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ECOENGINEERS People Driven Solutions 300 E. Locust, Ste 313 Des Moines, Iowa 50309 Phone: 515-985-1260 www.ecoengineers.us November 11, 2016 Joseph P. Riley Corn Oil One 4400 E University Ave Pleasant Hill, IA 50327 RE: REVIEW OF CORN OIL ONE FEEDSTOCK FOR CONFORMANCE TO THE DEFINITION OF "NON-FOOD GRADE CORN OIL" UNDER 40 CFR 80 SUBPART M 1.0 PURPOSE The purpose of this regulatory analysis is to determine whether EcoEngineers considers the Corn Oil One feedstock to classify under the EPA definition of "non-food grade corn oil" and is eligible as a feedstock for biodiesel and renewable diesel production under the Renewable Fuel Standard (RFS) 40 CFR 80 Subpart M. Furthermore, this analysis will determine whether EcoEngineers considers this feedstock to be a "biointermediate" under the proposed "REGS" rulemaking and biofuel gallons produced from the feedstock eligible to be validated under the EcoEngineers EPA Approved Q-RIN Quality Assurance Program. Please note that this determination from EcoEngineers is not a substitute for a determination from the EPA and does not provide Corn Oil One nor any biofuel producer who processes Corn Oil One feedstock any indemnification under the Renewable Fuel Standard, 40 CFR 80 Subpart M. 2.0 RFS REGULATORY FRAMEWORK USEPA Definition of Corn Oil: According to the EPA determination letter addressed to the Corn Refiners Association, dated October 24, 2013: "In the context of the Renewable Fuel Standard (RFS) and Table 1 to 80.1426, non-food grade corn oil refers to corn oil produced at a dry mill corn ethanol plants by extraction from the Distiller Grains (DG) co-product... only biodiesel and renewable diesel from corn oil that was produced by the extraction process at dry mill corn ethanol plants would be eligible to generate RINs under the existing non-food grade corn oil pathways in Table 1 to 80.1426. The existing pathway does not apply to corn oil derived by fractionation at a dry mill corn ethanol plant or corn oil derived from corn wet milling." USEPA Definition of a Biointermediate Feedstock: According to the preamble of the proposed rulemaking, "Renewables Enhancement and Growth Support Rule" (REGS), pre-published on October 3, 2016, "the definition of a "biointermediate feedstock" is any renewable fuel feedstock material that meets all of the following criteria: It is derived from renewable biomass 1 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00001 ECOENGINEERS People Driven Solutions 300 E. Locust, Ste 313 Des Moines, Iowa 50309 Phone: 515-985-1260 www.ecoengineers.us It does not meet the definition of renewable fuel and RINs were not generatedfor it It is produced at a facility that is registered with the EPA, but which is different than the facility at which it is used to produce renewable fuel It is made from the feedstock and will be used to produce the renewable fuel in accordance with the processes listed in the approved pathway It is processed in such a way that it is substantially altered from the feedstock listed in the approved pathway In addition, we are proposing that any feedstock listed in Table 1 to 40 CFR 80.1426 or in an approved pathway pursuant to 80 CFR 80.1416 is not a biointermediate, and that a mere form change to renewable biomass does not create a biointermediate ... In addition, certain processing of feedstocks would not result in sufficient alteration to result in a biointermediate ... We are proposing that renewable biomass subject to these types of processing (chopping, filtering, degumming vegetable oils, drying, adding water) would be excluded from the definition of biointermediate and, therefore, that such activities can be conducted at a different facility than the facility producing renewable fuel without triggering the need for the additional recordkeeping, reporting, and registration reguirements being proposed for producers of biointermediates." 