Adopt-a-mact Project: a Manual of Model Documents and Guidance to Aid Compliance and Enforcement of the Nutritional Yeast Mact (40 Cfr Part 63 Subpart Cccc)


ADOPT-A-MACT PROJECT
A Manual of Model Documents and Guidance to aid
Compliance and Enforcement of the
NUTRITIONAL YEAST MACT
(40 CFR Part 63, Subpart CCCC)
September 2003
Prepared by:
Kingsley Adeduro and Ed Snyder
Office of Radiation and Compliance Assurance
AIR Division
US EPA Region 9
-i-

-------
INTRODUCTION
To fulfill our Adopt-A-MACT commitment to Headquarters and OECA, Region 9 chose the
Nutritional Yeast MACT for our project to develop compliance tools. A goal in choosing this
MACT was to meet our commitment, while "piggy backing" on our efforts in West Oakland to
address air toxics and EJ issues associated with the Redstar/Lesaffre yeast manufacturing
facility. We knew that this MACT only impacted a few facilities nationwide, but sought to use
our work on this MACT as a component to our other work in West Oakland with Redstar.
Subsequent to our starting work on the nutritional yeast MACT, the Redstar facility announced it
was closing down.
The purpose of this checklist is to provide EPA inspectors with a tool to assist them in
determining compliance with and enforcement of the Nutritional Yeast MACT, 40 CFR Part 63,
Subpart CCCC. The checklist is designed to assist the inspector in planning for and conducting
on site inspections at facilities engaged in the manufacturing of nutritional yeast.
A Health and Safety field report from the facility inspection is also included, highlighting areas
that should be considered by inspectors conducting on site visits.
BACKGROUND
Yeast has been part of human history for more than 5000 years, first used to leaven bread and
produce alcoholic beverages. The biochemical process of fermentation was not understood until
the invention of the microscope and the later work of Louis Pasteur, who identified it as a living
organism. Isolation of yeast strains in pure culture form resulted in the commercial production of
nutritional yeast at the beginning of the 20th century.
The production of nutritional yeast begins with pure strains of Saccharomyces cerevisiae grown
on mixtures of cane and beet molasses. After fermentation is completed, the yeast is harvested,
washed, pasteurized, dried, and packaged.
The EPA identified the manufacturing of nutritional yeast as a major source of acetaldehyde, a
recognized hazardous air pollutant (HAP) and volatile organic compound (VOC). Section 112(d)
of the Clean Air Act (CAA) set emission standards, for HAPs, using the application of stringent
air pollution controls known as maximum achievable control technology (MACT). It is expected
that implementation of these standards will eliminate approximately 13% of acetaldehyde
emissions nationwide, with this sector seeing acetaldehyde emissions go from 240 tons a year to
31 tons a year. The final rule allows flexibility for facilities to meet the air emission (MACT)
standards using a variety of technologies. However, all the affected facilities have indicated that
they plan to meet the final standards using pollution prevention techniques and process controls.
Acute (short term) and chronic (long term) inhalation exposure to acetaldehyde is associated
with adverse health effects including irritation to the eyes, skin and respiratory tract.
Acetaldehyde is a potential developmental toxin and a possible human carcinogen.
-2-

-------
In the course of doing research and field work to understand the manufacturing of nutritional
yeast, several trends were observed. The production of nutritional yeast has become international
in scope, with a number of existing American facilities being taken over by European or
Canadian multinational conglomerates. The manufacture of nutritional yeast is moving from
local to regional facilities, with older, less efficient facilities being closed.
Some of the newer "state of the art" facilities in Europe and the United States can achieve
emission reductions through operation and process design, that are lower than the MACT
standards. The process for manufacturing nutritional yeast has become highly automated, using
computer programs to control all aspects of production. It is through the use of automated
process controls, combined with mechanical, biofilter and incineration techniques, that enable
some facilities to claim zero emissions.
Compliance Requirements:
Facilities that come under the Standard Industrial Classification (SIC) code 2099 or the North
American Industry Classification (NAICS) code 311999 are subject to these MACT
requirements.
Emission Limits:
Owners and operators of affected sources must comply with 40 CFR Part 63, Subpart CCCC. For
at least 98% of all batches in each 12-month period, the VOC concentration in the fermenter
exhaust may not exceed the following(measured as propane and averaged over the duration of a
batch):
• lOOppmv for the last stage (trade stage)
• 200ppmv for the second to last stage (first generation), and
• 300ppmv for the third to last stage (stock stage)
Facilities must continuously monitor VOC concentration in the fermenter exhaust during each
batch period. As an alternative, facilities may continuously monitor "brew ethanol" during
batches in lieu of fermenter exhaust performance testing. To comply under this option, facilities
must conduct performance tests to correlate brew ethanol concentrations with fermenter exhaust
concentrations (a "brew -to-exhaust" correlation). These tests must be repeated at least once a
year. Compliance would then be based on brew methanol concentrations equivalent to the above
standards.
Notification:
A notification of compliance status (NCS) must be submitted to EPA. Facilities required to
conduct performance tests must submit their NCS no later than 60 days after conducting the
performance test. All other facilities must submit their NCS no later than the first July 31 or
January 31 following the first 12 months of compliance with the rule. Initial reporting is
-3-

