feasibility study and permits


There are a variety of approaches used in organizing the feasibility study effort. The approach may be shaped by the skills of people associated with the proposed project, the availability of financial resources, and the resources available from other partners in the assessment, such as economic development organizations or energy companies. Based on these and other factors the steering committee should determine the means by which to undertake the feasibility study. There are many variations of this process but the preliminary economic assessment is generally followed by the more detailed feasibility study if the initial conclusion is favorable. The next phase generally includes several specific studies that must be integrated into the final economic assessment.


Each of these studies requires a different discipline and approach.
The full project evaluation typically includes:



Based on the specific skills and experience generally required for a credible ethanol plant assessment, many entities award a contract for these services.


The approach can and should directly involve project organizers, even to the extent that some information collection tasks are conducted by members of the steering committee or their designees. However, coordination and data assessment are essential during development of the study. Therefore, a contractor with no emotional attachment to the project or to a specific site will generally produce the most credible analysis.


Primary Criteria:


Determine the most economically viable combination of site, technology and feedstock that, when combined with other key location criteria, results in optimum ethanol production economics.


A general set of criteria has been developed over more than a decade and will be implemented in our feasibility studies.




During the site selection process, the project team should make an initial contact with state and local authorities who are responsible for environmental regulation and relevant zoning permits. The project team should confirm that no pre-existing conditions exist that may make the site difficult or impossible to permit in a timely fashion.


The permit process varies from state-to-state and local jurisdictions may also require specific action steps that can affect the project development time-frame. This initial review of permit requirements will help familiarize the project team with state and local contacts in the various regulatory agencies.


Discussions with regulatory officials will also help define the time-frame in which a project can reasonably be expected to receive permits.


Permit applications require technical data that is generally supplied by the engineering or evelopment firm(s) selected to design and build the ethanol plant. Since the project team may not have contracted with such a firm early in the development process, the project team may not be able to provide detailed information to regulatory authorities.


However, an initial review of this process is important to project developers and regulatory officials alike. As noted, this process can accomplish the following:




Ethanol Plant Emissions


Modern ethanol plants have been designed to incorporate a variety of emission control equipment to make the plants safe, efficient, and to control potential pollutants. It is important for project developers, and regulatory officials, to be familiar with the regulated pollutants. Plant emissions may vary slightly depending on process, design, plant type and feedstock. The typical ethanol production process includes feedstock delivery to the plant, feedstock handling and milling. During this process, tiny particles (particulate matter less than 10 microns in diameter, PM10) are released into the air. PM10 is also emitted during the drying process.


During fermentation, distillation and drying, volatile organic compounds (VOCs) are released. Some VOCs are known as hazardous air pollutants (HAPs). These include some or all of the following: acetaldehyde, acrolein, ethanol, formaldehyde, 2-furaldehyde, methanol, acetic acid and lactic acid. Potential emissions of these compounds must be measured and appropriate controls included in plant design regardless of the biofuel technology being considered.


Carbon monoxide, nitrogen oxides, and sulfur oxides are also generated from combustion in the boilers at the plant. Carbon monoxide may also be generated in the drying process if such a process is included in the plant design. Modern emissions control equipment is included in most plant designs. However, potential emissions must be calculated and appropriate control strategies included in permit pplications. Other emissions may result from activities not associated with the production process. These may include: hydrogen sulfide and VOCs released from the wastewater treatment process; PM10 from the cooling towers; fugitive PM10 and VOC emissions from haul road traffic and equipment leaks, respectively; PM10, NOx, SOx, CO and VOCs from emergency equipment; and potential VOC evaporative loss emissions from the wet distillers grains solids storage piles if dryers are not in use at the plant.



Air Quality Permits


Virtually every state has enacted air quality regulations that require facilities with the potential to emit air pollutants above specified levels to obtain construction and/or operating permits. State regulations may vary in terms of permit requirements and the time-frame for authorizing and issuing permits. The project development team will confirm that the engineering firm or permit consultant with whom they may contract for these services is properly licensed in the state. The project development team should also review applicable work of the prospective firm(s) to determine relevant experience in these important areas. The project team should maintain an awareness of permit conditions and requirements that may affect plant operations initially, and in the future if plant expansion is contemplated.



