

TECHNICAL MEMORANDUM

TO:	Bill Schrock, U.S. EPA/OAQPS/SPPD 

FROM:	Eastern Research Group, Inc.

DATE:	August 27, 2018
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SUBJECT:	Residual Risk Modeling File Documentation for the Solvent Extraction for Vegetable Oil Production Source Category
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 Introduction

      The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act (CAA), promulgated maximum achievable control technology (MACT) standards under a national emission standard for hazardous air pollutants (NESHAP) for the Solvent Extraction for Vegetable Oil Production source category on April 21, 2002 (40 CFR subpart 63, subpart GGGG). Under section 112(f)(2) of the CAA, the EPA must conduct risk assessments on each source category subject to MACT standards and determine if additional standards are needed to reduce residual risks. 

      This memorandum describes the background and methodology used to develop the risk modeling file for the Solvent Extraction for Vegetable Oil Production source category, including the identification of facilities and emission sources and the development of emission estimates. This memorandum is organized as follows:

      1.0	Introduction
      2.0	Solvent Extraction for Vegetable Oil Production Process
      3.0 	Solvent Extraction for Vegetable Oil Production NESHAP
      4.0	Residual Risk Modeling File Background 
      5.0	Facility Identification
      6.0	Facility Configuration
      7.0	Facility Emission Release Points
      8.0	Estimation of Emissions
      Appendix A -  Vegetable Oil Production Facilities Subject to the NESHAP 
 Solvent Extraction for Vegetable Oil Production Process

      Vegetable oil production processes include the production of vegetable oil and meal products using direct contact between oilseeds and an organic solvent to extract oil. There are eight types of oilseeds processed using solvent extraction, including soybean, cottonseed, canola, corn germ, sunflower, safflower, peanuts, and flax; the extraction process is the same for each.  In each case, the oilseeds are crushed and mixed with a hexane-based solvent in an extractor, where the oil is dissolved in the solvent. Next, the solution is separated from the seeds and heated to evaporate the solvent in a "desolventizing" process. The evaporated solvent is then condensed, recovered, and reused in the process. The seed meal is also dried and cooled as a separate product. 

      All vegetable oil extraction facilities operate some type of solvent collection and recovery system for the recovery of solvent. The solvent recovery system collects process gas streams from key process units including extractors, desolventizer-toasters, meal dryers and coolers, process evaporators, and oil/solvent distillation columns. The solvent collection and recovery system then routes the gathered process gas streams to a recovery device that generally consists of a packed-bed mineral oil scrubber and may include condensers, solvent distillation systems, and solvent storage tanks. The primary hazardous air pollutant (HAP) emitted from solvent extraction of vegetable oils is n-hexane. Emission points in vegetable oil production facilities generally include the main vent of the mineral oil recovery system, meal dryer and meal cooler vents, residual emissions from crude meal and crude oil, equipment leaks, and evaporation from equipment and storage tanks. 
 Solvent Extraction for Vegetable Oil Production source category NESHAP

      The NESHAP for solvent extraction for vegetable oil production was proposed on May 26, 2000 (65 FR 34252), promulgated on April 21, 2001 (66 FR 19006), and codified at 40 CFR part 63, subpart GGGG. The NESHAP regulates facilities that are major sources of HAP and that produce crude vegetable oil and meal products by removing oil from the eight listed oilseeds through direct contact with an organic solvent. The affected sources at a facility utilizing solvent extraction for vegetable oil production are the emission points associated with the continuous process equipment used for producing crude vegetable oil and meal products which may potentially release n-hexane, which is utilized as a solvent for the extraction. . The NESHAP defines the affected source in 40 CFR 63.2832 and the definition of vegetable oil production process in 40 CFR 63.2872, which describes the applicable emission units/processes as follows: 

      "Vegetable oil production process means the equipment comprising a continuous process for producing crude vegetable oil and meal products, including specialty soybean products, in which oil is removed from listed oilseeds through direct contact with an organic solvent. Process equipment typically includes the following components: oilseed preparation operations (including conditioning, drying, dehulling, and cracking), solvent extractors, desolventizer-toasters, meal dryers, meal coolers, meal conveyor systems, oil distillation units, solvent evaporators and condensers, solvent recovery system (also referred to as a mineral oil absorption system), vessels storing solvent-laden materials, and crude meal packaging and storage vessels. A vegetable oil production process does not include vegetable oil refining operations (including operations such as bleaching, hydrogenation, and deodorizing) and operations that engage in additional chemical treatment of crude soybean meals produced in specialty desolventizer units (including operations such as soybean isolate production)." 
      
