### Exemption of Point Source Volatile Organic Compounds for BART

Purposes

The State of Florida has determined through modeling that Volatile Organic Compounds (VOC) from point sources are not anticipated to cause or contribute significantly to any impairment of visibility in Class I areas and should be exempt for BART purposes.



### Method

The State of Florida determined through modeling that VOCs from point sources are not anticipated to cause or contribute significantly to any impairment of visibility in Class I areas.

Modeling was conducted through The Visibility Improvement State and Tribal Association of the Southeast (VISTAS). VISTAS is a collaborative effort of state governments, tribal governments, and various federal agencies established to initiate and coordinate activities associated with the management of regional haze, visibility and other air quality issues in the Southeastern United States. VISTAS contracted with Georgia Institute of Technology to perform model sensitivity runs to determine the impact of point source VOCs on visibility in

Class I areas.

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on regional haze, annual PM2.5, and 8-hour ozone concentrations using CMAQv4.4_SOAmods on the VISTAS 12 km modeling domain, using the 2009 OTW (on the way) BaseD emissions. One

such sensitivity run reduced anthropogenic, point source VOCs by 100%. The purpose was to quantify the impact of VOC emissions from VISTAS BART sources on Class I areas. Two periods were examined representing a summer and winter (annual) timeframe : June 1-July 10,

2002 a nd November 19

– December 19, 2002. The approach included calculating the extinction coefficient in dv (deciviews), then determining the maximum impact of point source VOCs. The chart below shows the impact on the following twenty-two Class I areas within the VISTAS

domain. 2

BRET = Breton, LA BRIG = Brigantine NWR, NJ CACR = Caney Creek, AR CHAS = Chassahowitzka, FL COHU = Cohutta, GA DOSO = Dolly Sods, WV EVER = Everglades, FL GRSM = Great Smoky Mountains National Park HEGL = Hercules Glade, MO

J ARI = James River Face, VA LIGO = Linville Gorge, NC MACA = Mammoth Cave, KY MING = Mingo, MO OKEF = Okefenokee, GAROMA = Cape Romain, SC

SAMA = Saint Marks, FL SHEN = Shenandoah, VA SHRO = Shining Rock, NC SIPS = Sipsey Wilderness, AL SWAN = Swanquarter, NC UPBU = Upper Buffalo Wilderness, AR WOLF = Wolf Island, GAMaximum Point VOC Impact



### Conclusions

The results show that the maximum impact from eliminating all point source VOC emissions in

the VISTAS 12 km domain is less than a 0.5 dv for all Class I areas in the VISTAS domain.

Give n that the fraction of the total point source VOC emissions that are also BART-eligible in the state of Florida is small, the expected impact of controlling VOCs from a BART source

would be much less than the 0.5 dv threshold. VISTAS and the State of Florida conclude that

VO Cs from point sources are not a visibility impairing pollutant for BART purposes and that BART-eligible sources do not need to consider VOC emissions.



### Treatment of Ammonia Emissions for BART Purposes

Similar to its treatment of VOCs, EPA guidance allows States the discretion to decide whether or not ammonia emissions are to be considered for BART purposes based on evaluations of the contributions of the emissions to haze at Class I areas in their areas of influence. One approach a State can use to determine whether applying BART will be needed is to evaluate the haze impacts of all current emissions from all BART-eligible sources in the State. If the impact from all sources in the state is less than the contribution threshold established by the State, 0.5 dv for

F lorida, then source by source analysis for BART is not needed.

The State of Florida has determined through modeling that ammonia (NH3) emissions from point sources are not anticipated to cause or contribute significantly to any impairment of visibility in Class I areas and should be exempt for BART purposes.

### Method

The State of Florida determined through modeling that ammonia emissions from point sources

a re not anticipated to cause or contribute significantly to any impairment of visibility in Class I

areas in or near Florida.

VISTAS contracted with Georgia Institute of Technology to perform model sensitivity runs to determine the impact of point source ammonia on visibility in Class I areas.

