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2.4- Multiple Emission Source(s) Specific Limitations and Conditions 

STATE-ONLY REQUIREMENT:

2.4.1 15A NCAC 2D .0543 BEST AVAILABLE RETROFIT CONTROL TECHNOLOGY

Based on the review of Permit Application 4400159.06E, and with the consideration of comments received from 

interested parties, the DAQ has determined that Best Available Retrofit Technology (BART) for the following 

emission sources subject to the requirements contained in 15A NCAC 2D .0543 “Best Available Retrofit Technology”

is no additional controls.

Emission Source Description 

G08020 No. 10 new design recovery furnace (121,000 pounds per hour 

maximum black liquor solids firing rate and 382 million Btu per 

hour maximum heat input rate from No. 6 fuel oil) 

G08021 

No. 11 new design recovery furnace (121,000 pounds per hour 

maximum black liquor solids firing rate, 382 million Btu per hour 

maximum heat input rate from No. 6 fuel oil, and 0.25 million Btu 

per hour maximum heat input rate from propane ignition) 

G08022 black liquor oxidation system (228,000 pounds per hour 

maximum feed rate based on calendar day average 

G08023 No. 10 recovery furnace smelt dissolving tank (121,000 pounds 

per hour black liquor solids feed rate) 

G08024 No. 11 recovery furnace smelt dissolving tank (121,000 pounds 

per hour black liquor solids feed rate) 

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SECTION 3 - GENERAL CONDITIONS

This section describes terms and conditions applicable to this Title V facility. All references to the “permit” in this section 

apply only to Part I of the permit. 

A. General Provisions [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)] 

1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A 

NCAC 2D and 2Q. 

2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding and 

enforceable pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or 

criminal penalties. Any unauthorized deviation from the conditions of this permit may constitute grounds for 

revocation and/or enforcement action by the DAQ. 

3. This permit is not a waiver of or approval of any other Department permits that may be required for other 

aspects of the facility which are not addressed in this permit. 

4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal 

or plant life, or property caused by the construction or operation of this permitted facility, or from penalties 

therefore, nor does it allow the Permittee to cause pollution in contravention of state laws or rules, unless 

specifically authorized by an order from the North Carolina Environmental Management Commission. 

5. Except as identified as state-only requirements in this permit, all terms and conditions contained herein shall 

be enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal Clean Air 

Act. 

6. Any stationary source of air pollution shall not be operated, maintained, or modified without the appropriate 

and valid permits issued by the DAQ, unless the source is exempted by rule. The DAQ may issue a permit 

only after it receives reasonable assurance that the installation will not cause air pollution in violation of any 

of the applicable requirements. A permitted installation may only be operated, maintained, constructed, 

expanded, or modified in a manner that is consistent with the terms of this permit. 

B. Permit Availability [15A NCAC 2Q .0507(k) and .0508(i)(9)(B)] 

The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit 

term one complete copy of the application and any information submitted in support of the application package. The 

permit and application shall be made available to an authorized representative of Department of Environment and 

Natural Resources upon request. 

C. Severability Clause [15A NCAC 2Q .0508(i)(2)] 

In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid, the 

provisions in this permit are severable so that all requirements contained in the permit, except those held to be invalid, 

shall remain valid and must be complied with. 

D. Submissions [15A NCAC 2Q .0507(e) and 2Q .0508(i)(16)] 

Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, notifications, 

request for renewal, and any other information required by this permit shall be submitted to the appropriate Regional 

Office. Refer to the Regional Office address on the cover page of this permit. For continuous emissions monitoring 

systems (CEMS) reports, continuous opacity monitoring systems (COMS) reports, quality assurance (QA)/quality 

control (QC) reports, acid rain CEM certification reports, and NOx budget CEM certification reports, one copy shall 

be sent to the appropriate Regional Office and one copy shall be sent to: 

Supervisor, Stationary Source Compliance 

North Carolina Division of Air Quality 

1641 Mail Service Center 

Raleigh, NC 27699-1641 

E. Duty to Comply [15A NCAC 2Q .0508(i)(2)] 

The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this 

permit. Noncompliance with any permit condition except conditions identified as state-only requirements constitutes 

a violation of the Federal Clean Air Act. Noncompliance with any permit condition is grounds for enforcement 

action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal 

application. 

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F. Circumvention - STATE ENFORCEABLE ONLY 

The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in 

air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent 

operation of its associated air pollution control device(s) and appurtenances. 

G. Permit Modifications

1. Administrative Permit Amendments [15A NCAC 2Q .0514] 

The Permittee shall submit an application for an administrative permit amendment in accordance with 15A 

NCAC 2Q .0514. 

2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 2Q .0505] 

The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 2Q.0524 and 

2Q .0505. 

3. Minor Permit Modifications [15A NCAC 2Q .0515] 

The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q 

.0515. 

4. Significant Permit Modifications [15A NCAC 2Q .0516] 

The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC 

2Q .0516. 

5. Reopening for Cause [15A NCAC 2Q .0517] 

The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q .0517. 

H. Changes Not Requiring Permit Modifications

1. Section 502(b)(10) Changes [15A NCAC 2Q .0523(a)] 

a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition. Such 

changes do not include changes that would violate applicable requirements or contravene federally 

enforceable permit terms and conditions that are monitoring (including test methods), recordkeeping, 

reporting, or compliance certification requirements. 

b. The Permittee may make Section 502(b)(10) changes without having the permit revised if: 

i. the changes are not a modification under Title I of the Federal Clean Air Act; 

ii. the changes do not cause the allowable emissions under the permit to be exceeded; 

iii. the Permittee notifies the Director and EPA with written notification at least seven days before the 

change is made; and 

iv. the Permittee shall attach the notice to the relevant permit. 

c. The written notification shall include: 

i. a description of the change; 

ii. the date on which the change will occur; 

iii. any change in emissions; and 

iv. any permit term or condition that is no longer applicable as a result of the change. 

d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised or 

renewed, whichever comes first. 

2. Off Permit Changes [15A NCAC 2Q .0523(b)] 

The Permittee may make changes in the operation or emissions without revising the permit if: 

a. the change affects only insignificant activities and the activities remain insignificant after the change; or 

b. the change is not covered under any applicable requirement. 

3. Emissions Trading [15A NCAC 2Q .0523(c)] 

To the extent that emissions trading is allowed under 15A NCAC 2D, including subsequently adopted maximum 

achievable control technology standards, emissions trading shall be allowed without permit revision pursuant to 

15A NCAC 2Q .0523(c). 

I.A. Reporting Requirements for Excess Emissions and Permit Deviations

[15A NCAC 2D .0535(f) and 2Q .0508(f)(2)] 

“Excess Emissions” - means an emission rate that exceeds any applicable emission limitation or standard allowed by 

any rule in Sections .0500, .0900, .1200, or .1400 of Subchapter 2D; or by a permit condition; or that exceeds an 

emission limit established in a permit issued under 15A NCAC 2Q .0700. (Note: Definitions of excess emissions 

under 2D .1110 and 2D .1111 shall apply where defined by rule.) 

“Deviations” - for the purposes of this condition, any action or condition not in accordance with the terms and 

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conditions of this permit including those attributable to upset conditions as well as excess emissions as defined above 

lasting less than four hours. 

Excess Emissions

1. If a source is required to report excess emissions under NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 

2D .1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of excess emissions, 

reporting shall be performed as prescribed therein. 

2. If the source is not subject to NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D .1110 or .1111), or 

these rules do NOT define "excess emissions," the Permittee shall report excess emissions in accordance with 

15A NCAC 2D .0535 as follows: 

a. Pursuant to 15A NCAC 2D .0535, if excess emissions last for more than four hours resulting from a 

malfunction, a breakdown of process or control equipment, or any other abnormal condition, the owner or 

operator shall: 

i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m. Eastern Time of the 

Division's next business day of becoming aware of the occurrence and provide: 

● name and location of the facility; 

● nature and cause of the malfunction or breakdown; 

● time when the malfunction or breakdown is first observed; 

● expected duration; and 

● estimated rate of emissions; 

ii. notify the Regional Supervisor or Director immediately when corrective measures have been 

accomplished; and 

iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A 

NCAC 2D .0535(f)(3). 

Permit Deviations

3. Pursuant to 15A NCAC 2Q .0508(f)(2), the Permittee shall report deviations from permit requirements (terms 

and conditions) as follows: 

a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered 

under 15A NCAC 2D .0535 quarterly. A written report to the Regional Supervisor shall include the 

probable cause of such deviation and any corrective actions or preventative actions taken. The responsible 

official shall certify all deviations from permit requirements. 

I.B. Other Requirements under 15A NCAC 2D .0535

The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D .0535, including 15A 

NCAC 2D .0535(c) as follows: 

1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of the 

appropriate rule unless the owner or operator of the sources demonstrates to the Director, that the excess 

emissions are a result of a malfunction. The Director shall consider, along with any other pertinent information, 

the criteria contained in 15A NCAC 2D .0535(c)(1) through (7). 

2. 15A NCAC 2D .0535(g). Excess emissions during start-up and shut-down shall be considered a violation of the 

appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable. 

J. Emergency Provisions [40 CFR 70.6(g)] 

The Permittee shall be subject to the following provisions with respect to emergencies: 

1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control 

of the facility, including acts of God, which situation requires immediate corrective action to restore normal 

operation, and that causes the facility to exceed a technology-based emission limitation under the permit, due to 

unavoidable increases in emissions attributable to the emergency. An emergency shall not include 

noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless 

or improper operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technologybased emission limitations if the conditions specified in 3. below are met. 

3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous 

operating logs or other relevant evidence that include information as follows: 

a. an emergency occurred and the Permittee can identify the cause(s) of the emergency; 

b. the permitted facility was at the time being properly operated; 

c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of 

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emissions that exceeded the standards or other requirements in the permit; and 

d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when 

emission limitations were exceeded due to the emergency. This notice must contain a description of the 

emergency, steps taken to mitigate emissions, and corrective actions taken. 

4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the 

burden of proof. 

5. This provision is in addition to any emergency or upset provision contained in any applicable requirement 

specified elsewhere herein. 

K. Permit Renewal [15A NCAC 2Q .0508(e) and 2Q .0513(b)] 

This permit is issued for a fixed term of five years for facilities subject to Title IV requirements and for a term not to 

exceed five years in the case of all other facilities. This permit shall expire at the end of its term. Permit expiration 

terminates the facility's right to operate unless a complete renewal application is submitted at least nine months before 

the date of permit expiration. If the Permittee or applicant has complied with 15A NCAC 2Q .0512(b)(1), this permit 

shall not expire until the renewal permit has been issued or denied. All terms and conditions of this permit shall 

remain in effect until the renewal permit has been issued or denied. 

L. Need to Halt or Reduce Activity Not a Defense [15A NCAC 2Q .0508(i)(4)] 

It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce 

the permitted activity in order to maintain compliance with the conditions of this permit. 

M. Duty to Provide Information (submittal of information) [15A NCAC 2Q .0508(i)(9)] 

1. The Permittee shall furnish to the DAQ, in a timely manner, any reasonable information that the Director may 

request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the 

permit or to determine compliance with the permit. 

2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies are 

requested by the Director. For information claimed to be confidential, the Permittee may furnish such records 

directly to the EPA upon request along with a claim of confidentiality. 

N. Duty to Supplement [15A NCAC 2Q .0507(f)] 

The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in 

the permit application, shall promptly submit such supplementary facts or corrected information to the DAQ. The 

Permittee shall also provide additional information as necessary to address any requirement that becomes applicable 

to the facility after the date a complete permit application was submitted but prior to the release of the draft permit. 

O. Retention of Records [15A NCAC 2Q .0508(f) and 2Q .0508 (l)] 

The Permittee shall retain records of all required monitoring data and supporting information for a period of at least 

five years from the date of the monitoring sample, measurement, report, or application. Supporting information 

includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring 

information, and copies of all reports required by the permit. These records shall be maintained in a form suitable 

and readily available for expeditious inspection and review. Any records required by the conditions of this permit 

shall be kept on site and made available to DAQ personnel for inspection upon request. 

P. Compliance Certification [15A NCAC 2Q .0508(n)] 

 The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61 

Forsyth Street, Atlanta, GA 30303)postmarked on or before March 1 a compliance certification (for the preceding 

calendar year) by a responsible official with all federally-enforceable terms and conditions in the permit, including 

emissions limitations, standards, or work practices. It shall be the responsibility of the current owner to submit a 

compliance certification for the entire year regardless of who owned the facility during the year. The compliance 

certification 

shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the Federal 

Clean Air Act. The compliance certification shall specify: 

1. the identification of each term or condition of the permit that is the basis of the certification; 

2. the compliance status (with the terms and conditions of the permit for the period covered by the certification); 

3. whether compliance was continuous or intermittent; and 

4. the method(s) used for determining the compliance status of the source during the certification period. 

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Q. Certification by Responsible Official [15A NCAC 2Q .0520] 

A responsible official shall certify the truth, accuracy, and completeness of any application form, report, or 

compliance certification required by this permit. All certifications shall state that based on information and belief 

formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. 

R. Permit Shield for Applicable Requirements [15A NCAC 2Q .0512] 

1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable 

requirements, where such applicable requirements are included and specifically identified in the permit as of the 

date of permit issuance. 

2. A permit shield shall not alter or affect: 

a. the power of the Commission, Secretary of the Department, or Governor under NCGS 143-

215.3(a)(12), or EPA under Section 303 of the Federal Clean Air Act; 

b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the 

effective date of the permit or at the time of permit issuance; 

c. the applicable requirements under Title IV; or 

d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain 

information to determine compliance of the facility with its permit. 

3. A permit shield does not apply to any change made at a facility that does not require a permit or permit revision 

made under 15A NCAC 2Q .0523. 

4. A permit shield does not extend to minor permit modifications made under 15A NCAC 2Q .0515. 

S. Termination, Modification, and Revocation of the Permit [15A NCAC 2Q .0519] 

The Director may terminate, modify, or revoke and reissue this permit if: 

1. the information contained in the application or presented in support thereof is determined to be incorrect; 

2. the conditions under which the permit or permit renewal was granted have changed; 

3. violations of conditions contained in the permit have occurred; 

4. the EPA requests that the permit be revoked under 40 CFR 70.7(g) or 70.8(d); or 

5. the Director finds that termination, modification, or revocation and reissuance of the permit is necessary to carry 

out the purpose of NCGS Chapter 143, Article 21B. 

T. Insignificant Activities [15A NCAC 2Q .0503] 

Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted 

from any applicable requirement or that the owner or operator of the source is exempted from demonstrating 

compliance with any applicable requirement. The Permittee shall have available at the facility at all times and made 

available to an authorized representative upon request, documentation, including calculations, if necessary, to 

demonstrate that an emission source or activity is insignificant. 

U. Property Rights [15A NCAC 2Q .0508(i)(8)] 

This permit does not convey any property rights in either real or personal property or any exclusive privileges. 

V. Inspection and Entry [15A NCAC 2Q .0508(l) and NCGS 143-215.3(a)(2)] 

1. Upon presentation of credentials and other documents as may be required by law, the Permittee shall allow the 

DAQ, or an authorized representative, to perform the following: 

a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is 

conducted, or where records are kept under the conditions of the permit; 

b. have access to and copy, at reasonable times, any records that are required to be kept under the 

conditions of the permit; 

c. inspect at reasonable times and using reasonable safety practices any source, equipment (including 

monitoring and air pollution control equipment), practices, or operations regulated or required under the 

permit; and 

d. sample or monitor substances or parameters, using reasonable safety practices, for the purpose of 

assuring compliance with the permit or applicable requirements at reasonable times. 

Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under 

Section 114 or other provisions of the Federal Clean Air Act. 

2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for 

purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or 

interfere with any such authorized representative while in the process of carrying out his official duties. Refusal 

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of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 

W. Annual Fee Payment [15A NCAC 2Q .0508(i)(10)] 

1. The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200. 

2. Payment of fees may be by check or money order made payable to the N.C. Department of Environment and 

Natural Resources. Annual permit fee payments shall refer to the permit number. 

3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate action to 

terminate the permit under 15A NCAC 2Q .0519. 

X. Annual Emission Inventory Requirements [15A NCAC 2Q .0207] 

The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 2Q 

.0207(a) from each emission source within the facility during the previous calendar year. The report shall be in or on 

such form as may be established by the Director. The accuracy of the report shall be certified by a responsible 

official of the facility. 

Y. Confidential Information [15A NCAC 2Q .0107 and 2Q. 0508(i)(9)] 

Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q .0107, the 

Permittee may also submit a copy of all such information and claim directly to the EPA upon request. All requests 

for confidentiality must be in accordance with 15A NCAC 2Q .0107. 

Z. Construction and Operation Permits [15A NCAC 2Q .0100 and .0300] 

A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or 

emission source which is not exempted from having a permit prior to the beginning of construction or modification, 

in accordance with all applicable provisions of 15A NCAC 2Q .0100 and .0300. 

AA. Standard Application Form and Required Information [15A NCAC 2Q .0505 and .0507] 

The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 

2Q .0505 and .0507. 

BB. Financial Responsibility and Compliance History [15A NCAC 2Q .0507(d)(3)] 

The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial 

compliance history. 

CC. Refrigerant Requirements (Stratospheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)] 

1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which use Class 

I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as 

refrigerants in 40 CFR Part 82 Subpart A Appendices A and B, the Permittee shall service, repair, and maintain 

such equipment according to the work practices, personnel certification requirements, and certified recycling and 

recovery equipment specified in 40 CFR Part 82 Subpart F. 

2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the environment 

during the repair, servicing, maintenance, or disposal of any such device except as provided in 40 CFR Part 82 

Subpart F. 

3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR  82.166. Reports shall 

be submitted to the EPA or its designee as required. 

DD. Prevention of Accidental Releases - Section 112(r) [15A NCAC 2Q .0508(h)] 

If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r) of 

the Clean Air Act, then the Permittee is required to register this plan in accordance with 40 CFR Part 68. 

EE. Prevention of Accidental Releases General Duty Clause - Section 112(r)(1) - 

FEDERALLY-ENFORCEABLE ONLY 

Although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any 

amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent 

the accidental release of such substance and to minimize the consequences of any release. 

FF. Title IV Allowances [15A NCAC 2Q .0508(i)(1)] 

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This permit does not limit the number of Title IV allowances held by the Permittee, but the Permittee may not use 

allowances as a defense to noncompliance with any other applicable requirement. The Permittee’s emissions may not 

exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act. 

GG. Air Pollution Emergency Episode [15A NCAC 2D .0300] 

Should the Director of the DAQ declare an Air Pollution Emergency Episode, the Permittee will be required to 

operate in accordance with the Permittee’s previously approved Emission Reduction Plan or, in the absence of an 

approved plan, with the appropriate requirements specified in 15A NCAC 2D .0300. 

HH. Registration of Air Pollution Sources [15A NCAC 2D .0200] 

The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to 

register a source of air pollution, this registration and required information will be in accordance with 15A NCAC 2D 

.0202(b). 

II. Ambient Air Quality Standards [15A NCAC 2D .0501(e)] 

In addition to any control or manner of operation necessary to meet emission standards specified in this permit, any 

source of air pollution shall be operated with such control or in such manner that the source shall not cause the 

ambient air quality standards in 15A NCAC 2D .0400 to be exceeded at any point beyond the premises on which the 

source is located. When controls more stringent than named in the applicable emission standards in this permit are 

required to prevent violation of the ambient air quality standards or are required to create an offset, the permit shall 

contain a condition requiring these controls. 

JJ. General Emissions Testing and Reporting Requirements [15A NCAC 2Q .0508(i)(16)] 

If emissions testing is required by this permit or the DAQ or if the Permittee submits emissions testing to the DAQ in 

support of a permit application, the Permittee shall perform such testing in accordance with the appropriate EPA 

reference method(s) as approved by the DAQ and follow the procedures outlined below. The Permittee must request 

in writing and receive approval from the DAQ for an alternate test method or procedure. 

1. The Permittee shall submit a completed Protocol Submittal Form to the DAQ Regional Supervisor at least 45 

days prior to the scheduled test date. A copy of the Protocol Submittal Form may be obtained from the Regional 

Supervisor. 

2. The Permittee shall notify the Regional Supervisor of the specific test dates at least 15 days prior to testing in 

order to afford the DAQ the opportunity to have an observer on-site during the sampling program. 

3. During all sampling periods, the Permittee shall operate the emission source(s) under maximum normal 

operating conditions or alternative operating conditions as deemed appropriate by the Regional Supervisor or his 

delegate. 

4. The Permittee shall submit two copies of the test report to the DAQ. The test report shall contain at a minimum 

the following information: 

a. a certification of the test results by sampling team leader and facility representative; 

b. a summary of emissions results and text detailing the objectives of the testing program, the applicable 

state and federal regulations, and conclusions about the testing and compliance status of the emission 

source(s); 

c. a detailed description of the tested emission source(s) and sampling location(s) process flow diagrams, 

engineering drawings, and sampling location schematics should be included as necessary; 

d. all field, analytical, and calibration data necessary to verify that the testing was performed as specified 

in the applicable test methods; 

e. example calculations for at least one test run using equations in the applicable test methods and all test 

results including intermediate parameter calculations; and 

f. documentation of facility operating conditions during all testing periods and an explanation relating 

these operating conditions to maximum normal operation. If necessary, provide historical process data to 

verify maximum normal operation. 

5. The testing requirement(s) shall be considered satisfied only upon written approval of the test results by the 

DAQ. 

6. The DAQ will review emission test results with respect exclusively to the specified testing objectives as 

proposed by the Permittee and approved by the DAQ. The use of the test results beyond the stated objectives 

remains subject to the approval of the DAQ. 

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KK. Reopening for Cause [15A NCAC 2Q .0517] 

1. A permit shall be reopened and revised under the following circumstances: 

a. additional applicable requirements become applicable to a facility with remaining permit term of three 

or more years; 

b. additional requirements (including excess emission requirements) become applicable to a source 

covered by Title IV; 

c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements were 

made in establishing the emissions standards or other terms or conditions of the permit; or 

d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with 

the applicable requirements. 

2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable 

requirement is promulgated. No reopening is required if the effective date of the requirement is after the 

expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 2Q .0513(c). 

3. Except for the state-enforceable only portion of the permit, the procedures set out in 15A NCAC 2Q .0507, 

.0521, or .0522 shall be followed to reissue the permit. If the State-enforceable only portion of the permit is 

reopened, the procedures in 15A NCAC 2Q .0300 shall be followed. The proceedings shall affect only those 

parts of the permit for which cause to reopen exists. 

4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened, 

except in cases of imminent threat to public health or safety the notification period may be less than 60 days. 

5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from the EPA 

that a permit needs to be terminated, modified, or revoked and reissued, the Director shall send to the EPA a 

proposed determination of termination, modification, or revocation and reissuance, as appropriate. 

LL. Reporting Requirements for Non-Operating Equipment [15A NCAC 2Q .0508(i)(16)] 

 The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken 

from and placed into operation. During operation the monitoring recordkeeping and reporting requirements as 

prescribed by the permit shall be implemented within the monitoring period. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 468 

 December 17, 2007
Permit 08961T?? DRAFT

Page 90 

ATTACHMENT 

List of Acronyms 

AOS Alternate Operating Scenario

BACT Best Available Control Technology 

Btu British thermal unit

CEM Continuous Emission Monitor

CFR Code of Federal Regulations 

CAA Clean Air Act

DAQ Division of Air Quality

DENR Department of Environment and Natural Resources 

EMC Environmental Management Commission

EPA Environmental Protection Agency

FR Federal Register

GACT Generally Available Control Technology

HAP Hazardous Air Pollutant

MACT Maximum Achievable Control Technology

NCAC North Carolina Administrative Code

NCGS North Carolina General Statutes 

NESHAPS National Emission Standards for Hazardous Air Pollutants

NOX Nitrogen Oxides

NSPS New Source Performance Standard

OAH Office of Administrative Hearings 

PM Particulate Matter 

PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less 

POS Primary Operating Scenario 

PSD Prevention of Significant Deterioration

SIC Standard Industrial Classification

SIP State Implementation Plan

SO2 Sulfur Dioxide

tpy Tons Per Year VOC Volatile Organic Compound

VOC Volatile Organic Compound

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 469 

 December 17, 2007
NORTH CAROLINA 

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 

DIVISION OF AIR QUALITY 

BEST AVAILIBLE RETROFIT TECHNOLOGY 

PRELIMINARY DETERMINATION 

FOR 

PCS Phosphate 

AURORA, BEAUFORT COUNTY 

NORTH CAROLINA 

THIS REVIEW WAS PERFORMED BY THE 

AIR PERMITS SECTION 

IN ACCORDANCE WITH 15A NCAC 2D .0543: 

BEST AVAILIBLE RETROFIT TECHNOLOGY 

October 9, 2007 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 470 

 December 17, 2007
PCS Phosphate BART determination 

TABLE OF CONTENTS

Section Page

1.0 Introduction .................................................................................................................... 1 

1.1 BART Determination ......................................................................................... 1 

2.0 BART Affected Units and Exemption Modeling Analysis............................................. 3 

2.1 BART Affected Units ......................................................................................... 3 

2.2 BART Exemption Modeling Analysis ............................................................... 5 

3.0 Regulatory Analysis ........................................................................................................ 7 

 3.1 Federal BART Applicability and Required Analyses................................7 

 3.2 North Carolina BART Applicability....................................................8 

 3.3 Required Air Quality Permits............................................................8 

4.0 Best Available Retrofit Technology Analysis................................................................. 9 

4.1 Summary ............................................................................................................. 9 

 4.2 BART Analysis Overview............................................. ..................................... 12 

 4.3 BART Analysis for Sulfuric Acid (SA) Plants Nos. 3 and 4 .............................. 16 

 4.3.1 Sulfur Dioxide Emissions........................................................................ 16 

 4.3.2 PM10 Emissions ..................................................................18 

4.3.3 Nitrogen Oxides Emissions ....................................................21 

 4.4 BART Analysis for Lime Storage Silo Baghouse............................................... 21 

 4.5 BART Analysis for Calciners ............................................................................. 21 

 4.5.1 PM10 Emissions ....................................................................................... 21 

 4.5.2 Sulfur Dioxide Emissions........................................................................ 21 

 4.5.3 Nitrogen Oxides Emissions ....................................................22 

 4.6 BART Analysis for Rock Dryer.......................................................................... 23 

 4.7 BART Analysis for Calciner Area Rock Handling Sources ............................... 24 

 4.8 BART Analysis for Diammonium Phosphate (DAP) Plants............................... 24 

 4.8.1 PM10 Emissions ....................................................................................... 25 

 4.8.2 Nitrogen Oxides Emissions..................................................................... 25 

 4.3.3 Sulfur Dioxide Emissions ............................................... ...... 26 

 4.9 BART Analysis for Superphosphoric Acid (SPA) Plants................................... 25 

 4.10 BART Analysis for Phosphoric Acid (PA) Plants .............................................. 26 

 4.10.1 Sulfur Dioxide Emissions ...................................................... 26 

 4.11 BART Analysis for Shipping Area Rock Handling Plants ................................. 27 

 

Response to EPA Comments on Bart Permit Application ......................... ........... APPENDIX A 

Public Notice for BART Title V Air Permit Modification .......................... ........... APPENDIX B 

Draft Air Permit Language ........................................................................... ........... APPENDIX C 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 471 

 December 17, 2007
PCS Phosphate BART determination 

1

SECTION 1.0 

INTRODUCTION 

PCS Phosphate, Inc. is the world’s largest fertilizer manufacturer. The Aurora facility is the 

largest integrated phosphate mine and chemical facility in the world. The facility operates a 

large number of processes for the production of fertilizer from the raw materials (e.g. phosphate 

rock from the mine) to intermediate products (e.g. sulfuric acid) to the finished products (e.g. 

diammonium phosphate). In addition, the facility manufactures and sells phosphoric acid and 

fluosilicic acid. PCS employs approximately 1,050 persons. The current operation, that is the 

active mine and manufacturing plant, occupy about 20,000 acres out of a total plant site of 

50,000 acres. The facility is a Title V facility and operates under air permit 04176T34. PCS 

Phosphate submitted a BART evaluation Permit Application to the North Carolina Department 

of Environment and Environmental Resources Division of Air Quality Division of Air 

Quality (NCDAQ) on November 28, 2006. 

The requirements for Best Available Retrofit Technology (BART) are set forth in 15A NCAC 

2D .0543 “Best Available Retrofit Technology.” This rule, currently State-Only enforceable, 

implements the BART provisions of 40 CFR 51.308(e) for emission sources that may cause or 

contribute to any visibility impairment in a mandatory Class I federal areas as determined using 

40 CFR 51, Subpart P. “BART-eligible” sources are those sources built between 1962 and 1977 

that have the potential to emit more than 250 tons per year of one or more visibility-impairing 

compounds including sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and 

volatile organic compounds (VOCs), and that fall within 26 industrial source categories 

(including Phosphate Rock Processing Plants). A review of the emission sources found that 

there were thirty one emission sources that were BART eligible. 

 

Under the authority of 15A NCAC 2D .0543(c), a BART-eligible source can be exempted from 

the BART requirements based on dispersion modeling demonstrating that the source cannot 

reasonably be anticipated to cause or contribute to visibility impairment in a Class I area. The 

emissions from these sources were modeled using CALPUFF to determine if the emissions from 

the BART eligible emission sources contributed to perceptible visibility impairment to Class I 

areas. The results of this modeling indicated that the visibility impact of the BART eligible 

emission sources on the Swanquarter Class I area was 0.976 deciview (dv), which is greater than 

the threshold visibility value of 0.50 dv. This indicated that these emission sources contribute to 

visibility impairment to the Swanquarter Class I area. Since these emission sources could 

not be otherwise exempted from BART, a BART analysis was conducted in accordance 

with the requirements set forth in 15A NCAC 2D .0543. 

1.1 BART Determination

The NCDAQ has made the determination that BART for the affected emission sources is no 

additional controls. DAQ also notes that even if additional controls were required, maximum 

reduction in visibility under all emission control scenarios, the resulting visibility impact on the 

Swanquarter Class I area would be reduced from 0.976 dv to 0.860 dv (0.116 dv reduction). 

NCDAQ proposes to issue an air permit with a specific permit condition that notes that the 

permittee has satisfied all of the requirements for BART and that no additional controls are 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 472 

 December 17, 2007
PCS Phosphate BART determination 

2

necessary. The remainder of this report contains a review by NCDAQ of the demonstration and 

analyses presented by PCS Phosphate. The response to the EPA comments may be found in 

Appendix A. 

BART will be implemented through a modification to PCS Phosphate’s Title V air permit. The 

Title V air permit application implementing BART must undergo adequate public participation. 

The NCDAQ solicits and encourages participation by the general public, industry, and other 

affected persons. Specific public notice requirements and a 30-day public comment period are 

required before the NCDAQ can take final action on this application. Appendix B contains a 

copy of the public notice, and the draft air permit language implementing the BART 

requirements may be found in Appendix C. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 473 

 December 17, 2007
PCS Phosphate BART determination 

3

SECTION 2.0 

2.1 BART Affected Units 

 “BART-eligible” sources are those sources built between 1962 and 1977 that have the potential 

to emit more than 250 tons per year of one or more visibility-impairing compounds including 

sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and volatile organic 

compounds (VOCs), and that fall within 26 industrial source categories (including Phosphate 

Rock Processing). The PCS Phosphate operation contains thirty-one BART-eligible emission 

units. Listed below is a brief description of all the BART-eligible emission units that emit SO2, 

NOx, H2SO4 mist, or PM10: 

• Sulfuric Acid Plant Nos. 3 and 4 (101, 102): These double absorption plants 

produce sulfuric acid that is used in other production areas of the facility. 

Emissions of SO2 are controlled by the double absorption process and emissions 

of sulfuric acid mist are controlled by mist eliminators. These units are in 

compliance with BACT limits and NSPS Subpart H emission limits for SO2 and 

H2SO4 mist. 

• Lime Storage Silo Baghouse No. 4 (121): This lime storage silo is located in the 

water treatment area and is controlled by a baghouse. 

• Calciner No. 1 (201): This calciner is located in the mill area and processes 

phosphate rock. It is a vertical fluidized bed rock calciner and is permitted to fire 

coal, coke, “off-spec” used oils, used oil sludge, used glycols, and residual oil. 

The nominal throughput is 105.1 tons of feed per hour. The unit is controlled by 

two duplex cyclones exhausting to a fixed throat venturi type wet scrubber 

exhausting to a wet electrostatic precipitator. This unit is in compliance with 

MACT Subpart AA PM limits. 

• Calciner No. 2 (202): This calciner is located in the mill area and processes 

phosphate rock. It is a vertical fluidized bed rock calciner and is permitted to fire 

coal, coke, “off-spec” used oils, used oil sludge, used glycols, and residual oil. 

The nominal throughput is 105.1 tons of feed per hour. The unit is controlled by 

two duplex cyclones exhausting to a fixed throat venturi type wet scrubber 

exhausting to a wet electrostatic precipitator. This unit is in compliance with 

MACT Subpart AA PM limits. 

• Calciner No. 3 (203): This calciner is located in the mill area and processes 

phosphate rock. It is a vertical fluidized bed rock calciner and is permitted to fire 

coal, coke, and residual oil. The nominal throughput is 105.1 tons of feed per 

hour. The unit is controlled by two duplex cyclones exhausting to a fixed throat 

venturi type wet scrubber exhausting to a wet electrostatic precipitator. This unit 

is in compliance with MACT Subpart AA PM limits. 

• Calciner No. 4 (204): This calciner is located in the mill area and processes 

phosphate rock. It is a vertical fluidized bed rock calciner and is permitted to fire 

coal, coke, and residual oil. The nominal throughput is 105.1 tons of feed per 

hour. The unit is controlled by two duplex cyclones exhausting to a fixed throat 

venturi type wet scrubber exhausting to a wet electrostatic precipitator. This unit 

is in compliance with MACT Subpart AA PM limits. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 474 

 December 17, 2007
PCS Phosphate BART determination 

4

• Calciner No. 5 (205): This calciner is located in the mill area and processes 

phosphate rock. It is a vertical fluidized bed rock calciner and is permitted to fire 

coal, coke, and residual oil. The nominal throughput is 105.1 tons of feed per 

hour. The unit is controlled by two duplex cyclones exhausting to a fixed throat 

venturi type wet scrubber exhausting to a wet electrostatic precipitator. This unit 

is in compliance with MACT Subpart AA PM limits. 

• Calciner No. 6 (206): This calciner is located in the mill area and processes 

phosphate rock. It is a vertical fluidized bed rock calciner and is permitted to fire 

coal, coke, and residual oil. The nominal throughput is 105.1 tons of feed per 

hour. The unit is controlled by two duplex cyclones exhausting to a fixed throat 

venturi type wet scrubber exhausting to a wet electrostatic precipitator. This unit 

is in compliance with MACT Subpart AA PM limits. 

• Rock Dryer (210): The rock dryer fires fuel oil to dry wet phosphate concentrate 

in a fluidized bed system. It is controlled by a duplex cyclone followed by a 

venturi scrubber. This unit is in compliance with MACT Subpart AA PM limits. 

• Calcine Conveyor Transfer Station (CTS) (220): This system transfers raw 

material from conveyor belt to conveyor belt and has enclosed transfer points to 

minimize fugitive emissions. 

• Calcine CTS baghouse (221): This system transfers raw material from conveyor 

belt to conveyor belt and has enclosed transfer points. The baghouse controls 

fugitive dust emissions for transfers from belt 55 to 70-1. 

• Storage Silo Baghouses (222): Calcined and dried rock is transferred between 

conveyor belts and storage silos and controlled with a baghouse on top of the 

storage silos. 

• Calcined/Dryed Rock Transfer (223): This system transfers raw material from 

conveyor belt to conveyor belt and has enclosed transfer points to minimize 

fugitive emissions. 

• Fugitives from Calciner Plant Area (291): This emission point represents 

fugitive emissions from rock handling in the calciner area. 

• Diammonium Phosphate (DAP) No. 1 Plant (301): Ammoniated phosphates 

are produced in the DAP plants by reacting anhydrous ammonia with phosphoric 

acid. This plant consists of a reactor, granulator, oil-fired dryer, material sizing 

and handling equipment, and cooler. The residual oil dryer has a nominal 

maximum input of 618 tons of fresh P2O5 and 275 tons of recycle per hour. These 

units are controlled by 4 Buell cyclones followed by a cyclonic/venturi type wet 

scrubber and a cyclonic-type tail gas scrubber. Note that PCS has shut down this 

plant as required by its Title V permit; this plant is not included in this analysis. 

• DAP No. 3 Plant (302): Ammoniated phosphates are produced in the DAP 

plants by reacting anhydrous ammonia with phosphoric acid. This plant consists 

of first and second stage reactors, granulator, residual oil-fired dryer, material 

sizing and handling equipment, and a cooler. The dryer is controlled by a cyclone 

scrubber and a wet cyclonic scrubber. The sizing and handling equipment is 

controlled by a dual cyclone and a cyclonic wet scrubber installed in series. The 

cooler and other material handling points are controlled by a dual cyclone and a 

wet cyclonic scrubber. The reactors and granulator are controlled by a saturation 

chamber and a wet cyclonic scrubber installed in series. The scrubbers are vented 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 475 

 December 17, 2007
PCS Phosphate BART determination 

5

to a cyclonic tail gas scrubber. This source is in compliance with 40 CFR 63, 

Subpart BB and BACT fluoride limits. 

• Superphosphoric Acid (SPA) No. 1, No. 2, No. 3, and No. 4 (330, 331, and 

332): Phosphoric acid is concentrated through one or two stage vacuum 

evaporation in the superphosphoric acid plants. SPA Plant Nos. 1 and 2 are each 

controlled by an eductor venturi type wet scrubber. The SPA plants No. 3 and No. 

4 share one eductor venturi type scrubber. These sources are in compliance with 

40 CFR 63, Subpart AA fluorides limits, Plants 3 and 4 are in compliance with 

BACT limits for SO2, and Plant 4 is in compliance with NSPS Subpart U 

fluorides limits. 

• Phosphoric Acid No. 1, No. 2, No. 3, and No. 4 Cross Flow Scrubber Stacks 

(401, 404, 406, and 409): The Phosphoric Acid Plants produce green and amber 

phosphoric acid from the reaction of calcined or uncalcined phosphate rock and 

sulfuric acid. The phosphoric acid production is controlled by crossflow 

scrubbers. The phosphoric acid plants are in compliance with 40 CFR 63, 

Subpart AA, NSPS Subpart T, and BACT limits for fluoride. 

• CTS- Grinder Loadout, Rock Loadout Station, CTS- Phosphate Rock 

Transfer Station Chute-Barge Rock Loadout, and Chute- Train Rock 

Loadout (650, 651, 652, 653, 655, and 656): These emission units represent 

rock transfer points in the shipping area and are enclosed to minimize fugitive 

emissions. 

• Rock Tower Loadout Facility (654): Dried and calcined rock loadout enclosed 

transfer station where rock is transferred from conveyor belt 30 to the loadout 

chute located beneath a baghouse. 

There are also several tanks in the shipping area tank farm (Emission Point ID 616) that are 

BART eligible units but do not emit SO2, NOx, H2SO4 mist, or PM10. Many of the BART 

eligible units above are required to meet MACT, NSPS, and/or BACT emission limits and 

therefore are already well controlled. 

2.2 BART exemption modeling analysis 

The first step of the BART process was to determine if any of the affected BART-eligible 

sources could be exempted based on their contribution to visibility impacts on the 

SwanquarterClass I area. According to 40 CFR Part 51, Appendix Y, a BART-eligible source is 

considered to “contribute” to visibility impairment in a Class I area if the modeled 98th percentile 

change in dv is equal to or greater than the “contribution threshold.” The contribution threshold 

is understood to be 0.5 deciview and a threshold of 1.0 deciview is understood to cause visibility 

impairment. Any BART-eligible source determined to cause or contribute to visibility impairment 

in any Class I area is subject to a BART evaluation. 

PCS Phosphate submitted a modeling protocol to NCDAQ on April 27, 2006. The objective of 

the modeling protocol was to obtain approval from NCDAQ on the modeling procedures that 

were used to conduct the BART exemption modeling for the PCS Phosphate facility. Upon 

review, DAQ requested that the protocol be revised since it deviated from the VISTAS protocol. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 476 

 December 17, 2007
PCS Phosphate BART determination 

6

The revised protocol was submitted to DAQ on October 2, 2006. The final protocol 

incorporated guidance developed by VISTAS for conducting a BART modeling analysis. The 

results of the exemption modeling indicated that visibility impact from the emissions from the 

BART eligible emission sources on the affected Class I was 0.976 dv. Since this value exceeds 

the 0.5 dv contribution threshold for the Swanquarter Class I area, a BART evaluation must be 

conducted for each of the thirty one BART-eligible emission sources. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 477 

 December 17, 2007
PCS Phosphate BART determination 

7

SECTION 3.0 

REGULATORY ANALYSIS 

 

3.1 Federal BART Applicability and Required Analysis 

The Clean Air Act established goals for visibility in many national parks and wilderness areas. 

Through the 1977 amendments to the Clean Air Act, Congress set a national goal for visibility as 

“the prevention of any future, and the remedying of any existing, impairment of visibility in 

mandatory Class I Federal areas which impairment results from manmade air pollution.” The 

Amendments required EPA to issue regulations to assure “reasonable progress” toward meeting 

the national goal. The Class I Areas affected by this facility is the Swanquarter National 

Wildlife Refuge. 

One of the principal elements of the visibility protection provisions of the Clean Air Act 

addresses installation of best available retrofit technology (BART) for certain existing sources. 

“BART-eligible” sources are those sources built between 1962 and 1977 that have the potential 

to emit more than 250 tons per year of one or more visibility-impairing compounds including 

sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and volatile organic 

compounds (VOCs), and that fall within 26 industrial source categories (including Phosphate 

rock processing plants). 

The BART requirements are found in 40 CFR 51.308(e) “Best Available Retrofit Technology 

(BART) requirements for regional haze visibility impairment.” In addition, the final BART 

implementation and guidance (40 CFR Part 51, Appendix Y) were published on July 6, 2005 and 

allow for a BART evaluation for any BART-eligible source that “emits any air pollutant which 

may reasonably be anticipated to cause or contribute to any impairment of visibility” in any 

mandatory Class I federal area. The guidance (40 CFR Part 51, Appendix Y) must only be 

followed by states for large fossil fuel fired electric steam generators, but is otherwise optional 

for other BART units. 

According to 40 CFR Part 51, Appendix Y, a BART-eligible source is considered to “contribute” 

to visibility impairment in a Class I area if the modeled 98th percentile change in dv is equal to or 

greater than the “contribution threshold.” The contribution threshold is understood to be 0.5 

deciview and a threshold of 1.0 deciview is understood to cause visibility impairment. Any 

BART-eligible source determined to cause or contribute to visibility impairment in any Class I 

area is subject to a BART evaluation. 

Based on the results of the BART evaluations, States will develop Regional Haze State 

Implementation Plans (SIPs). States must submit plans to implement the Regional Haze Rule for 

EPA review and approval by January 2008. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 478 

 December 17, 2007
PCS Phosphate BART determination 

8

3.2 North Carolina BART Applicability 

The BART requirements are implemented through 15A NCAC 2D .0543 “Best Available 

Retrofit Technology.” This rule, currently State-Only enforceable, implements the BART 

provisions of 40 CFR 51.308(3) for emission sources that may cause or contribute to any 

visibility impairment in a mandatory Class I federal areas as determined using 40 CFR 51, 

Subpart P. “BART-eligible” sources are those sources built between 1962 and 1977 that have 

the potential to emit more than 250 tons per year of one or more visibility-impairing compounds 

including sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and volatile 

organic compounds (VOCs), and that fall within 26 industrial source categories (including 

Phosphate rock processing plants). A review of the emission sources found that there were thirty 

one emission sources that were BART eligible. 

Under the authority of 15A NCAC 2D .0543(c), a BART-eligible source may be exempted from 

the BART requirements based on dispersion modeling demonstrating that the source cannot 

reasonably be anticipated to cause or contribute to visibility impairment in a Class I area. The 

emissions from these sources were modeled using CALPUFF to determine if the emissions from 

the BART eligible emission sources contributed to perceptible visibility impairment to Class I 

areas. The results of this modeling indicated that the emissions from the BART eligible emission 

sources contribute to visibility impairment at the Swanquarter Class I area. 

Since these emission sources could not be otherwise exempted from BART, a BART 

analysis was conducted in accordance with the requirements set forth in 15A NCAC 2D 

.0543. Under this rule, NCDAQ has the maximum flexibility allowed under 40 CFR 51, 

Appendix Y. 

3.3 Required Air Quality Permits 

The BART requirements, if any, will be implemented through the Title V permitting process. 

Since BART will not be required for any of the BART-eligible sources, the Title V permit will 

be modified to indicate that there are no applicable BART requirements for the BART-eligible 

emission sources at PCS Phosphate. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 479 

 December 17, 2007
PCS Phosphate BART determination 

9

SECTION 4.0 

BEST AVAILABLE RETROFIT TECHNOLOGY ANALYSIS 

4.1 Summary 

The following table summarizes the results of the cost analyses for the BART eligible emission 

sources as provided in the BART evaluation Permit Application. DAQ has determined that the 

costs required to implement BART are prohibitive on both a $/ton of pollutant controlled as well 

as in $/deciview. If all controls are implemented at a capital cost of $15.0 million with annual 

operating cots of $6,727,958, the total emission would be reduced by 708.95 tons per year ($ 

9,490/ton) and the visibility impacts on the Swanquarter Class I area would be reduced by 0.116 

dv, resulting in a cost effectiveness of $ 81,811/ton/dv. 

Table 4.1 PCS Phosphate BART Analysis 

BART Eligible 

Emission unit(s) 

Existing 

regulation(s) 

Existing 

controls BART Control Cost Effectiveness 

Sulfuric Acid 

Plant Nos. 3 and 4 

(101, 102 

BACT 

limits and 

NSPS 

Subpart H 

emission 

limits for 

SO2 and 

H2SO4 mist. 

double 

absorption 

process and 

emissions of 

sulfuric acid 

mist are 

controlled by 

mist eliminators 

Dual Absorption Process with 

Cesium Promoted Catalyst 

SO2 

PM10 (H2SO4 mist) current 

control technology represents 

BACT for PM10 emissions from 

sulfuric acid plants 

NOx No feasible controls for 

NOx

$4,108/ton SO2 (SA 

3) 

$5,584/ton SO2 (SA 

4) 

($81,602/ton/dv) 

Lime Storage Silo 

Baghouse No. 4 

(121) 

baghouse There are no other feasible 

PM10 control technologies for 

a source of this type and size. 

Therefore, BART is no 

additional control for this 

source. 

Calciner No. 1 

(201) 

Calciner No. 2 

(202) 

Calciner No. 3 

(203) 

Calciner No. 4 

(204) 

Calciner No. 5 

(205) 

Calciner No. 6 

(206) 

MACT Subpart 

AA PM (all 

units) 

The units are 

each controlled 

by two duplex 

cyclones 

exhausting to a 

fixed throat 

venturi type wet 

scrubber 

exhausting to a 

wet electrostatic 

precipitator 

PM10 controls already in 

place which are the most 

stringent controls available 

SO2 emissions are already 

controlled by the phosphate 

rock being dried and the 

existing venturi scrubber, 

additional SO2 control is 

impractical 

NOx staged combustion 

$3,451/ton of NOx

reduction 

($156,842/ton/dv) 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 480 

 December 17, 2007
PCS Phosphate BART determination 

10

Table 4.1 PCS Phosphate BART Analysis 

BART Eligible 

Emission unit(s) 

Existing 

regulation(s) 

Existing 

controls BART Control Cost Effectiveness 

Rock Dryer (210) MACT Subpart 

AA PM 

controlled by a 

duplex cyclone 

followed by a 

venturi scrubber 

potential retrofit control 

technologies for PM

emissions from the rock dryer 

were not further evaluated

since the unit is already 

equipped with the most 

stringent PM controls 

fluidized bed of rock provides 

approximately 90 percent 

inherent SO2 control, and test 

data show that the SO2

emissions are only 0.012 

lb/MmBtu fuel oil fired. At 

this low emission rate, there 

would be no additional 

technically or economically 

feasible SO2 emissions 

control option. 

NOx staged combustion

$4,007/ton of NOx 

($200,361/ton/dv)

Calcine Conveyor 

Transfer Station 

(CTS) (220) 

 enclosed 

transfer points 

to minimize 

fugitive 

emissions 

PM10 vent to a baghouse 

$161,060/ton PM10

removed. 

(8,052,991/ton/dv) 

Calcine CTS 

baghouse (221) 

baghouse no other technically feasible

PM control technologies for 

sources of this type and size 

Storage Silo 

Baghouses (222) 

baghouse no other technically feasible

PM control technologies for 

sources of this type and size 

Calcined/Dryed 

Rock Transfer 

(223) 

 enclosed 

transfer points 

to minimize 

fugitive 

emissions 

PM10 vent to a baghouse 

$161,060/ton PM10

removed. 

(8,052,991/ton/dv) 

Fugitives from 

Calciner Plant 

Area (291): 

 no other technically feasible

PM control technologies for 

sources of this type and size 

Diammonium 

Phosphate (DAP) 

No. 1 Plant (301) 

Shut down as per 

Title V permit 

Note that PCS 

has shut down 

this plant as 

required by its 

Title V permit; 

this plant is not 

included in this 

analysis.

 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 481 

 December 17, 2007
PCS Phosphate BART determination 

11

Table 4.1 PCS Phosphate BART Analysis 

BART Eligible 

Emission unit(s) 

Existing 

regulation(s) 

Existing 

controls BART Control Cost Effectiveness 

DAP No. 3 Plant 

(302) 

40 CFR 63, 

Subpart BB and 

BACT fluoride 

limits 

The dryer is 

controlled by a 

cyclone 

scrubber and a 

wet cyclonic 

scrubber. The 

sizing and 

handling 

equipment is 

controlled by a 

dual cyclone 

and a cyclonic 

wet scrubber 

installed in 

series. The 

cooler and other 

material 

handling points 

are controlled 

by a dual 

cyclone and a 

wet cyclonic 

scrubber. The 

reactors and 

granulator are 

controlled by a 

saturation 

chamber and a 

wet cyclonic 

scrubber 

installed in 

series. The 

scrubbers are 

vented to a 

cyclonic tail gas 

scrubber. 

additional PM control is 

technically infeasible and 

PM10 emissions are already 

well controlled, BART for 

PM10 emissions from the No. 

3 DAP plant is no additional 

control. 

NOx staged combustion 

SO2 emission inherently low, 

additional SO2 emissions 

control would be not 

technically or economically 

feasible 

$6,997/ton of NOx

($349,361/ton/dv) 

Superphosphoric 

Acid (SPA) No. 1, 

No. 2, No. 3, and 

No. 4 (330, 331, 

and 332) 

These sources 

are in 

compliance with 

40 CFR 63, 

Subpart AA 

fluorides limits. 

Plants 3 and 4 

are in 

compliance with 

BACT limits for 

SO2, and Plant 4 

is in compliance 

with NSPS 

Subpart U 

fluorides limits. 

SPA Plant Nos. 

1 and 2 are each 

controlled by an 

eductor venturi 

type wet 

scrubber. The 

SPA plants No. 

3 and No. 4 

share one 

eductor venturi 

type scrubber. 

Due to the low levels of SO2

emissions, there are no feasible 

retrofit control options;

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Appendix L.10 - 482 

 December 17, 2007
PCS Phosphate BART determination 

12

Table 4.1 PCS Phosphate BART Analysis 

BART Eligible 

Emission unit(s) 

Existing 

regulation(s) 

Existing 

controls BART Control Cost Effectiveness 

Phosphoric Acid 

No. 1, No. 2, No. 

3, and No. 4 Cross 

Flow Scrubber 

Stacks (401, 404, 

406, and 409) 

40 CFR 63, 

Subpart AA, 

NSPS Subpart T, 

and BACT limits 

for fluoride 

phosphoric acid 

production is 

controlled by 

crossflow 

scrubbers 

caustic scrubber for 

controlling SO2 emissions 

$10,974 per ton of 

SO2

($213,462/ton/dv) 

CTS- Grinder 

Loadout, Rock 

Loadout Station, 

CTS- Phosphate 

Rock Transfer 

Station ChuteBarge Rock 

Loadout, and 

Chute- Train Rock 

Loadout (650, 

651, 652, 653, 

655, and 656) 

 enclosed to 

minimize 

fugitive 

emissions 

PM10 emissions controlled by 

adding a baghouse to each of 

these emission points. 

cost effectiveness 

ranges from over 

$19,000/ton to almost 

$3 million/ton PM10

removed 

($2,271,849/ton/dv) 

Rock Tower 

Loadout Facility 

(654) 

 

Note: The capital cost to install all feasible controls is $15.0 million, and the annual operating cost is $6.7 million. 

This represents a capital cost of $81,811/ton/dv. 

4.2 BART Analysis Overview 

BART is defined as follows [40 CFR 51.301]: 

“Best Available Retrofit Technology (BART) means an emission limitation based 

on the degree of reduction achievable through the application of the best system 

of continuous emission reduction for each pollutant which is emitted by an 

existing stationary facility. The emission limitation must be established, on a 

case-by-case basis, taking into consideration the technology available, the costs of 

compliance, the energy and non-air quality environmental impacts of compliance, 

any pollution control equipment in use or in existence at the source, the remaining 

useful life of the source, and the degree of improvement in visibility which may 

reasonably be anticipated to result from the use of such technology.”

The BART analysis was conducted with consideration of the six requirements identified above 

and the five steps identified in 40 CFR 51 Appendix Y “Guidelines for BART Determinations 

Under the Regional Haze Rule.” Again, these guidelines are not the exclusive means of 

defining BART for facilities other than Electric Generating Units. However, they provide a 

convenient structure to consider. 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 483 

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PCS Phosphate BART determination 

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• Step 1—Identify All Available Retrofit Control Technologies, 

• Step 2— Eliminate Technically Infeasible Options, 

• Step 3— Evaluate Control Effectiveness of Remaining Control Technologies, 

• Step 4— Evaluate Impacts and Document the Results, and

• Step 5—Evaluate Visibility Impacts. 

Each of these steps is discussed in further detail in the sections presented below. 

4.2.1 Step 1 – Identify All Available Retrofit Control Technologies 

Appendix Y to 40 CFR 51 defines an available retrofit control option as an air pollution control 

technology with a practical potential for application to the emissions unit and the regulated 

pollutant under evaluation. Technologies available for compliance with Best Available Control 

Technology (BACT) or Lowest Achievable Emission Rate (LAER) regulations should be 

included as part of the BART analysis. Furthermore, technologies that are evaluated should 

include existing controls for the source category in question as well as the transfer of controls 

that have been applied to similar source categories and gas streams. However, control 

technologies which have not yet been applied to full scale operations are not required to be 

included in the evaluation. 

Potentially applicable control technologies can be grouped into one of three categories: 

• Pollution Prevention. As stated in the regulation this is “use of inherently lower-emitting 

processes/practices, including the use of control techniques (e.g., low-NOX burners) and 

work practices that prevent emissions and result in lower "production-specific" emissions.” 

• Add-on Control Technologies. “Use of (and where already in place, improvement in the 

performance of) add-on controls, such as scrubbers, fabric filters, thermal oxidizers and 

other devices that control and reduce emissions after they are produced.” 

• Combinations of the previous two categories. 

Sources that were used to determine the potentially applicable control technologies for the PCS 

Phosphate analysis include the Environmental Protection Agency’s RACT/BACT/LAER 

Clearinghouse (RBLC) and control technology vendors. 

4.2.2 Step 2 – Eliminate Technically Infeasible Options 

Step 1 of the BART analysis identifies all of the control technologies that are potentially 

available for the BART eligible emission units. In step 2 of the analysis this list is further 

refined to include only those technologies which are technically feasible. Appendix Y of 40 

CFR 51 defines a technically feasible control technology as: 

“Control technologies are technically feasible if either (1) they have been installed and 

operated successfully for the type of source under review under similar conditions, or (2) 

the technology could be applied to the source under review. Two key concepts are 

important in determining whether a technology could be applied: "availability" and 

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"applicability." ...a technology is considered "available" if the source owner may obtain 

it through commercial channels, or it is otherwise available within the common sense 

meaning of the term. An available technology is "applicable" if it can reasonably be 

installed and operated on the source type under consideration. A technology that is 

available and applicable is technically feasible.” 

Control technologies that are deemed technically infeasible in this step of the evaluation must 

include specific data stating that the technology is either commercially unavailable or outline the 

specific circumstances that preclude its application. Facilities may demonstrate that a particular 

technology is infeasible due to “unresolvable technical difficulties with applying the control to 

the source (e.g., size of the unit, location of the proposed site, operating problems related to 

specific circumstances of the source, space constraints, reliability, and adverse side effects on 

the rest of the facility).” 

Implications of cost effectiveness should not be included in this step of the analysis. 

