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September30, 2015 Mosaic Fertilizer, LLC 7250 Highway44 Uncle Sam, LA70792 www.mosaicco.com Tel225-474-9700 Fax225-474-4090

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 7013 2250 0001 5994 8857
Mr. Guy Donaldson (6PD-L) UnitedStatesEnvironrnentalf'r()tectionAgenc:y:-RE!giQnJ3 1445 RossAvenue, Suite 1200 Dallas, TX 75202-2733 SUBJECT: MOSAIC FERTILIZER, LLC - UNCLE SAM PLANT RESPONSE TO SEPTEMBER 1, 2015 CLEAN AIR ACT SECTION 114(a} INFORMATION REQUEST Dear Mr. Donaldson: On September 1, 2015, the United States Environmental Protection Agency (EPA), Region 6 emailed an Information Request to the Mosaic Fertilizer, LLC ("Mosaic") Uncle Sam Plant pursuant to Section 114(a) ofthe Clean Air Act, 42 U.S.C. 

### § 7414(a). The Information Request was served on Mosaic by Certified Mail on September 4, 2015. The EPA Information Request seeks information related to best available retrofit technology (BART) requirements under EPA's Regional Haze Rule, 40 C.F.R. 

### §§ 51.308 and 51.309 in order that EPA may develop a Federal Implementation Plan in the event that the Louisiana Department of Environmental Quality (LDEQ) does not timely amend its State Implementation Plan with regard to Regional Haze to address deficiencies noted by EPA. The Information Request required the requested information to be submitted to the EPA by September 30, 2015. Mosaic has made considerable effort in this short time period to provide timely, useful and complete responses to the Information Request. Notwithstanding its substantive response to the Information Request, Mosaic makes the following general qualifications and objectionstothe request: Mosaic objects to the Information Request to the extent that it seeks privileged information, including any communications that are protected from disclosure by the attorney-client communication privilege orany communications ordocuments protected bythe attorneywork productdoctrine. Mosaic objects to the Information Request to the extent that the information requested is irrelevant or outside the scope of Section 114 ofthe Clean AirAct, 42 U.S.C. 

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!**-------------------------~-**Responseto September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 Page 2

Mosaic objects to the Information Request to the extent that it is vague, unclear, ambiguous, oroverly burdensome. For some of the responses, we have relied on information supplied by third parties overwhom Mosaic has no control. In addition, Mosaic has prepared the responses based on reasonable investigation, and the responses may be subject to revision in the event additional or different information or analyses become 

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

------- --- ---- - -**-~** response to reflect any such additional ordifferent information oranalyses. Mosaic specifically objects to any use ofthe data by EPA that does not comply with EPA's Cross-Media Electronic Reporting Rule, 40 C.F.R. Part 3, or any internal EPA rules, policies ordirectives on use ofelectronicdata. Subject to and without waiving any of the foregoing qualifications and objections, and subject further to the reservations set forth below, Mosaic provides in this response information sought in the Information Request, through the following responses and attachments. Mosaic reserves the right to objectto any use of such data by EPA in any future rulemaking, permit, orenforcement proceedings. Mosaic responds to the September 1, 2015 Information Request as follows: Request 1. In reviewing the modeling conducted for the BARTanalysis submitted to LDEQ on July 17, 2015, the EPA identified that the meteorological data set and computational grid utilized by Mosaic was not the correct data set to utilize, as it was based on 

### a smaller modeling domain and 4km grid rather than the larger modeling domain and6kmgridconsistentwith the finalSidRichardson modelinganalysis. Please conduct CALPUFFmodeling andsubmitthe following modeling runs using the final Sid Richardson CALMET files (provided to Mosaic by LDEQ) and the larger CALPUFF modeling domain to ensure plumes that could transport to Breton stayin the modeling domain.

a. Base case scenario b. Currentcontrolsscenario c. Currentcontrolsscenario with addition of

### a scrubberon D Train as discussedbelow. Response 1. Mosaic has conducted CALPUFF modeling forthe three scenarios above using the final updated Sid Richardson CALMET files that were approved by the EPA and the larger CALPUFF modeling domain indicated by the EPA. A description of this CALPUFF modeling analysis and a summary ofthe modeling results using the protocols as directed by EPA in the Information Request are provided in Section 4 ofthe attached Mosaic Uncle Sam Plant Best Available Retrofit Technology Analysis, Rev. 1 (Attachment 1 ). Additionally, electronic copies ofthe CALPUFF input and output filesResponse to September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 Page 3

used and created in this CALPUFF modeling analysis are contained in Exhibit 11 of Attachment 1. The following person(s) assisted in the preparation of the response to Request 1: Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll Environ US Corporation ("Ramboll Environ"), consultantsto Mosaic. 

