From: Casey F Bradford [mailto:cbradford@jonesday.com] 

Sent: Friday, March 27, 2015 11:16 AM

To: Brandon Long

Cc: Ndoh.Tina@epa.gov; Jason Renzaglia; RSmith@potashcorp.com; SMJordan@potashcorp.com

Subject: Fw: Phosphates Comment Follow-up - Oxidation Reactors

Brandon,

PCS Phosphate Company, Inc. (PCS) provides the following information in response to your 

questions about the facility in Aurora. This response was prepared by PCS. I am sending it on the 

company's behalf due to folks' travel schedule and other commitments. Please let me know if you have 

further questions or need additional information about the cost estimates or equipment in Aurora. 

Question 1: In footnote 146 (provided below), PCS commented that it would cost approximately 

$500,000 to install equipment at PCS Aurora for oxidation reactors, clarifiers, and evaporator hotwells (perhaps 

you meant defluorination units instead of hot wells). However, no details about how this cost was estimated 

were provided. For your agitated tanks (specifically those tanks that operate an oxidation step in the SPA 

process at Aurora), what portion of the $500,000 is applicable and can you please explain what equipment 

would be necessary to control emissions? For example, would PCS Aurora need to install additional ductwork to 

exhaust oxidation reactor emissions to an existing wet scrubber?

Response: The estimate of $500,000 in footnote 146 of the PCS comments was a preliminary 

estimate that was developed during the comment period on the proposed rule. Upon further review, we 

have determined that the actual costs in Aurora would total at least $667,000. The Proposed Rule is 

unclear about what equipment would qualify as clarifiers, defluorination units, and oxidation reactors. 

Based on the information currently available, PCS estimates that Aurora would need to incur the 

following costs (totalling $667,000) to comply with EPA's proposed changes to process line definitions:

• $396,500 to Allow MACT Testing of Existing "Clarifier" Scrubbers: PCS estimated the cost to 

allow MACT emissions testing and continuous parameter monitoring of four (4) existing venturi 

type wet scrubbers associated with filter product / evaporator feed tanks and evaporator product 

tanks at the wet process phosphoric acid (WPPA) line. There is no definition of "clarifier" in the 

proposed rule, and PCS is not sure whether EPA intends to cover these tanks. We are including 

the costs to allow for MACT testing and monitoring of the associated scrubbers because the 

tanks could potentially be deemed clarifiers, based on a general understanding of that term. The 

tanks in question receive product that has already been filtered by the WPPA process line filters 

but still contains a small amount of suspended solids. As the product cools in the tanks, 

dissolved solids precipitate and settle to the bottom where they are raked to a center discharge 

and removed from the product. The filter product from the tanks serves as either feed to the 

evaporators or as raw material in downstream processes. If EPA intends for these tanks to be 

covered, PCS would need to install various modifications to allow for testing and monitoring 

consistent with MACT standards (e.g. install platforms and stack test ports, ensure adequate 

unobstructed lengths of stack before and after stack test ports, install permanent differential 

pressure measurement, permanent data recording, etc.). We estimate the cost of these 

modifications would be at least $396,500. This assumes the existing scrubbers are able to 

assure compliance with the MACT standards. We have not yet been able to determine the 

impacts of including the tank emissions in the facility's MACT emissions testing. As discussed on 

pages 60-61 of PCS' written comments, we are concerned that subjecting new equipment to 

regulation brings the validity of the MACT floor into question.

• $270,500 for Control of Oxidation Tanks & Associated Storage Tank -- PCS estimated the cost to 

install one (1) new venturi type wet scrubber to treat the two oxidation tanks and an associated 

large storage tank at the super-phosphoric acid (SPA) line in Aurora. These tanks currently do 

not have any form of emissions control device. We have included the storage tank because there 
is a possibility that residual oxidation happens in that tank. The cost of a new scrubber was 

estimated due to logistical complications and concerns about inadequate excess capacity of 

existing scrubbers at other SPA units. The estimate of $270,500 was determined by applying an 

inflation factor to the cost of a packaged scrubber system that was purchased for analogous 

equipment in Aurora in 2008. Additional modifications to bring the scrubber up to MACT 

standards were also included, along with the cost of necessary ductwork. The specific equipment 

included in our cost estimate for emission control of the oxidation reaction is shown in the list 

attached to this email. 

