&EPA
United S*i6
EiKviraimenlal Protection
Agency
COMPLIANCE DEMONSTRATION FOR
THE SOLVENT EXTRACTION FOR
VEGETABLE OIL PRODUCTION
NESHAP

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                                                             EPA-453/B-04-001
                                                                September 2001
Compliance Demonstration for the Solvent Extraction for Vegetable Oil
                           Production NESHAP
                                 Prepared for:
                          James Durham, Project Officer
                          Emissions Standards Division
                      U.S. Environmental Protection Agency
                    Office of Air Quality Planning and Standards
                          Emission Standards Division
                       Waste and Chemical Processes Group
                      Research Triangle Park, North Carolina

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                         TABLE OF CONTENTS

Section                                                                    Page

1.0    Introduction	1

2.0    HAP Loss Inventory Log	1

       2.1    Beginning and Ending Dates for Each Operating Status
             Period and the Process Operating Status   	2

       2.2    Beginning and Ending Solvent Inventory  	3

       2.3    Total  Quantity and Average HAP Content of Extraction
             Solvent Received	4

       2.4    Solvent Inventory Adjustments	5

       2.5    Monthly Actual Solvent Loss  	5

       2.6    Monthly Weighted Average HAP Content of Solvent  	6

       2.7    Actual Solvent Loss for the Previous 12 Operating Months	7

       2.8    Weighted Average HAP Content of Solvent for the Previous
             12 Operating Months	7

3.0    Oilseed Processed Inventory Log 	8

       3.1    Process Operating Status and Beginning and Ending
             Dates for Each Change in Process Operating Status	9

       3.2    Beginning and Ending Oilseed Inventory  	9

       3.3    Quantity of Oilseed Received  	9

       3.4    Oilseed Inventory Adjustments	10

       3.5    Monthly Determination of Quantity of Oilseed Processed	10

       3.6    Determining the Quantity of Oilseed Processed for the
             Previous 12 Operating Months  	11

4.0    Compliance Determination and Status Log   	12

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                              LIST OF TABLES




                                                                            Page




Table 1.  HAP Loss Inventory Log	15




Table 2A. Oilseed Processed Inventory Log - Flax  	17




Table 2B. Oilseed Processed Inventory Log - Cottonseed, Small 	19




Table 3.  Compliance Determination and Status Log	21




Table 4.  Oilseed Solvent Loss Factors for Determining Allowable HAP Loss	22
                                      11

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1.0 INTRODUCTION

The purpose of this document is to provide an example of how a vegetable oil production
process could demonstrate compliance with the solvent extraction for vegetable oil production
NESHAP (40 CFR 63, Subpart GGGG). To comply with these NESHAP, staff at affected
vegetable oil production processes need to monitor and record three types of information, as
listed below:

       1.      The HAP loss (gallons) from the vegetable oil production process.  An example
              HAP loss inventory log is shown as Table 1 and is described further in
              Section 2.0.

       2.      The quantity (tons) of each oilseed type processed at the vegetable  oil production
              process.  Example oilseed processed inventory logs are shown as Tables 2A and
              2B and are described in Section 3.0.

       3.      The determination and status of compliance. An example compliance
              determination and status log is shown as Table 3 and is described in Section 4.0.

Note: The example logs in this document are provided only as guidance for staff at vegetable oil
production processes. These example logs show how  required compliance information can be
recorded. This guidance document does not contain instructions for how staff at an affected
process must record compliance information.  Staff at  each vegetable oil production process may
develop its own recordkeeping logs, as long as all required information is properly recorded.

2.0  HAP LOSS INVENTORY LOG

Table 1 is an example log that shows how staff at a vegetable oil production process may wish to
organize and record monitoring information on HAP loss from the process. At a minimum, a
HAP Loss Inventory Log  should include entries to record the following information:

       1.      The beginning and ending dates for each operating status period and the process
              operating status (columns 1 and 2 of Table 1).

       2.      Beginning  and ending solvent inventory in gallons (columns 3 and  4 of Table 1).

       3.      Total quantity of extraction solvent received at the vegetable oil production
              process in gallons (column 5 of Table 1).

       4.      The average HAP content of solvent received at the vegetable oil production
              process represented as a volume fraction of the solvent (column 6 of Table 1).

       5.      If applicable, record and justify any adjustments made to the solvent inventory in
              gallons (column 7 of Table 1).

                                           1

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       6.      The monthly actual solvent loss in gallons (column 8 of Table 1).

       7.      The monthly weighted average HAP content of all solvent received represented as
              a volume fraction of the solvent (column 9 of Table 1).

       8.      The actual solvent loss for the previous 12 operating months in gallons
              (column 10 of Table 1).

       9.      The weighted average HAP content in solvent received for the previous 12
              operating months represented as a fraction of the volume of solvent.

Each of these listed entries is discussed in more detail in Sections 2.1 through 2.8.

2.1    Beginning and Ending Dates for Each Operating Status Period and the Process Operating
       Status

Columns 1 and 2 of Table 1 request the process operating status, and beginning and ending dates
for each change in operating status. In  §63.2853(a)(2) of the solvent extraction for vegetable oil
production NESHAP, five types of process operating status that a vegetable oil production
process may experience are listed and described:

       1.      normal operating period.,

       2.      nonoperating period,

       3.      initial startup period,

       4.      malfunction period, and

       5.      exempt period.

