Regional Haze SIP for Florida 

Exhibit 2

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Regional Haze SIP for Florida 

Exhibit 2

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Regional Haze SIP for Florida 

Exhibit 2

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Regional Haze SIP for Florida 

Exhibit 2

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Regional Haze SIP for Florida 

Exhibit 2

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Regional Haze SIP for Florida 

Exhibit 2

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Regional Haze SIP for Florida 

Exhibit 2

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D. Mosaic – New Wales 

Regional Haze SIP for Florida 

Exhibit 2

Page 368 of 501
Mosaic New Wales BART Exemption Modeling 

Mosaic New Wales has made federally enforceable changes to its operating permits to reduce 

emissions of visibility-impairing pollutants in order to meet the exemption criterion for the Best 

Available Retrofit Technology (BART) rule (62-296.340(5), F.A.C.). Specifically, they have 

provided for two options (scenarios A and B) that reduce emissions somewhat differently among 

the BART-eligible source, but both result in visibility improvement. Taking into consideration 

these emission reductions, Mosaic completed air quality modeling consistent with an approved 

modeling protocol submitted to the department. The EPA-approved CALPUFF dispersion 

model was used to determine visibility impacts on all federal Class I areas within 300 kilometers 

of the facility using three years of meteorological data derived from the MM5 meteorological 

model. This modeling was thoroughly reviewed by the department and determined to be 

appropriate for the purpose of meeting the exemption criteria of the BART rule. 

Visibility impacts were completed for two federal Class I areas: Chassahowitzka National 

Wilderness Area, located 104 kilometers from the facility and Everglades National Park (226 

kilometers).. The controlling area, that is the area with the greatest visibility impact from Mosaic 

New Wales, is Chassahowitzka. BART exemption modeling considered only the impacts from 

the BART-eligible sources within the facility. In this case, the No.’s 1, 2, and 3 sulfuric 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 In scenario A, Mosaic proposes that 

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. In scenario B, SO2 emissions from SAP’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. 

The results of the modeling, considering both scenarios A and B for the controlling 

Chassahowitzka area, are shown below as taken from the complete modeling report submitted by 

Mosaic. 

Regional Haze SIP for Florida 

Exhibit 2

Page 369 of 501
The maximum visibility impact at the Chassahowitzka National Wilderness area under the 

scenario A plan is 0.490 deciviews (dv). Under the scenario B plan, the maximum visibility 

impact is 0.496 dv. Both of these values are less than the criterion for exemption from the 

BART rule of 0.5 dv. Based on the emission changes made in this permit, following either 

scenario A or scenario B, and the modeling performed by the applicant, the department 

concludes that the BART-eligible source at Mosaic New Wales is exempt from the BART rule 

requirements. 

Regional Haze SIP for Florida 

Exhibit 2

Page 370 of 501
 

PERMITTEE 

Mosaic Fertilizer, LLC 

Post Office Box 2000 

Mulberry, FL 33860 

Authorized Representative: 

Mr. David B. Jellerson, Assistant Vice President - Environmental 

Air Permit No. 1050059-061-AC 

Expiration Date: June 30, 2013 

New Wales Facility 

BART Exemption Project 

PLANT AND LOCATION 

The Mosaic Fertilizer, LLC operates the New Wales facility, which is located at 3095 Highway 640, Mulberry in 

Polk County, Florida. The facility is an existing phosphate fertilizer manufacturer, which is identified by 

Standard Industrial Classification (SIC) code No. 2874. 

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.). 

Pursuant to Rule 62-296.340(5)(c) (escape BART), F.A.C., the permittee shall install the air pollution control 

equipment and/or implement the air pollution control measures that are specified by this permit to be exempt 

from a Best Available Retrofit Technology (BART) determination. 

EFFECTIVE DATE 

Unless otherwise specified by this permit, the affected emissions units shall comply with the conditions of this 

permit as expeditiously as practicable, but not later than the expiration date of this permit. [Rule 62-

296.340(3)(b)2., F.A.C.] 

Executed in Tallahassee, Florida 

___________________________________ _______________ 

Joseph Kahn, Director Effective Date 

Division of Air Resource Management 

JK/tlv/sa 

Regional Haze SIP for Florida 

Exhibit 2

Page 371 of 501
SECTION 1. GENERAL INFORMATION

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 2 of 18 

FACILITY DESCRIPTION

The applicant, Mosaic Fertilizer, LLC, operates an existing phosphate fertilizer manufacturer. The fertilizer 

complex processes phosphate rock into several different fertilizer products and animal feed ingredients. This is 

accomplished by reacting the phosphate rock with sulfuric acid to produce phosphoric acid and then converting 

the phosphoric acid to fertilizer and animal feed ingredient products. The facility consists of five double 

absorption sulfuric acid plants (SAP); three phosphoric acid plants (PAP); a phosphoric acid clarification and 

storage area; three diammonium phosphate (DAP) plants; a monoammonium phosphate (MAP) plant; a granular 

monoammonium phosphate (GMAP) plant; an animal feed ingredients (AFI) plant; a multifos production plant; a 

molten sulfur storage and handling system; a limestone storage silo/rock grinding operation and a phosphogypsum 

stack. 

FACILITY REGULATORY CLASSIFICATIONS 

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

• The facility does not operate emissions 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. 

AFFECTED EMISSIONS UNITS

Mosaic Fertilizer, LLC submitted an application to escape the BART determination requirements of Rule 62-

296.340(5)(c) (escape BART), F.A.C., which addresses the following emissions units with the potential to emit at 

least 50 tons per year (TPY) or more of a visibility-impairing pollutant: 

 

EU ID 

No. 

Brief Description 

-002 SAP No. 1 

-003 SAP No. 2 

-004 SAP No. 3 

-009 DAP Plant No. 1 

-011 MAP Plant 

-027 AFI Plant 

-036 Multifos A and B Kilns, Dryer and Blending Operations 

The rest of the BART-eligible emissions units at the New Wales facility are sources with relatively low 

particulate matter (PM) emissions (less than 5 lb/hr each). They are as follows: 

 

EU ID 

No. 

Brief Description 

-015 AFI truck loadout system 

-023 AFI storage silos - north side 

-024 AFI railcar loadout system 

Regional Haze SIP for Florida 

Exhibit 2

Page 372 of 501
SECTION 1. GENERAL INFORMATION

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 3 of 18 

-025 AFI limestone storage silos 

-026 AFI silica storage bin 

-028 AFI storage silos – south side 

-030 Multifos soda ash unloading 

-031 Multifos soda ash conveying 

-032 Multifos A kiln cooler 

-033 Multifos B kiln cooler 

-034 Multifos A and B kilns milling and sizing – West baghouses 

-035 Multifos A and B kilns milling and sizing – East baghouses 

-038 Multifos A and B kilns milling and sizing – surge bin 

-052 AFI limestone feed bin 

-055 MAP plant cooler 

-063 1,500-Ton truck unloading sulfur pit 

-066 200-Ton molten sulfur transfer pit 

-067 1,500-Ton truck unloading sulfur pit – front vents 

-068 1,500-Ton truck unloading sulfur pit – rear vents 

Except for the molten sulfur pits (EUs-063, -066, -067 and -068), all of theses emissions units emit only PM. The 

molten sulfur pits each emit 0.2 lb/hr or less of PM and 0.3 lb/hr or less of sulfur dioxide (SO2). 

Regional Haze SIP for Florida 

Exhibit 2

Page 373 of 501
SECTION 1. GENERAL INFORMATION

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 4 of 18 

CONTENTS 

Section 1. General Information 

Section 2. Administrative Requirements 

Section 3. Emissions Units Specific Conditions 

Section 4. Appendices 

Appendix A. Citation Formats 

Appendix B. General Conditions 

Appendix C. Standard Testing Requirements 

Appendix D. Memorandum of Understanding Regarding Best Operational Start-up Practices for 

Sulfuric Acid Plants

Regional Haze SIP for Florida 

Exhibit 2

Page 374 of 501
SECTION 2. ADMINISTRATIVE REQUIREMENTS 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 5 of 18 

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. 

2. Compliance Authority: All documents related to compliance activities such as reports, tests, and 

notifications shall be submitted to the Compliance Authority, Southwest District (SWD) Office. The 

Compliance Authority’s mailing address is: 

Florida Department of Environmental Protection Southwest District 

13051 N. Telecom Parkway 

Temple Terrace, Florida 33637-0926 

Telephone: 813/632-7600, Fax: 813/632-7665 

3. Appendices: The following Appendices are attached as part of this permit: Appendix A (Citation 

Formats); Appendix B (General Conditions); Appendix C (Standard Testing Requirements); and, 

Appendix D (Memorandum of Understanding Regarding Best Operational Start-up 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 Air Operation 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 air operation permit is required for regular operation of the permitted emissions unit. 

The permittee shall apply for a Title V air operation permit at least 90 days prior to expiration of this 

permit, but no later than 180 days after completing the required work and commencing operation. To 

apply for a Title V operation 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 Permitting Authority, the Florida Department of Environmental 

Protection, Southwest District Office. 

[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 (five) 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 (AOR): 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 1st of each year. [Rule 62-210.370(3), F.A.C.] 

NEW AND PREVIOUS PERMIT SPECIFIC CONDITIONS 

8. Pursuant to Rule 62-296.340(5)(c) (escape BART), F.A.C., the specific terms and conditions of this 

permit are required in order to escape a Best Available Retrofit Technology Determination. These 

specific terms and conditions apply to each emissions unit and are in addition to any other applicable 

standards. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Proposed by the Applicant in the Application; 

Regional Haze SIP for Florida 

Exhibit 2

Page 375 of 501
SECTION 2. ADMINISTRATIVE REQUIREMENTS 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 6 of 18 

and, Rules 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), 

F.A.C.] 

9. A relaxation of the specific terms and conditions of this permit may subject the facility to a BART and/or 

a Best Available Control Technology (BACT) determination. Any request to change the specific terms 

and conditions of this permit must be submitted to the Bureau of Air Regulation in the Division of Air 

Resource Management of the Florida Department of Environmental Protection. [Rule 62-296.340(5)(c) 

(escape BART), F.A.C.; and, Rules 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.] 

10. The applicant has proposed two emission reduction scenarios A and B for the BART-eligible emissions 

units at the New Wales facility. For each of the emissions reduction scenarios, the New Wales facility is 

exempt from BART because its contribution to visibility impairment does not exceed 0.5 deciview (dv) 

above natural conditions in any Class I area. Emissions Unit Specific Conditions in Section 3 of the 

permit will address both the emission reduction scenarios under different subsections. The applicant will 

make a decision to implement scenario A or B no later than January 1, 2010, at which time the scenario 

that was not selected will become obsolete. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Rules 

62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), F.A.C.] 

11. No emissions unit or facility subject to this permit shall be constructed or modified without obtaining the 

appropriate air construction permit from the Department. Such permit shall be obtained prior to 

beginning construction or modification. [Rules 62-210.300(1) and 62-212.300(1)(a), F.A.C.] 

12. Source Obligation: 

 (b) At such time that a particular source or modification becomes a major stationary source or major 

modification (as these terms were defined at the time the source obtained the enforceable limitation) 

solely by virtue of a relaxation in any enforceable limitation which was established after August 7, 

1980, on the capacity of the source or modification otherwise to emit a pollutant, such as a restriction 

on hours of operation, then the requirements of subsections 62-212.400(4) through (12), F.A.C., shall 

apply to the source or modification as though construction had not yet commenced on the source or 

modification. [Rule 62-212.400(12)(b), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 376 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A and 

B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 7 of 18 

This subsection addresses the following affected emissions units: 

 

EU ID 

No. 

Brief Description 

-002 SAP No. 1 

-003 SAP No. 2 

-004 SAP No. 3 

-009 DAP Plant No. 1 

-011 MAP Plant 

-027 AFI Plant 

-036 Multifos A and B Kilns, Dryer and Blending Operation 

ADMINISTRATIVE REQUIREMENTS 

1. Emission Reductions under Scenario A: This subsection deals with emission reductions for the above affected 

emissions units under Scenario A. The permittee shall notify the Department’s Bureau of Air Regulation and 

the SWD Office through a letter from the responsible official by January 1, 2010 whether Scenario A will be 

implemented. Under Scenario A, the permittee shall shutdown EU-036 (Multifos A and B Kilns including 

associated coolers) as expeditiously as practicable after January 1, 2010, but no later than June 30, 2013. [Rule 

62-296.340(5)(c) (escape BART), F.A.C. and Applicant’s Request received October 3, 2008] 

{Note: The dryer and blending operations under EU-036 will not be shut down as it is part of a mixed feed 

system that feeds Kiln C. The Multifos A and B Kiln coolers will be shut down and are designated as EU-032 

and EU-033, respectively.} 

2. Notification of Shutdown: The permittee shall notify the Department’s Bureau of Air Regulation, SWD Office 

and the Compliance Authority upon the shutdown of the EU-036 (Multifos A and B Kilns including associated 

coolers). If these emission units resume operations a BART analysis shall be performed as though they had not 

been shutdown. Other preconstruction review requirements may apply. [Rule 62-296.340(5)(c) (escape BART), 

F.A.C. and Applicant’s Request received October 3, 2008] 

ESSENTIAL POTENTIAL TO EMIT (PTE) PARAMETERS 

3. Design Capacity: The existing design capacity of each SAP, DAP Plant No. 1, MAP Plant and the AFI Plant 

shall not be changed as a result of the proposed work under this project, Permit No. 1050059-061-AC. The 

existing design capacity of each of these emissions units shall not exceed the following: 

EU ID No. Plant Description Design Production Capacity 

-002 SAP No. 1 3,400 TPD (tons per day) of 100% H2SO4 (sulfuric acid) 

-003 SAP No. 2 3,400 TPD of 100% H2SO4 

-004 SAP No. 3 3,400 TPD of 100% H2SO4

-009 DAP Plant No. 1 150 TPH (tons per hour) of MAP or DAP 

-011 MAP Plant 50 TPH of MAP 

-027 AFI Plant 120 TPH 

[Rules 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 377 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A and 

B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 8 of 18 

4. Methods of Operation - Fuels: The DAP Plant No. 1 and the AFI Plant dryers shall be fired by natural gas. The 

two dryers can be fired with No. 6 fuel oil or better grade fuel oil (as defined in Condition CC.20 in Permit 

1050059-045-AV) only during periods of natural gas curtailment. The permittee shall submit an official 

document from the natural gas pipeline vendor to the SWD Office for verification of natural gas curtailments. 

[Rules 62-4.070(1)&(3) (Reasonable Assurance) and Rule 62-210.200 (Definitions - Potential to Emit (PTE)), 

F.A.C.] 

5. Design Capacity and Permitted Production: The permittee shall submit a statement from the responsible official 

within 30 days after the completion of all of the proposed work under this project. [Rules 62-4.160(2) and 62-

210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

AIR POLLUTION CONTROL TECHNOLOGIES AND MEASURES 

6. SAP SO2 Controls: This BART exemption determination does not require new, modified or additional air 

pollution control systems for sulfur dioxide (SO2). To control emissions of SO2 from each SAP, the permittee 

shall continue the use of the existing double absorption system technology with vanadium and/or cesium catalyst 

in the converters and the use of good combustion practices and best operational practices to minimize excess 

emissions during startup and shutdown. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), 

F.A.C.; and, Proposed by the Applicant in the Application] 

7. SAP Acid Mist Controls: This BART exemption determination does require new, modified or additional air 

pollution control systems for sulfuric acid mist (SAM). By controlling SAM emissions, particulate 

matter/particulate matter less than 10 microns (PM/PM10) and visible emissions are minimized. To control 

emissions of SAM, the permittee shall install Brownian diffusion-type candles on SAPs 1 and 2, similar to the 

one employed on SAP No. 3. Other SAM control technologies may be considered by the Bureau of Air 

Regulation upon written request. The permittee shall submit a written request for other SAM control 

technologies to the Bureau of Air Regulation with a copy to the Compliance Authority for review and approval 

prior to use. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Proposed by the 

Applicant in the Application] 

8. 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.] 

EMISSION STANDARDS AND LIMITATIONS 

9. PM, NOx and SO2 Standards: Particulate matter, nitrogen oxides and sulfur dioxide emissions shall not exceed 

the following emissions standards. 

EU ID 

No.

Emissions Unit 

Description

Emissions Standards 

PM NOx SO2

-002 No.1 Sulfuric Acid Plant --- 17 lb/houra 496 lb/hourb

-003 No. 2 Sulfuric Acid Plant --- 17 lb/houra 496 lb/hourb

-004 No. 3 Sulfuric Acid Plant --- 17 lb/houra 496 lb/hourb

-009 DAP Plant No.1 15 lb/hour --- See Footnote “c”

-011 MAP Plant 7 lb/hour --- --- 

-027 AFI Plant 36.8 lb/hour --- See Footnote “c”

a. Nitrogen oxides (NOx) emissions from Nos. 1, 2, and 3 Sulfuric Acid Plants (EU-002, EU-003 and EU-004) 

Regional Haze SIP for Florida 

Exhibit 2

Page 378 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A and 

B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 9 of 18 

shall not exceed 17 lb/hour {Permitting Note (for information purposes only): equivalent to 0.12 lb/ton of 100% 

sulfuric acid at design capacity} based on a 3-hour average as determined by stack test data. 

b. Sulfur dioxide emissions from Nos. 1, 2, and 3 Sulfuric Acid Plants (EU-002, EU-003 and EU-004) shall not 

exceed 496 lb/hour based on a 24-hour (daily) block CEMS average. 

Permitting note (for information purposes only): SO2 emissions in lb/hour are equivalent to 3.5 lb/ton of 100% 

sulfuric acid at design capacity. A 24-hour (daily) block average was established based on the emission rate 

averaging period of 24-hour (daily) used in the air dispersion modeling. No stack testing is required. 

c. To control sulfur dioxide emissions from the dryers, only natural gas shall be fired as a fuel. During periods of 

natural gas curtailments, No. 6 fuel oil or better grade fuel oil (as defined in Condition CC.20 in Permit 

1050059-045-AV) may be fired as a fuel. 

[Rules 62-4.070(3) and 62-296.340(5)(c) (escape BART), F.A.C.] 

10. Opacity Standards: Visible emissions from the Nos. 1, 2 and 3 Sulfuric Acid Plants (EU-002, EU-003 and EU004) shall not exceed 10% opacity as determined by EPA Method 9. 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(5)(c) (escape BART), F.A.C.; and 40 CFR 60.83(a)2 and 40 CFR 60, Appendix A, Method 9] 

11. SO2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO2 

CEMS to be used to demonstrate continuous compliance with the SO2 emission standards and limitations 

specified in this section. 

a. In accordance with the New Source Performance Standards (NSPS) (40 CFR 60, Subpart H) requirements for 

sulfuric acid plants, the permittee shall continue to properly calibrate, maintain, and operate a CEMS to 

measure and record emissions of SO2. 

b. A CEMS shall be properly calibrated, maintained, and operated to comply with: 40 CFR 60 Subpart A, 

General Provisions; 40 CFR 60 Appendix B, Performance Specification 2; and, 40 CFR 60, Appendix F, 

Quality Assurance Procedures for Gas CEMS Used for Compliance Determination. 

c. The emissions data collected with the certified CEMS shall be used to demonstrate continuous compliance 

with the standards and limitations specified in this section. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.; and, Proposed by the Applicant in the Application] 

12. SAM Emission Standards and Limitations: This BART determination specifies new SAM emission standards. 

Emissions of SAM shall not exceed the following as demonstrated by stack test data: 

SAP No. lb/hour 

1 7.1 

2 7.1 

3 7.1 

Emissions of SAM shall not exceed 7.1 pounds per hour for each of the three SAPs based on a 3-hour average as 

determined by stack test data. 

{The equivalent lb SAM/ton 100% H2SO4 values for SAP Nos. 1, 2, and 3 at design capacity for each SAP is 

0.05 lb SAM/ton 100% H2SO4. The equivalent lb/ton value corresponding to the lb/hour limits is less than the 

current existing standards. The equivalent tons per year (TPY) values for SAP Nos. 1, 2, and 3 is 31.1 TPY. 

This permit requires stack test data to be used to demonstrate compliance. Compliance with the 3-hour average 

Regional Haze SIP for Florida 

Exhibit 2

Page 379 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A and 

B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 10 of 18 

by stack test assures compliance with a numerical standard on a 24-hour (daily) average basis. The air 

dispersion modeling was performed using a 24-hour (daily) average.} 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Proposed by the Applicant in the Application] 

EXCESS EMISSIONS 

13. Excess Emissions Prohibited: Excess emissions caused entirely or in part by poor maintenance, poor operation, 

or any other equipment or process failure that may reasonably be prevented during startup, shutdown or 

malfunction shall be prohibited. [Rule 62-210.700(4), F.A.C.] 

14. Excess Emissions Allowed: Unless otherwise specified by permit, excess emissions resulting from startup, 

shutdown or malfunction of any emissions unit shall be permitted providing (1) best operational practices to 

minimize emissions are adhered to and (2) the duration of excess emissions shall be minimized but in no case 

exceed two hours in any 24 hour period unless specifically authorized by the Department for longer duration. 

[Rule 62-210.700(1), F.A.C.] 

15. Excess Emissions Notification: In case of excess emissions resulting from malfunctions, the permittee shall 

notify the Compliance Authority in accordance with Rule 62-4.130, F.A.C. A full written report on the 

malfunctions shall be submitted in a quarterly report, if requested by the Department. [Rule 62-210.700(6), 

F.A.C.] 

16. Best Operational Practices to Minimize Excess Emissions:

a. The permittee shall follow the best operational practices to minimize excess emissions during startup and 

shutdown as described in the most recent Title V permit. 

b. Best operational practices to minimize excess SO2 and sulfur trioxide (SO3) emissions during startup are 

governed by this condition. The permittee shall follow the best operational practices to minimize excess 

emissions during startup contained within the attached Appendix D - Memorandum of Understanding 

Regarding Best Operational Start-up Practices for Sulfuric Acid Plants initially executed on October 25, 

1989. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Title V Permit No. 1050059-

045-AV] 

17. Best Operational Practices to Minimize Leaks of SO2 and SO3, or Other Fugitive Process Emissions: Best 

operational practices to minimize leaks of SO2 and SO3, or other fugitive process emissions shall be adhered to 

and shall include regular inspections and the prompt repair or correction of any leaks or other fugitive 

emissions. [Rules 62-4.070(1)&(3) and 62-296.320, F.A.C.] 

EMISSIONS TESTING 

18. Test Methods: The following reference methods (or more recent versions) shall be used to conduct any required 

emissions tests. 

Method Description of Method and Comments 

1 - 4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 

5 Determination of PM Emissions from Stationary Sources 

6 or 6C Determination of SO2 Emissions from Stationary Sources 

7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure) 

Regional Haze SIP for Florida 

Exhibit 2

Page 380 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A and 

B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 11 of 18 

Method Description of Method and Comments 

8 Determination of SAM and SO2 Emissions from Stationary Sources 

9 Visual Determination of Opacity from Stationary Sources 

EPA Methods 1, 2, 3 and 4 shall be used as necessary to support the other test methods. The above methods are 

described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. No other 

methods shall be used without prior written approval from the Permitting Authority. [Rules 62-204.800 and 62-

297.100, F.A.C.; and 40 CFR 60, Appendix A] 

19. Standard Testing Requirements: All required emissions tests shall be conducted in accordance with the 

requirements specified in Appendix C (Standard Testing Requirements) of this permit. [Rules 62-204.800 and 

62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

20. Compliance Test Schedule: In accordance with the following schedule, the permittee shall have stack tests 

conducted to demonstrate compliance with the emissions standards specified in this permit. 

a. Initial Test: On or before April 30, 2012, an initial test shall be conducted for NOx and SAM emissions 

from each SAP and PM emissions from DAP Plant No. 1, MAP Plant and the AFI Plant. The initial 

compliance test report for NOx, SAM and PM shall be submitted within 45 days of completion of testing. 

[Rules 62-296.340(5)(c) (escape BART) and 62-297.310(7)(a)1, F.A.C.] 

b. Initial and Special Test: A visible emissions (VE) test shall be conducted concurrently with one run of the 

SAM stack test to demonstrate initial compliance with the existing VE standards after the proposed work 

has been completed for each SAP. The VE test results shall be submitted with the SAM stack test report. 

[Rules 62-4.070(1)&(3) and 62-297.310(7)(b), F.A.C.] 

c. Tests Prior to Renewal: Within the 12-month period prior to renewing the Title V air operation permit, tests 

shall be conducted for SAM and NOx emissions from each SAP.

 [Rules 62-296.340(5)(c) (escape BART), and 62-297.310(7)(a)3, F.A.C.] 

{Note: Under this permit SO2 CEMS are required to demonstrate compliance on a continuous basis, therefore, 

no initial or annual compliance test for SO2 is necessary on the SAPs.} 

RECORDS AND REPORTS 

21. Quarterly Reporting Requirements: The owners or operators of facilities for which monitoring is required shall 

submit to the Department a written report of emissions in excess of emission limiting standards as set forth in 

Rule 62-296.402, F.A.C., for each calendar quarter. The nature and cause of the excessive emissions shall be 

explained. This report does not relieve the owner or operator of the legal liability for violations. All recorded 

data shall be maintained on file by the Source for a period of 5 (five) years. {The permittee is required to use 

SO2 continuous emissions monitoring systems for continuous compliance demonstrations.} [Rules 62-

296.402(5) and 62-213.440(1)(b)2., F.A.C.] 

