REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 28 of 30 COMPARISON OF EXISTING EMISSIONS LIMITS TO BART DETERMINTIONS Particulate-Only Emissions Units with Baghouses

EU No. EP No. Emissions Unit Description Emissions Standard Existing BART 001 Phosphate rock grinder 5% opacity 5% opacity

004 X-Train Dical Process

02 Dedust bin 5% opacity 5% opacity 03 Shipping area 5% opacity 5% opacity 04 Limestone silo 5% opacity 5% opacity 05 Reclaim bin 5% opacity 5% opacity 06 Material handling 5% opacity 5% opacity

042 DFP Feed Prep EP-01 Rock bin 5% opacity 5% opacity EP-02 Miscellaneous 5% opacity 5% opacity EP-03 Lime silo 5% opacity 5% opacity EP-04 Lime bin 5% opacity 5% opacity EP-06 Soda ash silo 5% opacity 5% opacity EP-07 Soda ash bin 5% opacity 5% opacity

062 DFP Product Silos EP-14 Product Sizing and Crushing Silos 5% opacity 5% opacity EP-16 Silos A - C and shipping operations 5% opacity 5% opacity
The above BART determinations also include the following baghouse design specification: Bags/filters in each baghouse control system shall be selected based on a design outlet specification of 0.01 grains per actual cubic feet of exhaust. Particulate-Only Emissions Units Controlled by Wet Scrubbers

EU No. Emissions Unit Description Emissions Standard Existing BART 010 No. 1 Storage/Shipping Building 36.17 lb/hour 4.7 lb/hour 015 MAP/DAP Shipping Facility 40.41 lb/hour 1.46 lb/hour 044 ‘A’ and ‘B’ DFP Coolers 25.04 lb/hour 17.5 lb/hour 065 Swift Creek Mine Silos 46.4 lb/hour 6.27 lb/hourREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 29 of 30 Emissions Units with Combustion – Particulate Matter

EU No. EP No. Emissions Unit Description Emissions Standards Existing BART 003 ‘A’ DFP Plant with PM and SO 2 controlled by wet scrubbing 14.05 lb/hour 12.8 lb/hour

004 X-Train Dical Process EP-01 X-Train Rotary Dryer with PM controlled by wet scrubbing 46.11 lb/hour 18 lb/hour (all modes)

008 Y-Train No. 1 DAP Plant with PM controlled by wet scrubbing 33.33 lb/hour 9.2 lb/hour (all modes) Y-Train No. 1 MAP Plant with PM controlled by wet scrubbing 45.15 lb/hour 021 ‘C’ Sulfuric Acid Plant with double absorption process 10% opacity 10% opacity 022 ‘D’ Sulfuric Acid Plant with double absorption process 10% opacity 10% opacity 032 Z-Train No. 2 DAP/MAP Plant EP-01 Main part of DAP process with PM controlled by wet scrubbing 47.37 lb/hour 9.2 lb/hour 038 ‘B’ DFP Plant with PM and SO 2 controlled by wet scrubbing 14.05 lb/hour 12.8 lb/hour

042 DFP Feed Prep EP-05 DFP Feed Prep Dryer with PM controlled by wet scrubber 31.99 lb/hour 4.5 lb/hour 064 Swift Creek Mine (SCM) Rock Dryer with PM controlled by wet scrubber 46.4 lb/hour 17.3 lb/hour

Emissions Units with Combustion – Sulfur Dioxide

EU No. EP No. Emissions Unit Description Emissions Standards Existing BART 003 ‘A’ DFP Plant with PM and SO 2 controlled by wet scrubbing 8.0 lb/hour 2.0 lb/hour, a

004 X-Train Dical Process EP-01 X-Train Rotary Dryer with PM controlled by wet scrubbing 11.1 lb/hour b

008 Y-Train No. 1 DAP Plant with PM controlled by wet scrubbing 11.1 lb/hour b Y-Train No. 1 MAP Plant with PM controlled by wet scrubbing 11.1 lb/hour b 021 ‘C’ Sulfuric Acid Plant with double absorption process 4 lb/ton AP 3.5 lb/ton AP, c 022 ‘D’ Sulfuric Acid Plant with double absorption process 4 lb/ton AP 3.5 lb/ton AP, c 032 Z-Train No. 2 DAP/MAP Plant EP-01 Main part of DAP process with PM controlled by wet scrubbing 11.8 lb/hour d 038 ‘B’ DFP Plant with PM and SO 2 controlled by wet scrubbing 8.0 lb/hour 2.0 lb/hour, a

042 DFP Feed Prep EP-05 DFP Feed Prep Dryer with PM controlled by wet scrubber 4.9 lb/hour b 064 Swift Creek Mine (SCM) Rock Dryer with PM controlled by wet scrubber 38.1 lb/hour e

a. In addition to the SO 2 emissions standard, sulfur dioxide emissions from these units shall be limited by firing natural gas as the only fuel. b. To control sulfur dioxide emissions, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.5% by weight may be fired as a backupREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 30 of 30 fuel.