The dates that define each operating status period include the beginning date of each calendar
month and the date of any change in the source operating status.  If the vegetable oil production
process maintains the same operating status during an entire calendar month, the beginning and
ending dates of the calendar month define the operating period.  However, a vegetable oil
production process may cycle through more than one type of operating status during any given
calendar month, as shown in the following example log entries for Table 1:

•      An example vegetable oil production process maintains a normal operating status
       throughout January 2001. Therefore, the example process enters only the first and last
       days of the month (January 1  through January 31). The entire first calendar month
       qualifies as an operating month because the example process operated continuously
       through the month under a normal operating period.  All solvent information related to

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       this operating month must be entered into the log no later than the end of the calendar
       month following this operating month (i.e., by February 28, 2001).

•      In February 2001, the example process maintains a normal operating status for most of
       the month, but has a planned maintenance  shutdown in the last few days of the month.
       The example process must enter the beginning and ending dates of the normal operating
       period (February 1 through February 25) and designate this interval as a normal
       operating period. Next, the example process enters the beginning and ending dates of the
       shutdown period (February 26 through February 28) and designates this interval as a
       nonoperatingperiod. Since the example vegetable oil production process operated at
       least once under a normal operating period, the interval from February 1 through
       February 25 qualifies as an operating month. All solvent information related to this
       operating month must be entered into this log no later than the end of the calendar month
       following this operating month (i.e. by March 31, 2001).

•      The example vegetable oil production process remains  shutdown throughout the entire
       next calendar month. Thus, the example process enters the first and last days of the
       month (March 1 through March 31) and continues to designate this interval as a
       nonoperating period. Since the example process  did not operate once under a normal
       operating period during the month of March, this  interval is not categorized as an
       operating month and is  excluded from any counts for determining the 12 previous
       operating months.

•      The example vegetable oil production process resumes normal operations for all of
       April 2001 and continues normal operations into  May (May 1 through May 9).
       However, the example process experiences an emergency shutdown due to an unforeseen
       process malfunction in the middle of May  (May 10 through May 15, which is designated
       a malfunction period).  Since the example  process operated at least once under a normal
       operating period in the month of May (May 1 through May 9 and May 16 through May
       31- two normal operating periods), then May qualifies as another operating month.
       Thus, all solvent information related to this operating month must be entered into this log
       no later than the end of the calendar month following this operating month (i.e., by June
       30,2001).

2.2    Beginning and Ending Solvent Inventory

Columns 3 and 4 of Table 1 request the beginning and ending solvent inventory for each normal
operating period.  Staff at the example vegetable oil production process must measure and
record the solvent inventory by following the procedures described in its plan for  demonstrating
compliance.  (Requirements for preparing a plan for demonstrating compliance  can be found at
§63.2851.) Examples of how the solvent inventory should be recorded under different
circumstances are  shown below:

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•      Refer to Table 1 and the example entries for June, July, and August of 2001. The ending
       solvent inventory for a given operating month is generally the beginning solvent
       inventory for the following operating month. An exception is when solvent is received
       during a nonoperating month that separates two operating months (refer to Table 1
       entries for February, March, and April of 2001). In this case, the amount of solvent
       received during March 2001 (a nonoperating month) is added to the beginning solvent
       inventory of the next operating month.

•      The prior mentioned relationship of ending and beginning solvent inventories also
       applies to solvent loss associated with a nonoperating period such as a planned
       maintenance shutdown of the vegetable oil production process. Refer to Table 1 and the
       example entries for February 2001 (ending inventory of 2,000 gallons) and April 2001
       (beginning inventory of 4,000 gallons). Any solvent lost during this planned shutdown
       should be included in the solvent inventory for the next operating period and subject to
       the HAP emission limits of these NESHAP.

•      Solvent loss that occurs when a vegetable oil production process operates under a
       malfunction period or an initial startup periodic excluded from the solvent loss
       inventory. Refer to Table 1 and the example entry for May 2001. Two normal operating
       periods (May  1 through May 9, and May 16 through May 31)  are interrupted by a brief
       malfunction period (May 10 through May 15).  The ending  solvent inventory for the first
       normal operating period (3,500 gallons) is 500 gallons more than the beginning solvent
       inventory (3,000 gallons) for the following normal operating period. In this example
       entry, 500 gallons  of solvent was lost during the malfunction period and excluded from
       the rolling solvent inventory. During malfunction or initial startup periods, solvent
       losses are excluded from the solvent inventory and are not subject to the HAP emission
       limits.  Instead, the solvent losses are subject to control requirements described in the
       process's startup, shutdown, and malfunction plan. (Requirements for preparing a
       startup, shutdown, and malfunction plan can be found at §63.2852.)

2.3    Total Quantity and Average HAP Content of Extraction Solvent Received

Columns 5 and 6 of Table 1 request information on  the quantity and HAP content of solvent
received at the vegetable oil production process. Whenever a shipment of solvent is received at
a vegetable oil production process, the volume of solvent received and the average HAP content
(expressed as a volume fraction) of the solvent are entered on the HAP Loss Inventory Log.
Staff at the vegetable oil production process must determine the HAP content of each solvent
receipt by following the procedures described in its plan for demonstrating compliance.  Listed
below are several examples of how staff should record the quantity and HAP content of solvent
received at a vegetable oil production process.

•      In March 2001, the example process received a single shipment of solvent (2,000
       gallons) with a corresponding HAP volume fraction of 0.70. However, the operational
       status of the example process was a nonoperating period when the solvent delivery was

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       accepted. Thus, all information on this solvent delivery is recorded in the next log entry
       for a normal operating period. When the solvent inventory for the beginning of April
       2001 is determined, the inventory will reflect the 2,000 gallons of solvent added during
       the nonoperating period.

