hydrolysis using dilute
sulfuric acid (< 5 percent). This process produces furfural in addition to
simple sugars. "The solubilized products are separated (stream B) in a flash
distillation step. The sugars are neutralized to remove the contaminants
7
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-------
(lignin, etc.) arid to alter the pH to provide a proper environment for the
fermentation yeast.
The simple sugars are 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, producing 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 aldehyde
impurities, separated and removed in a side stream, 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 two streams: one of anhydrous
ethanol and one containing benzene, ethanol, and water. The latter is treated
in a chilled separator, producing an ethanol/benzene-rich stream that is
recycled to the dehydration column and an ethanol/water-rich stream.
Ethanol and trace benzene are recovered from the ethanol/water-rich stream in
the benzene recovery column, then returned to the dehydration column (stream
G). The separated water is sent to the wastewater treatment facility.
Typically, the byproduct still age (stream C) 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 (stream D) or evaporated. The solid product (stream E),
containing unconverted materials and dead yeast, is low in nutrient value and
not typically used as a food supplement. If no byproduct use is available,
this still age is disposed of as solid waste. The drying operation may be
fueled by oil or gas. Process steam is produced on-site by a boiler, usually
oil- or coal-fired.
2.1.2.2 Air Emissions and Liquid and Solid 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, S0X, and N0X. 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 9, 10, 16, 17, 19,
20, 22, and 25). Fugitive particulates are produced by stover preparation
(stream 1).
All liquid effluents pass through wastewater treatment before leaving
the plant. The cooling tower blowdown contributes the major volume of
wastewater. The rectification and benzene recovery columns and equipment
washes also produce wastewater. The treated water may be recycled and used in
the process again if sufficiently cleansed of contaminants to the enzymes and
9
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yeasts. Recycling lowers the fresh water input of the process (e.g.,
stream 2). 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 on the boiler and rotary dryer. Mechanical collectors are
also used to capture and recycle dust emissions from stover preparation.
Condensers are placed on the vents to reduce hydrocarbon emissions from the
columns, fermentation tank, and separator. Condensates from these 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 BOO removal efficiency of
75 to 79 percent. The wastewater can be recycled to the process if it has
been sufficiently cleansed of contaminants.
2.1.2.4 Disposal of Wastes from Air, Liquid and Solid Streams
The liquid effluent from wastewater treatment can be discharged to a
waterway or, if it sufficiently uncontaminated, recycled to the process. The
solid wastes, lime sludge, stillage, and wastewater sludge (streams 12, 15,
and 24) must be disposed of via landfilling or land spreading.
The treatment of air streams produces three solid wastes: captured
flue gas particulates (flyash), coal dust collected from coal storage and
handling, and corn stover dust collected from stover handling and
preparations. These are disposed of via landfills.
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
defibration 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.
10
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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 byproduct of the cheese
industry. Whey is converted to a variety of products including animal feed
supplement, lactose, and food grade whey. Unconverted cheese whey is disposed
of via municipal treatment, land spreading, or land filling. Typical cheese
whey consists of water, lactose, and small amounts of proteins and fats. The
fats and proteins 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 solution 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, separated and removed in a side stream, can be combined with the
final ethanol fuel product.
Dehydration of the ethanol-water azeotrope 1s necessary to produce an
anhydrous product. A dehydrating agent (benzene) is added to the azeotrope in
the dehydration column. The column produces two streams: one of anhydrous
ethanol and one containing benzene, ethanol, and water. The latter is treated
in a chilled separator, producing an ethanol/benzene-rich stream that is
recycled to the dehydration column and an ethanol/water-rich stream. Ethanol
and trace benzene are recovered from the ethanol/water-rich stream in the
benzene recovery column, then returned to the dehydration column (stream B).
The separated water is sent to the wastewater treatment facility. Process
steam is produced on-site by a boiler, typically oil- or coal-fired.
2.1.3.2 Air Emissions and Liquid and Solid Effluents
The majority of the air pollutants from this process are produced by
fuel combustion in the boiler (stream 3) and consist mainly of particulates,
S0X, and N0X. Fugitive hydrocarbon emissions are produced by flash
cooling, fermentation, alcohol stripping, rectification, dehydration, chilled
separation, benzene recovery and wastewater treatment (streams 7, 8, 9, 12,
14, and 17).
11
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Preparation
Fermentation
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Cheese whey
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o Proteins, fats
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Figure 2-3. Ethanol production from whey sugars.
