15 OCT -5 PN 5: 24 

September 30, 2015 

Mosaic Fertilizer, LLC 

7250 Highway 44 

Uncle Sam, LA 70792 

www.mosaicco.com 

Tel225-474-9700 

Fax 225-474-4090 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 7013 2250 0001 5994 8857 

Mr. Guy Donaldson (6PD-L) 

UnitedStatesEnvironrnentalf'r()tectionAgenc:y:-RE!giQnJ3 

1445 Ross Avenue, Suite 1200 

Dallas, TX 75202-2733 

SUBJECT: MOSAIC FERTILIZER, LLC - UNCLE SAM PLANT 

RESPONSE TO SEPTEMBER 1, 2015 CLEAN AIR ACT SECTION 

114(a} INFORMATION REQUEST 

Dear Mr. Donaldson: 

On September 1, 2015, the United States Environmental Protection Agency (EPA), 

Region 6 emailed an Information Request to the Mosaic Fertilizer, LLC ("Mosaic") Uncle 

Sam Plant pursuant to Section 114(a) of the Clean Air Act, 42 U.S. C. § 7414(a). The 

Information Request was served on Mosaic by Certified Mail on September 4, 2015. 

The EPA Information Request seeks information related to best available retrofit 

technology (BART) requirements under EPA's Regional Haze Rule, 40 C.F.R. §§ 51.308 

and 51.309 in order that EPA may develop a Federal Implementation Plan in the event 

that the Louisiana Department of Environmental Quality (LDEQ) does not timely amend 

its State Implementation Plan with regard to Regional Haze to address deficiencies 

noted by EPA. The Information Request required the requested information to be 

submitted to the EPA by September 30, 2015. Mosaic has made considerable effort in 

this short time period to provide timely, useful and complete responses to the 

Information Request. 

Notwithstanding its substantive response to the Information Request, Mosaic makes the 

following general qualifications and objections to the request: 

Mosaic objects to the Information Request to the extent that it seeks privileged 

information, including any communications that are protected from disclosure by 

the attorney-client communication privilege or any communications or documents 

protected by the attorney work product doctrine. 

Mosaic objects to the Information Request to the extent that the information 

requested is irrelevant or outside the scope of Section 114 of the Clean Air Act, 

42 U.S.C. § 7411. 

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Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page 2 

Mosaic objects to the Information Request to the extent that it is vague, unclear, 

ambiguous, or overly burdensome. 

For some of the responses, we have relied on information supplied by third 

parties over whom Mosaic has no control. In addition, Mosaic has prepared the 

responses based on reasonable investigation, and the responses may be subject 

to revision in the event additional or different information or analyses become 

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available, Mosaicspecifically disclaims, howevef; any obligation to-update this ------- --- ---- - - -~ 

response to reflect any such additional or different information or analyses. 

Mosaic specifically objects to any use of the data by EPA that does not comply 

with EPA's Cross-Media Electronic Reporting Rule, 40 C.F.R. Part 3, or any 

internal EPA rules, policies or directives on use of electronic data. 

Subject to and without waiving any of the foregoing qualifications and objections, and 

subject further to the reservations set forth below, Mosaic provides in this response 

information sought in the Information Request, through the following responses and 

attachments. Mosaic reserves the right to object to any use of such data by EPA in any 

future rulemaking, permit, or enforcement proceedings. 

Mosaic responds to the September 1, 2015 Information Request as follows: 

Request 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. 

Response 1. Mosaic has conducted CALPUFF modeling for the three scenarios above 

using the final updated Sid Richardson CALMET files that were approved by the EPA 

and the larger CALPUFF modeling domain indicated by the EPA. A description of this 

CALPUFF modeling analysis and a summary of the modeling results using the protocols 

as directed by EPA in the Information Request are provided in Section 4 of the attached 

Mosaic Uncle Sam Plant Best Available Retrofit Technology Analysis, Rev. 1 

(Attachment 1 ). Additionally, electronic copies of the CALPUFF input and output files 
Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page 3 

used and created in this CALPUFF modeling analysis are contained in Exhibit 11 of 

Attachment 1. 