22. Construction Plan and Progress Reports: The permittee shall submit a Construction Plan within sixty (60) days 

of January 1, 2010 which shall contain the necessary milestones to comply with this permit. The Plan shall 

include at a minimum the necessary actions and corresponding scheduled due dates to complete those actions to 

comply with this permit. 

a. The permittee shall submit progress reports based on the anniversary date (one year from the effective date) of 

this permit regarding the status of the milestones in the Construction Plan to the Department and to the 

Compliance Authority, no less than annually in 2010 - 2013. 

Regional Haze SIP for Florida 

Exhibit 2

Page 381 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A and 

B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 12 of 18 

b. The permittee shall complete all required construction and modifications no later than June 30, 2013. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 382 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A 

and B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 13 of 18 

This subsection addresses the following affected emissions units: 

 

EU ID 

No. 

Brief Description 

-002 SAP No. 1 

-003 SAP No. 2 

-004 SAP No. 3 

-009 DAP Plant No. 1 

-011 MAP Plant 

-027 AFI Plant 

-036 Multifos A and B Kilns, Dryer and Blending Operation 

ADMINISTRATIVE REQUIREMENTS 

1. Emission Reductions under Scenario B: This subsection deals with emission reductions for the above 

affected emissions units under Scenario B. The permittee shall notify the Department’s Bureau of Air 

Regulation and the SWD Office through a letter from the responsible official by January 1, 2010 whether 

Scenario B will be implemented. Under Scenario B, the permittee shall reduce production rates of SAP Nos. 

1, 2 and 3 from 3,400 TPD to 3,200 TPD and reduce lower daily average of SO2 and SAM emissions rates 

from the three SAPs. The SAPs shall comply with the new BART exemption limits for SO2 and SAM by 

April 30, 2013. Multifos A and B Kilns (EU-036) will continue to operate with lower SO2 and PM emission 

rates. A new scrubber will be installed to meet the lower SO2 emission limits for Multifos A and B Kilns. 

The Multifos A and B Kilns shall comply with the new BART exemption limits for SO2 and PM as 

expeditiously as practicable after January 1, 2010, but no later than June 30, 2013. [Rule 62-296.340(5)(c) 

(escape BART), F.A.C. and Applicant’s Request received October 3, 2008] 

ESSENTIAL POTENTIAL TO EMIT (PTE) PARAMETERS 

2. Design Capacity: The design capacity of each SAP, DAP Plant No. 1, MAP Plant, AFI Plant and the 

Multifos A and B Kilns shall not exceed the following: 

EU ID No. Plant Description Design Production Capacity 

-002 SAP No. 1 3,200 TPD of 100% H2SO4 

-003 SAP No. 2 3,200 TPD of 100% H2SO4 

-004 SAP No. 3 3,200 TPD of 100% H2SO4

-009 DAP Plant No. 1 150 TPH of MAP or DAP 

-011 MAP Plant 50 TPH of MAP 

-027 AFI Plant 120 TPH 

-036 Multifos A and B Kilns, Dryer and 

Blending Operation 

15 TPH process input rate to each Kiln and 

150,000 tons per year (TPY) of multifos 

from both Kilns combined 

[Rules 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

3. Methods of Operation - Fuels: The DAP Plant No. 1, AFI Plant and the Multifos A and B Kilns dryers shall 

be fired by natural gas. The dryers can be fired with No. 6 fuel oil or better grade fuel oil (as defined in 

Regional Haze SIP for Florida 

Exhibit 2

Page 383 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A 

and B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 14 of 18 

Condition CC.20 in Permit 1050059-045-AV) only during periods of natural gas curtailment. The permittee 

shall submit an official document from the natural gas pipeline vendor to the SWD Office for verification of 

natural gas curtailments. [Rules 62-4.070(1)&(3) (Reasonable Assurance) and Rule 62-210.200 (Definitions - 

Potential to Emit (PTE)), F.A.C.] 

4. Design Capacity and Permitted Production: The permittee shall submit a statement from the responsible 

official within 30 days after the completion of all of the proposed work under this project. [Rules 62-4.160(2) 

and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

AIR POLLUTION CONTROL TECHNOLOGIES AND MEASURES 

5. SAP SO2 Controls: This BART exemption determination does require new, modified or additional air 

pollution control systems for SO2. To control emissions of sulfur dioxide (SO2) from each SAP, the 

permittee shall continue the use of the existing double absorption system technology with vanadium and/or 

cesium catalyst in the converters and the use of good combustion practices and best operational practices to 

minimize excess emissions during startup and shutdown. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; 

Rule 62-210.700(1), F.A.C.; and, Proposed by the Applicant in the Application] 

6. Proposed Work: The applicant is required to perform the following specific work activities under this project 

in order to escape BART: 

EU ID 

No. 

Work Activities 

-002 • Increase the catalyst loading ratio from approximately 147 liters per ton H2SO4 per day 

(L/TPD) at 3,400 TPD production rate to approximately 190 L/TPD at 3,200 TPD 

production rate {increases the current catalyst loading from approximately 498,400 

liters to 610,000 liters}; 

• Install a heat recovery system (HRS) to replace the interpass absorption (IPA) tower (If 

necessary, install/replace); 

• Replace the sulfur furnace (If necessary, install/replace); 

• Replace the drying tower (If necessary, install/replace); and 

• Install Brownian diffusion-type candles in the final absorption tower for SAM control. 

-003 • Increase the catalyst loading ratio from approximately 147 L/TPD at 3,400 TPD 

production rate to approximately 213 L/TPD at 3,200 TPD production rate {increases 

the current catalyst loading from approximately 498,400 liters to 610,000 liters}; 

• Install HRS to replace the IPA tower (If necessary, install/replace); 

• Replace the sulfur furnace (If necessary, install/replace); 

• Replace the drying tower (If necessary, install/replace); and 

• Install Brownian diffusion-type candles in the final absorption tower for SAM control. 

-004 • Increase the catalyst loading ratio from approximately 157 L/TPD at 3,400 TPD 

production rate to approximately 190 L/TPD at 3,200 TPD production rate {increases 

the current catalyst loading from approximately 535,200 liters to 610,000 liters}. 

-036 • Install caustic scrubber for each of the Multifos A and B Kilns. 

Higher catalyst loadings are allowed by this permit in order to meet the BART SO2 emission limits. The 

Brownian diffusion-type candles will be installed in the IPA tower which will become the final absorption 

tower after the reconfiguration. The candles will lower SAM emission rates from the two SAPs. A caustic 

scrubber is required for each Multifos A and B Kilns to meet the lower SO2 emission limits. [Rule 62-

Regional Haze SIP for Florida 

Exhibit 2

Page 384 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A 

and B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 15 of 18 

296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 62-4.070(1)&(3) (Reasonable Assurance), and, 

Proposed by the Applicant in the Application] 

7. SO2 Controls: The permittee shall use the specific catalyst loadings and types as cited in the study by the 

permittee’s catalyst supplier in Appendix C of the Application. The specific catalyst loadings and types in 

Appendix C of the Application provide the permitting authority reasonable assurances of compliance with 

this permit. The study confirms that with the proposed modifications to each SAP, the SAPs can achieve the 

SO2 emission rates of 3.0 lb SO2/ton 100% H2SO4. Other specific catalyst types may be considered by the 

Bureau of Air Regulation upon written request. The permittee shall submit a written request for other 

specific catalyst loadings and types to the Bureau of Air Regulation with a copy to the Compliance Authority 

for review and approval prior to use. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 

62-4.070(1)&(3) (Reasonable Assurance), F.A.C.; and, Proposed by the Applicant in the Application] 

8. SAP Acid Mist Controls: This BART exemption determination does require new, modified or additional air 

pollution control systems for sulfuric acid mist (SAM). By controlling SAM emissions, PM/PM10 and visible 

emissions are minimized. To control emissions of SAM, the permittee shall install Brownian diffusion-type 

candles on SAPs 1 and 2, similar to the one employed on SAP No. 3. Other SAM control technologies may 

be considered by the Bureau of Air Regulation upon written request. The permittee shall submit a written 

request for other SAM control technologies to the Bureau of Air Regulation with a copy to the Compliance 

Authority for review and approval prior to use. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-

210.700(1), F.A.C.; and, Proposed by the Applicant in the Application] 

9. 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.] 

EMISSION STANDARDS AND LIMITATIONS 

10. PM, NOx and SO2 Standards: Particulate matter, nitrogen oxides and sulfur dioxide emissions shall not 

exceed the following emissions standards. 

EU ID 

No. Emissions Unit Description

Emissions Standards 

PM NOx SO2

-002 No.1 Sulfuric Acid Plant --- 16 lb/houra 400 lb/hourb

-003 No. 2 Sulfuric Acid Plant --- 16 lb/houra 400 lb/hourb

-004 No. 3 Sulfuric Acid Plant --- 16 lb/houra 400 lb/hourb

-009 DAP Plant No.1 15 lb/hour --- See Footnote “c”

-011 MAP Plant 7 lb/hour --- --- 

-027 AFI Plant 36.8 lb/hour --- See Footnote “c”

-036 Multifos A and B Kilns, 

Dryer and Blending 

Operation 

25 lb/hour --- 25 lb/hourc 

a. Nitrogen oxides (NOx) emissions from Nos. 1, 2, and 3 Sulfuric Acid Plants (EU-002, EU-003 and EU-004) 

shall not exceed 16 lb/hour {Permitting Note (for information purposes only): equivalent to 0.12 lb/ton of 

100% sulfuric acid at design capacity} based on a 3-hour average as determined by stack test data. 

Regional Haze SIP for Florida 

Exhibit 2

Page 385 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A 

and B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 16 of 18 

b. Sulfur dioxide emissions from Nos. 1, 2, and 3 Sulfuric Acid Plants (EU-002, EU-003 and EU-004) shall not 

exceed 400 lb/hour {Permitting Note (for information purposes only): equivalent to 3.0 lb/ton of 100% 

sulfuric acid at design capacity} based on a 24-hour (daily) block CEMS average. 

Permitting note (for information purposes only): SO2 emissions in lb/hour are equivalent to 3.0 lb/ton of 

100% sulfuric acid at design capacity. A 24-hour (daily) block average was established based on the 

emission rate averaging period of 24-hour (daily) used in the air dispersion modeling. No stack testing is 

required. 

c. To control sulfur dioxide emissions from the dryers, only natural gas shall be fired as a fuel. During periods 

of natural gas curtailments, No. 6 fuel oil or better grade fuel oil (as defined in Condition CC.20 in Permit 

1050059-045-AV) may be fired as a fuel. [Rules 62-4.070(3) and 62-296.340(5)(c) (escape BART), F.A.C.] 

11. Opacity Standards: Visible emissions from the Nos. 1, 2 and 3 Sulfuric Acid Plants (EU-002, EU-003 and 

EU-004) shall not exceed 10% opacity as determined by EPA Method 9. 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(5)(c) (escape BART), F.A.C.; and 40 CFR 60.83(a)2 and 40 CFR 60, Appendix A, Method 

9] 

12. SO2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an 

SO2 CEMS to be used to demonstrate continuous compliance with the SO2 emission standards and limitations 

specified in this section. 

a. In accordance with the NSPS (40 CFR 60, Subpart H) requirements for sulfuric acid plants, the permittee 

shall continue to properly calibrate, maintain, and operate a CEMS to measure and record emissions of 

SO2. 

b. A CEMS shall be properly calibrated, maintained, and operated to comply with: 40 CFR 60 Subpart A, 

General Provisions; 40 CFR 60 Appendix B, Performance Specification 2; and, 40 CFR 60, Appendix F, 

Quality Assurance Procedures for Gas CEMS Used for Compliance Determination. 

c. The emissions data collected with the certified CEMS shall be used to demonstrate continuous compliance 

with the standards and limitations specified in this section. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.; and, Proposed by the Applicant in the Application] 

13. SAM Emission Standards and Limitations: This BART determination specifies new SAM emission 

standards. Emissions of SAM shall not exceed the following as demonstrated by stack test data: 

SAP No. lb/hour 

1 6.7 

2 6.7 

3 6.7 

Emissions of SAM shall not exceed 6.7 pounds per hour for each of the three SAPs based on a 3-hour 

average as determined by stack test data. 

{The equivalent lb SAM/ton 100% H2SO4 values for SAP Nos. 1, 2, and 3 at design capacity for each SAP is 

0.05 lb SAM/ton 100% H2SO4. The equivalent lb/ton value corresponding to the lb/hour limits is less than 

the current existing standards. The equivalent tons per year (TPY) values for SAP Nos. 1, 2, and 3 is 29.3 

TPY. This permit requires stack test data to be used to demonstrate compliance. Compliance with the 3-hour 

average by stack test assures compliance with a numerical standard on a 24-hour (daily) average basis. The 

air dispersion modeling was performed using a 24-hour (daily) average.} 

Regional Haze SIP for Florida 

Exhibit 2

Page 386 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A 

and B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 17 of 18 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Proposed by the Applicant in the Application] 

EXCESS EMISSIONS 

14. Excess Emissions Prohibited: Excess emissions caused entirely or in part by poor maintenance, poor 

operation, or any other equipment or process failure that may reasonably be prevented during startup, 

shutdown or malfunction shall be prohibited. [Rule 62-210.700(4), F.A.C.] 

15. Excess Emissions Allowed: Unless otherwise specified by permit, excess emissions resulting from startup, 

shutdown or malfunction of any emissions unit shall be permitted providing (1) best operational practices to 

minimize emissions are adhered to and (2) the duration of excess emissions shall be minimized but in no case 

exceed two hours in any 24 hour period unless specifically authorized by the Department for longer duration. 

[Rule 62-210.700(1), F.A.C.] 

16. Excess Emissions Notification: In case of excess emissions resulting from malfunctions, the permittee shall 

notify the Compliance Authority in accordance with Rule 62-4.130, F.A.C. A full written report on the 

malfunctions shall be submitted in a quarterly report, if requested by the Department. [Rule 62-210.700(6), 

F.A.C.] 

17. Best Operational Practices to Minimize Excess Emissions:

a. The permittee shall follow the best operational practices to minimize excess emissions during startup and 

shutdown as described in the most recent Title V permit. 

b. Best operational practices to minimize excess SO2 and SO3 emissions during startup are governed by this 

condition. The permittee shall follow the best operational practices to minimize excess emissions during 

startup contained within the attached Appendix D - Memorandum of Understanding Regarding Best 

Operational Start-up Practices for Sulfuric Acid Plants initially executed on October 25, 1989. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Title V Permit No. 

1050059-045-AV] 

18. Best Operational Practices to Minimize Leaks of SO2 and SO3, or Other Fugitive Process Emissions: Best 

operational practices to minimize leaks of SO2 and SO3, or other fugitive process emissions shall be adhered 

to and shall include regular inspections and the prompt repair or correction of any leaks or other fugitive 

emissions. [Rules 62-4.070(1)&(3) and 62-296.320, F.A.C.] 

EMISSIONS TESTING 

19. Test Methods: The following reference methods (or more recent versions) shall be used to conduct any 

required emissions tests. 

Method Description of Method and Comments 

1 - 4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 

5 Determination of PM Emissions from Stationary Sources 

6 or 6C Determination of SO2 Emissions from Stationary Sources 

7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure) 

8 Determination of SAM and SO2 Emissions from Stationary Sources 

9 Visual Determination of Opacity from Stationary Sources 

EPA Methods 1, 2, 3 and 4 shall be used as necessary to support the other test methods. The above methods 

Regional Haze SIP for Florida 

Exhibit 2

Page 387 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). SAP Nos. 1, 2 and 3, DAP Plant No. 1, MAP Plant, AFI Plant and Multifos A 

and B Kilns, Dryer and Blending Operation 

Mosaic Fertilizer, LLC Draft Permit No. 1050059-061-AC 

New Wales Facility BART Exemption Project 

Page 18 of 18 

are described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. No 

other methods shall be used without prior written approval from the Permitting Authority. [Rules 62-204.800 

and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

20. Standard Testing Requirements: All required emissions tests shall be conducted in accordance with the 

requirements specified in Appendix C (Standard Testing Requirements) of this permit. [Rules 62-204.800 

and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

21. Compliance Test Schedule: In accordance with the following schedule, the permittee shall have stack tests 

conducted to demonstrate compliance with the emissions standards specified in this permit. 

a. Initial Test: On or before April 30, 2013, an initial test shall be conducted for NOx and SAM emissions 

from each SAP and PM emissions from DAP Plant No. 1, MAP Plant and the AFI Plant. On or before 

April 30, 2013, an initial test shall be conducted for SO2 and PM emissions from Multifos A and B Kilns, 

Dryer and Blending Operation. The initial compliance test report for NOx, SO2, SAM and PM shall be 

submitted within 45 days of completion of testing. [Rules 62-296.340(5)(c) (escape BART) and 62-

297.310(7)(a)1, F.A.C.] 

b. Initial and Special Test: A visible emissions (VE) test shall be conducted concurrently with one run of 

the SAM stack test to demonstrate initial compliance with the existing VE standards after the proposed 

work has been completed for each SAP. The VE test results shall be submitted with the SAM stack test 

report. [Rules 62-4.070(1)&(3) and 62-297.310(7)(b), F.A.C.] 

c. Tests Prior to Renewal: Within the 12-month period prior to renewing the Title V air operation permit, 

tests shall be conducted for SAM and NOx emissions from each SAP.

[Rules 62-296.340(5)(c) (escape BART), and 62-297.310(7)(a)3, F.A.C.] 

{Note: Under this permit SO2 CEMS are required to demonstrate compliance on a continuous basis, 

therefore, no initial or annual compliance test for SO2 is necessary on the SAPs.} 

RECORDS AND REPORTS 

22. Quarterly Reporting Requirements: The owners or operators of facilities for which monitoring is required 

shall submit to the Department a written report of emissions in excess of emission limiting standards as set 

forth in Rule 62-296.402, F.A.C., for each calendar quarter. The nature and cause of the excessive emissions 

shall be explained. This report does not relieve the owner or operator of the legal liability for violations. All 

recorded data shall be maintained on file by the Source for a period of 5 (five) years. {The permittee is 

required to use SO2 continuous emissions monitoring systems for continuous compliance demonstrations.} 

[Rules 62-296.402(5) and 62-213.440(1)(b)2., F.A.C.] 

23. Construction Plan and Progress Reports: The permittee shall submit a Construction Plan within sixty (60) 

days of January 1, 2010 which shall contain the necessary milestones to comply with this permit. The Plan 

shall include at a minimum the necessary actions and corresponding scheduled due dates to complete those 

actions to comply with this permit. 

a. The permittee shall submit progress reports based on the anniversary date (one year from the effective 

date) of this permit regarding the status of the milestones in the Construction Plan to the Department and 

to the Compliance Authority, no less than annually in 2010 - 2013. 

b. The permittee shall complete all required construction and modifications no later than June 30, 2013. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.]

Regional Haze SIP for Florida 

Exhibit 2

Page 388 of 501
E. Mosaic – Riverview 

Regional Haze SIP for Florida 

Exhibit 2

Page 389 of 501
Mosaic Riverview BART Exemption Modeling 

Mosaic Riverview specifically made changes to reduce sulfur dioxide (SO2) and sulfuric acid 

mist, as contained in this permit, to meet exemption criteria in the Best Available Retrofit 

Technology (BART) rule (62-296.340, F.A.C.). Taking into consideration these emission 

reductions, Mosaic completed air quality modeling consistent with an approved modeling 

protocol submitted to the department. The EPA-approved CALPUFF dispersion model was used 

to determine visibility impacts on all federal Class I areas within 300 kilometers of the facility 

using three years of meteorological data derived from the MM5 meteorological model. This 

modeling was thoroughly reviewed by the department and determined to be appropriate for the 

purpose of meeting the exemption criteria of the BART rule. 

Visibility impacts were completed for three federal Class I areas: Chassahowitzka National 

Wilderness Area, located 87 kilometers from the facility; Everglades National Park (239 

kilometers); and, St. Marks National Wilderness Area (291 kilometers). The controlling area, 

that is the area with the greatest visibility impact from Mosaic Riverview, is Chassahowitzka. 

BART exemption modeling considered only the impacts from the BART-eligible sources within 

the facility. In this case, the 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. The results of the modeling for 

the controlling Chassahowitzka area is shown below as taken from the complete modeling report 

submitted by Mosaic. 

The maximum visibility impact at any of the three federal Class I areas is 0.494 deciviews (dv). 

This value is less than the criterion for exemption from the BART rule of 0.5 dv. Based on the 

emission changes made in this permit and the modeling performed by the applicant, the 

department concludes that the BART-eligible source at Mosaic Riverview is exempt from the 

BART rule requirements. 

 

Regional Haze SIP for Florida 

Exhibit 2

Page 390 of 501
PERMITTEE 

Mosaic Fertilizer, LLC 

8813 U.S. Highway 41 South 

Riverview, FL 33569 

Authorized Representative: 

Mr. Alan Lulf, Plant Manager 

Air Permit No. 0570008-061-AC 

Expiration Date: June 30, 2013

Riverview Facility 

BART Exemption Project 

PLANT AND LOCATION 

The Mosaic Fertilizer, LLC operates the Riverview Facility, which is a located at 8813 U.S. Highway 41 South, 

Riverview in Hillsborough County, Florida. The facility is an existing phosphate fertilizer manufacturer, which 

is identified by Standard Industrial Classification (SIC) code No. 2874. 

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.). 

Pursuant to Rule 62-296.340(5)(c) (escape Best Available Retrofit Technology (BART)), F.A.C., the permittee 

shall install the air pollution control equipment and/or implement the air pollution control measures that are 

specified by this permit to be exempt from a BART determination. 

EFFECTIVE DATE 

Unless otherwise specified by this permit, the affected emissions units shall comply with the conditions of this 

permit as expeditiously as practicable, but not later than the expiration date of this permit. [Rule 62-

296.340(3)(b)2., F.A.C.] 

Executed in Tallahassee, Florida 

___________________________________ _______________ 

Joseph Kahn, Director Effective Date 

Division of Air Resource Management 

JK/tlv/jkh/sms 

Regional Haze SIP for Florida 

Exhibit 2

Page 391 of 501
SECTION 1. GENERAL INFORMATION

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 2 of 13 

FACILITY DESCRIPTION

This facility consists of several industrial processes that convert insoluble rock containing phosphorus ore into a 

soluble form suitable for agricultural use. The processes consist of a molten sulfur storage & handling system, 

one material handling system, three (3) sulfuric acid plants, one (1) phosphoric acid plant (two trains), two (2) 

diammonium phosphate (DAP) plants, two (2) monoammonium phosphate (MAP) plants, one auxiliary boiler, and 

two (2) animal feed plants. 

FACILITY REGULATORY CLASSIFICATIONS 

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

• The facility does not operate emissions 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. 

AFFECTED EMISSIONS UNITS

This permitting action affects the following emissions units at the plant: 

EU ID 

No. 

Brief Description 

-022 No. 3 MAP Plant 

-023 No. 4 MAP Plant 

-024 South Cooler 

-063 Molten Sulfur Storage and Handling System -- Storage Tank Nos. 1, 2 and 3

-066 Molten Sulfur Storage and Handling System -- Storage Pit No. 7 

-067 Molten Sulfur Storage and Handling System -- Storage Pit No. 8 

-068 Molten Sulfur Storage and Handling System -- Storage Pit No. 9 

-004 No. 7 Sulfuric Acid Plant 

-005 No. 8 Sulfuric Acid Plant 

-006 No. 9 Sulfuric Acid Plant 

Regional Haze SIP for Florida 

Exhibit 2

Page 392 of 501
SECTION 1. GENERAL INFORMATION

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 3 of 13 

CONTENTS 

Section 1. General Information 

Section 2. Administrative Requirements 

Section 3. Emissions Units Specific Conditions 

Section 4. Appendices 

Appendix A. Citation Formats 

Appendix B. General Conditions 

Appendix C. Standard Testing Requirements 

Appendix D. Memorandum of Understanding Regarding Best Operational Start-up Practices for 

Sulfuric Acid Plants

Regional Haze SIP for Florida 

Exhibit 2

Page 393 of 501
SECTION 2. ADMINISTRATIVE REQUIREMENTS 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 4 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. 

2. Compliance Authority: All documents related to compliance activities such as reports, tests, and 

notifications shall be submitted to the Compliance Authority, the Environmental Protection 

Commission of Hillsborough County (EPCHC). The Compliance Authority’s mailing address is: 

Environmental Protection Commission Hillsborough County 

3629 Queen Palm Drive 

Tampa, Florida 33619 

Telephone: 813/627-2600, Fax: 813/627-2660 

3. Appendices: The following Appendices are attached as part of this permit: Appendix A (Citation 

Formats); Appendix B (General Conditions); Appendix C (Standard Testing Requirements); and, 

Appendix D (Memorandum of Understanding Regarding Best Operational Start-up 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 Air Operation 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 air operation permit is required for regular operation of the permitted emissions unit. 

The permittee shall apply for a Title V air operation permit at least 90 days prior to expiration of this 

permit, but no later than 180 days after completing the required work and commencing operation. To 

apply for a Title V operation 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 Permitting Authority, the Florida Department of Environmental 

Protection, Southwest District Office which is different from the Office cited in Condition No. 1

with copies to the Compliance Authority. The mailing address for the Southwest District Office is: 

Florida Department of Environmental Protection Southwest District 

13051 North Telecom Parkway 

Temple Terrace, FL 33637-0926 

Telephone: 813/632-7600, Fax: 813/744-6458 

[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 (five) 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 (AOR): 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 May 1, 2009 and April 1st of each year, thereafter. [Rule 62-210.370(3), 

F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 394 of 501
SECTION 2. ADMINISTRATIVE REQUIREMENTS 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 5 of 13 

NEW & PREVIOUS PERMIT SPECIFIC CONDITIONS 

8. Pursuant to Rule 62-296.340(5)(c) (escape BART), F.A.C., the specific terms and conditions of this 

permit are required in order to escape a Best Available Retrofit Technology Determination. These 

specific terms and conditions apply to each emissions unit and are in addition to any other applicable 

standards. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Proposed by the Applicant in the Application; 

and, Rules 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), 

F.A.C.] 