•      In May 2001, the example process received two separate solvent shipments (1,000
       gallons each). The first  solvent delivery was determined to have a HAP volume fraction
       of 0.75; while the second solvent delivery was determined to have a HAP volume
       fraction of 0.65. Therefore, the monthly weighted average HAP content of solvent
       received was determined and recorded as a volume fraction of 0.70.

2.4    Solvent Inventory Adjustments

Column 7 of Table  1 allows staff at a vegetable oil  production process to document periodic
adjustments to improve the recorded accuracy of the solvent inventory. Section 63.2853(a)(5) of
the solvent extraction for vegetable oil production NESHAP allows solvent inventory
adjustments to be made as long  as an adequate justification for the adjustment is provided.
Adjustments to the  solvent inventory are expected to be infrequent.  Examples of situations that
may require adjustments to the total solvent loss include, when solvent is destroyed in a control
device and when there  are changes in the solvent working capacity of the processing equipment.

2.5    Monthly Actual Solvent Loss

Based on information already recorded in  this type of log, staff at a vegetable oil production
process must determine its actual solvent loss for each operating month and enter the value, such
as under Column 8  of Table 1. The monthly actual solvent loss is the total solvent loss during all
normal operating periods of an  operating  month. The monthly actual solvent loss may be
determined using Equation 1 of §63.2853:
                           n
                         „  (SOLVB -  SOLVE + SOLVR ±_ SOLVA),
                          i=l
where:
       SOLVB    =  Gallons of solvent in the inventory at the beginning of normal operating
                    period "i" as determined at §63.2853 (a)(3).

       SOLVE    =  Gallons of solvent in the inventory at the end of normal operating period
                    "i" as determined at §63.2853 (a)(3).

       SOLVR    =  Gallons of solvent received between the beginning and ending dates of the
                    normal operating period "i" as determined at §63.2853 (a)(4).

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       SOLVA    =  Gallons of solvent added or removed from the solvent inventory during
                    operating period "i" as determined at §63.2853 (a)(5).

             i   =  An operating period.

             n   =  Number of operating periods within a calendar month.

•      Refer to Table 1 and the example entry for May 2001.  The example vegetable oil
       production process experiences two normal operating periods within the same month.
       The solvent losses corresponding to the first normal operating period (4,500 - 3,500 +
       1,000 + 0 = 2,000 gallons) and the second normal operating period (3,000 - 2,000 + 1,000
       + 0 = 2,000 gallons) are combined and recorded as the net solvent loss (4,000 gallons) for
       the entire operating month of May.

2.6    Monthly Weighted Average HAP Content of Solvent

Column 9 of Table 1 offers staff at the affected vegetable oil production process to determine the
weighted average HAP content of solvent received during a given month. The monthly weighted
average volume fraction  of HAP in the extraction solvent is based on all shipments of solvent
received since the last operating month, regardless of the operating status at the time of the
delivery. The monthly weighted average volume fraction of HAP may be determined using
Equation 1 of §63.2854:
              Monthly Weighted           Received *  Content             r   ,   ,
            Average  HAP Content =  £r_	~            EV- 1 °f
             of Extraction Solvent          Totai Received                  §63.2854
               (volume fraction)
where:

       Received;  =  Gallons of extraction solvent received in delivery "i".

       Content;   =  The volume fraction of HAP in extraction solvent delivery "i".

Total Received   =  Total gallons of solvent extraction received since the end of the previous
                    operating month. Note: this includes all solvent deliveries such as
                    deliveries  during nonoperational and malfunction periods that occur
                    between the end of the previous normal operating period and the
                    beginning of the next normal operating period.

              i   =  The delivery of extraction solvent.

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             n   =  The number of extraction solvent deliveries during the operating period.

•      For example, in May 2001 the example vegetable oil production process received two
       separate solvent shipments (1,000 gallons each). The first solvent delivery was
       determined to have a HAP volume fraction of 0.75; while the second solvent delivery
       was determined to have a HAP volume fraction of 0.65.  Using Equation 1 of §63.2854, a
       monthly weighted average HAP volume fraction in the solvent for this example entry was
       determined as 0.70.

2.7    Actual Solvent Loss for the Previous 12 Operating Months

After recording solvent loss information for 12 operating months, Column 10 of Table 1 allows
staff at a vegetable oil production process to determine and enter a value for the actual solvent
loss from the process for the previous 12 operating months. This solvent loss value is
determined by summing the actual solvent losses for the last twelve operating months.

Based on the example information recorded in Table 1, the first set of 12 operating months is
actually encompassed by the first 13 calendar months listed in Table 1.  This situation is the
result of the  example process being under a nonoperating status period for the entire month of
March 2001. Thus, the count for the 12 previous operating months begins in January 2001, skips
the entry for March 2001, and  continues through to January 2002, where the proper count of
operating month is attained.  The sum of the monthly actual solvent loss for the first 12 operating
months in this example log is 26,500 gallons.

2.8    Weighted Average HAP Content of Solvent for the Previous 12 Operating Months

After recording solvent loss and HAP content information for 12 operating months, Column 11
of Table 1 allows staff at a vegetable oil production process to determine and enter the weighted
average HAP content expressed as volume fraction of solvent received at the process for the
previous 12  operating months. This volume fraction value is determined using Equation 2 of
§63.2854:

                                      12
           12-Month Weighted             Received*  Content           „  .  ,
              Average HAP         =  ifr~	l_	^          E(l- 2 °J
       Content in Solvent Received           Total Received                §63.2854
            (volume fraction)
Where:
       Received;  =  Gallons of extraction solvent received in operating month "i" as
                    determined at §63.2853(a)(4).

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        Content;  =  Monthly average volume fraction of HAP in extraction solvent received in
                    operating month "i" as determined in accordance with §63.2854(b)(2).