3.0 CORN OIL ONE FEEDSTOCK ANALYSIS Description of Corn Oil One Feedstock: Non-Food Grade Corn oil is produced at the Southwest Iowa Renewable Energy (SIRE) Dry-Mill Ethanol Plant (or other dry-mill ethanol plants). The corn oil enters the co-located Corn Oil One facility where a dilute solvent (composed of ethanol and water) is added in order to solubilize soaps out of the corn oil. The final Corn Oil One feedstock is corn oil which has had Free Fatty Acids (FFAs), moisture and waxes removed. Laboratory Analysis from Iowa Central Fuel Testing Labs (ICFTL): Two (2) samples of crude corn oil and two (2) samples of Corn Oil One feedstock were submitted to Iowa Central Fuel Testing Laboratory for feedstock forensic analysis testing by gas chromatograph on November 7, 2016. ICFTL is an ISO-9001:2008 accredited laboratory and has analyzed over 100 feedstock samples by gas chromatograph under the EcoEngineers Q-RIN Quality Assurance Program. Tables 1 and 2 summarize the results of the laboratory analysis. Table 1: Summary of Crude Corn Oil Samples: 84683, 87846 Component % Sample 84683 % Sample 87846 Triglycerides 76.42 70.41 Diglycerides 5.49 5.64 Glycerol .04 .04 Methyl Esters 0 0 Ethyl Esters 2.14 3.39 Fatty Acids 14.59 18.57 Monoglycerides 0.17 .22 Squalene .09 .14 2 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00002 ECOENGINEERS People Driven Solutions 300 E. Locust, Ste 313 Des Moines, Iowa 50309 Phone: 515-985-1260 www.ecoengineers.us Tocopherol Sterols Other .08 .11 .86 1.21 .13 .28 Table 2: Summary of Corn Oil One samples: 85050, 88612 Component % Sample 85050 % Sample 88612 Triglycerides 89.27 89.12 Diglycerides 5.3 6.31 Glycerol 0 0 Methyl Esters 0 0 Ethyl Esters 3.72 3.02 Fatty Acids .41 .35 Monoglycerides .08 .1 Squalene .12 .08 Tocopherol .08 .08 Sterols .87 .81 Other .14 .12 ICFTL confirmed that the both the crude corn oil samples and the Corn Oil One samples contained the presence of squalene and ethyl esters, which is consistent with a corn oil feedstock profile. Furthermore, the presence of squalene and ethyl esters did not significantly change between the crude corn oil and Corn Oil One samples. The only significant change in composition between the crude corn oil samples and the Corn Oil One feedstock was noted in Fatty Acid content, which decreased from (15%-19%) to (0.4%) and Triglycerides, which increased from (70%-76%) to (89%). 4.0 Determination and Conclusion Does the Corn Oil One feedstock meet the definition of Non-Food Grade Corn Oil? The crude corn oil produced at the SIRE dry-mill ethanol plant is extracted from the distiller grains co-product. This has been confirmed by the Third-Party Engineering Review and site visit conducted on November 5, 2015 by Jim Ramm, PE. Corn Oil One must continue to utilize crude corn oil produced at dry-mill ethanol plants via extraction from distiller grains co-product in order to produce a qualifying Corn Oil One feedstock. Jim Ramm, PE reviewed the laboratory results from the Iowa Central Fuel Testing Laboratory and concluded that the decrease in Fatty Acid content and increase in Triglyceride content between the crude corn oil and Corn Oil One feedstock does not constitute a substantial alteration of the corn oil feedstock. Furthermore, the unchanged presence of key corn oil indicators (squalene and ethyl esters) between the crude corn oil and Corn Oil One feedstock suggest no substantial alteration between crude corn oil and Corn Oil One feedstock. Sierra Club v. EPA 18cv3472 NDCA 3 Tier 1 ED 002061 00069499-00003 ECOENGINEERS People Driven Solutions 300 E. Locust, Ste 313 Des Moines, Iowa 50309 Phone: 515-985-1260 www.ecoengineers.us Does the Corn Oil One feedstock meet the proposed definition as a "biointermediate"? The definition of "bio-intermediate" has not been finalized by the EPA, and we cannot state conclusively how Corn Oil One feedstock will ultimately be treated in the final rulemaking. However, EcoEngineers believes that the type of processing that occurs for Corn Oil One feedstock does not constitute a substantial alteration from the definition of Non-food grade corn oil in Table 1 of 80.1426. As a result of this analysis, EcoEngineers considers the Corn Oil One feedstock to meet the USEPA definition of "non-food grade corn oil" and is an eligible feedstock to produce biodiesel and renewable diesel under the Renewable Fuel Standard 40 CFR 80 Subpart M. EcoEngineers will include Corn Oil One feedstock as part of the list of "approved feedstock suppliers" under the EcoEngineers EPA-approved Q-RIN Quality Assurance Program from the date of this letter moving forward until further notice. Regards, Karyn Jones COO EcoEngineers kjones@ecoengineers.us Enel: 10/24/2013 EPA Letter of Determination to the Corn Refiners Association IA Central Fuel Testing Laboratory Corn Oil Analysis Sierra Club v. EPA 18cv3472 NDCA 4 Tier 1 ED 002061 00069499-00004 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OCT 2. 