STATE OF MISSISSIPPI 

HALEY BARBOUR 

GOVERNOR 

MlssISSIPPI DEPARTMENT OF ENVIRONMENTAL QUM 

TRUDY D. FISHER, EXECUTIVE DIRECTOR 

May 9,20 1 1 

Ms. Gwendolyn Keyes Fleming 

Regional Administrator 

U. S. Environmental Protection Agency 

6 1 Forsyth Street 

Atlanta, Georgia 30303-8960 

Dear Ms. Fleming: 

Re: State Implementation Plan (SIP) Revision 

Enclosed is the State Implementation Plan (SIP) Supplemental Information Document concerning federal 

regional haze requirements. The original SIP revision document was submitted September 22,2008. We 

are transmitting, under separate cover, additional copies to Dick Schutt of your agency. 

We certify that this SIP revision has been completed in accordance with the Mississippi Administrative 

Procedures Act and the Mississippi Pollution Control Law. We further certify that this information went to 

public notice. The only comments received were from the U.S. Fish and Wildlife Service. A copy of these 

comments and our response is included. 

We feel that this completes our SIP addressing Regional Haze. We understand that the CAIR rule is being 

replaced with the Transport Rule and that Mississippi is not subject to the Annual NOx or SO2 provisions in 

the proposed Transport Rule. Several Electric Generating Units in Mississippi relied upon the provisions in 

the CAIR to meet the BART requirements in the rule and their BART determinations may have to be 

reevaluated when the Transport Rule is final. We have notified the subject facilities of this and are currently 

working with them to set a timeline for submittal of the screening modeling and the engineering analysis 

required by the BART provisions. 

If you have any questions, please advise. 

Very truly yours, 

Maya kao, P.E., BCEE 

Chief, Air Division 

Enclosure 

OFFICE OF POLLUTION CONTROL 

POST OFFICE BOX 2261 JACKSON, MISSISSIPPI 392252261. TEL: (601) 961-5171 FAX: (601) 354-6612 www.deq.state.ms.us 

AN EQUAL OPPORTUNITY EMPLOYER 

Regional Haze Supplemental SIP Documentation 

The purpose of this document is to finalize the BART determination for Mississippi Phosphates, 

Pascagoula, MS and the reasonable progress determination for E. I. DuPont Plant, DeLisle, MS. 

This supplemental information is to augment the State Implementation Plan (SIP) Revision 

Regarding Federal Regional Haze Program Requirements originally adopted by the Mississippi 

Commission on Environmental Quality on August 28, 2008 and submitted to the U.S. 

Environmental Protection Agency on September 22,2008. 

MDEQ published a public notice on February 1, 201 1, allowing for a 30-day public comment 

period concerning the supplemental information. Addendum 4 contains the notice and proof of 

publication. Addendum 5 contains MDEQ's response to the comments received and a copy of 

the comments. 

Addendum 1: 

Add the following paragraph to the end of Section 7.3.3 on page 49 of the SIP Narrative 

Addressing Visibility Improvement in Federal Class I Areas (SIP Narrative). 

On November 9, 2010 ~ssissippi Phosphates was issued a Permit to Construct Air Emissions 

Equipment that included Best Available Control Technology (BACT) limits for Sulfur Dioxide 

(S02) and Sulfuric Acid Mist (H2S04). Emissions of Sulfur Dioxide are limited to 3.0 lb SO2 

per ton of acid produced, not to exceed 225 lbihr and 1700 tonsiyr. Emissions of sulfuric acid 

mist are limited to 0.1 lb H2S04 mist per ton of acid produced, not to exceed 7.5 lbh and 32.85 

tonsiyr. These limits have been determined to be BACT; therefore, Mississippi considers these 

limits adequate to meet BART requirements. The Final Determination document which includes 

the Permit to Construct is in Appendix L1 1 .lo. 

Addendum 2: 

Add the following paragraph to the end of Section 7.6 on page 65 of the SIP narrative. 

Using the methodology developed by VISTAS, DuPont was initially considered for controls to 

help meet the reasonable progress goals for the Breton National Wildlife Refuge in Louisiana. 

Since the time of the original SIP submittal, Louisiana has completed and submitted the SIP to 

address visibility at Breton and the DuPont DeLisle facility was not identified in the SIP as part 

of the control strategy needed for the reasonable progress goals for Breton. Consequently, no 

further control analysis is necessary and no controls are being proposed for the DuPont DeLisle 

facility during this planning period. 

Addendum 3: 

Add the following paragraphs to the end of Appendix L11.1 of the SIP narrative. 

On November 9, 2010 Mississippi Phosphates (MPC) was issued a Permit to Construct Air 

Emissions Equipment that included Best Available Control Technology limits for Sulh Dioxide 
(S02) and Sulfuric Acid Mist (H2S04). With this project, MPC is making many upgrades, 

including replacing the absorption towers, installing new economizers and new superheaters, 

replacing duct work and piping, relocating new or refurbished acid coolers (i.e., heat 

exchangers), repairing the cooling tower, and replacing the vanadium catalyst with cesium 

catalyst in the third and fourth converter passes. These upgrades will not result in increased 

sulfuric acid production capacity, which is currently permitted at 1800 tons per day per plant, but 

should allow for significant decreases in down-time due to more reliable operation of the plants. 

This will result in an actual-to-potential increase in tons SO2 per year; however, the project will 

result in greater emission controls and lower permitted short-term and annual emissions for both 

pollutants. 

BACT for SO2 was determined to be the replacement of vanadium catalyst with cesium catalyst 

in the third and fourth converter passes. The permitted sulfur dioxide limit is 3.0 lb of SO2 per 

ton of sulfuric acid produced, not to exceed 225 lbh and 1700 tonslyr. MDEQ considers ths 

limit appropriate and meets BART for this source. 

BACT for H2S04 was determined to be the installation of vertical tube mist eliminators in the 

interpass absorption tower. The final absorption tower already has these mist eliminators 

installed. MPC is also replacing the economizer prior to the final absorption tower with a larger 

one which will have the effect of lowering the exhaust gas temperature thus reducing sulfuric 

acid mist emissions. The permitted sulfuric acid mist limit is 0.10 lb H2S04 per ton of sulfiuic 

acid produced, not to exceed 7.5 lbhr and 32.85 tonslyr. MDEQ considers this limit appropriate 

and meets BART for this source. 

Addendum 4: 

Notice of public comment period concerning the supplemental information along with copy of 

the proof of publication. The public notice and the proof of publication follows this page. The 

notice was also posted on the department's website. 
Public Notice 

Mississippi Commission on Environmental Quality 

P. 0. Box 2261 

Jackson, MS 39225 

Telephone No. (60 1) 96 1-5 17 1 

Public Notice Start Date: February 1,20 1 1 

Deadline for Comment: March 3.201 1 

MDEQ Contact: Elliott Bickerstaff 

Please take note that the Mississippi Commission on Environmental Quality ("Commission") is 

providing supplemental information for comment regarding a revision to the State 

Implementation Plan for Air Pollution Control (SIP Revision) adopted on August 28, 2008, 

which involves the implementation of federal regional haze regulations as promulgated by the 

U. S. Environmental Protection Agency (EPA). 

The information provided in this public notice is supplemental and clarifying information 

regarding reasonable progress goals for visibility improvement in nearby Federal Class I areas 

and Best Available Retrofit Technology (BART) determinations for emission sources located in 

the State of Mississippi. Specifically, the information provides the BART determination for 

Mississippi Phosphates Corporation in Pascagoula, MS and the Reasonable Progress 

determination for the E. I. DuPont de Nemours & Company Inc, DeLisle Plant in DeLisle, MS. 

The supplemental and clarifying information does not involve any changes to the SIP Revision 

previously adopted by the Commission and submitted to EPA. 

Persons wishing to comment on the proposed determinations are invited to submit comments in 

writing to Elliott Bickerstaff at the Commission's address shown above, no later than March 3, 

2011. All comments received by this date will be considered in preparation of the final 

submission of the supplemental information for the SIP Revision to EPA. A public hearing will 

be held if the Commission frnds a significant degree of public interest in the supplemental 

information. 

Copies of the supplemental information may be obtained by writing or calling Edna Banks at the 

address and telephone number listed above. The supplemental information is also available for 

public review at the main branch of public libraries in cities of Gulfport, Jackson, and Tupelo. 

For those persons with internet access, the supplemental information may be found on the 

Mississippi Department of Environmental Quality's website at http://www.deq.state.ms.us 

Please bring the foregoing to the attention of persons whom you know will be interested. 
PASTE PROOF HERE 

PROOF OF PUBLICATION 

THE STATE OF MISSISSIPPI 

HINDS COUNTY 

PERSONALLY appeared befofe me, the undersigned notary 

public in and for Hinds County, Mississippi, 

QLORIA JOINER 

C5WQ 4 

an authorized clerk of THE CLARIONIEDGER, a 

MS DEPT. OF ENV. QUALITY, newspaper as defined and prescribed in Sodons 13-3-31 

0200344422 and 13-3-32, of the Mississippi Code of 197 2, as amended, 

Regional Haze Supplemental Public Notice who, being duly sworn, states that the notice, a true copy of 

which is hereto attached, appeared In the issues of said 

newspaper as fdowrr: 

Size: 369 words 1 2.00 col. x 58.00 lines 

Published: 1 time@) 

Authorized C of 

The Clarion-Ledger 

SWORN to and subscribed before me on 2/1/201?. ./i< f

luK ' I?, 7 

Notary Public c i RICK TYLER 

Notary Public State of Mississippi at Large. Bonded thru 

Notary Public Undetwriters 
Addendum 5 

Response to Comments regarding the Supplemental Information submitted on March 3, 201 1 by 

the U.S. Fish and Wildlife Service. See next page for copies of comments received regarding the 

supplemental information. 

Mississippi Phosphates Corporation 

The comments questioned and requested further documentation of the 3.0 lb SO2 per ton of 

H2S04 produced. The SO2 limit is the result of a BACT determination from a PSD permit that 

was issued November 9, 2010. Since this was a recent BACT determination, the BACT limit is 

adequate to meet BART. The justification for this limit is in the Permit's Final Determination 

document. 

The comments also recommend limits for NOx, particulate opacity and sulfuric acid mist. The 

Permit issue November 9, 2010 included a .10 lb Sulhc Acid Mist per ton of Sulfuric Acid 

Produced which is lower than the recommended limit. The facility's current Title V permit has a 

10% opacity limit which is what was recommended. While there is no NOx limit, the analysis in 

PSD permit application finds that the future NOx emissions from the Sulfuric Acid Plants to be 

below the significance thresholds and below the mass emissions rate that would result from the 

recommended limit. 

DuPont DeLisle Plant 

In response to the comments regarding the Dupont Delisle Plant, Mississippi will continue to 

consult with Louisiana to assess the impact of DuPont and other facilities in Mississippi to help 

meet the visibility goals for Breton. 

Chevron Products Company 

Finally, the comments stated that the BART determination for Chevron Pascagoula Refinery 

lacked rigorous cost analysis of control alternatives. The BART requirements for Chevron were 

largely met by controls required by a consent decree to rectify New Source Review violations. 