      Vegetable oil production that does not use an organic solvent or that does not use any of the listed oilseeds is not subject to the NESHAP. As noted above, facilities or emissions units associated with processes that refine extracted vegetable oil, process existing (received) vegetable oil, or include additional chemical treatment are also not subject to the NESHAP.

      Because of the variability in process and solvent recovery equipment, the current NESHAP restricts plant-wide hexane emissions from each affected facility rather than requiring individual controls at each emission point.  The NESHAP includes emission limitations based on the number of gallons of HAP lost per ton of oilseeds processed. Compliance is demonstrated monthly by calculating a compliance ratio comparing the actual HAP loss to the allowable HAP loss for the previous 12 operating months. Allowable HAP loss is based on acceptable oilseed solvent loss ratios provided in the rule in gallons per ton for new and existing sources. If the facility's calculated compliance ratio is less than one (i.e., the actual HAP loss is less than the calculated allowable HAP loss), then the facility is in compliance. Determination of compliance with the requirements of subpart GGGG requires the facility to keep records of production-related parameters, including the amount of hexane purchased, used, and recovered from the oilseed extraction process, the amount of oilseed processed, and the volume fraction of each HAP exceeding one percent in the extraction solvent used. 

      The rule was amended on September 1, 2004 (69 FR 53338) to acknowledge that a new low-HAP extraction solvent was introduced and in use by some facilities in the affected industry. Due to the low HAP level in the extraction solvents, facilities using this solvent would always be in compliance due to having a compliance ratio of zero. These facilities are only required to complete record keeping and reporting requirements to assure that the solvent used meets the low-HAP criteria.
 Residual Risk Modeling File Background 

      For a residual risk review, section 112(f)(2) of the CAA requires the EPA to assess the health and environmental risks that remain after sources achieve compliance with MACT standards. If additional risk reductions are necessary to protect public health with an ample margin of safety or to prevent adverse environmental effects, the EPA must develop standards to address these remaining risks. 

      To perform the risk analyses required by section 112(f)(2) of the CAA, the EPA identifies affected sources and conducts inhalation and multipathway modeling using emissions information available for each known source. To support the modeling analysis, the EPA collects, reviews, and compiles the emissions information into a risk modeling file that contains the following information for each affected source: 

          Facility identification information: This information includes the facility name and associated identification numbers (e.g., EPA Emissions Inventory System ID), parent company or owner name, physical address and coordinates of the facility, facility operating status, and brief descriptions of the facility such as North American Industrial Classification System (NAICS) and Standard Industrial Classification (SIC) codes.
          Facility configuration information: This information consists of emission units and emission processes. For each emission unit, the risk modeling file contains a unit identification number, description, design capacity, applicable regulatory code, and operating status. Each emission process has an assigned identification number, description, and applicable standard classification code (SCC).
          Emission release point information: This information includes the emission release points assigned to each emission unit and emission process combination. Depending on the facility configuration, multiple emission release points may be assigned to a single emission process, or multiple emission processes may be assigned to a single emission release point. Each emission release point has an assigned type (i.e., stack or fugitive) and appropriate parameters (e.g., stack height, diameter, temperature, and velocity or flow rate), in addition to latitude and longitude coordinates. 
          Emissions by pollutant: Emissions by pollutant are assigned to each emission release point. Emissions are calculated as "actual", "allowable", and "acute" on an annual basis. Actual emissions represent the mass emissions that were released from the facility for a period of interest. MACT allowable emissions represent the maximum amount of emissions that the facility is permitted to release for the period of interest at the MACT emission limit. Acute emissions represent the highest emissions that could be released during the facility operating period.
          Control information: Includes information on control measures in use by the facilities. Control measures include the air pollution control devices identified for each emissions release point and are assigned to each pollutant emitted that is controlled by the device. 
      The remainder of this memorandum describes the sources of data and the steps taken to identify facilities, collect and compile facility configuration information, identify emission release points, and estimate emission rates for the risk modeling file.
 Facility Identification