9. A relaxation of the specific terms and conditions of this permit may subject the facility to a BART 

determination. Any request to change the specific terms and conditions of this permit must be submitted 

to the Bureau of Air Regulation in the Division of Air Resource Management of the Florida Department 

of Environmental Protection. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Rules 62-

4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), F.A.C.] 

10. Some of the proposed work under this project to escape a BART determination is also permitted under a 

PSD avoidance permit, Permit No. 0570008-060-AC. A relaxation of the specific terms and conditions 

of this permit may subject the facility to a BART and/or a BACT determination. A copy of any request 

to change the specific terms and conditions of Permit No. 0570008-060-AC must be submitted to the 

Bureau of Air Regulation in the Division of Air Resource Management of the Florida Department of 

Environmental Protection. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Rules 62-4.070(1)&(3) 

(Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), F.A.C.] 

11. No emissions unit or facility subject to this permit shall be constructed or modified without obtaining the 

appropriate air construction permit from the Department. Such permit shall be obtained prior to 

beginning construction or modification. [Rules 62-210.300(1) and 62-212.300(1)(a), F.A.C.] 

12. Source Obligation: 

(a) Authorization to construct shall expire if construction is not commenced within 18 months after 

receipt of the permit, if construction is discontinued for a period of 18 months or more, or if 

construction is not completed within a reasonable time. This provision does not apply to the time 

period between construction of the approved phases of a phased construction project except that each 

phase must commence construction within 18 months of the commencement date established by the 

Department in the permit. [Rule 62-212.400(12)(a), F.A.C.] 

(b) At such time that a particular source or modification becomes a major stationary source or major 

modification (as these terms were defined at the time the source obtained the enforceable limitation) 

solely by virtue of a relaxation in any enforceable limitation which was established after August 7, 

1980, on the capacity of the source or modification otherwise to emit a pollutant, such as a restriction 

on hours of operation, then the requirements of subsections 62-212.400(4) through (12), F.A.C., shall 

apply to the source or modification as though construction had not yet commenced on the source or 

modification. [Rule 62-212.400(12)(b), F.A.C.] 

(c) At such time that a particular source or modification becomes a major stationary source or major 

modification (as these terms were defined at the time the source obtained the enforceable limitation) 

solely by exceeding its projected actual emissions, then the requirements of subsections 62-

212.400(4) through (12), F.A.C., shall apply to the source or modification as though construction had 

not yet commenced on the source or modification. [Rule 62-212.400(12)(c), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 395 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

A. No. 3 MAP Plant, No. 4 MAP Plant, South Cooler (EU-022, -023, -024) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 6 of 13 

This subsection addresses the following affected emissions units: 

EU ID 

No. 

Emissions Unit Description 

-022 

-023 

-024 

No. 3 MAP Plant 

No. 4 MAP Plant 

South Cooler 

PERMANENTLY SHUTDOWN EMISSIONS UNITS 

1. Permanent Shutdown: The permittee permanently shutdown the Nos. 3 & 4 MAP Plant and the South Cooler 

(Emission unit identification numbers (EU ID Nos.) -022, -023 & -024) in September 2004. These emissions 

units are included in the current Title V air operation permit, Permit Number 0570008-051-AV, effective 

October 27, 2008. As part of this BART exemption determination, these units are not allowed to operate. 

These units were not included in the applicant’s BART analysis. Since these units are deemed to be 

permanently shutdown, a BART analysis was not required for these units. If any of these units resume 

operations, a BART analysis shall be performed as though they had not been shutdown. Other 

preconstruction review requirements may apply. [Rule 62-296.340(5)(c) (escape BART), F.A.C. and 

Applicant’s Request dated January 31, 2007] 

2. Notification of Removal: The permittee shall notify the Department’s Bureau of Air Regulation, SWD 

Office and the Compliance Authority upon the physical removal of these emissions units from on-site. [Rule 

62-296.340(5)(c) (escape BART), F.A.C. and Applicant’s Request dated January 31, 2007]

Regional Haze SIP for Florida 

Exhibit 2

Page 396 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

B. Molten Sulfur Storage and Handling System -- Storage Tank Nos. 1, 2 & 3 (EU-063) and Storage Pit 

Nos. 7, 8, and 9 (EU-066, -067, -068) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 7 of 13 

EU ID 

No. 

Emissions Unit Description 

-063 

-066 

-067 

-068 

Molten Sulfur Storage and Handling System -- Storage Tank Nos. 1, 2 and 3 

Molten Sulfur Storage and Handling System -- Storage Pit No. 7

Molten Sulfur Storage and Handling System -- Storage Pit No. 8 

Molten Sulfur Storage and Handling System -- Storage Pit No. 9

Descriptions: 

The Molten Sulfur Storage and Handling System consists of storage tank nos. 1, 2 and 3 (capacity 

of 19,845 tons each), covered storage pit nos. 7, 8 and 9 (capacity of 127 tons, 127 tons, and 160 

tons respectively), a ship unloading dock, truck loading station and associated transfer pumps and 

piping for storage and handling of molten sulfur. 

Molten sulfur from ships may be transferred to any combination of the three molten sulfur storage 

tanks at a combined maximum total of 2,277,081 tons of molten sulfur per any consecutive 12-

month period. These tanks then transfer molten sulfur to the molten sulfur storage pits at the 

sulfuric acid plants (SAPs) and also to the molten sulfur truck loading station. 

The three molten sulfur storage pits are located at the three sulfuric acid plants. The pits receive 

molten sulfur from the molten sulfur storage tanks and/or by truck. Each of the storage pits may 

receive molten sulfur at a constant rate of 336 tons per hour. Each storage pit is allowed to transfer 

molten sulfur to each SAP at a maximum throughput rate of 492,361 tons per consecutive 12-month 

period. 

Initial construction of the three molten sulfur storage tanks and three molten sulfur storage pits was 

before August 7, 1977. 

Air Pollution Control Systems and Measures: A wet scrubber is currently used to control 

particulate matter (PM) emissions from the molten sulfur storage tank nos. 1, 2 and 3 as well as the 

truck loading station. Emissions from loading the three molten sulfur storage pits are uncontrolled, 

although they are equipped with covers. 

Monitoring: The scrubber pressure drop and liquid flow rate are recorded once every 8-hour shift. 

{Permitting notes: These emissions units are currently regulated under Rule 62-212.400, F.A.C., Prevention of 

Significant Deterioration (PSD) PSD-FL-315/0570008-036-AC; Rule 62-296.320, F.A.C., General Pollutant 

Emission Limiting Standards; and Rule 62-296.411, F.A.C., Sulfur Storage and Handling Facilities.}

ESSENTIAL POTENTIAL TO EMIT (PTE) PARAMETERS 

1. Molten sulfur from ships may be transferred to any combination of the three molten sulfur storage tanks at a 

combined maximum total not to exceed 2,277,081 tons of molten sulfur per any consecutive 12-month 

period. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 62-4.070(1)&(3) (Reasonable 

Assurance), and, Proposed by the Applicant in the Application] 

2. Each storage pit is allowed to transfer molten sulfur to each SAP at a maximum throughput rate of 492,361 

tons per consecutive 12-month period. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) 

and 62-4.070(1)&(3) (Reasonable Assurance), and, Proposed by the Applicant in the Application] 

Regional Haze SIP for Florida 

Exhibit 2

Page 397 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

C. Nos. 7, 8 and 9 Sulfuric Acid Plants (EU-004, -005, -006) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 8 of 13 

This subsection addresses the following affected emissions units: 

EU ID 

No. 

Emissions Unit Description 

-004 

-005 

-006 

No. 7 Sulfuric Acid Plant 

No. 8 Sulfuric Acid Plant 

No. 9 Sulfuric Acid Plant 

Descriptions: 

Sulfuric Acid Plants (SAPs) No. 7, No. 8 and No. 9 have a design capacity of 3,200 tons per day 

(TPD), 2,700 TPD, and 3,400 TPD of 100% sulfuric acid, respectively. Each SAP recovers a 

portion of the waste heat (steam) for process use and to generate electricity. Waste heat recovery 

reduces plume visibility. There are two electrical generators at each SAP, rated at 35 kilowatts 

(kW) and 36 kW for a total of 71 kW. These plants are sulfur burning, double conversion, double 

absorption plants of Leonard-Monsanto design. Sulfur is burned with dried atmosphere oxygen to 

produce sulfur dioxide (SO2). The sulfur dioxide is catalytically oxidized to sulfur trioxide (SO3) 

over a catalyst bed. The sulfur trioxide is then absorbed in sulfuric acid. The remaining sulfur 

dioxide, not previously oxidized, is passed over a final converter bed of catalyst and the sulfur 

trioxide produced is then absorbed in sulfuric acid. SAP Nos. 7, 8 and 9 began operating in 1961, 

1965, 1974, respectively. 

Air pollution control systems and measures: The control of SO2 emissions is primarily by the 

process itself. Currently, a double conversion, double absorption plant efficiently converts SO2 to 

SO3 then SO3 reacts in a mixture of water and sulfuric acid to produce sulfuric acid. In a double 

absorption system, the conversion efficiency from SO2 to SO3 is at least 99.7%. All three plants use 

a vanadium catalyst in the converters, except that in the 4th pass of the SAP No. 9 a cesium 

promoted catalyst is used. The current catalyst bed volumes in the No. 7 SAP are 102,000 liters in 

the 1st pass, 112,000 liters in the 2nd pass, 155,000 liters in the 3rd pass, and 209,000 liters in the 4th

pass; for a total of 578,000 liters. The current total catalyst volume in the No. 8 SAP is 472,000 

liters. The current total catalyst volume in the No. 9 SAP is 508,000 liters. Sulfuric acid mist 

(SAM) emissions are controlled by the use of high efficiency acid mist eliminators (demister pads) 

or impaction-type glass fiber collection devices. Best operational practices are followed to 

minimize excess emissions during startup and shutdown. 

Monitors: Each SAP is equipped with an existing SO2 continuous emissions monitoring system 

(CEMS). The SO2 CEMS have been required by the circa 1977 Standards of Performance for New 

Stationary Sources (NSPS). The CEMS installed for SAP No. 7 is an Ametek Model 4600B. SAP 

Nos. 8 and 9 each have an Ametek/Dupont Model 40/460 CEMS. 

Stack Parameters: Emissions not absorbed by each double absorption system are vented through 

each individual SAP’s 150 foot stack. The stack exhaust gas characteristics for SAP Nos. 7, 8 and 9 

are: exhaust gas temperatures of 170, 150 & 152 oF; exhaust gas flow rates 122,000, 105,000 & 

149,000 acfm; and, stack diameters of 7.5, 8.0 & 9.0 feet. 

{Permitting notes: The SAPs are currently regulated under NSPS 40 CFR 60, Subpart H, Standards of 

Performance for Sulfuric Acid Plants, adopted and incorporated by reference in Rule 62-204.800(7)(b)10., 

F.A.C.; Rule 62-212.400, F.A.C., Prevention of Significant Deterioration (PSD), PSD-FL-209 (AC29-241660) - 

1

st BACT for SAP Nos. 8 & 9, PSD-FL-250 (0570008-025-AC) - 1st BACT for SAP No. 7, PSD-FL-315 (0570008-

Regional Haze SIP for Florida 

Exhibit 2

Page 398 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

C. Nos. 7, 8 and 9 Sulfuric Acid Plants (EU-004, -005, -006) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 9 of 13 

036-AC) - 2ndBACT for SAP Nos. 8 & 9; Rule 62-296.402, F.A.C., Sulfuric Acid Plants; and, Rule 62-296.320, 

F.A.C., General Pollutant Emission Limiting Standards.} 

ESSENTIAL POTENTIAL TO EMIT (PTE) PARAMETERS 

1. Design Capacity: The existing design capacity of each SAP shall not be changed as a result of the proposed 

work under this project, Permit No. 0570008-061-AC. The existing design capacity of each SAP shall not 

exceed the following: 

SAP No. Design Production Capacity, 

TPD of 100% H2SO4 (sulfuric acid) 

7 3,200 

8 2,700 

9 3,400 

[Rules 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

2. Design Capacity: Any request to change the design capacity of each SAP must be submitted to the Bureau of 

Air Regulation in the Division of Air Resource Management of the Florida Department of Environmental 

Protection. [Rules 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

3. Design Capacity & Permitted Production: The permittee shall submit a statement from the responsible 

official within 30 days after the completion of all of the proposed work under this project indicating whether 

or not in fact the design capacity or permitted production of each SAP was changed. [Rules 62-4.160(2) and 

62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

AIR POLLUTION CONTROL TECHNOLOGIES & MEASURES 

4. SO2 Controls: This BART exemption determination does require new, modified or additional air pollution 

control systems for SO2. To control emissions of sulfur dioxide (SO2) from each SAP, the permittee shall 

continue the use of the existing double absorption system technology with vanadium and/or cesium catalyst 

in the converters and the use of good combustion practices & best operational practices to minimize excess 

emissions during startup and shutdown. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-

210.700(1), F.A.C.; and, Proposed by the Applicant in the Application] 

5. Proposed Work: The applicant is required to perform the following specific work activities under this project 

in order to escape BART: 

SAP No. Work Activities 

7 • Increase the catalyst loading ratio from approximately 181 liters per ton H2SO4 per day 

(L/TPD) to approximately 202 L/TPD {increases the current catalyst loading from 

approximately 578,000 liters to approximately 647,000 liters}; and, 

• Replace the cold gas-to-gas heat exchanger. 

8 • Increase the catalyst loading ratio from approximately 175 L/TPD to approximately 213 

L/TPD {increases the current catalyst loading from approximately 472,000 liters to 

approximately 575,000 liters. The 468,000 liters cited in the study was with the 

existing converter}; 

• Replace the cold gas-to-gas heat exchanger; 

• Replace the superheater; and, 

• Replace the converter with a larger one. 

Note: These work activities are permitted under Permit No. 0570008-060-AC. 

Regional Haze SIP for Florida 

Exhibit 2

Page 399 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

C. Nos. 7, 8 and 9 Sulfuric Acid Plants (EU-004, -005, -006) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 10 of 13 

9 • Increase the catalyst loading ratio from approximately 149 L/TPD to approximately 195 

L/TPD {increases the current catalyst loading from approximately 508,000 liters to 

approximately 663,000 liters}; and, 

• Install a heat recovery system (HRS) to replace the interpass absorption (IPA) tower. 

Additional catalyst may be added as necessary in order to meet the BART SO2 emission limits. [Rule 62-

296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 62-4.070(1)&(3) (Reasonable Assurance), and, 

Proposed by the Applicant in the Application] 

6. SO2 Controls: The permittee shall use the specific catalyst loadings & types as cited in the study by the 

permittee’s catalyst supplier in Appendix C of the Application. The specific catalyst loadings & types in 

Appendix C of the Application provide the permitting authority reasonable assurances of compliance with 

this permit. The study confirms that with the proposed modifications to each SAP, the SAPs can achieve the 

SO2 emission rates of 2.8 to 3.0 lb SO2/ton 100% H2SO4. Other specific catalyst types may be considered by 

the Bureau of Air Regulation upon written request. The permittee shall submit a written request for other 

specific catalyst loadings & types to the Bureau of Air Regulation with a copy to the Compliance Authority 

for review and approval prior to use. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 

62-4.070(1)&(3) (Reasonable Assurance), F.A.C.; and, Proposed by the Applicant in the Application] 

7. SAM Controls: This BART exemption determination does not require new, modified or additional air 

pollution control systems for SAM. By controlling sulfuric acid mist (SAM) emissions PM/PM10 and visible 

emissions are minimized. To control emissions of SAM, the permittee shall continue the use of the existing 

packed-fiber mist eliminators or demister pads to remove SAM. Other SAM control technologies may be 

considered by the Bureau of Air Regulation upon written request. The permittee shall submit a written 

request for other SAM control technologies to the Bureau of Air Regulation with a copy to the Compliance 

Authority for review and approval prior to use. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-

210.700(1), F.A.C.; and, Proposed by the Applicant in the Application] 

8. 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.] 

EMISSION STANDARDS & LIMITATIONS 

9. SO2 Emission Standards & Limitations: This BART determination specifies new SO2 emission standards. 

Emissions of SO2 shall not exceed the following as determined by certified CEMS data: 

SAP No. lb/hour 

7 400 

8 315 

9 425 

Emissions of SO2 shall not exceed 400 pounds per hour for No. 7 SAP, 315 pounds per hour for No. 8 SAP, 

and 425 pounds per hour for No. 9 SAP based on a 24-hour (daily) block average as determined by CEMS 

data. 

{The equivalent lb SO2/ton 100% H2SO4 values for SAP Nos. 7, 8 and 9 at design capacity are: 3.0 lb 

SO2/ton 100% H2SO4; 2.8 lb SO2/ton 100% H2SO4; and, 3.0 lb SO2/ton 100% H2SO4, respectively. The 

equivalent lb/ton values corresponding to the lb/hour limits are less than the current existing standards. The 

equivalent tons per year (TPY) values for SAP Nos. 7, 8 and 9 are: 1,752 TPY; 1,380 TPY; and, 1,862 TPY, 

respectively. This permit requires CEMS to be used to demonstrate compliance on a continuous basis on a 

Regional Haze SIP for Florida 

Exhibit 2

Page 400 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

C. Nos. 7, 8 and 9 Sulfuric Acid Plants (EU-004, -005, -006) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 11 of 13 

24-hour (daily) block average. A 24-hour (daily) block average was established based on the emission rate 

averaging period of 24-hour (daily) used in the air dispersion modeling.} 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Proposed by the Applicant in the Application] 

10. SO2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an 

SO2 CEMS to be used to demonstrate continuous compliance with the SO2 emission standards and limitations 

specified in this section. 

a. In accordance with the NSPS (40 CFR 60, Subpart H) requirements for sulfuric acid plants, the permittee 

shall continue to properly calibrate, maintain, and operate a CEMS to measure and record emissions of 

SO2. In accordance with PSD-FL-250 & PSD-FL-315, the permittee shall continue to use SO2 CEMS data 

to demonstrate compliance. 

b. A CEMS shall be properly calibrated, maintained, and operated to comply with: 40 CFR 60 Subpart A, 

General Provisions; 40 CFR 60 Appendix B, Performance Specification 2; and, 40 CFR 60, Appendix F, 

Quality Assurance Procedures for Gas CEMS Used for Compliance Determination. 

c. The emissions data collected with the certified CEMS shall be used to demonstrate continuous compliance 

with the standards and limitations specified in this section. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.; and, Proposed by the Applicant in the Application] 

11. SAM Emission Standards & Limitations: This BART determination specifies new SAM emission standards. 

Emissions of SAM shall not exceed the following as demonstrated by stack test data: 

SAP No. lb/hour 

7 6.7 

8 5.6 

9 7.1 

Emissions of SAM shall not exceed 6.7 pounds per hour for No. 7 SAP, 5.6 pounds per hour for No. 8 SAP, 

and 7.1 pounds per hour for No. 9 SAP based on a 3-hour average as determined by stack test data. 

{The equivalent lb SAM/ton 100% H2SO4 values for SAP Nos. 7, 8 and 9 at design capacity for each SAP is 

0.05 lb SAM/ton 100% H2SO4. The equivalent lb/ton value corresponding to the lb/hour limits is less than 

the current existing standards. The equivalent tons per year (TPY) values for SAP Nos. 7, 8 and 9 are: 29.3 

TPY; 24.5 TPY; and, 31.1 TPY, respectively. This permit requires stack test data to be used to demonstrate 

compliance. Compliance with the 3-hour average by stack test assures compliance with a numerical standard 

on a 24-hour (daily) average basis. The air dispersion modeling was performed using a 24-hour (daily) 

average.} 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Proposed by the Applicant in the Application] 

EXCESS EMISSIONS 

12. Excess Emissions Prohibited: Excess emissions caused entirely or in part by poor maintenance, poor 

operation, or any other equipment or process failure that may reasonably be prevented during startup, 

shutdown or malfunction shall be prohibited. [Rule 62-210.700(4), F.A.C.] 

13. Excess Emissions Allowed: Unless otherwise specified by permit, excess emissions resulting from startup, 

shutdown or malfunction of any emissions unit shall be permitted providing (1) best operational practices to 

minimize emissions are adhered to and (2) the duration of excess emissions shall be minimized but in no case 

Regional Haze SIP for Florida 

Exhibit 2

Page 401 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

C. Nos. 7, 8 and 9 Sulfuric Acid Plants (EU-004, -005, -006) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 12 of 13 

exceed two hours in any 24 hour period unless specifically authorized by the Department for longer duration. 

[Rule 62-210.700(1), F.A.C.] 

14. Excess Emissions Notification: In case of excess emissions resulting from malfunctions, the permittee shall 

notify the Compliance Authority in accordance with Rule 62-4.130, F.A.C. A full written report on the 

malfunctions shall be submitted in a quarterly report, if requested by the Department. [Rule 62-210.700(6), 

F.A.C.] 

15. Best Operational Practices to Minimize Excess Emissions:

a. The permittee shall follow the best operational practices to minimize excess emissions during startup and 

shutdown as described in the most recent Title V permit application. 

b. Best operational practices to minimize excess SO2 and SO3 emissions during startup are governed by this 

condition. The permittee shall follow the best operational practices to minimize excess emissions during 

startup contained within the attached Appendix D - Memorandum of Understanding Regarding Best 

Operational Start-up Practices for Sulfuric Acid Plants initially executed on October 25, 1989. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Proposed by the Applicant 

in the Application] 

16. Best Operational Practices to Minimize Leaks of SO2 and SO3, or Other Fugitive Process Emissions: Best 

operational practices to minimize leaks of SO2 and SO3, or other fugitive process emissions shall be adhered 

to and shall include regular inspections and the prompt repair or correction of any leaks or other fugitive 

emissions. [Rules 62-4.070(1)&(3) and 62-296.320, F.A.C.] 

EMISSIONS TESTING 

17. Test Methods: The following reference methods (or more recent versions) shall be used to conduct any 

required emissions tests. 

Method Description of Method and Comments 

1 - 4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 

6 or 6C Determination of SO2 Emissions from Stationary Sources 

8 Determination of SAM & SO2 Emissions from Stationary Sources 

9 Visual Determination of Opacity from Stationary Sources 

EPA Methods 1, 2, 3, 4 and 19 shall be used as necessary to support the other test methods. The above 

methods are described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. 

No other methods shall be used without prior written approval from the Permitting Authority. [Rules 62-

204.800 and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

18. Standard Testing Requirements: All required emissions tests shall be conducted in accordance with the 

requirements specified in Appendix C (Standard Testing Requirements) of this permit. [Rules 62-204.800 

and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

19. Compliance Test Schedule: In accordance with the following schedule, the permittee shall have stack tests 

conducted to demonstrate compliance with the emissions standards specified in this permit. 

a. Initial Test: On or before April 30, 2013, an initial test shall be conducted for SAM emissions from each 

SAP {June 30, 2013 -2 months.}. The initial compliance test report for SAM shall be submitted within 

Regional Haze SIP for Florida 

Exhibit 2

Page 402 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

C. Nos. 7, 8 and 9 Sulfuric Acid Plants (EU-004, -005, -006) 

Mosaic Fertilizer, LLC Final Permit No. 0570008-061-AC 

Riverview Facility BART Exemption Project 

Page 13 of 13 

45 days of completion of testing. [Rules 62-296.340(5)(c) (escape BART) and 62-297.310(7)(a)1, 

F.A.C.] 

b. Initial & Special Test: A visible emissions (VE) test shall be conducted concurrently with one run of the 

SAM stack test to demonstrate initial compliance with the existing VE standards after the proposed work 

has been completed for each SAP. The VE test results shall be submitted with the SAM stack test report. 

[Rules 62-4.070(1)&(3) and 62-297.310(7)(b), F.A.C.] 

c. Tests Prior to Renewal: Within the 12-month period prior to renewing the Title V air operation permit, 

tests shall be conducted for SAM emissions from each SAP. [Rules 62-296.340(5)(c) (escape BART), 

and 62-297.310(7)(a)3, F.A.C.] 

{Note: Under this permit SO2 CEMS are required to demonstrate compliance on a continuous basis, 

therefore, no initial or annual compliance tests are necessary.} 

RECORDS & REPORTS 

20. Quarterly Reporting Requirements: The owners or operators of facilities for which monitoring is required 

shall submit to the Department a written report of emissions in excess of emission limiting standards as set 

forth in Rule 62-296.402, F.A.C., for each calendar quarter. The nature and cause of the excessive emissions 

shall be explained. This report does not relieve the owner or operator of the legal liability for violations. All 

recorded data shall be maintained on file by the Source for a period of 5 (five) years. {The permittee is 

required to use SO2 continuous emissions monitoring systems for continuous compliance demonstrations.} 

[Rules 62-296.402(5) and 62-213.440(1)(b)2., F.A.C.] 

21. Construction Plan & Progress Reports: The permittee shall submit a Construction Plan within sixty (60) days 

of the effective date of this permit which shall contain the necessary milestones to comply with this permit. 

