### Permit 08961T?? DRAFT Page 81



## 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)Permit 08961T?? DRAFT Page 82



### SECTION 3 - GENERAL CONDITIONS

This section describes terms and conditions applicable to this Title V facility. All references to the “permit” in this sectio n 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 polluti on in contravention of state laws or rules, unless specifically authorized by an order from the Nort h 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 th e United States as defined in the Federal Clean Air

Act. 6. Any stationary source of air pollution shall not be ope rated, 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 insta llation will not cause air pollution in violation of any of the applicable requirements. A permitted installa tion 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 aut horized 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 bi nding permit in which a condition is held to be invalid, the provisions in this permit are severable so that all requiremen ts 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 info rmation 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, requi rements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition except cond itions identified as state-only requirements constitutes a violation of the Federal Clean Air Act. Noncomplia nce 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.Permit 08961T?? DRAFT Page 83

F. Circumvention - STATE ENFORCEABLE ONLY The facility shall be properly operated and maintained at all tim es 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 polluti on 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 Applicati on 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 c ontravene an express permit term or condition. Such changes do not include changes that would violate ap plicable 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 th e 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 th e 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 app licable emission limitation or standard allowed by any rule in Sections .0500, .0900, .1200, or .1400 of S ubchapter 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 andPermit 08961T?? DRAFT Page 84

conditions of this permit including those attributable to up set 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 und er NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D .1110 or .1111), or the operating permit provides for pe riodic (e.g., quarterly) repor ting 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 Pe rmittee shall report excess emissions in accordance with

15A NCAC 2D .0535 as follows: a. Pursuant to 15A NCAC 2D .0535, if excess emi ssions last for more than four hours resulting from a malfunction, a breakdown of process or control equipmen t, 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 w ithin 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 sh all report deviations from permit requirements (terms and conditions) as follows: a. Notify the Regional Supervisor or Director of a ll 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 acti ons 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 s ources 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 de monstrate 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 techno logy-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 prev entive maintenance, careless or improper operation, or operator error. 2. An emergency constitutes an affirmative defense to anaction 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 de monstrated 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 to ok all reasonable steps to minimize levels ofPermit 08961T?? DRAFT Page 85

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 up set 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 fac ilities subject to Title IV requirements and for a term not to exceed five years in the case of all other facilities. This pe rmit 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 applican t 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 re quired 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 supple mentary facts or corrected information to the DAQ. The Permittee shall also provide additional information as necessa ry 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, measur ement, report, or application. Supporting information

includes all calibration and maintenance records and all or iginal 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 sh all 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 speci fied 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.Permit 08961T?? DRAFT Page 86

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 certifi cations shall state that based on information and belief formed after reasonable inquiry, the statements and info rmation 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 incl uded 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 sour ce or activity is insignificant.

U. Property Rights [15A NCAC 2Q .0508(i)(8)] This permit does not convey any property rights in either r eal 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 f acility 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), practi ces, or operations regulated or required under the permit; and d. sample or monitor substances or parameters, us ing 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 aut horized 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. RefusalPermit 08961T?? DRAFT Page 87

of entry or access may constitute grounds for perm it 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 paym ents 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 accu racy 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 th e 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 fi nancial qualifications and/or a statement of substantial compliance history.

CC. Refrigerant Requirements (Stratos pheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)] 1. If the Permittee has appliances or refrigeration equipmen t, including air conditioning equipment, which use Class I or II ozone-depleting substances such as chlorofl uorocarbons 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, personne l 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 re lease 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 re gister 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 th e Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a gene ral 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)]Permit 08961T?? DRAFT Page 88

This permit does not limit the number of Title IV allowan ces held by the Permittee, but the Permittee may not use allowances as a defense to noncompliance with any other ap plicable requirement. The Permittee’s emissions may not exceed any allowances that the facility lawfully ho lds 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 approv ed Emission Reduction Plan or, in the absence of an approved plan, with the appropriate require ments 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 re quired 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 name d in the applicable emission standards in this permit are required to prevent violation of the ambient air quality stan dards 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 Subm ittal 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 op erate 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 samp ling team leader and facility representative; b. a summary of emissions results and text detailing th e 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 sour ce(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 duri ng 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 us e of the test results beyond the stated objectives remains subject to the approval of the DAQ.

### Permit 08961T?? DRAFT Page 89

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 mu st 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 pe rmit was extended pursuant to 15A NCAC 2Q .0513(c). 3. Except for the state-enforceable only portion of the pe rmit, 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 revo ked 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 mo nitoring recordkeeping and reporting requirements as prescribed by the permit shall be implemented within the monitoring period.

### 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

NO X 

### Nitrogen Oxides

NSPS New Source Performance Standard

OAH Office of Administrative Hearings

PM Particulate Matter

PM 10 

### Particulate Matter with Nominal Aerodyna mic Diameter of 10 Micrometers or Less

POS Primary Operating Scenario

PSD Prevention of Significant Deterioration

SIC Standard Industrial Classification

SIP State Implementation Plan

SO 2 

### Sulfur Dioxide
tpy Tons Per Year VOC Volatile Organic Compound
VOC Volatile Organic Compound

## 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

### 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 PM 10 

### 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 PM 10 

### 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 PM 10 

### 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 CPCS Phosphate BART determination



### 1 SECTION 1.0

INTRODUCTION

PCS Phosphate, Inc. is the world’s largest fer tilizer 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 fac ility 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 a bout 20,000 acres out of a total plant site of 50,000 acres. The facility is a Title V fac ility and operates under air permit 04176T34. PCS Phosphate submitted a BART evaluation Permit A pplication 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 se t 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 manda tory Class I federal areas as determined using 40 CFR 51, Subpart P. “BART-eligible” sour ces 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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), 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 NC AC 2D .0543(c), a BART-eligible source can be exempted from the BART requirements based on dispersion mode ling 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 usi ng 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 th at 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 indi cated 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 BA RT 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 s cenarios, the resulting visibility impact on the Swanquarter Class I area would be redu ced 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 arePCS Phosphate BART determination



### 2 necessary. The remainder of this report contai ns a review by NCDAQ of the demonstration and analyses presented by PCS Phosphate. The re sponse 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 participa tion by the general public, industry, and other affected persons. Specific public notice require ments 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.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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), particulate matter (PM), and volatile organic compounds (VOCs), and that fall within 26 indus trial 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 SO 2 

### , NO

x 

### , H 2 

### SO 4 

### mist, or PM 10 

### :

• 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 SO 2 

### 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 SO 2 

### and

H 2 

### SO 4 

### 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.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, gr anulator, oil-fired dryer, material sizing and handling equipment, and cooler. The residual oil dryer has a nominal maximum input of 618 tons of fresh P 2 

### O 5 

### 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, granul ator, 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 ventedPCS 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 SO 2 

### , 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 SO 2 

### , NO

x 

### , H 2 

### SO 4 

### mist, or PM 10 

### . 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 98 th 

### 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. U pon review, DAQ requested that the protocol be revised since it deviated from the VISTAS protocol.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.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 visib ility protection provisions of the Clean Air Act

addresses installation of best available retrof it technology (BART) for certain existing sources. “BART-eligible” sources are those sources bu ilt 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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), particulate matter (PM), and volatile organic compounds (VOCs), and that fall within 26 indus trial 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 guidan ce (40 CFR Part 51, Appendix Y) must only be followed by states for large fossil fuel fired elect ric steam generators, but is otherwise optional

for other BART units.

According to 40 CFR Part 51, Appe ndix Y, a BART-eligible source is considered to “contribute” to visibility impairment in a Class I area if the modeled 98 th 

### percentile change in dv is equal to or greater than the “contribution threshold.” Th e 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 evaluati ons, States will develop Regional Haze State Implementation Plans (SIPs). States must subm it plans to implement the Regional Haze Rule for EPA review and approval by January 2008.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 St ate-Only enforceable, implements the BART provisions of 40 CFR 51.308(3) for emission sour ces 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 t hose 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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), particulate matter (PM), and volatile organic compounds (VOCs), and that fall with in 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 mode ling 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 usi ng 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.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 Pe rmit 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 implem ented 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 Swa nquarter 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

SO 2 and

H 2 SO 4 mist. double absorption process and

emissions of

sulfuric acid

mist are controlled by

mist eliminators Dual Absorption Process with Cesium Promoted Catalyst

SO2

PM 10 (H2SO4 mist) current control technology represents

BACT for PM 10 emissions from sulfuric acid plants

NOx No feasible controls for
NOx $4,108/ton SO 2 (SA 3) $5,584/ton SO 2 (SA 4) ($81,602/ton/dv)

Lime Storage Silo Baghouse No. 4 (121) baghouse There are no other feasible

PM 10 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 PM 10 controls already in place which are the most stringent controls available

SO 2 emissions are already controlled by the phosphate rock being dried and the existing venturi scrubber,

additional SO 2 control is impractical

NO

x staged combustion $3,451/ton of NO

x reduction ($156,842/ton/dv)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 SO 2 control, and test

data show that the SO 2 emissions are only 0.012

lb/ MmBtu fuel oil fired. At this low emission rate, there

would be no additional technically or economically

feasible SO 2 emissions control option.

NO

x staged 

### combustion $4,007/ton of NO

x ($200,361/ton/dv)

Calcine Conveyor

Transfer Station (CTS) (220) enclosed transfer points

to minimize

fugitive

emissions PM 10 vent to a baghouse $161,060/ton PM 10 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 PM 10 vent to a baghouse $161,060/ton PM 10 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.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

PM 10 emissions are already well controlled, BART for

PM 10 emissions from the No. 3 DAP plant is no additional

control.

NO

x staged combustion

SO 2 emission inherently low,

additional SO 2 emissions

control would be not technically or economically

feasible $6,997/ton of NO

x ($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

SO 2 , 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 SO 2 emissions, there are no feasible
retrofit control options 

### ;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 SO 2 emissions $10,974 per ton of

SO 2 ($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 PM 10 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 PM 10 removed ($2,271,849/ton/dv)

Rock Tower Loadout Facility (654)

Note: The capital cost to inst all all feasible controls is $15.0 million, a nd 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 consider ation of the six requirements identified above and the five steps identified in 40 CFR 51 Appe ndix Y “Guidelines for BART Determinations Under the Regional Haze Rule.” Again, thes e guidelines are not the exclusive means of defining BART for facilities other than Electric Generating Units. However, they provide a

convenient structure to consider.PCS Phosphate BART determination



### 13 • 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 retr ofit control option as an air pollution control technology with a practical potential for applica tion to the emissions unit and the regulated pollutant under evaluation. Technologies availabl e for compliance with Best Available Control Technology (BACT) or Lowest Achievable Em ission Rate (LAER) regulations should be included as part of the BART analysis. Furt hermore, 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 cat egories 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-NO X 

### 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 whic h 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 tec hnology could be applied: "availability" andPCS Phosphate BART determination



### 14 "applicability." ...a technology is considered "available" if the source owner may obtain it through commercial channels, or it is othe rwise 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 unde r consideration. A technology that is available and applicable is technically feasible.”

