A new report from
June 2024 by the environmental group Environmental Integrity Project uses EPA data
to show that there is significantly higher emissions of certain hazardous
pollutants in biofuels plants vs. oil refineries. The new report Farm to Fumes:
Hazardous Air Pollution from Biofuel Production, claims that the excess of
these pollutants released by biofuel plants is resulting in elevated
atmospheric levels of them in nearby rural Midwestern communities. The
executive summary explains that the pollutants of concern that are beyond those
of oil refineries are:
“…formaldehyde (a carcinogen), acetaldehyde (a probable
carcinogen), hexane (which can attack the central nervous system and cause
dizziness, nausea, and headaches) and acrolein (which can cause nausea,
vomiting, diarrhea, lung and eye irritation, and shortness of breath). More
acrolein is emitted from the biofuels industry than any other source in the
U.S., according to reporting to EPA’s Toxics Release Inventory. The same four
pollutants also contribute to the formation of ground-level ozone, or smog,
which is linked to a wide variety of respiratory ailments; as well as
microscopic, soot-like particulates that can trigger heart and asthma attacks.
Many biofuels plants violate their air pollution control permits, releasing
illegal amounts of contaminants that threaten the health of downwind
communities. And although biofuel facilities release less carbon dioxide on
average than petroleum refineries, biofuel plants still emit large quantities
of greenhouse gases for an industry that portrays itself as climate-friendly.”
The report
examines EPA’s Toxic Release Inventory and zooms in on releases from biofuels
plants. It is true, of course, that overall pollution and carbon emissions from
oil refineries are higher than for biofuels plants. It is also true that air
pollution and carbon emissions from biofuels plants is still quite significant,
and that it is concerning for the four pollutants mentioned above: formaldehyde,
acetaldehyde, hexane, and acrolein. These are classed as volatile organic
compounds (VOCs). The report notes:
“EPA has identified 188 different pollutants as hazardous
air pollutants under the Clean Air Act.34 In 2022, 226 biofuel plants in the U.S.
reported emitting 12.9 million pounds of hazardous air pollutants.”
The table below compares emissions of these pollutants from
ethanol, biodiesel, total of biofuels plants, and oil refineries.
As the map below
shows, the Upper Midwest hosts the vast majority of biofuels plants, near to
where the biofuels crops corn and soybeans grow best in the rich loess soils. In
contrast, most of the oil refineries are on the Louisiana Coast and in
California. According to the USDA approximately 38 percent of corn and 46
percent of soybeans grown in the U.S. in 2022 were used to make biofuel. Of
course, that means that growing these crops for biofuel competes with growing
them for food and puts upward pressure on regional and global food prices.
The report
also highlights what they see as a troubled compliance history of biofuels
plants. EPA's Enforcement and Compliance Online (ECHO) database was used to
unravel this history.
The tables below show plants with the most Clean Air Act
violations and plants with the most failed stack tests. Stack tests measure the
amount of specific regulated pollutants to determine if those emissions are in
compliance with the Clean Air Act. Over the last five years 65 out of 182
biofuels plants, or 36%, reported failed stack tests (where pollutants were
higher than Clean Air Act limits).
The history of
biofuels development in the U.S. is recounted, noting that current trends
involve converting some oil refineries to biofuels production such as renewable
diesel. Both ethanol production and renewable diesel production continue to
grow as new plants, expansions, and conversions are planned and under
construction. These new projects could expand production by up to 33%. Much of
the new developments are focused on renewable diesel which is a “drop-in fuel”
rather than a fuel that is blended with hydrocarbons as ethanol and biodiesel
is and sustainable aviation fuel (SAF) which is a renewable diesel that can be
made from different sources including woody and other plant biomass. These
efforts are significantly subsidized by the U.S. government and have been for
many years. The U.S. is the world’s largest producer of biofuels, producing 18.5
billion gallons in 2022. The history of biofuels in the U.S. centers around developing
alternatives to importing fossil fuels for geopolitical purposes and helping
U.S. farmers grow profitable crops.
The report
notes that biofuels plants have less stringent air pollution requirements since
a 2007 EPA decision excluded corn-based ethanol plants from having to obtain
permits requiring stronger pollution abatement. The result is that pollution control
is inadequate for these plants. The report’s recommendations include ending
those exemptions. The full recommendations are as follows:
“1. END PERMITTING EXEMPTIONS FOR ETHANOL UNDER THE CLEAN AIR ACT: EPA should reverse its 2007 decision to relax major source permitting thresholds for ethanol manufacturers that allow these plants to emit more than twice the level of air pollution before needing to install better pollution controls.
