Federally mandated GHG reporting

On October 30, 2009, EPA finalized 40 CFR Parts 86, 87, and 89 Mandatory Reporting of Greenhouse Gases (GHG). This rule requires certain source categories to report actual GHG emissions to EPA on an annual basis. Ethanol production, source category 325193, is not included as part of the final rule, but is expected to be incorporated within the next year or so. ICM will keep you posted on any future updates to 40 CFR Parts 86, 87, and 89.

Even though ethanol production is considered exempt from reporting at this time, ethanol plants will be required to report combustion GHG emissions from the facility as part of Subpart C of this rule. The reporting threshold under this rule is 25,000 tons CO2e/year; therefore, all ethanol plants would be subject to this reporting threshold for combustion CO2e emissions.

Timeline

1/1/2010 – Start collecting data.
1/31/2010 – Deadline for submitting application to extend use of Best Available Monitoring Methods.*
3/31/2010 – Monitors installed and calibrated.  Begin using required monitoring methods (if extension request not obtained).
12/31/2010 – Complete 2010 data collection.
1/30/2011 – Submit certificate of representation.
3/31/2011 – Submit GHG Report for 2010 to EPA.

• Submit corrected report 45 days after each discovery.
• Submit annual reports on 3/31 of each year.

Monitoring Plan

• Identify responsibilities for data collection.
• Explain processes and methods used for data collection.
• Describe QA/QC procedures for monitors.
• On-site by 4/1/2010 – does not get submitted.

Special Provisions for 2010

• Best Available Monitoring Methods can be used through 3/31/2010
• Can be granted an extension through 2010, request must be made no later than 11/29/2009.
• Abbreviated emissions report for Subpart C facilities only.
• Can use any calculation method listed in Subpart C.

Relationship to State Programs

CO2e Emission Calculation Methods

• Four (4) methods (tiers).
• Tier usage based on unit size, fuel type, and other factors.
• Emission factors listed in regulation.
• CEMS monitoring may be required if certain conditions are met.

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ICM is here to help

ICM can help you meet all obligations associated with this federal mandate. We can help you determine applicability of this mandate to your specific plant, and if we find that your plant is required to report, we can help with:

• Emission Calculation
• Development of a monitoring plan
• Reporting
• Special Provisions for 2010
• Extension Applications

If you'd like a quote for our assistance with any or all of these services, please either call us at (970) 206-4480, or send us an e-mail.

Carbon Lifecycle Analysis

With the new Obama administration’s focus on creating green-collar jobs while reducing carbon emissions, documenting your facility’s carbon footprint now to establish a carbon emissions baseline is a smart business move. ICM anticipates carbon lifecycle analysis may be a requirement for the production of renewable fuels in the not-too-distant future, and your facility may reap financial benefits by documenting any reductions your plant makes in carbon emissions.

To document reductions, you must first establish a baseline. Whether you incorporate new energy-saving equipment or simply train your operators to run your plant more efficiently, it’s in your plant’s financial interest (from a carbon trading point of view) to draw your line in the sand now, so your facility will realize the benefits of every improvement your facility implements.

ICM’s Carbon Lifecycle Analysis utilizes a proprietary program customized for ethanol production to perform a full field-to-wheels carbon footprint baseline analysis for the ethanol produced by any ethanol facility, anywhere in the world. The report generated can be used today to help you analyze the production and energy use modifications necessary for your plant (with qualifying feedstock) to qualify as an Advanced Biofuels producer.

ICM's LCA gets results

Our analysis has already helped one ethanol facility save significant capital: Because of local eco-friendly farming practices used in growing that plant’s feedstock, our report found that the global warming intensity of their ethanol (as compared to gasoline) was already low enough to qualify as an advanced biofuel, and that no additional carbon reduction measures—such as the gasification unit the facility was considering purchasing—would be necessary.*  

We welcome the opportunity to talk to you about the benefits our analysis offers to your specific facility.

Please give us a call at 877-456-8588 to discuss how we can work together to achieve profitable results for your plant.

*Qualification as Advanced Biofuels producer is contingent upon indirect land use change adder value of zero.