As such, the controls that were put in place were BACT and therefore were considered to meet 

BART requirements. 
United States Department of the Interior 

HSH AND WILDLIFE SERVICE 

National Wildlife Refuge System 

Branch of Air Quality 

IN REPLY REF~R TO: 7333 W. Jefferson Ave., Suite 375 

Lakewoad. CO 80235-2017 

March 3,201 1 

Elliott Bickerstaff, P.E., DEE 

Chief, Air Support Branch 

Mississippi Department of Environmental Quality 

101 W. Capital Street 

Jackson, MS 39201 

Subject: Regional Haze State Implementation Plan Supplemental Information Comments 

Dear Mr. Bickerstaff: 

On February 1, 201 1, the State of Mississippi submitted, for public comment, proposed revisions 

to the Mississippi State Implementation Plan (SIP) for Air Pollution Control as adopted on 

August 28,2008, describing its proposal to improve air quality regional haze impacts at 

mandatory Class I areas across your region. 

We appreciate the opportunity to work closely with the State through the initial evaluation, 

development, and, now, subsequent review of this plan. Cooperative efforts such as these ensure 

that, together, we continue to make progress toward the Clean Air Act's goal of natural visibility 

conditions at all of our most pristine National Parks and Wilderness Areas for future generations. 

The U. S. Fish and Wildlife Service (FWS) is providing comments on the Best Available Retrofit 

Technology (BART) Supplemental Information for Mississippi Phosphates Corporation and the 

DuPont DeLisle Plant as they relate to the Mississippi Regional Haze State Implementation Plan 

(SIP). The FWS provided comments to the Mississippi Department of Environmental Quality 

(MDEQ) on an earlier BART analyses in June 2008. In addition, FWS is restating comment 

previously made on the Chevron Products Company Pascagoula Refinery BART determination. 

We are providing these comments to the State and ask that these be included in the official 

public record. We look forward to continuing to work with the Mississippi Department of 

Environmental Quality (MDEQ) staff towards resolving any of the issues discussed below. 

For hrther information, please contact Tim Allen with FWS at (303) 914-3802. 
Mr. Bickerstaff Page 2 

Again, we appreciate the opportunity to work closely with the State of Mississippi and 

compliment you on your hard work and dedication to significant improvement in our nation's air 

quality values and visibility. 

Sincerely, 1 - 

Sandra V. Silva, Chief 

FWS Branch of Air Quality 

Enclosure 

cc: 

Kay Prince, Chief Air Planning Branch 

US EPA Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303-8960 

Michele Notarianni 

US EPA Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303-8960 

Annette Sharp, Executive Director 

CENRAP 

10005 S. Pennsylvania, Ste. C 

Oklahoma City, Oklahoma 73 159 

John Hornbeck 

VISTAS Executive Director 

2526 Forest Parkway, Suite F 

Forest Park, GA 30297-6146 

Brian McManus, Deputy Chief Branch of 

Fire Management 

National Interagency Fire Center 

3833 South Development Ave. 

Boise, Idaho 83705 

Chief, Southeast Region 

National Wildlife Refuge System 

1875 Century Center 

Atlanta, Georgia 30345 

Kenneth Litzenberger 

Project Manager 

Southeast Louisiana Refuges 

61389 Hwy. 434 

Lacombe, Louisiana 70445 

James Burnett 

Refuge Manager 

St. Marks National Wildlife Refuge 

P.O. Box 68 

St. Marks, Florida 32355 
U.S. Fish and Wildlife Service Comments Regarding 

Mississippi Regional Haze Rule State Implementation Plan 

Supplemental Information 

March 3,2011 

Best Available Retrofit Technology 

The following are comments regarding the Best Available Retrofit Technology (BART) 

determinations for two facilities. 

Mississippi Phosphates Corporation - Pascagoula Facility 

Mississippi Phosphates Corporation and Mississippi Department of Environmental Quality 

(MDEQ) agreed to replace the absorption towers, install new economizers and new superheaters, 

replace duct work and refurbish acid coolers, repair the cooling tower and replace the vanadium 

catalyst with a cesium catalyst in the third and fourth converter passes. This will result in a 

permitted sulfur dioxide limit (S02) of 3.0 lb of SO2 per ton of sulhric acid produced, not to 

exceed 225 lbh and 1700 tonslyear. This is consistent with the recommendation made by the 

FWS in previous comments on the initial BART determinations. 

EPA, Region 4 requested MDEQ justify why the proposed configuration cannot reach a greater 

control efficiency than 3.0 lb of SO2 per ton of sulfuric acid produced. The current explanation 

is not as robust as it should be and does not provide documented comparative control levels or 

vendor guarantees; however, it does attempt to qualitatively justify the 3.0 lb control level. 

FWS previously provided the following comment on the on nitrogen oxides (NO,) emission 

limit. The current SIP revision does not discuss enforceable limits for NO,, particulates or 

sulfuric acid mist. Other phosphate facilities have reasonably meet a NO, limit of 0.1 1 - 0.12 

lblton of H2S04 product. Likewise, a 10% particulate matter opacity limit often is achievable. 

The sulfuric acid mist limit for diarnmonium phosphate1 monoammonium phosphate 

(DAPMP) units should be about 0.18 lblton of H2SO4. These limits can usually be attained 

without installation of additional pollution control equipment. Emission limits should be 

enforced using continuous emission monitoring systems. Such limits should be addressed in the 

facility's permit. 

DuPont DeLisle Plant -- Titanium Dioxide Pigment Plant 

The DuPont DeLisle Plant has two coal-fired boilers that have been shown to contribute 1.2% of 

the visibility impairment at the Breton National Wildlife Refuge (Breton), which is about 45 krn 

from the plant. Of all Mississippi industrial facilities, the DuPont DeLisle Plant's air emissions 

result in the second-highest visibility impact at Breton. The location of the Breton Wilderness 
Area suggests that several States and Gulf emissions sources are likely to contribute the visibility 

impairment. It is for this reason that a review of DuPont DeLisle Plant's control measures is 

being performed. This plant is not BART-eligible so the analysis is based on the "Reasonable 

Progress" four-factors outlined in the Regional Haze Rule (40 CFR 51.308(d)(l)(i)(A)), rather 

than the five-factor BART determination protocol. 

In the supplemental information submittal, MDEQ announced its decision to not require controls 

at the DuPont DeLisle Plant, because Louisiana Department of Environmental Quality did not 

request such controls from Mississippi in its Regional Haze SIP. However, FWS expressed 

significant concerns with Louisiana's SIP, specifically with the lack of area of influence analyses 

and discussion of attribution of haze impacts from sources outside of ~ouisiana.' Thus, even 

though the Louisiana Regional Haze SIP did not specifically cite DuPont DeLisle in the control 

strategy for Breton, FWS continues to encourage MDE to consider some level of emission 

control. In the previous FWS comments sent to MDEQ, several reasonably priced control 9 

options were identified. These options included: fuel switching and/or a spray dry absorber for 

SO2 control and low NO, burners for NO, control. FWS bases this recommendation on the 

emission contributions of DuPont DeLisle Plant and the proximity to Breton. These emission 

controls will help to minimize haze causing pollutants, reach reasonable progress goals and assist 

in the long-term strategy implementation and thereby reduce the visibility impairment at Breton. 

The supplemental information only covered MPC and DuPont DeLisle, however FWS had 

previously commented on Chevron. The following comment remains to be addressed. 

Chevron Products Company - Pascagoula Refinery 

The original MDEQ BART determination for the Chevron Products Company lacked rigorous 

cost analysis of control alternatives. MDEQ believed that significant visibility improvement 

could not be gained at reasonable cost over the improvements already attained through the 

refinery consent decree. A more robust cost analysis continues to be lacking in the SIP. 

' See Department of the Interior comments sent to Louisiana Department of Environmental Quality on January 22, 

2008, available at http://www.fws.govlre~ges/AirQuality/SIPPReview~Comments~Page.html 

See Department of the Interior comments sent to MDEQ on June 30,2008, available at 

http://www.fws.gov/refugedAirQuality/SIP~Review~Comments~Page.html 
Addendum 6: 

Add Appendix L. 1 1.10 (Attached) which contains the Final Determination document which 

includes the Permit to Construct for Mississippi Phosphates Corporation to the SIP Narrative. 
Appendix L1l.lO: 

Final Determination on the Approval of 

Mississippi Phosphates Corporation 

"Sulfuric Acid Plant Reliability and Upgrade Project" 
Final Determination 

On the Approval of 

Mississippi Phosphates Corporation 

"Sulfuric Acid Plant Reliability and Upgrade 

Project " 

To Modzh Air Emissions Equipment 

at Pascagoula, Mississippi 

(Jackson County) 

Air Reference No. 1280-00044 

November 201 0 

Technical Review by 

Carla Brown 

Air Quality Analysis by 

Bruce Ferguson 
Table of Contents 

Final Determination ............................................................................................. Section 1 

Copy of Construction Permit .............................................................................. Section 2 

Public Notice and Proof of Publication .............................................................. Section 3 

Transmittal letters to EPA and Jurisdictional Bodies ...................................... Section 4 

Ackowledgments Received .................................................................................. Section 5 

Response to Comments ........................................................................................ Section 6 
SECTION 1 

FINAL DETERMINATION 
I. General Information 

Mississippi Phosphates Corporation (MPC), located at 601 Highway 61 1, 

Pascagoula, Mississippi, (228) 762-32 10, owns and operates a fertilizer plant in 

the Bayou Casotte Industrial Park in Jackson County. The approximate Universal 

Transverse Mercator (UTM) coordinates for the fertilizer plant and proposed 

modifications are 356.79 km East and 3357.41 km North in UTM Zone 16. MPC 

manufactures diammonium phosphate (DAP) by reacting sulfuric acid made onsite with phosphate rock to produce phosphoric acid. The phosphoric acid is then 

reacted with ammonia to produce DAP. 

MPC submitted an air permit application deemed complete on May 7, 2010, for a 

Prevention of Significant Deterioration (PSD) Construction Permit to modify their 

two sulfuric acid plants. The proposed project will result in significant net 

emissions increases of sulfur dioxide (SO2) and sulfuric acid mist (H2S04) above 

the significant thresholds established in the PSD regulations. (See Table 1 on the 

following page.) Therefore, the proposed project is subject to review under the 

provisions of 40 CFR 52.21. At a minimum, an application for a PSD 

construction permit must include a Best Available Control Technology (BACT) 

Analysis, a Source Impact Analysis, and an Air Quality Analysis. 

11. Proiect Description 

MPC is proposing extensive upgrades and non-routine repairs and maintenance to 

the two sulfuric acid plants which may extend over a period of five or more years. 

These plants burn sulfbr in dry air to form SOz, and the SO2 gas stream then 

makes two passes through the vanadium catalyst converter to form S03. The So3 

is absorbed by a sulfuric acid stream in the interstage absorber to make a 

concentrated sulfuric acid product leaving the bottom of the absorber, while the 

exhaust gas exiting the top of the absorber makes two more passes through the 

vanadium catalyst converter before entering a second and final absorber. This 

process is referred to as a dual absorption system (DAS) with a 212 converter 

design. 