4.2.3 Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies, 

Control technologies determined to be not technically infeasible in step 2 of the analysis are 

further evaluated in step 3. As stated in the guidance, the two main issues in step 3 of the 

process are as follows: 

• Making sure that you express the degree of control using a metric that ensures an “apples to 

apples” comparison of emissions performance levels among options, and 

• Giving appropriate treatment and consideration of control techniques that can operate over a 

wide range of emission performance levels. 

The analysis should be based on the maximum level of control that a technology is capable of 

achieving. 

4.2.4 Step 4 – Evaluate Impacts and Document the Results 

For the control technologies determined to be commercially available and technically feasible, 

the affected facility must conduct the following analyses to select the control technology that 

meets the requirements of BART. 

The analysis evaluates four impacts that would potentially result from the installation of a control 

technology. 

Impact analysis part 1: Costs of compliance, 

Impact analysis part 2: Energy impacts,

Impact analysis part 3: Non-air quality environmental impacts, and 

Impact analysis part 4: Remaining useful life. 

Appendix Y to 40 CFR 51 presents detailed guidelines for conducting the evaluation of each 

potential impact. The analysis presented later in this section for each available and technically 

feasible control technology identified for the BART eligible emission units follows these 

guidelines with the greatest flexibility. 

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Appendix L.10 - 485 

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PCS Phosphate BART determination 

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4.2.5 Step 5 – Evaluate Visibility Impacts 

Once the facility has completed the steps outlined above and an available, technically feasible 

control technology has been selected, then the visibility improvements are evaluated in this final 

step. 

Baseline emissions and the visibility impacts are compared to the predicted visibility impacts 

from the emission sources with the control technology installed. If the net visibility 

improvement is less than that which would contribute to visibility impairment (as defined in the 

preamble to Appendix Y) then there is no need for the facility to implement the control 

technologies because the resulting visibility impacts would be negligible. 

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PCS Phosphate BART determination 

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4.3 BART Analysis for Sulfuric Acid (SA) Plants Nos. 3 and 4 

The SA Plants Nos. 3 and 4 (Emission Point IDs 101 and 102) emit PM10/H2SO4 mist, SO2, and 

NOx. As stated previously, the units use the double absorption process to control SO2 and mist 

eliminators to control H2SO4 mist (PM10) to meet BACT and NSPS limits for SO2 and H2SO4

mist. The principal steps in the sulfuric acid production process consist of burning sulfur (S) in 

air to form sulfur dioxide (SO2), combining the sulfur dioxide with oxygen (O2) to form sulfur 

trioxide (SO3), and combining the sulfur trioxide with water (H2O) to form a solution containing 

sulfuric acid (H2SO4). 

4.3.1 Sulfur Dioxide Emissions 

Sulfur dioxide is formed when elemental sulfur is sprayed into a horizontal spray-type burner, 

the sulfur dioxide gas exits the burner compartment at a higher temperature than the optimum for 

conversion and it enters a heat recovery boiler to be cooled off. Upon exiting the recovery 

boiler, the sulfur dioxide rich gas enters the first converter where it is partially converted to SO3. 

Not all the SO2 is converted to SO3; the conversion into SO3 is a function of the catalyst and 

oxygen present during the reaction. 

A summary of recent BACT determinations for SO2 emissions from sulfuric acid plants is 

provided in Table 4-2. 

Table 4.2 RBLC BACT Determinations for Sulfuic Acid Plants 

RBLC ID Process Name Control Method Description 

FL-0172 Sulfuric Acid Plant, Double Absorption Method 

Double absorption towers/fiber mist eliminators. 

Emission limit in lb/ton of 100% H2SO4 produced. 

Additional basis: NSPS. 

FL-0194 Sulfuric Acid Plant, Double Absorption Process Double absorption part of process. 

FL-0197 Sulfuric Acid Plant, Contact Process 

Double absorption process. Limit is on 24 hr basis. Limit 

is lb/ton of 100% H2SO4 per day. 

FL-0210 Sulfuric Acid Plant 

Double absorption towers/fiber mist eliminators. 

Emission limit in lb/ton of 100% H2SO4 produced. 

ID-0015 300 Sulfuric Acid Plant (single contact process) 

Dynawave reverse-jet scrubber followed by an Ammsox 

packed-bed ammonia scrubber. 

ID-0015 400 Sulfuric Acid Plant Double contact process 

NC-0088 Sulfuric Acid Plant, No. 4 Dual absorption catalyst 

NC-0099 Sulfuric Acid Plant No. 3 

Fiberglass packed mist eliminators and a mesh pad 

installed on the final absorbing tower. 

 The prevalent control technology for SO2 emissions from sulfuric acid plants is a dual 

absorption system with a catalyst, which is employed at SA Plants Nos. 3 and 4. Other 

technologies have been identified as potentially applicable control technologies for SO2

emissions from sulfuric acid plants. The following technologies are evaluated: 

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• Sodium Sulfite-bisulfite scrubbing 

• Molecular sieve 

• Ammonia scrubbing 

• Dual absorption process with cesium catalyst 

Sodium Sulfite-Bisulfite Scrubbing

In the sodium sulfite-bisulfite scrubbing process, SO2 is removed by scrubbing the exhaust gases 

with a sodium sulfite solution. The resulting sodium bisulfite solution is fed to a heated 

crystallizer where sodium sulfite crystals are formed with the release of SO2 and water vapor. 

The crystals are separated from the mother liquor and dissolved in the recovered condensate for 

recycle to the absorber. The recovered wet SO2 is recycled to the acid plant. In all processes 

employing sulfite-bisulfite absorption even without regeneration, some portion of the sulfite is 

oxidized to sulfate, from which SO2 cannot be regenerated in the heating sequence. This sulfate 

must be purged from the system. Some thio-sulfate can also be formed in the process. The 

extent of oxidation is dependent on several factors (some which may be difficult to control) such 

as the oxygen content of the gas stream, the temperature and residence time of the liquor in the 

recovery sections, and the presence of contaminants that may act as oxidizing catalysts. The 

formation of oxides, which readily precipitate from solution, can result in plugging and 

operational problems. Since promulgation of the NSPS for sulfuric acid manufacturing, two 

plants have used the sodium sulfite-bisulfite control technology. The sodium sulfite-bisulfite 

system at one of the plants experienced operational difficulties and was subsequently replaced by 

an ammonia scrubber. The other plant is a part of an Army ammunition production facility and 

has not been used since 1994. 

Sodium sulfite-bisulfite control technology is rejected from further consideration in this analysis 

because it has not been demonstrated commercially as providing reliable emissions control of 

less than 4.0 lb SO2/ton of 100 percent H2SO4 produced at a sulfur-burning sulfuric acid 

manufacturing plant. SA Plants 3 and 4 are currently limited to 4.0 lb SO2/ton H2SO4 by NSPS 

Subpart H and have daily SO2 mass emission limits that are equivalent to 3.8 lb SO2/ton H2SO4

at production capacity. 

Molecular Sieves

This process utilizes a proprietary molecular sieve system in which SO2 is adsorbed on synthetic 

zeolites. The adsorbed material is desorbed by purified hot tail gas from the operating system 

and sent back to the acid plant. Since the promulgation of the sulfuric acid plant NSPS, one new 

unit was built with a molecular sieve system to control SO2. However, extensive operational 

difficulties with the system caused this plant to be retrofitted with a dual absorption system for 

SO2 control. The dual absorption system was retrofitted in January 1979 and has operated 

satisfactorily since that time. Since molecular sieve control technology has not been 

commercially demonstrated, this option is considered technically infeasible for reducing SO2

emissions from SA Plants 3 and 4 and is rejected from further consideration. 

Ammonia Scrubbing

The ammonia scrubbing process uses anhydrous ammonia (NH3) and make-up water in a twostage scrubbing process to remove SO2. The typical SO2 removal efficiency of this control 

technology is not as high as conventional dual absorption technology; however, several facilities 

in the U.S. have used this technology to meet the NSPS for sulfuric acid manufacturing plants. 

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According to MECS, Inc., sulfur-burning sulfuric acid manufacturing plants that have used 

ammonia scrubbing technology have applied the technology as a retrofit to “existing” plants that 

were based on single absorption technology that had to improve emissions control to achieve the 

NSPS limit of 4.0 lb SO2/ton of 100 percent H2SO4 produced and comply with the more stringent 

state limit of 3.8 lb SO2/ton of 100 percent H2SO4 produced. Due to operational difficulties and 

high costs associated with operating ammonia scrubbing systems, all but two single absorption 

plants using ammonia scrubbing technology have been shut down, and the two existing plants 

still in operation are required to meet the both the NSPS emission limit of 4.0 lb SO2/ton of 100 

percent H2SO4 produced and the state limit of 3.8 lb SO2/ton of 100 percent H2SO4 produced.

Consequently, ammonia scrubbing is rejected from this analysis because it is commercially 

undemonstrated on dual absorption plants, because of operational difficulties that have been 

experienced by other sulfuric acid manufacturers, and because it is unknown whether additional 

control of SO2 emissions would be achieved by a retrofit with this type of system. 

Dual Absorption Process with Cesium Promoted Catalyst

Dual absorption technology is widely accepted as BACT for sulfuric acid plants. Conceptually, 

dual absorption is the addition of another converter and absorbing tower to the exhaust from a 

single absorption plant. Vanadium-based catalysts are used in virtually all existing dual 

absorption systems, including SA Plants Nos. 3 and 4. Cesium-promoted catalysts have recently 

been used, and provide higher levels of control. There are no by-products or waste scrubbing 

materials produced by the dual absorption process. Spent catalyst is not treated as hazardous 

waste. The cesium-promoted catalyst was developed specifically for lower temperature 

operations which can lead to greater SO2 conversion and hence lower SO2 emissions to the 

atmosphere. The cesium salt promoter reduces the required operating temperature for the 

sulfuric acid catalyst by as much as 40°C (70°F). Higher SO2 conversion is possible at lower 

temperatures as long as the catalyst is “active.” The cesium-promoted catalysts are sufficiently 

active at these lower temperatures (390-410°C/735-770°F) to take advantage of this conversion 

“opportunity.” 

PCS Phosphate conducted analyses based on this retrofit technology for SA Plants Nos. 3 and 4 

using the existing vanadium catalyst in beds 1, 2, and 3 to reduce the bed inlet temperature 

(saving energy and start-up time) followed by cesium catalyst in beds 4 and 5 (at a low inlet 

temperature) to maximize the SO2 conversion and provide SO2 emission reductions. PCS 

indicated that they made an inquiry regarding the retrofit of the existing vanadium-based control 

systems at SA Plants Nos. 3 and 4 with cesium catalyst was made to MECS, Inc. to specifically 

determine the feasibility of reducing SO2 emissions to 2.0 lb SO2/ton H2SO4 (the level of control 

a new plant would likely be able to reach). In order to achieve this reduction the existing 

vanadium catalyst in beds 1, 2, and 3 would have to be replenished, and that in beds 4 and 5 

would have to be removed, properly disposed of, and replaced with super cesium catalyst. PCS 

indicted that, according to MECS, Inc., this magnitude emissions reduction would also require a 

decrease in Plant Nos. 3 and 4 production levels from a throughput of 2000 ton H2SO4/day and 

1850 ton H2SO4/day, respectively, down to 1650 ton H2SO4/day per plant. This level of 

emission reduction has been rejected as a feasible control option because decreasing the 

production rates is not economical or practical. 

PCS also investigated the feasibility of reducing the SO2 emissions in plants 3 and 4 to 3.5 lb 

SO2/ton H2SO4. An inquiry into this magnitude of emissions reduction was also submitted to 

MECS, Inc. This magnitude emissions reduction requires the replenishment of vanadium 

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Appendix L.10 - 489 

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PCS Phosphate BART determination 

19

catalyst in beds 1, 2, and 3, and also requires the purchase and installation of super cesium 

catalyst in beds 4 and 5. This reduction is feasible as it does not require a decrease in the 

productivity of the plants. The economic impacts of modifying the catalyst beds in both SA 

plants 3 and 4 was determined by PCS. The capital cost is $1,441,100 for plant No.3 and 

$1,447,308 for plant No. 4. The annual operating costs would be $451,852 and $564,014 for 

plants 3 and 4 respectively. 

Installing these controls would result in a visibility improvement of 0.059 dv. The cost 

effectiveness of this control technology retrofit is $4,108/ton SO2 and $5,584/ton SO2 for SA 

plants 3 and 4, respectively (calculated based on a reduction from 3.8 to 3.5 lb/ton). The overall 

cost effectiveness would be $4,815/ton, and $81,610 /ton/dv. 

4.3.2 PM10 Emissions 

The PM10 emissions from sulfuric acid plants are made up primarily of sulfuric acid mist. 

Sulfuric acid mist is created when sulfur trioxide combines with water vapor at a temperature 

below the dew point of sulfuric acid. SA Plant 3 currently has vertical panel mist eliminators 

followed by a horizontal mesh pad, but is being retrofitted with vertical tube mist eliminators to 

control H2SO4 mist. SA Plant 4 uses vertical tube mist eliminators to control H2SO4 mist. They 

are subject to the NSPS limit of 0.15 lb H2SO4 mist/ton of 100 percent H2SO4 produced and 

BACT limits of 7.5 lb/hr apiece. The following section discusses other technologies available 

for H2SO4 mist control and their potential application to SA Plants Nos. 3 and 4. 

RBLC entries for PM10 emissions from sulfuric acid plants show that the H2SO4 mist control 

technology used in sulfuric acid plants is in the form of mist eliminators (there is one entry for a 

scrubber to control PM10, but scrubbers do not typically provide much control of sulfuric acid 

mist emissions, and this entry is RACT for a single-contact process where SO2 was also 

evaluated). H2SO4 mist elimination control technologies considered in this BART analysis 

include: 

• Electrostatic Precipitators (Wet or Dry); 

• Vertical Panel Mist Eliminators; and 

• Horizontal Dual Pad Mist Eliminators 

Electrostatic Precipitators

Electrostatic precipitators (ESPs) are frequently used in the purification section of spent acid 

plants; however, there are no sulfuric acid plants using ESPs to control H2SO4 mist emissions. 

ESPs are not used as control devices in sulfuric acid plants primarily due to their relatively large 

size and high costs when compared to fiber mist eliminators. Mist eliminators can achieve 

control efficiencies similar to the efficiencies that would likely be achieved with ESPs at only a 

fraction of the cost. 

Since ESP technology has not been demonstrated commercially as H2SO4 mist control 

technology in sulfuric acid plants and is much less cost effective than mist eliminators, this 

option is rejected from further consideration in this analysis. 

Vertical Panel Mist Eliminators

Panel mist eliminators use fiber panel elements mounted in a polygon framework, closed at the 

bottom by a slightly conical drain pan equipped with an acid seal pot to prevent the bypass of 

gas. The polygon top is surmounted with a circular ring that is usually installed in the absorption 

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Appendix L.10 - 490 

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PCS Phosphate BART determination 

20

tower and welded to the inside of the absorption tower head. The gas flows horizontally through 

the bed and requires a high superficial velocity since it uses an impact mechanism for collection 

of H2SO4 mist particles. Since a high superficial gas velocity is required, this technology is not 

ideal for the varying loads found at sulfuric acid plants. As production rate decreases, load to the 

panel mist eliminators decreases, which lowers gas velocity across the pads and increases H2SO4

mist emissions and stack opacity. 

Manufacturers of panel mist eliminators usually guarantee an emission rate of only 0.375 lb 

H2SO4 mist/ton of 100 percent H2SO4 produced, which is higher than the NSPS standard of 

0.15 lb H2SO4 mist/ton of 100 percent H2SO4 produced. Moreover, vertical panel mist 

eliminators are widely known to be a less effective technology than vertical tube mist 

eliminators. SA Plant 3 currently has vertical panel mist eliminators followed by a horizontal 

mesh pad, but is being retrofitted with vertical tube mist eliminators to control H2SO4 mist. SA 

Plant 4 uses vertical tube mist eliminators to control H2SO4 mist. Since vertical panel mist 

eliminators are less efficient that vertical tube mist eliminators this technology is removed from 

further analysis. 

Horizontal Dual Pads

The principle of horizontal dual pad mist eliminators is similar to panel mist eliminators except 

dual pad eliminators have two circular fiber beds held by stainless steel screens that are oriented 

horizontally in a vertical cylindrical vessel. These units also use high velocity impaction for mist 

collection, which also results in an unsatisfactory performance for H2SO4 mist control. Dual pad 

mist eliminators typically reduce H2SO4 mist emissions to 0.375 lb H2SO4 mist/ton of 100 

percent H2SO4 produced, which is higher than the relevant NSPS and less effective than vertical 

tube mist eliminators. SA Plant 3 currently has vertical panel mist eliminators followed by a 

horizontal mesh pad, but is being retrofitted with vertical tube mist eliminators to control H2SO4

mist. SA Plant 4 uses vertical tube mist eliminators to control H2SO4 mist. 

As the current control technology represents BACT for PM10 emissions from sulfuric acid plants 

and recent stack testing results were less than 0.05 lb H2SO4 mist/ton of 100 percent H2SO4

produced, no additional H2SO4 mist control is proposed for BART for SA Plants 3 and 4. 

4.3.3 Nitrogen Oxides Emissions 

Nitrogen oxides (NOx) are formed from the reaction of nitrogen (N2) and oxygen (O2) within the 

combustion air, creating thermal NOx. Increased quantities of oxygen in the combustion zone 

result in greater amounts of NOx formation. Once formed, the decomposition of NOx at lower 

temperatures, although thermodynamically favorable, is kinetically limited. Thus, NOx control 

strategies are based upon reducing formation of NOx within the combustion zone by reducing the 

combustion temperature, oxygen concentration in the high temperature combustion zone, and the 

gas residence time at high temperatures. 

Currently, there are no NOx add-on control technologies used at sulfuric acid plants according to 

EPA’s RBLC. However, the following control technologies were evaluated for technical 

feasibility: 

• Selective Catalytic Reduction (SCR) 

• Selective Non-Catalytic Reduction (SNCR) 

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21

A brief description of each technology and the reasons why those technologies are considered 

technically infeasible are provided below. 

Selective Catalytic Reduction (SCR)

SCR is typically used for NOx control on large utility boilers. The SCR process chemically 

reduces the NOx molecule into molecular nitrogen and water vapor. A nitrogen-based reagent 

such as ammonia or urea is injected into the ductwork, downstream of the combustion unit. The 

waste gas mixes with the reagent and enters a reactor module containing catalyst. The hot flue 

gas and reagent diffuse through the catalyst. The reagent reacts selectively with the NOx within 

a specific temperature range and in the presence of the catalyst and oxygen. The NOx reduction 

reaction is effective only within a given temperature range. The optimum range depends on the 

type of catalyst used and the flue gas composition. Optimum temperatures vary from 480°F to 

800°F. SCR has been applied mostly to coal and natural gas-fired utility boilers ranging in size 

from 250 to 8,000 mmBtu/hr. 

Capital costs are significantly higher than other types of NOx controls due to the large volume of 

catalyst that is required. SCR is not technically feasible for application to sulfuric acid plants 

because of the high outlet temperature required. The outlet temperature of SA Plants Nos. 3 and 

4 is about 152 °F. 

Selective Non-Catalytic Reduction (SNCR)

The SNCR process is based on the chemical reduction of the NOx molecule into molecular 

nitrogen and water vapor. The reduction occurs when a reagent such as ammonia or urea is 

injected into the post combustion flue gas at temperatures ranging from 1600°F to 2100°F. In 

the SNCR, the reduction occurs within the combustion unit, which acts as the reaction chamber. 

SNCR is usually applied to boilers using coal, oil, gas, biomass and waste ranging in size from 

50 to 6,000 MmBtu/hr. This technology has not been applied to sulfuric acid plants. As the 

outlet temperature of SA Plants Nos. 3 and 4 is about 152 °F, the use of SNCR is not technically 

feasible for sulfuric acid plants and is not considered for further analysis. In addition, there is the 

unwanted reaction of ammonia with sulfur compounds to form ammonium sulfates in the 

reaction chamber. 

Because there are no feasible retrofit technologies for NOx emissions from sulfuric acid plants, 

BART is no additional control. 

 

4.4 BART Analysis for Lime Storage Silo Baghouse 

This lime storage silo (Emission Point ID 121) has small emissions of PM10 and is controlled by 

a baghouse. Baghouses are typically used in industry to control these types of particulate matter 

sources. There are no other feasible PM10 control technologies for a source of this type and size. 

Therefore, BART is no additional control for this source. 

4.5 BART Analysis for Calciners 

The Nos. 1-6 Calciners (IDs 201-206) are located in the mill area and process phosphate rock. 

They are vertical fluidized bed rock calciners, and each is controlled by two duplex cyclones 

exhausting to a fixed throat venturi type wet scrubber exhausting to a wet electrostatic 

precipitator. Each calciner is in compliance with MACT Subpart AA PM limits. 

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PCS Phosphate BART determination 

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4.5.1 PM10 Emissions 

Particulate matter is emitted from the calciners primarily as phosphate rock dust that is entrained in 

the exhaust stream. Currently, only a few types of add-on control are commercially implemented 

for PM10 emissions from calciners, including electrostatic precipitators (ESP), wet scrubbers, and 

baghouses. However, Appendix Y to 40 CFR 51 states the following:

“If you find that a BART source has controls already in place which are the most 

stringent controls available (note that this means that all possible improvements to any 

control devices have been made), then it is not necessary to comprehensively complete 

each following step of the BART analysis in this section. As long as these most stringent 

controls available are made federally enforceable for the purpose of implementing BART 

for that source, you may skip the remaining analyses in this section, including the 

visibility analysis in step 5.” 

Recent stack testing showed emissions from each calciner range from 0.04 to 0.29 lb PM/ton 

feed; emissions are less than the MACT limit of 0.08 gr/dscf. Therefore, potential retrofit 

control technologies for PM emissions from the calciners were not further evaluated since the 

units are already equipped with the most stringent PM controls and the operation of these 

controls is required by the facility’s Title V Operating Permit. 

4.5.2 Sulfur Dioxide Emissions 

Sulfur dioxide is formed in the calciners as a by-product of fuel combustion. In the calcining 

process, SO2 is partially removed from the combustion gases when SO2 reacts with the wet 

phosphate rock being dried. Phosphate rock is rich in oxygenated calcium compounds and reacts 

with SO2 to form calcium sulfates/sulfites. Additional SO2 is thought to be removed in the 

existing venturi scrubber where calcium oxides may be present due to recirculation of the 

scrubbing liquor. The use of a scrubber coincides with the SO2 control methodology found in a 

search of the EPA’s RBLC for kilns and calciners in the mineral products industry. 

Additionally, the actual SO2 emissions from each calciner at PCS are less than 10 tpy. Because 

SO2 emissions are already controlled by the phosphate rock being dried and the existing venturi 

scrubber, additional SO2 control is impractical and has not been evaluated here. 

4.5.3 Nitrogen Oxides Emissions 

Nitrogen oxides are emitted from the calciners as a by-product of fuel combustion. The calciners 

use conventional combustion techniques and NOx emissions are uncontrolled. The temperature 

of the heated air from the calciner exhaust is approximately 160o

F. Although SCR, NSCR, and 

SNCR are highly effective NOx reduction technologies in various industries, they are not 

applicable to phosphate rock calciners and are rejected as BART based on technical infeasibility. 

Elevated temperatures and/or low particulate loading are essential for use of these technologies. 

First, temperature requirements range from 600 to 800o

F for SCR, 700 to 1500oF for NSCR, and 

1600 to 2200o

F for SNCR. The calciner exhaust temperature of approximately 160oF is 

substantially below the required temperatures for any of these technologies. Second, low 

particulate loading is needed to prevent deactivation of SCR and NSCR catalysts. The calciner 

exhaust contains some particulate loading and likely contains phosphorus compounds, which 

deactivate NOx reduction catalysts. Consequently, the use of SCR, SNCR, and NSCR 

technologies are not considered technically feasible for phosphate rock calciners. 

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EPA’s RBLC database for technologies used on kilns and calciners in other mineral processing 

industries yielded feasible and successfully implemented alternatives to SCR, SNCR, and NSCR. 

These alternatives include staged combustion and low-NOx burners. Although staged 

combustion and low-NOx burners are both technically feasible NOx control techniques, cost 

effectiveness was evaluated for only staged combustion because the cost of low-NOx burners is 

expected to be approximately equal to a staged combustion system, while achieving the same 

NOx reduction. Low-NOx burner technology for fuel oil combustion typically reduces NOx

emissions by 18 to 20 percent. While low-NOx burners could be used in the calciners, low-NOx

burners were not included in the cost analyses because of the similarities to staged combustion in 

cost and reduction efficiency. PCS indicates that, from previous experience in other industries, 

the annual costs of low-NOx burners are typically slightly more than staged combustion systems 

and, in this particular case, the annual cost of low-NOx burners is also expected to be very 

similar to that of staged combustion. 

Staged combustion is a technology commonly used to reduce NOx emissions in a variety of 

industries. This technology could also be retrofitted to the calciners’ combustion system. In 

staged combustion, combustion temperatures are kept lower in the burner zone by firing under 

fuel rich conditions and introducing staged air after the burner zone to complete combustion at 

reduced temperatures. A retrofit NOx reduction system incorporating recirculation of drying air 

for staged combustion was evaluated as part of previous BACT analyses performed on the 

calciners. In the current combustion system, additional make-up air is added after the 

combustion zone to reduce and maintain acceptable temperatures in the drying vessel. The 

retrofit staged combustion system would remove the recirculation gas from a point after the 

make-up air is added and return the gas to the combustion zone after the burner zone in order to 

complete combustion of the fuel. PCS indicated that they were not able to obtain a guaranteed 

emission level or reduction efficiency from the vendor that they consulted for system design. 

However, PCS indicated that a 20 percent control efficiency is typical for staged combustion (for 

coal firing, this represents a reduction from 31.6 lb/hr per calciner to 25.3 lb/hr per calciner, or 

138.4 tpy per calciner to 110.8 tpy per calciner). 

The cost evaluation for the staged combustion option followed the procedures outlined in the 

EPA control cost manual. A half percent fuel penalty was assumed for heat losses incurred from 

gas recirculation. Total capital and annual costs are estimated to be $150,000 and $95,516, 

respectively. The cost effectiveness is estimated to be $3,451/ton of NOx reduction. The 

visibility improvement resulting from the installation of NOx controls would be 0.022 dv 

($156,852/ton/dv). 

4.6 BART Analysis for Rock Dryer 

The phosphate rock dryer (ID 210) fires fuel oil to dry phosphate rock from approximately 

10 percent moisture to less than 1 percent moisture in a fluidized bed system. It is controlled by 

a duplex cyclone followed by a venturi scrubber. The rock dryer is in compliance with MACT 

Subpart AA PM limits. Appendix Y to 40 CFR 51 states the following: 

“If you find that a BART source has controls already in place which are the most 

stringent controls available (note that this means that all possible improvements to any 

control devices have been made), then it is not necessary to comprehensively complete 

each following step of the BART analysis in this section. As long as these most stringent 

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controls available are made federally enforceable for the purpose of implementing BART 

for that source, you may skip the remaining analyses in this section, including the 

visibility analysis in step 5.” 

Recent stack testing showed emissions were 0.05 lb PM/ton feed, which is less than the MACT 

limit of 0.215 lb/ton. Therefore, potential retrofit control technologies for PM emissions from 

the rock dryer were not further evaluated since the unit is already equipped with the most 

stringent PM controls and the operation of these controls is required by the facility’s Title V 

Operating Permit. 

The rock dryer also emits small amounts of SO2 and NOx emissions from fuel oil combustion; 

maximum fuel oil combustion is 620 gal/hr. However, the fluidized bed of rock provides 

approximately 90 percent inherent SO2 control, and test data show that the SO2 emissions are 

only 0.012 lb/MmBtu when fuel oil is fired. At this low emission rate, there would be no 

additional technically or economically feasible SO2 emissions control option. 

NOx control options for the rock dryer are the same as those for the calciners in that staged 

combustion is the best suited control technology to reduce NOx emissions. A 20 percent control 

efficiency is typical for staged combustion (for fuel oil firing, this represents a reduction from 

34.1 lb/hr to 27.3 lb/hr, or 149.4 tpy to 119.6 tpy). The control costs evaluation follows the 

procedures outlined in the EPA control cost manual. A half percent fuel penalty was assumed 

for heat losses incurred from gas recirculation. Total capital and annual costs are estimated to be 

$150,000 and $119,816, respectively. The estimated visibility improvement would be 0.02 dv. 

The cost effectiveness of NOx reduction is estimated to be $4,007/ton of NOx reduction and 

$200,361/ton/dv. 

4.7 BART Analysis for Calciner Area Rock Handling Sources 

The Calcine CTS baghouse (ID 221) and the storage silo baghouse (ID 222) have small 

emissions of PM10. Enclosures and/or baghouses are typically used in industry to control these 

types of particulate matter sources. There are no other technically feasible PM control 

technologies for sources of this type and size. 

The Calcine CTS (ID 220) and the Calcined/Dryed Rock Transfer (ID 223) sources represent 

transfer points on conveyor belts. These transfer points are enclosed to minimize fugitive 

emissions. The only additional technically feasible control would be to vent these transfer points 

to a baghouse, resulting in a visibility improvement of 0.02 dv. The estimated costs for this 

control option are not cost effective; The total annual cost for each transfer point is estimated to 

be $188,440 and the cost effectiveness is $161,060/ton PM10 removed, and $8,053,000/ton/dv. 

The Calciner Area Fugitives source (ID 291) potential PM-10 emissions are estimated at 

0.11 tons per year. Additional control is not technically or economically feasible, and likely 

would not provide a visibility improvement at Swanquarter, as the emissions reduced would only 

be a tenth of a ton. Therefore, BART is no additional control for the calciner area fugitives. 

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4.8 BART Analysis for Diammonium Phosphate (DAP) Plants 

As previously stated, DAP Plant No. 1 (ID 301) has been shut down in accordance with PCS’s 

Title V permit provisions. DAP Plant No. 3 (ID 302) is used to produce ammoniated phosphates 

by reacting anhydrous ammonia with phosphoric acid. DAP No. 3 can produce DAP, monoammonium phosphate (MAP), granulated triple superphosphate (GTSP), or partially acidulated 

phosphate rock (PAPR). This plant consists of first and second stage reactors, granulator, 

residual oil-fired dryer, material sizing and handling equipment, and a cooler. The dryer is 

controlled by a cyclone scrubber and a wet cyclonic scrubber. The sizing and handling 

equipment is controlled by a dual cyclone and a cyclonic wet scrubber installed in series. The 

cooler and other material handling points are controlled by a dual cyclone and a wet cyclonic 

scrubber. The reactors and granulator are controlled by a saturation chamber and a wet cyclonic 

scrubber installed in series. The scrubbers are vented to a cyclonic tail gas scrubber. This source 

is in compliance with 40 CFR 63, Subpart BB and BACT fluoride limits. 

In all four processes, the ammoniated phosphate slurry is sprayed into a granulator vessel where 

it is mixed with a recycled product stream in a rotating cylindrical vessel to produce a granular 

product. The granular product is then dried in the dryer, screened in the materials sizing and 

collection equipment to separate product-size granules, cooled and sprayed with a light oil prior 

to shipment or storage. Oversized granules are ground in enclosed chain mills prior to being 

recycled to the granulator along with undersize granules. 

The processes described above generate product-bearing off gases from the reactors, the 

granulator, the dryer, the material sizing and handling equipment, and the cooler. Product dust 

from the dryer, the material sizing and handling equipment, and the cooler is collected in the 

dryer cyclone, the dust cyclone, and the cooler cyclone, respectively. The dust collected by the 

cyclones is returned to the process. The exhaust gas from the three cyclones is directed in series 

to three parallel cyclone scrubbers (dryer scrubber, dust scrubber, and cooler scrubber). Fumes 

and dust from the reactors and granulator are controlled by a two stage scrubbing unit (dual mole 

scrubber) consisting of a venturi scrubber (high mole stage) followed by a cyclonic scrubber 

(low mole stage). The primary purpose of the venturi scrubber is to capture and recycle ammonia 

to the process. The exhaust from the four primary scrubbers is combined prior to passing through 

the tail gas scrubber. The tail gas scrubber also provides some ammonia emissions control. 

4.8.1 PM10 Emissions 

Particulate matter is emitted from DAP process equipment primarily as entrained fertilizer dust. 

As evidenced by the discussion above, the process units within DAP No. 3 are very well 

controlled for PM, utilizing multiple cyclones and scrubbers in parallel and in series. These 

controls meet MACT requirements. A search of the EPA’s RBLC showed the IMC-Agrico DAP 

plant utilizes scrubbers as BACT. 

Although the existing control technology meets the MACT standards for fluorides and provides 

sufficient PM control, many forms of add on PM control were considered for this analysis, 

including fabric filters, dry ESPs, and wet ESPs. The use of fabric filters for additional PM 

control has been determined to be infeasible because the emission stream has a high moisture 

content, which would likely cause condensation in the fabric bag, leading to bag blinding. 

Additional control using a dry ESP is considered infeasible because dry ESP control is 

undemonstrated on DAP plants and may be incompatible with exhaust stream characteristics. 

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The exhaust stream in the common header after the primary scrubbing systems is saturated with 

moisture and could contain hydrofluoric acid at concentrations that could be corrosive to the 

ESP. Additional control using a wet ESP is not considered further because wet ESP control is 

undemonstrated on DAP plants and is considered technically infeasible due to high maintenance 

(e.g., difficulties in keeping essential components clean for proper operation) and operational 

difficulties leading to problems in maintaining compliance with design/permitted emission 

levels. 

Current stack test data show that PM10 emissions are 0.123 lb/ton P2O5 input (2005 average 

emissions of 4.3 lb/hr), which is much lower than the most recent BACT determination. 

Therefore, as application of additional PM controls is technically infeasible and PM10 emissions 

are already well controlled, BART for PM10 emissions from the No. 3 DAP plant is no additional 

control. 

4.8.2 Nitrogen Oxides Emissions 

NOx emissions result from fuel oil combustion in the dryer. Although SCR, NSCR, and SNCR 

are highly effective NOx reduction technologies in other industries, they are not applicable to the 

DAP dryer and are rejected as BART based on technical infeasibility. Elevated temperatures 

and/or low particulate loading are essential for use of these technologies. First, temperature 

requirements range from 600 to 800o

F for SCR, 700 to 1500oF for NSCR, and 1600 to 2200oF 

for SNCR. The dryer exhaust temperature of 170 to 200o

F is substantially below the required 

temperatures for any of these technologies. Second, low particulate loading is needed to prevent 

poisoning of SCR and NSCR catalysts. The dryer exhaust contains substantial particulate 

loading, which may be difficult to reduce without further lowering exhaust temperature. The 

exhaust likely contains phosphorus compounds, which are severe catalyst deactivators. 

Consequently, the use of SCR, SNCR, and NSCR technologies are not considered technically 

feasible. 

Although staged combustion and low-NOx burners are both technically feasible NOx control 

techniques, only staged combustion is evaluated here because the cost of low-NOx burners is 

expected to be approximately equal to a staged combustion system, while achieving a lower NOx

reduction efficiency. Staged combustion is a technology commonly used to reduce NOx

emissions in a variety of industries. This technology could be retrofitted to the DAP dryer 

combustion system. In staged combustion, combustion temperatures are kept lower in the burner 

zone by firing under fuel rich conditions and introducing “staged air” after the burner zone to 

complete combustion at reduced temperatures. 

The design of the NOx reduction system that was evaluated incorporates recirculation of drying 

air for staged combustion. In the current combustion system, additional “make-up” air is added 

after the combustion zone to reduce and maintain acceptable temperatures in the drying vessel. 

The staged combustion system considered would remove the recirculation gas from a point after 

the make-up air is added and return the gas to the combustion zone after the burner zone in order 

to complete combustion of the fuel. A 20 percent control efficiency is typical for staged 

combustion and would decrease emissions from 60.9 tpy to 48.6 tpy. 

The costs for control were evaluated using the procedures outlined in the EPA control cost 

manual and EPA’s New Source Review manual. A half percent fuel penalty was assumed for 

heat losses incurred from gas recirculation. Total capital and annual costs are estimated to be 

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$150,000 and $85,364, respectively, and would result in a visibility improvement of 0.02 dv. 

The cost effectiveness of NOx reduction is estimated to be $6,997/ton of NOx reduction, and 

$349,850/ton/dv. 

4.8.3 Sulfur Dioxide Emissions 

Stack test data show that SO2 emissions are minimal from DAP production due to inherent 

ammonia scrubbing (0.009 lb/ton P2O5 input), with actual emissions on the order of 1 ton per 

year. Therefore, no additional SO2 emissions control would be technically or economically 

feasible. Ammonia emissions are also minimized from the DAP Plant No. 3 as the scrubbers are 

in place for both emissions control and for ammonia capture and recycle to the process. 

Therefore, BART for DAP No. 3 is no additional control, as the plant is already well-controlled 

and additional control is not cost effective. 

4.9 BART Analysis for Superphosphoric Acid (SPA) Plants 

The superphosphoric acid (SPA) production process concentrates various grades of phosphoric acid 

by removing water. SPA plants 1 and 2 have two stage, falling film evaporators that can operate in 

parallel, series, or stand alone. SPA plants 3 and 4 have forced circulation, single stage evaporators. 

SPA plants 1 and 2 each have a venturi scrubber that controls fluoride emissions from the product 

storage tank and evaporator hotwell and discharges through stack IDs 330 and 331, respectively. 

SPA plants 3 and 4 share a common venturi scrubber that controls fluoride emissions from the 

product storage tanks and evaporator hotwells and discharges through stack ID 332. The only 

BART compound emitted by the SPA plants is SO2. 

Sulfur dioxide (SO2) is emitted during concentration of phosphoric acid due to vaporization of 

residual SO2 in the acid. Stack testing at SPA plant Nos. 1 and 2 indicates that SO2 concentrations 

present in stack gas are typically less than 10 ppmv. Actual emissions from all four plants 

combined are less than 3 tpy SO2. Essentially no SO2 is removed in the venturi scrubbers that 

control fluoride emissions from the plants due to the extremely low concentrations of SO2 present in 

the off-gases and due to the fact the pond water used in the scrubbers is slightly acidic, which 

creates no “driving force” for SO2 removal. Due to the low levels of SO2 emissions, there are no 

feasible retrofit control options; therefore, BART for the SPA plants is no additional control. 

4.10 BART Analysis for Phosphoric Acid (PA) Plants 

PCS produces green and amber phosphoric acid in four trains from the reaction of phosphate rock 

and sulfuric acid. The BART-Eligible units in the PA Plants are PA No. 1, No. 2, No. 3, and 

No. 4 Cross Flow Scrubber Stacks (IDs 401, 404, 406, and 409). The only BART compound 

emitted by these units is SO2. 

4.10.1 Sulfur Dioxide Emissions 

Sulfur dioxide is emitted from the reactors during the digestion of the phosphate rock with 

sulfuric acid. Currently, reactor exhausts are treated in crossflow packed bed scrubbers (one for 

each of the four plants) using pond water as the scrubbing media. Since SO2 is readily absorbed in 

water, some SO2 evolved in the reactors is removed by the scrubbers. Based on previous stack 

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testing conducted by PCS Phosphate, sulfur dioxide concentrations from the crossflow scrubbers 

during green and amber phosphoric acid production are approximately 35 to 65 parts per million 

volume (ppmv). Additional SO2 removal is difficult at such low concentrations. The RBLC does 

not contain any previous BACT decisions for SO2 control from phosphoric acid manufacturing. 

Therefore, engineering knowledge was used to establish BART options to be evaluated. The 

most effective methods of removing SO2 from gas streams include absorption in various liquids, 

sorption by solids, and gas phase conversions. Absorption in liquids (scrubbing) is the most 

effective method of reducing SO2 emissions from phosphoric acid plants. The scrubbing 

technologies considered in this analysis as being potentially applicable are: 

• Ammonia Scrubbing, 

• Dual Alkali Scrubbing, and 

• Caustic Scrubbing. 

Ammonia Scrubbing

The ammonia scrubbing process involves reacting ammonia with SO2 in a scrubber. The byproduct of this process is ammonium sulfate, which typically requires disposal due to its inferior 

value as a fertilizer. Industries that have used ammonia scrubbing have typically achieved SO2

removal efficiencies of around 95 percent; however, the efficiency of this technology would be 

lower at the phosphoric acid plants due to the relatively low concentration of SO2 in the crossflow 

scrubber exhaust. 

Although use of ammonia scrubbing for SO2 control has been demonstrated in other industries, it 

has never been demonstrated on a phosphoric acid plant and may therefore not be technically 

feasible for this reason. More importantly, however, ammonia scrubbing systems have proven to be 

fraught with operational difficulties and the vast majority of U.S. installations have been shut down 

due to these problems. Because this technology has not been demonstrated at phosphoric acid 

plants and that many ammonia scrubbing systems have previously proven to be unreliable, 

ammonia scrubbing was rejected from further consideration in this analysis. 

Dual Alkali Scrubbing

In this process, SO2 is treated with soluble alkaline solutions, such as sodium sulfite or sodium 

hydroxide. The product of this reaction is reacted with a second alkaline material (normally lime or 

limestone) to precipitate the absorbed SO2 as an insoluble calcium sulfite or sulfate and to 

regenerate the absorbent solution. Several alkali combinations are possible; however, 

sodium/calcium based is the most frequently used alkali combination. 

This technology has not been demonstrated at phosphoric acid plants. Further, due to the low 

exhaust concentrations and the fact that, compared to other industries using this technology, 

relatively small quantities of SO2 are being emitted, dual alkali would be less cost effective than a 

caustic scrubbing system. 

Caustic Scrubbing 

With the caustic scrubber option, the exhaust from each existing phosphoric acid plant crossflow 

scrubber would be vented to a separate, new caustic scrubber. The design would include a 

horizontal SO2 scrubber vessel (including a mist eliminator) and associated tanks, pumps, and 

piping necessary to circulate the caustic solution and filter the sulfate/sulfite salts produced. New 

stacks and fans also would be necessary, as the existing stacks come directly off of the existing 

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crossflow scrubbers and addition of a caustic scrubber would increase the pressure drop of the 

exhaust gas. The design exit SO2 concentration of a new scrubber was estimated to be 

approximately 10 ppmv, based on a maximum inlet SO2 concentration provided to the vendor of 

100 ppmv (90 percent control). Use of caustic in the existing scrubbers is not possible because of 

plugging and fouling issues and because the pond water used in the scrubbers is also used in various 

phosphoric acid operations and is critical to maintaining necessary process temperatures. 

 The total capital cost of one system for Phosphoric Acid Train No. 3 was estimated to be 

$2,650,125. The total annual cost for the scrubbing system is approximately $865,187. The cost 

effectiveness of the scrubbing system is $10,974 per ton of SO2 removal, based on an actual SO2

emission rate of 20 lb/hr for PA Train No. 3. This cost would vary somewhat for the other 3 

trains, but can be considered representative for purposes of this analysis. The overall annual 

operating cost assuming equal costs for all of the trains would be $3,460,748, and would result in 

a SO2 reduction of 265.8 tons and a visibility improvement of 0.061 dv. This equates to a cost 

effectiveness of $13,020/ton, and $213,443/ton/dv. 

4.11 BART Analysis for Shipping Area Rock Handling Sources 

The Rock Tower Loadout Facility (ID 654) has very small PM10 emissions (0.257 lb/hr) that are 

controlled by a baghouse. Enclosures and/or baghouses are typically used in industry to control 

these types of particulate matter sources. There are no other technically feasible PM control 

technologies for sources of this type and size. 

The CTS-Grinder Loadout, Rock Loadout Station, CTS-Phosphate Rock Transfer Station ChuteBarge Rock Loadout, and Chute-Train Rock Loadout (IDs 650, 651, 652, 653, 655, and 656) 

emission units represent rock transfer points in the shipping area and are enclosed to minimize 

fugitive emissions. The only additional technically feasible control would be to vent each of 

these transfer points to a baghouse. The annualized cost for adding a baghouse to each of these 

emission points is $188,440. The cost effectiveness ranges from over $19,000/ton to almost 

$3 million/ton PM10 removed. Therefore, BART for these emission sources is no additional 

controls./

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APPENDIX A 

Response to EPA Comments on Bart Permit Application 

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Enclosure 1: Control and Cost Analyses 

1. Pollution Prevention (P2) and Process Changes: 

When identifying all available retrofit control technologies, the “Guidelines for 

BART Determinations Under the Regional Haze Rule” (BART Guidelines) 

clarify that consideration should be given not only to add-on controls but also 

improvement in the performance of existing controls and P2. The analysis does 

not discuss the facility’s evaluation of options for P2 and process changes for the 

BART-eligible units, with the exception of staged air combustion. 

PCS Phosphate Response 

PCS Phosphate has evaluated our control evaluation and has not identified any 

additional industry pollution prevention practices that could be employed for the 

BART eligible units at the Aurora facility. The facility maintains all process 

equipment and control devices on a continuous basis as outlined in the Title V 

operating permit in order to minimize emissions. This proper operation and 

maintenance minimizes air emissions. In addition, the raw materials used in the 

processes are required and fixed, and thus, raw material substitution is not a 

feasible option. 

2. Cesium Catalyst Use at Sulfuric Acid (SA) Plants 3 and 4: 

In Section 4.2.1, options to control sulfur dioxide (SO2) emissions from SA 

Plants 3 and 4 are discussed. Specifically, use of cesium catalyst in beds 4 and 5 

following existing vanadium catalyst in beds 1, 2, and 3 is analyzed. Based on 

our knowledge of this facility and of acid plant processes, we have the following 

comments regarding the analysis of this option presented on page 4-5. 

• The document should explain how it was determined on which beds to install 

the cesium catalyst at the sulfuric acid plants. The facility should include an 

option that considers installation of cesium catalyst on one bed instead of two 

beds to determine what effect this would have on both emissions reduced and 

the costs of control. 

PCS Phosphate Response

Installation of the super cesium catalyst is dependent on several factors, most 

importantly, inlet temperature. Based on conversations with MECS, Inc., the 

cesium catalyst is specifically designed for lower temperature operations. The SA 

Plants 3 and 4 have the ability to lower the final pass inlet temperatures, 

therefore, installation of the super cesium catalyst was considered for beds four 

and five. 

If the super cesium catalyst were installed in only one bed; the plants would have 

to further operate at lower production rates to achieve the lower emission rates. 

This option was rejected as a feasible control scenario because decreasing the 

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production rate is neither economical nor practical from a market demand standpoint as the plants currently operate at maximum capacity. 

• The document should explain why the production rate would decrease if the 

cesium catalyst was installed at the sulfuric acid plants, particularly since 

decreased production rates serve as the basis for rejection of a reduction of 

SO2 emissions to 2.0 pounds of SO2 per ton of sulfuric acid produced (lb 

SO2/ton H2SO4). 

PCS Phosphate Response

In order for the super cesium catalyst to achieve the desired reduction levels, a 

target catalyst loading must be achieved. The catalyst loading is defined as the 

liters of catalyst required per ton of sulfuric acid produced. SA plants No. 3 and 

4 at the Aurora facility are existing units with fixed catalyst volumes, therefore, 

the only variable that could be changed to meet the 2 pounds of SO2 emission rate 

per ton of sulfuric acid produced is to significantly reduce the production rate. 

• The BART Guidelines state that the most stringent emission control level that 

the technology is capable of achieving must be taken into account (1st col., 70 

FR 39166, July 6, 2005). The facility identified this most stringent level as 

2.0 lb SO2/ton H2SO4. It is our understanding from at least one vendor that 

cesium catalyst could reduce SO2 emissions to 1.31 lb SO2/ton H2SO4. The 

State may want to explore this possibility further by checking with vendors. 

PCS Phosphate Response

The response to this comment is similar to the description presented above. To 

achieve a desired emission rate, a target catalyst loading must be obtained. The 

SA Plants No. 3 and No. 4 are equipped with catalyst beds that are fixed in size. 

A 1.31 lb SO2/ton H2SO4 emission rate would not be achievable on these plants. 

• The discussion regarding the “subsequent theoretical analysis” (p.4-5) 

evaluates the feasibility of reducing the SO2 emissions from SA Plants 3 and 

4 from 3.8 to 3.5 lb SO2/ton H2SO4. The document should explain what 

emission rates were reviewed at the sulfuric acid plants and why those 

emission rates were selected. The BART Guidelines note that while the most 

stringent control level must be considered as one of the control options, it may 

be useful to consider less stringent levels of control where these levels have 

widely varying costs and other impacts (2nd col., 70 FR 39166, July 6, 2005). 

The State may want to evaluate emission rates between 2.0 and 3.5 lb SO2/ton 

H2SO4 for their technical feasibility. 

PCS Phosphate Response

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 515 

 December 17, 2007
3

The SA Plants No. 3 and No. 4 recently obtained PSD air permits and BACT 

emission limits that are equivalent to 3.8 lb/ton averaged over 24-hours. As 

part of the BACT analysis as well as the BART analysis, the vendor MECS, 

Inc. was contacted to determine the lowest emission rate that the existing 

plants could achieve with super cesium catalyst without having a production 

penalty. In each analysis, it was determined that a super cesium catalyst in 

the 4th and 5th beds could achieve 3.5 lbs/ton. However, the cost to retrofit 

with super cesium catalyst was determined to be cost prohibitive and NCDAQ 

issued PSD permits for the equivalent 3.8 lb/ton emission rate. This continues 

to be the case for the BART evaluation. 

• It would be helpful for the document to include the turnaround schedule of the 

SA plants and describe the activities conducted during the turnaround. 

Additionally, a description of how often PCS changes the current vanadium 

catalyst at the SA plants would be informative to understand the basis for the 

some of the costs in Tables 4-2 and 4-3. For example, if PCS uses its catalyst 

beds to their maximum life, consideration might be given to aligning 

installation of the cesium catalyst with removal of spent vanadium catalyst 

during a plant turnaround period to minimize cost of installation. 

PCS Phosphate Response

PCS performs turnarounds on our sulfuric acid plants on a 2 year cycle. We are 

evaluating going to a three year cycle. During a turnaround, they inspect the 

plant and make repairs based on inspections during the turnaround. As a normal 

practice, they screen the entire first pass. Based on catalyst samples from the 

previous turnaround and pressure drop surveys, they screen one additional pass 

and screen the top section of (scalp) the remaining passes. Based on inspections 

during turnaround, they may decide not to scalp one or all of the passes not 

screened. New catalyst is loaded on the top of each bed screened or scalped to 

replace catalyst lost during the screening process. 

As a general practice, PCS does do not replace entire beds of catalyst. The 

screening process typically removes about 10% to 25% of the catalyst, depending 

on catalyst age and condition. This results in replacement of part of each bed 

every time it is screened. 

As an example, over the previous 10 years, PCS has added 77,650 liters of new 

catalyst to the first pass of the No. 3 SA Plant. PCS has added 77,960 liters of 

new catalyst to the first pass of the No. 4 SA Plant. This equates to replacement 

of 132% of the nominal catalyst volume of 59,000 liters in the first pass of each 

plant. By placing the new catalyst on the top, we maximize conversion. The new 

catalyst should have the highest activity and is effective at lower inlet 

temperatures. The older catalyst, which may have lower activity, migrates to the 

bottom of the bed. The higher temperatures near the bottom of the bed make 

activity less important. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 516 

 December 17, 2007
4

Downstream passes are replaced more slowly, as they are not completely 

screened every turnaround, but they still go through the gradual replacement 

process. The first pass serves as an effective filter for any contaminants entering 

with the sulfur or combustion air. Also, since they operate at lower outlet 

temperatures, the downstream beds of catalyst should experience slower aging 

and loss of activity than the first pass. 

PCS feels this process provides a more consistent high level of conversion than 

the alternative of operating a bed of catalyst until it reaches the end of its life and 

then replacing the entire bed. To ensure that catalyst activity is acceptable, PCS 

has periodically requested MECS to come on site and evaluate catalyst activity 

using their Pegasys process. This test evaluates the actual performance of each 

bed of catalyst during operation. It can sometimes identify problems which 

sampling and visual observation may miss. 

PCS rarely replaces an entire bed of catalyst. They replaced the first bed catalyst 

in No. 6 Sulfuric in 1990 after a process problem had impacted the catalyst so 

that none of a bed was considered acceptable for reuse. 

• Use of cesium catalyst requires lower operating temperatures, which should 

result in savings in fuel costs. This should be included in the analysis when 

evaluating the economic feasibility of this control option. 

PCS Phosphate Response

In the sulfur-burning sulfuric acid production process, liquid elemental sulfur is 

sprayed into a horizontal spray-type sulfur burner. Combustion air is drawn 

through a drying tower to remove moisture and is blown into the sulfur burner 

where it reacts with the sulfur to form sulfur dioxide. 

The formation of sulfur dioxide in this process is an exothermic reaction. In 

order to begin the conversion process the gas stream must be cooled. To achieve 

this cooling, the gas is cooled in the primary heat recovery boiler that recovers 

the heat as steam. The gas then proceeds to a super heater where a portion of the 

steam produced in the primary and secondary heat recovery boilers is further 

elevated in temperature (superheated). Steam generated from the sulfuric acid 

plant is used in various process applications throughout the plant site and to 

generate electrical power in the cogeneration facility. 

In summary, there are no fuel savings through the use of a lower operating 

temperature catalyst. 

• On page 4-5, it appears that a summary is provided of two sets of "theoretical 

analyses" for use of cesium promoted catalysts. We suggest that the 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 517 

 December 17, 2007
5

theoretical analyses, including the economic analyses, be included with the 

determination. 

PCS Phosphate Response

As stated earlier, MECS, Inc. performed an evaluation of the retrofit possibilities 

for the plants and determined that the most effective control option without 

production penalties would be to install super cesium catalyst in the 4th and 5th

beds. 

• The document should clarify whether the analysis was performed for standard 

or super Cesium-enriched catalyst. 

PCS Phosphate Response

The analyses were performed with the potential installation of the super cesium 

catalyst. 

3. BART-Eligible Emission Units: 

It would be helpful to include a list either in the document or to provide it 

separately that shows what emission units were evaluated for BART eligibility at 

the PCS facility, and the data that either supported or did not support their 

inclusion/exclusion (i.e., dates of construction, potential emissions of visibilityimpairing pollutants). Doing so will help clarify why certain units are/are not 

included for review in the document. 

