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MEMORANDUM

TO: Tina Ndoh, U.S. EPA/OAQPS/SPPD

– Minerals and Manufacturing Group

FROM: Eastern Research Group, Inc.

DATE: June 9 , 2014

SUBJECT: Comparison of 40 CFR Part 60, subpart V (Standards of Performance for the

Phosphate Fertilizer Industry: Diammonium Phosphate Plants) and 40 CFR Part 63, subpart BB (National Emission Standards for Hazardous Air Pollution from Phosphate Fertilizers Product ion Plants)

This document presents a general comparison between the applicability, definitions, emission
standards, monitoring and operating requirements , and testing and compliance requirements of

NSPS 40 CFR Part 60, subpart V

, and NESHAP 40 CFR Part 63, subpart BB (hereafter referred
to as subpart V and subpart BB, respectively)

. Subpart V was last amended on October 17, 2000
and subpart AA was last amended on April 20, 2006. This document does not encompass
recordkeeping or reporting requ irements: each subpart reference s the respective general
provisions.

1.0 COMPARISON OF NSPS 40 CFR PART 60, SUBPART V TO NESHAP 40 CFR
PART 63, SUBPART BB

The following sections provide a brief comparison of subpart V to subpart BB standards for

diammon ium phosphate (DAP) plants

.

1.1 Applicability

Both subpart V and subpart BB apply to DAP production. However, s ubpart V does not apply to
monoammonium phosphate ( MAP ) prod uction and subpart BB does. Subpart V references
design capacity, while subpart BB applies to major sources. All emission points specified in
subpart V are also specified in subpart BB . Refer to Table 1.1 for details.

Table 1.1. Applicability Provisions in 40 CFR Part 60, Subpart V and 40 CFR Part 63, Subpart BB

40 CFR Part 60, Subpa rt V 40 CFR Part 63, Subpart BB The affected facility is each granular [a] diammonium phosphate plant [ b ] having a design capacity of more than 15 tons of equivalent P 2 O 5 feed per calendar day [ § 60.220(a)] Each new or existing diammonium and/or

monoammonium phosphate process line [a], [ b ] at a major source [§63.620( b )( 1 ) and §63.620(c)]

No R&D exemption Includes R&D exemption [ § 63.620(d)]

No SSM exemption Includes SSM exemption [§63.620(e)]

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[a] Although t

he term “granular” is explicitly used in the applicab ility of subpart V; subpart BB does not do this, i nstead, subpart

BB uses the term “granular” in the defin ition of a “ diammonium and/or monoammonium phosphate process line ” ( see Section

1.2 )

. [b] For both subpart V and subpart BB, requirements apply to: r eactors, granulators, dryers, coolers, screens, and mills.



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. 2. Definitions

The definitions are nearly identical for DAP, although subpart BB includes a note that the
phosphoric acid must be “ derived from or manufactured by reacting phosphate rock and acid ”

. Subpart BB does define DAP and MAP together, but this does not cause an issue for the DAP
definition comparison. Refer to Table 1.2 for details.

Table 1.2. Definitions in 40 CFR Part 60, Subpart V and 40 CFR Part 63, Subpart BB

40 CFR Part 60 , Sub part V 40 CFR Part 63, Subpart BB Granular diammonium phosphate plant : any plant manufacturing granular diammonium phosphate by reacting phosphoric acid with ammonia.
[ § 60.221(a)] Diammonium and/or monoammonium phosphate process line : any process line manufacturing granular diammonium and/or monoammonium phosphate by reacting ammonia with phosphoric acid that has been derived from or manufactured by reacting phosphate rock and acid. [ § 63.621]



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. 3. Total Fluorides Standards

The total fluorides standards are identical between subpart V and existing sources for subpart
BB. New sources do have a slightly lower (i.e., more stringent) total fluoride standard for subpart

BB

. Refer to Table 1 .3 for details.