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Request 2: In performing the five4actor analysis for the D Train controls, Mosaic

u -- -- .•.•.. u u ·-- modeled the base case scenario and the current controls scenario. In identifying the available control options, Mosaic identifieda scrubberas apotentialcontrol. However, Mosaic didnotinclude an analysis ofvisibilitybenefitthatcouldbe obtainedbyinstalling 

### a scrubber. Please modelthe currentcontrolscenario with the addition of

### a scrubberon the D Train to demonstrate the visibility benefit achievedbyinstalling 

### a scrubber. The delta-deciview benefit from installation ofcontrols should be included in the five-factor BARTanalysis evaluatingS02 controls forthe D Train. Response 2. Mosaic evaluated the visibility improvement that is modelled to occur at the Breton Wilderness Area as a result of equipping the D Train Double Absorption H2S04 Plant (EPN S-DTrain1, EQT 0074) with a wet scrubber. The revised 5-factor BART analysis performed for the D Train Double Absorption H2S04 Plant (EPN SDTrain1, EQT 0074), which includes this requested modeled visibility improvement evaluation, is presented in Sections 3.9 and 3.10 and 4 ofAttachment 1. In Section 4, Mosaic analysed three scenarios to estimate the visibility improvement: Baseline, With BART, With Bart + D Train Wet Scrubber. The modeling results are presented in Section 4.3 of Attachment 1 and indicate that the visibility improvement between the "With BART" scenario and the "With BART + D Train Wet Scrubber'' scenario is only 15% ofthe visibility improvement between the "Baseline" scenario and the "With BART" scenario. Given the extremely high capital investment cost (estimated $25 Million) for a wet scrubber, and the high annual operating cost (estimated $3.3 Million), it is not cost effective to install and operate a wet scrubber. In summary, Mosaic determined that a wet scrubber does not represent BARTforthe DTrain Double Absorption H2S04 Plant (EPN S-DTrain1, EQT 0074). The following person(s) assisted in the preparation of the response to Request 2: Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll Environ, consultants to Mosaic and Maureen Harbour! with Kean Miller LLP, counsel to Mosaic. Request 

### 3. Please provide 

### a narrative explanation including supportive information as necessary, forwhythe E Train is notBART-eligible. Response 3. A narrative explanation of why the E Train is not a BART-eligible , emissions unit is provided in Section 1.2.1 of Attachment 1. Additionally, supporting informationforthis determination is contained in Exhibits 1and 2 ofAttachment 1. 

# IResponseto September 1, 2015 Clean Air Act Section 114(a) Information Request September 30, 2015 Page4

The following person(s) assisted in the preparation ofthe response to Request 3: Todd Higginbothamwith Ramboll Environ, consultantsto Mosaic. Request 4. The emission rates for S0 2 and NOx baseline (pre-consent decree controls/emissions) do not match the values in the LDEQ's Regional Haze SIP from 