PCS Phosphate Response 

“BART-eligible” emission units are those built between 1962 and 1977 that have 

the potential to emit more than 250 tons per year of one or more visibilityimpairing compounds including sulfur dioxide (SO2), nitrogen oxides (NOx), 

particulate matter (PM), and volatile organic compounds (VOC), and that fall 

within 26 industrial source categories (including phosphate fertilizer 

manufacturing). The PCS Phosphate Aurora Facility conducted the following 

analysis in 2004 at the request of the North Carolina Division of Air Quality 

(NCDAQ). Table 1-1 presents the analysis conducted for all emission units at 

the facility. Table 1-2 presents a summary listing of the units meeting the BART 

eligibility requirements. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 518 

 December 17, 2007
Table 1-1. Summary of BART-Eligibility Analysis Prepared for PCS Phosphate Aurora Facility (2004) 

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

Sulfuric Acid Plants S-3 Double-absorption sulfuric acid plant No. 3 (1850 

tons per day nominal capacity) 

101 1/14/1974 TRUE Y -- -- 14.08 40.52 8.67 25.32 397.66 1,387.00 0.00 0.61 

S-4 Double-absorption sulfuric acid plant No. 4 (1850 

tons per day nominal capacity) 

102 10/10/1975 TRUE Y -- -- 20.97 40.52 9.21 25.32 600.68 1,283.34 0.00 0.61 

S-5 Double-absorption sulfuric acid plant No. 5 (3600 

tons per day nominal capacity) 

103 3/13/1982 FALSE 

S-6 Double-absorption sulfuric acid plant No. 5 (3800 

tons per day nominal capacity) 

104 12/20/1985 FALSE 

BW-2 One (1) distillate oil-fired boiler (99.56 million 

Btu per hour nominal capacity) 

110-new 2003 FALSE 

BW-1 One (1) distillate oil-fired boiler (125 million Btu 

per hour nominal capacity) 

111 1/1/1975 TRUE Y -- -- 1.19 78.80 0.06 3.94 1.89 166.60 0.01 0.79 

417-503-462 Lime silo No. 4 at water treatment area 121 1/1/1973 TRUE Y -- -- -- -- 0.69 0.70 -- -- -- -- 417-755-462 Lime silo No. 5 at water treatment area 122 1/1/1982 FALSE 417-756-462 Lime silo No. 6 at water treatment area 123 1/1/1982 FALSE Mill Area 339-051 vertical fluidized bed phosphate rock calciner unit 

No. 1 (105.1 tons per hour nominal feed); coal/coke/”off-spec” used oils, used oil sludge/used glycols/ residual oil-fired 

201 7/1/1966 TRUE Y -- -- 65.50 138.28 21.52 

363.54 

12.12 

187.25 

0.20 0.44 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 519 

 December 17, 2007
7

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

339-052 vertical fluidized bed phosphate rock calciner unit 

No. 2 (105.1 tons per hour nominal feed); coal/coke/”off-spec” used oils, used oil sludge/used glycols/ residual oil-fired 

202 7/1/1966 TRUE Y -- -- 70.40 138.28 30.06 0.02 0.20 0.44 

339-053 vertical fluidized bed phosphate rock calciner unit 

No. 3 (105.1 tons per hour nominal feed); coal/coke / residual oil-fired 

203 10/1/1966 TRUE Y -- -- 68.50 138.28 72.00 0.02 0.20 0.44 

339-054 vertical fluidized bed phosphate rock calciner unit 

No. 4 (105.1 tons per hour nominal feed); coal/coke / residual oil-fired 

204 10/1/1966 TRUE Y -- -- 55.01 138.28 48.79 0.01 0.20 0.44 

339-055 vertical fluidized bed phosphate rock calciner unit 

No. 5 (105.1 tons per hour nominal feed); coal/coke / residual oil-fired 

205 1/1/1976 TRUE Y -- -- 58.07 138.28 38.15 0.01 0.20 0.44 

339-056 vertical fluidized bed phosphate rock calciner unit 

No. 6 (105.1 tons per hour nominal feed); coal/coke / residual oil-fired 

206 1/1/1976 TRUE Y -- -- 71.11 138.28 67.73 0.02 0.20 0.44 

332-120 Residual oil-fired phosphate rock dryer (250 tons 

per hour nominal capacity) 

210 1/1/1966 TRUE Y -- -- 1.30 149.36 1.50 235.43 0.00 13.69 0.01 0.74 

341-300 Coal/coke pulverizer and thermal dryer system (20 

tons per hour nominal capacity) 

215 1/1/1983 FALSE 

Belt 39 to 70.1 Calcined rock CTS (Fugitive) 220 1/1/1966 TRUE Y -- -- -- -- 1.20 3.46 -- -- -- -- Belt 55 to Belt 70.1 Calcined rock CTS Baghouse 221 1/1/1974 TRUE Y -- -- -- -- 1.80 1.80 -- -- -- -- 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 520 

 December 17, 2007
8

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

Belt 21 to Belt 23 or Belt 24 

Storage silo baghouse 222 1/1/1966 TRUE Y -- -- -- -- 1.30 1.31 -- -- -- -- 

Belt 22 to Belt 23 or Belt 24 

Storage silo baghouse 

339-809-464 Calcined/dried rock CTS (Fugitive) 223 1/1/1966 TRUE Y -- -- -- -- 1.20 3.46 -- -- -- -- 224 One (1) polymer storage bin 224 1/1/1996 FALSE 225 One (1) lime storage silo 225 1/1/1985 FALSE F290 Mill Concentrator Fugitives 290 7/1/1966 TRUE N F291 Calciner Plant Area Fugitives 291 7/1/1966 TRUE Y -- -- -- -- 0.11 0.11 -- -- -- -- F292 Surge Pond Aerator 292 7/1/1966 TRUE N 341-100 Coal/coke railcar unloader (75 tons per hour 

nominal capacity) 

294a 1/1/1983 FALSE 

341-110, 341-111, 341-112, 341-120 

Three (3) parallel conveyor belts which transfer to one (1) single belt conveyor 

294b 1/1/1983 FALSE 

341-140 Single belt conveyor 294c 1/1/1983 FALSE 341-130 Coal/coke crusher (75 tons per hour nominal 

capacity) 

294d 1/1/1983 FALSE 

341-200 341-201 Two (2) coal/coke storage silos (1086 tons, 

nominal capacity each) 

294e 1/1/1983 FALSE 

341-230 One (1) conveyor belt 294f 1/1/1983 FALSE Fertilizer Production Area 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 521 

 December 17, 2007
9

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

504-107 504-016 Diammonium Phosphate Plant No. 1 combustion 

chamber and residual oil-fired dryer (Nominal maximum input rates of 618 tons fresh P2O5 and 275 tons of product per hour) 

301 12/1/1966 TRUE Y 56.50 186.70 3.72 32.11 14.64 152.25 0.27 138.30 0.03 0.18 

504-009 504-001 504-058 504-059 504-060 504-061 504-043 504-042 504-002 

Diammonium Phosphate Plant No. 1 cooler and material sizing and handling equipment (process screen feed drag conveyor, four (4) double-decked process screens, east cage mill, west cage mill, and recycle drag conveyor) 

301 

504-016 504-009 Diammonium Phosphate Plant No. 1 residual oilfired dryer(20 million Btu per hour nominal 

maximum heat input) and a cooler 

301 

504-030 504-032 Diammonium Phosphate Plant No. 1 reactor and 

granulator 

301 

504-030 301 504-032 504-016 504-019 

Diammonium Phosphate Plant No. 1 reactor, granulator, residual oil-fired dryer and cooler. 

511-085 511-086 511-070 

Diammonium Phosphate Plant No. 3 first stage reactor, second stage reactor, and granulator 

302 7/1/1974 TRUE Y 149.50 453.13 17.29 60.71 14.29 58.15 0.64 160.50 0.04 0.31 

302 511-032 Diammonium Phosphate Plant No. 3 residual oilfired dryer 

511-008 511-009 511-010 511-011 511-016 511-017 511-038 511-039 511-041 511-093 511-094 511-095 511-096 

Diammonium Phosphate Plant No. 3 process sizing and handling equipment (four (4) chain mills, screen feed drag conveyor, recycle drag conveyor, recycle elevator, dryer elevator, product elevator, and four (4) double-deck product screens) 

302 

511-025 Diammonium Phosphate Plant No. 3 cooler and 

other miscellaneous material handling points 

302 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 522 

 December 17, 2007
10

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

511-107B 511-103 511-104 511-106 

Diammonium Phosphate Plant No. 3 cyclonic scrubber, the two stage dryer wet cyclonic scrubber, the dust wet cyclonic scrubber, and the cooler wet cyclonic scrubber 

302 

505-104 Diammonium Phosphate Plant No. 2 residual oilfired dryer 303 505-107 505-114 505-110 505-143 

Diammonium Phosphate Plant No. 2 material sizing and handling equipment (eight (8) process screens, one (1) scalping screen, one (1) recycle drag conveyor, and a product bin) 

303 

505-111 Diammonium Phosphate Plant No. 2 cooler 303 505-123C 505-123B Diammonium Phosphate Plant No. 2 equipment 

cyclone and cooler duplex cyclone 

303 

505-103 505-121 Diammonium Phosphate Plant No. 2 granulator 

and reactor 

303 

505-117 505-118 Diammonium Phosphate Plant No. 2 cooler 

venturi wet scrubber and reactor-granulator 

venturi wet scrubber 

303 

1/1/1980 FALSE 

APP-1 Ammonium Polyphosphate Plant 304 1989 FALSE AFP-1 One (1) filter press 305 2003 FALSE 511-045 Diammonium Phosphate Plant No. 3 GTSP 

phosphate rock silo 

310 3/1/1976 TRUE Y -- -- -- -- 0.52 4.51 -- -- -- -- 

PA Pilot No. 1 Phosphoric Acid Pilot Plant No. 1 315 1978 FALSE PA Pilot No. 2 Phosphoric Acid Pilot Plant No. 2 316 1978 FALSE 318 Technical Services Dust Collection System 318 9/1/1979 FALSE 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 523 

 December 17, 2007
11

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

Superphosphoric Acid Production Area 451-418 and 451-409 

Superphosphoric acid plant No. 1 330 11/1/1966 TRUE Y -- -- -- -- -- -- 0.49 5.48 -- -- 

451-701 and 451-809 

Superphosphoric acid plant No. 2 331 1/1/1971 TRUE Y -- -- -- -- -- -- 1.33 9.13 -- -- 

451-316 and 451-308 

Superphosphoric acid plant No. 3 332 1/1/1976 TRUE Y -- -- -- -- -- -- 0.54 18.25 -- -- 

451-916 and 451-940 

Superphosphoric acid plant No. 4 332 

FPR-1 FPR-2 

No. 1 filter press/filter press repulp tank and No. 2 filter press/filter press repulp tank 

335 and 336 9/1/1985 FALSE 

453-485 One (1) potassium permanganate silo 340 3/1/1990 FALSE 453-468 One (1) clay additive storage silo 341 3/1/1990 FALSE DAP1WH1 Warehouse No. 1 for DAP 1 390 1/1/1967 TRUE Y 33.90 33.90 -- -- -- -- -- -- -- -- DAP2WH2 Warehouse No. 2 for DAP 2 390 DAP3WH3 Warehouse No. 3 for DAP 3 390 

Fertilizer Plant Area Fugitives 391, 392 1/1/1967 TRUE Y 20.72 20.72 -- -- -- -- -- -- -- -- 

Phosphoric Acid Production Area 421-201 421-000 421-325 421-324 421-327 421-326 421-223 421-232 421-218 421-330 

Reactor Train No. 1; tilting pan (Bird) filter No. 1; tilting pan (Bird) filter No. 1 primary vacuum pump installed on primary vacuum separator; secondary vacuum pump installed on secondary vacuum separator; (2) barometric condensers vacuum pumps; barometric condensers hotwell; and tilting pan (Bird) filter No. 1 seal tanks. 

401 12/1/1966 TRUE Y -- -- -- -- -- -- 21.70 88.70 -- -- 

441-000 Belt filter No. 1 402 4/1/1981 FALSE 441-000 442-000 441-031 

Belt filter No. 1, belt filter No. 2, and belt filter No. 1 seal tanks 

403 4/1/1981 FALSE 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 524 

 December 17, 2007
12

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

422-201 422-000 422-325 422-324 422-327 422-326 422-223 422-232 422-218 422-330 

Reactor Train No. 2; tilting pan (Bird) filter No. 2; tilting pan (Bird) filter No. 2 primary vacuum pump installed on primary vacuum separator; secondary vacuum pump installed on secondary vacuum separator; (2) barometric condensers vacuum pumps; barometric condensers hotwell; and tilting pan (Bird) filter No. 2 seal tanks. 

404 12/1/1966 TRUE Y -- -- -- -- -- -- 26.40 88.70 -- -- 

442-000 Belt filter No. 2 filtrate separator 405 12/1/1985 FALSE 423-201 423-000 423-325 423-324 423-327 423-326 423-223 423-232 423-218 423-330 

Reactor Train No. 3; tilting pan (Bird) filter No. 3; tilting pan (Bird) filter No. 3 primary vacuum pump installed on primary vacuum separator; secondary vacuum pump installed on secondary vacuum separator; (2) barometric condensers vacuum pumps; barometric condensers hotwell; and tilting pan (Bird) filter No. 3 seal tanks. 

406 1/1/1972 TRUE Y -- -- -- -- -- -- 34.10 175.20 -- -- 

443-000 Belt filter No. 3 filtrate separator 407 9/1/1986 FALSE 443-000 444-000 444-031 

Belt filter No. 3, belt filter No. 4, and belt filter No. 4 seal tanks 

408 9/1/1986 FALSE 

424-201 Y -- -- -- -- -- -- 14.10 102.60 -- -- 428-753 424-000 424-325 424-324 424-327 424-326 424-223 424-232 424-218 424-330 

Reactor Train No. 4; fluosilicic acid (H2SiF6) 

recycle tank; tilting pan (Bird) filter No. 4; tilting pan (Bird) filter No. 4 primary vacuum pump installed on primary vacuum separator; secondary vacuum pump installed on secondary vacuum separator; (2) barometric condensers vacuum pumps; barometric condensers hotwell; and tilting pan (Bird) filter No. 4 seal tanks. 

409 10/1/1975 TRUE 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 525 

 December 17, 2007
13

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

444-000 Belt filter No. 4 410 10/1/1980 FALSE 040 and 020 Two (2) phosphoric acid storage tanks 421 10/1/1980 FALSE 032, 033, 034, 060, and 035 

Four (4) phosphoric acid storage tanks and one (1) green acid sludge tank 

422 12/1/1980 FALSE 

429-002 421-115 Two (2) phosphate rock jet conveyors on reactor 

train No. 1 

430 1/1/1988 FALSE 

429-005 422-115 Two (2) phosphate rock jet conveyors on reactor 

train No. 2 

431 4/1/1988 FALSE 

429-152 429-001 429-004 429-151 

Phosphate rock storage silo No. 1 and three (3) transfer points 

434 7/1/1985 FALSE 

429-150 Phosphate rock transfer house 437 12/1/1966 TRUE Y -- -- -- -- 2.39 1.20 -- -- -- -- 426-156 433-158 433-165 

One (1) slurry mix tank, one (1) clarifier, and one (1) defluorinated acid pump tank 

450 5/1/1993 FALSE 

426-154 One (1) diatomaceous earth silo 451 4/1/1980 FALSE ES461 ES462 

One (1) phosphoric acid recirculation water cooling tower consisting of two (2) fans 

461 and 462 7/1/1992 FALSE 

None Phosphoric Acid Plant Fugitives 491 1/1/1966 TRUE N 30 N 31 428-440 428-442 433-182 

Two (2) phosphoric acid storage tanks (phosphoric acid tank farm), two (2) HFSA tanks, and one (1) carbon slurry tank 

492 1/1/1966 TRUE 

Purified Acid Production Area 

All sources 1989, 2002 FALSE 

DFP Production Area 

All sources 2001 FALSE 

Shipping Area Ammonia Unloading 

Ammonia Railroad Unloading 601, 602, 

and 603 

1/1/1966 TRUE Y 47.17 47.17 -- -- -- -- -- -- -- -- 

Ammonia Tanks Ammonia Storage Tanks 604 and 605 1/1/1981 FALSE Sulfur Unloading Sulfur Railroad Unloading 610, 611, 

612, 613, 

and 614 

1/1/1966 TRUE N 

Railcar Wash 1 Railcar Wash Station No. 1 615 1/1/1966 TRUE N 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 526 

 December 17, 2007
14

Emission Source 

ID No. Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

NH3 2002 

Actual, 

tpy 

NH3 

PTE, tpy 

NOx 2002 

Actual, 

tpy 

NOx 

PTE, tpy 

PM10 

2002 

Actual, 

tpy 

PM10 

PTE, tpy 

SO2 2002 

Actual, 

tpy 

SO2 PTE, 

tpy 

VOC 

2002 

Actual, 

tpy 

VOC 

PTE, tpy 

T-002 to T-012 T014 to T-019 Y 1.06 1.06 -- -- -- -- -- -- 5.30 21.2 T-021 to T-029 T-44 T-050 to T-052 T-054 to T-056 

Thirty-three (33) phosphoric acid storage tanks (shipping tank farm) 

616 

453-458 One (1) superphosphoric acid aging tank (shipping 

tank farm) 

616 

AT2 One (1) superphosphoric acid aging tank (shipping 

tank farm) 

616 

497-4-105 One (1) superphosphoric acid and clay additive 

mix tank (shipping tank farm) 

616 

No. 1 filter press feed tank No. 2 filter press feed tank and 

453-115 453-412 

No. 3 filter press feed tank 

616 

VSEP Tank One (1) 5,000 gallon VSEP feed tank 616 Black Lomag One (1) 110,000 gallon Black Lomag tank 616 Permeate Tank One (1) 1,000 gallon permeate tank 616 Concentrate Tank One (1) 1,000 gallon concentrate tank 616 552-003 552-005 552-050 

Three (3) liquid sulfur storage tanks 616 

1/1/1966 TRUE 

Railcar Wash 2 Railcar Wash Station No. 2 617 1/1/1966 TRUE N F650 CTS - Grinder Rock Loadout 650 1/1/1966 TRUE Y -- -- -- -- 0.00 0.07 -- -- -- -- F651 CTS - Grinder Rock Loadout 651 1/1/1966 TRUE Y -- -- -- -- 0.00 0.07 -- -- -- -- F652 Rock Loadout Transfer Station 652 1/1/1966 TRUE Y -- -- -- -- 0.00 4.01 -- -- -- -- F653 CTS - Phosphate Rock Transfer Station 653 1/1/1966 TRUE Y -- -- -- -- 0.00 4.01 -- -- -- -- F654 Rock Tower Loadout facility 654 1/1/1966 TRUE Y -- -- -- -- 0.00 1.13 -- -- -- -- F655 Chute-Barge Rock Loadout 655 1/1/1966 TRUE Y -- -- -- -- 0.00 4.01 -- -- -- -- F656 Chute-Train Rock Loadout 656 1/1/1966 TRUE Y -- -- -- -- 0.00 9.70 -- -- -- -- Miscellaneous Sources 214-613 Mine Pit Diesel Generator 801 2001 FALSE 326-800-484 Calciner Building Diesel Generator 802 not 

installed 

FALSE 

Sum 309 743 447 1,232 336 903 1,112 3,825 7 27 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 527 

 December 17, 2007
Table 1-2. Summary of Units Potentially BART-Eligible 

Emission 

Source ID 

No. 

Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

S-3 

Double-absorption sulfuric acid 

plant No. 3 (1850 tons per day 

nominal capacity) 

101 1/14/1974 TRUE Y 

S-4 

Double-absorption sulfuric acid 

plant No. 4 (1850 tons per day 

nominal capacity) 

102 10/10/1975 TRUE Y 

BW-1 

One (1) distillate oil-fired boiler 

(125 million Btu per hour nominal 

capacity) 

111 1/1/1975 Shutdown Y 

417-503-

462 

Lime silo No. 4 at water treatment 

area 

121 1/1/1973 TRUE Y 

339-051 

vertical fluidized bed phosphate 

rock calciner unit No. 1 (105.1 

tons per hour nominal feed); 

coal/coke/”off-spec” used oils, 

used oil sludge/used glycols/ 

residual oil-fired 

201 7/1/1966 TRUE Y 

339-052 

vertical fluidized bed phosphate 

rock calciner unit No. 2 (105.1 

tons per hour nominal feed); 

coal/coke/”off-spec” used oils, 

used oil sludge/used glycols/ 

residual oil-fired 

202 7/1/1966 TRUE Y 

339-053 

vertical fluidized bed phosphate 

rock calciner unit No. 3 (105.1 

tons per hour nominal feed); 

coal/coke / residual oil-fired 

203 10/1/1966 TRUE Y 

339-054 

vertical fluidized bed phosphate 

rock calciner unit No. 4 (105.1 

tons per hour nominal feed); 

coal/coke / residual oil-fired 

204 10/1/1966 TRUE Y 

339-055 

vertical fluidized bed phosphate 

rock calciner unit No. 5 (105.1 

tons per hour nominal feed); 

coal/coke / residual oil-fired 

205 1/1/1976 TRUE Y 

339-056 

vertical fluidized bed phosphate 

rock calciner unit No. 6 (105.1 

tons per hour nominal feed); 

coal/coke / residual oil-fired 

206 1/1/1976 TRUE Y 

332-120 

Residual oil-fired phosphate rock 

dryer (250 tons per hour nominal 

capacity) 

210 1/1/1966 TRUE Y 

Belt 39 to 

70.1 Calcined rock CTS (Fugitive) 220 1/1/1966 TRUE Y 

Belt 55 to 

Belt 70.1 Calcined rock CTS Baghouse 221 1/1/1974 TRUE Y 

Belt 21 to 

Belt 23 or 

Belt 24 

Storage silo baghouse 222 1/1/1966 TRUE Y 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 528 

 December 17, 2007
16

Emission 

Source ID 

No. 

Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

339-809-

464 

Calcined/dried rock CTS 

(Fugitive) 223 1/1/1966 TRUE Y 

F290 Mill Concentrator Fugitives 290 7/1/1966 TRUE N 

F291 Calciner Plant Area Fugitives 291 7/1/1966 TRUE Y 

F292 Surge Pond Aerator 292 7/1/1966 TRUE N 

504-107 

504-016 

Diammonium Phosphate Plant 

No. 1 combustion chamber and 

residual oil-fired dryer (Nominal 

maximum input rates of 618 tons 

fresh P2O5 and 275 tons of 

product per hour) 

301 12/1/1966 Shutdown Y 

511-085 

511-086 

511-070 

Diammonium Phosphate Plant 

No. 3 first stage reactor, second 

stage reactor, and granulator 

302 7/1/1974 TRUE Y 

511-045 Diammonium Phosphate Plant 

No. 3 GTSP phosphate rock silo 310 3/1/1976 TRUE Y 

451-418 

and 451-

409 

Superphosphoric acid plant No. 1 330 11/1/1966 TRUE Y 

451-701 

and 451-

809 

Superphosphoric acid plant No. 2 331 1/1/1971 TRUE Y 

451-316 

and 451-

308 

Superphosphoric acid plant No. 3 332 1/1/1976 TRUE Y 

DAP1WH1 Warehouse No. 1 for DAP 1 390 1/1/1967 Shutdown Y 

 Fertilizer Plant Area Fugitives 391, 392 1/1/1967 Shutdown Y 

421-201 

421-000 

421-325 

421-324 

421-327 

421-326 

421-223 

421-232 

421-218 

421-330 

Reactor Train No. 1; tilting pan 

(Bird) filter No. 1; tilting pan 

(Bird) filter No. 1 primary 

vacuum pump installed on 

primary vacuum separator; 

secondary vacuum pump installed 

on secondary vacuum separator; 

(2) barometric condensers vacuum 

pumps; barometric condensers 

hotwell; and tilting pan (Bird) 

filter No. 1 seal tanks. 

401 12/1/1966 TRUE Y 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 529 

 December 17, 2007
17

Emission 

Source ID 

No. 

Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

422-201 

422-000 

422-325 

422-324 

422-327 

422-326 

422-223 

422-232 

422-218 

422-330 

Reactor Train No. 2; tilting pan 

(Bird) filter No. 2; tilting pan 

(Bird) filter No. 2 primary 

vacuum pump installed on 

primary vacuum separator; 

secondary vacuum pump installed 

on secondary vacuum separator; 

(2) barometric condensers vacuum 

pumps; barometric condensers 

hotwell; and tilting pan (Bird) 

filter No. 2 seal tanks. 

404 12/1/1966 TRUE Y 

423-201 

423-000 

423-325 

423-324 

423-327 

423-326 

423-223 

423-232 

423-218 

423-330 

Reactor Train No. 3; tilting pan 

(Bird) filter No. 3; tilting pan 

(Bird) filter No. 3 primary 

vacuum pump installed on 

primary vacuum separator; 

secondary vacuum pump installed 

on secondary vacuum separator; 

(2) barometric condensers vacuum 

pumps; barometric condensers 

hotwell; and tilting pan (Bird) 

filter No. 3 seal tanks. 

406 1/1/1972 TRUE Y 

424-201 

Reactor Train No. 4; fluosilicic 

acid (H2SiF6) recycle tank; tilting 

pan (Bird) filter No. 4; tilting pan 

(Bird) filter No. 4 primary 

vacuum pump installed on 

primary vacuum separator; 

secondary vacuum pump installed 

on secondary vacuum separator; 

(2) barometric condensers vacuum 

pumps; barometric condensers 

hotwell; and tilting pan (Bird) 

filter No. 4 seal tanks. 

409 10/1/1975 TRUE Y 

429-150 Phosphate rock transfer house 437 12/1/1966 TRUE Y 

None Phosphoric Acid Plant Fugitives 491 1/1/1966 TRUE N 

30 

Two (2) phosphoric acid storage 

tanks (phosphoric acid tank farm), 

two (2) HFSA tanks, and one (1) 

carbon slurry tank 

492 1/1/1966 TRUE N 

Ammonia 

Unloading Ammonia Railroad Unloading 601, 602, and 603 1/1/1966 TRUE Y 

Sulfur 

Unloading Sulfur Railroad Unloading 

610, 611, 

612, 613, 

and 614 

1/1/1966 TRUE N 

Railcar 

Wash 1 Railcar Wash Station No. 1 615 1/1/1966 TRUE N 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 530 

 December 17, 2007
18

Emission 

Source ID 

No. 

Emission Source Description 

Emission 

Point ID 

No. 

Date of 

Operation 

BART 

Eligible? 

Emits BART 

Compounds? 

T-002 to T012 T-014 

to T-019 

Thirty-three (33) phosphoric acid 

storage tanks (shipping tank farm) 616 1/1/1966 TRUE N 

Railcar 

Wash 2 Railcar Wash Station No. 2 617 1/1/1966 TRUE N 

F650 CTS - Grinder Rock Loadout 650 1/1/1966 TRUE Y 

F651 CTS - Grinder Rock Loadout 651 1/1/1966 TRUE Y 

F652 Rock Loadout Transfer Station 652 1/1/1966 TRUE Y 

F653 CTS - Phosphate Rock Transfer 

Station 653 1/1/1966 TRUE Y 

F654 Rock Tower Loadout facility 654 1/1/1966 TRUE Y 

F655 Chute-Barge Rock Loadout 655 1/1/1966 TRUE Y 

F656 Chute-Train Rock Loadout 656 1/1/1966 TRUE Y 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 531 

 December 17, 2007
4. Lost Production Costs: 

There is no indication of whether the facility considered ways to mitigate the 

costs attributed to 10 days of “Lost Production” listed in Table 4-14 ($1,649,250). 

These costs account for approximately 62 percent of the total capital costs for a 

new SO2 scrubbing system following a phosphoric acid crossflow scrubber. For 

example, the facility should consider the effects on lost production if potential 

controls were installed during an already planned plant shutdown for 

maintenance, or when one of the units is off-line. Also, the possibility of 

increasing production significantly prior to and following the shut down to offset 

any lost production should be discussed. It is not clear whether the facility 

considered these types of possibilities and their effects on lost production costs. 

PCS Phosphate Response 

 

Table 4-14 refers to the Phosphoric Acid Train No. 3. PA Train 3 routinely 

operates at maximum capacity to meet the production demands of the facility; 

therefore, there are not significant blocks of time to conduct the modification 

when one unit is off-line. 

5. Capital Recovery and Contingencies: 

a) The facility should justify its capital recovery cost assumptions (i.e., equipment 

life and rate of return) listed in Tables 4-2, 4-3, 4-9, 4-10, 4-11, 4-13, 4-14 and 4-

15. If these assumptions differ from the EPA Cost Manual, the document should 

provide justification. 

PCS Phosphate Response 

Please refer to the following excerpt from page 2-13 of EPA’s Cost Control 

Manual: 

“Analysts use the interest rate to estimate the time value of money. It can 

be thought of as a return on investment or the cost of borrowing. The 

interest rate employed in this Manual differs from that used in nongovernmental financial analyses. It represents a social interest rate

established by the Office of Management and Budget (OMB) for the 

comparison of public policy issues. 

OMB sets the social interest rate for governmental analyses and it is 

currently set at seven percent. 

However, the social rate of interest is not appropriate for industry. When 

choosing between alternative air pollution control devices, the industrial 

planner must not only take into consideration the costs of each device, 

they must also understand how the cost of each device fits into the 

financial structure of their business. Furthermore, a number of air 

regulations allow sources of pollution to petition for extensions on 

deadlines, variances from the regulation, or exemption from installing 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 532 

 December 17, 2007
20

control devices, based upon the economic impact that equipment would 

have upon the source. In these cases, the source may find it useful to 

apply their own interest rate to the calculation of control costs. Common 

interest rates used by industry and accepted by the EPA for source 

petitions include the business’ current borrowing rate, the current prime 

rate, and other acceptable industrial rates of return.”

The application of a 7% interest rate is not appropriate for this analysis, and 

furthermore, the EPA Cost Control Manual does not require the use of 7% as 

discussed above. The 15% rate is being used to account for the project costs 

as well as for the lost capital available for funding other projects that could have 

positive return on investment at the facility.

b) Tables 4-14 and 4-15 list a contingency factor of fifteen and three percent, 

respectively. We recommend that the document provide a justification for any 

contingency factors used since there can be considerable variation in contingency 

factors across technologies, processes, and conditions at individual sites. The 

justification of a contingency factor should clarify the reason for the specific 

percentage applied. 

PCS Phosphate Response 

As stated in EPA’s Cost Control Manual: 

“Probably the most subjective part of a cost estimate occurs when the 

control system is to be installed on an existing facility. Unless the 

original designers had the foresight to include additional floor space and 

room between components for new equipment, the installation of 

retrofitted pollution control devices can impose an additional expense to 

“shoe-horn” the equipment into the right locations.” 

Table 4-14 details the costs associated with the installation of a scrubber on PA 

Train No. 3. Retrofit installations of scrubbing systems frequently require 

additional changes and modifications (i.e., piping, fans, etc) that were not 

included in the original cost estimates. Therefore, a contingency factor (or 

retrofit factor) of 15% was used in the analysis. Table 4-15 details the 

installation of a fabric filter on units 650-656. Retrofit installations of fabric 

filters should be much easier than the installation of a wet scrubber, therefore, a 

contingency factor (or retrofit factor) of 3% was used in the analysis. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 533 

 December 17, 2007
21

6. Piping Costs in Table 4-14

The piping costs listed in Table 4-14 do not appear to correctly use the piping 

factor provided in Chapter 1 in Section 5 of EPA’s Cost Manual. The factor 

applied to piping is 0.30 multiplied by the purchased equipment cost (B). The 

PCS document lists two types of piping, each applying a factor of 0.30B. This, in 

essence, is double counting the piping costs and is not an appropriate use of the 

Cost Manual piping cost factor. If the facility does not want to use the Cost 

Manual factor as described, the facility could instead provide specific cost 

estimates for the two types of piping listed. 

PCS Phosphate Response 

One of the entries is accounting for the piping associated with routing utilities to 

the proposed scrubber. This includes compressed air and water for operation of 

the scrubber. The second entry is accounting for ductwork associated with 

routing the exhaust to the scrubber. These are separate items and are not 

“double-counting” the piping costs associated with the installation of the 

scrubber. 

7. Incremental Maintenance Costs: 

Tables 4-9, 4-10, 4-13 list “incremental maintenance costs” with a factor of “2.75 

percent of TCC” (total capital costs) based on the Cost Manual. We are unclear 

from where in the Cost Manual the factor of “2.75 percent of TCC” is derived. 

Also, if this cost category refers to additional maintenance costs associated with 

operation of a control device, we agree it should be part of the direct annual costs. 

As such, we believe these costs should not be based on capital costs as depicted 

by the factor description. 

PCS Phosphate Response 

Higher maintenance costs associated with low-NOx burner systems is well known 

in the industry. This is because the more precise control of peak flame 

temperatures needed to minimize NOx formation requires more strict burner 

performance requirements and, therefore, resulting in higher maintenance costs. 

Some EPA cost methodologies break out increased maintenance costs into 1) 

maintenance labor, typically a number of hours per shift, and 2) maintenance 

capital, typically considered a percentage of maintenance labor. It has been our 

experience that in situations where only intermittent labor activities are needed, 

such as for a low-NOx burner, manufacturers will frequently apply an overall 

“percent of capital cost” to give customers an idea of true maintenance cost. 

8. References in the Cost Tables

In the cost tables provided in the document, there are references to vendor quotes 

listed in the “Basis” and “Basis/Comments” sections. To aid review of the 

document, we suggest that the document include the vendor quotes (e.g., “E-mail 

from John Horne” cited in Tables 4-2 and 4-3) as part of the document. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 534 

 December 17, 2007
22

PCS Phosphate Response 

We have attached information received from vendors. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 535 

 December 17, 2007
23

Enclosure 2: Modeling Analysis

1. Modeling Scenario #2 Visibility Estimates – Table 5-5

The modeled visibility impacts for Scenario #2 reflect the reduction of SO2

emissions from Sulfuric Acid Plants 3 and 4 from 3.8 lb SO2/ton H2SO4 to 3.5 lb 

SO2/ton H2SO4. EPA’s Comment # 2 in Enclosure 1 indicates that use of the 

cesium catalyst could reduce SO2 emission rates to between 2.0 and 3.5 lb 

SO2/ton H2SO4. If it is determined that lower SO2 emission rates are feasible and 

appropriate, the modeling for Scenario #2 should be redone to evaluate the 

visibility impacts. A SO2 emission rate of 2.0 lb SO2/ton H2SO4 would likely 

result in a significant reduction of the modeled visibility impacts at the 

Swanquarter Class I area. 

PCS Phosphate Response 

Emission rates lower than 3.5 lb/ton are not feasible without a production 

penalty, thus no modeling analyses were performed for lower emission rates. 

2. Baseline PM Emission Rates – Table 3-5

The baseline PM emission rates for Source ID#’s 201 through 206 (Calciners #1-

#6) listed in Table 3-5 are different than those presented in the October 2, 2006, 

BART Exemption Modeling Report. This appears to be a result of a change in the 

throughput from 113.5 tons feed/hr to 105.1 tons feed/hr. It is not understood 

why the throughput during the baseline condition would be different than that 

used in the October 2, 2006, BART Exemption Modeling Report. An explanation 

should be provided for these differences. 

PCS Phosphate Response 

Recent stack performed at PCS was performed at a maximum achievable 

production rate of 105.1 tons feed per hour. Thus, the permit has been revised 

with the lower production rates to be consistent with stack testing and permit 

requirements. 

3. Modeled Stack Parameters for Source ID #’s 437 and 654 – Table 5-1

The modeled stack parameters for Source ID # 437 (Calcined Rock CTS 

Baghouse) and Source ID# 654 (Rock Tower Loadout Baghouse) are different 

than those presented in the October 2, 2006, BART Exemption Modeling Report. 

An explanation should be provided for these differences. 

PCS Phosphate Response 

Source ID# 654 is no longer used at the facility. We inadvertently reported the 

stack parameters for Source ID #437 incorrectly in Table 5-1 of the BART 

evaluation report. 

4. Use of the New IMPROVE Equation – Section 5.8

(a) Section 5.8 of the determination report indicates that visibility impacts 

presented in the report were developed using the New IMPROVE equation as 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 536 

 December 17, 2007
24

implemented in an external spreadsheet created by Dr. Ivar Tombach. The report 

does not provide any discussion of the rationale for using the New IMPROVE 

algorithm instead of the default IMPROVE algorithm that is contained in 

CALPOST. The report should provide justification for using the new algorithm. 

(b) The report should reference the fact that the spreadsheets are contained on the 

CD that was submitted with the report. The version of the spreadsheet that is 

contained on the CD is different than that used in the October 2, 2006, BART 

Exemption Modeling Report in that it does not include the nitrogen dioxide term 

that is contained in the New IMPROVE Algorithm. EPA Region 4’s position on 

the use of the New IMPROVE algorithm is that any methodology used to 

implement the algorithm must address the entire algorithm (See additional 

discussion of this issue is contained in Attachment A – “U.S. EPA Region 4 

Review of the VISTAS Methodology for Implementing the New IMPROVE 

Equation with CALPUFF for BART Modeling”). EPA Region 4’s comments on 

the October 2, 2006, BART Exemption Modeling Report indicated that additional 

supporting documentation was needed to allow the use of the spreadsheet that 

incorporates the nitrogen dioxide term. These comments were not meant to 

suggest that PCS Phosphate should use the older form of the spreadsheet that does 

not include the nitrogen dioxide term, but that additional explanation was needed 

to allow use of the new spreadsheet. The nitrogen dioxide term may be especially 

important when comparing different control options since some of the options 

would reduce the NOx emissions and thus would affect the estimated nitrogen 

dioxide concentration. The rationale for using a methodology that does not 

include the nitrogen dioxide term should be provided by PCS Phosphate. 

PCS Phosphate Response 

The modeling methodology was reviewed and approved in the modeling protocols 

submitted to the NCDAQ. In addition, the New IMPROVE equation was 

approved and provided to us by NCDAQ for use in the BART modeling report. 

5. Visibility Impact Thresholds (Section 4.1.5, P. 4-3; Section 1.2, P. 1-1) 

Section 4.1.5 provides a summary of Step 5 of the BART Guidelines. The second 

paragraph of this section states: “If the net visibility improvement is less than the 

comparison threshold, then there is no need for the facility to implement the 

control technologies because the resulting visibility impacts would be negligible.” 

The BART Guidelines do not make such an assertion. Rather, the Guidelines 

provide flexibility to the States with setting thresholds and weighing each of the 

BART factors. (See 70 FR 39170, 1st col., July 6, 2005.) All of the statutory 

factors should be used in the determination of whether or not BART controls are 

needed. Visibility improvement based on modeling results is only one of the 

factors that should be assessed in this decision. 

Similarly, the document states on page 1-1 of Section 1.2 that, “...the additional 

controls will not result in a visibility improvement that EPA has states is 

perceivable to the human eye...” This statement implies that the controls are not 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 537 

 December 17, 2007
25

considered to make enough of an improvement in visibility at the Class I areas 

identified in the report. We note, however, that there is no bright line for 

evaluating in the BART determination analysis the degree of visibility 

improvement that is considered significant enough to warrant BART controls. 

Rather, a State has flexibility in setting absolute thresholds and determining the 

weight and significance to be assigned to each BART factor. (See 70 FR 39170, 

1st col., July 6, 2005.) Also, this statement does not recognize that a source may 

be contributing to visibility impairment at a Class I area. A source is contributing 

to visibility impairment if its impacts are 0.5dv or higher, which is below the 

1.0dv threshold referenced by the document as what is perceivable to the human 

eye. 

PCS Phosphate Response 

The Regional Haze Rule defines “visibility impairment” as “any humanly

perceptible change in visibility from that which would have existed under natural 

conditions” (see Federal Register Vol. 64, No. 126, page 35764). EPA states 

numerous times in the preamble and the rule that these thresholds are humanly

perceptible thresholds (see Federal Register Vol. 70, No. 128, page 39119, 

footnote 28 and page 39120, footnote 32). This is the basis for using human 

perception in the report. 

In order to evaluate the various control scenarios as part of the BART evaluation, 

the change in visibility was determined for the mill as compared to natural 

conditions as required by the BART rule. Thus, since we are required by the 

BART rule to evaluate the impact that our emissions would have on natural 

visibility conditions at each Class I area, it must be assumed that no other sources 

of air emissions would exist other than those from sources at the mill for the 

purpose of the analysis. According to 40 CFR Part 51, Appendix Y, an individual 

BART-eligible source is considered to “contribute” to visibility impairment in a 

Class I area if the modeled 98th percentile change in dv is equal to or greater than 

the “contribution threshold.” The contribution threshold is 0.5 deciview. Since 

the modeled change in visibility for each control scenario is less than the 0.5 dv 

contribution threshold as compared to natural conditions, it is appropriate to 

state that a control scenario would not result in a humanly perceptible change as 

compared to natural conditions. 

Furthermore, the existing regional haze in the subject Class I areas is on the 

order of 35 dv. Based on the modeling analyses performed in the BART 

evaluation, the greatest change in visibility is 0.383 dv. This would be less than a 

1% reduction in regional haze as compared to existing regional haze conditions. 

Based on the magnitude of costs for the control scenarios with minimal 

improvement in visibility, BART would be no further controls. 

6. Results tables specified in the VISTAS Protocol 

The VISTAS Protocol provides standard table formats for presenting modeling 

results. There should be a table showing number of days and number of receptors 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 538 

 December 17, 2007
26

with impact greater than 0.5 deciview (dv) for each Class 1 area, and for each 

year, number of days and number of receptors with impact greater than 1.0 dv for 

each Class 1 area for the entire 3-yr period, and the maximum 24-hr impact 

during the 3-yr period. These tables were provided in the facility’s BART 

Exemption Modeling Report, but have not been included in the November 2006 

document. It is suggested that similar tables be included in the determination 

report. Also, documentation that addresses the development of the baseline 

modeling should be included in the determination report. This may be in the 

BART exemption modeling report. It is suggested that the complete BART 

Exemption Modeling Report be included as an appendix to the determination 

report. 

PCS Phosphate Response 

The BART Exemption Modeling Report has been previously submitted to 

NCDAQ. Additional copies may be provided upon request. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 539 

 December 17, 2007
27

Enclosure 3: Text Clarifications 

Below are clarifications we wish to note on certain statements in the text. (The 

location of the text in the document is identified in parentheses.) 

1. Definitions 

(a) Just Noticeable Change (Section 2.1, P. 2-1) 

The document provides selected definitions from 40 CFR 51. We wish to clarify 

that the definition provided in Section 2.1 for Just Noticeable Change is not from 

the Definitions section of the Regional Haze regulations (40 CFR 51.301, 

“Definitions”). Including this definition appears misleading since it discusses the 

concept of Line-of-Sight (LOS). We recommend excluding this definition since, 

as the report indicates elsewhere in Section 1, this specific approach is not 

appropriate for BART modeling purposes. 

PCS Phosphate Response 

PCS Phosphate acknowledges the requested change. If the North Carolina 

Division of Air Quality requests a complete amended document then the 

change will be incorporated into the text. 

However, PCS Phosphate continues to maintain that the line-of-sight approach is 

the technically appropriate refined method for evaluating visibility impacts for 

BART exemption modeling when comparing a single source to the humanly 

perceptible change value of 1 deciview. Furthermore, this is consistent with the 

definition and scientific basis of a deciview. An approximate one (1.0) deciview 

change was defined by Pitchford and Malm (1992) as a “just noticeable change” 

to a human when the background visual range equals the line-of-sight (LOS) of 

the observer. 

According to L. Willard Richards in “Use of the Deciview Haze Index as an 

Indicator for Regional Haze,” if a shorter LOS distance than the background 

visual range (natural conditions) is used in performing the calculations then a 

higher extinction value, or deciview, is needed to cause a “just noticeable 

change.” In other words, when the LOS is less than the background visual range, 

then it would require a higher deciview value in order to be a “just noticeable 

change.” Thus, in order to more accurately compare the impact of a single 

source on a Class I area for comparison to the deciview thresholds, the deciview 

change would need to be calculated along the human line-of-sight that is equal to 

the background visual range as opposed to a single receptor point in the Class I 

area. The modeling we included in the BART evaluation calculates the change 

over a shorter distance than the background visual range and thus overestimates 

the impact that the BART eligible units have on each Class I area. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 540 

 December 17, 2007
28

(b) Potential to Emit (PTE) Thresholds (Section 2-2, P. 2-2) 

The PTE threshold provided for BART –eligible sources should be corrected to be 

consistent with the CFR to read as follows, “...the potential to emit more than 250 

tons per year or more...” (See 40 CFR 51.301, “Definitions,” Existing stationary 

facility.) 

PCS Phosphate Response 

PCS Phosphate acknowledges the requested change. If the North Carolina 

Division of Air Quality requests a complete amended document then the 

change will be incorporated into the text. 

(c) BART-eligible units (Section 3.2, P. 3-3) 

The document states that, “There are...tanks...that are BART eligible units but do 

not emit SO2, NOx, H2SO4 mist, or PM10.” We note that this statement appears 

misleading, as these units are not considered BART-eligible because they do not 

emit any visibility-impairing pollutants. 

PCS Phosphate Response 

PCS Phosphate acknowledges the requested change. If the North Carolina 

Division of Air Quality requests a complete amended document then the 

change will be incorporated into the text. 

2. Due date for Regional Haze SIPs (Section 2.2, P. 2-3) 

The document identifies a due date for Regional Haze SIPs of January 2008. To 

clarify, the due date for Regional Haze SIPs specified in the Regional Haze 

regulations at 40 CFR 51.308 (b) is: “...no later than December 17, 2007.” 

PCS Phosphate Response 

PCS Phosphate acknowledges the requested change. If the North Carolina 

Division of Air Quality requests a complete amended document then the 

change will be incorporated into the text. We would note that this is only an 

editorial change, both statements are correct as written. 

3. Cost Effectiveness Numbers (Section 4.2.1, P.4-5) 

On page 4-5 of the document, the cost effectiveness values for reducing SO2 

emissions from SA Plants 3 and 4 are slightly different than the corresponding 

values in Tables 4-2 and 4-3. The values presented in the text are $4,108/$5,584 

per ton SO2, and the corresponding values in the tables are $4,127/$5,568 per ton 

SO2, respectively. These differences should be clarified, and also correlated to 

the values in Tables 1-1 and 1-2. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 541 

 December 17, 2007
29

There is also a discrepancy of values listed in Tables 1-1 and 1-2 with some of the 

corresponding values computed in the detailed cost analysis tables listed further in 

that section. One suggestion to facilitate review and to minimize these 

discrepancies is to add a column to Tables 1-1 and/or 1-2 that lists the cost 

analysis table number along with the modeled scenario number. 

PCS Phosphate Response 

During report preparation and review, the calculations in Tables 4-2 through 4-

15 were updated, but some of the $/ton numbers in the text and Tables 1-1 and 1-

2 for individual control scenarios were inadvertently not updated in the final 

report. We have attached revised Tables 1-1 and 1-2 with corrected $/ton 

numbers and references to the individual control cost tables. The overall result of 

the analysis is not changed. 

4. Permit Changes (Section 4.4.1, P.4-9) 

The document asserts that emissions from the calciner are less than the Maximum 

Achievable Control Technology (MACT) standard for particulate matter (PM), 

and that this level of control is already required in the facility’s Title V operating 

permit. The BART Guidelines say if the most stringent control available is 

adopted, it must be made federally enforceable for purposes of BART. This 

should be described in the SIP narrative and when the Title V permit is reopened 

in accordance with the schedule in 40 CFR part 70 or 40 CFR part 71, the 

statement of basis for this control should be modified to include a statement that 

these controls and operating conditions also serve to satisfy BART for PM. 

PCS Phosphate Response 

The submitted document included a request to incorporate the presented emission 

levels as BART into the Title V operating permit for PCS Phosphate. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 542 

 December 17, 2007
PCS Phosphate BART determination 

APPENDIX B 

Public Notice for BART Title V Air Permit Modification 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 543 

 December 17, 2007
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES 

PUBLIC NOTICE AND NOTICE OF INTENT TO ISSUE AIR QUALITY PERMITS 

Notice is hereby given for a public hearing to be heard by the North Carolina Department of Environment 

and Natural Resources (DENR), Division of Air Quality (DAQ), concerning the proposed Regional Haze 

state implementation plan (SIP) and preliminary best available retrofit technology (BART) determinations. 

DAQ also hereby gives notice of intent to issue an Air Quality Permit to each of the facilities noted in the 

information section below. 

PURPOSE: The hearing is intended to inform interested parties on the Regional 

Haze SIP including BART determinations and intent to issue related 

Air Quality Permits. 

DATES AND LOCATIONS: November 13, 2007, 6:30 p.m., Asheville-Buncombe Technical 

Community College Main Campus, 1st Floor Lecture Room, 

Simpson Administrative Building, 340 Victoria Road, Asheville, 

NC 28801. 

November 15, 2007, 6:30 p.m., at the DENR Washington Regional 

Office, 943 Washington Square Mall, DENR Hearing Room, 

Washington, NC, 27889. 

COMMENT PROCEDURES: All persons interested in these matters are invited to attend the 

public hearing. Any person desiring to comment is requested to 

submit a written statement for inclusion in the record of proceedings 

at the public hearing. The hearing officer may limit oral 

presentation lengths if many people want to speak. The hearing 

record will remain open until November 26, 2007, to receive 

additional written statements. 

INFORMATION: Copies of the proposed Regional Haze SIP, the BART 

determinations, related permit reviews and draft permits, and a 

summary of initial Federal Land Managers comments on the 

Regional Haze SIP may be downloaded at 

http://daq.state.nc.us/planning/nc.sip.shtml. The documents may 

also be reviewed at the offices of the North Carolina Department of 

Environment and Natural Resources, Division of Air Quality, 

located in: 

 Raleigh, Planning Section (919) 715-7670 

Raleigh, Permits Section (919) 715-6237 

 Asheville Regional Office (828) 296-4500 

 Washington Regional Office (252) 946-6481 

Comments should be sent to and additional information concerning 

the hearings or the proposals may be obtained by contacting: 

 Ms. Laura Boothe 

Acting Chief, Planning Section 

 Division of Air Quality 

 1641 Mail Service Center 

 Raleigh, NC 27699-1641 

 Phone: (919) 733-1488 

 Fax: (919) 715-7476 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 544 

 December 17, 2007
daq.publiccomments@ncmail.net (Note: In the subject line 

type Regional Haze SIP) 

The following two facilities have submitted BART determinations 

under 15A NCAC 02D .0543 Best Available Retrofit Technology 

for DAQ to review and have applied for an Air Quality Permit 

which meets the requirements specified in 15A North Carolina 

Administrative Code 02Q .0300: 

PCS Phosphate Company 

1530 NC 306 South 

Aurora, NC 27806 

Beaufort County 

Permit # 04176 T34 App# 0700071.06D 

Blue Ridge Paper Company 

175 Main Street 

Canton, NC 28716 

Haywood County 

Permit # 08961 – T09 App# 440159.06E 

Comments should be sent to and additional information regarding 

the Air Quality Permits may be obtained by contacting: 

Mr. Donald van der Vaart, Ph. D., P.E. 

Chief, Air Permits Section 

Division of Air Quality 

1641 Mail Service Center 

Raleigh, NC 27699-1641 

Attn: Permits Section 

Phone: (919) 715-6253 

Fax: (919) 733-5317 

All comments received by November 26, 2007 will be considered in 

the final determinations regarding these Air Quality Permits. 

Date: ______________________ 

B. Keith Overcash, P.E., Director 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 545 

 December 17, 2007
PCS Phosphate BART determination 

APPENDIX C 

Draft Air Permit Language 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 546 

 December 17, 2007
 

????, 200? 

Mr. Richard Atwood DRAFT

Plant Manager 

PCS Phosphate Company, Inc. 

Aurora, North Carolina 27806 

Dear Mr. Atwood: 

SUBJECT: Air Quality Permit No. 04176T3?

Facility ID: 07-00071 

PCS Phosphate Company, Inc. 

Aurora 

Beaufort County 

Fee Class: Title V 

 In accordance with your completed Air Quality Permit Application 0700071.06D for a 

significant permit modification of a Title V permit received November 28, 2006, we are forwarding 

herewith Air Quality Permit No. 04176T3? to PCS Phosphate Company, Inc., Aurora, North 

Carolina authorizing the construction and the operation, of the emission source(s) and associated air 

pollution control device(s) specified herein. Additionally, any emissions activities determined from 

your Air Quality Permit Application as being insignificant per 15A North Carolina Administrative 

Code 2Q .0503(8) have been listed for informational purposes as an "ATTACHMENT." Please note 

the requirements for the annual compliance certification are contained in General Condition P in 

Section 3 of Part I. 

 As the designated responsible official it is your responsibility to review, understand, and 

abide by all of the terms and conditions of the attached permit. It is also your responsibility to ensure 

that any person who operates any emission source and associated air pollution control device subject 

to any term or condition of the attached permit reviews, understands, and abides by the condition(s) 

of the attached permit that are applicable to that particular emission source. The Permittee shall

notify the Director and the EPA with written notification at least seven days before the "change 

is made" pursuant to 15A NCAC 2Q .0523(a)(1)(C) for the air emission source(s) (ID No(s). 

ES424 and CD 438-200). 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 547 

 December 17, 2007
 

Mr. Richard Atwood

????, 200? 

Page 2 

If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable 

to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of 

this permit, identifying the specific issues to be contested. This hearing request must be in the form of 

a written petition, conforming to NCGS (North Carolina General Statutes) 150B-23, and filed with 

both the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-

6714 and the Division of Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh, North 

Carolina 27699-1641. The form for requesting a formal adjudicatory hearing may be obtained upon 

request from the Office of Administrative Hearings. Please note that this permit will be stayed in its 

entirety upon receipt of the request for a hearing. Unless a request for a hearing is made pursuant to 

NCGS 150B-23, this Air Quality Permit shall be final and binding 30 days after issuance. 

 You may request modification of your Air Quality Permit through informal means pursuant 

to NCGS 150B-22. This request must be submitted in writing to the Director and must identify the 

specific provisions or issues for which the modification is sought. Please note that this Air Quality 

Permit will become final and binding regardless of a request for informal modification unless a 

request for a hearing is also made under NCGS 150B-23. 

The construction of new air pollution emission source(s) and associated air pollution 

control device(s), or modifications to the emission source(s) and air pollution control device(s) 

described in this permit must be covered under an Air Quality Permit issued by the Division of 

Air Quality prior to construction unless the Permittee has fulfilled the requirements of GS 143-

215-108A(b) and received written approval from the Director of the Division of Air Quality to 

commence construction. Failure to receive an Air Quality Permit or written approval prior to 

commencing construction is a violation of GS 143-215.108A and may subject the Permittee to 

civil or criminal penalties as described in GS 143-215.114A and 143-215.114B.

 This Air Quality Permit shall be effective from ????, 200? until May 31, 2010, is 

nontransferable to future owners and operators, and shall be subject to the conditions and limitations 

as specified therein. 

 Should you have any questions concerning this matter, please contact Wallace Pitts at (919) 

715-1060. 

 Sincerely yours, 

Donald R. van der Vaart, Ph.D., P.E. 

Chief

Enclosure 

c: Washington regional Office 

Central Files 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 548 

 December 17, 2007
 

List of changes to permit 

Insignificant Activities under 15A NCAC 2Q .0503(8) 

PAGE CONDITION CHANGE 

All All Revised permit number and dates 

All 2.1 emission 

source tables 

Updated tables to identify emission sources subject to 15A 

NCAC 2D .0543 “Best Available Retrofit Technology (BART) 

131 - 134 2.3 Added 2.3 with list of BART determination for affected 

emission sources. 

0 

ID Number Emission Source Description 

I-T30 Storage tank which does not contain volatile organic liquids 

I-T50 Storage tank which does not contain volatile organic liquids 

I-T1030 Storage tank which does not contain volatile organic liquids 

I-T1050 Storage tank which does not contain volatile organic liquids 

I-15 Lime Hopper 

I-14 Two vacuum Cleaners in DFP area (one 30 and one 75 

horsepower) 

I-T556 DAB Hold Tank 

I-T554 PhosBrite Hold Tank 

I-T552 One (1) 90% Phosphoric acid storage tank 

I-T550 One (1) 88% Phosphoric acid storage tank 

I-971 Gypsum Stack Number 1 

I-972 Gypsum Stack Number 2 

I-973 Gypsum Stack Number 3/4 

I-974 Gypsum Stack Number 5 

I-975 Gypsum Stack Number 6 

I-426 STF Complex Cooling Tower Fan No. 1 

I-427 STF Complex Cooling Tower Fan No. 2 

I-317 Technical Services Pilot Plant 

I-10 Phosphoric Acid Storage 

I-9 Fuel Oil Storage Tank 

I-8 Coal Storage Silo 

I-7 Coal Mill 

I-6 Coal Transfer Conveyor 

I-5 Coal Unloading conveyor 

I-4 Phosphoric Acid storage tank 

I-3 Bright Dip Pilot Line 

I-2 2 conveyors for Moroccan ore - temporary 

I-1 60 tph crusher 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 549 

 December 17, 2007
 

State of North Carolina, 

Department of Environment, 

and Natural Resources 

Division of Air Quality DRAFT

AIR QUALITY PERMIT

Permit No. Replaces Permit No.(s) Effective Date Expiration Date

04176T3? 04176T3? ????, 200? May 31, 2010

Until such time as this permit expires or is modified or revoked, the below named Permittee is permitted 

to construct and operate, the emission source(s) and associated air pollution control device(s) specified 

herein, in accordance with the terms, conditions, and limitations within this permit. This permit is issued 

under the provisions of Article 21B of Chapter 143, General Statutes of North Carolina as amended, and 

Title 15A North Carolina Administrative Codes (15A NCAC), Subchapters 2D and 2Q, and other 

applicable Laws. 

Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any 

emission source(s) or air pollution control device(s) without having first submitted a complete Air Quality 

Permit Application to the permitting authority and received an Air Quality Permit, except as provided in 

this permit. 

Permittee: PCS Phosphate Company, Inc.

Facility ID: 07-00071

Facility Site Location: Highway 306 North of Aurora, North Carolina

City, County, State, Zip: Aurora, Beaufort County, North Carolina, 27806

Mailing Address: P.O. Box 48

City, State, Zip: Aurora, North Carolina, 27806

Application Number: 0700071.06D

Complete Application Date: November 28, 2006 

Primary SIC Code: 2874

Division of Air Quality, Washington Regional Office

Regional Office Address: 1424 Carolina Avenue

Washington, NC 27889

Permit issued this the ??th day of ????, 200? 

_________________________________________________ 

Donald R. van der Vaart, Ph.D., P.E., Chief, Air Permits Section 

By Authority of the Environmental Management Commission

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 550 

 December 17, 2007
 

Table Of Contents

DRAFT 

 

PART I 

SECTION 1: PERMITTED EMISSION SOURCE (S) AND ASSOCIATED 

 AIR POLLUTION CONTROL DEVICE (S) AND APPURTENANCES

 1. Sulfuric Acid Production Area 

 2. Mill Area 

 3. Fertilizer Production Area 

 4. Superphosphoric Production Area 

 5. Phosphoric Acid Production Area 

 6. Purified Acid Production Area 

 7. Defluorinated Feed Phosphate Area 

 8. Shipping Operations 

 9. Miscellaneous Sources 

 

SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS 

 2.1 - Emission Source(s) Specific Limitations and Conditions 

 (Including specific requirements, testing, monitoring, recordkeeping, and 

reporting requirements) 

1. Sulfuric Acid Production Area 

 2. Mill Area 

 3. Fertilizer Production Area 

 4. Superphosphoric Production Area 

 5. Phosphoric Acid Production Area 

 6. Purified Acid Production Area 

 7. Defluorinated Feed Phosphate Area 

 8. Shipping Operations 

 2.2 - Multiple Emission Source(s) Specific Limitations and Conditions 

 (Including specific requirements, testing, monitoring, recordkeeping, and 

 reporting requirements) 

2.3 - Multiple Emission Source(s) Specific Limitations and Conditions – Best Available 

Control Technology (BART) 

 

SECTION 3: GENERAL CONDITIONS 

ATTACHMENTS 

 1. List of Acronyms 

 2. List of North Carolina Air Toxics Emissions Limits 

PART II 

SECTION 1: PERMITTED EMISSION SOURCE (S) AND ASSOCIATED 

 AIR POLLUTION CONTROL DEVICE (S) AND APPURTENANCES

SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS

SECTION 3: GENERAL PERMIT CONDITIONS

 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 551 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 3 

PART I 

The Division of Air Quality (DAQ), the United States Environmental Protection Agency (EPA), and citizens as 

defined under the Federal Clean Air Act have the authority to enforce the terms, conditions, and limitations 

contained in Part I of this permit unless otherwise specified. 

