### MEMORANDUM To: Tina Ndoh, U

. S

. EPA/OAQPS/SPPD

- Minerals and Manufacturing Group From: Eastern Research Group, Inc. Date: August 20 , 2014 Subject: Emissions Data Used in Residual Risk Modeling: Phosphoric Acid and Phosphate Fertilizer Production Source Categories

1.0 INTRODUCTION The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act (CAA), is required to establish maximum achievable control t echnology (MACT) standards for phosphoric acid manufacturing plants (40 CFR part 63, subpart AA) and phosphate fertilizer production plants (40 CFR part 63, subpart BB) source categories. Under section 112(d)(6), EPA must review, and, if necessary, revise the MACT standards based on a residual risk and technology review (RTR). This memorandum describes the methodology used to develop the RTR modeling file and baseline emissions for phosphoric acid manufacturing plants and phosphate fertilizer production pla nts. This memorandum is organized as follows: 2.0 Emissions Testing Data Extraction and Compilation 3.0 Estimated Emissions for Point Sources N ot Tested 4.0 Estimated Emissions for Fugitive Sources N ot Tested 5.0 Speciation of Emissions 6.0 Acute Emissions Multiplier 7.0 Estimating MACT

- allowable emissions 8.0 Incorporation of Facility Wide National Emissions Inventory Category Data 9.0 Emission Corrections to RTR Modeling File 10.0 Additional Emissions Testing 11.0 Comparison o f Facility Emissions to Major Source Thresholds A ppendix A

– E xcel file “Emission_Data_Phosphate_Sector.xlsx”
EPA used results of stack testing required by an April 13, 2010 section 114 survey and testing request to inform the RTR modeling file and baseline emissions for phosphoric acid manufacturing plants and phos phate fertilizer production plants. Results of stack testing required by a January 24, 2014 section 114 survey and testing request were not used in the development

1

### of the RTR modeling file and baseline emissions for phosphoric acid manufacturing plants and phosphate fertilizer production plants ; except for Hg, as noted in section 9.0

. Sections 2.0 through 9 .0 and 1 1 .0 of this memorandum only apply to the emissions data received from the April 13, 2010 section 114 survey and testing request. Refer to section 10 .0 of this memorandum for further discussion about the emissions data received from the January 24, 2014 section 114 survey and testing request

. 2.0 EMISSIONS TESTING DATA EXTRACTION AND COMPILATION The survey responses, test reports received , and a file that contains the standardized data received by EPA is available in the docket for this action. The details of the survey, as well as standardization of the data receiv ed by EPA, are described in a separate memorandum. 1 

### A compilation of the emissions test data received is available in Appendix A

- 1; see those data labeled as “Tested” under the “Tested or Estimated” column. The production and feed rates for each process un it during the emissions tests are provided in Appendix A

- 2. The test data submitted by facilities in response to the section 114 were used to calculate hourly emission rates by multiplying the standardized concentration results by the reported volumetric f low rates for each emission point that was tested. The corresponding annual hours of production reported by facilities in the section 114 survey were then used to estimate the annual emissions for each pollutant and emission point tested. Facilities genera lly conducted three test runs for each method and pollutant concentration. Therefore, the average of the test runs was used to estimate the annual baseline emissions for each emission point at each facility. 3.0 ESTIMATED EMISSIONS FOR POINT SOURCES NO T TESTE D As described in a separate memorandum 1 

### , facilities were allowed to test one process in a group of identical processes as long as the tested process was representative of those which were not tested. For those emission points and processes which were not tested, a ratio based on production and annual operating hours was used to determine their estimated emissions. For tested emission points t he hourly production rates during the test were provided in test reports, and the operating hours were provided in the section 114 survey. Note that for emission points at the same process unit, operating hours were assumed to be identical. In certain situations, hourly production rates were not used. If the production rate during the test was not available, the annual production provided in the survey was used instead; in these cases operating hours were not used in the equation. For one facility the product flow rates (gallons per minute) were available and the flow rates could be attributed to specific emission point s. It was determined that flow rates would provide the most accurate method for comparison. In this instance the operating hours for both units were assumed to be equal and a ratio of the flow rates were used to calculate emissions. A brief description of the emission point which was determined to be representative and the production data used to calculate emissions for non

tested emission points is located in the column labeled “Data Source” in Appendix A

- 1 ; refer to the emission points labeled as “Estimat ed” under the “Tested or Estimated” column

.