The Plan shall include at a minimum the necessary actions and corresponding scheduled due dates to 

complete those actions to comply with this permit. 

a. The permittee shall submit progress reports based on the anniversary date (one year from the effective 

date) of this permit regarding the status of the milestones in the Construction Plan to the Department and 

to the Compliance Authority, no less than annually in 2009 - 2013. 

b. The permittee shall complete all required construction & modifications no later than June 30, 2013. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 403 of 501
F. CF Industries 

Regional Haze SIP for Florida 

Exhibit 2

Page 404 of 501
CF Industries BART Exemption Modeling 

CF Industries has made federally enforceable changes to its operating permits to reduce 

emissions of visibility-impairing pollutants in order to meet the exemption criterion for the Best 

Available Retrofit Technology (BART) rule (62-296.340(5), F.A.C.). Specifically, they have 

provided for two options (scenarios A and B) that reduce emissions somewhat differently among 

the BART-eligible source, but both result in visibility improvement. Taking into consideration 

these emission reductions, CF Industries completed air quality modeling consistent with an 

approved modeling protocol submitted to the department. The EPA-approved CALPUFF 

dispersion model was used to determine visibility impacts on all federal Class I areas within 300 

kilometers of the facility using three years of meteorological data derived from the MM5 

meteorological model. This modeling was thoroughly reviewed by the department and 

determined to be appropriate for the purpose of meeting the exemption criteria of the BART rule. 

Visibility impacts were completed for four federal Class I areas: Chassahowitzka National 

Wilderness Area (NWA), located 70 kilometers (km) from the facility, Everglades National Park 

(261 km), Okefenokee NWA (263 km), and Saint Marks NWA (273 km). The controlling area, 

that is the area with the greatest visibility impact from CF Industries, is Chassahowitzka. BART 

exemption modeling considered only the impacts from the BART-eligible sources within the 

facility. In this case, the “A”, “B”, “C”, and “D” sulfuric acid plants (SAP), the “A”, “X”, “Y”, 

and “Z” DAP/MAP plants, and the “A” and “B” shipping baghouses. 

In scenario A (the reduced production scenario), CF Industries proposes that the “A” SAP SO2 

emissions are reduced from 250.0 lb/hr to 75.8 lb/hr, 24-hour average, the “B” SAP SO2 

emissions are reduced from 233.3 lb/hr to 93.3 lb/hr, 24-hour average, and the “C” and “D” 

SAPs SO2 emissions are each reduced from 401.1 lb/hr to 303.3 lb/hr, 24-hour average. In 

addition, there would be reduced production capacities for the “C” and “D” SAPs from 2962 to 

2600 tons per day (TPD) each of sulfuric acid (H2SO4). NOx reductions would also occur as a 

result of the production decrease in the “C” and “D” SAPs, each reducing from 13.6 lb/hr to 11.9 

lb/hr. Similarly, there would be a reduction in sulfuric acid mist (SAM) as a result of the 

production decrease in these units from 11.4 lb/hr to 10.1 lb/hr, each. 

In scenario B (the converter replacement scenario), the “A” SAP SO2 emissions are reduced 

from 250.0 to 81.3 lbs/hr, the “B” SAP SO2 emissions from 233.3 to 100.0 lb/hr, the “C” and 

“D” SAPs SO2 emissions from 401.1 to 241.7 lb/hr each, all over a 24-hour average. Production 

in the “C” and “D” SAPs would also be slightly reduced from 2962 to 2900 TPD each. Again, 

the result of the production decrease will reduce NOx and SAM emissions. NOx emissions in 

the “C” and “D” SAPs are reduced from 13.6 to 13.3 lb/hr, and SAM emissions are reduced from 

11.4 to 11.2 lb/hr, each. 

Regional Haze SIP for Florida 

Exhibit 2

Page 405 of 501
The results of the modeling, considering both scenarios A and B for the controlling 

Chassahowitzka area, are shown below as taken from the complete modeling report submitted by 

CF Industries. 

The maximum visibility impact at the Chassahowitzka National Wilderness area under the 

scenario A plan is 0.499 deciviews (dv). Under the scenario B plan, the maximum visibility 

impact is 0.433 dv. Both of these values are less than the criterion for exemption from the 

BART rule of 0.5 dv. Based on the emission changes made in this permit, following either 

scenario A or scenario B, and the modeling performed by the applicant, the department 

concludes that the BART-eligible source at CF Industries is exempt from the BART rule 

requirements. 

Regional Haze SIP for Florida 

Exhibit 2

Page 406 of 501
 

PERMITTEE 

CF Industries, Inc. (CFI) 

Post Office Box Drawer L 

Plant City, FL 33564 

Authorized Representative: 

Mr. Ronald L. Brunk, Superintendent Environmental Affairs 

Air Permit No. 0570005-034-AC 

Expiration Date: December 31, 2013 

Plant City Phosphate Complex 

BART Exemption Project 

PLANT AND LOCATION 

CFI operates the Plant City Phosphate Complex, which is located at 10608 Paul Buchman Highway, Plant City in 

Hillsborough County, Florida. The facility is an existing phosphate fertilizer manufacturer, which is identified 

by Standard Industrial Classification (SIC) code No. 2874. 

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.). 

Pursuant to Rule 62-296.340(5)(c) (escape BART), F.A.C., the permittee shall install the air pollution control 

equipment and/or implement the air pollution control measures that are specified by this permit to be exempt 

from a Best Available Retrofit Technology (BART) determination. 

This final permit is organized into the following sections: Section 1 (General Information); Section 2 

(Administrative Requirements); Section 3 (Emissions Unit Specific Conditions); Section 4 (Appendices). 

Because of the technical nature of the project, the permit contains numerous acronyms and abbreviations, which 

are defined in Appendix A of Section 4 of this permit. As noted in the Final Determination provided with this 

final permit, only minor changes and clarifications were made to the draft permit. 

EFFECTIVE DATE 

Unless otherwise specified by this permit, the affected emissions units shall comply with the conditions of this 

permit as expeditiously as practicable. [Rule 62-296.340(3)(b)2., F.A.C.] 

Executed in Tallahassee, Florida 

___________________________________ _______________ 

Joseph Kahn, Director Effective Date 

Division of Air Resource Management 

JK/tlv/sa

Regional Haze SIP for Florida 

Exhibit 2

Page 407 of 501
SECTION 1. GENERAL INFORMATION

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 2 of 16 

FACILITY DESCRIPTION

The applicant, CFI, operates an existing phosphate fertilizer manufacturer. The fertilizer complex processes 

phosphate rock into several different fertilizer products. This is accomplished by reacting the phosphate rock with 

sulfuric acid to produce phosphoric acid and then converting the phosphoric acid to fertilizer. The facility consists 

of four sulfuric acid plants (SAPs); two phosphoric acid plants (PAPs); four diammonium/monoammonium 

phosphate (DAP/MAP) plants; molten sulfur storage and handling operations; product storage and shipping 

operations; and ancillary equipment. 

FACILITY REGULATORY CLASSIFICATIONS 

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

• The facility does not operate emissions 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. 

AFFECTED EMISSIONS UNITS

CFI submitted an application to escape the BART determination requirements of Rule 62-296.340(5)(c) (escape 

BART), F.A.C., which addresses the following emissions units with the potential to emit at least 50 tons per year 

(TPY) or more of a visibility-impairing pollutant: 

EU No. Emissions Unit Description

002 A Sulfuric Acid Plant 

003 B Sulfuric Acid Plant 

007 C Sulfuric Acid Plant 

008 D Sulfuric Acid Plant 

010 A DAP/MAP Plant 

011 Z DAP/MAP Plant 

012 X DAP/MAP Plant 

013 Y DAP/MAP Plant 

015 A Shipping Baghouse 

018 B Shipping Baghouse 

Regional Haze SIP for Florida 

Exhibit 2

Page 408 of 501
SECTION 1. GENERAL INFORMATION

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 3 of 16 

CONTENTS 

Section 1. General Information 

Section 2. Administrative Requirements 

Section 3. Emissions Units Specific Conditions 

Section 4. Appendices 

Appendix A. Citation Formats and Glossary of Common Terms 

Appendix B. General Conditions 

Appendix C. Standard Testing Requirements 

Appendix D. Memorandum of Understanding Regarding Best Operational Start-up Practices for 

Sulfuric Acid Plants

Regional Haze SIP for Florida 

Exhibit 2

Page 409 of 501
SECTION 2. ADMINISTRATIVE REQUIREMENTS 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 4 of 16 

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. 

2. Compliance Authority: All documents related to compliance activities such as reports, tests, and 

notifications shall be submitted to the Compliance Authority, Environmental Protection Commission 

of Hillsborough County (EPCHC) Office. The Compliance Authority’s mailing address is: 

Environmental Protection Commission of Hillsborough County 

3629 Queen Palm Drive 

Tampa, Florida 33619-1309 

Telephone: 813/627-2600, Fax: 813/627-2660 

3. Appendices: The following Appendices are attached as part of this permit: Appendix A (Citation 

Formats); Appendix B (General Conditions); Appendix C (Standard Testing Requirements); and, 

Appendix D (Memorandum of Understanding Regarding Best Operational Start-up 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 Air Operation 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 air operation permit is required for regular operation of the permitted emissions unit. 

The permittee shall apply for a Title V air operation permit at least 90 days prior to expiration of this 

permit, but no later than 180 days after completing the required work and commencing operation. To 

apply for a Title V operation 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 Permitting Authority, the Florida Department of Environmental 

Protection, Southwest District (SWD) Office. The SWD’s mailing address is: 

Florida Department of Environmental Protection Southwest District 

13051 N. Telecom Parkway 

Temple Terrace, Florida 33637-0926 

Telephone: 813/632-7600, Fax: 813/632-7665 

[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 (five) 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 (AOR): 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 1st of each year. [Rule 62-210.370(3), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 410 of 501
SECTION 2. ADMINISTRATIVE REQUIREMENTS 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 5 of 16 

NEW AND PREVIOUS PERMIT SPECIFIC CONDITIONS 

8. Pursuant to Rule 62-296.340(5)(c) (escape BART), F.A.C., the specific terms and conditions of this 

permit are required in order to escape a Best Available Retrofit Technology Determination. These 

specific terms and conditions apply to each emissions unit and are in addition to any other applicable 

standards. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; Proposed by the Applicant in the Application; 

and, Rules 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), 

F.A.C.] 

9. A relaxation of the specific terms and conditions of this permit may subject the facility to a BART and/or 

a Best Available Control Technology (BACT) determination. Any request to change the specific terms 

and conditions of this permit must be submitted to the Bureau of Air Regulation in the Division of Air 

Resource Management of the Florida Department of Environmental Protection. [Rule 62-296.340(5)(c) 

(escape BART), F.A.C.; and, Rules 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.] 

10. The applicant has proposed two emission reduction scenarios A and B for the BART-eligible emissions 

units at the Plant City Phosphate Complex. For each of the emissions reduction scenarios, the facility is 

exempt from BART because its contribution to visibility impairment does not exceed 0.5 deciview (dv) 

above natural conditions in any Class I area. Emissions Unit Specific Conditions in Section 3 of the 

permit will address both the emission reduction scenarios under different subsections. The applicant will 

make a decision to implement scenario A or B no later than June 1, 2010, at which time the scenario that 

was not selected will become obsolete. [Rule 62-296.340(5)(c) (escape BART), F.A.C.; and, Rules 62-

4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance of Compliance), F.A.C.] 

11. No emissions unit or facility subject to this permit shall be constructed or modified without obtaining the 

appropriate air construction permit from the Department. Such permit shall be obtained prior to 

beginning construction or modification. [Rules 62-210.300(1) and 62-212.300(1)(a), F.A.C.] 

12. Source Obligation: 

 (b) At such time that a particular source or modification becomes a major stationary source or major 

modification (as these terms were defined at the time the source obtained the enforceable limitation) 

solely by virtue of a relaxation in any enforceable limitation which was established after August 7, 

1980, on the capacity of the source or modification otherwise to emit a pollutant, such as a restriction 

on hours of operation, then the requirements of subsections 62-212.400(4) through (12), F.A.C., shall 

apply to the source or modification as though construction had not yet commenced on the source or 

modification. [Rule 62-212.400(12)(b), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 411 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 6 of 16 

This subsection addresses the following affected emissions units: 

 

EU ID 

No. 

Brief Description 

-002 A SAP 

-003 B SAP 

-007 C SAP 

-008 D SAP 

-010 A DAP/MAP Plant 

-011 Z DAP/MAP Plant 

-012 X DAP/MAP Plant 

-013 Y DAP/MAP Plant 

-015 A Shipping Baghouse 

-018 B Shipping Baghouse 

ADMINISTRATIVE REQUIREMENTS 

1. Emission Reductions under Scenario A: This subsection deals with emission reductions for the above affected 

emissions units under Scenario A. The permittee shall notify the Department’s Bureau of Air Regulation, EPCHC 

and the SWD Office through a letter from the responsible official by June 1, 2010 whether Scenario A will be 

implemented. If Scenario A is implemented, Scenario B becomes obsolete. Under Scenario A, the permittee shall 

reduce production rates of C and D SAPs from 2,962 TPD to 2,600 TPD and lower daily average SO2 emissions 

rates from the four SAPs. The permittee is required to comply with the BART exemption limits under Scenario A 

as soon as possible but not later than September 1, 2010. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C. and Applicant’s approval received via e-mail on September 8, 

2009] 

ESSENTIAL POTENTIAL TO EMIT (PTE) PARAMETERS 

2. Production Capacity: The existing production capacity of A and B SAPs, A, Z, X and Y DAP/MAP Plants, A and 

B Shipping Baghouses shall not be changed as a result of the proposed work under this project, Permit No. 

0570005-034-AC. The production capacity of C and D SAPs shall be reduced from the existing production 

capacity. The production capacity of each of these emissions units shall not exceed the following: 

EU ID No. Plant Description Production Capacity 

-002 A SAP 1,300 TPD (tons per day) of 100% H2SO4 (sulfuric acid) 

-003 B SAP 1,600 TPD of 100% H2SO4 

-007 C SAP 2,600 TPD of 100% H2SO4

-008 D SAP 2,600 TPD of 100% H2SO4

-010 A DAP/MAP Plant 29.53 TPH [tons per hour of phosphorus pentoxide (P2O5) input] for 

DAP; 33.30 TPH of P2O5 input for MAP 

-011 Z DAP/MAP Plant 48.7 TPH of P2O5 input for DAP; 55.0 TPH of P2O5 input for MAP 

-012 X DAP/MAP Plant 48.7 TPH of P2O5 input for DAP; 55.0 TPH of P2O5 input for MAP 

-013 Y DAP/MAP Plant 48.7 TPH of P2O5 input for DAP; 55.0 TPH of P2O5 input for MAP 

Regional Haze SIP for Florida 

Exhibit 2

Page 412 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 7 of 16 

EU ID No. Plant Description Production Capacity 

-015 A Shipping Baghouse 250 TPH 

-018 B Shipping Baghouse 500 TPH 

[Rules 62-296.340(5)(c) (escape BART), 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), 

F.A.C.] 

3. Methods of Operation - Fuels: The A, Z, X and Y DAP/MAP Plant dryers shall be primarily fired by natural gas. 

The dryers can be fired with No. 5 fuel oil or better grade fuel oil (i.e., No. 2, 3 or 4) as a back-up fuel. The 

maximum heat input rate to the four DAP/MAP Plant dryers shall be as follows: 

A DAP/MAP Plant dryer – 28.5 million British thermal units per hour (MMBtu/hr) 

Z DAP/MAP Plant dryer – 42.75 MMBtu/hr 

X DAP/MAP Plant dryer – 49.7 MMBtu/hr 

Y DAP/MAP Plant dryer – 49.5 MMBtu/hr 

[Rules 62-4.070(1)&(3) (Reasonable Assurance) and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

AIR POLLUTION CONTROL TECHNOLOGIES AND MEASURES 

4. SAP SO2 Controls: This BART exemption determination does not require new, modified or additional air 

pollution control systems for sulfur dioxide (SO2). To control emissions of SO2 from A and B SAPs, the permittee 

shall continue the use of the single stage absorption system technology followed by the two-stage ammonia 

scrubber. The permittee shall increase the scrubbing rate to the two-stage ammonia scrubber compared to the 

existing scrubbing rate in order to reduce the SO2 emissions from A and B SAPs. To control emissions of SO2

from C and D SAPs, the permittee shall continue the use of the existing double absorption system technology with 

vanadium and/or cesium catalyst in the converters and the use of good combustion practices and best operational 

practices to minimize excess emissions during startup and shutdown. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Proposed by the Applicant in 

the Application] 

5. SAP Acid Mist Controls: This BART exemption determination does not require new, modified or additional air 

pollution control systems for sulfuric acid mist (SAM). By controlling SAM emissions, particulate 

matter/particulate matter less than 10 microns (PM/PM10) and visible emissions are minimized. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Proposed by the Applicant in 

the Application] 

6. 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.] 

EMISSION STANDARDS AND LIMITATIONS 

7. PM, NOx and SO2 Standards: Particulate matter (PM), nitrogen oxides (NOx) and sulfur dioxide (SO2) emissions 

shall not exceed the following emissions standards. 

EU ID 

No.

Emissions Unit 

Description

Emissions Standards 

PM NOx SAM SO2

-002 A Sulfuric Acid Plant --- 6.5 lb/hra 1.43 lb/hrb75.8 lb/hrc

-003 B Sulfuric Acid Plant --- 8.0 lb/hra 1.8 lb/hrb 93.3 lb/hrc

Regional Haze SIP for Florida 

Exhibit 2

Page 413 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 8 of 16 

EU ID 

No.

Emissions Unit 

Description

Emissions Standards 

PM NOx SAM SO2

-007 C Sulfuric Acid Plant --- 11.9 lb/hra 10.1 lb/hrb303.3 lb/hrc

-008 D Sulfuric Acid Plant --- 11.9 lb/hra 10.1 lb/hrb303.3 lb/hrc

-010 A DAP/MAP Plant 13.0 lb/hr (DAP/MAP) 

& 56.9 TPY (tons per 

year)

--- --- See Footnote 

“d”

-011 Z DAP/MAP Plant 15.0 lb/hr(DAP/MAP) 

& 65.7 TPY

--- --- --- 

-012 X DAP/MAP Plant 10.62 lb/hr(DAP) 

13.75 lb/hr(MAP) & 

41.88 TPY(DAP/MAP)

--- --- See Footnote 

“d”

-013 Y DAP/MAP Plant 15.3 lb/hr(DAP/MAP) & 

67 TPY 

--- --- See Footnote 

“d”

a. Nitrogen oxides (NOx) emissions from A and B Sulfuric Acid Plants (EU-002 and EU-003) shall not exceed 6.5 

and 8.0 lb/hr, respectively {Permitting Note (for information purposes only): equivalent to 0.12 lb/ton of 100% 

sulfuric acid at design capacity} based on a 3-hour average as determined by stack test data. NOx emissions from 

C and D Sulfuric Acid Plants (EU-007 and EU-008) shall not exceed 11.9 lb/hr {Permitting Note (for information 

purposes only): equivalent to 0.11 lb/ton of 100% sulfuric acid at design capacity} based on a 3-hour average as 

determined by stack test data. 

b. Emissions of SAM for the four SAPs are based on a 3-hour average as determined by stack test data. 

Permitting note (for information purposes only): The equivalent lb SAM/ton 100% H2SO4 values for A and B 

SAP at design capacity is 0.027 lb SAM/ton 100% H2SO4. The equivalent lb SAM/ton 100% H2SO4 values for C 

and D SAP at design capacity is 0.093 lb SAM/ton 100% H2SO4. This permit requires stack test data to be used to 

demonstrate compliance. 

c. Sulfur dioxide emissions from A and B Sulfuric Acid Plants (EU-002 and EU-003) shall not exceed 75.8 and 93.3 

lb/hr based on a 24-hour (daily) block CEMS average. Sulfur dioxide emissions from C and D Sulfuric Acid 

Plants (EU-007 and EU-008) shall not exceed 303.3 lb/hr based on a 24-hour (daily) block CEMS average 

Permitting note (for information purposes only): SO2 emissions in lb/hour are equivalent to 1.4 lb/ton of 100% 

sulfuric acid for A and B SAPs at design capacity. SO2 emissions in lb/hour are equivalent to 2.8 lb/ton of 100% 

sulfuric acid for C and D SAPs at design capacity. A 24-hour (daily) block average was established based on the 

emission rate averaging period of 24-hour (daily) used in the air dispersion modeling. No stack testing is required. 

d. To control sulfur dioxide emissions from the dryers, natural gas shall be fired as a primary fuel. No. 5 fuel oil or 

better grade fuel oil (i.e., No. 2, 3 or 4) may be fired as a back-up fuel. 

[Rules 62-4.070(3) and 62-296.340(5)(c) (escape BART), F.A.C.] 

8. Opacity Standards: Visible emissions from the A and B Shipping Baghouse exhausts (EU-015 and EU-018) shall 

not exceed 5% opacity as determined by EPA Method 9. 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(5)(c) (escape BART), F.A.C.; and 40 CFR 60.83(a)2 and 40 CFR 60, Appendix A, Method 9] 

Regional Haze SIP for Florida 

Exhibit 2

Page 414 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 9 of 16 

9. SO2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO2 

CEMS to be used to demonstrate continuous compliance with the SO2 emission standards and limitations specified 

in this section. 

a. In accordance with the New Source Performance Standards (NSPS) (40 CFR 60, Subpart H) requirements for 

sulfuric acid plants, the permittee shall continue to properly calibrate, maintain, and operate a CEMS to 

measure and record emissions of SO2. 

b. A CEMS shall be properly calibrated, maintained, and operated to comply with: 40 CFR 60 Subpart A, 

General Provisions; 40 CFR 60 Appendix B, Performance Specification 2; and, 40 CFR 60, Appendix F, 

Quality Assurance Procedures for Gas CEMS Used for Compliance Determination. 

c. The emissions data collected with the certified CEMS shall be used to demonstrate continuous compliance with 

the standards and limitations specified in this section. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) 

(Assurance of Compliance), F.A.C.; and, Proposed by the Applicant in the Application] 

EMISSIONS TESTING 

10. Test Methods: The following reference methods (or more recent versions) shall be used to conduct any required 

emissions tests. 

Method Description of Method and Comments 

1 - 4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 

5 Determination of PM Emissions from Stationary Sources 

6 or 6C Determination of SO2 Emissions from Stationary Sources 

7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure) 

8 Determination of SAM and SO2 Emissions from Stationary Sources 

9 Visual Determination of Opacity from Stationary Sources 

EPA Methods 1, 2, 3 and 4 shall be used as necessary to support the other test methods. The above methods are 

described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. No other 

methods shall be used without prior written approval from the Permitting Authority. 

[Rules 62-204.800 and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

11. Standard Testing Requirements: All required emissions tests shall be conducted in accordance with the 

requirements specified in Appendix C (Standard Testing Requirements) of this permit. 

[Rules 62-204.800 and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

12. Compliance Test Schedule: In accordance with the following schedule, the permittee shall have stack tests 

conducted to demonstrate compliance with the emissions standards specified in this permit. 

a. Initial and Annual Tests: On or before September 1, 2010, an initial test shall be conducted for NOx and 

SAM emissions from each SAP; PM emissions from A, Z, X and Y DAP/MAP Plants and visible emissions 

(VE) test for A and B Shipping Baghouses. The initial compliance test report for NOx, VE, SAM and PM 

shall be submitted within 45 days of completion of testing. Thereafter, annual compliance test shall be done 

for the above pollutants during each federal fiscal year (October 1 – September 30). 

[Rules 62-296.340(5)(c) (escape BART) and 62-297.310(7)(a)1, F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 415 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection A (Scenario A). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 10 of 16 

b. Initial and Special Test: A visible emissions (VE) test shall be conducted concurrently with one run of the 

SAM stack test to demonstrate initial compliance with the existing VE standards for each SAP. The VE test 

results shall be submitted with the SAM stack test report. 

[Rules 62-4.070(1)&(3) and 62-297.310(7)(b), F.A.C.] 

c. Tests Prior to Renewal: Within the 12-month period prior to renewing the Title V air operation permit, tests 

shall be conducted for SAM and NOx emissions from each SAP.

 [Rules 62-296.340(5)(c) (escape BART), and 62-297.310(7)(a)3, F.A.C.] 

{Note: Under this permit SO2 CEMS are required to demonstrate compliance on a continuous basis, therefore, no 

initial or annual compliance test for SO2 is necessary on the four SAPs.} 

RECORDS AND REPORTS 

13. Quarterly Reporting Requirements: The owners or operators of facilities for which monitoring is required shall 

submit to the Department a written report of emissions in excess of emission limiting standards as set forth in Rule 

62-296.402, F.A.C., for each calendar quarter. The nature and cause of the excessive emissions shall be 

explained. This report does not relieve the owner or operator of the legal liability for violations. All recorded data 

shall be maintained on file by the Source for a period of 5 (five) years. {The permittee is required to use SO2

continuous emissions monitoring systems for continuous compliance demonstrations.} 

[Rules 62-296.402(5) and 62-213.440(1)(b)2., F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 416 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 11 of 16 

This subsection addresses the following affected emissions units: 

 

EU ID 

No. 

