Washington State Ethanol Production Facility Air Quality Permitting Experience

1. Washington StateEthanol Production FacilityAir Quality PermittingExperience Robin Priddy, PE Benton Clean Air Agency

2. Ethanol Plant Proposals2006-2007 Northwest Renewables, Longview Clint Lamoreaux, PE; Southwest Clean Air Agency Columbia Renewable Energy, Plymouth Columbia Renewable Energy, Finley Bernard Brady, PE; Ecology Headquarters E-85, Inc, Wallula Robert Koster, PE; Ecology Eastern Regional Office Pacific Ethanol, Plymouth Robin Priddy, PE; Benton Clean Air Agency

3. Plant Capacity

4. Emissions (approximate)

5. Ethanol Production(courtesy Renewable Fuels Association)

6. New experience for Ethanol Producers and Washington State Permit Writers

7. Washington State Toxics Rule (WAC 173-460)Controls for New Sources of Toxic Air Pollutants

8. Washington State Toxics Rule (WAC 173-460) Class A Toxic Air Pollutants (known and probable carcinogens) Class B Toxic Air Pollutants Small Quantity Emission Rates (SQER) Dispersion Modeling Acceptable Source Impact Levels (ASIL) Additional Controls or Second Tier Analysis

9. Sources of Toxics Fermentation Distillation Drying DDGS Wet Cake Storage Combustion

10. Toxics(modeled by sources) Acetaldehyde Acetic Acid Acrolein Benzene Chromium Cadmium Ethanol Ethyl Acetate Formaldehyde PAH Nickel Nitric Oxide Sulfuric Acid

11. Acetaldehyde Intermediate reaction product in the fermentation process Conditions unfavorable to completion of fermentation can lead to significant quantities In the liver, is converted to acetic acid Primary cause of hangovers

12. Acrolein Undesirable side product of fermentation Piercing disagreeable smell “pepper” in grain alcohol fermentation “pepper periods” inconsistently produced; seems to be produced by more efficient yeasts (Serjak et al, 1953) Can be produced in varying quantities 1-13 ppm depending on strain of yeast Difficult to eliminate particular strain of yeast

13. Five Plants, Five Solutionsto meet Toxics Rule Plymouth Finley Longview Wallula Plymouth, Take Two

15. Plymouth ISCST3 Dispersion modeling required for 8 compounds: acrolein, -- formaldehyde acetaldehyde, -- benzene nickel, -- chromium cadmium, -- sulfuric acid Fugitive emissions not included Very rural location About 400 feet to property line, no residential neighbors Based on modeling inputs, no further control or analysis needed

17. Finley ISCST3 Same size and configuration of plant as Plymouth Fugitive emissions included in estimates Dispersion modeling required for 8 compounds acrolein, -- formaldehyde acetaldehyde, -- benzene nickel, -- chromium cadmium, -- sulfuric acid Meteorological data from Pendleton produced more conservative results Stacks close to property line, railroad spur made this necessary Acrolein predicted impact was 0.0598 µg/m3; three times the ASIL.

18. Finley T-BACT Options RTO, Scrubber, DDGS Dryer Emissions Increase RTO size - cost, increase other pollutants Flaring– BTU of gas too low (<300 Btu/scf) Carbon Adsorption – PM in gas stream would foul adsorber Column Absorption – additional water treatment required, cost Cost of alternatives, “package plant”, made options infeasible

19. Finley – Second Tier Analysis Demographics such as population size, growth, sensitive subgroups Activity patterns nearby Exposure pathways Length of exposure and persistence in environment Current scientific information Extent to which human health might be affected

20. Not expected to be persistent in the environment Air Quality Impacts Maximum concentration at northern property boundary Nearest dwelling 1900 feet to the south – concentration at this receptor 0.02-0.03 µg/m3 8 days between 1987 and 1991 in which maximum 24-hour predicted impact greater than 0.05 µg/m3; majority in the winter (minimal outdoor activity) Of those days, predominant wind direction SW/W 75%, 25% NE; highest impacts minimal at household Predicted concentrations below ASIL at town of Finley, and at the school one mile west Analysis was accepted Finley Second Tier Analysis for Acrolein

