Governors Ethanol CoalitionOmaha, NE

August 29, 2007

by Bill Roddy & Greg Krissek

250 tpy Rule Update

● Fuel Ethanol Process Overview● Equipment Standards● Emission Sources● Rulemaking Dates● 250 tpy Rule Details● Q & A

Overview of Discussion

US Ethanol Production

● As of January 2007 Approximately 5.6 billion gallons ethanol

being produced annually in US. Up 300% since Year 2000 In 2006, approximately 17% of corn

produced went to ethanol productionSource: Renewable Fuels Association, Ethanol Industry Outlook 2007, Building New Horizons

Ethanol industry experiencing significant growth

110 MGY

50 MGY

Typical Air Emission Control Equipment:● Dryer (DDGS) Emissions: Thermal Oxidizer● Denatured Ethanol Loadout: Flare● Biomethanator: Flare● Fermentation: High Efficiency Packed Tower Scrubber● Fugitive VOCs: Leak Detection and Repair● Road Dust: Regular Plant Street Sweeping● Process Dust: Baghouses● Tanks: Internal Floating Roofs (with double wiper seals)● Process Vents: Vented to Thermal Oxidizer● Diesel Emergency Water Pump: Lean Burn Technology

Industry “Standards”

Typical Emission Sources

Bushmills Ethanol: 50 MMgpy (operating), 500,000 tons/yr grain (17,857,144 bu/yr), 162,218 tpy DDGS

EPA’s 250 tpy Rulemaking

Federal Register Rulemaking● March 9, 2006: Proposed Rule● May 1, 2007: Final Rule ● July 2, 2007: Effective Date

250 tpy Rule Summary

Air Permitting as “minor” source● < 100 tons/year (old rule)● < 250 tons/year (new rule)● States required to adopt 250 tpy rule● NRDC filed lawsuit on July 2, 2007● RFA team is preparing “Amicus Brief”● Public health, safety and environment

remain protected with new rule

250 tpy rule details

● Ethanol plants – no longer chemical process plants for PSD purposes.

● 250 rule applies – new and modified plants.● Fugitives (road dust, pumps, valves, flanges

& perhaps cooling towers) are no longer included in the PSD emission inventory for applicability. LDAR is still required.

● Existing plants may expand to 249 tons & remain minor. Leaves additional 249 tons.

● All plants will still need TOs and Scrubbers.

Thank you

Questions?