# 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 40 CFR63 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 ofOwner: 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 elemental sulfur which is then absorbed to prodnce sulfuric acid. Additional sulfnric acid ispurchased on the spot market and imported by truck and rail from vendors. Sulfuric acid is then either mixed with the phosphate rockconcentrate slnrry to produce phosphoric acid (H3P04)or placed in tankstorage for future nse. The produced phosphoric acid is filtered to remove gypsum and concentratedto 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 fertilizerat 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 controlledwith 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.

PermitNo. 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 permit shall be deemed compliance with any applicable requirements as ofthe date ofpermit 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), ifnecessary.
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 ofnot 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/hrSO, (iii) 5.84 

### Ib/hrNOx (iv) For fluoride, 

### 0.060 Ib/tonofP,O, feed, and 2.30 

### lb/hr 

### (v) 1.40 

### lb/hrCO (vi) 100 

### Ib/hrand 438 TPY 

### ofNl-l, (ammonia) (b) The ammoniumphosphate plant shall 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 inputbetween 122.5 and 350 

### MMBtulhrfor

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 of350 

### 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 (unit29) shall be Tier 3 certified, and shall not exceed 50 hours ofoperation per year; a non-resettable hour meter shall be operated and maintainedto 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 ofoperation. (i) The permittee shall operate and maintain the Cummins KTTA50-G2 generator engine in 

### accordance withthemanufacturer's orsupplier's recommendations. (ii) The permittee shall operate and maintainthe 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 (unit28) 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 ofoperation 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 orsupplier'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 ofan 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 similarto the unit replaced with emission levels at

or below those ofthe unit replaced. (c) The permittee shall notifythe Division in writing ofsuchreplacementwithin 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 ofany 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 emissions from 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 CFR 60 SubpartH 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 ofoperation 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 subjectto 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 testmethod 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 emissions from the phosphoric acid plants (units Ialia', 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 handlingbaghouse (unit 17),the permittee shall conduct monitoring as follows to determine the presence ofvisible 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 ofvisible emissions. (ii) The visual observations shall be conducted by a person who is educated on the general procedures for determiningthe presence ofvisible emissions but not necessarily certified to performMethod 9 observations. (iii) Observation ofvisible emissions from any source listed above shall promptirnmediateinspection 

### and, ifnecessary, 

### 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 monitoringrequirements for the phosphoric acid plants (units Iall 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 measureNOx 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 

### mostrecenttest; 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 ofeach sulfuric acid plant as indicated in the CAM plan, to determine the presence ofvisible emissions. (ii) The visual observations shall be conductedby 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, ifnecessary, 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 parametermeasurement outside the indicatorranges 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 ofthe 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 emissions testing, P,O, feed rate, and continuous scrubbermonitoringrequirements for the ammonium phosphate plantare 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 ofvisible 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 ofvisible emissions from any unit, and shall prompt immediate 

### inspection and, ifnecessary, 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 packagedboiler (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 ofWyoming'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 IIRecordkeeping 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 ofproductproduced; (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 ofSQ. (c) The permittee shall retain all records and support information for compliance with this condition and with the reporting requirements ofcondition F32 at the facility, for aperiod ofat 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 ofan 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 ofat 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 monitoringrequired 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) Forthe ammoniumphosphate plant (unit lOa)particulate emissions testing requiredby 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 monitoringrequired 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 observations required by the Divisionuuder conditions F14 and F15(c), the permittee shall keep field records in accordance with Section 2.2 ofMethod 9. (c) The permittee shall retain on-site at the facility, the records ofeach test, measurement, or observation and support information for a period ofat 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 monitoringrequired 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) ofany 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 emissions test results and the evaluation of CAM indicator ranges as specified by condition FI9(a)(iv). (iv) The date, time, and duration ofany 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 ImprovementPlan (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 ofat 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 monitoringrequired for the packagedboiler (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 calendaryear 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 packagedboiler 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 ofat 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 ofoperation 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) monitoringrequired 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 methodthan 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 ofconducting 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 abrief 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 ofopacity 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 ofoperation 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 ofdeviations from the conditions of thispermitmust 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 conditionP63·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/hr

### limit 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/ton

### of 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. Excessemissions forpurposes 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 122.5 MMBtulhrheat 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 of submission 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 of40 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 ofa Risk Management Plan.

