AIR QUALITY DIVISION

CHAPTER 6, SECTION 3

OPERATING PERMIT

WYOMING DEPARTMENT OF

ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

122 West 25th Street

Cheyenne, Wyoming 82002

PERMIT NO. 3-2-125-1

Issue Date: July 21, 2014

Expiration Date: August 17, 2016

Effective Date: July 21, 2014

Replaces Permit No.: 3-2-125

In accordance with the provisions ofW.S. §35-11-203 through W.S. §35-11-212 and Chapter 6,

Section 3 ofthe Wyoming Air Quality Standards and Regulations,

Simplot Phosphates LLC

Rock Springs Fertilizer Complex

Section 15, Township 18 North, Range 104 West

Sweetwater County, Wyoming

is authorized to operate a stationary source of air contaminants consisting ofemissionunits described

in this permit. The units described are subject to the terms and conditions specified in this permit.

All terms and conditions of the permit are enforceable by the State of Wyoming. All terms and

conditions ofthe permit, except those designated as not federally enforceable, are enforceable by

EPA and citizens under the Act. A copy of this permit shall be kept on-site at the above named

facility.

Steven A. Dietrich, Administrator

Air Quality Division

- \ 06~~ Todd Parfitt, Director

Department of Environmental Quality

Date

Date

7- 2/-1'1
WAQSR CHAPTER 6, SECTION 3 OPERATING PERMIT

WYOMING DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

TABLE OF CONTENTS

(Modified July 21,2014)

General Information 3

Source Emission Points 4

Total Facility Estimated Emissions 5

Facility-Specific Permit Conditions 6

Facility-Wide Permit Conditions 6

Source-Specific Permit Conditions. 6

Testing Requirements 8

Monitoring Requirements 9

Recordkeeping Requirements 12

Reporting Requirements 14

Accidental Release Prevention Requirements 17

PSD Applicability Demonstration Requirements 17

WAQSR Chapter 5, Section 2 and 40 CFR 60 Subpart Db Requirements 20

WAQSR Chapter 5, Section 2 and 40 CFR 60 Subpart H Requirements. 22

WAQSR Chapter 5, Section 2 and 40 CFR60 Subpart Illl Requirements.. 23

WAQSR Chapter 5, Section 2 and 40 CFR 60 SubpartJJJJ Requirements 23

40 CFR 61 Subparts A and R Requirements 23

WAQSR Chapter 5, Section 3 and 40CFR63 Subpart AARequirements 24

WAQSR Chapter 5, Section 3 and 40 CFR 63 Subpart BB Requirements 28

WAQSR Chapter 5, Section 3 and 40 CFR 63 Subpart ZZZZ Requirements 32

WAQSR Chapter 5, Section 3 and 40 CRF 63 Subpart DDDDD Requirements 32

WAQSR Chapter 7, Section 3 Compliance Assirance Monitoring Requirements 33

Compliance Certification and Schedule. 34

Compliance Certification 34

Compliance Schedule 36

General Permit Conditions 37

State Only Permit Conditions 42

Summary of Source Emission Limitsand Requirements .45

Abbreviations 54

Definitions 55

Appendix A: Reserved

Appendix B: Reserved

Appendix C: Compliance Assurance Monitoring Plan

Appendices D through L: Reserved

Appendix M: Fluoride Control Techniques

Appendix N: Permit CT-550A3

PermitNo. 3-2-125-1 Page2
GENERAL INFORMATION

(Modified July 21,2014)

Company Name: Simplot Phosphates LLC

Mailing Address: 515 South Highway 430

City: Rock Springs State: WY Zip: 82901

Plant Name: Rock Springs Fertilizer Complex

Plant Location: Section 15, Township 18 North, Range 104 West, Sweetwater County, WY

(4.5 miles southeast of Rock Springs)

Plant Mailing Address: 515 South Highway 430

City: Rock Springs State:WY Zip: 82901

Name of Owner: Simplot Phosphates LLC

Plant Manager/Contact: Martin Hunt

Phone: (307) 382-1532

Phone: (307) 382-1529

DEQ Air Quality Contact: District 5 Engineer Phone: (307) 332-6755

510 Meadowview Drive

Lander, WY 82520

SIC Code: 2819, 2874

Description of Process: The Rock Springs Fertilizer Complex consists of two sulfuric acid plants,

phosphoric acid and superphosphoric acid plants, an ammonium phosphate plant, and

miscellaneous product handling and support facilities.

The plant process begins by oxidizing elementalsulfur which is then absorbed to prodnce sulfuric

acid. Additionalsulfnric acid is purchased on the spot market and imported by truck and rail from

vendors. Sulfuric acid is then either mixed with the phosphate rock concentrate slnrry to produce

phosphoric acid (H3P04)or placed in tank storage for future nse. The produced phosphoric acid is

filtered to remove gypsum and concentrated to 52 percent P20S by evaporation. A portion ofthe 52

percent solution (dictated by market demand) is further concentrated to 70 percent P20S

(superphosphoric acid) for producing liquid fertilizer at other off-site locations. The remainder of

the 52 percent phosphoric acid is reacted with ammonia to produce granulated ammonium

phosphate fertilizers.

Permit No. 3-2-125-1 Page 3
SOURCE EMISSION POINTS

(Modified July 21, 2014)

This table may not include any or all insignificant activities at this facility.

lalla'

Ib

2

8a

9a Lurgi Sulfuric Acid Plant (0)

9b MEC Sulfuric Acid Plant (0)

lOa Ammonium Phosphate (MAP) Plant (d)

11

12

13a

14

15

17

19

22

23

24

25

26

27

28

29

30

34

1200 TPD P20, CT-550A, MD-384A,

MD-12795

1200 TPD P20, MD-384A, MD-12795

500 TPD P20, CT-550A, CT-I043

78.6 MMBtu/hr CT-I043, AP-12908

2100 TPD CT-550A, CT-I043,

MD-12795

1520 TPD MD-I130, MD-12795

75 TPH CT-550A, CT-550A2,

CT-I043, MD-12795

6000TPD MD-12795

6000TPD CT-I043, MD-12795

15 TPH CT-I043

350 acres max. AP-7283, MD-12795

NA CT-1043

10TPH CT-1043

350 MMBtu/hr CT-I043,AP-IOI71

416,447 allons None

416,447 allons None

416,447 allons None

NA None

NA None

205 hp None

wv-11961

183 hp wv-12054

1855 hp AP-2532

186 hp AP-10572

{a) Fluoride emissions are controlled with Venturi-cyclone fume scrubbers. Sources Ialia' and Ib share a

commou reactor and the combined total phosphoric acid capacity is approximately 1200 TPDID,.

(b) Fluoride emissions are controlled with Venturicyclone fume scrubbers/demister pads.

(0) S02 emissions controlled by dual absorption process. liSO, mist controlled with candle filters.

(d) Particulate, fluoride and ammonia emissions are controlled bjscrubbers with demisters.

Permit No. 3-2-125-1 Page4
TOTAL FACILITY ESTIMATED EMISSIONS

(Modified July 21, 2014)

For informational purposes only. These emissions are not to be assumed as permit limits.

Particulate Matter

PMIO Particulate Matter

Sulfur Dioxide (S02)

Nitrogen Oxides (NOx)

Carbon Monoxide (CO)

Volatile Organic Compounds (VOCs)

Fluoride (F) also includes HF

Ammonia (NH3)

SUlfuric Acid Mist (weight calculated as H2S04)

136

136

2587

535

248

23

(58.8)

46.8

12

41

438

85

Emission estimates for total HAPs and NH3 are from the operating permit application, the other

emission estimates are from the application analysis for permit MD-12795.

Permit No. 3-2-125-1 Page 5
FACILITY-SPECIFIC PERMIT CONDITIONS

Facility-Wide Permit Conditions

(FI) PERMIT SHIELD [WAQSR Chapter 6, Section 3(k)]

Compliance with the conditions ofthis permitshall be deemed compliance with any applicable requirements as

ofthe date of permit issuance.

(F2) SULFUR DIOXIDE EMISSIONS INVENTORY [WAQSR Ch 14, Sec 3]

The penuittee shall comply with the requirements ofWAQSR Ch 14, Sec 3, includingestimatingSO, emissions

in accordance with Ch 14 Sec 3(b), and adjusting estimates in accordance with Ch 14 Sec 3(c), if necessary.

Source-Specific Penuit Conditions

(F3) VISIBLE EMISSIONS [WAQSR Ch 3, Sec 2; 40 CFR 60 SubpartH] (Modified July 21, 2014)

(a) Visible emissions from the Lurgi and MEC sulfuric acid plants (units 9a and 9b) shall not exceed 10

percent opacity for each unit.

(b) Visible emissions from the emergency use diesel fired engines (units 27, 28, 29 and 30) shall not exceed

30 percent opacity except for periods not exceeding ten consecutive seconds.

(c) Visible emissions of any contaminant discharged into the atmosphere from any other single emission

source shall not exhibit greater than 20 percent opacity except for one period or periods aggregatingnot

more than six minutes in anyone hour of not more than 40 percent opacity.

(F4) PHOSPHORIC AND SUPERPHOSPHORlC ACID PLANTS (Modified July 21, 2014)

[WAQSR Ch 6, Sec 2 Permits CT-I043, and MD-384A; 40 CFR 63 SubpartAA]

(a) Reserved

(b) Total fluoride emissions from the phosphoric acid plant twin ventilation stacks (unit lalla') shall not

exceed 0.01350 lblton of equivalent P,O, feed, not to exceed 0.65 lblhr absolute mass cap. This

allowable emission rate shall be a common limit forboth GK-1304A and GK-1304B stacks, and shall

apply to total emissions measured simultaneously from these two stacks.

(c) Total fluoride emissions from the phosphoric acid plant #2 (unit lb) shall be limited to 0.01350 lb/ton of

equivalent P,O, feed, not to exceed 0.65 lblhr absolute mass cap.

(d) Fluoride emissionsfrom the superphosphoric acid plant (unit 2) shall not exceed 0.010 lb/ton ofP,O, feed

or 0.18Iblhr.

(e) Reserved

(F5) AUXILIARY BOILER [WAQSR Ch 6, Sec 2 Penuit CT-I043]

Emissions from the auxiliary boiler (unit 8a) shall not exceed the following:

(a) 0.55 lb/hr particulate

(b) 0.071blhr SO,

(c) 20.021b/hrNOx

(d) 1.87 lblhr CO

(F6) SULFURIC ACID PLANTS [WAQSR Ch 6, Sec 2 Penuits CT-I 043 and MD-I130; and 40 CFR 60 SubpartH]

(a) Emissions from the Lurgi and MEC sulfuric acid plants (units 9a and 9b) shall not exceed the limits

specified in Table 1.

(b) Production from the MEC sulfuric acid plant shall not exceed 1520 TPD of 100 percent sulfuric acid.

Permit No. 3-2-125-1 Page 6
(F7) AMMONIUM PHOSPHATE PLANT [WAQSR Ch 6, Sec 2 Permits CT-550A, CT-550A2 and CT-1043; and

40 CFR 63 Snbpart BB]

(a) Emissions from the ammonium phosphate plant (unit lOa) shall not exceed the following:

(i) 20.00 lblhr particulate

(ii) 19.88 Ib/hr SO,

(iii) 5.84 Ib/hr NOx

(iv) For fluoride, 0.060 Ib/tonofP,O, feed, and 2.30 lb/hr

(v) 1.40 lb/hr CO

(vi) 100 Ib/hr and 438 TPY of Nl-l, (ammonia)

(b) The ammoniumphosphate plantshall operate at a minimum ammoniarecovery efficiency of98 percent.

(c) The sulfur content ofthe fuel oil used in the ammonium phosphate dryer shall not exceed 0.5 percent.

(F8) BAGHOUSE-CONTROLLED SOURCES [WAQSR Ch 6, Sec 2 Permit CT-I043]

Particulate emissions from the following units shall not exceed the specified limits.

(a) For the ammonium phosphate loadout baghouse (unit 12): 0.50lb/hr

(b) For the lime handling baghouse, truck (unit 13a): O.lllb/hr

(c) For the soda ash handling baghouse (unit 17): 0.10 lb/hr

(F9) PACKAGED BOILER [WAQSR Ch 6, Sec 2 Permit CT-1043]

(a) The packaged boiler (unit 19) may operate at an hourly heat input between 122.5 and 350 MMBtulhr for

no more than 1056 hours per year.

(b) NOx emissions from the packaged boiler shall not exceed the following:

(i) At firing rates above 122.5 MMBtu/hr: 0.14IblMMBtu, not to exceed 49.00 lb/hrat the maximum

firing rate of 350 MMBtu/hr, for 1056 hours per year, and

(ii) At firing rates at or below 122.5 MMBtulhr: 0.14 Ib/MMBtu, not to exceed 17.20Iblhr, for the

remainder ofthe year.

(c) CO emissions from the packaged boiler shall not exceed 25.90 lb/hr,

(FlO) EMERGENCY ENGINES [WAQSR Ch 6, Sec 2 Waivers AP-2532, AP-I0572, wv-11961, wv-12054]

(a) The John Deere JU6H-UFADNG Clark engine (unit 29) shall be Tier 3 certified, and shall not exceed 50

hours of operation per year; a non-resettable hour meter shall be operated and maintained to record the

hours ofoperation. The Cummins KTTA50-G2 generator engine (unit 30) shall be limited to 250 hours

ofoperation per year; an hour meter shall be operated and maintained to record the hours of operation.

(i) The permittee shall operate and maintain the Cummins KTTA50-G2 generator engine in

accordance withthemanufacturer's or supplier's recommendations.

(ii) The permittee shall operate and maintain the John Deere Clark engine and monitoring equipment

according to good air pollution control practices at all times, including startup, shutdown, and

malfunction.

(b) Emissions from the CumminsMII-P (unit 28) and CumminsGM8.1L (unit 34) engines shall not exceed

the limits in Table H.

(i) The Cummins GM8.1 L engine shall not exceed 500 hours ofoperation per calendar year, and the

Cummins MII-P engine shall not exceed 2,000 hours of operation per calendar year. For each

engine, a non-resettable hour meter shall be operated and maintained to record the hours of

operation.

(ii) The permittee shall operate and maintain the Cummins MII-P in accordance with the

manufacturer's or supplier's recommendations.

Cummins MII-P (unit 28)

Cummius GM8.1L (unit 34)

Permit No. 3-2-125-1

7.6 3.1 0.8 19.8 8.1 2.0

Page 7
(FII) TEMPORARY ENGINE REPLACEMENT [WAQSR Ch 6, Sec 3(h)(i)(I)]

(a) Should an engine break down or require an overhaul, tbe permittee may bring on site and operate a

temporary replacement engine nntil repairs are made. Permanent replacement of an engine must be

evaluated by the Division under Ch 6, Sec 2 ofWAQSRto determine appropriate permitting action and

evaluate the need for additional requirements resulting from the permanent replacement

(b) The temporary replacement unit shall be identical or similar to the unit replaced with emission levels at

or below those ofthe unit replaced.

(c) The permittee shall notify the Division in writing ofsuch replacement within five working days, provide

the date ofstartup ofthe replacement engine, and provide a statementregarding the applicability ofany

New Source Performance Standards (NSPS) in 40 CFR, Part 60 and/or the applicability of any National

Emission Standards for Hazardous Air Pollutants (NESHAPs) in 40 CFR, Part 63.

TestingRequirements

(FI2) LURGI AND MEC SULFURIC ACID PLANTS TESTING [WAQSR Ch 6, Sec 3(h)(i)(C)(I)]

For H2S04 mist and NOx emissions from the Lurgi and the MEC sulfuric acid plants (units 9a and 9b), the

permittee shall conduct testing as follows to assess compliance with the limits specified in condition F6.

(a) For H2S04 mist emissionsfrom the Lurgi and the MEC sulfuric acid plants, the permittee shall test each

plant at least once every five years

(i) The methods and procedures specified in 40 CFR60 Subpart H shall be used to measure acid mist

emissions. Acid mist emissions shall be determined in Ib/hr and Ib/ton ofIj,SO, produced.

(ii) The permittee shall note wbether any visible emissions were present during the testing.

(b) For NOx emissions from the Lurgi and the MEC sulfuric acidplants, the permittee shall test each plant at

least once each calendar year using the methods as described in condition F14.

(c) Testing shall be conducted in accordance with WAQSR Ch 5, Sec 2 (h).

(FI3) PHOSPHORIC/SUPERPHOSPHORIC ACID PLANTS AND AMMONillMPHOSPHATEPLANT TESTING

[WAQSR Ch 6, Sec 3(h)(i)(C)(I)]

(a) For fluoride emissions from the phosphoric acid plants (units lalla', Ib and 2), the permittee shall

perform testing at least once each calendar year as specified nnder condition P63-AA2 ofthis permitto

assess compliance with the limits specified in condition F4.

(b) For particulate, fluoride, ammonia, NOx, and CO emissions from the ammoniumphosphate plaut (unit

lOa), the permittee shall perform testing as follows to assess compliance with the limits specified in

condition F7:

(i) For particulate, fluoride, and ammoniaemissions, the permittee performtesting at least once each

calendar year.

(A) For particulate emissions, methods as described in condition FI4 shall be used. The

permittee shall continuously measure the differential pressure across the scrubber and the

liquor flow rate to the scrubber during the testing to verify the validity ofthe compliance

assurance monitoring parameter ranges.

(B) For fluoride emissions, the permittee shall perform testing as specified in condition

P63-BB2 ofthis permit.

(C) For ammonia emissions, methods as described in condition FI4 shall be used. During

testing the permittee shall monitor and calculate the percert ammonia recovery.

(ii) The permittee shall measure NOx and CO emissions at least once every five years or every 8,000

hours of operation ofthe unit, whichever is more frequent, using the methods as described in

condition F14.

(c) Testing shall be conducted in accordance with WAQSR Chapter 5, Section 2(h).

(F14) ADDITIONAL EMISSIONS TESTING [W.S. 35-11-110]

(a) The Division reserves the right to require additional testing as provided nnder condition GI ofthis permit.

Should testing be required, test methods fonnd at 40 CFR 60, Appendix A, shall be used as follows:

(i) For visible emissions, Method 9 shall be used.

(ii) For particulate emissions, Methods 1-4 and 5 shall be used.

(iii) For S02 and sulfuric acid mist emissions from the sulfuric acid plants (units 9a and 9b), the

methods and procedures described in 40 CFR 60 Subpart H shall be used.

Permit No. 3-2-125-1 Page 8
(iv) For SO, emissions from other sources, Methods 1-4 and 6 or 6C shall be used.

(v) For engines subject to the requirements of40 CFR 60 SubpartJJJJ, testing for NOx, CO and VOC

emissions shall be conducted as specified in §60,4244.

(vi) For other NOx emissions, Methods 1-4 and 7 or 7E shall be used.

(vii) For other CO emissions, Methods 1-4 and 10 shall be used.

(viii) For ammonia emissions, Methods 1-4 and 206 shall be used.

(ix) For fluoride emissions from the ammonium phosphate plant (unit lOa), the methods and

procedures described in 40 CFR 63 Subpart BB shall be used.

(x) For fluoride emissions from the phosphoric acid plants and superphosphoric acid plant (units

la/la', Ib, and 2), the methods and procedures described in40 CFR 63 SubpartAA shall be used.

(xi) For alternative test methods, or methods used for other pollutants, the approval of the

Administrator must be obtained prior to using the test method to measure emissions

(b) Unless otherwise specified, testing shall be conducted in accordance with WAQSR Ch 5, Sec 2(h).

Monitoring Requirements

(FI5) VISIBLE EMISSIONS MONITORING [WAQSR Ch 6, Sec 3(h)(i)(C)(I)] (Modified July 21, 2014)

(a) For visible emissionsfrom the phosphoric acid plants (units I alia', and Ib), superphosphoric acid plant

(unit 2), and ammonium phosphate plant (unit lOa), and for visible and particulate emissions from the

lime handling baghouse (unit 13a), and soda ash handling baghouse (unit 17),the permittee shall conduct

monitoring as follows to determine the presence of visible emissions:

(I) The permittee shall conduct, at minimum, weekly Method 22-like visual observations of each

source listed above, for at least one minute to determine the presence of visible emissions.

(ii) The visual observations shall be conducted by a person who is educated on the general procedures

for determining the presence ofvisible emissions but not necessarily certified to performMethod

9 observations.

(iii) Observation ofvisible emissions from any source listed above shall promptirnmediateinspection

and, if necessary, corrective actions.

(b) For periodic monitoring ofvisible emissions from the auxiliary and packaged boilers (units 8a and 19),

and the Cummins GM8. IL emergency engine (unit 34), the permittee shall monitorthe type of fuel used

to ensure natural gas is the sale fuel used for these units.

(c) For visible emissions from the tailings booster pump engine (unit 28) the permittee shall conduct

observations at least once per calendar quarter using Method 9 to assess compliance with condition

F3(b). The visual observations shall be conducted by personnel certified to perform Method 9

observations. Observation ofvisible emissions which exceed the limit specified in condition F3(b) shall

trigger immediate inspection and, if necessary, corrective actions.

(d) Monitoring for visible emissions from the sulfuric acid plants (units 9a and 9b) is described under

condition F18. Monitoring for visible emissions from the ammoniumphosphate loadout baghouse (unit

12) is described under condition F20.

(FI6) PHOSPHORIC/SUPERPHOSPHORIC ACID PLANTS AND FLUORIDE MONITORING [WAQSR Ch 6,

Sec 3 (h)(i)(C)(I) and Ch 6, Sec 2 Permit CT-550A] (Modified July 21,2014)

For the fluoride emissions from the phosphoric/superphosphoric acid plants (units lalla', Ib and 2), the

permittee shall conduct monitoring as follows:

(a) Reserved

(b) Annual fluoride emission testing, P,O, feed rate, and continuous scrubber monitoring requirements for

the phosphoric acid plants (units I all a', Iband 2) as indicated under conditions P63-AA2 and P63-AA3.

(c) Reserved

(FI7) AUXILIARY BOILER MONITORING [WAQSR Ch 6, Sec 3 (h)(i)(C)(I)]

For particulate, SO" NOx, and CO emissions from the auxiliary boiler (unit 8a), the permittee shall conduct

monitoring as follows to assess compliance with the limits specified in condition F5:

(a) For particulate matter and SO, emissions, the permittee shall monitor the type of fuel used to ensure

natural gas is the sale fuel source for this unit.

(b) The permittee shall measure NOx and CO emissions at least once every five years; or at least once every

8,000 hours of operation ofthe unit beginning from the issuance date oflhis permit or the date oflhe

mostrecent test; whichever is more frequent

Permit No. 3-2-125-1 Page 9
(i) The permittee shall use the methods described in condition F14.

(ii) The permittee shall monitor the operating hours ofthe unit to determine the testing frequency in

accordance with this condition.

(F18) LURGI AND MEC SULFURIC ACID PLANT MONITORING [WAQSR Ch 6, Sec 3(h)(i)(C)(I); Ch 6, Sec 2

Permits CT-550A and MD-1l30; Ch 7, Sec 3(c)(ii); 40 CFR 60 Subpart H]

For H,S04, visible, SO, and NOx emissions, and acid production from the Lurgi and MEC sulfuric acid plants

(units 9a and 9b), the permittee shall conduct monitoring as follows to assess compliance with the limits in

conditions F3 and F6:

(a) ForH,S04 emissions from each sulfuric acid planl, the permittee shall adhere to the compliance assurance

monitoring (CAM) plan, attached as Appendix C ofthis permit, and shall conduct monitoring as follows:

(i) The permittee shall conduct, at minimum once daily, visual observations of each sulfuric acid

plant as indicated in the CAM plan, to determine the presence of visible emissions.

(ii) The visual observations shall be conducted by a person who is educated on the general procedures

for determining the presence ofvisible emissions but not necessarily certified to perform Method

9 observations.

(iii) An excursion is defined as observation of visible emissions from any unit, and shall prompt

immediate inspection and, if necessary, corrective action.

(iv) The permittee shall follow all other applicable requirements under conditions CAM-I through

CAM-4 ofthis permit.

(v) The permittee shall performtesting for acid mist from each sulfuric acid plant at least once every

five years as required by condition FI2(a), for comparisonwith the emission limits and to verify

the relationship between visible emissions and acid mist emissions.

(b) For SO, emissions from each sulfuric acid plant, the permittee shall continue to calibrate, maintain and

operate continuous emissions monitoring systems (CEMs) as described in condition P60-Hl.

(c) For NOx emissions monitoring from each sulfuric acid plant, the permittee shall perform testing at least

once each calendar year as required under condition F 12(b).

(d) The permittee shall measure the daily production ofsulfuric acid in the MEC sulfuric acid plant.

(F19) AMMONIUM PHOSPHATE PLANT MONITORING [WAQSRCh 6, Sec 3 (h)(i)(C)(I); Ch 7, Sec 3(c)(ii)]

For particulate, SO" NOx, CO, fluoride, and NH, emissions from the ammoniumphosphate plant (unit lOa), and

for the sulfur content ofthe fuel, the permittee shall conductmonitoring as follows for comparisonwith the limits

specified in condition F7:

(a) For particulate emissions from the ammonium phosphate plant, the permittee shall adhere to the CAM

plan, attached as Appendix C ofthis permit, and shall conduct monitoring as follows:

(i) The permittee shall continuously measure the differential pressure across the scrubber and the

liquor flow rate to the scrubber.

(ii) An excursion is defined as any parameter measurement outside the indicator ranges specified in

the CAM plan, and shall prompt immediate inspection and, if necessary, corrective action.

(iii) The permittee shall follow all other applicable requirements under conditions CAM-I through

CAM-4 ofthis permit.

(iv) The permittee shall perform testing for particulate matter emissions at least annually as required

by condition FI3(b), for comparison with the emission limits, and to verify the relationship

between the monitored parameters and particulate matter emissions.