Under Title 15A NCAC 2Q, the operation of emission source(s) and associated air pollution control device(s) and 

appurtenances listed in Part I of this permit is based on plans, specifications, operating parameters, and other 

information as submitted in the Air Quality Permit Application. 

SECTION 1- PERMITTED EMISSION SOURCE(S) AND ASSOCIATED 

 AIR POLLUTION CONTROL DEVICE(S) AND 

 APPURTENANCES 

1. Sulfuric Acid Area 

Emission 

Source 

ID No.

Emission Source 

Description

Control 

Device 

ID No.

Control Device 

Description

Emission 

Point ID No.

S-3 Double-absorption sulfuric 

acid plant No. 3 (2000 tons 

per day nominal capacity) 

BACT NSPS BART

413-336 Vertical tube mist eliminator 

system installed on final 

absorbing tower for H2SO4

Mist; double-absorption is 

control for SO2

101 

S-4 Double-absorption sulfuric 

acid plant No. 4 (1850 tons 

per day nominal capacity) 

BACT NSPS BART

414-436 Vertical tube mist eliminator 

system installed on final 

absorbing tower 

102 

S-5 Double-absorption sulfuric 

acid plant No. 5 (3600 tons 

per day nominal capacity) 

 NSPS

415-934 Vertical tube mist eliminator 

installed on final absorbing 

tower 

103 

S-6 Double-absorption sulfuric 

acid plant No. 6 (3800 tons 

per day nominal capacity) 

 NSPS

406-129 Mist eliminator system 

including two-inch layer of 

knitted wire mesh 

104 

BW-2 One (1) distillate oil-fired 

boiler (99.56 million Btu per 

hour nominal capacity) 

 NSPS

N/A N/A 110-new 

SAF Sulfuric Acid Plant Fugitives N/A N/A 190 

SAPCT Sulfuric Acid Plant Cooling 

Towers 

N/A N/A 

417-503-

462 

Lime silo No. 4 at water 

treatment area 

BART 

417-503-

471 

One (1) bagfilter (124 square 

feet of surface area) 

121 

417-755-

462 

Lime silo No. 5 at water 

treatment area 

417-755-

471 

One (1) bagfilter (124 

square feet of surface area) 

122 

417-756-

462 

Lime silo No. 6 at water 

treatment area 

417-756-

471 

One (1) bagfilter (124 

square feet of surface area) 

123 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 552 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 4 

2. Mill Area 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission Point 

ID No.

339-051 One coal/coke/”off-spec” 

used oils, used oil 

sludge/used glycols/ 

residual oil-fired vertical 

fluidized bed, phosphate 

rock calciner unit No. 1 

(105.1 tons per hour 

nominal feed capacity) 

MACT BART

339-381a 

339-381b 

339-381c 

339-381d 

Two (2) duplex cyclones 

exhausting to one (1) fixed 

throat venturi type wet 

scrubber exhausting to one 

(1) wet electrostatic 

precipitator 

201 

339-052 One coal/coke/”off-spec” 

used oils, used oil 

sludge/used glycols/ 

residual oil-fired vertical 

fluidized bed, phosphate 

rock calciner unit No. 2 

(105.1 tons per hour 

nominal feed capacity) 

MACT BART

339-382a 

339-382b 

339-382c 

339-382d 

Two (2) duplex cyclones 

exhausting to one (1) fixed 

throat venturi type wet 

scrubber exhausting to one 

(1) wet electrostatic 

precipitator 

202 

339-053 One coal/coke / residual oilfired vertical fluidized bed, 

phosphate rock calciner unit 

No. 3 (105.1 tons per hour 

nominal feed capacity) 

MACT BART

339-383a 

339-383b 

339-383c 

339-383d 

Two (2) duplex cyclones 

exhausting to one (1) fixed 

throat venturi type wet 

scrubber exhausting to one 

(1) wet electrostatic 

precipitator 

203 

339-054 One coal/coke / residual oilfired vertical fluidized bed, 

phosphate rock calciner unit 

No. 4 (105.1 tons per hour 

nominal feed capacity) 

MACT BART

339-384a 

339-384b 

339-384c 

339-384d 

Two (2) duplex cyclones 

exhausting to one (1) fixed 

throat venturi type wet 

scrubber exhausting to one 

(1) wet electrostatic 

precipitator 

204 

339-055 One coal/coke / residual oilfired vertical fluidized bed, 

phosphate rock calciner unit 

No. 5 (105.1 tons per hour 

nominal feed capacity) 

MACT BART

339-385a 

339-385b 

339-385c 

339-385d 

Two (2) duplex cyclones 

exhausting to one (1) fixed 

throat venturi type wet 

scrubber exhausting to one 

(1) wet electrostatic 

precipitator 

205 

339-056 One coal/coke / residual oilfired vertical fluidized bed, 

phosphate rock calciner unit 

No. 6 (105.1 tons per hour 

nominal feed capacity)

MACT BART

339-386a 

339-386b 

339-386c 

339-386d 

Two (2) duplex cyclones 

exhausting to one (1) fixed 

throat venturi type wet 

scrubber exhausting to one 

(1) wet electrostatic 

precipitator 

206 

332-120 Residual oil-fired phosphate 

rock dryer (250 tons per 

hour nominal capacity) 

MACT BART

332-370a 

332-370b 

One (1) duplex cyclone 

and one (1) venturi type 

wet scrubber 

210 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 553 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 5 

341-300 Coal/coke pulverizer and 

thermal dryer system (20 

tons per hour nominal 

capacity) 

341-310 

341-331 

341-332 

One (1) single cyclone 

exhausted to two (2) 

parallel bagfilters 

215 

Belt 39 to 

70.1 

Calcined rock CTS 

BART

339-821 Enclosed transfer point 220 

Belt 55 to 

Belt 70.1 

Calcined rock CTS 

Baghouse 

BART

339-860 One (1) bagfilter (580 

square feet of surface 

area) 

221 

Belt 21 to 

Belt 23 or 

Belt 24 

Storage silo baghouse 

BART

333-180 One (1) bagfilter (360 

square feet of surface 

area) 

222 

Belt 22 to 

Belt 23 or 

Belt 24 

Storage silo baghouse 

BART

333-190 One (1) bagfilter (75 

square feet of surface 

area) 

222 

339-809-

464 

Calcined/dried rock CTS 

BART

None None 223 

224 One (1) polymer storage bin 320-215-

478 

One (1) bagfilter (1200 

square feet of surface 

area) 

224 

225 One (1) lime storage silo 315-300-

478 

One (1) bagfilter (3000 

square feet of surface 

area) 

225 

F290 Mill Concentrator Fugitives N/A N/A 290 (State-only 

requirements) 

F291 Calciner Plant Area 

Fugitives 

BART

N/A N/A 291 (State-only 

requirements) 

F292 Surge Pond Aerator N/A N/A 292 (State-only 

requirements) 

341-100 Coal/coke railcar unloader 

(75 tons per hour nominal 

capacity) 

N/A Curtains, choke feeder, 

and wet suppression 

(spray) system 

294a 

341-110, 

341-111, 

341-112, 

341-120 

Three (3) parallel conveyor 

belts which transfer to one 

(1) single belt conveyor 

One (1) wet suppression 

(spray) system, conveyor 

skirts at transfer points, 

and hood covers 

294b 

341-140 Single belt conveyor One (1) wet suppression 

(spray) system and hood 

covers 

294c 

341-130 Coal/coke crusher (75 tons 

per hour nominal capacity) 

One (1) wet suppression 

(spray) system 

294d 

341-200 

341-201 

Two (2) coal/coke storage 

silos (1086 tons, nominal 

capacity each) 

Two (2) filtered bin vents, 

one per silo 

294e 

341-230 One (1) conveyor belt One (1) wet suppression 

(spray) system and hood 

covers 

294f 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 554 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 6 

3. Fertilizer Production Area 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission 

Point ID No.

511-085 

511-086 

511-070

Diammonium Phosphate 

Plant No. 3 

first stage reactor 

second stage reactor 

granulator 

MACT BACT BART

511-107A 

511-107B 

511-105

One (1) saturation 

chamber and one (1) wet 

cyclonic scrubber 

installed in a series 

One (1) cyclonic tail gas 

scrubber

302

511-032 Diammonium Phosphate 

Plant No. 3 residual oil-fired 

dryer 

MACT BACT BART

511-028 

511-103 

511-105

One (1) dryer quad 

cyclone scrubber and one 

(1) two-stage dryer wet 

cyclonic scrubber 

One (1) cyclonic tail gas 

scrubber

302

511-008 

511-009 

511-010 

511-011 

511-016 

511-017 

511-038 

511-039 

511-041 

511-093 

511-094 

511-095 

511-096

Diammonium Phosphate 

Plant No. 3 process sizing 

and handling equipment 

(four (4) chain mills, screen 

feed drag conveyor, recycle 

drag conveyor, recycle 

elevator, dryer elevator, 

product elevator, and four 

(4) double-deck product 

screens) 

MACT BACT BART

511-030 

511-104 

511-105

One (1) dust dual cyclone 

and one (1) dust cyclonic 

wet scrubber installed in 

a series 

One (1) cyclonic tail gas 

scrubber

302

511-025 Diammonium Phosphate 

Plant No. 3 cooler and other 

miscellaneous material 

handling points 

MACT BACT BART

511-029 

511-106 

511-105

One (1) cooler dual 

cyclone and one (1) 

cooler wet cyclonic 

scrubber 

One (1) cyclonic tail gas 

scrubber

302

505-104 

505-123A

Diammonium Phosphate 

Plant No. 2 residual oil-fired 

dryer 

One (1) duplex cyclone 

product separator

505-125 

505-147

one (1) venturi wet 

scrubber 

one (1) packed tower tail 

gas scrubber with saddletype packing and 

demister pads: all 

installed in a series

303

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 555 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 7 

505-107 

505-114 

505-110 

505-143

Diammonium Phosphate 

Plant No. 2 material sizing 

and handling equipment 

(eight (8) process screens, 

one (1) scalping screen, one 

(1) recycle drag conveyor, 

and a product bin)

505-123C 

505-117 

505-148

One (1) equipment 

cyclone 

One (1) cooler venturi 

wet scrubber 

One (1) packed tower tail 

gas scrubber with saddletype packing and 

demister pad

303

505-111 Diammonium Phosphate 

Plant No. 2 cooler

505-123B 

505-117 

505-148

One cooler duplex 

cyclone 

One (1) cooler venturi 

wet scrubber 

One (1) packed tower tail 

gas scrubber with saddletype packing and 

demister pad

303

505-103 

505-121

Diammonium Phosphate 

Plant No. 2 granulator and 

reactor

505-118 

505-148

One (1) reactorgranulator venturi wet 

scrubber 

One (1) packed tower tail 

gas scrubber with saddletype packing and 

demister pad

303

511-045 Diammonium Phosphate 

Plant No. 3 GTSP phosphate 

rock silo

511-035 One (1) bagfilter 

operating only during 

rock transfer

310

DAP1WH

1 

Warehouse No. 1 for DAP 1 None None 390 

DAP2WH

2

Warehouse No. 2 for DAP 2 None None 390

DAP3WH

3

Warehouse No. 3 for DAP 3 None None 390 

F391 Fertilizer Plant Fugitives A None none 391 

F392 Fertilizer Plant Fugitives B None None 392 

PA Pilot 

No. 2

Phosphoric Acid Pilot Plant 

No. 2

116-002 Venturi Scrubber 316 

(State-only 

requirements)

318 Technical Services Dust 

Collection System

CD318 One (1) bagfilter 318 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 556 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 8 

4. Superphosphoric Acid Production Area 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission 

Point ID No.

451-418 

and 451-

409

Superphosphoric acid plant 

No. 1 

MACT BACT NSPS 

BART

451-407 One (1) educator venturi 

type wet scrubber

330

451-701 

and 451-

809

Superphosphoric acid plant 

No. 2 

MACT BACT NSPS 

BART

451-807 One (1) educator venturi 

type wet scrubber

331

451-316 

and 451-

308

Superphosphoric acid plant 

No. 3 

MACT BACT NSPS 

BART

451-315 One (1) educator venturi 

type wet scrubber

332

451-916 

and 451-

940 

Superphosphoric acid plant 

No. 4 

MACT BACT NSPS 

BART

451-315 One (1) educator venturi 

type wet scrubber

332

FPR-1 

FPR-2

No. 1 filter press/filter press 

repulp tank and No. 2 filter 

press/filter press repulp tank

None None 335 and 336 

(state-only 

requirements)

453-485 One (1) potassium 

permanganate silo

453-488 One (1) bagfilter 340

453-468 One (1) clay or limestone 

additive storage silo*

453-470 One (1) bagfilter 341

APP-1 Ammonium Polyphosphate 

Plant (APP) 

454-1 One (1) mist eliminator 

installed on one (1) 

packed tower cooler

304 

(state-only 

requirements)

AFP-1 One (1) filter press None None 305

* This emission source and/or control device(s) (ID No(s). ES-453-468) when storing limestone are listed as a 

502(b)(10) change per NCAC 2Q .0523. The permit shield described in General Condition R does not apply.

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 557 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 9 

5. Phosphoric Acid Production Area 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission 

Point ID No.

421-201 Reactor Train No. 1 

MACT BACT NSPS 

BART

421-000 tilting pan (Bird) filter No. 1 

MACT BACT NSPS 

BART

421-325 tilting pan (Bird) filter No. 1 

primary vacuum pump 

installed on primary 

vacuum separator 

MACT BACT NSPS 

BART

421-327 secondary vacuum pump 

installed on secondary 

vacuum separator 

MACT BACT NSPS 

BART

421-223 

421-232 

(2) barometric condensers 

vacuum pumps; 

MACT BACT NSPS 

BART

421-218 barometric condensers 

hotwell 

MACT BACT NSPS 

BART

421-330 tilting pan (Bird) filter No. 1 

seal tanks. 

MACT BACT NSPS 

BART

421-225 One (1) spray cross-flow 

packed bed type scrubber

401

441-000 

441-015

Belt filter No. 1 filtrate 

separator 

Belt filter No. 1 vacuum 

pump

441-021 One (1) spray tower 

separator 

402

441-031 belt filter No. 1 seal tanks 442-061 One (1) cyclonic 

scrubber

403

422-201 Reactor Train No. 2 

MACT BACT NSPS 

BART

422-000 tilting pan (Bird) filter No. 2 

MACT BACT NSPS 

BART

422-225 One (1) spray cross-flow 

packed bed type scrubber

404

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 558 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 10 

422-325 tilting pan (Bird) filter No. 2 

primary vacuum pump 

installed on primary 

vacuum separator 

422-327 secondary vacuum pump 

installed on secondary 

vacuum separator 

422-223 

422-232 

(2) barometric condensers 

vacuum pumps 

422-218 barometric condensers 

hotwell 

422-330 tilting pan (Bird) filter No. 2 

seal tanks 

442-000 

442-015

Belt filter No. 2 filtrate 

separator 

Belt filter No. 2 vacuum 

pump

442-021 One (1) spray tower 

separator 

405

423-201 Reactor Train No. 3 

MACT BACT NSPS 

BART

423-000 tilting pan (Bird) filter No. 

3; 

MACT BACT NSPS 

BART

423-325 tilting pan (Bird) filter No. 3 

primary vacuum pump 

installed on primary 

vacuum separator; 

MACT BACT NSPS 

BART

423-327 secondary vacuum pump 

installed on secondary 

vacuum separator 

MACT BACT NSPS 

BART

423-223 

423-232 

(2) barometric condensers 

vacuum pumps 

MACT BACT NSPS 

BART

423-218 barometric condensers 

hotwell 

MACT BACT NSPS 

BART

423-330 tilting pan (Bird) filter No. 3 

seal tanks. 

MACT BACT NSPS 

BART

423-225 One (1) spray cross-flow 

packed bed type scrubber

406

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 559 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 11 

443-000 Belt filter No. 3 filtrate 

separator

443-021 

443-015

One (1) spray tower 

separator and vacuum 

pump

407

444-031 belt filter No. 4 seal tanks 443-061 One (1) cyclonic 

scrubber

408

424-201 Reactor Train No. 4 

MACT BACT NSPS 

BART

424-000 tilting pan (Bird) filter No. 

4; 

MACT BACT NSPS 

BART

424-325 tilting pan (Bird) filter No. 4 

primary vacuum pump 

installed on primary 

vacuum separator 

MACT BACT NSPS 

BART

424-327 secondary vacuum pump 

installed on secondary 

vacuum separator 

424-223 

424-232 

(2) barometric condensers 

vacuum pumps 

MACT BACT NSPS 

BART

424-218 barometric condensers 

hotwell 

MACT BACT NSPS 

BART

424-330 tilting pan (Bird) filter No. 4 

seal tanks. 

MACT BACT NSPS 

BART

424-225 One (1) spray cross-flow 

packed bed type scrubber

409

444-000 

444-015

Belt filter No. 4 

Belt filter No. 4 

vacuum pump

444-021 One (1) spray tower 

separator 

410

040 and 

020

Two (2) phosphoric acid 

storage tanks

433-056 One (1) venturi scrubber 421 

(state-only 

requirement)

032, 033, 

034, and 

060

Four (4) phosphoric acid 

storage tanks (tank 060 may 

instead store green acid 

sludge)

433-036 One (1) venturi scrubber 422 

(state-only 

requirements)

429-002 

421-115

Two (2) phosphate rock jet 

conveyors on reactor train 

No. 1

421-103 One (1) bagfilter 430

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 560 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 12 

429-005 

422-115

Two (2) phosphate rock jet 

conveyors on reactor train 

No. 2

422-103 One (1) bagfilter 431

429-152 

429-001 

429-004 

429-151

Phosphate rock storage silo 

No. 1 and three (3) transfer 

points

429-014 One (1) bagfilter 434

429-157 

429-158 

429-009 

429-181 

429-183 

Phosphate rock storage silo 

No. 2 and four (4) transfer 

points 

429-164 One (1) bagfilter 435 

429-150 Phosphate rock transfer 

house

429-168 One (1) bagfilter 437

426-156 

433-158 

433-165

One (1) slurry mix tank, one 

(1) clarifier, and one (1) 

defluorinated acid pump 

tank

426-165 One (1) venturi scrubber 

Operated only during 

defluorinated acid 

production

450 

(state-only 

requirements)

426-154 One (1) diatomaceous earth 

silo

426-161 One (1) bagfilter 451

ES461 

ES462

Two (2) fans constituting 

One (1) phosphoric acid 

recirculation water cooling 

tower 

None None 461 and 462 

(state-only 

requirements)

ES424* Silicon tetrafluoride (STF) 

Plants Nos. 1 and 2, each 

including drying column, 

flash drum and knock out 

drum 

CD 438-

200* 

One (1) venturi scrubber 

Operated only during 

loading and maintenance 

operations 

424 

ES425* Silicon tetrafluoride (STF) 

Plants Nos. 3 and 4, each 

including drying column, 

flash drum and knock out 

drum 

CD TBD* One (1) venturi scrubber 

Operated only during 

loading and maintenance 

operations 

425 

PAPF Phosphoric Acid Plant 

Fugitives

None none 491

030 

031 

428-440 

428-442 

433-182

Two (2) phosphoric acid 

storage tanks (phosphoric 

acid tank farm), two (2) 

HFSA tanks, and one (1) 

carbon slurry tank

None None 492 

(state-only 

requirements)

* These emission sources and/control devices (ID Nos. ES424, ES425, CD 438-200, and CD TBD) are listed as 502(b)(10) changes 

per NCAC 2Q .0523. The permit shield described in General Condition R does not apply. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 561 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 13 

6. Purified Acid Production (PAP) Area 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission 

Point ID No.

T24 

T224 

T324 

T346 

Three (3) scrub acid storage 

tanks discharging through a 

seal pot 

S324 

GC-1

One (1) packed bed 

scrubber 

One (1) gas chiller 

system

501

C10 

C20 

C210 

C220 

Four (4) extraction columns 

under nitrogen blanket 

system

GC-1 One (1) gas chiller 

system

501

T7, T12, 

T13, T212, 

T213, T1, 

T201, 

T40, T240, 

T57, 

Ten (10) tanks under 

nitrogen blanket system

GC-1 One (1) gas chiller 

system

501

T54, T44, 

T244, T34

Four (4) tanks with seal pots 

under nitrogen blanket 

system

GC-1 One (1) gas chiller 

system

501

T8, T15, 

T215, 

T315, T58, 

Five (5) seal pots under 

nitrogen blanket system

GC-1 One (1) gas chiller 

system

501

S53, S43, 

S243, 

S253, S33, 

S5

Six (6) separators under 

nitrogen blanket system

GC-1 One (1) gas chiller 

system

501

S4 One (1) still under nitrogen 

blanket system

GC-1 One (1) gas chiller 

system

501

S42, S242, 

S32, S52, 

S54

Five (5) strippers under 

nitrogen blanket system

GC-1 One (1) gas chiller 

system

501

S324 One (1) scrubber under 

nitrogen blanket system

GC-1 One (1) gas chiller 

system

501

S88 

T70

One (1) acid defluorination 

column and acid 

concentrator

S92 One (1) wet spray tower 

with a demister pad

502 

(state-only 

requirements)

S118 

T270

One (1) acid defluorination 

column and acid 

concentrator

S292 One (1) wet spray tower 

with a demister pad

502 

(state-only 

requirements)

S288 

T100

One (1) acid defluorination 

column and acid 

concentrator

S122 One (1) wet spray tower 

with a demister pad

502 

(state-only 

requirements)

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 562 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 14 

CT-1 Two (2) direct contact 

cooling tower fans

None None 510 and 511

CT-2 Two (2) indirect contact 

cooling tower fans

None None 512 and 513

T1024 

T1324 

T1346 

Two (2) scrub acid storage 

tanks discharging through a 

vent pot

S1324 

 GC-2

One (1) packed bed 

scrubber 

one gas chiller system

503

C1010 

C1020 

Two (2) extraction columns 

under nitrogen blanket 

system

GC-2 One (1) gas chiller 

system

503

T1007, 

T1012, 

T1013, 

T1212, 

T1001, 

T1040, 

T1057

seven (7) tanks under 

nitrogen blanket system

GC-2 One (1) gas chiller 

system

503

T1054, 

T1044, 

T1034

Three (3) tanks with seal 

pots under nitrogen blanket 

system

GC-2 One (1) gas chiller 

system

503

T1008, 

T1015, 

T1215, 

T1315, 

T1058

Five (5) seal pots under 

nitrogen blanket system

GC-2 One (1) gas chiller 

system

503

S1043, 

S1053, 

S1253, 

S1033, 

S1005

Five (5) separators under 

nitrogen blanket system

GC-2 One (1) gas chiller 

system

503

S1004 One (1) still under nitrogen 

blanket system

GC-2 One (1) gas chiller 

system

503

S1042, 

S1032, 

S1052, 

S1054

Four (4) strippers under 

nitrogen blanket system

GC-2 One (1) gas chiller 

system

503

S1324 One (1) scrubber under 

nitrogen blanket system

GC-2 One (1) gas chiller 

system

503

S1088 

T1070

One (1) acid defluorination 

column and acid 

concentrator

S1092 One (1) wet spray tower 

with a demister pad

504

S1118 

T1100

One (1) acid defluorination 

column and acid 

concentrator

S1122 One (1) wet spray tower 

with a demister pad

504

E1180-1 

E1180-2

Two (2) direct contact 

cooling tower fans

None None 514 and 515

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 563 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 15 

E1181-1 

E1181-2

Two (2) indirect contact 

cooling tower fans

None None 516 and 517

T1524** 

T1224** 

T1546** 

Two scrub acid storage 

tanks discharging through a 

vent pot to one gas 

scrubbing system 

S1324 

GC-2 

One packed bed scrubber 

One gas chiller system 

503 

C1210** 

C1220** 

Two extraction columns 

under nitrogen blanket 

system 

GC-2 One Gas chiller system 503 

T1201** 

T1207** 

T1213** 

T1240** 

T2057** 

Five tanks under nitrogen 

blanket system 

GC-2 One Gas Chiller system 503 

T1244** One tank with seal pots 

under nitrogen blanket 

system 

GC-2 One Gas chiller system 503 

T1415** 

T1515** 

T1208** 

T1258** 

T1546 

Five emergency vent pots GC-2 One Gas Chiller System 503 

S1243** 

S1205** 

Two separators under 

nitrogen blanket system 

GC-2 One Gas chiller system 503 

S1288** 

T1270** 

One acid defluorination 

column and acid 

concentrator 

S1292 One acid scrubber 506 

S1242 One stripper under nitrogen 

blanket system 

GC-2 One Gas chiller system 503 

S1204 One Still under nitrogen 

blanket system 

GC-2 One Gas Chiller system 503 

TBDA** PAP No. 2 Cooling Tower 

No. 3 

None 518 and 519 

TBDB** PAP No. 2 Cooling Tower 

No. 4 

None 520 and 521 

T3 

T1003**

Two (2) feed acid storage 

tanks in the PAP tank farm

None None 591

T137 

T1137

Two (2) product under flow 

acid storage tanks in PAP 

tank farm

None None 591 

593

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 564 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 16 

T67 

T467 

T267 

T1067 

T76 

T106 

T295 

T1125 

T276 

T1106 

T125 

T1076 

T95 

T1095 

T1267** 

T1467** 

T1276** 

T1295**

eighteen (18) carbon treated 

low alkali acid tanks in PAP 

tank farm

None None 591 

593

T130 

T131 

T132 

T1130 

T1131 

T1132** 

T1133**

Seven (7) product low alkali 

acid storage tanks in PAP 

tank farm

None None 590

T134A 

T134B 

T1134 

T1134B**

Four (4) product high alkali 

acid storage tanks in PAP 

tank farm

None None 590

T300 One (1) Phosbrite/DAB mix 

tank (blending process)

None None 590

T301 Dilution tank No. 1 

(blending process)

None None 590

T302 Dilution tank No. 2 

(blending process)

None None 590

T303 One (1) sulfuric acid/DAB 

storage tank (blending 

process)

None None 590

T304 Dilution tank No. 3 

(blending process)

None None 590

T305 

T306

Two (2) DAB CF mix tanks None None 590

T307 One (1) copper carbonate 

mix tank

None None 590

T308 

T309

Two (1) head tanks None None 590

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 565 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 17 

PAP No. 1 

Tank Farm

Purified Acid Plant No. 1 

Tank Farm Fugitives

None None 591 

(state-only 

requirements)

PAP 

Fugitives

Purified Acid Plant 

Fugitives

None None 592 

(state-only 

requirements)

PAP No. 2 

Tank Farm

Purified Acid Plant No. 2 

Tank Farm Fugitives

None None 593 

(state-only 

requirements)

** These sources are listed as a NCAC 2Q .0501(d)(2) modification. The permit shield described in General Condition R of Part I 

of the permit does not apply to these sources. The Permittee shall not begin operation of the air emission source(s) and associated air 

pollution control device(s) listed in Section 1 until a Title V Air Quality Permit Application is filed and an operation permit is obtained 

following the procedures of Section .0500 (except for Rule .0504 of this Section). 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 566 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 18 

7. Defluorinated Feed Phosphate (DFP) Area 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission 

Point ID No.

355-116-

455 A&B

Two (2) pug mills 360-120-

476

Limestone slurry wet 

scrubber

701 

365-135-

477

One (1) defluorination kiln 

(coal for standard operation, 

No. 2 fuel oil and propane 

for start up)

360-120-

476

Limestone slurry wet 

scrubber

701 

370-106-

468

Grate Cooler 370-110-

478

One (1) fabric filter 702

355-128-

462

One (1) soda ash day bin 355-134-

478

One (1) fabric filter 709

382-137-

463

One (1) soda ash unloading 382-105-

478

One (1) fabric filter 710

382-100-

462

Limestone storage silo 382-103-

478

One (1) fabric filter 711

370-169-

472

Classifier elevator 712

370-165-

452

Classifier 712

370-166-

478 

Classifier Baghouse 370-166-

478 

Fabric Filter (3167 

square feet 

712 

355-154-

463

Soda Ash Feeder 355-138-

478

One (1) fabric filter 713 

355-153-

463

Limestone Feeder 355-138-

478

One (1) fabric filter 713 

355-112-

473

Plenum Recycle Dust 

Discharge Conveyor

355-138-

478

One (1) fabric filter 713 

365-155-

472

Plenum Dust Elevator 355-138-

478

One (1) fabric filter 713 

355-125-

462

Plenum Dust Bin 355-138-

478

One (1) fabric filter 713 

355-129-

462

Phosphate Rock Surge Bin 355-137-

478

One (1) fabric filter 714

355-155-

463

Phosphate Rock Feeder 355-138-

478

One (1) fabric filter 714

355-156-

433

Recycle Feeder 355-138-

478

One (1) fabric filter 714

355-130-

462

Recycle Bin 355-141-

478

One (1) fabric filter 715 

370-120-

478 

Classifier product elevator 370-120-

478 

One (1) fabric filter 717 

370-176-

474

Product cooler discharge 

conveyer

370-120-

478

One (1) fabric filter 717

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 567 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 19 

370-155-

472

Clinker surge bin elevator 370-120-

478

One (1) fabric filter 717

370-177-

463 

370-174-

463

Clinker reclaim conveyor 

Nos. 1 and 2

370-120-

478

One (1) fabric filter 717

370-113-

462

Clinker surge bin 370-120-

478

One (1) fabric filter 717

370-156-

472

Screening feed elevator 370-120-

478

One (1) fabric filter 717

370-115-

462

Clinker reclaim hopper 370-120-

478

One (1) fabric filter 717

370-126-

480

Clinker reclaim crusher 370-120-

478

One (1) fabric filter 717

370-140-

452

Clinker screen 370-120-

478

One (1) fabric filter 717

370-114-

462

Abort surge bin 370-120-

478

One (1) fabric filter 717

370-175-

463

Crusher discharge conveyor 370-120-

478

One (1) fabric filter 717

370-148A463Product screen discharge 

conveyor 

370-120-

478

One (1) fabric filter 717

370-148B463Classifier discharge belt 

conveyor

370-120-

478

One fabric filter 717

375-117-

463

Product transfer conveyor 370-120-

478

One (1) fabric filter 718

375-118-

463

Product tripper conveyor 370-120-

478

One (1) fabric filter 718

370-173-

463

Clinker transfer conveyor 370-120-

478

One (1) fabric filter 717

370-143-

463

Clinker dump conveyor 370-120-

478

One (1) fabric filter 717

370-147-

450

Clinker surge bin feeder 370-120-

478

One (1) fabric filter 717

370-144-

463

Clinker feed conveyor 370-120-

478

One (1) fabric filter 717

370-131-

480

Primary clinker crusher 370-120-

478

One (1) fabric filter 717

370-132-

480

Secondary clinker crusher 370-120-

478

One (1) fabric filter 717

375-105-

462

 Product loadout hopper 375-111-

478

One (1) fabric filter 718

375-106-

462

Product Reclaim Hopper 375-111-

478

One (1) fabric filter 718

375-108-

452

Product Polishing screen 375-111-

478

One (1) fabric filter 718

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 568 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 20 

375-132-

472

Product loadout elevator 375-111-

478

One (1) fabric filter 718

375-119-

463

Product reclaim conveyor 375-111-

478

One (1) fabric filter 718

375-120-

463

Product loadout conveyor 375-135-

478

One (1) fabric filter 754

RCVH Rail car vent hoods(4) 375-135-

478 

One (1) fabric filter 754 

375-121-

463 

Product loadout car spout 375-135-

478 

One (1) fabric filter 754 

375-123-

463 

Car loading conveyor 375-135-

478 

One (1) fabric filter 754 

375-124-

461

Car loading conveyor 375-135-

478

One (1) fabric filter 754

365-136-

484

Emergency Kiln Drive 

(Diesel)

None None 755

365-160-

523

Emergency Generator 

(Diesel)

None None 756

370-196-

478

Lab Fume Hood Exhaust None None 757

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 569 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 21 

8. Shipping Operations 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission Point ID No.

Ammonia 

Unloading

Ammonia Railroad 

Unloading

None None 601, 602, and 603 

(State-only 

requirements)

Ammonia 

Tanks

Ammonia Storage Tanks None None 604 and 605 

(State-only 

requirements)

Sulfur 

Unloading

Sulfur Railroad Unloading None None 610, 611, 612, 613, and 

614 

(State-only 

requirements)

Railcar 

Wash 1

Railcar Wash Station 

No. 1

None None 615 

(State-only 

requirements)

T-002 to T-012 

T-014 to T-019 

T-021 to T-029 

T-44 

T-050 to T-052 

T-054 to T-056

Thirty-three (33) phosphoric 

acid storage tanks (shipping 

tank farm)

None None 616 

(state-only 

requirements)

453-458 One (1) superphosphoric 

acid aging tank (shipping 

tank farm)

None None 616 

(state-only 

requirements)

AT2 One (1) superphosphoric 

acid aging tank (shipping 

tank farm)

None None 616 

(state-only 

requirements)

497-4-105 One (1) superphosphoric 

acid and clay additive mix 

tank (shipping tank farm)

None None 616 

(state-only 

requirements)

453-115 

453-412

No. 1 filter press feed tank 

No. 2 filter press feed tank 

None None 616 

(state-only 

requirements)

VSEP 

Tank

One (1) 5,000 gallon VSEP 

feed tank

None None 616 (state-only 

requirements)

Black 

Lomag

One (1) 110,000 gallon 

Black Lomag tank

None None 616 (state-only 

requirements)

Permeate 

Tank

One (1) 1,000 gallon 

permeate tank

None None 616 (state-only 

requirements)

Concentrate 

Tank 

One (1) 1,000 gallon 

concentrate tank

None None 616 (state-only 

requirements)

CTP Concentrate storage pile None None 616 (state-only 

requirements)

552-003 

552-005 

552-050

Three (3) liquid sulfur 

storage tanks

None None 616 (state-only 

requirements)

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Appendix L.10 - 570 

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Permit 04176T3? DRAFT 

Page 22 

Railcar 

Wash 2

Railcar Wash Station 

No. 2

None None 617 

(State-only 

requirements)

F650 CTS - Grinder Rock 

Loadout 

None Enclosures 650

F651 CTS - Grinder Rock 

Loadout 

BART 

None Enclosures 651

F652 Rock Loadout Transfer 

Station 

BART

None Enclosures 652

F653 CTS - Phosphate Rock 

Transfer Station 

BART

None Enclosures 653

F654 Rock Tower Loadout 

facility 

BART

531-600 One (1) 

bagfilter

654

F655 Chute-Barge Rock Loadout 

BART

None Enclosures 655

F656 Chute-Train Rock Loadout 

BART

None Enclosures 656

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Page 23 

9. Miscellaneous Sources 

Emission 

Source ID 

No.

Emission Source 

Description

Control 

Device ID 

No.

Control Device 

Description

Emission 

Point ID No.

214-613 Mine Pit Diesel Generator None None 801

326-800-

484

Calciner Building Diesel 

Generator

None None 802

CP No. 1 Cooling Pond No. 1 None None 910-913 

(State-only 

requirements)

CP No. 2 Cooling Pond No. 2 None None 914-921 

(State-only 

requirements)

CP No. 3* Cooling Pond No. 3 None None 914-922 

(State-only 

requirements)

GYP Pond 

No. 1

Gypsum Stack Pond No. 1 None None 930-931 

(State-only 

requirements)

GYP Pond 

No. 2

Gypsum Stack Pond No. 2 None None 932-944 

(State-only 

requirements)

GYP Pond 

Nos. 5 

and 6

Gypsum Stack Pond No. 5 

and 6

None None 945-950 

(State-only 

requirements)

GYP Pond 

No. 3/4

Gypsum Stack Pond No. 3/4 None None 951-954 

(State-only 

requirements)

999 Mining operations fugitives None None 999 

R1-R8 Reclaim Areas 1,2,3,4,5,6,7, 

and 8

None None

* This emission source (ID No. CP No. 3) is listed as 502(b)(10) changes per NCAC 2Q .0523. The permit shield described in 

General Condition R does not apply. 

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SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS

2.1- Emission Source(s) and Control Devices(s) Specific Limitations and 

Conditions

The emission source(s) and associated air pollution control device(s) and appurtenances listed below are 

subject to the following specific terms, conditions, and limitations, including the testing, monitoring, 

recordkeeping, and reporting requirements as specified herein: 

2.1.1 SULFURIC ACID PRODUCTION AREA

2.1.1.A Sulfuric Acid Plants

one (1) glass fiber packed mist eliminator and a mesh pad installed on the final absorbing 

tower (ID No. 3-1) of one (1) double-absorption sulfuric acid plant No. 3 (ID No. S-3) {Source 

ID No. 101} 

one (1) glass fiber packed mist eliminator containing 18 candles and an additional two-inch 

layer of knitted wire mesh installed on the final absorbing tower (ID No. 4-1) of one (1) 

double-absorption sulfuric acid plant No. 4 (ID No. S-4) {Source ID No. 102} BACT 

one (1) glass fiber packed mist eliminator containing 18 candles and an additional two-inch 

layer of knitted wire mesh installed on the final absorbing tower (ID No. 5-1) of one (1) 

double-absorption sulfuric acid plant No. 5 (ID No. S-5) {Source ID No. 103} and 

one (1) glass fiber packed mist eliminator containing 18 candles and an additional two-inch 

layer of knitted wire mesh installed on the final absorbing tower(ID No. 6-1 of one (1) double 

adsorption sulfuric acid plant No. 6 (ID No. S-6) {Source ID No. 104}

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur dioxide 4 pounds per ton of sulfuric acid produced 2D .0524 (Subpart H) 

operating scenarios in section 2.2.A.1.a 2D .501(e) 

2D .0530 (NAAQS 

modeling limit) BACT

nitrogen 

dioxide 

5.8 pounds per ton of sulfuric acid produced 2D .0519 

visible 

emissions 

10 percent opacity 2D .0524 (Subpart H) 

sulfuric acid 

mist 

0.15 pounds per ton of sulfuric acid produced 2D .0524 (Subpart H) 

7.5 pounds per hour (calculated as a rolling annual 

average for five calendar years) (S-3)*

2D .0530 BACT

7.5 pounds per hour (calculated as a rolling annual 

average for five calendar years) (S-4)**

2D .0530 BACT

sulfuric acid 

mist (PM10), 

sulfur dioxide, 

nitrogen 

dioxide 

See 2.3 2D .0543 (BART) 

ES101 and ES102 only 

TAPS see 2.2 2D.1100 

*Upon completion of modification submitted in application No. A0700071.99A 

**Upon completion of modification submitted in application No. A0700071.02B

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Appendix L.10 - 573 

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Page 25 

1. 15A NCAC 2D. 0501(e) : COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

 Emission Standard

a. Sulfur dioxide emissions from sulfuric acid plants Nos. 3, 4, 5 and 6 shall comply with 

the limits found in 2.2.A.1.a. 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance 

with 15A NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are 

above the limit given in Section 2.1.1. A. 1. a., the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0501(e).

 Monitoring/ Recordkeeping

c. The Permittee shall measure sulfur dioxide emissions using a continuous emissions 

monitoring system (CEMS) as required in 2.1.1.A.3.g and h. To assure compliance with 

the facility operating requirements in 2.2.A.1.a, the Permittee shall maintain production 

records sufficient to demonstrate that the allowed combination of equipment was 

operating. Failure to maintain these records shall be deemed non-compliance with 15A 

NCAC 2D .0501(e). If the results of this monitoring show emissions in excess of the 

standards in a above, the Permittee shall be deemed in noncompliance with NCAC 2D 

.0501(e).

 

 Reporting [15A NCAC 2Q .0508(f)] 

 d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding 

six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

2. 15A NCAC 2D .0519 NITROGEN OXIDE EMISSIONS FROM SULFURIC ACID 

MANUFACTURING PLANTS 

Emission Standard

 a. The emissions of nitrogen dioxide shall not exceed 5.8 pounds per ton of acid produced 

from any sulfuric acid manufacturing plant. 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ found in Section 3. If the results of this 

test are above the limit given in Section 2.1.1. A. 2. a. above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0519. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. The Permittee shall demonstrate compliance with the standard in 2.a by conducting a 

performance test on at least one of the sulfuric acid plants at least once per every five 

year permit cycle. The test shall be conducted in accordance with 40 CFR Part 60 

Appendix A, Reference Method 7, or approved alternative method as described in 40 

CFR 60.8(b). The results of the testing must be submitted to the Division within 45 days 

of the completion of the test. The Permittee shall be deemed in noncompliance with 2D 

.0519 if the test is not performed with in the required time frame or if the results show an 

exceedance of the emission standard contained in 2.a above. 

 

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3. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART H 

 Emission Standard

a. The Permittee shall comply with all applicable provisions, including the notification, 

testing, , recordkeeping, and monitoring requirements contained in Environmental 

Management Commission Standard 15A NCAC 2D .0524 "New Source Performance 

Standards (NSPS) as promulgated in 40 CFR Part 60 Subpart H, including Subpart A 

"General Provisions."[15A NCAC 2D .0524] for each of the sulfuric acid plants. 

Emission Limitations [15A NCAC 2D .0524] 

b. Sulfur dioxide emissions from these sources shall not exceed 4 pounds per ton of sulfuric 

acid produced per 3 hour block average. 

 c. Sulfuric acid mist emissions from these sources shall not exceed 0.15 pounds per ton of 

sulfuric acid produced. 

d. Visible emissions shall not be more than 10 percent opacity when averaged over a sixminute period. 

Testing [15A NCAC 2Q .0508 (f)] 

e. If emissions testing is required, the Permittee shall perform such testing in accordance 

with General Condition JJ. If the results of this test are above the limit given in Section 

2.1.1.A.3.a to d above, the Permittee shall be deemed in noncompliance with 15A NCAC 

2D .0524.

 f. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance 

with the sulfuric acid mist emission limit above by testing each sulfuric acid plant (ID 

No. S-3 to S-6) annually for sulfuric acid mist in accordance with a testing protocol 

approved by the DAQ. (Note: To allow a concise description of the and sulfuric acid 

testing requirements in one place the details below cover all four sulfuric acid plants and 

describe testing to document compliance with NCAC 2D .0524 (Subpart H), 2D .1100, as 

well as 2D .0530): 

i. If Sulfuric Acid Plants 3 or 4 conduct more than one test in a single calendar 

year, all tests shall be averaged to calculate the averaged value for that calendar 

year. In addition, the facility shall use the averaged annual test result to 

calculate a five year rolling average. 

ii. The rolling average shall be calculated using calendar years. The facility shall 

use historical test data to begin reporting the rolling five year average emission 

rate requirement until five years of new data have been acquired. 

iii. If any of Sulfuric Acid Plants 3, 4, 5, or 6 operate for any day at a production 

rate exceeding that listed for that plant in Section 1, then the production rate 

required during annual testing for that plant will be determined as follows. The 

plant shall be tested annually at an hourly production rate at least 90 percent of 

the highest daily rate, as documented by the production records over the last 

production year, divided by 24. If an annual test, at a sufficient production rate 

as described above, was conducted within two weeks of the date that the highest 

production rate occurred, then the annual test for that plant for the following 

year may use the normal production rate as described below. 

iv. If any of Sulfuric Acid Plants 3, 4, 5 and 6 do not operate for any day at a 

production rate exceeding that listed for that plant in the Permitted Source List 

II.A.1 through 4, then the production rate required during annual testing for that 

plant will be determined as follows. The plant shall be tested annually at a rate 

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Appendix L.10 - 575 

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Permit 04176T3? DRAFT 

Page 27 

demonstrable by production records to be equal to or greater than the normal 

production rate of the source. 

v. The normal production rate (hourly) shall be calculated by dividing the total 

annual production for a given plant by the number of hours that plant was run 

during that year. The production rate for the source test must be approved by 

the Division of Air Quality in advance of the test. The facility shall establish the 

production rate, either 90 percent of highest or normal, using the production 

records over the last production year. A copy of the production records must 

accompany the request . 

 If the results of this test are above the limit given in Section 2.1.1. A.3.c. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524.

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

 g. The Permittee shall measure sulfur dioxide emissions using a continuous emissions 

monitoring system (CEMS). The calibration and calculation methods shall be as 

described in 40 CFR Part 60.84 and approved by the division before use. The Permittee 

shall record in a logbook (written or electronic format) the results of the CEMS. The 

Permittee shall also record in the logbook the times of start up and shutdown of each 

sulfuric acid plant. The Permittee shall be deemed in noncompliance with 15A NCAC 

2D .0524 if these records are not kept.

 

h. The Permittee shall maintain in a logbook (written or electronic format) production data 

sufficient to document the calculation of the normal production rate for determining the 

appropriate production rates at which to conduct the testing described above. The 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these 

records are not maintained. 

i. The Permittee shall calculate sulfur dioxide emissions in the format of the limit, as 

described in 40 CFR Part 60.84(b). The data will be in the form of three-hour block 

averages, as described in 40 CFR Part 60.84(e). If a three-hour block average during 

normal operation (not start-up or shut-down or malfunction) shows emissions exceeding 

the limit in Section 2.1.1.A.3.b above, the Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0524. 

 j. To assure compliance, once a month the Permittee shall observe the emission points of 

these sources for any visible emissions above normal. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit. If 

visible emissions from this source are observed to be above normal, the Permittee shall 

either: (a) be deemed to be in noncompliance with 15A NCAC 2D .0524 or (b) 

demonstrate that the percent opacity from the emission points of the emission source in 

accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in Section 

2.1.1.A.3.d. above. If the demonstration in (b) above cannot be made during the 

monitoring period, the Permittee shall be deemed to be in noncompliance with 15A 

NCAC 2D .0524. 

 k. The results of the visible emissions monitoring shall be maintained in a logbook (written 

or electronic format) on-site and made available to an authorized representative upon 

request. The logbook shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each observation and/or test noting those sources with emissions 

that were observed to be in noncompliance along with any corrective actions 

taken to reduce visible emissions; and 

 iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these 

records are not maintained. 

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Appendix L.10 - 576 

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Page 28 

 Reporting [15A NCAC 2Q .0508(f)] 

 l. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding 

six-month period between January and June. The report shall contain the following: 

. 

i. any excess sulfur dioxide emission reports as measured by the continuous 

emission monitor (CEM), by January 30 of each calendar year for the preceding 

six-month period between July and December and July 30 of each calendar year 

of each calendar year for the preceding six-month period between January and 

June. If there are no excess emissions during the calendar quarter, the Permittee 

shall submit a statement indicating that no excess emissions occurred during the 

reporting period; and 

ii. All instances of deviations from the requirements of this permit must be clearly 

identified. 

 Start-Up Procedures for Sulfuric Acid Plants [40 CFR Part 60 Subpart H] 

m. Only one sulfuric acid plant at a facility should be in start up mode and burning sulfur at 

a time. There are times when it will be acceptable for more than one sulfuric acid plant 

to be in the start-up mode at the same time, provided the following condition is met. It is 

not acceptable to initiate sulfur burning at one sulfuric acid plant when another plant at 

the same facility is emitting SO2 at a rate in excess of the emission limits imposed by the 

permit or rule, as determined by the CEMs emission rates for the immediately preceding 

20 minutes. 

n. A plant start-up must be at the lowest practicable operating rate, not to exceed 70 percent 

of the designed operating rate, until the SO2 monitor indicates compliance. Because 

production rate is difficult to measure during start-up, if a more appropriate indicator 

(such as blower pressure, furnace temperature, gas strength, blower speed, number of 

sulfur guns operating, etc.) can be documented, tested, and validated, the Department will 

accept this in lieu of directly documenting the operating rate. Implementation requires 

the development of a suitable list of surrogate parameters to demonstrate and document 

the reduced operating rate on a plant-by-plant basis. Documentation that the plant is 

conducting start-up at the reduced rate is the responsibility of the owner or operator. 

After start-up has begun, the foreman may approve an increase in rate if he judges that 

will result in faster reduction of emissions. 

o. Sulfuric acid plants are authorized to emit excess emissions from start-up for a period of 

three consecutive hours provided best operational practices, in accordance with this 

agreement, to minimize emissions are followed. No plant shall be operated (with sulfur 

as fuel) out of compliance for more than three consecutive hours. Thereafter, the plant 

shall be shut down. The plant shall be shut down (cease burning sulfur) if, as indicated 

by the continuous emission monitoring system, the plant is not in compliance within three 

hours of start-up. Restart may occur as soon as practicable following any needed repairs 

or adjustments, provided the corrective action is taken and properly documented. If the 

only reason for high emissions is low catalyst temperatures, the plant need not be shut 

down at the end of three hours as long as emissions have been decreasing. 

p. Cold Start-Up Procedures

 

 i. Converter 

(A) The inlet and outlet temperature at the first two masses of catalyst shall 

be sufficiently high to provide immediate ignition when SO2 enters the 

masses. In no event shall the inlet temperature to the first mass be less 

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Appendix L.10 - 577 

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than 800oF or the outlet temperature to the first two masses be less than 

700oF. These temperatures are the desired temperatures at the time the 

use of auxiliary fuel is terminated. 

(B) The gas stream entering the converter shall contain SO2 at a level less 

than normal, and sufficiently low to promote catalytic conversion to 

SO3. 

 ii. Absorbing Towers 

The concentration, temperature, and flow of circulating acid shall be as near 

to normal conditions as reasonably can be achieved. In no event shall the 

concentration be less than 96 percent H2SO4. 

 Warm Restart Procedures

 i. Converter 

The inlet and outlet temperatures of the first two catalyst masses should be 

sufficiently high to ensure conversion. One of the following three 

conditions must be met: 

(A) The first two catalyst masses inlet and outlet temperatures must be at a 

minimum of 700 F; or 

(B) Two of the four inlet and outlet temperatures must be greater than or 

equal to 780 F; or 

 

(C) The inlet temperature of the first catalyst must be greater than or equal 

to 600oF and the outlet temperature greater than or equal to 800oF. 

Also, the inlet and outlet temperatures of the second catalyst must be 

greater than or equal to 700oF. 

Failure to meet one of the above conditions, requires use of cold 

start-up procedures, unless the Superintendent (or Acting 

Superintendent) approves otherwise. 

To allow for technological improvement of individual plant conditions, 

alternative conditions will be considered by the Department in 

appropriate cases. 

 ii. Absorbing Towers 

 

The concentration, temperature, and flow of circulating acid shall be as near 

to normal conditions as reasonably can be achieved. In no event shall the 

concentration be less than 96 percent H2SO4. 

4. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

Emission standard - BACT

a. For Sulfuric Acid Plant 3 (ID No. S-3) the following table shall describe the emission 

standards 

Source Pollutant BACT Technology Emission Limit 

Sulfuric acid plant No. 3 (ID No. S-3) {Source 

ID No. 102} 

Sulfur dioxide dual adsorption 

catalyst 

7600 pounds per day 

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Sulfuric acid plant No. 3 ( ID No. S-3) {Source 

ID No. 102} 

sulfuric acid 

mist/TSP/PM10

Vertical tube mist 

eliminator 

 7.5 pounds per hour (calculated 

as a rolling annual average for 

five calendar years) 

b. For Sulfuric Acid Plant 4 (ID No. S-4) the following table shall describe the emission 

standards: 

Source Pollutant BACT Technology Emission Limit 

Sulfuric acid plant No. 4 (ID No. S-4) {Source 

ID No. 102} 

Sulfur dioxide dual adsorption 

catalyst 

7032 pounds per day 

Sulfuric acid plant No. 4 ( ID No. S-4) {Source 

ID No. 102} 

sulfuric acid 

mist/TSP/PM10

Vertical tube mist 

eliminator 

 7.5 pounds per hour (calculated 

as a rolling annual average for 

five calendar years) 

c. The emission standard contained in 4.a above shall only become effective upon the 

completion of the modification as submitted in A0700071.99A. This modification will 

become complete upon the replacement of the final absorbing tower. Upon completion 

of the modification the Permittee shall conduct a performance test to document the sulfur 

dioxide emissions as described in 4.f at an emission rate at least 90 percent of 7600 

pounds per day limit or at a rate acceptable to the Division as described in General 

Condition JJ. Prior to the completion of the modification the sulfur dioxide emission 

limit will be 7032 pounds per day. 

d. The emission standard contained in 4.b above shall only become effective upon the 

completion of the modification as submitted in A0700071.02B. 

Testing [15A NCAC 2Q .0508 (f)] 

 e. If emissions testing is required, the Permittee shall perform such testing in accordance 

with General Condition JJ. If the results of this test are above the limits given in Section 

2.1.1.A.4.a and b., the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.0530.

 f. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance 

with the emission limits above by testing the sulfuric acid plants Nos. 3 and 4 (ID Nos.S3 and S-4) annually for sulfuric acid mist in accordance with a testing protocol approved 

by the DAQ. Details of the emissions testing and requirements can be found in Section 3 

- General Condition JJ. For further details see 2.1.1.A.3.f. If the results of this test are 

above the limits given in Sections 2.1.1.A.4.a or b. above, the Permittee shall be deemed 

in noncompliance with 15A NCAC 2D .0530. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]

 g. The Permittee shall maintain in a logbook (written or electronic format) production data 

sufficient to document the calculation of the normal production rate for determining the 

appropriate production rates at which to conduct the testing described above. The 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records 

are not maintained. 

h. The Permittee shall measure sulfur dioxide emissions using a continuous emissions 

monitoring system (CEMS) as required in 2.1.1.A.3.g and h. If the results of this 

monitoring show emissions in excess of the standards in a and b above, the Permittee 

shall be deemed in noncompliance with NCAC 2D .0530. 

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Appendix L.10 - 579 

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Reporting [15A NCAC 2Q .0508 (f)] 

i. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding 

six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified 

 STATE-ONLY REQUIREMENT: 

5. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT - Pursuant 

to 15A NCAC 2D .1100, in accordance with the approved application for an air toxic compliance 

demonstration and in addition to other limits described in Section 2.2.A.3 the following permit 

limits shall not be exceeded: 

EMISSION SOURCE(S) TOXIC AIR POLLUTANT(S) EMISSION LIMIT(S)

Sulfuric acid Plant No. 3 (ID No. S-3) 

Sulfuric acid Plant No. 4 (ID No. S-4) 

Sulfuric acid Plant No. 5 (ID No. S-5) 

Sulfuric acid Plant No. 6 (ID No. S-6) 

Sulfuric acid mist 

Sulfuric acid mist 

Sulfuric acid mist 

Sulfuric acid mist 

10.00 pounds per hour 

9.25 pounds per hour 

17.00 pounds per hour 

18.00 pounds per hour 

[15A NCAC 2Q .0501 (c)(4)]

 a. If emissions testing is required, the Permittee shall perform such testing in accordance 

with 15A NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are 

above the limit given in Section 2.1.1. A. 1. a., the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1100.

 b. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance 

with the emission limit(s) above by testing each sulfuric acid plant (ID Nos. S-3 to S-6) 

annually for sulfuric acid mist in accordance with a testing protocol approved by the 

DAQ. Details of the emissions testing and requirements can be found in Section 3 - 

General Condition JJ. Further testing details can be found in 3.f. If the results of this test 

are above the limit given in Section 2.1.1. A. 5 above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1110.

 

 Monitoring/Recordkeeping /Reporting [15A NCAC 2Q .0508(f)] 

 c. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding 

six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

2.1.1.B. Auxiliary Boiler

 No. 2 fuel oil-fired boiler { ID No. BW-2} 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Particulate 

matter 

Boiler (Source ID No. 110 new) 0.268 lb./million Btu 2D .0503 

visible 

emissions 

20 percent opacity 2D .0524(Subpart Dc)*

sulfur dioxide 2.3 pounds per million Btu heat input 2D .0516 

fuel oil sulfur content limit of 0.5 percent* 2D .0524 (Subpart Dc ) 

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fuel oil sulfur content limit of 0.3 percent* 2Q .0317(a)(1) 

40 tons per year* 2Q .0317(a)(1) 

TAPS see 2.2 2D.1100 

*Boiler (ID No. 110 new) only 

1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT 

EXCHANGERS

 Emission Standard 

 a. Emissions of particulate matter from the combustion of No. 2 fuel oil, that are discharged from 

this source into the atmosphere shall not exceed the following emission limits per million Btu 

heat input. [15A NCAC 2D .0503(a)]: 

Source Emission Limit(s)

[1]Boiler (Source ID No. 110 new) 0.268 lb./million Btu

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.B.1. a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0503. 