PSD (Prevention ofSignificant 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 boilerproject described in AP-10171, and the auxiliary boiler project described in waiver AP-12908, do not result in a majormodificationunder 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-I0171, 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 averagepound per hour emissionrate 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 summingthe daily SO, emissions for the calendar year. Actual emissions from 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'

### !I b) 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 determinedusing 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 multiplyingthe 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 is required 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 ofeach 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) Ifinitial startup ofequipment after project completion has not yet occurred, that shall be so stated in the report in place ofemissions 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 ofatleast 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 19WAQSR 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 as tbey apply to each steam generating boiler as defmed under 

### §60AOb, including the packaged boiler (unit I

### lJ). (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 ofall 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 SubpartDb §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 ofthe 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 20performance 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 ofexcess 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 ofexcess 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 ofexcess 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 ofany malfunction (ifknown), 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 greaterof 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) Notwithstandingthe 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 permitpursuantto 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 21WAOSR 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 requirements specified 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 SubpartH as they apply to each sulfuric acid production unit defined under §60.80, includingthe 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 maintainrecords 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; allcontinuous monitoring 

### system performance evaluations; all continuons monitoring system or monitoring device calibration checks; and adjustments and maintenanceperformed 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 aperiod 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 SubpartH excess emissions and monitoring systemsperformance report (excess emissions are defined in paragraph (b) of this 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 ofeach calendar quarter. A separate written report shall be submitted for each sulfuric acid plant, and shall include the following information: (i) The magnitude ofexcess emissions computed in accordance with WAQSR Chapter 5, Section 2 (i)(viii), any conversion factor(s) used, and the date and tiroe ofconunencementand completion of each time period ofexcess emissions. The process operating time durirg the reporting period. (ii) Specific identification of each period ofexcess emissions that 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. Forthe purpose ofreporting under §60.7(c), periods ofexcess emissions shall be a1l3-hour periods (or the arithmetic average ofthree consecutive l-hourperiods) during whichthe integrated average sulfur dioxide emissions exceed 4 lb/ton ofacid 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, includingperiods ofstartup, shutdown, and malfunction, the permittee shall, to the extentpracticable, 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 ofSubpart 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 23WAOSR 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 SubpartAA 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 of the 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 theemission 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 requirements for 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 permanentlyrecords 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 permanentlyrecords 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. Exceptfor 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 ofthe 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 malfunctionplan (SSMP) that describes, in detail, procedures for operating and maintainingthe 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 withthe 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 ofeach 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 of5 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 otherplan, 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 malfunctionbut 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 maintainingthe source during similar malfunction events and a program ofcorrective action for similar malfunctions ofprocess 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, orrecord. At a minimum, themost
recent 2 years of data shall be retained on site at the facility. The remaining 3 years ofdata may be retained offsite. Such files may be maintained on microfilm, on a computer, on computerfloppy 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 ofequivalent P,O, feed, determined as described in condition P63-AA3(a)(i); (ii) The occurrence and duration of each startup, shutdown, or malfunctionofoperation (i.e., process equipment); (iii) The occurrence and duration ofeach malfunction ofthe air pollution control equipment; (iv) All maintenance performed on tbe air pollution control equipment; (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

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 informationneeded to demonstrate conformance with the SSMP may be recorded using a "checklist," or some other effective form ofrecordkeeping, 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 ofperformance 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 ofperformance tests and performance 

### evaluations; (xii) All documentation supporting initial notifications and notifications ofcompliance status under condition P63-AA 7 ofthis permit. (xiii) All records ofapplicability 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 Administratorin writing of their intentionto 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 SubpartAA. This shall include the results in lb/ton and Ib/hr ofany performancetest required under condition P63-AA2, which shall be reported within 60 days ofcompleting the test. Tbe Notification ofCompliance Status shall include all informationrequired by Ch 5, Sec 3(k)(viii). (d) The permittee shall submit all other notifications as required by 40 CFR SubpartAA 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. Ifexceedances are reported, the permittee shall report quarterly until arequestto 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 malfunctionofan affected source (including actions taken to correct amalfunction) are consistent with the procedures specified in the source's SSMP, the permittee shall state such information in a startup, shutdown, and malfunctionreport. 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 malfunctionreport shaJJbe delivered orpostmarkedby 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 malfunctionis not consistent with the procedures in the SSMP, the permittee shall make a report ofthe actions taken for the event within24 hours, by telephone call or facsimile (FAX) transmission. The immediatereport 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 commencing actions 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 27WAOSR 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 equipment subjectto SubpartBB, the permittee shall maintain daily averages ofthe pressure drop across each scrubber and ofthe flow rate of the scrubbing liquid to each scrubber within the allowable ranges established pursuantto §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 shallhave an accuracy of ±5 percent over its operating range. Equivalent

### 1',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 permanentlyrecords the flow rate ofthe 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, maintenanceperiods, 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 minimizingemissions 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 malfunctionplan (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 actiontaken 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 Administratorfor the life ofeach 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 of5 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 malfunctionbut 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 