c. Sulfur dioxide emissions from the “C” and “D” Sulfuric Acid Plants (EU-021 and EU-022) shall not exceed 3.5 lb/ton of 100% sulfuric acid produced (AP) based on a 24-hour rolling CEMS average. No stack testing is required. d. To control sulfur dioxide emissions, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil or on-specification used oil with a maximum sulfur content of 1.0% by weight may be fired as a backup fuel.

e. To control sulfur dioxide emissions, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.3% by weight or on-specification used oil with a maximum sulfur content of 1.0% by weight may be fired as backup fuel. Emissions Units with Combustion – Nitrogen Oxides There are no existing NO X emissions standards for the BART-eligible emissions units. The BART determinations are as follows. Nitrogen oxides emissions (expressed as NO 2 ) from the ‘C’ and ‘D’ Sulfuric Acid Plants (EU-021 and EU022) shall not exceed 0.14 lb/ton of 100% sulfuric acid produced as determined by EPA Method 7E upon request by the Department. Nitrogen oxides emissions from the remaining emissions units shall be controlled by the inherent combustion design of the existing units and the firing of natural gas as the primary fuel. [Rule 62-4.070(3), F.A.C.] Molten Sulfur System for ‘C’ and ‘D’ Sulfuric Acid Plants Rule 62-296.411, F.A.C. established work practice standards for “Molten Sulfur Facilities” to control sulfur and particulate emissions. The BART determination adopts these work practice standards, which includes an opacity limit of 20%.

6. MODELING ANALYSIS WITH BART CONTROLS As summarized in Section 2, the applicant conducted a BART modeling analysis based on current actual emissions rates from the BART-eligible emissions units. After consideration of the actual emissions from the BART-eligible units with existing controls in place, the existing equipment is considered a top control option. Therefore, it was not necessary to conduct an air quality modeling analysis for the purpose of determining the resulting visibility impacts.

7. PRELIMINARY DETERMINATION The Department makes a preliminary determination that the proposed project will comply with all applicable state and federal air pollution regulations regarding BART as conditioned by the draft permit. This determination is based on a technical review of the complete application, all available information, reasonable assurances provided by the applicant, and the conditions specified in the draft permit. Syed Arif is the project engineer responsible for reviewing the application and drafting the permit. Cleve Holladay is the project meteorologist responsible for reviewing the modeling analysis for visibility.PERMITTEE

White Springs Agricultural Chemicals, Inc. P.O. Box 300 White Springs, Florida 32096 Authorized Representative: W. K. Thornton, General Manager Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Expiration Date: June 30, 2014

PLANT AND LOCATION White Springs Agricultural Chemicals, Inc. operates the Suwannee River/Swift Creek complex, which processes phosphate rock into several products. The phosphate complex is classified by Standard Industrial Classification (SIC) Code No. 2874. The existing facility is located in Hamilton County at 15843 SE 78th Street in White Springs, Florida. This site is located about 25 kilometers from the Okefenokee National Wilderness Area, which is a PSD Class I Area. The UTM coordinates are Zone 17; 328.3 km E; 3368.8 km N.

STATEMENT OF BASIS This air pollution construction permit is issued under the provisions of Chapter 403 of the Florida Statutes (F.S.), and Chapters 62-4, 62-204, 62-210, 62-212, 62-296 and 62-297 of the Florida Administrative Code (F.A.C.). Specifically, this project is subject to Rule 62-296.340, F.A.C., which requires a determination of the Best Available Retrofit Technology (BART) for each BART-eligible source as defined in 40 Code of Federal Regulations (CFR) 51.301. The state rule implements the federal provisions of Appendix Y in 40 CFR Part 51, “Guidelines for BART Determinations Under the Regional Haze Rule”. In accordance with Appendix Y in 40 CFR 51, the affected visibility-impairing pollutants include the following: nitrogen oxides (NO X ), particulate matter (PM), and sulfur dioxide (SO 2 ). Pursuant to Rule 62-296.340, F.A.C., the permittee shall install or modify the air pollution control equipment and/or implement the air pollution control measures that are specified by this permit as the Best Available Retrofit Technology (BART).

EFFECTIVE DATE Unless otherwise specified by this permit, the BART-eligible sources shall demonstrate compliance with the conditions of this permit no later than December 31, 2013. [Rule 62-296.340(3)(b)2, F.A.C.] Executed in Tallahassee, Florida

___________________________________ _______________ Joseph Kahn, Director (Date) Division of Air Resource ManagementSECTION 1. GENERAL INFORMATION

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 2 of 13 FACILITY DESCRIPTION White Springs Agricultural Chemicals, Inc. operates an existing phosphate complex, which processes phosphate rock to produce several products at the Suwannee River/Swift Creek Complex (two plants). The facility consists of one rock grinder, two phosphoric acid plants, two defluorinated phosphate (DFP) plants, one dical process, two diammonium phosphate (DAP) plants, one monoammonium (MAP)/DAP storage building, one MAP/DAP screen/shipping building, four sulfuric acid plants (SAP), two phosphoric acid filters, four superphosphoric acid plants, one green superphosphoric acid plant, the Swift Creek Mine rock dryer, and one acid clarification plant. The facility also has storage silos associated with the Swift Creek Mine and the DFP plant. Sulfuric acid is produced on-site by burning elemental sulfur, converting the resulting sulfur dioxide to sulfur trioxide, and absorbing it into a recirculating sulfuric acid solution. Phosphoric acid is made by acidulation of phosphate rock with sulfuric acid. Waste gypsum is produced and stacked. The phosphoric acid is reacted with ammonia to make MAP and DAP. The phosphoric acid is reacted with limestone and other raw materials to make animal feed ingredients.
FACILITY REGULATORY CLASSIFICATIONS

• The facility is a major source of hazardous air pollutants (HAP).