### 2008 (Table 9-3). The table has emission totals forthe BARTunits ateach facilityand lists Mosaic Uncle Sam as 39.16 tpd ofS02 and 3.34 tpd ofNOx. The modeling for baseline emissions are/essthanthese totals at35c07tpdofSO:rand2c06·tpdofNOx, ····· ················ ······**-~­** Please investigate andprovide an explanation of these differences. While the larger emissions will notchange the subject to BARTdecision it willimpact the delta deciview analysis between baseline and different controls that are evaluated as part ofthe 5- factor BARTanalysis. Please provide this information to the EPA for reviewprior to conducting CALPUFFmodeling. Response 4. On August 11, 2006, Mosaic submitted an initial list of BART-eligible emissions units for the Uncle Sam Plant to the LDEQ (hereinafter this submittal is referenced as the "August 11, 2006 submittal"). As part of the August 11, 2006 submittal, for each ofthe listed emissions units, Mosaic indicated the 24-hour maximum sulfur dioxide (S02 ) emission rate and the 24-hour maximum oxides of nitrogen (NOx) emission rate, both in tons per day (tpd), emitted during routine operations (i.e., excluding start-ups, shutdowns, and malfunctions)from 2001 through 2005. In Table 9.3 of the June 2008 Louisiana State Implementation Plan Revision for Regional Haze Program, the LDEQ listed total S02 and NOx emission rates for the BART-eligible emissions units at the Uncle Sam Plant as 39.16 tpd and 3.34 tpd, respectively. Mosaic has estimated that the LDEQ calculated these emission rates by summing together the emissions unit-by-emissions unit 24-hour maximum hourly S02 and NOx emission rates, respectively, that were identified in the August 11, 2006 submittal. After the August 11, 2006 submittal, Mosaic determined that several ofthe emissions units identified as BART-eligible in that submittal were in fact not BART-eligible because they were not "in existence" on August 7, 1977 orthey were not stationary sources (i.e., they were "nonroad engines"). This revised determination of BART-eligible emissions units was documented in the June 2007 BestAvailable RetrofitTechnologyAnalysis that Mosaic submitted to the LDEQ for the Uncle Sam Plant, which the LDEQ included in Appendix G of the June 2008 Louisiana State Implementation Plan Revision for RegionalHaze Program. The same BART-eligible emissions units identified forthe Uncle Sam Plant in the June 2007 Best Available Retrofit Technology Analysis were evaluated as BART-eligible in the July 2015 Mosaic Uncle Sam Plant BestAvailable Retrofit Technology Analysis that was recently submitted to the LDEQ. Additionally, the same baseline S02 and NOx emission rates were evaluated in the June 2007 Best Available Retrofit TechnologyResponseto September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 Page 5
Analysis and the July 2015 Mosaic Uncle Sam Plant BestAvailable Retrofit Technology Analysis. Attachment 2 contains an electronic file in which we have calculated the S02 and NOx emission rates that the LDEQ listed for the Uncle Sam Plant in Table 9.3 ofthe June 2008 Louisiana State Implementation Plan Revision forRegionalHaze Program. In the same electronic file, we have also documented the calculation ofthe baseline S02 and -----Nox··emission···rates··thatwe evaluated···in···theJune2007Best····Available--Retrofit TechnologyAnalysis and the July 2015 Mosaic Uncle Sam Plant BestAvailable Retrofit TechnologyAnalysis. Attachment 3 contains a copy of the December 21, 1979 preconstruction air permit application requesting authorization forthe construction ofthe Sulfur Surge Tank (EPN S-SurgeTnk, EQT 0084). This air permit application is referenced in the electronic file contained in Attachment 2. Attachment 4 contains a copy ofthe December 27, 1979 air permit (Permit No. 1312T} that was issued by the predecessor agency to the LDEQ authorizing the construction of the Sulfur Surge Tank (EPN S-SurgeTnk, EQT 0084). This airpermit is referenced in the electronicfile contained in Attachment2. The following person(s) assisted in the preparation ofthe response to Request 4: Todd Higginbotham and Michael Carbon with Ramboll Environ, consultants to Mosaic, and Greg Davison with Mosaic. Request 5. Please recalculate and submit the cost analysis performedbased on 

### a 30 yearlife ratherthan 

### a 20yearlife. Response 5. Mosaic disagrees with the EPA that it is appropriate to use a 30-year life when performing the BART cost analyses for the Uncle Sam Plant. In fact, EPA has indicated that a high:end life for a scrubber is 20 years.' Nonetheless we have revised the BART analyses previously performed for the Uncle Sam Plant by using a 30-year life, as requested. The assumption of a 30-year life did not change our BART determinations. The results of the revised BART cost analyses are summarized in Section 3 ofAttachment 1. The revised BART cost analysis calculations are contained in Exhibits 3 through 10 of Attachment 1. Mosaic reserves all rights to challenge the appropriateness of use of a 30-year life in any BART cost analysis in any FIP, SIP, rulemaking, permitting, orenforcement proceeding. The following person(s) assisted in the preparation ofthe response to Request 5: Todd Higginbotham and Michael Carbon with Ramboll Environ, consultants to Mosaic and Maureen Harbour!with Kean Miller LLP, counsel to Mosaic.

1Robert D. Bauman, Chief, Standards Implementation Branch, Office ofAirQuality Planning and Standards, EPAto Stephen H. Rothblatt, Chief, Airand Radiation Branch, EPA Region V. July 24, 1987.Response to September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 Page6
Request 6. The ozone data used for CALPUFFmodeling should be hourly monitored ozone data from the years modeled, so the ozone data shouldbe from 2001, 2002 and 2003. A value of80 ppb should be used to fill in formissing data (CALPUFF setting BCK03 = 12*80). The EPA has ozone data files that we willprovide electronically to Mosaic andtheirmodelingcontractors. Response 6. Mosaic has conducted CALPUFF modeling using the ozone data files 1- --------provided by the EPAand

### a value of80 parts per billion byvolume (ppbv)formissing

......... ... ......... ... . 

