Page 1 of 85

MEMORANDUM

TO : Tina Ndoh, U.S. EPA/ OAQPS /SPPD

– Minerals and Manufacturing Group

FROM : Eastern Research Group, Inc.

DATE : October 20, 2014

SUBJECT : CAA Section 111(b)( 1)(B) and 112(d)(6) Reviews for the Phosphoric Acid

Manufacturing and Phosphate Fertilizer Production Source Categories

This memorandum summarizes the results of an analysis to identify developments in practices, processes, and control t echnologies that have occurred since the NESHAP and NSPS standards were promulgated for the P hosphoric A cid M anufacturing and P hosphate F ertilizer P roduction source categories. This analysis is part of the U.S. Environmental Protection Agency’s ( EPA ) review efforts in accordance with section s 111(b)(1)(B) and 112(d)(6) of the Clean Air Act (CAA). This memorandum is organized as follows:

1.0 Background

1.1 Description of the Phosphoric Acid Manufacturing Source Category

1.1.1 Phosphoric Acid Manufacturing NESHAP Requirements 1.1.2 Phosphoric Acid Manufacturing NSPS Requirements

1.2 Description of the Phosphate Fertilizer Production Source Category

1.2.1 Phosphate Fertilizer Production NESHAP Requirements 1.2.2 Phosphate Fertilizer Prod uction NSPS Requirements

1.3 Facility Overview

2.0 Introduction

3 .0 Stack Emissions

3 .1 Wet

- Process Phosphoric Acid Process Lines 3.2 Superphosphoric Acid Process Lines 3. 3 Purified Phosphoric Acid Process Lines 3. 4 Phosphate Rock Dryers 3. 5 Phospha te Rock Calciners 3.6 Diammonium a nd/ o r Monoammonium Phosphate Fertilizer Process Lines 3.7 Triple Superphosphate Lines and Storage Buildings 3. 8 Conclusions

4.0 Fugitive Emissions

5.0 ReferencesPage 2 of 85

1.0 BACKGROUND
Section 111 of the CAA requires EPA to establish standards for stationary sources that cause or contribute significantly to air pollution which may reasonably be anticipated to endanger public health or welfare. These standards must reflect the emission limitation achievable through application of the “best system of emission reduction” which the EPA determines has been adequately demonstrated. Section 111 also requires the EPA to review these standards. Specifically, paragraph 111(b)(1)(B) states:

(B) ... The Administrator shall, at least every 8 years, review and, if appropriate, revise such standards following the procedure required by this subsection for promulgation of such standards

... Section 112 of the CAA requires EPA to establish technology

- based standards for

sources o f hazardous air pollu tants (HAP)

. These technology

- based standards are often referred to as maximum achievable control t echnology, or MACT, standards. Section 112 also contains provisions requiring the EPA to periodi cally revisit these standards. Specifically, paragraph 112(d) (6) states:

(6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than
every 8 years.

In April 2010, EPA issued a request, pursuant to CAA section 114, to collect information from phosphoric acid and phosphate fertilizer manufacturing facilities. A vailable information was requested regarding process equipment, control technologies , point and fugitive emissions, and other aspects of facility operations. Companies completed the surveys for their facilities and submitted the responses to EPA in the fall of 2010. Additionally, EPA requested that the facilities conduct emissions tests i n 2010 for certain pollutants from specific processes. Pollutants tested included hydrogen fluoride ( HF ) , total fluorides (TF) , particulate matter (PM)

, and most HAP metals. F acilities also conducted analyses of the phosphate rock used in the manufacture of phosphoric acid. The results of these tests were submitted to EPA in the fall of 2010.

On January 24, 2014, EPA issued another section 114 survey and emissions testing request to certain facilities in order to gather additional mercury emissions and HF emissions from calciner operations, and additional HF emissions from certain wet process phosphoric acid (WPPA) lines, superphosphoric acid (SPA) lines, and monoammonium phosphate and diamm onium phosphate fertilizer (APF) lines.

For more information regarding the April 2010 section 114 and January 2014 section 114 requests, please refer to the memorandum entitled “Information Collection and Additional Data Received for the Phosphoric Acid a nd Phosphate Fertilizer Production Source Categories,” (ERG, 2014a ).Page 3 of 85

1.1 Description of the Phosphoric Acid Manufacturing Source Category The basic step for producing phosphoric acid through the wet phosphoric acid (WPPA)
process is the acidulation of phospha te rock. Typically, sulfuric acid, phosphate rock

, and water are reacted together to p roduce phosphoric acid and gypsum. When phosphate rock is acidulated to manufacture WPPA , fluorine contained in the rock is released. Fluoride compounds, including HF , ar e evolved as particulates and gases which are emitted to the atmosphere unless removed from the exhaust stream. Some of these same fluoride compounds also remain in the product acid and are available for release to the atmosphere during subsequent processing of the acid. Gypsum , a by

- product of the acidulation reaction, is pumped as a slurry to ponds atop stacks of waste gypsum where the liquid separate s from the slurry and is decanted for return to the process with process cooling water. The gypsum is d iscarded as a major solid waste stream , and stored in large piles that can cover several hundred acres and reach hundreds of feet in h eight . This discarded gypsum is commonly called a

, gypstack , or gypsum dewatering stack

. WPPA is concentrated to make SPA using evaporation.

The federal emission standards that are associated with the Phosphoric Acid Manufacturing source category and that were evaluated for this review are:

 National Emission Standards for Hazardous Air Pollutants from Phosphori c Acid Manufacturing Plants (40 CFR part 63, subpart AA);

 Standards of Performance for the Phosphate Fertilizer Industry: Wet

- Process Phosphoric Acid Plants (40 CFR part 60, subpart T); and

 Standards of Performance for the Phosphate Fertilizer Industry: Superphosphoric Acid Plants (40 CFR part 60, subpart U).

1.1.1 Phosph oric Acid Manufacturing NESHAP R equirements
The current National Emissio ns Standards for Hazardous Air Pollutants (NESHAP) for the phosphoric acid manufacturing source category was proposed on December 27, 1996 (61 FR 68429) and promulgated on June 10 , 199 9 ( 64 FR 31358 )

, and codified at 40 CFR part 63, subpart AA. As promulg ated in 1999 , the NESHAP applies to affected sources of HAP emissions at phosphoric acid manufacturing plants. The 1999 NESHAP was amended December 17, 2001 ( 66 FR 65072 ), June 12, 2002 (67 FR 40579), June 13, 2002 (67 FR 40817), and April 20, 2006 (71 FR 20457). The amendments revised the emission limit for calciners and corrected an inadvertent error in monitoring requirements. The current NESHAP regulates emissions from the following sources at a phosphoric acid manufacturing plant : (1) WPPA process lin es (including reactors, filters, evaporators, and hot wells) , (2) evaporative cooling towers

, (3) phosphate rock dryers, (4) phosphate rock calciners, (5) SPA process lines (including evaporators, hot wells, acid sumps, and cooling tanks), and (6) purified phosphoric acid (PPA) process lines (including solvent extraction process equipment, solvent stripping and recovery equipment, seal tanks, carbon treatment equipment, cooling towers, storage tanks, pumps, and process piping)

.

T he current NESHAP specifies numerical emissions limits for T F for existing WPPA process lines (0.020 pounds T F per ton of equivalent phosphorus pentoxide (P 2 O 5 )); and existing vacuum evaporation (0.010 pounds T F per ton of equivalent P 2 O 5 ) and submerged combustionPage 4 of 85

(0.20 pounds T F per ton of equivalent P 2 O 5 ) processes that are associated with SPA process lines. Additionally, emissions limits for PM are specified for existing phosphate rock dryers (0.215 pounds PM per ton of equivalent P 2 O 5 ) and existing rock calciners (0.080 grains per dry standard cubic foot).

T he current NESHAP specifies numerical emissions limits for T F for new WPPA process lines (0.0135 pounds T F per ton of equivalent P 2 O 5 ), and new SPA process lines (0.0087 pounds T F per ton of equivalent P 2 O 5 ). Additionally, emissions limits for PM are specified for new phosphate rock dryers (0.060 pounds PM per ton of equivalent P 2 O 5 ) and new rock calciners (0.040 grains per dry standard cubic foot).

PPA process lines (existing and new sources) are required to c omply with the Equipment Leak NESHAP (40 CFR 63, subpart H); and are subject to methyl isobutyl ketone (MIBK) concentration limitations. A lso

, the rule does not allow liquid effluent (from any wet scrubbing device that is installed to control emissions fro m process equipment) to be used in evaporative cooling towers.

As part of the NESHAP technology review, EPA evaluated HF emissions from emission points that have TF emission limits as a surrogate for HF

. Data for HF as measured by EPA method 26A w ere recei ved for most emission points. I n its previous analys i s (see preamble to the current NESHAP for phosphoric acid manufacturing at 61 FR 68429 ), EPA chose to calculate MACT floors using TF as a surrogate for HF because the EPA had a large body of existing data for the surrogate pollutant T F, and only a limited amount of direct HF emissions data. Also in the previous analysis, EPA chose to use PM as a surrogate for the HAP metals. PM is an appropriate surrogate for most HAP metals, but is not an adequate sur rogate for mercury (Hg) because Hg is volatile and not well controlled using emissions control technologies commonly used for other HAP metals. In this review, EPA performed a separate evaluation of Hg emissions.

1.1.2 Phosphoric Acid Manufacturing NSPS Requir ements The EPA promulgated 40 CFR part 60, subpart T for Wet

- Process Phosphoric Acid Plants on August 6, 1975 (40 FR 33154). The NSPS established standards to control TF emissions from WPPA plants, including reactors, filters, evaporators, and hot wells. F or new sources, WPPA plants are limited to 0.020 pounds TF per ton of equivalent P 2 O 5
. The EPA promulgated 40 CFR part 60, subpart U for Superphosphoric Acid Plants on August 6, 1975 (40 FR 33155). The NSPS established standards to control TF emissions fro m SPA plants, including evaporators, hot wells, acid sumps, and cooling tanks. For new sources, SPA plants are limited to 0.010 pounds TF per ton of equivalent P 2 O 5
.

For the NSPS review, EPA evaluated TF emissions f rom applicable phosphoric acid manufacturing emission points

.

1.2 Description of the Phosphate Fertilizer Production Source Category
P hosphate fertilizers (i.e., diammonium phosphate or monoammonium phosphate , or ammonium phosphate fertilizer (APF) ) are manufactured by way of three basic steps: reaction (where anhydrous ammonia is reacted with phosphoric acid to form diammonium phosphate or monoammonium phosphate), granulation (where solidification occurs), and finishing operationsPage 5 of 85

(where the solid material is dried, cooled, and sent through a screening arrangement for particle segregation). Side reactions resulting from the production of APF produce ammonium fluoride, ammonium sulfate, and ammonium fluorosilicate. Some of the fluoride contained in the phosphate rock is liberated in t he process as HF. Another phosphate fertilizer, triple superphosphate ( TSP )

, is made as run

- of

- the

- pile

- TSP (ROP

- TSP) and /or granular TSP (GTSP) by reacting phosphoric acid with ground phosphate rock

. The phosphoric acid used in the GTSP process is appreci ably lower in concentration (40 percent P 2 O 5 ) than that used to manufacture ROP

- TSP product (50 to 55 percent P 2 O 5 ). The GTSP process yields larger, more uniform particles with improved storage and handling properties than the ROP

- TSP process.

The federal emission standards that are associated with the Phosphate Fertilizer Production source category and are subject of this proposed rulemaking are:

 National Emission Standards for Hazardous Air Pollutants from Phosphate Fertilizers Production Plants (40 CFR part 63, subpart BB);

 Standards of Performance for the Phosphate Fertilizer Industry: Diammonium Phosphate Plants (40 CFR part 60, subpart V);

 Standards of Performance for the Phosphate Fertilizer Industry: Triple Superphosphate Plants (40 CFR part 60, s ubpart W); and

 Standards of Performance for the Phosphate Fertilizer Industry: Granular Triple Superphosphate Storage Facilities (40 CFR part 60, subpart X).

1.2.1 Phosphate Fertilizer Production NESHAP Requirements
The current NESHAP for the phosphate fertiliz er production source category was proposed on December 27, 1996 (61 FR 68429) and promulgated on June 10 , 199 9 ( 64 FR 31358 )

, and codified at 40 CFR part 63, subpart BB. As promulgated in 199 9 , the NESHAP applies to affected sources of HAP emissions at phosphate fertilizer production plants. The 199 9 NESHAP was amended December 17, 2001 ( 66 FR 65072 ), June 13, 2002 (67 FR 40818), and April 20, 2006 (71 FR 20457). The current NESHAP regulates emissions from the following sources at a phosphate fertilizer production plant : (1) diammonium and/or monoammonium phosphate process lines (including reactors, granulators, dryers, coolers, screens, and mills) , (2) GTSP process lines (including mixers, curing belts (dens), reactors, granulators, dryers, coolers,

scr eens, and mills)

, and (3) GTSP storage buildings (including storage or curing buildings, conveyors, elevators, screens, and mills).

