### STATEOF MISSISSIPPI HALEY BARBOUR GOVERNOR MlssISSIPPI DEPARTMENTOF ENVIRONMENTAL QUM TRUDY D. FISHER,EXECUTIVE DIRECTOR May 9,2011

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 aretransmitting, under separate cover, additional copies to Dick Schutt ofyour agency. We certify that this SIP revision has been completed in accordance with the Mississippi Administrative Procedures Act andthe 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 ofthese 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 subjecttothe 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 ofthis and are currently working with them to set a timeline for submittal ofthe 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 POSTOFFICE BOX 2261 JACKSON, MISSISSIPPI 392252261. TEL: (601) 961-5171 FAX:(601) 354-6612 www.deq.state.ms.us AN EQUAL OPPORTUNITY EMPLOYER

### Regional Haze SupplementalSIP 

### 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, 2011, 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 (SIPNarrative).
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 onpage 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 lbhand 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. (601)961-5 171 Public Notice Start Date: February 1,2011 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

PERSONALLYappeared befofe me, the undersigned notary public inand for Hinds County, Mississippi, QLORIA JOINER
C5WQ 4 an authorizedclerk of THE CLARIONIEDGER,a MS

### DEPT.OF ENV. QUALITY, newspaperas defined and prescribedin Sodons 13-3-31 0200344422 and 13-3-32, of the MississippiCode of 197 2, as amended, Regional Haze SupplementalPublic Notice who, beingduly sworn, states that 

### the notice, a 

### true copy of which 

### is heretoattached, appeared Inthe issuesof said newspaperas

### fdowrr:

Size: 369words 12.00 col. x 58.00lines Published: 1time@)

Authorized C of The Clarion-Ledger SWORNto and subscribed before meon 2/1/201?. 

# ./i< f luK ' I?, 

## 7 Notary Public c i RICKTYLER Notary Public Stateof Mississippiat 

### Large. Bonded

### thru Notary Public UndetwritersAddendum 5 Response to Comments regarding the Supplemental Information submitted on March 

### 3, 201 1 by the U.S. Fish and Wildlife Service. Seenext 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. Thejustification 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 SulhcAcid 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

# ofthe Interior
HSH AND

### WILDLIFE SERVICE

NationalWildlifeRefuge System Branch ofAir Quality
IN REPLYREF~R TO: 7333W. JeffersonAve., Suite375 Lakewoad. CO80235-2017



### 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 itsproposal to improve air quality regional haze impacts at mandatory Class 

### I areas 

### across your region. We appreciate the opportunityto work closely withthe Statethrough 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 ofourmost 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 tothe Mississippi Regional Haze State Implementation 

### Plan (SIP). The FWSprovided 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 commentsto 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
MicheleNotarianni 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 73159
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 SupplementalInformation
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 SO2per ton of sulhricacid produced, not to exceed 225 lbh and 1700 tonslyear. This is consistent with the recommendation made by the FWS inprevious 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 SO2per 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 onnitrogen oxides (NO,) emission limit. The current SIP revision does not discuss enforceable limits for NO,, particulates or sulfuric acid mist. Otherphosphate facilities have reasonably meet a NO, limit of0.1 1 -0.12 lblton of H2S04 product. Likewise, a 10% particulate matter opacity limit often is achievable. The sulfuric acid mist limit for diarnmoniumphosphate1monoammonium 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 WildernessArea 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 determinationprotocol.
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 ofhaze 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 

# 9 control. In the previous FWS comments sent to MDEQ, several reasonably priced control options were identified. These options included: fuel switching and/ora spray dry absorber for SO2control and low NO, burners forNO, 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 overthe improvements already attained through the refinery consent decree. A more robust cost analysis continues to be lacking in the SIP.



## ' See Department ofthe 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 ofthe 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. 11.10 (Attached) which contains the Final Determination document which includes the Permit to Construct for Mississippi Phosphates Corporation to the 

### SIPNarrative.

### 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

"SulfuricAcid Plant Reliability and Upgrade Project " 

# ToModzhAir 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 andJurisdictional Bodies

# ...................................... Section 4 

### Ackowledgments Received

# .................................................................................. Section 5 

### Response to Comments

# ........................................................................................ Section 6SECTION 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 1on 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 SO2gas 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 ofthe absorber, while the exhaust gas exiting the top ofthe 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 ofthe 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 SO2and 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 sourcesto 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. BestAvailable 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 WorkshopManual (Draft 1990),the PSD applicant goes through a five-step process to determine BACT: 

### (I) IdentifLall 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 

# ---- NfA 

## ----- 0 NO No N/A

188.4 NIA 19.3 Y/A NIA NlA NIAdetermined 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 SO2and HzS04. Therefore, MPC must evaluate BACT for both sulfuric acid plants.