• The facility does not operate units subject to the acid rain provisions of the Clean Air Act.

• The facility is a Title V major source of air pollution in accordance with Chapter 213, F.A.C.

• The facility is a major stationary source pursuant to Rule 62-212.400, F.A.C. for the Prevention of Significant Deterioration (PSD) of Air Quality.

• The facility operates BART-eligible units subject to Rule 62-296.340 (BART), F.A.C.
BART-ELIGIBLE EMISSIONS UNITS This permitting action affects the following BART-eligible emissions units (EU) at the plant.

EU No. Emission Unit Description 001 # 2 Phosphate Rock Grinder 003 ‘A’ DFP Plant 004 X-Train (Dical Process) 008 ‘Y’ Train - #1 DAP Plant 010 #1 MAP/DAP - Storage Building 015 MAP/DAP Shipping and Screening Facility 021 ‘C’ SAP 022 ‘D’ SAP 032 ‘Z’ Train - #2 DAP Plant 038 ‘B’ DFP Plant 042 DFP Feed Prep 044 ‘A’ and ‘B’ DFP Coolers 054 Molten Sulfur System 062 DFP Silos 064 Swift Creek Mine Rock Dryer 065 Swift Creek Mine SilosSECTION 2. ADMINISTRATIVE REQUIREMENTS

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 3 of 13 1. Permitting Authority : The Permitting Authority for this project is the Bureau of Air Regulation in the Division of Air Resource Management of the Florida Department of Environmental Protection. The mailing address for the Bureau of Air Regulation is 2600 Blair Stone Road, MS #5505, Tallahassee, Florida 32399- 2400 (phone number 850/488-0114). 2. Compliance Authority : All documents related to compliance activities such as reports, tests, and notifications shall be submitted to the Department’s Northeast District Office, 7825 Baymeadows Way, Suite B200, Jacksonville, Florida 32256-7577. 3. Appendices : The following Appendices are attached as an enforceable part of this permit: Appendix A. Citation Formats; Appendix B. General Conditions; Appendix C. Standard Testing Requirements; and Appendix D. Best Operational Startup Practices for Sulfuric Acid Plants. 4. Applicable Regulations, Forms and Application Procedures : Unless otherwise specified in this permit, the construction and operation of the subject emissions units shall be in accordance with the capacities and specifications stated in the application. The facility is subject to the applicable provisions of: Chapter 403, F.S.; Chapters 62-4, 62-204, 62-210, 62-212, 62-213, 62-296, and 62-297, F.A.C.; and the applicable parts and subparts of Title 40, Code of Federal Regulations (CFR)

. Issuance of this permit does not relieve the permittee from compliance with any applicable federal, state, or local permitting or regulations. 5. Title V Permit : This permit authorizes specific modifications and/or new construction on the affected emissions units as well as initial operation to determine compliance with conditions of this permit. A Title V operation permit is required for regular operation of the permitted emissions unit. The permittee shall apply for a revised Title V permit on or before December 31, 2013 . To apply for a Title V permit, the applicant shall submit the appropriate application form, compliance test results, and such additional information as the Department may by law require. The application shall be submitted to the appropriate Permitting Authority with copies to the Compliance Authority. [Rules 62-4.030, 62-4.050, 62-4.220, and Chapter 62-213, F.A.C.]
6. Records Retention : All measurements, records, and other data required by this permit shall be documented in a permanent, legible format and retained for at least 5 years following the date on which such measurements, records, or data are recorded. Records shall be made available to the Department upon request. [Rule 62- 213.440(1)(b)2, F.A.C.]
7. Annual Operating Report : The permittee shall submit an annual report that summarizes the actual operating rates and emissions from this facility. Annual operating reports shall be submitted to the Compliance Authority by April 1 st

of each year. [Rule 62-210.370(3), F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Particulate-Only Emissions Units Controlled by Baghouses