### maintainingthesource during similarmalfunction events and aprogram ofcorrective action forsimilar malfunctions ofprocess 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 ofdata shall be retained on site at the facility. The remaining 3 years ofdata 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 ofequivalentP2

### 0 , 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 ofeach 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 ofrecordkeeping, to minimize the recordkeeping burden for conformingevents); (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 ofperformance tests, in units of 

### lb/ton and lb/hr, (x) All CMS calibration checks, and all adjustments and maintenanceperformed on the CMS;; (xi) All measurements as may be necessary to determine the conditions ofperformance tests 'and 

### performance evaluations; (xii) All documentation supporting initial notifications and notifications ofcompliance status under condition P63-BB7 ofthis permit. (xiii) All records ofapplicability 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 reportedwithin 60 days of completing the test. The Notification ofCompliance Status shall include all informationrequired 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 Administratorand 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. Ifexceedances are reported, the permittee shall report quarterly until a requestto reduce frequency is approved as described in Ch 5, Sec 3(1)(v). The summary report shall include: (i) All exceedances ofpressure 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 areporting 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) Ifactions taken by the permittee during a startup, shutdown, or malfunctionofan 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 malfunctionreport. 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 postmarkedby 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 malfunctionis 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 immediatereport shall 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 events that affect a CMS and are not addressed by the SSMP, the permittee shall send a follow-up report within 2 weeks after commencing actions 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 31WAQSR 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 of40 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), ifan 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 CFR 63 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 major source ofHAPs as defined in §63.2, except that for oil and natural gas production facilities, a major source ofHAPS is as defined in §63.761 (40 CFR Part 63 SubpartHH). The types ofboilers 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 conditions CAM-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 ofcompliance 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) andhaveitavailable 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 of this 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 monitoringrequired 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 of40 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 phosphogypsumstackoperating 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. Permitexpiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted at least six months prior to the date ofpermit 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 ifthe 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 submit such 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 submissions to 

### 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 submissionto 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 ofEnforcement, 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 ofPartnerships 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 changehas met 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 writtennotificationrequiredshallincludea briefdescription 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 longerapplicable 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 permitamendmentif 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 becomeapplicable 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 assessmentis appealedpursuantto W.S. 35-11-211 (d). If anypartofthe fee assessmentis notappealed 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) andW.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.Theemissions inventory 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 withallconditions ofthis permit. Anypermitnoncompliance constitutes aviolationof 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 necessaryto haltorreducethepermitted activity inordertomaintain compliance withtheconditions ofthispermit.

PermitActions: [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.
Property Rights: [WAQSRCh 6, Sec 3(h)(i)(F)(IV)] (GI3) This permit does not conveyany property rights of any SOli, 

### or any exclusiveprivilege. Duty to ProvideInformation: [WAQSRCh 6, Sec 3(h)(i)(F)(V)] (G14) Thepermittee shallfurnish to theDivision, within areasonable time,anyinformation thattheDivisionmayrequest inwritingto determine whethercauseexists formodifying, revoking andreissuing, orterminating thepermitorto determine compliance withthe permit. Uponrequest, the pennlttee shallalsofurnish 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 clahnofconfidentiality.

EmissionsTrading: [WAQSRCh 6, Sec 3(h)(i)(H)] (G15) No permitrevisionis required,underany approvedeconomicincentives, marketable permits, emissions trading 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 emissionsrelatedactivity is conducted, or where records must be kept under the conditionsof this permit; (b) haveaccess toandcopyatreasonable tbnesanyrecords thatmustbe 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) sampleormonitoranysubstancesorparameters atanylocation, duringoperatinghonrs,for thepurpose of assnringcompliance with this permit or applicablerequirements.

Excess EmissionsDue to an Emergency. [WAQSRCh 6, Sec 3(1)] (G17) The permitteemayseekto establishthatnoncompliancewithatechnology-based emission limitationunderthis permitwas due to an emergency, as definedin Ch6, Sec 3(1)(i) of the WAQSR. To do so, thepermittee shall demonstrate the affirmative defenseofemergencythroughproperly 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 theemissions 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 theemergency, 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 ofair contaminant released tothe atmosphere, shall dilute or conceal an emission from a source, This condition shall not apply tl the control ofodors.

Unavoidable Equipment Malfunction: [WAQSR Ch I, Sec 5] (GI9) (a) Any source believing that any emissions in excess ofestablishedregulation limits or standards resulted from an unavoidable equipmentmalfunction, shall notifythe 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 ofthe 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 ofcarbon 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 ofgaseous dilutants to achieve compliance with a visible emissions standard, and the piecemeal carrying out ofan operationto avoid coverage by a standard that applies only to operations larger than a specified size. 

