UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGIONS 

1445 ROSS AVENUE, SUITE 1200 

DALLAS TX 75202-2733 

SEP 1- 2015 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED: 7011 3500 0000 0360 2165 

Mr. Steve J. Susick 

General Manager, Louisiana Operations 

Mosaic Fertilizer, LLC 

7250 Highway 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 Louisiana. This facility was identified by the 

LDEQ in its 2008 Regional Haze State Implementation Plan (SIP) as a Best Available Retrofit 

Technology (BART) eligible source. 

We understand that your company is working with the State of Louisiana in the development of a SIP, 

and that what is being requested in this letter may be similar to what you are providing to the State. The 

EPA is sending a formal Request for information in order to be in a position to develop a Federal 

Implementation Plan for Regional Haze for Louisiana should that prove necessary. To assist in this 

process, the EPA is seeking information regarding the operations at this facility, including a BART 

determination. The EPA is requesting that a BART analysis be performed in accordance with the BART 

Guidelines (70 FR 39158-39161 , July 6, 2005) and our regulations (Section 51.301)1 in response to this 

Request. 

Enclosure 1 contains instructions and definitions that you should use to provide the requested 

information. Enclosure 2 contains the specific list of requested information. 

Your response to this Request must be certified by a duly authorized officer or agent of your company 

by signing the enclosed Statement of Certification included as Enclosure 3 and returning it with your 

response. All information submitted in response to this Request must be certified as true, correct, 

accurate, and complete by an individual with sufficient knowledge and authority to make such 

representations. 

Under 40 C.F.R. Part 2, Subpart B, you may assert a claim of business confidentiality for any portion of 

the submitted information. You must specify the page, paragraph, and sentence when identifying the 

information subject to your claim. Enclosure 4 specifies the assertion and substantiation requirements 

for business confidentiality claims. 

1 See 77 Fed Reg. 11 839, at 11848. 

Internet Address (URL) • http://www.epa.gov/region6 

Recycled/Recyclable • Printed With Vegetable 011 Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
Failure 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 providing false information in 

response to this 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 administrative, 

civil, or criminal proceedings. 

The Request is not subject to the Paperwork Reduction Act, 44 U.S.C. § 3501 et seq., because it is not a 

collection of information, as defined in 44 U .S.C. § 3502(3). To aid in our electronic recordkeeping 

efforts, please provide your 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. Environmental Protection Agency- Region 6 

1445 Ross Avenue, Suite 1200 

Dallas, TX 75202-2733 

If you have any questions, need to request an extension, or wish to schedule a meeting to discuss this 

Request, please 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 

Louisiana Department of Environmental Quality 
ENCLOSURE 1; 

Instructions 

1. Provide a separate narrative response to each question set forth in the Request. Please provide all 

documents responsive 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 corresponds and at the end of each 

answer identify the person(s) that provided information that was used or considered in responding to 

that question, as well as each person that was consulted in the preparation of that response. 

3. Indicate on each document or electronic file produced in response to this Request, or in some other 

reasonable manner, the number of the 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 spreadsheet 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. If Excel or Lotus formats are not available, then 

the format should allow for data to be used in calculations by a standard spreadsheet program such 

as Excel or Lotus. 

6. When the requested information included electronic maps of the facility, the maps should be 

provided in electronic desktop geographical information system (GIS) shapefiles compatible with 

Arc View GIS 9.3, instead of PDF. 

7. Each document provided in electronic form, whether image or editable spreadsheet format, or GIS 

shapetiles, must still be provided in accordance with those instructions for submittal of documents as 

outlined above (e.g., each PDF document should include all enclosures/attachments associated with 

the document, or a reference page added to indicate that a separate PDF document is provided as the 

enclosure/attachment 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 specific question. We recommend the use of file folders organized by question 

number. In addition, each compact disc, flash drive and/or hard drive should be labeled appropriately 

(e.g., Company Name, Disc 1 of 4 for Information 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. If 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 this information request. 

Definitions 

All terms used in this Request will have their ordinary meaning unless such terms are defined in the 

CAA, 42 U.S.C. §§ 7401 et. seq., 40 C.F.R. Part 52 (which incorporates the Federally-approved 

State Implementation Plan), or other CAA implementing regulations. Additional clarifications are 

specified below. 

1. The terms "document" and "documents" shall mean any object that records, stores, or presents 

information, and includes writings, memoranda, records, or information of any kind, formal or 

informal, whether wholly or partially handwritten or typed, whether in computer format, 

memory, or storage device, or in hardcopy, including any form or format of these. If in computer 

format or memory, each such document shall be provided in translation to a form useable and 

readable by the EPA, with all necessary documentation and support. All documents in hard copy 

should also include attachments to or enclosures with any document. 

2. The terms " relate to" (or any form thereof) shall mean constituting, reflecting, representing, 

supporting, contradicting, referring to, stating, describing, recording, noting, embodying, 

containing, mentioning, studying, analyzing, discussing, evaluating or relevant to. 

3. The term " Mosaic" shall mean Mosaic, and all other subsidiaries, past owners/operators, and 

related entities. 

4. The term "Unit" shall mean all equipment used for the purpose of generating electricity including, 

but not limited to, coal handling facilities, boilers, ductwork, stacks, turbines, generators, and all 

ancillary equipment. 

5. The term, "scrubber," shall collectively refer to flue gas desulfurization technologies designed to 

remove S02 from exhaust gas streams by reacting lime, limestone, or other reagents with the exhaust 

gas stream. This includes, but is not limited to wet scrubbing, spray dry scrubbing, dry scrubbing, · 

and all variations of these basic types of scrubbing systems. 