The following person(s) assisted in the preparation of the response to Request 1: 

Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll 

Environ US Corporation ("Ramboll Environ"), consultants to Mosaic. 

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Request 2: In performing the five4actor analysis for the D Train controls, Mosaic u -- --.•.•.. u u ·--

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. 

Response 2. Mosaic evaluated the visibility improvement that is modelled to occur at 

the Breton Wilderness Area as a result of equipping the D Train Double Absorption 

H2S04 Plant (EPN S-DTrain1, EQT 0074) with a wet scrubber. The revised 5-factor 

BART analysis performed for the D Train Double Absorption H2S04 Plant (EPN SDTrain1, EQT 0074), which includes this requested modeled visibility improvement 

evaluation, is presented in Sections 3.9 and 3.10 and 4 of Attachment 1. In Section 4, 

Mosaic analysed three scenarios to estimate the visibility improvement: Baseline, With 

BART, With Bart + D Train Wet Scrubber. The modeling results are presented in 

Section 4.3 of Attachment 1 and indicate that the visibility improvement between the 

"With BART" scenario and the "With BART + D Train Wet Scrubber'' scenario is only 

15% of the visibility improvement between the "Baseline" scenario and the "With BART" 

scenario. Given the extremely high capital investment cost (estimated $25 Million) for a 

wet scrubber, and the high annual operating cost (estimated $3.3 Million), it is not cost 

effective to install and operate a wet scrubber. In summary, Mosaic determined that a 

wet scrubber does not represent BART for the D Train Double Absorption H2S04 Plant 

(EPN S-DTrain1, EQT 0074). 

The following person(s) assisted in the preparation of the response to Request 2: 

Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll 

Environ, consultants to Mosaic and Maureen Harbour! with Kean Miller LLP, counsel to 

Mosaic. 

Request 3. Please provide a narrative explanation including supportive information as 

necessary, for why the E Train is not BART-eligible. 

Response 3. A narrative explanation of why the E Train is not a BART-eligible , 

emissions unit is provided in Section 1.2.1 of Attachment 1. Additionally, supporting 

information for this determination is contained in Exhibits 1 and 2 of Attachment 1. 

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Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page4 

The following person(s) assisted in the preparation of the response to Request 3: Todd 

Higginbotham with Ram boll Environ, consultants to Mosaic. 

Request 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 /essthanthese totals at 35c07tpd ofSO:rand2c06·tpdofNOx, ····· ········· ··· ···· ·· · ··· -~­

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. 

Response 4. On August 11, 2006, Mosaic submitted an initial list of BART-eligible 

emissions units for the Uncle Sam Plant to the LDEQ (hereinafter this submittal is 

referenced as the "August 11, 2006 submittal"). As part of the August 11, 2006 

submittal, for each of the listed emissions units, Mosaic indicated the 24-hour maximum 

sulfur dioxide (S02) emission rate and the 24-hour maximum oxides of nitrogen (NOx) 

emission rate, both in tons per day (tpd), emitted during routine operations (i.e., 

excluding start-ups, shutdowns, and malfunctions) from 2001 through 2005. 

In Table 9.3 of the June 2008 Louisiana State Implementation Plan Revision for 

Regional Haze Program, the LDEQ listed total S02 and NOx emission rates for the 

BART-eligible emissions units at the Uncle Sam Plant as 39.16 tpd and 3.34 tpd, 

respectively. Mosaic has estimated that the LDEQ calculated these emission rates by 

summing together the emissions unit-by-emissions unit 24-hour maximum hourly S02 

and NOx emission rates, respectively, that were identified in the August 11, 2006 

submittal. 