(A) The permittee shall measure the CAM indicators during the tests. Following each annual

test, the permittee shall evaluate the data from the test, together with data from previous

testing, to determine ifthe indicator ranges in the CAM plan should be revised.

(b) In the event offuel oil firing in the anunonium phosphate dryer, the permittee shall monitor the sulfur

content of the fuel oil fired to assess compliance with the limit in condition F7(c), and calculate SO,

emissions to assess compliance with the limit in condition F7(a)(ii).

(c) The permittee shall measure NOx and CO emissions at least once every five years or every 8,000 hours

ofoperation as indicated under condition F13(b)(ii). The permittee shall monitorthe operating hours of

unit lOa to determine the testing frequency in accordance with this condition

(d) Annual fluoride emissionstesting, P,O, feed rate, and continuousscrubbermonitoring requirements for

the ammonium phosphate plant are indicated under conditions P63-BB2 and P63-BB3 ofthis permit.

Permit No. 3-2-125-1 Page 10
(e) For NH, (ammonia) emissions and percent recovery, the permittee shall perform testing at least once

each calendar year as required by condition FI3(b).

(F20) AMMONTIJMPHOSPHATE LOADOUTMONITORING [WAQSR Ch 6, Sec 3(h)(i)(C)(I); Ch 7, Sec 3(c)(ii)]

For particulate and visible emissions from the ammoniumphosphate loadout baghouse (unit 12), the permittee

shall adhere to the CAM plan, attached as Appendix C ofthis permit, and shall conductmonitoring as follows:

(a) The permittee shall conduct, at minimum once daily, visual observationsofthe ammonium phosphate

loadout baghouse to determine the presence of visible emissions.

(b) The visual observations shall be conducted by a person who is educated on the general procedures for

determiniug the presence of visible emissions but not necessarily certified to perform Method 9

observations.

(c) An excursion is defined as observation of visible emissions from any unit, and shall prompt immediate

inspection and, if necessary, corrective action.

(d) The permittee shall follow all other applicable requirements under conditions CAM-I through CAM-4.

(F21) PACKAGED BOILER MONITORING

[WAQSR Ch 6, Sec 3(h)(i)(C)(I); Ch 6, Sec 2 Permit CT-I043; and 40 CFR 60 Subpart Db]

For the heat input limits and NOx and CO emission limits from the packaged boiler (unit 19),the permitteeshall

conduct monitoring as follows to assess compliance with the limits specified in condition F9:

(a) The permittee shall calibrate, operate, and maintain a continuous gas flow meter on the packaged boiler

to determine hourly heat input to the boiler and to ensure the hourly heat input limit is not exceeded.

(b) For NOx emissions monitoring, the permittee shall continue to calibrate, maintain and operate a

continuous emissions monitoring system (CEMS) as described in condition P60-Db2. The CEMS shall

determine and record NOx emissions in IblMMBtu and Ib/hr.

(c) The permittee shall measure CO emissions at least once every five years, or every 8,000 hours of

operation ofthe unit, whichever is more frequent,using the methods described in condition F14. The

permittee shall monitor the operating hours ofthe unit to determine the testing frequency in accordance

with this condition.

(F22) ENGINE AND FLUOSILISIC ACID (FSA) RECOVERY MONITORING [WAQSR Ch 6, Sec 3(h)(i)(C)(I);

Ch 6, Sec 2 Waivers AP-2532, AP-10572, AP-2205 and wv-1196I] (Modified July 21, 2014)

(a) For the hours ofoperation limits on the CumminsMl l-P (unit 28),Curumins KTTA50-G2 (unit 30), and

Cununins GM8.IL (unit 34) engines, the permittee shall monitor the operating hours of each unit by

utilizing the hours meters required by condition FlO.

(b) For NOx, CO and VOC emissions, as applicable, from the Cummins MII-P (unit 28) and Cummins

GM8.IL (unit 34) engines, the permittee shall conduct monitoring as follows to assess compliance with

the limits specified in condition FIlJ(b):

(i) Testing shall be conducted at least once every three years.

(ii) For the Cummins GM8.IL (unit 34), testing for NOx, CO and VOC emissions shall consistofone

I-hour test following 40 CFR part 60, subpart JJJJ §60.4244.

(iii) For tbe Cummins MII-P (unit 28), testing for NOx and CO shall be conducted in accordance

with EPA reference methods in condition F 14, or the State of Wyoming's Portable Analyzer

Protocol.

(iv) The permittee shall notify the Division within 24-hours ifunits 28 or 34 testing/monitoring shows

operation outside the emission limits specified in conditionf'I O(b).

(A) The permittee shall repair the engine no later than seven calendar days of such a

testing/monitoring event, and shall repair and retest/monitor the engine to demonstrate it

has been returned to operation within the limits in condition FIO::b).

(B) Compliance with this condition regarding repair and retesting/monitoring shall not be

deemed to limit the authority of the Division to cite the owner or operator for an

exceedance ofthe emission limits for any testing/monitoringwhich shows noncompliance.

(c) The permittee shall monitor the amount offluosilisic acid (FSA) loaded out ofthe facility.

Permit No. 3-2-125-1 Page II
Recordkeeping Requirements

(F23) SULFUR DIOXIDE EMISSIONS INVENTORY RECORDS [WAQSR Ch 14, Sec 3(b)]

(a) The permittee shall maintain all records used in the calculation of S02 emissions for the inventory

required hy condition F2, including hut not limited to the following:

(i) Amount of fuel consumed;

(ii) Percent sulfur content offuel and how the content was determined;

(iii) Quantity of product produced;

(iv) Emissions monitoring data;

(v) Operating data; and

(vi) How the emissions are calculated, including monitoring/estimation methodology with a

demonstration that the selected methodology is acceptable under Ch 14, Sec 3.

(b) The permittee shall maintainrecords ofany physical changes to facility operations or equipment, or any

other changes (e.g. raw material or feed) that may affect emissions projections of SQ.

(c) The permittee shall retain all records and support information for compliance with this condition and

with the reporting requirements of condition F32 at the facility, for a period of at least ten (10) years

from the date of establishment, or ifthe record was the basis for an adjustment to the milestone, five

years after the date of an implementation plan revision, whichever is longer.

(F24) VISIBLE EMISSIONS MONITORING RECORDS [WAQSR Ch 6, Sec 3 (h)(i)(C)(lI)]

(a) For the visible emissions monitoring specified under condition FI5(a), FI8(a) and F20, the permittee

shall record, as applicable, the following:

(i) The date, place, and time ofthe observation;

(ii) The company or entity that performed the observation;

(iii) The observation results;

(iv) The operating conditions as they existed at the time ofthe observation; and

(v) Any corrective actions taken upon observing visihle emissions from the sources.

(b) The permittee shall retain on-site at the facility the records required by this condition for a period of at

least five years from the date such records are generated.

(F25) TESTING RECORDS [WAQSR Ch6, Sec 3(h)(i)(C)(1I)]

(a) For any testing or monitoring required under conditions F12, F13, F14, FI7(b), FI9(b)-(e), F21(c), and

F22(b), other than Method 9 observations, the permittee shall record, as applicable, the following:

(i) The date, place, and time ofsampling or measurements;

(ii) The date(s) the analyses were performed;

(iii) The company or entity that performed the analyses;

(iv) The analytical tecimiques or methods used;

(v) The results ofsuch analyses; and

(vi) The operating conditions as they existed at the time ofsamplingor measurement;

(vii) For the sulfuric acid plants (units 9a and 9b) testing nnder condition FI2(a), whether visible

emissions werepresent, and thedata, assumptions, and calculations usedtodetermine testresults

in terms oflb/hr and lb/ton OfIJ,S04 prodnced.

(viii) For the ammoniumphosphate plant (unit lOa) particulate emissions testing required by condition

FI3(b), the differential pressure across the scrubber and the liquor flow rate to the scrubber as

measured during particulate sampling, and the evaluation of indicator ranges, as required by

condition FI9(a)(iv).

(ix) For the NOx and CO monitoring required by conditions FI7(b), FI9(c), and F21(c), the hours of

operation ofthe auxiliary and packaged boilers (units 8a and 19) and the ammonium phosphate

plant (unit lOa) since the previousNOx and CO emissions tests.

(x) The permittee shall maintain records of any corrective actions taken.

(b) For any Method 9 observationsrequired by the Division uuder conditions F14 and F15(c), the permittee

shall keep field records in accordance with Section 2.2 of Method 9.

(c) The permittee shall retain on-site at the facility, the records ofeach test, measurement, or observation and

support information for a period of at least five years from the datesnch records are generated.

Permit No. 3-2-125-1 Page 12
(F26) P,O, FEED RATE RECORDS [WAQSR Ch 6, Sec 2 Permits CT-550A and MD-384A]

(Modified July 21, 2014)

For the monitoring required under condition F16, the permittee shall record the following:

(a) Reserved

(b) For fluoride emissions and P,O, feed rate monitoring required under condition F 16(h), records as

indicated under condition P63-AA6 ofthis permit

(c) Reserved

(d) The permittee shall retain on-site at the facility the records required by this condition for a period of at

least five years from the date such records are generated.

(F27) LURGI AND MEC SULFURIC ACID PLANTS CAM AND PRODUCTION RECORDS

[WAQSR Ch 6, Sec 3(h)(i)(C)(II); Ch 6, Sec 2 Pennits CT-550A and MD-1l30]

For emissions monitoring required for the Lurgi and MEC sulfuric acid plants (units 9a and 9b) under condition

F18, the permittee shall record the following:

(a) For the CAM visible emissions monitoring required under coudition FI8(a), information as specified

under condition F24. The permittee shall also maintain records (as applicable) of any written quality

improvementplan required pursuantto WAQSR Ch 7, Sec 3(h), any activitiesundertaken to iruplementa

Quality Improvement Plan (QIP), and other supporting information required to be maintained under

WAQSR Ch 7, Sec 3.

(h) For continuous SO, emissions monitoring reqnired by condition FI8(b), records in accordance with

condition P60-H2 ofthis permit.

(c) For NOx emissions monitoring required by condition F18(c), information as specifiedunder conditionF25.

(d) For the sulfuric acid production monitoring required by condition FI8(d), the daily sulfuric acid

production rate for the MEC sulfuric acid plant (unit 9b).

(e) The permittee shall retain on-site at the facility the records required by this condition for a period of at

least five years from the date such records are generated.

(F28) AMMONIUM PHOSPHATE PLANT MONITORING AND CAM RECORDS

[WAQSR Ch 6, Sec 3 (h)(i)(C)(II) and Ch 7, Sec 3]

For emissions monitoring required for the ammonium phosphate plant (unit lOa) under condition F19, the

permittee shall record the following:

(a) For the CAM required nnder condition FI9(a):

(i) The scrubber liquor flow rate and differential pressure over the scrubber, including each 15-

minute block average and each 3-hour rolling average.

(ii) Monitor performance data, including any calibration or maintenance.

(iii) Particulate matter emissionstest results and the evaluation of CAM indicator ranges as specified

by condition FI9(a)(iv).

(iv) The date, time, and duration of any excursions as well as the CAM indicator values during each

excursion.

(v) Any corrective actions taken upon measurement(s) ofindicator values outside the range specified

in the CAM plan.

(vi) The monitoring data, monitor performance data, corrective actions taken, any written quality

improvement plan required pursuant to WAQSR Ch 7, Sec 3(h), any activities undertaken to

iruplement a Quality Improvement Plan (QIP), and other supporting information required tobe

maintained under WAQSR Ch 7, Sec 3.

(b) In the event offuel oil firing in the ammonium phosphate dryer, the sulfur content ofthe fuel oil fired

and the calculations used to estimate SO, emissions.

(c) For the NOx, CO and ammonia emissions, and ammonia percent recovery monitoring required by

condition F19(c) and (e), information as specified under condition F25.

(d) For fluoride emissions monitoring required under condition FI9(d), recordkeeping requirements as

indicated under condition P63-BB6 ofthis permit.

(e) The permittee shall retain on-site at the facility the records required by this condition for a period ofat

least five years from the date such records are generaed,

Permit No. 3-2-125-1 Page 13
(F29) AMMONIUM PHOSPHATE LOADOUT BAGHOUSE MONITORING AND CAM RECORDS

[WAQSR Ch 6, Sec 3 (h)(i)(C)(II) and Ch 7, Sec 3]

(a) For the CAM required for the ammonium phosphate loadout baghouse (unit 12) specified under

condition F20, the permittee shall record the following:

(i) Information from visible emissions monitoring as specified under condition F24.

(ii) Any written quality hnprovementplan required pursuant to WAQSR Ch 7, Sec 3(h), anyactivities

undertaken to implement a Quality Improvement Plan (QIP), and other supporting information

required to be maintained under WAQSR Ch 7, Sec 3.

(b) The permittee shall retain on-site at the facility the records required by this condition for a period of at

least five years from the date such records are generated.

(F30) PACKAGED BOILER RECORDS [WAQSR Ch 6, Sec 3 (h)(i)(C)(II); Ch 6, Sec 2 Permit CT-I043]

For the monitoring required for the packaged boiler (unit 19) under conditionF2 I, the permittee shall recordthe

following:

(a) The hourly heat input to the packaged boiler using the continuous gas flow meter required under

condition F21(a). The total hours during each calendar quarter and calendar year that the heat inputwas

between 122.5 and 350 MMBtu/hr, to assess compliance with condition F9(a).

(b) For NOx emissions monitoringrequired under condition F21(b), continuous NOx emissions monitoring

records as described in condition P60-Db3.

(i) NOx emission records shall be in terms ofIb/MMBtu and Ib/hr.

(ii) The monitoring records shall indicate the dates and times during which the boiler was operating

above 122.5 MMBtu/hr.

(iii) A new 30-day rolling average emission rate in Ib/MMBtu shall be calculated and recorded each

day the packaged boiler is in operation as the average ofall the hourly NOx emission data for the

preceding 30 operating days of the unit.

(c) For CO emissions monitoring required by condition F21(c), information specified under condition F25.

(d) The permittee shall retain on-site at the facility the records required by this condition, including the

boiler hourly heat input log,for a period of at least five years from the date the records are generated.

(F3 I) ENGINE RECORDS AND FSA PRODUCTION RECORDS

[Ch 6, Sec 3 (h)(i)(C)(II); Ch 6, Sec 2 Waivers AP-2532, AP-2205, and wv-I 1961]

(a) The permittee shall maintain records of all maintenance activitiesrequired by conditionFlO, forthe John

Deere Clark engine (unit 29), and the CumminsMI I-P and CumminsKTTA50-G2 engines (units 28 &

30), including the following:

(i) The activity performed;

(ii) The date and place the activity was performed;

(iii) The company and individual(s) that performed the activity;

(iv) The propose ofthe activity; and

(v) An explanation for any deviation fromthe manufacturer's or supplier's recommendations

(b) For monitoring ofoperating hours required by condition F22(a), the permittee shall maintain records of

the total hours of operation ofthe John Deere Clark (unit 29), Cummins MI I-P (unit 28), Cummins

KTTA50-G2 (unit 30), and Cummins GM8.1L (unit 34) engines for each calendar year.

(c) For the emissions monitoring for the Cummins Ml l-P and CumminsGM8.IL engines (units 28 and 34)

required by condition F22(b), the permittee shall maintainthe information specifiedunder conditionF25.

(d) For fluosilisic acid (FSA) monitoring required by condition F22(c), the permittee shall keep a log ofthe

amount ofFSA loaded at the facility.

(e) Records ofTier 3 certification for the John Deere Clark engine (unit 29) shall be maintained.

(I) The permittee shall retain on-site at the facility, the records required under this condition for a period of

at least five years from the date such records are generated.

Reporting Requirements

(F32) SULFUR DIOXIDE EMISSIONS INVENTORY REPORTS

[WAQSR Ch 14, Sec 3(b) and (c)] (Modified July 21, 2014)

(a) The permittee shall report calendar year SO, emissions by April 151h of the following year. The

inventory shall be submitted in the format specified by the Division.

Permit No. 3-2-125-1 Page 14
(b) Emissions from startup, shutdown, and upset conditions shall be included in the inventory.

(c) Ifthe permittee uses a different emission monitoring or calculation method than was used to report S02

emissions in 2006, the permittee shall adjust reported S02 emissions to be comparable to the emission

monitoring or calculation method that was used in 2006. The calculations that are used to make this

adjustment shall be included with the annual emission report.

(d) The annual reports shall be submitted in accordance with condition G4 ofthis permit.

(F33) NOTIFICATIONS & TEST REPORTS [WAQSR Ch 6, Sec 3(h); Ch 6, Sec 2 waivers AP-I0572, wv-11961]

(a) For the testing required for the Cummins M11-P and Cummins GM8.1L engines (units 28 and 34) under

condition F22(b), the permittee shall provide the Division at least 15 days prior notice of the test date.

(b) The permittee shall report the results of any emissions tests required under conditions F12, F13, F14,

FI7(b), F19(b)-(e), F21(c), and F22(b), except fluoride emissions testing required under condition

F13(b)(i)(B), within 45 days of conducting the tests.

(i) However, ifeither Cummins engine (units 28 and 34) is found to be operating out ofcompliance,

the Division must be notified within 24 hours as indicated under condition F22(b).

(c) The requirements forreporting the fluoride emissions testing, referenced in condition F13(b)(i)(B), are

described in condition P63-BB7.

(d) The reports shall include the applicable information specified under condition F25 and shallbe submitted

to the Division in accordance with condition G4.

(F34) MONITORING REPORTS [WAQSRCh 6, Sec 3 (h)(i)(C)(III); Ch6, Sec2 Permits CT-1043 andMD-384A]

(Modified July 21, 2014)

(a) Within 30 days following the end ofeach calendar quarter, the permittee shall report to the Division the

number of hours the packaged boiler (unit 19) operated between 122.5 and 350 MMBtu/hr for that

quarter and calendar year-to-date, as described in condition F30(a).

(b) The following shall be reported to the Division by January 31 and July 31 each year for the previous

semiannual period:

(i) Summary results of the visible emissions monitoring required under condition FI5(a). Only

monitoring during which visible emissions are observed shall be included in the report with a brief

description of any corrective actions taken. If no visible emissions are observed during the

reporting period, this shall be stated in the report.

(ii) Documentationthe auxiliaryboiler (unit8a),the packagedboiler (unit 19),andthe CumminsGM8.IL

emergencyengine (unit 34) are firingnatural gas as specifiedin conditionsF15(b) and F17(a).

(iii) Summary results ofthe visible emissions monitoring conducted under condition F15(c), including

the date, time, and results of each Method 9 observation. For any observation indicating an

exceedance ofthe limits in condition F3(b), include a description ofthe operating conditions as

they existed at the time ofsampling or measurement and any corrective actions taken, as well as

the length oftime the unit operated in exceedance of opacity limits.

(iv) Any exceedances ofthe daily sulfuric acid production limit in condition F6(b). Ifthe production

limit is not exceeded during the reporting period, this shall be stated in the report.

(v) Any exceedances of the fuel oil sulfur content limit and/or the S02 emission limit for the

ammonium phosphate dryer (unit lOa) in condition F7. Ifthe limits are not exceeded during the

reporting period, this shall be stated in the report.

(c) The following shall be reported to the Division by January 31 each year:

(i) Reserved

(ii) The hours of operation of the Cummins KTTA50-G2 generator engine (unit 30), and the

Cummins GM8.IL generator engine (unit 34), during the previous calendar year and any

exceedances ofthe hours of operation limits in condition FlO.

(iii) For units 8a, lOa, and 19, the hours ofoperation for each unit since the last emissionstest required

by conditions F13(b)(ii), FI7(b), and F21(c).

(d) All instances of deviations from the conditions of this permit must be clearly identified in each report.

(e) The reports shall be submitted in accordance with condition G4 ofthis permit.

Permit No. 3-2-125-1 Page 15
(F35) ADDITIONAL CAM MONITORING REPORTS [WAQSR Ch 6, Sec 3 (h)(i)(C)(III) and Ch 7, Sec 3 (i)(i)]

(a) The results of Compliauce AssuranceMonitoring (CAM) required under conditions F18, FI9 and F20

for units 9a, 9b, lOa, and 12, shall be reported to the Division by January31 and July 31 each year and

shall include the following as applicable:

(i) Summaryinformation onthenumber, duration, and cause ofexcursions, and thecorrective actions

taken;

(ii) Summary information on the number, duration, and cause for monitor downtime incidents; and

(iii) A description ofthe action taken to implement a QIP (if required) during the reporting period as

specified in Chapter 7, Section3 (h). Upon completion ofa QIP, thepermittee shall include in

the next summary report documentation that the implementation of the plan has reduced the

likelihood of similar excursions.

(b) All instances of deviations from the conditions of thispermit must be clearly identified in each report.

(c) The reports shall be submitted in accordance with condition G4 of this permit.

(F36) Reserved (Modified July 21, 2014)

(F37) REPORTING EXCESS EMISSIONS & DEVIATIONS FROM PERMIT REQUIREMENTS

[WAQSR Ch 5, Sec 2(g); Ch 6, Sec 3(h)(i)(C)(III); Ch 6, Sec 2 Permits CT.550A, MD·1l30 and CT·1043]

(a) For the phosphoric and superphosphoricacid plants (units lalla', Ib, and2), reporting requirementsfor

excess fluoride emissions are described in condition P63·AA8 of this permit.

(b) For SO, emissions from the Lurgi and MEC sulfuric acid plants (units 9a and 9b), the permittee shall

follow the reporting requirements described in condition P60·H3 of this permit. Excess emissions for

purposesofthose reports are definedas thefollowinginadditionto thosedescribed inconditionPofl-IBtb):

(i) Excess emissionsfor the Lurgi plant (unit 9a) are defined as anyone hourperiodduringwhichthe

average SO, emissions exceed the 316.67 lb/hrlimit specified in condition F6.

(ii) Excess emissionsfor the MEC plant are defmed as anyone hourperiod during whichthe average

SO, emissions exceed either limit of253.3 lb/hr, or 4.0 Ib/tonof I00percent acid produced, as

specified in condition F6.

(c) For the ammoniumphosphate plant (units lOa),reporting requirementsfor excess fluorideemissionsare

described in condition P63·BB8 of this permit.

(d) For NOx emissions from the packaged boiler (unit 19), the permittee shall follow the reporting

requirements describedinconditionPou-Db-t. Excessemissionsforpurposes ofthosereports aredefinedas

the following in additionto those describedin conditionP60·Db4(b):

0) When operating above 122.5MMBtu/hrheat input, excess emissionsare defined as anyone hour

period during which the average NOx emissions exceed 49.00 Ib/hr.

(ii) When operating at 122.5MMBtulhrheat input and below,excessemissions willbe definedas any

one hour period when the average NOx emissions exceeds 17.2 lb/hr.

(iii) At all operating loads, excess emissionsare defined as any 30·day rolling average emissionNOx

emission rate above 0.14 Ib/MMBtu.

(e) Generalreporting requirements are described under the General Conditionsof thispermit. The Division

reserves the right to require reports as provided under condition GI of this permit.

(f) Emissions which exceed the limits specified in this permit and which are not reported under a different

condition of this permit shall be reported annually with the emission inventory unless specifically

supersededby condition G17,conditionG19, or other condition(s) ofthispermit. Theprobable causeof

such exceedanee, the duration ofthe exceedance,the magnitude of the exceedance, and any corrective

actionsor preventative measurestaken shallbe included in this annualreport. Forsourcesandpollutants

whichare not continuouslymonitored, if at anytime emissionsexceedthe limitsspecified in this permit

by 100percent, or if a single episode of emission limit exceedance spans a period of24 hours or more,

such exceedance shall be reported to the Division within one working day ofthe exceedance. (Excess

emissionsdue to an emergencyshall be reported as specified in condition017. Excess emissionsdueto

unavoidable equipment malfunction shall be reported as specified in condition G19.)

(g) Any other deviation fromthe conditionsofthis permit shall be reported to the Division in writing within

30 days of the deviation or discovery of the deviation.

Permit No. 3·2·125·1 Page 16
(F38) GREENHOUSE GAS REPORTS [W.S. 35-11-110]

The permittee shall submit to the Divisiou a summary of any report(s) required to be submitted to the EPA

under 40 CFR Part 98.

(a) The reports shall be submitted to the Division within 60 days ofsubmission to EPA, in a format as

specified by the Division.

(b) The reports shall be submitted in accordance with condition G4(a)(i) ofthis permit, to the attention ofthe

Division's Emission Inventory Program. A copy need not be sent to the DEQ Air Quality contact

Accidental Release Prevention Requirements

(F39) ACCIDENTAL RELEASE PREVENTION REQUIREMENTS [40 CFR Part 68]

(a) The permittee shall meet all requirements of 40 CFR Part 68 as they apply to the facility.

(b) The permittee shall submit, as part ofthe annual compliance certification submitted under condition CI

ofthis permit, a certification statement concerning the facility's compliance with all requirements of40

CFR Part 68, including the registration and submission of a Risk Management Plan.

PSD (Prevention of Significant Deterioration) Applicability Demonstration Requirements

(F40) PROJECT EMISSION LIMITS [WAQSR Ch \,6, Sec 2 Permits/Waivers MD-12795, AP-IOI71, and

AP-12908] (Modified July 21, 2014)

(a) The permittee shall track actual emissions from the sources listed in Table Ill, to demonstrate the 440K

reliability project described in permitMD-12795, the boiler project described in AP-10171, and the

auxiliary boiler project described in waiver AP-12908, do not result in a majormodification under Ch

6, Sec 4 ofthe WAQSR. Actual emissions shall be tracked as described under condition F41.