      To prepare the risk modeling file, multiple sources of information were reviewed to identify active facilities using solvent extraction for vegetable oil production that are subject to the NESHAP. Affected facilities were first identified through review of EPA databases, including the Enforcement and Compliance History Online (ECHO) database and the National Emission Inventory (NEI) database.  To identify potentially affected facilities, the ECHO and NEI databases were queried by MACT subpart code and SIC code. The relevant search criteria are shown in Table 1.

Table 1. Search Criteria for Identification of Vegetable Oil Extraction Facilities
                                Search Criteria
                          Search Criteria Description
                               Databases Queried
                                                                      MACT Code
MACT Subpart Code GGGG 
ECHO, NEI
                                                                       SIC Code
2046 - Wet corn milling
2074-Cottonseed oil mills
2075-Soybean oil mills
2076-Other vegetable oil mills, excluding soybeans and cottonseed mills
2869-Dry corn milling
ECHO, NEI

      Facilities were also identified from a facility list included in the initial 2000 rulemaking effort, additional industry trade materials, online searches of state operating permit databases, and consultation with EPA regional offices. Air operating and construction permits were requested from state and regional agencies and reviewed to confirm whether facilities are subject to the NESHAP. Additional web searches (online news articles, company websites, and review of Google Earth(R) satellite and street view imagery) were conducted to verify facility acquisition or closure. Through this process, 88 vegetable oil production facilities were identified as major sources of HAP subject to Subpart GGGG. Appendix A presents a list of these vegetable oil production facilities. 
 Facility Configuration

      Emission units, emission processes, stack parameters, and emissions release points to be included in the risk modeling file were identified for each facility subject to the NESHAP. Generally, emission units are meant to identify the specific equipment used within a facility process and emission processes describe the specific processes or operations within a facility. A facility may have multiple emission units as part of a single process or a single emission unit used for multiple processes.

 Identification of Emission Units, Emission Processes, and Assignment of Emission Process Groups
      
      For each facility, a list of the emission units and emission processes associated with vegetable oil production operations was identified using available data. The starting point used was 2014 NEI v1 Data. The NEI contains emissions data, emissions unit descriptions, process descriptions, stack parameters, stack coordinates, and other identifiers and descriptions. The NEI data was reviewed to identify affected units and processes in the source category, supplemented with additional permit and other available data (e.g., 2011 NEI Data or TRI Data), as explained in section 6.2. 

      The modeling file contains only those emission records for equipment and processes identified as part of the source category, such as oilseed preparation operations (including conditioning, drying, dehulling, and cracking), solvent extractors, desolventizer-toasters, meal dryers, meal coolers, meal conveyor systems, oil distillation units, solvent evaporators and condensers, solvent recovery system (also referred to as a mineral oil absorption system), vessels storing solvent-laden materials, and crude meal packaging and storage vessels. Therefore, emissions from refining operations or additional chemical treatment, combustion emissions from process meal dryers/coolers, or other on-site activities were not included; however, emissions from these sources are accounted for in the facility-wide assessment of risk. For a very small number of facilities (five), emissions of additional HAP from collocated ethanol processing facilities or vegetable oil refining or chemical treatment operations (such as bleaching, hydrogenation, or deodorizing processes), including acrolein and acetaldehyde, may exhaust from similar stacks; although these emissions are not a result of solvent extraction and are not considered a part of the Solvent Extraction for Vegetable Oil Production source category, they could not be easily separated from the source category emissions for modeling purposes, and therefore were included in the modeling file for a conservative estimate of risk.

      Facilities tended to report emissions data to the NEI in one of the following ways:

 Facilities reported HAP separately for each point or fugitive emission source in the vegetable oil production process (i.e., meal dryers, coolers, extractors, mineral oil stripper/solvent recovery, and solvent storage tanks); 
 Facilities reported the facility's complete process solvent loss as hexane or VOC as a single emission release point (either as a stack or fugitive point). These single emission release points were representative of the facility's combined emissions and were described accordingly (e.g, "complete process solvent loss average", "extraction including solvent storage" "imitation stack" "all hexane emissions are collectively accounted for in the total hexane losses"); 
 In some cases, facilities provided emission unit and process data for each point or fugitive emission source emitting HAP, but entered zero emission values for this data; instead, they provided the total facility "roll up" (complete solvent loss) HAP emissions as a separate line. 