### (b) All owners and operators conducting an asbestos abatementproject, 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 ofWAQSR Ch 3, Sec 8.

Permit No. 3-2-125-1 Page 40Open Burning Restrictions: [WAQSR Ch 10, Sec 2] (G23) The permittee conducting an open burn shall comply with all rules and regulations of the Wyoming Department ofEnviromnental 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 rubberproducts, includingtires; waste petrolemn products, such as oil or used oil filters; insulated wire; plastic products, includingpolyvinyl 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) 

### StandardsforAppliances [40 CFR Part 82, Subpart F] The permittee shall complywith the standards for recycling and emission reductionpursuantto 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) Equipmentused during the maintenance, service, repair, or disposal ofappliances 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 ofMotor 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 41STATE ONLY PERMIT CONDITIONS (Modified July 21, 2014) The conditions listed in this section are State only requirements and are not federallyenforceable.
Ambient Standards (SI) Tbe permittee shall operate the emission units described in this permit such 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 98 th Nitrogen dioxide 100 parts per billion percentile ofthe daily maximum I-hr 3 

### average concentration
0.053 parts per million 

### annual arithmetic mean

75 parts per billion three-year average ofthe annnal (99 th

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 exitprocess gas stream containinghydrogen sulfide which is dischargedto 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 42Odors; [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 designatedby the Division as producing equivalentresults. The occurrence ofodors shall be measured so that at least two measurements can be made within a period ofone hour, these determinations being separated by at least 15 minutes. (b) Odorproducing materials shall be stored, transported, and handled in a manner that odors produced from such materials are confmed and that accumulation of such 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 weightbasis, 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 priorto 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 indicatorofcompliance 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 ofat 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 Documentin 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 ofeach 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 ofeach 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 of the 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.

PermitNo. 3-2-125-1 Page 450.55 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 ofoperation 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 correspondingpermit conditions, listed in brackets, contain detailed descriptions of the compliancerequirements. Compliance

### withthe summaryconditions 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 ITestin g 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 of the 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 ofacid 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 ofacid Permit MD-1I30 produced [F6] Annual testing [F12] Additioual testing 

### if required [FI4] Testing per FI2 [F I 

### 8] Testrecords [F25] 

### [Testresults [F33] Report excess emissions and permit deviations [F3 7] 

### 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 of the compliancerequirements. Compliance withthe 

### summaryconditions in these tables may notbe 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 I

### Testing if

### required 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 permitconditions, 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.

PermitNo. 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] Projectreports [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] 

### Weeklyvisualobservations 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 compliancerequirements. Compliancewiththe summaryconditions 

### in thesetables may 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 of350 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 if

### requiredMonitor gas flow [F21] [F14]

Testing if

### requiredProject monitoring [F41] [F14] IWAQSRCh6, Sec 2 Permit 

### CT-I043 IWAQSRCh6, Sec 2 Permit MD-IOI71 Project emission levels [F40] 25.90 Ib/hr [F9] 

## co

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 of the 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.



### PermitNo. 3-2-125-1 Page 51

## Source 1D#:28 Source Description: Cummins Mll-P Emeraen

Particulate 30 percent opacity [F3]
2000 hours ofoperation 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 ofoperation 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 hours IRecord any test results ofoperation meter [F22] [F25]

Records ofmaintenance, hours ofoperation, 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 of the compliancerequirements. Compliancewiththe summaryconditions in these tables may notbe sufficientto meetpermitrequirements. 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 ofoperation per AP-2532 year. Maintain unit. [FlO] Testing ifrequired [F14] Maintain/operate an hours I Record any test results ofoperation meter [F22] [F25] Maintenance and hours of operation records [F31] Report annual hours ofoperation [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 ofoperation [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] 

# . I and Ch 6, Sec 2 waiver 250 hours ofoperation 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 Subpart 

### JJJJ 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 of the compliancerequirements. Compliancewiththe summaryconditions 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 53ACFM 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 ofEnviromnental 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 ofnitrogen Nou-selective catalytic reduction Oxygen Particulate matter Particulate matter less than or equal to a nominal diameter of 10 micrometers Prevention ofSignificaot 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 (includingrequirements 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 requirementprovided for in the Wyoming implementation plan approved or promulgated by EPA under title I ofthe Act that implements the 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 ofany 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 preventionunder Section 112(1')(7) of the Act and including any regulations promulgatedby 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 pursuantto Section 504(b) or Section I I4(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 ofvolatile organic compounds under ozone control requirements); 

### (j) Any standard or other requirement of the regulations promulgated to protect stratospheric 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 pollutant subjectto regulationunder 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 combustiontechniques for control ofsuch pollutant. Ifthe Administrator determines that technological or economic limitations on the application of measurementmethodologyto aparticular 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 combinationthereofto 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 equivalentresults. 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 thepermit, 