2

### Estimated Mercury Emissions for PCS Aurora Certain emission points at PCS Aurora were not tested for mercury, but after review of the available emissions data it was determined that an estimated mercury emissions value was necessary. These emission points were associated with ammonium phosphate fertilizer (APF) production, purified phosphoric acid (PAP) production, and superphosphoric acid (SPA) production. For emission points 302 and 303 (APF production), mercury emissions were estimated using available total mercury data from APF processes at other facilities. Data from eight facilities were used. Emission points 330, 331, and 332 are SPA lines at PCS Aurora and were estimated using total mercury data from SPA pr ocesses at three facilities. The SPA data from Simplot Don

- Pocatello were not used because Simplot Don

- Pocatello uses a proprietary process which was not considered representative. For each emission point related to APF or SPA production at the non

- Aurora facilities the total mercury emissions ( in tons per year ) were divided by the phosphorus pentoxide ( P 2 

### O 5 

### ) production rate ( tons per year ) to calculate a tons of total mercury per ton of P 2 

### O 5 

### factor. An average factor using the applicable emission points for APF production was calculated and a separate average factor for SPA processes was calculated

. Each of these factors was then applied to the appropriate emission points at PCS Aurora. The d etails to calculate the average factors are provided in Appendix A

- 3

. The emission points at the PAP line were also not tested. PCS Aurora was the only facility with a solvent extraction PAP line so representative data were not available. Mercury emissio ns from this process are expected to be low because vent temperatures are low (25 degrees C). Therefore, emissions were assumed to be at or near the method detection level. To estimate total mercury emissions for PAP emission points 502, 504, and 506 the a verage of all non - detect data reported for total mercury using the Ontario Hydro method for all facilities was calculated ( grains per dry standard cubic foot ). The non

- detect calculations are also available in Appendix A

- 3

. This average concentration value was then multiplied by the flow rate for each PAP emission point, as reported in stack test data for other pollutants, and the annual operating hours from the survey. After determining the estimated total mercury for the PCS Aurora emission points the mer cury was speciated according to the procedures described in section 5 .0. 4.0 ESTIMATED EMISSIONS FOR FUGITIVE SOURCES NOT TESTED Gypsum Dewatering Stack and Cooling Pond Emissions Estimate For gypsum dewatering stacks and cooling ponds, low, medium, and high estimated emission factors ( in tons per acre per year ) were calculated for hydrogen fluoride. These emission factors were derived from open path tunable diode laser or open path fourier transform infrared with radial plume mapping test s performed at s ix different facilities in the U

. S

. and Canada. These test reports are available in the docket for this action. Each of these test reports was reviewed and the emission factor data were assigned to gypsum dewatering stacks or cooling ponds. Four test repor ts included data for cooling ponds, and four test reports included data for the gypsum dewatering stack and associated gyp sum pond area. The test report emission factor data specific to gypsum dewatering stacks were used to develop gypsum dewatering stack emission factors. Similarly, cooling pond emission factors were used to develop corresponding emission factors. The medium emission factor for a cooling pond or a gypsum dewatering stack

3

### was calculated as the average of all data in the category. For the hi gh estimate, the low outlier hydrogen fluoride emission factor values were removed from the estimate. For the low estimate, high hydrogen fluoride outlier emission factors were removed. See Appendices A

- 4 and A

- 5 for details on the emission factor data that were available and the resulting low, medium, and high emission factors. The high, low, and medium emission factors were then applied to each facility to estimate fugitive emissions for each facility . If a fac ility had specific test data available, and th ese data were lower than the low emission factor calculated, these facility specific data were substituted for the low emission factor

. Refer to Appendix A

- 6 for more information regarding the specific emission factors applied to each facility . Note that Mosaic New Wales did have facility specific data available, which was close to the medium value; in this instance the medium factors were used. To apply the emission factor, an estimate of the total acreage of all gypsum dewatering stack s or cooling ponds at each facility was necessary. These data were provided in the section 114 survey on Form C

- 1

- b. In most instances the summation of the provided areas were used to calculate the actual emissions ( tons per year ). For a limited number of instances, facilities did not provide acreage data for either a cooling pond or gypsum dewatering stack , and when this occurred the area was estimated using Google Earth TM 

### . Documentation of when an acreage estimate from Google Ea rth TM 

### was used is provided in Appendix A

- 6 . For closed gypsum dewatering stack areas, the estimated area of the associated pond observed on Google Earth TM 

### was used, rather than the area of the entire gypsum dewatering stack , and the gypsum dewatering stack emission factor was applied. The equation below shows the calculation performed for each gypsum dewatering stack or cooling pond to determine its actual emissions: Actual emissions (tons/year) = emission factor (tons/acre/year) * acres Cooling Towers Emis sions estimates for cooling towers were determined using data provided by each of the facilities that operated cooling towers which used water containing fluorides. Cooling tower emissions were estimated for four facilities. Three of these facilities appea r to use process water with relatively high levels of fluoride as the cooling tower water source. One additional facility has a relatively low permitted level of fluoride emissions but was included in the data set due to the established permit limits. Emis sions were estimated from information available in test reports or from the total fluoride or hydrogen fluoride emissions limits in the Title V permit. For two cooling towers, total fluoride emissions data were provided and it was assumed that 93 percent o f the total fluoride emissions were attributable to hydrogen fluoride. The permitted emissions provided in pounds per day were converted to tons per year using 365 operating days. Details regarding the exact method used for each cooling tower are provided Appendix A

- 7

. Contribution to Source Category Emissions The largest sources of the hazardous air pollutant (HAP) HF that were identified from Phosphoric Acid Manufacturing and Phosphate Fertilizer Production facilities are fugitive emission sources, which include gypsum dewatering stacks, cooling ponds, and cooling towers.

