Complying with environmental regulations is a burdensome task that is part of daily operations at an ethanol plant. Failure to understand the consequences of this tangential yet important aspect of plant operations will in the short term bring a financial hit and in the long term carry a public relations scar.
Therefore, it is essential to understand how to efficiently comply with these regulations. Ethanol plant management personnel equipped with the right information are less likely to unintentionally allow their facility to violate its air permit. Likewise, they are more likely to get the most value out of their plant's environmental dollar by identifying the hidden costs in a stack-testing project and finding the vendor with the overall lowest cost. Armed with the right knowledge, management personnel are also able to match the type of test needed with the type of vendor available.
Let's start by looking at what is a common method of dealing with stack-testing for some U.S. ethanol plants. Typically, a plant engineer will issue a request for a quote (RFQ) from two local or regional stack-testing companies. The RFQ will ask for references and, most notably, a price for the services needed. With the answers to these two questions in hand, some ethanol plant management personnel might assume they have the necessary information to properly invest the plant's money in compliance testing.
However, that's not always the case. Here are a couple of plausible scenarios that could occur. Scerario No. 1: The management team of an ethanol plant pays little attention to the facility's stack-testing needs. Eventually, the need arises out of necessity, and they hire a local company to get the job done. As soon as the test results are submitted, the management team quickly sends the information to the state, but it doesn't bother to compare the results of the stack test to their air permit. The state regulators do make the comparison, however, and they quickly fine the plant for being out of compliance. In this case, the stack-testing company did nothing ostensibly wrong. It performed the tests and gave the plant's management personnel a set of emissions rates. Scenario No. 2: Again, the stack-testing company does just what the RFQ asks, performing a set of tests and giving the results to plant management. This time, the managers compare the emissions rates to the facility's permit, and all looks well. However, shortly after the report is submitted to the state, the plant is informed by state officials that an incorrect method was used in one of the tests. Part or all of the testing must be redone.
These scenarios illustrate the unfortunate fact that stack-testing receives little attention from some producers. However, the more management personnel know about emissions testing, the better prepared they are to efficiently invest their employer's money into it. A brief overview of the genesis of the business—and a primer on the "dos and don'ts" of picking a stack-testing company—is a good starting point.
In 1968, Congress passed the first Clean Air Act. It called for the U.S. EPA to regulate hazardous air pollutants. Those regulations grow tougher each year, as the lawmakers and bureaucrats churn out new standards. The ethanol industry will face federal environmental reviews every five years—and each milestone could bring new and tougher emissions limits.
The EPA is broken down into various regions. Most ethanol plants are in Region 5 or Region 7. The federal EPA delegates its authority to each state's environmental agency. It is from each state's environmental department that an ethanol plant receives its air permit. Permitting regulations require ethanol plants to conduct initial performance tests and usually subsequent annual testing. These tests determine whether or not an ethanol plant meets the requirements of its air permit.
Five Key Criteria
There are five key criteria with which to evaluate companies that perform stack-testing: company size, crew quality, report turnaround, safety and company focus. By prequalifying a vendor based on these standards, management personnel are making the first step in navigating through difficult waters. Producers who know which stack-testing companies lead in these critical areas will understand the total cost of stack testing, and be able to choose the best fit for the needs of a particular job.
Every air permit requires a stack test to be done while the plant is running at or near peak production. This often means a plant's first tests can't be conducted immediately after start-up, and small stack-testing firms can't always meet a schedule that has suffered through a postponement. The initial test of a plant requires a large crew to complete the project. The larger the job, the larger the capabilities of the company that performs the project should be.
The key factor for choosing a company for an initial start-up stack test is finding one with several crews. This will give a plant scheduling flexibility. Stack-testing companies should be asked how many equipped testing vehicles they own. The more they have, the more flexibility a producer may have in scheduling. Remember, new ethanol plants have only a certain amount of time to complete initial tests. If a small vendor is chosen, the tail may end up wagging the dog, so to speak.
Small Operators Adequate for Annual Tests
Looking for a large company is not necessary when it comes to an ethanol plant's annual stack test. That test requires a small crew to complete the project, and it would be acceptable to use a small company for the job.
Often, situations arise during testing that require the stack-testing crew to think through a problem. The more educated and experienced a crew is, the better it can help a producer deal with unplanned events. Ask vendors to supply résumés of the crew members who will be on-site. A good testing crew should always have a good communicator on-site during the testing. Furthermore, stack-testing companies sometimes use temporary or part-time help to accommodate busy schedules. Ethanol producers should demand that full-time, experienced experts perform the work.
Most companies claim they can have a completed stack emissions report back to the plant in four to five weeks. However, when schedules are full, one month sometimes turns into two. Have these service providers guarantee a timeline—four weeks or less. Once the report is submitted, it should be carefully reviewed. A good vendor can communicate to plant management what the results of half the tests are before leaving the site.
Stack-testing is a dangerous occupation. Insist on a vendor with an Experience Modification Rate under one. The insurance industry has developed experience-rating systems as an equitable means of determining premiums for workers' compensation insurance. These rating systems consider the average workers' compensation losses for a given firm's type of work and amount of payroll, and predict the dollar amount of expected losses to be paid by that employer in a designated rating period—usually three years. The rating is based on a comparison of firms doing similar types of work. The employer is rated against the average expected performance in each work classification. Losses incurred by the employer for the rating period are then compared with the expected losses to develop an experience rating. Workers' compensation insurance premiums for a contractor are adjusted by this rate, which is called the experience modification rate (EMR). Lower rates, meaning that fewer or less severe accidents had occurred than were expected, result in lower insurance costs. Any accident will affect an ethanol plant's insurance rates.
Last but not least, ask how long the company has been in business and what percentage of its sales come from stack-testing. The more focused the vendor is on stack-testing, the better qualified it likely is to perform the work. When the right vendor is on the job, utilize the company's experience and form a partnership to accomplish necessary goals.
Michael Cybulski is with Metco Environmental, an Indianapolis-based stack-testing company. Reach him at
mcybulski@testamericainc.com or (281) 391-1919.