### dueto unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

### improperly designed equipment, lackofpreventative maintenance, careless orimproper 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. "Insignificantactivities" 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.
"MACTU

### or "Maximum achievable controltechnology tr

### means themaximum degree ofreduction 

### inemissions thatis 

### 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 ispromulgated, 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 airpollutant" 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. IfEPA fails to promulgate a standard by the date established pursuantto Section 112(e) ofthe Act, any pollutantfor which a subject

source wouldbe 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 ofSection 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 ofa 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 officerhavingresponsibility for the overall operations ofaprincipal 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.
"WA QSR" means the Wyoming Air 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 57Permit No. 3-2-125-1 

### AppendixA B Reserved (Modified July 21, 2014)

### Permit No. 3-2-125-1 

### Appendix C Compliance Assurance Monitoring Plan

# SIMPLOTPHOSPHATESLLC

- ROCKSPRINGS, WYOMING ComplianceAssurance Monitoring Plan ForApplicable 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., H

## 2 S04MistandNO x


## B. Applicable Regulation, Emission Limits, andMonitoring Requirements Regulation: . 40 CFR60 Subpart H . CAM Emission Limits: Foremissions ofsulfur dioxide, theunitis equipped witha CEMS. Theuseof a CEMS is satisfactory formeeting CAM monitoring requirements under WAQSR Chapter 

## 7, Section 3(c)(lv). There areno 

# add ondevices for control of NO x emissions. 

## CAM does applyfor 

## H 2

S0 4mist. Pre-CAM Requirements: Annual source testing for emissions ofsulfur dioxide. Permit termsource testing foremissions ofH 2S04 mist andNO x. Proposed CAM Monitoring: Daily "see

## Ino see" visible emissions monitoring to

. address H2S04 mistpollutant. Observations to be conducted for at leastoneminute, Presence ofopacity will trigger corrective action. Reporting ofexcursions 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 TPYforemissions ofH 2S04 mistatefficiency 

## 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: Foremissions of sulfurdioxide, tileunit 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" visibleemissions monitoring to address H2S04 

## mistpollutant. Observations to be . conducted for at least one minute. Presence ofopacity wiil

## triggercorrective action. Reporting ofexcursions done quarterly.

C. Control Technology. CaptureSystem. Bypass,PTE: Controls: HighEfficiencyMistEliminators (Candle Filters) Capture System: Closed-duct system (cannotbe by-passed) PTE beforecontrols: >

## I00 TPY for emissions ofH2S04 mist at an efficiency estimate of96-98%. PTE aftercontrols: 6.2TPY

D. Justification for ProposedMonitoring: Opacityfrom source is usually due to the presenceof sulfurtrioxide/ sulfuric acidmist. Daily visibleemissions monitoring will help ensure thattileprocess 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 forHazardous Air ' Pollutants (NESHAP) for hydrogenfluoride from Phosphate fertilizer manufacturing plants requiressubject facilities to continuously monitorapplicable scrubbing systemdifferential pressure and liquorflow. 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 

## WDEQI AQD. Differential pressure andliquor flow parameterranges are established 

## annually along withoperating permitrequired
source testing foremissions offluoride. Thebasisofthe 

## NESHAP monitoring was thatEPAbelieved the parameters ofdifferential pressure andliquorflow are adequate 

## performance indicators ofmostscrubbing systems. It 

## is proposed thatthismonitoring willsatisfy CAM foremissions ofparticulate matter.-

An 

## excursion from theranges established 

## annually during fluoride (NESFIA.P) source testing willtrigger corrective action with reporting ofexcursions done quarterly. Monitoring willbebasedupon l5-minute block
, averages andexcursion reporting willbe basedupona

## 3- hourrolling average ofthe IS-minute blocks.

C. Control Technology. Capture System. Bypass, PTE: Controls: Packed Tower Scrubber with

## Demister

. Capture System: Closed-duct system (cannot beby-passed) PTEbefore controls: >

## 100 TPYforemissions ofparticulate matterat 99% efficiency. PTEafter controls: 5.6TPY.

D. Justification forProposed Monitoring: The scrubbing system for source lOA is designed to control NH3, fluoride and particulate 

## emissions. The

## NESHAP parameter monitoring foremissions offluoride (HF) has ensured consistent performance 

## ofthis system, Therefore, it 

## stands toreason thatthe
sameparametermonitoring will consistently control emissions ofparticulate matter. Highandlowvalues forpressure drop and

## +1- 20% liquor flow range will continue tobe established annually during fluoride source testing perestablished 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: W AQSR Chapter 3, 

## SectionZ CAM Emission Limits: CAM applies for particulate matter, Pre-CAM requirements: None. Proposed CAM Monitoring: Daily"see 

## 1no see" visible emissions monitoring. Observations to beconducted 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 this is 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, Ifvisible emissions are noted, corrective action will betaken,

Revised 8/26/10 08-27-2010 320125

# 140 CFR Subpart AA and BB Startup, Shutdown and Malfunction Plans

Sources la, 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 notdirectly related to plantrates. Thefollowing 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 theyarenotplugged.