Ialla'/lb

9a

9b

lOa

11

12

14

P,O, Plants

Lurgi Sulfuric Acid Plannhe

MEC Sulfuric Acid Plant

Ammonium Phosphate Plant

Ammonium Phosphate Loadout

Ammonium Phosphate Baghouse

Gypsum Tailings Pond

(b) For each project, the sum ofthe actual emissions, on a calendaryear basis, from the sources listed in

Table III shall not exceed the corresponding emission levels shown in Table IV:

Permit No. 3-2-125-1

PM,.,

S02

NOx

CO

VOC

56

2002

132

lOS

40

Page 17
Fluorides *

33

38

NOx 50

*Does not include hydrogen fluoride (HF)

(F41) PROJECT EMISSIONS MONITORING [WAQSR Ch 6, Sec 2 Permit/Waivers MD-12795, AP-I 0171, and

AP-12908] (Modified July 21, 2014)

Actual emissions from the sources listed in condition F40(a) shall be determined using the following

methodologies, unless au alternate method is approved by the Division.

(a) For the 440K reliability project described in permit MD-12795:

(i) For PM,.s emissions, actual emissions from point sources shall be determined using the tested

emission rate and operating hours for each source. Fugitive. emissions shall be calculated using

Division approved factors aud control efficiencies

(ii) For SO, emissions, actnal emissions from the Lurgi aud MEC plauts (units 9a and 9b) shall be

determined using the daily average pound per hour emission rate meetingthe requirements ofCh

5, Sec 20). Calendar year SO, emissions shall be determined by multiplying the daily average

SO, pound per hour emission rate by 24, and summing the daily SO, emissions for the calendar

year. Actual emissionsfrom the MAP plaut(unit lOa) shall be determined using AP-42 emissions

factors based on pounds per million staudard cubic foot and actual gas firing rate

(iii) For NOx emissions, actual emissions from the Lurgi and MEC plauts (units 9a and 9b) and MAP

plant (unit lOa) shall be determined using the tested emission rate and opeating hours for each

source.

(iv) ForCo emissions, actual emissions from the MAP plant (unit lOa)shall be determined usingAP-42

emissions factors based on pounds per million staudard cubic foot and actnal gas firing rate.

(v) For VOC emissions, actnal emissions from the MAP plaut (unit lOa) shall be determined using

AP-42 emissions factors based on pounds per million staudard cubic foot aud actnal gas firing rate.

(vi) For H,S04 emissions, actnal emissions from the Lurgi aud MEC plants (units 9a aud 9b) shall be

determined using the tested emission rate aud operating hours for each source

(vii) For fluoride emissions, actual emissions from the phosphoric acid plauts (Sources Iall a'!Ib) shallbe

determined using the tested emission rate aud operating hours for each source. Actual emissions

from the MAP plaut (unit lOa) shall be determined using the tested emissionrate and operatinghours

for the source. Actnal emissions from the gypsum pond are assumed to equal 35 TPY.

(viii) For each source, the permittee shall include fugitive emissions to the extent quantifiable aud

emissions associated with startnps, shutdowns and malfunctions

(b) For the boiler project described in AP-IOI71:

(i) For NOx emissions, actual emissions from the package boiler (unit 19) shall be determined using

the daily average pound per hour emission rate meeting the requirements of Ch 5, Sec 2(j).

Calendar year NOx emissions shall be determined by multiplying the daily average NOx pound

per hour emission rate by 24, aud summing the daily NO< emissions for the calendar year.

(ii) For CO emissions, actnal emissions from unit 19 shall be determined using AP-42 emissions

factors based on pounds per million staudard cubic feu aud actual gas firing rate.

(iii) For PM2.5 emissions, actual emissions from unit 19 shall be determined using AJt42 emissions

factors based on pounds per million standard cubic foot aud actual gas firing rate.

(c) For the auxiliary boiler project described in AP-12908:

(i) Actual NOx emissions from the auxiliary boiler (unit 8a) shall be determined using the most

recent tested emission rate for the unit and actual operating hours for the source.

Permit No. 3-2-125-1 Page 18
(F42) PROJECT NOTIFICATION REQUIREMENTS [WAQSR Ch 6, Sec 2 Permit MD-12795]

(Modified July 21, 2014)

(a) Writteu notification ofthe actual date ofinitial start-up for the 440K reliability project described in

MD-12795 isrequired within 15 days after startup in accordance with Ch 6, Sec 2(i)(ii) ofthe WAQSR,

upon completion ofthe modifications.

(b) Reserved

(F43) PROJECT RECORDKEEPING REQUIREMENTS [WAQSR Ch 6, Sec 2 Permits/Waivers, MD-12795,

AP-I017I, and AP-12908] (Modified July 21, 2014)

The permittee shall monitor emissions for each project in accordance withthe requirementsofconditionF4I(a),

(b), and (c), and shall calculate and maintain a record ofthe annual emissions in tons per calendar year. This

monitoring and recordkeeping shall begin upon startup ofoperations for each project.

(F44) REPORTING REQUIREMENTS [WAQSR Ch 6, Sec 2 Permit/Waivers, MD-12795, AP-IOI71, and

AP-12908j (Modified July 21, 2014)

The permittee shall report to the Division, within 60 days after the end of each calendar year, the following

project reports:

(a) Annual total emissions, for each pollutant listed in condition F40(b), for each source affected by the

440K reliability project listed in F40(a).

(b) Annual total emissions, for each pollutant listed in condition F40(b), for each source affected by the

boiler project listed in F40(a).

(c) Annual total NOx emissions from the auxiliary boiler (unit 8a).

(d) Ifinitialstartup ofequipment after project completion has not yet occurred, that shall be so stated in the

report in place of emissions for that project.

(e) The annual reports shall reference this permit condition (F44) and shall be submitted to the Division in

accordance with condition G4.

(F45) PROJECT COMPLETION CONDITIONS [WAQSR Ch 6, Sec 2 Permit/Waiver, MD-12795,AP-I0171,and

AP-12908j (Modified July 21, 2014)

(a) For each project described in condition F40, the requirements ofconditions F40 - F44 shall expire at the

end offive complete calendar years. The five-year period will start the following calendar year after the

notification ofstartup for each project is submitted to the Division.

(b) The records required by these projects shall be maintained for a period ofat least five years fromthe date

such records are generajed and the records shall be made available to the Division upon request.

Permit No. 3-2-125-1 Page 19
WAQSR CHAPTER 5, SECTION 2 NEW SOURCE PERFORMANCE STANDARDS (NSPS) AND

40 CFR 60 SUBPART Db REOUIREMENTS FOR INDUSTRIAL-COMMERCIAL-INSTITUTIONAL

STEAM GENERATING UNITS

(Modified July 21, 2014)

The subpart is available at http://www.gpoaccess.gov/cfr/retrieve.html. or from the Divisiou upon request.

(P60-Dbl) SUBPART Db REQUIREMENTS

[40 CFR 60 Subpart Db; WAQSR Ch 5, Sec 2 and Ch 6 Sec 2 Permit CT-I043]

The permittee shall meet all requirements of40 CFR 60 Subpart Db and WAQSR Ch 5, Sec 2 astbey apply to

each steam generating boiler as defmed under §60AOb, including the packaged boiler (unit IlJ).

(a) The permittee shall meet all applicable standards for NOx as specified in §60.44b(a)(I). Except as

provided under §60.44bU), compliance is determined on a 30-day rolling average basis. Compliance

with the Ib/MMBtu NOx emission limit in condition F9(b) is considered compliance with

§60.44b(a)(l)(ii).

(b) The NOx standards in Subpart Db apply at all times, including periods of startup, shutdown, and

malfunction.

(P60-Db2) COMPLIANCE DETERMINATION, MONITORING, AND GOOD AIR POLLUTION CONTROL

PRACTICE [40 CFR 60 Subpart Db §§60.46b and 60.48b; WAQSR Ch 5, Sec 2(b), (i), and U); and

Ch 6, Sec 2 Permit CT-1043]

(a) At all times, including periods ofstartup, shutdown, and malfunction, the permittee shall, to the

extent practicable, maintain and operate any affected facility, including associated air pollution

control equipment, in a manner consistent with good air pollution control practice for minimizing

emissions.

(b) Compliance with the NOx emission standards in Subpart Db shall be determined as required by

§60.46b.

(i) The permittee shall determine compliance on a continuous basisthrough the use ofa 30-day

rolling average emission rate. A new 30-day rolling average emission rate is calculated for

each steam generating unit operating day as the average of all ofthe hourlyNOx emission data

for the preceding 30 steam generating unitoperating days.

(c) The permittee shall calibrate, maintain, and operate continuous monitoring systems for emissions from

the boiler as described in 40 CFR 60 Subpart Db, WAQSR Ch 5, Sec 20), and condition F21(b).

(i) The permittee shall calibrate, maintain, and operate a CEMS, and record the output ofthat

system, for measuring theNOx and oxygen (or carbon dioxide) emissions discharged to the

atmosphere. The CEMs shall meet the applicable requirements of§60.48b(b), (c), (d), (e),

and (I).

(ii) The CEMS shall be operated and data recorded during all periods ofoperation of the packaged

boiler except for CEM breakdowns and repairs. Data is recorded during calibration checks, and

zero and span adjustments.

(iii) Due to limited operation ofthe boiler the permittee may, in lieu ofthe annual relative accuracy

test audit, perform the following as allowed under WAQSR Ch 5, Sec 2U)(ix)(B):

(A) Three-point gas calibrations for ppm NOx each quarter,

(B) Two-point gas calibrations for oxygen each quarter, and

(C) Quarterly air flow calibrations per the approved quality assurance/quality control plan.

(P60-Db3) RECORDKEEPING [40 CFR 60 Subpart Db §60.49b; WAQSR Ch 5, Sec 2(g)(ii) and (g)(v); andCh 6,

Sec 2 Permit CT-I043]

The permittee shall maintain records as required by WAQSR Ch 5 Sec 2(g), §60!l9b, and condition F30(b).

(a) The permittee shall maintain records ofthe occurrence and duration of any startup, shutdown, or

malfunction in the operatiou of the packaged boiler; any malfunction ofthe air pollution control

equipment; or any periods during which a continuous monitoring system or monitoring device is

inoperative.

(b) The permittee shall record and maintain records regarding fuel use as required by§60.49b(d).

(c) The permittee shall maintain records as required by the applicable requirements of §60.49b(g) and (p).

(d) The permittee shall maintain records of all measurements, including continuous monitoring system,

monitoring device, and performance testing measurements; all continuous monitoring system

Permit No. 3-2-125-1 Page 20
performance evaluations; all continuous monitoring system or monitoring device calibration checks;

adjustments and maintenance performed on these systems or devices; reports; and other information

required by the P60 conditions ofthis permit recorded in a permanent form suitable for inspection.

(c) These records shall be retained on-site at the facility for a period ofat least five years from the date such

records are generated.

(P60-Db4) EXCESS EMISSIONS AND MONITORING SYSTEM PERFORMANCE REPORTS

[40 CFR 60 Subpart Db §60.49b and WAQSR Ch 5, Sec 2(g)(iii) & (iv)]

The permittee shall submit reports as described in WAQSR Ch 5 Sec 2(g), §60.49b, and condition F37(d).

(a) The permittee shall submit an excess emissions and monitoring systems performance report (excess

emissions are defined in paragraph (b) ofthis condition) and/or a summary report form (see paragraph

(a)(v) ofthis condition) to the Administrator quarterly. All reports shall be postmarked by the 30th day

following the end of each calendar quarter. Written reports of excess emissions shall be in a format

approved by the Division and shall include the following information:

(i) The information described in §60.49b(g).

(ii) The magnitude of excess emissions computed in accordance with WAQSR Ch 5, Sec 2 U)(viii),

any conversion factor(s) used, and the date and time of commencement and completion of each

time period of excess emissions. The process operating time during the reportingperiod.

(iii) Specific identification ofeach period ofexcess emissions that occurs during start ups, shutdowns,

malfunctions ofthe boiler. The nature and cause of any malfunction (if known), the corrective

action taken or preventative measures adopted

(iv) The date and time identifying each period during which the continuous monitoring system was

inoperative except for zero and span checks and the nature ofthe system repairs or adjustments.

(v) When no excess emissions have occurred or the continuous monitoring system(s)have not been in

operative, repaired, or adjusted, such information shall be stated in the report.

(vi) One sununaryreport form for each pollutantmonitored for the boiler iu a format approved by the

Division.

(A) Ifthe total duration ofexcess emissions for the reporting period is less than one percent of

the total operating time for the reporting period and continuous monitoring system

downtime for the reporting period is less than five percent ofthe total operating time for

the reporting period, only the summary report form shall be submitted and the excess

emission report described in paragraph (a) ofthis condition need not be submitted unless

requested by the Administrator.

(B) Ifthe total duration ofexcess emissions for the reporting period is one percent or greater of

the total operating time for the reporting period or the total continuous monitoring system

downtime for the reporting period is five percent or greater ofthe total operating time for

the reporting period, the summaryreport form and the excess emissionreport described in

paragraph (a) ofthis condition shall both be submitted.

(b) For purposes ofreporting under this condition, excess emissions are defined as any calculated 3D-day

rolling average NOx emission rate, as determined in condition P60-Db2, that exceeds standards for NOx

as specified in §60.44b(a)(I). Excess emissions are further defined in condition F37(d)

(c) Notwithstanding the frequency ofreporting requirements specified in paragraph (a) ofthis condition, a

permittee who is required by an applicable subpart to submit excess emissions and monitoring systems

performance reports (and summary reports) on a quarterly (or more frequent) basis may reduce the

frequency ofreporting for that standard to semiannual as described in WAQSR Ch 5, Sec 2(g)(iv). Any

reduction in reporting frequency requires a significantmodification to this operating permit pursuantto

WAQSR Ch 6, Sec 3(d)(vi)(C).

(d) The permittee shall submit reports required by the applicable requirements of§60.49b(b), (c), and

(q).

(e) The reports shall be submitted to the Division in accordance with condition G4 ofthis permit.

Permit No. 3-2-125-1 Page 21
WAOSR CHAPTER 5, SECTION 2 NEW SOURCE PERFORMANCE STANDARDS (NSPSl

AND 40 CFR 60 SUBPART H REOUIREMENTS FOR SULFURIC ACID PLANTS

(Modified July 21, 2014)

The subpart is available at http://www,gpoacccss.gov/cfr/retrieve.html, or from the Divisiou upon request.

The permittee shall meet all standards specified in §60.82 and §60.83. Compliance with the lb/ton SO, and

acid mist limits in condition F6, and with the opacity limit in condition F3(a), is considered compliance with

§60.82 and §60.83.

The permittee shall calibrate, maintain, and operate a continuous in-stack monitoring system on each sulfuric

acid plant (units 9a and 9b) for measuring SO, emissions. Each monitoring system shall meet the

requirementsspecified in §60.84 and WAQSR Ch 5 Sec 2(i) and shall determine SO, emissions in Ib/ton of

acid produced and lb/hr,

(b)

SUBPART H REQUIREMENTS

[40 CFR 60 Subpart H; WAQSR Ch 5, Sec 2 and Cb 6, Sec 2 Permits CT-550A and MD-l130]

The permittee shall meet all requirements ofWAQSR Ch 5, Sec 2 and 40 CFR 60 Subpart H as they apply to each

sulfuric acid production unit defined under §60.80, including the Lurgi and MEC sulfuric acid plants (units 9a and

9b).

(a)

(P60-Hl)

(P60-H2)

(a)

(b)

(c)

RECORDKEEPING [40 CFR 60 Subpart H; WAQSR Ch 5, Sec 2(g)(ii)]

The permittee shall maintain records ofthe occurrence and duration ofany startup, shutdown, or malfunction

in the operation ofthe Lurgi and MEC sulfuric acid plants; any malfunction ofthe air pollution control

equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative.

The permittee shall maintain records of all measurements, including continuous monitoring system,

monitoring device,and performance testing measurements; all continuousmonitoring system performance

evaluations; all continuons monitoring system or monitoring device calibration checks; and adjustments and

maintenance performed on these systems or devices. The permittee shall also maintain anyrecords required

by §60.84.

All information required by these conditions shall be recorded in a permanent form suitable for inspection

and retained on-site at the facility for a period ofat least five years from the date such records are generated.

(P60-H3)

(a)

(b)

(c)

EXCESS EMISSIONS AND MONITORING SYSTEM PERFORMANCE REPORTS

[WAQSR Ch 5, Sec 2(g)(iii) and (iv); 40 CFR 60 Subpart H]

The permittee shall submit a Subpart H excess emissions and monitoring systemsperformance report (excess

emissions are defined in paragraph (b) ofthis condition) to the Administrator quarterly. All reports shall be

in a format approved by the Division, and postmarked by the 30th day following the end of each calendar

quarter. A separate written report shall be submitted for each sulfuric acid plant, and shall include the

following information:

(i) The magnitude of excess emissions computed in accordance with WAQSR Chapter 5, Section 2

(i)(viii), any conversion factor(s) used, and the date and tiroe of conunencementand completion of

each time period of excess emissions. The process operating time durirg the reporting period.

(ii) Specific identification of each period ofexcess emissionsthat occurs during start ups, shutdowns, or

malfunctions ofthe Lurgi and MEC sulfuric acid plants. The nature and cause ofany malfunction (if

known), the corrective action taken or preventative measures adopted.

(iii) The date and time identifying each period during which the continuous monitoring system was

inoperative except for zero and span checks and the nature ofthe system repairs or adjustments.

(iv) When no excess emissions have occurred or the continuous monitoring system(s) have not been

inoperative, repaired, or adjusted, such information shall be stated in the report.

For the purpose ofreporting under §60.7(c), periods ofexcess emissions shall be a1l3-hour periods (or the

arithmetic average ofthree consecutive l-hour periods) during which the integrated average sulfur dioxide

emissions exceed 4 lb/ton of acid produced, productiou beiug expressed as 10CPIo sulfuric acid.

The reports shall be submitted to the Division in accordance with condition G4 ofthis permit,

(P60-H4) GOOD AIR POLLUTION CONTROL PRACTICE [WAQSR Ch 5, Sec 2 (i)(iv)]

At all times, including periods ofstartup, shutdown, and malfunction, the permittee shall, to the extent practicable,

maintain and operate the Lurgi and MEC sulfuric acid plants including associated air pollution control equipment in

a manner consistent with good air pollution control practice for miniroizing emissions.

Permit No. 3-2-125-1 Page 22
WAOSR CHAPTER 5, SECTION 2 NEW SOURCE PERFORMANCE STANDARDS fNSPSl AND

40 CFR 60 SUBPART 1111 REOUIREMENTS

FOR STATIONARY COMPRESSION IGNITION INTERNAL COMBUSTION ENGINES

(Modified July 21,2014)

SUBPART nn REQUlREMENTS

[40 CPR60 Subparts Aaud IIII;WAQSRCh5, Sec2 aud Ch 6,Sec2 WaiversAP-2532, wv-11961 and wv-12054]

As applicable, the permittee shall meet the requirements of40 CFR 60 Subparts A and IlII and WAQSR Ch 5,

Sec 2, as they apply to stationary compression ignition (CI) internal combustion engines. (As required by

condition Fll(c), if an engine is replaced or reconstructed, subpart applicability will need to be

reevaluated and a statement regarding applicability submitted to the Dlvlsion.) For the purposes of this

subpart, the date that construction commences is the date the engine is ordered by the owner or operator. An

affected source is defmed at §60.4200.

On April 10, 2014, the emergency boiler feed water pump engine (unit 27), Cummins Mll-P tailings

booster pump engine (nnit 28), and Cummins KTTA50-G2 emergency generator engine (unit 30) were

not subject to SUbpart 1111 according to information submitted to the Division by the permittee, The

Johu Deere Clark emergency engine (unit 29) must meet the requirements of Subpart ZZZZ by meeting

the requiremeuts of 40 CFR 60, Subpart 1111, However, on April 10, 2014, the John Deere Clark

emergency engine (unit 29) had uo applicable requirements from Subpart 1111 because of its date of

manufacture,

WAOSR CHAPTER 5, SECTION 2 NEW SOURCE PERFORMANCE STANDARDS (NSPSl

AND 40 CFR 60 SUBPART JJJJ REOUIREMENTS

FOR STATIONARY SPARK IGNITION INTERNAL COMBUSTION ENGINES

(Modified July 21, 2014)

SUBPARTJJJJREQUlREMENTS [40CPR60Subparts A and JJJJ;WAQSRCh5, Sec2 aud Ch 6,Sec2 Waiver AP-I0572]

As applicable, the permittee shall meet all requirements of40 CFR 60 Subparts A aud JJJJ and WAQSR Ch 5,

Sec 2, as they apply to affected stationary spark ignition (SI) internal combustion engines (ICE). (As required

by condition F11(c), ifan engine is replaced or reconstructed, subpart applicability will need to be reevaluated

and a statement regarding applicability submitted to the Division.) For the purposes ofthis subpart,the datethat

construction commences is the date the engine is ordered by the owner or operator. An affected source is

defined at §60.4230, including the Cummins GM8,IL emergency generator (unit 34).

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS fNESHAPsl

40 CFR 61 SUBPART R REOUlREMENTS FOR RADON EMISSIONS FROM PHOSPHOGVPSUM STACKS

(Modified Jnly 21, 2014)

40 CFR61 SUBPARTRREQUIREMENTS [40 CFR61 Subparts A andR]

The permittee shall meet all requirements of 40 CFR 61 Subparts A and R as they apply to each

phosphogypsum stack as defined under §61.200, including the gypsum tailings pond (unit 14).

The subparts are available at http://www.gpoaccess.gov/cfr/retrieve.html. or from the Division upon request.

Permit No. 3-2-125-1 Page 23
WAOSR CHAPTER 5, SECTION 3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLLUTANTS (NESHAPs) AND 40 CFR 63 SUBPART AA REOUIREMENTS FOR

PHOSPHORIC ACID MANUFACTURING PLANTS

(Modified July 21,2014)

The subpart is available at http://www.gpoaccess.gov/cfr/retrieve.btml, or from the Division upon request.

(P63-AAI) 40 CFR63 SUBPART AA REQUIREMENTS [WAQSRCh 5, Sec 3 and 40 CFR63 SubpartAA]

The permittee shall meet all requirements of40 CFR 63 Subpart AA and WAQSR Chapter 5, Section 3 as they

apply to phosphoric acid manufacturingplants defined under §63.600. Affected sources include the phosphoric

acid plant #1 (unit lalla'), phosphoric acid plant #2 (unit lb), superphosphoric acid plant (unit 2).

(a) The permittee shall meet all applicable standards in §§63.602 and 63.603 for existing and new affected

facilities by the dates specified in §63.609.

(i) Compliance with the lb/ton fluoride emission limits in condition F4 shall be considered

compliance with §§63.602 and 63.603 for the phosphoric acid plants (units lalla', and lb).

(ii) Compliance with the lb/ton fluoride emission limits in condition F4 shall be considered

compliance with §63.602 for the superphospboric acid plant (unit 2).

(iii) Reserved

(b) For any wet scrubbing emission control system used on equipment subject to Subpart AA, the permittee

shall maintain dailyaverages ofthe pressure drop across each scrubber and ofthe flow rate ofthe scrubbing

liquid to each scrubber within the allowable ranges established pursuant to §63.605(d)(1) or (2).

(c) The emission lhuitations and operating parameter requirements ofthis condition do not apply during

periods ofstartup, shutdown, or malfunction, provided that the affected source is operated in accordance

with condition P60-AA4, §63.6(e)(l)(i), and the Startup, Shutdown, and Malfunction Plan prepared

pursuant to condition P60-AA5.

(P63-AA2)

(a)

(b)

(c)

(P63-AA3)

(a)

(b)

TESTING REQUIREMENTS [40 CFR 63 Subpart AA §63.606 and WAQSR Ch 5, Sec 3(h) and (i)]

The permittee shall demonstrate initial compliance with the emission standards in condition P63-AAl

using the test methods and procedures in §63.606, and WAQSR Ch 5, Sec 3(i).

Performance tests required under §63.606 shall be repeated every calendar year. Testing shall also

determine lb/hr fluoride emissions for comparison to the limits in conditionF4.

Performance testing shall meet all requirementsfor documentation, quality assurance, and other criteria

in §63.606 and WAQSR Ch 5, Sec 3(i).

MONITORING REQUIREMENTS [40 CFR 63 Subpart AA; WAQSR Ch 5, Sec 3(j) and Ch 6, Sec 2

Permit CT-550AJ

For the phosphoric acid plants (units lalla', and Ib) and the superphosphoric acid plant (unit 2), the

permittee shall:

(i) Calibrate, maintain, and operate a monitoring system which can be used to determine and

permanently record tbe mass flow of phosphorus-bearing feed material to the process. The

monitoring system shall have an accuracy of±5 percent over its operating range. Equivalent P20S

feed rate shall be calculated using the specifications in §63.606(c)(3).

(ii) For any wet scrubbing emission control system, the permittee shall calibrate, maintain, and

operate the following:

(A) A monitoring system which continuously measures and permanently records the pressure

drop across each scrubber in the process scrubbing system in IS-minute block averages.

The monitoring system shall be certified by the manufacturerto have an accuracy of±5

percent over its operating range.

(B) A monitoring system which continuouslymeasures 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 manufacturerto have an

accuracy of±5 percent over its operating range.

Except for system breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks,

and zero (low-level) and high-level calibration drift adjustments, all CMSs (continuous monitoring

systems) required by Subpart AA shall be in continuous operatiou.

Permit No. 3-2-125-1 Page 24
(c)

(p63-AA4)

(a)

(b)

(P63-AA5)

(a)

(b)

(c)

(d)

(e)

(I)

(g)

(p63-AA6)

(a)

(b)

(i) The permittee must keep the necessary parts for routine repairs of the CMS equipment readily

available.

(ii) Additional CMS requirements are specified in Ch 5 Sec 3(j)(iii)(A-C) and (iv).

The permittee shall meet all other applicable monitoring requirements as specified in §63.605 and

WAQSR Ch 5, Sec 3(j)(ii), (vi), and (vii).

