MPCA Guidelines For Ethanol Producers To Produce Sanitizer

  • Friday, 03 April 2020 09:44

The Minnesota Pollution Control Agency (MPCA) issued guidlines to ethanol producers earlier this week on conditions to immediately produce and ship 190 proof or 200 proof ethanol for hand sanitizer or surface sanitizer.

In the guidelines, the MPCA said ethanol production facilities in Minnesota will be allowed for the duration of the peacetime emergency in the state, including 60 days after the conclusion of the peacetime emergency.

Here are the MPCA's guidelines for ethanol producers:

Conditions To Begin Immediate Production And Shipment of 190 Proof or 200 Proof for Hand Sanitizer or Surface Sanitizer To Help Meet The Demand

  • You could ship 190 proof or 200 proof ethanol without added denaturant.
  • You could use an alternative denaturant provided that the following conditions are met:
    • denaturant is a chemical with equal or lower vapor pressure than gasoline,
    • denaturant is added in equal or lower mass ratio than the allowed gasoline/ethanol
    • ratio in the air emissions permit, and
    • denaturant does not have a higher human toxicity than gasoline

Required Notifications Before Determination On The Need Of An Air Permit Amendment

You must notify the MPCA within 7 days of beginning production and shipment that you have started production and shipment of 190 proof or 200 proof ethanol for hand sanitizer or surface sanitizer under the conditions described above.

Determination On The Need Of An Air Permit Amendment

It is the responsibility of the facility to determine if the process change will require a permit amendment.

• Within 30 days of beginning production and shipment of 190 proof or 200 proof ethanol for hand sanitizer or surface sanitizer you must either determine if a permit amendment is required for the necessary physical or operational modifications at your facility or submit an Applicability Determination request for a site-specific analysis. Either way, please consider the following as you read and analyze your air emission permit conditions:

    • Most fuel-ethanol Air Quality permits allow for the facility to produce and ship “ethanol” without regard to its final destination or purpose.
    • The permit will specify hourly and annual limits on ethanol production, as well as the method required to document the amount shipped and/or produced.
    • Current permits likely include flexibility language that authorizes the Permittee to add additional equipment without a permit amendment.
    • Additional equipment may be required to produce pharmaceutical-grade ethanol.
    • Change of denaturant may require a permit amendment or a notification.
    • Changes that would require a permit amendment include any increase in annual throughput amounts, and addition of equipment not pre-authorized by flexibility language.
    • If you determine you are not required to obtain a permit amendment or submit a notification, you must maintain documentation of this determination on-site.

Submittal Of Required Air Permit Application or Notification

If a permit amendment or notification is required, within 60 days of beginning production and shipment of 190 proof or 200 proof ethanol for hand sanitizer or surface sanitizer you must submit the required permit application or notification.

More information is detailed in this document