T he current NESHAP specifies numerical emissions limits for T F for existing diammonium and/or monoammonium phosphate process lines (0.060 pounds T F per ton of equivalent P 2 O 5 ); existing GTSP process lines (0.150 pounds T F per ton of equivalent P 2 O 5 ); and existing GTSP buildings (5.0 x 10 - 4 pounds T F per hour per ton of equivalent P 2 O 5 stored). The NESHAP specifies n umerical emissions limits for TF for new diammonium and/or monoammonium phosphate process lines (0.0580 pounds T F per ton of equivalent P 2 O 5 ); new GTSP process lines (0.123 pounds T F per ton of equivalent P 2 O 5 ); and new GTSP storage buildings (5.0 x 10 - 4 p ounds T F per hour per ton of equivalent P 2 O 5 stored). A lso

, the rule does not allow fresh GTSP to be shipped from an affected facility.Page 6 of 85

For the same reasons as discussed in Section 1. 1 .1 of this memorandum, EPA evaluated HF emission s for the NESHAP technol ogy review for those emission points that have a TF limit as a surrogate for HF

.

1.2.2 Phosphate Fertilizer Production NSPS Requirements The EPA promulgated 40 CFR part 60, subpart V for Diammonium Phosphate Plants on July 25, 1977 (42 FR 37938). The NSPS established standards to control TF emissions from DAP plants, including reactors, granulators, dryers, coolers, screens, and mills. For new sources, DAP plants are limited to 0.06 pounds TF per to n of equivalent P 2 O 5 feed.

The EPA promulgated 40 CFR part 60, subpart W for Triple Superphosphate Plants on July 25, 1977 (42 FR 37938). The NSPS established standards to control TF emissions from the production of ROP

- TSP and GTSP, and the storage of RO P

- TSP. For new sources, production of ROP

- TSP and GTSP and the storage of ROP

- TSP is limited to 0.20 pounds TF per ton of equivalent P 2 O 5 feed.

The EPA promulgated 40 CFR part 60, subpart X for Granular Triple Superphosphate Storage Facilities on July 25, 1977 (42 FR 37938). The NSPS established standards to control total fluoride emissions from the storage of GTSP, including storage or curing buildings (noted as “piles” in sub part X), conveyors, elevators, screens and mills. For new sources, the storage of GTSP is limited to 5.0x10 - 4 pounds of TF per hour per ton of equivalent P 2 O 5 stored.

For the NSPS review, EPA evaluated TF emissions from applicable phosphate fert ilizer production emission points.

1.3 Facility Overview Today, there are 12 phosphoric acid manufacturing facilities and 10 of the 12 facilities also produce phosphate fertilizers . One additional facility only produces phosphate fertilizers

. In total there ar e 13 facilities subject to the NESHAP and NSPS rules. We are not aware of any facility currently under construction, or in the process of expanding their operations. Appendix A provides a list of facilities located in the United States that are considered to be part of the phosphoric acid manufacturing and /or phosphate fertilizer production source category. Note, there are no facilities that currently operate a GTSP process line, although one facility retains a permit to store GTSP. 1

2.0 INTRODUCTION
We investigated developments in practices, processes, and control technologies at phosphoric acid manufacturing plants and phosphate fertilizer production plants for stack emissions of T F, HF, Hg, total metal HAP (excluding Hg and Phosphorous (P)), and PM

. This review also considered both (1) whether developments in technology or other factors support the conclusion that a different system of emissions reduction has become the “best system of emissions reduction” and (2) whether emissions limitations and pe rcent reductions beyond those required by the standards are achieved in practice.

1 The PCS Phosphate Company, Inc., located in Aurora, NC.Page 7 of 85

For the purposes of this review, we considered any of the following to be a “development ” :

 Any add

- on control technology or other equipment that was not identified and considered during development of the original NESHAP and NSPS standards.

 Any improvements in add

- on control technology or other equipment (that were identified and considered during development of the original NESHAP and NSPS standards) that could re sult in additional emissions reduction.

 Any work practice or operational procedure that was not identified or considered during development of the original NESHAP and NSPS standards.

 Any process change or pollution prevention alternative that could be br oadly applied to the industry and that was not identified or considered during development of the original NESHAP and NSPS standards.

 Any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA consid ered during the development of the original NESHAP and NSPS standards).

To identify developments, we examined the data EPA received in response to the section 114 request from the 1 3 operating facilities

. These data included descriptions of processes and detailed information on all control technologies in the source category. Stack test data were also collected in response to the section 114 request for T F, HF, PM, and the metal HAP compounds.

The stack test dat a was gathered in response to a section 114 request specifically for NESHAP development and review. However, this same data were also used when conducting the NSPS review because the NESHAP and NSPS rules cover the same sources. We established
t his overlap by comparing the regulatory requirements between the related NSPS and NESHAP regulations :

 NSPS subpart T cover s the same emission sources at WPPA plants and control the same pollutants as NESHAP subpart AA ( ERG, 2014 d );

 NSPS subpart U cover s th e same emission sources at SPA plants and control the same pollutants as NESHAP subpart AA ( ERG, 2014 e );

 NSPS subpart V cover s the same emission sources at DAP plants and control the same pollutants as NESHAP subpart BB (ERG, 2014 f );

 With the except ion of ROP

- TSP which is no longer being produced in North America (see Section 3.7 of this memorandum) , NSPS subparts W and X cover the same emission sources at TSP plants and control the same pollutants as NESHAP subpart BB (ERG, 2014 g )

.Page 8 of 85

Because the NESHAP and NSPS rules cover the same emission sources, the data gathered as part of the NESHAP development and technology review is also applicable for the NSPS review.

We also conducted searches of EPA’s RACT/BACT/LAER (Reasonably Achievable Control Tech nology/Best Available Control Technology/Lowest Achievable Emissions Rate) (U.S. EPA, 2012) clearinghouse and the Internet for information on phosphoric acid manufacturing and phosphate fertilizer production processes, reviewed technologies employed by sim ilar industries, and reviewed new or updated NESHAPs for other source categories. However, the majority of the information considered for this technology review was submitted in response to the section 114 data request

. The results of these analyses are pr esented in the following sections.

3.0 STACK EMISSIONS
Based on a search of EPA’s RACT/BACT/LAER database, we have found no new developments in practices, processes, and control technologies for phosphoric acid manufacturing and phosphate fertilizer production plants.

Wet scrubbing is the primary control technology used across the industry for control of TF and HF emissions. However, w e examined the stack emissions data provided by industry for outlier s . The primary purpose of this exercise was to determine wh ether outlier emissions data associated with specific stack emission points were related to a control technology (when compared to all other emission points). We could not directly calculate control efficiencies due to lack of inlet concentration data; how ever, we compared the outlet T F, HF, total metal (excluding Hg and P ) , Hg, and PM concentrations from the different control technologies based on emissions data that EPA received in response to the section 114 data request

. In addition, we compared normal ized emissions. We normalized the concentration data to a production basis ( pounds emitted per thousand tons of P 2 O 5 ) using each facility’s P 2 O 5 production rate 2 reported during the stack test. Emissions of P were excluded from the total metal HAP emission s analyses discussed in this memo because we do not believe the reported P emissions are in the form of the HAP white P, but rather in the form of a phosphate which is not a HAP metal. B ecause we were unable to speciate the reported P emissions into HAP P emissions and other non

- HAP P compound emissions

, we did not compare different control technologies based on P emissions data that EPA received in response to the section 114 request

.
To facilitate this exercise, we created concentration and normalized emi ssion bar charts using the stack emissions data provided by industry in response to the section 114 request

. Appendix B contains bar charts for emission points associated with WP PA process lines. Appendix C contains bar charts for emission points associate d with SPA process lines

. Appendix D contains bar charts for emission points associated with APF process lines. We were unable to determine outlier stack emissions data associated with PPA process lines, phosphate rock dryers, and phosphate rock calciners because EPA only received stack emissions data for these operations from one facility. There are no facilities that operate a GTSP process line or storage building; therefore, we did not receive and/or analyze stack emissions data for these operations.

2 The standard practice in the fertilizer industry is to use the oxide form, i.e., P 2 O 5 , to express the available phosphate content of the fertilizers made.Page 9 of 85

Pho sphoric acid manufacturing plants and phosphate fertilizer production plants may use multiple control technologies to comply with current standards. However, b ased on a review of the section 114 responses, the most common final control technology (i.e., th e control technology directly prior to the exit stack) used by these facilities is wet scrubbing (no matter whether the emission point is associated with a WP PA, APF, SPA, or PPA process). P M and acid gases ( from waste gas streams of stationary point sourc es ) are removed primarily during wet scrubbing through impaction, diffusion, interception and/or absorption of the pollutant onto droplets of liquid (U.S. EPA, 2002) . The liquid containing the pollutant is then collected for disposal.

There are numerous types of wet scrubbers wh ich remove both acid gas and PM (e.g., venturi, impingement, crossflow, or packed bed wet scrubbers). We examined outlier emissions data to compare whether one control technology used by phosphate facilities is more or less effecti ve than another (and /or whether any anomalies exist between measured emissions and a certain type of control technology)

. Sections 3.1 through 3. 7 provide a summary of the various control technology used at stack emission points. When possible, we also di scuss in these sections our observations and conclusions rega rding outlier emission data associated with fluoride ( T F and HF), total metal (excluding Hg and P), Hg , and PM emissions . Section 3. 8 provides an overall summary of our conclusions in regards to this analysis (for stack related processes)

. The outlier emissions analysis was initially conducted using only stack test data from the 2010 section 114 request. The subsequent section 114 request in 2014 gathered additional HF and Hg data for a subset of the emission points. Data were only provided for about 14 % of the total emission points in phosphoric acid or phosphate fertilizer plants, so a comprehensive data review was not possible. However, t he HF data from 2014 and 2010 were compared to determine i f using the 2010 HF data were still appropriate or if the 2014 HF data would provide a different conclusion. See Appendix F for a comparison of the data. Most of the 2014 HF test data were lower than the 2010 HF data, and would therefore not affect the results of the technology review. However, HF emissions data for EP

- 541 at Agrium Nu

- West ’s SPA process line was significantly different between 2010 and 2014 , which we believe to be partially due to this source being uncontrolled

. Therefore , the 2014 HF emissions test data has been incorporated into the SPA process line discussion (see section 3.2.2 of this technology review memorandum)

. In addition to reviewing the control technology which each facility uses to control emissions, we analyze d the elemental composition analyses of phosphate rock collected by each facility in response to the section 114 request

. We performed this analysis because emissions are derived from the metals and fluoride content of the mine d phosphate rock. F acilities were required to analyze their rock (i.e., phosphate rock ore and beneficiated phosphate rock) for the content of certain metals and fluorides. We determined no distinguishable correlation between the results of the rock analyses and the emissions test dat a. Those facilities with high metals or fluoride content in their phosphate rock did not necessarily exhibit high concentration s or high normalized emission rates from their stack test. Similarly, facilities with low metals or fluoride content in their pho sphate rock did not necessarily have low concentration s or low normalized emission rates

. These observations are illustrated in the figures presented in Appendix E. Due to the fact that no correlation was observed , a facility’s phosphate rock source was no t consideredPage 10 of 85

when performing the technology review to help explain why a particular facility had high or low concentrations or high or low normalized emission rates

.

3.1 Wet

- Process Phosphoric Acid Process Lines
A WPPA pr ocess line typically consists of a reaction and digestion step (where phosphate rock is acidulated with sulfuric acid to form phosphoric acid), a filtration step (where solids are separated from the acid to produce about a 30 percent concentrated phosphoric acid), and an evaporation step (w here the concentration of phosphoric acid is increased to about 54 percent). These process steps are controlled by wet scrubbing. However, the quantity and configuration of reactors/digesters, filters, and evaporators, as well as the type and configuration of the wet scrubbing technology used to control these processes, vary significantly between each facility. Because of the inconsistencies in the arrangement of the equipment exhausting to the wet scrubbers at WPPA pr ocess lines , it was difficult to determ ine whether outlier emissions data associated with each WPPA pr ocess line were related to a control technology (when compared to all other WPPA pr ocess lines).