4. Complete the pmprocedure's for the scrubbers including:

• Check sprays foroperation in 

## theventuri, cyclonic and separator sections.

• Check the demisters forpluggage 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 has fallen low, checkthe fanto seeifthe fan damper position has changed orifthereis aproblem with thefanbelts.

6. Check thepositions of the various slidegates, especially thoseabovethefilter tables, tomakesuretheyhave notbeenclosed.
Startup andshutdown procedures as outlined in thephosphoric 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, thefollowing 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 40pounds, thepump should be pulledand pump suctions checked to see if they areplugged.

2. Check the ductworkcoming from therepulp sump to make sureit 

## is clearof buildup which may decrease airflow.

3. Check the water levels in the first stageandsecond stagescrubbers.

A. Thelevel in the first stage scrubber should be running at the overflow point. B. Thelevel in the secondstage shouldbe running at approximately oneinch above thebottom of the drafttube. C. Pull samples 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. Ifany slidegates aremissing,replace them.

5. Check all sprays 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 Northplant superintendent or the environmental department for assistance.
Startup and shutdownprocedures 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 whatmeasures should be taken ifamalfunction in the ammonium phosphate plantscrubbing system occurs:

1. 

## Check the level

## in the reactorto make sureit is at least 65 percent.

2. Check therecycle 

## tank level and make sureit is at least 85%. Check the level indication and climb up to the top of the tankto do avisual check. If below 85%, add waterand/or acidin orderto maintain properlevelandpH (i.e., 4 to 7 per item 4 below).

3. Check the scrubber lines with the lasertemperature gun

## to see ifanylines are obviously plugged. Unplug lines as necessary.

4. Check the pH of the tailgasscrubber. ThepH shouldbe in therange 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 wateradded. This condition couldbe caused by the tailgas scrubber waternothaving beendumped 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 thetailgas scrubberon an acidwash. Ifproblems persist,shut down to check demister pads. Cleanand repairdemister pads as needed. This condition is likelycausedby solids accumulation in saddle packingand/ordemister pads. If the deltaP is less than4, shut downthe plant andreplace packingondemister 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 thereactor andrecheckboth the soniclevel indication anddo a visuallevel check. If a 65%plus level is verified, inspectthe feedtubes to determine if theyhave beendamaged. Repairthesetubes as needed.
Note: As part ofnormal operations of this plant, it is periodically necessary to do a "reversal" of thegranulator (thegranulator is the sectionof the plantwherethe actual fertilizer pellet isbuilt). Areversal is whenthe granulator is stopped androtated backin the opposite direction fora shortperiodof timeto allowexcessive buildup andlumps of fertilizer to beremoved and/orbrokenup. Thisprocess doespromote excessive particulateloading of the scrubbing and opacitydoesoftenresult. A reversal normally takes approximately 15 minutes andthe resulting opacitynormally doesnot persist for more than 30 minutes. This opacity is estimated at less than20%.
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 ofcompliance with W AQSR chapter 2, section 9 (a)(ii) regional ambient airfluoride standards, as administered, during the summers of 1994, 1995, and 1996. As aresult ofthismatter, a compliance order andNOV was issuedto the company onNovember 15, 1995 (Docket #2717-95). In summary, this NOV required SFP to evaluate the sources andcauses of theincreased fluoride emissions during these years and develop a plan orcorrective action. After much investigation and research, the companyput 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 ofapproximately $1.3 million.

PSA's are anecessary partofphosphate fertilizer production. The Environmental Protection Agency (EPA) states in 40 CFR 61.202: Eachperson who generatesphosphogypsum shallplace all phosphogypsum instacks

... 

# Prior EPA approval is required before using phosphogypsum for purposes other thanthose identified in SubpartR of40 CFR 61.