A. SO2 Analysis MPC identified a variety of control technologies for reducing SOzemissions, 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 ofthe project were an attempt made to transfer this technology to the sulfuric acid plants. All forms of wet scrubbing were determinedto 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 ofthe 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 improvethe SO2 to SO3 conversion, including replacement ofvanadium 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 increasingthe 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 ofwhat the converter equipment could safely handle. However, MPC did determine that replacing the vanadium catalyst with cesium catalyst in the 3rd and 4thconverter passes was feasible and would result in a significant reduction of SO2 emissions by resulting in higher conversion of SOzto SO3in 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 3rdand 4" converter passes, yielding emissions of 3.0 lb of SOzper 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 converterdesign that will not be modified within the scope ofthis project. The 212 converter design has only two catalyst passes through the converter to achieve the SOzto 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 SO2in the exhaust compared to the exhaust from a 212 converter design. A new 311 converter can achieve SO2emission 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 AcidMist 

## (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. SourceImpactAnalysis 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 ofrecord of meteorological data, and 3) the averaging time ofthe standard being analyzed. When the analysis is based on 5 years ofNational 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; andFor 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 51 (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 (1991to 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 alsoprocessed using the surface characteristics ofthe 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 100meter intervals along the fence linelpatrolled property line and out to a distance of2 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 10to 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 ofdetermining whether emissions of that pollutant would cause or contribute to a violation ofthe 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

## - Preconstructionde minimuslevels.

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 orNOx emission

increase < 100TPY 575 0.1 Modeled Concentration (yg/m3)

NIA

1.5 NIA N/A
NIA NIAambient 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 ofthe 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-hrNAAQS 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 SOzemissions are decreasing. The increase in the project is due to increased utilization. Since the short-term emission rates are decreasing the project is considered insignificantwith 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 isbelow 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 impairmentto 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 57437.31 I 57431.81



### F. Associated GrowthImpact 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)
flQ7n07 94030224 92031903 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/m3as proposed by the EPA. This level was reached at approximately 5.4 kilometers from the project site, which is well short ofthe 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 asthe Best Available Retrofit Technology (BART). BART is required for SO2emissions 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 51, Subpart P -Protection of Visibility. DEQ considers the BACT determination sufficient to meet the requirements ofthe 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 CEMSto be installed to demonstrate compliance with the SO:, emission limits for each sulfuric acid plant. A SO2CEMS 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 asnecessary to reflect any new H2SO4 control equipment installed aspart ofthis 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 staffofthe 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. 

### Ihis 

### 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 

### 52.21. 

### 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 ofthe 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)) Thepermit 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- 17-21) 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. 49-17-39)
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 (18) months from the date of issuance or if construction is suspended for eighteen (18) 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 ofthe 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, SectionVI.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 andNo. 3 Sulfuric Acid Plants, respectively. The sulfuric acid plants currently have dual absorption systems for control of SOzemissions 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 ofthe 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/tonof 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 1700TPY (365-day rolling total, determined daily)
Sulfuric Acid (~2~04)~ 0.10 lb H2SOdton of 100%H2S04produced (3-hr block average -BACT limit), not to exceed 7.5 lbh (3-hr block average) and 32.85TPY
The emission limitations shall apply at all times, except asprovided 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 SO2TPY 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 SO2emission limitations above for each plant upon certification of construction and startup of the modified converter, including the replacement of vanadium catalyst with cesium catalyst inboth the 3rd and 4th passes. The permittee shall comply with the combined TPY SO2emission 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 eachplant 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 theNew Source Performance Standards for SulfuricAcid Plants (40 CFRPart 60, Subpart H) and the applicable requirements of the General Provisions (40 CFR Part 60, Subpart A). Sulfur Dioxide: Thepermittee 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))
SulfuricAcid 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: Thepermittee shall not discharge into the atmosphere any gases which exhibit 10percent 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 180days 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.
Thepermittee 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 ofthe required test(s).

MONITORING REQUIREMENTS
Sulfur Dioxide: To demonstrate compliance with the SO2emission 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 SOzemissions 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 SO2emission 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 shallbe submittedto 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 SOzlimits for either sulfuric acid plant, whichever date comes first.

