UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REG IO N S 1445 ROSS AVENUE , S UIT E 1200 DALLAS TX 75202-2733 

# SEP 1- 2015

CERTIFIED MAIL- RETURN RECEIPT REQUESTED: 7011 3500 0000 0360 2165 Mr. Steve J. Susick Ge neral Manager, Louisiana Operations Mosaic Fertili zer, LLC 7250 H ighway 44 Uncle Sam, LA 70792 RE: Clean Air Act Section 114(a) Information Request Mosaic Fertilizer, LLC Uncle Sam Plant Dear Mr

. Susick: Enclosed is an Information Request (Request) issued to Mosaic**Fertilizer~** LLC Uncle Sam Plant under the authority of Section 114 of the Clean Air Act (CAA). The purpose of this Request is to obtain information related to Regional Haze requirements in Louisian a. This facility was identified by th e LDEQ in its 2008 Regio nal H aze State Implementat i on Plan (SIP) as a Be st Avai lable Retrofit Technology (BART) eligible so urce . We understand that your company is working with the State of Louisiana in the de velopment of a SIP, and that what is being requested in this letter may be similar to what yo u are providing to the State. T he EP A is sending a formal Request for information in order to be in a position to develop a Federal Implementati on Plan for Regional Haze f o r Loui s iana should that prove nece ssary. T o assist in thi s process, the EPA i s seekin g informati on regarding the operatio n s at this facility , including a B A RT determination. T he EPA is requesting that a BART analysis be performed in accordance with the BART Guidelines (70 FR 39158-39161 , July 6, 2005) and our regulation s (Section 51.301) 1 in respon se to this Request. En closure 1 contain s instructions and definition s that you sh o uld use to provide the requested in formati on. Enclosure 2 contains the specific li st ofrequeste d i nformati on. Your respon se to this Requ es t must be certifi ed by a duly authori zed officer or agent of your company by signing the en closed Statement of Certific at io n included as Enclo s ure 3 and returning it with your response. All i nf ormation submi tted in respon se to thi s Requ est must b e certified a s tru e, correct , accurate, and complete b y an i ndiv idual w ith suffi cient knowled ge and authority to make such representati ons. Under 40 C.F.R. Part 2, Subpart B, you may assert a claim of bu s ines s confidentiality for any port io n of the submitted information. You mu st spec ify th e page, paragraph , and sentence when identifyin g the information s ubject to yo ur claim. Enclo sure 4 specifies the assertion and s ub stantiati on requirem ents for b usiness c on fid entiality claim s.

1 See 77 F ed Reg . 11 839, at 11848. Intern et Address (URL) • http://www.epa.gov/reg i on 6 Recyc l ed/Re cyc l a b le • Printed Wi th Veg etable 011 Based Inks o n 100% Postconsumer, P rocess Chlorine Free Recycl ed PaperFailure to provide the required information may result in the initiation of a civil action pursuant to Section 11 3 (b) of the CAA, 42 U.S.C. 

### § 7413(b). In addition, knowingly provid in g false information in response to thi s Request may be actionable under Section 113(c) of the CAA, 42 U.S.C. § 7413(c) , and 18 U.S.C. §§ 1001 and 1341. The information you provide may be used by the EPA in administrati v e , civil, or criminal proceedings. The Request is not s ubject to the Paperwork Reduction Act, 44 U.S.C. 

### § 3501 et seq., because it is not a collection of information, as defi ned in 44 U .S.C. 

### § 3502(3). To aid in our electronic recordkeeping efforts, please provide y our response to this Request 

### in electronic format such as Portable Document Format (PDF) , saved to a compact disc or flash drive, rather than hard copy. Please provide the information requested by September 30, 2015 to the address below: Mr. Guy Donaldson (6PD-L) U.S. Envi ronmental Protection Agency- Region 6 1445 Ross Aven ue , Suite 1200 Dallas, TX 752 02-2733 If you have any questions, need to request an extension, or wish to schedule a meeting to discuss this Request, p lease contact Mr. Guy R. Donaldson of my staff at (2 14) 665-7242 or at Donaldson. Guy @ epa.gov.