      The affected emission units and processes were identified for each facility based on a review of the emission unit description, process description, SCC code, regulatory codes, and additional data provided in the 2014 NEI. The 2014 NEI data was cross-referenced against air permits for each facility to verify the emission units, processes, and stack parameters. The emissions from each identified unit and process were then assigned to an emission process group. Due to the variance in emissions reporting described above, emission process groups were developed for both emissions reported as complete process solvent loss (i.e., "facility roll-up") and individual facility processes as follows:

                            EMISSION_PROCESS_GROUP
                                  DESCRIPTION
Complete Process Solvent Loss (Facility Roll-up)
Complete Process Solvent Loss - Fugitives
Used where all hexane emissions were reported as a single facility total and assigned to a single fugitive point. Additional records may be present for separate emission units at the facility where hexane emissions are reported as 0.
Complete Process Solvent Loss - Stack
Used where all hexane emissions are reported as a single facility total and assigned to a single stack point. Additional records may be present for separate emission units at the facility where hexane emissions are reported as 0.
Additional Processes Reported (No Facility Roll-up)
Grain/Germ Dryers
Includes dryers that are used to prepare oilseed for extraction.
Cracking & Milling
Includes cracking, dehulling, and milling processes used to prepare germ or oilseeds for extraction.
Flaking & Conditioning
Includes flaking or conditioning processes used to prepare oilseeds for extraction. 
Solvent Extraction
Includes emissions from solvent extraction or solvent wash operations. Applied where these emissions are reported separately from other emission processes.
Desolventizer Toaster/Dryer Cooler
Includes desolventizers and DTDC units used to remove solvent from the oilseed/flakes. Used where these emissions are reported separately from other emission processes.  
Meal Dryer/Cooler
Includes meal dryers and coolers that are used following solvent extraction.
Expellers
Includes expellers from wet corn milling operations.
Mineral Oil Scrubber
Includes emissions from the mineral oil stripper vent. Used where emissions are reported separately from solvent stripping or other emission processes.
Hexane Storage Tanks
Includes solvent storage tanks that are reported separately from the extraction process.
Crude Oil Storage
Includes finished crude vegetable oil storage tanks.
Solvent Loss Fugitives
Used where fugitive emissions from solvent loss from all facility operations are reported separately from other emission units.

      Emissions from other equipment or operations outside Solvent Extraction for Vegetable Oil Production source category (e.g., boilers, tanks) that are not regulated by the NESHAP and that do not fit into these emission process groups were not included in the category risk modeling file. However, emissions from these sources are accounted for in the facility-wide assessment of risk. 

 Additional Emissions Data Relied on For the Modeling File

      For a limited number of facilities, the 2014 NEI data was supplemented with additional emissions data from the 2011 NEI, TRI Data, and data from state emission inventories. The 2014 NEI data was supplemented in the following situations: 
      
      Identification of Facility Emissions Not Reported to the 2014 NEI. Nine facilities did not appear to report HAP emissions to the 2014 NEI. Two of these facilities were able to be identified in 2011 NEI Data. The facility operating status flags were assessed and emissions from the 2011 NEI were included in the modeling file where appropriate (e.g., were the facility and process status flags indicated that the shutdown was temporary) and assigned to emission process groups following the methodology above. These records are included in the modeling file to provide a more conservative sample of the emissions. These facilities may be identified by their facility IDs (8120911 and 5612711) and the assigned "Start Date" of "20110101". For six facilities, data for hexane emissions was supplemented based on 2014 TRI data for facilities included on the facility lists. These facilities may be identified by the assigned "Data Source" of "TRI". The TRI emissions were reported by NAICS code and were assigned to either the "complete process solvent loss  -  stack" or the "complete process solvent loss  - fugitive" emission process groups, based on whether the emissions reported to TRI were identified as stack or fugitive. For one facility (Cargill  -  Blair, NE), the emission units and processes to which the emissions data reported to the NEI were assigned were unclear. For this facility, we developed inputs for the modeling file by identifying individual emission units, emission release points, and assigned emissions by pollutant based on a 2015 Emission Inventory prepared for the State of Nebraska and additional information provided by the facility. This facility may be identified by the Facility ID 10701611 and the assigned "Start Date" of "20150101".
      