In the summer of2007, theearth work and synthetic lining system for a 125 acre expansion ofthePSA was completed. Normal operations include changes inthe footprint ofthe stackto adhere to height/stability limits. To address these issues it isnecessary 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,updatedplan win

# '~li;lobeincluded in our upcoming operating permitapplicati6n:' " , "., " " '""

.. { :..:.'. ,: .; . ':'<', :'. ':"',-, ., /

.. .,,: ,:' ", ,- 

# It is the.goal andintent 

# ofSiIpplottorriaintain.coP'lpIiiLnce,"'ith the applicable W AQSRchapter'2: section'9shinaards. ' }:[owbver,Sifuplot

# haS 

# ai&iillber of legitimate concerns regardinii'iliestiirige:iJ,cYal1d applicability ofthese standards and it 

# is the company's desireto seekfuture changes to those standards, Simplot is happyto 

# reportthat afterover22 years**o,f.?pe~~t,~?n,** 

# ,no aqversEjetlyironrp.ental impacts have OCCUlTed as a resultoffluoride erilissions'fromthe ReickSprings**Fertil!zerqo1?plex~> ~.,**  ... ' .'. . 'j.'.'. "". ' . ':.

. .. :,. 

# INTROj):ficiJON',

" i' ,', : ".;'



### . " 

# ,," ".'



# This'docJimentJilllist

# tli~**fl~oride** control

# techni~lll:ls**t4~twere** used to.some, '**ext~ntattheRdck** Springs facility from 

# 1997

-2007ai1d allowing thecompany to 

# a2hieveconlp1iotnce. With

# W,AQ~R**Chapt~r** 2,.$ection9 

# (aXU) regional ambient air standl3IM;WitIiafewnoted'exGeptions in JUlyoiZQQ7 andAprilof2008. Some' techniques thatare.no.Ionger usedhav:e beenelimillated from'this updatedversion.

. . ' ,."
.. ," ,"
. 

### . 

## .. ' '. .'.:'

. , 

### ...... " ': '



### . , .,' ".

# Pleas~**~()te~l:1a~this** document is aievisionto,the.prigfnal

# v~sion submitted by SF' phosphates backilii 998. 

# .Simplotbecame**the~ol~oW!Ler** 

# of'the facilityin, " Novembe« of2064. .Simplot

# has spent**considerabletilne,~ffort** 

# andrnoneyin achieving this initial success. Webelieve thatthesetechniques will continue to be successful in future Y<1ars."

.Simplothas discussed thesetechniques with the WDEQI 

# AQ:D onnumerous occasions ,aD:dbelieve the AQD 

# has a reasonably good understanding of howthey are implemented.andofsome ofthepotentialpitfalls that are Inherentdne.to the dynamic nature ofthe

# PSA. 'The PSAis"anjritegral .,- part ofthe overallfacility waterbalance that is sometimes difficultto 

# maintain.

,": 

### ....... '.- "." .. :' '"', '

.... ,'

.. '**~',** '. ',

.. ' 

## '. ,,' " '. 

# COREFLUOR/DE CONTROL TECHNIQUES,

'. RimDitch (cell) Building Technique

- Thistechnique allows wider phosphogypsum storage cellsto be constructed so thatmoredike building gypsum material canbe stored in eachcell. Thislargercell building has ' become the standard operating procedure. .Eaoh individual cell doesnot have to be disturbed as oftenwhichfacilitates lowerfluoride emissions in itself because new surfaces are created withless frequency; 

# 'I:i:t addition, when these widercells are disturbed for dikebuilding, a larger lift canbe built so thatthe entire stackgoes up quicker. This mightallowconstruction to be limited or ceased during certain critical summer periods inthe 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. This water pondinganduniform wetting is achieved through the use ofweirs and by alternately discharging phosphogypsum slurry from various corners ofthe stacks. Thelargeincrease in temperature onthe surface ofthe PSAduring the

summermonths (measured in excess of 120degrees F) equates to increases in evaporation rates as well. This evaporation means that PSAsurfaces will dry outmore rapidly which, in turn, means that fluoride emissions willincrease as this drying process occurs. Bykeeping portions the PSAwetted, surface temperatures arelower, 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 gothrough a drying process, butnotto the extent that wateris ponded because more HF is driven off the free water
areas as surface temperature increases.

• LimitDikeBuilding, Material Hauling and Water SurfaceAreaDuring Critical

,Periods - Thistechnique employs an accelerated building strategy in the spring

and fall time periods whentemperatures, evaporation rates, andfluoride 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 theprocess. Ifenough 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. If

# more water can beponded and

.. " evaporated during the cooler periods, then a better waterbalance might be achieved sopondedwater canbe minimized duringthe summer. This technique is limited 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 isparamount andSimplot will conduct all operations with safety andlongtermbusiness liability in the forefront of ourthinking, A failure ofone of the stacked areas has happened withinourindustry andwould be devastating to ourbusiness 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 tokeep up with thecurrent production ofphosphogypsum.