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 4 of 13 This subsection addresses the following affected emissions units (EU) and emissions points (EP). EU No. EP No. Emissions Unit Description 001 Phosphate rock grinder controlled by a baghouse
004 X-Train Dical Process 02 Dedust bin controlled by a baghouse 03 Shipping area controlled by a baghouse 04 Limestone silo controlled by a baghouse 05 Reclaim bin controlled by a baghouse 06 Material handling controlled by a baghouse 042 DFP Feed Prep EP-01 Rock bin controlled by a baghouse EP-02 Miscellaneous activity controlled by a baghouse EP-03 Lime silo controlled by a baghouse EP-04 Lime bin controlled by a baghouse EP-06 Soda ash Silo controlled by a baghouse EP-07 Soda ash Bin controlled by a baghouse 062 DFP Product Silos EP-14 Product Sizing and Crushing Silos EP-16 Silo A, silo B, silo C and shipping operations controlled by a baghouse
Pursuant to Rule 62-296.340 (BART), F.A.C., the following standards represent the Best Available Retrofit Technology. These standards apply to each BART-eligible unit and are in addition, and supplement, all other applicable standards.
CONTROL EQUIPMENT AND METHODS 1. Baghouses : The baghouse control systems shall be operated and maintained to effectively control particulate matter from each of the emissions points identified above for the regulated emissions units. [Rules 62- 4.070(3) and 62-296.340 (BART), F.A.C.] 2. Circumvention : The permittee shall not circumvent any air pollution control device, or allow the emission of air pollutants without the applicable air pollution control device operating properly. [Rule 62-210.650, F.A.C.]

EMISSIONS LIMITING AND PERFORMANCE STANDARDS 3. Opacity Standard : Visible emissions from each baghouse exhaust shall not exceed 5% opacity as determined by EPA Method 9. [Rule 62-296.340 (BART), F.A.C.; and 40 CFR 60, Appendix A, Method 9] 4. Baghouse Design Specification : Bags/filters in each baghouse control system shall be selected based on a design outlet specification of 0.01 grains per actual cubic feet of exhaust. Compliance shall be demonstrated by maintaining the appropriate records. No stack testing is required. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Particulate-Only Emissions Units Controlled by Baghouses

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 5 of 13 EMISSIONS PERFORMANCE TESTING 5. Compliance Tests : During each federal fiscal year (October 1 st to September 30 th ), the permittee shall conduct visible emissions tests on each baghouse exhaust in accordance with EPA Method 9 to demonstrate compliance with the opacity standard. This method is described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. Initial compliance tests shall be conducted during federal fiscal year 2012/2013 and a test report demonstrating compliance shall be submitted before October 1, 2013. [Rules 62-204.800, 62-296.340(3)(b)2 and 62-297.310(7)(a)4, F.A.C.; and 40 CFR 60, Appendix A, Method 9] 6. Test Requirements : The permittee shall comply with the applicable “Common Testing Requirements” specified in Appendix C of this permit, which include test notifications, sampling facilities, test procedures, test frequencies, test records and test reports. [Rule 62-297.310(7)(a)9, F.A.C.]

RECORDS
7. Baghouse Records : The permittee shall maintain records on site of the vendor data sheets that demonstrate compliance with the baghouse design outlet specification for the bags/filters. To demonstrate initial compliance, the permittee shall provide copies of such records with the corresponding visible emissions test report that demonstrates initial compliance with the opacity standard. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS B. Particulate-Only Emissions Units Controlled by Wet Scrubbers

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 6 of 13 This subsection addresses the following affected emissions units. EU No. Emissions Unit Description 010 No. 1 Storage/Shipping Building controlled by wet scrubber 015 MAP/DAP Shipping Facility controlled by cyclone and wet scrubber 044 ‘A’ and ‘B’ DFP Coolers controlled by cyclonic wet scrubber 065 Swift Creek Mine Silos and Conveyor controlled by wet scrubber
Pursuant to Rule 62-296.340 (BART), F.A.C., the following standards represent the Best Available Retrofit Technology. These standards apply to each BART-eligible unit and are in addition, and supplement, all other applicable standards.
CONTROL EQUIPMENT AND METHODS 1. Wet Scrubbers : The wet scrubber controls shall be operated and maintained to effectively control particulate matter from each of the emissions points identified above for the regulated emissions units. [Rules 62- 4.070(3) and 62-296.340 (BART), F.A.C.] 2. Circumvention : The permittee shall not circumvent any air pollution control device, or allow the emission of air pollutants without the applicable air pollution control device operating properly. [Rule 62-210.650, F.A.C.]

EMISSIONS LIMITING AND PERFORMANCE STANDARDS 3. PM Standards : Particulate matter emissions shall not exceed the following emissions standards as determined by EPA Method 5. EU No. Emissions Unit Description BART Standard 010 No. 1 Storage/Shipping Building 4.7 lb/hour 015 MAP/DAP Shipping Facility 1.46 lb/hour 044 ‘A’ and ‘B’ DFP Coolers 17.5 lb/hour 065 Swift Creek Mine Silos 6.27 lb/hour [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]

EMISSIONS COMPLIANCE TESTING 4. Compliance Tests : During each federal fiscal year (October 1 st to September 30 th ), the permittee shall conduct tests on each wet scrubber exhaust in accordance with EPA Method 5 to demonstrate compliance with the PM standard. This method is described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. Initial compliance tests shall be conducted during federal fiscal year 2012/2013 and a test report demonstrating compliance shall be submitted before October 1, 2013. {Permitting Note: For the PM BART standard, it may be necessary to develop new excursion levels for the scrubber parameters if subject to a Compliance Assurance Monitoring (CAM) plan. This may require additional compliance testing.} [Rules 62-204.800, 62-296.340(3)(b)2, and 62-297.310(7)(a)4, F.A.C.; and 40 CFR 60, Appendix A] 5. Test Requirements : The permittee shall comply with the applicable “Common Testing Requirements”SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS B. Particulate-Only Emissions Units Controlled by Wet Scrubbers

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 7 of 13 requirements specified in Appendix C of this permit, which include test notifications, test procedures, sampling facilities, test frequencies, test records and test reports. Parametric data recorded for the wet scrubber during each test shall be provided with the required test report. [Rule 62-297.310(7)(a)9, F.A.C.]

