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 e stablish 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

mu st 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 aci d 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 phos phate 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.

1Table 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 Spring s, 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 t o 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 equipm ent 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 facilit y 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 request ed process production rate data concurrent with the duration of the emissions testing (e.g., phosphoric acid production in tons per hour of phosphorous pentoxide).

2The second testing requirement consisted of solid material assays. EPA required sampling o f 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, berylli um 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 i f 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 ext ension.

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 f luorides 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

-- 

-- 

3Company 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 non

confidential 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

- confid ential forms and revised Process Unit Flow Diagrams if there ha d been changes to their operations such that the forms no longer reflect ed the configuration of the process and control equipment for which emissions testing was required in the January 24, 201 4 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 o f 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 Acce ss 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 itera tions 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

4and/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 E lectronic 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 pe r 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 C elsius (°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 emitt ed 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 disp ersion 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: incor rect 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

5incorrect reporting of oxygen conc entrations. 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 cont act 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 Categor ies. 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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