We are in the process of applying for certification from the Roundtable on Sustainable Biofuels. Apart from being fiendishly complex, it is also mind numbingly dull.
Part of the process is the creation of an Environmental and Social Management Plan (ESMP). We did this months ago, and have incorporated it into our employee handbook. Here is a version for the web:
A) A description of the relevant laws and regulations, including international laws and agreements, which pertain to the operation undergoing certification.
Piedmont Biofuels is heavily regulated, and committed to adhering to all laws and regulations which apply to our operations. On the local level we maintain an active business license with the Town of Pittsboro. We also conform to all fire codes interpreted by the Chatham County Fire Marshal, including regular inspections. We maintain two overhead cranes and a sprinkler system that are also subject to annual inspection and maintenance.
From the State of North Carolina’s perspective we maintain licensure on a fleet of trucks and trailers, we maintain a Storm Water Management Plan for the Department of the Environment, including regular sampling of our runoff. We also comply with the Department of Labor for our boiler operations, and with the Employment Security Commission for our unemployment insurance and state payroll taxes. The Division of Air Quality has inspected our boiler operations, has approved of them, and deemed us to be too small to warrant an air permit. We also regularly file all road taxes and excise taxes and sales taxes associated with our operations. We also comply with the North Carolina Department of Agriculture Division of Weights and Measures for those meters that are dispensing fuel to the driving public.
On the federal level Piedmont complies with all applicable laws associated with the production of the manufacture of biodiesel. One aspect of this compliance is conforming to ASTM6751, registering our fuel with the Environmental Protection Agency, and paying all federal road and excise taxes associated with the sale of our fuel. We are too small to required compliance with the Occupational Safety and Health Administration, but we do maintain a safety committee, conduct quarterly safety audits of our facility, and undergo annual safety trainings as if we were complying with OSHA guidelines. We have a comprehensive Health and Safety Program in place. We also pay all federal payroll and income taxes.
When we shipped to the European Union we ensured that our fuel complied with the E.U. specifications for biodiesel, but otherwise we are not subject to other international regulations.
B) A plan to keep information related to legal requirements up-to-date, and an identified staff person(s) responsible for maintaining this information.
All of our regulatory and legal requirements are locked into schedules that are set by the regulatory agencies. Some are annual. Some are spot inspections. Some are occasional. Some are quarterly. We comply as needed, and we assign appropriate staff as needed.
Lyle Estill is responsible for our overall compliance, and he occasionally taps other people in the organization—from administration to production for assistance in ensuring that Piedmont passes all inspections and conforms to all regulatory requirements.
C) Copies of all legal permits or other regulatory compliance documents.
Town of Pittsboro Business License (copy attached)
Chatham County Fire Inspection (copy attached)
NC DENR Storm Water Management Plan: Current Permit NCS000521 is in force until February 2013. Renewal process is currently underway. (confirming letter attached)
Crane Inspection (copy attached)
Sprinkler Inspection (copy attached)
Boiler Licenses attached to boilers: NC386347, NC386348, NC386349
Truck Licenses attached to trucks
NC Department of Agriculture Weights and Measures Inspection stickers attached to meters
National Biodiesel Board Membership evidenced at http://www.nbb.org/about-us/member-plants/nbb-member-plant-lists. Last reporting 10/2012.
EPA fuel registration: 643712311
EPA FARRS ID: 6437
EPA RFS company ID: 4681
EPA RFS facility ID: 82824
NC sales tax remittance proof on file in office
NC manufacturer’s tax remittance proof on file in office
IRS Federal Excise tax records 720 on file in office
NC State Excise tax records 1264 on file in office
FICA/FUTA/Unemployment and Social Security remittances on file in office
Section 2: Social Programs and Activities
We feel that Piedmont Biofuels complies with the RSB Social Programs on a number of levels. Firstly, we are in the United States, and by complying with the laws of the United States much of the RSB verbiage associated with the developing world do not apply to us.
From a “Food Security” perspective, we are committed to running on used fats oils and greases. These typically do not come out of the “virgin” food supply chain—that is, they have already served their role in food before we turn them into fuel. That said, waste cooking oil contains calories that can be fed to animals for meat production, so even though we are lower on the chain than those operators using say, virgin soy oil, one could argue that we are extracting calories from the food supply. Our volumes are so small we do not believe that our operations pose a threat to food security.
When we bought this plant in 2004 it had 3.5 acres of turf grass surrounding the buildings. There were very few birds. No butterflies. In conjunction with the Agricultural Extension Service of NC State University we removed turf grass and planted native, drought resistant varieties of plants in order to increase bio-diversity at this facility. This investment has been maintained, and is on going. In conjunction with the Robeson Creek Watershed Council we constructed a wetland to clean storm water coming from our facility. We also constructed an irrigation pond that is now filled with life. Both have increased wildlife about the place.
Longtime denizens of the Piedmont Biofuels Eco-Industrial Park will attest to the increased presence of butterflies, bees, and other beneficial pollinators, along with frogs, snakes, birds, and lizards. It is not unusual to see a heron hunting about the place, or to see a kingfisher circling for its next meal. Most of this has occurred since our taking occupancy of the place.
Piedmont Biofarm does attract mice, rabbits, and deer that are periodically trapped or killed when they put pressure on farm production.
Section 3: Environmental Programs and Activities
We feel that Piedmont Biofuels is in compliance with the RSB Environmental Criteria through our normal business practices and stewardship of natural resources. We are perpetually working on reducing the carbon intensity of our fuel, and of our operations, and we feel that we currently produce some of the most sustainable biodiesel in the United States at present.
While we do not use rainwater in our production process, we have invested heavily in rainwater for irrigation. We also sell rain water systems stemming from our seemingly unending quantities of IBC totes and empty barrels that result from biodiesel production. We have played a minor role in the promotion of rainwater delivery systems, selling thousands of dollars worth of containers on a monthly basis.
We are mindful of the fact that our tank farm, which often holds 10K gallons of methanol and 30K gallons of biodiesel feedstock, is close to our pond and constructed wetland.
From a “Land Rights” perspective we have no involvement with indigenous peoples for this operation. It was an abandoned aluminum alloy plant before we came along and brought it back to life.
It should also be noted that we are in the process of constructing a “Nature Interpretive Trail” which will ultimately circle our campus. Once completed this will be turned over to the Abundance Foundation for their work with children relating to “nature deficit disorder.”
Section 4: Greenhouse Gases
After completing the RSB Greenhouse Gas Calculation module
Piedmont had the following scores: RSB=.98996. RED=1.00148 For the lay person, this score would indicate our fuel is 70% better than petroleum diesel according to RSB standards.
Much of this is based on our 2011 LCA.