MONITORING
6. Wet Scrubber Parameters : For each wet scrubber, the permittee shall install, operate and maintain devices to continuously monitor the scrubber water flow rate, the pressure drop across the scrubber and the fan amperage. Such devices shall be calibrated, fully functional and in operation before conducting the initial compliance tests.

a. For each emissions unit subject to a CAM plan, the scrubber parameters shall be continuously monitored and recorded. For each operating hour, the 1-hour block average shall be computed from at least four data points evenly spaced over each operating hour. This data shall be used to develop new excursion levels for the scrubber parameters in the CAM plan. b. For each emissions unit that is not subject to a CAM plan, the scrubber parameters shall be continuously monitored and manually recorded at least once during each eight-hour block of operation. Alternatively, the parametric data may be continuously recorded. During each required compliance test, such data shall be recorded at 15-minute intervals. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]

RECORDS
7. Wet Scrubber Records : The permittee shall maintain records on site of the scrubber water flow rate and the pressure drop across the scrubber. In addition, the following vendor design information shall be maintained on site for each wet scrubber: exhaust flow rate; scrubber water flow rate, scrubber pressure drop, dust inlet loading, dust outlet loading and control efficiency. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS C. Emissions Units with Combustion

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 8 of 13 This subsection addresses the following affected emissions units (EU).

EU No. Emission Unit Description 003 ‘A’ DFP Plant 004 X-Train (Dical Process) 008 ‘Y’ Train - #1 DAP Plant 021 ‘C’ SAP 022 ‘D’ SAP 032 ‘Z’ Train - #2 DAP Plant 038 ‘B’ DFP Plant 042 DFP Feed Prep 064 Swift Creek Mine Rock Dryer Pursuant to Rule 62-296.340 (BART), F.A.C., the following standards represent the Best Available Retrofit Technology. These standards apply to each BART-eligible unit and are in addition, and supplement, all other applicable standards.
CONTROL EQUIPMENT AND METHODS 1. Wet Scrubbers : The wet scrubber controls shall be operated and maintained to effectively control particulate matter from each of the emissions points identified above for the regulated emissions units. The wet scrubber controls on the ‘A’ and ‘B’’ DFP Plants (EU-003 and EU-038) shall also be operated and maintained to effectively control sulfur dioxide. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.] 2. Circumvention : The permittee shall not circumvent any air pollution control device, or allow the emission of air pollutants without the applicable air pollution control device operating properly. [Rule 62-210.650, F.A.C.] 3. Best Operational Startup Practices for Sulfuric Acid Plants (EU-021 and EU-022) : Sulfuric acid plants are authorized for excess emissions from startup for a period of three consecutive hours provided best operational practices to minimize emissions are adhered to in accordance with the agreement titled “Best Operational Startup Practices for Sulfuric Acid Plants” attached to this permit as Appendix D. [Rule 62- 210.700, F.A.C., 40 CFR 60.7] 4. General Best Operational Practices : Best operational practices to minimize leaks of sulfur dioxide and sulfur trioxide, or other fugitive process emissions shall be adhered to and shall include regular inspections and prompt repair or correction of any leaks or other fugitive emissions. [Rule 62-296.320, F.A.C.]

EMISSIONS LIMITING AND PERFORMANCE STANDARDS 5. PM and SO 2 Standards : Particulate matter and sulfur dioxide emissions shall not exceed the following emissions standards as determined by EPA Methods 5 and 6/6C, respectively.

EU No. EP No. Emissions Unit Description BART Standards PM SO 2 003 ‘A’ DFP Plant with PM and SO 2 controlled by wet scrubbing 12.8 lb/hour 2.0 lb/hour, a

004 X-Train Dical Process EP-01 X-Train Rotary Dryer with PM controlled by wet scrubbing 18 lb/hour (all modes) bSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS C. Emissions Units with Combustion

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 9 of 13 EU No. EP No. Emissions Unit Description BART Standards PM SO 2

008 Y-Train No. 1 DAP Plant with PM controlled by wet scrubbing 9.2 lb/hour (all modes) b Y-Train No. 1 MAP Plant with PM controlled by wet scrubbing
021 ‘C’ Sulfuric Acid Plant with double absorption process --- 3.5 lb/ton AP, c 335.4 lb/hour 022 ‘D’ Sulfuric Acid Plant with double absorption process --- 3.5 lb/ton AP, c 335.4 lb/hour 032 Z-Train No. 2 DAP/MAP Plant EP-01 Main part of DAP process with PM controlled by wet scrubbing 9.2 lb/hour d 038 ‘B’ DFP Plant with PM and SO 2 controlled by wet scrubbing 12.8 lb/hour 2.0 lb/hour, a