      Identification of Facilities Only Reporting VOC emissions. The primary HAP emitted by vegetable oil production facilities is hexane, and hexane is the only HAP reported for the majority of facilities. However, nine facilities did not report hexane emissions in the NEI but instead reported solvent loss as VOC. The reporting of criteria air pollutants to NEI is required from all state, local, and tribal agencies, while the reporting of HAP is voluntary. All emission records where hexane is reported as VOC were reviewed and included in the modeling file with the pollutant code and HAP category fields updated to reflect hexane emissions, accordingly, based on the assumption that all VOC emitted is HAP. The solvent used in vegetable oil production facilities is 100 percent volatile organic compounds and may range from less than 1 percent to 88 percent hexane. Because the actual hexane content for the solvents used by these facilities is unknown, assuming that all solvent loss reported as VOC is hexane provides the most conservative estimate of risk. Additionally, we reviewed 2011 NEI data to determine if hexane was reported in lieu of VOC in an earlier data year and compared these emissions to determine the most conservative representation of emissions.
      
      In these cases, we used the information provided in the NEI and additional permit and inventory data to assign the appropriate emission unit ids, process ids, emission release points, SCCs, and stack parameters to create records for the modeling file (see sections 6.3 and 6.4 for additional information). .
      
 Development of Emission Release Point Coordinates

      Following identification and assignment of emission units, emission processes, and emissions process groups, specific exhaust locations for emissions units and processes (i.e., emission release points) for each facility were added to the risk modeling file. Emission release points are assigned to each emission unit and emission process combination, depending on a facility's configuration (e.g., a single emission process could have multiple emission release points, or multiple emission processes could have a single emission release point). For example, if an emission unit for a process exhausts to multiple stacks, the emission unit was assigned an emission release point for each stack. In the risk modeling file, the emission release point type (e.g., stack or fugitive) was assigned to each record based on review of the available data from the 2014 NEI, air permits, and facility inventories.  

      For each emission release point, emission release point coordinates were developed from 2014 NEI Data, ECHO, and Google Earth(R). The NEI Data provides latitude and longitude coordinates, which were confirmed in ECHO and Google Earth(R). For each stack emission release point, the risk modeling file must have stack parameters including the height, diameter, temperature, exit gas velocity (or flow rate), and latitude and longitude coordinates. The source of the stack parameters are discussed in section 6.4 of this document. 

 Development of Stack Parameters
      
      Stack parameters (stack height, diameter, exit gas temp, exit gas flow rate, and exit gas velocity) were developed using NEI data and available permit data. The 2014 NEI data was used as a starting point. Parameters were confirmed or updated based on permit and other inventory records where incomplete. Permit data was used in place of the 2014 NEI data where the permit was newer (issued post-2014) or the data available in the permit was more complete than the 2014 NEI data.

      For many facilities, stack point parameters were missing or incomplete in the NEI data. Where stack point parameters were missing or incomplete, EPA populated the stack parameters using available permit or inventory data, calculated parameters such as velocity and flow rate based on the data available, calculated industry average values for missing stack parameters such as temperature, stack height, or stack diameter, or assigned modeling defaults. The following hierarchy was used to assign stack parameters for each emission unit and process id: 
      
 NEI Data 
 Other state inventory data 
 Air permits
 Calculated stack parameters
 Calculated industry average values 
 RTR Modeling Defaults (SCC or National Defaults). 

   Calculated parameters or modeling defaults were used as follows:
   
 Where only partial stack parameters (e.g., stack diameter and exit gas velocity) were available, additional stack parameters (e.g., exit gas flow rate) were calculated as needed.
      