With this project, MPC is considering many upgrades, including replacing the 

absorption towers, installing new economizers and new superheaters, replacing 

duct work and piping, relocating new or refurbished acid coolers (i.e., heat 

exchangers), repairing the cooling tower, and replacing the vanadium catalyst 

with cesium catalyst in the third and fourth converter passes. These upgrades will 

not result in increased sulfuric acid production capacity, which is currently 

permitted at 1800 tons per day per plant, but should allow for significant 

decreases in down-time due to more reliable operation of the plants. Since PSD 

applicability is evaluated on an annual basis, there is an increase in potential 

emissions as compared to past years due to less downtime. This is reflected in the 

emissions changes associated with the project, which were evaluated on a baseline 

actual-to-potential basis. Although the actual-to-potential emissions changes 

show an increase for SO2 and MPC is proposing lower potential, 
permitted short-term and annual emission for both pollutants, as shown in Table 

2. 

Table 1. PSD Applicability 

Emissions (tpy) 

Table 2. Previous and Proposed Permitted ~irnits' 

Net 

I As directed in the PM2 final NSR implementation rule, MDEQ is allowing sources to not include the 

condensable fraction of PM during the "transition period", during which EPA will promulgate a test 

method for accurately measuring this portion of PM. EPA has yet to finalize a more accurate test method. 

Both NO, and VOC are considered precursors for ozone with a significant emission rate of 40 TPY each. 

Caatempotmnmus 

Pollutant I Units I Previous Limit I Proposed Limit 

-- I 

Y5;Y 

Review 

Required? 

lbhr 

lblton 

- 

NO 

No 

No 

Yes 

No 

Yes 

Co 

NO." 

I I I I I 

I Limits are for each sulfuric acid plant with the exception of the TPY limit, 

which is a combined limit for emissions from both plants. 

--- 

4.0 

Iblton 

TPY 

111. Best Available Control Technolow (BACT) Analysis 

The applicant is required to perform a BACT analysis for all pollutants that have a 

significant net emissions increase. Utilizing the "top-down" approach detailed in 

EPA's New Source Review Workshop Manual (Draft 1990), the PSD applicant 

goes through a five-step process to determine BACT: (I) IdentifL all control 

technologies; (2) Eliminate technically infeasible control options; (3) Rank the 

remaining control technologies by control effectiveness; (4) Evaluate the most 

effective controls taking into consideration economic, energy, and environmental 

impacts; and (5) Select BACT. BACT is an emission limitation based on the 

maximum degree of pollutant reduction determined on a case-by-case basis, 

taking into account energy, environmental, and economic impacts, that is 

27.1 

28.4 

225 

3 .O 

------- 

No 

Yes 

No 

Yes 

0.15 

48.88 

1 00 

40 

0.10 

32.85 

NIA 

----- 

---- 

0.4 

----- 

Nf A 

0 

NO 

No 

N/A 

1 88.4 

NIA 

19.3 

Y/A 

NIA 

NlA 

NIA 
determined to be achievable for a source. A BACT analysis must be performed 

for each emission unit undergoing a physical change or change in the method of 

operation and that emits a pollutant that is undergoing a significant net emissions 

increase. 

For this project, there is a significant net emissions increase for SO2 and HzS04. 

Therefore, MPC must evaluate BACT for both sulfuric acid plants. 

A. SO2 Analysis 

MPC identified a variety of control technologies for reducing SOz emissions, 

including ammonia scrubbing, sodium sulfite-bisulfite scrubbing, lime slurry 

injection, molecular sieves, and hydrogen peroxide scrubbing. Molecular 

sieves were shown to be technically infeasible due to the exhaust gas 

characteristics. Hydrogen peroxide scrubbing has not been demonstrated as a 

viable control technology for sulfuric acid plants and would change the scope 

of the project were an attempt made to transfer this technology to the sulfuric 

acid plants. All forms of wet scrubbing were determined to infeasible from an 

environmental standpoint, as they would result in a process wastewater 

discharge. The federal effluent guidelines for phosphate fertilizer 

manufacturing, found in 40 CFR Part 41 8, prohibit the discharge of process 

wastewater, either directly to waters of the state or indirectly to a POTW. 

Therefore, MPC's only option would be to reuse such water. However, MPC 

already has excess water in the existing water balance and can not 

accommodate additional water. 

MPC also identified process changes that could potentially improve the SO2 to 

SO3 conversion, including replacement of vanadium catalyst with cesium 

catalyst, changing the catalyst loading rate to the converter, and operating at a 

higher 02/S02 ratio prior to the passes through the converter. MPC 

determined that they already operate at the optimum catalyst loading rate, and 

increasing the rate would only be possible by constructing a larger converter 

which is not within the scope of the project. MPC also determined that they 

are running at the appropriate 02/S02 ratio for the sulfuric acid plants and that 

any higher ratio would result in temperatures in excess of what the converter 

equipment could safely handle. However, MPC did determine that replacing 

the vanadium catalyst with cesium catalyst in the 3rd and 4th converter passes 

was feasible and would result in a significant reduction of SO2 emissions by 

resulting in higher conversion of SOz to SO3 in the 3rd and 4"' passes. 

Therefore, MPC proposed BACT to be the existing dual absorption system 

and replacement of vanadium catalyst with cesium catalyst in the 3rd and 4" 

converter passes, yielding emissions of 3.0 lb of SOz per ton of sulfuric acid 

produced. MDEQ believes that this BACT determination is sufficient for the 

following reasons: (1) MPC is retrofitting two older sulfuric acid plants with 

new pieces of equipment, as needed to improve the safety and reliability of 

these plants, as opposed to building new plants that could be designed 

differently to minimize emissions. (2) Sulfuric acid plants with more stringent 

limits had a 311 converter design as compared to MPC's current 212 converter 
design that will not be modified within the scope of this project. The 212 

converter design has only two catalyst passes through the converter to achieve 

the SOz to SO3 conversion; whereas, the 311 converter design allows for three 

catalyst passes - two passes before the first (or intermediate) absorption tower 

and one pass before the final absorption tower. Therefore, the 311 design 

achieves a higher conversion rate resulting in approximately a 50% reduction 

of SO2 in the exhaust compared to the exhaust from a 212 converter design. A 

new 311 converter can achieve SO2 emission rates below 2.0 lblton; whereas, 

MPC was quoted an emission rate of 3.1-3.2 lblton. In order for MPC to go 

from 212 to a 311 converter design, MPC would have to replace/modi@ their 

integrated steam equipment which is beyond the scope of this project. 

B. Sulfuric Acid Mist (mod Analysis 

MPC identified mist eliminators as the most effective sulfuric acid mist 

control technology. Two different design types were discussed - mesh pads 

and candles (or vertical tube mist eliminators). MPC has proposed to put 

vertical tube mist eliminators in the interpass absorption tower. The final 

absorption tower already has these mist eliminators installed. MPC is also 

proposing to replace the economizer prior to the final absorption tower with a 

larger one which will have the effect of lower the exhaust gas temperature 

thus reducing sulfuric acid mist emissions. Since the vertical tube mist 

eliminators are the most efficient add-on control technology, no additional 

control technologies were considered. 

MPC has proposed a sulfuric acid mist limit of 0.10 Ib sulfuric acid mist per 

ton of sulfuric acid produced. MDEQ considers this limit consistent with 

recent BACT determinations, since it is among the most stringent achieved in 

practice. 

IV. Source Impact Analysis 

The owner or operator of a proposed source or modification is required to 

demonstrate that allowable emission increases from the proposed source or 

modification, in conjunction with all other applicable emissions increases or 

reductions (including secondary emissions), will not cause or contribute to air 

pollution in violation of: 1) any national ambient air quality standard in any air 

quality control region; or 2) any applicable maximum allowable increase over the 

baseline concentration in any area. 

The modeled concentrations used to determine compliance with any NAAQS and 

PSD increment depend on 1) the type of standard, i.e., deterministic or statistical, 

2) the available length of record of meteorological data, and 3) the averaging time 

of the standard being analyzed. When the analysis is based on 5 years of National 

Weather Service meteorological data, the following estimates are used: 

For deterministically based standards (e.g., S02), the highest, secondhighest short term estimate and the highest annual estimate; and 
For statistically based standards (e.g., PMlo), the highest, sixth-highest 

estimate and highest 5-year average estimate. 

A. Existing Air Quality 

Any application for a permit under the Prevention of Significant Deterioration 

program is required to contain an analysis of ambient air quality in the area 

that the major stationary source or major modification would affect for each of 

the following pollutants: a) for the source, each pollutant that it would have 

the potential to omit in a significant amount; b) for the modification, each 

pollutant for which it would result in a significant net emissions increase. 

The existing air quality is defined by the natural and human-generated sources 

of air pollution. The area surrounding the Jackson County facility is 

considered rural and in attainment for all regulated pollutants. The pollutant 

under consideration in the analysis is sulfur dioxide (Sol). 

B. Modeling Procedure 

All estimates of ambient concentrations are to be based upon applicable air 

quality models, data bases and other requirements specified in appendix W of 

40 CFR Part 5 1 (Guideline on Air Quality Models). 

The AMS/EPA Regulatory Model (AERMOD) version 07026 was used to 

estimate impacts from all pollutants. The modeling analysis was conducted 

using the regulatory default options, with the exception that the option for 

horizontal emissions was used for the emergency generator. Building wake 

and downwash effects were accounted for using the Building Profile Input 

Program (BPIP) version 04274. 

Three point sources related to the project were considered in the analysis. 

These sources and the modeled emissions are presented in Table 4. The 

decrease in short term emissions is based upon the maximum short term 

emission rate over the past two years and the short term limit which is 

included in the permit. The preliminary analysis resulted in predicted 

concentrations below the modeling significance levels; therefore, no off-site 

sources were modeled. 

Table 3 - Project related sources 

Modeled Emissions 

Source Name Source Description PPH TPY 

MOO1 #2 Sulfuric Acid -1 7.48 187.83 

AAOI 7 #3 Sulfuric Acid -7.49 187.83 

AA031 Emergency Generator 0.35 0.41 

The hourly meteorological database used in the preliminary and full impact 

analysis consisted of five years (1 99 1 to 1995) of Mobile, AL surface data and 

Slidell, LA upper air combined. The meteorological data was processed with 

the surface characteristics of the Mobile, AL surface station and was also 
processed using the surface characteristics of the project site. The latest year 

of meteorological data from each set was used to determine impacts for the 

project. The meteorological dataset which predicted the most conservative 

concentrations was used for the compliance demonstration. The met data 

processed with the site surface characteristics was used for the short term 

averaging periods and the met data processed with the Mobile surface 

characteristics was used for the annual averaging period. 

