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 commitment s. 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 instal l 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. Up on 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 cur rently 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 adequa te 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 sc rubbers 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 conce rned 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 thereis a possibility that resi dual 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

i nflation 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

emis sion 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 co mpliance 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

p art 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 theoreticall y 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 e stimated

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.

Ca sey Fernung Bradford (bio)

Associate
JONES DAY®

- One Firm Worldwide SM 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, Tin a" < Ndoh.Tina@epa.gov >

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

Subject: Phosphates Comment Follow

- up

- Oxidation ReactorsHi 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 approximatel y $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 t o 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 Ph osphate 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 tan k

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