 If a permit identified a stack as present but no stack parameters were available, industry average values were developed for stack height, diameter, exit gas temp, and exit gas velocity based on non-zero values for similar emission process groups. The exit gas flow rate was then calculated based on the industry average values. Industry average values were developed for the "complete process solvent loss  -  stack" and "meal dryer/cooler" emission process groups and were applied to 8 of 88 facilities. 
      
 Where insufficient data existed to calculate an industry average value, RTR modeling SCC defaults were used. This applies to one conventional soybean processing facility that reported non-zero emissions of HAP from flaking and bean conditioning operations to the NEI (SCC code 30200787) without associated stack parameters. The remaining facilities reporting non-zero emissions from flaking and bean conditioning operations with available stack parameters were wet corn milling operations. Due to variations in conditioning operations at soybean and wet-corn milling operations, we determined that the RTR modeling SCC default would likely be more representative of stack conditions for the soybean facility rather than a calculated industry average value.

      For facilities only reporting emissions as "complete process solvent loss", emissions were assigned to either a stack (if a stack was identified in the 2014 NEI data or a permit) or a fugitive vent. Due to the nature of vegetable oil solvent recovery processes and presence of a solvent recovery system and scrubber, its assumed that these emissions would largely emit from a single stack or vent. Complete solvent loss emissions that were identified as stack emissions were assigned stack parameters following the hierarchy above. Complete solvent loss emissions that were identified as fugitive emissions source were treated as fugitive vent sources and the stack parameters were assigned modeling defaults for fugitive height and exit gas temperature if no parameters were present. 
         
      Stack default flag codes were assigned to each emission release point in the modeling file to indicate where stack parameters were updated and identify which methods were used to update the records. The stack default flag codes were updated following the QA checks discussed in section 8 of this memorandum. 
 Estimation of Emissions

      To model individual pollutants for affected facilities, the mass emission rates of pollutants emitted from each emission unit and process at the affected facilities were assigned to each emission release point. The mass emission rates for each emissions release point must include annual actual emissions in tons per year, allowable emissions in tons per year, and acute emissions in tons per hour. Actual annual emissions are the emissions estimated to be released by the facility assuming the facility's standard operating hours and levels of control. Allowable emissions are the emissions that each facility is capable of releasing based on the emissions reduction standards in the Solvent Extraction for Vegetable Oil Production NESHAP or permit limitations. Acute emissions reflect the highest emissions that may be released by a facility and are used to estimate acute risks. Sections 7.1 through 7.3 of this document describe the methodology for estimating the actual, allowable, and acute emissions from the drying and curing processes and binder application processes. 
 Estimated Actual Emissions

      Actual emission estimates for each affected facility were based on the 2014 and 2011 NEI data, TRI data, and the inventories provided by individual facilities, as described in section 6.0 of this memorandum.  Emission rates were provided separately for one facility (Cargill  -  Blair, NE), due to discrepancies in the data reported to the NEI. For this facility, all entries in the modeling file were created with individual emission units, emission release points, and assigned emissions by pollutant based on a 2015 Nebraska Emission Inventory and additional information provided by the source.  
 Estimated Allowable Emissions
      Annual allowable emissions were determined by estimating an average emissions multiplier for the industry. Permits for a subset (approximately 20 percent) of facilities in the source category were reviewed to determine annual allowable emissions based on individual permit limits that demonstrated compliance with the standards (in some cases, where permit limits are more stringent than the MACT). The annual allowable emissions from each facility permit were then compared to the actual emissions reported to the NEI from the facility to develop an allowance ratio. The calculated ratio of allowable (permitted) emissions to actual emissions is 3.139:1. The ratio was subsequently applied to the actual emissions of the remaining facilities to estimate the allowable emissions (Actual Emissions (tpy) x 3.139).  
 Estimated Acute Emissions
      Annual acute emissions were calculated using a conservative default multiplier of 10 (Actual Emissions (tpy) x 10).
 Quality Assurance
      
The following quality assurance activities were also performed for each modeling file record:

 Records were reviewed for potential duplicates and to assess status flags for process ids, emission release points, and emission units to ascertain whether the unit, process, and release point remain in operation. Emission records were retained where it was not clear that the emission unit, process, or release point is permanently closed, or where industry has identified a more recent closure, as a conservative estimate of emissions.
 Coordinates for each emission release point were reviewed against facility addresses in Google Earth to determine whether they are situated on facility property over the expected stacks, fugitive vents, fugitive area, and fugitive volume sources. In several instances the coordinates were revised to align with specific stack locations identified using Google Earth.
 Stack parameters were reviewed to ensure they complied with certain consistency checks. For example, the relationship between stack velocity, stack flow rate, and stack diameter is: flow rate = velocity * surface area. In instances where this check did not pass, either the flow rate or velocity was revised.
      