Total Received   =  Total gallons of extraction solvent received during the previous 12
                    operating months.

              i   =  The operating month.

Based on the example information recorded in Table 1 for the first 12 operating months, the 12-
month weighted average volume fraction of HAP, (f), is 0.655.

3.0  OILSEED PROCESSED INVENTORY LOG

An Oilseed Processed Inventory Log must be completed for each oilseed type processed. For
this example, vegetable oil production process, it is assumed that the total oilseed processing
capacity is below 120,000 tons/year, and two types of regulated oilseed (flax and cottonseed) are
processed.  The example log Table 2A is completed for the flax inventory and Table 2B is
completed for the cottonseed (small) inventory.  Tables 2A and 2B show how staff at a vegetable
oil production process may wish to organize and record monitoring information documenting the
quantity of each oilseed type processed.  According to §63.2855, an Oilseed Processed Inventory
Log  should include entries to record the  following information for each operating month:

       1.      Process operating status and the beginning and ending dates for each change in
              process operating status,

       2.      Beginning and ending oilseed inventory,

       3.      Quantity of each oilseed type received at the process,

       4.      Oilseed inventory adjustments,

       5.      Determination of the monthly quantity of each oilseed type processed, and

       6.      Determination of the quantity of each oilseed type processed for the previous 12
              operating months.

Each of these listed entries is discussed in more detail in Sections 3.1 through 3.6.

3.1    Process Operating Status and Beginning and Ending Dates for Each Change in Process
       Operating Status

Columns 1  and 2 of Tables 2A and 2B request the process operating status, and beginning and
ending dates for each change in operating status.  The dates and process operating  status entered

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on the Oilseed Inventory Log must coincide exactly with the dates entered on the HAP Loss
Inventory Log.

3.2    Beginning and Ending Oilseed Inventory

Columns 3 and 4 of Tables 2A and 2B request the beginning and ending oilseed inventory for
each normal operating period. The example vegetable oil production process must measure the
oilseed inventory by following the procedures described in its plan for demonstrating
compliance. The oilseed inventory must be recorded at the beginning and ending dates of each
normal operating periodthat occurs during an operating month, as shown in the following
examples:

•      Refer to Table 2A and the example entries for June, July, and August of 2001.  The
       ending oilseed inventory for a given operating month is the beginning oilseed inventory
       for the following operating month.

•      When a vegetable oil production process operates under a malfunction period or an initial
       startup period, the quantities of oilseed processed are excluded from the inventory.
       Refer to Table 2 A and the example entry for May 2001.  Two normal operating periods
       (May 1 through May 9, and May 16 through May 31) are interrupted by a brief
       malfunction period (May 10 through May 15). The ending oilseed inventory for the first
       normal operating period (5,500 tons of flax) is 500 tons more than the beginning oilseed
       inventory (5,000 tons of flax) for the following normal operating period. In this example
       entry, 500 tons of flax was processed during the malfunction period and excluded  from
       the rolling oilseed inventory. Like the solvent losses, during malfunction or initial
       star tup periods, quantities of oilseed processed are excluded from the oilseed inventory.

3.3    Quantity of Oilseed Received

Column 5 of Tables 2A and 2B request information on the quantity of oilseed received at the
vegetable oil production process.  Whenever a shipment of oilseed is received at a vegetable oil
production process, the oilseed quantity is entered on the Oilseed Inventory Log. The staff at the
process must determine the mass of each oilseed receipt by following the procedures described
in its plan for demonstrating compliance.  Two examples are described below for entering
information  on an Oilseed Inventory Log:

•      Refer to Table 2A and the entry for March 2001.  The example vegetable oil production
       process received a single shipment of flax (2,000 tons). However, the operational status
       of the example process was a nonoperatingperiod when the flax delivery was accepted.
       Thus, information on this flax delivery is recorded in the next log entry for a normal
       operating period.  When the flax inventory for the beginning of April 2001  is
       determined, the inventory  will reflect the 2,000 tons of flax added during the
       nonoperating period.

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•      Refer to Table 2 A and the entry for May 2001 .  The example vegetable oil production
       process received two separate flax shipments (2,000 tons each), for a total of 4,000 tons
       of flax received at the process during May 2001.

3.4    Oilseed Inventory Adjustments

Column 6 of Tables 2A and 2B allow staff at an affected process to document periodic
adjustments to improve the recorded accuracy of the oilseed inventory. In §63.2855(a)(5) of the
solvent extraction for vegetable oil production NESHAP, oilseed inventory adjustments can be
made, as long as, an adequate justification for the adjustment is provided. Entries to adjust the
oilseed inventory are  expected to be infrequent.  Examples of situations that may require
adjustments to the mass of oilseed processed include:

•      Oilseed that mold or otherwise become unsuitable for processing.

•      Oilseed you sell before it enters the processing operation.

•      Oilseed destroyed by an event such as a process malfunction, fire, or natural disaster.

•      Oilseed processed through operations prior to solvent extraction such as screening,
       dehulling, cracking, drying, and conditioning; but that are not routed to the solvent
       extractor for further processing.

•      Inventory corrections due to periodic physical measurements of inventory.

