Appendix L.9: Terra Mississippi Nitrogen Inc. Appendix L.9 contents: L.9.1 Appendix summary L.9.2 BART information request letter L.9.3 BART elig ibility letter L.9.4 Model plant exemption rationale L.9.5 BART exemption letterTerra Mississippi Nitrogen, Inc. (3020-00010) BART Process Summary As fossil fuel fired steam electric plant, Terra Mississippi Nitrogen, Inc. meets the initial BART eligibility requirement of source category code. The Yazoo City plant is 308 km from Sipsey Wilderness Area, a Class I area and has a possible visibility impact. Therefore, on February 28, 2002, Mississipp i Department of Environmental Quality (MDEQ) sent them a letter requesting information to determine BART eligibility. Based on the information received from Terra MS, seve ral units at each facility were deemed BART eligible because they met the following criteria:

• operating or under construction between Aug.7, 1962 to Aug.7, 1977

• having potential emissions that exceed the limit of 250 tons per year for SO 2 , NO x , or PM10.

The following are the BART-eligible point sources for Terra MS:

SO 2 NO x PM 10 Primary Reforme r 740 1 603 24 n/a Start-up Heater 33 0 14 1 n/a Totals 1 617 25 Emission Unit Heat Duty (MMBtu/hr) Maximum Emission Rates (tons per year) Existing Control Equip.

Terra Mississippi Nitrogen’s potential PM10, NO x , and SO 2 emissions are less than 1000 tons per year and the facility is greater than 100 kilometers from the closest Class 1 area (Sipsey). Therefore, Terra Mississippi N itrogen was deemed exempt from further demonstration due to the model plant criteria.STATE OF MrSSl'SSlPPI DA VlD RoNALD Ml.I9GAOVE, OOVERNoR M~SISSIPPI DEPARTMENT OF ENVIRONMENT At

0iA1U.ES H. CHISOLM, ~VE D1RI!C'roR 

# February 28, 2002 COP Y

Mr. Steve Brister MISSCHEM Nitrogen LLC P.O. Box 1348 Yazoo City, MS 39194 Re: BART Infonnation Request
Dear Mr. Brister: In July 1999, The Environmental Protection Agency~PA) issued regional haze regulations to improve visual air quality, or visibility, in specified national parks and wilderness areas across the country. These regulations r.equire sta~ to establish goals for improving visibility in these areas and to submit state implementation plans {SIPs) that contain enforceable measures and ~ontrol strategies for reducing visibility-impairing pollution. One component of these regulations is to reduce emissions &om certain, .existing, large emission units by installing the best available emission <:ontrols. This requirement, known as the Best Available tletrofit Technology (BART) r.equirement, applies to emission units that: were built between August 7, 1962 and August 7, 1977; have the potential to emit 250 tons per year or more of ammonia, nitmgen oxides, particulate matter less that 10 microns (PM 1 0), sulfur dioxide, or volatile organic compounds, either individually or in combination with other such units; and fall into one of 26 listed source categories, including 'Steam electric plants and industrial boilers, and large industrial plants such as pulp mills, refineries, and smelters. See attached list. 

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The final implementation plan should be submiued to EP A by December 31, must contain, among other things, the emission limits and 'COmpliance schedules BART subject source. The first step in this process is to identify all BART sources. Mississippi and other southeast.em states and tribes have formed a Regional Planning Organization, known as VISTAS, to work on the regional haze issue and the r.equired

()FfQ .~ c.. ---~ QUALITY

2008, and for ~ach subject

~L > -.u -.-.implementation plans. It is our ~oa1 to have all BART ~ubject faci1ities and the

emission units at the facilities identified by June 2002. An initial file review indica~s that your facility is p~ntially subject to the BART requirement because it falls into one of the 26 source <:a~ories, was built prior to August 7, 1977, and has potential emissions greater than 250 tons per year for at least one of the visibility-impairing pollutants. However, the infonnation lis~d below is needed to make a determination. The initial startup date for facility. The initial startup date for individual emission units. The dates of any modification or reconstruction for individual units. The BART source category of the emission units. 