Control technologies that are deemed technically in feasible 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 applicati on. 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 cons traints, 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 technica lly 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 an alyses to select the control technology that meets the requirements of BART. The analysis evaluates four impacts that would pot entially 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.PCS Phosphate BART determination



### 15 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.PCS Phosphate BART determination



### 16 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 PM 10 

### /H 2 

### SO 4 

### mist, SO 2 

### , and

NO

x 

### . As stated previously, the units use the double absorption process to control SO 2 

### and mist

eliminators to control H 2 

### SO 4 

### mist (PM 10 

### ) to meet BACT and NSPS limits for SO 2 

### and H 2 

### SO 4 

### mist. The principal steps in the sulfuric acid production process consist of burning sulfur (S) in air to form sulfur dioxide (SO 2 

### ), combining the sulfur dioxide with oxygen (O 2 

### ) to form sulfur trioxide (SO 3 

### ), and combining the sulfur trioxide with water (H 2 

### O) to form a solution containing sulfuric acid (H 2 

### SO 4 

### ).

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 compartmen t 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 SO 3



### . Not all the SO 2 

### is converted to SO 3 

### ; the conversion into SO 3 

### is a function of the catalyst and oxygen present during the reaction.

A summary of recent BACT determinations for SO 2 

### 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 Cont rol 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 scr ubber 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 SO 2 

### 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 potentia lly applicable control technologies for SO 2 

### emissions from sulfuric acid plants. Th e following technologies are evaluated:PCS Phosphate BART determination



### 17 • 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, SO 2 

### is removed by scrubbing the exhaust gases with a sodium sulfite solution. The resulting s odium bisulfite solution is fed to a heated crystallizer where sodium sulfite crysta ls are formed with the release of SO 2 

### 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 SO 2 

### 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 SO 2 

### cannot be regenerated in the h eating sequence. This sulfate must be purged from the system. Some thio-sulfa te can also be formed in the process. The extent of oxidation is dependent on several factor s (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 contamin ants 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 opera tional 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 reject ed from further consideration in this analysis

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

less than 4.0 lb SO 2 

### /ton of 100 percent H 2 

### SO 4 

### produced at a sulfur-burning sulfuric acid manufacturing plant. SA Plants 3 a nd 4 are currently limited to 4.0 lb SO 2 

### /ton H 2 

### SO 4 

### by NSPS Subpart H and have daily SO 2 

### mass emission limits that are equivalent to 3.8 lb SO 2 

### /ton H 2 

### SO 4 

### at production capacity.

Molecular Sieves This process utilizes a proprietary molecular sieve system in which SO 2 

### 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 prom ulgation of the sulfuric acid plant NSPS, one new unit was built with a molecular sieve system to control SO 2 

### . However, extensive operational difficulties with the system caused this plant to be retrofitted with a dual absorption system for

SO 2 

### control. The dual absorption system wa s retrofitted in January 1979 and has operated satisfactorily since that time. Since mol ecular sieve control technology has not been commercially demonstrated, this option is cons idered technically infeasible for reducing SO 2 

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

Ammonia Scrubbing The ammonia scrubbing process uses anhydrous ammonia (NH 3 

### ) and make-up water in a twostage scrubbing process to remove SO 2 

### . The typical SO 2 

### 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.PCS Phosphate BART determination



### 18 According to MECS, Inc., sulfur-burning sulfur ic acid manufacturing plants that have used ammonia scrubbing technology have applied the tec hnology 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 SO 2 

### /ton of 100 percent H 2 

### SO 4 

### produced and comply with the more stringent

state limit of 3.8 lb SO 2 

### /ton of 100 percent H 2 

### SO 4 

### produced. Due to operational difficulties and high costs associated with operating ammonia sc rubbing 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 SO 2 

### /ton of 100 percent H 2 

### SO 4 

### produced and the state limit of 3.8 lb SO 2 

### /ton of 100 percent H 2 

### SO 4 

### 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 SO 2 

### 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 convert er and absorbing tower to the exhaust from a single absorption plant. Vanadium-based catal ysts are used in virtually all existing dual absorption systems, including SA Plants Nos. 3 a nd 4. Cesium-promoted catalysts have recently been used, and provide higher levels of contro l. 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 de veloped specifically for lower temperature operations which can lead to greater SO 2 

### conversion and hence lower SO 2 

### emissions to the atmosphere. The cesium salt promoter reduces the required operating temperature for the sulfuric acid catalyst by as mu ch as 40°C (70°F). Higher SO 2 

### 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 cesiu m catalyst in beds 4 and 5 (at a low inlet temperature) to maximize the SO 2 

### conversion and provide SO 2 

### emission reductions. PCS indicated that they made an inquiry regarding th e retrofit of the existing vanadium-based control systems at SA Plants Nos. 3 and 4 with cesium cat alyst was made to MECS, Inc. to specifically determine the feasibility of reducing SO 2 

### emissions to 2.0 lb SO 2 

### /ton H 2 

### SO 4 

### (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 ma gnitude emissions reduction would also require a decrease in Plant Nos. 3 and 4 producti on levels from a throughput of 2000 ton H 2 

### SO 4 

### /day and

1850 ton H 2 

### SO 4 

### /day, respectively, down to 1650 ton H 2 

### SO 4 

### /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 SO 2 

### emissions in plants 3 and 4 to 3.5 lb

SO 2 

### /ton H 2 

### SO 4 

### . An inquiry into this magnitude of emissions reduction was also submitted to MECS, Inc. This magnitude emissions reduc tion requires the replenishment of vanadiumPCS 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 f easible as it does not require a decrease in the productivity of the plants. The economic impact s 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 opera ting 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 contro l technology retrofit is $4,108/ton SO 2 

### and $5,584/ton SO 2 

### 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 PM 10 

### Emissions

The PM 10 

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

Sulfuric acid mist is created when sulfur trioxi de 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 retr ofitted with vertical tube mist eliminators to

control H 2 

### SO 4 

### mist. SA Plant 4 uses vertical tube mist eliminators to control H 2 

### SO 4 

### mist. They are subject to the NSPS limit of 0.15 lb H 2 

### SO 4 

### mist/ton of 100 percent H 2 

### SO 4 

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

for H 2 

### SO 4 

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

RBLC entries for PM 10 

### emissions from sulfuric acid plants show that the H 2 

### SO 4 

### mist control technology used in sulfuric acid plants is in the fo rm of mist eliminators (there is one entry for a

scrubber to control PM 10 

### , but scrubbers do not typically provide much control of sulfuric acid mist emissions, and this entry is RACT for a single-contact process where SO 2 

### was also evaluated). H 2 

### SO 4 

### 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 H 2 

### SO 4 

### 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 H 2 

### SO 4 

### mist control technology in sulfuric acid plants and is much le ss 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 w ith 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 absorptionPCS Phosphate BART determination



### 20 tower and welded to the inside of the absorpti on tower head. The gas flows horizontally through the bed and requires a high superficial velocity si nce it uses an impact mechanism for collection

of H 2 

### SO 4 

### mist particles. Since a high superficial ga s 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 H 2 

### SO 4 

### mist emissions and stack opacity.

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

H 2 

### SO 4 

### mist/ton of 100 percent H 2 

### SO 4 

### produced, which is higher than the NSPS standard of

0.15 lb H 2 

### SO 4 

### mist/ton of 100 percent H 2 

### SO 4 

### produced. Moreover, vertical panel mist eliminators are widely known to be a less e ffective 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 ver tical tube mist eliminators to control H 2 

### SO 4 

### mist. SA

Plant 4 uses vertical tube mist eliminators to control H 2 

### SO 4 

### 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 eliminat ors 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. Thes e units also use high velocity impaction for mist collection, which also results in an unsatisfactory performance for H 2 

### SO 4 

### mist control. Dual pad mist eliminators typically reduce H 2 

### SO 4 

### mist emissions to 0.375 lb H 2 

### SO 4 

### mist/ton of 100 percent H 2 

### SO 4 

### 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 H 2 

### SO 4 

### mist. SA Plant 4 uses vertical tube mist eliminators to control H 2 

### SO 4 

### mist.

As the current control tec hnology represents BACT for PM 10 

### emissions from sulfuric acid plants and recent stack testing results were less than 0.05 lb H 2 

### SO 4 

### mist/ton of 100 percent H 2 

### SO 4 

### produced, no additional H 2 

### SO 4 

### mist control is proposed for BART for SA Plants 3 and 4.

4.3.3 Nitrogen Oxides Emissions Nitrogen oxides (NO

x 

### ) are formed from the reaction of nitrogen (N 2 

### ) and oxygen (O 2 

### ) within the combustion air, creating thermal NO

x 

### . Increased quantities of oxygen in the combustion zone result in greater amounts of NO

x 

### formation. Once formed, the decomposition of NO

x 

### at lower temperatures, although thermodynamically favorable, is kinetically limited. Thus, NO

x 

### control strategies are based upon reducing formation of NO

x 

### 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 NO

x 

### 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)PCS Phosphate BART determination



### 21 A brief description of each technology and the r easons why those technologies are considered technically infeasible are provided below.

Selective Catalytic Reduction (SCR) SCR is typically used for NO

x 

### control on large utility boilers. The SCR process chemically

reduces the NO

x 

### molecule into molecular nitrogen and water vapor. A nitrogen-based reagent such as ammonia or urea is injected into th e ductwork, downstream of the combustion unit. The waste gas mixes with the reagent and enters a r eactor module containing catalyst. The hot flue gas and reagent diffuse through the catalyst. The reagent reacts selectively with the NO

x 

### within a specific temperature range and in the presence of the catalyst and oxygen. The NO

x 

### reduction reaction is effective only within a given temper ature range. The optimum range depends on the type of catalyst used and the flue gas compos ition. Optimum temperatures vary from 480°F to 800°F. SCR has been applied mostly to coal a nd natural gas-fired utility boilers ranging in size from 250 to 8,000 mmBtu /hr.

Capital costs are significantly higher than other types of NO

x 

### 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. Th e 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 NO

x 

### 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, o il, gas, biomass and waste ranging in size from 50 to 6,000 MmBtu /hr. This technology has not been app lied 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 consider ed for further analysis. In addition, there is the

unwanted reaction of ammonia with sulfur co mpounds to form ammonium sulfates in the

reaction chamber. Because there are no feasible retrofit technologies for NO

x 

### 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 PM 10 

### and is controlled by a baghouse. Baghouses are typically used in industr y to control these types of particulate matter

sources. There are no other feasible PM 10 

### 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 calcine rs, 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.PCS Phosphate BART determination



### 22 4.5.1 PM 10 

### 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 PM 10 

### 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 stri ngent 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, SO 2 

### is partially removed from the combustion gases when SO 2 

### reacts with the wet phosphate rock being dried. Phosphate rock is rich in oxygenated calcium compounds and reacts

with SO 2 

### to form calcium sulfates/sulfites. Additional SO 2 

### 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 SO 2 

### control methodology found in a search of the EPA’s RBLC for kilns and calciners in the mineral products industry. Additionally, the actual SO 2 

### emissions from each calciner at PCS are less than 10 tpy. Because

SO 2 

### emissions are already controlled by the phosphate rock being dried and the existing venturi scrubber, additional SO 2 

### 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 NO

x 

### emissions are uncontrolled. The temperature of the heated air from the calciner exhaust is approximately 160 o 

### F. Although SCR, NSCR, and SNCR are highly effective NO

x 

### reduction technologies in various industries, they are not applicable to phosphate rock calciners and are re jected as BART based on technical infeasibility. Elevated temperatures and/or low particulate load ing are essential for use of these technologies. First, temperature requirements range from 600 to 800 o 

### F for SCR, 700 to 1500 o 

### F for NSCR, and

1600 to 2200 o 

### F for SNCR. The calciner exhaust temperature of approximately 160 o 

### F is substantially below the required temperatures for any of these technologies. Second, low particulate loading is needed to prevent deactiv ation of SCR and NSCR catalysts. The calciner exhaust contains some particulate loading and likely contains phosphorus compounds, which

deactivate NO

x 

### reduction catalysts. Consequentl y, the use of SCR, SNCR, and NSCR technologies are not considered technically feasible for phosphate rock calciners.PCS Phosphate BART determination



### 23 EPA’s RBLC database for technologies used on k ilns and calciners in other mineral processing industries yielded feasible and successfully impl emented alternatives to SCR, SNCR, and NSCR. These alternatives include staged combustion and low-NO

x 

### burners. Although staged

combustion and low-NO

x 

### burners are both technically feasible NO

x 

### control techniques, cost effectiveness was evaluated for only staged combustion because the cost of low-NO

x 

### burners is expected to be approximately equal to a stag ed combustion system, while achieving the same

NO

x 

### reduction. Low-NO

x 

### burner technology for fuel oil combustion typically reduces NO

x 

### emissions by 18 to 20 percent. While low-NO

x 

### burners could be used in the calciners, low-NO

x 

### burners were not included in the cost analyses b ecause 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-NO

x 

### burners are typically slightly mo re than staged combustion systems and, in this particular case, the annual cost of low-NO

x 

### burners is also expected to be very similar to that of staged combustion.

Staged combustion is a technology commonly used to reduce NO

x 

### emissions in a variety of industries. This technology could also be retr ofitted 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 NO

x 

### 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 co mbustion 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 e fficiency 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 NO

x 

### reduction. The visibility improvement resulting from the in stallation 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 stringentPCS Phosphate BART determination



### 24 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 sin ce the unit is already equipped with the most stringent PM controls and the operation of thes e controls is required by the facility’s Title V Operating Permit.