## .J ozone data. A description of the CALPUFF modeling analysis and a summary ofthe modeling results are provided in Section 4 of Attachment 1. Additionally, electronic copies of the CALPUFF input and output files used and created in the CALPUFF modeling analysis are contained in Exhibit 11 of Attachment 1. EPA and LDEQ guidance has previously indicatedthat 40 ppb is an appropriate defaultvalue for missing ozone data. Mosaic reserves all rights to challenge the appropriateness of use of 80 ppb as the defaultfor missing ozone data in any future FIP, SIP, rulemaking, permitting, orenforcement proceeding. The following person(s) assisted in the preparation of the response to Request 6: Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll Environ, consultantsto Mosaic. Request 7. Please submit 

### a revised 5 factor BART analysis addressing the above concerns. Response 7. Mosaic has revised the 5-factor BART analyses performed forthe BARTeligible emissions units at the Uncle Sam Plant as directed by the EPA in Requests 1 through 6. These revised 5-factor BART analyses are included in Sections 3 and 4 of Attachment 1. Mosaic reserves all rights to challenge the appropriateness of the modeling methodology and input assumptions for the modeling and 5-factor BART analysis in anyfuture FIP, SIP, rulemaking, permitting, orenforcement proceeding. The following person(s) assisted in the preparation of the response to Request 7: Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll Environ, consultants to Mosaic and Maureen Harbour! with Kean Miller LLP, counsel to Mosaic. Request8. SubmittalofModeling Modelingsubmissions mustinclude

• ModelingReportandConclusions • AllmodelingfilesResponse to September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 Page 7

Modeling files mustbeprovided on 

### a hard drive, USB drive, orelectronic ftp, andmust include allofthe following files as applicable:

• CALMEToutputfiles • CALPUFFinput, control, andoutputfiles • POSTUTIL input, control, andoutputfiles • CALPOSTinput, control, andoutputfiles ----------• - Executables-used, Response 8. The CALPUFF modeling report and a summary of the modeling conclusions are provided in Section 4 ofAttachment 1. Additionally, electronic copies of the CALPUFF input and output files used and created in the CALPUFF modeling analysis are contained in Exhibit 11 ofAttachment 1. The following person(s) assisted in the preparation of the response to Request 8: Michael Carbon, Todd Higginbotham, Bart Brashers, and Tim Sturtz with Ramboll Environ, consultantsto Mosaic. Attachment 5 contains the Statement of Certification required to be signed and returned with this response. If you or any member of your staff should have any questions or require additional information in regards to this submittal, please do not hesitate to contact David Oubre at (225) 474-1336. Thank you foryour consideration ofthis submission. We lookforward to working with EPA in acooperative mannerin this matter.

Plant Manager

- Louisiana Operations

AttachmentsResponse to September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 PageS

cc: with attachments LDEQ, Office ofEnvironmental Services David Oubre, Mosaic David Jellerson, Mosaic JeffStewart, Mosaic

--- PatrickvanderVoorn;Mosaic Diana Jagiella, Mosaic Michael Carbon, Ramboll Environ 

### 701322500001 59948840 i.Response to September 1, 2015 Clean Air Act Section 114(a) Information Request September30, 2015 Page 9

bee: with attachments
Steve Chatelain, Mosaic i i 

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## ATTACHMENT 1 Mosaic UncleSam Plant BestAvailable RetrofitTechnologyAnalysis, Rev. 1 September2015

## SeeAttached Flash Drive

## SeeAttached Flash Drive

## ATTACHMENT3 December

## 21, 1979 PreconstructionAirPermit Application Requesting Authorizationforthe ConstructionoftheSulfurSurgeTank (EPN S-SurgeTnk, EQT0084)

## SeeAttached Flash Drive

## ATTACHMENT4 December27, 1979 PermitNo. 1312TAuthorizing Constructionofthe SulfurSurgeTank (EPN S-SurgeTnk, EQT0084)

## SeeAttached Flash Drive

## ATTACHMENT5 

## StatementofCertification

## SeeAttached Flash Drive