2. BETTER MONITORING AND CONTROL OF HAZARDOUS AIR POLLUTANTS: EPA should require large biofuel plants to install air pollution monitoring devices along their fencelines to detect the levels of hazardous air pollutants, like acetaldehyde and acrolein, that could be drifting into nearby communities. EPA should also establish an ‘action level’ for these and other highly toxic pollutants, that, if exceeded, would obligate these facilities to identify the sources of the emissions and then fix the problems causing elevated concentrations.
3. STRONGER ENFORCEMENT OF AIR POLLUTION CONTROL PERMITS FOR BIOFUEL PLANTS: EPA and state regulatory agencies should more vigorously enforce air pollution control permits for biofuel plants, imposing penalties large enough to discourage future violations and protect downwind communities.
4. IMPROVE THE ACCURACY OF EMISSIONS REPORTING: Biofuels producers should be required, during the permit review and approval process, to expand their emissions testing and improve the accuracy of their pollution reporting to both EPA and the states.
5. END BIOFUEL SUBSIDIES AND MANDATES: Biofuels are growing at a rapid rate in part because of government funding and regulatory mandates for blending ethanol into gasoline. But the environmental benefits of these government supports are questionable at best. All existing subsidies and mandates for ethanol – including the renewable fuel standard – should be halted – and attention focused instead on clean energy sources like solar and wind and the infrastructure needed to support them.”
Most of these recommendations seem reasonable in the
interests of public health and fairness vs. other polluting industries. I was surprised
to see that they advocate for ending biofuel subsidies and mandates. This would
likely devastate the industry, lowering future pollution for sure, but also making
it difficult to build new biofuels plants, expand or convert existing ones.
With current focuses on developing SAFs and expanding renewable diesel production,
I think this will certainly not happen. It is both unfeasible and out of line
with most current policy approaches to develop fuel alternatives to fossil
fuels. Thus, I think we can chuck that last recommendation as environmentalist
propaganda.
The report
focuses on four types of biofuels: ethanol, biodiesel, renewable diesel, and
other biofuels (such as biomass-derived SAF). Both the Bipartisan
Infrastructure Bill and the Inflation Reduction Act have funding and incentives
for SAFs and biofuels. There are also agricultural subsidies for farmers who
grow corn and soybeans. Along with SAF there are renewable biofuels such as renewable
naphtha, a liquid that can be used to make jet fuel, plastic, and other
products. The report also covers new builds, expansions, and conversions for
biofuels production. Proposed projects, if all are built, can more than double U.S.
renewable diesel production from 2022 levels.
The VOC
hazardous air pollutants (HAPs) of concern that are at higher levels than at
oil refineries are described in more detail below:
“• ACROLEIN is also created during the ethanol
fermentation process. Effects including weakness, nausea, vomiting, diarrhea,
severe respiratory and eye irritation, shortness of breath, bronchitis,
pulmonary oedema, unconsciousness, and death have been observed upon accidental
exposure. Long-term exposure effects can consist of general respiratory
congestion, as well as irritation of the eyes, nose, and throat.
• FORMALDEHYDE is created in the fermentation process of ethanol production as well. EPA has preliminarily found that formaldehyde poses unreasonable risk to human health. High levels of exposures to formaldehyde can cause health problems when inhaled and if it is absorbed into the skin. Inhaling high levels of formaldehyde for a short period of time can cause sensory irritation such as eye irritation. Inhaling formaldehyde for longer periods of time can damage the lungs and increase asthma and allergy-related conditions and cause cancer.
• HEXANE is used to extract edible oils from seeds and
vegetables, as a special-use solvent, and as a cleaning agent. As such, it is
heavily involved in the production of most biofuel products. Short-term
exposure of humans to high levels of hexane causes mild central nervous system
effects, including dizziness, giddiness, slight nausea, and headache. Long-term
exposure to hexane is associated with polyneuropathy (nerve damage) in humans,
as well as numbness in the extremities, muscular weakness, blurred vision,
headache, and fatigue.”