3.5    Monthly Determination of Quantity of Oilseed Processed

Column 7 of Tables 2A and 2B allow staff at a vegetable oil production process to document the
quantity of each oilseed processed each operating month. The monthly quantity of oilseed
processed is the total  of each type of oilseed  processed during all normal operating periods of an
operating month.  The monthly oilseed processed may be determined using Equation 1 of
§63.2855:
       Monthly Quantity    n
        of Each Oilseed  =  E (SEEDB -  SEEDE +  SEEDR  - SEEDA).
        Processed (tons)     i=1

where:
                                                                               *,
                                                                               §63.
       SEEDB    =  Tons of oilseed in the inventory at the beginning of normal operating
                    period "i" as determined in paragraph §63.2855 (a)(3).
                                           10

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       SEEDE    =  Tons of oilseed in the inventory at the end of normal operating period "i"
                    as determined in paragraph §63.2855 (a)(3).

       SEEDR    =  Tons of oilseed received between the beginning and ending dates of the
                    normal operating period "i" as determined in §63.2855 (a)(4).

       SEEDA    =  Tons of oilseed added or removed from the solvent inventory during
                    operating period "i" as determined in §63.2855 (a)(5).

             i   =  An operating period.

             n   =  Number of normal operating periods in the calendar month during which
                    this type of oilseed was processed.

•      Refer to Table 2A and the example entry for May 2001.  The example process
       experiences two normal operating periods within the same month.  The quantity of flax
       processed during the first normal operating period (4,000 - 5,500 + 2,000 + 0 = 500 tons)
       and the second normal operating period (5,000 - 7,000 + 2,000 + 0 = 0 tons) are
       combined and recorded in Column 7 as the net quantity of flax processed (500 tons) for
       the entire operating month of May.

3.6    Determining the Quantity of Oilseed Processed for the Previous 12 Operating Months

After recording the quantity of all oilseed types processed for 12 operating months, Column 8 of
Tables 2A and 2B offers staff at the affected process to enter the quantity of each oilseed type
processed for the previous 12 operating months.  This quantity of oilseed processed is
determined by summing the monthly quantities of oilseed processed at the vegetable oil
production process for the last twelve operating months. Based on the example data provided in
Tables 2 A, the first, 12-month rolling sum (January  2001 through January 2002) of flax
processed includes only 6 months of operating data. In the following month, the second 12-
month rolling sum (February 2001 through February 2002) of flax processed now includes only
5 months of operating data.

Based on the example information recorded in Tables 2A and 2B, the first set of 12 operating
months is actually encompassed by the first 13 calendar months listed in Table 1.  This situation
is the result of the example process being under a nonoperating status periodTor the entire
month of March 2001. Thus, the count for the 12 previous operating months begins in January
2001, skips the entry for March 2001, and continues through to January 2002, where the proper
count of 12 operating months is attained. The quantities of flax and cottonseed processed  for the
first 12 operating months in this example log are 26,500 and 24,000 tons, respectively.
                                           11

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4.0 COMPLIANCE DETERMINATION AND STATUS LOG

Table 3 is an example log that shows how an affected process may wish to organize and record
the input variables for the compliance ratio calculation and the corresponding results. At a
minimum, a Compliance Determination and Status Log should include entries to record the
following information:

       1.     Beginning and ending dates defining each operating month,

      2.     Actual solvent loss for the previous 12 operating months (see Table 1),

      3.     Weighted average of HAP in solvent for the previous 12 operating months
             (see Table 1),

      4.     Quantity of each oilseed type processed for the previous 12 operating months
             (see Tables 2A and 2B),

      5.     Determination of the monthly compliance ratio, and

      6.     Determination of compliance status with the HAP emission limits of these
             NESHAP.

The 12-month rolling sum of actual solvent loss, weighted average HAP content, and quantity of
each oilseed type processed can be determined using the example data recorded in Tables 1, 2A,
and 2B.  These calculated and recorded values are copied over to Table 3 to support
documentation of the compliance ratio calculation.

The compliance ratio is simply the ratio of the "actual" HAP loss in gallons from an affected
process to the "allowable" HAP loss in gallons as permitted by the NESHAP.
                     n    ,.     v ..       "Actual"  HAP Loss
                     Compliance Ratio
                                         "Allowable" HAP Loss
The prior mentioned compliance ratio equation can be re-arranged to accept solvent loss
information instead of HAP loss information, as shown in Equation 2 from §63.2840(a)(2):

             ~,    ,.     „ ..        f *  Actual  Solvent Loss
             Compliance Ratio =  -
                 *
                                 -             Vf,  -.  r
                                          m                                &q-  2 of
                                 0.64 *   E  [(Oilseed^ *(SLF)j]             §63.2840
                                          12

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Where:
                           The weighted average volume fraction of HAP in solvent received
                           during the previous 12 operating months, as determined in
                           §63.2854, dimensionless. (Refer to Table 3, Column 3)

                           The average volume fraction of HAP in solvent in the baseline
                           performance data, dimensionless.

                           Gallons of actual solvent loss during previous 12 operating
                           months, as determined in §63.2853. (Refer to Table 3,  Column 2)

                           Tons of each oilseed type "j" processed during the previous 12
                           operating months, as shown in §63.2855. (Refer to Table 3,
                           Column(s) 4 and/or 5)

                           The corresponding solvent loss factor (gal/ton) for oilseed "j"
                           listed in Table 1 of §63.2840 of the NESHAP.  As a convenience,
                           the list of solvent loss factors has been reprinted in this document
                           as Table 4.
                    j   =   Each oilseed type processed.

                    m =   Number of oilseed types processed during the previous 12
                           operating months.

