TECHNICAL MEMORANDUM

TO: Tina Ndoh, U.S. EPA/OAQPS/SPPD - Minerals and Manufacturing Group

FROM: Eastern Research Group, Inc.

DATE: May 20, 2014

SUBJECT: Information Collection and Additional Data Received for the 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 technology (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 data collection and data preparation 

completed by EPA and ERG in an effort to perform the RTR for the phosphoric acid and 

phosphate fertilizer production plants source categories. Section 2.0 describes the data collection 

steps and Section 3.0 describes the data preparation and standardization completed in order to 

perform subsequent analyses. 

2.0 DATA COLLECTION

To collect data on phosphoric acid and phosphate fertilizer production plants, EPA 

reviewed previously collected information, current literature, and data from the National 

Emissions Inventory (NEI). EPA also held meetings with the phosphoric acid and phosphate 

fertilizer industry and visited several production facilities. 

On April 13, 2010, EPA issued a section 114 survey and testing request to 8 companies 

operating an estimated 15 phosphoric acid and/or phosphate fertilizer production plants in the 

U.S. A list of companies and corresponding facilities is presented in Table 2-1. 

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Table 2-1: Companies/Facilities Issued a Section 114 Survey 

and Testing Request on April 13, 2010

Company Facility

Mosaic Fertilizers, LLC

New Wales, FL

Riverview, FL

Bartow, FL

Uncle Sam, LA

Faustina, LA

Mississippi Phosphates Corp Pascagoula, MS

United Suppliers, Inc. Henry, IL

J.R. Simplot, Co Don Plant, Pocatello, ID

Rock Springs, WY

PCS Phosphate Co., Inc.

PCS Phosphate Company, Inc., Aurora, NC

White Springs Agricultural Chemicals, Inc., White Springs, FL

PCS Nitrogen Fertilizer, L.P., Geismar, LA

CF Industries, Inc. Plant City Phosphate Complex, Plant City, FL

Agrium U.S. Inc. Nu-West Industries, Inc. Conda Phosphate Operations (“CPO”) 

Soda Springs, ID

Agrifos Fertilizer L.L.C. Pasadena, TX

Following the issue of the April 13, 2010 section 114 survey and testing request, the EPA 

learned that the United Suppliers Henry, IL facility did not produce phosphoric acid or phosphate 

fertilizer. Additionally, Agrifos Fertilizer informed EPA of plans to cease production around 

December of 2010 as part of a consent decree. Due to the impending shutdown, emissions testing 

and solid material assays, as described in this memo, were not performed at the Agrifos 

Pasadena, TX facility. Discounting the Agrifos and United Suppliers facilities, the EPA 

determined there are 13 phosphoric acid and/or phosphate fertilizer facilities operating in the 

U.S. 

The April 13, 2010 section 114 request required companies to complete a survey and 

conduct emissions testing and solid material assays. The survey was formatted as a series of 

Microsoft (MS) Excel worksheets and collected basic data on each facility such as location, 

contact information, and permitting information. The survey also collected process and control 

equipment information such as equipment type, flow rates, and fuel types. The survey included 

specific sections for gypsum stacks and cooling ponds, startup and shutdown, heat exchange 

systems, and feedstock unloading. The testing requirement included two parts: emissions testing 

and solid material assays. The EPA required facilities to perform testing on rock dryers, rock 

calciners, phosphoric acid production process vents, phosphate fertilizer production process 

vents, and defluorination processes. Each facility was required to test for hydrogen fluoride, total 

fluorides, non-mercury metals, particulate matter, hexavalent chromium, mercury, and methyl 

isobutyl ketone (if the facility operated a solvent extraction process). In addition to the testing, 

EPA requested process production rate data concurrent with the duration of the emissions testing 

(e.g., phosphoric acid production in tons per hour of phosphorous pentoxide). 

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The second testing requirement consisted of solid material assays. EPA required 

sampling of the mined ore, beneficiated phosphate rock, post calcined rock, and phosphogypsum 

from active stacks. EPA required that facilities determine the concentrations of the following: 

fluorine and total fluorides, antimony compounds, arsenic compounds, beryllium compounds, 

cadmium compounds, chromium compounds, hexavalent chromium, cobalt compounds, lead 

compounds, manganese compounds, mercury compounds, nickel compounds, and selenium 

compounds.