A Cartesian receptor grid was used for the Screen modeling runs, including 

receptors spaced at 100 meter intervals along the fence linelpatrolled property 

line and out to a distance of 2 kilometers, 250 meter intervals from 2 

kilometers to 5 kilometers, 500 meter intervals from 5 kilometers to 10 

kilometers and and 1000 meter intervals from 10 to 50 kilometers. Discrete 

receptors were placed along the fenceline at 50-meter spacing. Receptor 

coordinates, elevations, height above ground, and hill height scales were 

produced the AERMAP terrain preprocessor version 04300 for input to 

AERMOD. 

Air Quality Monitoring Requirements 

The ambient air quality analysis is required to contain continuous air quality 

monitoring data gathered for purposes of determining whether emissions of 

that pollutant would cause or contribute to a violation of the standard or any 

maximum allowable increase. The source may be exempt from the 

preconstruction monitoring requirements if the air quality impacts are less 

than the monitoring de minimis concentrations. 

Table 4 - Preconstruction de minimus levels. 

Preliminary analysis results show the impact of SO2 to be below the 

monitoring de minimis concentrations. The preconstruction monitoring 

requirement for these pollutants is, therefore, waived. 

Pollutant 

PMIO 

so2 

NO2 

Ozone 

CO 

Lead 

D. PSD Preliminary Analysis Modeling Impacts 

In the preliminary analysis, only the significant increase in potential emissions 

of a pollutant from a proposed new source, or the significant net emission 

increase of a pollutant from a proposed modification is modeled. A full 

impact analysis for a particular pollutant is not required when emissions of 

that pollutant from a proposed source or modification would not increase 

Averaging Period 

24-hour 

24-hour 

Annual 

8-hour 

3-month avg 

Monitoring de minimis 

Concentration (yg/m3) 

10 

13 

14 

VOC or NOx emission 

increase < 100 TPY 

575 

0.1 

Modeled Concentration 

(yg/m3) 

NIA 

1.5 

NI A 

N/ A 

NIA 

NIA 
ambient concentrations by more than prescribed significant ambient impact 

levels. 

Table 5 summarizes the results of the preliminary analysis. The modeled 

results presented are the highest estimated concentration for averaging times 

of 24-hours or less and the highest annual average of the individual years for 

the annual averaging period. 

Table 5 - Significant Impact Modeling Results 

Modeled results for all averaging periods were below the modeling 

significance levels, therefore, no fixther analysis is required. 

Pollutant 

The new SO2 1-hr NAAQS became effective prior to the issuance of the 

permit, therefore, this standard must be addressed. With the exception of the 

emergency generator, the short-term SOz emissions are decreasing. The 

increase in the project is due to increased utilization. Since the short-term 

emission rates are decreasing the project is considered insignificant with 

respect to the short-term averaging periods. Additionally, the maximum 1-hr 

impact was determined for the 1992 year (produced highest 3-hr average) and 

was determined to be 5.41550 ugh3 which is below 4% of the standard. The 

4% mark has historically been used in developing SILs. 

E. Vegetation and Soils Impact 

The owner or operator is required to provide an analysis of the impairment to 

visibility, soils and vegetation that would occur as a result of the source or 

modification. The owner or operator need not provide an analysis of the 

impact on vegetation having no significant commercial or recreational value. 

Averaging 

Period 

A nnlrsl 

The modeled results were below the modeling significance levels and, 

therefore, no adverse impact on soils and vegetation is anticipated. 

SC 57437.3 1 

I 57431.81 

F. Associated Growth Impact 

Significant 

Impact 

Level 

(pg/m3) 

1 

The owner or operator is required to provide an analysis of the air quality 

impact projected for the area as a result of general commercial, residential, 

industrial and other growth associated with the source or modification. 

3360897.50 

3361091.50 

The project will not result in a population shift or increase and therefore, no 

impact is anticipated due to associated growth. 

Modeled 

Results 

@dm3) 

fl Q7n07 

94030224 

9203 1903 

UTM 

KM 

355509.31 

UTM 

(KM) 

3359071.50 

Event 

(YYMMDDHH) 

1991 
G. Class I Impact and Visibility 

The proposed facility is located approximately 50 km from the Breton 

Wilderness Area. There will be a decrease in the short term emissions due to 

limits contained in the permit. The Class 1 significance level for the SO:, 

annual averaging period is 0.1 ug/m3 as proposed by the EPA. This level was 

reached at approximately 5.4 kilometers from the project site, which is well 

short of the distance to the Class 1 area. A Class 1 increment analysis was not 

required, based upon this result. The applicant conducted a VISCREEN 

analysis at the request of the Federal Land Manager. The Level 2 analysis 

indicated that visibility would not be impacted above screening levels. Due 

the distance and the proposed emission rates, no adverse impacts at the Class 

1 areas are anticipated. 

V. BART and Other Requirements 

A. BART 

MPC is proposing that the approved BACT and corresponding SO:, emission 

limit be accepted as the Best Available Retrofit Technology (BART). BART 

is required for SO2 emissions from MPC7s sulfuric acid plants, since such 

emissions can contribute to visibility impairment at the nearby Class I area - 

Breton National Wildlife Refuge. MPC must comply with the permitted 

BART limit no later than five years from approval of Mississippi's SIP 

implementing the regional haze plan required under 40 CFR Part 5 1, Subpart 

P - Protection of Visibility. DEQ considers the BACT determination 

sufficient to meet the requirements of the BART determination. A 24-hr 

rolling average SO2 limit has been placed in the permit to protect visibility. 

B. Monitoring Requirements 

The permit requires a CEMS to be installed to demonstrate compliance with 

the SO:, emission limits for each sulfuric acid plant. A SO2 CEMS is already 

required under NSPS Subpart H. However, the proposed monitoring should 

more accurately reflect emissions because the MPC will directly monitor 

exhaust flow and hourly production and will not rely on the empirical 

equation from NSPS Subpart H for emission rate determinations. For sulfuric 

acid mist, an initial stack test'is required. The Title V Operating Permit 

currently contains a detailed Compliance Assurance Monitoring (CAM) plan, 

per 40 CFR Part 64, to ensure that the H2S04 control equipment is properly 

working. This will be modified as necessary to reflect any new H2SO4 control 

equipment installed as part of this project. 

C. NSPS Subpart H 

The sulfuric acid plants are already subject to this NSPS, which has SO2, 

H2S04, and opacity emission standards. The SO:, and H2SO4 BACT emission 

limits are more stringent than the NSPS limits. 
D. Other State Requirements 

APC-S-1, Section 4.2 contains emission standards for acid mist of 0.5 Iblton 

of acid produced and for sulfur trioxide of 0.2 Iblton of acid produced. The 

NSPS standard is much lower for sulfuric acid mist, and because MPC utilizes 

a dual absorption system, there are negligible amounts of sulfur trioxide. 

VI. Recommendation 

The impact of the emission of air contaminants from the project has been 

evaluated and the staff believes that, with proper constraints and limitations, this 

project will operate within all State and Federal air pollution control laws and 

standards and will protect public health and welfare. The staff also believes that 

this project is necessary to bring these sulhric acid plants back to a reliable state 

of operation given the excessive shutdowns, and hence, startups MPC has been 

experiencing over the past years, which produce excessive SO? emissions. 

Therefore, the staff of the Board has decided, based on available information, to 

recommend to the Board that a permit be issued for the construction of these 

various projects. 
SECTION 2 

COPY OF THE CONSTRUCTION PERMIT 
STATE OF MISSISSIPPI 

AIR POLLUTION CONTROL 

PERMIT 

AND PREVENTION OF SllCNIFICANT 

DETERIORATION AUTHORITY 

TO CONSTRUCT AIR EMISSIONS EQUIPMENT 

THIS CERTIFIES THAT 

Mississippi Phosphates Corporation 

601 Highway 61 1 

Pascagou fa, Mississippi 

Jackson County 

bbSuffuric Acid Plant Reiiabiiity and Upgrade Project'' 

has been granted permission to construct air emissions equipment to comply with 

emission limitations, monitoring requirements and other c~nditiuns set forth 

herein. I his permit is issued in accordance with the provisions of the Mississippi 

Air and Water Pollution Control Law (Section 49-1 7-1 et. .wq., Mississippi Code 

of 1972). and the regulations and standards adopted and promulgated thereutidcr 

and under authority granted by the Environmental Protection Agency under 40 

CFR 52.01 and 52.2 1. 

MlSSISSlPPl QUALITY PERMIT BOARD 
Page 2 of 11 

Permit No.: 1280-00044 

Part I 

GENERAL CONDITIONS 

This permit is for air pollution control purposes only. (Ref.: APC-S-2, Section 1.D) 

Any activities not identified in the application are not authorized by this permit. (Ref.: 

Miss. Code Ann. 49- 17-29 1 .b) 

The knowing submittal of a permit application with false information may serve as 

the basis for the Permit Board to void the permit issued pursuant thereto or subject the 

applicant to penalties for operating without a valid permit pursuant to State Law. 

(Ref.: APC-S-2, Section II.B.5) 

It is the responsibility of the app1icantJpermittee to obtain all other approvals, permits, 

clearances, easements, agreements, etc., which may be required including, but not 

limited to, all required local government zoning approvals or permits. (Ref.: APC-S2, Section I.D.6) 

The issuance of a permit does not release the permittee from liability for constructing 

or operating air emissions equipment in violation of any applicable statute, rule, or 

regulation of state or federal environmental authorities. (Ref.: APC-S-2, Section 

II.B.7) 

It shall not be a defense for a permittee in an enforcement action that it would have 

been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of the permit, unless halting or reducing activity 

would create an imminent and substantial endangerment threatening the public health 

and safety of the lives and property of the people of this state. (Ref.: APC-S-2, 

Section 1I.B. 15(a)) 

The permit andlor any part thereof may be modified, revoked, reopened, and reissued, 

or terminated for cause. Sufficient cause for a permit to be reopened shall exist when 

an air emissions stationary source becomes subject to Title V. The filing of a request 

by the permittee for a permit modification, revocation and reissuance, or termination, 

or of a notification of planned changes or anticipated noncompliance does not stay 

any permit condition. (Ref.: APC-S-2, Section 1I.B. 15(b)) 

The permit does not convey any property rights of any sort, or any exclusive 

privilege. (Ref.: APC-S-2, Section 1I.B. 15(c)) 

The permittee shall hrnish to the DEQ within a reasonable time any information the 

DEQ may request in writing to determine whether cause exists for modifying, 

revoking and reissuing, or terminating the permit or to determine compliance with the 

permit. Upon request, the permittee shall also furnish to the DEQ copies of records 

required to be kept by the permit or, for information claimed to be confidential, the 

permittee shall furnish such records to the DEQ along with a claim of confidentiality. 
Page 3 of 11 

Permit No.: 1280-00044 

The permittee may furnish such records directly to the Administrator along with a 

claim of confidentiality. (Ref.: APC-S-2, Section 1I.B. 15(d)) 

10. Design and Construction Requirements: The stationary source shall be designed and 

constructed so as to operate without causing a violation of an Applicable Rules and 

Regulations, without interfering with the attainment and maintenance of State and 

National Ambient Air Quality Standards, and such that the emission of air toxics does 

not result in an ambient concentration sufficient to adversely affect human health and 

well-being or unreasonably and adversely affect plant or animal life beyond the 

stationary source boundaries. (Ref.: APC-S-2, Section V.A) 

