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 eligibility letter 

 

 L.9.4 Model plant exemption rationale 

 

 L.9.5 BART exemption letter 
Terra 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, Mississippi Department of Environmental Quality 

(MDEQ) sent them a letter requesting information to determine BART eligibility. Based 

on the information received from Terra MS, several 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 

SO2, NOx, or PM10. 

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

SO2 NOx PM10

Primary Reformer 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, NOx, and SO2 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 Nitrogen was deemed exempt from further 

demonstration due to the model plant criteria. 

Appendix L.9.1
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.

.

.

.

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 -.-.

Appendix L.9.2
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.

.

.

.

.

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

specific

Appendix L.9.2
STATE 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.

Thefacility

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 thatwiJI

Appendix L.9.3
be 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,

~",.~

Appendix L.9.3
BART Exemption Rationale for Terra Mississippi Nitrogen, Inc. 

Terra Mississippi Nitrogen, Inc. is a BART eligible facility. 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 SO2 or NOx

or SO2 + NOx should be less than 500 tons for facilities 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 nearest Class I area. The model plant criteria 

proposed by the EPA does not consider 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 kilometers from the closest 

Class 1 area (Sipsey). However, the PM component 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 appropriately include PM in the model plant 

exemption process was developed by Jim Boylan of Georgia DNR. This rationale 

determines a “PM factor” to relate primary PM to secondary sulfate PM from SO2. Using 

his reasoning as our basis gives the following rationale to exclude the Terra Mississippi. 

• Only a fraction SO2 is converted to SO4 is and the amount is a function of the SO2

to SO4 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 SO2 to SO4 conversion of 8.3%. 

• Conversion of 1 ton SO2 (molecular weight =64) will produce 2.06 tons 

Ammonium Sulfate (MW=132). 

• Therefore, 1000 tons SO2*8.3% conversion*2.06 ton SO4/ton SO2 equals 171 tons 

SO4. 

• Assuming that all PM emissions are sulfate, 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 from 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, 

NOx and SO2 potentials are totaled, they equal 766.26 tpy which is less than the 1000 tpy 

model plant threshold. Based on the model plant criteria, Terra Mississippi would be 

exempt from further review. 

Appendix L.9.4
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

Appendix L.9.5