4 2013 OfftCE OF AiR AND RADIATION Mr, John W. Bode President and C.E.O, Com Refiners Association 1701 Pennsylvania Avenue, NW Suite 950 Washington, D.C. 20006-5806 Dear Mr. Bode: Thank you for the letter from your organization dated November 29, 2012, we apologize for the delay in responding. That letter requested clarification of the type or grade of com oil that is approved as eligible feedstock for biodiesel and renewable diesel production under 40 G.F.R. 80.1426, Table 1. The biodiesel and renewable diesel pathways in Table 1 to 80.1426 refer to "non-food grade com oil", and the letter from your organization requested a clarification of what is included in the category non-food grade com oil. In the context of the Renewable Fuel Standard (RFS) and Table 1 to 80.1426, non-food grade com oil refers to com oil produced at dry mill com ethanol plants by extraction from the Distiller Grains (DG) co-product. As discussed in the final rale published on March 26, 2010 (75 FR 14670) (the "March 2010 RFS rule"), dry mill com ethanol plants have two different technological methods to withdraw com oil during the ethanol production process. The fractionation process withdraws com oil before the production of the DG co-product The extraction process withdraws com oil after the production of the DG coproduct. In contrast to com dry mill plants, com wet mill facilities separate the kerne! prior to processing into its component parts (germ, fiber, protein, and starch) and in turn produce other co-products (including com oil) in addition to DG. Only biodiesel and renewable diesel from com oil that was produced by the extraction process at dry mill com ethanol plants would be eligible to generate RINs under the existing non-food grade corn oil pathways in Table 1 to 80,1426. The existing pathway does not apply to com oil derived by fractionation at a dry mill com ethanol plant or com oil derived from com wet milling. Although the regulations do not define non-food grade com oil as that term is used in 80.1401, we believe that the U.S. Environmental Protection Agency's March 2010 RFS rale clearly describes the type o f production process that the EPA intended to include in the non-food grade com oil pathway in Table 1 to 80,1426. * Pfin&d wtsh VVvNTNTvI-OV QW iok:* on 1<X)% P ogtcyistsror. P iyu'T yy O N o tto Fre* Page I 1 Gyyytt Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00005 In response to some of the additional points raised in the letter, the Preamble to the March 2010 RFS rale discusses the updated FASOM and FAPRI-CARD modeling that the EPA conducted for this pathway, indicating that we "model[ed] com oil from the dry mill ethanol extraction process as a new source of biodiesel." The EPA also indicates that "it is estimated that 70% of dry mill ethanol plants will withdraw com oil via extraction (from DG5), resulting in com oil that is non-food grade and can only be used as a biodiesel source; 20% will withdraw com oil via fractionation (prior to the creation of DGS), resulting in com oil that is food-grade". This specifically indicates that the EPA considered com oil from the extraction process as non-food grade for purposes of the pathway for biodiesel production and that we considered oil produced from the fractionation process as food grade com oil. When analyzing the feedstock production GHG impacts of non-food grade com oil we considered both the direct and indirect impacts. As with other feedstocks analyzed as part of the March 2010 RFS rale this was done with our FASOM and FAPRI-CARD models. The documentation to the FASOM model1indicates that the model includes "the potential for com oil to be derived from either extraction from DG or fractionation prior to the creation of DG. Com oil from fractionation is assumed to be food grade and a perfect substitute for com oil produced from the wet milling process. Com oil from extraction, however, is nonfood