-------
followed by semiannual compliance reporting on every July 31 and January 31. Monitoring and
reporting records must be retained for 5 years (2 years onsite).
Malfunction Plans:
Facilities must also develop and implement written malfunction plans. Immediate reporting
(within 2 days) is required if a malfunction occurs that is not consistent with the malfunction
plan.
Permits:
Finally, affected yeast manufacturing facilities must obtain and/or revise Title V operating
permits and met other requirements in the general NESHAP provisions.
For further information on this MACT, contact David W. Markwordt at (919)-541-0837 or
markwordt.david@epa.gov. For Region 9, contact Kingsley Adeduro at (415)-947-4182 or
adeduro.kingsley@epa.gov, or Ed Snyder at (415)-947-4186 or snyder.ed@epa.gov.
Pollution Prevention
The American Yeast facility in Bakersfield, California, has an agreement to pipe the ethanol
(which makes up 80 to 90 per cent of the VOC emissions produced as a "waste" of the
fermentation process), to a local water treatment plant to power a co-generation boiler used at the
facility. This use of "waste" from the nutritional yeast production process serves as a good
example of a pollution prevention opportunity.
A starting point for many companies interested in pollution prevention is the adoption of an
Environmental Management Systems (EMS). The use of an EMS by many facilities has resulted
in:
•	Reduced raw material use and waste generation
•	Reduced insurance premiums
•	Enhanced public image and competitiveness by emphasizing Pollution Prevention
(P2) and going beyond compliance
•	Reduced environmental costs and an improved bottom line
•	Improved relations with government agencies.
Assistance in setting up an EMS may be found at the Federal, state and local levels, as well as
private sector and non profit groups.
The benefits of adopting an Environmental Management Systems (EMS)
-4-

-------
It is possible for sources that are subject to the Nutritional Yeast MACT to come into compliance
with the standards and even go beyond compliance, while reducing costs and wastes and
materials used in the process(s). This can be accomplished through the adoption and use of an
EMS combined with the use of pollution prevention (P2) techniques. An EMS follows a
systematic approach of planning, implementing, evaluating and improving. The use of pollution
prevention techniques does not depend on the use of an EMS, but those organizations who have
adopted an EMS, have found that it helps promote the successful use of P2.
Protecting the environment by coming into compliance or, ideally, going beyond compliance can
be very attractive to companies engaged in nutritional yeast production. An EMS can help reduce
waste, costs, and inefficiencies. It promotes preservation of natural resources and can lessen the
impact of industrial processes on the environment. An EMS can make greater use of materials
already purchased and reduce purchasing costs. An EMS can aid an organization in having
cleaner emissions and can also lessen the severity of spills, leaks, and other accidents. Overall an
EMS can reduce costs for permitting, remediation, worker comp, insurance, and can also reduce
the risk for potential law suit and fines.
Protecting the environment involves purchasing smaller amounts of materials or purchasing less
toxic materials. These purchasing choices reduce OSHA reporting and record-keeping
requirements and costs. These choices improve worker safety and morale, leading to more
productive workers. Purchasing less hazardous materials reduces the need for and the costs
associated with special equipment, special training, and specially designed storage areas. These
purchasing practices also reduce the cost of disposal. Protecting the environment by going
beyond compliance helps keep regulators and inspectors out of the plant.
A major study by ICF Kaiser International "shows that when public companies improve their
corporate environmental practices, they are able to increase shareholder wealth by up to 5
percent...The findings suggest that when environmental risks are reduced, the company becomes
a more attractive investment to potential and current stockholders." Three factors contribute to
this result: corporate environmental management, environmental performance, and
environmental communications.
Success Stories: Businesses Profiting from an EMS
Many companies have profited from implementing an EMS. Here are descriptions of some brief
success stories which provide insights into the process and benefits of implementing an EMS. To
preserve confidentiality, some firms are referred to as "Company A" or similar.
• A manufacturer of office furniture eliminated the use of methyl
chloroform from its cleaning and fastening processes and reduced
the volume of VOC emissions by converting to a powder-based
coating system. These pollution prevention alternatives saved the
company more than $1.1 million per year, with a return on its $1
-5-

-------
million investment in less than one year. Other bonuses included
ease of compliance with increasingly stringent environmental
regulations and the elimination of incineration fees for solid and
liquid hazardous wastes.
Leff-Marvins Cleaners, Inc. provides dry cleaning services. The
company replaced its old equipment with new cold water chilled
closed loop systems to recycle PERC (perchloroethylene). The new
system also uses reusable nylon filters and increases efficiency,
since garments do not have to be transferred between machines.
The new equipment eliminated most VOC emissions (eliminating the
need for permits) and also reduced purchase of PERC from 200
gallons per month to 40 gallons per month. In addition, the
hazardous waste stream was reduced from over 1,900 gallons of
spent PERC per year to just 35 gallons of still residues per month.
The company realized a net savings of $1,400 per month with the
new system.
Company C considered trichloroethylene (TCE) emissions as
constituting a significant environmental impact due to: hazardous
waste disposal costs, TCE's impact on human health, and TCE's
toxicity rating (commonly listed as a potential carcinogen). Since
TCE emissions were identified as significant the company planned
to minimize TCE use and set a specific target of completely
eliminating TCE by the end of the fiscal year. The first step was
identifying areas where the TCE was used. Suppliers marked metal
parts using a grease coating to facilitate the stamping process.
Company C used TCE in a vapor degreaser to clean these metal
parts. The company convinced its suppliers to replace the grease
coating with a water-based lubricant, thereby eliminating TCE use
from the cleaning of about 80 percent of its parts. For the remaining
20 percent (parts that were cylindrical and required heavier oils in
their production), the company incorporated a two-step aqueous
cleaner to replace TCE. As a result, the degreasers were shut down.
By eliminating TCE in the facility, Company C saves approximately
$100,000 annually. More importantly, the company has reduced
health risks by eliminating the use of a suspected carcinogen in the
workplace.
During its EMS identification process, Company D noticed that one
of its large machines had a serious oil leak. The leak was quickly
repaired with a $5 gasket. This easy, inexpensive action cut by half
the amount of oil consumed by the company, creating significant
cost savings. In addition, the local municipal authority reclassified
-6-