-------
All liquid effluents pass through wastewater treatment before leaving
the plant. The cooling tower blowdown contributes the major volume of
wastewater. The rectification and benzene recovery columns and equipment
washes also produce wastewater. The treated water may be recycled and used in
the process again if sufficiently cleansed of contaminants to the enzymes and
yeasts. Recycling lowers the fresh water input of the process (e.g. stream 2).
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. Condensers are placed on
the vents to reduce hydrocarbon emissions from the fermentation tank, columns,
and separator. Condensates from these 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. The wastewater can be recycled to the process if it has
been sufficiently cleansed of contaminants.
2.1.3.4 Disposal of Wastes from Air, Liquid and Solid Streams
The liquid effluent from wastewater treatment can be discharged to a
waterway, or if sufficiently uncontaminated, recycled to the process. The
wastewater sludge and precipitated fats and proteins must be disposed of via
landfilling or land spreading.
The treatment of air streams produces two solid wastes: captured flue
gas particulates (flyash) and coal dust collected from coal storage and
handling. Both are disposed of via landfilling.
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
technologies that could affect the efficiencies and yields of the ethanol
fermentation process. For instance, gasoline has been substituted for benzene
as the dehydrating agent, and 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
13
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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:
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 there will be no drier emissions.
2.2.3 Pollution Control Systems
The on-farm process will be very small and will have few pollution
control systems. Because of the small size of the boiler, it will be
uncontrolled. Condenser vents will not be placed on the fermentation tank and
distillation/dehydration columns, and dust collection devices will not be
used. 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 conmercial application, with the exception of
supercritical fluid extraction of ethanol. This process is not applicable to
on-farm processes because of its complexity and cost. Increased automatic
14
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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 (currently derived from natural gas) at a temperature of
approximately 315°C and a pressure of 105 to 350 kg/cm2 (2H2 +
CO. The hydrogen and carbon monoxide precursors can also be
generated in other ways. 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, wood
wastes, refuse-derived fuel, and biomass. Present plans emphasize the use of
coal as the primary feedstock in the future.
The gasification of these feedstocks can occur at different
temperatures and pressures. This discussion focuses on 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 organics and then compressed to approximately 10
kg/cms The gas is subsequently passed through a hot potassium carbonate
scrubber and a monoethanolamine scrubber to remove the carbon monoxide.
The C02-free gas is treated cryogenically to remove methane,
hydrocarbons, and nitrogen. The gas 1s compressed to approximately
30 kg/cm2 and reacted over an iron catalyst used in the water shift
reaction. 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 CO? produced during this shift catalysis is removed in another
potassium carbonate scrubber. The synthesis gas is compressed to
approximately 175 kg/cm2 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.
15
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Condenser vents will be used to control fugitive hydrocarbon emissions
from the distillation columns and scrubbers.
2.3.2 Butanol Production Via Biological Conversion
Butanol can be produced biologically from pentoses (simple sugars) in a
process similar to ethanol production. 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, carbon dioxide, and hydrogen. Subsequent
process steps refine the alcohol and remove the water, solids, and other
hydrocarbons. Fuel-grade butanol, carbon dioxide, and hydrogen are the final
products.
Since this alcohol production technology is in the early stages of
development, the exact process characteristics are not certain. However,
because the process is very similar to ethanol fermentation from cellulosic
feedstocks, it is expected that the emissions and effluents, control
technologies, and disposal characteristics will also be similar.
16
/
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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 IERL-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 IERL-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 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 IERL-Ci research program are discussed in
Section 3.2.
3.2 PROGRAM SCHEDULE
As a result of a series of meetings among IERL-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.
17
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There are four important phases to this research plan: (1) information
surveys of the processes, (2) engineering analysis, (3) environmental data
acquisition, and (4) documentation including a Pollution Control Guidance
Document (PCGD) 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
relationships 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 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 lists
the major U.S. producers of ethanol, whether the product is
used for fuel or not (i.e., includes some distilleries) and
gives 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-Ci 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 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.
18
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cmms City Mtf. i Transcripts
teftoaVH Actifiti*
Starting HI/78 BIstMlcry Sttrwy
lEftL/Progrw Office/Re**®* V!( Ktjs.
SU 1EK. fe-F*r«
SM 1UL riiuli)
win. 0e»./OSB/£MQf5
Figure 3-1.
IERL program schedule for gasohol.
-------
~ 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 can be used in
the preparation of a PCGD if required ~ 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.
— 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
additional NSPS since the steam boiler, which is the major
source of emissions, will be controlled under an NSPS for
industrial boilers currently under development.
• 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.