EPA received emissions data for 19 different emission points in WPPA pr ocess lines. We analyzed the arrangement of equipment that exhausts through each of these emission points. We determined that in order to evaluate against existing emissions limits, obtain a complete representation of total emissions associated with an individual WPPA pr ocess lin e, and to perform consistent comparisons between individual process lines, we needed to group some emission points (either by summing emissions from the various emission points that the facility tested, and/or supplementing representative emissions data fo r emission points that were not tested, but still associated with a facility’s WPPA pr ocess line). The specific treatment of these emission points are discussed below (if a facility that reported emissions is not discussed below, we determined that the fac ility reported total WPPA pr ocess line emissions data in such a way that no grouping was necessary). This methodology for consolidating emission points into individual process lines is consistent with the method of compliance for the current rule.

The Mos aic New Wales facility reported emissions from the following two emission points: an emission point that is associated with only one of three reactor/filter trains located at the facility (EP

- 11); and an emission point that is associated with all three rea ctor/filter trains located at the facility (EP

- 22 which c aptures emissions from clarifiers and tanks ). The facility did not report emissions from EP

- 12 (which is also considered a primary emission point for the WPPA pr ocess line); the emission point was no t tested because the facility stated that EP

- 12 has similar emissions to EP

- 22. In order to account for all emissions associated with only one WPPA
pr ocess line at the Mosaic New Wales facility, we adjusted the reported emissions from emission point EP

- 22 downward by the ratio of P 2 O 5 feed through each of the three reactor/filter trains. We used EP

- 22 as representative emissions data for EP

- 12, and then combined EP

- 11, EP

- 12, and EP

- 22.

To account for all emissions associated with Agrium Nu

- West’s WPPA pr oc ess line, we combined the emissions from the four emission points reported (EP

- 283; EP

- 3241; EP

- 71; and EP

- 6101). Emissions from EP

- 3241 were tripled to account for emissions from two similar emission points not reported by the facility.Page 11 of 85

The PCS White Spri ngs facility provided emissions data for three emission points (EP

69.01; EP

- 20.01; and EP

- 20.02) which encompass two WPPA pr ocess lines. We combined the emissions from emissions points EP

- 20.01 and EP

- 20.02 because these emission points are associated wit h the same WPPA pr ocess line.

The PCS Aurora facility provided emissions data for four emission points (EP

- 403; EP

404; EP

- 408; and EP

- 409) which encompass two WPPA pr ocess lines. We combined the emissions from emissions points EP

- 403 and EP

- 404 because t hese emission points are associated with the same WPPA pr ocess line. We also combined the emissions from emissions points EP

- 408 and EP

- 409 because these emission points are associated with the other WPPA
pr ocess line. Emissions from emission points EP

- 404 and EP

- 409 were doubled to account for emissions from similar emission points not reported by the facility.

The Mosaic Uncle Sam facility is configured to produce high concentration phosphoric acid via evaporators; however, the reported emissions (EP

- 01) do not represent emissions from that portion of equipment. Therefore, EP

- 01 may not be comparable to other WPPA pr ocess lines examined because EP

- 01 only represents emissions from the reaction and filtration steps. We included this emission point in our an alysis. As expected, emissions from this emission point (for each pollutant) were low compared to the emissions associated with other WPPA pr ocess lines (because all other WPPA pr ocess lines reported emissions that include high concentration phosphoric acid equipment).

The following subsections of this memorandum discuss the emissions from s pecific WPPA emission points considered to be outlier emissions data. For the purposes of this analysis, we considered emissions data an outlier if the emissions were located in the upper 33 percent of the full range of available data (the range was determined by plotting all available emission points for a specific pollutant using a uniform, even spread that was based on the lowest and highest emissions for that speci fic pollutant). These outlier emissions data may be more easily identified by referencing the charts provided in Appendix B.

3.1.1 Total Fluoride Emission Outliers for Wet Process Phosphoric Acid Emission Points Reported

Direct measurements of T F concentration w ere provided for 11 of the 12 WP PA emission points we examined. Table 3

. 1 show s T F emissions from specific stack emission points with outlier emissions data highlighted in red

.
Table 3.1: Total Fluoride Emissions from Wet Process Phosphoric Acid Emission Points

Facility EP ID Total Fluoride

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
Agrium Nu

- West Combined 1.25E

- 03 14.4 CFI Plant City EP

- stack 1.20E

- 03 2.95

Mosaic New Wales Combined 4.11E

- 03 17.1

PCS Aurora Combined 8.76E

- 04 10. 8

PCS Aurora Combined 7.69E

- 04 6.52Page 12 of 85 Facility EP ID Total Fluoride

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
PCS White Springs EP

- 69.01 8.49E

- 04 3.25 Simplot Don

- Pocatello EP

- 501 1.92E

- 04 1.08

Mosaic Uncle Sam EP

- 01 7.74E

- 05 0.54 PCS White Springs Combined 5.00E

- 04 6.77

PCS Geismar EP

- 5 2.05E

- 05 0.11 Mississippi Phosphates EP

- 1 NA a NA a
Simplot Rock Springs EP

- 50 1.47E

- 04 0.17 a) Total Fluoride analysis for this emission point was not available

The Mosaic New Wales combined emission point (EP

- 11 and EP

- 22) emits about seven times the T F concentration compared to the average of the rest of the population of T F concentration data

. When normalized to total F emissions ( pounds T F per thousand tons P 2 O 5 ), the Mosaic New Wales combined emission point (EP

- 11 and EP

- 22), the Agrium Nu

- West comb ined emission point (EP

- 283; EP

- 3241; EP

- 71; and EP

- 6101) , and the PCS Aurora combined emission point (EP 401 and EP 404) are each at least four times higher than the average of the rest of the population of data. The se emissions are still below the curren t NESHAP emission limit of 0.020 pounds T F per ton P 2 O 5
.

Th e outlier TF emissions data may be related to the control technology being used; however, it is difficult to discern because each WPPA pr ocess line operate s a unique equipment and control technology configuration (i.e., there are no WPPA pr ocess lines that operate similar configuration s to compare )

. The three primary emission points associated with Mosaic New Wales’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 11 uses crossf low technology to control a reactor, filter, and evaporators; EP

- 12 uses packed bed technology to control tanks and clarifiers; and EP

- 22 uses packed bed technology to control tanks and clarifiers, as well as an extra filtration step). Three of the four pr imary emission points associated with Agrium Nu

- West’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 71 uses crossflow technology to control a reactor, filter, evaporator, tanks and clarifiers; EP

- 6101 uses packed bed technology to control an evaporator and tanks; EP

- 3241 uses an unknown scrubbing technology to control a filtration step; and EP

- 283 is an uncontrolled barometric condenser). Both emissions points for PCS Aurora are also controlled by wet scrubbers (EP

- 401 uses a cyclone scrubber to control filters and tanks; EP

- 404 uses a cyclone scrubber to control reactor, filter, hot well, barometric condenser, and tank emissions).

3.1.2 Hydrogen Fluoride Emission Outliers for Wet Process Phosphoric Acid Emission Points Reported
Direct HF concentrat ion measurements were provided for 11 of the 12 WP PA emission points we examined. Table 3

. 2 show s HF emissions from specific stack emission points with outlier emissions data highlighted in red

.Page 13 of 85

Table 3.2: Hydrogen Fluoride Emissions from Wet Process Pho sphoric Acid Emission Points

Facility EP ID Hydrogen Fluoride

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
Agrium Nu

- West Combined 3.60E

- 04 3.82 CFI Plant City EP

- stack NA a NA a

Mosaic New Wales Combined 3.58E

- 03 11.5

PCS Aurora Combined 1.42E

- 03 12.8

PCS Aurora Combined 1.27E

- 03 7.65 PCS White Springs EP

- 69.01 1.46E

- 03 5.35 Simplot Don

- Pocatello EP

- 501 1.71E

- 04 1.06

Mosaic Uncle Sam EP

- 01 2.67E

- 05 1.91E

- 01 PCS White Springs Combined 1.05E

- 03 14.2

PCS Geismar EP

- 5 1.55E

- 03 13.5 Mississippi Phosphates EP

- 1 3.14E

- 03 9.79 Simplot Rock Springs EP

- 50 1.31E

- 04 1.50E

- 01 a) HF data for this emission point was not available

The Mosaic New Wales combined emission point (EP

- 11 and EP

- 22) and the Mississippi Phosphates emission point EP

- 1 each emit about four times the HF concentration compared to the average of the rest of the population of HF concentration data

. When normalized to HF emissions ( pounds HF per thousand tons P 2 O 5 ), the Mosaic New Wales combined emission point (EP

- 11 and EP

- 22), the PCS Aurora co mbined emission point (EP 401 and EP 404), the PCS White Springs combined emission point (EP

- 20.01 and EP

- 20.02), and the PCS Geismar emission point EP

- 5 are each at least three times higher than the average of the rest of the population of data.

Th e outli er HF emissions data may be related to the control technology being used; however, it is difficult to discern because each WPPA pr ocess line operate s a unique equipment and control technology configuration (i.e., there are no WPPA pr ocess lines that operat e similar configuration s to compare )

. The three primary emission points associated with Mosaic New Wales’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 11 uses crossflow technology to control a reactor, filter, and evaporators; EP

- 12 uses pa cked bed technology to control tanks and clarifiers; and EP

- 22 uses packed bed technology to control tanks and clarifiers, as well as an extra filtration step). Both emissions points for PCS Aurora are controlled by wet scrubbers (EP

- 401 uses a cyclone scr ubber to control filters and tanks; EP

- 404 uses a cyclone scrubber to control reactor, filter, hot well, barometric condenser, and tank emissions). The two primary emission points associated with PCS White Spring s ’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 20.01 uses packed bed technology to control reactor s , filter s , evaporators , and tanks ; and EP

- 20.02 uses packed bed technology to control filter s , evaporators , and tanks ). The WPPA pr ocess line at the PCS Geismar facility uses seven wet scrubbers of unknown scrubbing technology to control reactor s , filter s , evaporators , and tanks. The equipment configuration associated with the WPPA pr ocess line at the Mississippi Phosphates facility is considered confidential.Page 14 of 85

3.1.3 Total Metals Emission Outl iers for Wet Process Phosphoric Acid Emission Points Reported The total metals analysis discussion is based on a review of all the metals data (excluding Hg and P) even if non

- detect data were present (i.e., metal emission concentrations reported as below detection limit or detection level limited were included in the total emissions reported )

. Direct measurements of total metals concentration were provided for all 12 WP PA emission points we examined. Table 3

. 3 show s total metals emissions from specific sta ck emission points with outlier emissions data highlighted in red

. It should be noted that even though we have identified outlier emissions data, the outlier total metals emissions are very low (i.e., the total sum of all total metals emissions reported at WPPA pr ocess lines, including outliers, is about 550 pounds of tot al metals per year); this analysis was only performed to discern if the outliers are related to a control technology (when compared to all other emission points).

Table 3.3: Total Metals Emissions from Wet Process Phosphoric Acid Emission Points

Facility E P ID Total Metals

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
Agrium Nu

- West Combined 5.51E

- 06 6.10E

- 02 CFI Plant City EP

- stack 8.42E

- 06 2.28E

- 02

Mosaic New Wales Combined 1.10E

- 05 3.57E

- 02

PCS Aurora Combined 2.82E

- 06 2.48E

- 02

PCS Aurora Combined 3.72E

- 06 3.16E

- 02 PCS White Springs EP

- 69.01 6.42E

- 06 2.46E

- 02 Simplot Don

- Pocatello EP

- 501 6.70E

- 06 3.96E

- 02

Mosaic Uncle Sam EP

- 01 1.29E

- 06 9.08E

- 03 PCS White Springs Combined 7.60E

- 06 9.81E

- 02

PCS Geismar EP

- 5 1.15E

- 05 9.67E

- 02
Mississippi Phosphates EP

- 1 2.88E

- 05 8.49E

- 02 Simplot Rock Springs EP

- 50 2.77E

- 06 3.18E

- 03

The Mississippi Phosphates combined emission point EP

- 1 emits about four and one

- half times higher total metals concentration compared to the average of the rest of the entire population of total metals concentration data

. When normalized to total metals emissions ( pounds metals per thousand tons P 2 O 5 ), the Mississippi Phosphates emission point EP

- 1, the PCS White Springs combined emission point s (EP

- 20.01 and EP

- 20.02), and the PCS Geismar emission point EP

- 5 are each at least three times higher than the average of the rest of the population of data.

Th e outlier total metals emi ssions data may be related to the control technology being used; however, it is difficult to discern because each WPPA pr ocess line operate s a unique equipment and control technology configuration (i.e., there are no WPPA pr ocess lines that operate similar configuration s to compare )

. The two primary emission points associated with PCS White Spring s ’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 20.01 uses packed bed technology to control reactor s , filter s , evaporators , and tanks ; and EP

- 20.02 usesPage 15 of 85

packed bed technology to control filter s , evaporators , and tanks ). The WPPA pr ocess line at the PCS Geismar facility uses seven wet scrubbers of unknown scrubbing technology to control
reactor s , filter s , evaporators , and tanks. The equipment configuration associated with the WPPA
pr ocess line at the Mississippi Phosphates facility is considered confidential.