 Monitoring/Recordkeeping/Reporting 

 c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of 

No. 2 fuel oil in this source. 

2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

 Emission Standard

a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat 

input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other 

substances shall be included when determining compliance with this standard. [15A NCAC 2D 

.0516] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.B.2. a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0516. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c.. No monitoring/recordkeeping is required for sulfur dioxide emissions from No. 2 fuel oil for this 

source. 

3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

 a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

 

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 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.B.4.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0516 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

 c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural 

gas/propane/No. 2 fuel oil in this source. 

4. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART Dc 

 Emission Standard

a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management 

Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as 

promulgated in 40 CFR Part 60 Subpart Dc, including Subpart A "General Provisions."[15A 

NCAC 2D .0524]for the boiler ID No. 110 new. 

Emission Limitations [15A NCAC 2D .0524] 

b. The maximum sulfur content of any fuel oil received and burned in the boiler shall not exceed 0.5 

percent by weight. 

c. Visible emissions from this source shall not be more than 20 percent opacity when averaged over a 

six-minute period, except for one six-minute period per hour of not more than 87 percent opacity. 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 d. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.B.4.1.b or c above, the Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0516 

 Monitoring [15A NCAC 2Q .0508(f)] 

e. To assure compliance, the Permittee shall monitor the sulfur content of the fuel oil by using fuel 

oil supplier certification of an agglomerated sample of all shipments received per month. The 

results of the fuel oil supplier certifications shall be recorded in a logbook (written or electronic 

format) on a quarterly basis and include the following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; and 

iv. a certified statement signed by the responsible official that the records of fuel oil supplier 

certification submitted represent all of the fuel oil fired during the period. 

. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

f. In addition to any other recordkeeping required by 40 CFR § 60.48c or recordkeeping 

requirements of the EPA, the Permittee shall record and maintain records of the amounts of fuel 

fired during each month. The Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.0524 if these records are not maintained.

 Reporting [15A NCAC 2Q .0508(f)] 

g. In addition to any other reporting required by 40 CFR § 60.48c or notification requirements to the 

EPA, the Permittee is required to NOTIFY the DAQ in writing of the following: 

i. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding sixBART Related Documentation 

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month period between January and June. The report shall contain the following fuel 

supplier information; 

(A) the name of the oil supplier 

(B) a statement from the oil supplier that the oil complies with the specification under the 

definition of distillate oil in 40 CFR § 60.41c; and 

(C) a certified statement signed by the owner or operator of an affected facility that the records 

of fuel supplier certification submitted represents all of the fuel fired during the semi annual 

period. 

ii. All instances of deviations from the requirements of this permit must be clearly identified. 

5. 15A NCAC 2Q.0317(a)(1): AVOIDANCE OF PREVENTION OF SIGNIFICANT 

DETERIORATION 

a. In order to avoid applicability of 15A NCAC 2D .0530(g), the boiler (ID No. BW-2) shall 

discharge into the atmosphere less than 40 tons of sulfur dioxide per consecutive 12-month 

period.. [15A NCAC 2Q .0317(a)(1)] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.B.5.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC Q .0317. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. The Permittee shall maintain an emissions log (written or electronic form) which demonstrates 

that actual annual (12-month) emissions of sulfur dioxide from the above source are less than 40 

tons. The following data will be measured and recorded, and calculations performed to obtain 

actual sulfur dioxide emissions. The Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .0530 if the sulfur dioxide emissions exceed the above limit. The log must be made 

available to an authorized representative upon request. 

To assure compliance, the Permittee shall monitor the sulfur content of the fuel oil by using fuel 

oil supplier certification of an agglomerated sample of all shipments received per month. The 

results of the fuel oil supplier certifications shall be recorded in a logbook (written or electronic 

format) on a quarterly basis and include the following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; and 

iv. a certified statement signed by the responsible official that the records of fuel oil supplier 

certification submitted represent all of the fuel oil fired during the period. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2Q.0317(a)(1) if the sulfur 

content of the oil is not monitored and recorded. To ensure federal enforceability of this limit, 

the following restrictions shall apply: 

 

i. the amount of fuel oil used shall be less than 1,870,000 gallons per consecutive 12-month 

period; and 

 ii. the sulfur content of the fuel oil shall be limited to 0.3 percent by weight. 

Reporting Requirements [15A NCAC 2Q .0508 (f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities within 30 

days after each calendar year quarter, due and post marked on or before January 30 of each 

calendar year for the preceding three-month period between October and December, April 30 of 

each calendar year for the preceding three-month period between January and March, July 30 of 

each calendar year for the preceding three-month period between April and June, and October 30 

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for the calendar year for the preceding three-month period between July and September. The 

report shall contain the following: 

i the monthly sulfur dioxide emissions for the previous 14 months. The emissions must be 

calculated for each of the three 12-month periods over the previous 14 months. The 

emissions shall be calculated as follows: 

 X = Z x 157 lbs sulfur dioxide x S 

 1000 gallon fuel oil 

 Where: X is the total actual emissions of sulfur dioxide in pounds 

 Z is the amount of fuel oil used in the boilers in gallons 

 S is the percent sulfur in the fuel oil 

ii. The monthly fuel use for the previous 14 months. 

iii. All instances of deviations from the requirements of this permit must be clearly identified 

2.1.1.C. Lime Storage Silos 

three (3) bagfilters (ID Nos. 417-503-471, 417-755-471 and 417-756-471) installed one each on 

three (3) lime silos Nos. 4, 5, and 6 (water treatment area) {Source ID Nos. 121, 122, and 123}

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Particulate 

matter 

E = 4.10 x P 0.67 Where 

E = allowable emission rate in pounds per hour and P = 

process weight in tons per hour 

2D .0515 

Visible 

emissions 

20 percent opacity 2D .0521 

TAPS see 2.2 2D.1100 

PM10 See 2.3 2D .0543 (BART) 

ES-121 only 

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.C.1.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0515. 

 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from the lime silos shall be controlled by the bagfilters. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

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manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or 

if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the 

ductwork and bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from the lime silos shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.C.2.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0521. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. The requirements for 2D .0515 shall be sufficient to meet the requirements of 2D .0521. 

2.1.2. MILL AREA

2.1.2.A Calciners Four (4) duplex cyclones exhausting two each to two (2) fixed throat venturi type wet scrubbers 

(430 gallons per minute minimum permitted liquid injection rate per unit when wet electrostatic 

precipitator is not in operation) exhausting one each to one of two modules of one (1) wet 

electrostatic precipitator (ID Nos. 339-381-476A and 339-381-476B) installed on two (2) coal/ 

coke/ "off-spec" used oils/ "off-spec" used oil sludge/ used glycols/ No. 6 fuel oil-fired vertical 

fluidized bed, phosphate rock calcining units Nos. 1 and 2 (54.833 million Btu per hour nominal 

heat input each) {Source ID Nos. 201 and 202} 

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Four (4) duplex cyclones exhausting two each to two (2) fixed throat venturi type wet scrubbers 

(430 gallons per minute minimum permitted liquid injection rate per unit when wet electrostatic 

precipitator is not in operation) exhausting one each to one of two modules of one (1) wet 

electrostatic precipitator (ID Nos.339-381-476C and 339-381-476D) installed on two (2) coal/ 

coke/ No. 6 fuel oil-fired vertical fluidized bed, phosphate rock calcining units Nos. 3 and 4 

(54.833 million Btu per hour nominal heat input each) {Source ID Nos. 203 and 204} 

Two (2) duplex cyclones exhausting to a fixed throat venturi type wet scrubber (250 gallons per 

minute minimum permitted liquid injection rate per unit) when wet electrostatic precipitator is not 

in operation exhausting to one module of one (1) wet electrostatic precipitator installed on a coal/ 

coke / No. 6 fuel oil-fired vertical fluidized bed, phosphate rock calcining unit No. 5 (54.833 

million Btu per hour nominal heat input each) {Source ID No. 205} 

Two (2) duplex cyclones exhausting to one (1) fixed throat venturi type wet scrubber (430 gallons 

per minute minimum permitted liquid injection rate per unit when wet electrostatic precipitator is 

not in operation) exhausting to one module of one (1) wet electrostatic precipitator installed on 

one (1) coal/ coke/ No. 6 fuel oil-fired vertical fluidized bed, phosphate rock calcining unit No. 6 

(54.833 million Btu per hour nominal heat input each) {Source ID No. 206}

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 

MACT

0.08 grains/dscf 40 CFR 63 Subpart AA 

E=55 x P0.11 where E = allowable emission rate in pounds 

per hour and P = rock throughput in tons per hour 

2D .0515 

1992 pounds per day total from all calciners 2D .0501(e) 

sulfur dioxide 0.75 pounds per million Btu 2D .0501(e) 

1026 pounds per day 2D .0501(e) 

visible 

emissions 

40 percent opacity (calciners 1, 2, 3, and 4) 2D .0521 

20 percent opacity (calciners 5 and 6) 2D .0521 

TAPS see 2.2 2D.1100 

PM10, sulfur 

dioxide, 

nitrogen 

dioxide 

See 2.3 2D .0543 (BART) 

1. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

a. Operation of the six calciners (ID Nos. 201 to 206) shall be limited as follows: [15A NCAC 2D 

.0501(e)] 

i. All calciners considered together shall be limited to 1992 pounds per day of PM10 

emissions total. 

ii. Each calciner shall be limited to 0.75 pounds of sulfur dioxide emissions per million Btu 

consumed. 

iii. All calciners considered together shall be limited to 1026 pounds per day of sulfur 

dioxide emissions. 

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Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.2.A. 1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 

c. Under the provisions of NCGS 143-215.108, the Permittee shall verify the allowable ranges of 

baseline average values for secondary voltage for the WESP’s as described below by annually 

testing the calciners for PM/ PM-10 in accordance with a testing protocol approved by the DAQ. 

The Permittee shall also use this testing to demonstrate compliance with the PM-10 emission limit 

above (1.a.i). Details of the emissions testing and requirements can be found in Section 3 - 

General Condition JJ. The calciners shall be tested annually at a rate demonstrable by production 

records to be equal to or greater than the normal production rate of the source. The normal 

production rate (hourly) shall be calculated by dividing the total annual production for each 

calciner by the number of hours that calciner was run during that year. The normal production rate 

for the source test must be approved by the Division of Air Quality in advance of the test. The 

facility shall establish the normal production rate using the production records over the last 

production year. A copy of the production records must accompany the request. At least one 

twelfth of the time during the test the WESP shall be in wash mode. If the results of this test are 

above the limit given in Section 2.1 A. 1. a.i above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0501. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

daily sulfur dioxide emission limit above (1.a.iii) by testing one calciner (ID Nos. 201 through 

206) annually for sulfur dioxide in accordance with a testing protocol approved by the DAQ. 

Details of the emissions testing and requirements can be found in Section 3 - General Condition 

JJ. The selected calciner shall be tested annually at a rate demonstrable by production records to 

be equal to or greater than the normal production rate of the source. The normal production rate 

(hourly) shall be calculated by dividing the total annual production for the selected calciner by the 

number of hours that calciner was run during that year. The normal production rate for the source 

test must be approved by the Division of Air Quality in advance of the test. The facility shall 

establish the normal production rate using the production records over the last production year. A 

copy of the production records must accompany the request. If the results of this test are above the 

limit given in Section 2.1 A. 1. a.ii and iii above, the Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0501. 

 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]

e. To assure compliance with 1.a.ii above, the Permittee shall monitor the sulfur and heat content of 

all the coal or coke burned during the period by using coal supplier certification per total 

shipment received. The coal supplier certification shall be recorded in a logbook (written or 

electronic format) per total shipment and include the following information: 

 i. the name of the coal/coke supplier; and 

 ii. a statement verifying that the methods used to determine the maximum sulfur content of 

the coal was in accordance with the following: 

 (A) sampling - ASTM Method D 2234; 

 (B) preparation - ASTM Method D 2013; 

 (C) gross calorific value (Btu) - ASTM Method D 5865; 

 (D) moisture content - ASTM Method D 3173; and 

 (E) sulfur content - ASTM Method D 3177 or ASTM Method D 4239. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .501(e) if the sulfur and 

heat content of the coal is not monitored and recorded. 

f. To assure compliance with 1.a.ii above, the Permittee shall monitor the sulfur and heat content of 

all liquid fuels burned during the period by using fuel supplier certification. The results of the 

fuel supplier certifications shall be recorded in a logbook (written or electronic format) on a 

quarterly basis and include the following information: 

i. the name of the fuel supplier; 

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ii. the maximum sulfur content of the fuel received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; 

iv. the minimum heat content of the fuel received during the quarter; 

v. the method used to determine the minimum heat content of the fuel; and 

vi. a certified statement signed by the responsible official that the records of fuel supplier 

certifications submitted represent all of the liquid fuel fired during the period in the calciners. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if the sulfur and 

heat content of the fuel is not monitored and recorded. 

 g. The permittee shall ensure compliance with the PM/PM10 emission limits stated above by 

monitoring the following operational parameters: 

i. Mass flowrate of phosphorus-bearing feed material to the process 

ii. Wet electrostatic precipitators secondary voltage. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if these records 

are not kept. 

h. The Permittee shall record in a logbook (written or electronic format) the following: 

i. a daily record of phosphate rock feed by determining the total mass rate in short ton/hour of 

phosphorus bearing feed using a monitoring system for measuring mass flowrate 

ii. Wet electrostatic precipitators secondary voltage.

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if these records 

are not kept or if any exceedances of the limits in Section 2. 1(a) are determined. 

 

 Reporting [15A NCAC 2Q .0508(f)] 

 i. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS 

AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING PLANTS 15a 

NCAC 2D .1111: Maximum Achievable Control Technology 

 Emission Standard

 a. Operation of the six calciners shall be limited as follows: [63.602 (d)] 

 i. No calciner (ID Nos. 201 through 206) shall discharge into the atmosphere gases which contain 

particulate matter in excess of 0.080 grains per dry standard cubic foot (gr/dscf). 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.2.B.2. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 c. Under the provisions of NCGS 143-215.108, the Permittee shall verify the allowable minimum 

secondary voltage for the WESP’s as described below by annually testing the calciners for PM/ PM-10 

in accordance with a testing protocol approved by the DAQ. The Permittee shall also use this testing to 

demonstrate compliance with the PM-10 emission limit above (1.a.i). Details of the emissions testing 

and requirements can be found in Section 3 - General Condition JJ. The calciners shall be tested 

annually at a rate demonstrable by production records to be equal to or greater than the normal 

production rate of the source. The normal production rate (hourly) shall be calculated by dividing the 

total annual production for each calciner by the number of hours that calciner was run during that year. 

The normal production rate for the source test must be approved by the Division of Air Quality in 

advance of the test. The facility shall establish the normal production rate using the production records 

over the last production year. A copy of the production records must accompany the request. During at 

least one twelfth of the duration of the test the WESP shall be in wash mode. If the results of this test 

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are above the limit given in Section 2.1.2.A. 2. a.i above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0501. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

d.. The permittee shall ensure compliance with the PM/PM10 emission limits stated above by monitoring 

the following operational parameters: 

i. Mass flowrate of phosphorus-bearing feed material to the process 

ii. Wet electrostatic precipitators secondary voltage 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if these records are not 

kept. 

 

e. The Permittee shall record in a logbook (written or electronic format) the following: 

i. a daily record of phosphate rock feed by determining the total mass rate in short ton/hour of 

phosphorus bearing feed using a monitoring system for measuring mass flowrate. 

ii. . Wet electrostatic precipitators secondary voltage.

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if these records are 

not kept or if any exceedances of the limits in Section 2. 1(a) are determined. 

The Permittee has chosen to determine the allowed ranges for the above operating parameters by the 

method described in 40 CFR 63.605(d)(2). The Permittee has submitted the results of previous tests to 

demonstrate allowed ranges for the parameter values listed above in (f). The allowed ranges are: 

i. WESP on calciner No. 1: 37.17 minimum Kv 

ii. WESP on calciner No. 2: 36.78 minimum Kv 

iii. WESP on calciner No. 3: 40.46 minimum Kv 

iv. WESP on calciner No. 4: 38.56 minimum Kv 

v. WESP on calciner No. 5: 37.95 minimum Kv 

vi. WESP on calciner No. 6: 41.62 minimum Kv 

 Should the results of any subsequent annual performance test demonstrate that the allowed minimum 

is incorrect, the Permittee shall submit those new ranges to the Division of Air Quality for inclusion in 

this permit. If the daily averages (for any day for which there are 24 hours of normal (not startup, 

shutdown or malfunction) operation) of minimum secondary voltage is below the allowable an 

exceedance will have occurred. The WESP will be allowed a maximum of two hours per day for 

cleaning the units. During this time the secondary voltage will be allowed to drop to zero. The 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 for each exceedance. 

 Reporting [15A NCAC 2Q .0508(f)] 

f. If the following reports are not submitted the permittee shall be deemed in non-compliance with 15A 

NCAC 2D .1111: 

i. Performance test report. As required by §63.10, the owner or operator shall report the results of the 

initial and annual performance tests as part of the notification of compliance status required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected source 

shall submit an excess emissions report for any exceedance of an operating parameter limit. The 

report shall contain the information specified in §63.10. When no exceedances of an operating 

parameter have occurred, such information shall be included in the report. The report shall be 

submitted semiannually and shall be delivered or postmarked by the 30th day following the end 

of the calendar half. If exceedances are reported, the owner or operator shall report quarterly 

until a request to reduce reporting frequency is approved as described in §63.10. 

iii. Summary report. If the total duration of control system exceedances for the reporting period is 

less than 1 percent of the total operating time for the reporting period, the owner or operator 

shall submit a summary report containing the information specified in §63.10 rather than the full 

excess emissions report, unless required by the Administrator. The summary report shall be 

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submitted semiannually and shall be delivered or postmarked by the 30th day following the end 

of the calendar half. 

iv. If the total duration of control system operating parameter exceedances for the reporting period 

is 1 percent or greater of the total operating time for the reporting period, the owner or operator 

shall submit a summary report and the excess emissions report. 

 

3.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General Condition 

JJ. If the results of this test are above the limit given in Section 2.1 A. 1. a. above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0515. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Permittee shall maintain production records which specify the quantity of dry phosphate rock 

processed and shall make these records available to a DAQ authorized representative upon request.

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the production 

records are not maintained.

 d. Particulate matter emissions from the calciners (ID Nos. 201 through 206) shall be controlled by the 

WESPs as installed. To assure compliance, the Permittee shall monitor and record WESP parameters 

as described in sections 2.d and 2.e above. The permittee shall also perform inspections and 

maintenance as recommended by the manufacturer. 

e. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook shall 

record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are 

not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 f. The Permittee shall submit the results of any maintenance performed on the control devices within 30 

days of a written request by the DAQ. 

g. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

4. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

Emission Standard

a. Visible emissions from the calciners nos. 5 and 6 (ID Nos 205 and 206 ) shall not be more than 20 

percent opacity when averaged over a six-minute period. However, six-minute averaging periods may 

exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. 

In no event shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

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b. Visible emissions from the calciners nos.1, 2, 3, and4 (ID Nos 201 through 204 ) shall not be more 

than 40 percent opacity when averaged over a six-minute period. However, six-minute averaging 

periods may exceed 40 percent not more than once in any hour and not more than four times in any 24-

hour period. In no event shall the six-minute average exceed 90 percent opacity. [15A NCAC 2D 

.0521(c)] 

 Testing [15A NCAC 2D .0501(c)(8)] 

 c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(8) and General Condition JJ. If the results of this test are above the limit given in Section 2.1 

A. 4.a. or b above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

d. To assure compliance, once a month the Permittee shall observe the emission points of this source for 

any visible emissions above normal. The Permittee shall establish “normal” for the source in the first 

30 days following the effective date of the permit. If visible emissions from this source are observed 

to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance with 15A NCAC 

2D .0521 or (b) demonstrate that the percent opacity from the emission points of the emission source in 

accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 A.3. a. above. If 

the demonstration in (b) above cannot be made during the month, the Permittee shall be deemed to be 

in noncompliance with 15A NCAC 2D .0521. 

 STATE-ONLY REQUIREMENT: 

5. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT - Pursuant to 15A 

NCAC 2D .1100, in accordance with the approved application for an air toxic compliance demonstration 

and in addition to other limits described in Section 2.2.A.3 the used oil/used oil sludge/ used glycols, 

combusted in the calciners shall not contain concentrations in excess of the following: 

Substance concentration (mg/l) 

Total Halogens 

Arsenic 

cadmium 

Chromium 

Lead 

4000 

5.0 

2.0 

10.0 

100.0 

 [15A NCAC 2Q .0501 (c)(4)]

 a. If emissions testing is required, the Permittee shall perform such testing in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above the limit given in 

Section 2.1.1. A. 1. a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1100.

 b. To assure compliance, the Permittee shall monitor the sulfur content of the fuel oil by using fuel oil 

supplier certification of an agglomerated sample of all shipments received per month. The results of 

the fuel oil supplier certifications shall be recorded in a logbook (written or electronic format) on a 

quarterly basis and include the following information: 

i. the substance content of the used oil for each aggregate during the quarter; 

ii. the method used to determine the maximum substance content of the used oil; and 

iii. a certified statement signed by the responsible official that the records of testing submitted 

represent all of the used oil fired during the period. 

Failure to maintain these records shall be deemed non-compliance with 15A NCAC 2D .1110.

 

 Monitoring/Recordkeeping /Reporting [15A NCAC 2Q .0508(f)] 

 c. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

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2.1.2.B. Rock Dryer

one (1) duplex cyclone and one (1) venturi type wet scrubber installed on one (1) No. 6 

fuel oil-fired phosphate rock dryer {Source ID No. 210} 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 

MACT

0.215 pounds per ton of phosphate rock dried. 40 CFR 63 Subpart AA 

E=55 x P0.11 where E = allowable emission rate in pounds 

per hour and P = rock throughput in tons per hour 

2D .0515 

sulfur dioxide 2.3 pounds per million Btu 2D .0516 

75 pounds per day 2D .0501(e) 

visible 

emissions 

40 percent opacity 2D .0521 

TAPS see 2.2 2D.1100 

PM10, sulfur 

dioxide, 

nitrogen 

dioxide 

See 2.3 2Dv .0543 (BART) 

1. 2.1.2.B.1 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR 

QUALITY STANDARDS 

 a. Operation of the rock dryer shall be limited as follows; the rock dryer (ID No. 210) shall be 

limited to 75 pounds per day (midnight to midnight) of sulfur dioxide emissions [15A NCAC 2D 

.0501(e)]. 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.2.B.1.a, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 c. Under the provisions of NCGS 143-215.108, the Permittee shall determine the ratio of pounds of 

SO2 emitted per pound of sulfur contained in the fuel oil burned as described below by testing the 

rock dryer (ID No. 210) for SO2 and recording the fuel oil characteristics and use in accordance 

with a testing protocol approved by the DAQ. Details of the emissions testing and requirements 

can be found in Section 3 - General Condition JJ. The rock dryer shall be tested annually at a rate 

demonstrable by production records to be equal to or greater than the normal production rate of the 

source. The normal production rate (hourly) shall be calculated by dividing the total annual 

production for rock dryer by the number of hours that it was run during that year. The normal 

production rate for the source test must be approved by the Division of Air Quality in advance of 

the test. The facility shall establish the normal production rate using the production records over 

the last production year. A copy of the production records must accompany the request. If the 

annual test shows that the ratio of pounds of SO2 emissions per pound of sulfur contained in the 

fuel oil burned is less than 0.013, then subsequent tests need only to be performed once per 5-year 

permit cycle to confirm that the source does not have the potential to violate the standard. 

 

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 Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508 (f)] 

 d. Based on the results of previous stack tests, potential emissions of SO2 from this source are 

significantly less than the 75 pounds per day limit. Because it does not appear that the source has 

the potential to violate the standard, no monitoring, recordkeeping, or reporting is required.

2. 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS 

AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING PLANTS 15a NCAC 2D 

.1111: Maximum Achievable Control Technology 

Emission Standard

a. Operation of the rock dryer shall be limited as follows: [63.602 (d)] 

 i. The rock dryer (ID No. 210) shall not discharge into the atmosphere gases which contain 

particulate matter in excess of 0.215 pounds per ton of phosphate rock dried. 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.2. B. 2. 

a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall 

determine the allowable ranges of baseline average values for the pressure drop and liquid 

injection rate for the scrubber as described below by annually testing the rock dryer (ID No. 

210) for PM/ PM-10 in accordance with a testing protocol approved by the DAQ. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. The rock 

dryer shall be tested annually at a rate demonstrable by production records to be equal to or 

greater than the normal production rate of the source. The normal production rate (hourly) shall 

be calculated by dividing the total annual production for rock dryer by the number of hours that 

it was run during that year. The normal production rate for the source test must be approved by 

the Division of Air Quality in advance of the test. The facility shall establish the normal 

production rate using the production records over the last production year. A copy of the 

production records must accompany the request. If the results of this test are above the limit 

given in Section 2.1.2. B. 2. a above, the Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .1111. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

d. The permittee shall ensure compliance with the PM/PM10 emission limits stated above by 

monitoring the following operational parameters: 

i. Pressure drop across the venturi scrubber, 

ii. Liquid injection rate of the venturi scrubber, and 

iii. Mass flowrate of phosphorus-bearing output material from the process. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1110 if these records are 

not kept. 

 

e. The Permittee shall record in a logbook (written or electronic format) the following: 

i. the pressure drop and flow rate of the scrubbing liquid to the scrubber in 15-minute 

block averages. 

ii. the pressure drop and flow rate of the scrubbing liquid to the scrubber in 24-hour 

(midnight to midnight) block averages. 

iii. a daily record of phosphate rock rock output by determining the total mass rate in short 

ton/hour of phosphorus bearing output using a monitoring system for measuring mass 

flowrate. 

iv. dates, start and end times for all start-ups, shutdowns, and malfunctions. 

 The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these records 

are not kept. 

The Permittee has chosen to determine the allowed ranges for the above operating parameters 

by the method described in 40 CFR 63.605(d)(2). The Permittee has submitted the results of 

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previous tests to demonstrate allowed ranges for the parameter values listed above in (f). The 

allowed ranges are: 

i. 8.2 to 23.5 inches of water (pressure drop), 873 to 1085 gpm (flowrate) 

 Should the results of any subsequent annual performance test demonstrate that the allowed 

range is incorrect, the Permittee shall submit those new ranges to the Division of Air Quality for 

inclusion in this permit. If the daily averages (for any day for which there are 24 hours of 

normal (not startup, shutdown or malfunction) operation) of the pressure drop or flowrate to 

the scrubber exceeds the allowable range an exceedance will have occurred. The Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111 for each exceedance. 

 Reporting [15A NCAC 2Q .0508(f)] 

f.. If the following reports are not submitted the permittee shall be deemed in non-compliance with 

15A NCAC 2D .1111: 

 i. Performance test report. As required by §63.10, the owner or operator shall report the 

results of the initial and annual performance tests as part of the notification of compliance 

status required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected 

source shall submit an excess emissions report for any exceedance of an operating 

parameter limit. The report shall contain the information specified in §63.10. When no 

exceedances of an operating parameter have occurred, such information shall be included 

in the report. The report shall be submitted semiannually and shall be delivered or 

postmarked by the 30th day following the end of the calendar half. If exceedances are 

reported, the owner or operator shall report quarterly until a request to reduce reporting 

frequency is approved as described in §63.10. 

iii. Summary report. If the total duration of control system exceedances for the 

reporting period is less than 1 percent of the total operating time for the reporting 

period, the owner or operator shall submit a summary report containing the 

information specified in §63.10 rather than the full excess emissions report, unless 

required by the Administrator. The summary report shall be submitted semiannually 

and shall be delivered or postmarked by the 30th day following the end of the 

calendar half. 

iv. If the total duration of control system operating parameter exceedances for the 

reporting period is 1 percent or greater of the total operating time for the reporting 

period, the owner or operator shall submit a summary report and the excess 

emissions report. 

3.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E = 55.0 x P 0.11 - 40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 

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 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.2.B.3.a above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. The Permittee shall maintain production records which specify the quantity of dry phosphate rock 

processed and shall make these records available to a DAQ authorized representative upon 

request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the

production records are not maintained.

 d. Particulate matter emissions from the rock dryer (ID No. 210) shall be controlled by the scrubbers 

and cyclone as installed. To assure compliance, the Permittee shall monitor and record the 

pressure drops across the scrubbers and the liquid flow rates to the scrubbers, as described in 

sections 2.d and 2.e above. The permittee shall also perform inspections and maintenance as 

recommended by the manufacturer. As a minimum, the inspection and maintenance program shall 

include an annual external inspection of the ductwork and cyclone, noting the structural integrity; 

e. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed; and 

 iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are 

not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 f. The Permittee shall submit the results of any maintenance performed on the control devices within 

30 days of a written request by the DAQ. 

g. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

4. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

 a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat 

input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other 

substances shall be included when determining compliance with this standard. [15A NCAC 2D 

.0516] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.2.B.4.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0516. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The maximum sulfur content of any No. 6 fuel oil received and burned in the rock dryer shall not 

exceed 2.1 percent by weight. The Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .0516 if the sulfur content of the fuel oil exceeds this limit. 

d. To assure compliance, the Permittee shall monitor the sulfur content of the No. 6 fuel oil by using 

fuel oil supplier certification per shipment received. The results of the fuel oil supplier 

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certifications shall be recorded in a logbook (written or electronic format) on a quarterly basis and 

include the following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; and 

iv. a certified statement signed by the responsible official that the records of fuel oil supplier 

certification submitted represent all of the No. 6 fuel oil fired during the period. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content 

of the oil is not monitored and recorded.

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on 

or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January 

and June. All instances of deviations from the requirements of this permit must be clearly 

identified. 

5. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

Emission Standard

a. Visible emissions from the rock dryer (ID No. 210 ) shall not be more than 40 percent opacity 

when averaged over a six-minute period. However, six-minute averaging periods may exceed 40 

percent not more than once in any hour and not more than four times in any 24-hour period. In no 

event shall the six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)] 

 Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(8) and General Condition JJ. If the results of this test are above the limit given in Section 

2.1.2.B.5.a above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

 Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The Permittee shall establish “normal” for the source in 

the first 30 days following the effective date of the permit. If visible emissions from this source 

are observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.2.B.5.a. above. If the demonstration in (b) above cannot be made during the 

monitoring period, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D 

.0521. 

2.1.2.C PULVERIZER AND DRYER SYSTEM

two (2) parallel bagfilters (ID Nos. 341-331 and 341-332) installed on one (1) single cyclone (ID No. 341-

310) installed on one coal/coke pulverizer and thermal dryer system (ID No. 341-300) (Emission Point ID 

No. 215) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 0.031 grains per dry standard cubic foot (dscf) NCAC 2D .0524 

(40 CFR 60 Subpart Y) 

Visible 

Emissions 

20 percent opacity NCAC 2D .0524 

(40 CFR 60 Subpart Y) 

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

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1. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART Y 

 Emission Standard

a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management 

Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as 

promulgated in 40 CFR Part 60 Subpart Y, including Subpart A "General Provisions."[15A NCAC 

2D .0524] for the coal processing system. 

Emission Limitations [15A NCAC 2D .0524] 

b. Thermal gases discharged into the atmosphere shall not contain more than 0.031 grains per dscf of 

particulate matter. 

c. Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute 

period. 

Testing [15A NCAC 2Q .0501 (c)(4)]

 d. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.2.C1.a ., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)][40 CFR 60.253(a)] 

e. The Permittee shall measure the temperature of the gas stream at the exit of the thermal dryer on a 

continuous basis (CMS). The calibration and calculation methods shall be as described in 40 

CFR Part 60.253 and approved by the division before use. The Permittee shall record in a logbook 

(written or electronic format) the results of the CMS. The Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0524 if these records are not kept.

f. Particulate matter emissions from the coal processing system (ID No. 341-300 ) shall be 

controlled by 1 cyclone and 2 bagfilters. To assure compliance, the Permittee shall perform 

inspections and maintenance as recommended by the manufacturer, if any. As a minimum, the 

inspection and maintenance program shall include: 

 i. monthly external inspection of the ductwork, cyclones, and bagfilters noting the structural 

integrity; and 

ii. annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilters noting the structural integrity and the condition of the filters. 

 The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the ductwork, 

cyclones and bagfilters are not inspected and maintained.

 Reporting [15A NCAC 2Q .0508(f)] 

g. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.2.D RAILCAR HANDLING

Coal/Coke Railcar Unloader, Three Parallel Conveyor Belts, Two Single Conveyor Belts, 

Coal/Coke Crusher, and Two Coal/Coke Storage Silos 

Emission Source ID Nos. 341-100, 341-110, 341-111, 341-112, 341-120, 341-140, 341-130, 

341-200, 341-201, 341-230 (Emission Point ID Nos. 294 (a-f)) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

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Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E=55 x P0.11 -40 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 

NCAC 2D .0515 

Visible 

Emissions 

20 percent opacity NCAC 2D .0524 

(40 CFR 60 Subpart Y) 

Toxic Air 

Pollutants 

See Section 2.2 -Multiple Source NCAC 2D .1100 

1. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART Y 

Emission Standard

a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management 

Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as 

promulgated in 40 CFR Part 60 Subpart Y, including Subpart A "General Provisions."[15A NCAC 

2D .0524] for the coal handling and crushing systems. 

Emission Limitations [15A NCAC 2D .0524] 

b. Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute 

period. 

Testing [15A NCAC 2Q .0501 (c)(4)]

 c. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.2.D.1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)][40 CFR 60.253(a)] 

d. The Permittee shall control visible emissions from all of the sources above by wet suppression 

systems. The suppression systems shall not be required to operate when the coal/coke is 

intrinsically sufficiently moist to limit visible emissions to less than the above limit. In addition, 

all hood covers, conveyor belt skirts, and transfer points shall be maintained and operated in a 

manner to avoid visible emissions. 

e. The permittee shall perform maintenance as required, but in no case less frequently than an annual 

inspection of all suppression equipment (including hood covers and belt skirts. The Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0524 if this maintenance is not 

performed. 

f. The results of inspection and maintenance for the suppression equipment shall be maintained in a 

logbook (written or electronic format) on-site and made available to an authorized representative 

upon request. The logbook shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; and 

 iii. the results of maintenance performed on any control device. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these records are 

not maintained. 

2.1.2.E TRANSFER POINTS

Calcined Rock Transfer Point - Emission Source ID Belt 39 to 70.1 (Emission Point ID No. 220) 

Calcined Rock Transfer Point - Emission Source ID 223 (Emission Point ID No. 223) 

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The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E=55 x P0.11 -40 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 

2D .0515 

Visible 

Emissions 

40 percent opacity NCAC 2D .0521 

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

PM10 See 2.3 2D .0543 (BART) 

1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=55 x P0.11 -40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition 

JJ. If the results of this test are above the limit given in Section 2.1.2.E.1. a. above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0515. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The permittee shall perform maintenance as required, but in no case less frequently than an annual 

inspection of all suppression equipment (including hood covers and belt skirts). The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515 if this maintenance is not performed. 

d. The results of inspection and maintenance for the suppression equipment shall be maintained in a 

logbook (written or electronic format) on-site and made available to an authorized representative upon 

request. The logbook shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; and 

 iii. the results of maintenance performed on any control device. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not 

maintained. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

Emission Standard

a. Visible emissions from these sources shall not be more than 40 percent opacity when averaged over a 

six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once 

in any hour and not more than four times in any 24-hour period. In no event shall the six-minute 

average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.2.E.1. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0501. 

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 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)][40 CFR 60.253(a)] 

c. The permittee shall perform maintenance as required, but in no case less frequently than an annual 

inspection of all suppression equipment (including hood covers and belt skirts). The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0524 if this maintenance is not performed. 

d. The results of inspection and maintenance for the suppression equipment shall be maintained in a 

logbook (written or electronic format) on-site and made available to an authorized representative upon 

request. The logbook shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; and 

 iii. the results of maintenance performed on any control device. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are 

not maintained.

2.1.2.F FABRIC FILTER CONTROLLED TRANSFER POINTS

one fabric filter (ID No. 339-680) installed on one Calcined Rock CTS Baghouse Point - Emission Source 

ID Belt 55 to 70.1 (Emission Point ID No. 221) 

one fabric filter (ID No. 333-180) installed on one Calcined rock Transfer Point - Emission Source ID Belt 

21 to 23 or 24, or one fabric filter (ID No. 331-190) installed on one Calcined rock Transfer Point - 

Emission Source ID Belt 22 to 23 or 24) (Emission Point ID No. 222) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E=55 x P0.11 -40 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 2D .0515 

Visible 

Emissions 20 percent opacity NCAC 2D .0521 

Toxic Air 

Pollutants See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

PM10 See 2.3 2D .0543 (BART) 

1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=55 x P0.11 -40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.2.F.1. a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Permittee shall maintain production records which specify the quantity of dry phosphate rock 

processed and shall make these records available to a DAQ authorized representative upon 

request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the

production records are not maintained.

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 d. Particulate matter emissions from the conveyor belt drop point shall be controlled by the bagfilter. 

To assure compliance, the Permittee shall perform inspections and maintenance as recommended 

by the manufacturer. In addition to the manufacturer’s inspection and maintenance 

recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, 

as a minimum, the inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

e. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

 iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 f. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 

days of a written request by the DAQ. 

g. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1 A. 1. 

a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)][40 CFR 60.253(a)] 

c. Particulate matter emissions from the conveyor belt drop point shall be controlled by the bagfilter. 

To assure compliance, the Permittee shall perform inspections and maintenance as recommended 

by the manufacturer. In addition to the manufacturer’s inspection and maintenance 

recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, 

as a minimum, the inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

 iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

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The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are 

not maintained 

2.1.2.G STORAGE AREAS

One fabric filter (ID No. 320-215-478, nominal1200 square feet of surface area) installed on one Polymer 

Storage bin – Emission Source ID 224 (Emission Point ID No. 224) 

One fabric filter (ID No. 315-300-478, nominal 3000 square feet of surface area) installed on one Lime 

Storage Silo – Emission Source ID 225 (Emission Point ID No. 225) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E= 4.10 x P0.67 where E = allowable emission rate in 

pounds per hour and P = throughput in tons per hour 

2D .0515 

Visible 

Emissions 

40 percent opacity NCAC 2D .0521 

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=4.10 x P0.67 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1 .2.G.1. a. above, 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from the silos shall be controlled by the bagfilter. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or 

if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are 

not maintained.

Reporting [15A NCAC 2Q .0508(f)]

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Appendix L.10 - 602 

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 e. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 40 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 40 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1 .2.G.2. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)][40 CFR 60.253(a)] 

c. Compliance with the requirements of 2.1 .2.G.1. c and d above will be sufficient to demonstrate 

compliance with 2D .0521.

2.1.3 FERTILIZER PRODUCTION AREA

2.1.3.A Diammonium Phosphate Plant No. 1* - Emission Source ID Nos. 504-107, 504-016, 

504-009, 504-001, 504-058, 504-059, 504-060, 504-061, 504-043, 504-042, 

504-002, 504-016, 504-009, 504-030, 504-032, 504-030, 504-032, 504-016, 504-019 

(Emission Point ID No. 301) 

1. 15A NCAC 2Q.0317(a)(1): AVOIDANCE OF PREVENTION OF SIGNIFICANT 

DETERIORATION BY NETTING 

a. In order to avoid applicability of 15A NCAC 2D .0530(g), the Diammonium Phosphate Plant 

No. 1 (Emission Point ID No. 301) has ceased operation. 

2.1.3.B Diammonium Phosphate Plant No. 2 - Emission Source ID 505-104, 505-107, 505-114, 

505-110, 505-143, 505-111, 505-123C, 505-123B, 505-103, 505-121, 505-117, 

505-118 (Emission Point ID No. 303) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

64.1 pounds per hour 

238.5 tons per year 

PM/PM10 2D .0530 (BACT) 

E=9.377 x P0.3067 where E = allowable emission rate in 

pounds per hour and P = production and recycle rate of 

fertilizer 

2D .0507 

sulfur dioxide 15 pounds per hour 2D .0530 (BACT) 

2.3 pounds per million Btu 2D .0516 

visible 

emissions 

20 percent opacity 2D .0521 

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0.055 pounds per ton of equivalent P2O5 feed 2D .1100 (State only) 

0.060 pounds per ton of equivalent P2O5 feed 40 CFR 63 Subpart BB 

Total 

Fluorides 

0.058 pounds per ton of equivalent P2O5 feed 2D .0530 (BACT) 

TAPS see 2.2 2D.1100 

2.1.3.B.1.. 40 CFR PART 63 SUBPART BB: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC FERTILIZER 

PRODUCTION PLANTS 15a NCAC 2D .1111: Maximum Achievable Control 

Technology –

 Emission Standard

a. The Permittee shall not cause to be discharged into the atmosphere from any affected source any 

gases which contain total fluorides in excess of 30 grams/metric ton equivalent P2O5 feed (0.060 

pounds/ton): [63.622 (a)] 

 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1. B. 1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 

c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall conduct a 

performance test to demonstrate compliance with the applicable emission standard for the 

diammonium phosphate process line in accordance with 40 CFR 63.626. Details of the emissions 

testing and requirements can be found in Section 3 - General Condition JJ. The fertilizer plant 

(Emission Point ID No. 303) shall be tested annually at a rate demonstrable by production records 

to be equal to or greater than the normal production rate of the source. The normal production rate 

(hourly) shall be calculated by dividing the total annual production for the plant by the number of 

hours that plant was operated during that year. The normal production rate for the source test must 

be approved by the Division of Air Quality in advance of the test. The facility shall establish the 

normal production rate using the production records over the last production year. A copy of the 

production records must accompany the request. If the results of this test are above the emission 

standard given above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.1111. The results of this testing shall be saved for possible inclusion in future determinations of 

operating parameter ranges. 

d. If the Permittee produces monoammonium phosphate in this fertilizer plant (Emission Point ID 

No. 303) during the life of this permit, then the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for that monoammonium 

phosphate process line in accordance with 40 CFR 63.626 while producing monoammonium 

phosphate.. The test must be performed before the expiration date of this permit. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. If the results 

of this test are above the emission standard given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1111. The results of this testing shall be saved for possible 

inclusion in future determinations of operating parameter ranges. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

e. The permittee shall install, calibrate, maintain, and operate a monitoring system which can be used 

to determine and permanently record the mass flow of phosphorus-bearing feed material to the 

process. The monitoring system shall have an accuracy of ±5 percent over its operating range. 

The results of the monitoring shall be recorded in a log (electronic or written form). The Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring system is not 

maintained, calibrated, operated, and the results recorded. 

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f. The permittee shall maintain a daily record of equivalent P2O5 feed by first determining the total 

mass rate in short ton/hour of phosphorus bearing feed using a monitoring system for measuring 

mass flowrate which meets the requirements of paragraph (c) of this section and then by 

proceeding according to §40 CFR 63.626(c)(3). 

g. The permittee shall install, calibrate, maintain, and operate the following monitoring systems 

installed on the wet scrubbing emission control system: 

i. A monitoring system which continuously measures and permanently records the pressure drop 

across each scrubber in the process scrubbing system in 15-minute block averages. The 

monitoring system shall be certified by the manufacturer to have an accuracy of ±5 percent 

over its operating range. 

ii. A monitoring system which continuously measures and permanently records the flow rate of 

the scrubbing liquid to each scrubber in the process scrubbing system in 15-minute block 

averages. The monitoring system shall be certified by the manufacturer to have an accuracy of 

±5 percent over its operating range. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. 

h. The Permittee has chosen to determine the allowed ranges for the above operating parameters by 

conducting performance tests as described in 40 CFR 63.625(f)(2). The Permittee has submitted 

the results of previous tests to demonstrate allowed ranges for the parameter values listed above in 

(f). The allowed ranges are: 

i. Reactor/Granulator/Tailgas Scrubber -Pressure drop: 7.8 to 21.2 inches of water 

 Flowrate: 2327 to 2829 gpm 

ii. Cooler Scrubber - Pressure drop: 6.2 to 17.0 inches of water 

 Flowrate: 840 to 1259 gpm 

iii. Reactor/Granulator acid scrubber - Pressure drop: 7.0 to 18.4 inches of water 

 Flowrate: 660 to 989 gpm(Upon addition of high mole saturation chamber and conversion of 

this unit to Low mole scrubber this pressure drop will need TBD) 

iv. Dryer/Scrubber - Pressure drop: 10.5 to 20.0 inches of water 

 Flowrate: 516 to 744 gpm 

v. Tailgas Scrubber -Pressure drop: 8.0 to 14.5 inches of water 

 Flowrate: 1138 to 1466 gpm 

vi. High mole (saturation chamber) – flow rate (TBD)

 Should the results of any subsequent annual performance test demonstrate that the allowed range 

is incorrect, the Permittee shall submit new ranges to the Division of Air Quality for inclusion in 

this permit. If the daily averages (for any day for which there are 24 hours of normal (not 

startup, shutdown or malfunction) operation) of the pressure drop or flowrate to the scrubber 

exceeds the allowable range an exceedance will have occurred. The Permittee shall be deemed 

in noncompliance with 15A NCAC 2D .1111 for each exceedance.

Reporting [15A NCAC 2Q .0508(f)] 

i. If the following reports are not submitted the permittee shall be deemed in non-compliance with 

15A NCAC 2D .1111: 

 i. Performance test report. As required by §63.10, the owner or operator shall report the results 

of the initial and annual performance tests as part of the notification of compliance status 

required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected source 

shall submit an excess emissions report for any exceedance of an operating parameter limit. 

The report shall contain the information specified in §63.10. When no exceedances of an 

operating parameter have occurred, such information shall be included in the report. The 

report shall be submitted semiannually and shall be delivered or postmarked by the 30th day 

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following the end of the calendar half. If exceedances are reported, the owner or operator shall 

report quarterly until a request to reduce reporting frequency is approved as described in 

§63.10. 

iii. Summary report. If the total duration of control system exceedances for the reporting period 

is less than 1 percent of the total operating time for the reporting period, the owner or operator 

shall submit a summary report containing the information specified in §63.10 rather than the 

full excess emissions report, unless required by the Administrator. The summary report shall 

be submitted semiannually and shall be delivered or postmarked by the 30th day following the 

end of the calendar half. 

iv. If the total duration of control system operating parameter exceedances for the reporting 

period is 1 percent or greater of the total operating time for the reporting period, the owner or 

operator shall submit a summary report and the excess emissions report. 

Start-up, Shutdown, and Malfunction Procedures

j. PCS Phosphate must operate and maintain the emission source(s) in accordance with the 

procedures specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all 

times, including periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and 

maintain the emission source(s), including associated air pollution control equipment, in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels 

required by all relevant standards. Malfunctions shall be corrected as soon as practicable after 

their occurrence in accordance with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made 

available for inspection, upon request, by the Administrator for the life of the affected source or 

until the affected source is no longer subject to the provisions of this part. In addition, if SSM 

plan is revised, PCS Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on 

record, to be made available for inspection, upon request, by the Administrator, for a period of 5 

years after each revision to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate 

shall revise the SSM plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control equipment. (40 CFR 

63 Subpart A) 

2. 15A NCAC 2D .0507: PARTICULATES FROM CHEMICAL FERTILIZER 

MANUFACTURING PLANTS

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0507] 

 E = 9.377 x P0.3067 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.3.B.2.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0507. 

 Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. The monitoring, recordkeeping, and reporting requirements for demonstrating compliance given in 

section 2.1.3.B.1. above are deemed sufficient to demonstrate compliance with 2D .0507. 

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3. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

 a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat 

input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other 

substances shall be included when determining compliance with this standard. [15A NCAC 2D 

.0516] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.3.B.3.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0516. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The maximum sulfur content of any fuel oil received and burned in the dryer shall not exceed 2.1 

percent by weight. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 

if the sulfur content of the fuel oil exceeds this limit. 

d. To assure compliance, the Permittee shall monitor the sulfur content of the fuel oil by using fuel 

oil supplier certification. The results of the fuel oil supplier certifications shall be recorded in a 

logbook (written or electronic format) on a quarterly basis and include the following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; and 

iv. a certified statement signed by the responsible official that the records of fuel oil supplier 

certification submitted represent all of the fuel oil fired during the period. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content 

of the oil is not monitored and recorded.

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on 

or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January 

and June. All instances of deviations from the requirements of this permit must be clearly 

identified. 

4. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

Emission Standard

a. Visible emissions from the emission point shall not be more than 20 percent opacity when 

averaged over a six-minute period. However, six-minute averaging periods may exceed 40 

percent not more than once in any hour and not more than four times in any 24-hour period. In no 

event shall the six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)] 

 Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(8) and General Condition JJ. If the results of this test are above the limit given in Section 

2.1.3.B.4.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

 Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The Permittee shall establish “normal” for the source in 

the first 30 days following the effective date of the permit. If visible emissions from this source 

are observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

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Section 2.1.3.B.4.a. above. If the demonstration in (b) above cannot be made during the month, 

the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521. 

5. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

a. Operation of the dryer shall be limited as follows, the dryer (ID No. 504-016) shall be limited to 

240 pounds per day (midnight to midnight) of sulfur dioxide emissions [15A NCAC 2D .0501(e)]. 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1 A. 1. a., the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. The permittee shall ensure compliance with the emission limit stated above by monitoring the fuel 

use in the dryer on a daily basis. The permittee shall also monitor the sulfur content of the fuel oil 

as described in 3.e above. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

daily sulfur dioxide emission limit above (1.a.iii) by testing the dryer for either DAP 1 or DAP 2 

once every five years for sulfur dioxide in accordance with a testing protocol approved by the 

DAQ. Details of the emissions testing and requirements can be found in Section 3 - General 

Condition JJ. The selected dryer shall be tested at a rate demonstrable by production records to be 

equal to or greater than the normal production rate of the source. The normal production rate 

(hourly) shall be calculated by dividing the total annual production for the selected dryer by the 

number of hours that dryer was run during that year. The normal production rate for the source 

test must be approved by the Division of Air Quality in advance of the test. The facility shall 

establish the normal production rate using the production records over the last production year. A 

copy of the production records must accompany the request. If the results of this test are above the 

limit given in 5.a, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 

e. Reporting [15A NCAC 2Q .0508(f)] 

 The summary report required in 6.e below is sufficient to demonstrate compliance with 2D 

.0501(e). 

6. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

Emission standard - BACT

a. For Diammonium Phosphate Plant No. 2 the following table shall describe the emission standards 

Source Pollutant BACT Technology Emission Limit 

Diammonium Phosphate Plant No. 2 Nitrogen 

oxides 

Conventional 

combustion 

 14.7 pounds per hour 

Diammonium Phosphate Plant No. 2 VOC Good engineering 

practices 

Diammonium Phosphate Plant No. 2 Sulfur dioxide Scrubbing with 

process ammonia 

15 pounds per hour 

Diammonium Phosphate Plant No. 2 Total fluorides Venturi and packed 

bed scrubbers 

0.058 pounds per ton of 

equivalent P2O5 feed 

Diammonium Phosphate Plant No. 2 TSP/PM10 Venturi and packed 

bed scrubbers 

 64.1 pounds per hour 

b. The emission standards contained in 6.a above shall only become effective upon the completion of 

the modification as submitted in A0700071.04D. This modification will become complete upon 

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the installation of the Dual mole scrubber. Prior to the completion of the modification the 

following limits will remain in effect: 

 i. 58.15 tons of particulate matter per year 

 ii. 160.50 tons per year of sulfur dioxide and 

 iii. 6.39 tons per year of total fluorides [15A NCAC 2Q .0317(a)(1)] 

Testing [15A NCAC 2Q .0508 (f)] 

c. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limits given in Section 2.1.3.B.6.a 

and b., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

fluoride and particulate emission limits above by testing the DAP No. 2 plant annually for fluoride 

and particulate in accordance with a testing protocol approved by the DAQ. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. If the results 

of this test are above the limits given above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0530. 

e. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

nitrogen oxides and sulfur dioxide emission limits above by testing the DAP No. 2 plant once 

every five years for nitrogen oxides and sulfur dioxide in accordance with a testing protocol 

approved by the DAQ. Details of the emissions testing and requirements can be found in Section 

3 - General Condition JJ If the results of this test are above the limits given above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0530. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]

 f. The Permittee shall demonstrate compliance with the fluorides and particulates emission limits 

given above by monitoring and recording the mass flow rate of phosphorus bearing material to 

the process, the pressure drop across each wet scrubber, and flow rate of scrubbing liquid to 

each scrubber as described in Section 2.1.3.B.1.e through h. The Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0530 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508 (f)]

g. The Permittee shall submit a summary report of monitoring , testing and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified

 STATE-ONLY REQUIREMENT: 

7. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT - Pursuant to 

15A NCAC 2D .1100, in accordance with the approved application for an air toxic compliance 

demonstration and to insure that limits described in Section 2.2.A.3 are not exceeded, the 

following operational limit shall not be exceeded: 

The equivalent P2O5 feed rate to the Diammonium Phosphate Plant No. 2 (Emission Point 

ID No. 303) shall not exceed 2563 tons per calendar day when producing MAP or DAP.

 [15A NCAC 2Q .0501 (c)(4)]

 a. If emissions testing is required, the Permittee shall perform such testing in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above the limit 

given in Section 2.1.3. B.7. a., the Permittee shall be deemed in noncompliance with 15A NCAC 

2D .1100.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

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 b. The Permittee shall use the production log (written or electronic form) (as mandated in 

2.1.3.B.1.e above) to document the compliance with the above requirement. Failure to maintain 

the production log or any instances of production rates above the above limit shall be deemed 

noncompliance with 2D .1100. 

 Reporting [15A NCAC 2Q .0508(f)] 

c. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified.

2.1.3.C. Diammonium Phosphate Plant No. 3 - Emission Source IDs. 511-085, 511-086, 

511-070, 511-032, 5111-008, 511-009, 511-010, 511-011, 511-016, 511-017, 511-038, 

511-039, 511-041, 511-093, 511-094, 511-095, 511-096, 511-025, 511-107B, 511-103, 

511-104, 511-106 (Emission Point ID No. 302) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 72.0 tons per year 2Q .0317(a)(1) [PSD Net 

out Limit]

E=9.377 x P0.3067 where E = allowable emission rate in 

pounds per hour and P = production and recycle rate of 

fertilizer 

2D .0507 

sulfur dioxide 226.2 tons per year 2Q .0317(a)(1) [PSD Net 

out Limit]

2.3 pounds per million Btu 2D .0516 

 

visible 

emissions 

20 percent opacity 2D .0521 

Total 

Fluorides 

0.060 pounds per ton of equivalent P2O5 feed (during 

DAP or MAP production) 

40 CFR 63 Subpart BB 

0.150 pounds per ton of equivalent P2O5 feed (during 

GTSP production) 

40 CFR 63 Subpart BB 

0.058 pounds per ton of equivalent P2O5 feed BACT 

TAPS see 2.2 2D.1100 

PM10, sulfur 

dioxide, 

nitrogen 

dioxide 

See 2.3 2D .0543 (BART) 

2.1.3.C.1 40 CFR PART 63 SUBPART BB: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC FERTILIZER PRODUCTION 

PLANTS 15a NCAC 2D .1111: Maximum Achievable Control Technology –

 Emission Standard

a. The Permittee shall not cause to be discharged into the atmosphere from any affected source any 

gases which contain total fluorides in excess of: 

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i. 30 grams/metric ton equivalent P2O5 feed (0.060 pounds/ton) during either monoammonium 

phosphate(MAP) or diammonium phosphate (DAP) production [63.622 (a)] 

ii. 75 grams/metric ton equivalent P2O5 feed (0.150 pounds/ton) during granular triple 

superphosphate (GTSP) production [63.622 (b)] 

 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.3.C.1.a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501.

 

c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall conduct a 

performance test to demonstrate compliance with the applicable emission standard for each 

diammonium and/or monoammonium phosphate process line in accordance with 40 CFR 63.626. 

Details of the emissions testing and requirements can be found in Section 3 - General Condition 

JJ. The fertilizer plant (Emission Point ID No. 302) shall be tested annually at a rate demonstrable 

by production records to be equal to or greater than the normal production rate of the source. The 

normal production rate (hourly) shall be calculated by dividing the total annual production for the 

plant by the number of hours that plant was operated during that year. The normal production rate 

for the source test must be approved by the Division of Air Quality in advance of the test. The 

facility shall establish the normal production rate using the production records over the last 

production year. A copy of the production records must accompany the request. If the results of 

this test are above the emission standard given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1111. The results of this testing shall be saved for possible 

inclusion in future determinations of operating parameter ranges. 

d. If the Permittee produces monoammonium phosphate in this fertilizer plant (Emission Point ID 

No. 302) during the life of this permit, then the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for that monoammonium 

phosphate process line in accordance with 40 CFR 63.626 while producing monoammonium 

phosphate.. The test must be performed before the expiration date of this permit. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. If the results 

of this test are above the emission standard given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1111. The results of this testing shall be saved for possible 

inclusion in future determinations of operating parameter ranges. 

e. If the Permittee produces granular triple superphosphate in this fertilizer plant (Emission Point ID 

No. 302) during the life of this permit, then the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for that granular triple 

superphosphate process line in accordance with 40 CFR 63.626 while producing granular triple 

superphosphate. The test must be performed before the expiration date of this permit. Details of 

the emissions testing and requirements can be found in Section 3 - General Condition JJ. If the 

results of this test are above the emission standard given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1111. The results of this testing shall be saved for possible 

inclusion in future determinations of operating parameter ranges. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

f. The permittee shall install, calibrate, maintain, and operate a monitoring system which can be used 

to determine and permanently record the mass flow of phosphorus-bearing feed material to the 

process. The monitoring system shall have an accuracy of ±5 percent over its operating range. 