-------
the plant as no longer generating hazardous waste.
The use of an EMS is not without cost or commitment, and while results will not come over
night, numerous companies have reported great success and returns for the effort. One company
reported energy savings of 15%, water costs reduced by 55%, costs for waste disposal reduced
by 50% and less chemical usage.
The current standard for Environmental Management Systems that is recognized world wide is
ISO 14000/14001.
If you would like more information on EMS, look at www.trst.com/isol-frame.htm and
www, i fc,oru/en vi ro/Publ i cati ons/EM S/em s. htm.
For additional information on pollution prevention (P2) and Environmental Management
Systems (EMSs), these Web sites offer a good starting point.
Internet Resources:
EPA:
www.epa.sov/ (EPA 's home page)
www, eya.gov epahome rules.html (Rules and regulations-
Nutritional Yeast is at 40CFR Part 63, Subpart CCCC)
www, eya. gov/sbo (EPA's small business home page-assistance
and links to other useful web sites)
www, eya. sov/oar/oaqys/ (Office of Air Quality Planning and
Standards-site offering a great deal of information relating to air
quality and technical assistance)
www, epa. sov/ttn/ (EPA's Technology Transfer Network (TTN)
electronic bulletin board system provides a wide range of technical
information about EPA's air toxics rules.)
www, eya.gov/ttn/sbay/access. html (Access to Small Business
Assistance Program Publications)
www, eya. gov/oeca/oc (Compliance assistance home page)
www, epa. gov/epahome/clearing. html (Compliance assistance and
sector links)
www, epa. gov/epahome/hotline. html (Telephone hotlines)
www, eya. gov/y2 (Pollutiom prevention information)
-7-

-------
http://es. eya. gov (EnviorSense-common sense solutions to
environmental problems.)
www. eya. sov/resion09 (Regional information-look for your
Regional Web-site)
-8-

-------
Health & Safety Field Report EPA Inspection
American Yeast, Bakersfield, California
Jeff Woodlee, CIH
September 18,2003
The Health & Safety Office of EPA Region 9 provided assistance to EPA 's Air Enforcement
inspectors during inspection of American Yeast, Bakersfield, California. American Yeast
produces bakers yeast by fermenting common yeast Saccharomyces Cerevisiae. Their
production facility includes indoor and outside operations that include fermentation tanks,
molasses tanks, mash tanks, aqueous ammonia system, miscellaneous feed systems, yeast
processing, yeast storage, natural gas boiler and laboratory. During the process volatile
organic compounds (VOCs) are produced. The San Joaquin Valley Air Pollution Control district
restricts air contaminant releases. Acetaldehyde was identified as a regulated VOC that might
cause significant exposure to inspectors. This field report evaluates exposure to acetaldehyde
and identifies other chemical exposures that may be important in future evaluations.
Acetaldehyde
During production acetaldehyde concentration is second to ethanol. Other by products consist of
organic acids, acetates and other alcohols. Approximately 80-90 percent of total VOC emissions
is ethanol and the remaining 10-20 percent consist of other alcohols and acetaldehyde.
Acetaldehyde is a hazardous air pollutant as defined under section 112 of the Clean Air Act.
Acetaldehyde is colorless, irritating, flammable, and highly reactive VOC. It can exist as liquid
or vapor. At dilute concentrations, it has a pleasant fruity odor. At high concentrations, the odor
becomes pungent and suffocating. Average low odor threshold for acetaldehyde is 67 ppb.
Occupational exposure limits include ACGIH-TLV of 25 ppm as a ceiling limit and OSHA PEL
of 200 ppm as an 8-hour time weighted average.
Health Effects
Acetaldehyde is primarily an inhalation hazard. Direct dermal contact with the liquid can cause
redness or burn. It is a confirmed animal carcinogen and NIOSH classified potential
occupational carcinogen. At low concentrations it is primarily an irritant and will cause eye
irritation when exposed to 50 ppm for 15 minutes. Concentrations over 200 ppm for prolonged
periods of time may cause narcosis, CNS depression, conjunctivitis and injury to the corneal
epithelium. The immediately dangerous to life and health (IDLH) level is 2000 ppm.
Engineering Controls
-1-

-------
U.S. EPA Region 9
Health and Safety
When investigating yeast production facilities it is important to identify ventilation control and
other engineer controls for VOC's. American Yeasts' major fermentation sources were found to
be outdoors and the indoor controls for processing and drying were general ventilation both
mechanical and leakage through large and small doorways. The outdoor fermentation was
process controlled to minimize acetaldehyde formation.
Exposure Assessment
S. cerevisieae is a commonly used industrial microorganism and is found in nature, being present
on fruits and vegetables. There is extensive history of use and exposure. Humans come into
contact with S. cervisiae on a daily basis through inhalation and ingestion. Review of the
literature indicates that it is not considered pathogenic and worst case exposure estimates
indicate low risk to workers from normal fermentation operations.
Of the associated VOC's released during fermentation, acetaldehyde is of primary concern due
its relative abundance and toxicity.
On April 29th 2003 EPA Region 9 inspected American Yeast facilities in Bakersfield, California.
Present for EPA were Ed Snyder, Kingsley Adeduro, John Brock and Jeff Woodlee. Personal
exposures to acetaldehyde were determined in the breathing zone of three inspectors using
NIOSH method 2538. Exposure to acetaldehyde was also monitored in real-time using length-of-
stain volumetric detector tubes. General Area samples were taken indoors and outdoors with
summa canisters and analyzed by GC-MS.
The real-time acetaldehyde measure was limited to a detection of 1 ppm. During the site visit
acetaldehyde was not detected by this method.
The personal samples were collected on XAD sorbent tubes treated with 2-hydroxymethyl
piperidine that provide a limit of detection of approximately 0.74 ppm. The average of personal
exposures were below the methods reported lower limit, however trace levels were reported that
averaged approximately 0.17 ppm. It is important to note that personal exposure levels are
below the limit for the method and indicate a range of exposure from 0 ppb to a few hundred
ppb as acetaldehyde. This range is further substantiated by semi-quantitative summa
measurements that indicate low ppb levels.
GC-MS data of the summa samples indicated the presence of ethanol, acetaldehyde, ethyl acetate
and other alcohols.
Summary
Exposure assessment of EPA personnel during inspection of American Yeast determined the
presence of acetaldehyde at low ppb levels. This is consistent with outdoor controlled process
-2-