042 DFP Feed Prep EP-05 DFP Feed Prep Dryer with PM controlled by wet scrubber 4.5 lb/hour b 064 Swift Creek Mine (SCM) Rock Dryer with PM controlled by wet scrubber 17.3 lb/hour e

a. In addition to the SO 2 emissions standard, sulfur dioxide emissions from these units shall be limited by firing natural gas as the only fuel. b. To control sulfur dioxide emissions, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.5% by weight may be fired as a backup fuel.

c. Sulfur dioxide emissions from the “C” and “D” Sulfuric Acid Plants (EU-021 and EU-022) shall not exceed 3.5 lb/ton of 100% sulfuric acid produced (AP) based on a 24-hour rolling CEMS average. No stack testing is required. d. To control sulfur dioxide emissions, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil or on-specification used oil with a maximum sulfur content of 1.0% by weight may be fired as a backup fuel.

e. To control sulfur dioxide emissions, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.3% by weight or on-specification used oil with maximum sulfur content of 1.0% by weight may fired as backup fuel. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]
6. Opacity Standards : Visible emissions from the ‘C’ and ‘D’ Sulfuric Acid Plants (EU-021 and EU-022) shall not exceed 10% opacity as determined by EPA Method 9. Visible Emissions from the Z-Train (EU-032) dryer and cooler shall not exceed 20% opacity. Opacity observations shall be made at the point of greatest opacity in that portion of the plume where condensed water vapor is not present. [Rule 62-296.340 (BART), F.A.C.; and 40 CFR 60.83(a)2 and 40 CFR 60, Appendix A, Method 9]
7. NOx Emissions Standards : Nitrogen oxides emissions (expressed as NO 2 ) from the ‘C’ and ‘D’ Sulfuric Acid Plants (EU-021 and EU-022) shall not exceed 0.14 lb/ton of 100% sulfuric acid produced as determined by EPA Method 7E upon request by the Department. Nitrogen oxides emissions from the remaining emissions units shall be controlled by the inherent combustion design of the existing units and the firing of natural gas as the primary fuel. [Rule 62-4.070(3), F.A.C.]

EMISSIONS COMPLIANCE TESTINGSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS C. Emissions Units with Combustion

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 10 of 13 8. Compliance Tests : During each federal fiscal year (October 1 st to September 30 th ), the permittee shall conduct the following compliance tests.

a. The permittee shall conduct visible emissions tests on the ‘C’ and ‘D’ Sulfuric Acid Plants (EU-021 and EU-022) in accordance with EPA Method 9 to demonstrate compliance with the opacity standard. b. The permittee shall conduct tests on each wet scrubber exhaust with a PM standard in accordance with EPA Method 5 to demonstrate compliance with the corresponding standard.

c. The permittee shall conduct tests on each wet scrubber exhaust with a SO 2 standard in accordance with EPA Method 6/6C to demonstrate compliance with the corresponding standard. d. These methods are described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62- 204.800, F.A.C.

e. Initial compliance tests shall be conducted during federal fiscal year 2012/2013 and a test report demonstrating compliance shall be submitted before October 1, 2013. {Permitting Note: For the PM and SO 2 BART standards, it may be necessary to develop new excursion levels for the scrubber parameters if subject to a Compliance Assurance Monitoring (CAM) plan. This may require additional compliance testing.} [Rules 62-204.800, 62-296.340(3)(b)2, and 62-297.310(7)(a)4, F.A.C.; and 40 CFR 60, Appendix A] 9. Test Requirements : The permittee shall comply with the applicable “Common Testing Requirements” requirements specified in Appendix C of this permit, which include test notifications, test procedures, sampling facilities, test frequencies, test records and test reports. Parametric data recorded for the wet scrubber during each test shall be provided with the required test report. As necessary, EPA Methods 1 – 4 shall be conducted to support the other test methods. [Rule 62-297.310(7)(a)9, F.A.C.]

MONITORING 10. Wet Scrubber Parameters : For each wet scrubber, the permittee shall install, operate and maintain devices to continuously monitor the scrubber water flow rate, the pressure drop across the scrubber and the fan amperage. Such devices shall be calibrated, fully functional and in operation before conducting the initial compliance tests. In addition, the permittee shall install, operate and maintain devices to continuously monitor the pH level of the caustic solution in the wet scrubbers for the ‘A’ and ‘B’ DFP Plants (EU-003 and EU-038).