After the August 11, 2006 submittal, Mosaic determined that several of the emissions 

units identified as BART-eligible in that submittal were in fact not BART-eligible because 

they were not "in existence" on August 7, 1977 or they were not stationary sources (i.e., 

they were "nonroad engines"). This revised determination of BART-eligible emissions 

units was documented in the June 2007 Best Available Retrofit Technology Analysis that 

Mosaic submitted to the LDEQ for the Uncle Sam Plant, which the LDEQ included in 

Appendix G of the June 2008 Louisiana State Implementation Plan Revision for 

Regional Haze Program. 

The same BART-eligible emissions units identified for the Uncle Sam Plant in the June 

2007 Best Available Retrofit Technology Analysis were evaluated as BART-eligible in 

the July 2015 Mosaic Uncle Sam Plant Best Available Retrofit Technology Analysis that 

was recently submitted to the LDEQ. Additionally, the same baseline S02 and NOx 

emission rates were evaluated in the June 2007 Best Available Retrofit Technology 
Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page 5 

Analysis and the July 2015 Mosaic Uncle Sam Plant Best Available Retrofit Technology 

Analysis. 

Attachment 2 contains an electronic file in which we have calculated the S02 and NOx 

emission rates that the LDEQ listed for the Uncle Sam Plant in Table 9.3 of the June 

2008 Louisiana State Implementation Plan Revision for Regional Haze Program. In the 

same electronic file, we have also documented the calculation of the baseline S02 and 

-----Nox·· emission···rates·· that we evaluated···in···theJune2007Best····Available--Retrofit 

Technology Analysis and the July 2015 Mosaic Uncle Sam Plant Best Available Retrofit 

Technology Analysis. 

Attachment 3 contains a copy of the December 21, 1979 preconstruction air permit 

application requesting authorization for the construction of the Sulfur Surge Tank (EPN 

S-SurgeTnk, EQT 0084). This air permit application is referenced in the electronic file 

contained in Attachment 2. Attachment 4 contains a copy of the December 27, 1979 air 

permit (Permit No. 1312T} that was issued by the predecessor agency to the LDEQ 

authorizing the construction of the Sulfur Surge Tank (EPN S-SurgeTnk, EQT 0084). 

This air permit is referenced in the electronic file contained in Attachment 2. 

The following person(s) assisted in the preparation of the response to Request 4: Todd 

Higginbotham and Michael Carbon with Ramboll Environ, consultants to Mosaic, and 

Greg Davison with Mosaic. 

Request 5. Please recalculate and submit the cost analysis performed based on a 30 

year life rather than a 20 year life. 

Response 5. Mosaic disagrees with the EPA that it is appropriate to use a 30-year life 

when performing the BART cost analyses for the Uncle Sam Plant. In fact, EPA has 

indicated that a high:end life for a scrubber is 20 years.' Nonetheless we have revised 

the BART analyses previously performed for the Uncle Sam Plant by using a 30-year 

life, as requested. The assumption of a 30-year life did not change our BART 

determinations. The results of the revised BART cost analyses are summarized in 

Section 3 of Attachment 1. The revised BART cost analysis calculations are contained 

in Exhibits 3 through 10 of Attachment 1. Mosaic reserves all rights to challenge the 

appropriateness of use of a 30-year life in any BART cost analysis in any FIP, SIP, 

rulemaking, permitting, or enforcement proceeding. 

The following person(s) assisted in the preparation of the response to Request 5: Todd 

Higginbotham and Michael Carbon with Ramboll Environ, consultants to Mosaic and 

Maureen Harbour! with Kean Miller LLP, counsel to Mosaic. 

1 Robert D. Bauman, Chief, Standards Implementation Branch, Office of Air Quality Planning and 

Standards, EPA to Stephen H. Rothblatt, Chief, Air and Radiation Branch, EPA Region V. July 

24, 1987. 
Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page6 

Request 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 setting 

BCK03 = 12*80). The EPA has ozone data files that we will provide electronically to 

Mosaic and their modeling contractors. 