-------
U.S. EPA Region 9
Health and Safety
fermentation, the presence of adequate indoor general ventilation and use of closed indoor feed
tanks.
The inspection illustrated a well run clean yeast production operation. It also revealed the
presence of a 15,325 gallon aqueous ammonia tank. Exposure to ammonia should be considered
and evaluated before and during future investigations.
-3-

-------
Subpart CCCC - National Emission Standards for Hazardous
Air Pollutants:
- Manufacturing of Nutritional Yeast
Compliance checklists

-------
TABLE OF CONTENTS
FACILITY INFORMATION
GENERAL QUESTIONS
INSPECTION CHECKLIST FOR BREW ETHANOL
o Use this checklist if Facility is demonstrating compliance by monitoring Brew
Ethanol
INSPECTION CHECKLIST FOR FERMENTER EXHAUST
o Use this checklist if Facility is demonstrating compliance by monitoring
Fermenter Exhaustl
FEDERAL REGISTER COMPLIANCES TABLES - Tables 1 through 6
These tables are summaries of the Regulations
Table 1 - Section 63.2140 - Subpart CCCC - Emission Limitations
This table summarizes how to comply with the Emission Limitations
Table 2 - Section 63.2161 - Subpart CCCC - Performance Tests
(Brew Ethanol Monitoring only)
This table summarizes the requirements for Performance Tests if the Facility is
demonstrating compliance by monitoring Brew Ethanol.

-------
Page 2 - Table of Contents
Table 3 - Subpart CCCC - Initial Compliance with Emission Limitations
As stated in Sec. 63.2165 (if you monitor Fermenter Exhaust, and in Sec. 63.2166 (if
you monitor Brew Ethanol).
This table summarizes how to comply with the requirements to demonstrate Inidial
Compliance with one applicable Emission Limitation.
Table 4 - Subpart CCCC - Continuous Compliance with Emission
Limitations
This table summarizes how to comply with the requirements to demonstrate
Continuous Compliance with the applicable Emission Limitations.
Table 5 - Requirement for Subpart CCCC - Reports
This table summarizes how to comply with the requirements of Sec. 63.2181,
Submission of Compliance Reports which include the Submission of Malfunction
Reports
Table 6 - Subpart CCCC - Applicability of General Provisions
This table summarizes how to comply with the applicable General Provisions
requirements as stated in Sec. 63.2190

-------
SECTION 1	FACILITY INFORMATION
Facility's Name

Facility's Address

Mailing Address (if different)

Facility's Owner

Owner's Address

Responsible Official, Name & Title

Mailing Address

Telephone

Facility's Primary Activity

S I C Code(s)

Environmental Contact

Contact's Telephone Number

Owner's Registered Agent

Registered Agent's Address

-------
Page 1 - General Questions
section 2	GENERAL QUESTIONS

Yes
No
NA






1.-
~
~
~
Does Facility manufacture Nutritional Yeast?





2.-
~
~
~
Is Facility's location a major source of HAP emissions?





3.-
~
~
~
Is Facility a non-major (area) source but will later increase its potential to emit HAP to major




source levels ?





4.-
~
~
~
When does Facility become a major source?




Date:




Amount of HAP





5.-
~
~
~
Does Facility produce Saccharomyces Cerevisiae?









Are all fermentation production lines exceeding 7000 gallons capacity (I.e. fermenters used




in the last three fermentation states, including the final batch. Other terms for fermentation




include "Stock first generation and trade" and CB4, CB5, and CB6









Note: A fermentation production line doesnot include Flask, pure-culture,or yeasting-tank




fermentations. It excludes all operations after the last dewatering operation such as




filtration.










6.-
~
~
~
Is yeast produced at this Facility for the purpose of becoming a dough ingredient for bread,




or for any other yeast-raised baked product, or for use as a nutritional food additive?









Note: 1. Specialty yeasts such as those for wine, champagne, whisky and beer are exempt.




2. Torula yeast (Candida utiles) using aerobic fermentation is also exempt.










7.-
~
~
~
Does Facility plan to be in compliance by monitoring BREW ETHANOL?




If YES: complete the Check List for Brew Ethanol

-------
Page 2 - General Questions

Yes
No
NA











8.-
~
~

Does Facility plan to be in compliance by monitoring FERMENTER EXHAUST?




If YES: complete the Check List for Fermenter Exhaust

-------
Page 1 - Brew Ethanol
Compliance Inspection Checklist for Brew Ethanol
Yes No NA
Cite
~ ~ ~
Has the facility been in compliance with the applicable emission
limitations for at least 98% of all batches (sum of batches from last,
second-to-last and third-to-last stages) in each 12-month rolling
calculation period (limitations are 100 ppmv for last stage, 200 ppmv
for second-to-last stage, or 300 ppmv for the third-to-last stage,
measured as propane, and averaged over the duration of the batch)?
63.2150(a)
CH EH CH Has a written malfunction plan been developed and implemented?
63.2150(c)
I—I.—| |—| Has initial compliance been demonstrated within 180 calendar days
before May 21, 2004, as per 63.2161 and 63.2165?
~ ~ ~
Has the facility established a brew-to-exhaust correlation as per
63.2161?
63.2161
Has a subsequent performance test been performed within one year of	.
~ ~ ~ the last performance test?	63.2162(b)
Are CEMS installed, operated, and maintained according to
~ ~ ~ manufacturer's specifications and the facility's malfunction plan?
63.2164(a)
Has each CEMS completed a minimum of one cycle of operation for	164(b)
~ ~ ~ each successive 30-minute period within each batch monitoring period?