     Appendix A: Vegetable Oil Production Facilities Subject to the NESHAP
                                   Facility 
                                     State
                              Oilseeds Processed 
                             Number of VOPP Lines
Bunge North America - Decatur
                                      AL
Soybean
1
Cargill, Inc. - Guntersville
                                      AL
Soybean
1
Sessions Company, Inc
                                      AL
Peanut
1
Planters Cotton Oil
                                      AR
Cottonseed 
1
Riceland Foods, Inc.
                                      AR
Soybean (conventional)
1
Adams Specialty Oils
                                      CA
Soybean, canola, safflower, sunflower (specialty)
1
J.G. Boswell Company
                                      CA
Cottonseed, safflower
1
ADM - Valdosta
                                      GA
Soybean, Large Cottonseed
2
Cargill - Gainesville
                                      GA
Soybean (conventional)
1
Golden Peanut - Dawson
                                      GA
Peanut 
1
ADM Bioprocessing - Clinton
                                      IA
Wet corn milling
1
ADM Soybean Processing  -  Des Moines
                                      IA
Soybean (conventional)
1
Ag Processing, Inc - Eagle Grove
                                      IA
Soybean
1
Ag Processing, Inc - Emmetsburg
                                      IA
Soybean (conventional, specialty, and combination)
1
Ag Processing, Inc - Sergeant Bluff
                                      IA
Soybean (conventional)
1
Ag Processing, Inc - Mason City
                                      IA
Soybean (conventional)
1
Ag Processing, Inc - Manning
                                      IA
Soybean (conventional)
1
Ag Processing, Inc - Sheldon
                                      IA
Soybean
1
Bunge North America, Inc 
                                      IA
Soybean (conventional)
1
Cargill, Inc.  -  Des Moines 
                                      IA
Soybean (Closed)
1
Cargill, Inc. - Eddyville
                                      IA
Wet corn milling
1
Cargill, Inc. - Cedar Rapids (East)
                                      IA
Soybean (specialty)
1
Cargill, Inc. - Cedar Rapids (West)
                                      IA
Soybean (conventional)
1
Cargill, Inc. - Sioux City
                                      IA
Soybean
1
Cargill, Inc. - Iowa Falls
                                      IA
Soybean
1
CHS Oilseed Processing
                                      IA
Soybean (specialty)
1
ADM - Quincy
                                      IL
Soybean, Wet corn milling 
2
Archer Daniels Midland Co  -  Decatur (East Plant)
                                      IL
Corn germ, Soybean
1
Archer Daniels Midland Co  -  Decatur (West Plant)
                                      IL
Corn germ, Soybean (specialty)
2
Bunge Milling - Danville
                                      IL
Corn germ, Soybean 
2
Bunge North America, Inc. - Cairo
                                      IL
Soybean 
1
Cargill, Inc. - Bloomington
                                      IL
Soybean (conventional and specialty)
1
Solae  -  Gibson City
                                      IL
Soybean (conventional and specialty)
1
Incobrasa Industries Ltd
                                      IL
Soybean
1
Ingredion Inc. - Argo Plant
                                      IL
Wet corn milling 
1
Viobin USA 
                                      IL
Soybean (conventional and specialty)
1
Archer Daniels Midland - Frankfort
                                      IN
Soybean (conventional)
1
Bunge Ltd - Morristown
                                      IN
Soybean (conventional) (Closed)
1
Bunge North America (East), Ltd
                                      IN
Soybean (conventional)
1
Cargill, Inc. - LaFayette
                                      IN
Soybean - conventional and specialty
1
Consolidated Barge and Grain Co
                                      IN
Soybean, Dry corn milling
1
Louis Dreyfus Agricultural Industries LLC 
                                      IN
Soybean (conventional, specialty, and combination)
1
Rose Acre Farms, Inc.
                                      IN
Soybean
1
Bunge Oilseed Processing Plant -Emporia
                                      KS