The rock dryer also emits small amounts of SO 2 

### and NO

x 

### emissions from fuel oil combustion; maximum fuel oil combustion is 620 gal/hr. However, the fluidized bed of rock provides approximately 90 percent inherent SO 2 

### control, and test data show that the SO 2 

### 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 SO 2 

### emissions control option.

NO

x 

### 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 NO

x 

### 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 manua l. 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 NO

x 

### reduction is estimated to be $4,007/ton of NO

x 

### reduction and $200,361/ton/dv.

4.7 BART Analysis for Calciner Area Rock Handling Sources

The Calcine CTS baghouse (ID 221) and the st orage silo baghouse (ID 222) have small

emissions of PM 10 

### . Enclosures and/or baghouses are typically used in industry to control these types of particulate matter sources. There ar e 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 transf er 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 improveme nt of 0.02 dv. The estimated costs for this control option are not cost effective; The total annua l cost for each transfer point is estimated to be $188,440 and the cost effectiveness is $161,060/ton PM 10 

### 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 t echnically or economically feasible, and likely would not provide a visibility improvement at Sw anquarter, as the emissions reduced would only be a tenth of a ton. Therefore, BART is no additional control for the calciner area fugitives.PCS Phosphate BART determination



### 25 4.8 BART Analysis for Diammonium Phosphate (DAP) Plants

As previously stated, DAP Plan t 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 s uperphosphate (GTSP), or partially acidulated phosphate rock (PAPR). This plant consists of first and second stage reactors, granulator, residual oil-fired dryer, material sizing and ha ndling 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 cy clonic 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 gra nulator are controlled by a saturation chamber and a wet cyclonic

scrubber installed in series. The scrubbers are vent ed 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 sl urry 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 granul es, 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 produc t-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 scrubbe r, dust scrubber, and cooler scrubber). Fumes and dust from the reactors and granulator are c ontrolled by a two stage scrubbing unit (dual mole scrubber) consisting of a venturi scrubber (hi gh mole stage) followed by a cyclonic scrubber (low mole stage). The primary purpose of the ve nturi 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 scr ubber also provides some ammonia emissions control.

4.8.1 PM 10 

### 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 consider ed infeasible because dry ESP control is undemonstrated on DAP plants and may be incompatible with exhaust stream characteristics.PCS Phosphate BART determination



### 26 The exhaust stream in the common header after the primary scrubbing systems is saturated with moisture and could contain hydrofl uoric 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 component s clean for proper operation) and operational difficulties leading to problems in maintain ing compliance with design/permitted emission

levels.

Current stack test data show that PM 10 

### emissions are 0.123 lb/ton P 2 

### O 5 

### 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 PM 10 

### emissions are already well controlled, BART for PM 10 

### emissions from the No. 3 DAP plant is no additional

control.

4.8.2 Nitrogen Oxides Emissions

NO

x 

### emissions result from fuel oil combustion in the dryer. Although SCR, NSCR, and SNCR are highly effective NO

x 

### reduction technologies in other industries, they are not applicable to the DAP dryer and are rejected as BART based on t echnical infeasibility. Elevated temperatures and/or low particulate loading are essential for use of these technologies. First, temperature requirements range from 600 to 800 o 

### F for SCR, 700 to 1500 o 

### F for NSCR, and 1600 to 2200 o 

### F for SNCR. The dryer exhaust temperature of 170 to 200 o 

### 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 drye r 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-NO

x 

### burners are both technically feasible NO

x 

### control techniques, only staged combustion is evaluated here because the cost of low-NO

x 

### burners is expected to be approximately equal to a staged combustion system, while achieving a lower NO

x 

### reduction efficiency. Staged combustion is a technology commonly used to reduce NO

x 

### 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 NO

x 

### 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 re move 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 bePCS Phosphate BART determination



### 27 $150,000 and $85,364, respectively, and would result in a visibility improvement of 0.02 dv.

The cost effectiveness of NO

x 

### reduction is estimated to be $6,997/ton of NO

x 

### reduction, and $349,850/ton/dv.

4.8.3 Sulfur Dioxide Emissions

Stack test data show that SO 2 

### emissions are minimal from DAP production due to inherent ammonia scrubbing (0.009 lb/ton P 2 

### O 5 

### input), with actual emissions on the order of 1 ton per year. Therefore, no additional SO 2 

### 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 c oncentrates various grades of phosphoric acid by removing water. SPA plants 1 and 2 have two st age, 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 th at controls fluoride emissions from the product storage tank and evaporator hotwell and discha rges through stack IDs 330 and 331, respectively. SPA plants 3 and 4 share a common venturi scrubbe r 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 SO 2



### .

Sulfur dioxide (SO 2 

### ) is emitted during concentration of phos phoric acid due to vaporization of

residual SO 2 

### in the acid. Stack testing at SPA plant Nos. 1 and 2 indicates that SO 2 

### concentrations present in stack gas are typically less than 10 ppmv. Actual emissions from all four plants combined are less than 3 tpy SO 2 

### . Essentially no SO 2 

### is removed in the venturi scrubbers that control fluoride emissions from the plants due to the extremely low concentrations of SO 2 

### present in the off-gases and due to the fact the pond water us ed in the scrubbers is slightly acidic, which creates no “driving force” for SO 2 

### removal. Due to the low levels of SO 2 

### 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 com pound emitted by these units is SO 2



### .

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 treat ed in crossflow packed bed scrubbers (one for each of the four plants) using pond wate r as the scrubbing media. Since SO 2 

### is readily absorbed in water, some SO 2 

### evolved in the reactors is removed by the scrubbers. Based on previous stackPCS Phosphate BART determination



### 28 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 SO 2 

### removal is difficult at such low concentrations. The RBLC does not contain any previous BACT decisions for SO 2 

### control from phosphoric acid manufacturing. Therefore, engineering knowledge was used to es tablish BART options to be evaluated. The most effective methods of removing SO 2 

### from gas streams include ab sorption in various liquids, sorption by solids, and gas phase conversions. Absorption in liquids (scrubbing) is the most effective method of reducing SO 2 

### 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 SO 2 

### 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 SO 2 

### 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 SO 2 

### in the crossflow

scrubber exhaust.

Although use of ammonia scrubbing for SO 2 

### 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 majo rity 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, SO 2 

### 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 SO 2 

### 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 SO 2 

### 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 SO 2 

### 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 existingPCS Phosphate BART determination



### 29 crossflow scrubbers and addition of a caustic scrubber would increase the pressure drop of the exhaust gas. The design exit SO 2 

### concentration of a new scrubber was estimated to be approximately 10 ppmv, based on a maximum inlet SO 2 

### 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 SO 2 

### removal, based on an actual SO 2 

### 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 PM 10 

### emissions (0.257 lb/hr) that are controlled by a baghouse. Enclosures and/or baghous es 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 PM 10 

### removed. Therefore, BART for these emission sources is no additional

controls./

### PCS Phosphate BART determination



## APPENDIX A

Response to EPA Comments on Bart Permit Application

### 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 give n 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

### 2production 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 SO 2 

### 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 (1 st 

### 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 (2 nd 

### 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

### 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 4 th 

### and 5 th 

### 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 th e 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.

### 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

### 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 4 th 

### and 5 th



### 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 theirinclusion/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 havethe potential to emit more than 250 tons per year of one or more visibilityimpairing compounds including sulfur dioxide (SO 2 