-------
Page 2 - Brew Ethanol
Yes	No	NA
~	~	~
~	~	~
~	~	~
~	~	~
~	~	~
~	~	~
~	~	~
Has the CEMS data been reduced to arithmetic batch averages from
two or more data points over each 1-hour period, except during periods
when calibration, quality assurance, or maintenance activities are being
performed?
63.2164(c)
Does the facility have valid CEMS data from at least 75 percent of the
full hours over the entire batch monitoring period
63.2164(d)
Has the CEMS span been set to correspond not greater than 5 times
the relevant emission limit, using the most recent performance test
data (1.5 to 2.5 times the relevant emission limit being the range
considered optimum by EPA)?
63.2164(e)
Have the results of each inspection, calibration, and validation check
been recorded?
63.2164(f)
Has the GC (that is being used to calibrate the CEMS) been calibrated
at least daily, utilizing standard solutions of ethanol in water (0.05%, 63.2164(g)(1)
0.15% and 0.3 percent)?
Does the facility use either a Porapak® Q, 80-100 mesh, 6' X 1 /8",
stainless steel packed column, or the DB Wax, 0.53mm X 30 m	63.2164(h)(1)
capillary column?
If a CEMS ethanol value has differed by 20 percent or more from the
corresponding GC ethanol value, did the facility determine the brew
ethanol values through out the rest of the batch monitoring period by 63.2164(h)(2)
injecting brew samples into the GC not less frequently than every 30
minutes?

-------
Page 3 - Brew Ethanol
Yes No
~ ~
NA
~
Has the facility performed a calibration of the CEMS at least four times
per batch?
63.2164(h)(3)
Has a Notification of Compliance Status containing the results of the
CH EH CH initial compliance demonstration been submitted according 63.2180?
63.2166
~ ~ ~
Has the facility monitored continuously during each batch monitoring
period (with the exception of monitor malfunctions, associated repairs,
and required quality assurance or control activities (including, as
applicable, calibration checks and required zero and span
adjustments)?
63.2170(b)
~ ~ ~
Has the facility used data recorded during monitoring malfunctions,
associated repairs, and required quality assurance or quality control	^ o 170(c)
activities in data averages and calculations used to report emission or
operating levels, or to fulfill a minimum data availability requirement?
~ ~ ~
Has the facility used data collected during all other periods (i.e., periods
not involving monitoring malfunctions, associated repairs, and required
quality assurance or quality control activities) in assessing the
operation of the control system ?
63.2170(c)
~ ~ ~
Has the facility calculated the percentage of within-concentration
batches for each monthly rolling 12-month period as required in
63.2171?
63.2171(b)
If the facility had periods of malfunction, did they operate in accordance ^„ ,
~ ~ ~ with their maffimction plan?	63.2171(b)

-------
Page 4 - Brew Ethanol
Yes No
NA
~ ~ ~
Has the facility submitted all of the notifications in 63.7(b) and (c),
63.8(e), (f)(4) and (6), and 63.9(b) through (h) that apply?
63.2180(h)
~ ~ ~
Did the facility submit a notification of the intent to conduct a
performance test at least 60 days before the performance test is
scheduled?
63.2180(c)
Did the facility submit a Notification of Compliance Status according to
~ ~ ~ 63.9(h)(2)(ii) and according to paragraphs (e)(1) and (2) of 63.2180?
63.2180(e)
~ ~ ~
Has the facility submitted a Semi-Annual Compliance Report consistent
with the requirements and timelines specified in Table 5 to Subpart
CCCC and 63.2181?
63.2181(a)
~ ~ ~
If the facility had a malfunction during the reporting period that is not
consistent with the malfunction plan, has the facility submitted an
Immediate Malfunction Report consistent with the requirements and
timelines specified in Table 5 to Subpart CCCC and 63.2181?
63.2181(c)
Does the facility keep records of submitted notifications and reports,
records related to malfunction (as per 63.6(e)(3)(iii) through (v), records
of performance tests and performance evaluations (as per	63.2182(a)
I II II I 63.10(b)(2)(viii), and records of results of brew-to-ethanol exhaust
correlation tests?

-------
Page 5 - Brew Ethanol
Yes No NA
For each CEMS, does the facility maintain records as required by
63.10(b)(2)(vi), all required measurements needed to demonstrate
compliance with a relevant standard, records described in
(63.10(b)(2)(viii) through (xi) (the CEMS system must allow the amount
of excess zero and high-level calibration drift measured at the interval
checks to be quantified and recorded), all required CEMS
measurements, identification of each batch during which the CEMS
was inoperative (except for zero and high-level checks), identification of 63.2182(b)
| || || | each batch during which the CEMS was out of control (as defined in
63.2163(k)), previous versions of the performance evaluation plan,
request for alternatives to relative accuracy test for CEMS (as required
by 63.8(f)(6)(i), and records of each batch for which the batch-average
VOC concentration exceeded the applicable maximum VOC
concentration in Table 1 to Subpart CCCC and whether the batch was
in production during a period of malfunction or during another period?
EH EH dl Does the facility keep the records required in Table 4 to Subpart CCCC? 63.2182(c)
Has the facility kept records of unique batch identification number,
~ ~ ~ fermentation stage for which the fermenter is being used, and unique
CEMS equipment identification number?	63.2182(d)
~ ~ ~
Has the facility kept all required records in a form suitable and readily
available for expeditious review (as per 63.10(b)(1)?	63.2183(a)

-------
Page 6 - Brew Ethanol
Yes No NA
~ ~ ~
Has the facility kept all required records for a period not less than five
years following the date of the each occurrence, measurement,	63.2182(b)
maintenance, corrective action, report, or record?
Has the facility kept all required records onsite for a period not less
than two years following the date of the each occurrence, measurement, 2182(c)
| | maintenance, corrective action, report, or record (the records can be
kept off site for the remaining three years)?