4

### See Table 1 for the fugitive emissions summary by facility. Fugitive emissions from these three sources account for approximately 95 percent of total HF emissions for the Phosphoric Acid Manufacturing and Phosphate Fertilizer Production source categories. Fugitive emissions from these three sources account for more than 96 percent of total HF emissions for the Phosphoric Acid source category and gypsum dewatering stacks and cooling ponds a re the two predominant sources. Table 1. Fugitive HF emissions summary for each facility (medium emission factor) (a).

Facility Tons HF per year Gypsum Dewatering Stacks Cooling Pond Cooling Tower Total Agrium Nu

- West 45 24 N/A 69 CFI Plant City 78 43 N/A 121 Mississippi Phosphates 15 68 N/A 83 Mosaic Bartow 65 143 N/A 208 Mosaic New Wales 61 156 N/A 218 Mosaic Riverview 101 174 N/A 275 Mosaic Uncle Sam 40 34 N/A 74 PCS Aurora 69 204 5 278 PCS Geismar 49 16 17 83 PCS White Springs 155 298 N/A 453 Simplot Don

- Pocatello 88 N/A 116 204 Simplot Rock Springs 85 N/A (b) 4 89 Total 851 1 , 161 143 2 , 155 Note: (a) A range of emission estimates was developed because there was a high amount of variability in the submitted emissions testing data. This chart presents the mid range estimates. (b) Although Simplot Rock Springs does use cooling ponds, sufficient data was not provided to develop an emission estimate


### . 5.0 SPECIATION OF EMISSI ONS Mercury Facilities reported total and elemental mercury using EPA Me thod 30B and Hg ASTM

D6784

- 02 (i.e., the Ontario Hydro method) respectively. Where facilities reported elemental or total mercury results using both test methods, only the Ontario Hydro results were included in the modeling file calculations

. Mercury was speciated in the final modeling file into elemental gaseous mercury, gaseous divalent mercury, and particulate divalent mercury using the following procedure. If a facility reported both elemental and total mercury, the difference of the two was calculated . It was assumed that half of the difference was gaseous divalent mercury, the balance being particulate divalent mercury. If a facility only reported total mercury or elemental mercury, it

5

### was assumed that 80 percent of the total mercury was elemental mer cury, and the gaseous divalent and particulate divalent fractions were each ten percent of the total mercury. Chromium Facilities reported total chromium and hexavalent chromium using EPA Method 29 and SW

- 846 Method 0061 HC respectively. It was assumed that the difference of the total chromium and hexavalent chromium was trivalent chromium. In instances where the total chromium concentration was less than the hexavalent chromium concentration, it was assumed that all chromium was hexavalent, and only the test value for hexavalent chromium was used for the modeling file. Fluorides Facilities reported total fluorides and hydrogen fluoride using EPA Method 13B and EPA Metho d 26A respectively. A majority of facilities reported both types of fluoride for each emission point. However; in a few instances data were only available for total fluorides. A conservative one to one molar ratio was used to determine the amount of hydrog en fluoride for instances where only data for total fluorides were available. 6.0 ACUTE EMISSIONS MULT IPLIER In order to provide maximum emissions for the acute exposure analysis, a multiplier of 10 times the actual emissions was used for point sources. EPA u ses a multiplier of 10 to predict worst case emissions during a process upset or control device malfunction. For fugitive emissions of hydrogen fluoride from gypsum dewatering stacks, cooling ponds and cooling towers, an acute multiplier of one was used for all sources. Fugitive emissions are not expected to increase with an increase in production rate, or increase significantly during a process upset. For cooling ponds, because of their general homeostatic nature, changes with time are expected to be min or. Emissions are expected to be higher during daylight hours. Test data for these sources were obtained during the spring and summer seasons, and during daylight hours, and therefore emissions would not be expected to increase significantly beyond the lev els measured during the tests. The range of estimates developed (high, medium, and low) is expected to account sufficiently for any changes to emissions as ambient conditions change. 7.0 ESTIMATING MACT - ALLOWABLE EMISSIONS To calculate allowable emissions for hydrogen fluoride, metals, and methyl isobutyl ketone (MIBK) an appropriate multiplier to the actual emissions was calculated. The multiplier was based on the ratio of permit limits to actual emissions for hydrogen fluoride. For metals and MIBK, the multi plier was based on a ratio of permitted production to actual production. Hydrogen Fluoride - Point Sources To calculate the hydrogen fluoride multiplier to determine allowable emissions, the total fluoride limit from the permit was compared to the actual total fluoride emissions which were calculated using stack test data. The permit for each facility was examined and the total fluoride

6

### limit for each process unit was documented. Using the permitted total fluoride limit, a ratio of permitted to actual emis sions was calculated using the following equation: Hydrogen fluoride multiplier = per mitted total fluoride limit (tons/year) / actual total fluoride annual emission s (tons/year) Total fluoride limits are on a process unit level, which may encompass multiple emissions. For process units which have multiple emission points the actual total fluoride emissions would be the sum of annual total fluoride emissions for each applicable emission point. Metals and Methyl Isobutyl Ketone Multiplier To calculate allowable emissions for metals and MIBK data, a different procedure was necessary since permit limits are not provided for metals or MIBK. Actual emissions were scaled up in proportion to the ratio of permitted production to actual production. The followi ng equation was used: Metals multiplier = (permitted production (tons/hour) * 8760 operating hours) / (actual production (tons/hour) * actual operating hours) Each production value generally corresponds to the P 2 