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. A list of emission units obtained from our files is enclosed. Please -enter the dates of initial start-up and any modification or reconstruction, review and make any corrections to the listed source category, and review and make any~orrections to the potential emissions. This information is also available in ~xcel spreadsheet format which can be completed and submitted electronically. Please respond by April 19, 2002. If this infonnation is not reoeived, the facility and all emission units at the facility will be considered subject to the BART pequirements. However, the final detenninations will not be made until the SIP development process. Thank you for your help with this project. If you have any questions, please ~ontact me at (601)961-5176 or Deborah Boleware at (601)961-5768. If you would like the electronic copy of the emission unit list, please send an e-mail to deborah 

## - boleware@deq.state.ms.us and elliott 

## - bickerstafi@deq .sta~.ms. us.

Sincerely, 

## ! N&j~..8J;'~ Elliott Bickerstaff, P .E. Chief, Air Support Branch 

### specificSTATE OF MISSISSIPPI DAVID RoNAW M~ROVE. OOVERNoR MmmIPpt DEPARTMENT OF ENVIRONMENT AL ~UALITY

CHARLES H. OiISOLM. ExIiCUTIYE DIRECTOR

September 9, 2002 Mr. Kearney Crochet MISSCHEM Nitrogen LLC P.O. Box 1348 Yazoo City, MS 

### 39194

Dear Mr. Crochet: This letter is to acknowledge receipt of your April 25, 2002 response to our Best A vailab1e Retrofit Technology (BART) information request. After reviewing the information you submitted, it appears your facility is BART eligible for the following reasons:


### 1.
2.
3. The facility Many units date range. The emissions 

### MMBTU

On May 24, 2002, the D.C. circuit court Haze Rule (RHR). At issue is the method installing BART at a particular source. The made on a group or collective basis; however, it requires this determination to be made on a three-judge panel agreed with the petitioners requiring EPA to revise the BART requirements approach. EPA has moo a petition seeking Depending on the outcome of the appeals prooess, this ruling may affect a BART applicable source will be required to install, but the ruling did not therefore will not impact the methods in defermining the BART applicable plan to proC6ed with identifying the specific emission units at the facility subject to this requirement. Please nose that a BART applicable source is

OfDoOf ~
~ -- ......- 

# ------- Re: BART Information Response MISSCHEM Nitf"ogen LLC Yawo County, Missmippi

meets the category requirement for fossil fuel-fired boilers (2'50 input per hour). began operation during the August 7, 1962 to August 7, 1977 from these units exceed the 2SO tons per year limit. beat

vaca~ the BART provisions of the Regional of determining the cost and benefits of RHR requires this determination to be was argued that the Clean Air Act sour<:e by SOUfCe basis. In a 2-1 decision, and vacated the BART provisions, to incorporate a 50uroe by souPCe rehearing of the a'Se by the fulh:ourt.