a. For each emissions unit subject to a CAM plan, the scrubber parameters shall be continuously monitored and recorded. For each operating hour, the 1-hour block average shall be computed from at least four data points evenly spaced over each operating hour. This data shall be used to develop new excursion levels for the scrubber parameters in the CAM plan. b. For each emissions unit that is not subject to a CAM plan, the scrubber parameters shall be continuously monitored and manually recorded at least once during each eight-hour block of operation. Alternatively, the parametric data may be continuously recorded. During each required compliance test, such data shall be recorded at 15-minute intervals. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.] 11. CEMS Compliance Demonstration : The permittee currently operates continuous emissions monitoring systems (CEMS) to determine SO 2 emissions from the “C” and “D” Sulfuric Acid Plants (EU-021 and EU022. The permittee shall operate and maintain each CEMS to demonstrate compliance with the BART SO 2 standards specified in this permit, which requires the data to also be reduced to 24-hour rolling averages.SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS C. Emissions Units with Combustion

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 11 of 13 Each CEMS shall be certified to meet Performance Specification 2 and Performance Specification 3 in Appendix B of 40 CFR 60 and the quality assurance procedures specified in Appendix F of 40 CFR 60. [Rules 62-296.340 (BART) and 62-4.070(3), F.A.C.]

RECORDS 12. Wet Scrubber Records : The permittee shall maintain records on site of the scrubber water flow rate and the pressure drop across the scrubber. In addition, the following vendor design information shall be maintained on site for each wet scrubber: exhaust flow rate; scrubber water flow rate, scrubber pressure drop, dust inlet loading, dust outlet loading and control efficiency. [Rules 62-4.070(3) and 62-296.340 (BART), F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS D. Molten Sulfur System for ‘C’ and ‘D’ Sulfuric Acid Plants

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 12 of 13 This subsection addresses the following affected emissions units. EU No. Emissions Unit Description 054 Molten Sulfur System for ‘C’ and ‘D’ sulfuric acid plants
Pursuant to Rule 62-296.340 (BART), F.A.C., the following standards represent the Best Available Retrofit Technology. These standards apply to each BART-eligible unit and are in addition, and supplement, all other applicable standards.

EMISSIONS LIMITING AND PERFORMANCE STANDARDS 1. Molten Sulfur Facilities – Work Practice Standards : All molten sulfur facilities shall employ, as a minimum, the following practices to minimize the emission of sulfur particulate matter into the atmosphere.

a. All molten sulfur transfer shall be through enclosed piping systems where feasible and practical. In user facilities, molten sulfur may be transferred by covered trench or a movable spout which is positioned over a receiving pit. Contact surfaces between movable unloading arms and stationary pipes shall seat effectively around the entire circumference to minimize spillage. b. All areas surrounding points where molten sulfur pipes are routinely disconnected and areas where molten sulfur is transferred to trucks or railcars shall be paved and curbed within 20 feet of the point of disconnection or transfer to contain any spilled molten sulfur, or shall be provided with non-corrodible drip pans or other secondary containment, positioned to collect spills, that are adequate to contain amounts of sulfur that may escape during routine disconnection, reconnection or operation of the piping system.

c. All spilled molten sulfur shall be collected and properly disposed of whenever the containment area is filled to one-half its containment capacity, or monthly, whichever is more frequent. Spills of molten sulfur outside of a containment area, or where subject to vehicular traffic, shall be collected and disposed of as soon as possible, but no later than 24 hours after the spill occurs. Drip pans or other secondary containment shall be cleaned as needed to prevent exceedance of capacity, but at least weekly. d. All vent surfaces shall be cleaned monthly to remove captured particles.

e. All owners and operators of molten sulfur storage and handling facilities shall maintain records of spills outside of containment areas and of collection and disposal of spilled sulfur. Such records shall be retained for a minimum of two years and shall be available for inspection by the Department upon request. f. Owners and operators shall establish and implement procedures to minimize spills from any movable loading arm or pipe upon disconnection, reconnection or operation. [Rules 62-296.340 (BART) and 62-296.411, F.A.C.] 2. Opacity Standard : As determined by EPA Method 9, visible emissions from any emission point in the molten sulfur facility shall not exceed 20% opacity (6-minute average). [Rules 62-296.340 (BART) and 62-296.411, F.A.C.]

EMISSIONS PERFORMANCE TESTING 3. Compliance Tests : The permittee shall conduct visible emissions tests every 5 years (prior to operation permit renewal) in accordance with EPA Method 9 to demonstrate compliance with the opacity standard. This method is described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800,SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS D. Molten Sulfur System for ‘C’ and ‘D’ Sulfuric Acid Plants

White Springs Agricultural Chemicals, Inc Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 13 of 13 F.A.C. When the Department, after investigation, has good reason (such as complaints, increased visible emissions or questionable maintenance of control equipment) to believe that any applicable emission standard contained in a Department rule or in a permit issued pursuant to those rules is being violated, it shall require the owner or operator of the emissions unit to conduct compliance tests which identify the nature and quantity of pollutant emissions from the emissions unit and to provide a report on the results of said tests to the Department. [Rules 62-204.800, 62-296.340(3)(b)2 and 62-297.310(7)(a)4, F.A.C.; and 40 CFR 60, Appendix A, Method 9] 4. Test Requirements : The permittee shall comply with the applicable “Common Testing Requirements” specified in Appendix C of this permit, which include test notifications, sampling facilities, test procedures, test frequencies, test records and test reports. [Rule 62-297.310(7)(a)9, F.A.C.]