3.1.4 Mercury Emission Outliers for Wet Process Phosphoric Acid Emission Points Reported Direct measurements of Hg concentration (usi ng EPA Method 30B) were provided for nine of the 12 WP PA emission points we examined. Direct measurements of Hg concentration using the Ontario

- Hydro Method were also provided by facilities, but we used the measurements associated with Method 30B because t he method typically results in better detection limits

. Table 3

. 4 show s Hg emissions from specific stack emission points with outlier emissions data highlighted in red

. It should be noted that even though we have identified outlier emissions data, the outl ier Hg emissions are very low (i.e., the total sum of all Hg emissions reported at WPPA
pr ocess lines, including outliers, is about 4.0 pounds of Hg per year); this analysis was only performed to see if the outliers are related to a control technology (whe n compared to all other emission points).

Table 3.4: Mercury Emissions from Wet Process Phosphoric Acid Emission Points

Facility EP ID Mercury

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
Agrium Nu

- West Combined 4.42E

- 08 4.63E

- 04 CFI Plant City EP

- stack 7.53E

- 08 1.83E

- 04

Mosaic New Wales Combined NA NA

PCS Aurora Combined 1.63E

- 08 1.36E

- 04

PCS Aurora Combined 3.59E

- 08 2.48E

- 04 PCS White Springs EP

- 69.01 1.65E

- 07 6.39E

- 04 Simplot Don

- Pocatello EP

- 501 7.74E

- 08 4.72E

- 04

Mosaic Uncle Sam EP

- 01 NA NA PCS White Springs Combined 3.99E

- 08 5.07E

- 04

PCS Geismar EP

- 5 NA NA Mississippi Phosphates EP

- 1 1.35E

- 07 4.16E

- 04 Simplot Rock Springs EP

- 50 1.57E

- 08 1.80E

- 05

The PCS White Springs emission point (EP

- 69.01) and Mississippi Phosphates combined emission point EP

- 1 each emit about three to four times higher Hg concentration compared to the average of the rest of the entire population of total Hg concentration data

. When normalized to Hg emissions ( pounds Hg per thousand tons P 2 O 5 ), the Agrium Nu

- West combined emission point (EP

- 283; EP

- 3241; EP

- 71; and EP

- 6101), and the PCS White Springs emission point (EP

69.01) and combined emission point (EP

- 20.01 and EP

- 20.02) are each about two to three times higher than the average of the re st of the population of data.Page 16 of 85

Th e outlier total Hg emissions data may be related to the control technology being used; however, it is difficult to discern because each WPPA pr ocess line operate s a unique equipment and control technology configuration (i.e.

, there are no WPPA pr ocess lines that operate similar configuration s to compare )

. Three of the four primary emission points associated with Agrium Nu

- West’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 71 uses crossflow technology to contro l a reactor, filter, evaporator, tanks and clarifiers; EP

- 6101 uses packed bed technology to control an evaporator and tanks; EP

- 3241 uses an unknown scrubbing technology to control a filtration step; and EP

- 283 is an uncontrolled barometric condenser). Th e equipment associated with PCS White Springs’s emission point EP

- 69.01 is configured with a wet scrubber that uses crossflow technology to control a reactor, filter, and tanks . The equipment associated with PCS White Springs’s emission points EP

- 20.01 and EP

- 20.02 are each controlled by a wet scrubber (EP

- 20.01 uses packed bed technology to control reactor s , filter s , evaporators , and tanks ; and EP

- 20.02 uses packed bed technology to control filter s , evaporators , and tanks ). The equipment configuration asso ciated with the WPPA pr ocess line at the Mississippi Phosphates facility is considered confidential.

3.1.5 PM Emission Outliers for PA Emission Points Reported Direct measurements of PM concentrations were provided for 10 of 12 PA emission points we examined. Table 3

. 5 show s PM emissions from specific stack emission points with outlier emissions data highlighted in red

.

Table 3.5: Particulate Matter Emissions from Phosphoric Acid Emission Points

Facility EP ID Particulate Matter

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
Agrium Nu

- West Combined 4.90E

- 04 4.55 CFI Plant City EP

- stack NA NA
Mosaic New Wales Combined 9.80E

- 03 32.2

PCS Aurora Combined 2.93E

- 03 25.77

PCS Aurora Combined 2.46E

- 03 17.4 PCS White Springs EP

- 69.01 5.32E

- 03 19.5 Simplot Don

- Pocatello EP

- 501 4.03E

- 03 22.5

Mosaic Uncle Sam EP

- 01 2.56E

- 03 19.0 PCS White Springs Combined 3.18E

- 03 38.3

PCS Geismar EP

- 5 3.08E

- 03 27.2 Mississippi Phosphates EP

- 1 NA NA Simplot Rock Springs EP

- 50 1.48E

- 03 1.92

The Mosaic New Wales combined emission point (EP

- 11 and EP

- 22) emits about three and one

- half times higher PM concentration compared to the average of the rest of the entire population of PM concentration data

. When normalized to PM emissions ( pounds particulate per thousand tons P 2 O 5 ), the PCS White Springs combined emission point (EP

- 20.01 and EP

- 20.02) is about two times higher than the average of the rest of the population of data.Page 17 of 85

Th e outlier PM emissions data may be related to the control techn ology being used; however, it is difficult to discern because each WPPA pr ocess line operate s a unique equipment and control technology configuration (i.e., there are no WPPA pr ocess lines that operate similar configuration s to compare )

. The three primary emission points associated with Mosaic New Wales’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 11 uses crossflow technology to control a reactor, filter, and evaporators; EP

- 12 uses packed bed technology to control tanks and clarifiers; and EP

- 22 uses packed bed technology to control tanks and clarifiers, as well as an extra filtration step). The two primary emission points associated with PCS White Spring s ’s WPPA pr ocess line are each controlled by a wet scrubber (EP

- 20.01 uses packed bed t echnology to control reactor s , filter s , evaporators , and tanks ; and EP

- 20.02 uses packed bed technology to control filter s , evaporators , and tanks ).

3.2 Superphosphoric Acid Process Lines In general, there is a consistent arrangement of equipment which exhausts to control technologies at SPA process lines. Most often a SPA process line consists of nothing more than additional evaporation steps immediately following a WPPA pr ocess line; the additional evaporation steps increase the concentration of the ph osphoric acid to about 70 percent. However, some SPA process lines may also include an oxidation step to remove organic impurities from the acid (not every facility has a need to remove organic impurities, and one facility calcines their feed rock prior to processing and uses an oxidation step after processing due to the high organic content of the phosphate ore).

For all SPA process lines that we examined, emissions from the evaporators are sent to a single wet scrubber. The type of wet scrubbing system v aried between each SPA emission point (i.e., venturi, crossflow, packed bed, or other wet scrubber type ). We analyzed whether outlier emissions data associated with each SPA process line were related to a control technology (when compared to all other SPA process lines).

EPA received emissions data for seven different emission points in SPA process lines. However, we analyzed the arrangement of equipment that exhausts through each of these emission points and determined that it was necessary to combine the Agrium Nu

- West emissions points EP

- 541 and EP

- 522 (i.e., by summing the reported emissions) in order to obtain a complete representation of total emissions associated with the individual SPA process line that includes an oxidation reactor. After combining the emission points, we could compare the emissions to another facility (Simplot Don

- Pocatello) that also operates an oxidation reactor as part of their SPA process line as indicated in the facility’s Title V permit. This methodology for consolidating emi ssion points into individual process lines is consistent with the method of compliance for the rule

. The following subsections of this report discuss the emissions from s pecific SPA emission points considered to be outlier emissions data. For purposes of t his analysis, we considered emissions data an outlier if the emissions were located in the upper 33 percent of the full range of available data (the range was determined by plotting all available emission points for a specific pollutant using a uniform, ev en spread that was based on the lowest and highest emissions for that specific pollutant). These outlier emissions data may be more easily identified by referencing the charts provided in Appendix C.Page 18 of 85

3.2.1 Total F luoride Emission Outliers for Superphosphoric Acid Emission Points Reported
Direct TF concentration measurements were provided for all six SPA emission points we examined. Table 3

. 6 show s total F emissions from specific stack emission points with outlier emissions data highlighted in red

.

Table 3.6: Total Fluoride Emissions from Superphosphoric Acid Emission Points

Facility EP ID Control Technology Total Fluorides

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Agrium Nu

- West 1,2 Combined Crossflow Scrubber 4.45E

- 03 6.84
Simplot Don

- Pocatello 1,3 EP

- 401 Packed Bed Scrubber 4.53E

- 04 4.76E

- 01 PCS White Springs EP

- 70.01 Other Scrubber Type 1.62E

- 03 7.63

PCS Aurora EP

- 331 Venturi Scrubber 3.34E

- 04 1.39E

- 01

PCS Aurora EP

- 332 Venturi Scrubber 6.13E

- 04 2.36E

- 01 Simplot Rock Springs EP

- 40 Venturi Scrubber 7.69E

- 04 1.38 Notes: 1. Emissions from the oxidation reactor process are included. 2. Emissions from the oxidation reactor process are uncontrolled. 3. Emissions from the oxidation reactor process are controlled.

The Agrium Nu

- West combined emission point (EP

- 522 and EP

- 541) emits about six times the TF concentration compared to the average of the rest of the population of TF concentration data

. When normalized to TF emissions ( pounds T F per thousand tons P 2 O 5 ), th e Agrium Nu

- West combined emission point (EP

- 522 and EP

- 541) and the PCS White Springs emission point EP

- 70.01 are each at least 12 times higher than the average of the rest of the population of data. The se emissions are still below the current NESHAP emis sion limit of 0.010 pounds T F per ton P 2 O 5
. We determined that the uncontrolled oxidation process associated with the Agrium Nu

West SPA process line only contributes a small percentage to the observed high T F emissions. If the emissions associated with ju st the oxidation process were removed from the analysis, the TF emissions ( pounds T F per thousand tons P 2 O 5 ) from the Agrium Nu

- West SPA process line, would still be at least 10 times higher than the average emissions of the rest of the population (exclud ing the PCS White Springs emission point EP

- 70.01). This outlier TF emissions data may be related to the crossflow scrubbing technology being used; however, it is difficult to be certain because there are no other emission points that operate a similar scrubber to compare

. We are unable to conclude whether control technology plays a role on the PCS White Spring outlie r TF emissions data point because we do not know the type of scrubber being used to control this specific SPA process line.

3.2.2 HF Emission Outliers for SPA Emission Points Reported Direct measurements of HF concentration were provided for the six SPA emission points we examined. HF emissions data from both the 2010 section 114 testing and 2014 section 114 testing are included in the HF outlier analysis for Agrium Nu

- West. Table 3

. 7 show s HF emissions from specific stack emission points with outlier emissions d ata highlighted in red

.Page 19 of 85

Table 3.7: Hydrogen Fluoride Emissions from Superphosphoric Acid Emission Points

Facility EP ID Control Device Hydrogen Fluoride

Test Year (gr/dscf) (lbs/thousand tons of P 2 O 5 )

Agrium Nu

- West 1,2 Combined Crossflow Scrubber 2010 6.80E

- 03 9.9
Agrium Nu

- West 1,2 Combined Crossflow Scrubber 2014 1.41E

- 01 19.7
Simplot Don

- Pocatello 1,3 EP

- 401 Packed Bed Scrubber 2010 8.58E

- 04 6.73E

- 01 PCS White Springs EP

- 70.01 Other Scrubber Type 2010 7.59E

- 04 3.56

PCS Aurora EP

- 331 Venturi Scrubber 2010 5.66E

- 04 3.80E

- 01

PCS Aurora EP

- 332 Venturi Scrubber 2010 2.00E

- 03 1.24E+00 Simplot Rock Springs EP

- 40 Venturi Scrubber 2010 5.95E

- 04 1.27 Simplot Rock Springs EP

- 40 Venturi Scrubber 2014 1.08E

- 03 4.52 Notes: 1. Emissions from the oxidation reactor process are included. 2. Emissions from the oxidation reactor process are uncontrolled. 3. Emissions from the oxidation reactor process are controlled.

The Agrium Nu

- West combined emission point (EP

- 522 and EP

- 541 ) emits about seven times (referring to 2010 Agrium Nu

- West test data) or 144 times (referring to 2014 Agrium Nu

West test data) the HF concentration compared to the average of the rest of the population of HF concentration data

. When normalized to HF emissions ( pounds HF per thousand tons P 2 O 5 ), the same emission point is about five times (referring to 2010 Agrium Nu

- West test data) or ten times (referring to 2014 Agrium Nu

- West test data) higher than the average of the rest of the population of data.