-------
Page 1 - Fermenter Exhaust
Compliance Inspection Checklist for Fermenter Exhaust
Yes No NA	Cite
Has the facility been in compliance with the applicable emission
limitations for at least 98% of all batches (sum of batches from last,
|—| |—| |—| second-to-last and third-to-last stages) in each 12-month rolling	63 2150(a)
calculation period (limitations are 100 ppmv for last stage, 200 ppmv
for second-to-last stage, or 300 ppmv for the third-to-last stage,
measured as propane, and averaged over the duration of the batch)?
CH EH CH Has a written malfunction plan been developed and implemented?
63.2150(c)
~ ~ ~
Has initial compliance been demonstrated 12 months after May 21,
2004, as per 63.2161 and 63.2165?
63.2160(b)
~ ~ ~
Is each CEMS installed, operated, and maintained according to the
applicable performance standard in Appendix B to 40 CFR Part 60?
63.2163(a)
~ ~ ~
Has the source conducted a Performance evaluation of each CEMS
according to the requirements of 63.8, according to the applicable
Performance Specification of 40 CFR Part 60, Appendix B, and
63.2163(b)(1) through (4)?
63.2163(b)
EH EH dl Has the CEMS been calibrated with propane?
63.2163(c)

-------
Page 2 - Fermenter Exhaust
Yes No
NA
~ ~
~ ~
~
~
Has the CEMS span been set at not greater than 5 times the relevant
emission limit, with 1.5 to 2.5 times the relevant emission limit being
the range considered optimum by EPA?
Does the source monitor VOC concentration in fermenter exhaust at
any point prior to dilution of the exhaust stream?
63.2163(d)
63.2163(e)
Has each CEMS completed a minimum of one cycle of operation for
EH EH EH each successive 30-minute period within each batch monitoring period?
63.2163(f)
~ ~ ~
Has the CEMS data been reduced to arithmetic batch averages from
two or more data points over each 1-hour period, except during periods
when calibration, quality assurance, or maintenance activities are being
performed?
63.2163(g)
Does the facility have valid CEMS data from at least 75 percent of the	163(h)
D ED CD full hours over the entire batch monitoring period
Have the results of each inspection, calibration, and validation check
~ ~ ~ been recorded?	63-2163M
Has the facility checked the zero and high-level calibration drifts for
ED ED ED each CEMS in accordance with the applicable PS of 40 CFR Part 60,
Appendix B?
~ ~ ~
Have the zero and high-level calibration drifts been adjusted, at a
minimum, whenever the zero drift exceeds 2 times the limits of the
applicable PS?
63.2163(j)

-------
Page 3 - Fermenter Exhaust
Yes No
~ ~
NA
~
Have calibration checks been performed at least once daily except as
provided under 63.2163(j)(l) through (3)?
63.2163(j)
| | | | | | If the CEMS was out of control during this period, did the facility take
corrective action according to paragraphs 63.2163(k)(l) through (3)?
63.2163(k)
Has a Notification of Compliance Status containing the results of the
dl CH CH initial compliance demonstration been submitted according 63.2180?
63.2165
~ ~ ~
Has the facility monitored continuously during each batch monitoring
period (with the exception of monitor malfunctions, associated repairs,
and required quality assurance or control activities (including, as
applicable, calibration checks and required zero and span
adjustments)?
63.2170(b)
~ ~ ~
Has the facility used data recorded during monitoring malfunctions,
associated repairs, and required quality assurance or quality control
activities in data averages and calculations used to report emission or
operating levels, or to fulfill a minimum data availability requirement?
63.2170(c)
Has the facility used data collected during all other periods (i.e., periods
not involving monitoring malfunctions, associated repairs, and required	2170(c)
| | quality assurance or quality control activities) in assessing the
operation of the control system ?

-------
Page 4 - Fermenter Exhaust
Yes No NA
~ ~ ~
Has the facility calculated the percentage of within-concentration
batches for each monthly rolling 12-month period as required in	63.2171(b)
63.2171?
If the facility had periods of malfunction, did they operate in accordance ^„ ,
~ ~ ~ with their malfunction plan?	63.2171(b)
~ ~ ~
Has the facility submitted all of the notifications in 63.7(b) and (c),
63.8(e), (f)(4) and (6), and 63.9(b) through (h) that apply?
63.2180(h)
~ ~ ~
Did the facility submit a notification of the intent to conduct a
performance test at least 60 days before the performance test is
scheduled?
63.2180(d)
Did the facility submit a Notification of Compliance Status according to
~ ~ ~ 63.9(h)(2)(ii) and according to paragraphs (e)(1) and (2) of 63.2180?
63.2180(e)
~ ~ ~
Has the facility submitted a Semi-Annual Compliance Report consistent
with the requirements and timelines specified in Table 5 to Subpart
CCCC and 63.2181?
63.2181(a)
~ ~ ~
If the facility had a malfunction during the reporting period that is not
consistent with the malfunction plan, has the facility submitted an
Immediate Malfunction Report consistent with the requirements and
timelines specified in Table 5 to Subpart CCCC and 63.2181?
63.2181(c)

-------
Page 5 - Fermenter Exhaust
Yes No NA
Does the facility keep records of submitted notifications and reports,
records related to malfunction (as per 63.6(e)(3)(iii) through (v), and	^ 2182(a)
'—' '—' '—' records of performance tests and performance evaluations (as per
63.10(b) (2) (viii)?
For each CEMS, does the facility maintain records as required by
63.10(b)(2)(vi), all required measurements needed to demonstrate
compliance with a relevant standard, records described in
(63.10(b)(2)(viii) through (xi) (the CEMS system must allow the amount
of excess zero and high-level calibration drift measured at the interval
checks to be quantified and recorded), all required CEMS
|—| measurements, identification of each batch during which the CEMS
was inoperative (except for zero and high-level checks), identification of 63.2182(b)
each batch during which the CEMS was out of control (as defined in
63.2163(k), previous versions of the performance evaluation plan,
request for alternatives to relative accuracy test for CEMS (as required
by 63.8(f)(6)(i), and records of each batch for which the batch-average
VOC concentration exceeded the applicable maximum VOC
concentration in Table 1 to Subpart CCCC and whether the batch was
in production during a period of malfunction or during another period?
EH EH dl Does the facility keep the records required in Table 4 to Subpart CCCC? 63.2182(c)
~ ~ ~
Has the facility kept records of unique batch identification number,
fermentation stage for which the fermenter is being used, and unique
CEMS equipment identification number?	63.2182(d)

-------
Page 6 - Fermenter Exhaust
Yes	No	NA
~	~	~
~	~	~
~	~	~
Has the facility kept all required records in a form suitable and readily
available for expeditious review (as per 63.10(b)(1)?	63.2183(a)
Has the facility kept all required records for a period not less than five
years following the date of the each occurrence, measurement,	63.2182(b)
maintenance, corrective action, report, or record?
Has the facility kept all required records onsite for a period not less
than two years following the date of the each occurrence, measurement, 2182(c)
maintenance, corrective action, report, or record (the records can be
kept off site for the remaining three years)?