Soybean
1
Cargill, Inc. - Wichita
                                      KS
Soybean
1
Northern Sun - Goodland
                                      KS
Sunflower, Canola (combination)
1
Owensboro Grain
                                      KY
Soybean (conventional)
1
Bunge Corporation - Destrehan
                                      LA
Soybean
1
Perdue Salisbury Feed and Grain - Salisbury
                                      MD
Soybean (conventional, specialty, and combination)
1
Zeeland Farm Soya
                                      MI
Soybean (conventional)
1
ADM - Mankato
                                      MN
Soybean (conventional)
1
ADM  -  Red Wing
                                      MN
Soybean (conventional)
1
Ag Processing Inc - Dawson
                                      MN
Soybean (conventional)
1
CHS Fairmont
                                      MN
Soybean
1
CHS Hallock - Kennedy
                                      MN
Canola/rapeseed
1
CHS Oilseed Processing - Mankato
                                      MN
Soybean (conventional, specialty, and combination)
1
Minnesota Soybean Processors
                                      MN
Soybean, rapeseed (conventional)
1
ADM Soybean Processing - Mexico
                                      MO
Soybean (conventional)
1
Ag Processing Inc. - Saint Joseph
                                      MO
Soybean (conventional, specialty, and combination)
1
Cargill, Inc.  -  Kansas City
                                      MO
Soybean
1
Prairie Pride, Inc.
                                      MO
Soybean 
1
Delta Oil Mill
                                      MS
Cottonseed (Closed)
1
Express Grain Terminals LLC
                                      MS
Soybean, Corn, and other grains
1
Cargill, Inc. - Fayetteville
                                      NC
Soybean (conventional)
1
Cargill, Inc. - Raleigh
                                      NC
Soybean (Closed)
1
Perdue Farms Inc.  -  Cofield 
                                      NC
Soybean (conventional)
1
ADM Northern Sun Division - Enderlin
                                      ND
Soybean, sunflower
1
ADM Processing - Velva
                                      ND
Canola/rapeseed
1
Cargill, Inc.  -  West Fargo
                                      ND
Soybean
1
ADM - Fremont
                                      NE
Soybean
1
ADM Soybean Processing - Lincoln
                                      NE
Soybean
1
AGP Ag Processing, Inc. - Hastings
                                      NE
Soybean
1
Cargill Corn Milling NA - Blair
                                      NE
Wet corn milling.
1
Archer Daniels Midland - Fostoria
                                      OH
Soybean (conventional)
1
Bunge North America - Bellevue 
                                      OH
Soybean - conventional, soybean - specialty, ethanol soybean extraction
1
Bunge Oilseed Processing - Delphos
                                      OH
Soybean - conventional and specialty
1
Cargill Soy Processing - Sidney
                                      OH
Soybean (conventional)
1
Producers Cooperative Oil Mill
                                      OK
Canola, sunflower, peanut, corn germ (Closed)
1
Archer Daniels Midland Soybean Div - Kershaw
                                      SC
Soybean (conventional)
1
Hartsville Oil Mill - Darlington
                                      SC
Cottonseed, peanut
1
South Dakota Soybean Processors
                                      SD
Soybean (combination)
1
Archer Daniels Midland Company - Memphis
                                      TN
Large Cottonseed
1
Cargill, Inc. - Memphis
                                      TN
Wet corn milling
1
ADM/Southern Cotton Oil Co - Lubbock
                                      TX
Cottonseed 
1
ADM/Southern Cotton Oil Co - Richmond
                                      TX
Large Cottonseed, Corn Germ
1
Pyco Industries Inc.  -  Avenue A 
                                      TX
Cottonseed
1
Pyco Industries Inc.  -  East 50[th] 
                                      TX
Cottonseed (Closed)
1
Valley Co-op Oil Mill
                                      TX
Cottonseed
1
Perdue Farms Incorporated  -  Chesapeake Grain
                                      VA
Soybean (conventional)
1
                                       