CODB'ols and We 

### a

what' addJess sources that are one that 

### wiJIbe considered for retrofit tachnology controls. It does not necessarily mean that

additional controls will be required for the source. Those determinations will be matte over the next several years during the Regional Haze planning and our State Implementation Plan development process. Attached are the BART requirement text and the applicable defmitioDS Kom the Code of Federal Regulations. If you have questions or <;omments regarding the BART requirements or this designation, please contact me at ~601) 961-5176 or Deborah Boleware at (601) 961-5768.
Sincerely, ~",.~BART Exemption Rationale for Terra Mississippi Nitrogen, Inc. Terra Mississippi Nitrogen, Inc. is a BART eligible facilit y. We are electing to use the Model Plant rule as given in Part III, Option 2 of the BART Guidelines to exempt this facility. The model plant criteria states for exemption potential emissions of SO 2 or NO x or SO 2 + NO x should be less than 500 tons for facili ties greater than 50 kilometers (km) from the nearest class I area or potential emissions should be less than 1000 tons for facilities greater than 100 km from the n earest Class I area. The model plant criteria proposed by the EPA does not cons ider the contribution from PM. The plant’s total potential emissions of NOx and SO2 for BART eligible units are less than 1000 tons per year and the facility is greater than 100 kilomete rs from the closest Class 1 area (Sipsey). However, the PM co mponent needs to be addressed and simply adding it in with the NOx and SO2 may not be correct since it can have a different impact on visibility than NOx and SO2. Logic to ap propriately include PM in the model plant exemption process was developed by Jim B oylan of Georgia DNR. This rationale determines a “PM factor” to relate prim ary PM to secondary sulfate PM from SO 2 . Using his reasoning as our basis gives the following rationale to exclude the Terra Mississippi.

• Only a fraction SO 2 is converted to SO 4 is and the amount is a function of the SO 2 to SO 4 conversion rate, the distance and the wind speed.

• Using a conversion rate of 1.5 % per hour, wind speed of 5m/s and a distance of 100km gives a SO 2 to SO 4 conversion of 8.3%.

• Conversion of 1 ton SO 2 (molecular weight =64) will produce 2.06 tons Ammonium Sulfate (MW=132).

• Therefore, 1000 tons SO 2 *8.3% conversion*2.06 ton SO 4 /ton SO 2 equals 171 tons SO 4 . • Assuming that all PM emissions are sulf ate, gives a PM factor of 1000/171 or 5.85. In reality, only a fraction of the PM would be sulfate and most other components have lower extinction coefficients than that of sulfate, making this a very conservative value.

Terra Mississippi Nitrogen, Inc. is 308 km fr om the nearest Class 1 area and has potential emissions of 25.2 tons per year (tpy) PM10, 617.36 tpy NOx, and 1.48 tpy SO2 from its BART eligible units. Applying the PM factor, 25.2* 5.85 =147.42. When the PM10, NO x and SO 2 potentials are totaled, they equal 76 6.26 tpy which is less than the 1000 tpy model plant threshold. Based on the model pl ant criteria, Terra Mississippi would be exempt from further review.STATE OF MISSISSIPPI HALEY 8AR8oUlt GovERNoR MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY TauDy D. FI5HIR. ExEamvI DwIcroR

November 27,2007 Kearney Crochet Terra Mississippi Nitrogen Inc. POBox 1348 Yazoo City, MS 39194-1348 Subject: Exemption from Best Available Retrofit Technology (BART) Detennination Requirements TeJTa Mississippi Nitrogen, (3020)163-00010 Yazoo County, Mississippi

Dear Mr. Crochet: Due to Terra Mississippi Nitrogen being BART eligible, the visibility impacts of the BART eligible sources had to be analyzed to detennine if they were BART subject. The total potential PM 1 0, NOx, and S02 emissions for the BART eligible units were small enough to use the model plant option in the BART Guidelines to propose exemption for the plant. Please see attached explanation of the model plant option and calculations for your facility. Mississippi Department of Environmental Quality (MDEQ) will include documentation of the proposed exemptions in our Regional Haze State Implementation Plan (SIP) submittal. The SIP is reviewed and commented on by the Environmental Protection Agency (EP A) and other parties with Terra Mississippi Nitrogen's exemption contingent on EPA's approval. If you have any questions (601-961-5176) or Deborah Boleware (601-961-5768) of my staff. Sincerely,

PosT 0mcI! Box 10385 . JACKSON, this matter, please feel free to contact Elliott Bickerstaff regarding

OFFICE OF POlLunON CONTROL
MISSISSIPPI 39289-0385 

# . TEL: (601) 961-5171 

# . FAX: (601) 35+6612 . WWW.deq~U5