-------
FEDERAL REGISTER TABLES
As stated in Sec. 63.2140, you must comply with the emission limitations in the following table:
Table 1 to Subpart CCCC.-Emission Limitations
For each fed-batch fermenter producing
yeast in the following fermentation stage....
You must meet the following
emission limitation ....
Last stage (Trade); or Second-to-last stage
(First Generation); or Third-to-last stage (Stock).
a.	For at least 98 percent of all batches
(sum of batches from last, second-to-last,
and third-to-last stages) in each 12-month
calculation period described in Sec.
63.2171(b), the VOC concentration in the
fermenter exhaust does not exceed the
applicable maximum concentration
(100 ppmv for last stage, 200 ppmv for
second-to-last stage, or 300 ppmv
for third-to-last stage), measured
as propane, and averaged over
the duration of a batch.
b.	The emission limitation does not apply
during the production of specialty yeast.

-------
As stated in Sec. 63.2161, if you demonstrate compliance by monitoring brew ethanol,
you must comply with the requirements for performance tests in the following table:
Table 2 to Subpart CCCC.
Requirements for Performance Tests
[Brew Ethanol Monitoring Only]
For each fed-batch fermenter
for which compliance is
determined by monitoring
brew ethanol concentration
and calculating VOC
concentration in the fermenter
exhaust according to the
procedures in Sec. 63.2161, you must..
Using ...
According to the following
requirements:
1.	Measure VOC as propane...
2.	Select the sampling port's
location and the number of
traverse points.
Method 25A*, or an alternative validated by
EPA Method in the 301* and approved by
the Administrator
Method 1*
You must measure the VOC
concentration in the fermenter
exhaust at any point prior to
dilution of the exhaust stream
3. Measure volumetric flow rate
Method 2*

4. Perform gas analysis to determine
the dry molecular weight of the
stack gas.
Method 3*

5. Determine moisture content of the
stack gas.
Method 4*

*EPA Test Methods found in appendix A of 40 CFR part 60.

-------
As stated in sec. 63.2165 (if you monitor fermenter exhaust) and sec. 63.2166 (if you brew ethanol), you must comply
with the requirements to demonstrate initial compliance with the applicable emission limitations in the following table:
Table 3 to Subpart CCCC.
Initial Compliance With Emission Limitations
For...
For the following emission limitation ...
You have demonstrated initial
compliance if...
1. Each fed-batch fermenter pro-
ducing yeast in a fermentation
stage (last Trade), second-to-
last (First Generation), or third-
to-last (Stock) for which comp-
liance is determined by moni-
toring VOC concentration in
the fermenter exhaust
2. Each fed-batch fermenter pro-
ducing yeast in a fermentation
stage (last Trade), second-to-
last (First Generation), or third-
to-last (Stock) for which comp-
liance is determined by moni-
toring brew ethanol concent-
ration and calculating VOC con-
centration in the fermenter ex-
haust according to the proce-
dures in para. 63.2161.
The VOC concentration in the fermenter ex-
haust, averaged over the duration of the
batch, does not exceed the applicable max-
imum concentration (100 ppmv for last stage,
200 ppmv for second-to-last stage, or 300
ppmv forthir-to-last stage), measured as
propane ..
The VOC concentration in the fermenter ex-
haust, averaged over the duration of the
batch, does not exceed the applicable max-
imum concentration (100 ppmv for last stage,
200 ppmv for second-to-last stage, or 300
ppmv forthir-to-last stage), measured as
propane ..
a. You reduce the CEMS data batch
averages according to
para. 63.2163(g)
b. The average VOC concentration in
the fermenter exhaust for at least
98 percent of the batches (sum of
batches from last, second-to-last,
and third-to-last stages) during the
initial compliance period described
in para. 63.2160(a) does not exceed
the applicable maximum concent-
ration.
a. The VOC fermenter exhaust concen-
tration over the period of the Me-
thod 25A* performance test does
not exceed the applicable maximum
concentration.
b. You have a record of the brew-to-
exhaust correlation during the
Method 25A* performance test
during which the VOC fermenter
exhaust concentration did not
exceed the applicable maximum
concentration.
* EPA Test Method in appendix A of 40 CFR part 60.