11. Solids Removal: The necessary facilities shall be constructed so that solids removed 

in the course of control of air emissions may be disposed of in a manner such as to 

prevent the solids from becoming windborne and to prevent the materials from 

entering State waters without the proper environmental permits. (Ref.: Miss. Code 

Ann. 49- 17-29) 

12. Diversion and Bypass of Air Pollution Controls: The air pollution control facilities 

shall be constructed such that diversion from or bypass of collection and control 

facilities is not needed except as provided for in Regulation APC-S-1, "Air Emission 

Regulations for the Prevention, Abatement, and Control of Air Contaminants", 

Section 10. (Ref.: APC-S-1, Section 10) 

13. Fugitive Dust Emissions from Construction Activities: The construction of the 

stationary source shall be performed in such a manner so as to reduce fugitive dust 

emissions from construction activities to a minimum. (Ref.: APC-S-2, Section 

V.A.4) 

14. Right of Entry: The permittee shall allow the Mississippi Department of 

Environmental Quality Office of Pollution Control and the Mississippi Environmental 

Quality Permit Board andlor their representatives upon presentation of credentials: 

a) To enter upon the permittee's premises where an air emission source is located or 

in which any records are required to be kept under the terms and conditions of 

thrs permit; and 

b) At reasonable times to have access to and copy any records required to be kept 

under the terms and conditions of this permit; to inspect any monitoring 

equipment or monitoring method required in this permit; and to sample any air 

emissions. (Ref.: Miss. Code Ann. 49- 17-2 1) 

15. Permit Modification or Revocation: After notice and opportunity for a hearing, the 

Permit Board may modify the permit or revoke it in whole or in part for good cause 

shown including, but not limited to: 

a) Persistent violation of any of the terms or conditions of this permit; 
Page 4 of 11 

Permit No.: 1280-00044 

b) Obtaining this permit by misrepresentation or failure to disclose fully all relevant 

facts; or 

c) A change in federal, state, or local laws or regulations that require either a 

temporary or permanent reduction or elimination of previously authorized air 

emission. 

(Ref.: APC-S-2, Section 1I.C) 

16. Public Record and Confidential Information: Except for data determined to be 

confidential under the Mississippi Air & Water Pollution Control Law, all reports 

prepared in accordance with the terms of this permit shall be available for public 

inspection at the offices of the Mississippi Department of Environmental Quality, 

Office of Pollution Control. (Ref.: Miss. Code Ann. 49-1 7-39) 

17. Permit Transfer: This permit shall not be transferred except upon approval of the 

Permit Board. (Ref.: APC-S-2, Section XV1.B) 

18. Severability: The provisions of this permit are severable. If any provision of the 

permit, or the application of any provision of the permit to any circumstances, is 

challenged or held invalid, the validity of the remaining permit provisions andlor 

portions thereof or their application to other persons or sets of circumstances, shall 

not be affected thereby. (Ref. APC-S-2, Section I.D.7) 

19. Permit Expiration: The permit to construct will expire if construction does not begin 

within eighteen (1 8) months from the date of issuance or if construction is suspended 

for eighteen (1 8) months or more. (Ref.: APC-S-2, Section V.C. I) 

20. Certification of Construction: A new stationary source issued a Permit to Construct 

cannot begin operation until certification of construction by the permittee. (Ref.: 

APC-S-2, Section V.D.3) 

21. Beginning Operation: Except as prohibited in Part I, Condition 24 of this permit, after 

certification of construction by the permittee, the Permit to Construct shall be deemed 

to satisfy the requirement for a permit to operate until the date the application for 

issuance or modification of the Title V Permit or the application for issuance or 

modification of the State Permit to Operate, whichever is applicable, is due. This 

provision is not applicable to a source excluded fiom the requirement for a permit to 

operate as provided by APC-S-2, Section XII1.G. (Ref.: APC-S-2, Section V.D.4) 

Application for a Permit to Operate: Except as otherwise specified in Part I, 

Condition 24 of this permit, the application for issuance or modification of the State 

Permit to Operate or the Title V Permit, whichever is applicable, is due twelve (12) 

months after beginning operation or such earlier date or time as specified in the 

Permit to Construct. The Permit Board may specify an earlier date or time for 

submittal of the application. Beginning operation will be assumed to occur upon 
Page 5 of Sl 

Permit No.: 1280-00044 

certification of construction, unless the permittee specifies differently in writing. 

(Ref.: APC-S-2, Section V.D.5) 

23. Operating Under a Permit to Construct: Except as otherwise specified in Part I, 

Condition 24 of this permit, upon submittal of a timely and complete application for 

issuance or modification of a State Permit to Operate or a Title V Permit, whichever 

is applicable, the applicant may continue to operate under the terms and conditions of 

the Permit to Construct and in compliance with the submitted application until the 

Permit Board issues, modifies, or denies the Permit to Operate. (Ref.: APC-S-2, 

Section V.D.6) 

24. Application Requirements for a Permit to Operate for Moderate Modifications: For 

moderate modifications that require contemporaneous enforceable emissions 

reductions from more than one emission point in order to "net" out of PSD/NSR, the 

applicable Title V Permit to Operate or State Permit to Operate must be modified 

prior to beginning operation of the modified facilities. (Ref.: APC-S-2, Section 

V.D.7) 

25. Compliance Testing: Regarding compliance testing: 

a) The results of any emissions sampling and analysis shall be expressed both in 

units consistent with the standards set forth in any Applicable Rules and 

Regulations or this permit and in units of mass per time. 

b) Compliance testing will be performed at the expense of the permittee. 

c) Each emission sampling and analysis report shall include but not be limited to the 

following: 

(I) detailed description of testing procedures; 

(2) sample calculation(s); 

(3) results; and 

(4) comparison of results to all Applicable Rules and Regulations and to 

emission limitations in the permit. 

(Ref.: APC-S-2, Section VI.B.3,4, and 6) 
Page 6 of 11 

Permit No.: 1280-00044 

B. GENERAL NOTIFICATION REQUIREMENTS 

1. Within fifteen (15) days of beginning actual construction, the permittee must notify 

DEQ in writing that construction has begun. (Ref.: APC-S-2, Section V.C.2) 

2. The permittee must notify DEQ in writing when construction does not begin within 

eighteen (18) months of issuance or if construction is suspended for eighteen (18) 

months or more. (Ref.: APC-S-2, Section V.C.3) 

3. Upon the completion of construction or installation of an approved stationary source 

or modification, the applicant shall notify the Permit Board that construction or 

installation was performed in accordance with the approved plans and specifications 

on file with the Permit Board. (Ref.: APC-S-2, Section V.D.1) 

4. The Permit Board shall be promptly notified in writing of any change in construction 

from the previously approved plans and specifications or permit. If the Permit Board 

determines the changes are substantial, it may require the submission of a new 

application to construct with "as built" plans and specifications. Notwithstanding any 

provision herein to the contrary, the acceptance of an "as built" application shall not 

constitute a waiver of the right to seek compliance penalties pursuant to State Law. 

(Ref.: APC-S-2, Section V.D.2) 
Page 7 of 11 

Permit No.: 1280-00044 

PART I1 

EMISSION LIMITATIONS AND MONITORING REQUIREMENTS 

Beginning upon permit issuance, the permittee is authorized to modify air emissions 

equipment for the emission of air contaminants from Emission Points AA-001 and AA017, the No. 2 and No. 3 Sulfuric Acid Plants, respectively. The sulfuric acid plants 

currently have dual absorption systems for control of SOz emissions and are equipped 

with Brinks Demisters in the final absorption towers and other mist eliminators 

throughout the process to control sulfuric acid mist. Modifications to reduce SO2 

emission will include replacement of the vanadium catalyst with cesium catalyst in the 3rd 

and 4th converter passes. To reduce sulfuric acid mist, additional vertical tube mist 

eliminators, or candles, will be installed, and the economizer prior to each final 

absorption tower will be replaced. Other modifications may include replacement of the 

drying towers, interpass absorption towers, final absorption towers, acid coolers, and heat 

exchangers. 

The air emissions equipment shall be modified to comply with the emission limitations 

and monitoring requirements specified below. These emission limitations shall become 

effective as specified below but no later than five years from the date Mississippi's 

Regional Haze SIP is approved by EPA. 

Sulfur Dioxide (~02)~ 3.0 lb S02/ton of 100% H2SO4 produced (3-hr rolling 

average, determined hourly - BACT limit), not to exceed 

225 lbh (24-hr rolling average, determined hourly - 

BART limit) and 1700 TPY (365-day rolling total, 

determined daily) 

Sulfuric Acid (~2~04)~ 0.10 lb H2SOdton of 100% H2S04 produced (3-hr block 

average - BACT limit), not to exceed 7.5 lbh (3-hr block 

average) and 32.85 TPY 

The emission limitations shall apply at all times, except as provided for in APC-S-1, 

Section 10. All emissions, including those during startups, shutdowns, and malfunctions, 

shall be used to determine compliance with the TPY emission limitations. 

The SO2 TPY limit is a combined limit for both sulfuric acid plants (Emission Point 

AA-001 and AA-017). All other emission limits are individual limits for each sulfuric 

acid plant. 

The permittee shall comply with the short-term SO2 emission limitations above for each 

plant upon certification of construction and startup of the modified converter, including 

the replacement of vanadium catalyst with cesium catalyst in both the 3rd and 4th passes. 

The permittee shall comply with the combined TPY SO2 emission limit above upon 

certification and startup of the converters in both sulfuric acid plants. 
Page 8 of 11 

Permit No.: 1280-00044 

The permittee shall comply with the H2S04 emission limitations above for each plant 

upon certification of construction and startup of the modifiedkeplaced interpass 

absorption tower and replacement of the economizer prior to the final absorption tower. 

NSPS Subpart H - SULFURIC ACID PLANTS 

For Emission Points AA-001 and AA-017, the permittee is subject to and shall comply 

with the New Source Performance Standards for Sulfuric Acid Plants (40 CFR Part 60, 

Subpart H) and the applicable requirements of the General Provisions (40 CFR Part 60, 

Subpart A). 

Sulfur Dioxide: 

The permittee shall not discharge into the atmosphere any gases which contain sulfur 

dioxide in excess of 4 lb per ton of acid produced, the production being expressed as 100 

percent H2S04. (Ref.: 40 CFR 60.82(a)) 

Sulfuric Acid Mist: 

The permittee shall not discharge into the atmosphere any gases which contain acid mist, 

expressed as &So4, in excess of 0.15 lb per ton of acid produced, the production being 

expressed as 100 percent H2S04. (Ref.: 40 CFR 60.83(a)(l)) 

Opacity: 

The permittee shall not discharge into the atmosphere any gases which exhibit 10 percent 

opacity, or greater. (Ref.: 40 CFR 60.83(a)(2)) 

INITIAL COMPLIANCE DEMONSTRATION 

For each sulfuric acid plant, within 60 days after achieving the maximum production rate 

at which the plant will be operated, but not later than 180 days after completion of 

modification/replacement of the interpass absorption tower and replacement of the 

economizer prior to the final absorption tower, the permittee shall demonstrate initial 

compliance with the emission limits and standards for the following pollutant by stack 

testing in accordance with the specified method(s). 

