Wilkerson Biofuels

7/26/2019 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

R a yC la y

P la tte

B u c h a n a nC lin to n

C a ld w e ll

M o rg a nB e n to n

M o n it e a uH e n ry

B a te s

H ic k o ry

S t. C l a ir

V e rn o n

C e d a r

B a rto nD a d e

M a rie s C ra w fo rd

O s a g e

C a m d e n

L a c le d eD a lla s

P o lk

L a w re n c eJ a s p e r

W e b s te r W rig h t

P u la s k i

C o le

M ille r

T e x a s

N o d a w a y W o rth H a rri s o nA tc h is o n

H o lt

G e n try

A n d re w

C la rkS c o tla n dS c h u y le rP u tn a mM e rc e r

G ru n d yS u lliv a n A d a ir K n o x L e w is

D e K a lbD a v ie s s

L in n

R a n d o lp h

M a c o n

S h e lb yM a rio n

L in c o ln

W a rre n S t. C h a rle s

C a lla w a y

B o o n e

C o o p e rP e ttis

W a s h in g t o n S te .G e n e v i e v e

F ra n k lin

L a fa y e tte

L iv in g s to nC a rro ll

C h a rito n

S a lin eH o w a rd

M o n ro e R a lls

A u d ra inP ik e

J e ffe rso n

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B a rryM c D o n a ldT a n e y O z a rk

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

S to n e

B u tle r

G re e n e

D e n t Iro n S t. F ra n c o is

M a d is o n

W a yn e

C a p eG ir a rd e a u

P e rry

S c o tt

S to d d a rd

R e y n o ld s

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D u n klin

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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