We determined that the uncontrolled oxidati on process (EP

- 541) associated with the Agrium Nu

- West SPA process line may contribute a significant percentage to the observed high HF emissions. While the oxidation process contribute d only four percent of the HF emissions based on the 2010 test data, th e oxidation process contributed 81 percent of the SPA process line emissions based on 2014 test data

. This 2014 HF data exceed the proposed HF limit for SPA process lines in subpart AA. The lack of control technology for the oxidation process is a main factor when examining the emissions data. If this emission point we re controlled by a wet scrubber , the Agrium Nu

- West SPA process line 2014 HF data would not be consider ed an outlier nor exceed the proposed HF limit

. In addition, the use of wet scrubbing technology would be consistent with other SPA process lines, where all applicable emission points are controlled by wet scrubbers.

3.2.3 Total Metals Emission Outliers for Superphosphoric Acid Emission Points Reported The total metals analysis discussion is ba sed on a review of all the metals data (excluding Hg and P) even if non

- detect data were present (i.e., metal emission concentrations reported as below detection limit or detection level limited were included in the total emissions reported )

. Direct measur ements of total metals concentration were provided for all six SPA emission points we examined. Table 3

. 8 show s total metals emissions from specific stack emission points with outlier emissions data highlighted in red

. It should be noted that even though w e have identifiedPage 20 of 85

outlier emissions data, the outlier total metals emissions are very low (i.e., the total sum of all total metals emissions reported at SPA process lines, including outliers, is about 170 pounds of total metals per year); this analysis was only performed to see if the outliers are related to a control technology (when compared to all other emission points).

Table 3.8: Total Metals Emissions from Superphosphoric Acid Emission Points

Facility EP ID Control Technology Total Metals

(gr/dscf ) (lbs/thousand

tons of P 2 O 5 )

Agrium Nu

- West 1,2 Combined Crossflow Scrubber 4.54E

- 06 6.93E

- 03 Simplot Don

- Pocatello 1,3 EP

- 401 Packed Bed Scrubber 1.18E

- 05 1.10E

- 02 PCS White Springs EP

- 70.01 Other Scrubber Type 1.01E

- 04 4.38E

- 01

PCS Aurora EP

- 331 Venturi Scrubber 3.36E

- 06 1.89E

- 03

PCS Aurora EP

- 332 Venturi Scrubber 4.14E

- 06 4.25E

- 03 Simplot Rock Springs EP

- 40 Venturi Scrubber 1.48E

- 04 3.01E

- 01
Notes: 1. Emissions from the oxidation reactor process are included. 2. Emissions from the oxidation reactor process are uncontrolled. 3. Emissions from the oxidation reactor process are controlled.

The PCS White Springs emission point EP

- 70.01 and Simplot Rock Springs emission point EP

- 40 each emit at least 17 times higher total metals concentration compared to the average of the rest of the entire population of total metals concentration data

. When normalized to total metals emissions ( pounds metals / thousand tons P 2 O 5 ), these emission points are each at least 50 times higher than the average of the rest of the population of data.

We are unable to conclude whether control technology plays a role on the PCS White Spring outlier total metals emissions data point because we do not know the type of scrubber being used to control this specific SPA process line. As in dicated in the facility’s air permit , the Simplot Rock Springs emission point EP

- 40 uses a venturi scrubber. This outlier total metals emissions point does not appear to be related to the control technology because there are other emission points with simi lar control technologies that reported much lower emissions

.

3.2.4 Mercury Emission Outliers for Superphosphoric Acid Emission Points Reported Direct measurements of Hg concentration (using Method 30B) were provided for four of the six SPA emission points we examined. Direct measurements of Hg concentration using the Ontario

- Hydro Method were also provided by facilities, but we used the measurements associated with Method 30B because the method typically results in better detection limi ts

. Table 3

. 9 show s Hg emissions from specific stack emission points with outlier emissions data highlighted in red

. It should be noted that even though we have identified outlier emissions data, the outlier Hg emissions are very low (i.e., the total sum of all Hg emissions reported at SPA process lines, including outliers, is less than 1.0 pound of Hg per year); this an alysis was only performed to see if the outliers are related to a control technology (when compared to all other emission points).Page 21 of 85 Table 3.9: Mercury Emissions from Superphosphoric Acid Emission Points

Facility EP ID Control Technology Mercury

(gr/ dscf) (lbs/thousand

tons of P 2 O 5 )

Agrium Nu

- West 1,2 Combined Crossflow Scrubber 2.98E

- 08 4.33E

- 05 Simplot Don

- Pocatello 1,3 EP

- 401 Packed Bed Scrubber 1.84E

- 07 2.05E

- 04 PCS White Springs EP

- 70.01 Other Scrubber Type 2.49E

- 08 1.35E

- 04

PCS Aurora EP

- 331 Venturi Scrubber NA NA

PCS Aurora EP

- 332 Venturi Scrubber NA NA Simplot Rock Springs EP

- 40 Venturi Scrubber 1.53E

- 07 3.28E

- 04
Notes: 1. Emissions from the oxidation reactor process are included. 2. Emissions from the oxidation reactor process are uncontrolled. 3. Emissions from the oxidation reactor process are controlled.

The Simplot Don

- Pocatello emission point EP

- 401 and Simplot Rock Springs emission point identified EP

- 40 each emit at least five and one

- half times higher Hg concentration compared to the average of the rest of the entire population of Hg concentration data. When normalized to Hg emissions ( pounds Hg per thousand tons P 2 O 5 ), the Simplot Rock Springs emission point identified EP

- 40 is about two and one

- half tim es higher than the average of the rest of the population of data.

The outlier total metals emissions data for Simplot Don

- Pocatello may be related to the packed bed scrubbing technology being used; however, it is difficult to be certain because there are no other emission points that operate a similar scrubber to compare. The Simplot Rock Springs emission point EP

- 40 uses a venturi scrubber; this out lier Hg emission point does not appear to be related to the control technology because there are other emission points with similar control technologies that reported much lower emissions

.

3.2.5 Particulate Matter Emission Outliers for Superphosphoric Acid Emiss ion Points Reported Direct measurements of PM concentration were provided for all six SPA emission points we examined. Table 3

. 10 show s PM emissions from specific stack emission points with outlier emissions data highlighted in red

.

Table 3.10: Particulat e Matter Emissions from Superphosphoric Acid Emission Points

Facility EP ID Control Technology Particulate Matter

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Agrium Nu

- West 1,2 Combined Crossflow Scrubber 7.73E

- 04 1.60 Simplot Don

- Pocatello 1,3 EP

- 401 Packed Bed Scrubber 4.13E

- 03 3.92 PCS White Springs EP

- 70.01 Other Scrubber Type 9.08E

- 04 5.22

PCS Aurora EP

- 331 Venturi Scrubber 3.38E

- 03 2.15E+00

PCS Aurora EP

- 332 Venturi Scrubber 5.32E

- 03 2.78Page 22 of 85 Facility EP ID Control Technology Particulate Matter

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )
Simplot Rock Springs EP

- 40 Venturi Scrubber 2.57E

- 03 5.79
Notes: 1. Emissions from the oxidation reactor process are included. 2. Emissions from the oxidation reactor process are uncontrolled. 3. Emissions from the oxidation reactor process are controlled.

The Simplot Don

- Pocatello emission point EP

- 401 and PCS Aurora emi ssion point EP

332 each emit at least two times higher PM concentration compared to the average of the rest of the entire population of PM concentration data

. When normalized to PM emissions ( pounds particulate per thousand tons P 2 O 5 ), the Simplot Rock Springs emission point identified as EP

- 40 and PCS White Springs EP

- 70.01 are two times higher than the average of the rest of the population of data.

The outlier PM emissions data for Simplot Don

- Pocatello may be related to the packed bed scrubbing techn ology being used; however, it is difficult to be certain because there are no other emission points that operate a similar scrubber to compare. The PCS Aurora emission point EP

- 332 and Simplot Rock Springs emission point EP

- 40 each use a venturi scrubber. These outlier PM emission points do not appear to be related to the control technology because there are other emission points with similar control technologies that reported much lower emissions

. We are unable to conclude whether control technology plays a role on the PCS White Spring outlier PM emissions data point because we do not know the type of scrubber being used to control this specific SPA process line.

3.3 Purified Phosphoric Acid Process Lines
PPA is used in technical and food grade manufacturing

, although both technical and food grade acid can be produced through other processes . There is only one facility (PCS Aurora) located in the United States that produces PPA through a solvent extraction process . The following is a description of their operat ion for which we paraphrased from information provided in the section 114 responses

. The PCS Aurora PPA operations consist of two process lines where p hosphoric acid is mixed with a solvent in one of two extraction columns operated in parallel. The phosph oric acid

- solvent extract streams enter one of two release columns ( also operated in parallel ) . A stream of purified, low

- alkali phosphoric acid is recovered from near the middle of each release column; a stream of purified, high

- alkali phosphoric acid is recovered from near the bottom of each column. The high

- alkali acid streams from the release columns are passed through stream strippers where residual solve nt is removed and recycled to solvent storage tank s . The se tanks ( a s well as other process vessels ) are kept under a nitrogen blanket system that vents to a chilled stack where the solvent is condense d for reuse. Spray tower scrubbers control the fluoride emissions from the concentrators and defluorination columns in the low alkali acid and high alkali acid
streams.Page 23 of 85

As part of the section 114 request , PCS Aurora tested emission point EP

- 501 (which is associated with a chiller used to reclaim solvent), and emission point EP

- 502 (which is associated with a spray tower scrubber that controls emissions from one of their PPA process lines). EP

- 501 was only tested for MIBK. The emissions data are presented in Table 3.11; however, it is not possible to discern whether the control technology being used at these emission points is more (or less) effective than ano ther because there are no other PPA solvent extraction process lines to compare.

Table 3.11: Emissions from Purified Phosphoric Acid Solvent Extraction Emission Points

Pollutant EP

- 501 EP

- 502

(gr/dscf) (lbs/thousand

tons of P 2 O 5 ) (gr/dscf) (lbs/thousand tons of P 2 O 5 )

Total Flourides NA NA 5.92E

- 04 5.00E

- 01 Hydrogen Flouride NA NA NA NA
Total Metals NA NA 2.03E

- 06 1.73E

- 03
Mercury NA NA NA NA
Total Particulate NA NA 1.07E

- 03 0.95 Methyl Isobutyl
Ketone NA 44.3 NA NA

3.4 Phosphate Rock Dryers As part of the section 114 request , PCS Aurora tested emission point EP

- 210 which is associated with a venturi scrubber that controls emissions from a phosphate rock dryer. The dryer was used to decrease moisture in the wet phosphate rock (downstream of mi ning and beneficiation) from approximately 10 percent moisture , to less than one percent moisture. However, following the section 114 submission the facility indicated that the dryer is no longer used for the purpose of phosphoric acid production. The emissions data are presented in Table 3.12; however, it is not possible to discern whether the control technology being used at this emission points is more (or less) effective than another because there are no other phosphate rock dryer emission data to compare. T he PM emissions from EP

- 210 are below the current NESHAP emission limit of 0.215 pounds PM per ton P 2 O 5
.

Table 3.1 2 : Emissions from Phosphate Rock Dryer Emission Points

Pollutant EP

- 210

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Total Flourides 3.09E

- 04 1.21 Hydrogen Flouride 8.27E

- 05 2.80E

- 01

Total Metals 4.93E

- 05 1.78E

- 01
Mercury 3.06E

- 07 1.13E

- 03

Total Particulate 1.72E

- 02 54.5Page 24 of 85

3.5 Phosphate Rock Calciners There is only one facility (PCS Aurora) located in the United States that operates phosphate rock calciners. These fluidized bed calciners (a total of six at PCS Aurora ) remove organic impurities from the phosphate rock prior to acidulat ion with sulfuric acid to form phosphoric acid. The calciners consist of a pre

- heat section, fluidized bed calcination, and a cooling compartment for the calcined rock. Emissions from the pre

- heat section and the cooling compartment of each calciner exhaust through individual cyclones and a venturi scrubber, using water as the scrubbing solution. Each calc iner is also equipped with a wet electrostatic precipitator (WESP) following the scrubber for additional emissions control. The se calciners had wet scrubbers installed prior to the current NESHP PM limits being promulgated. To meet the current PM limits, the facility added WESP in addition to the previously installed wet scrubbers. The emissions data are presented in Table 3.13; how ever, it is not possible to discern whether the control technology being used at these emission points is more (or less) effective than another because there are no other phosphate rock calciner emission data to compare. T he PM emissions are below the curr ent NESHAP emission limit of 0.080 grains PM per dry standard cubic foot

. Based on the data submitted by facilities in response to the April 2010 CAA section 114 request, PM emissions from these units vary from 0.0012 to 0.0695 grains PM per dry standard c ubic foot. This range of emissions indicates that the current limits represent expected performance of the control technology configuration

. Also, the Hg emissions are considerably higher than any other emission source located a t a phosphoric acid manufact uring plant (i.e., Hg emissions from phosphate rock calciners are approximately 98 percent of the total Hg emissions attributed to the phosph oric acid manufacturing plant source category)

.

