MEMORANDUM

TO: Tina Ndoh, OAQPS/SPPD

– Minerals and Manufacturing Group

FROM: Eastern Research Group, Inc.

DATE: August 14, 2012

SUBJECT: S ummary of August 14 , 201 2 US EPA Meeting with PCS Phosphate

1.0 Introduction

On August 14 , 2012

, the U.S. Environmental Protection Agency (EPA) met with

representatives of PCS Phosphate

. The purpose of the meeting was to discuss the Risk and

Technology Review (RTR) for the Phosphate Sector. A brief summary of the visit and discussion

is outlined in Section 3 .0 below.

2.0 Attendees

Name Affiliation

John Hewson PCS Phosphate

Ross Smith PCS Phosphate

Barrie Winn PCS Phosphate

Susan Jordan PCS Phosphate

Randy Taylor URS

Keith Barnett US EPA

Tina Ndoh US EPA

Anne Pope US EPA

James Hirtz US EPA

Donna Lazzari ERG

3.0 Summary of Meeting

EPA gave a brief overview of the Risk and Technology Review process and the status of

the review for the phosphate sector. EPA is in the process of concluding the risk assessment. The

ecological risk is still in the process of evaluation. Because the risk and technology review and

any changes to the NESHAPs are on a timeline to be proposed by the end of October, and thereMemorandum

US EPA Meeting with PCS Phosphate

p. 2 of 2

is an extensive review process, the re is limited time for industry to provide additional

information.

EPA gave an overview of the proces s to assess the risks when a persistent bio

accumulative HAP is evaluated in a risk review.

The emissions estimates for mercury from the PCS Aurora facility’s phosphate rock

calciners were presented to PCS Phosphate and it was agreed that the estimates we re correct and

were properly calculated from the stack tests that were submitted by PCS Phosphate

. EPA discussed the necessity to establish a MACT limit for mercury. Also, EPA is

required to conduct a beyond

- the

- floor analysis that considers the cost and availability of

emissions controls for further reducing emissions

. The group discussed the technical reasons why phosphate rock calciners are used at the

Aurora facility and are not used elsewhere in the United States. The organic content of the

phosphat e ore in North Carolina is much higher than in other sources of phosphate ore. Because

of this, an oxidation process is not capable of removing all of the carbon. Carbon affects the

color of the final product and must be removed for some applications. Also , in the purification

system used to produce purified phosphoric acid , the purification solvent will dissolve the carbon

and will contaminate the solvent over time. PCS has studied other options for removing organics

from the North Carolina ore but has not been successful in developing an economic or technical

alternative. PCS commented that phosphate rock calciners are used in both Morocco and Israel.

The group discussed potential methods to control mercury from phosphate rock calciners.

One method being evaluated by EPA at this time is carbon adsorption in a fixed

- bed because

carbon injection along with a fabric filter was considered a less desirable option due to the high

moisture content of the stack gas. PCS suggested that it may be possible to use ca rbon injection

and capture the carbon in the currently installed wet electrostatic precipitators. Also, t he majority

of the mercury is present in the gaseous elemental form, and a carbon that is specific to this form

of mercury must be used.