Georgia Tech performed emission sensitivities to examine the impact of emission reductions on regional haze using CMAQv4.5 with SOA mods on the VISTAS 12 km modeling domain, using the VISTAS 2009 OTW (on the way) Base F4 emissions. One such sensitivity run reduced, BART-eligible source ammonia by 100%. The purpose was to quantify the impact of ammonia emissions from VISTAS BART sources on Class I areas. Two periods were examined: June 1- July 10, 2002 and November 19

– December 19, 2002. The approach included calculating theextinction coefficient in dv (deciviews), then determining the maximum impact of BARTe ligible source ammonia. The chart below, taken from the VISTAS analysis, shows the impact on the following twenty-two Class I areas within the VISTAS domain. 2

Maximum NH3 Impact - Maximum contributions of all BART-eligible NH 3 point sources in the VISTAS region to haze in Class I areas during the CMAQ-modeled periods.

The chart shows the largest haze impact in delta dv over the two timeframes at each Class I area. These delta dv changes represent the haze contribution of all BART source ammonia emissions

relative to assumed natural haze levels. The natural haze levels are based on EPA-default annual average natural concentrations for the East and monthly- varying “climatologically representative” relative humidity at each Class I area.During the periods modeled the ammonia emissions from all BART-eligible sources contributed

more than 0.5 dv to haze at Mammoth Cave National Park (MACA), Kentucky; Mingo Wilderness (MING), Missouri, Cape Romain National Wildlife Refuge Area (ROMA) South

C arolina, and Swanquarter National Wildlife Refuge (SWAN), North Carolina. All of these

C lass 1 areas are located more than 300 km from Florida BART-eligible sources.



### Conclusions

The BART requirements of the regional haze rule allow states to determine whether or not ammonia is to be considered a visibility impairing pollutant to be addressed for BART purposes. NH3 emissions from BART sources may impair visibility; however the majority of NH3 emissions in the VISTAS region are from a few BART sources. Removal of the large NH3 emission sources results in minimal impact on visibility at Class I areas in the VISTAS region. At their discretion states may ask those few large sources to evaluate NH3 impacts and potential

controls for NH3.

# Appendix L6

Summary of BART Modeling ExemptionsFACILITY

ID OWNER COMPANY NAME SITE NAME Meets Modeling
Exemption Meets

Model Rule Exemption Max Visibility
Impact
(deciviews)

0990016 ATLANTIC SUGAR ASSOCIATION ATLANTIC SUGAR MILL x 0.490
1230001 BUCKEYE FLORIDA, LIMITED PARTNERSHIP BUCKEYE FLORIDA, LIMITED PARTNERSHIP x 0.388
0570005 CF INDUSTRIES, INC., PLANT CITY PHOS CF INDUSTRIES, INC., PLANT CITY PHOSP xx 0.498
0010006 CITY OF GAINESVILLE, GRU DEERHAVEN GENERATING STATION x 0.018

0730003 CITY OF TALLAHASSEE ARVAH B.HOPKINS GENERATING STATION x 0.444

0610029 CITY OF VERO BEACH CITY OF VERO BEACH MUNICIPAL UTILITIES x 0.052

1130005 EXXONMOBIL PRODUCTION COMPANY ST REGIS TREATING FAC AND JAY GAS PLANT x 0.390
0090006 FLORIDA POWER & LIGHT (PCC) CAPE CANAVERAL POWER PLANT x 0.206
0850001 FLORIDA POWER & LIGHT (PMR) FPL / MARTIN POWER PLANT x 0.449
0810010 FLORIDA POWER & LIGHT (PMT) MANATEE POWER PLANT x 0.458
0110036 FLORIDA POWER & LIGHT (PPE) PORT EVERGLADES POWER PLANT x 0.462
1070014 FLORIDA POWER & LIGHT (PPN) PUTNAM POWER PLANT x 0.099
0990042 FLORIDA POWER & LIGHT (PRV) RIVIERA POWER PLANT x 0.194

