Iowa Department of Natural Resources

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. . Ethanol Emission Sources (dry factories). Grain Receiving, Conveying,

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Iowa Department of Natural Resources Governor's Ethanol Conference, Kansas City, KS February 9, 2006

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Ethanol Emission Sources (dry plants) Grain Receiving, Conveying, & Storage Hammermill Fermentation & Distillation Boiler DDGS Dryer & Cooler DDGS Storage & Loading Storage Tanks Ethanol Loadout Haul Roads, Cooling Towers, Equipment Leaks, and so forth

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Federal necessities NSPS Subparts VV, Db or Dc, Kb Normally insufficient capacity limit with regards to DD Subpart Y for coal-terminated plants NESHAP No measures as of now apply aside from DDDDD (evaporator MACT) Dry factories in Iowa are manufactured minors, and DNR has not needed to do a 112(g)

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Federal Requirements (cont.) PSD Most dry factories are engineered minor – Iowa has one which is tripling limit and going through PSD now Capacity regularly between 45 to 65 mmgal/yr DNR has allowed up to 130 mmgal/yr as an engineered minor – requiring intermittent testing Support office issues with co-found grain lifts or CO2 preparing offices Issues with plants that include limit soon after development – staged venture or not?

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Other Requirements State Requirements – Iowa is requiring container vent channels on the grain stockpiling storehouses, or else that they be under negative weight when filling (and along these lines debilitating through the corn accepting baghouse), as the DNR has worries that the storehouses can't dependably meet the state standard of 0.1 gr/scf when uncontrolled Modeled consistence with NAAQS – ordinarily not an issue. Pull streets can bring about challenges with PSD destinations, contingent upon the area of the receptor network. Scent – Iowa does not manage smells Air toxics – Iowa does not require air toxics chance appraisals

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Grain Receiving, Handling & Hammermills Standard AP-42 discharge variables Controlled by texture channels Potential PSD issues on the off chance that they are co-situated with a current lift from whom they will get a greater part of their corn.

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Fermentation & Distillation Usually controlled by a scrubber, and now and then further vented to the warm oxidizer on the DDGS dryers. CO2 discharges from fermenters might be sold to an outsider

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Fermentation & Distillation proceeded with Based on DNR tests, VOC emanation elements (scrubber just) are exceptionally factor Fermentation 0.026 to 3.04 lb/1000 lady Distillation ( 1 source) – 0.007 lb/1000 lady HAP outflows comparably factor Acetaldehyde most astounding

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Boilers Most regular gas let go Some utilization warm recuperation steam generators, tied in with the warm oxidizer on the DDGS dryers EPA direction that NSPS Subpart Db applies to HRSGs in light of the rating of the warm oxidizer Some utilizing PEMS – EPA has a proposition to build the exhibition expected to meet precision necessities

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Boilers (cont.) 2 plants with coal-let go percolating liquid bed boilers allowed in 2005 as manufactured minors – 220 MMBtu/hr with 165,000 lb/hr steam HRSG Used as control for the DDGS dryers and refining gear Controlled by SNCR, lime infusion, & baghouse, with max 0.25% S coal.

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Permitted Boiler Comparison (55 mmgal/yr plants) Coal – 220 mmbtu/hr, with 165,000 lb/hr steam HRSG, 2 methanators, 3 dryers, refining prepare. – PM likewise incorporates coal, limestone & flyash taking care of PTEs Natural Gas – HRSG (125 mmbtu/hr TO), 2 dryers, methanator, refining gear

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DDGS Dryer Controlled by warm oxidizers to remain minor for PSD Variable VOC discharge components 0.013 lb/1000 lady to 0.17 lb/1000 lady Highly factor HAP emanations Acetaldehyde or methanol most astounding

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DDGS Cooler & Handling Variable VOC outflows on DDGS cooler 0.0265 lb/ton to 0.147 lb/ton Acetaldehyde most noteworthy HAP DDGS Loadout controlled by baghouse

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Storage Tanks & Ethanol Loadout Tank outflows utilizing EPA's TANK program Loadout - take after AP-42 If non-committed tanks or trucks permitted, controlled by flares in everything except littlest plants Rail loadout in devoted tank autos might be controlled by flares, particularly if the plant is more than 65 mmgal/yr

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Other sources Haul streets Higher limit plants may require point by point working conditions NSPS VV sources Cooling towers Wetcake stockpiling Miscellaneous subordinate sources (germ & grain creation, fire pumps, turbines or generators, and so forth.)

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