### O 5 

### production rate. The actual production i n tons per hour as reported for the stack test conducted for the section 114 was used as the actual hourly production rate. Actual operating hours were provided in the section 114 responses. For some process units, the production rate during the stack test was not available. For these process units, the annual production provided in the section 114 survey Excel files was used. Note that if annual production was used, then actual operating hours were not used. The metals and MIBK multipliers calculated to de termine allowable emissions for each emission point are provided in Appendix A

- 8

. Final Allowable Calculation The allowable emissions were then calculated for each pollutant using the appropriate multiplier (either the fluoride or metals multiplier) and th e actual emissions. The allowable emissions were calculated using the following equation: Allowable emissions (tons/yr) = actual emissions (tons/yr) * multiplier

8.0 INCORPORATION OF FAC ILITY WIDE NATIONAL EMISSIONS INVENTORY CATEGORY DATA Three modeling files were developed for use in the risk review; a file with data for only the Phosphoric Acid Manufacturing source category (MACT code 1411) , a file with data for only the Phosphate Fertilizer Production source category (MACT code 1410) , and a facility wi de modeling file. Data that were submitted for the s ection 114 request were used as primary data.

7

### To create the facility wide modeling file a dditional emissions data that were not submitted for the s ection 114 request were extracted from the 2005 National Emissions Inventory (NEI). NEI data were extracted for all records for all pollutants in the database for the facilities identified in this analysis. The records were sorted by MACT code. The standard classification code ( SCC ) codes for the records extra cted and sorted were reviewed to identify any mislabeled data, and data were re - assigned to a MACT (or non

- MACT) category where appropriate. For the MACT records in the NEI, records were removed for any pollutants that were included in the test results sub mitted as part of the s ection 114 request and the data submitted by the facilities as described in this memo was substituted. The 2008 NEI was also reviewed for pollutants that were not reported in the 2005 NEI; any records identified as missing in the 20 05 NEI were added from the 2008 NEI data. 9.0 EMISSION CORRECTIONS TO RTR MODELING FILE After the RTR modeling file was compiled and the risk assessments were performed, certain corrections to the emissions data were identified. These corrections were reviewed on a case - by

- case basis to determine if they would impact the risk results. In each instance, it was determined the RTR modeling file did not need to be revised because the actual emissions for each facility decreased, which would result in lower human and ecological risk , or had a negligible increase which would not affect human and eco logical risk . Since the original modeled emissions did not present any risks that were determined to be unacceptable, lower or negligibly changed emissions values would not need remodeling as the acceptability is already known. Each of the identified corre ctions are discussed here. Note that while these emission corrections were not incorporated into the modeling file, they were used when other emissions analyses were conducted, such as the Technology Review. PCS Aurora Calciner Emissions (EP 201 - 206) Emiss ions for PCS Aurora’s calciners were calculated using emissions data from the one calciner tested (EP

- 203). The emissions for each non

- tested calciner were then calculated using annual production data. An incorrect annual production value was used for the tested calciner (EP

- 203) so the estimated emissions for the other five calciners are high. The corrected emissions for all pollutants were reduced by approximately 46%. Table 2 shows the specific correction factor that can be applied to each pollutant emi ssions value for calciners EP

- 201, 202, 204, 204, and 206 in the modeling file to determine the corrected emissions. Table 2 . Emission Correction Summary for PCS Aurora ’ s Calciners. Facility Name Process Unit Emission Point Original Production Value CORRE CTED Production Value Correction Factor PCS Aurora 203 EP

- 20 3 250,842 365,695 0.6859 

### PCS Aurora MAP/DAP Emissions (EP - 302 and 303) As discussed in section 3.0 above, mercury was not tested for two APF emission points (EP

- 302 and EP

- 303) and an estimate was made using mercury data from all APF processes.

8

### Based on a review of data, the mercury emissions for both emission points were ove restimated because several of the production rates and operating hours were incorrect for the non

- PCS Aurora APF processes. Correcting these values resulted in a change of the average APF Hg emission factor from 2.96E

- 09 tons Hg per ton of P 2 

### O 5 

### to 2.87 ton s Hg per ton of P 2 

### O 5 

### (see Appendix A

- 2 for the development of the APF Hg emission factor and its application to calculate Hg emissions). For EP

- 302 and EP

- 303 the corrected emissions would be reduced by 3%. Mosaic New Wales (P - 5, EP - 06) Emission point EP

- 06 at process unit P

- 5 was not tested, and emissions data from a representative emission point was used to estimate emissions. However, the production rate used to scale emissions for EP

- 06 was misinterpreted as a P 2 

### O 5 

### basis. The corrected emissions for al l pollutants would be reduced by approximately 62%. Table 3 shows the specific correction factor that can be applied to each pollutant emissions value for EP

