                      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          SECTOR POLICIES AND PROGRAMS DIVISION
                       OFFICE OF AIR QUALITY PLANNING AND STANDARDS
                               OFFICE OF AIR AND RADIATION


MEMORANDUM

TO:	Docket No.: EPA-HQ-OAR-2019-0208

FROM:	Bill Schrock, Allison Costa
	EPA/Office of Air Quality Planning and Standards (OAQPS)

--------------------------------------------------------------------------------
Subject:	Summary of Communications with Industry and Stakeholder Input for Risk and Technology Review for the Solvent Extraction for Vegetable Oil Production Source Category
--------------------------------------------------------------------------------

 Introduction

This memorandum summarizes the communications between EPA and affected facilities to discuss EPA's risk and technology review (RTR) for the Solvent Extraction for Vegetable Oil Production source category under section 112(f)(2) of the Clean Air Act (CAA). This memorandum is organized as follows:

 Introduction
 Communications with Industry Trade Groups and Trade Group Members 
      Attachments: 
          A.1 U.S. Environmental Protection Agency (EPA) and National Oilseed Processors Association (NOPA) Communications Regarding Facility List
          A.2 Communications from Cargill  -  Blair Facility Regarding HAP
          A.3	Summary of Conference Call between the EPA and NOPA, October 30, 2018, and NOPA White Paper on Periods of Initial Startup
          A.4 Communications from NOPA on Periods of Initial Startup and Malfunction, December 6, 2018
 CommunicationS WITH Industry trade groups and trade group members 

EPA conducted meetings with several stakeholders in the development of the risk and technology review, via teleconference or site visit. These communications include the following conferences and exchanges:

 EPA met with the National Oilseed Processors Association (NOPA) via teleconference on November 3, 2016 to notify them that EPA had begun work on the RTR for the Solvent Extraction for Vegetable Oil Production source category and provide information on the rulemaking process. Following the teleconference, EPA forwarded a draft list of facilities to NOPA on November 3, 2016. NOPA provided updates to the facility list on December 9, 2016. (The information provided is included in Attachment A.1 of this document.)
      
 EPA met with Jay Frazer and Nick Remn of Cargill Corn Milling North America (Blair, NE) via teleconference on January 20, 2017 to discuss specific HAPs emitted from the Cargill  -  Blair facility and to determine whether the stacks associated with the emissions included emissions from the vegetable oil extraction and production operations. Following the teleconference, Michelle Bucklin of Cargill provided information to confirm the sources of the HAP included two vegetable oil production processes (flaker conditioner aspiration and cooker expeller aspiration) and provided emissions estimates for each HAP from each process. (The information provided is included in Attachment A.2 of this document.)
      
 EPA conducted a site visit to the Cargill, Inc. - Fayetteville, NC facility on December 5, 2017. EPA observed the vegetable oil production processes and discussed potential revisions to the startup, shutdown, and malfunction revisions. 
      
 EPA met with the National Oilseed Processors Association (NOPA) via teleconference on August 30, 2018 to discuss the status of the RTR and discuss the SSM provisions. 
      
 EPA conducted a site visit to the Perdue Agribusiness, LLC/Marietta  -  Bainbridge, PA facility on September 26, 2018. EPA observed the vegetable oil production processes and controls and discussed initial startup and shutdown procedures at the facility. 
      
 EPA met with Lorraine Gershman of NOPA, NOPA Counsel, and NOPA member companies on October 30, 2018 to discuss alternate standards for periods of initial startup or malfunction for the risk and technology review. NOPA provided a white paper on the initial startup provisions for the call. (A summary of the meeting and a copy of materials provided is included in Attachment A.3 of this document.)

 As a follow up to the October 30, 2018 teleconference, NOPA provided a submission to EPA on December 6, 2018 regarding initial startup periods and malfunction periods and recommendations for work practice standards that could be adopted for these periods. (A copy of the materials provided is included in Attachment A.4 of this document.)

 EPA met with NOPA representatives (David Hovermale, Tom Hammer) on March 5, 2018 to discuss proposed rule options and industry concerns regarding periods of malfunction. 