Facilities were allowed to submit previous testing in lieu of new testing if the results were 

representative of current operations and the testing was performed using phosphate rock from the 

same geological deposit as current operations. Facilities were also allowed to test one process in 

a group of identical processes if all processes were processing rock from the same ore body, 

using the same raw materials, and had identical processing rates, capacities, and temperatures. 

Facilities were allowed to test one process out of similar processes as long as the process tested 

had the highest potential to release HAP and the process was identical in operation and design to 

the other processes aside from capacity. 

Responses to the survey and testing requirements were due to EPA by August 12, 2010 

unless the facility requested an extension. 

On February 16, 2012, EPA requested clarifications regarding facility responses to the 

April 13, 2010 section 114. The clarifications focused on emissions testing results and to which 

processes and facilities representative data should apply. On June 1, 2012 EPA requested 

clarification of the process rate data submitted by facilities in response to the April 13, 2010 

section 114. Responses to the June 1, 2012 clarification requests were due by June 15, 2012, 

unless facilities requested and extension.

On January 24, 2014, EPA issued another section 114 survey and testing request to the 

companies identified in Table 2-2 in order to gather additional mercury emissions and hydrogen 

fluoride emissions from calciner operations, and additional total fluorides and hydrogen fluoride 

emissions from certain wet process phosphoric acid (WPPA) lines, superphosphoric acid (SPA) 

lines, and monoammonium and diammonium fertilizer (APF) lines. The selection of WPPA, 

SPA, and APF lines to be tested were based on a review of the data received from the April 13, 

2010 section 114. In addition to the testing, EPA requested process production rate data 

concurrent with the duration of the emissions testing (e.g., phosphoric acid production in tons per 

hour of phosphorous pentoxide).

Table 2-2: Companies/Facilities Issued a Section 114 Survey 

and Testing Request on January 24, 2014

Company Facility Process Lines Requested To Test

Calciner WPPA SPA APF

Mosaic 

Fertilizers, 

LLC

New Wales, FL --  -- 

Mississippi 

Phosphates 

Corp

Pascagoula, MS --  -- 

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Company Facility Process Lines Requested To Test

J.R. Simplot, 

Co Rock Springs, WY -- --  --

PCS Phosphate 

Co., Inc.

PCS Phosphate Company, Inc., 

Aurora, NC  -- -- --

White Springs Agricultural 

Chemicals, Inc., White Springs, 

FL

--  [1] --

Agrium U.S. 

Inc.

Nu-West Industries, Inc. Conda 

Phosphate Operations (“CPO”) 

Soda Springs, ID

-- --  

[1] On February 21, 2014, EPA removed the requirement for emissions data from the SPA line at this 

facility.

As part of the January 24, 2014 survey, the companies were asked to review the nonconfidential forms that they provided to EPA in response to the April 2010 section 114 survey 

and testing request. Companies were only required to re-submit these non-confidential forms and 

revised Process Unit Flow Diagrams if there had been changes to their operations such that the 

forms no longer reflected the configuration of the process and control equipment for which 

emissions testing was required in the January 24, 2014 survey.

Responses to the survey and testing requirements were due to EPA by March 14, 2014; 

however, in response to a letter from Gallagher and Kennedy on behalf of The Fertilizer Institute 

(TFI) dated February 14, 2014, EPA extended the due date for all companies/facilities to April 

29, 2014. EPA also removed the requirement for total fluorides emissions data to minimize cost 

burden as much as practical in response to financial concerns raised by industry.

3.0 DATA PROCESSING AND STANDARDIZATION

The survey responses and emissions testing results were standardized before performing 

technical analyses. Descriptions of the data preparation and standardization steps are provided 

below. 

Survey Data

The April 13, 2010 survey was originally formatted as a series of MS Excel spreadsheets 

designed to be imported into a MS Access database. 1 Several facilities modified the structures of 

certain forms. Such forms required formatting corrections due to modification by facilities. Data 

contained in the forms requiring correction were not altered. 