Sulfuric Acid Mist EPA Test Methods 8 

(40 CFR Part 60, Subpart A) 

All test methods specified above shall be those versions, or their approved equivalents, 

which are in effect upon permit issuance. For the purpose of demonstrating compliance, 

the permittee shall operate the sulfuric acid plant as close to its maximum rated capacity 

as operating conditions allow. 
Page 9 of 11 

Permit No.: 1280-00044 

The permittee shall use the procedures in 40 CFR 60.85(d) to determine the lb H2SOdton 

of 100% &So4 produced. 

The permittee shall submit a test protocol at least thirty (30) days prior to the scheduled 

test date to ensure that all test methods and procedures are acceptable to the DEQ. The 

DEQ must be notified at least ten (10) days prior to the scheduled test date so that an 

observer may be scheduled to witness the test(s). A stack test report containing the 

results of the test(s) shall be submitted within sixty (60) days of completion of the 

required test(s). 

MONITORING REQUIREMENTS 

Sulfur Dioxide: 

To demonstrate compliance with the SO2 emission limits expressed as lblton, lbh, and 

TPY, the permittee shall develop a comprehensive monitoring plan containing the 

following information: 

(1) The use of a continuous emissions monitoring system for measuring and 

recording the concentration of SOz emissions from each sulfuric acid plant, 

including the frequency of measurement, performance specifications, and quality 

assurance procedures; 

(2) The use of an instrument for continuously measuring and recording the exhaust 

flow from each sulfuric acid plant, including performance specifications and 

quality assurance procedures; 

(3) The procedures the permittee will use to determine the hourly production rate of 

100% sulfuric acid at each sulfuric acid plant; 

(4) The methods andlor calculations the permittee will use to determine the lblhr and 

lblton SO2 emission rate on an hourly basis and the todday SO2 emission rate on 

a daily basis; and 

(5) The use of an automated data acquisition and handling system, including a 

description of the data acquired, the method by which data will be reduced to the 

units and averaging periods of the applicable emission limitations, and the 

procedures for addressing missing or invalid data. 

The comprehensive monitoring plan shall be submitted to both the Environmental 

Permits Division and the Environmental Compliance and Enforcement Division of DEQ 

for approval within two years of permit issuance or 120 days prior to the effective date of 

the SOz limits for either sulfuric acid plant, whichever date comes first. 
Page 10 of 11 

Permit No.: 1280-00044 

RECORDKEEPING REQUIREMENTS 

In accordance with Part 111, Condition 1, the permittee shall maintain electronic records 

of all CEMS data required to be monitored and recorded in a data acquisition and 

handling system and production data used to convert SO:! emissions to units of lblton. 

The permittee shall maintain electronic records of the average hourly SO2 emission rates 

in lblton, the average hourly SO2 emission rate in lbh, and the calculated 3-hr rolling 

average SO2 emission rates in lblton and lblhr. The permittee shall calculate and record 

the daily SO2 emissions in todday and the rolling 365-day total SO2 emissions in TPY. 

NOTIFICATION AND REPORTING REQUIREMENTS 

In addition to the reporting requirements of 40 CFR 60.7, the permittee shall report all 

deviations from the permitting requirements specified herein in accordance with Part 111, 

Condition 3. 

Within sixty (60) days of permit issuance, the permittee shall submit a schedule of 

proposed construction activities and modifications to take place at the No. 2 and No. 3 

Sulfuric Acid Plants. The schedule shall be updated annually thereafter to reflect 

completed construction, on-going construction, and planned construction. 

The permittee shall promptly notify DEQ of any delay(s) in construction in accordance 

with Part I.B.2. of this permit. In accordance with Part I.B.3, the permittee shall also 

certify construction for each significant modification to the sulfuric acid plants, including 

but not limited to any modification that will trigger the emission limits established herein 

and replacement of any absorption or drying tower. 
Page 11 of 11 

Permit No.: 1280-00044 

PART I11 

OTHER REQUIREMENTS 

Records: 

(1) The permittee shall maintain on-site records of all required monitoring data and 

support information required by this permit for a period of at least five (5) years 

from the date of the monitoring sample, measurement, report, or application. 

These records shall be made available for review upon request from DEQ 

personnel. 

Reporting Deviations: 

(2) The permittee shall report any deviations from the permit requirements, including 

deviations attributable to upsets, within five (5) working days of such deviation. 

The report shall also include the cause of the deviation(s) and any corrective 

action(s) or preventive measure(s) taken. A copy of the report shall be maintained 

in accordance with Part 111, Condition 1. 

Semiannual Reports: 

(3) The permittee shall submit semiannual reports of the information specified in 

herein by July 30 and January 30 for the preceding six-month period. All 

instances of deviations from permit requirements must be clearly identified in 

such reports and a responsible official must certify all required reports. 
SECTION 3 

PUBLIC NOTICE AND PROOF OF PUBLICATION 
Publ~c Noirce 

Mlwcqq~t'nvironnicntal ()ual~t> I'crtntt Hoard 

I' 0 llttx 1?61 

Jackson, MS 19125 

1 clephone No (60 1 ) 96 1 -5 17 1 

Public Notice Start Date: lune 16. 20 10 

Ikadfine For C~cimment: July 15,2010 

MDEQ Contact: C'aria Rrown 

Mississippi Phosphates Corporation (MPC.:), located at 60 l tiighwdy 6 1 1 in Pascagoula. MS. f 228) 762-32 10. has 

applied to the Mississippi Ikpartrnent of L:nvirimmetrtal Oualit) for the hllowing permitting action: issuancc of a 

Prevention of Significant Detcriorntion (PSD) IWnit to (.onstrnct. Air Ref. No. 1280-00044. I'hc :rpplicont's 

operations fall within SIC: ('ode 1874 for Phosphatic Fertili~ers. 

MPC.' manul:dcturcs diarnnionium phosphate (DAP) fertilixer hy reacting wlfuric acid made on-sitc with phosphate 

rock to protlucc phmphtrric acid. The phosphoric ;icitl is then reiictcd with anlnionta to pri>duce 1)AY. MYC is 

proposing extensive upgrades and non-routine repairs and rnaintenancc to the two sulfuric acrd plants. I hcse 

rnvdiftcatiorls will not result in an increased capacity at the sulfuric acid plants but will allow far more reliable 

operation of the plants. MPC cvaluatcd the potential emisions incrcaws from thcse moditications to the sulfuric 

acid plantc and determined that increases of dfiir dioxide and sulfuric acid mist would be abovc the PSI1 

significant thresholds of 40 tons per year for sulfttr dioxide and 7 tons per year for sulfuric acid mist. Therefore. 

MPC perfbrnied n Best Available Control 'I'echnology (UAC'I') analysis to determine the rippropriate control 

technology(ies) and emission linlitations for the project. k1PC also cubmitted a Source Impact Analysis sho\sing that 

the project would not have ;in adverse impact on air quality. vegetation and soils, and visibility. 

'Fhe I'SD regulations set certain requirements on the permissible increme~ital impact on air quality and the dcprce of 

contrrrl of.;rir contmninants. which havc hccn reviewed for compliance with those regulations The prqject will tte 

located in a PSI) Class f i area and the Ihllowing consutnption of air quality increments is predicted to occur, 

Sulfur Dioxide 

Annual 0.92 micrograms per cubic meter or 

4.6% of the 20 micrograms per cubic meter increment. 

?&hour I 46 micrograms per cubic meter or 

I 6% of the 91 micrograms per cubic meter increment 

3-hour 4.52 micrograms per cubic meter or 

0.8S0/b of the 5 I2 micrograms per cubic increment 

'l'hc staR'of the Permit f3oard has developed this draft permit based on inforn~ation submitted to the Permit Board by 

the applicant, appropriate State and Federal agencies and other interested parties. fhe staff of the Permil f3oarcI is 

soliciting all relative information pertaining to the proposed activity, including public comment, to ensure that the 

final staff recomtnendation on the draft permit cotnplies with a11 State and Federal regulations. Public review and 

coniment on the draft perniit and supporting documentation is an important elemcnt in the staff evaluation and 

resulting recommendation to the Permit Board. The draft permit conditions have been developed to ensure 

cornpliatice with a11 State and Federal regulations but are subject to change based on information received ;is a result 

of public participation. 

Persons wishing to comment upon or object to the proposed determinations are invited to submi( comments in 

writmg to Carla t3rown at the Pemiit l3oard's address shown above. no later than July 15. 2010 A11 comments 

receivcd by this date will be considered in the formulation of final determinations regarding the application(s1. A 

public hearing will be held if the Permit Board finds a significant degree of public interest in the proposed prn~it(s). 

I'he Permit Board is limited in the scope of its analysis to environmental tmpact. Any comments relative to zoning 

or economic and social impact5 are within the jurisdiction of local zoning and planning authorities and should be 

addressed to them. 

Additional details about the application(s). incluciing a copy of the draft permit(s). are available hy writing or calling 

Edna Ranks at the above Permit bard address and telephone number. Additiottaily, as a courtesy. fur those with 

Internet access, a copy of the proposed draft ptrmit(s) mag he found on the Mississippi Department of 
Environmental (Suaiity's website at: http:.'/opc.dey.state.ms.us~rcp~~rt public notice.aspx. This infortnation is also 

available for review at the fclllow~np locatmisf during normal busitws hours: 

Mississippi fkpartment of F,nvir.on~nental (Juality 

Office of Polltition C'cx~trol 

MDEQ S I5 E. Amite St 

Jackson, MS 3920 I 

I'ascagoula Public Ltbrary 

32 Id f'ascagot~la Street 

Pascagoula, MS 39567 

Plcase bring the fbrcgoing to the attcntm of pcrsons whom you know will be intcrcsted. 
PROOF OF PUBLICATIWEIVED ., 

STATE OF MISSISSIPPI ,~UN ') 1 

COUNTY OF HARRISON r ,, ,,~,,~rrmental Qualrty 

&lice of Pollution Control 

Before me, the undersigned Notary of Harrison County, 

Mississippi personally appeared p- 4kkg2C4g2Cwho, being by me first duly sworn, did depose and say that she is a 

clerk of The Sun Herald , a newspaper published in the city 

Gulfport , in Harrison County, Mississippi, and the publication 

of the notice, a copy of which is hereto attached, has been made 

in said paper \ times in the following numbers and on the 

following dates of such paper, viz: 

Vol . No,. --_- dated day of ,20___ 

Vol . No., - dated day of ,20- 

Vol . NO., --.- dated day of ,20- 

Voi . NO., - dated day of ,20- 

Vol . No., - dated day of ,20- 

Vol . No., - dated day of .20- 

Affiant further states on oath that said newspaper has been 

established and published continuously in said country for a period 

of more than twelve months next prior to the first publication of said 

notice. 

dUN 1 4 2010 

Clerk 

Sworn to and subscribed before me this 1 k~ day of 

-x-U~z , A.D., 20 l 0 
LEGAL AFFIDAVIT 

Account Number 1007381 

Ad Numbsr 0001643808 /" 

Pertod Endmg 6/16/2010 12 00 01 AM 

MISSISSIPPI DEPARTMENT OF 

ENVIRONMENTAL QUALITY 

ATTN: lNVOlCESlLlNDA STANFORD 

P. 0 BOX 2369 

JACKSON, MS 39225 

Name MISSISStPPI DEPARTMENT OF ENVIRONMENTAL 

Saks &&p Christrne Devins 

251-219-5000 

Billmg lnqulrles Please Calk 

9 Press - Regcster 

Lock Box 1712 

. - Mobfie, AL 36633-1712 - -- -- 

....... .. .............................................................. ." . . .............................. ................. 