The results of the monitoring shall be recorded in a log (electronic or written form). The Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring system is not 

maintained, calibrated, operated, and the results recorded. 

g. The permittee shall maintain a daily record of equivalent P2O5 feed by first determining the total 

mass rate in short ton/hour of phosphorus bearing feed using a monitoring system for measuring 

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mass flowrate which meets the requirements of paragraph (c) of this section and then by 

proceeding according to §40 CFR 63.626(c)(3). 

h. The permittee shall install, calibrate, maintain, and operate the following monitoring systems 

installed on the wet scrubbing emission control system: 

i. A monitoring system which continuously measures and permanently records the pressure drop 

across each scrubber in the process scrubbing system in 15-minute block averages. The 

monitoring system shall be certified by the manufacturer to have an accuracy of ±5 percent 

over its operating range. 

ii. A monitoring system which continuously measures and permanently records the flow rate of 

the scrubbing liquid to each scrubber in the process scrubbing system in 15-minute block 

averages. The monitoring system shall be certified by the manufacturer to have an accuracy of 

±5 percent over its operating range. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. 

i. The Permittee has chosen to determine the allowed ranges for the above operating parameters by 

the method described in 40 CFR 63.625(f)(2). The Permittee has submitted the results of previous 

tests to demonstrate allowed ranges for the parameter values listed above in (f). The allowed 

ranges are: 

i. Low Mole (scrubber) -Pressure drop: 9.4 to 16.1inches of water 

 Flowrate: 867 to 1300 gpm 

ii. High Mole (saturation chamber) -Flowrate: 1000 to 1650 gpm 

iii. Dust scrubber -Pressure drop: 4.4 to 9.0 inches of water 

 Flowrate: 300 to 600 gpm 

iv. Cooler scrubber -Pressure drop: 4.3 to 11.3 inches of water 

 Flowrate: 400 to 650 gpm 

v. Dryer No. 1 scrubber -Pressure drop: 6.8 to 10.2 inches of water 

 Flowrate: 600 to 900 gpm 

vi. Dryer No. 2 scrubber -Pressure drop: 2.8 to 6.1inches of water 

 Flowrate: 357 to 536 gpm 

vii. Tailgas scrubber -Pressure drop: 3.4 to 5.1inches of water 

 Flowrate: 1066 to 1600 gpm 

 Should the results of any subsequent annual performance test demonstrate that allowed range is 

incorrect, the Permittee shall submit those new ranges to the Division of Air Quality for inclusion 

in this permit. If the daily averages (for any day for which there are 24 hours of normal (not 

startup, shutdown or malfunction) operation) of the pressure drop or flowrate to the scrubber 

exceeds the allowable range an exceedance will have occurred. The Permittee shall be deemed 

in noncompliance with 15A NCAC 2D .1111 for each exceedance.

Reporting [15A NCAC 2Q .0508(f)] 

j. If the following reports are not submitted the permittee shall be deemed in non-compliance with 

15A NCAC 2D .1111: 

i. Performance test report. As required by §63.10, the owner or operator shall report the 

results of the initial and annual performance tests as part of the notification of compliance 

status required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected source 

shall submit an excess emissions report for any exceedance of an operating parameter limit. 

The report shall contain the information specified in §63.10. When no exceedances of an 

operating parameter have occurred, such information shall be included in the report. The 

report shall be submitted semiannually and shall be delivered or postmarked by the 30th 

day following the end of the calendar half. If exceedances are reported, the owner or 

operator shall report quarterly until a request to reduce reporting frequency is approved as 

described in §63.10. 

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iii. Summary report. If the total duration of control system exceedances for the reporting 

period is less than 1 percent of the total operating time for the reporting period, the owner 

or operator shall submit a summary report containing the information specified in §63.10 

rather than the full excess emissions report, unless required by the Administrator. The 

summary report shall be submitted semiannually and shall be delivered or postmarked by 

the 30th day following the end of the calendar half. 

iv. If the total duration of control system operating parameter exceedances for the reporting 

period is 1 percent or greater of the total operating time for the reporting period, the owner 

or operator shall submit a summary report and the excess emissions report. 

Start-up, Shutdown, and Malfunction Procedures

k. PCS Phosphate must operate and maintain the emission source(s) in accordance with the 

procedures specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all 

times, including periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and 

maintain the emission source(s), including associated air pollution control equipment, in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels 

required by all relevant standards. Malfunctions shall be corrected as soon as practicable after 

their occurrence in accordance with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made 

available for inspection, upon request, by the Administrator for the life of the affected source or 

until the affected source is no longer subject to the provisions of this part. In addition, if SSM 

plan is revised, PCS Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on 

record, to be made available for inspection, upon request, by the Administrator, for a period of 5 

years after each revision to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate 

shall revise the SSM plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control equipment. (40 CFR 

63 Subpart A) 

2. 15A NCAC 2D .0507: PARTICULATES FROM CHEMICAL FERTILIZER 

MANUFACTURING PLANTS

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0507] 

 E = 9.377 x P0.3067 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.3.C.2.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0507. 

 Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. The monitoring, recordkeeping, and reporting requirements for demonstrating compliance given in 

section 2.1.3.C.1. above are deemed sufficient to demonstrate compliance with 2D .0507. 

3. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

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 a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat 

input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other 

substances shall be included when determining compliance with this standard. [15A NCAC 2D 

.0516] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.3.C.3.a.. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0516. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The maximum sulfur content of any fuel oil received and burned in the dryer shall not exceed 2.1 

percent by weight. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 

if the sulfur content of the fuel oil exceeds this limit. 

d. To assure compliance, the Permittee shall monitor the sulfur content of the fuel oil by using fuel 

oil supplier certification per shipment received. The results of the fuel oil supplier certifications 

shall be recorded in a logbook (written or electronic format) on a quarterly basis and include the 

following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; and 

iv. a certified statement signed by the responsible official that the records of fuel oil supplier 

certification submitted represent all of the fuel oil fired during the period. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content 

of the oil is not monitored and recorded.

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on 

or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January 

and June. All instances of deviations from the requirements of this permit must be clearly 

identified. 

4. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

Emission Standard

a. Visible emissions from the any emission point shall not be more than 20 percent opacity when 

averaged over a six-minute period. However, six-minute averaging periods may exceed 40 

percent not more than once in any hour and not more than four times in any 24-hour period. In no 

event shall the six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)] 

 Testing [15A NCAC 2D .0501(c)(8)] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(8) and General Condition JJ. If the results of this test are above the limit given in Section 

2.1 A. 4.a. or b above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.0521. 

 Monitoring [15A NCAC 2Q .0508(f)] 

 c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The Permittee shall establish “normal” for the source in 

the first 30 days following the effective date of the permit. If visible emissions from this source 

are observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.3.C.4.a.. above. If the demonstration in (b) above cannot be made during the 

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monitoring period, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D 

.0521. 

5. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

a. Operation of the dryer shall be limited as follows, the dryer (ID No. 504-016) shall be limited to 

2087 pounds per day (midnight to midnight) of sulfur dioxide emissions [15A NCAC 2D 

.0501(e)]. 

Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1 A. 1. a., the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. The permittee shall ensure compliance with the emission limit stated above by monitoring the fuel 

use in the dryer on a daily basis. The permittee shall also monitor the sulfur content of the fuel oil 

as described in 3.e above. 

d. The Permittee shall demonstrate compliance with the emission limit above as follows: 

The use of fuel oil in the dryer shall be limited such that sulfur dioxide emissions shall not 

exceed 2087 pounds per day (midnight to midnight). Calculations shall be made daily and 

recorded in a logbook (written or in electronic format), according to the following formula: 

 X = Z x 157 lbs sulfur dioxide x S 

 1000 gallon fuel oil 

 Where: X is the total actual emissions of sulfur dioxide in pounds 

 Z is the amount of fuel oil used in the boilers in gallons 

 S is the percent sulfur in the fuel oil 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if the sulfur 

dioxide emissions exceed the above limit. 

 

e. The Permittee shall record in a logbook (written or electronic format) the following: 

i. the fuel oil used per day (midnight to midnight) 

ii. the sulfur content of the fuel oil used. 

iii. a daily record of the calculated sulfur dioxide emissions for that day (midnight to 

midnight). 

 The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e) if these records 

are not kept . 

 Reporting [15A NCAC 2Q .0508(f)] 

 f. The summary report required in 6.e below is sufficient to demonstrate compliance with 2D 

.0501(e). 

6. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

Emission standard - BACT

a. For Diammonium Phosphate Plant No. 3 the following table shall describe the emission standards 

Source Pollutant BACT Technology Emission Limit 

Diammonium Phosphate Plant No. 3 F Dual mole 

scrubbing 

 14.7 pounds per hour 

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c. The emission standards contained in 6.a above shall only become effective upon the completion of 

the modification as submitted in A0700071.04D. This modification will become complete upon 

the installation of the dual mole scrubber on DAP No. 2. Prior to the completion of the 

modification the following limits will remain in effect: 

 

 i. 4.34 tons per year of total fluorides [15A NCAC 2Q .0317(a)(1)] 

Testing [15A NCAC 2Q .0508 (f)] 

 e. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limits given in Section 2.1.1.A.4.a 

and b., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.

f. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

fluoride and particulate emission limits above by testing the DAP No. 3 plant annually for fluoride 

and particulate in accordance with a testing protocol approved by the DAQ. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. If the results 

of this test are above the limits given above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0530. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]

 g. The Permittee shall maintain in a logbook (written or electronic format) production data 

sufficient to document the calculation of the normal production rate for determining the 

appropriate production rates at which to conduct the testing described above. The Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not maintained. 

h. The Permittee shall demonstrate compliance with the fluorides emission limits given above by 

monitoring and recording the mass flow rate of phosphorus bearing material to the process, the 

pressure drop across each wet scrubber, and flow rate of scrubbing liquid to each scrubber as 

described in Section 2.1.3.C.1.f through i. The Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0530 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508 (f)] 

i. The Permittee shall submit a summary report of monitoring, testing and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified 

 STATE-ONLY REQUIREMENT: 

7. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT

a. Pursuant to a. 15A NCAC 2D .1100, in accordance with the approved application for an air toxic 

compliance demonstration and to insure that limits described in Section 2.2.A.3 are not exceeded, 

the following operational limits shall not be exceeded: 

 The equivalent P2O5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point 

ID No. 302) shall not exceed 714 tons per calendar day when producing GTSP.

The equivalent P2O5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point 

ID No. 302) shall not exceed 1188 tons per calendar day when producing MAP.

The equivalent P2O5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point 

ID No. 302) shall not exceed 1188 tons per calendar day when producing DAP.

The equivalent P2O5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point 

ID No. 302) shall not exceed 840 tons per calendar day when producing PAPR.

 Testing [15A NCAC 2Q .0501 (c)(4)] 

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 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above the limit 

given in Section 2.1.3. C. 7. a., the Permittee shall be deemed in noncompliance with 15A NCAC 

2D .1100.

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. The Permittee shall use the production log (written or electronic form) (as mandated in 2.1.3.C.1.f 

above) to document the compliance with the above requirement. Failure to maintain the 

production log or any instances of production rates above the above limit shall be deemed 

noncompliance with 2D .1100. 

 Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.3.D. Ammonium Polyphosphate Plant - Emission Source ID APP-1 (Emission Point ID No. 

304), Filter Press Number 3- Emission Source ID AFP-1 (Emission Point ID No. 305) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

visible 

emissions 

40 percent opacity 15A NCAC 2D .0521 

Total 

Fluorides 

No control* 15A NCAC 2D .0530 

BACT 

Particulate 

matter 

E = 55 x P 0.11 -40 Where 

E = allowable emission rate in pounds per hour and P = 

process weight in tons per hour 

15A NCAC 2D .0515 

TAPS See Section 2.2.A.3 

The equivalent P2O5 feed rate to the Ammonium 

Polyphosphate Plant (Emission Point ID No. 304) shall 

not exceed 475 tons per calendar day. 

15A NCAC 2D .1100 

*Filter Press Number 3 only 

2.1.3.D.1. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

Emission Standard

a. Visible emissions from any emission point shall not be more than 40 percent opacity when 

averaged over a six-minute period. However, six-minute averaging periods may exceed 40 

percent not more than once in any hour and not more than four times in any 24-hour period. 

In no event shall the six-minute average exceed 90 percent opacity. [15A NCAC 2D 

.0521(c)] 

 Testing [15A NCAC 2D .0501(c)(8)] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A 

NCAC 2D .0501(c)(8) and General Condition JJ. If the results of this test are above the 

limit given in Section 2.1.3.D.1.a above, the Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0521. 

 Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this 

source for any visible emissions above normal. If visible emissions from this source are 

observed to be above normal, the Permittee shall either: 

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i. take appropriate action to correct the above-normal emissions within the 

monitoring period and record the action taken as provided in the recordkeeping 

requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission 

source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.3.D.1. a. above. 

If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) 

above cannot be made, the Permittee shall be deemed to be in noncompliance with 15A 

NCAC 2D .0521. 

d. To assure compliance, the Permittee shall perform inspections and maintenance as 

recommended by the manufacturer. In addition to the manufacturer’s inspection and 

maintenance recommendations, or if there is no manufacturer’s inspection and maintenance 

recommendations, as a minimum, the inspection and maintenance requirement shall include 

an annual visual external inspection of the mist eliminator (ID No. 451-1) for leaks. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if the system 

is not inspected and maintained.

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

Emission standard - BACT

a. For the Filter Press No. 3- Emission Source ID AFP-1 (Emission Point ID No. 305) the 

following table shall describe the emission standards 

Source Pollutant BACT Technology Emission Limit 

Filter Press No. 3 (ID No. 305) Total Fluorides Uncontrolled N/A 

3. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate 

as calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E = 55 x P 0.11 -40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ found in Section 3. If the results of this 

test are above the limit given in Section 2.1.3.D.3.a above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0515. 

 

 Monitoring/Recordkeeping/ Reporting [15A NCAC 2Q .0508(f)] 

c. Due to the inherent high moisture content of the filter cake, essentially no particulate 

emissions occur from this process. Therefore no monitoring, recordkeeping or reporting 

requirements are necessary to verify compliance with 2D .0515. 

 STATE-ONLY REQUIREMENT: 

4. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT 

a. Pursuant to a. 15A NCAC 2D .1100, in accordance with the approved application for an air 

toxic compliance demonstration and to insure that limits described in Section 2.2.A.3 are 

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not exceeded, the equivalent P2O5 feed rate to the Ammonium Polyphosphate Plant 

(Emission Point ID No. 304) shall not exceed 475 tons per calendar day.

 Testing [15A NCAC 2Q .0501 (c)(4)] 

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

15A NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above 

the limit given in Section 2.1.3. D. 4. a., the Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .1100.

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. The Permittee shall use the production log (written or electronic form) (as mandated in 

2.1.3.C.1.f above) to document the compliance with the above requirement. Failure to 

maintain the production log or any instances of production rates above the above limit shall 

be deemed noncompliance with 2D .1100. 

 Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding sixmonth period between January and June. All instances of deviations from the requirements 

of this permit must be clearly identified. 

2.1.3.E. GTSP Rock Storage Silo - controlled by fabric filter Emission Source ID 511-045 

(Emission Point ID No. 310) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Particulate 

matter 

E = 55 x P 0.11 -40 Where 

E = allowable emission rate in pounds per hour and P = 

process weight in tons per hour 

2D .0515 

visible 

emissions 

20 percent opacity 2D .0521 

TAPS see 2.2 2D.1100 

2.1.3.E.1 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate 

as calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E = 55 x P 0.11 -40 Where E = allowable emission rate in pounds per 

hour 

 P = process weight in tons per hour

 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 

2D .0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are 

above the limit given in Section 2.1.3.E.1.a. above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0515. 

 

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Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 The requirements in c, d, e, and f are only applicable when the GTSP process is operating. 

 c. Particulate matter emissions from the silo shall be controlled by the bagfilter. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

manufacturer. In addition to the manufacturer’s inspection and maintenance 

recommendations, or if there is no manufacturer’s inspection and maintenance 

recommendations, as a minimum, the inspection and maintenance requirement shall include 

the following: 

i. a monthly visual inspection of the system ductwork and material collection unit for leaks; 

and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection 

of the bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the 

ductwork and bagfilters are not inspected and maintained.

 d. The results of inspection and maintenance shall be maintained in a logbook (written or 

electronic format) on-site and made available to an authorized representative upon request. 

The logbook shall record the following: 

 i. the date and time of each recorded action; 

ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

 iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the bagfilters within 

30 days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month 

period between January and June. All instances of deviations from the requirements of this 

permit must be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

Emission Standard

a. Visible emissions from the silos shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event 

shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 

2D .0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are 

above the limit given in Section 2.1.3.E.2.a. above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0521. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. The requirements for 2D .0515 shall be sufficient to meet the requirements of 2D .0521. 

2.1.4 SUPERPHOSPHORIC ACID PLANT AREA 

2.1.4.A Superphosphoric Acid Plant Nos. 1 and 2 Emission Source ID 451-418 and 451-409; 451-701 

and 451-809; and 451-316 and 451-308 (Emission Point ID No. 330, and 331) 

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The following table provides a summary of limits and standards for the emission source(s) described 

above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur dioxide 30 pounds per day (Plant No. 1) 2D .0501(e) 

50 pounds per day (Plant No. 2 2D .0501(e) 

Total 

Fluorides 

0.010 pounds per ton of equivalent P2O5 feed 2D .1111 

[MACT Subpart AA]

TAPS See 2.2 2D .1100 

sulfur dioxide See 2.3 2D .0543 (BART) 

2. 1.4.A.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS 

AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING PLANTS

 15A NCAC 2D .1111: Maximum Achievable Control Technology 

 Emission Standard

 a. Operation of the superphosphoric acid plants shall be limited as follows: [63.602 (b)(1)] 

 i. No superphosphoric acid plant (Emission Point ID No. 330, and 331) shall discharge into the 

atmosphere gases which contain total fluorides in excess of 5.0 grams per metric ton of 

equivalent P2O5 feed (0.010 pound/ton). 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2. 1.4.A.1. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111. 

 c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall conduct a 

performance test to demonstrate compliance with the applicable emission standard for the 

superphosphoric acid plant process line in accordance with 40 CFR 63.626. Details of the emissions 

testing and requirements can be found in Section 3 - General Condition JJ. Each superphosphoric acid 

plant (Emission Point ID No. 330, or 331) shall be tested annually at a rate demonstrable by production 

records to be equal to or greater than the normal production rate of the source. The normal production 

rate (hourly) shall be calculated by dividing the total annual production for the plant by the number of 

hours that plant was operated during that year. The normal production rate for the source test must be 

approved by the Division of Air Quality in advance of the test. The facility shall establish the normal 

production rate using the production records over the last production year. A copy of the production 

records must accompany the request. If the results of this test are above the emission standard given 

above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. The results of this 

testing shall be saved for possible inclusion in future determinations of operating parameter ranges. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

d. The permittee shall install, calibrate, maintain, and operate a monitoring system which can be used to 

determine and permanently record the mass flow of phosphorus-bearing feed material to the process. 

The monitoring system shall have an accuracy of ±5 percent over its operating range. The results of 

the monitoring shall be recorded in a log (electronic or written form). The Permittee shall be deemed 

in noncompliance with 15A NCAC 2D .1111 if this monitoring system is not maintained, calibrated, 

operated, and the results recorded. 

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e. The permittee shall maintain a daily record of equivalent P2O5 feed by first determining the total mass 

rate in ton/hour of phosphorus bearing feed using a monitoring system for measuring mass flowrate 

which meets the requirements of paragraph (c) of this section and then by proceeding according to §40 

CFR 63.626(c)(3). 

f. The permittee shall install, calibrate, maintain, and operate the following monitoring systems installed 

on the wet scrubbing emission control system: 

i. A monitoring system which continuously measures and permanently records the pressure drop 

across each scrubber in the process scrubbing system in 15-minute block averages. The 

monitoring system shall be certified by the manufacturer to have an accuracy of ±5 percent over 

its operating range. 

ii. A monitoring system which continuously measures and permanently records the flow rate of the 

scrubbing liquid to each scrubber in the process scrubbing system in 15-minute block averages. 

The monitoring system shall be certified by the manufacturer to have an accuracy of ±5 percent 

over its operating range. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. 

g. The Permittee has chosen to determine the allowed ranges for the above operating parameters by the 

method described in 40 CFR 63.605(d)(2). The Permittee has submitted the results of previous tests to 

demonstrate allowed ranges for the parameter values listed above in (f). The allowed ranges are: 

i. SPA No. 1 - pressure drop: 1.1 to 2.8 inches of water 

 flow rate: 81 to 163 gpm 

ii. SPA No. 2 - pressure drop: 1.1 to 2.8 inches of water 

 flow rate: 112 to 163 gpm 

 Should the results of any subsequent annual performance test demonstrate that the allowed range is 

incorrect, the Permittee shall submit those new ranges to the Division of Air Quality for inclusion in 

this permit. If the daily averages (for any day for which there are 24 hours of normal (not startup, 

shutdown or malfunction) operation) of the pressure drop or flowrate to the scrubber exceeds the 

allowable range an exceedance will have occurred. The Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .1111 for each exceedance.

Reporting [15A NCAC 2Q .0508(f)] 

h. If the following reports are not submitted the permittee shall be deemed in non-compliance with 

15A NCAC 2D .1111: 

i. Performance test report. As required by §63.10, the owner or operator shall report the results 

of the initial and annual performance tests as part of the notification of compliance status 

required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected source 

shall submit an excess emissions report for any exceedance of an operating parameter limit. 

The report shall contain the information specified in §63.10. When no exceedances of an 

operating parameter have occurred, such information shall be included in the report. The 

report shall be submitted semiannually and shall be delivered or postmarked by the 30th day 

following the end of the calendar half. If exceedances are reported, the owner or operator shall 

report quarterly until a request to reduce reporting frequency is approved as described in 

§63.10. 

iii. Summary report. If the total duration of control system exceedances for the reporting period 

is less than 1 percent of the total operating time for the reporting period, the owner or operator 

shall submit a summary report containing the information specified in §63.10 rather than the 

full excess emissions report, unless required by the Administrator. The summary report shall 

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be submitted semiannually and shall be delivered or postmarked by the 30th day following the 

end of the calendar half. 

iv. If the total duration of control system operating parameter exceedances for the reporting 

period is 1 percent or greater of the total operating time for the reporting period, the owner or 

operator shall submit a summary report and the excess emissions report. 

Start-up, Shutdown, and Malfunction Procedures

i. PCS Phosphate must operate and maintain the emission source(s) in accordance with the 

procedures specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all 

times, including periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and 

maintain the emission source(s), including associated air pollution control equipment, in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels 

required by all relevant standards. Malfunctions shall be corrected as soon as practicable after 

their occurrence in accordance with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made 

available for inspection, upon request, by the Administrator for the life of the affected source or 

until the affected source is no longer subject to the provisions of this part. In addition, if SSM 

plan is revised, PCS Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on 

record, to be made available for inspection, upon request, by the Administrator, for a period of 5 

years after each revision to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate 

shall revise the SSM plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control equipment. (40 CFR 

63 Subpart A) 

2. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

a. Operation of the superphosphoric acid plants (Emission Point ID No. 330, or 331) shall be limited 

as follows: 

i. superphosphoric acid plant No. 1 (Emission Point ID No. 330) shall be limited to 30 

pounds per calendar day of sulfur dioxide emissions 

ii. superphosphoric acid plant No. 2 (Emission Point ID No. 331) shall be limited to 50 

pounds per calendar day of sulfur dioxide emissions [15A NCAC 2D .0501(e)]. 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.4. A.1. 2. 

a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

emission limits above by testing each superphosphoric acid plant (Emission Point ID No. 330, 

331, or 332) annually for sulfur dioxide in accordance with a testing protocol approved by the 

DAQ. Details of the emissions testing and requirements can be found in Section 3 - General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0501(e).

 

 Monitoring/Recordkeeping /Reporting [15A NCAC 2Q .0508(f)] 

d. The reporting requirements of 2.1.4.A.1.h shall be sufficient to demonstrate compliance with 2.a 

above 

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2.1.4.B Superphosphoric Acid Plant No. 3 and No. 4 - Emission Source ID 451-316 and 

451-308; and 451-916 and 451-940 (Emission Point ID No. 332) 

The following table provides a summary of limits and standards for the emission source(s) described above 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur dioxide 400 pounds per day (combined Plant Nos. 3 and 4) 2D .0530 BACT

Total 

Fluorides 

0.010 pounds per ton of equivalent P2O5 feed 2D .1111 

MACT Subpart AA] 

2D .0524 (Plant No. 4 only) 

[NSPS Subpart U]

TAPS see 2.2 2D.1100 

sulfur dioxide See 2.3 2D .0543 (BART) 

2. 1.4.B.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 

 A NCAC 2D .1111: Maximum Achievable Control Technology 

 Emission Standard

a. Operation of the superphosphoric acid plants shall be limited as follows: [63.602 (b)(1)] 

i. No superphosphoric acid plant (Emission Point ID No. 332) shall discharge into the 

atmosphere gases which contain total fluorides in excess of 5.0 grams per metric ton of 

equivalent P2O5 feed (0.010 pound/ton). 

 Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.4. B.1. 

a.i., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall conduct a 

performance test to demonstrate compliance with the applicable emission standard for the 

superphosphoric acid plant process line in accordance with 40 CFR 63.626. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. 

The combined superphosphoric acid plant exhausts (Nos. 3 or 4 Emission Point ID No. 332) shall 

be tested annually at a rate demonstrable by production records to be equal to or greater than the 

normal production rate of the source. The normal production rate (hourly) shall be calculated by 

dividing the total annual production for the plant by the number of hours that plant was operated 

during that year. The normal production rate for the source test must be approved by the Division 

of Air Quality in advance of the test. The facility shall establish the normal production rate using 

the production records over the last production year. A copy of the production records must 

accompany the request. If the results of this test are above the emission standard given above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. The results of this 

testing shall be saved for possible inclusion in future determinations of operating parameter 

ranges. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

d. The permittee shall install, calibrate, maintain, and operate a monitoring system which can be used 

to determine and permanently record the mass flow of phosphorus-bearing feed material to the 

process. The monitoring system shall have an accuracy of ±5 percent over its operating range. 

The results of the monitoring shall be recorded in a log (electronic or written form). The Permittee 

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Permit 04176T3? DRAFT 

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shall be deemed in noncompliance with 15A NCAC 2D .1111 if this monitoring system is not 

maintained, calibrated, operated, and the results recorded. 

e. The permittee shall maintain a daily record of equivalent P2O5 feed by first determining the total 

mass rate in ton/hour of phosphorus bearing feed using a monitoring system for measuring mass 

flowrate which meets the requirements of paragraph (c) of this section and then by proceeding 

according to §40 CFR 63.626(c)(3). 

f. The permittee shall install, calibrate, maintain, and operate the following monitoring systems 

installed on the wet scrubbing emission control system: 

i. A monitoring system which continuously measures and permanently records the pressure 

drop across each scrubber in the process scrubbing system in 15-minute block averages. 

The monitoring system shall be certified by the manufacturer to have an accuracy of ±5 

percent over its operating range. 

ii. A monitoring system which continuously measures and permanently records the flow rate 

of the scrubbing liquid to each scrubber in the process scrubbing system in 15-minute block 

averages. The monitoring system shall be certified by the manufacturer to have an accuracy 

of ±5 percent over its operating range. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. 

g. The Permittee has chosen to determine the allowed ranges for the above operating parameters by 

the method described in 40 CFR 63.605(d)(2). The Permittee has submitted the results of previous 

tests to demonstrate allowed ranges for the parameter values listed above in (f). The allowed 

ranges are: 

i. SPA No. 3/4 - pressure drop: 0.7 to 1.8 inches of water 

 flow rate: 115 to 147 gpm 

 Should the results of any subsequent annual performance test demonstrate that the allowed range 

is incorrect, the Permittee shall submit those new ranges to the Division of Air Quality for 

inclusion in this permit. If the daily averages (for any day for which there are 24 hours of normal 

(not startup, shutdown or malfunction) operation) of the pressure drop or flowrate to the 

scrubber exceeds the allowable range an exceedance will have occurred. The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .1111 for each exceedance.

Reporting [15A NCAC 2Q .0508(f)] 

h. If the following reports are not submitted the permittee shall be deemed in non-compliance with 

15A NCAC 2D .1111: 

i. Performance test report. As required by §63.10, the owner or operator shall report the 

results of the initial and annual performance tests as part of the notification of compliance 

status required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected 

source shall submit an excess emissions report for any exceedance of an operating 

parameter limit. The report shall contain the information specified in §63.10. When no 

exceedances of an operating parameter have occurred, such information shall be included in 

the report. The report shall be submitted semiannually and shall be delivered or postmarked 

by the 30th day following the end of the calendar half. If exceedances are reported, the 

owner or operator shall report quarterly until a request to reduce reporting frequency is 

approved as described in §63.10. 

iii. Summary report. If the total duration of control system exceedances for the reporting 

period is less than 1 percent of the total operating time for the reporting period, the owner 

or operator shall submit a summary report containing the information specified in §63.10 

rather than the full excess emissions report, unless required by the Administrator. The 

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summary report shall be submitted semiannually and shall be delivered or postmarked by 

the 30th day following the end of the calendar half. 

iv. If the total duration of control system operating parameter exceedances for the reporting 

period is 1 percent or greater of the total operating time for the reporting period, the owner 

or operator shall submit a summary report and the excess emissions report. 

Start-up, Shutdown, and Malfunction Procedures

i. PCS Phosphate must operate and maintain the emission source(s) in accordance with the 

procedures specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all 

times, including periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and 

maintain the emission source(s), including associated air pollution control equipment, in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels 

required by all relevant standards. Malfunctions shall be corrected as soon as practicable after 

their occurrence in accordance with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made 

available for inspection, upon request, by the Administrator for the life of the affected source or 

until the affected source is no longer subject to the provisions of this part. In addition, if SSM 

plan is revised, PCS Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on 

record, to be made available for inspection, upon request, by the Administrator, for a period of 5 

years after each revision to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate 

shall revise the SSM plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control equipment. (40 CFR 

63 Subpart A) 

2. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART U 

 Emission Standard

a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management 

Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as 

promulgated in 40 CFR Part 60 Subpart U, including Subpart A "General Provisions."[15A NCAC 

2D .0524]for Plant No. 4. 

Emission Limitations [15A NCAC 2D .0524] 

b. Operation of the superphosphoric acid plant No. 4 shall be limited as follows: [60.212] 

i. No superphosphoric acid plant (Emission Point ID No. 332) shall discharge into the atmosphere 

gases which contain fluorides in excess of 5.0 grams per metric ton of equivalent P2O5 feed 

(0.010 pound/ton). 

Monitoring/Recordkeeping/Reporting

c. Satisfying the requirements of 2. 1.4.B.1 above will be considered sufficient to demonstrate 

compliance with 2D .0524. 

3. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

Emission standard - BACT

a. For SPA Plants Nos. 3 and 4 the following table shall describe the emission standards 

Source Pollutant BACT Technology Emission Limit 

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Superphosphoric Acid plants 3 and 4 

(combined) 

Sulfur dioxide Wet scrubbing 400 pounds per day 

Testing [15A NCAC 2Q .0508 (f)] 

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limits given in Section 2.1.1.A.4.a 

and b., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

sulfur dioxide emission limits above by testing the SPA Nos. 3 and 4 plants annually for sulfur 

dioxide in accordance with a testing protocol approved by the DAQ. Details of the emissions 

testing and requirements can be found in Section 3 - General Condition JJ. If the results of this 

test are above the limits given above, the Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .0530. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]

h. The Permittee shall demonstrate compliance with the sulfur dioxide emission limits given above 

by monitoring and recording the mass flow rate of phosphorus bearing material to the process, 

the pressure drop across each wet scrubber, and flow rate of scrubbing liquid to each scrubber 

as described in Section 2.1.4.B.1.d through g. The Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0530 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508 (f)] 

i. The Permittee shall submit a summary report of monitoring, testing and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified 

2.1.4.C SPA Filter Press No. 1 and No. 2 - Emission Source ID FPR-1 and FPR-2 Emission 

Point ID Nos. 335 and 336 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

TAPS see 2.2 2D.1100 

2.1.4.D Potassium Permanganate Storage Silo - Emission Source ID 453-485 (Emission 

Point ID No. 340) 

Clay or Limestone Additive Storage Silo - Emission Source ID 453-470 

(Emission Point ID No. 341) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

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Particulate 

matter 

E = 4.10 x P 0.67 Where 

E = allowable emission rate in pounds per hour and P = 

process weight in tons per hour 

2D .0515 

20 percent opacity 2D .0521 

TAPS see 2.2 2D.1100 

2.1.4.D.1 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

Emission Standard

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E =4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.4.D.1.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0515. 

 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from the silo shall be controlled by the bagfilter. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or 

if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 d. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 

days of a written request by the DAQ. 

e. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

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Appendix L.10 - 628 

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 Emission Standard

a. Visible emissions from the silos shall not be more than 20 percent opacity when averaged over a 

six-minute period. However, six-minute averaging periods may exceed 20 percent not more than 

once in any hour and not more than four times in any 24-hour period. In no event shall the sixminute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.C.2.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0521. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. Satisfying the requirements for 2D .0515 shall be sufficient to meet the requirements of 2D .0521. 

2.1.4.E Fertilizer Warehouse Fugitives: Warehouse No. 1 and No. 2 - Emission 

Source ID DAP1WH1 and DAP2WH2 (Emission Point ID No. 390) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

TAPS see 2.2 2D.1100 

2.1.4.F Fertilizer Warehouse Fugitives: Warehouse No. 3 - Emission Source ID 

DAP3WH3 (Emission Point ID No. 390) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

total Fluorides 

0.0005 lb/hr/ton P2O5 cured or stored for GTSP 

production 

40 CFR 63 Subpart BB 

(MACT)

TAPS see 2.2 2D.1100 

2.1.4.F.1 40 CFR PART 63 SUBPART BB: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC FERTILIZER 

PRODUCTION PLANTS 15a NCAC 2D .1111: Maximum Achievable Control 

Technology -

 Emission Standard

a. The Permittee shall not cause to be discharged into the atmosphere from any affected source any 

gases which contain total fluorides in excess of .0.250 grams/hr/metric ton equivalent P2O5 stored 

(0.0005 pounds/hr/ton stored) [63.622 (c)(1)] 

Operating Standard

b. The Permittee shall not ship granular triple superphosphate (GTSP) produced within the previous 

72 hours from any warehouse[63.622 (c)(2)]. 

 

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 Testing [15A NCAC 2Q .0501 (c)(4)]

 c. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.4.F. 1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501. 

 

d. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall conduct a 

performance test to demonstrate compliance with the applicable emission standard for the 

warehouse in accordance with 40 CFR 63.626. Details of the emissions testing and requirements 

can be found in Section 3 - General Condition JJ. The warehouse (Emission Point ID No. 390) 

shall be tested annually. If no GTSP production has occurred during the year, then the only 

requirement is to state that no production has occurred on any report. Upon resumption of GTSP 

production, the Permittee shall conduct the performance tests only when the total GTSP is at least 

10 percent of the building capacity, fresh GTSP is at least 6 percent of the total amount of GTSP, 

or if the previous parameters exceed production capabilities of fresh GTSP, then fresh GTSP is 

equal to at least 5 days maximum production. If the results of this test are above the emission 

standard given above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.1111. The results of this testing shall be saved for possible inclusion in future determinations of 

operating parameter ranges. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

The requirements in f and g below only apply when GTSP is being produced. 

e. The Permittee shall maintain an accurate account of granular triple superphosphate in storage to 

permit the determination of the amount of equivalent P2O5 stored. The Permittee shall maintain a 

daily record of total equivalent P2O5 stored by multiplying the percentage P2O5 content, as 

determined by § 63.626(d)(3), times the total mass of granular triple superphosphate stored. The 

Permittee shall develop for approval by the Administrator a site-specific methodology including 

sufficient recordkeeping for the purposes of demonstrating compliance with § 63.622(c)(2) or § 

63.623(c)(2), as applicable. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if the records are not 

maintained, or if the site specific methodology is not submitted. 

Reporting [15A NCAC 2Q .0508(f)] 

f. If the following reports are not submitted the permittee shall be deemed in non-compliance with 

15A NCAC 2D .1111: 

 g. Performance test report. As required by §63.10, the owner or operator shall report the results of 

the initial and annual performance tests as part of the notification of compliance status required in 

§63.9. No report is required if no production of GTSP has occurred during the year. 

2.1.4.G. Two Phosphoric Acid Pilot Plants - Emission Source ID 315 and 316 

(Emission Point ID No. 315 and 316) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

TAPS see 2.2 2D.1100 

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2.1.5 PHOSPHORIC ACID PRODUCTION AREA

2.1.5.A Phosphoric Acid Train No. 1 - Emission Source ID 421-201, 421-000, 421-325, 421-324, 

421-327, 421-326, 421-223, 421-232, 421-232, 421- 218, 421-330 - (Emission Point ID 

401) 

Emission Source ID 441-000 - (Emission Point ID 402) 

Emission Source ID 441-000, 442-000, 441-031 - (Emission Point ID 403) 

Phosphoric Acid Train No. 2 - Emission Source ID 422-201, 422-000, 422-325, 422-324, 

422-327, 422-326, 422-223, 422-232, 422-232, 422- 218, 422-330 - (Emission Point ID 

404) 

Emission Source ID 442-000 - (Emission Point ID 405) 

Phosphoric Acid Train No. 3 - Emission Source ID 423-201, 423-000, 423-325, 423-324, 

423-327, 423-326, 423-223, 423-232, 423-232, 423- 218, 423-330 - (Emission Point ID 

406) 

Emission Source ID 443-000 - (Emission Point ID 407) 

Emission Source ID 443-000, 444-000, 444-031 - (Emission Point ID 408) 

Phosphoric Acid Train No. 4 - Emission Source ID 424-201, 428-753, 424-000, 424-325, 

424-324, 424-327, 424-326, 424-223, 424-232, 424-232, 424- 218, 424-330 - (Emission 

Point ID 409) 

Emission Source ID 444-000 - (Emission Point ID 410) 

 Phosphoric Acid Plant Fugitives - Emission Point ID No. 491 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur dioxide 486 pounds per day (Train No. 1 - measured at crossflow 

scrubber stacks) 

2D .0501(e) (BACT) 

486 pounds per day (Train No. 2 - measured at crossflow 

scrubber stacks) 

2D .0501(e) (BACT) 

960 pounds per day (Train No. 3 - measured at 

crossflow scrubber stacks) 

2D .0501(e) (BACT) 

960 pounds per day (Train No. 4 - measured at 

crossflow scrubber stacks) 

2D .0501(e) 

Total Reduced 

Sulfur 

2207.61 tons per year (Trains 1, 2, 3 and 4) 2Q .0317(a)(1) PSD 

Avoidance limit

1728.3 tons per year (Trains 1 and 2)(also Train 4 when 

using calcined rock) 

2Q .0317(a)(1) PSD 

Avoidance limit

Hydrogen 

sulfide 

4.24 pounds per ton P2O5 input (when processing 

calcined rock – Trains 1, 2 and 4) 

2Q .0317(a)(1) PSD 

Avoidance limit

510 pounds per day (Train 4) 

435 pounds per day (Train 3) 

2D .0530 (BACT) 

Total 

Fluorides 

10.0 gram/metric feed per ton of equivalent P2O5 feed 

(0.020 lb/ton) 

2D .1111 (all trains) 

[MACT Subpart AA]

2D .0524 

[NSPS Subpart T]

2D .0530 (Trains 1 , 2, 3, and 

4) [BACT]

TAPS see 2.2 2D.1100 

sulfur dioxide See 2.3 2D .0543 (BART) 

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2.1.5.A.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 

15A NCAC 2D .1111: Maximum Achievable Control Technology 

 Emission Standard

 a. Operation of the phosphoric acid trains shall be limited as follows: 

i. no owner or operator subject to the provisions of this subpart shall cause to be discharged into 

the atmosphere from any affected source any gases which contain total fluorides in excess of 

10.0 gram/metric ton of equivalent P2O5 feed (0.020 lb/ton). [63.602 (a)] 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.5.A.1. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111.

 c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall conduct a 

performance test to demonstrate compliance with the applicable emission standard for the phosphoric 

acid plant process line in accordance with 40 CFR 63.626. Details of the emissions testing and 

requirements can be found in Section 3 - General Condition JJ. Each phosphoric acid train shall be 

tested annually at a rate demonstrable by production records to be equal to or greater than the normal 

production rate of the source. The normal production rate (hourly) shall be calculated by dividing the 

total annual production for the plant by the number of hours that plant was operated during that year. 

The normal production rate for the source test must be approved by the Division of Air Quality in 

advance of the test. The facility shall establish the normal production rate using the production records 

over the last production year. A copy of the production records must accompany the request. If the 

results of this test are above the emission standard given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1111. The results of this testing shall be saved for possible 

inclusion in future determinations of operating parameter ranges. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

d. The permittee shall install, calibrate, maintain, and operate a monitoring system which can be used to 

determine and permanently record the mass flow of phosphorus-bearing feed material to the process. 

The monitoring system shall have an accuracy of ±5 percent over its operating range. The results of 

the monitoring shall be recorded in a log (electronic or written form). The Permittee shall be deemed 

in noncompliance with 15A NCAC 2D .1111 if this monitoring system is not maintained, calibrated, 

operated, and the results recorded. 

e. The permittee shall maintain a daily record of equivalent P2O5 feed by first determining the total mass 

rate in short ton/hour of phosphorus bearing feed using a monitoring system for measuring mass 

flowrate which meets the requirements of paragraph (c) of this section and then by proceeding 

according to §40 CFR 63.626(c)(3). 

f. The permittee shall install, calibrate, maintain, and operate the following monitoring systems installed 

on the wet scrubbing emission control system: 

i. A monitoring system which continuously measures and permanently records the pressure drop 

across each scrubber in the process scrubbing system in 15-minute block averages. The 

monitoring system shall be certified by the manufacturer to have an accuracy of ±5 percent 

over its operating range. 

ii. A monitoring system which continuously measures and permanently records the flow rate of 

the scrubbing liquid to each scrubber in the process scrubbing system in 15-minute block 

averages. The monitoring system shall be certified by the manufacturer to have an accuracy of 

±5 percent over its operating range. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. 

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g. The Permittee has chosen to determine the allowed ranges for the above operating parameters by the 

method described in 40 CFR 63.605(d)(2). The Permittee has submitted the results of previous tests to 

demonstrate allowed ranges for the parameter values listed above in (f). The allowed ranges are: 

i. Crossflow scrubbers Nos. 1 to 3 - pressure drop: 0.5 to 3.5 inches of water 

 flowrate: 700 to 1135 gpm 

ii. Crossflow scrubber No. 4 - pressure drop: 0.5 to 3.5 inches of water 

 flowrate: 700 to 1135 gpm 

iii. Cyclonic scrubbers Nos. 1/2 and 3/4 - pressure drop: 6.8 to 9.3 inches of water 

 flowrate: 50 to 116 gpm 

 Should the results of any subsequent annual performance test demonstrate that the allowed range is 

incorrect, the Permittee shall submit those new ranges to the Division of Air Quality for inclusion in 

this permit. If the daily averages (for any day for which there are 24 hours of normal (not startup, 

shutdown or malfunction) operation) of the pressure drop or flowrate to the scrubber exceeds the 

allowable range an exceedance will have occurred. The Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .1111 for each exceedance. 

.

Reporting [15A NCAC 2Q .0508(f)] 

h. If the following reports are not submitted the permittee shall be deemed in non-compliance with 15A 

NCAC 2D .1111: 

 i. Performance test report. As required by §63.10, the owner or operator shall report the results 

of the initial and annual performance tests as part of the notification of compliance status 

required in §63.9. 

ii. Excess emissions report. As required by §63.10, the owner or operator of an affected source 

shall submit an excess emissions report for any exceedance of an operating parameter limit. 

The report shall contain the information specified in §63.10. When no exceedances of an 

operating parameter have occurred, such information shall be included in the report. The 

report shall be submitted semiannually and shall be delivered or postmarked by the 30th day 

following the end of the calendar half. If exceedances are reported, the owner or operator shall 

report quarterly until a request to reduce reporting frequency is approved as described in 

§63.10. 

iii. Summary report. If the total duration of control system exceedances for the reporting period 

is less than 1 percent of the total operating time for the reporting period, the owner or operator 

shall submit a summary report containing the information specified in §63.10 rather than the 

full excess emissions report, unless required by the Administrator. The summary report shall 

be submitted semiannually and shall be delivered or postmarked by the 30th day following the 

end of the calendar half. 

iv. If the total duration of control system operating parameter exceedances for the reporting 

period is 1 percent or greater of the total operating time for the reporting period, the owner or 

operator shall submit a summary report and the excess emissions report. 

Start-up, Shutdown, and Malfunction Procedures

i. PCS Phosphate must operate and maintain the emission source(s) in accordance with the procedures 

specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all times, including 

periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and maintain the emission 

source(s), including associated air pollution control equipment, in a manner consistent with good air 

pollution control practices for minimizing emissions at least to the levels required by all relevant 

standards. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance 

with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made available for 

inspection, upon request, by the Administrator for the life of the affected source or until the affected 

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source is no longer subject to the provisions of this part. In addition, if SSM plan is revised, PCS 

Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on record, to be made 

available for inspection, upon request, by the Administrator, for a period of 5 years after each revision 

to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of a 

malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate shall 

revise the SSM plan within 45 days after the event to include detailed procedures for operating and 

maintaining the source during similar malfunction events and a program of corrective action for similar 

malfunctions of process or air pollution control equipment. (40 CFR 63 Subpart A) 

2. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY STANDARDS 

a. Operation of the phosphoric acid trains shall be limited as follows: 

i. phosphoric acid train No. 1 shall be limited to 486 pounds per calendar day of sulfur dioxide 

emissions 

ii. phosphoric acid train No. 2 shall be limited to 486 pounds per calendar day of sulfur dioxide 

emissions 

iii. phosphoric acid train No. 3 shall be limited to 960 pounds per calendar day of sulfur dioxide 

emissions 

iv. phosphoric acid train No. 4 shall be limited to 960 pounds per calendar day of sulfur dioxide 

emissions 

[15A NCAC 2D .0501(e)]. 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.5. A. 2. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0501. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

emission limits above by testing one phosphoric acid train producing acid from calcined rock (a 

“green” acid train) and one phosphoric acid train producing acid from uncalcined rock (an “amber” 

acid train) annually for sulfur dioxide in accordance with a testing protocol approved by the DAQ. 

Details of the emissions testing and requirements can be found in Section 3 - General Condition JJ. If 

the results of this test are above the limit given above, the Permittee shall be deemed in noncompliance 

with 15A NCAC 2D .0501(e).

 

 Monitoring/Recordkeeping /Reporting [15A NCAC 2Q .0508(f)] 

 d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

3. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

Emission standard - BACT

a. For the identified Phosphoric Acid trains the following table shall describe the emission standards: 

Source Pollutant BACT Technology Emission Limit 

Phosphoric Acid (PA) Train No. 1 

(ID No.401, 402, 403) 

Total Fluorides crossflow packed 

scrubber 

0.020 pound per ton P2O5 feed 

PA Train No. 1 

(ID No.401, 402, 403) 

Sulfur dioxide Crossflow packed 

scrubber 

486 pounds per day 

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PA Train No. 2 (ID No. 403, 404, 405) Sulfur dioxide Crossflow packed 

scrubber 

486 pounds per day 

PA Train No. 2 (ID No. 403, 404, 405) Total Fluorides crossflow packed 

scrubber 

0.020 pounds per ton P2O5

feed 

PA Train No. 3 (ID No. 406, 407, 408) Total Fluorides Crossflow packed 

scrubber 

0.02 pounds per ton P2O5 feed 

PA Train No. 3 (ID No. 406, 407, 408) Hydrogen sulfide Water scrubbing 435 pounds per day 

PA Train No. 3 (ID No. 406, 407, 408) Sulfur dioxide Water scrubbing 960 pounds per day 

PA Train No. 4 (ID No. 409, 410) Total Fluorides crossflow packed 

scrubber 

0.020 pounds per ton P2O5

feed 

PA Train No. 4 (ID No. 409, 410) Hydrogen sulfide crossflow packed 

scrubber 

510 pounds per day 

PA Train No. 4 (ID No. 409, 410) Sulfur dioxide crossflow packed 

scrubber 

960 pounds per day 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.5.A.1. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall conduct a compliance test on PA 

Trains Nos. 3 or 4 to demonstrate compliance with the emission standards above for hydrogen sulfide 

given above in accordance with 15A NCAC 2D .0530. Details of the emissions testing and 

requirements can be found in Section 3 - General Condition JJ. Either phosphoric acid train Nos. 3 or 

4 shall be tested once every five years at a rate demonstrable by production records to be equal to or 

greater than the normal production rate of the source. The normal production rate (hourly) shall be 

calculated by dividing the total annual production for the plant by the number of hours that plant was 

operated during that year. The normal production rate for the source test must be approved by the 

Division of Air Quality in advance of the test. The facility shall establish the normal production rate 

using the production records over the last production year. A copy of the production records must 

accompany the request. If the results of this test are above the emission standard given above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. The results of this testing 

shall be saved for possible inclusion in future determinations of operating parameter ranges. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall conduct a compliance test on PA 

Trains Nos. 3 or 4 and one compliance test on PA Trains Nos. 1 or 2 to demonstrate compliance with 

the emission standards above for sulfur dioxide given above in accordance with 15A NCAC 2D .0530. 

Details of the emissions testing and requirements can be found in Section 3 - General Condition JJ. 

Either phosphoric acid train Nos. 3 or 4 shall be tested once every year at a rate demonstrable by 

production records to be equal to or greater than the normal production rate of the source. The normal 

production rate (hourly) shall be calculated by dividing the total annual production for the plant by the 

number of hours that plant was operated during that year. The normal production rate for the source 

test must be approved by the Division of Air Quality in advance of the test. The facility shall establish 

the normal production rate using the production records over the last production year. A copy of the 

production records must accompany the request. If the results of this test are above the emission 

standard given above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

The results of this testing shall be saved for possible inclusion in future determinations of operating 

parameter ranges. 

Monitoring/Reporting/Recordkeeping

e. The requirements for /Monitoring/ Recordkeeping given in 2.1.5.A.1 above will be sufficient to 

demonstrate compliance with 2D .0530. 

f. The Permittee shall submit a summary report of monitoring, testing and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period between 

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July and December and July 30 of each calendar year for the preceding six-month period between 

January and June. All instances of deviations from the requirements of this permit must be clearly 

identified 

4. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART U 

Emission Standard

a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management Commission 

Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as promulgated in 40 

CFR Part 60 Subpart U, including Subpart A "General Provisions."[15A NCAC 2D .0524]for the 

phosphoric acid trains. 

Emission Limitations [15A NCAC 2D .0524] 

b. Operation of the phosphoric acid trains shall be limited as follows: [60.202] 

 i. No phosphoric acid train shall discharge into the atmosphere gases which contain fluorides in 

excess of 10.0 grams per metric ton of equivalent P2O5 feed (0.020 pound/ton). 

Testing/Monitoring/Recordkeeping/Reporting

c. The requirements for testing/Monitoring/Reporting/Recordkeeping given in 2.1.5.A.1 above will be 

sufficient to demonstrate compliance with 2D .0524. 

5. 15A NCAC 2Q.0317(a)(1): AVOIDANCE OF PREVENTION OF SIGNIFICANT 

DETERIORATION 

a. In order to avoid applicability of 15A NCAC 2D .0530(g), the Phosphoric Acid trains shall discharge 

into the atmosphere less than: 

 i. 2207.61 tons of Total Reduced Sulfur (TRS) per year from all four trains total, and 

ii. 1728.3 tons per year of TRS from trains 1,2, or 4 total, when processing calcined rock, [15A 

NCAC 2Q .0317(a)(1)] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the limit 

given in Section 2.1.5.A.5.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 

2Q .0317. 

c. In order to verify the accuracy of the average emission factor listed in 2.1.5.A.5.e.i., the Permittee shall 

test for TRS emissions from the cross flow scrubber stack of one green acid train at least once during 

the five year permit term. In addition, subsequent to the first time that the normal production rate 

(defined below) at any green acid train exceeds 1350 tons per day, a test of TRS emissions will be 

required. A test triggered by exceeding 1350 tons per day will satisfy the once per five year permit 

term testing requirement. 

Testing shall be performed in accordance with 40 CFR Part 60 Appendix A, Reference Method 16A 

(Determination of TRS Emissions from Stationary Sources) or an approved alternative method as 

described in 40 CFR §60.8(b) and as approved by the DAQ. The performance test shall be performed 

at production rates equal to or greater than the normal production rate. The normal production rate 

shall be determined by dividing the total annual production from the most recent production year by 

the number of hours operated during the previous 12 months. The normal production rate to be 

achieved during the performance test must be approved by the DAQ Regional Supervisor prior to the 

performance test. The test results must be submitted to the Regional Supervisor, Division of Air 

Quality, in accordance with the approved procedures of the Environmental Management Commission 

within 30 days of test completion. 

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 Monitoring/Recordkeeping/Calculations [15A NCAC 2Q .0508 (f)] 

d. The Permittee shall use the production log (written or electronic form) (as mandated in 2.1.5.A.1.d 

above) along with the emission factors detailed below to demonstrate compliance with emission 

limits in 2.1.5.A.5.a above. To insure that the yearly emission limits are not exceeded, the yearly 

production shall be limited as follows 

i. the production of phosphoric acid from calcined rock shall be limited to a P2O5 input rate of 

815,217 tons per year, calculated each month for the previous twelve (12) months, 

ii. the production of phosphoric acid from uncalcined rock at Trains 3 and 4 shall be limited to a 

P2O5 input rate of 981,120 tons per year, calculated each month for the previous twelve (12) 

months, 

iii. the production of phosphoric acid from uncalcined rock at Train 4 shall be limited to a P2O5

input rate of 535,000 tons per year, calculated each month for the previous twelve (12) months( 

Note: This limit was accepted as part of the 2004 PSD review analysis). 

If a production rate is above these limits for any consecutive 12 month period, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2Q .0317.

e. To calculate emissions to determine if the emission limits above are exceeded, the permittee shall use 

the following emission factors to determine if the emission limits above are exceeded (all emissions 

per ton of P2O5 feed): 

i. for TRS emissions from trains processing calcined rock - 4.24 pounds, 

ii. for TRS emissions from Trains 3 and 4 processing uncalcined rock - 0.30 pounds 

If the results of the above calculations show emissions above any of the limits in 5.a above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2Q .0317. 

Reporting Requirements [15A NCAC 2Q .0508 (f)] 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities within 30 

days after each calendar year quarter, due and post marked on or before January 30 of each calendar 

year for the preceding three-month period between October and December, April 30 of each calendar 

year for the preceding three-month period between January and March, July 30 of each calendar year 

for the preceding three-month period between April and June, and October 30 for the calendar year for 

the preceding three-month period between July and September. The report shall contain the following: 

i. for production using uncalcined and calcined rock, the monthly TRS emissions for the previous 

fourteen (14) months and the annual total TRS emissions for each of the three 12-month periods 

over the previous 14 months (calculations must be included). 

ii. the monthly P2O5 input rates for calcined and uncalcined rock for the previous fourteen (14) 

months and the annual totals for calcined and uncalcined P2O5 input rates for each of the three 

12-month periods over the previous 14 months, 

iii. the daily P2O5 input rate for calcined and uncalcined rock for the previous quarter, and 

iv. the monthly total fluoride and sulfur dioxide emissions from Train 4 processing uncalcined rock 

for the previous twelve (12) months and the annual total emissions for each of the three 12-

month periods over the previous 14 months (calculations must be included). 