Enclosures (4) Sincerely,

# ~. Wren Stenger Director Multimedia Planning and

Permitting Division

cc: Ms. Tegan Treadaway, Assistant Secretary Louisian a Department of Env ironmental Quality

### ENCLOSURE 1; Instructions 1. Provide a sep arate narrative response to each question set forth in the Request. Pleas e pro v ide all documents respo n si ve to this Request in electronic format such as Portable Document Format (PDF), saved to a compact disc or flash drive, rather than hard copy. 2. Precede each answer with the number of the question to which it correspo nd s and at the end of each answer identify the p erson(s) that provided information that was used or considered in responding to th at question, as well as each person that was consulted in the preparation of that response. 3. Indicate on each document or e lectronic fi le produced in response to this Request, or in some ot h er reasonable manner, the number oft he question to which it corresponds. 4. When a response is provided in the form of a number, specify the units of measure of the number in a precise manner. 5. When data to be provided exists in electronic sp read sheet format, the data and corresponding information should be provided in editable Excel or Lotus format, and not in image format, such that any original underlying cell formulae are present. 

### IfExce l or Lotus formats are not available, then the format shou ld all ow for data to be used in calculations by a standard spreadsheet program such as Excel or Lotus. 6. When th e requested information included electronic maps of the facility, the map s shou ld be provided in electronic desktop geographical information system (GIS) shapefi les compatib le with ArcView GIS 9.3, in stead of PDF. 7. Each document provided in electronic form, whether image or editab le sp readsheet format, or GIS s hapeti les, must still be provided in accordance with those instructions for submitta l of documents as outlined above (e.g., each PDF document shou ld include all enclos ures/attachments assoc iated with the document, or a reference page added to indicate that a separate PDF document is provided as the encl os ure / attac hment so referenced). 8. For each compact disc, flash drive and/or hard drive containing electronic documents submitted in response to our request, a table of contents for the electronic documents on individual and/or multiple discs/ drives must be provided so that each document can be accurately identified in relation to your response to a spec ifi c question. We recommend the use of file fo lders organized by question number. In additi on , each compact disc, flash drive and/or hard drive should be labeled appropriately (e.g., Company Name, Disc 1 of 4 for Inform ation Request Response, Date of Response). 9. Where documents or information necessary for a response are neither in your possession nor available to you, indicate in your response why such documents or information is not available or in your possession and identify any source that either possesses or is likely to possess such information

. 10. I f any of the above information has previously been provided to the EPA under Section 114(a) of the Clean Air Act (CAA), you may direct us to that specific response in lieu of reproducing that information in responding to thi s information reque s t.

### Definitions All terms used in this R e quest will have their ordinary meaning unless s uch terms are defined in th e CAA, 42 U.S.C. 

### §§ 740 1 et. seq., 40 C.F.R. Part 52 (which incorporate s the Federally -approv e d Sta te Implementation P l an), or other CAA impl ementing regulations. A dditional clarification s are spec ifi ed below. 1. The terms " document " and " documents " sh all mean any object that records, stores, or presents inf ormation , and includes writings, m emoranda , r ecords , or inform ation of an y kind , formal or informal, whether wholly or partially handwritte n or typed, whether in com puter format, memory, or storage d e vice, or in hardcopy , includi n g any form or format of these. If in comput e r format or me mory , each such document shall be provided in translation to a form useable and r eadable by the 

### EPA, with all necessary docume ntation and support. All documents in hard c opy sho uld also include attac hments to or en cl os ures w ith any document

. 

### 2. Th e terms " re late to " (or any form thereof) shall m ean con stitutin g, reflecting, representin g, s upporting, contra di ctin g, referring to , sta t i ng, describing, r eco rdi ng , notin g, embodying, 

### cont aining, m entioni ng, s tudying, analy zing, discussing, evaluating or re levan t to. 3. The term " M osaic " shall mean Mosaic , and all other subsidiaries, past owners/operators, an d re lated entities. 4. The term "Unit " s ha ll mean all equipment used for the purpose o f generating e lectricity incl ud in g , but n ot limited to , coal handling faciliti es , b oilers , ductwork, stacks, turbin es, generator s, and all ancillary equipment. 5. The term , "scrubber , " s hall collectively refer to flue gas desulfurization techno l ogies design e d to remove S02 from exh au st gas streams by reactin g lime , lime stone, or other reagents with the exha u st gas stream. T hi s includes, but is not limited to wet scrubbing, spray dry sc rubbing , dry scrubb in g, · and all varia ti ons of these basic types of scrubbing systems.ENCLOSURE 2: Questions 1. In reviewing the modeling conducted for the BART analy s is submitted to LDEQ on July 17,2015, the EPA identified that the meteorological data set and computati onal grid utilized by Mosaic was not the correct data set to utilize, as it was based on a smaller modeling domain and 4km grid rather than the larger modeling domain and 6km grid consistent with the final Sid Richardson modeling analysis. Please conduct CALPUFF modeling and submit the following modeling runs usin g the final Sid Richardson CALMET files (provided to Mosaic by LDEQ) and the l arger CALPUFF modeling domain to ensure plumes that could transport to Breton stay in the modeling domain.