OPERATION & MAINTENANCE REQUIREMENTS [WAQSR Ch 5, Sec 3(h)(iv)(A)(l) and (II)]

At all times, including periods ofstartup, shutdown, and malfunction, the permittee shall operate and

maintain the affected sources, including associated air pollution control equipment, in a manner

consistentwith good air pollution control practices for minimizing emissions as required by Ch 5 Sec 3.

Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the

startup, shutdown, and malfunction plan required in condition P63-AA5 ofthis permit.

STARTUP, SHUTDOWN, AND MALFUNCTION PLAN [WAQSR Ch 5, Sec 3 (h)(iv)(C)]

The permittee shall maintain and implement a written startup, shutdown, and malfunction plan (SSMP)

that describes, in detail, procedures for operating and maintaining the source during periods ofstartup,

shutdown, and malfunction, and a program of corrective action for malfunctioning process and air

pollution control equipment used to comply with Subpart AA. The plan shall identify all routine or

otherwise predictable CMS malfunctions.

During periods of startup, shutdown, and malfunction, the permittee shall operate and maintain all

affected sources (including associated air pollution control equipment) in accordance with the procedures

specified in the SSMP developed under paragraph (a) ofthis condition.

When actions taken by the permittee during a startup, shutdown, or malfunction (including actions taken

to correct a malfunction) are consistent with the procedures specified in the SSMP, the permittee shall

keep records for that event that demonstrate the procedures specified in the plan were followed. These

records may take the form of a "checklist," or other effective form ofrecordkeepiog, that confirms

conformance with the SSMP for that event.

Ifan action taken by the permittee during a startup, shutdown, or malfunction (including an action taken

to correct a malfunction) is not consistent with the procedures specified in the SSMP, the permittee shall

record the actions taken for that event.

The permittee shall keep the written SSMP on record to be made available for inspection, upon request,

by the Administrator for the life of each affected source or until the affected source is no longersubject

to the provisions ofChapter 5, Section 3. In addition, if the SSMP is revised, the permittee shall keep

previous (i.e., superseded) versions ofthe SSMP 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.

To satisfy the requirements ofthis condition to develop a SSMP, the permittee may usetheir standard

operating procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) or

other plan, provided the alternative plans meet all the requirements ofChapter 5, Section 3 and are made

available for inspection when requested by the Administrator.

If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a

malfunction but was not included in the SSMP at the time the permittee developed the plan, the permittee

shall revise the SSMP within 45 days after the event to include detailed procedures for operating and

maintaining the source during similar malfunction events and a program ofcorrective action for similar

malfunctions of process or air pollution control equipment.

RECORDKEEPING REQUIREMENTS

[40 CFR 63 Subpart AA and WAQSR Ch 5, Sec 3(l)(ii) and (iii)]

The permittee shall maintain files ofall information (including all reports and notifications) required by

Subpart AA and Chapter 5, Section 3 recorded in a form suitable and readily available for expeditious

inspection and review. The files shall be retained for at least 5 years following the date of each

occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, themost

recent 2 years of data shall be retained on site at the facility. The remaining 3 years of data may be

retained offsite. Such files may be maintained on microfilm, on a computer, on computer floppy disks,

on magnetic tape disks, or on microfiche.

The permittee shall maintain relevant records for each affected source ofthefollowing:

Permit No. 3-2-125-1 Page 25
(i) For each phosphoric acid plant (units la/la', and Ib) and the superphosphoricacid plant(unit 2),

a daily record of equivalent P,O, feed, determined as described in condition P63-AA3(a)(i);

(ii) The occurrence and duration of each startup, shutdown, or malfunction ofoperation (i.e., process

equipment);

(iii) The occurrence and duration of each malfunction ofthe air pollution control equipment;

(iv) All maintenance performed on tbe air pollution control equipment;

(v) Actionstaken during periods ofstartup, shutdown, and malfunction (including corrective actions

to restore malfunctioning process and air pollution control equipment to its normal or usual

mauner ofoperation) when such actions are different from the procedures specified in tbe SSMP;

(vi) All information necessary to demonstrate conformance with the SSMP when all actions taken

during periods of startup, shutdown, and malfunction (including corrective actions to restore

malfunctioning process and air pollution control equipment to its normal or usual mauner of

operation) are consistent with the procedures specified in such plan. (The information needed to

demonstrate conformance with the SSMP may be recorded using a "checklist," or some other

effective form ofrecord keeping, to minimize the recordkeeping burden for conforming events);

(vii) Eacb period during which a CMS is malfunctioning or inoperable (including out-of-control

periods);

(viii) All required measurements needed to demonstrate compliance with Subpart AA;

(ix) All results of performance tests, in units oflb/ton and lb/hr;

(x) All CMS calibration checks, and all adjustments and maintenance performed on the CMSs;

(xi) All measurements as may be necessary to determine the conditions of performance tests and

performance evaluations;

(xii) All documentation supporting initial notifications and notifications of compliance status under

condition P63-AA 7 ofthis permit.

(xiii) All records of applicability determination, including supporting analysis;

(xiv) All other records for CMSs required by Ch 5 Sec 3(1)(iii)(A), (B), (D-I), and (K).

(xv) All other records required by Subpart AA and Chapter 5, Section 3.

(P63-AA7) NOTIFICATION REQUIREMENTS

[40 CFR 63 Subpart AA §63.607 and WAQSR Ch 5, Sec 3(h), (i), U), and (k)]

(a) The permittee shall submit notifications required underthis permit condition (P63-AA7), Subpart AA,

and Chapter 5, Section 3 to the Administrator and U.S. EPA Region VIII in accordance with condition

G4 ofthis permit.

(h) The permittee shall notify the Administrator in writing oftheir intention to conduct any performance test

required by condition P63-AA2 at least 60 calendar days before the performance test is scheduled to

begin.

(c) The permittee shall submit a Notification of Compliance Status upon completion of any relevant

compliance demonstration activity specified in Subpart AA. This shall include the results in lb/ton and

Ib/hr ofany performance test required under condition P63-AA2, which shall be reported within 60 days

ofcompleting the test. Tbe Notification ofCompliance Status shall include all information required by

Ch 5, Sec 3(k)(viii).

(d) The permittee shall submit all other notifications as required by 40 CFR Subpart AA and WAQSR Ch 5

Sec 3.

(P63-AA8) REPORTING REQUIREMENTS [40 CFR 63 SubpartAA §§63.602, 63.603, and 63.607; and WAQSR

Ch 5, Sec 30) and Sec 3(1)(i), (iv), and (v)]

(a) The permittee shall submit reports required under this permit condition (P63-AA8), Subpart AA, and

Chapter 5, Section 3 to the Administrator and U.S. EPA Region VIII in accordance with condition G4.

(h) As part ofthe armual compliance certification, the permittee shall certify whether or not any liquid

effluentfrom any wet scrubbing device installed to control emissions from process equipment subject to

Subpart AA, has been introduced into any affected evaporative cooling tower.

(c) The permittee shall submit Subpart AA emissionsreports for any exceedance ofan operating parameter

limit, postmarked or delivered by January 30 and July 30 each year. If exceedances are reported, the

permittee shall report quarterly until a request to reduce frequency is approved as described in Ch 5, Sec

3(l)(v). The summary report shall include:

Permit No. 3-2-125-1 Page 26
(i) All exceedances ofpressure drop or flow rate limitations specified in P63-AAI(b);

(ii) All other information listed in WAQSR Ch 5, Sec 3(l)(v)(C)(VI), except CMS performance

reports are not required;

(iii) When no exceedances of an operating parameter have occurred, such information shall be

included in the report; and

(iv) The name, title, and signature ofthe responsible official who is certifying the accuracy ofthe

report.

(d) Ifthe total duration ofoperating parameter exceedances for a reporting period is I percent or greater of

the total operating time for that reporting period, the permittee shall submit a summary report, as

described in paragraph (c) above, and an excess emissions report. The reports shall be postmarked or

delivered within 30 days ofthe end ofthe calendar quart". and shall include the following:

(i) Information required by WAQSR Ch 5, Sec 3(1)(iii)(B) and (D) through (I);

(ii) The name, title, and signature of the responsible official who is certifying the accuracy ofthe

report.

(e) Periodic startup, shutdown, and malfunction reports:

(i) Ifactions taken by the permittee during a startup, shutdown, or malfunction ofan affected source

(including actions taken to correct a malfunction) are consistent with the procedures specified in

the source's SSMP, the permittee shall state such information in a startup, shutdown, and

malfunction report. Reports shall only be required ifa startup, shutdown, or malfunctionoccurred

during the reporting period. The startup, shutdown, and malfunction report shall consist of a

letter, containing the name, title, and signature ofthe responsible official who is certifying its

accuracy, which shall be submitted to the Administrator semiannually. The startup, shutdown,

and malfunction report shaJJbe delivered or postmarked by the 30th day followingthe end ofeach

calendar half, and may be submitted simultaneously with the Subpart AA emissions reports.

(ii) Immediate startup, shutdown, and malfunction reports. Any time an action taken by a permittee

during a startup, shutdown, or malfunction is not consistent with the procedures in the SSMP, the

permittee shall make a report ofthe actions taken for the event within 24 hours, by telephone call

or facsimile (FAX) transmission. The immediate report shall be followed by a letter, deliveredor

postmarked within 7 working days after the end ofthe event, that contains the name, title, and

signature oflhe responsible official who is certifying its accuracy, explaining the circumstancesof

the event, the reasons for not following the SSMP, and whether any excess emissions and/or

operating parameter exceedances are believed to have occurred.

(iii) For those malfunctions and or other events that affect a CMS and are not addressed bythe SSMP,

the permittee shall send a follow-up report within 2 weeks after commencingactions inconsistent

with the plan that either certifies that corrections have been made or includes a corrective action

plan and schedule. The permittee shall provide proofthat repair parts have been ordered or any

other records that would indicate that the delay in making repairs is beyond their control.

(I) The permittee shall submit all other reports as required by §63.607 and Chapter 5, Section 3.

Permit No. 3-2-125-1 Page 27
WAOSR CHAPTER 5, SECTION 3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLLUTANTS (NESHAPs) AND 40 CFR 63 SUBPART BB REOUIREMENTS

FOR PHOSPHATE FERTILIZERS PRODUCTION PLANTS

(Modified July 21, 2014)

The subpart is available at http://www.gpoaeeess.gov/cfr/retrieve.html. or from the Division upon request.

(P63-BBl) 40 CFR63 SUBPARTBB REQUIREMENTS [WAQSRCh 5, Sec 3 and 40 CFR63 SubpartBB]

The permittee shall meet allrequirements of 40 CFR 63 SubpartBB and WAQSR Chapter 5, Section 3 as they

apply to the affected sources described in §63.620. Affected sources include the ammoniumphosphate plant

(unit lOa) process line (reactor, granulator, dryer, cooler, and screens).

(a) The permittee shall meet all applicable standards in §§63.622 and 63.623 for existing and new affected

sources. Compliance with the lb/ton fluoride emission limits in condition F7 shall be considered

compliance with §63.622 for the ammonium phosphate plant (unit lOa).

(b) For any wet scrubbing emission control system used on equipmentsubject to SubpartBB, the permittee

shall maintain daily averages of the pressure drop across each scrubber and of the flow rate of the

scrubbing liquid to each scrubber within the allowable ranges established pursuant to §63.625(f)(1) or

(2).

(c) The emission limitations and operating parameter requirements ofthis condition do not apply during

periods ofstartup, shutdown, or malfunction, provided that the affected source is operated in accordance

with condition P60-BB4, §63.6(e)(1)(i), and the Startup, Shutdown, and Malfunction Plan prepared

pursuant to condition P60-BB5.

(P63-BB2)

(a)

(b)

(c)

(P63-BB3)

(a)

(b)

(c)

TESTING REQUIREMENTS [40 CFR 63 Subpart BB and WAQSR Ch 5, Sec 3(h) and (i)]

The permittee shall demonstrate initial compliance with the emission standards in condition P63-BBI

using tbe test methods and procedures in §63.626, and WAQSR Ch 5, Sec 3(i). .

Performance tests required under §63.626 shall be repeated every calendar year. Testing shall also

determine lblhr fluoride emissions for comparison to the limit in condition F7.

Performance testing shall meet all requirements for documentation, quality assuranee, and other criteria

in §63.626 and WAQSR Ch 5, Sec 3(i).

MONITORING REQUIREMENTS [40 CFR 63 Subpart BB; WAQSR Ch 5, Sec 3G) and Ch 6, Sec 2

Permit CT-550A]

For each affected source, the permittee shall:

(i) Calibrate, maintain, and operate a monitoring system which can be used to determine and

permanently record the mass flow of phosphorus-hearing feed material to the process. The

monitoring system shall have an accuracy of±5 percent over its operating range. Equivalent1',0,

feed rate shall be calculated using the specifications in §63.626(c)(3).

(ii) For any wet scrubbing emission control system, the permittee shall calibrate, maintain, and

operate the following:

(A) A monitoring system which continuously measures and permanently records the pressure

drop across each scrubber in the process scrubbing system in 15-minute block averages.

The monitoring system shall be certified by the manufacturer to have an accuracy of±5

percent over its operating range.

(B) 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 IS-minute

block averages. The monitoring system shall be certified by the manufacturerto have an

accuracy of±5 percent over its operating range.

Except for system breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks,

and zero (low-level) and high-level calibration drift adjustments, all CMSs (continuous monitoring

systems) required by Subpart BB shall be in continuous operation.

(i) The permittee must keep the necessary parts for routine repairs of the CMS equipment readily

available.

(ii) Additional CMS requirements are specified in Ch 5 Sec 3(j)(iii)(A-C) and (iv).

The permittee shall meet all other applicable monitoring requirements as specified in §63.625 and

WAQSR Ch 5, Sec 3(j)(ii), (vi), and (vii).

Permit No. 3-2-125-1 Page 28
(P63-BB4)

(a)

(b)

(P63-BB5)

(a)

(b)

(c)

(d)

(e)

(f)

(g)

(p63-BB6)

(a)

(b)

OPERATION & MAINTENANCE REQUIREMENTS [WAQSR Ch 5, Sec 3(h)(iv)(A)(I) and (II)]

At all times, including periods ofstartup, shutdown, and malfunction, the permittee shall operate and

maintain the affected sources, including associated air pollution control equipment, in a manner

consistent with good air pollution control practices for minimizing emissions as required by Ch 5 Sec 3.

Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the

startup, shutdown, and malfunction plan required in condition P63-BB5 ofthis permit.

STARTUP, SHUTDOWN, AND MALFUNCTION PLAN [WAQSR Ch 5, Sec 3 (h)(iv)(C)]

The permittee shall maintain and implement a written startup, shutdown, and malfunction plan (SSMP)

that describes, in detail, procedures for operating and maintaining the source during periods of startup,

shutdown, and malfunction, and a program of corrective action for malfunctioning process and air

pollution control equipment used to comply with Subpart BB. The plan shall identify all routine or

otherwise predictable CMS malfunctions.

During periods of startup, shutdown, and malfunction, the permittee shall operate and maintain all

affected sources (including associated air pollution control equipment) in accordance with the procedures

specified in tbe SSMP developed under paragraph (a) ofthis condition.

When actions taken by the permittee during a startnp, shutdown, or malfunction (including actions taken

to correct a malfunction) are consistent with the procedures specified in the SSMP, the permittee shall

keep records for that event that demonstrate the procedures specified in the plan were followed. These

records may take the form of a checklist," or other effective form of recordkeeping, that confirms

conformance with the SSMP for that event.

Ifan action taken by the permittee during a startup, shutdown, or malfunction (including an action taken

to correct a malfunction) is not consistentwith the procedures specified in the SSMP, the permittee shall

record the actions taken for that event.

The permittee shall keep the written SSMP on record to be made available for inspection, upon request,

by the Administrator for the life of each affected source or until the affected source is no longer subject

to the provisions ofChapter 5, Section 3. In addition, if the SSMP is revised, the permittee shall keep

previous (i.e., superseded) versions ofthe SSMP 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.

To satisfy the requirements of this condition to develop a SSMP, the permittee may use their standard

operating procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) or

other plan, provided the alternative plans meet all the requirements ofChapter 5, Section 3 and are made

available for inspection when requested by the Administrator.

If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a

malfunction but was not included in the SSMP at the time the permittee developed the plan, the permittee

shall revise the SSMP within 45 days after the event to include detailed procedures for operating and

maintaining thesource during similar malfunction events and aprogram of corrective action forsimilar

malfunctions of process or air pollution control equipment.

RECORDKEEPING REQUIREMENTS

[40 CFR 63 Subpart BB and WAQSR Ch 5, Sec 3(l)(ii) and (iii)]

The permittee shall maintain files ofall information (including all reports and notifications) required by

Subpart BB and Chapter 5, Section 3 recor7ded in a form suitable and readily available for expeditious

inspection and review. The files shall be retained for at least 5 years following the date of each

occurrence, measurement, maintenance, corrective action, report, orrecord. At a minimum, themost

recent 2 years of data shall be retained on site at the facility. The remaining 3 years of data may be

retained offsite. Such files may be maintained on microfihn, on a computer, on computerfloppy disks,

on magnetic tape disks, or on microfiche.

The permittee shall maintain relevant records for each affected source ofthe following:

(i) For the ammoniumphosphate plant(unit lOa), a daily record ofequivalent P20 , feed, determined

as described in condition P63-BB3(a)(i);

(ii) The occurrence and duration ofeach startup, shutdown, or malfunction of operation (i.e., process

equipment);

(iii) The occurrence and duration of each malfunction ofthe air pollution controlequipment;

(iv) All maintenance performed on the air pollution control equipment;

Permit No. 3-2-125-1 Page 29
(v) Actions taken during periods ofstartup, shutdown, and malfunction (including corrective actions

to restore malfunctioning process and air pollution control equipment to its normal or usual

manner of operation) when such actions are different from the procedures specified in the SSMP;

(vi) All information necessary to demonstrate conformance with the SSMP when all actions taken

during periods of startup, shutdown, and malfunction (including corrective actions to restore

malfunctioning process and air pollution control equipment to its normal or usual manner of

operation) are consistent with the procedures specified in such plan. (The informationneeded to

demonstrate conformance withthe SSMP maybe recorded usinga vchecklist," or some other

effective form of recordkeeping, to minimize the recordkeeping burden for conforming events);

(vii) Each period during which a CMS is malfunctioning or inoperable (including out-of-control

periods);

(viii) All required measurements needed to demonstrate compliance with Subpart BB;

(ix) All results of performance tests, in units of lb/ton and lb/hr,

(x) All CMS calibration checks, and all adjustments and maintenance performed on the CMS;;

(xi) All measurements as may be necessary to determine the conditions of performance tests 'and

performance evaluations;

(xii) All documentation supporting initial notifications and notifications of compliance status under

condition P63-BB7 ofthis permit.

(xiii) All records of applicability determination, including supporting analysis;

(xiv) All other records for CMSs required by Ch 5 Sec 3(1)(iii)(A), (B), (]).1), and (K).

(xv) All other records required by Subpart BB and Chapter 5, Section 3.

(P63-BB7) NOTIFICATION REQUIREMENTS

[40 CFR 63 Subpart BB and WAQSR Ch 5, Sec 3(h), (i), 0), and (k)]

(a) The permittee shall submit notifications required under this permit condition (P63-BB7), Subpart BB,

and Chapter 5, Section 3 to the Administrator and U.S. EPA Region VIII in accordance with condition

G4 of this permit.

(b) The permittee shall notify the Administratorin writing of their intention to conduct any performance test

required by condition P63-BB2 at least 60 calendar days before the performance test is scheduled to

begin.

(c) The permittee shall submit a Notification of Compliance Status upon completion of any relevant

compliance demonstration activity specified in SubpartBB. This shall include the results in Ib/ton and

lb/hr ofany performance test required under condition P63-BB2, which shall be reported within 60 days

of completing the test. The Notification ofCompliance Status shall include all information required by

Ch 5, Sec 3(k)(viii).

(d) The permittee shall submit all othernotifications as required by 40 CFR Subpart BB and WAQSR Ch 5

Sec 3.

(P63-BB8) REPORTING REQUIREMENTS

[40 CFR 63 Subpart BB and WAQSR Ch 5, Sec 30); Sec 3(1)(i), (iv), and (v)]

(a) The permittee shall snbmit reports required under this permit condition (P63-BB8), Subpart BB, and

Chapter 5, Section 3 to the Administrator and U.S. EPA Region VIII in accordance with condition G4 of

this permit.

(b) The permittee shall submit SubpartBB emissions reports for any exceedance of an operating parameter

limit, postmarked or delivered by January 30 and July 30 each year. If exceedances are reported, the

permittee shall report quarterly until a request to reduce frequency is approved as described in Ch 5, Sec

3(1)(v). The summary report shall include:

(i) All exceedances of pressure drop or flow rate limitations specified in P63-BBI(b);

(ii) All other information listed in WAQSR Ch 5, Sec 3(1)(v)(C)(VI), except CMS performance

reports are not required;

(iii) When no exceedancesof an operating parameter have occurred, such information shall be

included in the report; and

(iv) The name, title, and signature ofthe responsible official who is certifying the accuracy ofthe

report.

Permit No. 3-2-125-1 Page 30
(c) Ifthe total duration ofoperating parameter exceedances for a reporting period is I percent or greater of

the total operating time for that reporting period, the permittee shall submit a summary report, as

described in paragraph (b) above, and an excess emissions report. The reports shall be postmarked or

delivered within 30 days ofthe end ofthe calendar quarter and shall include the following:

(i) Information required by WAQSR Ch 5, Sec 3(l)(iii)(B) and (D) through (I);

(ii) The name, title, and signature ofthe responsible official who is certifying the accuracy of the

report.

(d) Periodic startup, shutdown, and malfunction reports:

(i) If actions taken by the permittee during a startup, shutdown, or malfunction of an affected source

(including actions taken to correct a malfunction) are consistent with the procedures specified in

the source's SSMP, the permittee shall state such information in a startup, shutdown, and

malfunction report. Reports shall only be required ifa startup, shutdown, or malfunction occurred

during the reporting period. The startup, shutdown, and malfunction report shall. consist of a

letter, containing the name, title, and signature ofthe responsible official who is certifying its

accuracy, which shall be submitted to the Administrator semiannually. The startup, shutdown,

and malfunctionreport shall be delivered or postmarked by the 30th day following the end of each

calendar half, and may be submitted simultaneously with the Subpart BB emissions reports.

(ii) Immediate startup, shutdown, and malfunction reports. Any time an action taken by a permittee

during a startup, shutdown, or malfunction is not consistent with the procedures in the SSMP, the

permittee shall make a report ofthe actions taken for the event within 24 hours, by telephone call

or facsimile (FAX) transmission. The immediate reportshall be followed by a letter, delivered or

postmarked within 7 working days after the end ofthe event, that contains the name, title, and

signature ofthe responsible officialwho is certifying its accuracy, explaining the circumstances of

the event, the reasons for not following the SSMP, and whether any excess emissions and/or

operating parameter exceedances are believed to have occurred.

(iv) For those malfunctions and or other eventsthat affect a CMS and are not addressed by the SSMP,

the permittee shall send a follow-up report within 2 weeks after commencingactions inconsistent

with the plan that either certifies that corrections have been made or includes a corrective action

plan and schedule. The permittee shall provide proofthat repair parts have been ordered or any

other records that would indicate that the delay in making repairs is beyond their control.

(e) The permittee shall submit all other reports as required by §63.627 and Chapter 5, Section 3.

Permit No. 3-2-125-1 Page 31
WAQSR CHAPTER 5, SECTION 3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLLUTANTS (NESHAPS) AND 40 CFR 63 SUBPART ZZZZ REQUIREMENTS FOR

STATIONARY RECIPROCATING INTERNAL COMBUSTIQN ENGINES

(Modified July 21, 2014)

SUBPART ZZZZREQUIREMENTS [40 CFR 63 Subparts A and ZZZZ; WAQSR Cb 5, Sec 3; C1l6, Sec 2

Waivers AP-2532, wv-11961, wv-12054, and AP-I0572]

The permittee shall meet all requirements of 40 CFR 63 Subparts A and ZZZZand WAQSR C1l5, Sec 3 as

they apply to each affected source as indicated in §63.6590(a). An affected source is any existing, new, or

reconstructed stationary RICE located at a major or area source ofHAP emissions, excluding stationary RICE

being tested at a stationary RICE test cell/stand. (As required by condition FII(c), if an engine is replaced or

reconstructed, subpart applicability will need to be re-evaluated, and a statement regarding applicability

submitted to the Division.) This facility is a major source ofHAP emissions. Affected sources at this facility

include the diesel fired engines (units 27, 28, 29 and 30), and the natural gas fired emergency engine (unit 34).

WAOSR CHAPTER 5, SECTION 3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLLUTANTS (NESHAPs) AND 40 CFR 63 SUBPART DDDDD REOUIREMENTS FOR

INDUSTRIAL, COMMERCIAL, AND INSTITUTIONAL BOILERS AND PROCESS HEATERS

(Modified July 21, 2014)

SUBPART DDDDD REQUIREMENTS [40 CFR 63 Subparts A and DDDDD]

The permittee shall meet all requirements of40 CFR63 Subparts A and DDDDD and WAQSR C1l5, Sec 3 as

they apply to owners or operators ofindustrial, commercial, or institutional boilers or process heaters as

defined in §63.7575 that are located at, or are part of, a majorsource of HAPs as defined in §63.2, except

that for oil and natural gas production facilities, a major source of HAPS is as defined in §63.761 (40

CFRPart 63 Subpart HH). The types of boilers and process heaters listed in §63.7491 are not subject to

Subpart DDDDD. This subpart applies to:

(a) The collection of existing industrial, commercial, and institutional boilers and process heaters

within a subcategory.

(b) New or reconstructed industrial, commercial,or institutional boilers or process heaters, including

tile auxiliary and packaged boilers (units 8a and 19).

The subparts are available at http://www.gpoaccess.gov/cfr/retrieve.html, or from the Division upon request.