Table: 3.13: Emissions f rom Phosphate Rock Calciner Emission Points

Pollutant EP

- 203

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Total Flourides 1.06E

- 04 4.46E

- 01 Hydrogen Flouride 1.66E

- 04 1.51
Total Metals 6.25E

- 06 4.57E

- 02
Mercury 1.44E

- 05 8.16E

- 02

Total Particulate 3.80E

- 03 25.9

3.6 Diammonium and/or Monoammonium Phosphate Fertilizer Process Lines An APF process line typically consists of a reaction step (where anhydrous ammonia is reacted with phosphoric acid to form diammonium phosphate and monoammonium phosphate), a granulation step (where solidification occurs) , and finishing operations (where the solid material is dried, cooled, and sent through a screening arrangement for particle segregation).

EPA received emissions data for 14 different emission points in APF process lines. We analyzed the arrangement of eq uipment that exhausts through each of these emission points and determined that it was necessary to combine (i.e., by summing the reported emissions) the three Simplot Don

- Pocatello emission points (EP

- 101; EP

- 102; and EP

- 103); as well as the two Mississip pi Phosphates emission points (EP

- 1 and EP

- 2), in order to evaluate against existingPage 25 of 85

emissions limits, obtain a complete representation of total emissions associated with an individual APF process line, and to perform consistent comparisons between individ ual APF process lines. We also determined that CFI Plant City reported two sets of emissions for the same emission point (i.e., the facility based these two sets of emissions on the type of APF process they tested); therefore, for simplicity we chose to co nsider only the set with higher emissions. This methodology for consolidating emission points into individual process lines is consistent with the method of compliance for the current rule

. In general, there is a consistent arrangement of equipment which exhausts to control technologies at APF process lines. For nine of the 11 APF emission points we examined, emissions from reactors and granulators are combined before going to a wet scrubber followed by another (final) wet scrubber. For these nine APF emission points, the d ryer, screen, mill, and cooler emissions are fed individually or combined to cyclones, followed by a wet scrubber, and are also sent to the final wet scrubber. The primary difference be tween these nine APF emission points is inherent to the type of wet scrubber(s) being used. The remaining APF emission points we examined (that are associated with reactors and granulators ) operate only one non

- packed bed wet scrubber. Tables 3

. 14 through 3

. 17 show how we categorized each APF emission point based on equipment and control technology configuration. Table 3

. 18 provides a legend for each “specific equipment and control technology layout” presented in Tables 3

. 14 through 3

. 17

.Page 26 of 85 

### Table 3

. 14 : Ammonium Phosphate Fertilizer Emission Point Configuration A

 Reactor/granulator operations vent through at least one venturi scrubber, and always a single packed bed (or impingement) scr ubber in series.

 Dryer operations vent through a cyclone, at least on e venturi scrubber, and always a single packed bed (or impingement) scrubber in series.

 Screen, Mill, and Cooler operations vent through a cyclone, a venturi scrubber, and a single packed bed scrubber (or impingem ent) in series.

Facility Process ID EP Specific Equipment and Control Technology Layout Final Control Technology

Mosaic New Wales P

- 2 EP

- 05 ScrImFW ( ScrVPA ( PreScrubber ( Reactor,Granulator ) +Cycl ( Screens,Mill ) +Cycl ( Cooler ) ) + ScrVPA ( Cycl ( Dryer ) ) ) Scrubber

- Impingement
CFI Plant City Y

- DAP/

Y

- MAP EP

- stack ScrPBFW ( ScrVPW ( ScrVPA ( Reactor,Granulator ) ) +ScrVPW ( ScrVPA ( Cycl ( Dryer ) ) ) + ScrVPA ( Cycl ( Screens,Mills ) ) +ScrVPW ( Cycl ( Cooler ) ) ) Scrubber

- Packed Bed

Mosaic Bartow P

- 23 EP

- 2 ScrPBPW ( ScrVPA ( Cycl ( Dryer ) ) ) +ScrPBPW ( ScrVPA ( ( Reactor,Granulator ) +Cycl ( Screens,Mills ) ) + ScrVPW ( Cycl ( Cooler ) ) ) Scrubber

- Packed Bed

PCS Aurora 303 EP

- 303 ScrPBFW ( ScrVPA ( Reactor,Granulator ) +ScrVPA ( Cycl ( Screens,Mill ) +Cycl ( Cooler ) ) ) + ScrPBFW ( ScrVPA ( Cycl ( Dryer ) ) ) Scrubber

- Packed Bed Simplot Rock Springs P

- 1 EP

- 10 Not available, PFD is CBI Scrubber

- Packed Bed

**This drawing is intended to assist the reader in understanding Configuration A; however, it does not reflect the actual qua ntity of the equipment and/or control technologies located at each facility. For example, the dryer emissions may feed to the same controls used by the screens, mills, and cooler (and not to a separate, dedicated set of controls); this example would still be considered Configuration A .**Page 27 of 85 

### Table 3

. 15 : Ammonium Phosphate Fertilizer Emis sion Point Configuration B

 Reactor/granulator operations vent through at least two wet scrubbers in series ( no packed bed scrubbers).

 Dryer operations vent through a cyclone, and two wet scrubbers in series ( no packed bed scrubbers).

 Screen, Mill, and Cooler operations vent through a cyclone, and two wet scrubbers in series ( no packed bed scrubbers).

Facility Process

ID EP Specific Equipment and Control Technology Layout Final Control Technology

PCS Aurora 302 EP

- 302 ScrUFWCa ( ScrVProcW ( Reactor,Granulator ) +ScrUProcW ( Cycl ( Dryer ) ) + ScrUProcW ( Cycl ( Screens,Mills ) ) +ScrUProcW ( Cycl ( Cooler ) ) ) Scrubber

- Unknown

Mosaic Faustina P

- 43 EP

- 07 ScrVPW ( ScrU ( Reactor ) +ScrU ( Granulator ) +ScrU ( Cycl ( Dryer ) ) +ScrU ( Cycl( Screens,Mill,Cooler ) ) ) Scrubber

- Venturi MS Phosphates a P

- 2 EP

- 1 Not available, PFD is CBI Baghouse
MS Phosphates a P

- 2 EP

- 2 Not available, PFD is CBI Scrubber

- Unknown

a

— I n order to use MS Phosphates emissions data, EP

- 1 and EP

- 2 were added together because the equipment associated with these emission points are similar to the type of equipment and control as the other configuration B emission points ; however, the emissions exit two stacks instead of one . Note: emissions from EP

- 2 are only vented through a baghouse in lieu of a cyclone and two scrubbers in series.

**This drawing is intended to assist the reader in understanding Configuration B ; however, it does not reflect the actual quantity of the equipment and/or control technologies located at each facility. For example, the dryer emissions may feed to the same controls used by the screens, mills, and cooler ( and not to a separate, dedicated set of controls); t his example would stil l be considered Configuration B .**Page 28 of 85 

### Table 3

. 16 : Ammonium Phosphate Fertilizer Emission Point Configuration C

 Reactor/granulator operations vent through one venturi scrubber.

 Dryer operations vent through one venturi scrubber.

 Screen, Mill, and Cooler operations vent through at least a baghouse.

Facility Process

ID EP Specific Equipment and Control Technology Layout Final Control Technology

Agrium Nu

- West Gran EP

- 6 ScrVRW ( Cycl ( Dryer+BH ( Cooler,Screens,Mills ) ) ) +ScrVRW ( Reactor,Granulator ) Scrubber

- Venturi Simplot Don

Pocatello a P

- 1 EP

- 101 ScrVProcWPA ( Reactor,Granulator ) Scrubber

- Venturi Simplot Don

Pocatello a P

- 1 EP

- 102 ScrVProcWPA ( Dryer ) Scrubber

- Venturi Simplot Don

Pocatello a P

- 1 EP

- 103 Not available, PFD is CBI Baghouse

a

— I n order to use Simplot Don

- Pocatello emissions data, EP

- 101, EP

- 102, and EP

- 103 were added together because the equipment associated with these emission points are similar to the type of equipment and control as the other configuration C emission points; h owever, the emissions exit three stacks instead of one

.

**This drawing is intended to assist the reader in understanding Configuration C; however, it does not reflect the actual qua ntity of the equipment and/or control technologies located at each facility. For example, the dryer emissions may feed to the same venturi scrubber as the reactor and granulator ( and not to a separate, dedicated venturi scrubber ); t his example would stil l be considered Configuration C .**Page 29 of 85 

### Table 3.17 : Ammonium Phosphate Fertilizer Emission Point Configuration D

 Reactor/granulator operations vent through one venturi scrubber and two packed bed scrubber in series.

 Dryer operations vent through a cyclone, venturi scrubber, and two packed bed scrubber in series.

 Screen and Mill operations vent through a cyclone, venturi scrubber, and two packed bed scrubber in series. (no cooler operations)

Facility Process

ID EP Specific Equipment and Control Technology Layout Final Control Technology
PCS White Springs 32 EP

- 32 ScrPBCaFW ( ScrPBPW ( ScrVPA ( Reactor,Granulator ) ) +ScrPBPW ( ScrVPA ( Cycl ( Dryer ) ) ) + ScrPBPW ( ScrVPA ( Cycl ( Screens,Mills ) ) ) ) Scrubber

- Packed Bed

**This drawing is intended to assist the reader in understanding Configuration D ; however, it does not reflect the actual quantity of the equipment and/or control technologies located at each facility. For example, the dryer emissions may feed to the same controls used by the screens and mills ( and not to a separate, dedicated set of controls); t his example would stil l be considered Configuration D .**Page 30 of 85



### Table 3 .1 8 : Legend For Specific Control Technology Layout For Ammonium

Phosphate Fertilizer Emission Points

Abbreviations Used For Control Technology Layout

Cycl Cyclone BH Baghouse Scr Scrubber

Abbreviations Specific To Scrubbers

Scrubber T

ypes: U Unknown Scrubber Type, Information Was Not Provided V Venturi Scrubber C Crossflow Scrubber PB Packed Bed Scrubber Im Impingement Scrubber Cy Cyclonic Scrubber ST Spray Tower

Scrubbing Liqu id : PW = Pond Water FW = Fresh Water ProcW = Process Water PA = Phosphoric Acid Ca = Caustic RW = Recirculating Water

As an example, a packed bed scrubber which uses pond water as the scrubbing liquid is displayed in Tables 3.14 through 3.17 as “ ScrPBPW ”. In certain cases multiple liqu ids are used; when this occurs

, both liqu id abbreviations are the n provided one after the other.Page 31 of 85

The following subsections of this report discuss the emissions from s pecific APF emission points (grouped by configuration) considered to be outlier emissions data. For the purposes of this analysis, we considered emissions data an outlier if the emissions were located in the upper 33 percent of the full range of available data (the range was determined by plotting all availabl e emission points for a specific pollutant using a uniform, even spread that was based on the lowest and highest emissions for that specific pollutant). These outlier emissions data may be more easily identified by referencing the charts provided in Append ix D.

3.6.1 Total F luoride Emission Outliers for Ammonium Phosphate Fertilizer Emission Points Reported
Direct measurements of TF concentration were provided for nine of the 11 APF emission points we examined. Table 3

. 19 show s TF emissions from specific stack emission points (grouped by configuration) with outlier emissions data highlighted in red

.

Table 3.19: Total Fluoride Emissions from Ammonium Phosphate Fertilizer Emission Points Grouped By Configuration

Facility EP ID Configuration Total Fluorides

( gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Mosaic New Wales EP

- 05 A 3.42E

- 03 61. 9 CFI Plant City EP

- stack A 3.26E

- 04 8.87

Mosaic Bartow EP

- 2 A 3.80E

- 04 6.45

PCS Aurora EP

- 303 A 6.79E

- 04 16.0 Simplot Rock Springs EP

- 10 A 1.40E

- 04 2.94

PCS Aurora EP

- 302 B 6.27E

- 05 1.21 Mississippi Phosphates Combined B NA NA

Mosaic Faustina EP

- 07 B NA NA Simplot Don

- Pocatello Combined C 2.58E

- 04 4.39 Agrium Nu

- West EP

- 6 C 3.79E

- 03 53.4
PCS White Springs EP

- 32 D 1.17E

- 03 29.2

The Mosaic New Wales EP

- 05 and Agrium Nu

- West EP

- 6 emission point s each emit at least eight times the TF concentration compared to the average of the rest of population of total F concentration data

. When normalized to TF emissions ( pounds T F / thousand tons P 2 O 5 ), the emission point s are more than five and one

- half times higher than the average of the rest of the population of data.