1010017 FLORIDA POWER CORP. ANCLOTE POWER PLANT x 0.488

1030011 FLORIDA POWER CORPORATION FPC-BARTOW PLANT x 0.182

1110003 FT PIERCE UTILITIES AUTHORITY FT PIERCE UTIL/H D KING PWR PLNT x
1070005 GEORGIA-PACIFIC CORP. PULP/PAPER MILL GEORGIA-PACIFIC CORP. PULP/PAPER MILL xx 0.480

0050014 GULF POWER COMPANY LANSING SMITH PLANT x 0.060

0330045 GULF POWER COMPANY CRIST ELECTRIC GENERATING PLANT x 0.210
0310071 IFF CHEMICAL HOLDINGS, INC. IFF CHEMICAL HOLDINGS, INC. x 0.269

1050055 IMC PHOSPHATES COMPANY SOUTH PIERCE x 0.494

0330042 INTERNATIONAL PAPER COMPANY PENSACOLA MILL x 0.057

0310045 JEA NORTHSIDE/SJRPP x 0.402

0990045 LAKE WORTH UTIL. TOM G. SMITH PLANT x
1050003 LAKELAND ELECTRIC CHARLES LARSEN MEMORIAL POWER PLANT x 0.074

1050004 LAKELAND ELECTRIC C.D. MCINTOSH, JR. POWER PLANT x 0.215

0570008 MOSAIC RIVERVIEW xx 0.494

1050046 MOSAIC - BARTOW BARTOW x 0.144

1050053 MOSAIC - GREEN BAY GREEN BAY PLANT x 0.219

1050059 MOSAIC - NEW WALES NEW WALES xx 0.496

0990019 OSCEOLA FARMS OSCEOLA FARMS x 0.302
0090196 RELIANT ENERGY INDIAN RIVER, L.L.C. INDIAN RIVER PLANT - RELIANT x 0.178
0890003 SMURFIT STONE CORPORATION (US) JSC-FERNANDINA BEACH PAPERBOARD MILL xx 0.495

0330040 SOLUTIA INC. SOLUTIA INC. x 1130003 STERLING FIBERS, INC. STERLING FIBERS, INC. x
0050009 STONE CONTAINER CORPORATION PANAMA CITY MILL xx 0.498

0990026 SUGAR CANE GROWERS CO-OP SUGAR CANE GROWERS CO-OP x 0.467

0570039 TAMPA ELECTRIC COMPANY BIG BEND STATION x 0.466

0510003 U.S. SUGAR CORP. CLEWISTON MILL U.S. SUGAR CLEWISTON MILL AND REFINERY x 0.265

35 4BART Modeling Review

Atlantic Sugar

– units 1, 2, 3, and 4 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM based on maximum stack test data for NOx and PM (bagasse), and for SO2 (bagasse) from industry test data; AP-42 was used for NOx and SO2 emissions

when firin g fuel oil; maximum allowable permitted PM for fuel oil; condensable

emissions from AP-42 input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOS T

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.490 dv (Everglades NP) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Buckeye

–

units 7, 11, 22, and 23 (No.’s 3 and 4 recovery boilers, and No.’s 3 and 4 smelt dissolving tanks) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM SO2 and NOx emissions based on maximum permitted process rate and NCASI emission factors developed for the industry; PM emissions based on maximum

stack test data input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– in puts correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.284 dv (St. Marks NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

CF Industries

– units 2,3,7,8,10,11,12,13,15, and 18 (A, B, C, and D sulfuric acid plants, A, Z, X, and Y DAP/MAP plants, and, A and B shipping baghouses.

Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP Comments were appropriately responded to by the applicant

Protocol includes the evaluation of three scenarios for emission reductions sufficient to meet the exemption criteria. Only scenarios A and B have been

evaluate d because scenario C was not deemed consistent with current permit conditions and was dismissed by the department. A federally enforceable permit requiring the implementation of either A or B scenarios is being issued.

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

Two emission reduction scenarios evaluated

– CFI has the option of choosing

either .