grade and can only be used in biodiesel production in the model," The FASOM documentation also indicates that the model was modified "to apply different replacement rates for ffactionated/extracted DG and traditional DG when used in swine and poultry feed." Therefore, the indirect GHG impacts of non-food grade com oil in our analysis was based on the market impacts that com oil from the dry mill com ethanol extraction process has on the DG market. This was based on the different quality of the DG with the oil removed. Com oil from the dry mill com ethanol fractionation process and com oil from com wet milling are modeled as perfect substitutes and used in the vegetable oil food market and would therefore have different market impacts when used for biodiesel as compared to extracted non-food grade com oil and different indirect GHG impacts as well. The EPA drew the same distinction when discussing the non-food grade com oil pathway in the Preamble to the March 2010 RFS rule. For example, the EPA discusses com ethanol dry mill plants and indicates "there are a growing number of plants using front-end fractionation to produce food-grade com oil or back-end extraction to produce fuel-grade com oil for the biodiesel industry."2 The EPA drew the distinction between food-grade com oil produced from fractionation and fuel-grade com oil used to make biodiesel produced from extraction. The Preamble also discusses wet mill com plants and indicates that they "produce other co-products (usually gluten feed, gluten meal, and food-grade com oil)".3 Again, for purposes of this pathway the EPA drew the distinction that wet mill com plants were considered a source of food grade com oil, not non-food grade com oil. 1U.S. Agricultural and Forestry Impacts of the Energy Independence and Security Act: FASOM Results and Model Description Final Report, EPA-BQ-OAR-2005-0161-3178, page 1-23, 175 FR at 14744, 3 id. Page 1 2 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00006 Also, in the context of discussing a number of potential biodiesel and renewable diesel feedstocks in the March 2010 RFS rale, the volumes of diesel feedstocks from com oil that were assumed in the analysis were based on non-food grade com oil from extraction as the diesel feedstock. The Regulatory Impact Analysis (RIA) of the March 2010 RFS rule states that "approximately 70 percent of projected total ethanol production will implement some type of com oil extraction system by 2022, generating approximately 680 million gallons per year of com oil biofuel feedstock"/ This amount of com oil matches the indication in the Preamble of non-food grade com oil from com dry milling extraction. Table LI-25 of the RIA lists 680 million gallons of biodiesel produced from "Com oil from ethanol production" as used in the analysis for the rulemaking.5 Therefore, the non-food grade com oil used in our modeling of biodiesel feedstock for the March 2010 RFS rule was solely from dry mill com ethanol extraction. The letter mentions that your organization plans to submit a petition requesting the approval of a fuller range of com oils. The differences in modeling discussed in this response should help in developing a petition in order for the EPA to consider biodiesel or renewable diesel produced from the dry mill com ethanol fractionation process or from com wet milling. The petition process under 80.1416 of our regulations describe what type of information is required for submitting a petition to the agency, and additional guidance is available on our website (frttp://www.epa.gov/otaQ/fuels/renewablefue1s/new-pathways/lca-petition-instmetions.htni) . Sincerely, Karl Simon, Director Transportation and Climate Division 4Ses p, 55 of the RIA at http://www.epa.gov/otaq/renewablefuels/420rl000S.pdf. 5Id. at p. 64. Page I 3 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00007 Iowa Central Fuel Testing Laboratory Four Triton Circle Fort Dodge, Iowa, USA 50501 Laboratory Results Report Customer Name: Customer Address: Customer's Sample ID: Sample Type: EcoEngineers 300 East Locust Street, Suite 313 Des Moines, IA 50309 COO 84683 Crude Corn Oil Test Method j Feedstock Forensic Analysis j See attached summary and chromatograms Result Sample ID: Customer ID: I Received on: Completed: f 110116S EcoEngineers 11/1/2016 ~ 11/7/2016 Unit Notes: Approval: Printed copies are uncontrolled Sierra Club v. EPA 18cv3472 NDCA --- Title: QMR or designee Date: November 7, 2016 REC 7.1,5 V-1.0 Effective 9-14-2011 Tier 1 ED 002061 00069499-00008 110116S COO 84683 Crude Corn Oil ICFTL received a sample of corn oil feedstock. We analyzed the sample by gas chromatography (maximum oven temperature of 380C) and also by GC/MS (maximum oven temperature of 355C). Analysis by gas chromatography shows that the majority of the sample is in the form of triglycerides (76.42 %). The GC/MS overview sheet shows a small amount of glycerin. The first close-up view shows mainly C16 and C18 fatty acids and ethyl esters, whereas the second close-up view shows several monoglycerides, tocopherols and sterols. Squalene is also noted. The presence of squalene and ethyl esters is consistent with a crude corn oil feedstock. The percent content (by peak area) for each of the major components is listed below. COMPONENT Triglycerides Diglycerides Glycerol Methyl Esters Ethyl Esters Fatty Acids Monoglycerides Squalene Tocopherol Sterols Other PERCENT OF SAMPLE 76.42 5.49 0.04 0 2.14 14.59 0.17 0.09 0.08 0.86 0.13 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00009 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00010  33.47 28.47 23 47 18.47 13.47 8.47 3.47 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00011 ED 002061 00069499-00012 Tier 1 Sierra Club v. EPA 18cv3472 NDCA 19.67...........20.17............20.67 21.17 2167 22,17 22.67 23,17 23.67 24,17 24.67 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED_002061^00069499-00013 Iowa Central Fuel Testing Laboratory Four Triton Circle Fort Dodge, Iowa, USA 50501 Laboratory Results Report Io w a C e n tra l ns o ot Customer Name: Customer Address: Customer's Sample ID: Sample Type: EcoEngineers 300 East Locust Street, Suite 313 Des Moines, IA 50309 COO 87846 Crude Corn Oil Sample ID: Customer ID: Received on: Completed: 110116U EcoEngineers 11/1/2016 11/7/2016 Test Method Result Unit Feedstock Forensic Analysis See attached summary and chromatograms Notes: Approval: .. Printed copies are uncontrolled Sierra Club v. EPA 18cv3472 NDCA Title: QMR or designee Date: November 7, 2016 REC 7.1.5 v-l.O Effective 9-14-2011 Tier 1 ED 002061 00069499-00014 110116U COO 87846 Crude Corn Oil ICFTL received a sample of crude corn oil feedstock. We analyzed the sample by gas chromatography (maximum oven temperature of 38QC) and also by GC/MS (maximum oven temperature of 355C). Analysis by gas chromatography shows that the majority of the sample is in the form of triglycerides (70.41 %). The GC/MS sheet shows a small glycerin peak. The first close-up view shows mainly C16 and C18 fatty acids and ethyl esters, whereas the second close-up view shows several monoglycerides, tocopherols and sterols. Squalene is also noted. The presence of squalene and ethyl esters is consistent with a corn oil feedstock. The percent content (by peak area) for each of the major components is listed below. COMPONENT Triglycerides Diglycerides Glycerol Methyl Esters Ethyl Esters Fatty Acids Monoglycerides Squalene Tocopherol Sterols Other I PERCENT OF SAMPLE 70.41 5.64 0.04 0 3.39 18.57 0.22 0.14 0.11 1.21 0.28 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00015 i thforrhi1gr.ims |11f)116U 11_JM _?01 003 raw] Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00016 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00017 3.3 6 8.3 6 13.36 18.36 23.36 28.36 33.36 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00018 35.21 34.21 33.21 32.21 OO".t iLcU. SH-- O"t OS cm 12 C0O5 + Vs* O r- il s); v K --U COD CuOd ClOM i> CM / ON ~yf ^ j $ CCOO SD ?