Ethanol Environmental Compliance System (ECS)

This user-friendly, paperless program automates all of your plant’s environmental management information and reporting, so it saves you time, money, and headaches. In an easy-to-use Microsoft® Excel format, ICM’s Ethanol ECS will keep your plant in line with your permits while recording 12-month rolling averages. Used widely throughout the ethanol industry, ICM’s Ethanol ECS software is the only environmental management system developed specifically for the ethanol industry. This one-stop location for record keeping requirements helps a state agency inspection go more smoothly.

Please give us a call at 877-456-8588 to discuss how we can support your environmental compliance needs.

Site Security Plan (SSP)

ICM draws from years of experience in the ethanol industry to assist you in managing your plant DOT security compliance obligations for hazardous material transportation. Our easy-to-use, DOT-approved, customizable Site Security Plan covers:

• Hazardous Materials
• Security Plan Implementation, Administration, & Training
• Threat Levels
• Vulnerabilities & Prevention

Our team can even help you customize it.

Please give us a call at 877-456-8588 to discuss how we can support your site security needs.

Hazardous Waste Characterization Tool (WCT)

Keeping records of waste generation, storage, and disposal as required for ethanol plants to retain their classification as Conditionally Exempt Small Quantity Generators (CESQG) is simple with ICM’s Hazardous Waste Characterization Tool. Pre-classifying more than 50 basic wastes, this tool can easily integrate with ICM’s Ethanol Environmental Compliance System.

Please give us a call 877-456-8588 to discuss how we can support your reporting needs.

Leak Detection and Repair (LDAR) Kit

Under 40 CFR 60 (Title 40 of the Code of Federal Regulations, Part 60), Subparts VV and VVa regulate VOC equipment leaks in the Synthetic Organic Chemicals Manufacturing Industry. This regulation is known throughout the industry as Leak Detection and Repair, or LDAR. Subparts VV and VVa require ethanol facilities to perform monitoring on a regular basis, in addition to implementing record keeping and semi-annual reporting.

ICM’s LDAR Kit makes the monitoring, record keeping, and reporting requirements of Subparts VV and VVa easy and inexpensive. For about the same cost as hiring a company to perform the service on a one-time basis, you can purchase our easy-to-use kit that includes all the tools necessary to perform LDAR requirements in-house, saving thousands of dollars in a few years’ time. Our kit includes:

• VOC monitor
• Intrinsically safe barcode scanner/PDA
• Barcode creation and printing capabilities
• Reporting tool

Depending on your needs, we can also supply equipment tags preprinted with your facility's LDAR points.

Please give us a call at 877-456-8588 to discuss how we can help you with your LDAR monitoring and reporting requirements.

Permitting Service and Support

With worldwide permitting experience in 37 states and nine countries across a wide base of industries, ICM's Environmental Affairs team has the background necessary to assist in securing the permits, plans, and approvals necessary to build, start up, and continue operating your facility.

As a single-source, full-service provider, ICM delivers the solutions your plant needs. When you trust ICM to manage your full scope of environmental needs, you'll have the peace of mind guaranteed by our assurance that nothing will get missed in your plant's complex maze of reporting and permitting regulations.

We offer services for an all-inclusive list of permitting requirements. Our services include:

• Air Construction Permit (including expansions and modifications)
• Storm Water (Construction and Industrial)
• State Historical Research
• Endangered Species Research
• Water Discharge Permit (NPDES, POTW, Irrigation, and/or Irrigation Plan)
• Spill Prevention Control and Countermeasures Plan / Facility Response Plan
• Risk Management Plan
• Operating Permit
• Compliance Audits
• Annual Reporting (Tier II, TRI, Emissions Inventory)

Please give us a call at 877-456-8588 to discuss how we can help you manage your environmental needs.

2010 Environmental Compliance Conference

August 25 – 26, 2010 | Fort Collins, Colorado

Sign up today for ICM's 6th Annual Environmental Compliance Conference. Held in beautiful Fort Collins, CO, this two-day conference willl cover new regulations, environmental management solutions, and all aspects of environmental permitting including required permit updates and common pitfalls.

You'll also have the opportunity to attend a presentation given by Region 8 EPA, in conjunction with Region 7, about RMP compliance.

Learn more about: Carbon Modeling RFS2 RMP/PSM GHG Reporting Plus Much More! $325 Registration Fee Includes: 2-day training session Complimentary tour of New Belgium Brewery Lunch and dinner provided on August 25

Download Tentative Agenda Download Travel Information

Questions? For more information, contact Adrien Kogut at 970.206.4480 or Adrien.Kogut@icminc.com.