STATE-ONLY REQUIREMENT: 

6. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT - Pursuant to 15A 

NCAC 2D .1100, in accordance with the approved application for an air toxic compliance demonstration 

and to insure that limits described in Section 2.2.A.3 are not exceeded, the following operational limits 

shall not be exceeded: 

a. Only two trains (of trains 1, 2, or 4 which are the three trains capable of processing calcined rock) may 

process calcined rock at any given time. Only trains 3 and 4 may process uncalcined rock at any given 

time, 

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b. All four (4) trains of the phosphoric acid plant may manufacture phosphoric acid solely by the wet 

process operating in the dihydrate mode. 

c. The phosphoric acid plant may use phosphate ore sources other than PCS Phosphate Aurora (outside 

ore) in the manufacture of “green acid.” During any given day, however, the ore used in the 

manufacture of “green acid” may only come from two separate places including Aurora ore. The 

maximum outside ore content shall be determined by a compliant source test for fluoride, sulfur 

dioxide, total reduced sulfur or other pollutants as deemed necessary by the division. To be a 

compliant source test, it must be submitted and accepted in writing by the division. The Permittee 

shall notify the division 30 days before any test that is anticipated to be used as a compliant source test 

to change the maximum allowable outside ore content as defined above; ore from each different mine 

or area will be tested separately. The Permittee shall conduct a compliance test within 60 days of 

beginning manufacture of acid using the new ore. If the compliance test does not show compliance 

with any applicable air standard, the permittee will be considered out of compliance with that standard 

for all days of operation with the new ore. At the discretion of the Division, the Permittee may use the 

results of the test to satisfy other requirements for a compliance test on the “green acid” train for these 

three pollutants. However, the Permittee must declare their intention to use the test for such purposes 

in advance and will be held to the results of the test. The division will notify the permittee in writing 

of the results of the compliance test. The division’s letter will be kept on site attached to the current 

Air Permit. Use of outside ore will be limited to the percentage of total ore feed used for the 

compliance test. On-going compliance with this provision will be demonstrated based on a monthly 

average of daily records. 

d. The phosphoric acid plant may use phosphate ore from sources other than PCS Phosphate Aurora 

(outside ore) in the manufacture of “amber acid.” During any given day, however, the ore used in the 

manufacture of “amber acid” may only come from two separate places including Aurora ore. The 

maximum outside ore content shall be determined by a compliant source test for fluoride or other 

pollutants as deemed necessary by the division. To be a compliant source test, it must be submitted 

and accepted in writing by the division. The Permittee shall notify the division 30 days before any test 

that is anticipated to be used as a compliant source test to change the maximum allowable outside ore 

content as defined above; ore from each different mine or area will be tested separately. The Permittee 

shall conduct a compliance test within 60 days of beginning manufacture of acid using the new ore. If 

the compliance test does not show compliance with any applicable air standard, the permittee will be 

considered out of compliance with that standard for all days of operation with the new ore. At the 

discretion of the Division, the Permittee may use the results of the test to satisfy other requirements for 

a compliance test on the “amber acid” train for these pollutants. However, the Permittee must declare 

their intention to use the test for such purposes in advance and will be held to the results of the test. 

The division will notify the permittee in writing of the results of the compliance test. The division’s 

letter will be kept on site attached to the current Air Permit. Use of outside ore will be limited to the 

percentage of total ore feed used for the compliance test. On-going compliance with this provision 

will be demonstrated based on a monthly average of daily records. The use of 20 percent by weight 

Florida ore has been approved. 

Monitoring/Recordkeeping /Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall use the production log (written or electronic form) (as mandated in 2.1.5.A.1. 

above) and other production records to document the compliance with the above operational practices 

limits. Failure to maintain the production log or any instances of production practices differing form 

the above restrictions shall be deemed noncompliance with 2D .1100. 

 Reporting [15A NCAC 2Q .0508(f)] 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

 STATE-ONLY REQUIREMENT: 

7. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT - 

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a. Pursuant to 15A NCAC 2D .1100, in accordance with the approved application for an air toxic 

compliance demonstration and to insure that limits described in Section 2.2.A.3 are not exceeded, the 

following operational limits shall not be exceeded: 

i. The feed rate (calcined rock) to trains 1, 2 or 4 shall not exceed 1450 tons per calendar day.

ii. The feed rate (uncalcined rock) to train 3 shall not exceed 1450 tons per calendar day.

iii. The feed rate (uncalcined rock) to train 4 shall not exceed 1700 tons per calendar day. 

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above the limit given in 

Section 2.1.5.A. 7. a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1100.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Permittee shall use the production log (written or electronic form) (as mandated in 2.1.5.A.1.d 

above) to document the compliance with the above requirement. Failure to maintain the production 

log or any instances of production rates above the above limit shall be deemed noncompliance with 2D 

.1100. 

 Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified.

2.1.5.B Two Phosphoric Acid Storage Tanks - Emission Source ID 040 and 020( 

Emission Point ID No. 421) 

Four Phosphoric Acid Storage Tanks or Three Phosphoric Acid Storage 

Tanks and One Green Acid Sludge Tank - Emission Source ID 032, 033, 

034, and 060- (Emission Point ID No. 422) 

One Slurry Mix Tank, One Clarifier, and One Defluorinated Acid Pump 

Tank - Emission Source ID 426-156, 433-158, and 433-165 - Emission 

Point ID No. 450 

Two Phosphoric Acid Storage Tanks (Phosphoric Acid Tank Farm - Emission 

Source ID 030 and 031 - Emission Point ID No. 492 

Two HFSA Tanks (Phosphoric Acid Tank Farm - Emission Source ID 428-440 

and 428-442) - Emission Point ID No. 492 

One Carbon Slurry Tank (Phosphoric Acid Tank Farm - Emission Source ID 

433-182) - Emission Point ID No. 492 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

TAPS see 2.2 2D.1100 

2.1.5.C Phosphate Rock Transfer Points - Emission Source ID 429-002, 421-115 and 

422-107 Emission Point ID No. 430 

Phosphate Rock Transfer Points - Emission Source ID 429-005, 422-115 and 

422-107 Emission Point ID No. 431 

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The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E=55 x P0.11 - 40 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 

NCAC 2D .0515 

10.7 pounds per day NCAC 2D .0530 BACT

Total Fluoride 0.0178 pounds per hour NCAC 2D .0530 BACT

Visible 

Emissions 

20 percent opacity NCAC 2D .0521 

Toxic Air 

Pollutants 

See Section 2.A.3 -State Enforceable Only NCAC 2D .1100 

2.1.5.C.1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=55 x P0.11 - 40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from the conveyor belt drop point shall be controlled by the bagfilter. 

To assure compliance, the Permittee shall perform inspections and maintenance as recommended 

by the manufacturer. In addition to the manufacturer’s inspection and maintenance 

recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, 

as a minimum, the inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

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Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.5.C. 1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The results of these observations shall be recorded in a 

logbook (written or electronic form). The Permittee shall establish “normal” for the source in the 

first 30 days following the effective date of the permit. If visible emissions from this source are 

observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.5.C.2. a. above. If the demonstration in (b) above cannot be made during the month, 

the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521. 

 Reporting [15A NCAC 2Q .0508(f)]

 d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

3. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

Emission standard - BACT

a. For the identified Phosphoric Acid trains the following table shall describe the emission 

standards: 

Source Pollutant BACT Technology Emission Limit 

PA No. 1 Rock Transfer Point (conveyor GS103 and PA Train 1 transfer point) 

 (ID No. 430) 

Total Fluorides enclosure and 

fabric filtration 

1.78 x 10-2 pound per hour 

PA No. 1 Rock Transfer Point (conveyor GS103 and PA Train 1 transfer point) 

 (ID No. 430) 

PM10 enclosure and 

fabric filtration 

10.7 pounds per day 

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PA No. 2 Rock Transfer Point (conveyor GS203 and PA Train 2 transfer point) 

 (ID No. 431) 

Total Fluorides enclosure and 

fabric filtration 

1.78 x 10-2 pound per hour 

PA No. 2 Rock Transfer Point (conveyor GS203 and PA Train 2 transfer point) 

 (ID No. 431) 

PM10 enclosure and 

fabric filtration 

10.7 pounds per day 

Testing/Monitoring/Reporting/Recordkeeping

b. The requirements for testing/Monitoring/Reporting/Recordkeeping given in 2.1.5.C.1 and 2 above 

will be sufficient to demonstrate compliance with 2D .0530. 

2.1.5.D Phosphate Rock Storage Silo No. 1 and Three Transfer Points - Emission 

Source ID 429-152, 429-001, 429-004, and 429-151 Emission Point ID No. 

434 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E=55 x P0.11 - 40 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 

NCAC 2D .0515 

8.74 pounds per day NCAC 2D .0530 BACT

Total Fluoride 0.0146 pounds per hour NCAC 2D .0530 BACT

Visible 

Emissions 

20 percent opacity NCAC 2D .0521 

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

2.1.5.D.1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=55 x P0.11 - 40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from the conveyor belt drop point shall be controlled by the bagfilter. 

To assure compliance, the Permittee shall perform inspections and maintenance as recommended 

by the manufacturer. In addition to the manufacturer’s inspection and maintenance 

recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, 

as a minimum, the inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

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Appendix L.10 - 642 

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Permit 04176T3? DRAFT 

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ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.5.C. 1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The results of these observations shall be recorded in a 

logbook (written or electronic form). The Permittee shall establish “normal” for the source in the 

first 30 days following the effective date of the permit. If visible emissions from this source are 

observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.5.C.2. a. above. If the demonstration in (b) above cannot be made during the 

monitoring period, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D 

.0521. 

 Reporting [15A NCAC 2Q .0508(f)]

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

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3. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

Emission standard - BACT

a. For the identified Phosphoric Acid trains the following table shall describe the emission 

standards: 

Source Pollutant BACT Technology Emission Limit 

PA Rock Transfer Points (conveyor 70-1 and 

70-2 transfer point) (ID No. 434) 

Total Fluorides enclosure and 

fabric filtration 

1.46 x 10-2 pound per hour 

PA Rock Transfer Points (conveyor 70-1 and 

70-2 transfer point) (ID No. 434) 

PM10 enclosure and 

fabric filtration 

8.74 pounds per day 

Testing/Monitoring/Reporting/Recordkeeping

b. The requirements for testing/Monitoring/Reporting/Recordkeeping given in 2.1.5.D.1 and 2 above 

will be sufficient to demonstrate compliance with 2D .0530. 

2.1.5.EPhosphate Rock Transfer House - Emission Source ID 429-150 Emission Point ID No. 

437 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E=55 x P0.11 - 40 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 

NCAC 2D .0515 

6.58 pounds per day NCAC 2D .0530 BACT

Total Fluoride 0.0110 pounds per hour NCAC 2D .0530 BACT

Visible 

Emissions 

20 percent opacity NCAC 2D .0524 

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

2.1.5.E.1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=55 x P0.11 - 40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition 

JJ. If the results of this test are above the limit given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0515. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

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c. Particulate matter emissions from the conveyor belt drop point shall be controlled by the bagfilter. To 

assure compliance, the Permittee shall perform inspections and maintenance as recommended by the 

manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if 

there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained. 

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook shall 

record the following: 

i. the date and time of each recorded action; 

ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not 

maintained.

Reporting [15A NCAC 2Q .0508(f)]

e. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 days of 

a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a 

six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once 

in any hour and not more than four times in any 24-hour period. In no event shall the six-minute 

average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.5.C. 1. a., the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source for 

any visible emissions above normal. The results of these observations shall be recorded in a logbook 

(written or electronic form). The Permittee shall establish “normal” for the source in the first 30 days 

following the effective date of the permit. If visible emissions from this source are observed to be 

above normal, the Permittee shall either: (a) be deemed to be in noncompliance with 15A NCAC 2D 

.0521 or (b) demonstrate that the percent opacity from the emission points of the emission source in 

accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1.5.C.2. a. above. If 

the demonstration in (b) above cannot be made during the month, the Permittee shall be deemed to be 

in noncompliance with 15A NCAC 2D .0521. 

Reporting [15A NCAC 2Q .0508(f)]

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Appendix L.10 - 645 

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d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

3. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

Emission standard - BACT

a. For the identified Phosphoric Acid processes the following table shall describe the emission standards: 

Source Pollutant BACT Technology Emission Limit 

PA Rock Transfer Point (conveyor 70-2 

transfer point) (ID No. 437) 

Total Fluorides enclosure and 

fabric filtration 

1.10 x 10-2 pound per hour 

PA Rock Transfer Point (conveyor 70-2 

transfer point) (ID No. 437) 

PM10 enclosure and 

fabric filtration 

6.58 pounds per day 

Testing/Monitoring/Reporting/Recordkeeping

b. The requirements for testing/Monitoring/Reporting/Recordkeeping given in 2.1.5.E.1 and 2 above will 

be sufficient to demonstrate compliance with 2D .0530. 

2.1.5.F One Diatomaceous Earth Silo - Emission Source ID 426-154 Emission Point ID No. 

451 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E= 4.10 x P0.67 where E = allowable emission rate in 

pounds per hour and P = rock throughput in tons per hour 

NCAC 2D .0515 

Visible 

Emissions 

20 percent opacity NCAC 2D .0521 

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

2.1.5.F.1.. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E=4.10 x P0.67 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from the transfer pipe shall be controlled by the bagfilter. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or 

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if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and 

bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are 

not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.5.F. 1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The results of these observations shall be recorded in a 

logbook (written or electronic form). The Permittee shall establish “normal” for the source in the 

first 30 days following the effective date of the permit. If visible emissions from this source are 

observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.5.C.2. a. above. If the demonstration in (b) above cannot be made during the month, 

the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521. 

 Reporting [15A NCAC 2Q .0508(f)]

 d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

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between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.5.G One Phosphoric Acid Recirculation Water Cooling Tower Consisting of 

Two Fans - Emission Source ID ES461, ES462 - Emission Point ID No. 461 

and 462 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

2.1.5.G.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 

 15A NCAC 2D .1111: Maximum Achievable Control Technology 

 Operation of the cooling tower shall be limited as follows: No introduction of any liquid 

effluent from any wet scrubbing device installed to control emissions from process equipment 

into any evaporative cooling tower shall be allowed. Compliance with this requirement shall 

be shown during inspections by the DAQ and by certification by the permittee. [40 CFR 

PART 63 SUBPART AA - 63.603(e)]

2.1.5.H Four Silicon Tetrafluoride (STF) recovery plants (ID Nos. ES424 and 

ES425) with venturi scrubbers ID Nos. CD 438-200and CD TBD) - 

Emission Point ID Nos. 424 and 435 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

 STATE-ONLY REQUIREMENT: 

1. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT - 

a. Pursuant to 15A NCAC 2D .1100, in accordance with the approved application for an air toxic 

compliance demonstration and to insure that limits described in Section 2.2.A.3 are not exceeded, 

the following operational procedures shall be followed: 

i. The venturi scrubber (ID No. CD 438-200) shall be operated whenever the STF recovery plant’s 

(ID No. ES424) lines are purged (including loading and maintenance activities). The venturi 

scrubber (ID No. CD TBD) shall be operated whenever the STF recovery plant’s (ID No. 

ES425) lines are purged (including loading and maintenance activities). 

ii. The venturi scrubber (ID No. CD 438-200) will maintain a liquid injection flow rate of (to be 

determined. Permittee will follow scrubber manufacturer’s guidelines and shall submit said 

guidelines to DAQ) whenever the STF recovery plant’s (ID No. ES424) are purged. The venturi 

scrubber (ID No. CD TBD) will maintain a liquid injection flow rate of (to be determined. 

Permittee will follow scrubber manufacturer’s guidelines and shall submit said guidelines to 

DAQ) whenever the STF recovery plant’s (ID No. ES425) lines are purged. 

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iii. At no time shall emissions from the STF recovery plants be exhausted directly to the 

atmosphere without first passing through a venturi scrubber operated in accordance with (ii) 

above. 

Testing [15A NCAC 2Q .0501 (c)(4)] 

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above the limit given in 

Section 2.1.5.A. 7. a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1100.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Permittee shall maintain a log (written or electronic form) to document the compliance with the 

above requirement. The liquid injection rates of the venturi scrubbers will be recorded every five 

minutes whenever they are in operation. Failure to maintain the log or any instances of operational 

procedures that do not follow 2.1.5.H.1.a.i to iii above shall be deemed noncompliance with 2D .1100. 

 Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified.

2.1.6 Purified Acid Area 

2.1.6.A Purified Acid Area Storage Tanks T1, T201, T12, T13, T212, and 

T213- Emission Point ID No. 501 

 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated 

Pollutant

Limits/Standards Applicable Regulation

No applicable 

requirement

Recordkeeping 15A NCAC 2D. 0524 

(40 CFR 60, Subpart Kb)

Toxic Air 

Pollutants

- State Only Requirement

(See Section 2.2 Multiple Emissions Sources)

15A NCAC 2D .1100

2.1.6.A.1 15A NCAC 2D. 0524 (40 CFR 60, Subpart Kb) - VOLATILE ORGANIC LIQUID 

STORAGE TANKS 

 

a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management 

Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as 

promulgated in 40 CFR Part 60 Subpart Kb, including Subpart A "General Provisions."[15A 

NCAC 2D .0524] 

 Monitoring and Recordkeeping [15A NCAC 2Q .0508(f)] 

b. The owner or operator of the storage vessel shall keep readily accessible records showing the 

dimension of the storage vessel and an analysis showing the capacity of the storage vessel.[40 

CFR 60.16b(b)] 

c. The owner or operator of the storage vessel with a design capacity greater than or equal to 75 m3

but less than 151 m3

 storing a liquid with a maximum true vapor pressure greater than or equal to 

15.0 kPa shall maintain a record of the VOL stored, the period of storage, and the maximum true 

vapor pressure of that VOL during the respective storage period. The vapor pressure of Methyl 

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isobutyl ketone (MIBK) is less than the 15.0 kPa at standard operating conditions. Therefore, the 

requirements of section c. will not apply as long as MIBK is stored within these tanks.

2.1.6.B Purified Acid Plant No. 1 

Three (3) Scrub Acid Storage Tanks Discharging through One (1) Seal Pot to 

One (1) Gas Chiller (T24, T224, T324, T346, GC-1), 

Four (4) Extraction Columns Under Nitrogen Blanket System (C10, C20, 

C210, C220), 

Fifteen (15) Tanks Under Nitrogen Blanket System (T7, T12, T13, T212, 

T213, T1, T201, T24, T224 T40, T240, T57, T324), 

Four (4) tanks with Seal Pots Under Nitrogen Blanket System (T54, T44, 

T244, T34), 

Six (6) Seal Pots Under Nitrogen Blanket System (T8, T15, T215, T315, T58, 

T346), 

Six (6) Separators Under Nitrogen Blanket System (S53, S43, S243, S253, 

S33, S5), 

One (1) Still Under Nitrogen Blanket System (S4), 

Five (5) Strippers Under Nitrogen Blanket System (S42, S242, S32, S52, 

S54), and 

One (1) Scrubber Under Nitrogen Blanket System (S324). 

(Emission Point ID No. 501) 

 The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

 Methyl Isobutyl 

Ketone (MIBK) 

twenty parts per million in each product acid stream (thirty 

day average) 

2D .1111 

40 CFR 63 Subpart AA 

thirty parts per million in each raffinate stream (thirty day 

average) 

2D .1111 

40 CFR 63 Subpart AA 

chiller gas steam exit temperature less than or equal to 50 

Farenheit 

2D .1111 

40 CFR 63 Subpart AA 

removal efficiency of 85 percent 2D .0958 

See section 2.2.A.3 multiple sources 2D .1111 

40 CFR 63 Subpart H 

TAPS see 2.2 2D.1100 

2.1.6.B.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 15A NCAC 2D .1111: Maximum Achievable Control Technology 

 Emission Standard

 a. Operation of the Purified Acid Plant No. 1 shall be limited to not exceed any of the following: 

i. A thirty day average of daily concentration measurements of methyl isobutyl ketone in excess of 

twenty parts per million for each product acid stream. 

ii. A thirty day average of daily concentration measurements of methyl isobutyl ketone in excess of 

thirty parts per million for each raffinate stream. 

iii. A daily average chiller stack exit gas stream temperature less than or equal to fifty degrees 

Fahrenheit. [63.602 (f)] 

 Testing [15A NCAC 2Q .0501 (c)(4)]

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 b. If emissions testing is required, the Permittee shall perform such testing in accordance with General 

Condition JJ. If the results of this test are above the limit given in Section 2.1.2.B.2. a., the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111.

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

 c. The Permittee shall: 

 i. Install, calibrate, maintain, and operate a monitoring system which continuously measures and 

permanently records the stack gas exit temperature for each chiller stack. 

 ii. Measure and record the concentration of methyl isobutyl ketone in each product acid stream and 

each raffinate stream once daily. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring systems any exceedances of 

the standards given in section a. above. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked 

on or before January 30 of each calendar year for the preceding six-month period between July and 

December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

Start-up, Shutdown, and Malfunction Procedures

e. PCS Phosphate must operate and maintain the emission source(s) in accordance with the procedures 

specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all times, including 

periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and maintain the emission 

source(s), including associated air pollution control equipment, in a manner consistent with good air 

pollution control practices for minimizing emissions at least to the levels required by all relevant 

standards. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance 

with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made available for 

inspection, upon request, by the Administrator for the life of the affected source or until the affected 

source is no longer subject to the provisions of this part. In addition, if SSM plan is revised, PCS 

Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on record, to be made 

available for inspection, upon request, by the Administrator, for a period of 5 years after each revision 

to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of a 

malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate shall 

revise the SSM plan within 45 days after the event to include detailed procedures for operating and 

maintaining the source during similar malfunction events and a program of corrective action for similar 

malfunctions of process or air pollution control equipment. (40 CFR 63 Subpart A) 

STATE ENFORCEABLE ONLY

2. Work Practices for Sources of Volatile Organic Compounds 2D .0958(e)

As required by 15A NCAC 2D .0958(e), the permittee shall maintain a minimum recovery 

efficiency of 85 percent for all sources of MIBK at the plant site.

2.1.6.CThree (3) Acid Defluorination Columns and Concentrators - Emission Source ID 

S88, T70, S288, T100, S118, and T270 Emission Point ID No. 502 

The following table provides a summary of limits and standards for the emission source(s) described above: 

BART Related Documentation 

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Appendix L.10 - 651 

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Regulated 

Pollutant

Limits/Standards Applicable Regulation

 Volatile 

Organic 

Compounds 

See section 2.2.A.3 multiple sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.D PAP No. 1 Direct Cooling Tower and PAP Indirect Cooling Tower Consisting of 

Two Fans Each - Emission Source ID CT-1 and CT-2 Emission Point ID 

No. 510/511 and 512/513 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Toxic Air 

Pollutants 

See Section 2.2.A.3 -State Enforceable Only NCAC 2D .1100 

2.1.6.D.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 15A NCAC 2D .1111: Maximum Achievable Control Technology 

a. Operation of the cooling towers shall be limited as follows: No introduction of any liquid 

effluent from any wet scrubbing device installed to control emissions from process equipment 

into any evaporative cooling tower shall be allowed. Compliance with this requirement shall 

be shown during inspections by the DAQ and by certification by the permittee. [40 CFR 

PART 63 SUBPART AA - 63.603(e)]

2.1.6.E Purified Acid Area Storage Tanks T1001, T1201, T1012, T1013, and T1212 - 

Emission Point ID No. 503 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

 Volatile 

Organic 

Compounds 

See section 2.2.A.3 multiple sources 2D .0958 

No applicable 

requirement

Recordkeeping 2D .0524 

NSPS Subpart Kb 

TAPS see 2.2 2D.1100 

2.1.6.E.1 15A NCAC 2D. 0524 (40 CFR 60, Subpart Kb) - VOLATILE ORGANIC LIQUID 

STORAGE TANKS 

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 a. The Permittee shall comply with all applicable provisions, including the notification, testing, , 

recordkeeping, and monitoring requirements contained in Environmental Management 

Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as 

promulgated in 40 CFR Part 60 Subpart Kb, including Subpart A "General Provisions."[15A 

NCAC 2D .0524] 

Monitoring and Recordkeeping [15A NCAC 2Q .0508(f)] 

b. The owner or operator of the storage vessel shall keep readily accessible records showing the 

dimension of the storage vessel and an analysis showing the capacity of the storage vessel.[40 

CFR 60.16b(b)] 

c. The owner or operator of the storage vessel with a design capacity greater than or equal to 75 m3

but less than 151 m3

 storing a liquid with a maximum true vapor pressure greater than or equal to 

15.0 kPa shall maintain a record of the VOL stored, the period of storage, and the maximum true 

vapor pressure of that VOL during the respective storage period. The vapor pressure of Methyl 

isobutyl ketone (MIBK) is less than the 15.0 kPa at standard operating conditions. Therefore, the 

requirements of section c. will not apply as long as MIBK is stored within these tanks. 

2.1.6.F Purified Acid Plant No. 2

Two (2) Scrub Acid Storage Tanks Discharging through One (1) Seal Pot to One (1) Gas 

Chiller (T1024, T1324, T1346, GC-2), 

Two (2) Extraction Columns Under Nitrogen Blanket System (C1010, C1020), 

Nine (9) Tanks Under Nitrogen Blanket System (T1007, T1012, T1013, T1212, T1324, 

T1001, T1024, T1040, T1057), 

Three (3) tanks with Seal Pots Under Nitrogen Blanket System (T1054, T1044, T1034), 

Six (6) Seal Pots Under Nitrogen Blanket System (T1008, T1015, T1215, T1315, T1058, 

T1346), 

Five (5) Separators Under Nitrogen Blanket System (S1043, S1053, S1253, S1033, 

S1005), 

One (1) Still Under Nitrogen Blanket System (S1004), 

Four (4) Strippers Under Nitrogen Blanket System (S1042, S1032, S1052, S1054), 

One (1) Scrubber Under Nitrogen Blanket System (S1324). 

(Emission Point ID No. 503) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

 Methyl 

Isobutyl 

Ketone 

(MIBK) 

twenty parts per million in each product acid stream 

(thirty day average) 

2D .1111 

40 CFR 63 Subpart AA 

thirty parts per million in each raffinate stream (thirty 

day average) 

2D .1111 

40 CFR 63 Subpart AA 

chiller gas steam exit temperature less than or equal to 50 

Farenheit 

2D .1111 

40 CFR 63 Subpart AA 

2D.0530 BACT

Total 

Fluorides 

0.0152 pounds per hour 2D .0530 BACT

VOC see 2.2.A.3 multiple Sources 2D .0958 

See section 2.2 multiple sources 2D .1111 

40 CFR 63 Subpart H 

TAPS see 2.2 2D.1100 

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2.1.6.F.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID 

MANUFACTURING PLANTS 15A NCAC 2D .1111: 

Maximum Achievable Control Technology 

 Emission Standard

a. Operation of the Purified Acid Plant No. 2 shall be limited to not exceed any of the following: 

i. A thirty day average of daily concentration measurements of methyl isobutyl ketone in 

excess of twenty parts per million for each product acid stream. 

ii. A thirty day average of daily concentration measurements of methyl isobutyl ketone in 

excess of thirty parts per million for each raffinate stream. 

iii. A daily average chiller stack exit gas stream temperature less than or equal to fifty degrees 

Fahrenheit. [63.602 (f)] 

 Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.F.1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111.

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. The Permittee shall: 

i. Install, calibrate, maintain, and operate a monitoring system which continuously measures and 

permanently records the stack gas exit temperature for each chiller stack. 

ii. Measure and record the concentration of methyl isobutyl ketone in each product acid stream 

and each raffinate stream once daily. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring systems any 

exceedances of the standards given in section a. above. 

d. Subpart AA contains a reference to Subpart H. Therefore a leak detection and repair (LDAR) 

program is required. For specific requirements see Section xx. The Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .1111 if the required inspections are not conducted and the 

results of these inspections recorded. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

Start-up, Shutdown, and Malfunction Procedures

f. PCS Phosphate must operate and maintain the emission source(s) in accordance with the 

procedures specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all 

times, including periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and 

maintain the emission source(s), including associated air pollution control equipment, in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels 

required by all relevant standards. Malfunctions shall be corrected as soon as practicable after 

their occurrence in accordance with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made 

available for inspection, upon request, by the Administrator for the life of the affected source or 

until the affected source is no longer subject to the provisions of this part. In addition, if SSM 

plan is revised, PCS Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 654 

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Permit 04176T3? DRAFT 

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record, to be made available for inspection, upon request, by the Administrator, for a period of 5 

years after each revision to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate 

shall revise the SSM plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control equipment. (40 CFR 

63 Subpart A) 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

Emission standard - BACT

a. For Purified Acid Plant (ID No. 503) the following table shall describe the emission standards: 

Source Pollutant BACT 

Technology

Emission Limit

Purified Acid Plant (PAP) No. 2 Chiller Stack (ID 

No. 503) 

VOC Chiller Maintain a daily 

average chiller 

stack exit gas 

stream 

temperature less 

than or equal to 

50(F 

PAP No. 2 Chiller Stack (ID No. 503) Total Fluorides Chiller 1.52 x 10-2

pounds per hour 

 Testing/Monitoring/Reporting/Recordkeeping

b. The requirements for testing/Monitoring/Reporting/Recordkeeping given in 2.1.6.F.1 above will 

be sufficient to demonstrate compliance with 2D .0530 for the chiller stack temperature 

requirement. 

Testing

c. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.F.2. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for the purified phosphoric acid 

plant chiller stack. Details of the emissions testing and requirements can be found in Section 3 - 

General Condition JJ. The chiller stack shall be tested once per five-year permit period at a rate 

demonstrable by production records to be equal to or greater than the normal production rate of the 

source. The normal production rate (hourly) shall be calculated by dividing the total annual 

production for the plant by the number of hours that plant was operated during that year. The 

normal production rate for the source test must be approved by the Division of Air Quality in 

advance of the test. The facility shall establish the normal production rate using the production 

records over the last production year. A copy of the production records must accompany the 

request. If the results of this test are above the emission standard given above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0530. 

2.1.6.G One (1) Acid Defluorination Column and Concentrator - Emission Source ID S1088, 

T1070, S1118, and T1100 Emission Point ID No. 504 

The following table provides a summary of limits and standards for the emission source(s) described above: 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 655 

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Regulated 

Pollutant

Limits/Standards Applicable Regulation

Total 

Fluorides 

0.0688 pounds per hour 2D .0530 BACT

VOC see 2.2.A.3 multiple Sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.G.1 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

 Emission standard - BACT

a. For the Acid Defluorination and Concentrators the following table shall describe the emission 

standards: 

Source Pollutant BACT 

Technology

Emission Limit

PAP No. 2 Scrubber Stack (ID No.504) Total Fluorides Scrubbers 6.88 x 10-2

pounds per hour 

Testing

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.G.1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for Emission Point 504. Details of 

the emissions testing and requirements can be found in Section 3 - General Condition JJ. The 

scrubber stack shall be tested once per five-year permit period at a rate demonstrable by 

production records to be equal to or greater than the normal production rate of the source. The 

normal production rate (hourly) shall be calculated by dividing the total annual production for the 

plant by the number of hours that plant was operated during that year. The normal production rate 

for the source test must be approved by the Division of Air Quality in advance of the test. The 

facility shall establish the normal production rate using the production records over the last 

production year. A copy of the production records must accompany the request. If the results of 

this test are above the emission standard given above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0530. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

 d. The Permittee shall install, calibrate, maintain, and operate a monitoring system which 

continuously measures and permanently records the pond liquid injection rate for each wet spray 

tower scrubber. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if 

these monitoring systems are not maintained, calibrated, operated, and the results recorded. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.6.H PAP No. 2 Direct Cooling Tower Consisting of Two Fans - Emission Source 

ID E1180-1 and E1180-2 Emission Point ID No. 514/515

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Appendix L.10 - 656 

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The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Total 

Fluorides 

0.072 pounds per hour 2D .0530 BACT

Particulates 0.11 pounds per hour 2D .0530 BACT

VOC see 2.2.A.3 multiple Sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.H.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 15A NCAC 2D .1111: Maximum Achievable Control Technology 

a. Operation of the cooling towers shall be limited as follows: No introduction of any liquid effluent 

from any wet scrubbing device installed to control emissions from process equipment into any 

evaporative cooling tower shall be allowed. Compliance with this requirement shall be shown 

during inspections by the DAQ and by certification by the permittee. [40 CFR PART 63 

SUBPART AA - 63.603(e)] 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

 Emission standard - BACT

a. For the concentrators, the following table shall describe the emission standards: 

Source Pollutant BACT 

Technology

Emission Limit

PAP No. 2 Cooling Tower No. 1 Fans 1 and 

2 (ID Nos. 514 and 515) 

PM10 Drift 

Elimination 

System 

0.11 pounds per 

hour 

PAP No. 2 Cooling Tower No. 1 Fans 1 and 

2 (ID Nos. 514 and 515) 

Total Fluorides Drift 

Elimination 

System 

7.2 x 10-2

pounds per hour 

Testing

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 

2.1.6.G.1. a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.1111.

2.1.6.I PAP No. 2 Indirect Cooling Tower Consisting of Two Fans - Emission 

Source ID E1181-1 and E1181-2 Emission Point ID No. 516/517 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Total 

Fluorides 

2D .0530 BACT

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Appendix L.10 - 657 

 December 17, 2007
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Particulates 0.0058 pounds per hour 2D .0530 BACT

VOC see 2.2.A.3 multiple Sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.I.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 15A NCAC 2D .1111: Maximum Achievable Control Technology 

a. Operation of the cooling towers shall be limited as follows: No introduction of any liquid 

effluent from any wet scrubbing device installed to control emissions from process equipment 

into any evaporative cooling tower shall be allowed. Compliance with this requirement shall 

be shown during inspections by the DAQ and by certification by the permittee. [40 CFR 

PART 63 SUBPART AA - 63.603(e)] 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

 Emission standard - BACT

a. For the PAP Indirect Cooling Tower, the following table shall describe the emission 

standards: 

Source Pollutant BACT 

Technology

Emission Limit

PAP No. 2 Cooling Tower No. 2, Fans 1 and 2 

(ID Nos. 516 and 517) 

PM10 Drift 

Elimination 

System 

0.0058 pounds 

per hour 

PAP No. 2 Cooling Tower No. 2, Fans 1 and 2 

(ID Nos. 516 and 517) 

Total Fluorides Drift 

Elimination 

System 

No emission 

limit required 

Testing

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.I.2. 

a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

Monitoring/Recordkeeping /Reporting[15A NCAC 2Q .0508 (f)] 

c. No monitoring, recordkeeping or reporting is required to show compliance with this standard. 

2.1.6.J Purified Acid Plant No. 2 Train No. 4

One (1) Gas Chiller* (GC-2) controlling the following: 

One (1) Scrub Acid Storage Tank Discharging through One (1) Seal Pot to (T1524, 

T1546), Two (2) Extraction Columns Under Nitrogen Blanket System (C1210, C1220), 

Seven (7) Tanks Under Nitrogen Blanket System (T1201, T1224, T1524, T1207, T1213, 

T1240, T1257), 

One (1) tank with Seal Pot Under Nitrogen Blanket System (T1244), 

Six (6) emergency vent pots (T1415, T1515, T1208, T1258, T1546, T1215) 

Two (2) Separators Under Nitrogen Blanket System (S1243, S1205), 

One (1) Stripper Under Nitrogen Blanket System (S1242), 

One (1) Solvent still (S1204). 

(Emission Point ID No. 503)

* Listed previously at 2.1.6.I 

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Appendix L.10 - 658 

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Regulated 

Pollutant

Limits/Standards Applicable Regulation

 Methyl 

Isobutyl 

Ketone 

(MIBK) 

twenty parts per million in each product acid stream 

(thirty day average) 

2D .1111 

40 CFR 63 Subpart AA 

thirty parts per million in each raffinate stream (thirty 

day average) 

2D .1111 

40 CFR 63 Subpart AA 

chiller gas steam exit temperature less than or equal to 50 

Fahrenheit 

2D .1111 

40 CFR 63 Subpart AA 

2D.0530 BACT

Total 

Fluorides 

0.0152 pounds per hour 2D .0530 BACT

VOC see 2.2.A.3 multiple Sources 2D .0958 

See section 2.2.A.3 multiple sources 2D .1111 

40 CFR 63 Subpart H 

TAPS see 2.2 2D.1100 

2.1.6.J.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID 

MANUFACTURING PLANTS 15A NCAC 2D .1111: 

Maximum Achievable Control Technology 

 Emission Standard

a. Operation of the Purified Acid Plant No. 2 Train No. 4 shall be limited to not exceed any of the 

following: 

i. A thirty day average of daily concentration measurements of methyl isobutyl ketone in 

excess of twenty parts per million for each product acid stream. 

ii. A thirty day average of daily concentration measurements of methyl isobutyl ketone in 

excess of thirty parts per million for each raffinate stream. 

iii. A daily average chiller stack exit gas stream temperature less than or equal to fifty 

degrees Fahrenheit. [63.602 (f)] 

 Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.F.1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111.

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. The Permittee shall: 

i. Install, calibrate, maintain, and operate a monitoring system which continuously measures and 

permanently records the stack gas exit temperature for each chiller stack. 

ii. Measure and record the concentration of methyl isobutyl ketone in each product acid stream 

and each raffinate stream once daily. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring 

systems are not maintained, calibrated, operated, and the results recorded. The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .1111 if these monitoring systems any 

exceedances of the standards given in section a. above. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

BART Related Documentation 

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Appendix L.10 - 659 

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between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

Start-up, Shutdown, and Malfunction Procedures

e. PCS Phosphate must operate and maintain the emission source(s) in accordance with the 

procedures specified in the facility's start-up, shut-down, and malfunction (SSM) plan. At all 

times, including periods of startup, shutdown, and malfunction, PCS Phosphate shall operate and 

maintain the emission source(s), including associated air pollution control equipment, in a manner 

consistent with good air pollution control practices for minimizing emissions at least to the levels 

required by all relevant standards. Malfunctions shall be corrected as soon as practicable after 

their occurrence in accordance with the startup, shutdown, and malfunction plan. 

PCS Phosphate shall keep the written SSM plan on record after it is developed to be made 

available for inspection, upon request, by the Administrator for the life of the affected source or 

until the affected source is no longer subject to the provisions of this part. In addition, if SSM 

plan is revised, PCS Phosphate shall keep previous (i.e., superseded) versions of the SSM plan on 

record, to be made available for inspection, upon request, by the Administrator, for a period of 5 

years after each revision to the plan. 

If the SSM plan fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction but was not included in the SSM plan at the time it was developed, PCS Phosphate 

shall revise the SSM plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control equipment. (40 CFR 

63 Subpart A) 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

Emission standard - BACT

a. For Purified Acid Plant No. 2 train No. 4 (ID No. 505) the following table shall describe the 

emission standards: 

Source Pollutant BACT 

Technology

Emission Limit

Purified Acid Plant (PAP) No. 2 Train No. 4 Chiller 

Stack (ID No. 503) 

VOC Chiller Maintain a daily 

average chiller 

stack exit gas 

stream 

temperature less 

than or equal to 

50(F 

PAP No. 2 No. 2 Train No. 4 Chiller Stack (ID 

No. 503) 

Total Fluorides Chiller 1.52 x 10-2

pounds per hour 

 Testing/Monitoring/Reporting/Recordkeeping

b. The requirements for testing/Monitoring/Reporting/Recordkeeping given in 2.1.6.J.1 above will be 

sufficient to demonstrate compliance with 2D .0530 for the chiller stack temperature requirement. 

Testing

c. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.F.2. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for the purified phosphoric acid plant chiller 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 660 

 December 17, 2007
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stack. Details of the emissions testing and requirements can be found in Section 3 - General Condition JJ. 

The chiller stack shall be tested once per five-year permit period at a rate demonstrable by production 

records to be equal to or greater than the normal production rate of the source. The normal production rate 

(hourly) shall be calculated by dividing the total annual production for the plant by the number of hours 

that plant was operated during that year. The normal production rate for the source test must be approved 

by the Division of Air Quality in advance of the test. The facility shall establish the normal production rate 

using the production records over the last production year. A copy of the production records must 

accompany the request. If the results of this test are above the emission standard given above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0530. 

2.1.6.K One (1) Acid Defluorination Column and Concentrator - Emission Source ID S1288, 

T1270, Emission Point ID No. 506 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Total 

Fluorides 

0.0688 pounds per hour 2D .0530 BACT

VOC see 2.2 multiple Sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.K.1 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) 

BACT

 Emission standard - BACT

a. For the Acid Defluorination and Concentrators the following table shall describe the emission 

standards: 

Source Pollutant BACT 

Technology

Emission Limit

PAP No. 2 Scrubber Stack (ID No.506 Total Fluorides Scrubbers 6.88 x 10-2

pounds per hour 

Testing

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.K.1. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall conduct a performance test to 

demonstrate compliance with the applicable emission standard for Emission Point 503. Details of 

the emissions testing and requirements can be found in Section 3 - General Condition JJ. The 

chiller stack shall be tested once per five-year permit period at a rate demonstrable by production 

records to be equal to or greater than the normal production rate of the source. The normal 

production rate (hourly) shall be calculated by dividing the total annual production for the plant by 

the number of hours that plant was operated during that year. The normal production rate for the 

source test must be approved by the Division of Air Quality in advance of the test. The facility 

shall establish the normal production rate using the production records over the last production 

year. A copy of the production records must accompany the request. If the results of this test are 

above the emission standard given above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0530. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

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Permit 04176T3? DRAFT 

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 d. The Permittee shall install, calibrate, maintain, and operate a monitoring system which 

continuously measures and permanently records the pond liquid injection rate for each wet spray 

tower scrubber. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if 

these monitoring systems are not maintained, calibrated, operated, and the results recorded. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.6.L PAP No. 2 Direct Cooling Tower No. 3 Consisting of Two Fans - Emission 

Source ID TBD Emission Point ID No. 518/519

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Total 

Fluorides 

0.072 pounds per hour 2D .0530 BACT

Particulates 0.0.0367 pounds per hour 2D .0530 BACT

VOC see 2.2 multiple Sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.H.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 15A NCAC 2D .1111: Maximum Achievable Control Technology 

a. Operation of the cooling towers shall be limited as follows: No introduction of any liquid effluent 

from any wet scrubbing device installed to control emissions from process equipment into any 

evaporative cooling tower shall be allowed. Compliance with this requirement shall be shown 

during inspections by the DAQ and by certification by the permittee. [40 CFR PART 63 

SUBPART AA - 63.603(e)] 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

 Emission standard - BACT

a. For the concentrators, the following table shall describe the emission standards: 

Source Pollutant BACT 

Technology

Emission Limit

PAP No. 2 Cooling Tower No. 1 Fans 1 and 

2 (ID Nos. 514 and 515) 

PM10 Drift 

Elimination 

System 

0.0367 pounds 

per hour 

PAP No. 2 Cooling Tower No. 1 Fans 1 and 

2 (ID Nos. 514 and 515) 

Total Fluorides Drift 

Elimination 

System 

7.2 x 10-2

pounds per hour 

Testing

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 

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Page 114 

2.1.6.G.1. a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.1111.

2.1.6.M PAP No. 2 Indirect Cooling Tower No. 4 Consisting of Two Fans - 

Emission Source ID TBD Emission Point ID No. 520/521 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Total 

Fluorides 

No numerical standard 2D .0530 BACT

Particulates 0.0058 pounds per hour 2D .0530 BACT

VOC see 2.2 multiple Sources 2D .0958 

TAPS see 2.2 2D.1100 

2.1.6.I.1 40 CFR PART 63 SUBPART AA: NATIONAL EMISSIONS STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING 

PLANTS 15A NCAC 2D .1111: Maximum Achievable Control Technology 

a. Operation of the cooling towers shall be limited as follows: No introduction of any liquid 

effluent from any wet scrubbing device installed to control emissions from process equipment 

into any evaporative cooling tower shall be allowed. Compliance with this requirement shall 

be shown during inspections by the DAQ and by certification by the permittee. [40 CFR 

PART 63 SUBPART AA - 63.603(e)] 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

 Emission standard - BACT

a. For the PAP Indirect Cooling Tower, the following table shall describe the emission 

standards: 

Source Pollutant BACT 

Technology

Emission Limit

PAP No. 2 Cooling Tower No. 2, Fans 1 and 2 

(ID Nos. 520 and 521) 

PM10 Drift 

Elimination 

System 

0.0058 pounds 

per hour 

PAP No. 2 Cooling Tower No. 2, Fans 1 and 2 

(ID Nos. 520 and 521) 

Total Fluorides Drift 

Elimination 

System 

No emission 

limit required 

Testing

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.6.I.2. 

a., the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

Monitoring/Recordkeeping /Reporting[15A NCAC 2Q .0508 (f)] 

d. No monitoring, recordkeeping or reporting is required to show compliance with this standard. 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 663 

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Page 115 

2.1.6.N Purified Acid Plant No. 1 and No. 2 Tank Farm Fugitives and Storage 

Tank Fugitives –Emission Point ID No. 590, 591, 592, and 593 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

 Volatile 

Organic 

Compounds 

See section 2.2 multiple sources 2D .0958 

recordkeeping 2D .0524 

NSPS Subpart Kb 

TAPS see 2.2 2D.1100 

2.1.6.J.1 15A NCAC 2D. 0524 (40 CFR 60, Subpart Kb) - VOLATILE ORGANIC LIQUID 

STORAGE TANKS 

 

 a. The Permittee shall comply with all applicable provisions, including the notification, 

testing, , recordkeeping, and monitoring requirements contained in Environmental 

Management Commission Standard 15A NCAC 2D .0524 "New Source Performance 

Standards (NSPS) as promulgated in 40 CFR Part 60 Subpart Kb, including Subpart A 

"General Provisions."[15A NCAC 2D .0524] 

Monitoring and Recordkeeping [15A NCAC 2Q .0508(f)] 

 b. The owner or operator of the storage vessel shall keep readily accessible records showing 

the dimension of the storage vessel and an analysis showing the capacity of the storage 

vessel.[40 CFR 60.16b(b)] 

 c. The owner or operator of the storage vessel with a design capacity greater than or equal 

to 75 m3

 but less than 151 m3 storing a liquid with a maximum true vapor pressure 

greater than or equal to 15.0 kPa shall maintain a record of the VOL stored, the period of 

storage, and the maximum true vapor pressure of that VOL during the respective storage 

period. The vapor pressure of Methyl isobutyl ketone (MIBK) is less than the 15.0 kPa at 

standard operating conditions. Therefore, the requirements of section c. will not apply as 

long as MIBK is stored within these tanks.

2.1.7 Defluorinated Feed Phosphate Production Area 

2.1.7.A Two (2) Pug Mills and One (1) Defluorination Kiln - Emission Source ID 

355-116-455A, 355-116-455B and 365-135-477 (Emission Point DFP 

Kiln Stack - ID No. 701) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur dioxide 329.2 pounds per day 2D .0501(e) 

39.5 tons per year 2Q .0317(a)(1) PSD 

Avoidance limit

2.3 pounds per million Btu 2D .0516 

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Appendix L.10 - 664 

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Carbon 

Monoxide 

117.52 pounds per hour 2D .0530 BACT

Sulfuric Acid 

Mist 

6.57 pounds per hour 2D .0530 BACT

NOx 210 pounds per hour 2D .0530 BACT

562.5 tons per year 2D .0501(e) 

Particulates 727.2 pounds per 3 hour block 

132.7 tons per year 

2D .0501(e) 

25.0 pounds per hour (filterable) 2D .0530 BACT

E = 4.10 x P 0.67 (for P < 30 tons per hour) or 

E = 55 x P 0.11 - 40 ( for P > 30 tons per hour) 

Where 

E = allowable emission rate in pounds per hour and P = 

process weight in tons per hour 

2D .0515 

TAPS see 2.2 2D.1100 

2.1.7.A.1. 15A NCAC 2D. 0501(e) : COMPLIANCE WITH NATIONAL AMBIENT AIR 

QUALITY STANDARDS 

 Emission Standard

a. Sulfur dioxide emissions from the kiln shall not exceed 329.2 pounds per day 

b. Nitrogen oxide (NOx) emissions from the kiln shall not exceed 562.5 tons per year. 

c. Particulate matter emissions limits from the Pug Mill and Kiln are found in the multiple source 

section 2.2.B.1.A. 

 Testing [15A NCAC 2Q .0501 (c)(4)]

 d. If emissions testing is required, the Permittee shall perform such testing in accordance with 15A 

NCAC 2D .0501(c)(4) and General Condition JJ. If the results of this test are above the limit 

given in Section 2.1.7. A. 1. a., the Permittee shall be deemed in noncompliance with 15A NCAC 

2D .0501(e).

e. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

emission limits for sulfur dioxide above by testing the kiln (ID No. 365-135-477) once per five 

year permit period for sulfur dioxide in accordance with a testing protocol approved by the DAQ. 

Details of the emissions testing and requirements can be found in Section 3 - General Condition 

JJ. If the results of this test are above the limit given in Section 2.1.7. A. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0501(e). 

f. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the 

emission limits for NOx above by testing the kiln (ID No. 365-135-477) once per five year permit 

period for NOx in accordance with a testing protocol approved by the DAQ. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. If the 

results of this test are above the limit given in Section 2.1.7. A. 1. b. above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0501(e). 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

g.. To comply with the provisions of this permit and ensure that emissions do not exceed the 

regulatory limits, the Permittee shall perform periodic inspections and maintenance (I&M) as 

recommended by the manufacturer plus any additional I&M as listed below. The results of all 

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Appendix L.10 - 665 

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Permit 04176T3? DRAFT 

Page 117 

inspections and any variance from manufacturer’s recommendations or from those given in this 

permit shall be investigated with corrections made and the dates of all actions recorded in a 

logbook. Records of all maintenance and monitoring activities shall be recorded on the logbook. 

The logbook (in written or electronic form) shall be kept on site and made available to DAQ 

personnel upon request. Failure to maintain this logbook will be deemed noncompliance with 15A 

NCAC 2D .0501(e). 

 Reporting [15A NCAC 2Q .0508(f)]

 h. The Permittee shall submit a summary report of testing monitoring, and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION (PSD) BACT

Emission standard - BACT

a. For the Pug Mills and Defluorination Kiln (Emission Point DFP Kiln Stack - ID No. 701) the 

following table shall describe the emission standards: 

Source Pollutant BACT 

Technology

Required1

Removal 

Efficiency

Emission 

Limit 2

Pugmill, Defluorination Kiln 

(ID Nos. 355-116-455A+B, 

365-135-477) 

Particulate 

(filterable 

particulate) 

2 Jet 

Scrubber 

98.31% 25 lb/hr 

Sulfuric Acid 

mist 

2 Jet 

Scrubber

20.8% 6.57 lb/hr

carbon 

monoxide 

good 

combustion 

practices 

not 

applicable 

117.52 

lb/hr 

nitrogen 

oxides 

good 

combustion 

practices 

not 

applicable 

210.0 

lb/hr 

 i. Removal Efficiency required to be met at all times at any operational rate, or at the 

maximum level as described in the SSM plan (see 2.1.7.A.2. 

ii. Emission Limit is maximum allowable, not to be exceeded as determined by the 

compliance method. 

 Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

15A NCAC 2D ..0530 and General Condition JJ. If the results of this test are above the limit 

given in Section 2.1.7. A.2. a., the Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .0501(e). 

c. Under the provisions of NCGS 143-215.108 and per 40 CFR 63.606, the Permittee shall 

conduct a performance test to demonstrate compliance with the applicable particulate and 

sulfuric acid mist emission standards for the Pug Mills and Defluorination Kiln (Emission 

Point DFP Kiln Stack - ID No. 701) in accordance with 40 CFR 63.626. Details of the 

emissions testing and requirements can be found in Section 3 - General Condition JJ. The 

sources shall be tested once per five-year permit period at a rate demonstrable by production 

records to be equal to or greater than the normal production rate of the source. The normal 

production rate (hourly) shall be calculated by dividing the total annual production for the 

plant by the number of hours that plant was operated during that year. The normal production 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 666 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 118 

rate for the source test must be approved by the Division of Air Quality in advance of the test. 

The facility shall establish the normal production rate using the production records over the 

last production year. A copy of the production records must accompany the request. If the 

results of this test are above the emission standard given above, the Permittee shall be deemed 

in noncompliance with 15A NCAC 2D .0530. 

 Monitoring/Inspection/Recordkeeping

d. The permittee shall ensure compliance with the PM/PM10 emission limits stated above by 

monitoring the following operational parameters and performing the required Inspection and 

Maintenance procedures:

Source Control Device Inspection and 

Maintenance

Monitoring 

Parameter minimum Frequency

DFP Pugmill 

and Kiln (ID 

Nos. 355-116-

455A+B & 

365-135-477) 

Limestone Slurry 

Scrubber (ID No. 

360-120-476) 

Perform periodic 

inspections and 

maintenance (I&M) 

as recommended by 

the manufacturer. 

Recycle liquid 

flow rate 

Set during 

compliance 

test 

Daily 

Pressure drop 

across 

scrubber 

55 inches of 

water 

Daily 

pH Set during 

compliance 

test 

Daily 

Operation of the kiln while the daily average (midnight to midnight) of any of the scrubber 

parameters are below the minimum above shall be deemed non-compliance with 15A NCAC 

2D.0530, except start up, shut down and malfunctions as described in 3.I. 

e. The results of all inspections and any variance from manufacturer’s recommendations or from 

those given in this permit shall be investigated with corrections made and the dates of all 

actions recorded in a logbook. Records of all maintenance and monitoring activities 

shall be recorded on the logbook. The logbook (in written or electronic form) shall be 

kept on site and made available to DAQ personnel upon request. Failure to maintain this 

logbook will be deemed noncompliance with 15A NCAC 2D .0501(e).

Reporting [15A NCAC 2Q .0508(f)]

f. The Permittee shall submit a summary report of testing monitoring, and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding 

six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

3. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 667 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 119 

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

 E = 4.10 x P 0.67 (for P < 30 tons per hour) or 

E = 55 x P 0.11 - 40 ( for P > 30 tons per hour) 

Where 

E = allowable emission rate in pounds per hour and P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515. 

c. Compliance with the requirements of stipulation 2.1.7.A.2 shall be sufficient to comply with 2D 

.0515.

4. 15A NCAC 2Q.0317(a)(1): AVOIDANCE OF PREVENTION OF SIGNIFICANT 

DETERIORATION 

a. In order to avoid applicability of 15A NCAC 2D .0530(g), the defluorination kiln (Emission Point 

DFP Kiln Stack - ID No. 701) shall discharge into the atmosphere less than 39.50 tons per year of 

sulfur dioxide.[15A NCAC 2Q .0317(a)(1)] 

b. To insure compliance with the emission limit above, annual production of defluorinated feed 

phosphate shall be limited to 175,000 tons per year. 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 c . If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1 7.A.4. a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC Q .0317. 

 Monitoring/Recordkeeping/Calculations [15A NCAC 2Q .0508 (f)] 

 d. The Permittee shall maintain a production log (written or electronic form) to demonstrate 

compliance with the production limit in 2.1.7.A.4.b above. If the production rate shown in the 

production log is above the limit in 4.b above for any consecutive 12 month period, the Permittee 

shall be deemed in noncompliance with 15A NCAC Q .0317.

e. The monitoring and recordkeeping required in 2.1.2.A.1.e and g shall be used in determining 

compliance with 2.1.7.A.4.a. for solid fuels. The Permittee shall monitor the sulfur content of the 

fuel oil by using fuel oil supplier certification of an agglomerated sample of each shipment 

received per month. The results of the fuel oil supplier certifications shall be recorded in a 

logbook (written or electronic format) on a quarterly basis and include the following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the quarter; 

iii. the method used to determine the maximum sulfur content of the fuel oil; and 

iv. a certified statement signed by the responsible official that the records of fuel oil supplier 

certification submitted represent all of the fuel oil fired during the period. 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 668 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 120 

The Permittee shall be deemed in noncompliance with 15A NCAC 2Q .0317 if these records are 

not kept.. 

Reporting Requirements [15A NCAC 2Q .0508 (f)] 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities within 30 

days after each calendar year quarter, due and post marked on or before January 30 of each 

calendar year for the preceding three-month period between October and December, April 30 of 

each calendar year for the preceding three-month period between January and March, July 30 of 

each calendar year for the preceding three-month period between April and June, and October 30 

for the calendar year for the preceding three-month period between July and September. The 

report shall contain all instances of deviations from the requirements of this permit clearly 

identified. 

5. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

 Emission Standard

a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat 

input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other 

substances shall be included when determining compliance with this standard. [15A NCAC 2D 

.0516] 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.1.B.2. a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0516. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c.. The monitoring, recordkeeping, and reporting requirements in 2.1.7.A.4 above will be sufficient to 

demonstrate compliance with 2D .0516. 

2.1.7.BMaterials Handling Sources

Grate Cooler - Emission Source ID 370-106-468 - (Emission Point ID No. 702) 

Soda Ash Day Bin and Soda Ash Unloading - Emission Source ID 355-128-462 

and 382-137-463 (Emission Point ID No. 709 and 710)

Limestone Storage Silo - Emission Source 382-100-462 (Emission Point ID No. 