-`3 i;/ " f CCMO 80 CO COD CO ioad CM 3 N CM 31.21 30.21 29.21 28.21 27.21 26.21 25.21 3 CD OO O ^ T Sierra Club v. EPA 18cv3472 NDCA Tier 1 O ED 002061 00069499-00019 Iowa Central Fuel Testing Laboratory Four Triton Circle Fort Dodge, Iowa, USA 50501 Laboratory Results Report I o w a (Central Custom er Name: Customer Address: Customer's Sample ID: Sample Type: EcoEngineers 300 East Locust Street, Suite 313 Des Moines, IA 50309 COO 85050 COl refined corn oil Sample ID: j Customer ID: j__ Received on: Completed: 110116T EcoEngineers 11/1/2016 11/7/2016 Test Method Result Unit 1 Feedstock Forensic Analysis j See attached summary and chromatograms Notes: Approval: Printed copies are uncontrolied Sierra Club v. EPA 18cv3472 NDCA Title: QMR or designee Date; November 7, 2016 REC 7,1.5 V-1. Effective 9-14-2011 Tier 1 ED_002061 00069499-00020 110116T COO 85050 CO l Refined Corn Oil ICFTL received a sample of corn oil feedstock. We analyzed the sample by gas chromatography (maximum oven temperature of 380C) and also by GC/MS (maximum oven temperature of 355C). Analysis by gas chromatography shows that the majority of the sample is in the form of triglycerides (89.27 %). Glycerin was not detected in this sample. The first close-up view shows mainly C16 and C18 fatty acids and ethyl esters, whereas the second close-up view shows several monoglycerides, tocopherols and sterols. Squalene is also noted. The presence of squalene and ethyl esters is consistent with a corn oil feedstock. The percent content (by peak area) for each of the major components is listed below. COMPONENT Triglycerides Diglycerides Glycerol Methyl Esters Ethyl Esters Fatty Acids Monoglycerides Squalene Tocopherol Sterols Other PERCENT OF SAMPLE 89.27 5.30 0 0 3,72 0.41 0.08 0.12 0.08 0.87 0.14 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00021 33000-661769000 1-90300 <33 l Jail VOQN 3/l7A08l. Vd3 a qn|o BJJ0|S Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00023 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00024 Sierra Club v. EPA 18cv3472 NDCA 1101161 103 %- 9 01-Nov-2016 + 14:04:20 Scan EI+ 34.98 TIC .G O Tier 1 ED 002061 00069499-00025 0 ---------- :---- -- -...................:-.......- --------------- ------ 25.12 26.12 27.12 28.12 29.12 ---- rTM-- 30.12 ............... 31.12 .... 32.12 ......; ....-.......... -................... Tid e 33.12 34.12 35.12 Iowa Central Fuel Testing Laboratory Four Triton Circle Fort Dodge, Iowa, USA 50501 Laboratory Results Report Io w a C e n t r a l Customer Name: Customer Address: Customer's Sample ID: Sample Type: EcoEngineers 300 East Locust Street, Suite 313 Des Moines, IA 50309 COO 88612 COl refined corn oil Sample ID: Customer ID: Received on: Completed: 110116V EcoEngineers 11/1/2016 11/7/2016 Test Method I Feedstock Forensic Analysis | See attached summary and chromatograms Result Unit Notes: I f Approval: _/ * * * * .......................... - Printed copies are uncontrolled Title: QMR or designee Date: November 7, 2016 REC 7.2.5 v-1.0 Effective 9-14-2011 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00026 110116V COO 88612 CO l Refined Corn Oil iCFTL received a sample of crude corn oil feedstock. We analyzed the sample by gas chromatography (maximum oven temperature of 380C) and also by GC/MS (maximum oven temperature of 355C). Analysis by gas chromatography shows that the majority of the sample is in the form of triglycerides (89.12 %). Glycerin was not detected in this sample. The first close-up view shows mainly C16 and C18 fatty acids and ethyl esters, whereas the second close-up view shows several monoglycerides, tocopherols and sterols. Squalene is also noted. The presence of squalene and ethyl esters is consistent with a corn oil feedstock. The percent content (by peak area) for each of the major components is listed below. COMPONENT Triglycerides Diglycerides Glycerol Methyl Esters Ethyl Esters Fatty Acids Monoglycerides Squalene Tocopherol Sterols Other PERCENT OF SAMPLE 89.12 6.31 0 0 3.02 0.35 0.10 0.08 0.08 0.81 0.12 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00027 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00069499-00028 eco Sierra Club v. EPA 18cv3472 NDCA Tier 1 %:" 4.06 3.87 ! ED_002061_00069499-00029 3.51 8.51 13.51 ? 11 o i l L 1 / I 9 X TIC 9.34e9 21.48 22.24 23.51 30.49 28.51 34.25I ^ __ 33.51 Sierra Club v. EPA 18cv3472 NDCA e> 110116V 100 s Tier 1 ED 002061 00069499-00030 0 1----------------------- -- ----- :............. =................r-------'-----<--------- , 19,80............M M 20.80 21.30 21.80 22.30 23.39 , 01-Nov-2016 +16:03:21 Sean E1+ 5.85e9 "T Ji o v C? 9 t / z Vi v.. Vi X V \l 23,49 O 24.09 22.80 23.30 23.80 Tme 24 80 ED 002061 00069499-00031 Tier 1 Sierra Club v. EPA 18cv3472 NDCA 24.88.......... 25.88...........26.88.. 27.88 28.88 29.88 30.88 31.88 32.88 33.88 34 88