### ), nitrogen oxides (NO

x 

### ), 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.Table 1-1. Summary of BART-Eligibility Analysis Prepared for PCS Phosphate Aurora Facility (2004)Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpySulfuric Acid PlantsS-3Double-absorption sulfuric acid plant No. 3 (1850tons 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 0.61S-4Double-absorption sulfuric acid plant No. 4 (1850tons per day nominal capacity)102 10/10/1975 TRUE Y -- -- 20.97 40.529.21 25.32 600.68 1,283.34 0.00 0.61S-5Double-absorption sulfuric acid plant No. 5 (3600tons per day nominal capacity)103 3/13/1982 FALSES-6Double-absorption sulfuric acid plant No. 5 (3800tons per day nominal capacity)104 12/20/1985 FALSEBW-2One (1) distillate oil-fired boiler (99.56 millionBtu per hour nominal capacity)110-new 2003 FALSEBW-1One (1) distillate oil-fired boiler (125 million Btuper hour nominal capacity)111 1/1/1975 TRUE Y -- -- 1.19 78.80 0.06 3.94 1.89 166.60 0.01 0.79417-503-462 Lime silo No. 4 at water treatment area121 1/1/1973 TRUE Y-- -- -- -- 0.69 0.70 -- -- -- --417-755-462 Lime silo No. 5 at water treatment area122 1/1/1982 FALSE417-756-462 Lime silo No. 6 at water treatment area123 1/1/1982 FALSEMill Area339-051vertical fluidized bed phosphate rock calciner unitNo. 1 (105.1 tons per hour nominal feed);coal/coke/”off-spec” used oils, used oilsludge/used glycols/ residual oil-fired201 7/1/1966 TRUE Y -- -- 65.50 138.28 21.52363.5412.12187.250.20 0.447Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpy339-052vertical fluidized bed phosphate rock calciner unitNo. 2 (105.1 tons per hour nominal feed);coal/coke/”off-spec” used oils, used oilsludge/used glycols/ residual oil-fired202 7/1/1966 TRUE Y -- -- 70.40 138.28 30.060.020.20 0.44339-053vertical fluidized bed phosphate rock calciner unitNo. 3 (105.1 tons per hour nominal feed);coal/coke / residual oil-fired203 10/1/1966 TRUE Y -- -- 68.50 138.28 72.000.020.20 0.44339-054vertical fluidized bed phosphate rock calciner unitNo. 4 (105.1 tons per hour nominal feed);coal/coke / residual oil-fired204 10/1/1966 TRUE Y -- -- 55.01 138.28 48.790.010.20 0.44339-055vertical fluidized bed phosphate rock calciner unitNo. 5 (105.1 tons per hour nominal feed);coal/coke / residual oil-fired205 1/1/1976 TRUE Y -- -- 58.07 138.28 38.150.010.20 0.44339-056vertical fluidized bed phosphate rock calciner unitNo. 6 (105.1 tons per hour nominal feed);coal/coke / residual oil-fired206 1/1/1976 TRUE Y -- -- 71.11 138.28 67.730.020.20 0.44332-120Residual oil-fired phosphate rock dryer (250 tonsper hour nominal capacity)210 1/1/1966 TRUE Y -- -- 1.30 149.36 1.50 235.43 0.00 13.69 0.01 0.74341-300Coal/coke pulverizer and thermal dryer system (20tons per hour nominal capacity)215 1/1/1983 FALSEBelt 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 Baghouse221 1/1/1974 TRUE Y-- -- -- -- 1.80 1.80 -- -- -- --8Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpyBelt 21 to Belt 23 orBelt 24Storage silo baghouse 222 1/1/1966 TRUE Y -- -- -- -- 1.30 1.31 -- -- -- --Belt 22 to Belt 23 orBelt 24Storage silo baghouse339-809-464 Calcined/dried rock CTS (Fugitive)223 1/1/1966 TRUE Y -- -- -- -- 1.20 3.46 -- -- -- --224One (1) polymer storage bin224 1/1/1996 FALSE225One (1) lime storage silo225 1/1/1985 FALSEF290Mill Concentrator Fugitives 2907/1/1966TRUENF291Calciner Plant Area Fugitives291 7/1/1966 TRUE Y -- -- -- -- 0.11 0.11 -- -- -- --F292Surge Pond Aerator292 7/1/1966 TRUE N341-100Coal/coke railcar unloader (75 tons per hournominal capacity)294a 1/1/1983 FALSE341-110, 341-111,341-112, 341-120Three (3) parallel conveyor belts which transfer toone (1) single belt conveyor294b 1/1/1983 FALSE341-140Single belt conveyor294c 1/1/1983 FALSE341-130Coal/coke crusher (75 tons per hour nominalcapacity)294d 1/1/1983 FALSE341-200 341-201 Two (2) coal/coke storage silos (1086 tons,nominal capacity each)294e 1/1/1983 FALSE341-230One (1) conveyor belt294f 1/1/1983 FALSEFertilizer Production Area9Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpy504-107 504-016 Diammonium Phosphate Plant No. 1 combustionchamber and residual oil-fired dryer (Nominalmaximum input rates of 618 tons fresh P2O5 and275 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 0.18504-009 504-001504-058 504-059504-060 504-061504-043 504-042504-002Diammonium Phosphate Plant No. 1 cooler andmaterial sizing and handling equipment (processscreen feed drag conveyor, four (4) double-deckedprocess screens, east cage mill, west cage mill,and recycle drag conveyor)301504-016 504-009 Diammonium Phosphate Plant No. 1 residual oilfired dryer(20 millionBtu per hour nominalmaximum heat input) and a cooler301504-030 504-032 Diammonium PhosphatePlant No. 1 reactor andgranulator301504-030301504-032504-016504-019Diammonium Phosphate Plant No. 1 reactor,granulator, residual oil-fired dryer and cooler.511-085 511-086511-070Diammonium Phosphate Plant No. 3 first stagereactor, second stage reactor, and granulator302 7/1/1974 TRUE Y 149.50 453.13 17.29 60.71 14.29 58.15 0.64 160.50 0.04 0.31302511-032Diammonium Phosphate Plant No. 3 residual oilfired dryer511-008 511-009511-010 511-011511-016 511-017511-038 511-039511-041 511-093511-094 511-095511-096Diammonium Phosphate Plant No. 3 processsizing and handling equipment (four (4) chainmills, screen feed dragconveyor, recycle dragconveyor, recycle elevator, dryer elevator, productelevator, and four (4) double-deck productscreens)302511-025Diammonium Phosphate Plant No. 3 cooler andother miscellaneous material handling points30210Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpy511-107B 511-103511-104 511-106Diammonium Phosphate Plant No. 3 cyclonicscrubber, the two stage dryer wet cyclonicscrubber, the dust wet cyclonic scrubber, and thecooler wet cyclonic scrubber302505-104Diammonium Phosphate Plant No. 2 residual oilfired dryer303505-107 505-114505-110 505-143Diammonium Phosphate Plant No. 2 materialsizing and handling equipment (eight (8) processscreens, one (1) scalpingscreen, one (1) recycledrag conveyor, and a product bin)303505-111Diammonium Phosphate Plant No. 2 cooler303505-123C 505-123B Diammonium Phosphate Plant No. 2 equipmentcyclone and cooler duplex cyclone303505-103 505-121 Diammonium Phosphate Plant No. 2 granulatorand reactor303505-117 505-118 Diammonium Phosphate Plant No. 2 coolerventuri wet scrubber and reactor-granulatorventuri wet scrubber3031/1/1980 FALSEAPP-1Ammonium Polyphosphate Plant304 1989 FALSEAFP-1One (1) filter press305 2003 FALSE511-045Diammonium Phosphate Plant No. 3 GTSPphosphate rock silo310 3/1/1976 TRUE Y -- -- -- -- 0.52 4.51 -- -- -- --PA Pilot No. 1 Phosphoric Acid Pilot Plant No. 1315 1978 FALSEPA Pilot No. 2 Phosphoric Acid Pilot Plant No. 2316 1978 FALSE318Technical Services Dust Collection System318 9/1/1979 FALSE11Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpySuperphosphoric Acid Production Area451-418 and 451-409Superphosphoric acid plant No. 1 330 11/1/1966 TRUE Y -- -- -- -- -- -- 0.49 5.48 -- --451-701 and 451-809Superphosphoric acid plant No. 2 331 1/1/1971 TRUE Y -- -- -- -- -- -- 1.33 9.13 -- --451-316 and 451-308Superphosphoric acid plant No. 3 332 1/1/1976 TRUE Y -- -- -- -- -- -- 0.54 18.25 -- --451-916 and 451-940Superphosphoric acid plant No. 4 332FPR-1FPR-2No. 1 filter press/filter press repulp tank and No. 2filter press/filter press repulp tank335 and 336 9/1/1985 FALSE453-485One (1) potassium permanganate silo340 3/1/1990 FALSE453-468One (1) clay additive storage silo341 3/1/1990 FALSEDAP1WH1 Warehouse No. 1 for DAP 1390 1/1/1967 TRUE Y 33.90 33.90 -- -- -- -- -- -- -- --DAP2WH2 Warehouse No. 2 for DAP 2390DAP3WH3 Warehouse No. 3 for DAP 3390Fertilizer Plant Area Fugitives391, 3921/1/1967 TRUE Y 20.72 20.72 -- -- -- -- -- -- -- --Phosphoric Acid Production Area421-201 421-000421-325 421-324421-327 421-326421-223 421-232421-218 421-330Reactor Train No. 1; tiltingpan (Bird) filter No. 1;tilting pan (Bird) filter No. 1 primary vacuumpump installed on primary vacuum separator;secondary vacuum pump installed on secondaryvacuum separator; (2) barometric condensersvacuum pumps; barometric condensers hotwell;and tilting pan (Bird) filter No. 1 seal tanks.401 12/1/1966 TRUE Y -- -- -- -- -- -- 21.70 88.70 -- --441-000Belt filter No. 1402 4/1/1981 FALSE441-000 442-000441-031Belt filter No. 1, belt filter No. 2, and belt filterNo. 1 seal tanks403 4/1/1981 FALSE12Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpy422-201 422-000422-325 422-324422-327 422-326422-223 422-232422-218 422-330Reactor Train No. 2; tiltingpan (Bird) filter No. 2;tilting pan (Bird) filter No. 2 primary vacuumpump installed on primary vacuum separator;secondary vacuum pump installed on secondaryvacuum separator; (2) barometric condensersvacuum pumps; barometric condensers hotwell;and tilting pan (Bird) filter No. 2 seal tanks.404 12/1/1966 TRUE Y -- -- -- -- -- -- 26.40 88.70 -- --442-000Belt filter No. 2 filtrate separator405 12/1/1985 FALSE423-201 423-000423-325 423-324423-327 423-326423-223 423-232423-218 423-330Reactor Train No. 3; tiltingpan (Bird) filter No. 3;tilting pan (Bird) filter No. 3 primary vacuumpump installed on primary vacuum separator;secondary vacuum pump installed on secondaryvacuum separator; (2) barometric condensersvacuum pumps; barometric condensers hotwell;and tilting pan (Bird) filter No. 3 seal tanks.406 1/1/1972 TRUE Y -- -- -- -- -- -- 34.10 175.20 -- --443-000Belt filter No. 3 filtrate separator407 9/1/1986 FALSE443-000 444-000444-031Belt filter No. 3, belt filter No. 4, and belt filterNo. 4 seal tanks408 9/1/1986 FALSE424-201Y -- -- -- -- -- -- 14.10 102.60 -- --428-753424-000 424-325424-324 424-327424-326 424-223424-232 424-218424-330Reactor Train No. 4; fluosilicic acid (H2SiF6)recycle tank; tilting pan (Bird) filter No. 4; tiltingpan (Bird) filter No. 4 primary vacuum pumpinstalled on primary vacuum separator; secondaryvacuum pump installed on secondary vacuumseparator; (2) barometric condensers vacuumpumps; barometric condensers hotwell; and tiltingpan (Bird) filter No. 4 seal tanks.40910/1/1975TRUE13Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpy444-000Belt filter No. 4410 10/1/1980 FALSE040 and 020 Two (2) phosphoric acid storage tanks421 10/1/1980 FALSE032, 033, 034, 060,and 035Four (4) phosphoric acid storage tanks and one (1)green acid sludge tank422 12/1/1980 FALSE429-002 421-115 Two (2) phosphate rock jet conveyors on reactortrain No. 1430 1/1/1988 FALSE429-005 422-115 Two (2) phosphate rock jet conveyors on reactortrain No. 2431 4/1/1988 FALSE429-152 429-001429-004 429-151Phosphate rock storage silo No. 1 and three (3)transfer points434 7/1/1985 FALSE429-150 Phosphate rock transfer house437 12/1/1966 TRUE Y -- -- -- -- 2.39 1.20 -- -- -- --426-156 433-158433-165One (1) slurry mix tank, one (1) clarifier, and one(1) defluorinated acid pump tank450 5/1/1993 FALSE426-154One (1) diatomaceous earth silo451 4/1/1980 FALSEES461ES462One (1) phosphoric acid recirculation watercooling tower consisting of two (2) fans461 and 462 7/1/1992 FALSENonePhosphoric Acid PlantFugitives 4911/1/1966TRUEN30N31428-440428-442433-182Two (2) phosphoric acid storage tanks (phosphoricacid tank farm), two (2) HFSA tanks, and one (1)carbon slurry tank4921/1/1966TRUEPurified Acid Production AreaAll sources1989, 2002 FALSEDFP Production AreaAll sources2001 FALSEShipping AreaAmmoniaUnloadingAmmonia Railroad Unloading 601, 602,and 6031/1/1966 TRUE Y 47.17 47.17 -- -- -- -- -- -- -- --Ammonia Tanks Ammonia Storage Tanks604 and 605 1/1/1981 FALSESulfur Unloading Sulfur Railroad Unloading610, 611,612, 613,and 6141/1/1966 TRUE NRailcar Wash 1 Railcar Wash Station No. 1615 1/1/1966 TRUE N14Emission SourceID No.Emission Source DescriptionEmissionPoint IDNo.Date ofOperationBARTEligible?Emits BARTCompounds?NH3 2002Actual,tpyNH3PTE, tpyNOx 2002Actual,tpyNOxPTE, tpyPM102002Actual,tpyPM10PTE, tpySO2 2002Actual,tpySO2 PTE,tpyVOC2002Actual,tpyVOCPTE, tpyT-002 to T-012 T014 to T-019Y 1.06 1.06 -- -- -- -- -- -- 5.30 21.2T-021 to T-029T-44T-050 to T-052T-054 to T-056Thirty-three (33) phosphoric acid storage tanks(shipping tank farm)616453-458One (1) superphosphoric acid aging tank (shippingtank farm)616AT2One (1) superphosphoric acid aging tank (shippingtank farm)616497-4-105One (1) superphosphoricacid and clay additivemix tank (shipping tank farm)616No. 1 filter press feed tankNo. 2 filter press feed tank and453-115 453-412No. 3 filter press feed tank616VSEP Tank One (1) 5,000 gallon VSEP feed tank616Black Lomag One (1) 110,000 gallon Black Lomag tank616Permeate Tank One (1) 1,000 gallon permeate tank616Concentrate Tank One (1) 1,000 gallon concentrate tank616552-003552-005552-050Three (3) liquid sulfur storage tanks6161/1/1966TRUERailcar Wash 2 Railcar Wash Station No. 2617 1/1/1966 TRUE NF650 CTS - Grinder Rock Loadout650 1/1/1966 TRUE Y -- -- -- -- 0.00 0.07 -- -- -- --F651 CTS - Grinder Rock Loadout651 1/1/1966 TRUE Y -- -- -- -- 0.00 0.07 -- -- -- --F652 Rock Loadout Transfer Station652 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 -- -- -- --F654Rock Tower Loadout facility654 1/1/1966 TRUE Y -- -- -- -- 0.00 1.13 -- -- -- --F655 Chute-Barge Rock Loadout655 1/1/1966 TRUE Y -- -- -- -- 0.00 4.01 -- -- -- --F656 Chute-Train Rock Loadout656 1/1/1966 TRUE Y -- -- -- -- 0.00 9.70 -- -- -- --Miscellaneous Sources214-613Mine Pit Diesel Generator801 2001 FALSE326-800-484 Calciner Building Diesel Generator802 notinstalledFALSESum309 743 447 1,232 336 903 1,112 3,825 7 27

### 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

### 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 F ugitives 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 Fugitiv es 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

### 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 Plan t 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

### 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

### 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 SO 2 

### 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 . Theinterest 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

### 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.

### 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.

### 22 PCS Phosphate Response

We have attached information received from vendors.

### 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 SO 2 

### emissions from Sulfuric Acid Plants 3 and 4 from 3.8 lb SO 2 

### /ton H 2 

### SO 4 

### to 3.5 lb

SO 2 

### /ton H 2 

### SO 4 

### . EPA’s Comment # 2 in Enclosure 1 indicates that use of the cesium catalyst could reduce SO 2 

### emission rates to between 2.0 and 3.5 lb

SO 2 

### /ton H 2 

### SO 4. 

### 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 SO 2 

### emission rate of 2.0 lb SO 2 

### /ton H 2 

### SO 4 

### 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 app ears 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

### 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, 1 st 

### 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

### 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,

1 st



### 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 98 th 

### 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

### 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.

### 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.

### 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.

### 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.

### PCS Phosphate BART determination



## APPENDIX B

Public Notice for BART Title V Air Permit Modification

### 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 Qu ality (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 determinati ons 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, 1 st 

### 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 re views 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

### 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 a dditional 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

### PCS Phosphate BART determination



## APPENDIX C

Draft Air Permit Language

### ????, 200?

Mr. 

### Richard Atwood 

## DRAFT Plant Manager PCS Phosphate Company, Inc. Aurora, North Carolina 27806

Dear Mr. 

### Atwood :

SUBJECT: Air Quality Permit No. 04176T 3? 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 ).

### 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 modifica tion 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? un til 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

### 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

## 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 r eceived 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

### 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

### Permit 04176T3? DRAFT Page 3



# PART I

The Division of Air Quality (DAQ), th e United States Environmental Protec tion Agency (EPA), and citizens as

defined under the Federal Clean Air Ac t have the authority to enforce th e 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 base d on plans, specifications, ope rating 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 H 2 

### SO 4 

### Mist; double-absorption is

control for SO 2 

### 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

### 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

### 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

### 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 tailgas scrubber with saddletype packing and demister pads: all

installed in a series 303

### 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 tailgas 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 tailgas 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 tailgas 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

### 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 sh ield described in Genera l Condition R does not apply.

### 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

### 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

### 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

### 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, ES 425, CD 438-200, and CD TBD) are listed as 502(b)(10) changes

per NCAC 2Q .0523. The permit shield desc ribed in General Condition R does not apply.