Table 1.3. Total Fluori des Standards in 40 CFR Part 60, Subpart V and 40 CFR Part 63, Subpart

BB

40 CFR Part 60, Subpart V 40 CFR Part 63, Subpart BB Existing Sources New Sources

Each Granular Diammonium Phosphate

Plant: 30 g/Mg of equivalent P 2 O 5 feed (0.06 lb/ton) [§63.222 (a) ] Each Diammonium and/or Monoammonium Phosphate

Process Line: 30 g/metric ton of equivalent P 2 O 5 feed (0.06 lb/ton) [§63.622(a)] Each Diammonium and/or Monoammonium Phosphate

Process Line : 29 g/metric ton of equivalent

P 2 O 5 f eed (0.058 lb/ton) [§63.623(a)]



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. Monitoring and Operating Requirements

The most substantial difference between subpart V and subpart BB in regards to monitoring and
compliance is related to establishing and adhering to parameter monitoring ranges for wet
scrubbing systems. Each subpart include s requirements to operate a continuous parameter
monitoring system to record pressure drop, but only subpart BB includes a requirement to

monitor an d record the flow rate of scrubbing liquid. Subpart BB also includes specific language

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that facilities must operate within the establish ed parameters, whereas such language is not
included in subpart V

. Refer to Table 1 .4 for details.

Table 1.4. Monitorin g and Operating Requirements in 40 CFR Part 60, Subpart V and 40 CFR Part 63, Subpart BB 40 CFR Part 60, Subpart V 40 CFR Part 63, Subpart BB

P 2 O 5 Feed Accounting

 Install, calibrate, maintain, and operate a monitoring device which can be used to determine the mass flow of phos

- bearing feed to process within an accuracy of ±5% over operating range. [§60.2 2 3 (a) ]

 Maintain a daily record of eq. P 2 O 5 feed according to procedures in subpart. [§60.22 3 (b) ]  Install, calibrate, maintain, and operate a monitoring

device which can be used to determine and permanently record the mass flow of phos

- bearing feed to process within an accuracy of ±5% over operating range. [§63.625(a)]

 Maintain a daily record of eq. P 2 O 5 feed according to procedures in subpart. [§63.625(b)]

Scrubbing Systems Install, calibrate, maintain, and operate a monitoring device which continuously measures and permanently records the total pressure drop across the scrubbing system (accuracy of ± 5% over operating range). [§60. 223(c) ] Install, calibrate, maintain, and operate a monitoring system which continuously measures and permanently

records:

A) the pressure drop across [§63.625(c)(1)] , and

B) the flow rate of scrubbing li quid to [§63.625(c)(2)]

,

Each scrubber in the process scrubbing system in 15

- min block averages (accuracy of ± 5% over operating range). [§63.625(c) (1) and (c) (2)]

Establish allowable ranges, maintain daily averages within the established ranges, for pressure drop and flow rate. [§63.624 and §63.625(f)]



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. Testing and Compliance

The testing and compliance requirements vary in frequency and method between subpart V and
subpart BB. Subpart V only require s an initial performance test, whereas subpart BB requires
initial and annual testing. Subpart BB also allows facilities a broader choice of test methods than
subpart V in determining P 2 

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. Refer to Table 1 .5 for details.

Table 1.5. Testin g and Compliance in 40 CFR Part 60, Subpart V, and 40 CFR Part 63, Subpart BB

40 CFR Part 60, Subpart V 40 CFR Part 63, Subpart BB Frequency of Performance Test

Within 60 days of max production rate, but no later than 180 days after initial startup [§60.8] Existing Sources : On or before applicable compliance

date and then annually

. [§63.626(a)(1)]

New Sources: Within 180 days of compliance date and

### 4 Table 1.5. Testin g and Compliance in 40 CFR Part 60, Subpart V, and 40 CFR Part 63, Subpart BB

40 CFR Part 60, Subpart V 40 CFR Part 63, Subpart BB

then annually

. [§63.626(a)(2)] Sampling and Analysis Methods

Total Fluorides: Method 13A or 13B with 60 minute sampling time and 0.85 dscm (30 dscf) sample volume. [§60. 224 (b)(2)]

P 2 O 5 Content of Feed : The Association of Official Analytical Chemists (AOAC) Method

9. [§60. 224 (b)(3)(ii)] Total Fluorides: Method 13A or 13B with a 1 hour sampling time and 0.85 dscm (30 dscf) sample volume. [§63.626(c)(2)]

P 2 O 5 Content of Feed: Various methods from t he Association of Florida Phosphate Chemists, Seventh

Edition 1991 and the Official Methods of Analysis of

AO AC International, sixteenth Edition, 1995. [§63.626(c) (3)(ii) ]