Brief Description 

-002 A SAP 

-003 B SAP 

-007 C SAP 

-008 D SAP 

-010 A DAP/MAP Plant 

-011 Z DAP/MAP Plant 

-012 X DAP/MAP Plant 

-013 Y DAP/MAP Plant 

-015 A Shipping Baghouse 

-018 B Shipping Baghouse 

ADMINISTRATIVE REQUIREMENTS 

1. Emission Reductions under Scenario B: This subsection deals with emission reductions for the above affected 

emissions units under Scenario B. The permittee shall notify the Department’s Bureau of Air Regulation, EPCHC 

and the SWD Office through a letter from the responsible official by June 1, 2010 whether Scenario B will be 

implemented. If Scenario B is implemented, Scenario A becomes obsolete. Under Scenario B, the permittee shall 

reduce production rates of C and D SAPs from 2,962 TPD to 2,900 TPD and reduce lower daily average SO2

emissions rates from the four SAPs. A and B SAPs shall comply with the new BART exemption limit for SO2 by 

September 1, 2010. BART exemption limits for one of the C and D SAPs shall be complied with by January 1, 

2012, and for the other SAP by December 31, 2013. The permittee shall notify the Department’s Bureau of Air 

Regulation, EPCHC and the SWD Office through a letter from the responsible official by June 30, 2011, the 

turnaround schedule for the C and D SAPs. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C. and Applicant’s approval received via e-mail on September 8, 2009] 

ESSENTIAL POTENTIAL TO EMIT (PTE) PARAMETERS 

2. Production Capacity: The existing production capacity of A and B SAPs, A, Z, X and Y DAP/MAP Plants, A and B 

Shipping Baghouses shall not be changed as a result of the proposed work under this project, Permit No. 0570005-

034-AC. The production capacity of C and D SAPs shall be reduced from the existing production capacity. The 

production capacity of each of these emissions units shall not exceed the following: 

EU ID No. Plant Description Production Capacity 

-002 A SAP 1,300 TPD of 100% H2SO4 

-003 B SAP 1,600 TPD of 100% H2SO4 

-007 C SAP 2,900 TPD of 100% H2SO4

-008 D SAP 2,900 TPD of 100% H2SO4

-010 A DAP/MAP Plant 29.53 TPH of P2O5 input for DAP; 33.30 TPH of P2O5 input for MAP 

-011 Z DAP/MAP Plant 48.7 TPH of P2O5 input for DAP; 55.0 TPH of P2O5 input for MAP 

-012 X DAP/MAP Plant 48.7 TPH of P2O5 input for DAP; 55.0 TPH of P2O5 input for MAP 

Regional Haze SIP for Florida 

Exhibit 2

Page 417 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 12 of 16 

EU ID No. Plant Description Production Capacity 

-013 Y DAP/MAP Plant 48.7 TPH of P2O5 input for DAP; 55.0 TPH of P2O5 input for MAP 

-015 A Shipping Baghouse 250 TPH 

-018 B Shipping Baghouse 500 TPH 

[Rules 62-296.340(5)(c) (escape BART), 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), 

F.A.C.] 

3. Methods of Operation - Fuels: The A, Z, X and Y DAP/MAP Plant dryers shall be primarily fired by natural gas. 

The dryers can be fired with No. 5 fuel oil or better grade fuel oil (i.e., No. 2, 3 or 4) as a back-up fuel. The 

maximum heat input rate to the four DAP/MAP Plant dryers shall be as follows: 

A DAP/MAP Plant dryer – 28.5 million British thermal units per hour (MMBtu/hr) 

Z DAP/MAP Plant dryer – 42.75 MMBtu/hr 

X DAP/MAP Plant dryer – 49.7 MMBtu/hr 

Y DAP/MAP Plant dryer – 49.5 MMBtu/hr 

[Rules 62-4.070(1)&(3) (Reasonable Assurance) and Rule 62-210.200 (Definitions - Potential to Emit (PTE)), 

F.A.C.] 

4. Design Capacity and Permitted Production: The permittee shall submit a statement from the responsible official to 

the Department’s Bureau of Air Regulation, EPCHC and the SWD Office within 30 days after the completion of all 

of the proposed work under this project. 

[Rules 62-4.160(2) and 62-210.200 (Definitions - Potential to Emit (PTE)), F.A.C.] 

AIR POLLUTION CONTROL TECHNOLOGIES AND MEASURES 

5. SAP SO2 Controls: This BART exemption determination does require new, modified or additional air pollution 

control systems for SO2. To control emissions of SO2 from A and B SAPs, the permittee shall continue the use of 

the single absorption system technology followed by the two-stage ammonia scrubber. The permittee shall increase 

the scrubbing rate to the two-stage ammonia scrubber compared to the existing scrubbing rate in order to reduce the 

SO2 emissions from A and B SAPs. To control emissions of SO2 from C and D SAPs, the permittee shall replace the 

four-stage catalytic converters and continue the use of the existing double absorption system technology with 

vanadium and/or cesium catalyst in the converters and the use of good combustion practices and best operational 

practices to minimize excess emissions during startup and shutdown. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Proposed by the Applicant in the 

Application] 

6. Proposed Work: The applicant is required to perform the following specific work activities under this project in 

order to escape BART: 

EU ID No. Work Activities 

-007 (C SAP) • Increase the catalyst loading ratio from approximately 137.3 liters per ton H2SO4 

per day (L/TPD) at 2,962 TPD production rate to approximately 200 L/TPD at 

2,900 TPD production rate; 

• Replace the four-stage catalytic converter. 

Regional Haze SIP for Florida 

Exhibit 2

Page 418 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 13 of 16 

EU ID No. Work Activities 

-008 (D SAP) • Increase the catalyst loading ratio from approximately 140.5 L/TPD at 2,962 TPD 

production rate to approximately 200 L/TPD at 2,900 TPD production rate; 

• Replace the four-stage catalytic converter. 

Higher catalyst loadings are allowed by this permit in order to meet the BART exemption SO2 emission limits. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 62-4.070(1)&(3) (Reasonable Assurance), 

and, Proposed by the Applicant in the Application] 

7. SO2 Controls: The permittee shall submit a written request for other specific catalyst loadings and types to the 

Bureau of Air Regulation with a copy to the Compliance Authority for review and approval prior to use. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rules 62-4.160(2) and 62-4.070(1)&(3) (Reasonable Assurance), 

F.A.C.; and, Proposed by the Applicant in the Application] 

8. SAP Acid Mist Controls: This BART exemption determination does not require new, modified or additional air 

pollution control systems for sulfuric acid mist (SAM). By controlling SAM emissions, PM/PM10 and visible 

emissions are minimized. 

[Rule 62-296.340(5)(c) (escape BART), F.A.C.; Rule 62-210.700(1), F.A.C.; and, Proposed by the Applicant in the 

Application] 

9. 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.] 

EMISSION STANDARDS AND LIMITATIONS 

10. PM, NOx and SO2 Standards: Particulate matter, nitrogen oxides and sulfur dioxide emissions shall not exceed the 

following emissions standards. 

EU ID 

No.

Emissions Unit 

Description

Emissions Standards 

PM NOx SAM SO2

-002 A Sulfuric Acid Plant --- 6.5 lb/hra 1.43 lb/hrb81.3 lb/hrc

-003 B Sulfuric Acid Plant --- 8.0 lb/hra 1.8 lb/hrb 100.0 lb/hrc

-007 C Sulfuric Acid Plant --- 13.3 lb/hra 11.2 lb/hrb241.7 lb/hrc

-008 D Sulfuric Acid Plant --- 13.3 lb/hra 11.2 lb/hrb241.7 lb/hrc

-010 A DAP/MAP Plant 13.0 lb/hr (DAP/MAP) 

& 56.9 TPY (tons per 

year)

--- --- See Footnote 

“d”

-011 Z DAP/MAP Plant 15.0 lb/hr(DAP/MAP) 

& 65.7 TPY

--- --- --- 

-012 X DAP/MAP Plant 10.62 lb/hr(DAP) 

13.75 lb/hr(MAP) & 

41.88 TPY(DAP/MAP)

--- --- See Footnote 

“d”

Regional Haze SIP for Florida 

Exhibit 2

Page 419 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 14 of 16 

EU ID 

No.

Emissions Unit 

Description

Emissions Standards 

PM NOx SAM SO2

-013 Y DAP/MAP Plant 15.3 lb/hr(DAP/MAP) & 

67 TPY 

--- --- See Footnote 

“d”

a. Nitrogen oxides (NOx) emissions from A and B Sulfuric Acid Plants (EU-002 and EU-003) shall not exceed 6.5 and 

8.0 lb/hr, respectively {Permitting Note (for information purposes only): equivalent to 0.12 lb/ton of 100% sulfuric 

acid at design capacity} based on a 3-hour average as determined by stack test data. NOx emissions from C and D 

Sulfuric Acid Plants (EU-007 and EU-008) shall not exceed 13.3 lb/hr {Permitting Note (for information purposes 

only): equivalent to 0.11 lb/ton of 100% sulfuric acid at design capacity} based on a 3-hour average as determined 

by stack test data. 

b. Emissions of SAM for the four SAPs are based on a 3-hour average as determined by stack test data. 

Permitting note (for information purposes only): The equivalent lb SAM/ton 100% H2SO4 values for A and B SAP 

at design capacity is 0.027 lb SAM/ton 100% H2SO4. The equivalent lb SAM/ton 100% H2SO4 values for C and D 

SAP at design capacity is 0.093 lb SAM/ton 100% H2SO4. This permit requires stack test data to be used to 

demonstrate compliance. 

c. Sulfur dioxide emissions from A and B Sulfuric Acid Plants (EU-002 and EU-003) shall not exceed 81.3 and 100.0 

lb/hr based on a 24-hour (daily) block CEMS average. Sulfur dioxide emissions from C and D Sulfuric Acid Plants 

(EU-007 and EU-008) shall not exceed 241.7 lb/hr based on a 24-hour (daily) block CEMS average 

Permitting note (for information purposes only): SO2 emissions in lb/hour are equivalent to 1.5 lb/ton of 100% 

sulfuric acid for A and B SAPs at design capacity. SO2 emissions in lb/hour are equivalent to 2.0 lb/ton of 100% 

sulfuric acid for C and D SAPs at design capacity. A 24-hour (daily) block average was established based on the 

emission rate averaging period of 24-hour (daily) used in the air dispersion modeling. No stack testing is required. 

d. To control sulfur dioxide emissions from the dryers, natural gas shall be fired as a primary fuel. No. 5 fuel oil or 

better grade fuel oil (i.e., No. 2, 3 or 4) may be fired as a back-up fuel. 

[Rules 62-4.070(3) and 62-296.340(5)(c) (escape BART), F.A.C.] 

11. Opacity Standards: Visible emissions from the A and B Shipping Baghouse exhausts (EU-015 and EU-018) shall 

not exceed 5% opacity as determined by EPA Method 9. 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(5)(c) (escape BART), F.A.C.; and 40 CFR 60.83(a)2 and 40 CFR 60, Appendix A, Method 9] 

12. SO2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO2 

CEMS to be used to demonstrate continuous compliance with the SO2 emission standards and limitations specified 

in this section. 

a. In accordance with the NSPS (40 CFR 60, Subpart H) requirements for sulfuric acid plants, the permittee shall 

continue to properly calibrate, maintain, and operate a CEMS to measure and record emissions of SO2. 

b. A CEMS shall be properly calibrated, maintained, and operated to comply with: 40 CFR 60 Subpart A, General 

Provisions; 40 CFR 60 Appendix B, Performance Specification 2; and, 40 CFR 60, Appendix F, Quality 

Assurance Procedures for Gas CEMS Used for Compliance Determination. 

c. The emissions data collected with the certified CEMS shall be used to demonstrate continuous compliance with 

the standards and limitations specified in this section. 

Regional Haze SIP for Florida 

Exhibit 2

Page 420 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 15 of 16 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance 

of Compliance), F.A.C.; and, Proposed by the Applicant in the Application] 

EMISSIONS TESTING 

13. Test Methods: The following reference methods (or more recent versions) shall be used to conduct any required 

emissions tests. 

Method Description of Method and Comments 

1 - 4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 

5 Determination of PM Emissions from Stationary Sources 

6 or 6C Determination of SO2 Emissions from Stationary Sources 

7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure) 

8 Determination of SAM and SO2 Emissions from Stationary Sources 

9 Visual Determination of Opacity from Stationary Sources 

EPA Methods 1, 2, 3 and 4 shall be used as necessary to support the other test methods. The above methods are 

described in 40 CFR 60, Appendix A, which is adopted by reference in Rule 62-204.800, F.A.C. No other methods 

shall be used without prior written approval from the Permitting Authority. 

[Rules 62-204.800 and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

14. Standard Testing Requirements: All required emissions tests shall be conducted in accordance with the 

requirements specified in Appendix C (Standard Testing Requirements) of this permit. 

[Rules 62-204.800 and 62-297.100, F.A.C.; and 40 CFR 60, Appendix A] 

15. Compliance Test Schedule: In accordance with the following schedule, the permittee shall have stack tests 

conducted to demonstrate compliance with the emissions standards specified in this permit. 

a. Initial and Annual Tests: On or before September 1, 2010, an initial test shall be conducted for NOx and SAM 

emissions from A and B SAPs; PM emissions from A, Z, X and Y DAP/MAP Plants and VE test for A and B 

Shipping Baghouses. On or before January 1, 2012, an initial test shall be conducted for NOx and SAM 

emissions from one of the C and D SAPs. On or before December 31, 2013, an initial test shall be conducted for 

NOx and SAM emissions from the other SAP. The initial compliance test report for NOx, VE, SAM and PM 

shall be submitted within 45 days of completion of testing. Thereafter, annual compliance test shall be done for 

the above pollutants during each federal fiscal year (October 1 – September 30). [Rules 62-296.340(5)(c) 

(escape BART) and 62-297.310(7)(a)1, F.A.C.] 

b. Initial and Special Test: A visible emissions (VE) test shall be conducted concurrently with one run of the SAM 

stack test to demonstrate initial compliance with the existing VE standards after the proposed work has been 

completed for each SAP. The VE test results shall be submitted with the SAM stack test report. [Rules 62-

4.070(1)&(3) and 62-297.310(7)(b), F.A.C.] 

c. Tests Prior to Renewal: Within the 12-month period prior to renewing the Title V air operation permit, tests 

shall be conducted for SAM and NOx emissions from each SAP.

[Rules 62-296.340(5)(c) (escape BART), and 62-297.310(7)(a)3, F.A.C.] 

{Note: Under this permit SO2 CEMS are required to demonstrate compliance on a continuous basis, therefore, no 

initial or annual compliance test for SO2 is necessary on the SAPs.} 

RECORDS AND REPORTS 

Regional Haze SIP for Florida 

Exhibit 2

Page 421 of 501
SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS 

Subsection B (Scenario B). A, B, C and D SAPs; A, Z, X and Y DAP/MAP Plants; A and B Shipping Baghouses 

CF Industries, Inc. Air Permit No. 0570005-034-AC 

Plant City Phosphate Complex BART Exemption Project 

Page 16 of 16 

16. Quarterly Reporting Requirements: The owners or operators of facilities for which monitoring is required shall 

submit to the Department a written report of emissions in excess of emission limiting standards as set forth in Rule 

62-296.402, F.A.C., for each calendar quarter. The nature and cause of the excessive emissions shall be explained. 

This report does not relieve the owner or operator of the legal liability for violations. All recorded data shall be 

maintained on file by the Source for a period of 5 (five) years. {The permittee is required to use SO2 continuous 

emissions monitoring systems for continuous compliance demonstrations.} [Rules 62-296.402(5) and 62-

213.440(1)(b)2., F.A.C.] 

17. Construction Plan and Progress Reports: The permittee shall submit a Construction Plan within sixty (60) days of 

June 1, 2010 for C and D SAPs which shall contain the necessary milestones to comply with this permit. The Plan 

shall include at a minimum the necessary actions and corresponding scheduled due dates to complete those actions 

to comply with this permit. 

a. The permittee shall submit progress reports based on the anniversary date (one year from the effective date) of 

this permit regarding the status of the milestones in the Construction Plan to the Department and to the 

Compliance Authority, no less than annually in 2010 - 2013. 

b. The permittee shall complete all required construction and modifications for one of the C and D SAP no later than 

September 30, 2011. 

c. The permittee shall complete all required construction and modifications for the other SAP no later than 

September 30, 2013. 

[Rules 62-296.340(5)(c) (escape BART), 62-4.070(1)&(3) (Reasonable Assurance), and 62-213.440(1) (Assurance 

of Compliance), F.A.C.]

Regional Haze SIP for Florida 

Exhibit 2

Page 422 of 501
Evidence of Shut-down 

A. U.S. Sugar - Bryant 

Regional Haze SIP for Florida 

Exhibit 2

Page 423 of 501
Regional Haze SIP for Florida 

Exhibit 2

Page 424 of 501
Regional Haze SIP for Florida 

Exhibit 2

Page 425 of 501
Regional Haze SIP for Florida 

Exhibit 2

Page 426 of 501
Regional Haze SIP for Florida 

Exhibit 2

Page 427 of 501
Regional Haze SIP for Florida 

Exhibit 2

Page 428 of 501
B. IMC Port Sutton (currently Kinder Morgan) 

First item: Previous Title V operating permit showing the rock dryer (unit 1) as a valid unit. 

Second item: Current Title V operating permit showing that the rock dryer is no longer included. 

Regional Haze SIP for Florida 

Exhibit 2

Page 429 of 501
Robert H. Kinsey/IMC-Agrico

Port Sutton Terminal

Facility ID No.: 0570024

Hillsborough County

Initial Title V Air Operation Permit

FINAL Permit No.: 0570024-003-AV

Permitting Authority:

Environmental Protection Commission

of Hillsborough County

1410 N. 21st Street

Tampa, FL 33605

Telephone: (813) 272-5530

Fax: (813) 272-5605

[electronic file name: 0570024f.doc]

Regional Haze SIP for Florida 

Exhibit 2

Page 430 of 501
Initial Title V Air Operation Permit

FINAL Permit No.: 0570024-003-AV

Table of Contents

Section Page Number

Statement of Basis........................................................................................................ ii

Placard Page................................................................................................................... 1

I. Facility Information ............................................................................................. 2 - 3

A. Facility Description.

B. Summary of Emissions Unit ID No(s). and Brief Description(s).

C. Relevant Documents.

II. Facility-wide Conditions .................................................................................... 4 - 6

III. Emissions Unit(s) and Conditions...................................................................... 7 - 30

A. -001 Phosphate Rock Dryer

B. -002 Railcar Unloading Scrubber

-004 C17 transfer point E

C. -003 Shiploading baghouse (C13 to C14 and C14 to Shiphold)

-005 C12 transfer point A

-006 C30 transfer point C

-013 Shiphold Opening

D. -007 C18 transfer point D

-009 C19 transfer point G

E. -008 Animal Feed Ingredient Handling

F. -012 Conveyor transfer points from railcar unloading and rock dryer to

storage silos

G. -100 DAP Truck Unloading Station No.2

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Permittee: FINAL Permit No.: 0570024-003-AV

Robert H. Kinsey/IMC-Agrico Facility ID No.: 0570024

P.O. Box 2000 SIC Nos.: 51

Mulberry, FL 33860-1100 Project: Initial Title V Air Operation Permit

This permit is for the operation of the Port Sutton Terminal. This facility is located at Port

Sutton, Tampa, Hillsborough County; UTM Coordinates: Zone 17,360.1 km East and 3087.5

km North; Latitude: 27° 54’ 24” North and Longitude: 82° 25’ 18” West.

STATEMENT OF BASIS: This Title V air operation permit is issued under the provisions of

Chapter 403, Florida Statutes (F.S.), and Florida Administrative Code (F.A.C.) Chapters 62-4,

62-210, and 62-213. The above named permittee is hereby authorized to perform the work or

operate the facility shown on the application and approved drawing(s), plans, and other

documents, attached hereto or on file with the permitting authority, in accordance with the terms

and conditions of this permit.

Referenced attachments made a part of this permit:

Appendix I-1, List of Insignificant Emissions Units and/or Activities

Appendix O-1, Operation and Maintenance Plans for Particulate Control

APPENDIX TV-3, TITLE V CONDITIONS (version dated 4/30/99)

APPENDIX SS-1, STACK SAMPLING FACILITIES (version dated 10/07/96)

Effective Date: June 26, 2000

Renewal Application Due Date: December 28, 2004

Expiration Date: June 26, 2005

Environmental Protection Commission

of Hillsborough County

___________________________

Roger P. Stewart

Executive Director

RPS/AHH/sp

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Robert H. Kinsey/ IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

Page 2

Section I. Facility Information.

Subsection A. Facility Description.

This facility consists of phosphate rock dryer, truck and railcar unloading operation for

phosphate rock, animal feed ingredient (AFI) and chemicals (MAP, DAP, GTSP),

product storage, and ammonia handling and storage.

The facility can dry phosphate rock using a single dryer firing natural gas or fuel oil. Wet

phosphate rock can be trucked or delivered by railcar to the facility and stored outside

until processed. The dried phosphate rock is stored within enclosed storage silos until

transported off site by ship or barge. The majority of the dry phosphate rock handling

operations are enclosed to control fugitive dust emissions.

Additionally, the terminal does receive dry phosphate rock, AFI and MAP, DAP, GTSP

by railcar and truck. The products can be transferred directly to a shiphold or stored in

silos (rock and AFI) or chemical storage buildings (MAP, DAP, GTSP). This facility is

subject to PM-RACT and the monitoring requirements, along with daily visible emissions

readings, fuel sampling, and annual PM and EPA Method 9 testing, have been determined

by the Agency to satisfy the requirements of 40CFR70.6 and Chapter 62-296, F.A.C.

Also included in this permit are miscellaneous insignificant emissions units and/or

activities.

Based on the initial Title V permit application received June 14, 1996, this facility is not

a major source of hazardous air pollutants (HAPs).

Subsection B. Summary of Emissions Unit ID No(s). and Brief Description(s).

E.U.

ID No. Brief Description

-001 Phosphate Rock Dryer

-002 Railcar Unloading Scrubber

-003 Shiploading baghouse (C13 to C14 and C14 to Shiphold)

-004 C17 transfer point E

-005 C12 transfer point A

-006 C30 transfer point C

-007 C18 transfer point D

-008 Animal Feed Ingredient Handling

-009 C19 transfer point G

-012 Conveyor transfer points from railcar unloading and rock dryer to storage silos

-013 Shiphold Opening

-100 DAP Truck Unloading Station No. 2

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Port Sutton Terminal

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Please reference the Permit No., Facility ID No., and appropriate Emissions Unit(s) ID

No(s). on all correspondence, test report submittals, applications, etc.

Subsection C. Relevant Documents.

The documents listed below are not a part of this permit, however, are specifically related

to this permitting action.

These documents are provided to the permittee for information purposes only:

Table 1-1, Summary of Air Pollutant Standards and Terms

Table 2-1, Summary of Compliance Requirements

Appendix A-1, Abbreviations, Acronyms, Citations, and Identification Numbers

Appendix H-1, Permit History / ID Number Changes

These documents are on file with permitting authority:

Initial Title V Permit Application received June 14, 1996.

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Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

Page 4

Section II. Facility-wide Conditions.

The following conditions apply facility-wide:

1. APPENDIX TV-3, TITLE V CONDITIONS (version dated 4/30/99), is a part of this

permit.

{Permitting note: APPENDIX TV-3, TITLE V CONDITIONS, is distributed to the

permittee only. Other persons requesting copies of these conditions shall be provided one

copy when requested or otherwise appropriate.}

2. General Pollutant Emission Limiting Standards. Objectionable Odor Prohibited. The

permittee shall not cause, suffer, allow, or permit the discharge of air pollutants which

cause or contribute to an objectionable odor.

[Rule 62-296.320(2), F.A.C.]

3. General Particulate Emission Limiting Standards. General Visible Emissions

Standard. Except for emissions units that are subject to a particulate matter or opacity

limit set forth or established by rule and reflected by conditions in this permit, no person

shall cause, let, permit, suffer or allow to be discharged into the atmosphere the emissions

of air pollutants from any activity, the density of which is equal to or greater than that

designated as Number 1 on the Ringelmann Chart (20 percent opacity). EPA Method 9 is

the method of compliance pursuant to Chapter 62-297. F.A.C..

[Rule 62-296.320(4)(b)1., F.A.C.]

4. Prevention of Accidental Releases (Section 112(r) of CAA). If required by 40 CFR

68, the permittee shall submit to the implementing agency:

a. a Risk Management Plan (RMP) when, and if, such requirement becomes

applicable; and

b. certification forms and/or RMPs according to the promulgated rule schedule.

[40 CFR 68]

5. Insignificant Emissions Units and/or Activities. Appendix I-1, List of Insignificant

Emissions Units and/or Activities, is a part of this permit.

[Rules 62-213.440(1), 62-213.430(6), and 62-4.040(1)(b), F.A.C.]

6. General Pollutant Emission Limiting Standards. Volatile Organic Compounds (VOC)

Emissions or Organic Solvents (OS) Emissions. The permittee shall allow no person to

store, pump, handle, process, load, unload or use in any process or installation, volatile

organic compounds (VOC) or organic solvents (OS) without applying known and existing

vapor emission control devices or systems deemed necessary and ordered by the

Department.

A) Maintain tightly fitting cover, lids, etc. on all containers when they are not being

handled, tapped, etc.

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B) Where possible and practical, procure/fabricate a tightly fitting cover for any open

trough, basin, etc. of VOC so that it can be covered when not in use.

C) Immediately attend to all spills/waste as appropriate.

[Rule 62-296.320(1)(a), F.A.C.; Proposed by applicant in the initial Title V permit

application received June 16, 1996]

7. Reasonable precautions to prevent emissions of unconfined particulate matter at this

facility in accordance with the provision in Rule 62-296.320, F.A.C. These provisions are

applicable to any source, including, but not limited to, vehicular movement, transportation

of materials, construction, alterations, demolition or wrecking, or industrial related activities

such as loading, unloading, storing and handling. Reasonable precautions shall include, but

not limited to, the following:

A) Maintenance of parking areas and yards.

B) Removal of particulate matter from paved areas, buildings and work areas under the

control of the permittee.

C) Reduce vehicular speed. Post limits, if necessary.