Permit No. 3-2-125-1 Page 32
WAQSR CHAPTER 7, SECTION 3

COMPLIANCE ASSURANCE MQNITORING (CAM) REQUIREMENTS

(Modified July 21, 2014)

WAQSR Ch 7, Sec3 is available at http://deq.state.wy.us/aqd/staudards.asp,orfrom the Division upon request.

(CAM-I) COMPLIANCE ASSURANCEMONITORING REQUIREMENTS [WAQSRCh7, Sec3(b) and(c)]

The permitteeshall followthe CAMplan attachedas AppendixC ofthispermitandmeetallCAMrequirements

ofWAQSR Ch7, Sec3 as they applyto acid mist emissionsfromthe Lurgi andMEC sulfuricacidplants(units

9a and9b), andparticulatematteremissionsfromthe ammoniumphosphateplant(unitlOa) andtheammonium

phosphate loadout (unit 12). Compliancewith the source specificmonitoring,recordkeeping,and reporting

requirementsof this permitmeetsthe monitoring,recordkeeping,andreportingrequirements ofWAQSRCh7,

Sec 3, except for additionalrequirements specifiedunder conditionsCAM-2 through CAM-4.

(CAM-2)

(a)

(b)

(c)

(d)

OPERATION OF APPROVEDMONITORING [WAQSRCh 7, Sec 3(g)]

At all times,the permitteeshallmaintainthemonitoringunderthis section,includingbut not limitedto,

maintaining necessary parts for routinerepairs of the monitoring equipment.

Except for monitoring malfunctions, associated repairs, and required quality assurance or control

activities, the permitteeshall conductall monitoringin continuousoperation(or at allrequired intervals)

at all times that the pollutant specific emissions unit is operating.

Upon detectingan excursion,the permitteeshallrestore operationof thepollutant-specific emission unit

to its normal or usual manner of operation as expeditiouslyas practicablein accordancewithgood air

pollutioncontrolpractices. The responseshall includeminimizingthe period of any start-up, shutdown

or malfunction and taking any corrective actions to restore normal operation and prevent the likely

recurrence of the causeof anexcursion.

Ifthe permitteeidentifiesa failureto achievecompliance withanemission limitforwhichthemonitoring

did not provide an indicationofan excursionwhileprovidingvaliddata, or the results of compliance or

performance testing documents a need to modify the existing indicator ranges, the permittee shall

promptlynotifythe Divisionand, ifnecessary, submita proposed modificationto thispermitto address

the necessary monitoring changes.

(I)

(c)

(e)

(b)

(d)

QUALITYIMPROVEMENTPLAN (QIP) REQUIREMENTS [WAQSRCh 7, Sec 3(h)]

Ifthe Divisionor the EPA Administratordetermines, based on availableinformation,thatthepermittee

has used unacceptable procedures in response to an excursion or exceedance, the permittee may be

required to develop and implement a QualityImprovementPlan (QIP).

Ifrequired, the permitteeshallmaintaina writtenQualityImprovementPlan (QIP) andhaveit available

for inspection.

The plan shall include procedures for conductingone or more of the followng:

(i) Improved preventative maintenancepractices.

(ii) Process operation changes.

(iii) Appropriate improvementsto control methods.

(iv) Other steps appropriateto correct control.

(v) More frequent or improved monitoring (in conjunctionwith (i)- (iv) above).

If a QIPis required,the permitteeshall developandimplementa QIP as expeditiously aspracticable and

shall notifythe Divisionif the period for completingthe QIP exceeds 180 daysfromthe date on which

the need to implementthe QIP was determined.

Followingimplementationof a QIP, upon anysubsequentdeterminationunderparagraph(a) above,the

Divisionmay require the permitteeto make reasonablechangesto the QIP if the QIP failedto address

the cause of control device problems, or failed to provide adequate procedures for correctingcontrol

deviceproblems as expeditiouslyas practicable.

Implementation of a QIP shall not excuse the permittee from compliance with any existingemission

limit(s) or any existing monitoring, testing, reporting, or recordkeeping requirements that may be

applicableto the facility.

(CAM-4) SAVINGS PROVISIONS [WAQSRCh 7, Sec 30)]

Nothing inthe CAMregulationsshall excusethepermitteefromcompliancewithanyexisting emission limitor

standard,or anyexistingmonitoring,testing,reportingor recordkeepingrequirementthatmaybe applicable to

the facility.

(CAM-3)

(a)

Permit No. 3-2-125-1 Page 33
COMPLIANCE CERTIFICATION AND SCHEDULE

Compliance Certification [WAQSR Ch 6, Sec 3(h)(iii)(E)] (Modified July 21, 2014)

(CI) (a) The permittee shall submit by January 31 each year a certification addressing compliance with the

requirements ofthis permit. The certification shall be submitted as a stand-alonedocument separate from

any monitoring reports required under this permit.

(b) (I) For the sulfur dioxide emissions inventory, the permittee shall assess compliancewith condition

F2 by reviewing records kept in accordance with condition F23 and verifying reports were

submitted in accordance with condition F32.

(ii) For visible emissions from the Lurgi and MEC sulfuric acid plants (units 9a and 9b), the

permittee shall assess compliance with conditions F3(a) and P60-Hl by conducting the CAM

required by condition FI8(a).

(iii) For visible emissions from the phosphoric acid plants, and the ammoniumphosphate plant (units

1all a', 1b, 2, and lOa), the permittee shall assess compliance with condition F3(c) by conducting

the monitoring required by condition FI5(a).

(iv) For visible and particulate matter emissions from the ammonium phosphate loadoutbaghouse

(unit 12), the permittee shall assess compliance with conditions F3(c) and F8(a) by conducting

the CAM required by condition F20.

(v) For visible and particulate matter emissions from the lime handling baghouse and soda ash

handling baghouse (units 13a and 17), the permittee shall assess compliance with conditions

F3(c) and F8(b) and (c) by conducting the monitoring required by condition Fl:(a).

(vi) For visible emissious from the auxiliary and packaged boilers (units 8a and 19) and from the

Cummins GM8.1L emergency engine (unit 34), the permittee shall assess compliance with

condition F3(c) by verifying natural gas was the sole fuel source used as specified under

condition FI5(h).

(vii) For visible emissions from the tailings booster engine (unit 28), the permittee shall assess

compliance with conditions F3(b) by conducting monitoring required by condition F15(c).

(viii) Reserved

(ix) For P,O, feed rate and fluoride emissions from the phosphoric acid plants (units lalla', 1b, and

2), the permittee shall assess compliancewith conditions F4(h)-(d) andP63-AA I by conducting

the testing and monitoring required by condition P63-AA3.

(x) Reserved

(xi) For particulate matter and SO, emissions from the auxiliary boiler (unit 8a), the permittee shall

assess compliance with condition F5 by verifying natural gas was the sole fuel source used as

specified under condition FI7(a).

(xii) For NOx and CO emissions from the auxiliary boiler (unit 8a), the permittee shall assess

compliance with condition F5 by conducting monitoring required by condition FI7(b)

(xiii) For SO, emissions from the sulfuric acid plants (units 9a and 9b), the permittee shall assess

compliance with conditions F6, and P60-Hl(a) by conducting the monitoring required by

conditions FI8(h) and P60-Hl(b).

(xiv) For sulfuric acid mist emissions from the sulfuric acid plants (units 9a and 9b), the permittee

shall assess compliance with condition F6 by conducting the testing required by condition Fl2(a)

and the CAM required by condition FI8(a).

(xv) For NOx emissions from the sulfuric acid plants (units 9a and 9b), the permittee shall assess

compliance with condition F6 by conducting the testing required by condition FI2(b).

(xvi) For sulfuric acid production from the MEC sulfuric acid plant, the permittee shall assess

compliance with condition F6(b) by conducting the monitoring required by condition FI8(d).

(xvii) For particulate matter emissions from the ammoniumphosphate plant (unit lOa), the permittee

shall assess compliance with condition F7(a) by conducting the testing required by condition

FI3(b) and the CAM required by condition FI9(a).

(xviii) For S02 emissions from the sulfuric acid plants (units 9a aud 9b), the permittee shall assess

compliance with couditions F6, and P60-HI(a) by conducting the monitoring required by

conditions FI8(b) and P60-H 1(b)..

Permit No. 3-2-125-1 Page 34
(xix) For NOx and CO emissions from the ammonium phosphate plant, the permittee shall assess

compliance with condition F7(a) by conducting testing required by condition F13(b).

(xx) For fluoride emissions from the ammonium phosphate plant, the permittee shall assess

compliance with conditions F7(a) and P63-BB I by conducting the testing required by condition

P63-BB2, and the monitoring required by condition P63-BB3.

(xxi) For ammonia emissions from the ammonium phosphate plant, the permittee shall assess

compliance with condition F7(a) and (b), by condnctingthe testingrequired by conditionF13(b).

(xxii) For hourly heat input limitations for the packaged boiler (unit 19), the permittee shall assess

compliance with condition F9(a) by conducting monitoring required by condition nl(a).

(xxiii) For NOx emissions from the packaged boiler (unit 19), the permittee shall assess compliance

with conditions F9(b) and P60-DbI by conductingmonitoringrequired by conditionP60-Db2(c).

(xxiv) For CO emissions from the packaged boiler (unit 19), the permittee shall assess compliancewith

condition F9(c) by conducting monitoring required by condition F21(c).

(xxv) For the operating hour limit and maintenance forthe Cummins KITA50-02 generator engine

(unit 30), the permittee shall assess compliance with condition FI O(a) by conducting monitoring

required under condition F22(a), and reviewing records kept in accordance with condition F31.

(xxvi) For the emissions and operating hour limit for the Cummins OM8.IL generator engine(unit34),

the permittee shall assess compliance with the condition FI O(b)by conducting monitoring and

testing required by condition F22(a) and (b).

(xxvii) For fluosilisic acid recovery, the permittee shall assess compliance with condition F22(c) by

reviewing records kept in accordance with condition F31(c).

(xxviii) For the accidental release prevention requirements, the permittee shall assess compliance with

condition F39 by verifying certification was submitted as required by condition F39(b).

(xxix) For each PSD project emission limit, the permittee shall assess compliance with condition F40

by conducting the monitoring required by condition F41 and verifying notification andreporting

was completed as required by condition F42 and F44.

(xxx) For the Cummins OM8.IL generator engine (unit 34) and any other engines subject to the

requirements of 40 CFR 60 Subpart JJJJ, the permittee shall assess compliance with Subpart

JJJJ by conducting any applicable testing and monitoring required by §§60.4237, 60.4243,

and 60.4244, and by reviewing the records reqnired by §§60.4245 and 60.4246.

(xxxi) For radon emissions from the phospho gypsum stacks and other phosphogypsumstack operating

requirements, the permittee shall assess compliance with 40 CFR 61 Subpart R by conducting

the monitoring required under §§61.202, 61.204 and 61.205, and by reviewing the records

required by §§61.203, 61.207, 61.208 and §61.209.

(xxxii) For any engine subject to 40 CFR 60 Subpart I1I1, the permittee shall assess compliance

with Subpart IIII by conducting any applicable testing and monitoring required by

§§60.4209, 60.4211, 60.4212, and 60.4213, and by reviewing the records required by

§§60.4211 and 60.4214.

(xxxiii) For the reciprocating internal combustion engines (units 27-30 and 34), the permittee shall

assess compliance with 40 CFR 63 Subpart ZZZZ by conducting any applicable testing and

monitoring required by §§63.6610 through 63.6640 and by reviewing the records required by

§§63.6655 and 63.6665.

(xxxiv) For the boilers 8a and 19, the permittee shall assess compliance with 40 CFR 63 Subpart

DDDDD by conducting any applicable testing and monitoring required by §§63.7505

through 63.7541 and by reviewing any records required by §§63.7555 and 63.7560.

(xxxv) For fluoride emissions, the permittee shall assess compliance with conditions S4 and S5 by

conducting the monitoring required by conditions S6 and S7 and by reviewing the records

required by conditions S8, S9, and SIO.

(c) The compliance certification shall include:

(i) The permit condition or applicable requirement that is the basis ofthe certification;

(ii) The current compliance status;

(iii) Whether compliance was continuous or intermittent; and

(iv) The methods used for determining compliance.

Permit No. 3-2-125-1 Page 35
(d) For any permit conditions or applicable requirements for which the source is not in compliance, the

permittee shan submit with the compliance certification a proposed compliance plan and schedule for

Division approval.

(e) The compliance certification shan be submitted to the Division in accordance with condition G4 ofthis

permit and to the Assistant Regional Administrator, Office of Enforcement, Compliance, and

Environmental Justice (8ENF-T), U.S. EPA -RegionVlll, 1595WynkoopStreet,Denver,CO 80202-1129.

(t) Determinations of compliance or violations of this permit are not restricted to the monitoring

requirements listed in paragraph (b) ofthis condition; other credible evidence may be used.

Compliance Schedule [WAQSR Ch 6, Sec 3(h)(iii)(C) and (D)]

(C2) The permittee shall continue to comply with the applicable requirements with which the permitree has certified

that it is already in compliance.

(C3) The permittee shan comply in a timely manner with applicable requirements that become effective during the

term ofthis permit.

Permit No. 3-2-125-1 Page 36
GENERAL PERMIT CONDITIONS

Powers ofthe Administrator. [W.S. 35- II-II0]

(G I) (a) The Administrator may require the owner or operator of any point source to complete plans and

specifications for any application for a permit required by the Wyoming Environmental Quality Act or

regulations made pursuant thereto and require the submission of such reports regarding actual or

potential violations ofthe Wyoming Enviromnental Quality Act or regulations thereunder.

(b) The Administrator may require the owner or operator of any point source to establish and maintain

records; make reports; install, useand maintainmonitoringequipmentormethods; sample emissions, or

provide such other information as may be reasonably required and specified.

Permit Renewal and Expiration: [WAQSR Ch 6, Sec 3(c)(i)(C), (d)(li), (d)(iv)(B), and (h)(i)(B)] [W.S. 35-11-206(1)]

(G2) This permit is issued for a fixed term of five years. Permit expiration terminates the permittee'sright to operate

unless a timely and complete renewal application is submitted at least six months prior to the date of permit

expiration. Ifthe permittee submits a timely and complete application for renewal, the permittee's failure to

have an operating permit is not a violation ofWAQSR Chapter 6, Section 3 until the Division takes fmal action

on the renewal application. This protection shall cease to apply after a completeness determination if the

applicant fails to submit by the deadline specified in writing by the Division any additional information

identified as being needed to process the application.

Duty to Supplement [WAQSR Ch 6, Sec 3(c)(lii)]

(G3) The permittee, upon becoming aware that any relevant facts were omitted or incorrect information was

submitted in the permit application, shall promptly submitsuch supplementary facts or corrected information.

The permittee shall also provide additional information as necessary to address any requirements that become

applicable to the facility after this permit is issued.

Submissions: [WAQSR Ch 6, Sec 3(c)(iv)] [W.S. 35-11-206(c)]

(G4) Any document submitted shall be certified as being true, accurate, and complete by a responsible official.

(a) Submissions to the Division.

(i) Any submissionsto the Division including reports, certifications, and emission inventoriesrequired

under this permit shall be submitted as separate, stand-alone documents and shall be sent to:

Administrator, Air Quality Division

122 West 25th Street

Cheyenne, Wyoming 82002

(ii) Unless otherwise noted elsewhere in this permit, a copy ofeach submission to the Administrator

under paragraph (a)(i) of this condition shall be sent to the DEQ Air Quality Contact listed on

page 3 ofthis permit.

(b) Submissions to EPA.

(i) Each certification required under condition CI ofthis permit shall also be sent to:

Assistant Regional Administrator

Office of Enforcement, Compliance, and Environmental Justice (8ENFT)

U.S. EPA - Region VIII

1595 Wynkoop Street

Denver, CO 80202-1129.

(ii) All other required submissions to EPA shall be sent to:

Office of Partnerships and Regulatory Assistance

Air and Radiation Program (8P-AR)

U.S. EPA - Region VIII

1595 Wynkoop Street

Denver, CO 80202-1129

Permit No. 3-2-125-1 Page 37
Changesfor WhichNo Pennit Revision Is Reqnired: [WAQSRCh 6, Sec 3(d)(iii)]

(G5) The permitteemay change operationswithout a permitrevision providedthat:

(a) The change is not a modification under any provisionof title I of the CleanAir Act;

(b) The changehasmet the requirements of Chapter6, Section2 of the WAQSRandis not a modification

under Chapter 5, Section2 or Chapter6, Section4 of the WAQSRand the changes do not exceedthe

emissionsallowedunderthe permit(whetherexpressedthereinas arate of emissionsor intermsoftotal

emissions); and

(c) ThepermitteeprovidesEPA andthe Divisionwithwrittennotification at least 14daysin advanceofthe

proposed change. The permittee, EPA, and the Division shall attach such notice to their copy ofthe

relevantpermit. Foreachsuchchange,the writtennotification requiredshallincludea brief description

of the change within the permitted facility, the date on which the change will occur, any change in

emissions, and any permitterm or conditionthat is no longer applicable as a result ofthe change. The

permit shield, if one exists for this permit, shallnot applyto any such changemade.

Transferof Ownershipor Operation: [WAQSRCh 6, Sec 3(d)(v)(A)(IV)]

(G6) A changein ownershipor operationalcontrolofthisfacilityistreatedas an administrative permitamendment if

no otherchangeinthis permitis necessaryand providedthat a writtenagreementcontaininga specificdatefor

transfer of permit responsibility, coverage, and liability between the current and new permittee has been

submittedto the Division.

Reopeningfor Cause: [WAQSRCh 6, Sec 3(d)(vii)] [W.S. 35-11-206(f)(ii) and (iv)]

(G7) The Division will reopen and revise this permit as necessary to remedy deficiencies in the following

circumstances:

(a) Additionalapplicablerequirements under the CleanAir Actor the WAQSRthat become applicable to

this source if the remainingpermitterm is three or moreyears. Suchreopeningshall be completednot

laterthan 18monthsafter promulgationof the applicablerequirement. No reopeningis requiredif the

effective date of the requirementis later than the date on whichthe permit is due to expire, unlessthe

originalpermit or any of its terms and conditionshave been extended.

(b) Additionalrequirements (includingexcess emissionsrequirements) become applicableto an affected

source under the acid rain program. Upon approval by EPA, excess emissionsoffset plans shall be

deemed to be incorporated into the permit.

(c) The Divisionor EPAdetermines thatthe permitcontainsa materialmistake orthatinaccurate statements

were made in establishing the emissionsstandardsor otherterms or conditions of the permit,

(d) The Divisionor EPA determines that the permitmust be revisedor revokedto assurecompliancewith

applicablerequirements.

Annual Fee Payment [WAQSRCh 6, Sec 3(f)(i), (ii), and (vi)] [W.S. 35-11-211]

(G8) The permitteeshall,as a conditionof continuedoperations,submitan annualfeeto the Divisionas established

in Chapter 6, Section3 (f) of the WAQSR. The Divisionshall give writtennotice of the amountof fee to be

assessedand the basisfor suchfee assessment annually. The assessedfee is due on receipt ofthe noticeunless

the fee assessment is appealedpursuantto W.S.35-11-211 (d). If anypartofthe fee assessment is not appealed

it shall be paid to the Divisionon receipt of the written notice. Any remainingfee which may be due after

completionof the appealis immediately due and payableupon issuanceofthe Council's decision. Failureto

pay fees owedthe Divisionis a violationof Chapter6, Section3 (f) and W.S. 35-11-203 andmaybe causefor

the revocationof this permit.

AnnualEmissions Inventorie. [WAQSRCh 6, Sec 3(f)(v)(G)]

(G9) The permitteeshallsubmitan annualemissioninventoryfor thisfacilityto the Divisionfor fee assessment and

compliancedeterminations within60 daysfollowingthe end ofthe calendaryear.The emissionsinventory shall

be in a format specifiedby the Division.

Pennit No. 3-2-125-1 Page 38
SeverabilityClause: [WAQSR Ch 6, Sec 3(h)(i)(E)]

(GI0) The provisions of this permit are severable, and if any provision of this permit, or the application of any

provision of this permit to any circumstance, is held invalid, the application of such provision to other

circumstances, and the remainder of this permit, shall not be affected thereby.

Compliance: [WAQSRCh 6, Sec 3(h)(i)(F)(I)and (II)] [W.S. 35-11-203(b)]

(GII) Thepermittee mustcomply withall conditions ofthis permit. Anypermitnoncompliance constitutes a violation of

the CleanAir Act, Article 2 of the Wyoming Enviromnental Quality Act, and the WAQSRand is grounds for

enforcement action; for permit termination, revocation and reissuance, ormodification; orfor denial of apermit

renewal application. It shallnot be a defense for a permittee in an enforcement actionthat it would havebeen

necessary to haltorreducethepermitted activity inordertomaintain compliance withtheconditions ofthispermit.

Permit Actions: [WAQSRCh 6, Sec 3(h)(i)(F)(III)] [W.S. 35-11-206(£)]

(G12) Thispermitmaybe modified,revoked,reopened,andreissued, orterminatedfor cause. Thefilingof a request

by the permittee for a permitmodification, revocation and reissuance,or termination, or of a notification of

planned changesor anticipated noncompliancedoes not stay any permit condition.

PropertyRights: [WAQSRCh 6, Sec 3(h)(i)(F)(IV)]

(GI3) This permit does not conveyany property rights of any SOli, or any exclusiveprivilege.

Duty to Provide Information: [WAQSRCh 6, Sec 3(h)(i)(F)(V)]

(G14) Thepermittee shallfurnish to theDivision, within a reasonable time,anyinformation thattheDivisionmayrequest

inwritingto determine whether causeexistsformodifying, revoking andreissuing, orterminating thepermitorto

determine compliance withthe permit. Uponrequest, the pennlttee shallalso furnish to theDivision copies of

recordsrequired to bekeptbythepermit, including information clabnedandshownto be confidential underW.S:

35-11-1101 (a)oftheWyoming Environmental Quality Act. UponrequestbytheDivision, thepermittee shall also

furnish confidential information directly to EPA alongwitha clahnof confidentiality.

EmissionsTrading: [WAQSRCh 6, Sec 3(h)(i)(H)]

(G15) No permitrevisionis required,underany approvedeconomicincentives, marketable permits, emissionstrading

and other sbnilar programs or processes for changesthat are provided for in this permit.

Inspection and Entry: [WAQSRCh 6, Sec 3(h)(iii)(B)] [W.S. 35-11-206(c)]

(G16) Authorizedrepresentatives of the Division,upon presentationof credentialsand other documents as maybe

required by law, shall be given permissionto:

(a) enteruponthepermittee's premiseswhereasourceis locatedor emissionsrelated activity is conducted,

or where records must be kept under the conditionsof this permit;

(b) haveaccess toandcopyatreasonable tbnesanyrecordsthatmustbe keptundertheconditions ofthispermit;

(c) inspect at reasonable times any facilities, equipment(includingmonitoring and air pollution control

equipment), practices,or operationsregulated or reqnired under this permit;

(d) sampleormonitoranysubstancesor parameters atany location, duringoperatinghonrs,for thepurpose

of assnring compliance with this permit or applicablerequirements.

Excess EmissionsDue to an Emergency. [WAQSRCh 6, Sec 3(1)]

(G17) The permitteemayseekto establishthatnoncompliancewitha technology-based emission limitation underthis

permitwas due to an emergency, as definedin Ch6, Sec 3(1)(i) of the WAQSR. To do so, the permittee shall

demonstrate the affirmative defenseof emergencythroughproperly signed, contemporaneous operating logs, or

other relevant evidencethat:

(a) an emergency occurred and that the permitteecan identifythe 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 emissions standards, orother requirements in this permit;

Permit No. 3-2-125-1 Page 39
(d) The permittee submitted uotice ofthe emergeucy to the Division within one working day ofthe time

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

of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

Diluting and Concealing Emission. [WAQSR Ch I, Sec 4]

(G 18) No person shall cause or permit the installation or use of any device, contrivance, or operational schedule

which, without resulting in reduction ofthe total amount of air contaminant released tothe atmosphere, shall

dilute or conceal an emission from a source, This condition shall not apply tl the control of odors.

Unavoidable Equipment Malfunction: [WAQSR Ch I, Sec 5]

(GI9) (a) Any source believing that any emissions in excess ofestablished regulation limits or standards resulted

from an unavoidable equipmentmalfunction, shall notify the Division within 24 hours ofthe incident via

telephone, electronic mail, fax, or other similar method. A detailed description ofthe circumstances of

the incident as described in paragraph 5(a)(i)(A) Chapter I, including a corrective program directed at

preventing future such incidents, must be submitted within 14 days ofthe onset ofthe incident. The

Administrator may extend this 14-day time period for cause.

(b) The burden of proof is on the owner or operator of the source to provide sufficient information to

demonstrate that an unavoidable equipment malfunction occurred.

Fugitive Dust: [WAQSR Ch 3, Sec 2(f)]

(G20) The permittee shall minimize fugitive dust in compliance with standards in Ch 3, Sec 2(f) of WAQSR for

construction/demolition activities, handling and transportation ofmaterials, and agricultural practices.

Carbon Monoxide: [WAQSR Ch 3, Sec 5]

(G21) The emission of carbon monoxide in stack gases from any stationary source shall be limited as may be necessary

to prevent ambient standards from being exceeded.

Asbestos: [WAQSR Ch 3, Sec 8]

(G22) The permittee shall comply with emission standards for asbestos during abatement, demolition, renovation,

manufacturing, spraying and fabricating activities.

(a) No owner or operator shall build, erect, install, or use any article, machine, equipment, process, or

method, the use of which conceals an emission which would otherwise constitute a violation of an

applicable standard. Such concealment includes, but is not limited to, the use of gaseous dilutants to

achieve compliance with a visible emissions standard, and the piecemeal carrying out ofan operation to

avoid coverage by a standard that applies only to operations larger than a specified size.