Revised August12,2008 3

# • Surfa'ceAf2plii:JationofSlCkedLime- Slakedlime 

## is appliedtoaccessible 

## surfaces ofthePSA with aspeclallyequipped

## truck. The Iimematerial neutralizes**fltiOl:i~",** 

## onthe ·sU:tfa:ce ofthe phosphogypsiJiri'arid alsoprovides a reflectivecoating which decreases the temperature of'the smfaceithas been appliedto, Thistebhnique is timedfot nlaximumbertefit. becatlse.'all ofthe active areas of.ihestabkarenew every fourto sixweeks

# and 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 stageof the buildingprocess 

## the particularareais in:
.,.Anyresidualliine 

## coveredover shouldstuihave somepositive effect, but appropriate'tiniingofthe surface apfllicatJ.o:i1shouldproduce 

## the maximumbenefit,
., . .

, ,,', .,:,.' (. . . ;..... ' 

### .. "'

.. :. ;', .,,"

,



# •

.SoilCar/ptng0nd VegetationAp'plication -Simplot hascoveredapJlroximately 40 

## acres of non-active

# or permanent areas ofthe'PSA Withsoilarid reclaimed this area with vegetation, 

## Thistechniqueeffectively seals these areas ofthe phosphogypsum dil<6sfromeniitting fluoride and whl provide' a templatefor '

,postclosurereclamatiori, WebelieveWe have achievedsome success with this

techniqueand approximately**40~50** 

## moreacres will be readyfor

# soil capand vegetationwithin

# the nexttwo years

. . ... 

# FLUORIDEREMOVALSTRATEGY

:"


### .. , .; .



# • Fluorosili'Cid

# Acid(ESA) RecoVliry"':"

## Due to the complexchemistrYWithin the '

. ,phospnogypsWnstorageareaand th{)unpreaiCfitblemeteorqlqglcalcondrtions" aroundtheRbcK Springssite, Simplothas shiftedmuchofourfocusregarding 

## fluoride toremovalofthe fluoride priorto bemgplacedifLt6the 

# pElA.·

. . "'.


### . ".'. .',.' 

# '...

. '. 

## .. ..' 

### ',. ',,'.



### . . .'



## .Simplotinstalled afluorosilicic acidrecovery pro'cess

# ~d beganproduction of thismaterial in February of2006: This process eliminatesapproximately 4,500tpy 

## of'fhioride (24,000 tonso:f24%FSA) from everenteringthe phcsphogypsum'storage areabytaking a fluol:idewaste streamfr6U:i the MustangD-Bvaporitor that hadbeengoingto the :EiSA

# and processingthat

. " " ,. " 

## streaminto a useablewaterfluoridation product.

.. , .

, 

### . - -. . ...'

.. 

## Simplothas plansto recoveradditional FSA as part

# Ofa 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 this idea.


# PROGRESS REPORTING

The ambient fluoride data is included 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 eachcritical timeframe (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 fordetermining compliance with theWyoming fluoride in 

## forage standards at the existing SF Phosphates Fertilizer Plantlocated in Section 15, !l8N, Rl04W, approximately 4.5 miles east southeast ofRock 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 beenreceived. 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 orplace on or atwhich .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 ofthis 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 setforth 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 mi 2 

## core area, whichexcludes.fenced.aites 115,116,1119,1120, #24,1125; 

## #26 & 

## #27, and also excludes expanded sites

## 1140 through 

## 1147 located in the 30nifiinpad area, This Raw. Monitored Data Average concentration willbe 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 

# W AQS&R 30 day 'forage 

## iil' fluoride standardof 80 ppm and the Rock Springs fertilizer facility will. be deemed:to have recorded an exceedarice ofthat 30 day fluoride in forage standard.

. c) . SF Phosphates will calculate II rolling two-month 'average-fromvthe monthly "compliance averages" described in step,b) ofthis 

## 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 Of

## 60ppm.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, This

# Raw MonitoredData

Average concentratiorrwill 

## becompared (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 thantheWAQS&Rlirlnria!forage influorideetandard of 30

# ppm alidthe Rock Springs fertilizer facility will be deemed to'have recorded nnexceedance of that annual fluoride .Inforage standard,

. . . . ....

. ;' \

.. . . ':.' .' ': 1:' ," ,.: ;'" : . . , . , ,','. . . " ".' ",

.. , ", ".



## ; It mustbe 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 inorder'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 ofinitial start- up, andSection 21(h) requires thatconstruction

..

## Mr. James M. Williams February 7, 1995 

## Page 3

or modification must commence within 24 months ofdate ofpermit 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, /''/ ;' , 

# ckwLa,**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 

# c 30 

## 50 61 108 

## 31 52 62 110 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



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