       Based on the example information recorded in Tables 1, 2A, and 2B for the first 12
       operating months, the result of the first compliance ratio calculation is 0.84. An example
       calculation of how this compliance ratio was determined is shown below:
                 f  =
             0.64   =
Actual Solvent Loss  =
          Oilseed   =
             SLF   =
 smpliance Ratio =
                                           0.66  *  26,500 gal.
                    0.64 *  [(26,500 tons *  0.6 gal/ton)  + (24,000 tons *  0.7 gal/ton
                     Compliance Ratio
                                      17,490 gal. HAP
                                      20,928 gal. HAP
0.84
                                          13

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When the value of the compliance ratio, as determined above, is less than 1.00, then the affected
vegetable oil production process is in compliance with the allowable HAP emissions under these
NESHAP. The word, "Yes," can then be entered under Column 7 of Table 3. When the
compliance ratio is greater than 1.00, then the affected process is not in compliance with the
allowable HAP emissions under these NESHAP. The word, "No," should then be entered under
Column 7 of Table 3.

•      In Table 3, all of the example data show that all of the monthly compliance ratio values
       are below 1.00. Thus, the example vegetable oil production process is in compliance
       with the allowable HAP emissions under these NESHAP for the period of 12/01/01 to
       02/28/02.

•      Note:  In a case where an affected process handles two or more oilseed types, it is not a
       requirement for compliance to determine or record a "weighted average" SLF value. The
       above compliance ratio equation requires only the substitution of the SLF (from Table 4
       of this document) that corresponds to each oilseed type processed and the quantity (in
       tons) of each oilseed type processed over the previous 12  operating months. The above
       compliance ratio equation format has the advantage of simplifying the procedure for
       comparing the "actual" HAP loss to the "allowable" HAP loss from a vegetable oil
       production process.  Thus,  there is no need to determine a "weighted average" SLF value.
                                          14

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TABLE 1. HAP LOSS INVENTORY LOG

[1]


Dates of Each
Operating
Status
Period
§63.2853
(a)(l)
1/1-31/01
2/1-25/01
2/26-28/01
3/1-31/01



4/1-30/01
5/1-9/01
5/10-5/15
5/16-31/01
6/1-30/01
7/1-31/01
8/1-31/01
[2]





Operating
Status
§63.2853
(a)(2)
Normal
Normal
Non-operating
Non-operating



Normal
Normal
Malfunction
Normal
Normal
Normal
Normal
Solvent Inventory
(gallons)
§63.2853(a)(3)



[3]


Beginning
4,000
3,000
—
—



4,000
4,500
—
3,000
2,000
1,000
2,000



[4]


Ending
3,000
2,000
—
—



4,500
3,500
—
2,000
1,000
2,000
1,000
[5]


Total
Extraction
Solvent
Received
(gallons)
§63.2853
(a)(4)
1,000
2,000
0
2,000 gal. were
received but it is
recorded in next
operating month
2,000
1,000
0
1,000
2,000
3,000
0
[6]

Average
HAP Content ol
Solvent
Received
(Volume
fraction)
§63.2854
(b)
0.70
0.70
—
0.70
recorded in next
operating month

0.70
0.75
—
0.65
0.70
0.70
—
[7]


Solvent
Inventory
Adjustments
[+/-]
(gallons)
§63.2853
(a)(5)
0
0

0



0
0
0
0
0
0
0
[8]


Monthly
Actual
Solvent
Loss
(gallons)
§63.2853
(b)
2,000
3,000

—



1,500

4,000

3,000
2,000
1,000
[9]
Monthly
Weighted
Average HAP
Content of
Solvent
(Volume
fraction)
§63.2854
(b)(2)
0.70
0.70

0.70
recorded in
next operating
month
0.70

0.70

0.70
0.70
0.70
For the Previous
12 Operating
Months

[10]
Actual
Solvent Loss
(gallons)
§63.2853
(c)















[11]
f
(Volume
fraction)
§63.2854
(b)














             15

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TABLE 1. HAP LOSS INVENTORY LOG

[1]


Dates of Each
Operating
Status
Period
§63.2853
(a)(l)
9/1-30/01
10/1-31/01
11/1-30/01
12/1-31/01
1/1-31/02
2/1-28/02
3/1-31/02
[2]





Operating
Status
§63.2853
(a)(2)
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Solvent Inventory
(gallons)
§63.2853(a)(3)



[3]


Beginning
1,000
1,000
1,000
1,000
1,000
1,000
1,000



[4]


Ending
1,000
1,000
1,000
1,000
1,000
1,000
1,000
[5]


Total
Extraction
Solvent
Received
(gallons)
§63.2853
(a)(4)
2,000
2,000
2,000
2,000
2,000
1,000
2,000
[6]

Average
HAP Content ol
Solvent
Received
(Volume
fraction)
§63.2854
(b)
0.60
0.60
0.60
0.60
0.60
0.60
0.60
[7]


Solvent
Inventory
Adjustments
[+/-]
(gallons)
§63.2853
(a)(5)
0
0
0
0
0
0
0
[8]


Monthly
Actual
Solvent
Loss
(gallons)
§63.2853
(b)
2,000
2,000
2,000
2,000
2,000
1,000
2,000
[9]
Monthly
Weighted
Average HAP
Content of
Solvent
(Volume
fraction)
§63.2854
(b)(2)
0.60
0.60
0.60
0.60
0.60
0.60
0.60
For the Previous
12 Operating
Months

[10]
Actual
Solvent Loss
(gallons)
§63.2853
(c)




26,500
25,500
24,500

[11]
f
(Volume
fraction)
§63.2854
(b)




0.655
0.650
0.641
             16

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                          TABLE 2A. OILSEED PROCESSED INVENTORY LOG
OILSEED TYPE:
FLAX
[1]
Dates of Each
Operating Status
Period
§63.2855(a)(l)
1/1-31/01
2/1-25/01
2/26-28/01