The Mosaic New Wales emission point follows configuration A and Agrium Nu

- West emission point EP

- 6 uses configuration C (see Table 3.16). These outlier TF emissions data do not appear to be related to the control technology because there are other emission points of similar configurations that reported lower emissions

.Page 32 of 8 5

3.6.2 H ydrogen F luoride Emission Outliers for Ammonium Phosphate Fertilizer Emission Points Re ported Direct measurements of HF concentration were provided for 10 of the 11 APF emission points we examined. Table 3

. 20 show s HF emissions from specific stack emission points (grouped by configuration) with outlier emissions data highlighted in red

. Table 3.20: Hydrogen Fluoride Emissions from Ammonium Phosphate Fertilizer Emission Points Grouped By Configuration

Facility EP ID Configuration Hydrogen Fluoride

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Mosaic New Wales EP

- 05 A 3.38E

- 03 59.1

CFI Plant City EP

- stack A NA NA

Mosaic Bartow EP

- 2 A 1.36E

- 03 23.4

PCS Aurora EP

- 303 A 2.16E

- 03 42.3 Simplot Rock Springs EP

- 10 A 2.20E

- 04 4.89

PCS Aurora EP

- 302 B 8.07E

- 05 2.10 Mississippi Phosphates Combined B 2.00E

- 03 41.9

Mosaic Faustina EP

- 07 B 3.14E

- 05 0.86 Simplot Don

- Pocatello Combined C 3.03E

- 04 5.86 Agrium Nu

- West EP

- 6 C 1.52E

- 02 208.2
PCS White Springs EP

- 32 D 1.09E

- 03 22.1

The Agrium Nu

- West emission point EP

- 6 emits about 13 times the HF concentration compared to the average of the rest of population of HF concentration data

. When normalized to HF emissions ( pounds HF per thousand tons P 2 O 5 ), the emission point is about nine times higher than the average of the rest of the population of data.

The Agrium Nu

- West emission point EP

- 6 uses the control technology identified in configuration C (see Table 3.16). This outlier HF emissions point does not appear to be related to the control technology because there are other emission points of similar configuration that reported much lower emissions

.

3.6.3 Total Metals Emission Outliers for Ammonium Phosphate Fertilizer Emission Points Reported The total metals analysis discussion is based on a review of all the metals data (excluding Hg and P) even if non

- detect data were present (i.e., metal emission concentrations reported as below detection limit or detection level limited were included in the total emissions reported )

. Direct concentration measurements of total metals were provided for all 11 APF emission points we examined. Table 3

. 21 show s total m etals emissions from specific stack emission points (grouped by configuration) with outlier emissions data highlighted in red

. It should be noted that even though we have identified outlier emissions data, the outlier total metals emissions are very low (i .e., the total sum of all total metals emissions reported at APF process lines, includingPage 33 of 85

outliers, is about 1.0 ton of total metals per year); this analysis was only performed to see if the outliers are related to a control technology (when compared to all other emission points).

Table 3.21: Total Metals Emissions from Ammonium Phosphate Fertilizer Emission Points Grouped By Configuration

Facility EP ID Configuration Total Metals

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Mosaic New Wales EP

- 05 A 1.29E

- 05 2.42E

- 01 CFI Plant City EP

- stack A 1.79E

- 05 4.68E

- 01

Mosaic Bartow EP

- 2 A 5.96E

- 06 9.72E

- 02

PCS Aurora EP

- 303 A 2.27E

- 05 4.72E

- 01 Simplot Rock Springs EP

- 10 A 3.46E

- 06 7.36E

- 02

PCS Aurora EP

- 302 B 1.02E

- 05 3.02E

- 01 Mississippi Phosphates Combined B 8.61E

- 05 1.76

Mosaic Faustina EP

- 07 B 1.56E

- 05 4.41E

- 01 Simplot Don

- Pocatello Combined C 1.12E

- 05 2.01E

- 01 Agrium Nu

- West EP

- 6 C 4.39E

- 06 8.28E

- 02 PCS White Springs EP

- 32 D 9.35E

- 06 1.92E

- 01

The Mississippi Phosphates combined emission point (EP

- 1 and EP

- 2) has a significantly higher (about seven times higher) total metals concentration and normalized emissions when compared to the average of the rest of the population of total metals data

.

The Mississippi Phosphates emission point EP

- 2 uses the control technology identified in configuration B (see Table 3.15). This outlier total metals emissions data point does not appear to be related to the control technology because there are other emission points of similar config uration that reported much lower emissions

.

3.6.4 Me r

cury Emission Outliers for Ammonium Phosphate Fertilizer Emission Points Reported Direct measurements of Hg concentration (using Method 30B) were provided for six of the 11 APF emission points we examined; however, we did not use one of these measurements because there were no test method verification tests included with the measurement. Direct measurements of Hg concentration using the Ontario

- Hydro Method were also provided by facilities, but we used the measurements associated with Method 30B because the method typically results in better detection limits

. Table 3

. 22 show s Hg emissions from specific stack emission points with outlier emissions data highlighted in red

. It should be noted that even though we have identified outlier emissions data, the outlier Hg emissions are very low (i.e., the total sum of all Hg emissions reported at APF process lines, including outliers, is about 38.0 pounds of Hg per year); this analysis was only performed to see if the outliers are related to a control technology (when compared to all other emission points).Page 34 of 85

Table 3.22: Mercury Emissions From Ammonium Phosphate Fertilizer Emission Points Grouped By Configuration

Facility EP ID Configuration Mercury

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Mosaic New Wales EP

- 05 A NA NA CFI Plant City EP

- stack A 1.23E

- 07 3.32E

- 03

Mosaic Bartow EP

- 2 A NA NA

PCS Aurora EP

- 303 A NA NA Simplot Rock Springs EP

- 10 A 3.03E

- 08 8.78E

- 04

PCS Aurora EP

- 302 B NA NA Mississippi Phosphates Combined B 2.09E

- 07 4.65E

- 03

Mosaic Faustina EP

- 07 B NA NA Simplot Don

- Pocatello Combined C 5.25E

- 07 9.96E

- 03
Agrium Nu

- West EP

- 6 C 4.46E

- 08 5.75E

- 04 PCS White Springs EP

- 32 D 4.01E

- 08 8.73E

- 04

The Simplot Don

- Pocatello combined emission point (EP

- 1 01, EP

- 10 2 , and EP

- 103) has about six times higher Hg concentration and five times higher normalized emissions when compared to the average of the rest of the population of Hg data

.

The Simplot Don

- Pocatello process line uses the control technology identified in configuration C (see Table 3.15). This outlier total metals emissions data point does not appear to be related to the control technology because there are other emission points of similar configuration that reported much lower emissions

.

3.6.5 P articulate Matter Emission Outliers for Ammonium Phosphate Fertilizer Emission Points Reported Direct measurements of PM concentration were provided for 10 of the 11 APF emission points we examine d. Table 3

. 23 show s PM emissions from specific stack emission points (grouped by configuration) with outlier emissions data highlighted in red

.

Table 3.23: Particulate Matter Emissions from Ammonium Phosphate Fertilizer Emission Points Grouped By Configur ation

Facility EP ID Configuration Particulate Matter

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

Mosaic New Wales EP

- 05 A 1.13E

- 02 20 3 CFI Plant City EP

- stack A NA NA

Mosaic Bartow EP

- 2 A 8.09E

- 03 13 5

PCS Aurora EP

- 303 A 9.66E

- 03 21 1 Simplot Rock Springs EP

- 10 A 3.48E

- 03 75.9Page 35 of 85 Facility EP ID Configuration Particulate Matter

(gr/dscf) (lbs/thousand

tons of P 2 O 5 )

PCS Aurora EP

- 302 B 3.50E

- 03 92.9 Mississippi Phosphates Combined B NA NA

Mosaic Faustina EP

- 07 B 5.92E

- 02 1677 Simplot Don

- Pocatello Combined C 1.50E

- 02 263 Agrium Nu

- West EP

- 6 C 1.35E

- 02 17 8 PCS White Springs EP

- 32 D 4.65E

- 03 108

The Mosaic Faustina emission point EP

- 07 emits about seven times the PM concentration compared to the average of the rest of population of PM concentration data

. When normalized to PM emissions ( pounds particulate per thousand tons P 2 O 5 ), the emission point is about 10 times higher than the average of the rest of the population of data.

The Mosaic Faustina emission point EP

- 07 uses the control technology identified in configuration B (see Table 3.15). This outlier PM emissions point doe s not appear to be related to the control technology because there are other emission points of similar configuration that reported much lower emissions

.

3.7 Triple Superphosphate Process Lines and Storage Buildings TSP is a phosphate fertilizer process

, but none of the 11 facilities with APF processes have active operations for TSP production or storage based on the section 114 responses. Therefore, emissions data and currently used controlled technologies were not available for comparison. While one facility is permitted to store GTSP, we do not anticipate that the facility will resume GTSP operations at any point in the future because Nor th American production of TSP ceased in 2007 (IFA, 2014)

. Figure 1 below shows how production and consumption of TSP have decreased since 2002. Also n ote that all TSP consumed in North America since 2007 is imported.

However, if a facility were to start producing and storing TSP, the control technologies would be the same as those already used at APF process lines because th e same, or very similar, equipment is used to produce and store TSP as what is used to produce and store APF ( U.S. EPA, 1996). TSP production and storage emission limits are also only specified for TF, which is the same pollutant specified for APF process lines. Because we did not identify any new control technologies for APF production, no new control technologies are applicable for TSP production and storage processes.Page 36 of 85

Figure 1. Plot of production and consumption of TSP in North America from 2002 to 20 12 (IFA, 2014)

.

3.8 Conclusions
Based on a review of the section 114 responses , we have determined that the control technologies used at phosphoric acid manufacturing and phosphate fertilizer production plants have not changed since the original NESHAP and NS PS regulations. For the NESHAP technology review specifically, the control technologies used were previously discussed in the memorandum entitled National Emission Standards for Hazardous Air Pollutants from Phosphoric Acid Manufacturing and Phosphate Fert ilizers Production; Proposed Rules

– Draft Technical Support Document and Additional Technical Information (U.S. EPA, 1996). In general, the phosphoric acid manufacturing and phosphate fertilizer production source categories still use wet scrubbing technol ogy to control T F and HF emissions from the various processes located at these source categories (i.e., WP PA, SPA, PPA, and APF processes). However , the type and configuration of the wet scrubbing technology varies significantly between facilities and betw een process lines within a facility . Furthermore, we have not found any developments in wet scrubbing methods used at phosphoric acid manufacturing and phosphate fertilizer production plants. A ll control technologies used by each facility are also necessary to comply with the current emission s limit ations , and revised emissions limitations beyond those currently required are not appropriate

. Even though wet scrubbers are the most common control technology used at phosphoric acid manufacturing and p hosphate fertilizer production plants, a wet scrubber’s ability to control Hg emissions is minimal. There are two main control technology options for removal of Hg thatPage 37 of 85

are currently employed in other industries; activated carbon injection (ACI) with fabri c filters, and fixed

- bed carbon adsorption. Based on information provided in the Sewage Sludge Incinerators (SSI) preamble (U.S. EPA, 2011a) and Response to Comments memorandum (U.S. EPA, 2011b), the use of ACI may pose challenges for the phosphate industr y. It was noted in these SSI documents that for streams with high moisture content, the use of ACI was not possible due to the plugging of fabric filters which are necessary after ACI to collect the activated carbon media . Multiple emission points at phosp horic acid and phosphate fertilizer process units have moisture contents between 20 and 40 percent moisture and thus the use of ACI may not be practical. For fixed

- bed carbon adsorption, while moisture content is certainly a factor to consider, it is more manageable to control high moisture streams because a fabric filter is not required to collect particulate. Therefore, a case

- by

- case look at the stream properties would be necessary to determine the Hg control technology most suitable for a particular emi ssion point; further detail is provided in a separate memorandum entitled “ Control Costs and Emissions Reductions for Phosphoric Acid and Phosphate Fertilizer Production Source Categories ” (ERG, 2014b ).

For WPPA pr ocess lines, t h e outlier emissions data that we discuss in Section 3.1 of this memorandum may be related to the control technology being used; however, it is difficult to discern because each WPPA pr ocess line operate s a unique equipment and control technology configuration (i.e., there are no W PPA pr ocess lines that operate similar configuration s to compare )

. We observed some differences in total F emissions from SPA process lines. However, we did not find any patterns in emissions reductions based on control technology used because most of the SPA process lines that were tested operate a unique equipment and c ontrol technology configuration. For all SPA process lines that we examined, emissions from the evaporators are sent to a single wet scrubber, but the type of wet scrubber used at these SPA process lines varies.