### Page 10of 

### 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. Thepermittee shall maintain electronic records of the average hourly SO2emission rates in lblton, the average hourly SO2emission rate in lbh,and the calculated 3-hr rolling average SO2emission rates in lblton and lblhr. The permittee shall calculate and record the daily SO2emissions in todday and the rolling 365-day total SO2emissions 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 ofpermit 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.
Thepermittee 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) orpreventive 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-monthperiod. 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 PUBLICATIONPubl~c Noirce Mlwcqq~t 'nvironnicntal ()ual~t> I'crtntt Hoard I' 0 llttx 1?61 Jackson, MS 19125 1clephone No (601 ) 96 1-5171
Public Notice Start Date: lune 16. 20 10 Ikadfine For C~cimment: July 15,2010 MDEQContact: C'aria Rrown

Mississippi Phosphates Corporation (MPC.:), located at 60l tiighwdy 61 1 in Pascagoula. MS. f 228) 762-3210. 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 fi 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 microgramsper cubic meter increment 3-hour 4.52microgramsper cubic meter or 0.8S0/b ofthe 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 ofpublic 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 ifthe 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 ofEnvironmental (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 locatmisfduring normal busitws hours: Mississippi fkpartment of F,nvir.on~nental (Juality Officeof Polltition C'cx~trol MDEQSI5 E. Amite St Jackson, MS 3920 I I'ascagoula Public Ltbrary 32Id f'ascagot~laStreet Pascagoula, MS 39567
Plcase bring the fbrcgoing to the attcntmofpcrsons whom you know will be intcrcsted.

# PROOF 

# OFPUBLICATIWEIVED

., 

### STATE 

### OF MISSISSIPPI 

### ,~UN ') 

### 1 COUNTY

## OF HARRISON r ,, 

### ,,~,,~rrmental Qualrty &lice of PollutionControl 

### 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 morethan twelve months next prior to thefirst publicationof said notice. 

# dUN 1 4 

## 2010 Clerk Swornto 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 01AM

MISSISSIPPI DEPARTMENTOF ENVIRONMENTALQUALITY ATTN: lNVOlCESlLlNDASTANFORD P. 0 BOX 2369 JACKSON, MS 39225 Name MISSISStPPI DEPARTMENT OF ENVIRONMENTAL Saks &&p ChristrneDevins 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

06116/20? 

### 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 Pascagouband 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) 219-5037 mg dnnvn~ntal no rr a, aRmr(an( rltmmt In thestdlcraivldlonant iw(bn9 mwfmtrdr trm. to the PernutWd Ik drfl oermO cw

pants MPC euaiiste3 thr emuj ernmom &wing a cw of th~ drafl irrrm st arc man irrreaxstor: Ibw mdi&%otxto fit sw aje by witw or (dgt ~dna(Ba;~o at the fsmArd manis ad dPfermioedth3fmcrcme5 &YC Pcrlmt kd &LIs &Id

11 uPgetatmnmdso4r and vui0lbty 

### % 

### brtguratiMLIset c&aa rcquvcmenlr

### hctof POII&MI tan^^ on the wrm- mccementa! ,rnmon 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 wthtbme 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 nmopramsWr wMc mar @ 4fhof the 20 rmcm~rans veF

wb~c mcta in crernent 29-Mf 146mkrqramspereuk metera, 1 bu of thsPI mnogrami pw c&lc meter irr :refmL 3 Putn 4 52mwqramsper c9.z meterw Wnof mt 512 mmprurr~ pc? &c lowe 7imt iH€MISSISSIPPI PRESS JdNElb,2OlO~ x June 1 

### I, 2010

$ .i Pascagouia Public Library 7214 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 isa 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 ofthis information,but it should not leavcthe library Finally, enclosed please find a duplication

### ofthis letter with a place for your signature and the date acknowledgingyour receipt ofthe package and your agreementto carry out our request. A self-addressed stamped envelope is enclosed for your convenience. Weate 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 cooperationin 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

# &&. 

# u, Agreed to By LIS ~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 EQLALOPPORTUNITY EMPI OMHSEC'TION 4

TRANSMITTAL LETTERS TO EPA AND.JIfRISDICTIONAI, BODIESSTATE

### OP MISSISSlPPI HNEY RARBC)UR GOVERNOR MLESISSIPPIDEPARlUENT 

### OF ENVIRONMENTALQUm 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 

### Ifyou have any questions, please contact me at (601) 961-5235 

### Sincerely, A



### Carla Brown, P 

### E. ChemicalBranch 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 POSTOFFICE BOX2261 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 