a. Base case scenario b. Current controls scenario c. Current controls scenario with addition of a scrubber on D Train as d i scussed below. 2. In performing t he five-factor analysis for the D Train controls, Mosaic modeled the base case scenario and the current controls scenario. In identifying the available control options, Mo saic identified a scrubber as a potential control. However , Mosaic did not include an analysis of visibility benefit that could be obtained by installing a scrubber. Please model th e current control scenario with the addition of a scrubber on the D Train to demonstrate the vis ibility benefit achieved by installing a scrubber. The delta-deciview benefit from installation of controls sho uld be included in the five-factor BART analysis evaluating S02 controls for the D Train. 3. Please provide a narrative explanation including supportive information as necessary, for why theE Train is not BART-eligible. 4. The emiss io n rates for S02 and NOx baseline (pre-consent decree controls/ emiss i ons) do not match the values in the LDEQ ' s Regional H aze SIP from 2008 (Table 9-3). The table has emission totals for the BART units at each faci lity and lists Mosaic Uncle Sam as 39.16 tpd of S02 and 3.34 tpd of NOx. The mo de ling for baseline emissions are less than these totals at 35.07 tpd ofS02 and 2.06 tpd ofNOx. Please investigate and provide an explanation of these differences. While the larger emissions will not change the subject to BART decision it will impact the de lta deciv iew analysis between basel i ne and different cont rol s that are evaluated as part of the 5-factor BART analysis. Please provide this information to the EPA for review prior to conducting CALPUFF mod e ling. 5. Pl ease recalculate and submit the cost analysis performed based on a 30 year life rather than a 20 year life. 6. The ozone data u sed for CALPUFF modeling should be hourly monitored ozone data from the years mode led, so the ozone data should be from 2001, 2002 and 2003. A val ue of 80 ppb should be used to fill in for missing data (CALPUFF**~etting** BCK03 = 12*80). The EPA has ozone data files that we will prov i de electronically to Mosaic and their modeling contractors. 7. Please submit a revised 5 factor BART analysis addressing the above concerns.8. Submittal of Modeling Modelin g submiss io n s must include

• Modeling Report and Conclusion s • All mo del i ng fi les M ode lin g fi les must be provided on a hard drive , USB driv e, or electronic ftp, and must include all of the fo llowing file s as app li cab le:

• CALMET output files • CALPUFF input, control, and output file s • POSTUTIL input, control, and output files • CALPOST input, control, and output files • Executab les used.ENCLOSURE 3: Statement of Certification I ce rtify under penalty of law that I have examin ed and am familiar with th e information in the enclosed documents, including all attachments. Based on my inquily of those individ uals with p rimaty responsibility fo r obtaining the information, I certify that the statements and information are to the best o f my know ledge and belie f, true and complete

. I am aware that there are significant penalties for knowi ngly submitting false s tatements and information, including the possibility of fines o r imprisonmentpursuant to section 113(c)(2) of the CAA , and 18 USC.§ § 1001 and 1341.

(Signature)

(Title)ENCLOSURE 4: Con.fidential Business Information (CBI) Requirements Assertion Requirements You may assert a business confidentiality claim covering all or part of the information requested in the attached letter, as provided in 40 C.P.R.§ 2.203(b). To make a confidentiality claim, submit the requested information and indicate that you are making a claim of confidentiality. Any document over which you make a claim of confidentiality should be marked by attaching a cover sheet stamped or typed with a legend to indicate the intent to claim confidentiality. The stamped or typed legend or o ther suitable form of notice should employ language such as "trade secret" or "proprietary" or "company confidential" and indicate a date, if any, when the information should no longer be treated as confidential. Information covered by such a claim will be disclosed by the U.S. Environmental**Prot~ction** Agency only to the extent permitted and by means of the procedures set forth by Sectio n 114(c) of CAA, and 40 C.F 

### .R. Part 2. Allegedly confidential portions of otherwise non-confidential documents should be clearly identified. The EPA will construe the failure to furnish a confidentiali ty claim with your response to the attached letter as a waiver of that claim, and the information may be made available to the public without further notice to you. Certain categories of information outlined in 40 C.F.R. §§ 2.301-2.311, such as emission data and effluent data, or other information that is otherwise publicly available, are not eligible for confident ial treatment. Please segregate personnel, medical, and similar files from your responses and include that information on separate sheet(s) marked as "Personal Pri

