1. Governors Ethanol Coalition Omaha, NE August 29, 2007 by Bill Roddy & Greg Krissek 250 tpy Rule Update

2. ● Fuel Ethanol Process Overview ● Equipment Standards ● Emission Sources ● Rulemaking Dates ● 250 tpy Rule Details ● Q & A Overview of Discussion

3. US Ethanol Production ● As of January 2007 Approximately 5.6 billion gallons ethanol being produced annually in US. Up 300% since Year 2000 In 2006, approximately 17% of corn produced went to ethanol production Source: Renewable Fuels Association, Ethanol Industry Outlook 2007, Building New Horizons Ethanol industry experiencing significant growth

5. 110 MGY

6. 50 MGY

7. Typical Air Emission Control Equipment: ●Dryer (DDGS) Emissions: Thermal Oxidizer ●Denatured Ethanol Loadout: Flare ●Biomethanator: Flare ●Fermentation: High Efficiency Packed Tower Scrubber ●Fugitive VOCs: Leak Detection and Repair ●Road Dust: Regular Plant Street Sweeping ●Process Dust: Baghouses ●Tanks: Internal Floating Roofs (with double wiper seals) ●Process Vents: Vented to Thermal Oxidizer ●Diesel Emergency Water Pump: Lean Burn Technology Industry “Standards”

8. Typical Emission Sources Bushmills Ethanol: 50 MMgpy (operating), 500,000 tons/yr grain (17,857,144 bu/yr), 162,218 tpy DDGS

9. EPA’s 250 tpy Rulemaking Federal Register Rulemaking ● March 9, 2006: Proposed Rule ● May 1, 2007: Final Rule ● July 2, 2007: Effective Date

10. 250 tpy Rule Summary Air Permitting as “minor” source ● < 100 tons/year (old rule) ● < 250 tons/year (new rule) ● States required to adopt 250 tpy rule ● NRDC filed lawsuit on July 2, 2007 ● RFA team is preparing “Amicus Brief” ● Public health, safety and environment remain protected with new rule

11. 250 tpy rule details ● Ethanol plants – no longer chemical process plants for PSD purposes. ● 250 rule applies – new and modified plants. ● Fugitives (road dust, pumps, valves, flanges & perhaps cooling towers) are no longer included in the PSD emission inventory for applicability. LDAR is still required. ● Existing plants may expand to 249 tons & remain minor. Leaves additional 249 tons. ● All plants will still need TOs and Scrubbers.

12. Thank you Questions ?