Integration of biodiesel RIN verification in the BQ-9000 program
October 2, 2012
BY Pete Moss
BQ-9000 is the gold standard for quality control in the biodiesel industry. The accreditation program was developed by the National Biodiesel Board to ensure better quality in a rapidly growing market. A study completed in 2005-‘06 by the NBB and the National Renewable Energy Laboratory found that 50 percent of tested biodiesel samples failed at least one of the categories in ASTM D6751. At the time, very few biodiesel firms were BQ-9000-certified. Now, 44 biodiesel producers are BQ-9000-accredited, representing 80 percent of biodiesel production, according to the National Biodiesel Accreditation Commission. Quality issues are on the decline and BQ-9000 plants are generally held in higher regard.
RIN fraud is another area that has plagued the industry. Biodiesel RINs, created when biodiesel is produced from an approved pathway, have failed integrity trials at the national level. The U.S. EPA has determined that more than 140 million invalid RINs were generated in 2010 and 2011, costing obligated parties almost $200 million to replace the RINs and $3.6 million in settlements. Experts believe that more fraud has yet to be uncovered by authorities, and that fraudulent RINs only represent a portion of the total number of invalid RINs that have been generated. The biodiesel industry’s reputation, perhaps its very survival, is at risk. Certainly small producers have been disproportionally affected.
Fraud is committed when a producer knowingly generates invalid RINs, sometimes when no physical gallons are produced. Invalid RINs, however, can also be generated in ignorance by using unapproved feedstock, misrepresenting feedstock, separating RINs without meeting the EPA requirements, and neglecting temperature correction factors, to name a few. Reprocessing biodiesel produced at another facility will also lead to invalid RINs. Whether by fraud or ignorance, there are relatively simple solutions that can be employed to greatly minimize the generation of invalid RINs.
The EPA uses the term Quality Assurance Program to refer to a third-party validation program that checks for fraud and mistakes. One concept recently introduced by Frazier, Barnes & Associates is the integration of the BQ-9000 program with the QAP. This combination will deliver equally beneficial results as the original BQ-9000 program—unfreezing the market and restoring faith in producers. RINtrust, a QAP formed by FBA and RIN Attest and Advisory Services, has recently formed a strategic alliance with Biodiesel Quality Systems, a leading BQ-9000 service provider, to integrate its RIN verification program into BQ-9000 programs. Biodiesel companies that adopt this powerful new program will not only gain increased credibility in the marketplace, but also a streamlined approach to doing business and a much more sustainable operation.
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The option to integrate the RINtrust verification program into a new or existing BQ-9000 program adds structure to the biodiesel facility and allows the plant to better manage document tracking, thus minimizing the possibility of mistakes. Plants that choose to use BQ-9000 and a RIN QAP will demonstrate to the market their commitment to quality and accuracy. As the 2013 mandate ramps up to 1.28 billion gallons, it is increasingly important to make sure that every one of those gallons, and the associated RINs, are generated properly.
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