Scenario A

– SO2 emissions are reduced from the “A” SAP 250 lb/hr to 75.8 lb/hr (24- hr average), from the “B” SAP 233.3 lb/hr to 93.3 lb/hr, from the “C” SAP 401.1 lb/hr to 303.3 lb/hr, and from “D” SAP 401.3 lb/hr to 303.3 lb/hr.

Additional minor reductions in NOx and sulfuric acid mist are obtained from reductions in production.

Scenario B

– SO2 emissions are reduced from the “A” SAP 250 lb/hr to 81.3 lb/hr, from the “B” SAP 233.3 lb/hr to 100 lb/hr, from the “C” SAP 401.1 lb/hr to 241.7 lb/hr, and from “D” SAP 401.1 lb/hr to 241.7 lb/hr. Again, min or reductions from NOx and sulfuric acid mist will occur resulting from production

decreases. All data input correctly and consistent with protocol Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.498 dv (Chassahowitzka NWA) for scenario A, and 0.432 dv (Chassahowitzka NWA) for scenario B from modeling report

b ased on new IMPROVE equationDepartment recommendation: Either scenario meets BART exemption criteria, source

exempt.BART Modeling Review

Gainesville Deerhaven

– unit 1 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.022 dv (Okefenokee NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

City of Tallahassee Hopkins

– units 1 and 4 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol

Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum stack test data, using maximum rated heat input input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.522 dv (St. Marks NWA), based on the old IMPROVE equation

maximum 8 th highest daily visibility value at any Class I area = 0.444 dv (St. Marks NWA), based on new IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

City of Vero Beach

– units 2, 3, and 4 Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Fo llowed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum allowable permitted rates input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.052 dv (Everglades NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Exxon Mobil

– unit 34 (sulfur recovery plants) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM SO2 based on stack test data; PM and NOx based on annual operation reports; PM and NOx emissions are very small and variations of these values would not be expected to significantly change the results input correctly and consistent with protocol default speciation used correctly (all PM is fine and is organic carbon)

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report output for 2002 inconsistent with values listed in the report, other years are consistent; the model output takes precedence, and no further action is necessary

maximum 8 th highest daily visibility value at any Class I area = 0.390 dv (Breton NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

FPL Cape Canaveral

– units 1 and 2 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data input correctly and consistent with the revised protocol. speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with revised protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.206 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

FPL Martin

– units 1 and 2 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data input correctly and consistent with the revised protocol. speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent wi th applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.449 dv (Everglades NP) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

FPL Manatee

– units 1 and 2 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data input correctly and is consistent with the revised protocol. speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.458 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

FPL Port Everglades

–

units 3 and 4 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum permitted emission rates from the Title V permit and actual maximum heat input rates based on stack tests. input correctly and consistent with the protocol. speciation correctly input and consistent with protocol

Result s from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.594 dv (Everglades NP), based on old IMPROVE equation new IMPROVE equation was used correctly, giving a maximum 8 th highest daily visibility value of 0.462 dv

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

FPL Riviera

– unit 4 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data input correctly and consistent with the revised protocol. speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.194 dv (Everglades NP) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Progress Energy Anclote

– units 1 and 2 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were considered in the final report

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test emission rates input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applican t’s report

maximum 8 th highest daily visibility value at any Class I area = 0.576 dv (Chassahowitzka NWA), based on the old IMPROVE equation

maximum 8 th highest daily visibility value at any Class I area = 0.488 dv (Chassahowitzka NWA), based on the new IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Progress Energy Bartow

– unit 3 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were considered in the final report

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum allowable emission rates input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.182 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Georgia Pacific

– units 15, 16, 17, 18, and 19 (No. 5 power boiler, No. 4 combination boiler, No. 4 lime kiln, No. 4 recovery boiler, No. 4 smelt dissolving tank) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were not completely responded to by the applicant, additional information showing the data and calculations for the maximum 24-hour emissions is necessary

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM
SO2, NOx, and PM emissions from units 17 and 18 based on maximum stack test data; more information requested Some errors in the input files for summing concentrations; re-runs requested speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.489 dv (Okef enokee NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Gulf Power Lansing Smith