[Rule 62-296.320(4)(c)2., F.A.C.; Proposed by applicant in the initial Title V permit

application received June 16, 1996]

8. The permittee shall notify the Air Compliance Section of the Environmental Protection

Commission of Hillsborough County at least 15 days prior to the date on which each formal

compliance test is to begin of the date, time, and place of each such test, and the contact

person who will be responsible for coordinating and having such test conducted.

[Rule 62-297.310, F.A.C]

9. Submit to the Environmental Protection Commission of Hillsborough County each

calendar year on or before March 1, completed DEP Form 62-210.900(5), "Annual

Operating Report for Air Pollutant Emitting Facility", for the preceding calendar year. [Rule

62-210.370(2), F.A.C.]

10. The permittee shall comply with Appendix O-1, Operation and Maintenance Plans for

Particulate Control. In the event of a deviation from the monitoring parameters, the facility

shall take corrective actions to remedy the situation. Notify the Environmental Protection

Commission of Hillsborough County within 24 hours of the problem. The emission unit

shall not be operated until the problem is corrected. A written explanation and the

corrective actions implemented shall be submitted in the semi-annual report required in the

TV-3 Condition Nos. 43, 44, 45. Records of inspections, maintenance, and performance

parameters shall be retained for a minimum of five years and shall be made available to the

Environmental Protection Commission of Hillsborough County upon request.

[Rule 62-296.700(6)(e), F.A.C.]

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11. When appropriate, any recording, monitoring or reporting requirements that are timespecific shall be in accordance with the effective date of this permit, which defines day

one.

[Rule 62-213.440(1), F.A.C.]

12. The permittee shall submit all compliance related notifications and reports required

of this permit to the Environmental Protection Commission of Hillsborough County at:

Environmental Protection Commission

Air Management Division

1410 North 21st Street

Tampa, FL 33605

Telephone: 813/272-5530, Fax: 813/272-5605

13. Any reports, data, notifications, certifications and requests required to be sent to the

United States Environmental Protection Agency, Region 4, should be sent to:

United States Environmental Protection Agency Region 4

Air EPCRA Enforcement Branch

Air Compliance Section

61 Forsyth Street

Atlanta, Georgia 30303

Telephone: 404/562-9099

Fax: 404/562-9095

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Exhibit 2

Page 437 of 501
Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

Page 7

Section III. Emissions Unit(s) and Conditions.

Subsection A. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-001 Phosphate Rock Dryer

For the operation of a phosphate rock dryer designed for processing 393 TPH, annual

average, of wet phosphate rock dried to approximately 2% moisture. Particulate matter

emissions generated during drying operations are controlled by two Buell Dry Cyclones

in parallel, followed in series by an Airetron, Model No. 261-1, Wet Cyclonic Scrubber.

The rock dryer is fired on natural gas or No. 6 fuel oil with a maximum sulphur content

not to exceed 2.0 % by weight.

{Permitting note(s): This emissions unit is regulated under Rule 62-296.320, F.A.C.,

General Pollutant Emission Limiting Standards and PM RACT under Rule 62-296.700,

F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

A.1. Capacity. The maximum material handling rate of the dryer shall not exceed 575

tons/hr (TPH) in any given hour and 393 TPH on an annual average.

[Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

A.2. Methods of Operation - (i.e., Fuels). The dryer shall be fired with natural gas or

new fuel oil (grade No. 1 to grade No. 6 inclusive) only. The maximum sulfur content of

the fuel oil shall not exceed 2.0% by weight.

[Rules 62-4.160(2), F.A.C. and 62-213.440(1), F.A.C.]

A.3. Hours of Operation. This emissions unit is allowed to operate continuously, i.e.,

8,760 hours/year.

[Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

A.4. The maximum allowable particulate emission rate shall not exceed 43.8 lbs/hr and

191.8 tons per consecutive twelve month period when the process rate exceeds 333 TPH

of phosphate rock. From 200 TPH to 333 TPH, the emission limit shall be set by the

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Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

Page 8

Process Weight Rate formula E= 17.31 P0.16. For a production rate of less than 200 TPH,

the maximum allowable particulate emission rate shall be 0.2 lb/ton of rock dried

(equivalent to a maximum particulate emissions of 40lb/hr).

[Rule 62-296.320, F.A.C.]

A.5. Visible emissions from the rock dryer scrubber shall not be equal to or greater than

20 % opacity.

[Rule 62-296.320(4)(b), F.A.C.]

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

A.6. Test the emissions for the following pollutant(s) annually during each federal fiscal

year October1 - September 30 and submit two copies of test data to the Air Management

Division of the Environmental Protection Commission of Hillsborough County within

forty-five days of such testing. Testing procedures shall be consistent with the requirements

of Rule 62-297.310, F.A.C.:

(X) Particulates (X) Sulfur Oxides*

(X) Opacity

* Only required if fuel oil was used to fire the dryer for more than 400 hours in the last 12

months prior to the annual compliance test. Fuel oil analysis to determine sulfur content of

the fuel shall be carried out in accordance with ASTM D129-64 and may be submitted for

required sulfur dioxide emission test.

A.7. Compliance with the emission limitations of Specific Condition No. A.4. and A.5.

shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix

A and adopted by reference in Rule 62-297, F.A.C. The minimum requirements for stack

sampling facilities, source sampling and reporting, shall be in accordance with Rule 62-297,

F.A.C. and 40 CFR 60, Appendix A.

[Rule 62-297, F.A.C]

A.8. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of the maximum 575 TPH of wet phosphate rock

processing rate . If it is impracticable to test at capacity, then the source may be tested at

less than capacity; in this case subsequent source operation is limited to 110% of the test

load until a new test is conducted. Once the unit is so limited, then operation at higher

capacities is allowed for no more than fifteen days for purposes of additional compliance

testing to regain the rated capacity in the permit, with prior notification to the EPC. Failure

to submit the input rates and actual operating conditions may invalidate the test.

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Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

Page 9

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

A.9. The visible emissions test shall be conducted by a certified observer and be a

minimum of 60 minutes in duration. The test observation period shall include the period

during which the highest opacity emissions can reasonably be expected to occur and shall

coincide with the particulate testing.

[Rule 62-297.310(4)(a)2.,F.A.C.]

A.10. If fuel oil of any grade (No 1 to No.6 inclusive) has been used in the rock dryer for

a sum total of more than 400 hours from the date of the previous compliance test, then

compliance testing shall be conducted while firing fuel oil. If a test is conducted while

firing natural gas, and in the 12 month period following the test, oil of any grade is

burned for a sum total of more than 400 hours, then an additional visible emission test per

Condition A.5. shall be conducted, while burning oil in that source, within 30 days of

having exceeded the 400 hour oil burning limit. A compliance test submitted using a

lower grade number fuel oil than grade No. 6 fuel oil, will automatically amend this

operation permit to allow subsequent operation on less than or equal grade numbers than

that lower grade number oil.

[Rule 62-297.310(7), and 62-4.070(3), F.A.C.]

Recordkeeping and Reporting Requirements

A.11. In order to demonstrate compliance with Specific Condition Nos. A.1, A.2, A.4, A.6.

and A.10., the permittee shall maintain monthly records of operations for the most recent

five year period. The records shall be made available to the Environmental Protection

Commission of Hillsborough County, state or federal air pollution agency upon request.

The records shall include, but not limited to, the following:

[Rule 62-296.320, F.A.C.]

a) Month, year

b) Hours of Operation

c) Fuel Type and Usage (gal)

d) Material throughput (TPH)

e) Rolling twelve month total of d) above.

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Exhibit 2

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Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

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Subsection B. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-002 Railcar Unloading Scrubber

-004 C17 transfer point E

EU No. 2: For the operation of a railcar unloading operation. Railcars are pulled into a

partially enclosed structure and unloaded through grates in the floor of the structure into

six hoppers. Emissions from each hopper are vented to a dry cyclone. Butterfly valves in

the riser pipe routed to each dry cyclone will be used to isolate or shut off air flow to

hoppers not being used. Typically four of the six hoppers are used during unloading

operations. Dry phosphate rock is transferred from the unloading hoppers to conveyor

C17 for subsequent storage in silos via conveyors C19 and C38, or it is transferred for

shiploading via conveyors C18, C12, and C13. Fertilizer products (Diammonium

Phosphate (DAP), Monoammonium Phosphate (MAP), Animal Feed Ingredient (AFI),

and Granular Triple Superphosphate (GTSP)) are transferred from the unloading hoppers

to conveyor C17 for subsequent shiploading via conveyors C18, C12, and C13.

Particulate matter emissions generated from the railcar unloading of dry phosphate rock,

MAP, GTSP, and AFI are controlled by six dry cyclones followed by a 100,000 ACFM

Amerex Type C Venturi scrubber. Particulate matter emissions generated from the railcar

unloading of DAP are controlled by the application of a dust suppressant oil applied to

the product at the chemical processing facility prior to shipping. The scrubber will

operate during the unloading of DAP as needed.

EU No. 4: For the operation of the C17 transfer point E. The system is used to transfer

phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) from Conveyor C17

to either Conveyor C18 or C19. Maximum material transfer rate is 1250 TPH for the

pebble phosphate rock and chemical products, and 1800 TPH for the concentrate

phosphate rock.

Particulate emissions generated during the transfer process are controlled by a 6000

ACFM Poly-Con, Model Venturi 1506MS, scrubber.

{Permitting note(s): These emissions unit is regulated under Rules 62-296.320 and 62-

296.711, F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

B.1. Capacity. The maximum product unloading rates are limited as follows:

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Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

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1. Concentrate rock (phosphate rock typically 69-72 BPL grade) 1800 TPH

2. Pebble rock (phosphate rock typically 66-68 BPL grade) 1250 TPH

3. Chemical Products: MAP, DAP, GTSP, AFI 1250 TPH

[Rule 62-4.160(2), F.A.C. , Rule 62-210.200, F.A.C., Definitions - (PTE), and

Construction Permit AC29-237340]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

B.2. The maximum allowable particulate emissions for the scrubbers shall not exceed the

following for any given hour and any 12 consecutive month period:

[Rules 62-4.070(3) and 62-296.711, F.A.C., Construction Permit AC29-237340, and

Alternative RACT determination issued February 23, 1990]

a) EU. No. 2: based on a design flow of 100,000 ACFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 25.7 112.6 0.03 grains/dscf

Visible Emissions 20% opacity

b) EU No. 4 based on a design flow of 6000 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 1.54 6.75 0.03 grains/dscf

B.3. Visible emissions from the railcar unloading structure, EU No. 4 scrubber exhaust and

outside pick up points shall not be equal to or greater than 5 % opacity.

[Rule 62-4.070(3) F.A.C., Construction Permit AC29-237340]

B.4. During the handling of DAP with the scrubber(s) turned off, the following conditions

shall be met:

[Rule 62-4.070(3) F.A.C., Construction Permit AC29-237340]

a) The opacity limitation in Specific Condition No. B.3. shall be monitored by a

certified smoke reader or trained plant personnel.

b) The product shall be sufficiently treated with a non-hazardous oil or dust

suppressant to meet the opacity limit in Specific Condition No. B.3.

Test Methods and Procedures

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Port Sutton Terminal

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{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

B.5. Test the 1)EU No. 2 scrubber exhaust and the railcar unloading enclosure concurrently

and 2)EU No. 4 scrubber exhaust and outside pick up points for the following pollutant(s) )

annually during each federal fiscal year October1 - September 30 and submit two copies of

test data to the Air Management Division of the Environmental Protection Commission of

Hillsborough County within forty-five days of such testing. Testing procedures shall be

consistent with the requirements of Rule 62-297.310, F.A.C.:

(X) Particulates* (X) Opacity *

Scrubber Exhaust Only

B.6. Compliance with the emission limitations of Specific Condition No. B.2. and B.3. shall

be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A

and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be

conducted by a certified observer and be a minimum of sixty (60) minutes in duration for

the scrubber exhaust and thirty (30) minutes in duration for the railcar enclosure. The

minimum requirements for stack sampling facilities, source sampling and reporting, shall be

in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A.

[Rule 62-297, F.A.C]

B.7. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of the maximum unloading rates of 1250 TPH for pebble

rock and 1800 TPH for concentrate rock (note: If dry phosphate rock handling has been and

is expected to remain minimal, testing may be conducted based on the maximum unloading

rate of 1250 TPH for AFI). If it is impracticable to test at capacity, then the source may be

tested at less than capacity; in this case subsequent source operation is limited to 110% of

the test load until a new test is conducted. Once the unit is so limited, then operation at

higher capacities is allowed for no more than fifteen days for purposes of additional

compliance testing to regain the rated capacity in the permit, with prior notification to the

EPC. Failure to submit the input rates and actual operating conditions of the scrubber such

as inlet pressure drop and liquor feed rate, may invalidate the test.

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

B.8. Test the emissions from the railcar enclosure for opacity at least 6 months prior to

the expiration of this permit while unloading oiled DAP at 90 to 100 percent of the rate of

1250 TPH. During testing, the scrubber is not to be operated. Two copies of the test

data are to be submitted to the Air Management Division of the Environmental Protection

Commission of Hillsborough County.

[Rule 62-297,F.A.C. and Rule 62-4.070(3), F.A.C.]

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B.9. The use of dust suppressant in lieu of operating the scrubber for product other than

DAP is allowed provided that IMC-Agrico Company (IMC) satisfies the following

requirements:

[Construction Permit AC29-237340]

a) IMC will notify the EPC prior to the deactivation of control devices for the

purpose of conducting visible emission tests to demonstrate compliance with

the standards.

b) IMC shall conduct an initial compliance test for visible emissions at the railcar

enclosure while handling each additional product. The deactivation of the

control devices is limited to the time required to conduct these tests, until

authorization by the EPC is issued.

c) Testing shall be conducted within 90-100% of the maximum handling rate for

each additional product. The actual handling rate and oil to product ratio

(gallon/ton) shall be included with the test results.

d) Two copies of the test results, along with the applicable permit amendment

requests, shall be submitted to the Air Division of the EPC within 45 days of

testing.

e) The EPC shall acknowledge that the above conditions have been satisfied by

amending the corresponding permits for approval and issuing.

Recordkeeping and Reporting Requirements

B.10. In order to comply with Specific Condition Nos. B.3., B.4., and B.9. the permittee

shall maintain records for the most recent 5 year period. The recordkeeping shall be

made available to the EPC of Hillsborough County, state or federal air pollution agency

upon request. The records shall include, but are not limited to, the following:

[Rule 62-4.070(3), F.A.C.]

a) Typical amount and type of dust suppressant applied (gallon/ton) for each

product unloaded during the preceding month

b) Certificate for smoke reader at the facility who monitored DAP or other

fertilizer product unloading with the scrubber off and/or,

c) Training program for trained plant personnel

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Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

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Subsection C. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-003 Shiploading Baghouse

-005 C12 transfer point A

-006 C30 transfer point C

-013 Shiphold Opening

EU No. 3 and No. 13: The operation of the a) shiploader telescopic chute and OBA

chokefeeder, b) transfer of material from conveyor C14 to the shiphold, and c) final

transfer point from conveyor C13 to conveyor C14. The system is used to transfer

phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) to the shiphold.

The maximum transfer rate is 2300 TPH.

Particulate emissions generated during the transfer operation are controlled by the use of

a modified Mikro-Pulsaire, Model 1F2 baghouse and/or a gantry mounted dust

suppression system. The dust suppression system consists of four (4) spray headers

located throughout the gantry using a surfactant chemical mixed with water.

EU No. 5: For the operation of the C12 Transfer Point A. The system is used to transfer

phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) from conveyor C12

to conveyor C13 at a maximum transfer rate of 2300 TPH.

Particulate emissions generated during the transfer process are controlled by a 8000

ACFM Mikro-Pulsaire, Model 80F2 baghouse.

EU No. 6.: For the operation of the C30 Transfer Point C. The system is used to transfer

various grades of phosphate rock or Animal Feed Ingredients (AFI) from conveyor C30 to

conveyor C12 at a maximum transfer rate of 2300 TPH.

Particulate matter emissions generated during the transfer operation are controlled by a

Mikro-Pulsaire, Model 1215-8-80 baghouse.

{Permitting note(s): These emission units are regulated under Rule 62- 296.711(2)(b),

F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

C.1. Capacity. The maximum transfer rate of material shall not exceed 2300 TPH.

[Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

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Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

C.2. The maximum allowable particulate emissions for these baghouses shall not exceed

the following for any given hour and for any 12 consecutive month period:

[Rule 62-296.711(2)(a), F.A.C.]

a) EU No. 3 based on a design flow of 9000 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 2.31 10.12 0.03 grains/dscf

b) EU No. 5 based on a design flow of 8000 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 1.8 9.0 0.03 grains/dscf

c) EU No. 6 based on a design flow of 6000 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 1.54 6.75 0.03 grains/dscf

C.3. The maximum opacity from the baghouse exhaust and outside pickup point shall

not exceed 5% and the opacity from the discharge to the shiphold shall not exceed 10%.

[Rule 62-296.711(2)(a) and (b), F.A.C.]

C.4. In order to show compliance with the limits of Specific Condition Nos. C.2. and

C.3., the following restrictions shall apply:

[Rule 62-4.070(3)]

a) All dust laden air from the transfer operation shall be vented to the baghouse.

b) The dust suppression system shall be maintained in operable condition so that

it can be operated at any time as necessary during the loading of dry phosphate

rock, as well as other products, to maintain compliance with the permitted

opacity limit of 10% opacity from the discharge to the hold of the ship.

Periods of operation may include, but are not limited to start-up, trimming,

and during upset conditions.

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

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C.5. Test the emissions from the 1) baghouse exhaust (EU No.3), shiphold, and C13 to

C14 transfer point; 2) baghouse exhaust (EU. No.5) and the outside pick up point; and 3)

baghouse exhaust (EU. No.6) and the outside pick up point for opacity annually during

each federal fiscal year October1 - September 30 and submit two copies of test data to the

Air Management Division of the Environmental Protection Commission of Hillsborough

County within forty-five days of such testing. Testing procedures shall be consistent with

the requirements of Rule 62-297.310, F.A.C..

C.6. Test the baghouse exhaust for particulate matter at least 120 days prior to the

expiration date of this permit while handling dry phosphate pebble rock of approximately

68 grade. Particulate test shall be conducted under similar process rate and operating

condition(s) as the visible emission test for the baghouse exhaust. If possible, the visible

emission test shall be performed simultaneously with one of the test run for the particulate

matter emissions.

[Rule 62-297.340(c), F.A.C.]

C.7. Compliance with the emission limitations of Specific Condition No. C.2. and C.3. shall

be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A

and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the

source shall be thirty (30) minutes in duration, and the test shall be conducted concurrently

on the control equipment exhaust and the transfer point. The minimum requirements for

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule

62-297, F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the dust

suppression system was operating during the visible emission readings.

[Rule 62-297, F.A.C]

C.8. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of 2300 TPH of handling rate for dry phosphate rock of

approximately 68 grade (note: If dry phosphate rock handling has been and is expected to

remain minimal, testing may be conducted based on the maximum material transfer rate of

2300 TPH for AFI). If it is impracticable to test at capacity, then the source may be tested at

less than capacity; in this case subsequent source operation is limited to 110% of the test

load until a new test is conducted. Once the unit is so limited, then operation at higher

capacities is allowed for no more than fifteen days for purposes of additional compliance

testing to regain the rated capacity in the permit, with prior notification to the EPC. Failure

to submit the input rates and actual operating conditions may invalidate the test.

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

C.9. The permittee is allowed to handle dust suppressant oiled DAP product with the

control device turned off provided that:

a) Visible emissions at the transfer point shall be less than 5 % opacity.

b) The product shall be sufficiently treated with a non-hazardous oil or dust

suppressant to meet the opacity limit in Specific Condition No. C.5. If a

visible emission test is conducted at the transfer point, the test shall indicate

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the approximate rate of usage of the dust suppressant (gal./ton) and the

approximate date the DAP was oiled. The maximum storage time prior to

handling shall not exceed one month.

c) The maximum oiled DAP product handling rate shall be 1250 TPH as

demonstrated during the initial compliance tests on October 25, 1994.

d) The oiled DAP product handling rate during compliance testing shall be at

approximately (90-100%) of the permitted handling rate of 1250 TPH.

C.10. The use of dust suppressant in lieu of operating the current control systems during

the handling of chemical products other than DAP is allowed provided that the permittee

satisfies the following requirements:

[Rule 62-4.070(3), F.A.C.]

a) IMC will notify the EPC prior to the deactivation of control devices for the

purpose of conducting visible emission tests to demonstrate compliance with

the standards.

b) IMC shall conduct an initial compliance test for visible emissions at each

source for visible emissions (30 minutes, EPA Method 9) at the transfer point

while handling each additional product. The deactivation of the control

devices is limited to the time required to conduct these tests, until

authorization by the EPC is issued.

c) Testing shall be conducted within 90-100% of the maximum handling rate for

each additional product. The actual handling rate and oil to product ratio

(gallon/ton) and maximum product storage time shall be included with the test

results.

d) Two copies of the test results, along with the applicable permit amendment

requests, shall be submitted to the Air Division of the EPC within 45 days of

testing.

e) The EPC shall acknowledge that the above conditions have been satisfied by

amending the corresponding permits for approval and issuing.

Recordkeeping and Reporting Requirements

C.11. In order to demonstrate compliance with Specific Condition Nos. C.1., the permittee

shall maintain records of operations for the most recent five year period. The records shall

be made available to the Environmental Protection Commission of Hillsborough County,

state or federal air pollution agency upon request. The records shall include, but not limited

to, the following:

[Rule 62-4.070(3), F.A.C.]

a) Month, year

b) Hours of operation

c) Material throughput (TPH)

d) Rolling twelve month total of c) above.

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Subsection D. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-007 C18 Conveyor Transfer Point D

-009 C19 Conveyor Transfer Point G

EU No. 7: For the operation of the C18 conveyor transfer point D. The system is used

to transfer phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) from

conveyor C18 to conveyor C12. Maximum material transfer rate is 1250 TPH for pebble

phosphate rock and chemical products and 1800 TPH for concentrate phosphate rock.

Particulate matter emissions generated during the transfer process are controlled by a

6000 ACFM Mikro-Pulsaire, Model 1215-8-80 baghouse.

EU No. 9: For the operation of the C19 Conveyor Transfer Point G. The system is used

to transfer various grades of phosphate rock or Animal Feed Ingredients (AFI) from

Conveyor C19 to Conveyor C38 at the maximum transfer rate of 1250 tons per hour.

Particulate matter emissions generated during the transfer process are controlled by a

5000 ACFM Mikro-Pulsaire, Model 100S-8-TR-20 baghouse.

{Permitting note(s): These emission units are regulated under Rule 62- 296.711(2)(b),

F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

D.1. Capacity. The maximum transfer rate of material shall not exceed:

1. Concentrate rock (phosphate rock typically 69-72 BPL grade) 1800 TPH

2. Pebble rock (phosphate rock typically 66-68 BPL grade) 1250 TPH

3. Chemical Products: MAP, DAP, GTSP, AFI 1250 TPH

[Rule 62-4.160(2), F.A.C. , Rule 62-210.200, F.A.C., Definitions - (PTE)]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

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D.2. The maximum allowable particulate emissions for these baghouses shall not exceed

the following for any given hour and for any 12 consecutive month period:

[Rule 62-296.711(2)(b), F.A.C.]

a) EU No. 7 based on a design flow of 6000 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 1.54 6.75 0.03 grains/dscf

b) EU No. 9 based on a design flow of 4096 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 1.05 4.6 0.03 grains/dscf

D.3. The maximum opacity from the baghouse exhaust and the outside pickup point shall

not exceed 5% .

[Rule 62-296.711(2)(a) and (b), F.A.C.]

D.4. In order to show compliance with the limits of Specific Condition Nos. D.2. and

D.3., the following restrictions shall apply:

[Rule 62-4.070(3)]

a) All dust laden air from the transfer operation shall be vented to the baghouse.

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

D.5. Test the emissions from the baghouse exhaust and the outside pickup points

concurrently for opacity annually during each federal fiscal year October1 - September 30

and submit two copies of test data to the Air Management Division of the Environmental

Protection Commission of Hillsborough County within forty-five days of such testing.

Testing procedures shall be consistent with the requirements of Rule 62-297.310, F.A.C..

D.6. Test the baghouse exhaust for particulate matter at least 120 days prior to the

expiration date of this permit while handling dry phosphate pebble rock of approximately

68 grade. Particulate test shall be conducted under similar process rate and operating

condition(s) as the visible emission test for the baghouse exhaust. If possible, the visible

emission test shall be performed simultaneously with one of the test run for the particulate

matter emissions.

[Rule 62-297.340(c), F.A.C.]

D.7. Compliance with the emission limitations of Specific Condition No. D.2. and D.3.

shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix

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A and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the

source shall be thirty (30) minutes in duration, and the test shall be conducted concurrently

on the control equipment exhaust and the transfer point. The minimum requirements for

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule

62-297, F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the dust

suppression system was operating during the visible emission readings.

[Rule 62-297, F.A.C]

D.8. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of a) 1250 TPH of handling rate for dry phosphate pebble

rock of 68 grade and b) 1800 TPH for concentrated phosphate (note: If dry phosphate rock

handling has been and is expected to remain minimal, testing may be conducted based on

the maximum material transfer rate of 1250 TPH for AFI). If it is impracticable to test at

capacity, then the source may be tested at less than capacity; in this case subsequent source

operation is limited to 110% of the test load until a new test is conducted. Once the unit is

so limited, then operation at higher capacities is allowed for no more than fifteen days for

purposes of additional compliance testing to regain the rated capacity in the permit, with

prior notification to the EPC. Failure to submit the input rates and actual operating

conditions may invalidate the test.