-------
As stated in Sec. 63.2171, you must comply with the requirements to demonstrate
continuous compliance with the applicable emission limitations in the following table:
Table 4 to Subpart CCCC.
— Continuous Compliance with Emission Limitations
For
For the following emission limitation ...
You must demonstrate continuous compliance
by...
1.	Each fed-batch fermenter pro-
ducing yeast in a fermentation
stage (last Trade), second-to-
last (First Generation), or third-
to-last (Stock) for which comp-
liance is determined by moni-
toring VOC concentration in
the fermenter exhaust
2.	Each fed-batch fermenter pro-
ducing yeast in a fermentation
stage (last Trade), second-to-
last (First Generation), or third-
to-last (Stock) for which comp-
liance is determined by moni-
toring brew ethanol concent-
ration and calculating VOC con-
centration in the fermenter ex-
haust according to the proce-
dures in para. 63.2161.
For at least 98 percent of all batches (sum
of batches from last, second-to-last, and
third-to-last stages) in each 12-month calc-
ulation period described in para. 63.2171(b),
the VOC concentration in the fermenter
exhaust, averaged over the duration of the
batch, does not exceed the applicable max-
imum concentration (100 ppmvfor last
stage, 200 ppmv for second-to-last stage,
or 300 ppmv for third-to-last stage),
measured as propane.
For at least 98 percent of all batches (sum
of batches from last, second-to-last, and
third-to-last stages) in each 12-month calc-
ulation period described in para. 63.2171(b),
the VOC concentration in the fermenter
exhaust, averaged over the duration of the
batch, does not exceed the applicable max-
imum concentration (100 ppmvfor last
stage, 200 ppmv for second-to-last stage,
or 300 ppmv for thir-to-last stage), measur-
ed as propane.
a.	Collecting the monitoring data according to
para. 63.2163(f).
b.	Reducing the data according to para.
63.2163(g).
c.	For at least 98 percent of the batches (sum
of batches from last, second-to-last, and
third-to-last stages) for each 12-month pe-
riod ending within a seminannual reporting
period described in para. 63.2181(b)(3), the
batch average VOC concentration in the
fermenter exhaust does not exceed the
applicable maximum concentration.
a.	Collecting the monitoring data according to
para. 63.2164(b).
b.	Reducing the data according to para.
63.2164(c).
c.	For at least 98 percent of the batches (sum
of batches from last, second-to-last, and
third-to-last stages) for each 12-month pe-
riod ending within a seminannual reporting
period described in para. 63.2181(b)(3), the
batch average VOC concentration in the
fermenter exhaust does not exceed the
applicable maximum concentration.

-------
As stated in Sec. 63.2181, you must submit a compliance report that contains the information in
Sec. 63.2181(c) as well as the information in the following table; you must also submit malfunction
reports according to the requirements in the following table:
Table 5 to Subpart CCCC.
-Requirements for Reports
You must submit a(n)
The report must contain ...
You must submit the report...
1.	Compliance Report...
2.	Immediate malfunction report if
you had a malfunction during
the reporting period that is not
consistent with your malfunction
plan
a.	Your calculated percentage of within-con-
centration batches, as described in
para 63.2171(b), for 12-month calculation
periods ending on each calendar month
that falls within the reported period.
b.	If you had a malfunction during the rep-
orting period and you took actions cons-
istent with your malfunction plan, the
compliance report must include the info-
rmation in para. 63.10(d)(5)(i).
a.	Actions taken for the event...
b.	The information in para. 6.10(d)(5)(ii)...
Semiannually according to the require-
ments in para. 63.2181(b)
Semiannually according to the require-
ments in para. 63.2181(b)
By fax or telephone within 2 working
days after starting actions inconsistent
with the plan
By letter within 7 working days after the
end of the event unless you have made
alternative arrangements with the
permitting authority (para. 63.10(d)(5)(ii)

-------
Page 1 - Table 6
As stated in Sec. 63.2190, you must comply with the applicable
General Provisions requirements according to the following table:
Table 6 to Subpart CCCC.
Applicability of General Provisions to Subpart CCCC
Citation
Subject
Applicable to Subpart CCCC?
Sect. 63.1	
Applicability	
Yes.
Sect. 63.2	
Definitions	
Yes.
Sect. 63.3	
Units and Abbreviations	
Yes.
Sect. 63.4	
Prohibited Activities and Circumvention	
Yes.
Sect. 63.5	
Construction and Reconstruction	
Yes.
Sect. 63.6	
Compliance with Standards and Maintenance
1. For Para. 63.6(e) and (f), require-

Requirements.
ments for startup, shut-down, and


malfunctions apply only to mal-


functions.


2. Para. 63.6(h) does not apply.


3. Otherwise, all apply.
Sect. 63.7	
Performance Testing Requirements	
1. Para. 63.7(a)(1)-(2) and (e)(3) do


not apply, instead specified in this


subpart.


2. Otherwise, all apply.
Sect. 63.8	
Monitoring Requirements	
1. Para. 63.8(a)(2) is modified by


Para 63.2163


2. Para. 63.8(a)(4) does not apply.


3. For Para. 63.8(c)(1), requirements for


startup, shutdown, and malfunctions


apply only to malfunctions, and no


report pursuant to Para. 63.10(d)(5)(i)


is required.

-------
Page 2 - Table 6
Citation
Subject
Applicable to Subpart CCCC?


4. For Para. 63.8(d), requirements for


startup, shutdown, and malfunctions


apply only to malfunctions.


5. Para. 63.8(c)(4)(i), (c)(5), (e)(5)(ii), and


(g)(5) do not apply.


6. Para. 63.8(c)(4)(ii), (c)(6)-(8), (e)(4), and


(g)(1)-(4), do not apply, instead


specified in this subpart.


7. Otherwise, all apply.
Sect. 63.9	
Notification Requirements	
1. Para. 63.9(b)(2) does not apply,


because rule omits requirements for


initial notification for sources that


start up prior to May 21, 2001.


2. Para. 63.9(f) does not apply.


3. Otherwise, all apply.
Sect. 63.10	
Recordkeeping and Reporting Requirements ..
1. For Para. 63.10(b)(2)(i)-(v), (c)(9)-(15),


and (d)(5), requirements for startup,


shutdown, and malfunctions apply


only to malfunctions.


2. Para. 63.10(b)(2)(i), and (c)(1)-(6),


do not apply, instead specified in this


subpart.


3. Para. 63.10(c)(7)-(8), (d)(3), (e)(2)(ii)-


(4), (e)(3)-(4) do not apply.


4. Otherwise, all apply.
Sect. 63.11	
Flares	
No.
Sect. 63.12	
Delegations	
Yes.
Sect. 63.13	
Addresses	
Yes.
Sect. 63.14	
Incorporation by Reference	
Yes.
Sect. 63.15	
Availability of Information	
Yes.

-------