20
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TABLE 3-1. SUMMARY OF S&A INTEREST IN ALCOHOL PRODUCTION PLANTS BY
PROGRAM OFFICES/ORO
Program Office/ORD/Regional Involvement3
Plant OWPS/EGD OSW/HIWD OAQPS/ESED ORD/IERL-Ci Regions
Midwest Solvents C* C C C* C*
Georgia-Pacific I NI NI I I
American Distilling II C I I
Milbrew II I I I
Grain Processing II I I I
Natick Army Labs II NI I I
ADM I NI NI I I
Jacquins II NI I I
On-Farw (2) II
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 EGO
21
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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 Midwest Solvents
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 with BATF
Farm Environmental Operations Manual
Department of Agriculture Liaison
Adaptation of Regional
Model to other Regions
PCGD
EAR
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 & ORD/IERL-Ci
Program Offices
Region VII
Region VII
Region VII
Regions & ORD/IERL-Ci
ORD/IERL-Ci
ORD/IERL-Ci
ORD/IERL-Ci
22
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TABLE 3-3. SAMPLING AND ANALYSIS PROGRAM MATRIX FOR EACH SITE
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
Particulate
NOv
SO?
CO, C02, 02
Hydrocarbons
II. Laboratory Analysis
Method
EPA Method-5
EPA Method-7
EPA Method-6
EPA Method-3
GC w/FID
Solid Streams:
Liquid Stream:
Phenols, Cyanides, Ammonia Sulfate, Sulfites, Nitrates,
22 Metals,** Including Solid Extraction
Organics by GC/MS, Acid Fraction, Base Neutral
Fraction, Pesticides
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.
**The 22 metals include A1, Bi, Ca, Fe, Mg, Mn, Y, Ti, Sb, As, Be, Cd,
Cr, Cu, Pb, Hg, Ni, Se, Ag, Tl, Zn, and B.
23
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Task order
awarded
Plan
approval
Profile
(1/2/80) (1/18/80) (3/1/80)
ro
Sampling
plant
selection
Technology
selection
(3/1/80)
Sampling
ini tiated
Completion of
sampling &
analyses
(3/1/80) \ (3/21/80)(6/15/80)
Field
Assessment
of technology
Subcategory
selection/
paragraph/
BCT test 8
{10/30/80)1
Review
/ fhinlngiral)
flonralete \ Draft
bv
Final
(3/21/80)
I f%A
(6/15/«°>|(10/l/80
DO
(11/1/80)
DO RMP
(12/1/80)
In-plant
l treatment
\ assessment
y (3/21/80)
\ 308 data
i \ collection
\ (4/15/80)
\ Initiation
I of cost
I manual
1 Site
/ verification
Final
cost
report
(3/1/80)
(7/15/80) (9/1/80)
Approximately eight plants will be sampled.
One EGO and one IERL-Ci project officer
full time are required.
Figure 3-2. Gasohol effluent guidelines development.
-------
However, since the DD will be essentially a waste water
document, the PCGD may still be required to discuss the solid
waste and air emissions management concerns, in-plant
strategies that might be employed for each media to minimize
effluent controls, and the role of new technologies for ethanol
production which are not currently covered in this plan. The
PCGD could also provide engineering analysis of emerging
technologies for other alcohols to establish the need for an
SSP update and continued research.
— The Farm Environmental Operations Manual will provide guidance
to the BATF on what environmental questions should be examined
when issuing their permit for a still and 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.
-- A Regional Enforcement Model will be developed by Region VII
with the cooperation of the BATF. The BATF is developing a new
permitting system for alcohol fuel producers (see Section 4.2)
to replace the present cumbersome and outdated system now in
use. In order to access environmental information about the
site and the production system, the permit applicant will be
required, as part of the permitting procedure, to provide
information about their facility of an environmental nature,
(size, discharge, solid waste handling and disposal, etc.)
Region VII, BATF and IERL-Ci are cooperating in developing
exactly what kind and type of information is needed to optimize
the quality of the information gathered. The Farm
Environmental Operations Manual (mentioned above) will contain
guidance to the farmer as to his response to these questions as
well as how to operate the system in an environmentally safe
manner.
The responses to the environmental portion of the permit
will be reviewed by a BATF inspector, who will be informed in
methods designed to detect situations potentially harmful to
the environment. The information necessary to perform this
task will be provided in a document called the "BATF
Environmental Information Manual for On-farm Alcohol Production
Systems."
The remaining task in this area will be to develop the
mechanism by which BATF will alert the state and EPA Region as
to a potential problem situation. This task will be the joint
responsibility of EPA Region VII, BATF, and IERL-Ci.