(b) All owners and operators conducting an asbestos abatement project, including an abatement project on a

residential building, shall be responsible for complying with Federal requirements and State standards for

packaging, transportation, and delivery to an approved waste disposal facility as provided in paragraph

(m) ofCh 3, Sec 8.

(c) The permittee shall follow State and Federal standards for any demolition and renovation activities

conducted at this facility, including:

(i) A thorough inspection of the affected facility or part of the facility where the demolition or

renovation activity will occur shall be conducted to determine the presence of asbestos, including

Category I and Category II non-friable asbestos containing material. The results of the inspection

will determine which notification and asbestos abatement procedures are applicable to the activity.

(ii) The owner or operator shall follow the appropriate notiflcationrequirements ofCh 3, Sec 8(i)(ii).

(iii) The owner or operator shall follow the appropriate procedures for asbestos emissions control, as

specified in Chapter 3, Section 8(i)(iii).

(d) No owner or operator of a facility may install or reinstall on a facility component any insulatingmaterials

that contain commercial asbestos ifthe materials are either molded and friable or wet-applied and friable

after drying. The provisions of this paragraph do not apply to spray-applied insulating materials

regulated under paragraph 0) ofCh 3, Sec 8.

(e) The permittee shall comply with all other requirements of WAQSR Ch 3, Sec 8.

Permit No. 3-2-125-1 Page 40
Open Burning Restrictions: [WAQSR Ch 10, Sec 2]

(G23) The permittee conducting an open burn shall comply with all rules and regulations ofthe Wyoming Department

of Enviromnental Quality, Division ofAir Quality, and with the Wyoming Enviromnental Quality Act.

(a) No person shall burn prohibited materials using an open burning method, except as may be authorizedby

permit. "Prohibited materials" means substances including, but not limited to; natural or synthetic

rubber products, including tires; waste petrolemn products, such as oil or used oil filters; insulated wire;

plastic products, including polyvinyl chloride ("PVC") pipe, tubing and connectors; tar, asphalt, asphalt

shingles, or tar paper; railroad ties; wood, wood waste, or lumber that is painted or chemically treated;

explosives or ammunition; batteries; hazardous waste products; asbestos or asbestos containing

materials; or materials which cause dense smoke discharges, excluding refuse and flaring associated with

oil and gas well testing, completions and well workovers.

(b) No person or organization shall conduct or cause or permit open burning for the disposal of trade wastes,

for a salvage operation, for the destruction of fire hazards if so designated by a jurisdictional fire

anthority, or for firefighting training, except when it can be shown by a person or organization that such

open burning is absolutely necessary and in the public interest. Any person or organization intending to

engage in such open burning shall file a request to do so with the Divisim.

Sulfur Dioxide Emission Trading and Inventory Program[WAQSR Ch 14]

(G24) Any BART (Best Available Retrofit Technology) eligible facility, or facility which has actual emissions of SO,

greater than 100 tpy in calendar year 2000 or any subsequent year, shall comply with the applicable

requirements ofWAQSR Ch 14, Sections I through 3, with the exceptions described in sections 2(c) and 3(a).

Stratospheric Ozone Protection Requirements: [40 CFR Part 82]

(G25) The permittee shall comply with all applicable Stratospheric Ozone Protection Requirements, including but not

limited to:

(a) Standardsfor Appliances [40 CFR Part 82, Subpart F]

The permittee shall complywith the standards for recycling and emission reduction pursuantto 40 CFR

Part 82, Subpart F - Recycling and Emissions Reduction, except as provided for motor vehicle air

conditioners (MVACs) in Subpart B:

(i) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices pursuant to §82.156.

(ii) Equipment used during the maintenance, service, repair, or disposal of appliances must comply

with the standards for recycling and recovery equipment pursuant to §82.158.

(iii) Persons performingmaintenance, service, repair, or disposal of appliances must be certified by an

approved technician certification program pursuant to §82.161.

(iv) Persons disposing ofsmall appliances, MVACs and MVAC-like appliances must comply with

record keeping requirements pursuantto §82.166. ("MYAC-likeappliance" as defmedat §82.152).

(v) Persons owning commercial or industrial process refrigeration equipment must comply with the

leal, repair requirements pursuant to §82.166.

(vi) Owners/operators ofappliances normally containing 50 or more pounds ofrefrigerantmust keep

records ofrefrigerant purchased and added to such appliances pursuant to §82.166.

(vii) The permittee shall comply with all other requirements of Subpart F.

(b) Standardsfor Motor Vehicle Air Conditioners [40 CFR Part 82, Subpart B]

Ifthe permittee performs a service on motor (fleet) vehicles when this service involves ozone-depleting

substance refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the

applicable requirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air

Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in which fmal

assembly of the vehicle has not been completed. The term "MVAC" as used in Subpart B does not

include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on

passenger buses using HCFC-22 refrigerant.

Permit No. 3-2-125-1 Page 41
STATE ONLY PERMIT CONDITIONS

(Modified July 21, 2014)

The conditions listed in this section are State only requirements and are not federally enforceable.

Ambient Standards

(SI) Tbe permittee shall operate the emission units described in this permitsuch that the following ambient standards

are not exceeded, in accordance with 40 CFR 50:

50 micrograms per cubic meter annual arithmetic mean PM IO particulate 24-hr average concentration with not more 2 (a) matter 150 micrograms per cubic meter than one exceedance per year

PM,., particulate 15 micrograms per cubic meter annual arithmetic mean

matter 35 micrograms per cubic meter 98th percentile 24-hour average concentration

2 (b)

53 parts per billion annual average concentration

three-year average ofthe annual 98th

Nitrogen dioxide 100 parts per billion percentile of the daily maximum I-hr 3

average concentration

0.053 parts per million annual arithmetic mean

75 parts per billion three-year average of the annnal (99th

Sulfur dioxide

percentile) of the daily max I-hr average 4

0.5 parts per million 3-hr blocks not to be exceeded more than

once per calendar year

10 milligrams per cubic meter max 8-hr concentration with not more than 5

Carbon one exceedance per year

monoxide 40 milligrams per cubic meter max I-hr concentration with not more tban

one exceedance per year

Ozone 0.075 parts per million three-year average ofthe annual fourth- 6

highest daily maximum S-hr average

concentration

70 micrograms per cubic meter Y, hour average not to be exceeded more than 7

Hydrogen sulfide

two times per year

40 micrograms per cubic meter Y, hour average not to be exceeded more than

two times in any five consecutive days

0.25 milligrams So, per 100 maximum annual average 8

Suspended square centimeters per day

sulfate 0.50 milligrams So, per 100 maximum 3D-dayvalue

square centimeters per day

Lead and its 0.15 micrograms per cubic meter

maximum arithmetic 3-month mean 10

compounds concentration for a 3-year period

Hydrogen Sulfide: [WAQSR Cli 3, Sec 7]

(S2) Any exit process gas stream containing hydrogen sulfide which is discharged to the atroosphere from any source

shall be vented, incinerated, flared or otherwise disposed ofin such a manner that ambient sulfur dioxide and

hydrogen sulfide standards are not exceeded.

Permit No. 3-2-125-1 Page 42
Odors; [WAQSR Ch 2, Sec 11]

(S3) (a) The ambient air standard for odors from any source shall be limited to an odor emission at the property

line which is undetectable at seven dilutions with odor free air as determined by a scentometer as

manufactured by the Barnebey-Cheney Company or any other instrument, device, or technique

designated by the Division as producing equivalent results. The occurrence ofodors shall be measured so

that at least two measurements can be made within a period of one hour, these determinations being

separated by at least 15 minutes.

(b) Odor producing materials shall be stored, transported, and handled in a manner that odors produced from

such materials are confmed and that accumulation ofsuch materials resulting from spillage or other

escape is prevented.

Fluorides; [WAQSR Ch 2, Sec 9]

(S4) (a) The permittee shall operate the emission units described in this permit such that the following ambient

standards for fluorides, measured as hydrogen fluorides, are not exceeded;

1.2

1.8

4.0

0.4

0.5

1.8

3.0

10.0

(i) Statewide Standard

12 hours

24 hours

7 days

30 days

(Ii) Regional Standard

12 hours

24 hours

7 days

30 days

The Regional Standard applies to the area encompassing the following lands in Sweetwater County,

Wyoming;

Tl9N RI04W, E Y, Section 31 & Sections 32, 33, 34, 35, 36;

Tl9N RI03W, Section 31;

Tl8N RI05W, S Y, Section I & Sections 12, 13,24,25,35,36;

Tl8N RI04W, All Sections I through 36;

Tl8N RI03W, Sections 6, 7, 18, 19,30, 31, 32, 33;

Tl7N RI05W, Sections 1,2, II, 12, 13, 14,23,24,25,26;

Tl7N RI04W, Sections I through 30; and

Tl7N RI03W, Sections 4,5,6,7,8,9, 16, 17, 18, 19,20,21,28,29,30

(b) The standards for fluoride in forage for animal consumptionmeasured as fluorine, dry weight basis, are;

One year 30

60 days 60

30 days 80

Permit No. 3-2-125-1 Page 43
(S5) FLUORIDE CONTROL TECHNIQUES [WAQSR Ch 6, Sec 2 Permit AP-7283]

The permittee shall continue to implementthe techniques for controlling fluoride emissions from the gypsum

pond (unit 14) as outlined in Appendix M of this permit. Any revisions to the plan must be approved by the

Division prior to implementation.

Monitoring Requirements

(S6) AMBIENT & METEOROLOGICAL MONITORING [WAQSRCh 6, Sec2Permits CT-550A andMD-384A]

(a) The permittee shall continue to operate an ambient fluoride monitoring program acceptable to the

Division. Monitoring ofambient hydrogen fluoride (HF) shall be used as a direct indicator ofcompliance

with the standards in condition S4(a) ofthis permit.

(b) The permittee shall continue to maintain a meteorological station acceptable to the Division to gather

meteorological data including wind speed, wind direction, and atmospheric stability.

(c) The permittee shall maintain a quality assurance plan for the monitoringnetwork, as required by 40 CFR

Part 58. The plan shall be submitted and approved by the Division. The permittee shall comply with all

commitments made in the plan.

(S7) FLUORIDE IN FORAGE MONITORING [WAQSR Ch 6, Sec 2 Permit CT-550A3]

The permittee shall monitor fluoride in forage to determine compliancewith the standards in condition S4(b) of

this permit. Monitoring shall be conducted as specified in condition #3 of permit CT-550A3 provided in

Appendix N ofthis permit.

Recordkeeping Requirements

(S8) FLUORIDE CONTROL RECORDS [WAQSR Ch 6, Sec 3 (h)(i)(C)(II)]

The permittee shall maintain records of what techniques are used and when the techniques are used for

controlling fluoride emissions from the gypsum pond (unit 14) as described in condition S5 ofthis permit. The

permittee shall retain on-site at the facility all fluoride control records fora period ofat least five years from the

date such records are generated.

(S9) AMBIENT & METEOROLOGICAL MONITORING RECORDS [WAQSR Ch 6, Sec 3 (h)(i)(C)(II)]

The permittee shall maintain records of the data generated by the ambient monitoring program and

meteorological station. The permittee shall retain on-site at the facility all ambient and meteorological

monitoring records for a period ofat least five years from the date such records are generated.

(SIO) FLUORIDE IN FORAGE MONITORING RECORDS [WAQSR Ch 6, Sec 3 (h)(i)(C)(II)]

The permittee shall maintain records of the data generated by the fluoride in forage monitoring program

described in condition S7 ofthis permit. The permittee shall retain on-site at the facility all fluoride in forage

monitoring records for a period of at least five years from the date such records are generated.

Reporting Requirements

(SI1) FLUORIDE CONTROL PROGRESS REPORTS [WAQSR Ch 6, Sec 3 (h)(i)(C)(III)]

The permittee shall submit progress reports on the control offluoride emissions from the gypsum pond (unit 14)

as described in the Fluoride Control Techniques Document in Appendix M ofthis permit. The reports shall be

submitted to the Division in accordance with condition G4 ofthis permit.

(SI2) AMBIENT MONITORING REPORTS [WAQSR Ch 6, Sec 2 Permit CT-550A]

The ambient monitoring data retained in accordance with condition S9 shall be submitted to the Division in an

acceptable format within 60 days ofthe end of each calendar quarter. The reports shall be submitted to the

Division in accordance with condition G4 ofthis permit.

(S13) FLUORIDE IN FORAGE MONITORING REPORTS [WAQSR Ch 6, Sec 2 Permit CT-550A]

The fluoride in forage monitoring data retained in accordance with condition SIO of this permit shall be

submitted to the Division in an acceptable format within 60 days ofthe end of each calendar quarter. The

reports shall be submitted to the Division in accordance with condition G4 of this permit,

Permit No. 3-2-125-1 Page 44
SUMMARY OF SOURCE EMISSION LIMITS AND REQUIREMENTS

(Modified July 21, 2014)

Weekly visual observations IVisible emissions

and corrective actions monitoring records [F24]

[FI5]

Particulate 120 percent opacity [F3]

Fluoride [For units lalla' and Ib:

0.01350 Ib/ton ofP20, feed,

0.65 lb/hr [F4 and P63-AAI]

For unit 2: 0.010 Ib/ton of

P20, feed, 0.18 Ib/hr [F4 and

P63-AAI]

Pressure drop and flow rate

requirements for scrubber

[P63-AAI]

Various IProject emission levels for

lalla' and Ib [F40]

WAQSR Ch 3, Sec 2 [Testing ifrequired

[F14]

WAQSR Ch 6, Sec 2 Additional testing if

Permits CT-550A, required [F14]

MD-384A, CT-I043 Testaunuallyfor

WAQSR Ch 5, Sec fluoride [F13

3; 40 CFR63

SubpartAA

WAQSR Ch 6, Sec 21TeSting ifrequired

Permit MD-12795 [FI4]

Monitor P20, production

[F16]

Monitor process feed rate,

scrubber liquor flow rate,

and scrubber pressure drop

[F16 & P63-AA3]

Project monitoring [F41]

Record any testing [F25]

Record P20, production

[F26]

Record test results and

monitoring [P63-AA6]

Project recordkeeping [F43

andF45]

Visible emissionsmonitoring

reports [F34]

rt excess emissions and penni!

deviations [F37]

Notification oftesting and

compliance status [p63-AA7]

Excess emissions,operating

parameter exceedances, periodic

startup, shutdown, and

malfunction reports [F37 and

P63-AA8]

Report excess emissions and

permit deviations [F37]

Project notifications [F42]

Project reports [F44]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliance with the summary conditions in these tables may not be sufficientto meet permit reqnirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 45
0.55 Iblhr [F5]

Particulate 20 percent opacity [F3] IWAQSR Ch 3, Sec 2

and Ch 6, Sec 2

Permit CT-1043

Testiug if INatural gas firing [F15 and

required [F14] F 17]

Record any test results [F25] Report fuel type [F34]

Report excess emissions and permit

deviations [F37]

SO, 0.Q71blhr [F5] WAQSR Ch 6, Sec 2

Permit CT-I043

Testiug if [Natural gas firing [F17]

required [FI4]

Record any test results [F25] Report fuel type [F34]

Report excess emissions and permit

deviations [F37]

HAPs I WAQSR Ch 5, Sec 3 and 40 CFR 63 Snbpart DDDDD

WAQSR Ch 6, Sec 2 ITesting if ITest every 5 years or 8,000

PermitCT-I043 required [F14] hours [F17]

NOx

co

20.02 Iblhr [F5]

50 TPY emission level

[F40]

1.87 Iblhr [F5]

WAQSR Ch 6, Sec 2

Permits CT-I043,

AP-12908

Testiug if

required [F14]

Test every 5 years or 8,000

hours [F17]

Project monitoring [F41]

Testing and hours of operation

records [F25]

Project recordkeeping [F43

and F45]

lTestiug and hours ofoperation

records [F25]

Report test results [F33]

Report excess emissionsandpermit

deviations [F37]

Project Reports [F44]

Report test results [F33]

Report excess emissions and permit

deviations [F37]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliancewiththe summary conditions in these tables may not be sufficient to meetpermitrequirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 46
Source ID#: 9a Source Description: Lurzi Sulfuric Acid Plant

S02 316.67Iblbr,4 lbfton of

acid produced [F6 and

P60-HI]

WAQSR Ch 6, Sec 2

Permits CT-550A and

CT-I043, Ch 5, Sec 2;

40 CFR 60 Subpart H

Testing ifrequired

[FI4]

Continuous emissions

monitoring [F18 and

P60-HI]

Monitoring records [F27 and IReport excess emissions

P60-H2] quarterly [P60-H3]

Report excess emissionsand

permit deviations [F37]

Opacity/

sulfuric

acid mist

NOx

10 percent opacity [F3] IWAQSR Ch 6, Sec 2

Permit CT-I043;

11.88 Ib/hr, 0.15 lb/ton oflCh 5, Sec 2;

acid produced [F6] 40 CPR 60 Subpart H

53.53 lblbr [F6] IWAQSR Ch 6, Sec 2

Permit CT-I043

Sulfuric acid testing

every five years [F12]

Additional testing if

required [FI4]

Annual testing [FI2]

Additional testing if

required [FI4]

CAM - daily visual Visible emissions monitoring Test results [F33]

observations and records [F24] CAM reports [F35]

corrective actions [F18] Test records [F25] Report excess emissions and

CAM records [F27] permit deviations [F37]

Testing per Fl2 [F18] ITest records [F25] ITest results [F33]

Report excess emissions and

permit deviations [F37]

Various [Project emission levels IWAQSR Ch 6, Sec 2 ITesting ifrequired IProject monitoring IProjectrecordkeeping [F43 IReport excess emissions and

[F40] Permit MD-12795 [F14] [F41] and F45] permit deviations [F37]

Project notifications [F42]

Project reports [F44]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliance with the summary conditions in these tables maynot be sufficientto meet permit reqnirements.These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 47
Source ID#: 9b Source Description: MEC Acid Plant

S02

Opacityl

sulfuric

acid mist

253.3 Ib/hr and 1109.6

TPY, 4 Ib/ton of acid

produced [F6]

10 percent opacity [F3]

6.3 Iblhr, 27.7 TPY, 0.10

Ib/ton acid produced [F6]

1520 TPD 100% sulfuric

acid production [F6]

WAQSR Ch 6, Sec 2

PennitMD-1I30;

Ch 5, Sec 2;

40 CFR 60 Suhpart H

WAQSRCh6, Sec 2

Permit MD-l130;

Ch 5, Sec 2;

40 CFR 60 Subpart H

Testing ifrequired

[F14]

Test every five years

[FI2]

Additional testing if

required [Fl4]

Continuous emissions

monitoring [P60-HI]

CAM- daily visual

observations and

corrective actions [F18]

Monitor sulfuric acid

production [F18]

Monitoring records [p60-H2] [Report excess emissions

quarterly [P60-H3]

Report excess emissions and

permit deviations [F37]

Visible emissions monitoring Test results [F33]

records [F24] Production monitoring reports

Test records [F25] [F34]

CAM and production records CAM reports [F35]

[F27] Report excess emissions and

permit deviations [F37]

NOx 16.3 Ib/hr, 71.3 TPY, and IWAQSR Ch 6, Sec 2

0.26 Ib/ton of acid Permit MD-1I30

produced [F6]

Annual testing [F12]

Additioual testing if

required [FI4]

Testing per FI2 [F I 8] Test records [F25] [Testresults [F33]

Report excess emissions and

permit deviations [F37]

Various Project emission levels

[F40]

WAQSR Ch 6, Sec 2

Permit MD-12795

Testing ifrequired

[F14]

Project monitoring [F41] [Project recordkeeping [F43

andF45]

Report excess emissions and

permit deviations [F37]

Project notifications [F42]

Project reports [FM]

These tables are intended only to highlight and summarize applicable requirements for each source. The correspondingpermit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliance with the summary conditions in these tables may not be sufficientto meetpennitrequirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 48
Particulate 120 percent opacity [F3]

20.00 Ib/hr [F7]

WAQSR Ch 3, Sec 2

and Ch 6, Sec 2

Permit CT-I043

Test annually [F13]

Additional testing if

required [F14]

Weekly visual

observations and

corrective actions [F15]

CAM - monitor scrubber

pressure drop and liquor

flow daily [F19]

Visible emissions

monitoring records

[F24]

Test records [F25]

CAM records [F28]

Test results [F33]

Visible emissions monitoring

reports [F34]

CAM reporting [F35]

Report excess emissions and

permit deviations [F37]

SO, 19.88 Ib/hr, 0.5% fuel oil

sulfur content for dryer

[F7]

WAQSR Ch 6, Sec 2 ITesting ifrequired

Permits CT-550A and [F14]

CT-I043

Monitor fuel oil sulfur

content [F19]

Fuel sulfur monitoring

records [F28]

Fuelsulfur monitoring reports

[F34]

Report excess emissions and

permit deviations [F37]

NOx 15.84 Ib/hr [F7] IWAQSR Ch 6, Sec 2 ITest every five years,

Permit CT-I043 or 8,000 hours [F13]

Additional testing if

required [F14]

Fluoride 10.060 Ib/ton ofP,O, feed; WAQSR Ch 6, Sec 2 Test annually [F13 and

2.30 Ib/hr [F7, P63-BB1],] Permit CT-1043; P63-BB2]

P dr dfl WAQSRCh5,Sec3; Additi I . if ressure op an ow rate 40 CFR 63 Sub art .tIona testmg 1

for scrubber 0 BB P required [F14]

CO 11.40 Ib/hr [F7] !WAQSRCh 6, Sec2 ITest every five years,

Permit CT-1043 or 8,000 hours [F13]

Additional testing if

required [FI4]

Testing per F13 [F19]

Monitor process feed

rate, scrubber pressure

drop and liquor flow

[F19 and P63-BB3]

Testing per F13 [F19]

Testing and hours of

operation records [F25]

Testing and monitoring

records [F25 and

P63-BB6]

Testing and hours of

operation records [F25]

Test results [F33]

Report excess emissions and

permit deviations [F37]

Summary; excess emissions; SSM

reports, and permit deviations

[F37 and P63-BB8]

Notification oftesting and

compliance status [P63-BB7]

Test results [F33]

Report excess emissions and

permit deviations [F37]

Ammonia 100 Ib/hr, 438 TPY;

98% minimum recovery

efficiency [F7]

WAQSR Ch 6, Sec 2

Permit CT-550A2

Test annually [F13]

Additional testing if

required [F14]

Testing per FI3 [F19] Test records [F25] Test results [F33]

Report excess emissionsand

permit deviations [F37]

Various Project emission levels

[F40]

WAQSR Ch 6, Sec 2

Permit MD-12795

Testing ifrequired

[F14]

Project monitoring [F41] [Projectrecordkeeping

[F43 and F45]

Report excess emissionsand

permit deviations [F37]

Project notifications [F42]

Project reports [F44]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance reqnirements. Compliancewith the surnmaryconditions in these tables may not be sufticientto meerpermitrequirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 49
Source ID#: 12 Source Description: Ammonium Phosphate Loadout Bazhouse

Particulate 120percent opacity [F3]

0.50 Ib/hr [F8]

WAQSRCb3, Sec 2

and Ch 6, Sec 2 Permit

CT-I043

Testing ifrequired

[F14]

CAM - daily visual Visible emissions

observations and corrective monitoring records [F24]

actions [F20] CAM records [F29]

CAM reports [F35]

Report excess emissions and

permit deviations [F37]

Various Project emission levels

[F40]

WAQSR Ch 6, Sec 2

Permit MD-12795

Testing ifrequired

[FI4]

Project monitoring [F41] IProject recordkeeping [F43

andF45]

Report excess emissions and

permit deviations [F37]

Project notifications [F42]

Project reports [F44]

Source ID#: 13a and 17 Source Description: Lime and Soda Ash Handl

Particulate 120percent opacity [F3]

Unit 13a: O.l1lb/hr

Unit 17: 0.10 Ib/hr [F8]

WAQSR Ch 3, Sec 2

and Ch 6, Sec 2 Permit

CT-I043

Testing ifrequired

[F14]

Weeklyvisual observations IViSible emissions

and corrective actions monitoring records [F24]

[F15]

Visible emissions monitoring

reports [F34]

Report excess emissions and

permit deviations [F37]

Fluoride

HAPs

Various

Continue to implement

the Fluoride Control

Techniques attached as

Appendix M [S5]

Project emission levels

for [F40]

WAQSR Ch 6, Sec 2

Permit AP-7283

WAQSR Ch 6, Sec 2

Permit MD-12795

Testing if

required [F14]

Testing if

required [FI4]

Ambient HFmonitoring results used to

determine additional actions under the

decision tree contained in the Fluoride

Control Techniques document

(Appendix M) [S5 and 6]'*

40 CFR 61 Subpart R

Project monitoring [F41]

Record techniques used

to control fluoride

emissions from the

gypsum pond [S8]

I

Projectrecordkeeping

[F43 and F45]

Report excess emissions and

permit deviations [F37]

Progress reports on gypsum

pondfluoride emissions control

[Sl1]

Report excess emissions and

permit deviations [F37]

Project notifications [F42]

Project reports [F44]

*' Additional requirements which are not specific to a single source at the facility include monitoring, recordkeeping, and reporting requirements for ambient HF

monitoring and fluoride in forage monitoring contained in conditions S6, S7, S9, SIO, S12, and S13.