Please note that the cost estimate of $667,000 does not include the annual cost of testing the new 

emission points. Nor does it include any amount for constructing or operating a system to treat the 

effluent from the new scrubber (because the new scrubber's effluent would not be directed to any cooling 

tower). PCS also did not include any costs of MACT compliance for finished product storage tanks that 

are located a significant distance away from the WPPA manufacturing process in Aurora. Although some 

residual settling of solids may occur in these finished product tanks, PCS does not consider them to be 

part of the affected facility because they are used only for storage of finished product and not as part of 

the WPPA manufacturing process. These storage tanks are discussed on page 59 of the PCS comments 

("Other pieces of equipment that could theoretically be characterized as 'clarifiers' are associated with 

product storage rather than manufacturing."). If EPA intends for the finished product tanks to be included 

as "clarifiers" under the proposed rule, the costs of compliance would be even greater than estimated 

above. 

Question 2. Are potassium permanganate, nitric acid, or ammonium nitrate used in the oxidation step 

carried out in agitated tanks?

Response: Potassium permanganate is used in the oxidation reaction at Aurora SPA.

Casey Fernung Bradford (bio)

Associate

JONES DAY® - One Firm WorldwideSM

1420 Peachtree Street, N.E.

Suite 800

Atlanta, GA 30309

Office +1.404.581.8119

cbradford@jonesday.com

Brandon Long --- Phosphates Comment Follow-up - Oxidation Reactors ---

From: "Brandon Long" <Brandon.Long@erg.com>

To: smjordan@potashcorp.com, rsmith@pcsphosphate.com

Cc: "Jason Renzaglia" <Jason.Renzaglia@erg.com>, "Ndoh, Tina" <Ndoh.Tina@epa.gov>

Date: Wed, Mar 11, 2015 12:07 PM

Subject: Phosphates Comment Follow-up - Oxidation Reactors
Hi Ross and Susan,

I am a contractor assisting EPA with the rules for Phosphoric Acid Manufacturing Plants (40 CFR part 63, subpart 

AA) and Phosphate Fertilizers Production Plants (40 CFR part 63, subpart BB). We have questions regarding certain 

comments that PCS provided on the proposed rule about oxidation reactors at the Aurora plant. If you would 

please respond to these questions we would appreciate it. We can also discuss these items during the industry 

meetings with EPA on Thursday, if necessary.

1. In footnote 146 (provided below), PCS commented that it would cost approximately $500,000 to install 

equipment at PCS Aurora for oxidation reactors, clarifiers, and evaporator hotwells (perhaps you meant 

defluorination units instead of hot wells). However, no details about how this cost was estimated were provided. 

For your agitated tanks (specifically those tanks that operate an oxidation step in the SPA process at Aurora), what 

portion of the $500,000 is applicable and can you please explain what equipment would be necessary to control 

emissions? For example, would PCS Aurora need to install additional ductwork to exhaust oxidation reactor 

emissions to an existing wet scrubber?

2. Are potassium permanganate, nitric acid, or ammonium nitrate used in the oxidation step carried out in 

agitated tanks?

Footnote 146: At the PCS Phosphate Aurora facility, for example, it is projected that two new emission control 

devices may have to be installed on evaporator hotwells and oxidation reactors in addition to bringing clarifier 

emission controls up to NESHAP standards. The cost for this work is projected to be approximately $500,000, but 

this cost does not include the additional annual cost for testing up to eight new emission points. 

Thank you for your time,

Brandon

Brandon Long

Chemical Engineer 

Eastern Research Group, Inc (ERG)

Morrisville, NC | 919-468-7886

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PCS Phosphate, Aurora SPA:

Equipment Included in Cost Estimate 

for Oxidation Reactors Under EPA Proposed Rule

Ducts from each oxidation tank to the venturi 

Duct from the storage tank to the venturi 

Recirculation line from the discharge of the recirculation pump to the venturi 

Recirculation pump and motor along with associated starter and drive 

Separation Tank 

Make-up water piping to the separation tank 

Overflow line returning to Cooling Pond 

Stack with stack test openings and monorails 

Stack test platforms 

Differential pressure monitoring device with connectivity back to area control room 

Motor status monitoring with connectivity back to area control room 

Recirculation flow rate monitoring device with connectivity back to area control room 

Make up water flow rate monitoring device with connectivity back to area control room