### courthouseon 

### or beforeJune 16, 2010.


### Ifyou 

### are unable 

### to 

### do soor 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 BOX2261 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 tothe 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 orany portion ofthis 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 ofthe 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 regardingenvironmental permits. Since accesstothe public library is so 

### convenient for so many we hopetouse 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 PermitsDivision

2068 

### PER20090002 

### PSD
OFFICE OF POLLUTION CONTROL Pm-rOFFICE BOX2261 JACKSON, MISSISSIPPI 39225-22610TEL: (601) 961-5171 Fnx: (601) 354-6612 www.dq.am.ms.us

... "- 

# - -

### STATEOF MISSISSIPPI HNEY BARBOUR (~?~RNoR ,!mm.SSIPPI DEPARTMENT 

### OF ENVLROIWENTAL QUrn TRUDY D FISHER, EXECIWF DIREOR 

### June 1

### I, 2010 Postmaster Pascagoula, hlissi

### ssippi 39567
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 soor ifyou 

### have any 

### questions, please 

### contact me at (601) 961-5235. 

### Sincerely,

CarlaBrown, 

### 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 ENVIRONMENTALQUm 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 ofthe public notice for comment for a 

### Prevention of Significant Deterioration Construction Permit requested by 

### the above reference facility. Ifyou have 

### any comments concerning

### the contents

### ofthe draR permit, please notifjl-this office in 

### writing no later than July 15, 

### 2010. 

### If you would 

### liketo contact 

### me to discuss any ofthese 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 CountyBoard 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 ofthe public notice for comment for a Prevention of SignificantDeterioration Construction Permit requested by 

### the above 

### reference facility.
If

### there are any 

### questions regarding this 

### matter, please contactme at (601) 961-5235



### Carla Brown, 

### P.E. Chemical Branch Environmental Permits Division 

### Enclosure

2068 PER20090002 

### PSD
OFFICE OF POLLUTION CONTROL POST OFFICE BOX2261 JKWN, MISSISSIPPI 39225-2261-TEL: (601) 361-5171 FA^. (601) 354-6612 www.deq.scare.ms.usZ 

### ;, 

## *- 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 noticefor legals .section
Please publish the attached notice inthe legals section of your newspaperon or beforeJune 16, 2010 Please provide a statement and proofof publicationand also a cover invoice indicatingthe following information: "your newspaper's name and mailingaddress, * the date the public noticewas actually published, "the referencedfacility name, and * the amount charged for the ad. The invoiceand proof of publicationshould be sent to MDEQ, PO Box 2369, Jackson, MS 39225. Ifyou have any questionsor any problemswith the attachment, please 1st me know. Thank you! Carla Brown, P.E. Environmental Permits Division Office of PollutionControl MississippiDepartment of EnvironmentalQuality P.O. Box 2261 Jackson, MS 39225

Mlssisspp Phosphates Pubkc NoticedocCarla-Brown@deq.state.ms To Carla_~Brown@deq.state.ms.us
CC 06/11/2010 07.38 PM Please respond to kc Carla-Brown@deq.state ms.u Subject EPA/MDEQ PSD Draft Permct enReview(Mississippi 

# I
Phosphates Corparatlon)



### PSD Notice The Mississippi Department of Environmental Quality has prepared a draft PSD permitfor the facility identifiedbelow. A copy of this draft permit and other relevant documents can be viewed usingthe following link. Permit No. 1280-00044. Additional facility informationcan be viewed at: Mississi~pi Phos~hates Cor~oration.
A summary of all PSD applications under review in Mississippican be viewed at: MDEQ PSD enReview. Facifity Name: Mississippi Phosphates Corporation City: Pascagoula County: Jackson Please contact the permitwriter, 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 associateddocuments 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 Thisemaii was el~~frontcally generatedon F~ 1I-hn-2010 19:00:24and is intendedfo comp/etethe notificationrequirements under40 CFR 52.21(p)(l) adoptedbyreference in Mississippi Commissionon Envifonmental Qualrty RegulationAPC-5-5.SECTION 5

ACKNOWLEDGEMENTS RECEIVED (Comments from only EPA were received.)*\@ =4** 3 UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 

### July 15,2010

CarlaBrown, P.E. Environmental Permits Division Office ofPollution Control Mississippi Department ofEnvironmental Quality P.O. Box 2261 Jackson, Mississippi 39225
Dear Ms Brown: 

### Thankyou for sendingthe preliminary determinationof aPrevention of Significant Deterioration(PSD) permit applicationfor aproposed project at MississippiPhosphates Corporation(MPC),located at 601 Highway 61 1in Pascagoula,MS. The facility

### has applied to the Mississippi DepartmentofEnvironmental Quality for a PSDpermit to modify their two sulfuric acid plants. Theproposed project will result 

### in significant net emissionsincreasesof sulfur dioxide (SO2) and sulfuric acid mist (HzS04), abovethe significant thresholdsestablished in

### thePSD regulations. Thepermit applicationis identified asAir Ref. No. 1280-00044. The Region 4 office ofthe U.S. Environmental Protection Agency (EPA)has reviewed the permit application, andhas the following comments:
1. 

### BACTBART Determination: MPC 

### proposes best 

### available control technology (BACT) and best availableretrofit technology (BART) to be 

### the existing dual absorption system andreplacementof vanadium catalystwith cesium catalyst in the 3rd 

### and 4* converter passes, yielding emissions of 3.0 lb Saltonof 100%HzS04produced 

### (3-hr rolling average, determined hourly), not to exceed 225 lb/hr(24-hrrolling average, determined hourly) and 1700TPY (365day rollingtotal, determined daily. The Mississippi Department ofEnvironmentalQualitybelieves that these BACTlBART limits areconsistent with BACT determinations for other sulfbricacid plants, taking into account the current design of the MPC sulfuricacid plants.
EPA notes that there are numerous recently permitted SulfuricAcid plants recently permitted in the 1.5to 2.5 lb S02/tonof 100%H2S04produced (3-hrrolling average, determined hourly) range. What appears to distinguish thisplant fromthese othersisthe 212 pass configurationin the design of this facility. We recommend strengthening the record for thisby providing additionaldocumentation, such as engineeringtechnical analysesor operations modeling analyses,to supportthat this facility is limitedto being able to meet 3.0 lb S02/tonof 100%H2SO4 produced (3-hrrolling average, determined hourly).

Internet Address (URL) http:l/w.epagov RocycledlRocyclablm. Piinledwlth VegetaMe 08BasedInkson WdedPaper(l&nhurn 30% Postcon.

### 2. 

### monitor in^ and record keep in^ 

### requirements:


### We note that the permit requires the permitteeto use the continuous emissions monitoring system (CEMS) consistentwith the requirementsofthe new sourceperformance standards (NSPS), and to maintain electronic records ofall CEMS data and dataused to convert SO2emissionsto units 

### oflblton, electronic records ofthe averagehourly SO2emission rates in lblton, the total hourly SOzemissionrate in lbh,and the calculated 3-hrrolling average SO2 emission rates in lblton and lbh. Thepermitteeisalso required to calculateand record the daily SO2 emissionsintodday and the rolling 365-day total SO2 emissionsin 

### TPY. Unfortunately the NSPS provisions for monitoring for sulfuric acid plants dateback to 1980. They do not reflect improvementsmade in specifyinghow to best monitor and maintain records and do not include adequate procedures for performing annual and daily tons 

### calculations. We suggestyou update the requirements to betterreflect today's technology and addressthe methodology for calculating compliancewith atodday and the rolling 365-day total SO2emission limit. As 

### examplesof more recent monitoring and recordkeeping provisions which would we believe would

### be more appropriatefor this facility, we suggestyou consider relevant provisions ofEPA's acidrainrules 40 CFR part 

### 75 

## -particularly, therequirementsfor installation, certification, operation, and maintenanceof SO2CEMS and continuous flow rate monitoring systems in $75.10(a)(l); the performance, quality assurance, and quality control requirements in $75.10(b);thehourly operating requirementsin $75.1O(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 questionsabout these commentsor require additional information, please contact John Calcagni at (919) 541-9775 orHeatherAbrams at (404) 562-9185. Sincerely, 

# 4wq.9 ' Gregg 

### M. Worley Chief Air Permits SectionSECTION 6

RESPONSE TO EPA's COMMENTSAugust 26,2010


### Mr. Gregg Worley Air Permits Section U.S. EPA, Region 4 Atlanta Federal Center 61 Forsyth Street SW Atlanta, Georgia 30303-3104

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 SOzemission rates. The PSD permit was initially revised to incorporate extensive language regarding SO2CEMS, 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 asto 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 SO2emissions 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 shouldbe received by your office shortly.Again, we do appreciate the technical oversight and input EPA has provided during this permitting process. 

### Ifyou 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