- 06 in the modeling file to determine the corrected emissions. Table 3 . Emission Correction Summary for Mosaic New Wales. Facility Name Process Unit Emission Point Original Production Value CORRECTED Production Value Correction Factor Mosaic New Wales P

- 5 EP

- 06 118.3 44.62 0.3772 

### Mosaic Riverview (P - 12, EP - 4; P - 13, EP - 5 and EP - 6) Certain emission points ( P

- 12, EP

- 4; P

- 13, EP

- 5 and EP

- 6 ) were not tested, and emissions data from a representative emission point was used to estimate emissions. However, the production rate used to scale emissions for each of the three emission points was misinterpreted as a P 2 

### O 5 

### basis. The corrected emissions for all pollutants would be reduced by approximately 34% or 54% for each emission point. Table 4 shows the specific correction factor that can be applied to each pollutant emissions value for EP

- 4, EP

- 5, and EP

- 6 in the modeling file to determine the corrected emissions. Table 4. Emission Correction Summary for Mosaic Riverview. Facility Name Process Unit Emission Point Original Production Value CORRECTED Production Value Correction Factor Mosaic Riverview P

- 12 EP

- 4 126.33 83.59 0.6617 Mosaic Riverview P

- 13 EP

- 5 133.83 91.66 0.4632 Mosaic Riverview P

- 13 EP

- 6 133.83 91.66 0.4632



### Mercury Ontario - Hydro Method QA A detailed review of the Ontario

- Hydro Method (OH) Hg data was conducted that identified certain issues. Notably, there was a discrepancy in the manner in which testing companies handled field blanks or non - detect data

. Each facility’s OH Hg data were examined and corrected as appropriate so that a consistent protocol was followed. The resulti ng change in emissions for each facility is provided in Table 5.

9

### Table 5. Emission Correction s Resulting from Ontario - Hydro Method QA.

Facility Name Process Unit Emission Point Pollutant Hg Emission s from Modeling File (TPY) New Hg Emissions from QA