Construction Permits


Before a new plant is built or an existing facility expands or modifies its plant, an air quality construction permit may be required. There are two types of construction permits: state and federal, known as Prevention of Significant Deterioration (PSD) permits. The type of construction permit needed will depend on the air pollutants that could be released from the new plant or expansion project.


Purpose: First and foremost, air quality construction permits are needed to protect the ambient air quality. Ambient air is the air outside of buildings that the general public has access to. The U.S. Environmental Protection Agency (EPA) has developed national ambient air quality standards (NAAQS) to protect the public health, welfare, and the environment.


Predictive computer modeling is conducted prior to issuing construction permits to valuate the potential impact the plant will have on the ambient air quality. A construction permit cannot be issued if the plant will cause or significantly contribute to violations of the ambient air quality standards. Construction permits also impose federally enforceable requirements that are recognized by the EPA.


Construction permits include emission and/or production limits that ensure air quality protection. The permits contain record keeping, reporting, monitoring, and testing requirements to ensure the plant is able to demonstrate that the permitted limits are met.


The public is given notice that a construction permit may be issued and is given an opportunity to comment on activities that affect their environment. The public notice also provides an opportunity for communities to be educated about the environmental impacts of plants locating in their area.


State Construction Permits Many states have had air quality construction permits in place since 1972 or earlier. In recent years, state permit requirements have been modified to reflect changes in the Clean Air Act Amendments of 1990. Facilities are typically required to obtain a construction permit before they construct, reconstruct or modify any air contaminant source or emission unit where there is a net increase in the potential-to-emit above prescribed quantities. Potential-to-emit (PTE) means the maximum emissions that would result from operating the source at full capacity 24 hours a day, 7 days a week, 52 weeks a year taking into consideration federally enforceable requirements.


Federal Construction Permits EPA developed the federal construction permit program, known as the New Source Review program, in 1977. Many states have incorporated the federal program into the state regulations and thereby maintain the authority to implement and enforce these rules. This program assures the following: economic growth will occur in harmony with the preservation of existing clean air resources; public health and welfare will be protected from adverse affects which might occur even at pollution levels below the ambient standards; and the air quality in areas of special natural recreation, scenic, or historic value, such as national parks and wildlife areas, will be preserved, protected and enhanced.



Operating Permits


An ethanol plant or any other type of biofuels plant may also need to obtain an air quality operating permit. There are two types of operating permits: major source (federal program) and minor source (state program). Again, the potential emissions from the plant will determine whether a facility must obtain a major or minor operating permit.


Purpose: The federal operating permit program, known as the Title V program, was created by the Clean Air Act Amendments of 1990 and was designed to create a “one stop” permit. The Title V operating permit compiles all of the applicable state and federal regulatory requirements, existing construction permit provisions, and record keeping, reporting, testing, and monitoring requirements into one permit. The intention behind listing everything in one permit is to assist facilities with maintaining compliance. Often times, a facility will have several construction permits for several pieces of equipment and it is difficult to keep track of all of the requirements in each permit. One permit with all of the facility’s requirements is intended to make it easier to track the requirements. Public notification is also an important aspect of the operating permit program. The public is notified when an operating permit is proposed and is given the opportunity to comment during the 30-day public notice period.
This gives the public the opportunity to become educated about the impacts that the facility may have on their environment.


Many states have implemented comprehensive operating permit programs for facilities emitting certain air pollutants. Several states have taken the operating permit program one step further than the federal Title V operating permit program. The federal program only regulates larger facilities (or major sources) of air pollution while some state operating permit programs regulate both larger and smaller facilities (or minor sources) of air pollution.
Unlike a construction permit that must typically be obtained prior to construction and is generally valid for the life of the emission unit, an operating permit must usually be applied for within some period, often 2 months, after the facility begins operation. The operating permit may be issued for a specific period of time rather than the life of the operating unit. Project developers should contact state regulatory officials to determine specific permit requirements for the proposed project.


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