Recently, there appears to be an uptick in EPA audits of ethanol facilities. Preparing now for an unexpected audit can save you headaches down the road and potential consent decrees.
What We Know About the Scope of the Audits
Based on information received from audited ethanol facilities, EPA personnel are onsite using infrared red (IR) cameras to identify emissions leaks on equipment identified in facility Title V air permits. IR cameras are being used to detect emissions from the top of fermentation tanks and the beer well, including agitators, pressure relief or vacuum breaker valves, access doors, and connectors.
While theoretically this equipment should only emit carbon dioxide (CO2), when not properly functioning, maintained, or monitored, volatile organic compounds (VOC) emissions - such as ethanol vapor or acetaldehyde - can potentially be observed. In some cases, the audits have included a review of the leak detection and repair (LDAR) program and other stationary emission sources at the facility.
How Should Facilities Prepare for an Audit?
Several proactive steps can be taken now to help you avoid surprises during an audit, which include:
- Performing voluntary inspections of emission sources using an IR camera to develop baseline monitoring data and/or identify any possible issues.
Contacting your LDAR contractor and inquiring about voluntary monitoring of components located at the top of fermentation tanks and beer well using a flame.
Including your LDAR contractor and environmental consultant in reviewing the cited violations, if you receive a notice of violation (NOV). This can help assure that additional requirements are realistic and consistent with existing monitoring procedures and protocols. You can submit requests to EPA to change or update your program before the resulting requirements are incorporated into your facility air permit.
If you need assistance with any of the above actions, contact Trihydro’s air compliance team.
Mike Ogden, Air Compliance Specialist
John Schneider, Senior Consultant - Ethanol Programs