(TPY) Percent Change Agrium Nu

- West Gran EP

- 6 Elemental Gaseous Hg 2.99E

- 05 4.20E

- 05 41% Agrium Nu

- West Gran EP

- 6 Gaseous Divalent Hg 9.88E

- 06 1.67E

- 05 69% Agrium Nu

- West Gran EP

- 6 Particulate Divalent Hg 9.88E

- 06 1.67E

- 05 69% Agrium Nu

- West SPA 2Filt Elemental Gaseous Hg 6.51E

- 07 9.34E

- 07 43% Agrium Nu

- West SPA 2Filt Gaseous Divalent Hg 2.32E

- 07 3.77E

- 07 63% Agrium Nu

- West SPA 2Filt Particulate Divalent Hg 2.32E

- 07 3.77E

- 07 63% Agrium Nu

- West SPA 3131 Elemental Gaseous Hg 7.08E

- 07 1.02E

- 06 43% Agrium Nu

- West SPA 3131 Gaseous Divalent Hg 2.53E

- 07 4.11E

- 07 63% Agrium Nu

- West SPA 3131 Particulate Divalent Hg 2.53E

- 07 4.11E

- 07 63% Agrium Nu

- West SPA 3241 Elemental Gaseous Hg 9.38E

- 07 1.35E

- 06 43% Agrium Nu

- West SPA 3241 Gaseous Divalent Hg 3.35E

- 07 5.44E

- 07 63% Agrium Nu

- West SPA 3241 Particulate Divalent Hg 3.35E

- 07 5.44E

- 07 63% Agrium Nu

- West SPA 6101 Elemental Gaseous Hg 5.30E

- 07 9.15E

- 07 73% Agrium Nu

- West SPA 6101 Gaseous Divalent Hg 6.62E

- 08 4.52E

- 07 582% Agrium Nu

- West SPA 6101 Particulate Divalent Hg 6.62E

- 08 4.52E

- 07 582% Agrium Nu

- West SPA EP

- 283 Elemental Gaseous Hg 5.92E

- 07 7.48E

- 07 26% Agrium Nu

- West SPA EP

- 283 Gaseous Divalent Hg 7.67E

- 08 1.78E

- 07 132% Agrium Nu

- West SPA EP

- 283 Particulate Divalent Hg 7.67E

- 08 1.78E

- 07 132% Agrium Nu

- West SPA EP

- 522 Elemental Gaseous Hg 6.94E

- 07 1.22E

- 05 1662% Agrium Nu

- West SPA EP

- 522 Gaseous Divalent Hg 3.05E

- 07 3.03E

- 06 895% Agrium Nu

- West SPA EP

- 522 Particulate Divalent Hg 3.05E

- 07 3.03E

- 06 895% Agrium Nu

- West SPA EP

- 71 Elemental Gaseous Hg 5.96E

- 05 8.38E

- 05 40% Agrium Nu

- West SPA EP

- 71 Gaseous Divalent Hg 1.89E

- 05 3.42E

- 05 81% Agrium Nu

- West SPA EP

- 71 Particulate Divalent Hg 1.89E

- 05 3.42E

- 05 81% CFI Plant City A

- DAP A

- DAP Elemental Gaseous Hg 6.60E

- 05 8.33E

- 05 26% CFI Plant City A

- DAP A

- DAP Gaseous Divalent Hg 3.58E

- 06 3.87E

- 06 8% CFI Plant City A

- DAP A

- DAP Particulate Divalent Hg 3.58E

- 06 3.87E

- 06 8% CFI Plant City A

- PAP A

- PAP Elemental Gaseous Hg 1.66E

- 04 1.94E

- 04 17% CFI Plant City A

- PAP A

- PAP Gaseous Divalent Hg 5.14E

- 06 6.75E

- 06 31% CFI Plant City A

- PAP A

- PAP Particulate Divalent Hg 5.14E

- 06 6.75E

- 06 31% CFI Plant City B

- PAP B

- PAP Elemental Gaseous Hg 2.98E

- 04 3.49E

- 04 17% CFI Plant City B

- PAP B

- PAP Gaseous Divalent Hg 9.22E

- 06 1.21E

- 05 31% CFI Plant City B

- PAP B

- PAP Particulate Divalent Hg 9.22E

- 06 1.21E

- 05 31% CFI Plant City X

- MAP X

- MAP Elemental Gaseous Hg 3.75E

- 03 2.30E

- 03

- 39% CFI Plant City X

- MAP X

- MAP Gaseous Divalent Hg 1.77E

- 05 1.43E

- 05

- 19% CFI Plant City X

- MAP X

- MAP Particulate Divalent Hg 1.77E

- 05 1.43E

- 05

- 19%



### 10Facility Name Process Unit Emission Point Pollutant Hg Emission s from Modeling File (TPY) New Hg Emissions from QA

