Biodiesel Technology In Iowa: Hot Issue ASTSWMO Solid Waste Managers Conference June 16 18, 2009 New Orleans, LA Alex Moon Land Quality Bureau Iowa DNR
FACTS: Pi Primary feedstock is soy 16 plants in Iowa (350 mil gal/yr) 148 plants nationwide (1.39 billion gal/yr Adds $12 billion (about (b t9%) to Iowa GDP Generates $576 million in state tax revenue Supports nearly 83,000 jobs in Iowa
A majority of the biodiesel plants in Iowa are owned by the same investor group Same owner means same technology/equipment used at each plant for processing and refining Combining Vegetable Oil or Animal Fat (100 lbs.) + Methanol or Ethanol (10 lbs.) Yields Biodiesel (100 lbs.) + Glycerin (10 lbs.) Impurities in feedstock requiring filtering of the fuel
Biodiesel Filtering Process Filtering takes place at two stages using diatomaceous earth as the filter media Pretreatment of crude oil Final refining
What Happened in Iowa? Rush to get biodiesel plants into production in 2006 Spent DE filter cake had little to no reuse value It was a new waste stream and initial test results did not point to any glaring concerns Was considered non hazardous and taken to landfills for disposal Not long after landfills started accepting DE, reports of smoldering and then fires started to occur
HELP! Landfills looked to DNR for guidance on DE handling and disposal though our Special Waste Authorization Program With guidance from EPA Region 7, DNR developed a special waste acceptance criteria (SWAC)guideline for the landfills to follow
SWAC identified analytical testing and criteria for handling the DE at the landfill: VOC s s Semi VOC s Diesel l Range Organics Ignitability test Corrosivity test Paint filter test Manage DE separate from MSW Cover the load and bury immediately
Results from SWAC Implementation No glaring gproblems from test data Results gave very little insight to the reason for combustion Still more biodiesel plants were coming online and more reports of fires were being generated Hazmat teams and local lfire departments became involved
What Next? Several landfills indicated that the DE was rarely ever consistent from one load to the next Some loads were soupy while others were dry DNR visited biodiesel plants to view the process by which h the spent DE was generated td
What we found was that all of the plants used the same equipment and the samefiltering process Also found that DE from both stages, initial soy oil refining and final filtration, were being put in the same roll off (this made it difficult to pinpoint problem) What was the cause of the smoldering and spontaneous combustion? Why were some loads a fine dry powder and some not able to pass the paint filter test? Was microbial action the culprit? Was there hexane or methane still in the DE? Should the waste streams be separated and evaluated?
Reached out to others for their expertise/experience i Spoke with other industries in Iowa that used DE as a filtering media (wineries, Cargill) We called other states to see if they had similar experiences with DE Spoke with the biodiesel plant equipment manufacturers
Equipment Vendor A Possible Lead? Felt that the blowers/dryers were not large enough to adequately dry filter cake Soupiness of DE filter cake showing up at landfills tied into inadequate drying time Pointed out how critical it was to ensure that the manufacturer removed excess methanol used in the manufacturing process Residual methanol in the fuel is a safety issue, because even very small amounts reduce the flash point It was determined that the waste was not being dried to the specified standards thus causing the oils to heat up, together withthe the volatiles and spontaneously combusting on hot summer days
Back to the Drawing Board SWAC Re Evaluation 1. Ignitability test 1030and closed cup would be run on DE at all plants 2. Test for Polynuclear Aromatics (PNAs or PAHs) 3. Waste product must be dried thoroughly!
Other Disposal Options: Land Application BOD over 200,000 000 mg/l Would require a lot of land and a very low application rate Strict controls on run off and waterway/well setback distances
Composting Drawbacks Took a long time for piles to heat up Iowa only has one major commercial solid waste compost facility
Refuse Derived Fuel 7,500 8,000 Btu
Landfilling was still the preferred disposal option for the industry as the other options were going gto take more time and research to establish as a permanent solution Landfills were reluctant to take any more DE and DNR was reluctant in having them do so Discussed declaring DE a hazardous waste Since Iowa does not have RCRA C authorization, i we looked to EPA Region 7 for guidance on hazardous waste determination
Characteristic Hazardous Waste? EPA inspected several plants in Iowa Held a workshop in Iowa to provide compliance assistance training to biodiesel plants, landfills and the DNR Contentious training event!
Workshop Follow Up EPA, DNRand industry representatives metas a group to discuss proper waste characterization procedures EPA explained that it was the waste generator s responsibility to ensure that the DE was non hazardous The best way to do prove this was to develop Standard Operating Procedures (SOP)
SOP Similar to SWAC for landfills, but directed at procedures that each plant would follow to ensure that the DE was non hazardous and safe for disposal Provided dthat t SOP was followed, it would be less likely that EPA s first action would be enforcement tif there was a fire
Did the SOP Work? Not consistently, reportsofof landfill fires continued Landfills faced pressure from industry to keep taking the DE DNR looked again to EPA to decide whether h or not the DE should be treated as hazardous waste What Next?
SOP Re reviewed by EPA and DNR
EPA and DNR collaborate to recommend revisions/improvements to SOP
Suggested changes Have the SOP more closely reflect the conditions of 40 CFR Part 262.11 (hazardous waste determination) Reference EPA document SW 846 which provides detailed descriptions of sampling and testing ti methods Include a measurement of percent moisture content Should dictate appropriate actions on the part of the landfill and transporter to assure proper management of the waste Should address what actions the plant should take if it determines a batch of DE is hazardous. Are there disposal options in place? Who should they call for disposal?
Industry very reluctant to even consider the outcome of following the SOP as DE being considered hazardous Agreed to make some changes to SOP based on DNR/EPA recommendations Industry requests 90 days to work out the bugs of following the SOP and for management to talk with personnel at each biodiesel plant
Outcome EPA agrees to 90 day trial period and to focus on compliance assistance instead of enforcement during that time period Industry takes SOP seriously Plant workers are trained properly on SOP No fires since SOP revised
Question? Alex Moon Iowa DNR 515 281 6807 alex.moon@dnr.iowa.gov Thank You