### 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)

### 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

### 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

### 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

### 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) modifica tion. The permit shield described in General Condition R of Pa rt I of the permit does not apply to these sources. The Permittee shall not begin operation of the air emission source(s) and associ ated air pollution control device(s) listed in Section 1 until a Title V Ai r Quality Permit Application is filed and an operation permit is obtained following the procedures of Section .0500 (except for Rule .0504 of this Section).

### 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

### 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

370-148A463 Product screen discharge

conveyor 370-120-

478 One (1) fabric filter 717

370-148B463 Classifier 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

### 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

### 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)

### 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

### Permit 04176T3? DRAFT 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.

### Permit 04176T3? DRAFT Page 24



## 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

### Permit 04176T3? DRAFT Page 25

1. 15A NCAC 2D. 0501(e) : COMPLIANCE WI TH 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 Pe rmittee 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 demons trate 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 th e 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 sha ll 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 tes ting shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and Genera l 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 sulfur ic 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 approve d 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 standa rd contained in 2.a above.

### Permit 04176T3? DRAFT Page 26

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 NC AC 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 s ources 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 Perm ittee 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 a bove 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 c oncise description of the and sulfuric acid testing requirements in one place the details be low 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 aver aged to calculate the averag ed 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 dete rmined 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 tw o 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 th at 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

### 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 elect ronic 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 (w ritten 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 th e 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 observe d 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 m onitoring 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

.

### Permit 04176T3? DRAFT 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 th e 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 calenda r 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 be tween 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 s hould 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 th e 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 SO 2 monitor indicates compliance. Because production rate is difficult to measure during start-up, if a more appropriate indicator (such as blower pressure, furnace temperatur e, 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. Im plementation 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 th e 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 em it excess emissions from start-up for a period of three consecutive hours provided best operati onal practices, in acco rdance with this agreement, to minimize emissions are followed. No plant shall be operated (with sulfur as fuel) out of compliance for more than th ree consecutive hours. Thereafter, the plant shall be shut down. The plant shall be s hut 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

### Permit 04176T3? DRAFT Page 29

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 cat alyst 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 improveme nt 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

### Permit 04176T3? DRAFT Page 30

Sulfuric acid plant No. 3 ( ID No. S-3) {Source ID No. 102} sulfuric acid

mist/TSP/PM 10 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/PM 10 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 submitte d 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 de scribed 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 modificati on as submitted in A0700071.02B.

Testing [15A NCAC 2Q .0508 (f)] e. If emissions testing is required, the Pe rmittee 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.

### Permit 04176T3? DRAFT Page 31

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 th e 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 a pproved application for an air toxic compliance

demonstration and in addition to other limits de scribed 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 Pe rmittee 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 protoc ol 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 th e 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 st andards 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 m illion Btu heat input 2D .0516

fuel oil sulfur content limit of 0.5 percent * 2D .0524 (Subpart Dc )

### Permit 04176T3? DRAFT Page 32

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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound 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 sour ces 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound 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. Howe ver, six-minute averaging peri ods 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)]

### Permit 04176T3? DRAFT Page 33

Testing [15A NCAC 2D .0501(c)(4) ] b. If emissions testing is require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.1.B.4.a. above, the Pe rmittee 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 mo re 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound 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 samp le of all shipments received per month. The results of the fuel oil supplier certifications sh all 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 th e fuel oil received during the quarter;
iii. the method used to determine the maxi mum 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 th e preceding six-month period between July and December and July 30 of each calendar year for the preceding six### Permit 04176T3? DRAFT Page 34

month period between January and June. Th e 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.1.B.5.a. above, the Pe rmittee 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 samp le of all shipments received per month. The results of the fuel oil supplier certifications sh all 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 th e fuel oil received during the quarter;

iii. the method used to determine the maxi mum 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 enfo rceability 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 peri od between October and December, April 30 of each calendar year for the preceding three-month period between January a nd March, July 30 of each calendar year for the preceding three-month period between April a nd June, and October 30

### Permit 04176T3? DRAFT Page 35

for the calendar year for the preceding three-m onth 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 pe riods 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 t reatment area) {Source ID Nos. 121, 122, and 123}

The following table provides a summary of limits and st andards 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 sour ce 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.1.C.1.a. above, the Pe rmittee 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 inspec tions and maintenance as recommended by the

### Permit 04176T3? DRAFT Page 36

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) intern al 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 au thorized 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 recomme ndations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.1.C.2.a. above, the Pe rmittee 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 tw o (2) fixed throat vent uri type wet scrubbers (430 gallons per minute minimum pe rmitted liquid injection rate pe r 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}

### Permit 04176T3? DRAFT Page 37

Four (4) duplex cyclones exhausting two each to tw o (2) fixed throat vent uri type wet scrubbers (430 gallons per minute minimum pe rmitted liquid injection rate pe r 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 thro at 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) we t 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 st andards 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 P 0.11 

### 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 pe r 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 WI TH 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 sh all be limited to 1992 pounds per day of PM10

emissions total. ii. Each calciner shall be limited to 0.75 pounds of sulfur dioxide em issions per million Btu

consumed. iii. All calciners considered together sha ll be limited to 1026 pounds per day of sulfur
dioxide emissions.

### Permit 04176T3? DRAFT Page 38

Testing [15A NCAC 2Q .0501 (c)(4)] b. If emissions testing is required, the Permittee shall perform such te sting in accordance with
General Condition JJ. If the results of this test ar e 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 fo r 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 testi ng 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 ra te using the production records over the last production year. A copy of th e 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 requireme nts can be found in Sec tion 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 re quest. 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 Perm ittee shall monitor the sulf ur 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 certifica tion 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 Perm ittee shall monitor the sulf ur 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;

### Permit 04176T3? DRAFT Page 39

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 th e 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 (w ritten or electronic format) the following: i. a daily record of phosphate rock feed by dete rmining 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 PHOSPO RIC 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 sh all 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, th e Permittee shall verify the allowable minimum secondary voltage for the WESP’s as described belo w by annually testing the calciners for PM/ PM-10 in accordance with a testing protocol approved by th e 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 calcine r by the number of hours that calci ner was run during that year. The normal production rate for the source test must be approved by the Divi sion 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 c opy 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

### Permit 04176T3? DRAFT Page 40

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 (w ritten or electronic format) the following: i. a daily record of phosphate rock feed by dete rmining 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 w ith 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 Permitt ee has submitted the results of previous tests to demonstrate allowed ranges for the parameter valu es 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 perfo rmance 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 perm ittee shall be deemed in non-compliance with 15A

NCAC 2D .1111 :

i. Performance test report. As required by §63.10, th e owner or operator shall report the results of the initial and annual performance tests as part of the no tification of compliance st atus 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 cont rol 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

### Permit 04176T3? DRAFT Page 41

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 sour ce 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 give n 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 th e 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 sha ll 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 aut horized 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 recomme ndations, 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 si x-month period between July and December and July 30 of each calendar year for th e 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)]

### Permit 04176T3? DRAFT Page 42

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 averagedover 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 deem ed 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 sh all 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 th e 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 app lication for an air toxic compliance demonstration
and in addition to other limits desc ribed 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 testi ng in accordance with 15A NCAC 2D .0501(c)(4) and Ge neral Condition JJ. If the results of th is 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 (w ritten 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 si x-month period between July and December and July 30 of each calendar year for th e preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified.

### Permit 04176T3? DRAFT Page 43



## 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 P 0.11 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): COMP LIANCE 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 Perm ittee shall perform such te sting 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

SO 2 emitted per pound of sulfur contained in the fuel oil burned as described below by testing the rock dryer ( ID No. 210 ) for SO 2 and recording the fuel oil ch aracteristics and use in accordance with a testing protocol approved by the DAQ. De tails 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 Qu ality in advance of the test. The facility shall es tablish the normal production rate using the production records over the last production year. A copy of the produc tion records must accompany the request. If the annual test shows that the ratio of pounds of SO 2 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.

### Permit 04176T3? DRAFT Page 44

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508 (f)] d. Based on the results of previous stack tests, potential emissions of SO 2 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 PHOSPO RIC 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 te sting 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 aver age 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 pr otocol approved by the DAQ. Details of the emissions testing and requireme nts can be found in Section 3 - General Condition JJ. The rock dryer shall be tested annually at a rate demons trable 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 th e results of this test are above the limit given in Section 2.1.2. B. 2. a above, the Perm ittee 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 (w ritten 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 a ll 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 allo wed ranges for the above operating parameters by the method described in 40 CFR 63.605(d)(2). The Permittee has submitted the results of

### Permit 04176T3? DRAFT Page 45

previous tests to demonstrate allowed ranges fo r 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 perm ittee 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 test s 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 o ccurred, such information shall be included in the report. The report shall be submitte d semiannually and shall be delivered or postmarked by the 30th day following the e nd 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 durati on 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 summa ry 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 syst em 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 sour ce 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.

### Permit 04176T3? DRAFT Page 46

Testing [15A NCAC 2D .0501 (c)(3)] b. If emissions testing is required, the testi ng 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 reco rds 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 complia nce, 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 au thorized 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.2.B.4.a. above, the Pe rmittee 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 fu el 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 recei ved. The results of the fuel oil supplier

### Permit 04176T3? DRAFT Page 47

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 th e fuel oil received during the quarter;

iii. the method used to determine the maxi mum 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 cal endar 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. Howe ver, 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 aver age exceed 90 percent opacity. [15A NCAC 2D .0521(c)]

Testing [15A NCAC 2D .0501(c)(8)] b. If emissions testing is require d, 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 Permitt ee shall observe the emission points of this source for any visible emissions above nor mal. The Permittee shall estab lish “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 sha ll 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 demonstra tion 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) si ngle 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 st andards 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 En forceable Only NCAC 2D .1100

### Permit 04176T3? DRAFT Page 48

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 sh all not contain more than 0.031 grains per dscf of particulate matter.

c. Visible emissions shall not be more than 20 pe rcent opacity when aver aged over a six-minute period.

Testing [15A NCAC 2Q .0501 (c)(4)] d. If emissions testing is required, the Permittee shall perform such te sting 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 te mperature of the gas stream at the exit of the thermal dryer on a continuous basis (CMS). The calibration and calcu lation methods shall be as described in 40 CFR Part 60.253 and approved by th e 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, th e Permittee shall perform inspections and maintenance as recommended by th e 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 in itial inspection) intern al inspection of the bagfilters noting the structural inte grity 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 st andards for the emission source(s) described above:

### Permit 04176T3? DRAFT Page 49

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E=55 x P 0.11 -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 pe rcent opacity when aver aged over a six-minute period.

Testing [15A NCAC 2Q .0501 (c)(4)] c. If emissions testing is required, the Permitt ee shall perform such te sting 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 requi red, but in no case less frequently than an annual inspection of all suppression equipment (incl uding 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)

### Permit 04176T3? DRAFT Page 50

The following table provides a summary of limits and st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E=55 x P 0.11 -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 En forceable 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 sour ce 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

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 give n 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 requi red, but in no case less frequently than an annual inspection of all suppression equipm ent (including hood covers and belt sk irts). 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 mo re than 40 percent opacity when averaged over a six-minute period. Howeve r, 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 sh all 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.

### Permit 04176T3? DRAFT Page 51

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)][40 CFR 60.253(a)] c. The permittee shall perform maintenance as requi red, but in no case less frequently than an annual inspection of all suppression equipm ent (including hood covers and belt sk irts). 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 Poin t - 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 st andards for the emission source(s) described above:
Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E=55 x P 0.11 -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 En forceable 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 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.

Testing [15A NCAC 2D .0501 (c)(3)] b. If emissions testing is required, the testi ng 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 th e 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.

### Permit 04176T3? DRAFT Page 52

d. Particulate matter emissions from the conveyor belt drop point shall be controlled by the bagfilter. To assure compliance, the Permittee shall perfo rm 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) intern al 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 au thorized 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 te sting 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 perfo rm 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) intern al 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 au thorized 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.

### Permit 04176T3? DRAFT Page 53

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 squa re 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E= 4.10 x P 0.67 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 En forceable Only NCAC 2D .1100

1.

. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES Emission Standard a. Emissions of particulate matter from this sour ce 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 testi ng 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 inspec tions 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) intern al 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 au thorized 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 recomme ndations, 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)]

### Permit 04176T3? DRAFT Page 54

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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 te sting 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

64.1 pounds per hour 238.5 tons per year 2D .0530 (BACT) PM/PM10

E=9.377 x P 0.3067 where E = allowable emission rate in pounds per hour and P = production and recycle rate of

fertilizer 2D .0507

15 pounds per hour 2D .0530 (BACT) sulfur dioxide

2.3 pounds per million Btu 2D .0516

visible

emissions 20 percent opacity 2D .0521

### Permit 04176T3? DRAFT Page 55

0.055 pounds per ton of equivalent P 2 O 5 feed 2D .1100 (State only)

0.060 pounds per ton of equivalent P 2 O 5 feed 40 CFR 63 Subpart BB Total

Fluorides

0.058 pounds per ton of equivalent P 2 O 5 feed 2D .0530 (BACT)

TAPS see 2.2 2D.1100

2.1.3.B.1.