– units 1 and 2 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum stack test data and maximum heat input derived from CEMS input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.06 dv (St. Marks NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Gulf Power Crist

– units 6 and 7 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum stack test data and maximum heat input derived from CEMS input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is con sistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.21 dv (Breton NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

IFF Chemicals - unit 3 (boiler 2) Reque sts exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx and PM emissions PM emissions based on maximum allowable permitted; NOx emissions based on maximum AP-42 emission factors, SO2 emissions based on maximum potential hourly rate for fuel burning plus the maximum actual 24-hour average due to CST (crude sulfate terpentine) vapor incineration. input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.269 dv (Okefenokee NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Mosaic South Pierce

– units 4, 5, 22, 23, 24, 25, 26, 30-39, and 40- 43 (No.’s 10 and 11

sulfuric a cid plants, No. 2 ball mill, GTSP production plant, GTSP east storage building north and south scrubbers, GTSP rock hopper, molten storage tanks, and molten storage pits) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– Stack height for molten sulfur storage pits (unit 40-43) input at 9.1 m, protocol indicates stack height is 3.05 m

– this is judged an insignificant error because

these sources have very small emissions. Otherwise, all stack parameters are consistent with the protocol

Emissions

– SO2, NOx, and PM

SO2 and H2SO4 emissions from units 4 and 5 based on maximum allowable permitted with maximum actual 24-hour production; SO2, NOx, and H2SO4 emissions from the GTSP production plant based on AP-42 emission factors; SO2 emissions from the molten sulfur storage and transfer units based on maximum allowable permitted; PM emissions from all sources based on maximum allowable permitted input correctly and consistent with protocol Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.642 dv (Chassahowitzka NWA) using the old IMPROVE equation ; = 0.494 dv using the new IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

International Paper Pensacola

– units 29, 30, 32, and 38 (No. 1 Recovery Furnace, No. 1 Smelt Dissolving Tank, No. 2 Recovery Furnace, No. 2 Smelt Dissolving Tank) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM SO2 and NOx emissions based on NCASI technical bulletin 884; speciated PM emissions based on AP-42 table 10.2-3, based on data from the maximum stack

test value input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report used RH-varying natural visibility

maximum 8 th highest daily visibility value at any Class I area = 0.057 dv (Breton NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

JEA Northside unit 3 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum AP-42 emission factors (oil/gas), daily measured oil/gas heat input (CEM), and monthly heating values. Note: cross-checked with the actual maximum stack test data and found the applicant’s method provided higher

emission rate. input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.402 dv (Okefenokee NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Lakeland Larsen

– unit 4 (boiler 7) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were addressed within the final report

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum allowable permit limit input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.074 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Lakeland McIntosh

– units 1 and 5 (boilers 1 and 2) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were addressed within the final report

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum allowable permit limit input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.215 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Mosaic Riverview

– units 4, 5 , 6, 63, 66, 67, and 68 (No.’s 7, 8, and 9 sulfuric acid plants, molten sulfur storage tanks 1, 2, and 3, and molten sulfur storage and handling pits 7, 8, and 9) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM For sulfuric acid plants based on maximum allowable permitted for SO2 and H2SO4, reduced specifically to meet the BART exemption criteria. These decreased emissions in the sulfuric acid plants will result from increased vanadium catalyst. NOx emissions based on data from a PSD permit application. No changes to the emissions (PM) from the molten sulfur storage tanks or pits, and are based on data from a PSD permit application. All data input correctly and consistent with protocol Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.494 dv (Chassahowitzka NWA) from modeling report based on new IMPROVE equation

De partment recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Mosaic Bartow

– unit 54 (No. 3 sulfuric acid plant) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2 based on maximum allowable permitted for SO2 and H2SO4 input correctly and consistent with protocol

No PM emissions

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.144 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Mosaic Green Bay