711) 

Air Classifier equipment and baghouse (Emission Point ID No. 712) 

 Soda Ash Feeder, Limestone Feeder, Plenum Recycle Dust Discharge Conveyor, 

Plenum Dust Elevator, and Plenum Dust Bin - Emission Source ID 

355-154-463,355-153-463, 355-112-473, 365-155-472, and 355-125-462 

(Emission Point ID No. 713)

Phosphate Rock Surge Bin, Phosphate Rock Feeder, and Recycle Feeder - 

Emission Source ID No. 355-129-462, 355-155-463 and 355-156-463 

(Emission Point ID No. 714)

Recycle Bin - Emission Source ID 355-130-462 (Emission Source ID No. 715) 

BART Related Documentation 

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Appendix L.10 - 669 

 December 17, 2007
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Product Cooler Discharge Conveyor, Clinker Surge Bin Elevator, Clinker 

Reclaim Conveyors 1 and 2, Clinker Surge Bin, Screening Feed Elevator, 

Clinker Reclaim Hopper, Clinker Reclaim Crusher, Clinker Screen, Screen 

Elevator, Abort Surge Bin, Crusher Discharge Conveyor - Emission Source 

ID No. 370-176-474, 370-155-472, 370-177-463,370-174-463, 

370-113-463, 370-156-472, 370-115-462, 370-126-480, 370-140-432, 

370-150-472, 370-114-462 and 370-175-463 (Emission Point ID No. 717) 

Product Screen Discharge Conveyor, Product Transfer Conveyor, Product Tripper 

Conveyor, Product Loadout Hopper, Product Loadout Elevator, Product 

Loadout Elevator and Product Loadout Conveyor - Emission Source ID 

370-148-463, 375-117-463,375-118-463, 375-103-462, 375-132-472 and 

375-120-463 (Emission Point ID No. 718)

Product Shipping Emission Source ID 375-135-478 (Emission Point ID 754) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E = 4.10(P)0.67 calculated to three significant figures for 

process weight rates less than or equal to 60,000 pounds 

per hour. For process weight rates greater than 60,000 

pounds per hour, the allowable emission rates for 

particulate matter shall not exceed the level calculated 

with the equation E = 55.0(P)0.11- 40 calculated to three 

significant figures. 

NCAC 2D .0515 

Visible 

Emissions 

20 percent opacity NCAC 2D .0521 

PM/PM10 See Section 2.2 -Multiple Source NCAC 2D .530 

2.1.7.B.1 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS 

INDUSTRIAL PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equations: [15A NCAC 2D .0515(a)] 

 E = 4.10(P)0.67 calculated to three significant figures for process weight rates less than or 

equal to 60,000 pounds per hour. For process weight rates greater than 60,000 pounds per 

hour, the allowable emission rates for particulate matter shall not exceed the level calculated 

with the equation E = 55.0(P)0.11- 40 calculated to three significant figures.

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 c. Particulate matter emissions from these sources shall be controlled by bagfilters. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 670 

 December 17, 2007
Permit 04176T3? DRAFT 

Page 122 

manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or 

if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

bagfilter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the 

ductwork and bagfilters are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the bagfilters; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are 

not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the bagfilter within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.7.B. 2. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The results of these observations shall be recorded in a 

logbook (written or electronic form). The Permittee shall establish “normal” for the source in the 

first 30 days following the effective date of the permit. If visible emissions from this source are 

observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

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Section 2.1.5.C.2. a. above. If the demonstration in (b) above cannot be made during the month, 

the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521. 

 Reporting [15A NCAC 2Q .0508(f)]

 d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.8 Shipping and Miscellaneous Operations

2.1.8.A Rail Car Operations 

 Ammonia Railroad Unloading - Emission Point ID Nos. 601, 602, and 603 

Ammonia Storage Tanks - Emission Point ID Nos. 604 and 605 

Sulfur Railroad Unloading - Emission Point ID Nos. 610, 611, 612, 613, and 

614 

Railcar Wash Station No. 1 - Emission Point ID No. 615 

Tank Farm Fugitives - Emission Point ID No. 616 

Railcar Wash Station No. 2 - Emission Point ID No. 617 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

Toxic Air 

Pollutants 

See Section 2.2 -Multiple Source NCAC 2D .1100 

2.1.8.B Rock Tower Barge Loadout - Emission Point ID No. 650, 651, 652, and 653 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM/PM10 E= 55.0 x P0.11 -40 where E = allowable emission rate 

in pounds per hour and P = rock throughput in tons per 

hour 

NCAC 2D .0515 

Visible 

Emissions 

20 percent opacity NCAC 2D .0521 

PM10 See 2.3 NCAC 2D .0543 (BART) 

2.1.8.B.1 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 

PROCESSES

 Emission Standard

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

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 E= 55.0 x P0.11 -40 Where E = allowable emission rate in pounds per hour 

 P = process weight in tons per hour

 Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

 

 Testing [15A NCAC 2D .0501 (c)(3)] 

 b. If emissions testing is required, the testing shall be performed in accordance with General 

Condition JJ. If the results of this test are above the limit given above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

Requirements c, d, e, and f only apply when the Rock Tower Barge Loadout has been used within 

the last month. Notification to DAQ is required 30 days prior to startup of this equipment. 

 c. Particulate matter emissions from these sources shall be controlled by enclosures. To assure 

compliance, the Permittee shall perform inspections and maintenance as recommended by the 

manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or 

if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the 

inspection and maintenance requirement shall include the following: 

 i. a monthly visual inspection of the system enclosures unit for leaks; and 

ii. an annual (for each 12 month period following the initial inspection) internal inspection of the 

enclosure's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the enclosure is 

not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic 

format) on-site and made available to an authorized representative upon request. The logbook 

shall record the following: 

i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the enclosures; and 

iv. any variance from manufacturer’s recommendations, if any, and corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records 

are not maintained.

Reporting [15A NCAC 2Q .0508(f)]

 e. The Permittee shall submit the results of any maintenance performed on the enclosures within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

 Emission Standard

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged 

over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

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more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2Q .0501 (c)(4)]

b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.1.7.B. 2. a., 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

Requirements c and d only apply when the Rock Tower Barge Loadout has been used within the 

last month. Notification to DAQ is required 30 days prior to startup of this equipment. 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source 

for any visible emissions above normal. The results of these observations shall be recorded in a 

logbook (written or electronic form). The Permittee shall establish “normal” for the source in the 

first 30 days following the effective date of the permit. If visible emissions from this source are 

observed to be above normal, the Permittee shall either: (a) be deemed to be in noncompliance 

with 15A NCAC 2D .0521 or (b) demonstrate that the percent opacity from the emission points of 

the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the limit given in 

Section 2.1.8.B.2. a. above. If the demonstration in (b) above cannot be made during the month, 

the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521. 

 Reporting [15A NCAC 2Q .0508(f)]

 d. The Permittee shall submit a summary report of monitoring and recordkeeping activities 

postmarked on or before January 30 of each calendar year for the preceding six-month period 

between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must 

be clearly identified. 

2.1.8.C Mine Pit Diesel Generator - Emission Point ID Nos. 801

 Calciner Building Diesel Generator - Emission Point ID Nos. 802 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516 

visible 

emissions 

20 percent opacity (except during startup, shutdowns, and 

malfunctions approved as such according to procedures 

approved under 15A NCAC 2D .0535) when averaged 

over a six-minute period except that six-minute periods 

averaging not more than 87 percent opacity may occur not 

more than once in any hour nor more than four times in 

any 24-hour period 

15A NCAC 2D .0521 

NOx 39.3 tons per year 15A NCAC 2Q.0317(a)(1) 

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1. 15A NCAC 2D .0516: “SULFUR DIOXIDE EMISSIONS FROM COMBUSTION 

SOURCES” 

 a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat 

input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other 

substances shall be included when determining compliance with this standard. [15A NCAC 2D 

.0516] 

b. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of 

No. 2 fuel oil in this source. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from this source shall not be more than 20 percent opacity (except during 

startup, shutdowns, and malfunctions approved as such according to procedures approved under 

15A NCAC 2D .0535) when averaged over a six-minute period. However, six-minute averaging 

periods may exceed 20 percent not more than once in any hour and not more than four times in 

any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [15A 

NCAC 2D .0521 (d)] 

 Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(8). 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a day, when the generators are operating, the Permittee shall observe 

the emission points of this source for any visible emissions above normal. The daily observation 

must be made for each day of the calendar year period to ensure compliance with this requirement. 

No record is required for days the unit does not operate. The Permittee shall establish “normal” 

for the source in the first 30 days that the source operates following the effective date of the 

permit. If visible emissions from this source are observed to be above normal, the Permittee shall 

either: (a) immediately shutdown the source and repair the malfunction, (b) be deemed to be in 

noncompliance with 15A NCAC 2D .0521 or (c) demonstrate that the percent opacity from the 

emission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8) for 30 

minutes is below the limit given in Section 2.1.8.C.2.a above.

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the 

following: 

 i. the date and time of each recorded action; 

 ii. the results of each observation and/or test noting those sources with emissions that were 

observed to be in noncompliance along with any corrective actions taken to reduce visible 

emissions; and 

 iii. the results of any corrective actions performed. 

 Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the observations by January 30 of each calendar 

year for the preceding six-month period between July and December and July 30 of each calendar 

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year for the preceding six-month period between January and June. All instances of deviations 

from the requirements of this permit must be clearly identified. 

3. 15A NCAC 2Q.0317(a)(1): AVOIDANCE OF PREVENTION OF SIGNIFICANT 

DETERIORATION 

a. In order to avoid applicability of 15A NCAC 2D .0530(g), the generators (Emission Point ID Nos. 

801 and 802) shall each discharge into the atmosphere less than 40 tons of nitrogen oxides per 

consecutive 12-month period.. [15A NCAC 2Q .0317(a)(1)] 

b. To ensure compliance with the emission limit above total fuel usage in each generator shall be 

limited to 223,000 gallons of diesel fuel per consecutive 12 month period. 

 Testing [15A NCAC 2D .0501(c)(4) ] 

 c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D 

.0501(c)(4) and General Condition JJ found in Section 3. If the results of this test are above the 

limit given in Section 2.1.8.C.3.a. above, the Permittee shall be deemed in noncompliance with 

15A NCAC Q .0317. 

 Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)] 

 d. The Permittee shall maintain fuel usage log (written or electronic form) which demonstrates that 

actual annual (12-month) consumption of diesel fuel from the above sources are each less than 

223,000 gallons. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if 

the fuel usage exceeds the above limit. The log must be made available to an authorized 

representative upon request. 

Reporting Requirements [15A NCAC 2Q .0508 (f)] 

e. The Permittee shall submit a summary report of monitoring and recordkeeping activities within 30 

days after each calendar year quarter, due and post marked on or before January 30 of each 

calendar year for the preceding three-month period between October and December, April 30 of 

each calendar year for the preceding three-month period between January and March, July 30 of 

each calendar year for the preceding three-month period between April and June, and October 30 

for the calendar year for the preceding three-month period between July and September. The 

report shall contain the monthly fuel use for the previous 14 months. All instances of deviations 

from the requirements of this permit must be clearly identified. 

2.2- Multiple Emission Source(s) Specific Limitations and Conditions

A. Facility wide 

The following table provides a summary of limits and standards for the emission source(s) describe above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

sulfur 

dioxide 

see tables below 15A NCAC 2D .0501(e) 

VOC Work practices 15A NCAC 2D .0958 

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TAPS Specific limits listed in Attachment 2 15A NCAC 2D .1100 

1. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

a. Operation of all equipment at the facility shall be limited as follows: [15A NCAC 2D .0501(e)] 

i. With the exception of the equipment listed below, all equipment can run at full capacity 

ii. Scenario 1: the equipment shall operate as described in the following table. 

two boilers (ID Nos. 

110new and 111) 

Sulfuric Acid (SA) 

Plant No. 3 (ID No. 

101) 

SA Plant No. 4 (ID 

No. 102) 

SA Plant No. 5 (ID 

No. 103) 

SA Plant No. 6 (ID 

No. 104) 

shut down 7600 pounds per day 

of sulfur dioxide 

emissions 

7032 pounds per day 

of sulfur dioxide 

emissions 

12920 pounds per 

day of sulfur 

dioxide emissions 

13680 pounds per 

day of sulfur dioxide 

emissions 

iii. Scenario 2: the equipment shall operate as described in the following table with the 

additional restriction that one of the sulfuric plants must be shutdown. 

two boilers (ID Nos. 

110new and 111) 

Sulfuric Acid (SA) 

Plant No. 3 (ID No. 

101) 

SA Plant No. 4 (ID 

No. 102) 

SA Plant No. 5 (ID 

No. 103) 

SA Plant No. 6 (ID 

No. 104) 

full capacity 7600 pounds per day 

of sulfur dioxide 

emissions 

7032 pounds per day 

of sulfur dioxide 

emissions 

13680 pounds per 

day of sulfur 

dioxide emissions 

14440 pounds per 

day of sulfur dioxide 

emissions 

Testing [15A NCAC 2Q .0501 (c)(4)]

 b. If emissions testing is required, the Permittee shall perform such testing in accordance with 

General Condition JJ. If the results of this test are above the limit given in Section 2.2.A. 1. a., the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e). 

 

 Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508 (f)]

c. The monitoring, recordkeeping, and reporting requirements contained 2.1.1.A.1.c and d will be 

sufficient to demonstrate compliance with this requirement. 

2. 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC 

COMPOUNDS

a. Pursuant to 15A NCAC 2D .0958, for all sources that use volatile organic compounds (VOC) 

as solvents, carriers, material processing media, or industrial chemical reactants, or in 

similar uses that mix, blend, or manufacture volatile organic compounds, or emit volatile 

organic compounds as a product of chemical reactions, and whose emissions of VOC are 

greater than 15 pounds per day; the Permittee shall: 

(1) store all material, including waste material, containing volatile organic compounds in tanks or 

in containers covered with a tightly fitting lid that is free of cracks, holes, or other defects, 

when not in use, 

(2) clean up spills of volatile organic compounds as soon as possible following proper safety 

procedures, 

(3) store wipe rags containing volatile organic compounds in closed containers, 

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(4) not clean sponges, fabric, wood, paper products, and other absorbent materials with volatile 

organic compounds, 

(5) transfer solvents containing volatile organic compounds used to clean supply lines and other 

coating equipment into closable containers and close such containers immediately after each 

use, or transfer such solvents to closed tanks, or to a treatment facility regulated under section 

402 of the Clean Water Act, 

(6) clean mixing, blending, and manufacturing vats and containers containing volatile organic 

compounds by adding cleaning solvent and close the vat or container before agitating the 

cleaning solvent. The spent cleaning solvent shall then be transferred into a closed container, 

a closed tank or a treatment facility regulated under section 402 of the Clean Water Act. [15A 

NCAC 2D .0958(c)] 

b. When cleaning parts with a solvent containing a volatile organic compound, the Permittee shall: 

(1) flush parts in the freeboard area, 

(2) take precautions to reduce the pooling of solvent on and in the parts, 

(3) tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all 

dripping has stopped, whichever is longer, 

(4) not fill cleaning machines above the fill line, 

(5) not agitate solvent to the point of causing splashing. [15A NCAC 2D .0958(d)] 

 Monitoring

c. To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum, 

perform a visual inspection once per month of all operations and processes utilizing volatile 

organic compounds. No inspection is required in any area that has not utilized volatile organic 

compounds during the previous month. The inspections shall be conducted during normal 

operations. If the required inspections are not conducted the permittee shall be deemed to be in 

noncompliance with 15A NCAC 2D .0958. 

Recordkeeping

d. The results of the inspections shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the 

following: 

 i. the date and time of each inspection; and 

 ii. the results of each inspection noting whether or not noncompliant conditions were 

observed. 

 If the required records are not maintained the permittee shall be deemed to be in noncompliance 

with 15A NCAC 2D .0958. 

 Reporting

e. The Permittee shall submit a summary report of the observations by January 30 of each calendar 

year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations 

from the requirements of this permit must be clearly identified. 

STATE-ONLY REQUIREMENT: 

2. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REQUIREMENT 

a. Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic 

compliance demonstration, the permit limits found in Attachment 2 shall not be exceeded. 

b. To ensure compliance with the limits in Attachment 2, the following restrictions shall apply: 

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 i. The Permittee shall maintain records of production rates, material feed rates and other 

process operational information as is necessary to determine compliance with the process 

operating limitations cited for each affected source in Section 2.1 of this permit and the 

corresponding toxic pollutant emission limits contained in Attachment 2. 

ii. For each process source affected by 15A NCAA 2D .1100, as specifically provided in 

Section 2.1 of this permit, for which emissions are abated by control devices or enclosures, an 

inspection, maintenance and monitoring program shall be provided to ensure that maximum 

control efficiency is maintained. The Permittee shall maintain a written, comprehensive 

program on site which details the scheduled maintenance and monitoring activities for each 

control device as recommended by the equipment manufacturer. The defined activities will be 

performed on a set schedule (weekly, monthly, quarterly, annually) with a method of tracking 

and recording the completion of each activity. Both the monitoring and maintenance activities 

will be specific. The monitoring activities will be quantifiable and will be compared against 

design parameters with dated actions noted to correct out of specification operations. A 

centralized recording keeping system shall be utilized to define the activities and record 

actions as a demonstration of compliance. 

iii. The air toxic model submitted as part of your most recent application is considered part of the 

binding limits and conditions of this permit. Your application specified certain parameters for 

modeling compliance with 15A NCAC 2D .1100 "Control of Toxic Air Pollutants." A new 

permit is required prior to changing any of these parameters. 

Changes in equipment of operations that affect stack exhaust temperature or the stack gas exit 

velocity, or changes in facilities such as location of new buildings or structures in close 

proximity to the modeled stack, that could significantly increase the modeled emissions, 

would require an amended permit application. 

c. For compliance purposes, within 30 days after each calendar year quarter the following shall be 

reported to the Regional Supervisor, DAQ: 

 i. A verification that all actual measured production and material feed rates cited in NCAC 2D 

.1100 stipulations throughout this permit were all within the permit limitations over the past 

quarter. If exceedences occur, identify source, limitation, date, and corrective actions taken to 

bring into compliance. 

ii. A verification that all scheduled maintenance and monitoring activities required in NCAC 2D 

.1100 stipulations throughout this permit were completed as scheduled. 

B. DFP Area, Pug Mill, Kiln, and Materials Handling Sources (Section 2.1.7.B) 

The following table provides a summary of limits and standards for the emission source(s) describe above: 

Regulated 

Pollutant

Limits/Standards Applicable Regulation

PM-10 727.2 pounds per 24 hours 

137.2 tons per year 

2D .0501(e) 

1. 15A NCAC 2D. 0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY 

STANDARDS 

a. Operation the equipment listed above shall be limited as follows: [15A NCAC 2D .0501(e)]

i. emissions of PM-10 from all of the sources considered together shall not exceed 727.2 

pounds per 24 hours (midnight to midnight). 

ii. emissions of PM-10 from all of the sources considered together shall not exceed 

137.2 tons per year. 

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2.3- Multiple Emission Source(s) Specific Limitations and Conditions

 STATE-ONLY REQUIREMENT:

2.3.1 15A NCAC 2D .0543Best Available Retrofit Technology 

Based on the review of Permit Application 0700071.06D, and with the consideration of comments received 

from interested parties, the DAQ has determined that Best Available Retrofit Technology (BART) for the 

following emission sources subject to the requirements contained in 15A NCAC 2D .0543 “Best Available 

Retrofit Technology” is no additional controls.

Emission Source Description Emission 

Point ID No. 

S-3 

Double-absorption sulfuric acid plant No. 3 (2000 tons per 

day nominal capacity) 101 

S-4 Double-absorption sulfuric acid plant No. 4 (1850 tons per 

day nominal capacity) 102 

417-503-462 Lime silo No. 4 at water treatment area 121 

339-051 One coal/coke/”off-spec” used oils, used oil sludge/used 

glycols/ residual oil-fired vertical fluidized bed, phosphate 

rock calciner unit No. 1 (105.1 tons per hour nominal 

feed capacity) 

201 

339-052 One coal/coke/”off-spec” used oils, used oil sludge/used 

glycols/ residual oil-fired vertical fluidized bed, phosphate 

rock calciner unit No. 2 (105.1 tons per hour nominal 

feed capacity) 

202 

339-053 One coal/coke / residual oil-fired vertical fluidized bed, 

phosphate rock calciner unit No. 3 (105.1 tons per hour 

nominal feed capacity) 

203 

339-054 One coal/coke / residual oil-fired vertical fluidized bed, 

phosphate rock calciner unit No. 4 (105.1 tons per hour 

nominal feed capacity) 

204 

339-055 One coal/coke / residual oil-fired vertical fluidized bed, 

phosphate rock calciner unit No. 5 (105.1 tons per hour 

nominal feed capacity) 

205 

339-056 One coal/coke / residual oil-fired vertical fluidized bed, 

phosphate rock calciner unit No. 6 (105.1 tons per hour 

nominal feed capacity)

206 

332-120 Residual oil-fired phosphate rock dryer (250 tons per hour 

nominal capacity) 210 

Belt 39 to 70.1 Calcined rock CTS 220 

Belt 55 to Belt 

70.1 

Calcined rock CTS Baghouse 221 

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Emission Source Description Emission 

Point ID No. 

Belt 21 to Belt 23 

or Belt 24 

Storage silo baghouse 222 

Belt 22 to Belt 23 

or Belt 24 

Storage silo baghouse 222 

339-809-464 Calcined/dried rock CTS 223 

F291 Calciner Plant Area Fugitives 291 

511-085 511-

086 511-070

Diammonium Phosphate Plant No. 3 

first stage reactor 

second stage reactor granulator

302 

511-032 Diammonium Phosphate Plant No. 3 residual oil-fired 

dryer

302 

511-008 511-

009 511-010 

511-011 511-

016 511-017 

511-038 511-

039 511-041 

511-093 511-

094 511-095 

511-096

Diammonium Phosphate Plant No. 3 process sizing and 

handling equipment (four (4) chain mills, screen feed 

drag conveyor, recycle drag conveyor, recycle elevator, 

dryer elevator, product elevator, and four (4) doubledeck product screens) 302 

511-025 Diammonium Phosphate Plant No. 3 cooler and other 

miscellaneous material handling points

302 

451-418 and 

451-409

Superphosphoric acid plant No. 1 330 

451-701 and 

451-809

Superphosphoric acid plant No. 2 331 

451-316 and 

451-308

Superphosphoric acid plant No. 3 332 

451-916 and 

451-940

Superphosphoric acid plant No. 4 332 

421-201 Reactor Train No. 1 401 

421-000 tilting pan (Bird) filter No. 1 401 

421-325 tilting pan (Bird) filter No. 1 primary vacuum pump 

installed on primary vacuum separator 

421-327 secondary vacuum pump installed on secondary 

vacuum separator 

401 

421-223 421-

232 

(2) barometric condensers vacuum pumps; 401 

421-218 barometric condensers hotwell 401 

421-330 tilting pan (Bird) filter No. 1 seal tanks. 401 

422-201 Reactor Train No. 2 404 

422-000 tilting pan (Bird) filter No. 2 404 

422-325 tilting pan (Bird) filter No. 2 primary vacuum pump 

installed on primary vacuum separator 

404 

422-327 secondary vacuum pump installed on secondary 404 

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Emission Source Description Emission 

Point ID No. 

vacuum separator 

422-223 422-

232 

(2) barometric condensers vacuum pumps 404 

422-218 barometric condensers hotwell 404 

422-330 tilting pan (Bird) filter No. 2 seal tanks 404 

423-201 Reactor Train No. 3 406 

423-000 tilting pan (Bird) filter No. 3; 406 

423-325 tilting pan (Bird) filter No. 3 primary vacuum pump 

installed on primary vacuum separator;

406 

423-327 secondary vacuum pump installed on secondary 

vacuum separator

406 

423-223 423-

232 

(2) barometric condensers vacuum pumps 406 

423-218 barometric condensers hotwell 406 

423-330 tilting pan (Bird) filter No. 3 seal tanks. 406 

424-201 Reactor Train No. 4 

409 

424-000 tilting pan (Bird) filter No. 4; 409 

424-325 tilting pan (Bird) filter No. 4 primary vacuum pump 

installed on primary vacuum separator 409 

424-327 secondary vacuum pump installed on secondary 

vacuum separator 

409 

424-223 424-

232 

(2) barometric condensers vacuum 409 

424-218 barometric condensers hotwell 409 

424-330 tilting pan (Bird) filter No. 4 seal tanks. 409 

F650 CTS - Grinder Rock Loadout 650 

F651 CTS - Grinder Rock Loadout 651 

F652 Rock Loadout Transfer Station 652 

F653 CTS - Phosphate Rock Transfer Station 653 

F654 Rock Tower Loadout facility 654 

F655 Chute-Barge Rock Loadout 655 

F656 Chute-Train Rock Loadout 656 

 

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SECTION 3 - GENERAL CONDITIONS

This section describes terms and conditions applicable to this Title V facility. All references to the “permit” in 

this section apply only to Part I of the permit. 

A. General Provisions [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)] 

1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined 

in 15A NCAC 2D and 2Q. 

2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding 

and enforceable pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil 

and/or criminal penalties. Any unauthorized deviation from the conditions of this permit may 

constitute grounds for revocation and/or enforcement action by the DAQ. 

3. This permit is not a waiver of or approval of any other Department permits that may be required for 

other aspects of the facility which are not addressed in this permit. 

4. This permit does not relieve the Permittee from liability for harm or injury to human health or 

welfare, animal or plant life, or property caused by the construction or operation of this permitted 

facility, or from penalties therefore, nor does it allow the Permittee to cause pollution in 

contravention of state laws or rules, unless specifically authorized by an order from the North 

Carolina Environmental Management Commission. 

5. Except as identified as state-only requirements in this permit, all terms and conditions contained 

herein shall be enforceable by the DAQ, the EPA, and citizens of the United States as defined in the 

Federal Clean Air Act. 

6. Any stationary source of air pollution shall not be operated, maintained, or modified without the 

appropriate and valid permits issued by the DAQ, unless the source is exempted by rule. The DAQ 

may issue a permit only after it receives reasonable assurance that the installation will not cause air 

pollution in violation of any of the applicable requirements. A permitted installation may only be 

operated, maintained, constructed, expanded, or modified in a manner that is consistent with the 

terms of this permit. 

B. Permit Availability [15A NCAC 2Q .0507(k) and .0508(i)(9)(B)] 

The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of 

the permit term one complete copy of the application and any information submitted in support of the 

application package. The permit and application shall be made available to an authorized representative 

of Department of Environment and Natural Resources upon request. 

C. Severability Clause [15A NCAC 2Q .0508(i)(2)] 

In the event of an administrative challenge to a final and binding permit in which a condition is held to be 

invalid, the provisions in this permit are severable so that all requirements contained in the permit, except 

those held to be invalid, shall remain valid and must be complied with. 

D. Submissions [15A NCAC 2Q .0507(e) and 2Q .0508(i)(16)] 

Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, 

notifications, request for renewal, and any other information required by this permit shall be submitted to 

the appropriate Regional Office. Refer to the Regional Office address on the cover page of this permit. 

For continuous emissions monitoring systems (CEMS) reports, continuous opacity monitoring systems 

(COMS) reports, quality assurance (QA)/quality control (QC) reports, acid rain CEM certification 

reports, and NOx budget CEM certification reports, one copy shall be sent to the appropriate Regional 

Office and one copy shall be sent to: 

Supervisor, Stationary Source Compliance 

North Carolina Division of Air Quality 

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1641 Mail Service Center 

Raleigh, NC 27699-1641 

E. Duty to Comply [15A NCAC 2Q .0508(i)(2)] 

The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth 

in this permit. Noncompliance with any permit condition except conditions identified as state-only 

requirements constitutes a violation of the Federal Clean Air Act. Noncompliance with any permit 

condition is grounds for enforcement action, for permit termination, revocation and reissuance, or 

modification, or for denial of a permit renewal application. 

F. Circumvention - STATE ENFORCEABLE ONLY 

The facility shall be properly operated and maintained at all times in a manner that will effect an overall 

reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated 

without the concurrent operation of its associated air pollution control device(s) and appurtenances. 

G. Permit Modifications

1. Administrative Permit Amendments [15A NCAC 2Q .0514] 

The Permittee shall submit an application for an administrative permit amendment in accordance 

with 15A NCAC 2Q .0514. 

2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 

2Q .0505] 

The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 

2Q.0524 and 2Q .0505. 

3. Minor Permit Modifications [15A NCAC 2Q .0515] 

The Permittee shall submit an application for a minor permit modification in accordance with 15A 

NCAC 2Q .0515. 

4. Significant Permit Modifications [15A NCAC 2Q .0516] 

The Permittee shall submit an application for a significant permit modification in accordance with 

15A NCAC 2Q .0516. 

5. Reopening for Cause [15A NCAC 2Q .0517] 

The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q 

.0517. 

H. Changes Not Requiring Permit Modifications

1. Section 502(b)(10) Changes [15A NCAC 2Q .0523(a)] 

a. "Section 502(b)(10) changes" means changes that contravene an express permit term or 

condition. Such changes do not include changes that would violate applicable requirements or 

contravene federally enforceable permit terms and conditions that are monitoring (including test 

methods), recordkeeping, reporting, or compliance certification requirements. 

b. The Permittee may make Section 502(b)(10) changes without having the permit revised if: 

i. the changes are not a modification under Title I of the Federal Clean Air Act; 

ii. the changes do not cause the allowable emissions under the permit to be exceeded; 

iii. the Permittee notifies the Director and EPA with written notification at least seven days 

before the change is made; and 

iv. the Permittee shall attach the notice to the relevant permit. 

c. The written notification shall include: 

i. a description of the change; 

ii. the date on which the change will occur; 

iii. any change in emissions; and 

iv. any permit term or condition that is no longer applicable as a result of the change. 

d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised 

or renewed, whichever comes first. 

2. Off Permit Changes [15A NCAC 2Q .0523(b)] 

The Permittee may make changes in the operation or emissions without revising the permit if: 

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a. the change affects only insignificant activities and the activities remain insignificant after the 

change; or 

b. the change is not covered under any applicable requirement. 

3. Emissions Trading [15A NCAC 2Q .0523(c)] 

To the extent that emissions trading is allowed under 15A NCAC 2D, including subsequently 

adopted maximum achievable control technology standards, emissions trading shall be allowed 

without permit revision pursuant to 15A NCAC 2Q .0523(c). 

I.A. Reporting Requirements for Excess Emissions and Permit Deviations

[15A NCAC 2D .0535(f) and 2Q .0508(f)(2)] 

“Excess Emissions” - means an emission rate that exceeds any applicable emission limitation or standard 

allowed by any rule in Sections .0500, .0900, .1200, or .1400 of Subchapter 2D; or by a permit condition; 

or that exceeds an emission limit established in a permit issued under 15A NCAC 2Q .0700. (Note: 

Definitions of excess emissions under 2D .1110 and 2D .1111 shall apply where defined by rule.) 

“Deviations” - for the purposes of this condition, any action or condition not in accordance with the terms 

and conditions of this permit including those attributable to upset conditions as well as excess emissions 

as defined above lasting less than four hours. 

Excess Emissions

1. If a source is required to report excess emissions under NSPS (15A NCAC 2D .0524), NESHAPS 

(15A NCAC 2D .1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) 

reporting of excess emissions, reporting shall be performed as prescribed therein. 

2. If the source is not subject to NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D .1110 or 

.1111), or these rules do NOT define "excess emissions," the Permittee shall report excess emissions 

in accordance with 15A NCAC 2D .0535 as follows: 

a. Pursuant to 15A NCAC 2D .0535, if excess emissions last for more than four hours resulting 

from a malfunction, a breakdown of process or control equipment, or any other abnormal 

condition, the owner or operator shall: 

i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m. Eastern 

Time of the Division's next business day of becoming aware of the occurrence and provide: 

● name and location of the facility; 

● nature and cause of the malfunction or breakdown; 

● time when the malfunction or breakdown is first observed; 

● expected duration; and 

● estimated rate of emissions; 

ii. notify the Regional Supervisor or Director immediately when corrective measures have 

been accomplished; and 

iii. submit to the Regional Supervisor or Director within 15 days a written report as described 

in 15A NCAC 2D .0535(f)(3). 

Permit Deviations

3. Pursuant to 15A NCAC 2Q .0508(f)(2), the Permittee shall report deviations from permit 

requirements (terms and conditions) as follows: 

a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not 

covered under 15A NCAC 2D .0535 quarterly. A written report to the Regional Supervisor 

shall include the probable cause of such deviation and any corrective actions or preventative 

actions taken. The responsible official shall certify all deviations from permit requirements. 

I.B. Other Requirements under 15A NCAC 2D .0535

The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D .0535, 

including 15A NCAC 2D .0535(c) as follows: 

1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation 

of the appropriate rule unless the owner or operator of the sources demonstrates to the Director, that 

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the excess emissions are a result of a malfunction. The Director shall consider, along with any other 

pertinent information, the criteria contained in 15A NCAC 2D .0535(c)(1) through (7). 

2. 15A NCAC 2D .0535(g). Excess emissions during start-up and shut-down shall be considered a 

violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions 

are unavoidable. 

J. Emergency Provisions [40 CFR 70.6(g)] 

The Permittee shall be subject to the following provisions with respect to emergencies: 

1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond 

the control of the facility, including acts of God, which situation requires immediate corrective action 

to restore normal operation, and that causes the facility to exceed a technology-based emission 

limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. 

An emergency shall not include noncompliance to the extent caused by improperly designed 

equipment, lack of preventive maintenance, careless or improper operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such 

technology-based emission limitations if the conditions specified in 3. below are met. 

3. The affirmative defense of emergency shall be demonstrated through properly signed 

contemporaneous operating logs or other relevant evidence that include information as follows: 

a. an emergency occurred and the Permittee can identify the cause(s) of the emergency; 

b. the permitted facility was at the time being properly operated; 

c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of 

emissions that exceeded the standards or other requirements in the permit; and 

d. the Permittee submitted notice of the emergency to the DAQ within two working days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain 

a description of the emergency, steps taken to mitigate emissions, and corrective actions taken. 

4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency 

has the burden of proof. 

5. This provision is in addition to any emergency or upset provision contained in any applicable 

requirement specified elsewhere herein. 

K. Permit Renewal [15A NCAC 2Q .0508(e) and 2Q .0513(b)] 

This permit is issued for a fixed term of five years for facilities subject to Title IV requirements and for a 

term not to exceed five years in the case of all other facilities. This permit shall expire at the end of its 

term. Permit expiration terminates the facility's right to operate unless a complete renewal application is 

submitted at least nine months before the date of permit expiration. If the Permittee or applicant has 

complied with 15A NCAC 2Q .0512(b)(1), this permit shall not expire until the renewal permit has been 

issued or denied. All terms and conditions of this permit shall remain in effect until the renewal permit 

has been issued or denied. 

L. Need to Halt or Reduce Activity Not a Defense [15A NCAC 2Q .0508(i)(4)] 

It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt 

or reduce the permitted activity in order to maintain compliance with the conditions of this permit. 

M. Duty to Provide Information (submittal of information) [15A NCAC 2Q .0508(i)(9)] 

1. The Permittee shall furnish to the DAQ, in a timely manner, any reasonable information that the 

Director may request in writing to determine whether cause exists for modifying, revoking and 

reissuing, or terminating the permit or to determine compliance with the permit. 

2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such 

copies are requested by the Director. For information claimed to be confidential, the Permittee may 

furnish such records directly to the EPA upon request along with a claim of confidentiality. 

N. Duty to Supplement [15A NCAC 2Q .0507(f)] 

The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was 

submitted in the permit application, shall promptly submit such supplementary facts or corrected 

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information to the DAQ. The Permittee shall also provide additional information as necessary to address 

any requirement that becomes applicable to the facility after the date a complete permit application was 

submitted but prior to the release of the draft permit. 

O. Retention of Records [15A NCAC 2Q .0508(i)(16) and 2Q .0517(f)] 

The Permittee shall retain records of all required monitoring data and supporting information for a period 

of at least five years from the date of the monitoring sample, measurement, report, or application. 

Supporting information includes all calibration and maintenance records and all original strip-chart 

recordings for continuous monitoring information, and copies of all reports required by the permit. These 

records shall be maintained in a form suitable and readily available for expeditious inspection and review. 

Any records required by the conditions of this permit shall be kept on site and made available to DAQ 

personnel for inspection upon request. 

P. Compliance Certification [15A NCAC 2Q .0508(n)] 

The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, 

Region 4, 61 Forsyth Street, Atlanta, GA 30303) postmarked on or before March 1 a compliance 

certification (for the preceding calendar year) by a responsible official with all federally-enforceable 

terms and conditions in the permit, including emissions limitations, standards, or work practices. It shall 

be the responsibility of the current owner to submit a compliance certification for the entire year 

regardless of who owned the facility during the year. The compliance certification 

shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the 

Federal Clean Air Act. The compliance certification shall specify: 

1. the identification of each term or condition of the permit that is the basis of the certification; 

2. the compliance status (with the terms and conditions of the permit for the period covered by the 

certification); 

3. whether compliance was continuous or intermittent; and 

4. the method(s) used for determining the compliance status of the source during the certification 

period. 

Q. Certification by Responsible Official [15A NCAC 2Q .0520] 

A responsible official shall certify the truth, accuracy, and completeness of any application form, report, 

or compliance certification required by this permit. All certifications shall state that based on information 

and belief formed after reasonable inquiry, the statements and information in the document are true, 

accurate, and complete. 

R. Permit Shield for Applicable Requirements [15A NCAC 2Q .0512] 

1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable 

requirements, where such applicable requirements are included and specifically identified in the 

permit as of the date of permit issuance. 

2. A permit shield shall not alter or affect: 

a. the power of the Commission, Secretary of the Department, or Governor under NCGS 143-

215.3(a)(12), or EPA under Section 303 of the Federal Clean Air Act; 

b. the liability of an owner or operator of a facility for any violation of applicable requirements 

prior to the effective date of the permit or at the time of permit issuance; 

c. the applicable requirements under Title IV; or 

d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain 

information to determine compliance of the facility with its permit. 

3. A permit shield does not apply to any change made at a facility that does not require a permit or 

permit revision made under 15A NCAC 2Q .0523. 

4. A permit shield does not extend to minor permit modifications made under 15A NCAC 2Q .0515. 

S. Termination, Modification, and Revocation of the Permit [15A NCAC 2Q .0519] 

The Director may terminate, modify, or revoke and reissue this permit if: 

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1. the information contained in the application or presented in support thereof is determined to be 

incorrect; 

2. the conditions under which the permit or permit renewal was granted have changed; 

3. violations of conditions contained in the permit have occurred; 

4. the EPA requests that the permit be revoked under 40 CFR 70.7(g) or 70.8(d); or 

5. the Director finds that termination, modification, or revocation and reissuance of the permit is 

necessary to carry out the purpose of NCGS Chapter 143, Article 21B. 

T. Insignificant Activities [15A NCAC 2Q .0503] 

Because an emission source or activity is insignificant does not mean that the emission source or activity 

is exempted from any applicable requirement or that the owner or operator of the source is exempted 

from demonstrating compliance with any applicable requirement. The Permittee shall have available at 

the facility at all times and made available to an authorized representative upon request, documentation, 

including calculations, if necessary, to demonstrate that an emission source or activity is insignificant. 

U. Property Rights [15A NCAC 2Q .0508(i)(8)] 

This permit does not convey any property rights in either real or personal property or any exclusive 

privileges. 

V. Inspection and Entry [15A NCAC 2Q .0508(l) and NCGS 143-215.3(a)(2)] 

1. Upon presentation of credentials and other documents as may be required by law, the Permittee shall 

allow the DAQ, or an authorized representative, to perform the following: 

a. enter the Permittee's premises where the permitted facility is located or emissions-related 

activity is conducted, or where records are kept under the conditions of the permit; 

b. have access to and copy, at reasonable times, any records that are required to be kept under the 

conditions of the permit; 

c. inspect at reasonable times and using reasonable safety practices any source, equipment 

(including monitoring and air pollution control equipment), practices, or operations regulated or 

required under the permit; and 

d. sample or monitor substances or parameters, using reasonable safety practices, for the purpose 

of assuring compliance with the permit or applicable requirements at reasonable times. 

Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the 

Permittee under Section 114 or other provisions of the Federal Clean Air Act. 

2. No person shall refuse entry or access to any authorized representative of the DAQ who requests 

entry for purposes of inspection, and who presents appropriate credentials, nor shall any person 

obstruct, hamper, or interfere with any such authorized representative while in the process of 

carrying out his official duties. Refusal of entry or access may constitute grounds for permit 

revocation and assessment of civil penalties. 

W. Annual Fee Payment [15A NCAC 2Q .0508(i)(10)] 

1. The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200. 

2. Payment of fees may be by check or money order made payable to the N.C. Department of 

Environment and Natural Resources. Annual permit fee payments shall refer to the permit number. 

3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate 

action to terminate the permit under 15A NCAC 2Q .0519. 

X. Annual Emission Inventory Requirements [15A NCAC 2Q .0207] 

The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 

15A NCAC 2Q .0207(a) from each emission source within the facility during the previous calendar year. 

The report shall be in or on such form as may be established by the Director. The accuracy of the report 

shall be certified by a responsible official of the facility. 

Y. Confidential Information [15A NCAC 2Q .0107 and 2Q. 0508(i)(9)] 

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Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q 

.0107, the Permittee may also submit a copy of all such information and claim directly to the EPA upon 

request. All requests for confidentiality must be in accordance with 15A NCAC 2Q .0107. 

Z. Construction and Operation Permits [15A NCAC 2Q .0100 and .0300] 

A construction and operating permit shall be obtained by the Permittee for any proposed new or modified 

facility or emission source which is not exempted from having a permit prior to the beginning of 

construction or modification, in accordance with all applicable provisions of 15A NCAC 2Q .0100 and 

.0300. 

AA. Standard Application Form and Required Information [15A NCAC 2Q .0505 and .0507] 

The Permittee shall submit applications and required information in accordance with the provisions of 

15A NCAC 2Q .0505 and .0507. 

BB. Financial Responsibility and Compliance History [15A NCAC 2Q .0507(d)(3)] 

The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of 

substantial compliance history. 

CC. Refrigerant Requirements (Stratospheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)] 

1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, 

which use Class I or II ozone-depleting substances such as chlorofluorocarbons and 

hydrochlorofluorocarbons listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B, 

the Permittee shall service, repair, and maintain such equipment according to the work practices, 

personnel certification requirements, and certified recycling and recovery equipment specified in 40 

CFR Part 82 Subpart F. 

2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the 

environment during the repair, servicing, maintenance, or disposal of any such device except as 

provided in 40 CFR Part 82 Subpart F. 

3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR  82.166. 

Reports shall be submitted to the EPA or its designee as required. 

DD. Prevention of Accidental Releases - Section 112(r) [15A NCAC 2Q .0508(h)] 

If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to 

Section 112(r) of the Clean Air Act, then the Permittee is required to register this plan in accordance with 

40 CFR Part 68. 

EE. Prevention of Accidental Releases General Duty Clause - Section 112(r)(1) - 

FEDERALLY-ENFORCEABLE ONLY 

Although a risk management plan may not be required, if the Permittee produces, processes, handles, or 

stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as 

are necessary to prevent the accidental release of such substance and to minimize the consequences of 

any release. 

FF. Title IV Allowances [15A NCAC 2Q .0508(i)(1)] 

This permit does not limit the number of Title IV allowances held by the Permittee, but the Permittee 

may not use allowances as a defense to noncompliance with any other applicable requirement. The 

Permittee’s emissions may not exceed any allowances that the facility lawfully holds under Title IV of 

the Federal Clean Air Act. 

GG. Air Pollution Emergency Episode [15A NCAC 2D .0300] 

Should the Director of the DAQ declare an Air Pollution Emergency Episode, the Permittee will be 

required to operate in accordance with the Permittee’s previously approved Emission Reduction Plan or, 

in the absence of an approved plan, with the appropriate requirements specified in 15A NCAC 2D .0300. 

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HH. Registration of Air Pollution Sources [15A NCAC 2D .0200] 

The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee 

is required to register a source of air pollution, this registration and required information will be in 

accordance with 15A NCAC 2D .0202(b). 

II. Ambient Air Quality Standards [15A NCAC 2D .0501(e)] 

In addition to any control or manner of operation necessary to meet emission standards specified in this 

permit, any source of air pollution shall be operated with such control or in such manner that the source 

shall not cause the ambient air quality standards in 15A NCAC 2D .0400 to be exceeded at any point 

beyond the premises on which the source is located. When controls more stringent than named in the 

applicable emission standards in this permit are required to prevent violation of the ambient air quality 

standards or are required to create an offset, the permit shall contain a condition requiring these controls. 

JJ. General Emissions Testing and Reporting Requirements [15A NCAC 2Q .0508(i)(16)] 

If emissions testing is required by this permit or the DAQ or if the Permittee submits emissions testing to 

the DAQ in support of a permit application, the Permittee shall perform such testing in accordance with 

the appropriate EPA reference method(s) as approved by the DAQ and follow the procedures outlined 

below. The Permittee must request in writing and receive approval from the DAQ for an alternate test 

method or procedure. 

1. The Permittee shall submit a completed Protocol Submittal Form to the DAQ Regional Supervisor at 

least 45 days prior to the scheduled test date. A copy of the Protocol Submittal Form may be 

obtained from the Regional Supervisor. 

2. The Permittee shall notify the Regional Supervisor of the specific test dates at least 15 days prior to 

testing in order to afford the DAQ the opportunity to have an observer on-site during the sampling 

program. 

3. During all sampling periods, the Permittee shall operate the emission source(s) under maximum 

normal operating conditions or alternative operating conditions as deemed appropriate by the 

Regional Supervisor or his delegate. 

4. The Permittee shall submit two copies of the test report to the DAQ. The test report shall contain at 

a minimum the following information: 

a. a certification of the test results by sampling team leader and facility representative; 

b. a summary of emissions results and text detailing the objectives of the testing program, the 

applicable state and federal regulations, and conclusions about the testing and compliance status 

of the emission source(s); 

c. a detailed description of the tested emission source(s) and sampling location(s) process flow 

diagrams, engineering drawings, and sampling location schematics should be included as 

necessary; 

d. all field, analytical, and calibration data necessary to verify that the testing was performed as 

specified in the applicable test methods; 

e. example calculations for at least one test run using equations in the applicable test methods and 

all test results including intermediate parameter calculations; and 

f. documentation of facility operating conditions during all testing periods and an explanation 

relating these operating conditions to maximum normal operation. If necessary, provide 

historical process data to verify maximum normal operation. 

5. The testing requirement(s) shall be considered satisfied only upon written approval of the test results 

by the DAQ. 

6. The DAQ will review emission test results with respect exclusively to the specified testing objectives 

as proposed by the Permittee and approved by the DAQ. The use of the test results beyond the stated 

objectives remains subject to the approval of the DAQ. 

KK. Reopening for Cause [15A NCAC 2Q .0517] 

1. A permit shall be reopened and revised under the following circumstances: 

a. additional applicable requirements become applicable to a facility with remaining permit term of 

three or more years; 

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b. additional requirements (including excess emission requirements) become applicable to a source 

covered by Title IV; 

c. the Director or EPA finds that the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or conditions of the 

permit; or 

d. the Director or EPA determines that the permit must be revised or revoked to assure compliance 

with the applicable requirements. 

2. Any permit reopening shall be completed or a revised permit issued within 18 months after the 

applicable requirement is promulgated. No reopening is required if the effective date of the 

requirement is after the expiration of the permit term unless the term of the permit was extended 

pursuant to 15A NCAC 2Q .0513(c). 

3. Except for the state-enforceable only portion of the permit, the procedures set out in 15A NCAC 2Q 

.0507, .0521, or .0522 shall be followed to reissue the permit. If the State-enforceable only portion 

of the permit is reopened, the procedures in 15A NCAC 2Q .0300 shall be followed. The 

proceedings shall affect only those parts of the permit for which cause to reopen exists. 

4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be 

reopened, except in cases of imminent threat to public health or safety the notification period may be 

less than 60 days. 

5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from 

the EPA that a permit needs to be terminated, modified, or revoked and reissued, the Director shall 

send to the EPA a proposed determination of termination, modification, or revocation and reissuance, 

as appropriate. 

LL. Reporting Requirements for Non-Operating Equipment [15A NCAC 2Q .0508(i)(16)] 

The Permittee shall maintain a record of operation for permitted equipment noting whenever the 

equipment is taken from and placed into operation. During operation the monitoring recordkeeping and 

reporting requirements as prescribed by the permit shall be implemented within the monitoring period.

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ATTACHMENT 

List of Acronyms 

AOS Alternate Operating Scenario

BACT Best Available Control Technology

Btu British thermal unit

CEM Continuous Emission Monitor

CFR Code of Federal Regulations 

CAA Clean Air Act

DAQ Division of Air Quality

DENR Department of Environment and Natural Resources 

EMC Environmental Management Commission

EPA Environmental Protection Agency

FR. Federal Register

GACT Generally Available Control Technology

HAP Hazardous Air Pollutant

MACT Maximum Achievable Control Technology

NCAC North Carolina Administrative Code

NCGS North Carolina General Statutes 

NESHAPS National Emission Standards for Hazardous Air Pollutants

NOX Nitrogen Oxides

NSPS New Source Performance Standard

OAH Office of Administrative Hearings 

PM Particulate Matter 

PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers 

or Less 

POS Primary Operating Scenario 

PSD Prevention of Significant Deterioration

SIC Standard Industrial Classification

SIP State Implementation Plan

SO2 Sulfur Dioxide

tpy Tons Per Year

VOC Volatile Organic Compound 

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PART II 

SECTION 1: PERMITTED EMISSION SOURCE(S) AND 

ASSOCIATED AIR POLLUTION CONTROL 

DEVICE(S) AND APPURTENANCES 

The following table contains a summary of all listed emission sources and associated air pollution control 

devices and appurtenances associated with Air Quality Permit Applications 07-00071.05A

{PRIVATE 

}Emissio

n Source 

ID No. 

Emission Source 

Description 

Control 

Device 

ID No. 

Control Device 

Description 

Emission 

Point ID No. 

T1524 

T1224 

T1546 

Two scrub acid storage tanks 

discharging through a vent pot 

S1324 

GC-2 

One packed bed scrubber 

One gas chiller system 

503 

C1210 

C1220 

Two extraction columns under 

nitrogen blanket system 

GC-2 One Gas chiller system 503 

T1201 

T1207 

T1213 

T1240 

T2057 

Five tanks under nitrogen 

blanket system 

GC-2 One Gas Chiller system 503 

T1244 One tank with seal pots under 

nitrogen blanket system 

GC-2 One Gas chiller system 503 

T1415 

T1515 

T1208 

T1258 

T1546 

T1215 

Six emergency vent pot GC-2 One Gas Chiller System 503 

S1243 

S1205 

Two separators under nitrogen 

blanket system 

GC-2 One Gas chiller system 503 

S1288 

T1270 

One acid defluorination 

column and acid concentrator 

S1292 One acid scrubber 506 

S1242 One stripper under nitrogen 

blanket system 

GC-2 One Gas chiller system 503 

S1204 One Still under nitrogen 

blanket system 

GC-2 One Gas Chiller system 503 

TBD PAP No. 2 Cooling Tower No. 

3 

None 518 and 519 

TBD PAP No. 2 Cooling Tower No. 

4 

None 520 and 521 

T3 

T1003 

Two (2) feed acid storage 

tanks in the PAP tank farm 

None None 591

These sources are listed as a 15A NCAC 2Q .0501(c)(2) modification. The permit shield described in 

General Condition R of Part I of the permit does not apply to these sources.

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The following table contains a summary of all listed emission sources and associated air pollution control 

devices and appurtenances associated with Air Quality Permit Applications 07-00071.06C and 07B

{PRIVATE 

}Emissio

n Source 

ID No. 

Emission Source 

Description 

Control 

Device 

ID No. 

Control Device 

Description 

Emission 

Point ID No. 

CP No. 3* Cooling Pond No. 3 None None 914-922 

(State-only 

requirements) 

ES424* Two Silicon tetrafluoride 

(STF) plants, each including 

drying column, flash drum and 

knock out drum 

CD 438-

200* 

One (1) venturi scrubber 

Operated only during 

loading and maintenance 

operations 

424 

ES425* Two Silicon tetrafluoride 

(STF) plants, each including 

drying column, flash drum and 

knock out drum 

CD TBD* One (1) venturi scrubber 

Operated only during 

loading and maintenance 

operations 

425 

* These emission sources and/or control devices (ID No(s). CP No. 3, ES424, ES425, CD 438-200 and CD TBD) 

are listed as a 502(b)(10) change per NCAC 2Q .0523. The permit shield described in General Condition R does not 

apply. 

SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS

The air emission source(s) and associated air pollution control device(s)and appurtenances listed in Section 1 

are subject to the following specific terms, conditions, and limitations, including the monitoring, 

recordkeeping, and reporting requirements as specified herein: 

1. Any air emission sources or control devices authorized to construct in Section 1 must be constructed 

and maintained in accordance with the provisions contained herein and operated in accordance with 

provisions contained in Part I of this permit. The Permittee shall comply with applicable 

Environmental Management Commission Regulations, including Title 15A NCAC, Subchapter 2D 

.0530 and .1111. 

2. NOTIFICATION REQUIREMENT - If the proposed operational date of January 31, 2008 is not 

met for ID No. ES425 and ID No. ES424 (plant 2), a revised permit is not needed. However, within 

15 days after the proposed operational date is not met, the Permittee shall notify in writing the 

Regional Supervisor of the new proposed operational date. Any existing equipment being replaced 

is permitted to operate in compliance until the replacement equipment is operational. 

3. NOTIFICATION REQUIREMENT - In accordance with 15A NCAC 2Q .0523(a)(1)(C), the 

Permittee shall notify the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61 Forsyth 

Street, Atlanta, GA 30303) in writing at least seven days before the change is made. The written 

notification shall include: 

 a. a description of the change at the facility; 

 b. the date on which the change will occur; 

 c. any change in emissions; and 

 d. any permit term or condition that is no longer applicable as a result of the change. 

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SECTION 3: GENERAL CONDITIONS:

This section describes terms and conditions applicable to the construction of the air emission source(s) and 

associated air pollution control device(s) listed in Section 1 and State-only emission sources listed in Part I of 

the permit. Unless otherwise specified herein all references to the “permit” in this section apply only to Part II 

of the permit. 

A. Operating Conditions

 All conditions for the air emission source(s) and associated air pollution control device(s) listed in 

Section 1 are under Part I of this permit. 

B. General Provisions

 1. This permit is nontransferable by the Permittee. Future owners and operators must obtain a new 

Air Quality Permit from the DAQ. 

 2. This issuance of this permit in no way absolves the Permittee of liability for any potential civil 

penalties which may be assessed for violations of state law which have occurred prior to the 

issuance date of this permit. 

 3. A violation of any term or condition of Part II of this permit shall subject the Permittee to 

enforcement pursuant to NCGS 143-215.114A, 143-215.114B, and 143-215.114C, including 

assessment of civil and/or criminal penalties. 

C. Submissions (reports, test data, monitoring data, notifications, and requests for renewal)

 Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, 

notifications, request for renewal, and any other information required by this permit shall be 

submitted to the appropriate Regional Office. Refer to the Regional Office address on the cover 

page of this permit. 

D. Part II Renewal Request

 The Permittee shall request renewal of the emission source(s) and associated air pollution control 

device(s) listed in Section 1 at the same time as specified in Part I, Section 3 - General Condition K 

of this permit. 

E. Annual Fee Payment

 The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200 and in conjunction with 

Part I, Section 3 - General Condition W of this Air Quality Permit. 

F. Reporting Requirements 

 

 Any of the following that would result in new or increased emissions from the emission source(s) 

listed in Section 1 must be reported to the Regional Supervisor, DAQ: 

 1. changes in the information submitted in the application; 

 2. changes that modify equipment or processes; or 

 3. changes in the quantity or quality of materials processed. 

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 If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary 

changes in the permit conditions. In no case are any new or increased emissions allowed that will 

cause a violation of the emission limitations specified herein. 

G. Termination, Modification, and Revocation of the Permit 

 The Director may terminate, modify, or revoke and reissue this permit if: 

 1. the information contained in the application or presented in support thereof is determined to be 

incorrect; 

 2. the conditions under which the permit or permit renewal was granted have changed; 

 3. violations of conditions contained in the permit have occurred; or 

 4. the Director finds that termination, modification, or revocation and reissuance of the permit is 

necessary to carry out the purpose of NCGS Chapter 143, Article 21B. 

H. Inspection and Entry 

 Upon presentation of credentials and other documents as may be required by law, the Permittee shall 

allow the DAQ, or an authorized representative, to perform the following: 

 1. enter the Permittee's premises where the permitted facility is located or emissions-related 

activity is conducted, or where records are kept under the conditions of the permit; 

 2. have access to and copy, at reasonable times, any records that are required to be kept under the 

conditions of the permit; 

 3. inspect at reasonable times and using reasonable safety practices any source, equipment 

(including monitoring and air pollution control equipment), practices, or operations regulated or 

required under the permit; and 

 4. sample or monitor substances or parameters, using reasonable safety practices, for the purpose 

of assuring compliance with the permit or applicable requirements at reasonable times. 

I. Circumvention - STATE ENFORCEABLE ONLY 

 The facility shall be properly operated and maintained at all times in a manner that will effect an 

overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may 

be operated without the concurrent operation of its associated air pollution control device(s) and 

appurtenances.

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 696 

 December 17, 2007
[1]Please add an additional row for each additional pollutant.

To add an additional row:

& place the cursor anywhere in the existing table;

& pick "table" from the menu bar;

& select "insert";

& select the radio button for "row";

& select whether you want the new row to be "before" or "after" the cursor;

& click ok.

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Appendix L.10 - 697 

 December 17, 2007