Biofuels production also emits significant amounts of most
of the seven criteria air pollutants including nitrogen oxides, sulfur dioxide,
lead, particulate matter, carbon monoxide. The report also notes that in Iowa
and Illinois, 70% of all HAPs come from biofuels production and a significant number
of total VOCs as well. In terms of the total amount of HAPs, biofuels
production produces more than oil refineries, 14.5 million lbs. vs. 12.9
million lbs. Of course, not all HAPs are equally harmful so that statistic may
be less relevant to a comparison of the real dangers. The report lists and
ranks the facilities responsible for the most emissions of each of these pollutants of concern.
As I show
below in a graph, in total, oil and gas refineries in the U.S. still emit nearly 10 times as much
greenhouse gases as biofuels plants (but they produce much more product), but there is a climate advantage for
biofuels. EIP’s contention that such low-emissions fuels could be replaced by
wind-and-solar-powered electric transport is simply not feasible at this time. Even
with those lower emissions biofuels plants are pushing to capture and sequester
CO2. This can be advantageous for these plants since CO2 can be captured at
high percentages from ethanol plants due to the purity of the emissions stream
vs. combustion flue gas streams. CO pipelines have been networked and larger
networks are in the works in the Midwest which will support a strong biofuels
CCS industry. Currently only about 0.5 million metric tons, or 1.5% of
emissions are captured and sequestered. That should increase significantly in
the future, making biofuels even better for ghg emissions reduction. However,
studies of the life cycle greenhouse gas emissions of biofuels adding in land
use changes and agricultural emissions show that by volume they could be as
high or higher than those of gasoline (one study concluded 24% higher). Thus,
capturing and storing more of those emissions is desirable.
The report includes four case studies that emphasize biofuels pollution threats. An ethanol plant in Decatur, Illinois is the highest emitter of hexane. Air pollution monitors set up downwind from the plant recorded expected amounts of NOx and SO2, but five times expected amounts for VOCs. This suggests that the facility underreported its VOC emissions. A new CCS operation at the plant is resulting in 10-12% of its emissions being captured and sequestered into a sandstone formation in the Illinois Basin. As of July 2022, 3.9 million metric tons of CO2 have been sequestered. An Earth Justice attorney has claimed that the injected CO2 has already leaked away from its target area, although this may not be as concerning as she thinks nor affect the success or failure of future projects. Another plant in Iowa along the Mississippi River has often exceeded its limits of SO2 pollution and is the highest SO2 emitter in the state. This plant, along with the previous one once burned coal to power the plants but was forced in 2015 to install pollution controls and then switched from burning coal to burning natural gas, which produces some NOx but no SO2. Thus, it appears that was not a good choice of example if the issue has been more or less resolved. I am not sure why they mentioned it since it would be more a case of past violations that have been corrected. The third case study is a refinery in San Francisco converted to biofuels production, specifically renewable diesel. That case is weak to as they argue that biofuels are not the ideal green solution and, in these cases, just extend the lifespans of oil refineries. Th last case study is of a woody biomass (wood pellet) plant in Louisiana that converts the pellets into SAF. The report notes that 52% of wood pellet plants have violated the Clean Air Act and that wood-to-SAF plants are on track to do the same. EIP claims that the company’s tests used to predict their pollutant emissions were inadequate. The company claimed that it would emit about 91 tons of VOCs per year, just under the 100 tons that would require additional abatement. However, according to the EIP the emissions could be as much as 10 times more:
“EPA has compiled a vast database of real-world
emissions testing on wood dryers that indicate the company’s dryers will more
likely emit around 1,000 tons of VOCs and several hundred tons of hazardous air
pollutants per year.”
The facility was permitted by Louisiana state regulators.
References:
Biofuel’s
Dirty Secret: Toxic Chemicals Threatening Communities Under the Name of Green. Joe
Lysikatos. Microsoft. Eco Hugo. July 8, 2024. Biofuel’s
Dirty Secret: Toxic Chemicals Threatening Communities Under the Name of Green
(msn.com)
Farm
to Fumes: Hazardous Air Pollution from Biofuel Production. Environmental
Integrity Project. June 12, 2024. EIP_Report_FarmtoFumes_06.12.2024.pdf
(environmentalintegrity.org)
Greenhouse
gas emissions produced by oil and gas facilities in the United States from 2011
to 2022. Statista. U.S.
oil & gas GHG emissions 2022 | Statista
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