. 40 CFR PART 63 SUBPART BB: NAT IONAL 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 in to the atmosphere from any affected source any gases which contain total fluorides in excess of 30 grams/metric ton equivalent P 2 O 5 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 te sting 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 w ith 40 CFR 63.626. Details of the emissions testing and requirements can be found in Section 3 - General C ondition 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 re quirements 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.

### Permit 04176T3? DRAFT Page 56

f. The permittee shall maintain a daily record of equivalent P 2 O 5 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 manuf acturer 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 manufact urer 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 allo wed 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 allo wed ranges for the parameter values listed above in (f). The allowed ranges are:

i. Reactor/Granulator/Tailgas Scrubber -Pre ssure 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 sc rubber - Pressure drop: 7.0 to 18.4 inches of water Flowrate: 660 to 989 gpm(Upon addition of high mole saturation chambe r and conversion of

this unit to Low mole scrubber th is 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 perfo rmance 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 ha ve 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 perm ittee 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 pa rt 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 an y exceedance of an operating parameter limit. The report shall contain the information speci fied in §63.10. When no exceedances of an operating parameter have occurred, such inform ation shall be included in the report. The report shall be submitted semiannually and shall be delivered or postmarked by the 30th day

### Permit 04176T3? DRAFT Page 57

following the end of the calendar half. If exceedan ces 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 c ontrol 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, a nd 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 previ ous (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 a ddresses an event that m eets 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 sour ce shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC 2D .0507]

E = 9.377 x P 0.3067 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 testi ng 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.

### Permit 04176T3? DRAFT Page 58

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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound 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 fu el 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 incl ude the following information: i. the name of the fuel oil supplier;

ii. the maximum sulfur content of th e fuel oil received during the quarter;

iii. the method used to determine the maxi mum 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 cal endar 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 aver age exceed 90 percent opacity. [15A NCAC 2D .0521(c)]

Testing [15A NCAC 2D .0501(c)(8)] b. If emissions testing is require d, 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 deem ed in noncompliance with 15A NCAC 2D .0521.

Monitoring [15A NCAC 2Q .0508(f)] c. To assure compliance, once a month the Permitt ee shall observe the emission points of this source for any visible emissions above nor mal. The Permittee shall estab lish “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 sha ll 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

### Permit 04176T3? DRAFT Page 59

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 WI TH 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 te sting 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 pr otocol approved by the DAQ. Details of the emissions testing and re quirements 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 re quest. 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 P 2 O 5 feed Diammonium Phosphate Plant No. 2 TSP/PM 10 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

### Permit 04176T3? DRAFT Page 60

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 Permitt ee shall perform such te sting 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 re quirements can be found in Section 3 - General Condition JJ. If the results of this test are above the limits given above, th e 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 te st 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 sc rubber, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 appr oved application for an air toxic compliance

demonstration and to insure that limits desc ribed in Section 2.2.A.3 are not exceeded, the following operational limit shall not be exceeded: The equivalent P 2 O 5 feed rate to the Diammonium Phosphate Plant No. 2 (Emission Point ID No. 303) shall not exceed 2563 tons per calenda r day when producing MAP or DAP. [15A NCAC 2Q .0501 (c)(4)] a. If emissions testing is required, the Permittee shall perform such testi ng 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)]

### Permit 04176T3? DRAFT Page 61

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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 st andards 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 P 0.3067 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 P 2 O 5 feed (during DAP or MAP production) 40 CFR 63 Subpart BB

0.150 pounds per ton of equivalent P 2 O 5 feed (during GTSP production) 40 CFR 63 Subpart BB

0.058 pounds per ton of equivalent P 2 O 5 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 P HOSPORIC FERTILIZER PRODUCTION
PLANTS 15a NCAC 2D .1111: Maximum Achievable Control Technology –

Emission Standard

a. The Permittee shall not cause to be discharged in to the atmosphere from any affected source any gases which contain total fluorides in excess of:

### Permit 04176T3? DRAFT Page 62

i. 30 grams/metric ton equivalent P 2 O 5 feed (0.060 pounds/ton) during either monoammonium phosphate(MAP) or diammonium phosphate (DAP) production [63.622 (a)] ii. 75 grams/metric ton equivalent P 2 O 5 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 te sting 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 monoammoni um phosphate process line in accordance with 40 CFR 63.626. Details of the emissions testing and requireme nts can be found in Sec tion 3 - General Condition JJ. The fertilizer plant (Emission Point ID No. 302) sh all 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 ra te 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 gi ven 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 re quirements 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 superphos phate 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 th e 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 requi rements can be found in Section 3 - General Condition JJ. If the

results of this test are above the emission standa rd 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 P 2 O 5 feed by first determining the total mass rate in short ton/hour of phosphorus bearing feed using a monitoring system for measuring

### Permit 04176T3? DRAFT Page 63

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 manuf acturer 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 manufact urer 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 allo wed 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 para meter 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 dr op: 3.4 to 5.1inches of water Flowrate: 1066 to 1600 gpm Should the results of any subsequent annual perfo rmance 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 ha ve 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 perm ittee 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 test s 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 an y exceedance of an operating parameter limit. The report shall contain the information speci fied in §63.10. When no exceedances of an operating parameter have occurred, such inform ation shall be included in the report. The report shall be submitted semiannually and sha ll 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.

### Permit 04176T3? DRAFT Page 64

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, a nd 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 previ ous (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 a ddresses an event that m eets 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 sour ce shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC 2D .0507]

E = 9.377 x P 0.3067 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 testi ng 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

### Permit 04176T3? DRAFT Page 65

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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.3.C.3.a.. above, the Pe rmittee 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 fu el 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. Th e results of the fuel o il supplier certifications shall be recorded in a logbook (written or electr onic format) on a quarterly basis and include the following information: i. the name of the fuel oil supplier;
ii. the maximum sulfur content of th e fuel oil received during the quarter;

iii. the method used to determine the maxi mum 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 cal endar 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 aver age exceed 90 percent opacity. [15A NCAC 2D .0521(c)]

Testing [15A NCAC 2D .0501(c)(8)] b. If emissions testing is require d, 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 Permitt ee shall observe the emission points of this source for any visible emissions above nor mal. The Permittee shall estab lish “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 sha ll 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 demonstra tion in (b) above cannot be made during the

### Permit 04176T3? DRAFT Page 66

monitoring period, the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D

.0521.

5. 15A NCAC 2D. 0501(e): COMPLIANCE WI TH 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 te sting 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 (w ritten 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

### Permit 04176T3? DRAFT Page 67

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 Perm ittee shall perform such te sting 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 re quirements can be found in Section 3 - General Condition JJ. If the results of this test are above the limits given above, th e 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 w ith 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 accord ance with the approved app lication 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 P 2 O 5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point ID No. 302) shall not exceed 714 tons per cal endar day when producing GTSP. The equivalent P 2 O 5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point ID No. 302) shall not exceed 1188 tons per cal endar day when producing MAP. The equivalent P 2 O 5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point ID No. 302) shall not exceed 1188 tons per cal endar day when producing DAP. The equivalent P 2 O 5 feed rate to the Diammonium Phosphate Plant No. 3 (Emission Point ID No. 302) shall not exceed 840 tons per cal endar day when producing PAPR.

Testing [15A NCAC 2Q .0501 (c)(4)]

### Permit 04176T3? DRAFT Page 68

b. If emissions testing is required, the Permittee shall perform such testi ng 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 (writte n 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 ra tes 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 st andards 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 P 2 O 5 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-mi nute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)]

Testing [15A NCAC 2D .0501(c)(8)] b. If emissions testing is required, the tes ting shall be performed in accordance with 15A NCAC 2D .0501(c)(8) and Genera l 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 Perm ittee 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:

### Permit 04176T3? DRAFT Page 69

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 sha ll 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 Sour ce 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 tes ting shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and Genera l 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

### Permit 04176T3? DRAFT Page 70

not exceeded, the equivalent P 2 O 5 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 Perm ittee shall perform such te sting in accordance with 15A NCAC 2D .0501(c)(4) and Ge neral 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 th e 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 in stances of deviations from the requirements of this permit must be clearly identified.



### 2.1.3.E. GTSP Rock Storage Silo

- controlled by fabric f ilter Emission Source ID 511-045 (Emission Point ID No. 310)

The following table provides a summary of limits and st andards 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

E mission 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 testi ng shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ found in S ection 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.

### Permit 04176T3? DRAFT Page 71

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 inspec tions 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 reco mmendations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for th e 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 op acity when averaged over a six-minute period. Howe ver, six-minute averaging peri ods 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 per cent opacity. [15A NCAC 2D .0521 (d)]

Testing [15A NCAC 2D .0501(c)(4) ] b. If emissions testing is required, the testi ng shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ found in S ection 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)

### Permit 04176T3? DRAFT Page 72

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 P 2 O 5 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 PHOSPO RIC 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 P 2 O 5 feed (0.010 pound/ton).

Testing [15A NCAC 2Q .0501 (c)(4)] b. If emissions testing is required, the Permittee sh all perform such testing in accordance with General

Condition JJ. If the results of this test are above th e 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 a nd 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 Cond ition JJ. Each superphosphoric acid plant (Emission Point ID No. 330, or 331) shall be te sted 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 fu ture 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.

### Permit 04176T3? DRAFT Page 73

e. The permittee shall maintain a daily record of equivalent P 2 O 5 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 pa ragraph (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 manufact urer 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 ma nufacturer 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 allowe d ranges for the above operating parameters by the method described in 40 CFR 63.605(d)(2). The Permitt ee has submitted the results of previous tests to demonstrate allowed ranges for the parameter valu es 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 perform ance 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 perm ittee 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 pa rt 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 an y exceedance of an operating parameter limit. The report shall contain the information speci fied in §63.10. When no exceedances of an operating parameter have occurred, such inform ation 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 exceedan ces 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 c ontrol 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

### Permit 04176T3? DRAFT Page 74

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, a nd 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 previ ous (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 a ddresses an event that m eets 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 WI TH 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 te sting 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 superphos phoric acid plant (Emission Point ID No. 330, 331, or 332) annually for sulfur dioxide in accord ance with a testing protocol approved by the DAQ. Details of the emissions testing and re quirements can be found in Section 3 - General
Condition JJ. If the results of this test are a bove 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

### Permit 04176T3? DRAFT Page 75

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 st andards for the emission source(s) described above
Regulated

Pollutant Limits/Standards Applicable Regulation

sulfur dioxide 400 pounds per day (combi ned Plant Nos. 3 and 4) 2D .0530 BACT

Total

Fluorides 0.010 pounds per ton of equivalent P 2 O 5 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: NAT IONAL EMISSIONS STANDARDS FOR

HAZARDOUS AIR POLLUTANTS FROM PHOSPORIC ACID MANUFACTURING

PLANTS A NCAC 2D .1111: Maximum Achievable Control Technology

Em ission 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 P 2 O 5 feed (0.010 pound/ton).

Testing [15A NCAC 2Q .0501 (c)(4)] b. If emissions testing is required, the Permittee shall perform such te sting 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 acco rdance with 40 CFR 63.626. Details of the emissions testing and require ments can be found in Secti on 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 fac ility 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 st andard 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

### Permit 04176T3? DRAFT Page 76

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 P 2 O 5 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 requireme nts 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-mi nute block averages. The monitoring system shall be certified by th e 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 th e process scrubbing syst em in 15-minute block averages. The monitoring system shall be certified by the manuf acturer 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 allo wed 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 para meter 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 perfo rmance 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 fo r 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 perm ittee 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 test s 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 occu rred, such information shall be included in the report. The report shall be submitted semia nnually and shall be delivered or postmarked by the 30th day following the end of the cal endar 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

### Permit 04176T3? DRAFT Page 77

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, a nd 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 previ ous (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 a ddresses an event that m eets 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 P 2 O 5 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

### Permit 04176T3? DRAFT Page 78

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 Perm ittee shall perform such te sting 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 approve d 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 st andards 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

### Permit 04176T3? DRAFT Page 79

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: PARTICUL ATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES

Emission Standard a. Emissions of particulate matter from this sour ce 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.4.D.1.a. above, the Pe rmittee 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 inspec tions 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) intern al 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 au thorized 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 recomme ndations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations from the requirements of this permit must be clearly identified.