(TPY) Percent Change CFI Plant City Y

- MAP Y

- MAP Elemental Gaseous Hg 3.04E

- 03 3.43E

- 03 13% CFI Plant City Y

- MAP Y

- MAP Gaseous Divalent Hg 5.84E

- 05 6.64E

- 05 14% CFI Plant City Y

- MAP Y

- MAP Particulate Divalent Hg 5.84E

- 05 6.64E

- 05 14% CFI Plant City Z

- MAP Z

- MAP Elemental Gaseous Hg 3.75E

- 03 2.30E

- 03

- 39% CFI Plant City Z

- MAP Z

- MAP Gaseous Divalent Hg 1.77E

- 05 1.43E

- 05

- 19% CFI Plant City Z

- MAP Z

- MAP Particulate Divalent Hg 1.77E

- 05 1.43E

- 05

- 19% Mosaic New Wales P

- 1 EP

- 22 Elemental Gaseous Hg 2.57E

- 06 2.46E

- 06

- 4% Mosaic New Wales P

- 1 EP

- 22 Gaseous Divalent Hg 3.21E

- 07 3.08E

- 07

- 4% Mosaic New Wales P

- 1 EP

- 22 Particulate Divalent Hg 3.21E

- 07 3.08E

- 07

- 4% Mosaic New Wales P

- 2 EP

- 05 Elemental Gaseous Hg 3.70E

- 04 4.01E

- 04 8% Mosaic New Wales P

- 2 EP

- 05 Gaseous Divalent Hg 4.62E

- 05 5.01E

- 05 8% Mosaic New Wales P

- 2 EP

- 05 Particulate Divalent Hg 4.62E

- 05 5.01E

- 05 8% PCS Aurora 406 EP

- 408 Elemental Gaseous Hg 1.81E

- 06 2.93E

- 06 62% PCS Aurora 406 EP

- 408 Gaseous Divalent Hg 5.09E

- 07 1.41E

- 06 178% PCS Aurora 406 EP

- 408 Particulate Divalent Hg 5.09E

- 07 1.41E

- 06 178% PCS White Springs 20 20.01 Elemental Gaseous Hg 1.15E

- 04 1.03E

- 04

- 11% PCS White Springs 20 20.01 Gaseous Divalent Hg 1.44E

- 05 6.13E

- 06

- 57% PCS White Springs 20 20.01 Particulate Divalent Hg 1.44E

- 05 6.13E

- 06

- 57% PCS White Springs 20 20.01 Elemental Gaseous Hg 8.70E

- 05 1.03E

- 04 18% PCS White Springs 20 20.01 Gaseous Divalent Hg 1.09E

- 05 6.13E

- 06

- 44% PCS White Springs 20 20.01 Particulate Divalent Hg 1.09E

- 05 6.13E

- 06

- 44% PCS White Springs 32 EP

- 32 Elemental Gaseous Hg 2.57E

- 04 2.93E

- 04 14% PCS White Springs 32 EP

- 32 Gaseous Divalent Hg 3.21E

- 05 1.36E

- 05

- 57% PCS White Springs 32 EP

- 32 Particulate Divalent Hg 3.21E

- 05 1.36E

- 05

- 57% PCS White Springs 36 34.01 Elemental Gaseous Hg 1.43E

- 04 1.38E

- 04

- 3% PCS White Springs 36 34.01 Gaseous Divalent Hg 1.78E

- 05 7.01E

- 06

- 61% PCS White Springs 36 34.01 Particulate Divalent Hg 1.78E

- 05 7.01E

- 06

- 61% PCS White Springs 69 69.01 Elemental Gaseous Hg 2.42E

- 04 2.52E

- 04 4% PCS White Springs 69 69.01 Gaseous Divalent Hg 3.03E

- 05 1.93E

- 05

- 36% PCS White Springs 69 69.01 Particulate Divalent Hg 3.03E

- 05 1.93E

- 05

- 36% PCS White Springs 70 70.01 Elemental Gaseous Hg 1.86E

- 04 1.80E

- 04

- 3% PCS White Springs 70 70.01 Gaseous Divalent Hg 2.33E

- 05 9.16E

- 06

- 61% PCS White Springs 70 70.01 Particulate Divalent Hg 2.33E

- 05 9.16E

- 06

- 61% PCS White Springs EU 008 EP

- 8 Elemental Gaseous Hg 1.70E

- 04 1.94E

- 04 14% PCS White Springs EU 008 EP

- 8 Gaseous Divalent Hg 2.12E

- 05 9.01E

- 06

- 57% PCS White Springs EU 008 EP

- 8 Particulate Divalent Hg 2.12E

- 05 9.01E

- 06

- 57% Simplot Don

- Pocatello P

- 1 EP

- 101 Elemental Gaseous Hg 1.11E

- 05 4.50E

- 06

- 59%



### 11Facility Name Process Unit Emission Point Pollutant Hg Emission s from Modeling File (TPY) New Hg Emissions from QA