# D. Progress Energy

– Crystal River

# E. City of Tallahassee

– Purdom

# Permits Necessary for BART Exemption

A. Smurfit-Stone

–

Fernandina BeachBART-EXEMPTION SUMMARY

Smurfit-Stone Container Enterprises, Fernandina Mill Project No. 0890003-018- AC BART -Eligible Emissions Units Smurfit-Stone Container Enterprises, Inc. (Smurfit Stone) operates an existing pulp and paper facility located at North 8 th Street in Fernandina Beach, Nassau County, Florida. The UTM coordinates of this facility are: Zone 17; 456.2 km East; and, 3394.1 km North. This facility is a Kraft pulp and paper mill that consists of major activities areas such as: wood yard, pulp mill, recycling plant, chemical recovery, powerhouse, paperboard mill, and a corrugated containers plant. The facility operates the following BART -eligible emissions units subject to the requirements of Rule 62- 296.340(BART), F.A.C.: No. 5 Power Boiler 006; No. 4 Recovery Boiler 007; and No. 4 Smelt Dissolving Tank 013. Affected Pollutants The affected visibility-impairing pollutants include NO X , PM 10 and SO 2 . Project Description and Status On February 2, 2007, the Smurfit Stone submitted an application requesting emission limits to be exempt from the BART program

. The application was complete on December 21 , 2007. The applicant requested a new limit for the No. 5 Power Boiler of 550.0 pounds per hour (lb/hr) of sulfur dioxide (SO2) emissions based on a 24-hour rolling average as demonstrated by continuous emissions monitoring system (CEMS). The applicant provided an air quality modeling analysis indicating a visibility impairment of 0.495 deciviews to the Okefenokee National Wildlife Refuge. This level is below the regulatory threshold and allows the Fernandina Beach Mill to avoid a BART determination.
Exemption from BART The Department issued a draft air construction Permit No. 0890003- 018 -AC on February 1, 2008 that established the following emission limitations to exempt the facility from BART: 4. SO2 Standard. Sulfur dioxide emissions shall not exceed 550.0 lb/hour based on a 24-hour rolling average as determined by SO 2 CEMS. Compliance with this standard ensures that the mill is exempt from the provisions of BART at Rule 62-296.340, F.A.C. Failure to comply with the SO 2 standard in this permit may subject this facility to BART review. [Rules 62-4.070(3) and 62-296.340(BART), F.A.C.]
There were no comments related to the BART exemption emission limit on this draft permit and the final permit was issued on March 27, 2008.

# B. Smurfit-Stone

– Panama CityBART-EXEMPTION SUMMARY

Smurfit-Stone Container Enterprises, Panama City Mill Project No. 0050009-029- AC BART -Eligible Emissions Units Smurfit-Stone Container Enterprises, Inc. (Smurfit Stone) operates an existing pulp and paper facility located at One Everitt Avenue in Panama City, Bay County, Florida. The UTM Coordinates are: Zone 16, 632.8 km East and 3335.1 km North; and, Latitude: 30 08’ 30” North and Longitude: 85 37’ 25” West. The facility operates the following BART -eligible emissions units subject to the requirements of Rule 62- 296.340(BART), F.A.C.: Source Emissions Unit No. No. 1 Recovery Boi ler 1 No. 2 Recovery Boiler 19 No. 4 Combination Boiler 16 No. 1 Smelt Dissolving Tank 21 No. 2 Smelt Dissolving Tank 20 Lime Kiln 4 Lime Slaker 5

Affected Pollutants The affected visibility-impairing pollutants include NO X , PM 10 and SO 2 . Project Description and Status On January 29, 2007, the Smurfit Stone submitted an application requesting emission limits to be exempt from the BART program

. The application was complete on November 2, 2007. The applicant requested a new limit of 690 pounds per hour of sulfur dioxide (SO 2 ) emissions from the No. 4 combination boiler based on a 24-hour rolling continuous emissions monitoring system (CEMS) average. The applicant provided an air quality modeling analysis including this proposed emission limit that demonstrated a visibility impairment of 0.498 deciviews to the St. Marks National Wilderness Area. This level is below the regulatory threshold and allows the Panama City mill to avoid a BART determination. Exemption from BART The Department issued a draft air construction Permit No. 0050009- 027 -AC on November 20, 2007 that established the following emission limitations to exempt the facility from BART: 4. SO 2 Emissions Limit . Sulfur dioxide emissions shall not exceed 690 pounds per hour, 24-hour rolling average, as determined by the required continuous emissions monitoring system (CEMS). Compliance with this limit ensures that the mill is exempt form the provisions of BART at Rule 62-296.340, F.A.C. The effective date of this standard is 30 calendar da ys after issuance of this permit. [Rules 62-4.070(3), 62-296.340(BART) and 62-297.520, F.A.C.; 40 CFR 60, Appendices B and F; and applicant requested]. There were no comments related to the BART exemption emission limit on this draft permit and the final permit was issued on December 20, 2007.