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

### Permit 04176T3? DRAFT Page 80

Emission Standard

a. Visible emissions from the silos shall not be more than 20 percent opacity when averaged over a six-minute period. However, si x-minute averaging periods may exceed 20 percent not more thanonce in any hour and not more than four times in any 24-hour period. In no event shall the sixminute average exceed 87 percent opac ity. [15A NCAC 2D .0521 (d)]

Testing [15A NCAC 2D .0501(c)(4) ] b. If emissions testing is require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound in Section 3. If the results of this test are above the limit given in Section 2.1.1.C.2.a. above, the Pe rmittee 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 st andards 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

total Fluorides 0.0005 lb/hr/ton P 2 O 5 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: NAT IONAL 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 in to the atmosphere from any affected source any gases which contain total fluorides in excess of .0.250 grams/hr/metric ton equivalent P 2 O 5 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)].

### Permit 04176T3? DRAFT Page 81

Testing [15A NCAC 2Q .0501 (c)(4)] c. If emissions testing is required, the Permitt ee shall perform such te sting in accordance with
General Condition JJ. If the results of this test ar e 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 NC GS 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 tes ting 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 performan ce 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 producti on 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 P 2 O 5 stored. The Permittee shall maintain a daily record of total equivalent P 2 O 5 stored by multiplying the percentage P 2 O 5 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 speci fic methodology is not submitted.

Reporting [15A NCAC 2Q .0508(f)]

f. If the following reports are not submitted the perm ittee 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

TAPS see 2.2 2D.1100

### Permit 04176T3? DRAFT Page 82



## 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 st andards 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 P 2 O 5 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 P 2 O 5 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: NAT IONAL 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 gase s which contain total fluorides in excess of 10.0 gram/metric ton of equivalent P 2 O 5 feed (0.020 lb/ton). [63.602 (a)]

Testing [15A NCAC 2Q .0501 (c)(4)] b. If emissions testing is required, the Permittee sh all 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 a nd 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 accordan ce with 40 CFR 63.626. Details of the emissions testing and requirements can be found in Sec tion 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 Divi sion 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 mu st accompany the request. If the
results of this test are above the emission standa rd 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 determinati ons 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 P 2 O 5 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 requireme nts 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 manuf acturer 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 manufact urer 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.

### Permit 04176T3? DRAFT Page 84

g. The Permittee has chosen to determine the allowe d ranges for the above operating parameters by the method described in 40 CFR 63.605(d)(2). The Permitt ee has submitted the results of previous tests to demonstrate allowed ranges for the parameter valu es 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 perform ance 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 perm ittee 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 pa rt 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 an y exceedance of an operating parameter limit. The report shall contain the information speci fied in §63.10. When no exceedances of an operating parameter have occurred, such inform ation 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 exceedan ces 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 c ontrol 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 em ission source(s) in accordan ce 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 s oon as practicable after th eir 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 Admi nistrator for the life of the aff ected source or until the affected

### Permit 04176T3? DRAFT Page 85

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 a ddresses an event that meet s 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 even t 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 da y 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 sh all perform such testing in accordance with General
Condition JJ. If the results of this test are above th e 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 di oxide 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 si x-month period between July and December and July 30 of each calendar year for th e 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 P 2 O 5 feed

PA Train No. 1 (ID No.401, 402, 403) Sulfur dioxide Crossflow packed

scrubber 486 pounds per day

### Permit 04176T3? DRAFT Page 86

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 P 2 O 5 feed PA Train No. 3 (ID No. 406, 407, 408) Total Fluorides Crossflow packed
scrubber 0.02 pounds per ton P 2 O 5 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 P 2 O 5 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 su ch 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 Secti on 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 st andard 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 su lfur dioxide given above in accord ance 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 deem ed in noncompliance with 15A NCAC 2D .1111. The results of this testing shall be saved for possi ble 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

### Permit 04176T3? DRAFT Page 87

July and December and July 30 of each calendar year for the preceding si x-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 cont ained in Environmental Management Commission

Standard 15A NCAC 2D .0524 "New Source Perfo rmance 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 P 2 O 5 feed (0.020 pound/ton).

Testing/Monitoring/Recordkeeping/Reporting c. The requirements for testing/M onitoring/Reporting/Recor dkeeping 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 Phosphor ic 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound 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 aci d 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 A ppendix 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 annua l 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 appr oved 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.

### Permit 04176T3? DRAFT Page 88

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 y early 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 P 2 O 5 input rate of 815,217 tons per year, calculate d 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

P 2 O 5 input rate of 981,120 tons pe r year, calculated each month fo r the previous twelve (12) months,

iii. the production of phosphoric acid from uncalcine d rock at Train 4 shall be limited to a P 2 O 5 input rate of 535,000 tons per y ear, 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 th e emission limits above are exceeded (all emissions per ton of P 2 O 5 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 quart er, due and post marked on or be fore 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 Ja nuary and March, July 30 of each calendar year for the preceding three-month period between April a nd June, and October 30 fo r the calendar year for the preceding three-month period between July and Se ptember. 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 P 2 O 5 input rates for calcined and uncalcined rock for the previous fourteen (14)

months and the annual totals for calcined and uncalcined P 2 O 5 input rates for each of the three 12-month periods over the previous 14 months, iii. the daily P 2 O 5 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 app lication 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,

### Permit 04176T3? DRAFT Page 89

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.” Duri ng any given day, however, the ore used in the manufacture of “green acid” may only come from tw o 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 accep ted 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 othe r 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 tw o 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 divisi on. The Permittee shall notify the division 30 days before any test that is anticipated to be used as a compliant sour ce 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 co mpliance 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 si x-month period between July and December and July 30 of each calendar year for th e 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

-

### Permit 04176T3? DRAFT Page 90

a. Pursuant to 15A NCAC 2D .1100, in accordan ce 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 testi ng in accordance with 15A NCAC 2D .0501(c)(4) and Ge neral Condition JJ. If the results of th is 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 (w ritten 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 si x-month period between July and December and July 30 of each calendar year for th e 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 Tank s 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 st andards 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

### Permit 04176T3? DRAFT Page 91

The following table provides a summary of limits and st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E=55 x P 0.11 - 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 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.

Testing [15A NCAC 2D .0501 (c)(3)] b. If emissions testing is required, the testi ng 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 perfo rm 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) intern al 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 au thorized 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 recomme ndations, if any, and corrections made. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records

are not maintained

.

### Permit 04176T3? DRAFT Page 92

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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 te sting in accordance with

General Condition JJ. If the results of this test ar e 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 Permitt ee 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 sh all 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 demonstrati on 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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) PM 10 enclosure and

fabric filtration 10.7 pounds per day

### Permit 04176T3? DRAFT Page 93

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) PM 10 enclosure and

fabric filtration 10.7 pounds per day

Testing/Monitoring/Reporting/Recordkeeping b. The requirements for testing/Monitoring/Reporti ng/Recordkeeping given in 2.1.5.C.1 and 2 above
will be sufficient to demonstr ate 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E=55 x P 0.11 - 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 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.

Testing [15A NCAC 2D .0501 (c)(3)] b. If emissions testing is required, the testi ng 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 perfo rm 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

### Permit 04176T3? DRAFT Page 94

ii. an annual (for each 12 month period following the initial inspection) intern al 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 au thorized 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 recomme ndations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 te sting in accordance with

General Condition JJ. If the results of this test ar e 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 Permitt ee 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 sh all 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 demonstr ation 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations from the requirements of this permit must be clearly identified.

### Permit 04176T3? DRAFT Page 95

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) PM 10 enclosure and

fabric filtration 8.74 pounds per day

Testing/Monitoring/Reporting/Recordkeeping b. The requirements for testing/Monitoring/Reporti ng/Recordkeeping given in 2.1.5.D.1 and 2 above
will be sufficient to demonstr ate compliance with 2D .0530.



### 2.1.5.E Phosphate Rock Transfer House - Emission Source ID 429-150 Emission Point ID No.

437

The following table provides a summary of limits and st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E=55 x P 0.11 - 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 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.

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)]

### Permit 04176T3? DRAFT Page 96

c. Particulate matter emissions from the conveyor belt drop point shall be c ontrolled by the bagfilter. To assure compliance, the Permittee shall perform in spections 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) intern al 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 aut horized 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 reco mmendations, 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 si x-month period between July and December and July 30 of each calendar year for th e 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 mo re than 20 percent opacity when averaged over a six-minute period. Howeve r, 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 sh all perform such testing in accordance with General

Condition JJ. If the results of this test are above th e 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 d eemed 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)]

### Permit 04176T3? DRAFT Page 97

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 si x-month period between July and December and July 30 of each calendar year for th e 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) PM 10 enclosure and

fabric filtration 6.58 pounds per day

Testing/Monitoring/Reporting/Recordkeeping b. The requirements for testing/M onitoring/Reporting/Recor dkeeping 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

PM/PM10 E= 4.10 x P 0.67 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 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 testi ng 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 inspec tions and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or

### Permit 04176T3? DRAFT Page 98

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) intern al 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 au thorized 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 reco mmendations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 te sting in accordance with

General Condition JJ. If the results of this test ar e 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 Permitt ee 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 sh all 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 demonstrati on 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period

### Permit 04176T3? DRAFT Page 99

between January and June. All instances of devi ations 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 st andards 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: NAT IONAL 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 certificati on 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 st andards 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 appli cation 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 load ing 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 lo ading and maintenance activities). ii. The venturi scrubber (ID No. CD 438-200) will ma intain a liquid injection flow rate of ( to be determined. Permittee will follow scrubber manufacturer’s guideline s 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 guideline s and shall submit said guidelines to DAQ ) whenever the STF recovery plant’s (ID No. ES425) lines are purged.

### Permit 04176T3? DRAFT Page 100

iii. At no time shall emissions from the STF recovery plants be exhausted directly to the atmosphere without first passi ng 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 testi ng in accordance with 15A NCAC 2D .0501(c)(4) and Ge neral Condition JJ. If the results of th is 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 injec tion 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 a bove 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 si x-month period between July and December and July 30 of each calendar year for th e 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 Ta nks T1, T201, T12, T13, T212, and

T213 - Emission Point ID No. 501

The following table provides a summary of limits and st andards for the emission s ource(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 accessi ble 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 m 3

but less than 151 m 3 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

### Permit 04176T3? DRAFT Page 101

isobutyl ketone (MIBK) is less th an the 15.0 kPa at standard opera ting 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: NAT IONAL 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 ex ceed 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 fo r 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)]

### Permit 04176T3? DRAFT Page 102

b. If emissions testing is required, the Permittee sh all 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 opera te a monitoring system which continuously measures and permanently records the stack gas ex it 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 syst ems 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 si x-month period between July and December and July 30 of each calendar year for th e 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 em ission source(s) in accordan ce 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 s oon as practicable after th eir 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 Admi nistrator for the life of the aff ected 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 a ddresses an event that meet s 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 even t 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 NC AC 2D .0958(e), the permittee shall maintain a minimum recovery efficiency of 85 percent for all s ources of MIBK at the plant site.



### 2.1.6.C Three (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 st andards for the emission source(s) described above:

### Permit 04176T3? DRAFT Page 103

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 st andards 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: NAT IONAL 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 certificati on 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 st andards 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

### Permit 04176T3? DRAFT Page 104

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 accessi ble 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 m 3

but less than 151 m 3 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 th an the 15.0 kPa at standard opera ting conditions. Therefore, the
requirements of section c. will not appl y 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 Bl anket 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 st andards 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

### Permit 04176T3? DRAFT Page 105

2.1.6.F.1 40 CFR PART 63 SUBPART AA: NAT IONAL 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 ex ceed 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 te sting 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 ex it temperature for each chiller stack.

ii. Measure and record the concentration of me thyl 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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, a nd 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 previ ous (i.e., superseded) versions of the SSM plan on

### Permit 04176T3? DRAFT Page 106

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 a ddresses an event that m eets 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/R eporting/Recordkeeping b. The requirements for testing/ Monitoring/Reporting/Reco rdkeeping 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 Permitt ee shall perform such te sting 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, th e 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 tes ting 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 Divisi on of Air Quality in advance of the test. The facility shall estab lish 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 th e 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 st andards for the emission source(s) described above:

### Permit 04176T3? DRAFT Page 107

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 te sting 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, th e Permittee shall conduct a performance test to demonstrate compliance with the applicable emission standard for Emission Point 504. Details of the emissions testing and requi rements can be found in Secti on 3 - General Condition JJ. The scrubber stack shall be tested once per five-y ear 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 ra te 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 gi ven 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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

### Permit 04176T3? DRAFT Page 108

The following table provides a summary of limits and st andards 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: NAT IONAL 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 limite d 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 certifi cation 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 tabl e 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) PM 10 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 te sting 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 st andards for the emission source(s) described above:

Regulated

Pollutant Limits/Standards Applicable Regulation

Total
Fluorides 2D .0530 BACT

### Permit 04176T3? DRAFT Page 109

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: NAT IONAL 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 certificati on 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) PM 10 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 te sting 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 Nitroge n 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

### Permit 04176T3? DRAFT Page 110

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: NAT IONAL 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 Tr ain 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 te sting 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 ex it temperature for each chiller stack.
ii. Measure and record the concentration of me thyl 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 cal endar year for the pr eceding six-month period

### Permit 04176T3? DRAFT Page 111

between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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, a nd 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 previ ous (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 a ddresses an event that m eets 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/R eporting/Recordkeeping b. The requirements for testing/M onitoring/Reporting/Recor dkeeping given in 2.1.6.J.1 above will be sufficient to demonstrate complia nce with 2D .0530 for the chiller stack temperature requirement.