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliancewith the summary conditions inthese tablesmay notbe sufficientto meetpermitrequirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 50
Hourly heat input not to exceed 122.5 WAQSR Ch 6,

ru/hr for more than 1056 hrs/yr [F9] Sec 2 Permit

0.14Ib/MMBtu, not to exceed 49.00 Ib/hr CT-1043

at the maximum firing rate of 350

MMBtnIhr for 1056 hrs/yr AND

0.14Ib/MMBtu, not to exceed 17.20 Ib/hr

at firing rates at or below 122.5

MMBtnIhr [F9 andP60-Db1]

Project recordkeeping [F43 Report excess emissions and

and F45] permit deviations [F37]

Project notifications [F42]

Project reports[F<\<\]

ITesting if requiredlTest once during permit ITeSting and hours of

[F14] term (every five years), or operation records [F25]

every 8,000 hours [F21]

.eportexcess emissions and

ermit deviations [F37]

Test report [F33]

IReportexcess emissions and

ermit deviations [F37]

Report excess emissions and

Ipermitdeviations [F37]

IReportheat input quarterly [F37,

P60-Db-4]

Emissions monitoring

Irecords [F30, P60-Db3]

IHourlyheat inpnt records

[F30]

Continuous emissions

Imonitoring[F21, P60-

Db2]

Testing ifrequiredMonitor gas flow [F21]

[F14]

Testing ifrequiredProject monitoring [F41]

[F14]

IWAQSRCh6,

Sec 2 Permit

CT-I043

IWAQSRCh6,

Sec 2 Permit

MD-IOI71

Project emission levels [F40]

co 25.90 Ib/hr [F9]

IVarious

HAPs WAQSR Ch 6, Sec 3 and 40 CFR 63 Subpart DDDDD

Particnlate 130 percent opacity [F3] WAQSR Ch 3, Sec 2 Testing ifrequired

[F14]

None Record monitoring andanylMOnitOring resn1ts [F34]

test results [F25] Report excess emissions and

ermit deviations [F37]

HAPs WAQSR Ch 5, Sec 3 and 40 CFR 63 Subpart zzzz

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliance with the summary conditions in these tables maynot be sufficientto meet permitrequirements.These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 51
Source 1D#:28 Source Description: Cummins Mll-P Emeraen

Particulate 30 percent opacity [F3]

2000 hours of operation

per year. Maintain unit.

[FlO]

WAQSR Ch 3, Sec 2,

and Ch 6, Sec 2 waiver

wv-1196 I

Testing ifrequired

[F14]

Quarterly Method 9 [F15] Record any test results

M · ain! h [F25] amt operate an ours M . t d h f , am enance an ours 0

of operation meter [F22] operation records [F31]

Report annual hours ofoperation

[F34]

Report excess emissions and

ermit deviations fF37

NOx

co

5.0 grlhp-hr, 2.71blhr and IWAQSR Ch 6, Sec 2

2.7 1PY [F 10] waiver wv-1196 I

2.6 grlhp-hr, 1.4 Iblhr and IWAQSR Ch 6, Sec 2

1.41PY [FlO] waiver wv-1196 I

Testing ifrequired

[F14]

Testing ifrequired

[F14]

Test every three years

[F22]

Test every three years

[F22]

Test records [F25]

Test records [F25]

Test results and non-compliance

[F33]

Report excess emissions and

ermit deviations [F37]

Test results and non-compliance

,[F33]

I

Report excess emissions and

permit deviations [F37]

HAPs WAQSR Ch 5, Sec 3 and 40 CFR 63 Subpart ZZZZ

Particulate 130 percent opacity [F3]

50 hours ofoperation per

year. Maintain unit. [FlO]

WAQSR Ch 3, Sec 2,

and Ch 6, Sec 2 waiver

wv-12054

Testing ifrequired

[F14]

Maintain/operate an hoursIRecord any test results

of operation meter [F22] [F25]

Records ofmaintenance,

hours of operation, Tier 3

certification. [F31

Monitoring results [F34]

Report excess emissions and

permit deviations [F37]

NOx,CO,

NMHG,PM,

HAPs

WAQSR Ch 5, Sec 2 and 40 CFR 60 Subpart IllI, as applicable

WAQSR Ch 5, Sec 3 and 40 CFR 63 Subpart ZZZZ

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliancewith the summary conditions in these tables may not be sufficientto meet permitrequirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 52
Source ID#: 30 Source Description: Cummins KTTA50-G2 Emergency Generator Enzine

Particulate 130 percent opacity [F3] WAQSR Ch 3, Sec 2,

. and Ch 6, Sec 2 waiver

250 hours of operation per AP-2532

year. Maintain unit. [FlO]

Testing ifrequired

[F14]

Maintain/operate an hours IRecord any test results

of operation meter [F22] [F25]

Maintenance and hours of

operation records [F31]

Report annual hours of operation

[F34]

Report excess emissions and

ermit deviations fF37

HAPs WAQSR Ch 5, Sec 3 and 40 CFR 63 Subpart ZZZZ

Test results and non-compliance

[F33]

Report excess emissions and

permit deviations [F37]

Report fuel type and annual

hours of operation [F34]

Report excess emissions and

ermit deviations [F37]

Test results and non-compliance

[F33]

Report excess emissions and

permit deviations [F37]

Test records [F25]

Test records [F25]

Test every three years

[F22]

Test every three years

[F22]

Natiual gas firing [F15]

Maintain and operate

hours meter [F22]

Testing ifrequired

[F14]

Testing ifrequired

[FI4]

20 percent opacity [F3]

. Iand Ch 6, Sec 2 waiver 250 hours of operation per AP-I0572

year. Maintain unit. [FlO]

Source ID#: 34 Source Description: Cummins KTTA50-G2 Emerzencv Generator E

19.8 gr/hp-hr, 8.llb/hr andlWAQSR Ch 6, Sec 2

2.0 TPY [FlO] waiver AP-I0572;

7.6 gr/hp-hr, 3.llb/hr and IWAQSR Ch 6, Sec 2

0.8 TPY [FlO] waiver AP-10572;

co

NOx

VOC 0.4 gr/hp-hr, 0.2 lb/hr and IWAQSR Ch 6, Sec 2

<0.1 TPY [FlO] waiver AP-I0572;

Testing ifrequired

[F14]

Test every three years

[F22]

Test records [F25] Test results and non-compliance

[F33]

Report excess emissions and

permit deviations [F37]

NOx,CO,

VOC WAQSR Ch 5, Sec 2 and 40 CFR 60 Subpart JJJJ

HAPs WAOSR Ch 5, Sec 2 and 40 CFR 60 SubpartJJJJ and WAQSR Ch 5, Sec 3 and 40 CFR 63 Subpart ZZZZ

These tables are intended ouly to higbligbt and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain

detailed descriptions ofthe compliance requirements. Compliancewith the summary conditions in these tables may not be sufficientto meet permitrequirements. These

tables may not reflect all emission sources at this facility.

Permit No. 3-2-125-1 Page 53
ACFM

AFRC

AQD

BACT

Btu

CAA

CAM

CFR

CO

CO,e

DEQ

EPA

ESP

g/hp-hr

gal

gr

H2S

HAP(s)

hp

hr

Ib

M

MACT

mfr

mg

MM

MVACs

NMHC(s)

NOx

NSCR

02

PM

PMIO

PSD

ppmv

ppmw

QIP

RICE

SCF

SCFD

SCM

SIC

SO,

SOx

TPD

TPH

TPY

U.S.C.

Ilg

VOC(s)

W.S.

WAQSR

ABBREVIATIONS

(Modified July 21, 2014)

Actual cubic feet per minute

Air-fuel ratio controls

Air Quality Division

Best available control technology (see Definitions)

Britisb Thermal Unit

Cleao Air Act

Compliaoce Assuraoce Monitoring

Code ofFederal Regulations

Carbon monoxide

Carbon dioxide equivalent

Wyoming Department of Enviromnental Qnality

United States Environmental Protection Agency(see Definitions)

Electrostatic Precipitator

Gram(s) per horsepower bonr

Gallon(s)

Grain(s)

Hydrogen sulfide

Hazardous air pollutaot(s)

Horsepower

Honr(s)

Pound(s)

Thousand

Maximum available control technology (see Definitions)

Manufacturer

Milligram(s)

Million

Motor vehicle air conditioners

Non-methane hydrocarbon(s)

Oxides of nitrogen

Nou-selective catalytic reduction

Oxygen

Particulate matter

Particulate matter less than or equal to a nominal diameter of 10 micrometers

Prevention of Significaot Deterioration

Parts per million (by volume)

Parts per million (by weight)

Quality Improvement Plan

Reciprocating internal combustion engine

Standard cubic foot (feet)

Standard cubic foot (feet) per day

Standard cubic meter(s)

Standard Industrial Classification

Sulfur dioxide

Oxides ofsulfur

Ton(s) per day (1 ton =2000 pounds, unless otherwise specified)

Ton(s) per hour (1 ton =2000 pounds, unless otherwise specified)

Tons per year (l ton = 2000 pounds, uuless otherwise specified)

United States Code

Microgram(s)

Volatile organic compound(s)

Wyoming Statute

Wyoming Air Quality Standards & Regulations (see Definitions)

Permit No. 3-2-125-1 Page 54
DEFINITIONS

"Act" means the Clean Air Act, as amended, 42 U.S.C. 7401,et seq.

"Administrator" means Administrator ofthe Air Quality Division, Wyoming Department ofEnvironmental Quality.

"Applicable requlrement" means all ofthe following as they apply to emissions units at a source subject to Chapter 6,

Section 3 ofthe WAQSR (including requirements with future effective compliance dates that have been promulgated or

approved by the EPA or the State through rulemaking at the time ofissuance ofthe operating permit):

(a) Any standard or other requirement provided for in the Wyoming implementation plan approved or promulgated

by EPA under title I ofthe Act that implementsthe relevant requirements ofthe Act, including any revisions to

the plan promulgated in 40 CFR Part 52;

(b) Any standards or requirements in the WAQSR which are not a part ofthe approved Wyoming implementation

plan and are not federally enforceable;

(c) Any term or condition of any preconstruction permits issued pursuantto regulations approved or promulgated

through rulemaking under title I, including parts C or D ofthe Act and including Chapter 5, Section 2 and

Chapter 6, Sections 2 and 4 ofthe WAQSR;

(d) Any standard or other requirement promulgated under Section III of the Act, including Section I I I(d) and

Chapter 5, Section 2 ofthe WAQSR;

(e) Any standard or other requirement under Section 112 ofthe Act, including any requirement concerning accident

prevention under Section 112(1')(7) ofthe Act and including any regulations promulgated by EPA and the State

pursuant to Section 112 ofthe Act;

(I) Any standard or other requirement of the acid rain program under title IV of the Act or the regulations

promulgated thereunder;

(g) Any requirements established pursuant to Section 504(b) or Section II4(a)(3) ofthe Act concerning enhanced

monitoring and compliance certifications;

(b) Any standard or other requirement governing solid waste incineration, under Section 129 ofthe Act;

(i) Any standard or other requirement for consumer and commercial products, under Section 183(e) of the Act

(having to do with the release of volatile organic compounds under ozone control requirements);

(j) Any standard or other requirement of the regulations promulgated to protectstratospheric ozone undertitle VI

ofthe Act, unless the EPA has determined that such requirements need not be contained in a title V permit;

(k) Any national ambient air quality standard or increment or visibility requirement under part C of title I of the

Act, but only as it would apply to temporary sources permitted pursuant to Section 504(e) ofthe Act; and

(l) Any state ambient air quality standard or increment or visibility requirement ofthe WAQSR.

(m) Nothing under paragraphs (A) through (L) above shall be construed as affecting the allowance program and

Phase II compliance schedule under the acid rain provision ofTitle IV ofthe Act.

"BACT" 01' "Best available control technology" means an emission limitation (including a visible emission standard)

based on the maximumdegree ofreduction ofeach pollutantsubject to regulation under the WAQSR or regulation under

the Federal Clean Air Act, which would be emitted from or which results for any proposed major emitting facility or

major modification which the Administrator, on a case-by-case basis, taking into account energy, environmental, and

economic impacts and other costs, determines is achievable for such source or modification through application or

production processes and available methods, systems, and techniques, including fuel cleaning or treatment or innovative

fuel combustion techniques for control ofsuch pollutant. Ifthe Administrator determines that technological or economic

limitations on the application ofmeasurementmethodology to a particular class of sources would make the imposition of

an emission standard infeasible, he may instead prescribe a design, equipment, work practice or operational standard or

combination thereofto satisfy the requirement ofBest Available Control Technology. Such standard shall, to the degree

possible, set forth the emission reduction achievable by implementation ofsuch design, equipment, work practice, or

operation and shall provide for compliance by means which achieve equivalent results. Application ofBACT shall not

result in emissions in excess ofthose allowed under Chapter 5, Section 2 ofthc WAQSR and any other new source

Permit No. 3-2-125-1 Page 55
performance standard or national emission standards for hazardous air pollutants promulgated by EPA but not yet

adopted by the state.

"Department" means the Wyoming Department of Environmental Quality or its Director.

"Director" means the Director of the Wyoming Department ofEnvironmental Quality.

"Division" means the Air QualityDivision of'the WyomingDepartment of EnvironmentalQuality or its Administrator.

"Emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the

source, including acts of God, whichsituation requires immediate corrective action torestore normal operation, andthat

causes thesource to exceeda technology-based emission limitation under the permit, dueto unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by

improperly designed equipment, lackof preventative maintenance, careless or improper operation, oroperator error.

"EPA" means the Administrator of the U.S. Environmental Protecfon Agency or the Administrator's designee.

"Fuel-burning equipment" means any furnace,boiler apparatus, stack, or appurtenancesthereto used in the process of

bnrning fuel or other combustible material for the purpose of producing heat or power by indirect heat transfer.

"Fugitive emissions" means those emissions whichcould notreasonably passthrough a stack chimney, vent, orother

functionally equivalent opening.

"Insignificant activities" meanstbose activitieswhich are incidentalto the facility'sprimarybusinessactivityandwhich

result in emissions of less than one ton per year of a regulated pollutant not included in the Section 112 (b) list of

hazardous air pollutants or emissions less than 1000 pounds per year of a pollutant regulated pnrsuantto listing under

Section 112 (b) of the Act provided,however,such emissionlevels of hazardous air pollutantsdo not exceedexemptions

based on insignificantemissionlevelsestablishedby EPA through rulemakingfor modificationunder Section112(g) of

the Act.

"MACTUor "Maximum achievable control technology tr meansthemaximum degree ofreduction inemissionsthatis

deemed achievable for new sonrces in a categoryor subcategorythat shall not be less stringentthan the emissioncontrol

that is achieved in practice by the best controlled similarsource, as determinedbytheAdministrator. Emissionstandards

promulgated for existingsources in a categoryor subcategorymay be less stringentthan standardsfornew sonrcesinthe

same category or subcategory but shall not be less stringent, and may be more stringent than:

(a) the average emission limitationachieved by the best performing 12 percent of the existing sonrces (for which

the Administrator has emission information), excluding those sonrces that have, within 18 months beforahe

emissionstandard is proposed or within 30 monthsbefore such standard is promulgated, whicheveris later,first

achieved a level of emission rate or emission reduction which complies, orwould comply ifthe sonrce is not

subject to such standard, with the lowest achievable emission rate applicable to the source category and

prevailing at the time, inthe category or subcategoryfor categories and subcategorieswith 30 or more sources,

or

(b) the average emission limitationachieved by the best performingfivesonrces(forwhichtheAdministratorhas or

could reasonably obtain emissions information) in the category or subcategoryfor categories or subcategories

with fewer than 30 sources.

"Modification" means any physical change in, or change in the method of operation of, an affected facility which

increasesthe amount of any air pollutant (to which any state standards applies) emittedbysuchfacilityorwhichresultsin

the emission of any such air pollutant not previously emitted.

"Permittee" means the person or entity to whom a Chapter 6, Sectirn 3 permit is issued.

"Potential to emit" means the maximumcapacity of a stationary source to emit any air pollutant under its physical and

operational design. Anyphysical or operational limitationon the capacity of a source to emit an air pollutant, including

air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted,

stored or processed, shall be treated as part of its design if the limitation is enforceableby EPA and the Division, This

term does not alter or affect the use ofthis term for any other purposes under the Act, or the term "capacity factor" as

used in title IV of the Act or the regulations promulgated thereunder.

"Regulated air pollutant" means the following:

Permit No. 3-2-125-1 Page 56
(a) Nitrogen oxides (NOx) or any volatile organic compound;

(b) Any pollutant for which a national ambient air quality standard has been promulgated;

(c) Any pollutantthat is subjectto any standard established in Chapter 5, Section 2 ofthe WAQSR or Section III

ofthe Act;

(d) Any Class I or 11 substance subject to a standard promulgated under or established by title VI ofthe Act; or

(e) Any pollutant subject to a standard promulgated under Section 112 or other requirements established under

Section 112 ofthe Act, including Sections 112(g), 0), and (r) ofthe Act, including the following:

(i) Any pollutant subject to requirements under Section 1120) ofthe Act. If EPA fails to promulgate a

standard by the date established pursuantto Section 112(e) ofthe Act, any pollutantfor which a subject

source would be major shall be considered to be regulated on the date 18months after the applicable date

established pursuant to Section 112(e) ofthe Act; and

(ii) Any pollutant for which the requirements of Section 112(g)(2) ofthe Act have been met, but only with

respect to the individual source subject to Section 112(g)(2) requirement.

(1) Pollutants regulated solely under Section 112(r) of the Act are to be regulated only with respect to the

requirements of Section 112(r) for permits issued under this Chapter 6, Section 3 ofthe WAQSR.

"Renewal" means the process by which a permit is reissued at the end ofits term.

"Responsible official" means one ofthe following:

(a) For a corporation:

(i) A president, secretary, treasurer, or vice-president ofthe corporation in charge of a principal business

function, or any other person who performs similar policy or decision-making functions for the

corporation; or

(ii) A duly authorized representative of such person if the representative is responsible for the overall

operation ofone or more manufacturing, production, or operating facilities applying for or subject to a

permit and either:

(A) the facilities employmore than 250 persons or have gross annual sales or expenditures exceeding

$25 million (in second quarter 1980 dollars); or

(B) the delegation of authority to such representative is approved in advance by the Division;

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively;

(c) For a municipality, State, Federal, or other public agency: Either a principal executive officer or ranking

elected official. For the purposes of this part, a principal executive officer of a federal agency includes the chief

executive officer having responsibility for the overall operations ofa principal geographic unit ofthe agency; or

(d) For affected sources:

(i) The designated representative or alternate designated representative in so far as actions, standards,

requirements, or prohibitions under title IV ofthe Act or the regulations promulgated thereunder are

concerned; and

(ii) The designated representative, alternate designated representative, or responsible official under Chapter

6, Section 3 (b)(xxvi) ofthe WAQSR for all other purposes under this section.

"WAQSR" means the WyomingAir Quality Standards and Regulations promulgated under the Wyoming Enviromnental

Quality Act, W.S. §35-11-101, et seq.

Permit No. 3-2-125-1 Page 57

Permit No. 3-2-125-1

AppendixA B

Reserved (Modified July 21, 2014)

Permit No. 3-2-125-1

Appendix C

Compliance Assurance Monitoring Plan

SIMPLOTPHOSPHATES LLC- ROCKSPRINGS, WYOMING

Compliance Assurance Monitoring Plan For Applicable Sources -

Revision 4

SOURCE 9A- LURGI SULFURIC ACID PLANT.

A. Emissions Unit

Description:

Identification:

Facility:

Pollutants Emitted:

Lurgi Sulfuric Acid Plant

Source 9a

Rock Springs Fertilizer Complex

SOt., H2S04MistandNOx

B. Applicable Regulation, Emission Limits, andMonitoring Requirements

Regulation: . 40 CFR60Subpart H .

CAM Emission Limits: For emissions ofsulfur dioxide, theunitis equipped witha

CEMS. Theuseof a CEMS issatisfactory formeeting

CAM monitoring requirements under WAQSR Chapter 7,

Section 3(c)(lv). There areno add on devices for control of

NOx emissions. CAM does apply for H2S0 4mist.

Pre-CAM Requirements: Annual source testing for emissions ofsulfur dioxide.

Permit termsource testing for emissions ofH2S04 mist

andNOx.

Proposed CAM Monitoring: Daily "seeI no see" visible emissions monitoring to

. address H2S04 mistpollutant. Observations to be

conducted for at leastoneminute, Presence of opacity

will trigger corrective action. Reporting of excursions done

quarterly,

C. Control Technology, Capture System, Bypass, PTE:

Controls: High Efficiency MistElimitiators (Candle Filters)'

Capture System: Closed-duct system (cannot beby-passed)

PTE before controls: >100 TPYfor emissions ofH2S04 mistat efficiency

estimate of96-98%.

PTEafter controls: 10.5 TPY

D. Justification forProposed Monitoring:

Opacity fromsource is usually due to thepresence ofsulfurtrioxide / sulfuric acid mist.

. Daily visible emissions monitoring willhelpensure thattheprocess is operating

properly.

SOURCE 9B - MEC SULFURIC ACID PLANT.

A. Emissions Unit

Description:

Identification:

Facility:

'Pollutants Emitted:

Revised 8/26/10

MEC Sulfuric Acid Plant

'Source 9b

Rocle Springs Fertilizer Complex

S02,H2S04 MistandNOx

08-21-2010 320125
B. Applicable Regulation, EmissionLimits, andMonitoring Requirements

Regulation: 40 CFR60 SubpartH

CAMEmission Limits: For emissions of sulfurdioxide, tile unit is equipped with a

CEMS. Theuse ofa CEMS is satisfactory formeeting

CAM monitoring requirements under WAQSRChapter 7, .

Section3(c)(iv). There are no add on devices to control

emissions ofNOx. CAM does apply for H.S04 mist.

Pre-CAMrequirements: Annual sourcetestingfor emissions of sulfurdioxide.

Permitterm sourcetestingfor emissions of H2S04mist

andNOx.

ProposedCAMMonitoring: Daily' "see / no see" visible emissions monitoring to

address H2S04 mistpollutant. Observations to be .

conducted for at least one minute. Presence ofopacity

wiiltrigger corrective action. Reporting of excursions done

quarterly.

C. Control Technology. CaptureSystem. Bypass,PTE:

Controls: HighEfficiencyMistEliminators (Candle Filters)

Capture System: Closed-duct system(cannotbe by-passed)

PTE before controls: >I00 TPY for emissions of H2S04 mist at an efficiency

estimate of96-98%.

PTE after controls: 6.2TPY

D. Justification for ProposedMonitoring:

Opacityfrom source is usually due to the presenceof sulfurtrioxide/ sulfuric acidmist.

Daily visible emissions monitoring will help ensure that tileprocess is operating

properly.

SOURCE lOA - AMMONIUM PHOSPHATE PLANT.

A. Emissions Unit

Description:

Identification:

Facility:

Pollutants Emitted:

Ammonium Phosphate Plant

Source lOa

Rock SpringsFertilizerComplex

Fluoride, NH3 andParticulate

B. Applicable Regulation. EmissionLimits,Md Monitoring Requirements

Regulation: 40 CFR 63 SubpartBB & WAQSR Chapter5, Section3

CAMEmissionLimits: Sourceis exemptfrom CAMfor fluoride andNl-lj, CAM

applies for particulate matter.

Pre-CAMrequirements: Annual source testingfor ail pollutants. Continuous

monitoring ofscrubbing systemliquor flow and differential

pressure.

ProposedCAM Monitoring: TheNationalEmission Standards for Hazardous Air '

Pollutants (NESHAP) for hydrogenfluoride from

Phosphate fertilizer manufacturing plants requiressubject

facilities to continuously monitor applicable scrubbing

systemdifferential pressure and liquor flow. Fortile

ammonium phosphate plant, this is codified under

40CFR63, SubpartBB.

Revised 8/26/10

08-27-2010 320125

J 3<2'('· ... ~. '\
Simplot Phosphates LLC has been conducted thisrequired

monitoring andassociated record keeping andreporting

since 2001 permethodology approved by WDEQIAQD.

Differential pressure andliquor flow parameterranges are

established annually along with operating permitrequired

source testing for emissions offluoride. Thebasisofthe

NESHAP monitoring was thatEPAbelieved the

parameters of differential pressure andliquorflow are

adequate performance indicators ofmostscrubbing

systems. It is proposed thatthismonitoring willsatisfy

CAM for emissions ofparticulate matter.-

An excursion from the ranges established annually

during fluoride (NESFIA.P) source testing willtrigger

corrective action with reporting of excursions done

quarterly. Monitoring will bebasedupon l5-minute block ,

averages andexcursion reporting willbe based upona3-

hourrolling average ofthe IS-minute blocks.

C. Control Technology. Capture System. Bypass, PTE:

Controls: Packed Tower Scrubber withDemister .

Capture System: Closed-duct system (cannot be by-passed)

PTEbefore controls: >100 TPYfor emissions of particulate matterat 99%

efficiency.

PTEafter controls: 5.6TPY.

D. Justification forProposed Monitoring:

The scrubbing system forsource lOA is designed to control NH3, fluoride and particulate

emissions. TheNESHAP parameter monitoring for emissions offluoride (HF) has

ensured consistent performance ofthissystem, Therefore, itstands to reason thatthe

sameparametermonitoring will consistently control emissions ofparticulate matter.

Highandlowvalues for pressure drop and+1- 20% liquor flow range will continue tobe

established annually during fluoride source testing per established NESHAP procedures.

SOURCE 12 - AMMONIUM PHOSPHATE LOADOUT BAGHOUSE.

A. Emissions Unit

Description:

Identification:

Facility: .

Pollutants Emitted:

Ammonium Phosphate Loadout BagHouse

Source 12

Rock Springs Fertilizer Complex

Particulate Matter

B, Applicable Regulation, Emission Limits, and Monitoring Requirements

Regulation: WAQSR Chapter 3, SectionZ

CAM Emission Limits: CAM applies for particulate matter,

Pre-CAM requirements: None.

Proposed CAM Monitoring: Daily"see1no see" visible emissions monitoring.

Observations to be conducted for at leastoneminute.