– units 4, 7, and 29 (No. 4 sulfuric acid plant, South AP fertilizer plant, and North MAP/DAP fertilizer plant) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM based on maximum allowable permitted for PM, for all units; SO2 and H2SO4 for unit 4 based on maximum allowable permitted; NOx for unit 4 based on maximum allowable permitted limit for unit 3 sulfuric acid plan; for other units, NOx based on AP-42; NOx, SO2, and H2SO4 for units 7 and 29 based on AP-42 Unit 7 dryer NOx emissions were input to the model based on fuel oil burning (8.9 lb/hr)

– protocol indicated a maximum of 12.6 lb/hr based on LPG; this difference is not considered significant in this case and no re-run is deemed

necessary Otherwise, input correctly and consistent with protocol Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol modeling output is inconsistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.241 dv (Chassahowitzka NWA) from modeling report; = 0.219 dv from model output based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Mosaic New Wales

– units 2,3,4,9,11,27,36,15,23-28,29-35,38,52,55,63, and 66- 68 (No.’s
1, 2, and 3 sul furic acid plants, DAP plant No. 1, MAP plant, AFI plant, multifos A and B kilns, dryer and blending operation, and various low emitting particulate-only sources

Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP Comments were appropriately responded to by the applicant

Protocol includes the evaluation of two scenarios for emission reductions

sufficient t o meet the exemption criteria. A federally enforceable permit requiring the implementation of one or the other of these scenarios is being issued.

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

Two emission reduction scenarios evaluated

– Mosaic New Wales has the option of choosing either .

Scenario A

– Sulfuric acid mist emissions from SAP’s No. 1,2, and 3 are reduced from 14.0 to 7.1 lbs/hr; DAP plant No. 1 and AFI plant dryers are fired using only

natural gas; multifos plant kilns A and B are shut-down; DAP plant No. 1 PM emissions are reduced from 28.6 to 15 lbs/hr; and, MAP plant PM emissions are

reduced from 15 to 7 lbs/hr.

Scenario B

– SO2 emissions from SA P’s 1, 2, and 3 each are reduced from 496 to 400 lbs/hr; sulfuric acid mist emissions from the SAP’s reduced from 14.0 to 6.7 lbs/hr; NOx emissions from the SAP’s reduced from 17 to 16 lbs/hr; DAP plant No. 1 and AFI plant dryers are fired using only natural gas; multifos A and B kilns dryer is fired with only natural gas and PM emissions are reduced from 29.8 to 25 lbs/hr; SO2 emissions from the multifos A and B kilns dryer reduced from 316 to 25 lbs/hr; PM emissions from DAP plant No. 1 reduced from 28.6 to 16 lbs/hr; and, MAP plant PM emissions are reduced from 15 to 7 lbs/hr. All PM emissions from sources not requiring a reduction via scenario A or B use

maximum actual values. All data input correctly and consistent with protocol Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s reportmaximum 8 th highest daily visibility value at any Class I area = 0.490 dv (Chassahowitzka NWA) for scenario A, and 0.496 dv (Chassahowitzka NWA) for scenario B from modeling report based on new IMPROVE equation

Department recommendation: Either scenario meets BART exemption criteria, source

exempt.BART Modeling Review

Osceola Farms

– units 2 and 4 (mill boilers No.’s 2 and 4) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PMbased on maximum stack test data for SO2,NOx, and PM (bagasse) ;based on AP42 for SO2, NOx, and PM emissions when firing fuel oil, and for determining

condensable emissions. input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.302 dv (Everglades NP) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Reliant Indian River

–

units 2 and 3 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum allowable rate considering both normal operation and soot blowing input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.178 dv (Chassahowitzka NWA) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Smurfit Stone Container Fernandina Beach

– units 6, 7 and 13 (No. 5 power boiler, No. 4 recovery boiler, and No. 4 smelt dissolving tank) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM SO2 and NOx emissions from the recovery boilers and smelt dissolving tanks are based on maximum permitted process rate and NCASI emission factors developed for the industry, and by AP-42; A new SO2 emissions limit of 550 lb/hr (24-hour average) is being requested by the applicant on the No. 5 power boiler to limit their visibility impact to less than 0.5 dv. input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.915 dv (Okefenokee NWA) using the old IMPROVE equation and 1026 lb SO2/hr on PB 5, and 0.495 dv, using the new emissions limitation of 550 lb SO2/hr and the new IMPROVE equation.

