Wilkerson Biofuels
Transcript of Wilkerson Biofuels
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DEPARTMENT OF
NATURALRESOURCES
E nvironmental E mergency R esponse
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Belle Fountain Ditch
Glycerin ReleaseBy:
Travis Abernathy
Curtis GateleyJosh Wilkerson
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Overview
Biodiesel Industry (Process, ingredients,
products, proper disposal)
Belle Fountain Ditch Incident
Site Cleanup, Permitting Process
Biodiesel Industry Inspections
Improvements: Biodiesel Compliance
Manual
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Biodiesel
Biodegradable, combustible fuel derived
from vegetable oil/animal fat
B100; Blends of B5, B20
Industries throughout regional area
Homebrewers are common
C a s sJ o h n s o n
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C a lla w a y
B o o n e
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L iv in g s to nC a rro ll
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D o u g la s
S h a n n o n
C a rte rH o w e ll
O re g o nR ip le y
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B u tle r
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D e n t Iro n S t. F ra n c o is
M a d is o n
W a yn e
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P e rry
S c o tt
S to d d a rd
R e y n o ld s
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J a c k s o n
S p rin g fie ld
P o p la r B lu ff
K a n s a s C it y
S t. L o u is
M a c o n
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Biodiesel
Commercial biodiesel production is usually done by base-catalyzed transesterification of fats/oils.
Fats/oils are reacted with alcohol (methanol), using astrong alkaline catalyst.
This yields mono-alkyl methyl esters (biodiesel) andglycerin.
Glycerin is a sugar and by-product of the process.
100 pounds + 10 pounds = 10 pounds + 100 poundsTriglyceride Alcohol Glycerin Mono-Alkyl Esters
(Soy Oil) (Methanol) (Biodiesel)
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Biodiesel Process
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Biodiesel
Feedstock
Methanol
Catalyst
Glycerin Waste
Finished Biodiesel
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Hazards
Methanol- Highly Flammable- Health Hazard (toxic)
Sodium/Potassium Hydroxide, Sodium Methylate- Corrosive (Alkaline)
Glycerin- High Oxygen Demand
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Glycerin by-product
Approximately 10 gallons of glycerin is
created for every 100 gallons of biodieselproduced.
Glycerin is commonly contaminated withunused alkaline catalyst and excessmethanol. Glycerin would requireprocessing to elevate the purity to 99% ormore for marketability.
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Glycerin-Haz Waste?
Methanol contamination could elevate the
glycerin to an ignitable haz waste due toflashpoint
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Belle Fountain Ditch
EER Spill Line notified of large fish kill on 9/30/07
Additional calls and investigation led to findingunrefined waste glycerin in agricultural fieldditch.
Field ditch was tributary to Waters of the State.
Runoff from waste entered the stream.
RP was in the Biodiesel Production Industry.
Land application of glycerin was conducted, alongwith an additional dumpsite found.
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Site Map
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2nd
Glycerin Dumpsite
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Damages/Costs
EER and other State and Federal agenciesconducted oversight of site for months
Decreased water quality
25,000 fish counted, amounting to ~100,000
fish dead
Killed last population of federally listedFat Pocketbook Mussel, Potamilus capax .
Violations of State and Federal environmentallaws resulting in substantial penalties.
Federal Felony Indictment for CWA violations.
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Responsible Party Costs
Violation of Clean Water Act
- 2 years probation- $10,000 fine
Cleanup Cost
Costs associated w/ agencies involved
Wildlife/Natural Resource damages
Attorney fees
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Fish damages
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Mussel Damages
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Agencies Involved
MO Department of Natural Resources
MO Department of Conservation
EPA Regions 6 & 7
US Fish and Wildlife Service
Arkansas Deparment of EnvironmentalQuality (ADQ)
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Permitting Considerations
Big piles of glycerin contaminated soil
Very high oxygen demand in glycerin
Methanol present at high levels
Storm water flows during cleanup
Completing the clean up and returning thearea to crop production
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Permitting Considerations
Contaminated soil was covered in plastic
Investigation revealed soil was nothomogeneous, clumps of unincorporatedglycerin still present.
Methanol content within these clumpsexceeded our Default Target Levels forground water and drinking waterprotection.
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What are we going to allow?