22. Longview AERMOD Dispersion modeling required for acrolein acetaldehyde Initially unable to meet ASIL for acrolein and acetaldehyde Relatively urban location Routed scrubber emissions through the RTO Raised stack to 250’ Later, concerns that technology provider would not guarantee acrolein emission rate

24. Wallula AERMOD Dispersion Modeling required for 8 compounds: Acetaldehyde -- Formaldehyde Benzene, -- PAH Nitric Oxide -- Acetic Acid Ethanol -- Ethyl Acetate Initially not meeting ASIL at property boundary Routing scrubber emissions through the RTO was considered, but dryer design precluded this solution Stacks on three scrubbers were raised by 45 feet to meet ASIL requirements; to 125’

26. Plymouth – Take Two AERMOD Plant design routes scrubber emissions through RTO Planning not to dry distillers grains – Wet Cake significant source of acrolein Dispersion modeling required for: acrolein -- formaldehyde, acetaldehyde -- benzene, beryllium, -- cadmium formaldehyde -- PAH Very rural location About 400 feet to property line This proposal routes scrubber emissions through RTO, same size as earlier application yet just meets ASIL for acrolein

27. Five Plants, Five Solutionsto meeting Toxics Rule Plymouth – no additional controls Finley - Second Tier Analysis Longview – rerouted scrubber emissions, raised RTO stack Wallula – raised scrubber stacks Plymouth – rerouted scrubber emissions…not done yet

28. SummaryEthanol in Washington Ethanol producers had not dealt with a rule similar to Washington’s Air Toxics Rule Washington Permit writers had not dealt much with ethanol production Initially caused quite a bit of consternation A variety of site and source specific solutions have been found to allow ethanol production and protect public health

29. Resources Brady, Daniel, and Gregory Pratt; “Volatile Organic Compound emissions Fro Dry Mill Ethanol Production” Minnesota Pollution Control Agency; August 2006; Number 8. Renewable Fuels Association; “How Ethanol is Made”; www.ethanolrfa/org/resource/made Shapouri, Hosein; and James Duffield; “The 2001 Net Energy Balance of Corn-Ethanol”; USDA Office of the Chief Economist; www.ethnaol-gec.org/netenergy/NEYShapouri.htm Serjak, W. C., W. H. Day, J. M. Van Lanen, and C. S. Borruff; “Acrolein Production by Bacteria Found in distillery Grain Mashes; Research Department, Hiram Walker and Sons, Inc., Peoria, Illinois, 1953. Wikipedia; various articles Bernard Brady, P. E.; Order of Approval 0600300; Benton Clean Air Authority, Richland, WA. (Finley) Bernard Brady, P. E.; Order of Approval 2006-0009; Benton Clean Air Authority, Richland, WA. (Plymouth) Clint Lamoreaux, P. E.; Technical Support Document for Air Discharge Permit 06-2704, Southwest Clean Air Agency, Vancouver, WA. (Longview) Robert W. Koster, P. E.; Preliminary Determination for E-85, Inc., Wallula Ethanol Plant (Wallula)

30. Typical Emissions Control

31. Washington State Toxics Rule 

32. Persistence in the Environment Short half life, between 15-20 hours, long range transport unlikely Significant adsorption to solids or sediment not expected; Short groundwater half life of 30-100 hours Uptake predicted to be insignificant due to chemical properties and high reactivity Air Quality Maximum concentration at northern property boundary – 0.0598 µg/m3 Nearest dwelling 1900 feet to the south – concentration at this receptor 0.02-0.03 µg/m3 8 days between 1987 and 1991 in which maximum 24-hour predicted impact greater than 0.05 µg/m3; majority in the winter (minimal outdoor activity) Of those days, predominant wind direction SW/W 75%, 25% NE; highest impacts minimal at household Predicted concentrations below ASIL at town of Finley, and at the school one mile west Finley Second Tier Analysis for Acrolein