Revised 8/26/10

.08-27-2010 320125
C, Control Technology, Capture System, Bypass, PT~:

Controls: Pulse JetBag House

Capture System: Closed baghouse system

PTE before controls: 438 TPYat 99% efficiency,

PTE after controls: l.l TPY

D. Jystification forProposed Monitoring:,

Because thisis sucha small baghousecontrolled source thatnormally does not exhibit

visible emissions, it is believed th3.t daily visible emission monitoring willbe adequate to

ensure consistent performance ofthe baghouse, If visible emissions are noted, corrective

action will be taken,

Revised 8/26/10

08-27-2010 320125
140 CFR Subpart AA and BB Startup, Shutdown and Malfunction Plans

Sourcesla, la' and Ib - Phosphoric Acid Plants (Sllbpart AA)

The la, la' and lb fume scrubbing systems simply collect fumes from various vessels,

sumps and filter tables in the plantphosphoric acidplant, but emissions are not directly

related to plantrates. The following procedures will be followed by plantoperators when

a scrubbing system malfunction occurs.

I. For the la/la' (Badger Plant) systems, check the scrubber pumps (PP-1307als)

and confirm they are operating correctly. For the Ib (Mustang Plant) system,

check thePP-6309 als pumps.

2. Check to seeifthe applicable flow meterinstrumentation is reading properly.

3. Check stack drains and confirm theyarenot plugged.

4. Complete the pmprocedure's for the scrubbers including:

• Check sprays for operation in theventuri, cyclonic and separator sections.

• Check the demisters for pluggage or damage.

• Check the drains forpluggage in the venturi, cyclonic andseparator sections.

5. Check theDeltaP's across the scrubbers. Verifyinstrumentation is working

properly. If the DeltaP hasfallen low, checkthe fanto see ifthe fan damper

position has changed or ifthereis a problem with thefan belts.

6. Check thepositions of the various slidegates, especially thoseabovethe filter

tables, tomakesuretheyhave notbeenclosed.

Startup andshutdown procedures as outlined in the phosphoric acidplantoperating

manual should be followed.

11-06-2008 320125

Revised October 2, 2008
Source 2 - Superphosphoric Acid Plant (Subpart AN

The SPA plantfume scrubbing systemsimply collects fumes from various vessels, sumps

etc. in the plant, but emissions arenot directly related to the batchprocess rates.

However, the following procedures will be followed byplantoperators whena fume

scrubbing system malfunction occurs;

1. Check discharge pressures on the 1'1 and2nd stage scrubber pumps PP-2760 and

PP-2766. Thedischarge pressure should be running between40 & 80 pounds. If

thedischarge pressure is lessthan 40 pounds, thepump should be pulledand

pump suctions checked to see if they areplugged.

2. Check the ductwork coming from therepulp sump to make sureit is clearof

buildup which may decrease airflow.

3. Check the water levels in the first stageandsecond stagescrubbers.

A. The level in the first stage scrubber should be running at the overflow point.

B. The level in the secondstage shouldbe running at approximately oneinch

above thebottom of the drafttube.

C. Pullsamples fromthe first andsecondstages forfluoride analysis,

4. Checkslidegates on all vessels that the scrubber system pullsfumes from.

A, Adjust slidegates so that no noticeable fumes aredetected leavingthe vessels.

B. If any slidegates aremissing,replace them.

5. Check allsprays on the systemto makesure theyareworkingproperly.

6. Check DeltaP across the scrubber tomake sure it is withincurrentoperating

parameters.

A. If the DeltaP is not withinthe established parameters, it canbe adjusted by

changing thesetting ofthe slidegateto the ductdrawing fromthe repulp

sumpand/or by adjusting makeup waterto the system.

B. If the DeltaP cannot be controlled, the I&E department mayneed to check the

instrumentation andthe systempm should be checked or conducted again.

Checkwiththe Northplantsuperintendent or the environmental department

for assistance.

Startup and shutdown procedures as outlined in tilesuper-phosphoric acidplant operating

manualshouldbe followed.

11~06~2008 320125

Revised October 2, 2008
Source lOa - Ammonium Phosphate Plant (Subpart BB)

Following is a general description of what measures should be taken if amalfunction in

the ammonium phosphate plantscrubbing system occurs:

1. Check the levelin the reactorto make sureit is at least 65 percent.

2. Check the recycle tank level and make sureit is at least 85%. Check the level

indication and climb up to the top of the tankto do a visual check. If below85%,

add water and/or acidin orderto maintain properlevelandpH (i.e., 4 to 7 per

item 4 below).

3. Check the scrubber lines with the lasertemperature gunto see if anylines are

obviously plugged. Unplug lines as necessary.

4. Check the pH of the tailgasscrubber. ThepH shouldbe in the range of 4 to 7. If

it is above7, it canbe decreased by adding morephosphoric acidto the scrubbers.

This condition wouldmost likely be caused by excessive carryover from the

reactor. Ifthe pH is lessthan 4, the tailgas scrubber water should be dumped to

the sumpandnew makeup water added. This condition couldbe caused by the

tailgas scrubber waternothaving been dumped afteran acid wash.

5. Check the tailgas scrubber deltaP reading to make sureit is in the 4- 12range

(range will change annually). Ifit is greater than 12,put the tailgas scrubberon

an acidwash. If problems persist,shut down to check demister pads. Clean and

repairdemister pads as needed. This condition is likelycausedby solids

accumulation in saddle packingand/ordemister pads. If the deltaP is less than4,

shut downthe plant and replace packingon demister pads. This condition is

likely caused by a largehole in the saddlepackingand demister pad.

6. If opacity(indicating malfunction) still exists aftergoingthroughthe systems

checks outlined above, goback to the reactor and recheck both the soniclevel

indication anddo a visuallevel check. If a 65%pluslevel is verified, inspectthe

feedtubes to determine if theyhave been damaged. Repairthese tubes as needed.

Note: As part of normal operations of this plant, it is periodically necessary to do a

"reversal" of thegranulator (the granulator is the sectionof the plantwherethe actual

fertilizer pellet is built). A reversal is whenthe granulator isstopped and rotated backin

the opposite direction fora shortperiodof timeto allowexcessive buildup and lumps of

fertilizer to be removed and/orbrokenup. Thisprocess doespromote excessive

particulateloading of the scrubbing and opacitydoesoftenresult. A reversal normally

takes approximately 15minutes andthe resulting opacitynormally doesnot persist for

more than 30 minutes. This opacity is estimated at less than 20%.

Startup and shutdown procedures as outlined in the ammonium phosphate plant operating

manual shouldbe followed.

11-06-2008 320125

Revised Octobel' 2, 2008

Permit No. 3-2-125-1

Appendix D - L

Reserved (Modified July 21, 2014)

PennitNo.3-2-125-1

AppendixM

Fluoride Control Techniques

, Simplot Phosphates LLC

Phosphogypsum Storage Area

Fluoride Control Techniques Document

August 2008

BACKGROUNDSUMMARY

SFPhosphates Limited Company (SFP) was out of compliance with WAQSR

chapter 2,section 9 (a)(ii) regional ambient airfluoride standards, as administered,

during the summers of 1994, 1995, and 1996. As a result ofthismatter, a

compliance order andNOV was issued to the company onNovember 15, 1995

(Docket #2717-95). In summary, this NOV required SFP to evaluate the sources

and causes of the increased fluoride emissions during these years and develop a

plan or corrective action. After much investigation and research, the company put

together a comprehensive fluoride remediation plan which focused onthe

phosphogypsum storage area (hereafter "PSA") as theprimary source ofthe

increased fluoride emissions. This planwas submitted to theWbEQ/AQD in

November of 1996. The unique and innovative techniques within thisplan were

successfully implemented and compliance was achieved during the summer of

1997 at a cost of approximately $1.3 million.

PSA's are a necessary partof phosphate fertilizer production. The Environmental

Protection Agency (EPA) states in 40CFR 61.202:

Each person who generates phosphogypsum shallplace allphosphogypsum

instacks...

Prior EPA approval isrequired before using phosphogypsum for purposes other

thanthose identified in Subpart R of 40 CFR 61.

In the summer of2007, the earth work and synthetic lining system for a 125 acre

expansion ofthe PSA was completed. Normal operations include changes inthe

footprint ofthe stack to adhere to height/stability limits. To address these issues it

is necessary to pre-build areas for additional storage. We believe that this .

additional area willprovide additional options to decrease fluoride emissions

during the summer months as noted below, TIle construction ofthe

phosphogypsum dike surrounding this new area is currently underway and should

be completed sometime in 2010.

TheWDEQ-AQD has asked for additional information under Permit Application

No. AP-7283 and we believe thatthisupdated fluoride remediation plan provides

Revised August 12,2008
., , .

thatrequestedinformation..:Chis,updated plan win'~li;lobeincluded in our

upcoming operating permitapplicati6n:' " , "., " " '"" ..{ :..:.'. ,: .; . ':'<', :'. ':"',-, ., / .. .,,: ,:' ", ,-

It isthe.goal andintent ofSiIpplottorriaintain.coP'lpIiiLnce,"'ith the applicable

WAQSRchapter'2:section'9shinaards. '}:[owbver,Sifuplot haS ai&iillber of

legitimate concerns regardinii'iliestiirige:iJ,cYal1d applicability ofthese standards

and it isthe company's desireto seekfuture changes to those standards, Simplot

is happyto reportthat after over 22 years o,f.?pe~~t,~?n, ,no aqversEjetlyironrp.ental

impacts have OCCUlTed as a result offluoride erilissions'from the ReickSprings

Fertil!zerqo1?plex~> ~., ... ' .'. . 'j.'.'. "". ' . ':. . .. :,.

INTROj):ficiJON' , " i' ,', : ".;' . " ,,"

".'

This'docJimentJilllisttli~ fl~oride control techni~lll:ls t4~twere used to.some, '

ext~ntattheRdck Springs facility from 1997 -2007ai1d allowingthecompany to

a2hieveconlp1iotnce. With W,AQ~R Chapt~r 2,.$ection9 (aXU) regional ambient air

standl3IM;WitIiafewnoted'exGeptions in JUlyoiZQQ7 andAprilof2008. Some'

techniques that are.no.Ionger usedhav:e beenelimillated from'this updatedversion. . . ' ,." .. ," ," . . .. ' '. .'.:' . , ...... " ': '

. , .,' ".

Pleas~ ~()te~l:1a~thisdocument is aievisionto,the.prigfnal v~sion submitted by SF'

phosphates back ilii 998. .Simplot became the~ol~oW!Ler of'the facilityin, "

Novembe« of 2064. .Simplothas spent considerabletilne,~ffort andrnoney in

achieving thisinitialsuccess. Webelieve that thesetechniques will continue to be

successful in future Y<1ars." .Simplot has discussed these techniques with the

WDEQIAQ:D on numerous occasions,aD:dbelieve the AQD has a reasonably good

understanding of howthey are implemented.andofsome ofthe potentialpitfalls

that are Inherentdne.to the dynamic nature ofthePSA. 'The PSAis"an jritegral .,-

part ofthe overallfacility water balance that is sometimes difficultto maintain. ,": .......'.- "." .. :' '"', '.... ,' .. ' ~', '. ', .. ' '. ,,' " '.

CORE FLUOR/DE CONTROL TECHNIQUES,

'. RimDitch (cell) Building Technique - Thistechnique allows wider

phosphogypsum storage cellsto be constructed so thatmoredike building

gypsum material canbe stored in eachcell. Thislarger cell building has '

become the standard operating procedure. .Eaoh individual cell doesnot have

to be disturbed as oftenwhichfacilitates lowerfluoride emissions in itself

because newsurfaces are created withlessfrequency; 'I:i:t addition, when these

widercells are disturbed for dikebuilding, a larger lift canbe built so thatthe

entire stack goes up quicker. This mightallowconstruction to be limited or

ceased during certain criticalsummer periods in the future as our new area

becomes operational., .:

(

, c _

''.'-.-,

Revised August12,2008 2
• KeepingPhosphogypsum AreasActive (wetted) - The idea behind this .

technique was to keepthe four main (current) storage areas in operation

simultaneously through efforts to keep water ponds on portions ofthese areas

and to keep the remaining areas of the stacks uniformly wetted. Thiswater

pondinganduniform wetting is achieved through the use ofweirs and by

alternately discharging phosphogypsum slurry from various corners ofthe

stacks. Thelarge increase in temperature onthe surface ofthe PSAduring the

summer months (measured in excess of 120 degrees F) equates to increases in

evaporation rates as well. This evaporation means that PSAsurfaces will dry

out more rapidly which, in turn, means that fluoride emissions willincrease as

this drying process occurs. Bykeeping portions the PSAwetted, surface

temperatures are lower, which should resultin lower fluoride emissions. The

more current thinking regarding this management technique still holdstrue

from the standpoint ofsurface temperatures, but we try andmanage this in the

summer months so that the stacks don't go through a drying process, butnotto

the extent that wateris ponded because more HF is driven off the free water

areas assurface temperature increases.

• LimitDikeBuilding, Material Hauling and Water Surface AreaDuringCritical

,Periods - Thistechnique employs an accelerated building strategy in the spring

and fall time periods whentemperatures, evaporation rates, and fluoride

emission rates are lower dueto lowersurface temperatures. Material handling

will be stopped first as this activity spreads material out overlong distances

and creates newemitting surfaces in the process. If enough additional storage

area is created in the spring and fall, then dike buildingcan be decreased or

eventemporarily ceased during portions of themore critical summer months

when fluoride emissions arehigher. Ifmore water can be ponded and.. "

evaporated during the cooler periods, then a better waterbalance might be

achieved sopondedwater canbe minimized duringthe summer. This

technique islimited by the storage margin necessary to maintain a stable stack,

but should allow additional flexibility in the future as the new areais placed

fully into service (anticipated 2010). Please note that the overall stability ofthe'

stackedphosphogypsum is paramount andSimplot will conduct all operations

with safety andlongtermbusiness liability in the forefront of ourthinking, A

failure of one of the stacked areas has happened withinourindustry andwould

be devastating to our business anda serious environmental and safety concern.

Pleasenote that limited activity is currently notpossible as continuous dike

building must be conducted onthe developed areas of the PSAin order to keep

up with the current production of phosphogypsum.

Revised August12,2008 3
• Surfa'ceAf2plii:JationofSlCkedLime- Slakedlime is appliedtoaccessible

surfaces ofthePSA with aspeclallyequippedtruck. The Iimematerial

neutralizes fltiOl:i~", onthe ·sU:tfa:ce ofthe phosphogypsiJiri'arid alsoprovides a

reflectivecoating which decreases the temperature of'the smfaceithas been

applied to, Thistebhnique istimedfot nlaximumbertefit. becatlse.'all ofthe

active areas of.ihestabkarenew every four to sixweeksand thus; lime applied

t06early is coeVeredoverwithnewphosphogypsUfu arid'wo'L1ldnbt he as •

.:effective'when needed (staildards atemeasi.lredagairisttinatol1ing~a:verage

basis),The lirrieis appliedto the permanent'surfaces witbirtthePSA based on

meteorologicalconditionsprioriothb'criticalsummer'months> The active

areas are treatedbased on meteorological conditions and. the stageofthe

buildingprocess the particular area isin:.,. Anyresidualliine coveredover

shouldstuihave somepositive effect, but appropriate'tiniingofthe surface

apfllicatJ.o:i1shouldproduce the maximumbenefit, ., . . , ,,', .,:,.' (. . . ;..... ' .."'.. :.;', .,," ,

• .SoilCar/ptng0nd VegetationAp'plication -Simplot hascoveredapJlroximately

40 acres ofnon-active or permanent areas ofthe'PSA Withsoilarid reclaimed

this area with vegetation, Thistechnique effectively seals these areas ofthe

phosphogypsum dil<6sfromeniitting fluoride and whl provide' a templatefor '

,postclosurereclamatiori, Webelieve We have achievedsome success with this

techniqueand approximately 40~50 moreacres will be readyforsoil capand

vegetationwithin the nexttwo years . . ...

FLUORIDE REMOVALSTRATEGY :" .. , .; .

• Fluorosili'Cid Acid(ESA) RecoVliry"':" Due to the complexchemistrYWithin the '

. ,phospnogypsWnstorageareaand th{)unpreaiCfitblemeteorqlqglcalcondrtions"

aroundtheRbcK Springssite, Simplothas shiftedmuchof ourfocusregarding

fluoride toremovalofthe fluoride priorto bemgplaced ifLt6the pElA.· . . "'. . ".'. .',.''... . '. .. ..' ',. ',,'. . . .'

.Simplotinstalled afluorosilicic acid recovery pro'cess ~d began production of

thismaterial in February of2006: This process eliminatesapproximately

4,500 tpy of'fhioride (24,000 tonso:f24%FSA)from ever enteringthe

phcsphogypsum'storage areaby taking a fluol:idewaste streamfr6U:i the

MustangD-Bvaporitor that had been going to the :EiSA and processingthat . " " ,. "

streaminto a useablewaterfluoridation product. .. , . , . - -. . ...' ..

Simplothas plansto recover additional FSA as partOf a plannedreactor

replacement projectthatwilleliminate approximately 4,500 additional tpy of

fluoride (production ofFSA up to approximately 48,·000 tpy) fromentering the ( .

PSA. In addition, new fluoride recovery products will be evaluated as part of

the longerterm expansion plans ofthe facility. This fluoride recovery.idea is

Revised August12,2008 4
....-

difficult to quantify into emissions decreases due to the complex chemistry and

the unpredictable meteorological conditions, but Simplot believes this to be a

positive and long termmethod ofremoving fluoride. A basicfluoride balance

is provided belowto betterillustrate thisidea.

PROGRESS REPORTING

The ambient fluoride data isincluded in the quarterly environmental monitoring

reports submitted to the division within 60 days ofthe end of each calendar

quarter. In addition, a separate ambient fluoride report will be submitted annually

to the division at the end of each critical time frame (i.e., September- October).

Any of this data as well as on sitemeteorological dataare available at anytime

upon request.

Revised August 12,2008 5

Permit No. 3-2-125-1

AppendixN

Permit CT-550A3

Department of Environmental Quality . Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002

THE STATE

)JIM GERINGER

GOVERNOR

ADMINISTRATION

1307) 777-7758

FAX777·7662

OFWYOMING

ABANDONED MINES AIRQUAliTY INDUSTRIAl SITING lAND QUAliTY SOliD & HAZARDOUS WASTE

13871777-6145 13071777·7391 1307} 777·7358 1307)77'/·7756 130'/1777-7762

fAX 634·0799 fAX 777·661ij fAX 717·6937 FAX 634·0799 fAX 177.6973

February 7, 1995

i

r \\ '\ .../ _. y

WATER QUALITY

13071777·7781

FAX 777·5973

Mr. James M. Williams

Vice President of OperationsSF Phosphates Limited Company

P.O. Box 1789 . Rock Springs, WY 829Q2·1789

Permit No. CT·550A3

Dear Mr. Williams:

The Division of Air Quality of the Wyoming Department of Environmental Quality has

completed fmal review of SF Phosphates Company's application to amend Air Quality Permit

CT-550A to incorporate a specific methodology for determining compliance with theWyoming

fluoride in forage standards at the existing SF Phosphates Fertilizer Plant located in Section 15,

!l8N, Rl04W, approximately 4.5 miles east southeast of Rock Springs, in Sweetwater-County,

Wyoming.

Following thi~ agency's proposed approval of the request as published January 4, 1995 and in

accordance with Section 21(m) of the Wyoming Air Quality Standards and Regulations, the

public was afforded a 3D-day period in which to submit comments concerning the proposed new

source, and an opportunity for a public hearing. No comments have been received. Therefore,

on the basis of the information provided to us, approval to amend the permit for the fluoride

monitoring methodology as described in the application is hereby granted pursuant to Section

21 of the regulations with the following conditions:

1. That authorized representatives of the Division of Air Quality be given permission

to enter and inspect any property, premise or place on or at which .an airpollution source

is located or is being constructed or installed for the purpose of investigating actual or

potential sources of airpollution, and fordetermining compliance 01' non-compliance with

any rules, regulations, standards, permits or orders.

2. That all commitments and descriptions set forth in the application for this permit,

unless superseded by a specific condition of this permit, are incorporated herein by this

reference and are enforceable as conditions of this permit.'

3. The method by which SF Phosphates will determine compliance with Wyoming's

fluoride in forage standards as set forth in Section 11 (b) of the Wyoming Air Quality

Standards & Regulations (WAQS&R) at their Rock Springs phosphate fertilizer

production plant, -will be 'to incorporate a "Random Walk" sample averaging method, as

described by the following steps.
Mr. James M. Williams

February 7, 1995

Page 2

,.;,' .

:-:..,:.:,: ../ . ...; " ':'~,,,,,, "':""'" "." ,",':.;':,:, ..: ';':'.•.;.'/: '·;~;·:.':·i ·t;..:·~> ".»: :, ":'1":;':"<:';":"::':"::";';' ;":";':':~:':"<:.' ",. a)' On.arnonthlybasis, SF Phosphates will continue to COllect data'from the 47 sites on

theircurr¢ntf1uorideiri forage iUo.nitodng network (drawingll,D10CI001),'and report , thl':.t1uc>~ide concentrations recorded at each'of'thosestationstn a'quarterly .monitoring

rer:.o,rt; ':':'>;,'::' '; .' .: . ',J~; '.

lJ) SF Ph~fphates wllicdlcuiate ;~c6rri~li~~e~ average" oithe 31 plots intne12 mi2

core area, whichexcludes.fenced.aites 115,116,1119,1120, #24,1125; #26 & #27, and also

excludes expanded sites1140 through 1147 located in the 30nifiinpad area, This Raw.

Monitored Data Average concentration will be compared:a:gairistthe'correlateciR,andom

Walk verageconcentratlon in Tab~e r ofthis'permit, If the ~\'Y M:Q~itqred D~ta "compliance average" for the month IS greater than)43ppm fluol'1~e, theuthe .potential

animal diet is presumed to be greater than the WAQS&R 30 day 'forage iil'fluoride

standardof 80 ppm and the Rock Springs fertilizer facility will. be deemed:to have

recorded an exceedarice of that 30 day fluoride in forage standard. .

c) . SF Phosphates will calculate II rolling two-month 'average-fromvthe monthly

"compliance averages" described in step,b) of this condition. ThisRawMonitoredData

A-verage concentration willbe comparedagainst thecorrelated RandomWalkAverage · corcentrationIn Table Iof this' perni.it;.' 'If the Raw: MoriitoredDatli'.'coPlpliance

average" is greater-than ]Qq ppriJ:nuQrjde;:theri the potentialanimaldietispresumed to

'be greater th~hthe'WAQS&R 60dayforagein'fluoridestaooaid Of60 ppm.and:t)1e Rock -. Spririgsfertiliier facility willbedeemed to haverecorded an exeeedanceof that 60.day fluoride in forage standard: . . . . ...;: " ': ."

· d) SF Phosphates will calculate a. rblli~g twelve-mouth average.from thenionthly · "compliance averages" described in step b) ofthis condition, ThisRaw MonitoredData

Average concentratiorrwill be compared (lgainSt.the correlated Random:WalkAverage

•. concerttrationjnTable .1' of 'this permit> :.Jfthe.'Raw Monitored Data ."compliance

" .' average" .is greater than 50 ppmfluQride, f1!eii:thepotential animal-diet isp~esume4 to

be greater than theWAQS&Rlirlnria!forage influorideetandard of 30ppm alidthe Rock

Springs fertilizer facility will be deemed to'have recorded nnexceedance of that annual

fluoride .In forage standard, . . . . .... . ;' \ .. . . ':.' .' ': 1:' ," ,.: ;'" : . . , . , ,','. . . " ".' ", .., ", ".

; It must be noted that this approval doC:S not relieve you ofyour'obligation to comply with all ,applicable county;"state, and-federal standards, regulations or ordinances-. Special attentionmust

be given to Sectiori21 of the Wyoming Air Quality StandardsandRegulations.' Section 21(a) .

req~ires that.a perm,it to o~erate is!equ!red in order'to oper~te ida~i1ity'a~tedI120.day start-up ·C';' period, Section 21(1) requires notification of start-up, Section 210) requires that performance, .

tests be conducted within 90 days of initial start- up, andSection 21(h) requires that construction ..
Mr. James M. Williams

February 7, 1995

Page 3

or modification must commence within 24 months of date of permit issuance or the permit will

become invalid, unless the Administrator extends such time period based on a satisfactory

justification of the requested extension. Any appeai of this permit as a final action of the

Department must bemade to theEnvironmental Quality Council within sixty(60) days ofpermit

issuance per Section 16, Chapter I, General Rules of Practice and Procedure, Department of

Environmental Quality. , . '

If we may be of further assistance to YOU}leaSe feel f~7/~7contact .this office.

Sincerely, /''/;' ,

ckwL a, O~eL~ 'tM11CJ!l/~'/ ,

Charles A. Collins I Dennis Hemmer

Administrator Director

Air Quality Division , Dept. of Environmental Quality

CAC:DHlBJD.
, 0

," .....

.. .....

c • ~.,

",'TdbleI.... , "PermitCT·S5iJA3'··.· , ...... i '; :':.." ; ('. , .

. i' ....

. . . ,

,:-." .

."SFPhQsphates RockSprings Fe'rtiilzerpiant-' Forage i~ FluorldeCdmpl{ance Table

'.,". '. , , .

Random Walk Raw Monitored Data Random Walk Raw MonitoredData

Average (ppm) Average (pJiin) , Average (ppm) Average (ppm)

6 6 ',' 50 88

20 32 51 89

21 34 52 .91 .'

22, 36 53 '9;3 .'

23 38 54 95

24 39 55 97

25 41 56 . '99

26 43 57 '101

27 45 58 102

28 47' .59 104

29 49 60 106

30

31

50

52 62

61

110

108 c

32 54 63 112

33 56 64 113

34 58 65 115

35 60 66 117

36 " " 62 ' 67 119

37 63 68 121

38 65 69 123

39 67 70 125 . 40 69 71 126

41 71 72 128

42 73 ' 73 130

43 75 74 132

44 76 75 134

45 78 76 136

46 80 77 , 138

47 82 78 ' 139

48 84 79 141

49 ' 86 80 143

, C,"" ;a