ENCLOSURE 2: 

Questions 

1. In reviewing the modeling conducted for the BART analysis submitted to LDEQ on July 17,2015, 

the EPA identified that the meteorological data set and computational 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 using the 

final Sid Richardson CALMET files (provided to Mosaic by LDEQ) and the larger 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 discussed below. 

2. In performing the 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, Mosaic 

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 the current control scenario 

with the addition of a scrubber on the D Train to demonstrate the visibility benefit achieved by 

installing a scrubber. The delta-deciview benefit from installation of controls should 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 emission rates for S02 and NOx baseline (pre-consent decree controls/emissions) do not match 

the values in the LDEQ's Regional Haze SIP from 2008 (Table 9-3). The table has emission totals 

for the BART units at each facility and lists Mosaic Uncle Sam as 39.16 tpd of S02 and 3.34 tpd of 

NOx. The modeling 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 delta deciview analysis 

between baseline and different controls that are evaluated as part of the 5-factor BART analysis. 

Please provide this information to the EPA for review prior to conducting CALPUFF modeling. 

5. Please recalculate and submit the cost analysis performed based on a 30 year life rather than a 20 

year life. 

6. The ozone data used for CALPUFF modeling should be hourly monitored ozone data from the years 

modeled, so the ozone data should be from 2001, 2002 and 2003. A value 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 provide electronically to Mosaic and their modeling contractors. 

7. Please submit a revised 5 factor BART analysis addressing the above concerns. 
8. Submittal of Modeling 

Modeling submissions must include 

• Modeling Report and Conclusions 

• All modeling files 

Modeling files must be provided on a hard drive, USB drive, or electronic ftp, and must include 

all of the following files as applicable: 

• CALMET output files 

• CALPUFF input, control, and output files 

• POSTUTIL input, control, and output files 

• CALPOST input, control, and output files 

• Executables used. 
ENCLOSURE 3: 

Statement of Certification 

I certify under penalty of law that I have examined and am familiar with the information in the enclosed 

documents, including all attachments. Based on my inquily of those individuals with primaty 

responsibility for obtaining the information, I certify that the statements and information are to the best 

of my knowledge and belief, true and complete. I am aware that there are significant penalties for 

knowingly submitting false statements and information, including the possibility of fines or 

imprisonment pursuant 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 other 

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 Section 

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 confidentiality 

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 confidential 

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 

requestor without further notice to you. For each item or class of information that you identify as being 

subject to CBI, you must answer the following questions, giving as much detail as possible: 

Substantiation Requirements 

All 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 fee.l that some or all ofthe provided information is entitled to confidential treatment, please 

specify 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 

specifically identified as subject to a confidentiality claim may be disclosed to the public without further 

notice to you. In accordance with 40 C.F.R. § 2.204(e), please answer the following questions, giving as 

much detail as possible, for each item or class of information that you identify as being subject to your 

claim: 
1. What specific portions of the information do you allege to be entitled to confidential treatment? For 

what period of time do you request that the information be maintained as confidential, e.g., until a 

certain date, until the occurrence of a specified event, or permanently? If the occurrence of a specific 

event will eliminate the need for confidentiality, please specify that event. 

2. Information submitted to the EPA becomes stale over time. Why should the information you claim 

as confidential be protected for the time period specified in your answer to question # 1? 

3. What measures have you taken to protect the information claimed as confidential? Have you 

disclosed the information to anyone other than a governmental body or someone who is bound by an 

agreement not to disclose the information further? If so, why should the information still be 

considered confidential? 

4. Is the information contained in any publicly available material such as the Internet, publicly 

available databases, promotional publications, annual reports, or articles? Is there any means by 

which a member of the public could obtain access to the information? Is the information of a kind 

that you would customarily not release to the public? 

5. Has any governmental body made a determination as to the confidentiality of the information? If so, 

please attach a copy of the determination. 

6. For each category of information claimed as confidential, explain with specificity why release of the 

information is likely to cause substantial harm to your competitive position. Explain the specific 

nature of those harmful effects, why they should be viewed as substantial, and the causal relationship 

between disclosure and such harmful effects. How could your competitors make use of this 

information to your detriment? 

7. Do you assert that the information is submitted on a voluntary or a mandatory basis? Please explain 

the reason for your assertion. If you assert that the information is voluntarily submitted information, 

explain whether and why disclosure of the information would tend to lessen the availability to the 

EPA of similar information in the future. 

8. If you believe any information to be (a) trade secret(s), please so state and explain the reason for 

your belief. Please attach copies of those pages with brackets around the text that you claim to be (a) 

trade secret(s). 

9. Any other issue you deem relevant, including, where applicable, reasons why you believe that the 

information you claim to be CBI is not emission data, information collected under section 

21 l(b)(2)(A) of the Clean Air Act, effluent data, a standard or limitation, or information dealing with 

the existence, absence, or level of contaminants in drinking water. You may refer to 40 C.F.R. §§ 

2.301-2.3 11 for discussion of certain types of information not eligible for confidential treatment. 

The EPA Office of Regional Counsel may make a final confidentiality determination concerning this 

information. 

If you receive a request for a substantiation letter from the EPA, you bear the burden of substantiating 

your confidentiality claim. Conclusory allegations will be given little or no weight in the 

determination. In substantiating your CBI claim(s), you must bracket all text so claimed and mark it 
"CBI." Information so designated will be disclosed by the EPA only to the 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.