Testing c. If emissions testing is required, the Permitt ee shall perform such te sting 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, th e Permittee shall conduct a performance test to demonstrate compliance with the a pplicable emission standard for th e purified phosphoric acid plant chiller

### Permit 04176T3? DRAFT Page 112

stack. Details of the emissions te sting 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 de monstrable 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 a dvance of the test. The facility sha ll 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 st andards 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 te sting 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, th e Permittee shall conduct a performance test to demonstrate compliance with the applicable emission standard for Emission Point 503. Details of the emissions testing and requi rements can be found in Secti on 3 - General Condition JJ. The chiller stack shall be tested once per five-year pe rmit period at a rate de monstrable 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 accomp any the request. If the results of this test are above the emission standard give n above, the Permittee shall be deemed in noncompliance with

15A NCAC 2D .0530.

Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]

### Permit 04176T3? DRAFT Page 113

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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devia tions 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 st andards 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: NAT IONAL 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 limite d 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 certifi cation 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 tabl e 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) PM 10 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 te sting in accordance with General Condition JJ. If the results of this test are above the limit given in Section

### Permit 04176T3? DRAFT 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 st andards 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: NAT IONAL 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 certificati on 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) PM 10 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 te sting 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.

### Permit 04176T3? DRAFT 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 st andards 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 ve ssel shall keep readily accessible records showing the dimension of the storage vessel and an an alysis 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 m 3 but less than 151 m 3 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 st andards 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

### Permit 04176T3? DRAFT Page 116

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) : COMP LIANCE 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 P ug 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 testi ng 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 accordan ce with a testing protoc ol approved by the DAQ. Details of the emissions testing and requireme nts can be found in Sec tion 3 - General Condition JJ. If the results of this test are above the limit gi ven 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 pr otocol approved by the DAQ. Details of the emissions testing and requireme nts can be found in Section 3 - General Condition JJ. If the results of this test are above the limit given in S ection 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 pe rmit 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

### 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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 (E mission Point DFP Kiln Stack - ID No. 701) the following table shall describe the emission standards:

Source Pollutant BACT Technology Required 1

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 te sting in accordance with

15A NCAC 2D ..0530 and General C ondition 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 acco rdance with 40 CFR 63.626. Details of the emissions testing and require ments can be found in Section 3 - General Condition JJ. The sources shall be tested once per five-year perm it 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

### 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 producti on 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 sta ndard 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 pers onnel 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 th e 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

### 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 testi ng 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 de fluorination 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 f ound 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 fo r 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 o il supplier certifications sh all be recorded in a logbook (written or electronic format ) on a quarterly basis and incl ude the following information:
i. the name of the fuel oil supplier;

ii. the maximum sulfur content of th e fuel oil received during the quarter;

iii. the method used to determine the maxi mum 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.

### 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 peri od between October and December, April 30 of each calendar year for the preceding three-month period between January a nd March, July 30 of each calendar year for the preceding three-month period between April a nd June, and October 30 for the calendar year for the preceding three-m onth 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 sour ces 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 require d, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4) and General Condition JJ f ound 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 re quirements in 2.1.7.A.4 above will be sufficient to demonstrate compliance with 2D .0516.



### 2.1.7.B Materials 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)

### Permit 04176T3? DRAFT Page 121

Product Cooler Discharge Conveyor, C linker 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, Produc t 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 st andards 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 particulat e 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 testi ng 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 inspec tions and maintenance as recommended by the

### 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) intern al 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 au thorized 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 recomme ndations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods 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 te sting in accordance with

General Condition JJ. If the results of this test ar e 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 Permitt ee 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 sh all 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

### Permit 04176T3? DRAFT Page 123

Section 2.1.5.C.2. a. above. If the demonstrati on 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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 st andards 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 st andards 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)]

### Permit 04176T3? DRAFT Page 124

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 testi ng 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 inspec tions 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) intern al 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 au thorized 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 recomme ndations, 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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. Howe ver, six-minute averaging peri ods may exceed 20 percent not

### Permit 04176T3? DRAFT Page 125

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 te sting in accordance with

General Condition JJ. If the results of this test ar e 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 Permitt ee 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 sh all 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 demonstrati on 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 cal endar year for the pr eceding six-month period between July and December and July 30 of each calendar year for the pr eceding six-month period between January and June. All instances of devi ations 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 st andards 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)

### Permit 04176T3? DRAFT Page 126

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 malfunc tions approved as such accordi ng 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 require d, 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 acco rdance 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 Janua ry 30 of each calendar year for the preceding six-month period between July and Decembe r and July 30 of each calendar

### Permit 04176T3? DRAFT Page 127

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 atmos phere less than 40 tons of nitrogen oxides per consecutive 12-month period.

. [15A NCAC 2Q .0317(a)(1)]

b. To ensure compliance with th e 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 f ound in Section 3. If the results of this test are above the limit given in Section 2.1.8.C.3.a. above, the Pe rmittee 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 (w ritten 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 av ailable 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 peri od between October and December, April 30 of each calendar year for the preceding three-month period between January a nd March, July 30 of each calendar year for the preceding three-month period between April a nd June, and October 30 for the calendar year for the preceding three-m onth 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 st andards 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

### Permit 04176T3? DRAFT Page 128

TAPS Specific limits listed in Attachment 2 15A NCAC 2D .1100

1. 15A NCAC 2D. 0501(e): COMPLIANCE WI TH NATIONAL AMBIENT AIR QUALITY
STANDARDS
a. Operation of all equipment at the facility sh all 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 te sting 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 sou rces that use volatile organic compounds (VOC) as solvents, carriers, material processing med ia, 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 chemica l 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 contai ning volatile organic compounds in closed containers,

### Permit 04176T3? DRAFT Page 129

(4) not clean sponges, fabric, w ood, paper products, and other abso rbent materials with volatile organic compounds,
(5) transfer solvents containi ng volatile organic compounds used to clean supply lines and other coating equipment into closable containers and close such c ontainers immediately after each use, or transfer such solvents to closed tanks, or to a treatme nt 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 spen t cleaning solvent shall then be tran sferred 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 containi ng a volatile organic compound, the Permittee shall:
(1) flush parts in the freeboard area,
(2) take precautions to reduce the pooli ng of solvent on and in the parts,
(3) tilt or rotate parts to drain solvent and allo w a minimum of 15 seconds for drying or until all dripping has stopped, whichever is longer,
(4) not fill cleaning machin es 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) a nd (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 ha s not utilized volatile organic compounds during the previous month. The inspections shall be conducted during normal operations. If the required inspecti ons 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 main tained 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 noncomp liant 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 Janua ry 30 of each calendar year for the preceding six-month period between July and Decembe r 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 accordan ce with the approved application for an air toxic compliance demonstration, the permit limits f ound in Attachment 2 shall not be exceeded.

b. To ensure compliance with the limits in Attachment 2, the following restrictions shall apply:

### Permit 04176T3? DRAFT Page 130

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 s ource 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 sp ecifically 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 a nd 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 mo st 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 a ll within the permit limitations over the past quarter. If exceedences occur, iden tify 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 perm it 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 st andards 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 WI TH 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 sour ces considered together shall not exceed 137.2 tons per year.

### Permit 04176T3? DRAFT Page 131



## 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

### Permit 04176T3? DRAFT Page 132

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

### Permit 04176T3? DRAFT Page 133

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

### Permit 04176T3? DRAFT Page 134



## 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, a nd 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 de viation 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 an y 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 th e 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 a ssurance that the insta llation will not cause air pollution in violation of any of the applicable requirements. A permitted installation may only be operated, maintained, constructed, expanded, or m odified 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 applica tion 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 admini strative challenge to a final and binding pe rmit 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 Regiona l 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 c ontrol (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

### Permit 04176T3? DRAFT Page 135

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 pe rmit 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 App lication 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 reope ning 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 th at would violate applicable requirements or contravene federally enforceable permit terms a nd conditions that are m onitoring (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 unde r 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 th e 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:

### Permit 04176T3? DRAFT Page 136

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 st andards, 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 unde r 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 attributab le 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 emi ssions 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 NC AC 2D .0524), NESHAPS (15A NCAC 2D .1110 or .1111), or these rules do NOT define "excess emi ssions," the Permittee shall report excess emissions

in accordance with 15A NCAC 2D .0535 as follows: a. Pursuant to 15A NCAC 2D .0535, if excess em issions 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), th e 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 devia tion and any corrective ac tions or preventative actions taken. The responsible official sha ll 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

### Permit 04176T3? DRAFT Page 137

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 fro m 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 th e 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 defens e to an action brought for noncompliance with such technology-based emission limitations if the c onditions specified in 3. below are met. 3. The affirmative defense of emergency sh all 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 emergenc y 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 establis h 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 enfor cement 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 reco rds required to be kept by the permit when such copies are requested by the Dir ector. 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

### Permit 04176T3? DRAFT Page 138

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 m onitoring 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 ma intenance records and all original strip-chart recordings for continuous monitoring information, and c opies 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 perm it 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 EP A (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 calenda r 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 s ubmit a compliance certifica tion 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 comp liance 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 requirement s 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 S ection 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:

### Permit 04176T3? DRAFT Page 139

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 contai ned 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 re quirement. The Permittee shall have available at the facility at all times and made available to an authorized representativ e upon request, documentation, including calculations, if necessary, to demonstrate th at 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 e ither 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 documen ts as may be required by law, the Permittee shall allow the DAQ, or an authorized repr esentative, 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, an y records that are required to be kept under the conditions of the permit; c. inspect at reasonable times and using reas onable safety practices any source, equipment (including monitoring and air pollution control equi pment), 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 provisi ons 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 es tablished by the Director. The accuracy of the report shall be certified by a responsib le official of the facility.

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

### Permit 04176T3? DRAFT Page 140

Whenever the Permittee submits information under a cl aim of confidentiality pur suant to 15A NCAC 2Q .0107, the Permittee may also submit a copy of all su ch 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 sh all 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 a ll 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 (Stratos pheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)] 1. If the Permittee has appliances or refrigerati on 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 r ecycling 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 ma y not be required, if the Permitt ee 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 accident al 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 noncomplia nce with any other applicable requirement. The Permittee’s emissions may not exceed any allowances th at 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 Em ission 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 pe rmit 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 th e Permittee submits emissions testing to the DAQ in support of a permit application, the Perm ittee shall perform such te sting in accordance with the appropriate EPA reference method(s) as appr oved 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 operati ng 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 conc lusions 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 sampli ng 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 opera ting conditions during all testi ng 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 resp ect exclusively to the sp ecified 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 re vised 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 c ontains 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 re vised permit issued within 18 months after the applicable requirement is promulgated. No re opening 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-en forceable 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 pub lic 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 termina tion, 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

NO X 

### Nitrogen Oxides

NSPS New Source Performance Standard

OAH Office of Administrative Hearings

PM Particulate Matter

PM 10 

### 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

SO 2 

### Sulfur Dioxide tpy Tons Per Year
VOC Volatile Organic Compound

### Permit 04176T3? DRAFT Page 144



# 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.

### Permit 04176T3? DRAFT Page 145

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 contro l 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. Th e 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 authori zed to construct in Section 1 must be constructed

and maintained in accord ance 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 sha ll notify in writing the Regional Supervisor of the new proposed operational date. Any ex isting 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.

### Permit 04176T3? DRAFT Page 146



# 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 ope rators 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 othe r 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 emissi on 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 reporte d 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.

### Permit 04176T3? DRAFT Page 147

If appropriate, modifications to the permit may th en 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 contai ned 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 repr esentative, 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, an y records that are required to be kept under the conditions of the permit; 3. inspect at reasonable times and using reas onable safety practices any source, equipment (including monitoring and air pollution control equi pment), 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.

### [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.