Date position Description P.O. Number Ad Size Total Cost 

0611 6/20? c / Legals-Mississippi Public Nottce Mississippi Environmental 715 WDS 85.80 

Mee~a Carlson bemg sworn, says that she IS bookkeeper of 

Press-Reg~ster wh~ch publffihes a daily newspaper in the 

Ctty of Pascagoub and County of Jackson, State of 

Misscss~pp~ 

and attached not~ce appeared In the cssue of 

Mtss~sstpp~ Press0611W2010 

.- 

2010 

fLh&k 

Sworn to and subscribed before me thts 16th day of June 

J 

FOR QUESTIONS CONCERNtNG THIS AFFIDAVIT, 

PLEASE CALL MECIA CARLSQN AT (251) 219-5418. 

YOU CAN PLACE A LEGAL NOTtCE BY EMAlL OR FAX: 

MSLEGALS@PRESS-REGISTER,COM OR FAX# (251) 

2 19-5037 

mg dnnvn~ntal no rr a, aRmr(an( rltmmt In 

the stdl craivldlon ant iw(bn9 mwfmtrdr trm. to the Pernut Wd Ik drfl oermO cw 

pants MPC euaiiste3 thr emuj ernmom &wing a cw of th~ drafl irrrm st arc man irrreaxs tor: Ibw mdi&%otx to fit sw aje by witw or (dgt ~dna(Ba;~o at the fsm Ard manis ad dPfermioed th3f mcrcme5 &YC Pcrlmt kd &LIs &Id 

11 uPgetatmnmdso4r and vui0lbty % b rtguratiMLI set c&aa rcquvcmenlr hct of POII&MI tan^^ on the wrm- mccementa! ,rnm on ar WS15 E AmrteSt 

sual~ty and the de ree $1 co*r$i 01 ar Jxhq MS 39Zbl contaminants, whttli !we beer rentwed lor Pam , Pubicitbray CY i~xl wth tbme repa%i,L p-qeci 32i( k%&mU %re& d% lbca!ea i? a PSD lass IT area wd tho PascapauLa !AS 39567 

&rut c~wdc Ancad 0 92 nmoprams Wr wMc mar @ 

4fh of the 20 rmcm~rans veF wb~c mcta in crernent 

29-Mf 146 mkrqramsper euk meter a, 1 bu of ths PI mnogrami pw c&lc meter irr :refmL 

3 Putn 4 52 mwqrams per c9.z meter w Wn of mt 512 mmprurr~ pc? &c lowe 7imt 

iH€ MISSISSIPPI PRESS JdNE lb,2OlO 
~ x June 1 I, 20 10 

$ .i 

Pascagouia Public Library 

7 2 14 Pascagoula Street 

Pascagoula, MS 39567 

Dear 1,ibrarian. 

Re Mississippi Phosphates C'urpc~ration (MPr) 

Drafi PSD Permit Public Notice 

SutfUric Acid Plants Project 

Air Ref No 1280-00044 

Jackson County 

Enclosed is a copy ofthe public notice for comment on the above referenced cnvironn~enlal 

pcrmit Ptease post this notice in your library 

Also, enclosed is a copy of information pertinent to the permit. This information should be kept 

on hand for review by the public until July 15,2010, afier which it may be discarded The public 

may photocopy a11 or any portion of this information, but it should not leavc the library 

Finally, enclosed please find a duplication of this letter with a place for your signature and the 

date acknowledging your receipt of the package and your agreement to carry out our request. A 

self-addressed stamped envelope is enclosed for your convenience. 

We ate attempting to better keep the public informed of and involved in this Office's actions 

regarding environmental permits Since access to the public library is so convenient for so many 

we hope to use thcsc facilities as often as possible Your cooperation in this matter is greatly 

appreciated 

If'vou have any questions, please let me know at (601) 961-5235 

Sincerely, 

Carla Brown, P E. 

Chemical Branch 

Environmental Permits Division 

Enclosures i I 

Received and 

Agreed to By 

&&. LIS u, ~itle AYG~,~'s~~-T Date -& -22 -1 0 

'i->c Qa Ti13 

2068 PER20090002 PSD 

OFFICE OF PO1.LLJTION CONTROL 

Posr Owct Hox 2201 JACK~HV, Mruiuwrt 39225-2261* Tu: ((dl} 961-5171 FAX: (601) 354 -6612 ww.dcq.srare.mr.us 

AN EQLAL OPPORTUNITY EMPI OMH 
SEC'TION 4 

TRANSMITTAL LETTERS TO EPA AND .JIfRISDICTIONAI, BODIES 
STATE OP MISSISSlPPI 

HNEY RARBC)UR 

GOVERNOR 

MLESISSIPPI DEPARlUENT OF ENVIRONMENTAL QUm 

Tnuuv D. FISHER, EXECL~V~ DIRECTOR 

June 11,2010 

Mr. Thomas McKiernon 

Vice President 

Mississippi Phosphates Corporation 

PO Box 848 

Pascagoula, IMS 39568-0848 

Dear Nr. McKiernon: 

Re Mississippi Phosphates Corporation (MPC) 

Draft PSD Permit Public Notice 

Sulfiric Acid Plants Project 

Air Ref. No. 1280-00044 

Jackson County 

EncIosed are the public notice, draft permit and rationale for the above referenced permit. If you 

have not already done so, you are invited to submit written comments by no later than Juiy IS, 

20 10. A decision regarding the proposed permit(s) will be made after all public comments have 

been duly considered 

If you have any questions, please contact me at (601) 961-5235 

Sincerely, A 

Carla Brown, P E. 

Chemical Branch 

Environmental Permits Division 

Endusures 

cc: Samuel Cunningham, MPC 

Michael Caples, Butler Snow (via e-mail) 

Dwight Wylie, Eco-Systems (via e-mail) 

2068 PER20090002 PSD 

OFFICE OF POLLUTION CONTROL 

POST OFFICE BOX 2261 JACKSON, MISSISSIPPI 30225-2261. TEL (601) 961-5 171 FAX: (G01) 354-6612 w.dq.state.ms.us . ..- n - 
June If. 2010 

Jackson County Chancery Clerk 

PO Box 998 

Pnscagmla, MS 39567 

Dear Sir. 

Re: Mississippi Phosphates Corporation (MPC) 

Draft PSD Permit Public Notice 

Sulkric Acid Plants Project 

Air Ref No. 1280-00044 

Jackson County 

Please post the enclosed public notice in your courthouse on or before June 16, 2010. 

If you are unable to do so or if you have any questions, please contact me at (601) 961-5235 

Carla Brown, P.E. 

Chemical Branch 

Environmental Permits Division 

2068 PEW0090002 PSD 

OFFICE OF POLLUTION COhTROL 

POST OFF~CE BOX 2261 JACKXIH, MISSISS~PPL 39225-2261* TEL: (601) 961-5171 F,w (601) 354-6612 u~nu.dcq.ztarc.rns.m .. "-. - - 
Enclosures 

June 11,2010 

Pascagoula Public Library 

32 14 Pascagoula Street 

Pascagoula, MS 39567 

Dear Librarian: 

Re Mississippi Phosphates Corporation (MPC) 

Draft PSD Permit Public Notice 

Sulfuric Acid Plants Project 

Air Ref No. 1280-00044 

Jackson County 

Enclosed is a copy of the public notice for comment on the above referenced environmental 

permit. Please post this notice in your library. 

Also, enclosed is a copy of information pertinent to the permit. This information should be kept 

on hand for review by the public until July 15, 2010, after which it may be discarded. The public 

may photocopy all or any portion of this information, but it should not leave the library. 

Finally, enclosed please find a duplication of this letter with a place for your signature and the 

date acknowledging your receipt of the package and your agreement to carry out our request. A 

self-addressed stamped envelope is enclosed for your convenience. 

We are attempting to better keep the public informed of and involved in this Ofice's actions 

regarding environmental permits. Since access to the public library is so convenient for so many 

we hope to use these facilities as often as possible. Your cooperation in this matter is greatly 

appreciated. 

If you have any questions, please let me know at (601) 96 1-5235, 

Sincerely, 

Carla Brown, P.E. 

Chemical Branch 

Environmental Permits Division 

2068 PER20090002 PSD 

OFFICE OF POLLUTION CONTROL 

Pm-r OFFICE BOX 2261 JACKSON, MISSISSIPPI 39225-22610 TEL: (601) 961-5171 Fnx: (601) 354-6612 www.dq.am.ms.us ... "- - - 
STATE OF MISSISSIPPI 

HNEY BARBOUR 

(~?~RNoR 

,!mm.SSIPPI DEPARTMENT OF ENVLROIWENTAL QUrn 

TRUDY D FISHER, EXECIWF DIREOR 

June 1 I, 2010 

Postmaster 

Pascagoula, hlissi ssippi 3 9567 

Dear Postmaster: 

Re: Mississippi Phosphates Corporation (MPC) 

Draft PSD Permit Public Notice 

Sulhric Acid Plants Project 

Air Ref No. 1280-00044 

Jackson County 

Please post the attached public notice in your post ofice on or before June 16,2010. 

If you are unable to do so or if you have any questions, please contact me at (601) 961-5235. 

Sincerely, 

Carla Brown, P E. 

Chemical Branch 

Environmental Permits Division 

Enclosure 

2068 PER20090002 PSD 

OFFICE OF POLLUTION CONTRCX 

POST OFFICE BOX 2261 JACKSON, MISSISSIPPI 39225-2261, TEL: (601) 961-5171 FAX: (601) 3546612 www.dcq.wate.ms.us A *. 
STATE OF MISSISSIPPI 

HALEY BARBO~IR 

G~VFRUOR 

MlssfSSIPPI DEPARTMEMT OF ENVIRONMENTAL QUm 

TRUDY D FIFHFR. FYK~ DIRFCTUR 

June 11,2010 

City of Pascagouia 

PO Drawer 908 

Pascagoula, MS 395680908 

Honorable Mayor: 

Re: Mississippi Phosphates Corporation (MPC) 

Draft PSD Permit Public Notice 

Sulhric Acid Plants Project 

,4ir Ref No. 1280-00044 

Jackson County 

Enclosed is a copy of the public notice for comment for a Prevention of Significant Deterioration 

Construction Permit requested by the above reference facility. 