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Smurfit Stone Panama City

– units 16, 1, 19, 20, 21, 4 and 5 (No. 4 combination boiler, No.’s 1 and 2 recovery boilers, and No.’s 1 and 2 smelt dissolving tanks, lime kiln, and lime slaker) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM SO2 and NOx emissions from the recovery boilers and smelt dissolving tanks are based on maximum permitted process rate and NCASI emission factors developed for the industry, and by AP-42; A new SO2 emissions limit of 690 lb/hr (24-hour average) is being requested by the applicant on the No. 4 combination boiler to limit their visibility impact to less than 0.5 dv. The lime kiln SO2 and NOx

emissions are based on maximum stack test data. PM emissions based on

maximum stack test data input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.586 dv (St. Marks NWA) using the old IMPROVE equation, and 0.498 dv, using the new IMPROVE equation.

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

Sugarcane Growers

– units 1, 2, 4, and 5 (boilers 1,2,4, and 5) Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, SO4, NOx, and PM Because of the seasonal nature of sugar cane operations, crop season (October through April) and off-crop season emission scenarios were modeled. SO2 emissions were based on industry test data and assumptions in the Title V permit. PM and NOx emissions were based on stack test data. PM was speciated using AP-42 factors for wood-fired boilers (no specific factors are available for bagas se -fired boilers). Condensible PM emissions were based on AP-42 and divided equally between organic and inorganic species. input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.634 dv (Everglades NP) using the old IMPROVE equation and 0.467 dv, using the new IMPROVE equation.

Departmen t recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

TECO Big Bend

– units 1, 2, and 3 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only based on maximum stack test data, with maximum allowable heat input rate input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol modeling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.577 dv (Chassahowitzka NWA), based on the old IMPROVE equation

maximum 8 th highest daily visibility value at any Class I area = 0.466 dv (Chassahowitzka NWA), based on new IMPROVE equation New IMPROVE equation applied using VISTAS conversion spreadsheet; applicant used a Rayleigh scattering value of 11.4 instead of the rounded number, 11, suggested in the spreadsheet. If “11” is used the visibility value increases to

0.474 dv

Department recommendation: Meets BART exemption criteria, source exempt.BART Modeling Review

U.S. Sugar Clewiston

– units 1 an d 2 Requests exemption based on modeled impact less than 0.5 dv.

Protocol: Followed VISTAS common protocol Reviewed by DEP and EPA Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM based on maximum stack test data for NOx and PM (bagasse and fuel oil), and for SO2 (boiler 1) when firing bagasse (applied to boiler 2 since nearly identical);

AP -42 was used for PM and SO2 emissions when firing fuel oil and for determining condensable emissions. input correctly and consistent with protocol speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

mod eling output is consistent with applicant’s report

maximum 8 th highest daily visibility value at any Class I area = 0.265 dv (Everglades NP) based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.BART Exemption Sources

The following sources were determined to be exempt from the BART rule in accordance with Rule 62-296.340(5)(a)1. or Rule 62-296.340(5)(a)2, Florida Administrative Code. These exemptions follow the U.S. EPA “model rule” criteria whereby BAR T-eligible sources located greater than 50 (or 100) km from any Class I area and having potential emissions of SO2+NOx+PM less than 500 (or 1000) tons is exempt. In making this determination, the PM emissions are speciated and an equivalent tonnage is calculated based on each species sulfate-equivalent extinction.

ARMS

ID Source Name Minimum Distance to Any Class I Area (km) Total Emissions SO2 + NOx + PM (tpy)

0330040 Solutia 166 963

0990045 Lake Worth Utilities

–

Tom G. Smith Plant 104 276 1

1110 003 Ft. Pierce Utilities

–

H.D. King Plant 190 18 1

1130003 Sterling Fibers 177 828

1 Only PM is considered because electric generating units are subject to CAIR

The department has verified the distance and potential emissions data used to make these exemption determinations.