Initial thought was simply to require all of
the soil to be landfilled
Applicant sought to land apply everything
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The Plan
Decided to allow bioremediation treatment
of most of the soil
clumps of glycerin hauled to landfill,department staff overseeing visual segregation
Area receiving land applied soil bermed toprevent storm water runon, and prevent runoff
Soil spread in treatment cell, allowing glycerin
and methanol to break down
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Permit Conditions
Plastic must be removed and properly
disposed of in a landfill
Storm Water Pollution Prevention Planrequired before permit issuance, then
incorporated into the permit by reference
Instream monitoring to demonstrate nofurther impact on the stream
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How do we know if it works?
Permit required soil samples taken from
the treatment cell to verify methanol isgone
Vegetation must be established
However
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Results
All soil samples revealed non detect for
methanol
Area will be returned to crop production
Once plastic is removed, the NPDESpermit may be terminated
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Results
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Inspection Process
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The Inspections.
Inspected a total of three facilities in our
region.
Two had several deficiencies.
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Problems Faced. Very little information on large scale
biodiesel production.
Most information obtained from the internetdeals with small scale production or homebrewers.
Public misconceptions on biofuels.
Sold to the public as safe for the
environment (biodegradable).
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Inexperience of manufacturers.
Many were farmers, small business owners and/orentrepreneurs with little or no experience in fuelmanufacturing.
The sudden and rapid growth of the industry.
The plants are relatively simple and easy to construct.
The facilities basically consist of a large metal building,secondary containment and a tank farm. The rest of theequipment is brought in on skids and put together on-site.
Problems Faced.
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Plant equipment is broughtin on skids and puttogether on-site.
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Lack of industry specific regulations and
government oversight.
Regulations did not have time to catch up with
the rapidly growing and relatively newindustry.
No prior inspections or enforcement cases to
reference.
Lack of industry standards and support.
Did not appear to be a set standard or
guidelines in the construction of thesefacilities.
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What we discovered.
Shoddy construction andquestionable materials
used.
Tank insulation material ishighly absorbent.
Tanks sit on a gasket thatwould dissolve once itcomes in contact withproduct and leave an oilysheen during rain events.
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Tank Insulation
One of the facilities weinspected reported releaseof poultry fat into the
secondary containment .
After the spill was cleanedup, the insulation absorbedthe product or poultry fat
and would continue to seepout and leave an oily sheenduring rain events.
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Tank Gasket
The tanks sit on gasketconstructed of felt or tar
paper like material.
One of the facilities weinspected reported a spill ofbiodiesel product into the
secondary containment.
The gasket under the tanksdissolved and wouldcontinue to leave an oilysheen during rain events.
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Shoddy construction.
Cracks in concrete walls ofthe secondary containmentstructure.
This facility was a littleover a year old at the timethis picture was taken .
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Lack of Industry Standards
This facility did nothave secondarycontainment for spillsthat may occur insidethe production plant.
Floor of facility wasflat and did not haveany built in
containment.
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Faulty equipment & design.
Two of the facilitiesreported problems with
the oil & waterseparators.
Facilities claimed thatthe equipment wasfaulty and not effectivein removing oil andproduct from the stormwater.
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What we learned.
No production/operational/technical support from NaturalBiodiesel Board (NBB) and little provided frommanufacturer.
Some voiced concerns over shoddy construction methodsand designs and would like to see industry minimums orrecommendations.
MFA will only buy biodiesel derived from soy oil (whichcurrently is the more expensive of the common feedstocks).
Construction materials not compatible with finished product(ie. gaskets that dissolve or crack when in contact withbiodiesel).
Lack of business management skills appears to be moredetrimental than market conditions
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Where to go from here?
Increase public awareness.
Current media and internet outlets have notprovided accurate information on biofuels.
Because something is biodegradable does notmake it safe for the environment.
Set industry minimum design standards.
Increase discussions with industry
stakeholders.
Provide additional training to State andFederal regulators.
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Steps Taken
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Purpose of the ManualThis compliance assistance manual serves as a road map ofinformation on federal environmental programs and federal,
state, and local agency roles as they apply to partiesinterested in designing, building, and operating biodieselmanufacturing facilities. This manual emphasizes federalenvironmental laws and regulations implemented by the
United States Environmental Protection Agency and itsstate partners. Air, water, hazardous waste, accidentprevention and release reporting are examples ofrequirements that might apply.
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Questions?