Permitting of Wastewater Discharges from Biodiesel Production Facilities in Colorado

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Permitting of Wastewater Discharges from Biodiesel Production Facilities in Colorado Presentation at A Biodiesel CO-OPS Conference Strategies for Community-Based Biodiesel Groups http://www.collectivebiodiesel.org/ Hosted by the Student Council on Sustainability at the Colorado School of Mines July 13-15, 2007 Gary Beers, PhD, Manager Industrial Permits Unit (Permits Section) Water Quality Control Division Colorado Department of Public Health and Environment Denver, Colorado http://www.cdphe.state.co.us/wq/permitsunit/index.html

Jurisdiction Authority Federal Within Within Facilities Tribal State of Boundaries Colorado EPA EPA Tribe State Agencies

Discharge to Surface Waters Release to natural drainage systems or man-made conveyance systems (including alluvial groundwaters and excluding waters withdrawn for use) WQCD Permit

Discharge to Groundwaters Injection Well Unlined Pond Land Disposal WQCC sets WQ standards and implementing agencies can issue permits (SB 89-181, 1990) EPA UIC Permit Hazardous Materials and Waste Management Division CO Oil and Gas Conservation Commission CO Department of Natural Resources (DMG) State Engineer s Office Division of Oil and Public Safety Water Quality Control Division (WQCD)

Types of WQCD Discharge Permits General Permits Category of dischargers or dischargers within a geographical area. Certification issued to each discharger Individual Permits Individual discharger Usually flow greater than 1 MGD and/or high risk of toxic pollutants Permit issued to each discharger

Types of Individual Permits Stormwater (6) Municipal 4 cities and CDOT Industrial DIA Process Water (430) Domestic surface water (230) groundwater (100) Industrial surface water (90) groundwater (10)

Types of General Permits Stormwater (5,555) Construction (3723) Sand and Gravel (465) Light Industries (706) Heavy Industries (154) Mining Industries (77) Recycling Industries (103) MS4 Phase II (116) NO Exposure (183) Industrial Process Water (1,146) Construction Dewater (156) Sand and gravel (633) Coal Mining (15) Coalbed methane (13) Water Treatment (80) Water Distribution (9) Groundwater Remediation (21) Minimal Industrial (218) Aquatic Production (13)

Establishing Effluent Limits Technology-based Limits Federal Effluent Limitation Guidelines (ELG) based on processes. State secondary treatment requirements (TSS, BOD, ph, oil grease) Water-quality-based Limits State How much additional load can stream receive without concentration exceeding water quality standard. Use reasonable potential analysis. Also, certain waters need additional protection under antidegradation review Select most stringent as effluent limit (can require additional monitoring for reasonable potential analysis)

Water Pollutants of Concern from Biodiesel Plants Process feedstock (vegetable oils, used cooking oil) plus alcohol (methanol), strong base (sodium hydroxide) Wastewater Fatty acids ( = BOD) Residual alcohol ( = BOD) Organic by-product glycerin (= BOD) Residual strong base (= high ph) Disposal Discharge to surface waters Discharge to ground waters

Alta Energy - Monte Vista, Colorado Application for discharge permit June 27 2006 Industry - makes biodiesel from vegetable oil - annually produces -12 million gallons of 100% biodiesel (B100) 2.6 million gallons of glycerin Discharge flow - Intermittent discharge - 3X/day for 15 minutes at 140 gal/minute - operation -12 mos, 5 days/week, 8 hrs/day - average 0.0044 MGD with max of 0.0094 MGD Chemical additions - methanol, sodium hydroxide, and phosphoric acid - no reason to expect priority or other pollutants present - biodiesel has a low toxicity (lower than table salt) and biodegrades faster than refined cane sugar Treatment - residual methanol removal (flash distillation at 250F) for recycle - ph adjustment to 7.0 using phosphoric acid Discharge - effluent enters lagoon and eventually groundwater - adding cattails and bull rushes to improve lagoon function and create wildlife habitat)

Highway Overview of Site Facility outfall Lagoon Tributary to Rio Grande River enters ground water

CERTIFICATION AUTHORIZATION TO DISCHARGE UNDER THE CDPS INDUSTRIAL GENERAL MINIMAL DISCHARGE PERMIT Category 26, Subcategory 2, General Permits, Current fee $448/year (CRS 25-8-502) SIC Code: 4221 COG-0600734 This permit specifically authorizes: with the facility contacts of: Alta Energy Daniel Mortenson, Managing Member 5492 East Highway 160 Monte Vista, CO 81144 (719) 589-2312 Fax (719) 589-3359 Robert Bond, Manager to discharge from facilities identified as the Alta Energy, located at 5492 East Highway 160, Monte Vista, Rio Grande County (Latitude 37 32 21.19 N, Longitude 106 02 58.14W), as shown in figures 1-3 of this certification, from Outfall 001A. Outfall 001A is discharge of byproduct water from biodiesel production that is treated prior to being discharged to groundwater alluvium tributary to the Rio Grande River, with a maximum flow rate of 9,400 gpd. The discharge is to the Rio Grande River; Segment 15 of the Rio Grande Sub-basin and Basin, found in the Classifications and Numeric Standards for the Rio Grande River Basin (5 CCR 1002-36), last update effective March 2, 2006. Segment 15 has been designated Use Protected, and has been classified for the following uses: Recreation, Class 2; Aquatic Life, Class 2 (Warm); Agriculture. Applicable limitations and monitoring requirements are listed in the following table. Parameter 30-day avg Discharge Limitation 7-day avg Daily max Frequency Sample Type Flow, gpm Report Report Weekly Instantaneous Total Suspended Solids, mg/l 30 45 Monthly Grab BOD 5, mg/l 30 45 Monthly Grab ph, s.u.. (minimum-maximum) 6.5-9.0 Monthly Grab Oil & Grease, mg/l 10 Weekly Visual Total Phosphorus monitoring is not required. Total Dissolved Solids is not required. Best Management Practices, as discussed in Part I.E.5. of the permit shall be followed for the duration of the discharge. Chemicals Used: As part of its permit application signed June 27, 2006, the permittee indicated that the following chemicals are used in the treatment process: Chemical Purpose Phosphoric Acid ph adjustment Until approved, use of any chemical in waters that may be discharged could result in a discharge of pollutants not authorized under the permit. However, the permittee may be allowed to use a different vendor for the same compound. ISSUED AND EFFECTIVE JULY 13, 2006 EXPIRATION DATE JULY 31, 2006