3/1-31/01


4/1-30/01
5/1-9/01
5/10-15/01
5/16-31/01
6/1-30/01
[2]
Operating
Status
§63.2855
(a)(2)
Normal
Normal
Non-
operating
Non-
operating

Normal
Normal
Malfunction
Normal
Normal
[3]
Beginning
Inventory
(tons)
§63.2855(a)(3)
6,500
5,000


	


6,000
4,000
—
5,000
7,000
[4]
Ending
Inventory
(tons)
§63.2855(a)(3)
5,000
4,000


	


4,000
5,500
—
7,000
4,000
[5]
Oilseed
Received
(tons)
§63.2855(a)(4)
4,500
5,000


2,000 tons were
received but it is
recorded in next
operating month
2,000
2,000
0
2,000
3,000
[6]
Oilseed
Inventory Adjustments
[+/-]
(tons)
§63.2855(a)(5)
0
0


0


0
0
0
0
0
[7]
Quantity of
Flax
Processed
(tons)
§63.2855(b)
6,000
6,000


	


4,000

500

6,000
[8]
"Oilseed"
12-Month
Rolling Sum
of Flax
(tons)
§63.2855(c)












                                            17

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                                    TABLE 2A.  OILSEED PROCESSED INVENTORY LOG
OILSEED TYPE:
FLAX
[1]


Dates of Each
Operating Status
Period
§63.2855(a)(l)
7/1-31/01
8/1-31/01
9/1-30/01
10/1-31/01
11/1-30/01
12/1-31/01
1/1-31/02
2/1-28/02
3/1-31/02
[2]


Operating
Status
§63.2855
(a)(2)
Normal
Normal*
Normal*
Normal*
Normal*
Normal*
Normal*
Normal*
Normal*
[3]


Beginning
Inventory
(tons)
§63.2855(a)(3)
4,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
[4]


Ending
Inventory
(tons)
§63.2855(a)(3)
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
[5]


Oilseed
Received
(tons)
§63.2855(a)(4)
10,000
0
0
0
0
0
0
0
0
[6]

Oilseed
Inventory Adjustments
[+/-]
(tons)
§63.2855(a)(5)
0
0
0
0
0
0
0
0
0
[7]

Quantity of
Flax
Processed
(tons)
§63.2855(b)
4,000
0
0
0
0
0
0
0
0
[8]
"Oilseed"
12-Month
Rolling Sum
of Flax
(tons)
§63.2855(c)






26,500
20,500
14,500
       Although the quantity of flax processed is zero for this calendar month, the operating status of the example vegetable oil production process is "normal"
       because another type of oilseed (cottonseed, refer to Table 2B) is being processed.
                                                              18

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                            TABLE 2B.  OILSEED PROCESSED INVENTORY LOG
OILSEED TYPE:    COTTONSEED - SMALL (<120. OOP tons of total oilseed/year processed)
[1]
Dates of Each
Operating Status
Period
§63.2855(a)(l)
1/1-31/01
2/1-25/01
2/26-28/01

3/1-31/01


4/1-30/01
5/1-9/01
5/10-15/01
5/16-31/01
6/1-30/01
7/1-31/01
[2]
Operating
Status
§63.2855
(a)(2)
Normal*
Normal*
Non-
operating
Non-
operating

Normal*
Normal*
Malfunction
Normal*
Normal*
Normal*
[3]
Beginning
Inventory
(tons)
§63.2855(a)(3)
0
0


	


0
0
—
0
0
0
[4]
Ending
Inventory
(tons)
§63.2855(a)(3)
0
0


	


0
0
—
0
0
0
[5]
Oilseed
Received
(tons)
§63.2855(a)(4)
0
0


2,000 tons were
received but it is
recorded in next
operating month
0
0
0
0
0
0
[6]
Oilseed
Inventory
Adjustments
[+/-]
(tons)
§63.2855(a)(5)
0
0


0


0
0
0
0
0
0
[7]
Quantity of
Cottonseed
Processed
(tons)
§63.2855(b)
0
0


	


0

0

0
0
[8]
"Oilseed"
12-Month
Rolling Sum
of Cottonseed
(tons)
§63.2855(c)













                                                19

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                                   TABLE 2B.  OILSEED PROCESSED INVENTORY LOG
OILSEED TYPE:     COTTONSEED - SMALL (<120. OOP tons of total oilseed/year processed)
[1]


Dates of Each
Operating Status
Period
§63.2855(a)(l)
8/1-31/01
9/1-30/01
10/1-31/01
11/1-30/01
12/1-31/01
1/1-31/02
2/1-28/02
3/1-31/02
[2]


Operating
Status
§63.2855
(a)(2)
Normal
Normal
Normal
Normal
Normal
Normal
Normal
Normal
[3]


Beginning
Inventory
(tons)
§63.2855(a)(3)
10,000
8,000
5,000
4,000
6,000
4,000
4,000
6,000
[4]


Ending
Inventory
(tons)
§63.2855(a)(3)
8,000
5,000
4,000
6,000
4,000
4,000
6,000
5,000
[5]


Oilseed
Received
(tons)
§63.2855(a)(4)
2,000
3,000
1,000
8,000
2,000
2,000
4,000
1,000
[6]
Oilseed
Inventory
Adjustments
[+/-]
(tons)
§63.2855(a)(5)
0
0
0
0
0
0
0
0
[7]

Quantity of
Cottonseed
Processed
(tons)
§63.2855(b)
4,000
6,000
2,000
6,000
4,000
2,000
2,000
2,000
[8]
"Oilseed"
12-Month
Rolling Sum
of Cottonseed
(tons)
§63.2855(c)