. vacy Information" given that disclosure of such information to the general public may constitute an invasion of privacy. Any information not specifically identified as subject to a confidentiality claim may be disclosed to the r equestor without further notice to you. For each item or class of information that you identify as being subject t o CBI, you must answer the following questions, giving as much detail as possible: Substantiation Requirements A ll confidentiality claims are subject to the EPA verification and must be made in accordance with 40 C .F.R. § 2.208 which provides in part that you satisfactorily show that you have taken reasonable measures to protect the confidentiality of the information and that you intend to continue to do so; and that the information is not and has not been reasonably obtainable by legitimate means without your consent. If you f ee. l that some or all ofthe provided information is entitled to confidential treatment, please speci fy which portions of the information you consider confidential. Please be specific by page, paragraph, and sentence when identifying the information subject to your claim. Any information not specifi c all y identified as subject to a confidentiality claim may be disclosed to the public without further n

otice to you. In accordance with 40 C.F.R. 

### § 2.204(e), please answer the following questions , giving as much de tail as possible, for each item or class of information that you identify as being subject to your claim:1. What specific po rtions of the information d o you allege to b e entitled to confidential treatment ? For what peri o d of ti me do yo u request that th e inf orm ation be maintained as confidential, 

### e.g., unti l a certain date, until the occurrence of a specified event, or permanent ly? If th e occurrence of a specific event w ill eliminate the need fo r confide nti ality, please specify that event. 2. Informati o n submitted to the EPA becomes stale over time. Why s hould the information you cl a im as confide ntia l b e protect ed for the time period specified in your answer to question # 1? 3. What measure s have you taken to protect the information claimed as confidential ? Have you disclosed the info rmation to anyone other than a governmen ta l body or someone who i s bound by an agreement not to disclose the informatio n furthe r ? If so, w h y s hould the information sti ll be considered confi d ential ? 4. Is the informatio n contained i n any publicly ava ilable material suc h as the Internet , publicly availab l e databases, promotional p ubli cations, annual report s, or articles? I s th ere any means by w hi ch a member of the publi c coul d obtain access to the information? Is the i nformatio n of a kind that you wou l d customaril y not re l ease to the public? 5. Has any go vernmental body made a determination as to the confidentiality o f the information ? If so, please attach a co py of the determination. 6. For each category of in format i o n claimed as confidential, exp lain w i th specificity why release of the information is likely to cause s ubstantial harm to yo ur competitive position. Explain the spec i fic nature of th ose harmful effects, w hy they sho uld b e view ed as substantial , a nd the ca usal re l ationship between di sclosure and suc h harmful effects. How cou ld your co mpetitors make u se of thi s information to your detriment? 7. D o yo u assert that the inf ormatio n is submitted o n a v oluntar y or a mandato ry basis? Please explain the reason for y our assertion. 

### If you assert that the inform ation i s vo lunta rily submitted informat i on, explain whether and why disclosure of the information would tend to less en th e avai lability to the EP A of simi lar information in the future. 8. If you believe any information to be (a) trade secret (s), p le ase so sta te and exp lai n the reason for your belief. Pl ease attach co pie s of those pages with brackets around the text th at you claim to be (a) trade secret(s). 9

. Any other issue you de em relevant, includin g, where applicable , reasons why you be lieve th at the information you claim to be CB I is 

### not em iss ion data, information co llected und er section 21 l (b)(2)(A) of the C l ean A ir Act, effluent data, a standard or limita tion, o r in fo rmation dealing w ith the existence , absence, or leve l of contami nants in drinking wate r. You may refe r to 40 C .F. R

. §§ 2.30 1-2.3 11 f or discussion of certain type s of informatio n n ot e ligible fo r confide nti al tre atm e nt. The E PA Office o f Reg ion al Cou ns e l may make a final confidentiality determinati o n concerning this informati on. If yo u receiv e a requ est for a sub stantiation letter f ro m the EPA , 

### yo u bear the burden of substantiating your confidentiali ty claim. Conclusory allegations will be given little or no weight in the determination. In s ubstantiatin g your CBI claim(s), you must brac ket all text so claimed and mark it"CBI." Information so designated will be disclosed by the EPA only to th e extent allowed by, and by means of the procedures set forth in, 40 C.F.R. Part 2, Subpart B. If you fail to claim the information as confidential , it may be made available to the public without further notice to you.