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

D.9. The permittee is allowed to handle dust suppressant oiled DAP product with the

control device turned off provided that:

a) Visible emissions at the transfer point shall be less than 5 % opacity.

b) The product shall be sufficiently treated with a non-hazardous oil or dust

suppressant to meet the opacity limit in Specific Condition No. D.5. If a

visible emission test is conducted at the transfer point, the test shall indicate

the approximate rate of usage of the dust suppressant (gal./ton) and the

approximate date the DAP was oiled. The maximum storage time prior to

handling shall not exceed one month.

c) The maximum oiled DAP product handling rate shall be 1250 TPH as

demonstrated during the initial compliance tests on October 25, 1994.

d) The oiled DAP product handling rate during compliance testing shall be at

approximately (90-100%) of the permitted handling rate of 1250 TPH.

D.10. The use of dust suppressant in lieu of operating the current control systems during

the handling of chemical products other than DAP is allowed provided that the permittee

satisfies the following requirements:

[Rule 62-4.070(3), F.A.C.]

a) IMC will notify the EPC prior to the deactivation of control devices for the

purpose of conducting visible emission tests to demonstrate compliance with

the standards.

b) IMC shall conduct an initial compliance test for visible emissions at each

source for visible emissions (30 minutes, EPA Method 9) at the transfer point

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while handling each additional product. The deactivation of the control

devices is limited to the time required to conduct these tests, until

authorization by the EPC is issued.

c) Testing shall be conducted within 90-100% of the maximum handling rate for

each additional product. The actual handling rate and oil to product ratio

(gallon/ton) and maximum product storage time shall be included with the test

results.

d) Two copies of the test results, along with the applicable permit amendment

requests, shall be submitted to the Air Division of the EPC within 45 days of

testing.

e) The EPC shall acknowledge that the above conditions have been satisfied by

amending the corresponding permits for approval and issuing.

Recordkeeping and Reporting Requirements

D.11. In order to demonstrate compliance with Specific Condition Nos. D.1., the permittee

shall maintain records of operations for the most recent five year period. The records shall

be made available to the Environmental Protection Commission of Hillsborough County,

state or federal air pollution agency upon request. The records shall include, but not limited

to, the following:

[Rule 62-4.070(3), F.A.C.]

a) Month, year

b) Hours of operation

c) Material throughput (TPH)

d) Rolling twelve month total of c) above.

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Subsection E. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-008 Animal Feed Ingredient Handling

For the operation of a truck unloading station, three storage silos, and a transfer conveyor

system for animal feed ingredient storage facility. Particulate matter emissions generated

during the loading of any silo are controlled by one common Mikro-Pulsaire Model 49S8-20 baghouse. Conveyor transfer points and the truck unloading station are covered by

enclosures.

{Permitting note(s): These emission units are regulated under Rule 62- 296.711(2)(b),

F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

E.1. Capacity. The maximum material handling rate shall not exceed 120 tons per hour

and 300,000 tons per year of animal feed ingredient for any 12 consecutive month period.

[Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE),

Construction Permit AC-22822]

E.2. Hours of Operation. The hours of operation for this emissions unit shall not exceed

2,500 hours/year.

[Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

E.3. The maximum allowable particulate emissions for this baghouse shall not exceed the

following for any given hour and for any 12 consecutive month period:

[Rule 62-296.711(2)(b), F.A.C., Construction Permit AC-22822]

a) EU No. 8 based on a design flow of 3540 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 0.5 0.6 0.02 grains/dscf

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E.4. The maximum allowable unconfined particulate emissions for the enclosure shall not

exceed 5.14 tons per consecutive 12 month period.

[Rule 62-4-070(3), F.A.C. and AC-22822]

E.5. The maximum opacity from the baghouse exhaust and the outside pickup point shall

not exceed 5% .

[Rule 62-296.711(2)(a) and (b), F.A.C.]

E.6. In order to show compliance with the limits of Specific Condition Nos. E.1., E.3.,

E.4. and E.5., the following restrictions shall apply:

[Rule 62-4.070(3)]

a) All dust laden air from the transfer operation shall be vented to the baghouse.

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

E.7. Test the emissions from the baghouse exhaust for the following pollutant(s) annually

during each federal fiscal year October1 - September 30 and submit two copies of test data

to the Air Management Division of the Environmental Protection Commission of

Hillsborough County within forty-five days of such testing. Testing procedures shall be

consistent with the requirements of Rule 62-297.310, F.A.C.:

(X) Particulate* (X) Opacity

* The particulate emission test may be waived if a test is submitted demonstrating

compliance with the 5% opacity standard.

E.8. Compliance with the emission limitations of Specific Condition No. E.3. and E.5. shall

be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A

and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the

source shall be thirty (30) minutes in duration, and the test shall be conducted concurrently

on the control equipment exhaust and the transfer point. The minimum requirements for

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule

62-297, F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the dust

suppression system was operating during the visible emission readings.

[Rule 62-297, F.A.C]

E.9. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of 120 tons per hour of animal feed ingredient. If it is

impracticable to test at capacity, then the source may be tested at less than capacity; in this

case subsequent source operation is limited to 110% of the test load until a new test is

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conducted. Once the unit is so limited, then operation at higher capacities is allowed for no

more than fifteen days for purposes of additional compliance testing to regain the rated

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates

and actual operating conditions may invalidate the test.

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

Recordkeeping and Reporting Requirements

E.10. In order to demonstrate compliance with Specific Condition Nos. E.1. and E.2., the

permittee shall maintain records of operations for the most recent five year period. The

records shall be made available to the Environmental Protection Commission of

Hillsborough County, state or federal air pollution agency upon request. The records shall

include, but not limited to, the following:

[Rule 62-4.070(3), F.A.C.]

a) Month, year

b) Hours of operation

c) Material throughput (TPH)

d) Rolling twelve month total of c) above.

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Subsection F. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-012 Conveyor transfer points from railcar unloading and rock dryer to storage silos

For a material (dry phosphate rock) handling operation consisting of two (2) belt

conveyor transfer points and two (2) drop points serving sixteen (16) outer storage silos

and seven (7) smaller inner silos. The material originates at a phosphate rock dryer and at

a railcar unloading operation which have a maximum production rates as follows:

- Phosphate rock dryer: Depending on the moisture content of the rock, which is

variable and based on 575 TPH

- Railcar unloading operation: 1,250 tons per hour based on an individual railcar

load.

The phosphate rock dryer and the rail car unloading can operate simultaneously to

produce the maximum material handling rate for this operation.

Particulate matter emissions generated by this material handling operation are controlled by

a 23,100 DSCFM Ducon Venturi Oriclone, VVO, 36/84 scrubber located at ground level

directly north of the storage silos. The scrubber has three vents which pickup on: (1) outer

silos 9-16, inner silos 21-23, and conveyor 27; (2) outer silo 7, inner silo 20, conveyors 38

and 44; (3) and outer silos 1-6, 8 and inner silos 17-19. The phosphate rock dryer and the

railcar unloading operation are permitted above.

{Permitting note(s): These emission units are regulated under Rule 62- 296.711(2)(b),

F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

F.1. Capacity. The maximum transfer rate of material shall not exceed:

1. Railcar Unloading 1250 TPH

2. Rock Dryer 575 TPH

[Rule 62-4.160(2), F.A.C. , Rule 62-210.200, F.A.C., Definitions - (PTE)]

Emission Limitations and Standards

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{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

F.2. The maximum allowable particulate emissions for the scrubber shall not exceed the

following for any given hour and for any 12 consecutive month period:

[Rule 62-296.711(2)(b), F.A.C.]

a) EU No. 12 based on a design flow of 23100 DSCFM:

Pollutant lbs./hr. tons/yr. Emission Limitation

Particulate Matter 5.94 26.01 0.03 grains/dscf

F.3. The maximum opacity from the scrubber exhaust and the outside pickup point shall

not exceed 5% .

[Rule 62-296.711(2)(a) and (b), F.A.C.]

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

F.4. Test the emissions from the scrubber exhaust and the outside pickup points

concurrently for the following pollutant(s) ) annually during each federal fiscal year

October1 - September 30 and submit two copies of test data to the Air Management

Division of the Environmental Protection Commission of Hillsborough County within

forty-five days of such testing. Testing procedures shall be consistent with the requirements

of Rule 62-297.310, F.A.C.:

(X) Opacity

(X) Air Flow Rate (Scrubber exhaust only)

(X) Particulate Matter*

*Prior to permit renewal

F.5. Compliance with the emission limitations of Specific Condition No. F.2. and F.3. shall

be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A

and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the

source shall be thirty (30) minutes in duration, and the test shall be conducted concurrently

on the control equipment exhaust and the transfer point. The minimum requirements for

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule

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62-297, F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the dust

suppression system was operating during the visible emission readings.

[Rule 62-297, F.A.C]

F.6. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of the maximum handling rate which requires the

simultaneous operation of the rock dryer and the railcar (note: If dry phosphate rock

handling has been and is expected to remain minimal, testing may be conducted based on

the maximum material railcar unloading rate of 1250 TPH for AFI). If it is impracticable to

test at capacity, then the source may be tested at less than capacity; in this case subsequent

source operation is limited to 110% of the test load until a new test is conducted. Once the

unit is so limited, then operation at higher capacities is allowed for no more than fifteen

days for purposes of additional compliance testing to regain the rated capacity in the permit,

with prior notification to the EPC. Failure to submit the input rates and actual operating

conditions may invalidate the test.

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

Recordkeeping and Reporting Requirements

F.7. In order to demonstrate compliance with Specific Condition No. F.1., the permittee

shall maintain records of operations for the most recent five year period. The records shall

be made available to the Environmental Protection Commission of Hillsborough County,

state or federal air pollution agency upon request. The records shall include, but not limited

to, the following:

[Rule 62-4.070(3), F.A.C.]

a) Month, year

b) Hours of operation

c) Material throughput (TPH)

d) Rolling twelve month total of c) above.

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Subsection G. This section addresses the following emissions unit(s).

E.U.

ID No. Brief Description

-100 DAP Truck Unloading Station No.2

For the operation of DAP truck unloading station No. 2. The trucks are driven into a

partially enclosed structure and unloaded through grates in the floor of the structure. The

DAP drops onto conveyor C-2 which operates at 339 fpm. Conveyor C-2 transfers the DAP

to the bucket elevator C-3. The bucket elevator is capable of elevating 250 TPH. The

bucket elevator transfers the DAP to conveyor C-4 at a rate of 687 fpm. Conveyor C-4

transfers the product to conveyor C-7. Conveyor C-7 transports at a rate of 621 fpm.

Conveyor C-4 and C-7 are completely enclosed in a building and the DAP is coated with a

dust suppressant oil to control emissions.

{Permitting note(s): These emission units are regulated under Rule 62- 296.711(2)(b),

F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

G.1. Capacity. The maximum truck unloading rate shall not exceed 250 tons per hour of

oiled DAP.

[Rule 62-4.160(2), F.A.C. , Rule 62-210.200, F.A.C., Definitions - (PTE)]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms,

summarizes information for convenience purposes only. This table does not supersede

any of the terms or conditions of this permit.}

G.2. The maximum opacity from the emission unit shall not exceed 5% .

[Rule 62-296.711(2)(a) and (b), F.A.C.]

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes

information for convenience purposes only. This table does not supersede any of the

terms or conditions of this permit.}

G.3. Test the emissions from the emission unit for the following pollutant(s) ) annually

during each federal fiscal year October1 - September 30 and submit two copies of test data

to the Air Management Division of the Environmental Protection Commission of

Regional Haze SIP for Florida 

Exhibit 2

Page 460 of 501
Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV

Port Sutton Terminal

Page 30

Hillsborough County within forty-five days of such testing. Testing procedures shall be

consistent with the requirements of Rule 62-297.310, F.A.C.:

(X) Opacity

G.4. Compliance with the emission limitations of Specific Condition No. G.2. shall be

determined using EPA Method 9 contained in 40 CFR 60, Appendix A and adopted by

reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the source shall be

thirty (30) minutes in duration, and the test shall be conducted concurrently on the control

equipment exhaust and the unloading point. The minimum requirements for stack sampling

facilities, source sampling and reporting, shall be in accordance with Rule 62-297, F.A.C.

and 40 CFR 60, Appendix A. The test report shall indicate whether the dust suppression

system was operating during the visible emission readings.

[Rule 62-297, F.A.C]

G.5. Testing of emissions shall be conducted with the source operating at capacity.

Capacity is defined as 90-100% of the maximum handling rate described above. If it is

impracticable to test at capacity, then the source may be tested at less than capacity; in this

case subsequent source operation is limited to 110% of the test load until a new test is

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no

more than fifteen days for purposes of additional compliance testing to regain the rated

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates

and actual operating conditions may invalidate the test.

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

Recordkeeping and Reporting Requirements

G.6. In order to demonstrate compliance with Specific Condition No. G.1., the permittee

shall maintain records of operations for the most recent five year period. The records shall

be made available to the Environmental Protection Commission of Hillsborough County,

state or federal air pollution agency upon request. The records shall include, but not limited

to, the following:

[Rule 62-4.070(3), F.A.C.]

a) Month, year

b) Hours of operation

c) Material unloaded (TPH)

d) Rolling twelve month total of c) above.

Regional Haze SIP for Florida 

Exhibit 2

Page 461 of 501
 

Kinder Morgan Terminals 

Tampaplex Terminal 

Facility ID No.: 0570024 

Hillsborough County 

 

Title V Air Operation Permit Revision 

FINAL Title V Permit No.: 0570024-014-AV 

Permitting Authority:

Environmental Protection Commission 

of Hillsborough County 

3629 Queen Palm Dr. 

Tampa, FL 33619 

Telephone: (813) 627-2600 

Fax: (813) 627-2660 

 

Regional Haze SIP for Florida 

Exhibit 2

Page 462 of 501
Title V Air Operation Permit Revision 

FINAL Title V Permit No.: 0570024-014-AV 

Table of Contents

Section Page Number 

Statement of Basis................................................................................................... ii 

Placard Page............................................................................................................ 1 

I. Facility Information ............................................................................................. 2 - 6 

 A. Facility Description. 

 B. Summary of Emissions Unit ID No(s). and Brief Description(s). 

 C. Relevant Documents. 

II. Facility-wide Conditions .................................................................................... 7 - 12 

III. Emissions Unit(s) and Conditions..................................................................... 13 - 38 

A. -002 Railcar Unloading 

-004 C17 Transfer Point E (C17 to C18 or C17 to C19) 

B. -003 Shiploading Operation (C13 to C14) 

-005 C12 Transfer Point A (C12 to C13) 

-006 C30 Transfer Point C (C30 to C12) 

-013 Shiphold Loading (C14 to Shiphold) 

C. -007 C18 Transfer Point D (C18 to C12) 

-009 C19 Transfer Point G (C19 to C38) 

D. -008 Material Handling and Storage Silos 

E. -012 Railcar Transfer to Storage Silos (C19 to C38) 

F. -100 Truck and Railcar Unloading Station No. 2 and Transfer Points (C2, 

 C3, C4, C7, C11, C94) in Storage Building Nos. 1 and 2 

G. -102 Truck Unloading Station No. 1 and Transfer Point (C82 to C83) 

 - 103 Transfer Points (C83, C84 and C104) in Storage Building No. 3 

H. - 104 – 112 Stevedoring Operations: 

104 Clamshell to Hopper(s) RH-01 and RH-02 

105 RH-01 and RH-02 to Conveyor BC-01 

106 Conveyor BC-01 to Radial Stacker RS-01 

107 RS-01 to Conveyor BC-02 or Conveyor PC-01 

108 Conveyor BC-02 to Conveyor BC-03 or PC-01 to Conveyor PC-02 

109 Conveyor BC-03 to Stacker Wing or PC-02 to Radial Stacker RS-02 

110 Stacker Wing to Storage Pile or RS-02 to Storage Pile 

111 Front End Loader to Truck 

 112 Stevedoring at Other Berths

 

Regional Haze SIP for Florida 

Exhibit 2

Page 463 of 501
Permittee: FINAL Permit No. 0570024-014-AV

Kinder Morgan Terminals Facility ID No.: 0570024 

Tampaplex Terminal SIC Nos.: 51 

5321 Hartford St. Project: Bulk Material Handling 

Tampa, FL 33619 

 

This permit is for the revision of a phosphate rock, animal feed ingredient (AFI), fertilizer 

products (MAP, DAP, GTSP) and other bulk materials handling facility to include the 

operation of a marine vessel (stevedoring) bulk material loading and unloading operation and 

stockpiling. This facility is located at 4801 Port Sutton Road, Tampa, Hillsborough County; 

UTM Coordinates: Zone 17,360.1 km East and 3087.5 km North; Latitude: 27° 54’ 24” 

North and Longitude: 82° 25’ 18” West. 

This Title V Air Operation Permit Revision is issued under the provisions of Chapter 403, 

Florida Statutes (F.S.), and Florida Administrative Code (F.A.C.) Chapters 62-4, 62-210 and 

62-213. The above named permittee is hereby authorized to operate the facility shown on the 

application and approved drawing(s), plans, and other documents, attached hereto or on file 

with the permitting authority, in accordance with the terms and conditions of this permit. 

Referenced attachments made a part of this permit:

Appendix I-1, List of Insignificant Emissions Units and/or Activities 

Appendix O-1, Operation and Maintenance Plans for Particulate Control 

Appendix CAM 

APPENDIX TV-6, TITLE V CONDITIONS (version dated 6/23/2006) 

APPENDIX SS-1, STACK SAMPLING FACILITIES (version dated 10/07/96) 

 Effective Date: October 28, 2009 

 Renewal Application Due Date: September 16, 2012 

 Expiration Date: April 29, 2013 

 ___________________________ 

 Richard D. Garrity, Ph.D. 

 Executive Director 

RDG/LAW/law 

Regional Haze SIP for Florida 

Exhibit 2

Page 464 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

 

Page 2 of 38 

Section I. Facility Information.

Subsection A. Facility Description.

This facility consists of truck and railcar unloading operations, a ship loading operation, silo 

and building storage for phosphate rock, animal feed ingredient (AFI), fertilizer products 

(MAP, DAP, GTSP) and other bulk materials as defined in this permit’s material handling 

list/group description. In addition, the facility operates a marine vessel (stevedoring) loading 

and unloading operation of various bulk materials. 

The facility receives dry phosphate rock, AFI, and fertilizer products by truck or railcar to the 

facility, which is stored within enclosed storage silos or buildings until transported off site by 

ship or barge. The products can also be transferred directly to a shiphold from a truck or 

railcar. The majority of these material handling operations are enclosed and controlled 

through baghouses. The following is a more detailed process of this operation. 

During the railcar unloading operation (EU 002), the railcars are pulled into a partially 

enclosed structure and bottom unloaded through grates in the floor of the structure into six 

hoppers. Emissions from the hoppers are vented to dry cyclones. Typically four of the six 

hoppers are used during unloading operations. Material can then transferred from the 

unloading hoppers to conveyor C17 for subsequent storage in silos via conveyors C19 and 

C38 (EU 012), or transferred for ship loading via conveyors C18, C12, C13 and C14. The 

material that will be stored in the silos can be conveyed to the outer silo Nos. 1 – 16 using a 

series of conveyor belts, Conveyor Belt Nos. C27, C44, and C28, or to the inner silo Nos. 17 

-23 using a series of conveyor belts, Conveyor Belt Nos. C19, C38, and C29. All silos are 

unloaded using Conveyor Belt No. 30 prior to ship loading. 

Particulate matter emissions generated from the railcar unloading operation are controlled by 

six parallel dry cyclones followed by a 100,000 ACFM Amerex Type C Venturi scrubber 

and/or by the application of dust suppressant oil applied to the fertilizer product at the 

chemical processing facility prior to shipping. Particulate matter emissions generated from the 

silo loading are controlled by a 23,100 DSCFM Ducon Venturi Oriclone, VVO, 36/84 scrubber 

located at ground level directly north of the storage silos. 

The facility operation of the various conveyor transfer points include the following; C12 

Transfer Point A (EU 005), C30 Transfer Point C (EU 006), C18 Transfer Point D (EU 007), 

C19 Transfer Point G (EU 009) and C17 Transfer Point E (EU 004). Particulate matter 

emissions generated during these transfer processes are controlled by Mikro-Pulsaire 

baghouses, except for C17 Transfer Point E, which is controlled by a 6000 ACFM Poly-Con, 

Model Venturi 1506MS, scrubber. 

The material handling and storage operation (EU 008) consists of a truck unloading 

station, three storage silos, and a transfer conveyor system. Material is conveyed from 

the truck unloading station to three storage silos using Conveyor Belt No. C92. When the 

material is ready for shiploading, it is unloaded from the silos and conveyed to Conveyor 

Belt No. C12 using Conveyor Belt No. C93, and then conveyed to Conveyor Belt Nos. 

C13, and C14 prior to loading on the ship. Particulate matter emissions generated during 

the loading of any silo are controlled by a common Mikro-Pulsaire baghouse. Particulate 

Regional Haze SIP for Florida 

Exhibit 2

Page 465 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 3 of 38

matter emissions from the conveyor transfer point (C93 to C12) and the truck unloading 

station are controlled through the use of partial enclosures. 

Trucks can unload material at the truck unloading Station No. 1. Trucks are driven into a 

partially enclosed structure and unload material through grates in the floor of the structure. The 

materials are dropped onto Conveyor Belt No. C82, which transfers the material from the truck 

unloading Station No. 1 to Conveyor Belt No. C83 (EU 102). This transfer point is entirely 

enclosed. Conveyor Belt No. C83 transfers the material to Conveyor Belt No. C84, which is 

located inside Storage Building No. 3 (EU 103). Inside the building there is a movable tipper 

which allows the storage piles to be placed at different locations within the building. Materials 

are moved within the building with a front end loader, which is also used to transfer the material 

out of the building to a hopper located on the side of the storage building. The hopper feeds 

Conveyor Belt No. C104, which transfers material to Conveyor Belt No. C12, using the C12 

Transfer Point A associated with EU 005. Storage Building No. 3 is solely associated with 

Truck Unloading Station No.1. Particulate matter emissions are controlled through the use of 

dust suppressants (oiling) and enclosures. 

Trucks can also unload material at Station No. 2 (EU 100), where they are driven into a partially 

enclosed structure and unload through grates in the floor of the structure. The material is 

conveyed into three storage silos using a series of conveyor belts, Conveyor Belt Nos. C2, C4, 

C7, and C94, and a bucket elevator, No. C3. Conveyor Belt No. C4 can transfer the material to 

either Conveyor Belt No. C7 or C11. Conveyor Belt No. C7 transfers material to Conveyor 

Belt No. C94 which loads the three storage silos associated with EU 008. Conveyor Belt No. 

C11 transfers material to Transfer Point D (EU 007). Conveyor Belt Nos. C4 and C7 are 

completely enclosed in Storage Building Nos. 1 and 2. Material is also stored in the Blackpoint 

Storage Building, located on a Kinder Morgan land parcel west of the Tampaplex facility, 

across the TECO discharge slip. The Blackpoint Storage Building is used to store bagged 

product only. 

The ship loading operation (EU 013) involves the loading of phosphate rock, fertilizer 

products, AFI and/or other bulk material, which can be conveyed either directly from the 

railcar, truck, storage buildings, or from the storage silos to the shiphold using a series of 

conveyor belts, Conveyor Belt Nos. C12, C13, and C14. A telescopic chute and an OBA 

chokefeeder are used to load the shiphold. Particulate matter emissions generated during the 

shiphold loading operation are controlled by a modified 9,000 DSCFM Mikro-Pulsaire, 

Model 1F2, baghouse and/or a gantry mounted dust suppression system. The dust 

suppression system consists of four spray headers located throughout the gantry using a 

surfactant chemical that is mixed with water. 

Kinder Morgan is also authorized to operate a marine vessel (stevedoring) bulk material 

loading and unloading operation at the Kinder Morgan’s Tampaplex location and at numerous 

berths in Hillsborough County. The stevedoring operation involves the loading and unloading 

of various bulk materials that include fertilizer materials, coal, limestone, granite, bauxite, 

etc., onto and from marine vessels. These materials are divided into different group 

categories. 

 

Regional Haze SIP for Florida 

Exhibit 2

Page 466 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 4 of 38

At the Tampaplex Terminal, material is unloaded from a ship by one of two clamshells. The 

clamshell transfers the material to one of two onshore receiving hoppers. Both hoppers, RH01 and RH-02 (EU 104) are equipped with windshields and water sprays. From the hoppers, 

material is gravity transferred to a belt conveyor, BC-01 (EU 105), and then to a Radial 

Switch Stacker, RS-01 (EU 106). From RS-01, material can be transferred in two directions. 

From RS-01, material is gravity fed to a belt conveyor, PC-01 (EU 107), then to a second 

conveyor belt PC-02 (EU 108), and then to a second Radial Switch Stacker, RS-02 (EU 109). 

From RS-02, material is loaded directly into a truck or stockpiled on the ground (EU 110). A 

front-end loader loads the material into a truck (EU 111) for shipment offsite or for 

transporting the material to the storage areas. 

If material is directed to the dual wing stacker, material from Radial Switch Stacker, RS-01, 

is gravity transferred to a belt conveyor, BC-02 (EU 107), then to a chute, and then to an 

uncovered belt conveyor, BC-03 (EU 108). Material is transferred from BC-03 to a dual 

wing stacker (EU 109) where it is stockpiled (EU 110) in one of two storage areas, the north 

and south storage areas. From the storage areas, a front-end loader loads the material into a 

truck (EU 111) for shipment offsite. 