24,000
26,000
28,000
      Although the quantity of cottonseed processed is zero for this calendar month, the operating status of the example vegetable oil production process is
      "normal" because another type of oilseed (flax, refer to Table 2A) is being processed.
                                                            20

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TABLE 3. COMPLIANCE DETERMINATION AND STATUS LOG



[1]
See Table 1

Dates Defining
Each
Operating
Month
§63.2853
(a)(l)
1/1-31/01
2/1-25/01
4/1-30/01
5/1-9/01 and
5/16-31/01
6/1-30/01
7/1-31/01
8/1-31/01
9/1-30/01
10/1-31/01
11/1-30/01
12/1-31/01
1/1-31/02
2/1-28/02



[2]
See Table 1

Actual
Solvent Loss
for Previous
12 Operating
Months
(gallons)
§63.2853
(c)











26,500
25,500
24,500



[3]
See Table 1

f, Weighted
Average HAP
Content in Solvent
Received for
Previous 12
Operating Months
(weight %)
§63.2854(b)











0.66
0.65
0.64

The SLF for Flax
is 0.6 sal/ton
See Table 1 of
§63.2840
[4]
See Table 2A

Quantity of
Flax
Processed for
Previous 12
Operating
Months
(tons)
§63.2855(c)











26,500
20,500
14,500
The SLF for
Cottonseed is 0.7
gal/ton
See Table 1 of
§63.2840
[5]
See Table 2B

Quantity of
Cottonseed
Processed for
Previous 12
Operating
Months
(tons)
§63.2855(c)











24,000
26,000
28,000





[6]
Compliance
Ratio
§63.2840(b)











0.84
0.86
0.89



[7]
Is Your Source
in
Compliance?
(i.e., is the
compliance
ratio < 1.00?)
§63.2840(c)











Yes
Yes
Yes
                                21

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TABLE 4. OILSEED SOLVENT LOSS FACTORS FOR DETERMINING
                ALLOWABLE HAP LOSS
Type of Oilseed
Processed
1. Corn Germ, Wet
Milling
2. Corn Germ, Dry
Milling
3. Cottonseed, Large
4. Cottonseed, Small
5. Flax
6. Peanuts
7. Rapeseed
8. Safflower
9. Soybean,
Conventional
10. Soybean, Specialty
11. Soybean,
Combination Plant with
Low Specialty
Production
12. Sunflower
A Source that...
processes corn germ that has been separated from
other corn components using a "wet" process of
centrifuging a slurry steeped in a dilute sulfurous
acid solution
processes corn germ that has been separated from the
other corn components using a "dry" process of
mechanical chafing and air sifting.
processes 120,000 tons or more of a combination of
cottonseed and other listed oilseeds during all normal
operating periods in a 12 operating month period.
processes less than 120,000 tons of a combination of
cottonseed and other listed oilseeds during all normal
operating periods in a 12 operating month period.
processes flax
processes peanuts
processes rapeseed
processes safflower
uses a conventional style desolventizer to produce
crude soybean oil products and soybean animal feed
products.
uses a special style desolventizer to produce soybean
meal products for human and animal consumption.
processes soybeans in both specialty and
conventional desolventizers and the quantity of
soybeans processed in specialty desolventizers
during normal operating periods is less than 3.3
percent of total soybeans processed during all normal
operating periods in a 12 operating month period.
The corresponding solvent loss factor is an overall
value and applies to the total quantity of soybeans
processed.
processes sunflower
Oilseed Solvent Loss Factor
(gal/ton)
Existing
Sources
0.4
0.7
0.5
0.7
0.6
1.2
0.7
0.7
0.2
1.7
0.25
0.4
New Sources
0.3
0.7
0.4
0.4
0.6
0.7
0.3
0.7
0.2
1.5
0.25
0.3
                        22

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                                      TECHNICAL REPORT DATA
                                 (Please read Instructions on reverse before completing)
 1. REPORT NO.
   EPA-453/B-04-001
                                                                      3. RECIPIENT'S ACCESSION NO.
 4. TITLE AND SUBTITLE
 Compliance Demonstation of the Solvent Extraction for
 Vegetable Oil Production NESHAP
5. REPORT DATE
 September 2001
                                                                      6. PERFORMING ORGANIZATION CODE
                                                                      OAQPS/ESD	
 7. AUTHOR(S)
   James Durham
                                                                      8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                                       10. PROGRAM ELEMENT NO.
                                                                       11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                                       13. TYPE OF REPORT AND PERIOD COVERED
   Office of Air Quality Planning and Standards

   U.S. Environmental Protection Agency
   Research Triangle Park, NC  27711	
14. SPONSORING AGENCY CODE
EPA/200/04
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
 This documents provides an example scenario for how a facility can demonstrate compliance with the
 Solvent Extraction for Vegetable Oil Production NESHAO
 17.
                                        KEY WORDS AND DOCUMENT ANALYSIS
                     DESCRIPTORS
                                                    b. IDENTIFIERS/OPEN ENDED TERMS
                                                                                          c. COSATI Field/Group
                                                    Air Pollution control
 18. DISTRIBUTION STATEMENT
   Release Unlimited
                                                    19. SECURITY CLASS (Report)
                                                      Unclassified
                    21. NO. OF PAGES
                           23
                                                    20. SECURITY CLASS (Page)
                                                      Unclassified
                                                                                          22. PRICE
EPA Form 2220-1 (Rev. 4-77)    PREVIOUS EDITION IS OBSOLETE

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United States                              Office of Air Quality Planning and Standards                       Publication No. EPA-453/B-04-001
Environmental Protection                   Emission Standards Division                                      September 2001
Agency                                   Research Triangle Park, NC

-------