The corrected forms were imported into a MS Access database. Quality assurance and 

quality control (QA/QC) checks were performed to ensure the data in each MS Excel form were 

correctly imported into the Access database. Errors identified as a result of the QA/QC effort 

were addressed in subsequent iterations of the database. 

Limited amounts of data were modified to improve presentation and analysis. Data were 

only modified if the intention of the facility was directly obvious. The extent of the modifications 

included, but was not limited to, separation of records containing multiple pieces of equipment 

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and/or emission points in one field, deletion of records containing only “N/A” of “Unknown” 

entries, and the relocation of text entered by facilities into numerical fields to appropriate “notes” 

fields. An “analysis” version of the database was then created by removing blank and duplicate 

records.

Emissions Test Data

The emissions testing data were originally formatted as a series of Microsoft (MS) Excel 

workbooks and MS Access files created using the EPA Electronic Reporting Tool (ERT). 

Data contained in the MS Excel templates were combined into a single MS Excel 

workbook. Data from the ERT MS Access files were extracted using a structured query language 

(SQL) program. The data extracted from the ERT were combined with those extracted from the 

MS Excel templates into a single MS Excel workbook. 2

Following the combination, the data were quality assured (QA) to ensure accurate 

transfer from the MS Excel and MS Access files submitted by facilities. QA checks included 

cross referencing the originally submitted data and the combined MS Excel workbook for 

consistency, referencing facility provided test reports to ensure correct reporting units (e.g., dry 

standard cubic feet per minute versus actual cubic feet per minute, corrected to a three percent 

oxygen concentration basis, etc.) and general checks for data outliers. 

Several corrections and clarifications were made to the compiled MS Excel work book in 

preparation of data analysis. Blank and duplicate records were removed. Process unit identifiers, 

equipment identifiers, and dates were standardized to the format requested by EPA. Control 

equipment gas flow rates were standardized to units of dry standard cubic feet per minute and 

gas temperatures reported as Celsius (°C) were converted to Fahrenheit (°F). Gas flow rate units 

were corrected by comparing the facility submitted emissions testing template to the stack test 

report, if the report was available. 

Facilities reported several HAP concentrations as non-detect (ND) values by using the 

“less than” (<) symbol. The notation was removed and an indicator column was added to the data 

set to note which values were reported as ND. 

Emissions testing results were reported using various concentration units. Concentrations 

were standardized to units of grains per dry standard cubic foot. Emissions testing results were 

also converted to production based emission rates (e.g., pounds emitted per ton of phosphoric 

acid produced on a phosphorus pentoxide basis). 

The emissions test data received from the April 13, 2010 survey were compiled into a 

modeling file which contained all the stack and area source parameters necessary for the air 

dispersion model inputs. 

A quality assurance review of the April 13, 2010 survey data submitted for mercury 

analysis in the excel worksheets revealed discrepancies between the worksheets and the 

laboratory reports submitted. Errors identified included: incorrect use of field blank values in 

concentration calculations, transcription errors between lab results and facility calculations, 

incorrect reporting of data flags, incorrect summations of individual mercury fractions and 

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incorrect reporting of oxygen concentrations. These errors were corrected and the emissions file 

was updated with the revised values. As a result of corrections to the data, there was a net 

decrease in emissions from the industry compared to the original data submitted and supplied in 

the modeling file. 

An updated database of emissions on a production basis was developed using the 

emissions data as discussed and production information as submitted by the facilities in the stack 

test reports or as available on the surveys. A follow-up contact was made with each facility to 

verify the specific production rate associated with each emissions test report.

4.0 REFERENCES

1. Facility Information Collection Request Survey Database for the Phosphoric Acid and 

Phosphate Fertilizer Production Source Categories. Docket ID: EPA-HQ-OAR-2012-

0522.

2. Eastern Research Group, Inc. “Emissions Data Used in Residual Risk Modeling: 

Phosphoric Acid and Phosphate Fertilizer Production Source Categories.” Docket ID: 

EPA-HQ-OAR-2012-0522. August 2014. 

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