All conveyor belts and radial stackers have partial enclosures except for Conveyors BC-01 

and BC-03. Conveyor BC-01 has side skirts only because the receiving hoppers can travel 

along the length of the conveyor belt and partial enclosure would hinder the movement of the 

receiving hoppers. Conveyor BC-03 has side skirts at the chute transfer point because it is 

equipped with a moveable dual-wing stacker that travels along the length of the conveyor, 

which prevents the installation of covers or side skirts along that length. All of the conveyors 

and radial stackers are equipped with a water spray system. Certain materials (i.e., bauxite, 

magnetite, etc.), due to their physical nature, cannot be unloaded using the conveyor system. 

To unload these and any other materials in a manner outlined below for offsite operations, the 

clamshell transfers material from the ship directly into a truck or into a receiving hopper and 

into a truck for shipment offsite or for storage. Bauxite is required to be coated with a dust 

suppressant at the first transfer point at the Tampaplex Site. 

In addition the Kinder Morgan Tampaplex site can receive products onto the site from Belted 

Self Unloading Vessels. During this operation the vessel will be equipped with an 

extendable conveyor belt that would transfer product directly onto a storage pile. A front-end 

loader loads the material into a truck for shipment offsite. 

Particulate matter (PM) emissions from these facility operations are controlled by the use of a 

water spray system and partial enclosures, and or dust suppressants. The facility operates a truck 

wheel wash to wash particulate material from truck tires prior to the trucks leaving the site. 

When operating at berths other than the Kinder Morgan’s Tampaplex site, the Stevedoring 

operation operates as follows: 

A maximum of three, portable clamshells used to either load or unload material from a ship are 

mounted to barges and moved to any of the Berths listed below. The clamshells may operate at 

a maximum of three berths simultaneously. 

Regional Haze SIP for Florida 

Exhibit 2

Page 467 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 5 of 38

When material is unloaded from ships, material is transferred from the shiphold using one of the 

three clamshells to a portable receiving hopper, then to a truck, and then transported either 

offsite or to a storage pile. The receiving hoppers are equipped with windshields and a water 

spray system around the perimeter. 

When material will be loaded into ships, trucks transport the material to the dock and the 

portable clamshells transfer the material from the dock into a shiphold. However, the material 

should not stockpiled on the dock longer than 24 hours. 

The Stevedoring operation is permitted to operate at the following berths in Hillsborough 

County: 

1, 2, 3, 23, 24, 24B, North Star Recycling Slip 30, 31, 201, 202, 204, 205, 206, 208, 209, 210, 

211, 212, 214, 215, 219, 220, 223, 224, 225, 227, 230, 232, 250, 251, 252, 253, 256, 263, 264, 

265, 268, 272, 273, 

Kinder Morgan’s Tampaplex Terminal 

Port Tampa (near Picnic Island): 119 - Tampa Bulk Services 

Rattlesnake Point: 126 - Misener Rock Company 

Alafia River: Cargill Fertilizer Dock 

The facility is subject to Rules 62-296.320 – General Pollutant Emission Limiting Standards and 

62-296.711, F.A.C. - Materials Handling, Sizing, Screening, Crushing and Grinding Operations 

and Chapter 1-3.52, Rules of the EPC, which limit the visible emissions to a 5% opacity 

standard for all of the material handling operations. EPA Method 5 and EPA Method 9 testing 

have been determined by the Agency to satisfy the requirements of 40 CFR 70.6 and Chapter 

62-296, F.A.C. 

Also included in this permit are miscellaneous insignificant emissions units and/or activities.

Based on the Title V Air Operation Permit Revision application received October 8, 2007, 

this facility is not a major source of hazardous air pollutants (HAPs).

Subsection B. Summary of Emissions Unit ID No(s). and Brief Description(s). 

E.U. ID 

No.

Brief Description

-002 Railcar Unloading 

-003 Shiploading Operation (C13 to C14) 

-004 C17 Transfer Point E (C17 to C18 or C17 to C19) 

-005 C12 Transfer Point A (C12 to C13) 

-006 C30 Transfer Point C (C30 to C12) 

-007 C18 Transfer Point D (C18 to C12) 

-008 Material Handling and Storage Silos 

-009 C19 Transfer Point G (C19 to C38) 

-012 Railcar Transfer to Storage Silos (C19 to C38) 

-013 Shiphold Loading (C14 to Shiphold) 

-100 Truck and Railcar Unloading Station No. 2 and Transfer Points (C2, C3, C4, 

C7, C11, C94) in Storage Building Nos. 1 and 2 

-102 Truck Unloading Station No. 1 and Transfer Point (C82 to C83) 

Regional Haze SIP for Florida 

Exhibit 2

Page 468 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 6 of 38

-103 Transfer Points (C83, C84 and C104) in Storage Building No. 3 

-104 - 112 Stevedoring Operation: 

-104 Clamshell to Hopper(s) RH-01 and RH-02 

-105 RH-01 and RH-02 to Conveyor BC-01 

-106 Conveyor BC-01 to Radial Stacker RS-01 

-107 RS-01 to Conveyor BC-02 or Conveyor PC-01 

-108 Conveyor BC-02 to Conveyor BC-03 or PC-01 to Conveyor PC-02 

-109 Conveyor BC-03 to Stacker Wing or PC-02 to Radial Stacker RS-02 

-110 Stacker Wing to Storage Pile or RS-02 to Storage Pile 

-111 Front End Loader to Truck 

-112 Stevedoring at Other Berths

Please reference the Permit No., Facility ID No., and appropriate Emissions Unit(s) ID 

No(s). on all correspondence, test report submittals, applications, etc. 

Subsection C. Relevant Documents. 

The documents listed below are not a part of this permit, however, are specifically related 

to this permitting action. 

These documents are provided to the permittee for information purposes only:

Table 1-1, Summary of Air Pollutant Standards and Terms 

Table 2-1, Summary of Compliance Requirements 

Appendix A-1, Abbreviations, Acronyms, Citations, and Identification Numbers 

Appendix H-1, Permit History/ID Number Changes 

These documents are on file with permitting authority:

Initial Title V Permit Application received June 14, 1996 

Initial Title V Permit issued October 26, 2000 

Title V Air Operation Permit Revision issued May 30, 2001 

Title V Air Operation Permit Administrative Correction issued January 21, 2004 

Title V Air Operation Permit Renewal issued April 29, 2008

Regional Haze SIP for Florida 

Exhibit 2

Page 469 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 7 of 38

Section II. Facility-wide Conditions. 

The following conditions apply facility-wide:

1. General Pollutant Emission Limiting Standards. Objectionable Odor Prohibited. 

No person shall cause, suffer, allow, or permit the discharge of air pollutants which cause 

or contribute to an objectionable odor. 

[Rule 62-296.320(2), F.A.C. and Permit No. 0570024-015-AC] 

2. General Particulate Emission Limiting Standards. General Visible Emissions 

Standard. Except for emissions units that are subject to a particulate matter or opacity 

limit set forth or established by rule and reflected by conditions in this permit, no person 

shall cause, let, permit, suffer or allow to be discharged into the atmosphere the emissions 

of air pollutants from any activity, the density of which is equal to or greater than that 

designated as Number 1 on the Ringelmann Chart (20 percent opacity). EPA Method 9 is 

the method of compliance pursuant to Chapter 62-297, F.A.C. 

[Rules 62-296.320(4)(b)1. & 4., F.A.C.] 

3. Prevention of Accidental Releases (Section 112(r) of CAA).

a. The permittee shall submit its Risk Management Plan (RMP) to the Chemical 

Emergency Preparedness and Prevention Office (CEPPO) RMP Reporting Center when, 

and if, such requirement becomes applicable. Any Risk Management Plans, original 

submittals, revisions or updates to submittals, should be sent to: 

RMP Reporting Center 

Post Office Box 1515 

Lanham-Seabrook, MD 20703-1515 

Telephone: 301/429-5018 

b. The permittee shall submit to the permitting authority Title V certification forms or a 

compliance schedule in accordance with Rule 62-213.440(2), F.A.C. 

[40 CFR 68] 

4. Insignificant Emissions Units and/or Activities. Appendix I-1, List of 

Insignificant Emissions Units and/or Activities, is a part of this permit. 

[Rules 62-213.440(1), 62-213.430(6) and 62-4.040(1)(b), F.A.C.] 

5. General Pollutant Emission Limiting Standards. Volatile Organic Compounds 

(VOC) Emissions or Organic Solvents (OS) Emissions. The permittee shall allow no 

person to store, pump, handle, process, load, unload or use in any process or installation, 

volatile organic compounds (VOC) or organic solvents (OS) without applying known and 

existing vapor emission control devices or systems deemed necessary and ordered by the 

Department. 

Regional Haze SIP for Florida 

Exhibit 2

Page 470 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 8 of 38

A) Maintain tightly fitting cover, lids, etc. on all containers when they are not being 

handled, tapped, etc. 

B) Where possible and practical, procure/fabricate a tightly fitting cover for any open 

trough, basin, etc. of VOC so that it can be covered when not in use. 

C) Immediately attend to all spills/waste as appropriate. 

[Rule 62-296.320(1)(a), F.A.C. and Proposed by applicant in the initial Title V permit 

application received June 16, 1996] 

6. Emissions of Unconfined Particulate Matter. Pursuant to Rules 62-

296.320(4)(c)1., 3. & 4., F.A.C., reasonable precautions to prevent emissions of 

unconfined particulate matter at this facility include the following requirements (see 

Condition 57. of APPENDIX TV-6, TITLE V CONDITIONS). 

A) Post and enforce a speed limit of 10 miles per hour 

B) Maintain material drop points as low as possible 

C) Curtail operations during high wind conditions, if necessary 

D) Exercise good housekeeping at all times 

E) Application of asphalt, water, oil, chemicals or other dust suppressants to unpaved 

roads, yards, and open stock piles, as necessary 

F) Removal of particulate matter from buildings, work areas, roads and other paved 

areas under the control of the owner or operator of the facility to prevent 

entrainment, as necessary 

G) Maintenance of parking areas and yards 

H) Landscaping or planting of vegetation 

I) Water sprays shall be used as necessary to ensure compliance with the 5% opacity 

standard. 

 [Rule 62-296.320(4)(c)2., F.A.C.; Proposed by applicant in the initial Title V permit 

application received June 16, 1996; and Permit No. 0570024-016-AC] 

7. The permittee shall notify the Air Compliance Section of the Environmental 

Protection Commission of Hillsborough County at least 15 days prior to the date on which 

each formal compliance test is to begin of the date, time, and place of each such test, and the 

contact person who will be responsible for coordinating and having such test conducted. 

[Rule 62-297.310, F.A.C.] 

8. When appropriate, any recording, monitoring, or reporting requirements that are 

time-specific shall be in accordance with the effective date of the permit, which defines 

day one. 

[Rule 62-213.440, F.A.C.]

9. Statement of Compliance. The annual statement of compliance pursuant to Rule 

62-213.440(3)(a)2., F.A.C., shall be submitted to the Environmental Protection 

Commission and EPA within 60 (sixty) days after the end of the calendar year using DEP 

Form No. 62-213.900(7), F.A.C. 

[Rules 62-213.440(3) and 62-213.900, F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 471 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 9 of 38

{Permitting Note: This condition implements the requirements of Rules 62-

213.440(3)(a)2. & 3., F.A.C. (see Condition 51. of APPENDIX TV-6, TITLE V 

CONDITIONS)} 

10. Submit to the Environmental Protection Commission of Hillsborough County each 

calendar year on or before April 1, completed DEP Form 62-210.900(5), "Annual Operating 

Report for Air Pollutant Emitting Facility", for the preceding calendar year. 

[Rule 62-210.370(2), F.A.C.] 

11. The permittee shall comply with Appendix O-1, Operation and Maintenance Plans 

for Particulate Control. In the event of a deviation from the monitoring parameters, the 

facility shall take corrective actions to remedy the situation. Notify the Environmental 

Protection Commission of Hillsborough County within 24 hours of the problem. The 

emission unit shall not be operated until the problem is corrected. A written explanation and 

the corrective actions implemented shall be submitted in the semi-annual report required in 

the TV-6 Condition Nos. 43, 44, 45. Records of inspections, maintenance, and performance 

parameters shall be retained for a minimum of five years and shall be made available to the 

Environmental Protection Commission of Hillsborough County upon request. 

[Rules 62-296.700(6)(e) and 62-4.070(3), F.A.C.] 

12. The permittee shall submit all compliance related notifications and reports 

required of this permit to the Environmental Protection Commission of Hillsborough 

County at: 

Environmental Protection Commission 

Air Management Division 

3629 Queen Palm Dr. 

Tampa, FL 33619 

Telephone: 813/627-2600, Fax: 813/627-2660 

13. Any reports, data, notifications, certifications, and requests required to be sent to 

the United States Environmental Protection Agency, Region 4, should be sent to: 

United States Environmental Protection Agency 

Region 4 

Air, Pesticides & Toxics Management Division 

Air and EPCRA Enforcement Branch 

Air Enforcement Section 

61 Forsyth Street 

Atlanta, Georgia 30303-8960 

Telephone: 404/562-9155; Fax: 404/562-9163 

14. When the Environmental Protection Commission of Hillsborough County (EPC) 

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 Rules 62-204, 62-210, 62-212, 62-296, or 62-297, F.A.C., or in a 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 10 of 38

permit issued pursuant to those rules is being violated, it may require the owner or operator 

of the source to conduct compliance tests which identify the nature and quantity of pollutant 

emissions from the source and to provide a report on the results of said tests to the EPC. 

[Rule 62-297.310(7)(b), F.A.C. and Permit No. 0570024-015-AC] 

15. The permittee shall give prior notification and obtain approval from the EPCHC for 

the loading and/or unloading of any new material not identified in this permit. 

[Rules 62-4.070(3) and 62-210.200(205), F.A.C. and Permit No. 0570024-016-AC] 

16. The permittee shall provide timely notification to the Environmental Protection 

Commission of Hillsborough County prior to implementing any changes that may result in a 

modification to this permit pursuant to Rule 62-210.200(205), F.A.C., Modification. The 

changes do not include normal maintenance, but may include, and are not limited to, the 

following, and may also require prior authorization before implementation: [Rules 62-

210.300 and 62-4.070(3), F.A.C. and Permit No. 0570024-015-AC] 

A) Alteration or replacement of any equipment or major component of such 

equipment. 

B) Installation or addition of any equipment which is a source of air pollution. 

C) The handling of any new material not identified in this permit. 

17. Certification by Responsible Official (RO). In addition to the professional 

engineering certification required for applications by Rule 62-4.050(3), F.A.C., any 

application form, report, compliance statement, compliance plan and compliance 

schedule submitted pursuant to Chapter 62-213, F.A.C., shall contain a certification 

signed by a responsible official that, based on information and belief formed after 

reasonable inquiry, the statements and information in the document are true, accurate, 

and complete. Any responsible official who fails to submit any required information or 

who has submitted incorrect information shall, upon becoming aware of such failure or 

incorrect submittal, promptly submit such supplementary information or correct 

information. 

[Rule 62-213.420(4), F.A.C.] 

18. APPENDIX TV-6, TITLE V CONDITIONS, is a part of this permit. 

[Rule 62-4.070(3), F.A.C.] 

19. The permittee shall handle the following materials at the Tampaplex site and at all 

Stevedoring locations. 

[Rule 62-4.07(1), F.A.C. and Permit No. 0570024-016-AC] 

A) 

Group I – Dusty Fertilizers 

Ammonium Sulfate Granular Sulfate of Potash Animal Feed 

Ingredients 

Standard Muriate of Potash Standard Sulfate of Potash Standard Potassium 

Nitrate 

Granular Muriate of Potash Granular Sulfate of PotashMagnesium Standard Sulfate of 

Potash-Magnesium 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 11 of 38

Group II – Phosphate Rock 

Phosphate Products Rock 

Group III – Minimally Dusty Fertilizers 

Ammonium Nitrate Sodium Potassium Nitrate MAP 

Calcium Ammonium Nitrate Compound Fertilizers DAP 

Potassium Nitrate Dried Sludge GTSP

Calcium Nitrate Urea Kieserite 

Group I V – Millscale 

Millscale 

Group V– Moderately Dusty Non-Fertilizer Products 

Coal Syngypsum Clay 

Petcoke Iron Ore Magnetite/Ferrous 

Oxides 

Group VI – Minimally Dusty Non-Fertilizer Products 

Gypsum Alumina Hydrate Filler Materials 

Pumice Vermiculite Peanut Hulls 

Wood Chips Dolomite Salt (solar) 

Ferrous Sulfate Glass Bio-Mass 

Ferro Alloys Iron Scrap (including 

shredded scrap metal) 

Granulated Furnace 

Slag 

Clinker (treated or screened) Prilled Sulfur 

Group VII – Coal Slag 

Coal Slag

Group VIII – Agricultural Products 

Grains Grain Meals Seeds 

Soybeans Grain Byproducts Peas 

Wheat, Rye, Barley Citrus Pellets 

Group IX – Bauxite/Alumina and similar Dusty Cement-like Products 

Bauxite Alumina Slag Cement 

Group X - Aggregate 

Limestone Granite Rocks 

Gravel Stone 

Group XI – Sand and Similar Materials 

Sand Soil Limestone Fines 

Dirt 

Regional Haze SIP for Florida 

Exhibit 2

Page 474 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 12 of 38

 B) Millscale shall be treated with water or a dust suppressant at the first material 

transfer point and subsequent material transfer points as necessary to meet 

the 5% opacity standard. 

C) All materials in Group IX shall be treated with a dust suppressant at the first 

material transfer point and subsequent material transfer points as necessary to 

meet the 5% opacity standard. 

20. As requested by the permittee, in order to remain a synthetic minor facility with 

respect to the requirements of Rule 62-212.400, Prevention of Significant Deterioration, 

F.A.C., the maximum potential to emit (PTE) particulate matter emissions shall not exceed 

249 tons per twelve consecutive month period, which is comprised of the following 

operations: 

A) Particulate Matter Emissions from the Tampaplex Operation: 51 tons 

B) Particulate Matter Emissions from the Stevedoring Operation: 198 tons 

[Rule 62-4.070(3), F.A.C. and Permit No. 0570024-016-AC] 

21. In order to ensure compliance with the emission limitations in Specific Condition 

No. 20., the following restrictions and limitations shall apply for any consecutive twelve 

month period: [Rule 62-4.070(3), F.A.C. and Construction Permit No. 0570024-016-AC] 

A) The maximum combined throughput amount of material handled at the 

Tampaplex location shall not exceed 11,826,000 tons 

B) The combined material throughput handled through the Stevedoring operation 

shall not result in that operation emitting more than 198 tons of particulate 

matter emissions per twelve consecutive month period. 

Regional Haze SIP for Florida 

Exhibit 2

Page 475 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 13 of 38

Section III. Emissions Unit(s) and Conditions. 

Subsection A. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-002 Railcar Unloading 

-004 C17 Transfer Point E (C17 to C18 or C17 to C19) 

EU No. 002: During the railcars unloading operation, railcars are pulled into a partially 

enclosed structure and bottom unloaded through grates in the floor of the structure into 

six hoppers. Emissions from the hoppers are vented to dry cyclones. Butterfly valves in 

the riser pipe routed to each dry cyclone are used to isolate or shut off airflow to hoppers 

not being used. Typically four of the six hoppers are used during unloading operations. 

Material can be transferred from the unloading hoppers to conveyor C17 for subsequent 

storage in silos via conveyors C19 and C38, or transferred for ship loading via conveyors 

C18, C12, C13 and C14. 

Particulate matter emissions generated from the railcar unloading operation are controlled 

by six parallel dry cyclones followed by a 100,000 ACFM Amerex Type C Venturi 

scrubber and/or by the application of a dust suppressant oil applied to the product at the 

chemical processing facility prior to shipping. 

EU No. 004: The C17 transfer point E directs material from Conveyor Belt No. C17 

either to Conveyor Belt No. C18 or to Conveyor Belt No. C19. Particulate matter 

emissions generated during the transfer process are controlled by a 6000 ACFM PolyCon, Model Venturi 1506MS, scrubber. 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

A.1. Capacity. The maximum product unloading rate shall not exceed 1800 tons/hour. 

[Rule 62-210.200, F.A.C., Definitions – Potential to Emit, and Construction Permit Nos. 

AC29-237340 and 0570024-016-AC] 

Emission Limitations and Standards

A.2. The maximum allowable particulate emissions from each scrubber shall not exceed 

the following for any given hour and any twelve consecutive month period: 

 a) EU No. 002 based on a design flow of 100,000 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 28.2 0.01 grains/dscf 6570 

 Visible Emissions 5% opacity 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 14 of 38

b) EU No. 004 based on a design flow of 6,000 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 1.7 0.01 grains/dscf 6570 

 Visible Emissions 5% opacity 

[Rules 62-4.070(3) and 62-296.711(b), F.A.C. and Construction Permit Nos. AC29-237340 

and 0570024-016-AC] 

A.3. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from the railcar unloading operation and the scrubber exhaust, and from the C17 

Transfer Point E and the scrubber exhaust. 

[Rule 62-296.711(a), F.A.C. and Construction Permit 0570024-016-AC] 

A.4. During the handling of DAP with the scrubber(s) turned off, the following conditions 

shall be met: 

a) The opacity limitation in Specific Condition No. A.3. shall be monitored by a 

certified smoke reader. 

b) The product shall be sufficiently treated with a non-hazardous oil or dust 

suppressant to meet the opacity limit in Specific Condition No. A.3. 

[Rule 62-4.070(3) F.A.C. and Construction Permit AC29-237340] 

Test Methods and Procedures

A.5. Test EU 002 (scrubber exhaust and the railcar unloading enclosure) and EU No. 004 

(scrubber exhaust and transfer point enclosure) for opacity once per federal fiscal year 

(October1 - September 30) and submit two copies of test data to the Air Management 

Division of the Environmental Protection Commission of Hillsborough County within fortyfive days of such testing. Testing procedures shall be consistent with the requirements of 

Rule 62-297.310, F.A.C. [Rule 62-297.310(7)(a)4., F.A.C.] 

A.6. Test EU No. 002 for particulate matter (PM) once per federal fiscal year (October1 - 

September 30) and submit two copies of test data to the Air Management Division of the 

Environmental Protection Commission of Hillsborough County within forty-five days of 

such testing. Testing procedures shall be consistent with the requirements of Rule 62-

297.310, F.A.C. [Rule 62-297.310(7)(a)4., F.A.C.] 

A.7. [Reserved.] 

A.8. Test EU No. 004 for particulate matter (PM) within 120 days prior to expiration of this 

permit and submit two copies of test data to the Air Management Division of the 

Environmental Protection Commission of Hillsborough County within forty-five days of 

such testing. Testing procedures shall be consistent with the requirements of Rule 62-

297.310, F.A.C. [Rules 62-297.310(7)(a)4. and 62-4.070(3), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 15 of 38

A.9. [Reserved.] 

A.10. Compliance with the emission limitations of Specific Condition No. A.2. and A.3. 

shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix 

A and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be 

conducted by a certified observer and be a minimum of sixty (60) minutes in duration for 

the scrubber exhaust and thirty (30) minutes in duration for the railcar enclosure. The 

minimum requirements for stack sampling facilities, source sampling and reporting, shall be 

in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A. 

[Rule 62-297.310(4)(a)2., F.A.C.] 

A.11. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of the maximum unloading rates of 1800 TPH. If it is 

impracticable to test at capacity, then the source may be tested at less than capacity; in this 

case subsequent source operation is limited to 110% of the test load until a new test is 

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no 

more than fifteen days for purposes of additional compliance testing to regain the rated 

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates 

and actual operating conditions of the scrubber such as inlet pressure drop and liquor feed 

rate, may invalidate the test. [Rules 62-297.310(2) and 62-4.070(3), F.A.C.] 

A.12. The use of dust suppressant in lieu of operating the current control system(s) 

during the handling of materials is allowed provided that the operation does not exceed 

the 5% opacity standard. [Rule 62-4.070(3), F.A.C. and Permit No. 0570024-016-AC] 

Recordkeeping and Reporting Requirements

A.13. In order to demonstrate compliance with Specific Condition Nos. A.1. and A.2., the 

permittee shall maintain a monthly recordkeeping system for the most recent 5 year 

period. The records shall be made available to the EPC of Hillsborough County, state or 

federal air pollution agency upon request. The records shall include, but are not limited 

to, the following: 

a) Day, Month, Year 

b) Amount and type of dust suppressant applied (gallon/ton) for each oiled 

product unloaded during the preceding month. 

c) Certificate for smoke reader at the facility who monitored DAP or other 

fertilizer product unloading with the scrubber off. 

d) Hours of operation for each emission unit and scrubbers 

e) Amount and type of material unloaded from railcars (tons) 

f) Rolling twelve month total of d) and e) above for each material handled 

 [Rule 62-4.070(3), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 478 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 16 of 38

Subsection B. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-003 Shiploading Operation 

-005 C12 Transfer Point A (C12 to C13) 

-006 C30 Transfer Point C (C30 to C12) 

-013 Shiphold Loading (C14 to Shiphold) 

EU Nos. 003 and No. 013: The shiphold loading operation involves the loading of 

phosphate rock, fertilizer products, AFI and/or other bulk material, which can be 

conveyed either directly from the railcar or from the storage silos to the shiphold using a 

series of conveyor belts, Conveyor Belt Nos. C12, C13, and C14. A telescopic chute and 

an OBA chokefeeder are used to load the shiphold. 

Particulate matter emissions generated during the shiphold loading operation are 

controlled by a modified 9,000 DSCFM Mikro-Pulsaire, Model 1F2, baghouse and/or a 

gantry mounted dust suppression system. The dust suppression system consists of four 

spray headers located throughout the gantry using a surfactant chemical that is mixed 

with water. 

EU No. 005: The C12 Transfer Point A transfers material from Conveyor Belt No. C12 

to Conveyor Belt No. C13. