TO: Tina Ndoh and Keith Barnett, EPA

FROM: ERG

DATE: February 2, 2015

SUBJECT Notes from meeting between EPA and PCS Aurora

Summary :

A meeting was held at EPA

- RTP to discuss PCS Aurora’s unique gypsum stack rotation operations and management syste m , and how the proposed definitions (i.e.

, ‘closed gypsum dewatering stack’ versus ‘ a ctive gypsum dewatering stack ’; and ‘new source ’ vs. ‘existing source ’) and requirements in the proposed rule m ay apply to the system.

Names of participants :

• Tina Ndoh

– EPA/ OA QPS

• Keith Barnett

– EPA/ O AQPS

• Tom Walton

– EPA/OAQPS

• Ann Johnson

– EPA/ OP

• Terrence Lee Baker

– PCS Aurora

• Susan M. Jordan

– PCS Aurora

• Ross M. Smith

– PCS Aurora

• Judith Ann George

– PCS Aurora (internal council for PCS Aurora)

• Charles T. Wehland

– Jones Day (external council for PCS Aurora )

• Jason Renzaglia

– ERG

Topic s of discussion:

1. EPA and PCS Aurora discussed matters regarding their unique gypsum stack rotation operations and management system. These matters were previously addressed in PCS

A urora’s comments which are included in the docket, except for the following:

• Details of the functionality related to PCS Aurora’s gypsum stack rotation operations and management system was discussed

, including how the system

interacts with their mine pit

.

• Characteristics of the PCS Aurora mine were discussed, including how it is unique to other phosphate ore mines. The PCS Aurora facility has been issued a mine permit that requires gypsum reclamation.

• An aerial photo was provided by PCS that illustrates th e gypsum stacks at PCS Aurora facility (refer to page 3 below)

. The aerial photo shows gypsum s tack s #4, #5, #6 make up PCS Aurora’s gypsum stack rotation operations and management

system. The status of PCS Aurora’s gypsum stacks as depicted in their aeria l photo is as follows:

o Gypsum Stack #6

– receiving gypsum

Page 1 of 3o Gypsum Stack #5

– supplying gypsum for mine reclamation

o Gypsum Stack #4

– in process of being dewatered

• PCS Aurora pointed out that they are concerned about triggering the proposed regulation for a ‘new source’ each time they rotate the functionality of their three gypsum stack sites . For example, PCS Aurora is currently in the process of rotating their stacks such that Gypsum Stack #5 would be the receiving, Gypsum

Stack #6 dewatering, and Gypsum St ack #4 supplying gypsum for mine reclamation. During this rotation, the company is concerned that Gypsum Stack #5 would be considered a ‘new source’, which would trigger the ratio requirement under the proposed rule.

• Two potenti al options were discussed th at c ould allow for gypsum dewatering stack sites to be used for reclamation and not trigger the proposed requirements

for a “new” gypsum dewatering stack:

o PCS Aurora confirmed that the location and size of the footprint for each gypsum stack in their rotat ion o perations and management system do es not change. The proposed definition of “existing” gypsum dewatering

stack could be revised to incorporate the concept of existing acreage/footprint.

o PCS Aurora confirmed that they would be required to obtain a per mit to construct a new gypsum stack. The proposed definition of “new” gypsum dewatering stack could be revised to include permitting language so that any existing permitted gypsum dewatering stack could not trigger “new”.

2. EPA d iscussed the process it use s for addressing comments

.

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