Some SPA process lines include an oxidation step to remove organic impurities from the acid. For Agrium Nu

- West, we noted relatively high HF emissions from a currently uncontrolled oxidation process and control technology may be necessary. The application of wet scrubbing control technology would b e consistent with other SPA process lines, where all applicable emission points are controlled by wet scrubbers. We believe the use of wet scrubbing control technology would result in a reduction of emission from the identified oxidation process to levels consistent with other industry wide SPA emissions. Agrium Nu

- West already has wet scrubbing technology for their SPA process line, and we believe the facility would only need to install additional ductwork from the uncontrolled emission point to the wet sc rubber. Therefore, it would not be necessary to install a new wet scrubber to control the oxidation process emissions. See the memorandum “Control Costs and Emissions Reductions for Phosphoric Acid and Phosphate Fertilizer Production Source Categories” (ER G, 2014b) for additional discussion regarding the uncontrolled oxidation process.

For PPA process lines, p hosphate r ock d ryers , and p hosphate r ock c alciners (each emission source is discussed separately in Sections 3.3, 3.4, and 3.5 of this memorandum,

re spectively), it is difficult to discern whether the control technology being used at these emission points are more (or less) effective than another because there is minimal emission data
to compare.Page 38 of 85

One could potentially conclude that for APF process line s (as discussed in Section 3.6 of this memorandum), APF control technology associated with configuration D (see Table 3.17) provide s the best level of control for TF, HF, total metal (excluding Hg and P), Hg, and PM emissions because there were no outlier emissions data associated with this configuration. C onfiguration D use s two wet scrubbers in series and the final wet scrubber is a packed bed scrubber. However, there is only one process line associated with configuration D, so ample evidence is not available. In addition, we noted that for every outlier APF emission point that uses control technology associated with configurations A

, B

, or C, there are other emission points of similar configuration that reported much lower emissions. This indicates that control technology associated with configurations A, B

, and C could be designed to be just as good at controlling emissions as contr ol technology associated with configuration D.

For APF process lines, configurations B and C have outlier emissions data for all of the pollutants. Although in each instance the outlier data is attributed to a different facility, thus there is no consisten cy to determine distinguishing characteristics. Furthermore, even though configurations B and C were associated with each outlier emission point for all pollutants analyzed, if the outliers are excluded, then comparison of the remaining data shows similar concentration and normalized emissions for all control technology and associated configurations.

It is likely that the outlier emissions data discussed in this memorandum , except for one SPA process line, are caused by something other than inadequate cont rol technology (e.g., subtle differences in sampling and analytical techniques, age of control equipment, and differences in facility operation ). W ithout control technology efficiency data it is not possible to truly determine which control technologies ar e more effective at controlling emissions

.

F or TSP process lines and storage buildings, none of the facilities with APF proces ses have active operations for TSP. Even so, since TSP equipment is similar to APF equipment and b ecause we did not identify any new control technologies for APF production, no new control
t echnologies are applicable for TSP production and storage.

Although one of the primary purposes of Section 3.0 of this memorandum was to determine whether outlier emissions data associated with s pecific stack emission points were related to a control technology (when compared to all other emission points), we also made some general observations regarding total stack emissions from various processes located at the phosphoric acid manufacturing and phosphate fertilizer production source categories (i.e., WP PA, SPA, PPA, and APF processes). We observed that stack emissions contribute only about 5.5 percent (or 124 tons per year) of the total HF emissions associated with the entire phosphoric acid manu facturing and phosphate fertilizer production source categories; the majority (about 95 percent) of the HF emissions come from fugitive emissions associated with gypsum dewatering stack s, cooling pond s, and cooling towers which are discussed in Section 4.0 of this memorandum. We also observed that total metals emissions (excluding Hg and P) from all WP PA, SPA, PPA, and APF process lines combined equal approximately 1.5 tons per year; and the majority of Hg stack emissions (about 80 percent, or 244 pounds pe r year) come from the phosphate rock calciners; only about 12 percent, or 38 pounds Hg per year come from the APF process lines, and the remaining 20 pounds of Hg per year come from WP PA, SPA, and PPA process lines combined.Page 39 of 85

4.0 FUGITIVE EMISSIONS
Fugitive em issions from gypsum dewatering stack s, cooling ponds, and cooling towers have been identified as significant sources of HF emissions. Emission factors for gypsum dewatering stack s and ponds were derived from radial plume mapping test data performed at six facilities in the US and Canada ( ERG, 2014c ). Emissions from cooling towers were determined using data provided by each of the facilities that operated cooling towers which used water containing fluorides. The estimates of HF from these sources were approx imately 95 percent of the total HF emissions for the phosphoric acid and phosphate fertilizer production source categories

. While these sources have significant HF emissions, they are not regulated under the current NESHAP and NSPS and are thus considered unregulated sources. The CAA s ection 111(b)(1)(B) and 112(d)(6) r eviews are only applicable to currently regulated sources, and as such these fugitive emissions sources were not considered for either r eview.Page 40 of 85

5.0 REFERENCES Eastern Research Group, Inc. (ERG). 2014a . Information Collection and Additional Data Received for the Phosphoric Acid and Phosphate Fertilizer Production Source Categories. Prepared for the U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

2012

- 0522.

Eastern Research Group, Inc. (ERG). 2014b . Control Costs and Emissions Reductions for Phosphoric Acid and Phosphate Fertilizer Production So urce Categories. Prepared for the U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2012

- 0522

Eastern Research Group, Inc. (ERG). 2014 c. Phosphoric Acid and Phosphate Fertilizer RTR Modeling File Development. Prepared for the U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2012

- 0522.

Eastern Research Group, Inc. (ER G). 2014 d

. Comparison of 40 CFR Part 60, subpart T (Standards of Performance for the Phosphate Fertilizer Industry: Wet

- Process Phosphoric Acid Plants) and 40 CFR Part 63, subpart AA (National Emission Standards for Hazardous Air Pollution from Phosphoric Acid Manufacturing Plants

. Prepared for the U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2012

- 0522.

Eastern Research Group, Inc. (ERG). 2014 e

. Comparison of 40 CFR Part 60, subpart U (Standards of Performance for the Phosphate Fertilizer Industry: Superphosphoric Acid Plants) and 40 CFR Part 63, subpart AA (National Emission Standards for Hazardous Air Pollution from Phosphoric Acid Manufacturing Plants

. Prepa red for the U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2012

- 0522.

Eastern Research Group, Inc. (ERG). 2014 f

. Comparison of 40 CFR Part 60, subpart V (Stand ards of Performance for the Phosphate Fertilizer Industry: Diammonium Phosphate Plants) and 40 CFR Part 63, subpart BB (National Emission Standards for Hazardous Air Pollution from Phosphate Fertilizers Production Plants

. Prepared for the U.S. EPA Office

o f Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2012

- 0522.

Eastern Research Group, Inc. (ERG). 2014 g

. Comparison of 40 CFR Part 60, subpart W and subpart X (Standards of Perform ance for the Phosphate Fertilizer Industry: Triple Superphosphate Plants and Granular Triple Superphosphate Storage Facilities) and 40 CFR Part 63, subpart BB (National Emission Standards for Hazardous Air Pollution from Phosphate Fertilizers Production Pl ants

. Prepared for the U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2012

- 0522.Page 41 of 85

International Fertilizer Industry Association (IFA). 2014. Production and trad e statistics: TSP table. Available at http://www.fertilizer.org/ifa/HomePage/STATISTICS/Production

- and

- trade

. U.S. EPA. 2002. Air pollution control cost manual, 6th ed. EPA/452/B

- 02

- 001.

U.S. EPA. 1996. Memorandum: National Emission Standards for Hazardous Air Pollutants from Phosphoric Acid Manufacturing and Phosphate Fertilizers Production; Proposed Rules

– Draft Technical Support Document and Additional Technical Information. September 24, 1996. Available at www.regulations.gov in Docket ID No. A

- 94

- 02.

U.S. EPA. 2011a. Preamble: EPA, Standards Of Performance For New Stationary Sources And Emission Guidelines For Existing Sources: Sewage Sludge Incineration Units, Final Rule. March 2011. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2009

- 0 559.

U.S. EPA. 2011b. Comments: EPA, Standards Of Performance For New Stationary Sources And Emission Guidelines For Existing Sources: Sewage Sludge Incineration Units, Summary Of Public Comments And Responses. February 2011. Available at www.regulations.gov in Docket ID No. EPA

- HQ

- OAR

- 2009

- 0559.

U.S. EPA. 2012. RACT/BACT/LAER Clearinghouse. Available at http://cfpub.epa.gov/RBLC/

.Page 42 of 85 

### Appendix APage 43 of 85 Active Facilities (1) Located In The United States That Are Considered To Be Part Of The Phosphoric Acid Manufacturing And /Or Phosphate Fertilizer Production Source Categor ies

Facility Name Location Process Type(s) At Facility (1)
WP PA SPA PPA APF
Agriphos Fertilizer, LLC ( 2 ) Pas a dena, Texas Unknown Unknown Unknown Unknown

Agrium Nu

- West Industries, Inc. Soda Springs, Idaho   NA 

CF Industries, Inc. Plant City, Florida  NA NA 

J.R. Simplot Company Pocatello, Idaho    

J.R. Simplot Company Rock Springs, Wyoming   NA 

Mississippi Phosphates Corporation Pascagoula, Mississippi  NA NA 

Mosaic Fertilizer, LLC (Bartow Facility) Bartow, Florida   NA 

Mosaic Fertilizer, LLC (Faustina Facility) St. James Parish, Louisiana NA NA NA 

Mosaic Fertilizer, LLC (Riverview Facility) Riverview, Florida   NA 

Mosaic Fertilizer, LLC (New Wales Facility) Mulberry, Florida  NA NA 

Mosaic Fertilizer, LLC (Uncle Sam Facility) St. James Parish, Louisiana  NA NA NA

Potash Corporation (PCS) Aurora, North Carolina    

Potash Corporation (PCS) Geismar, Louisiana  NA NA NA

Potash Corporation (PCS) White Springs, Florida   NA 

NA

– Not Applicable 1

– As o f April 13, 2010. 2

– Based on response to the April 13, 2010 Section 114 r equest, this facility indicated to U.S. EPA that it would be shutdown by the end of 2012.Page 44 of 85 

### Appendix B

Emissions b y WPPA pr ocess LinePage 45 of 85Page 46 of 85Page 47 of 85Page 48 of 85Page 49 of 85Page 50 of 85Page 51 of 85Page 52 of 85Page 53 of 85Page 54 of 85Page 55 of 85 

### Appendix C

Emissions b y SPA Process LinePage 56 of 85Page 57 of 85Page 58 of 85Page 59 of 85Page 60 of 85Page 61 of 85Page 62 of 85Page 63 of 85Page 64 of 85Page 65 of 85Page 66 of 85 

### Appendix D Emissions By APF Process LinePage 67 of 85Page 68 of 85Page 69 of 85Page 70 of 85Page 71 of 85Page 72 of 85Page 73 of 85Page 74 of 85Page 75 of 85Page 76 of 85Page 77 of 85 

### Appendix E
Reported Phosphate Rock Concentration Compared

To Reported Emissions DataPage 78 of 85Page 79 of 85Page 80 of 85Page 81 of 85Page 82 of 85Page 83 of 85Page 84 of 85 

### Appendix F
Comparison of 2010 and 2014 Emissions DataPage 85 of 85 COMPARISON OF 2014 DATA TO 2010 DATA FOR WP PA, SPA , AND APF PROCESS LINES

Process Line Facility Process Unit & EP 2010 2014

Notes HF (gr/dscf) HF

(lb / ton
P 2 O 5 ) HF

(gr/dscf) HF

(lb / ton
P 2 O 5 )
Method 26A Method 320
WPPA PCS White Springs 69 (EP

- 69.01) 1.46E

- 03 5.33E

- 03 5.54E

- 04 1.45E

- 03
WPPA Mosaic New Wales Combined 3.58E

- 03 1.15E

- 02 1.89E

- 03 2.95E

- 03 EP

- 11 & EP

- 22
SPA Agrium Nu

- West Combined 6.80E

- 03 9.91E

- 03 1.41E

- 01 1.99E

- 02 EP

- 522 & EP

- 541
SPA Simplot Rock Springs P

- 4 (EP

- 40) 5.95E

- 04 1.27E

- 03 1.08E

- 03 4.52E

- 03
APF Agrium Nu

- West Gran (EP

- 6) 1.52E

- 02 2.08E

- 01 1.38E

- 03 1.43E

- 02
APF Mosaic New Wales P

- 2 (EP

- 05) 3.38E

- 03 5.92E

- 02 3.54E

- 03 5.66E

- 02