— The results of the IERL program will form the basis for the
preparation of an EAR. Environmental Assessment Reports are
25
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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 IERL-Ci, the Program Offices, and
Region VII, responsibilities for the various activities identified in this SSP
were assigned. IERL-Ci and EGD will perform the solid and liquid waste S&A
program for the cormtercial units. This program will include air emissions
sampling at two of the commercial units. A complete sampling program for
solid, liquid, and air effluents will be carried out at two on-farm
facilities. Responsibility for this program lies with IERL-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 may be
necessary that a second SSP on fuel-grade alcohol production be prepared in
early 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 3-2. ORD's role is to respond to the needs of the Program
Offices and Regional 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.
26
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IERL-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
PCGD and an EAR. Additionally, at the completion of the program outlined in
this 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 may be required.
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 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 inmediacy of obtaining data to
assess their impact.
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.
27
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TABLE 3-4. ALCOHOL FUEL/ENERGY COORDINATORS/CONTACTS
ORD/IERL-Ci
Robert Mournighan
(513)
684-4334
OAQPS/ESED
Dave Markwordt
(919)
629-5371
OWPS/EGD
John Lum
(202)
426-4617
OSW/HIWD
Bill Kline
(202)
755-9200
ORD/EPD
David Berg
(202)
755-0205
Regional Services
Staff
Joseph Roesler
(513)
684-7285
Region 1
Dick Keppler
(617)
223-3477
Region 2
Paul Pruchan
(212)
264-7665
Region 3
Bernard Turlinski
(215)
597-9944
Region 4
Bob Humphries/Dave Hopkins
(404)
257-3004
Region 5
Jim Phillips/Cliff Risley
(213)
886-6054
Region 6
John Accardi
(214)
729-2650
Region 7
Charles Hajinian
(816)
758-2921
Region 8
Terry Thoem
(303)
327-5914
Region 9
Carl Kohnert
(415)
556-7858
Region 10
George Hofer
(206)
399-1125
28
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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
difference in the amount of oil used to produce each fuel. Two alcohol fuels,
ethanol and methanol, are corrmercially 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
29
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asoline. 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:
• 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
• 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
• The relative cost of competing fuels
*At 1979 prices.
30
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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.
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 methyl tertiary butyl ether (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
*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 PCGDs and EARs.
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TABLE 4-1. PROJECTED MAXIMUM U.S. BIOMASS AVAILABLE FOR ALCOHOL PRODUCTION
(million dry tons per year)
1980 1985 1990 2000
Biomass Source
Quantity
Percent
Quantity
Percent
Quantity
Percent
Quantity
Percent
Woodb
499
61
464
56
429
49
549
48
Agricultural
residues
193
23
220
26
240
28
278
24
Grains0
38
5
38
5
28
3
23
2
Sugarsc
—
—
8
1
69
8
172
15
Municipal solid
waste (MSW)
86
. 10
92
11
99
11
116
10
Food processing
wastes
6
1
7
1
8
1
10
1
Total 822 100 829 100 873 100 1,148 100
Reference 4-1
bAssumes wood from sivicultural energy farms starting in 1995
cEstimates for grains and sugars assume development program to establish sweet sorghum as a cash crop
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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 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. In fact, the President's Program for Ethanol Production has actual
production goals of less than 1 percent of the maximum production in 1980 and
approximately 5 percent of the maximum production in 1983.
4.2 REGULATORY REQUIREMENTS AND PLANS, 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 responsibility of BATF is to
protect revenue. (For Section 4.2, 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 law, a
commercial facility can produce beverage or industrial alcohol. Qualification
as a coirmercial 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
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TABLE 4-2. PROJECTED MAXIMUM ALCOHOL PRODUCTION FROM U.S. BIOMASS RESOURCES9
(billion gallons per year)
1980
1985
1990
2000
Biomass Source
Ethanol
Methanol
Ethanol
Methanol
Ethanol
Methanol
Ethanol
Methanol
Wood
23.5
86.3
21.8
80.2
20.2
74.2
25.8
95.0
Agricultural
residues
9.1
33.4
10.3
38.1
11.3
41.5
13.1
48.1
NSW
2.2
8.6
2.3
9.2
2.5
9.9
2.9
11.6
Subtotal
34.8
128.3
34.4
127.5
34.0
125.6
41.8
154.7
Sugars
~
—
0.4
—
3.7
~
9.0
—
Grains
3.9
—
3.8
—
2.8
—
2.3
—
Food processing
wastes
0.5
—
0.6
--
0.7
—
0.7
—
Subtotal
4.4
—
4.8
~
7.2
«
12.2
Total
4.
39.2
128.3
39.2
127.5
41.2
125.6
54.0
154.7
^Reference 4-1
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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 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
• 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.
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
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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.
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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.
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