(TPY) Percent Change Simplot Don

- Pocatello P

- 1 EP

- 101 Gaseous Divalent Hg 1.38E

- 06 6.01E

- 07

- 56% Simplot Don

- Pocatello P

- 1 EP

- 101 Particulate Divalent Hg 1.38E

- 06 6.01E

- 07

- 56% Simplot Don

- Pocatello P

- 1 EP

- 102 Elemental Gaseous Hg 8.33E

- 05 5.03E

- 05

- 40% Simplot Don

- Pocatello P

- 1 EP

- 102 Gaseous Divalent Hg 1.04E

- 05 1.10E

- 05 6% Simplot Don

- Pocatello P

- 1 EP

- 102 Particulate Divalent Hg 1.04E

- 05 1.10E

- 05 6% Simplot Don

- Pocatello P

- 1 EP

- 103 Elemental Gaseous Hg 4.75E

- 06 2.21E

- 06

- 53% Simplot Don

- Pocatello P

- 1 EP

- 103 Gaseous Divalent Hg 5.94E

- 07 1.72E

- 06 191% Simplot Don

- Pocatello P

- 1 EP

- 103 Particulate Divalent Hg 5.94E

- 07 1.72E

- 06 191% Simplot Don

- Pocatello P

- 2 EP

- 201 Elemental Gaseous Hg 5.76E

- 05 2.21E

- 05

- 62% Simplot Don

- Pocatello P

- 2 EP

- 201 Gaseous Divalent Hg 7.20E

- 06 1.33E

- 05 84% Simplot Don

- Pocatello P

- 2 EP

- 201 Particulate Divalent Hg 7.20E

- 06 1.33E

- 05 84% Simplot Don

- Pocatello P

- 2 EP

- 202 Elemental Gaseous Hg 5.76E

- 05 2.21E

- 05

- 62% Simplot Don

- Pocatello P

- 2 EP

- 202 Gaseous Divalent Hg 7.20E

- 06 1.33E

- 05 84% Simplot Don

- Pocatello P

- 2 EP

- 202 Particulate Divalent Hg 7.20E

- 06 1.33E

- 05 84% Simplot Don

- Pocatello P

- 3 EP

- 301 Elemental Gaseous Hg 1.19E

- 05 6.85E

- 06

- 42% Simplot Don

- Pocatello P

- 3 EP

- 301 Gaseous Divalent Hg 1.49E

- 06 1.60E

- 06 8% Simplot Don

- Pocatello P

- 3 EP

- 301 Particulate Divalent Hg 1.49E

- 06 1.60E

- 06 8% Simplot Don

- Pocatello P

- 3 EP

- 302 Elemental Gaseous Hg 1.19E

- 05 6.85E

- 06

- 42% Simplot Don

- Pocatello P

- 3 EP

- 302 Gaseous Divalent Hg 1.49E

- 06 1.60E

- 06 8% Simplot Don

- Pocatello P

- 3 EP

- 302 Particulate Divalent Hg 1.49E

- 06 1.60E

- 06 8% Simplot Don

- Pocatello P

- 3 EP

- 303 Elemental Gaseous Hg 1.19E

- 05 6.85E

- 06

- 42% Simplot Don

- Pocatello P

- 3 EP

- 303 Gaseous Divalent Hg 1.49E

- 06 1.60E

- 06 8% Simplot Don

- Pocatello P

- 3 EP

- 303 Particulate Divalent Hg 1.49E

- 06 1.60E

- 06 8% Simplot Don

- Pocatello P

- 4 EP

- 401 Elemental Gaseous Hg 1.80E

- 05 1.46E

- 05

- 19% Simplot Don

- Pocatello P

- 4 EP

- 401 Gaseous Divalent Hg 2.25E

- 06 2.44E

- 06 8% Simplot Don

- Pocatello P

- 4 EP

- 401 Particulate Divalent Hg 2.25E

- 06 2.44E

- 06 8% Simplot Don

- Pocatello P

- 5 EP

- 501 Elemental Gaseous Hg 1.27E

- 04 4.97E

- 05

- 61% Simplot Don

- Pocatello P

- 5 EP

- 501 Gaseous Divalent Hg 1.59E

- 05

- 3.22E

- 05

- 303% Simplot Don

- Pocatello P

- 5 EP

- 501 Particulate Divalent Hg 1.59E

- 05

- 3.22E

- 05

- 303% Simplot Rock Springs P

- 4 EP

- 40 Elemental Gaseous Hg 5.54E

- 06 6.98E

- 06 26% Simplot Rock Springs P

- 4 EP

- 40 Gaseous Divalent Hg 1.59E

- 06 8.72E

- 07

- 45% Simplot Rock Springs P

- 4 EP

- 40 Particulate Divalent Hg 1.59E

- 06 8.72E

- 07

- 45%



### 10.0 ADDITIONAL EMISSIONS TESTING DA TA As described in a separate memorandum 1 

### , o n January 24, 2014, EPA issued a section 114 survey and testing request in order to gather additional mercury and hydrogen fluoride emissions

12

### data from calciner operations, and additional hydrogen fluoride emissions data from certain WPPA , SPA, and APF lin es. H ourly emission rates were calculated by multiplying the standardized concentration results by the reported volumetric flow rates for each emission point that was tested. The corresponding annual hours of production reported by facilities in the secti on 114 survey were then used to estimate the annual emissions for each pollutant and emission point tested. For calciner operations, the f acilit y conducted three tests using EPA Method 30B for mercury, and two tests using EPA Method 320 for hydrogen fluoride (each test consisting of three consecutive one - hour runs ). For hydrogen fluoride testing on WPPA, SPA, and APF process lines, f acilit ies conducted one test using EPA Method 320 consisti ng of three consecutive one

- hour runs . T he average of the test runs was used to estimate the annual baseline emissions for each emission point at each facility. As described in a separate memorandum 2 

### , the additional mercury data were used to inform the ma ximum achievable control technology (MACT) floor determinations for mercury for phosphate rock calciners in the phosphoric acid manufacturing plants (40 CFR part 63, subpart AA) source category

. The hydrogen fluoride emissions data were used to investigat e whether hydrogen fluoride emission limits could be used as an alternative to the total F emission limits in 40 CFR part 63, subpart AA and subpart BB

. The EPA is proposing to translate the current total F limit (lbs total F/ton P 2 

### O 5 

### feed) into the equiva lent HF limit (lbs HF/ ton P 2 

### O 5 

### feed). The additional mercury emissions were used to advise an updated risk analysis. The multipathway modeling methodology has been updated since the original modeling was conducted for this project. Given the new mercury t est data that was collected from calciner units as part of the 2014 section 114 testing request and the updated modeling methodology, corrected calciner mercury emissions were used for multipathway modeling. None of the HF data collected in the 2014 ICR te sting request were incorporated into the modeling file to re

- run the risk assessments. This is because all HF emissions from 2014 were less than or similar to the emissions from 2010. Therefore, we do not expect any significant impact on the risk assessmen t results nor a change to the proposed rule revisions. 11.0 COMPARISON OF FACILI TY EMISSIONS TO MAJOR SOURCE THRESHOLDS When evaluating the facilities that would be included in the analyses conducted for the phosphoric acid and phosphate fertilizer RTR, the available emissions data were reviewed. These emissions data were reviewed to examine how facility emissions compared to the thresholds for major source applicability. Facilities are major sources if a single HAP has emissions greater than 10 tons per year, or if total HAP emissions are greater than 25 tons per year. Most phosphoric acid and phosphate fertilizer facilities easily exceeded these thresholds . H owever, Mosaic Uncle Sam and Mississippi P hosphates reported in their 2010 section 114 responses that they are area sources and thus not subject to NESHAP subpart AA or NESHAP subpart BB

. A table comparing the available emissions data is provided in Appendix A

- 9. This table includes 2005, 2008, an d 2011 NEI emissions data along with the estimated emissions from the modeling file for each facility. Because the HF emissions for Mosaic Uncle Sam and Mississippi

13

### Phosphates show the potential to exceed the 10 tons per year threshold for major sources , w e determined it was appropriate for these facilities to be included in all analyses conducted to support the RTR development. Therefore, the available data from all 13 phosphoric acid manufacturing and phosphate fertilizer production facilities were used i n all analyses conducted. 12.0 REFERENCES 1. ERG, 2014

. “ Information Collection and Additional Data Received for the Phosphoric Acid and Phosphate Fertilizer Production Source Categories. ” May 2014

. 2. ERG, 201 4

. “ Maximum Achievable Control Technology (MACT) Floor Analysis for Phosphate Rock Calciners at Phosphoric Acid Manufacturing Plants

. ” May 2014.

14