If you have any comments concerning the contents of the draR permit, please notifjl- this office in 

writing no later than July 15, 2010. If you would like to contact me to discuss any of these 

concerns, please call me at (601) 961-5235. 

Carla Brown, P.E 

Chemical Branch 

Environmental Permits Division 

Enclosure 

1068 PER20090002 PSD 

OFFICE OF POLLUTION CONTROL 

POST ~mCE Box 2261 JACKSON, MISSISSIPP~ 39225-226Cll- TEL (601) 961-5171 FAX (601) 354-6612 mw.dq.aare.m.ur . .- - 
June 11,2010 

Jackson County Board of Supervisors 

PO Box 998 

Pascagoula, MS 39568 

Dear Sirs: 

Re: Mississippi Phosphates Corporation (WC) 

Drafl PSD Permit Public Notice 

Sulfbric Acid Plants Project 

Air Ref. No 1280-00044 

Jackson County 

Enclosed is a copy of the public notice for comment for a Prevention of Significant Deterioration 

Construction Permit requested by the above reference facility. 

If there are any questions regarding this matter, please contact me at (601) 961-5235 

Carla Brown, P.E. 

Chemical Branch 

Environmental Permits Division 

Enclosure 

2068 PER20090002 PSD 

OFFICE OF POLLUTION CONTROL 

POST OFFICE BOX 2261 JKWN, MISSISSIPPI 39225-2261-TEL: (601) 361-5171 FA^. (601) 354-6612 www.deq.scare.ms.us 
;, Z *- Carla To shlegals@sunherald.com, 

I r"c*,e5 B~Qw~~EPD~OPC~DEQ e * mslegais@them~ss~ssipprpress corn 

*** 06/51/2010 17 01 PM cc Lmda StanfordlOPC/DEQ@DEQ, Carla 

Brow~PDIOPCIDEQ~ 

bcc 

Subject notice for legals .section 

Please publish the attached notice in the legals section of your newspaper on or before June 16, 2010 

Please provide a statement and proof of publication and also a cover invoice indicating the following 

information: 

"your newspaper's name and mailing address, 

* the date the public notice was actually published, 

"the referenced facility name, and 

* the amount charged for the ad. 

The invoice and proof of publication should be sent to MDEQ, PO Box 2369, Jackson, MS 39225. If you 

have any questions or any problems with the attachment, please 1st me know. 

Thank you! 

Carla Brown, P.E. 

Environmental Permits Division 

Office of Pollution Control 

Mississippi Department of Environmental Quality 

P.O. Box 2261 

Jackson, MS 39225 

Mlssisspp Phosphates Pubkc Notice doc 
Carla-Brown@deq.state.ms To Carla_~Brown@deq.state.ms.us 

CC 

06/11/2010 07.38 PM 

Please respond to kc I Carla-Brown@deq.state ms.u Subject EPA/MDEQ PSD Draft Permct enReview (Mississippi 

Phosphates Corparatlon) 

PSD Notice 

The Mississippi Department of Environmental Quality has prepared a draft PSD permit for the facility 

identified below. A copy of this draft permit and other relevant documents can be viewed using the 

following link. 

Permit No. 1280-00044. 

Additional facility information can be viewed at: Mississi~pi Phos~hates Cor~oration. 

A summary of all PSD applications under review in Mississippi can be viewed at: MDEQ PSD enReview. 

Facifity Name: Mississippi Phosphates Corporation 

City: Pascagoula 

County: Jackson 

Please contact the permit writer, Carla Brown ((601) 961-5235 / Carla-Brown@deq.state.ms.us), or the 

branch manager, Toby Cook ((601) 961-5067 / Toby-Cook@deq.state.ms.us). for additional information 

or if any of the associated documents are not available. 

Recipients: Carla-Brown@deq.state.ms.us, Toby~Cook@deq.state.ms.us, 

brute-ferguson@deq.state.ms.us, Krivo.Stanley@epa.gov, adams.yolanda@epa.gov, 

abrams.heather@epa.gov, forney.kathleen@epa.gov, Jill-Webster@fws.gov, chuber@fs.fed.us 

This emaii was el~~frontcally generated on F~ 1 I-hn-2010 19:00:24 and is intended fo comp/ete the 

notification requirements under 40 CFR 52.21(p)(l) adopted by reference in Mississippi Commission on 

Envifonmental Qualrty Regulation APC-5-5. 
SECTION 5 

ACKNOWLEDGEMENTS RECEIVED 

(Comments from only EPA were received.) 
*\@ =4** 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

July 15,2010 

Carla Brown, P.E. 

Environmental Permits Division 

Office of Pollution Control 

Mississippi Department of Environmental Quality 

P.O. Box 2261 

Jackson, Mississippi 39225 

Dear Ms Brown: 

Thank you for sending the preliminary determination of a Prevention of Significant 

Deterioration (PSD) permit application for a proposed project at Mississippi Phosphates 

Corporation (MPC), located at 601 Highway 61 1 in Pascagoula, MS. The facility has applied to 

the Mississippi Department of Environmental Quality for a PSD permit to modify their two 

sulfuric acid plants. The proposed project will result in significant net emissions increases of 

sulfur dioxide (SO2) and sulfuric acid mist (HzS04), above the significant thresholds established 

in the PSD regulations. The permit application is identified as Air Ref. No. 1280-00044. 

The Region 4 office of the U.S. Environmental Protection Agency (EPA) has reviewed 

the permit application, and has the following comments: 

1. BACTBART Determination: 

MPC proposes best available control technology (BACT) and best available retrofit 

technology (BART) to be the existing dual absorption system and replacement of vanadium 

catalyst with cesium catalyst in the 3rd and 4* converter passes, yielding emissions of 3.0 lb 

Salton of 100% HzS04 produced (3-hr rolling average, determined hourly), not to exceed 225 

lb/hr (24-hr rolling average, determined hourly) and 1700 TPY (365day rolling total, determined 

daily. The Mississippi Department of Environmental Quality believes that these BACTlBART 

limits are consistent with BACT determinations for other sulfbric acid plants, taking into account 

the current design of the MPC sulfuric acid plants. 

EPA notes that there are numerous recently permitted Sulfuric Acid plants recently 

permitted in the 1.5 to 2.5 lb S02/ton of 100% H2S04 produced (3-hr rolling average, determined 

hourly) range. What appears to distinguish this plant from these others is the 212 pass 

configuration in the design of this facility. We recommend strengthening the record for this by 

providing additional documentation, such as engineering technical analyses or operations 

modeling analyses, to support that this facility is limited to being able to meet 3.0 lb S02/ton of 

100% H2SO4 produced (3-hr rolling average, determined hourly). 

Internet Address (URL) http:l/w.epagov 

RocycledlRocyclablm. Piinled wlth VegetaMe 08 Based Inks on Wded Paper (l&nhurn 30% Postcon. 
2. monitor in^ and record keep in^ requirements: 

We note that the permit requires the permittee to use the continuous emissions 

monitoring system (CEMS) consistent with the requirements of the new source performance 

standards (NSPS), and to maintain electronic records of all CEMS data and data used to convert 

SO2 emissions to units of lblton, electronic records of the average hourly SO2 emission rates in 

lblton, the total hourly SOz emission rate in lbh, and the calculated 3-hr rolling average SO2 

emission rates in lblton and lbh. The permittee is also required to calculate and record the daily 

SO2 emissions in todday and the rolling 365-day total SO2 emissions in TPY. Unfortunately the 

NSPS provisions for monitoring for sulfuric acid plants date back to 1980. They do not reflect 

improvements made in specifying how to best monitor and maintain records and do not include 

adequate procedures for performing annual and daily tons calculations. We suggest you update 

the requirements to better reflect today's technology and address the methodology for calculating 

compliance with a todday and the rolling 365-day total SO2 emission limit. As examples of 

more recent monitoring and recordkeeping provisions which would we believe would be more 

appropriate for this facility, we suggest you consider relevant provisions of EPA's acid rain rules 

40 CFR part 75 - particularly, the requirements for installation, certification, operation, and 

maintenance of SO2 CEMS and continuous flow rate monitoring systems in $75.10(a)(l); the 

performance, quality assurance, and quality control requirements in $75.10(b); the hourly 

operating requirements in $75.1 O(d); the measurement requirements in $75.10(f); the 

recordkeeping and reporting requirements in 575.10(g); and the monitoring plan requirements in 

$75.53(a)(2); 575.53(b); $75.53(e)(l)(i)(A) and (E); $75.53(e)(l)(iv)(A), (C), (F), and (G); 

$75.53(e)(l)(x); Ij75.53(e)(l)(xiv); and $75.53(e)(2). 

If you have any questions about these comments or require additional information, 

please contact John Calcagni at (919) 541-9775 or Heather Abrams at (404) 562-9185. 

Sincerely, 

4wq.9 ' Gregg M. Worley 

Chief 

Air Permits Section 
SECTION 6 

RESPONSE TO EPA's COMMENTS 
August 26,201 0 

Mr. Gregg Worley 

Air Permits Section 

U.S. EPA, Region 4 

Atlanta Federal Center 

6 1 Forsyth Street SW 

Atlanta, Georgia 30303-3 104 

Dear Mr. Worley: 

Re: Mississippi Phosphates Corporation 

Response to EPA Comments on MPC PSD 

Air Ref. No. 1280-00044 

Jackson County 

Thank you for providing comments dated July 15,2010, on the proposed PSD permit for 

Mississippi Phosphates Corporation (MPC). We have taken these comments into consideration 

and made changes to both the explanation of the BACTBART determination and the monitoring 

requirements of the permit. The BACTBART determination was revised to better justify the 

emission limits in the permit by adding more detailed information regarding the difference in 

MPC's sulfuric acid plant configuration and the configuration of most other plants such that 

these plants are able to achieve lower SOz emission rates. 

The PSD permit was initially revised to incorporate extensive language regarding SO2 CEMS, 

continuous measurement of exhaust gas flow, and requirements for a monitoring plan. The 

proposed language was emailed to both Heather Abrams and John Calcagni, as well as to MPC, 

for their review and comment a few weeks ago. After conversations with MPC, MDEQ has 

decided to revise the language yet again to require continuous monitors for both SO2 emissions 

and exhaust flow and to require hourly determinations of sulfuric acid production. However, 

instead of going into great detail about the requirements for these monitoring systems, the permit 

requires that MPC submit an extensive monitoring plan for MDEQ's approval prior to 

completing the permitted construction activities. MDEQ believes this is the best approach given 

the extent of uncertainty surrounding the exact specifications for installing, operating, and 

maintaining a continuous monitoring system and the likelihood that providing a great level of 

detail at this time would warrant future modifications to the PSD permit. This revised language 

was also provided to Heather Abrams and will appear in the final permit which should be 

received by your office shortly. 
Again, we do appreciate the technical oversight and input EPA has provided during this 

permitting process. If you have any questions regarding the responses above, please contact me 

at (601) 961-5235. 

Sincerely, 

Carla Brown, P.E. 

Chemical Branch 

Environmental Permits Division 

cc: Ms. Heather Abrams, EPA Region 4