Response 6. Mosaic has conducted CALPUFF modeling using the ozone data files 1-

--------provided by the EPA and a value of80 parts per billion by volume (ppbv)formissing ... .... .. ... ......... . .. . .J 

ozone data. A description of the CALPUFF modeling analysis and a summary of the 

modeling results are provided in Section 4 of Attachment 1. Additionally, electronic 

copies of the CALPUFF input and output files used and created in the CALPUFF 

modeling analysis are contained in Exhibit 11 of Attachment 1. EPA and LDEQ 

guidance has previously indicated that 40 ppb is an appropriate default value for missing 

ozone data. Mosaic reserves all rights to challenge the appropriateness of use of 80 

ppb as the default for missing ozone data in any future FIP, SIP, rulemaking, permitting, 

or enforcement proceeding. 

The following person(s) assisted in the preparation of the response to Request 6: 

Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll 

Environ, consultants to Mosaic. 

Request 7. Please submit a revised 5 factor BART analysis addressing the above 

concerns. 

Response 7. Mosaic has revised the 5-factor BART analyses performed for the BARTeligible emissions units at the Uncle Sam Plant as directed by the EPA in Requests 1 

through 6. These revised 5-factor BART analyses are included in Sections 3 and 4 of 

Attachment 1. Mosaic reserves all rights to challenge the appropriateness of the 

modeling methodology and input assumptions for the modeling and 5-factor BART 

analysis in any future FIP, SIP, rulemaking, permitting, or enforcement proceeding. 

The following person(s) assisted in the preparation of the response to Request 7: 

Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll 

Environ, consultants to Mosaic and Maureen Harbour! with Kean Miller LLP, counsel to 

Mosaic. 

Request 8. Submittal of Modeling 

Modeling submissions must include 

• Modeling Report and Conclusions 

• All modeling files 
Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page 7 

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, 

Response 8. The CALPUFF modeling report and a summary of the modeling 

conclusions are provided in Section 4 of Attachment 1. Additionally, electronic copies of 

the CALPUFF input and output files used and created in the CALPUFF modeling 

analysis are contained in Exhibit 11 of Attachment 1. 

The following person(s) assisted in the preparation of the response to Request 8: 

Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll 

Environ, consultants to Mosaic. 

Attachment 5 contains the Statement of Certification required to be signed and returned 

with this response. 

If you or any member of your staff should have any questions or require additional 

information in regards to this submittal, please do not hesitate to contact David Oubre at 

(225) 474-1336. Thank you for your consideration of this submission. We look forward 

to working with EPA in a cooperative manner in this matter. 

Plant Manager - Louisiana Operations 

Attachments 
Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

PageS 

cc: with attachments 

LDEQ, Office of Environmental Services 

David Oubre, Mosaic 

David Jellerson, Mosaic 

Jeff Stewart, Mosaic 

---PatrickvanderVoorn;Mosaic 

Diana Jagiella, Mosaic 

Michael Carbon, Ramboll Environ 

7013 2250 0001 5994 8840 i. 
Response to September 1, 2015 Clean Air 

Act Section 114(a) Information Request 

September 30, 2015 

Page 9 

bee: with attachments 

Steve Chatelain, Mosaic 

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ATTACHMENT 1 

Mosaic Uncle Sam Plant 

Best Available Retrofit Technology Analysis, Rev. 1 

September 2015 
See Attached Flash Drive 
See Attached Flash Drive 
ATTACHMENT 3 

December 21, 1979 Preconstruction Air Permit 

Application Requesting Authorization for the 

Construction of the Sulfur Surge Tank (EPN S-SurgeTnk, 

EQT0084) 
See Attached Flash Drive 
ATTACHMENT 4 

December 27, 1979 Permit No. 1312T Authorizing 

Construction of the Sulfur Surge Tank (EPN S-SurgeTnk, 

EQT 0084) 
See Attached Flash Drive 
ATTACHMENT 5 

Statement of Certification 
See Attached Flash Drive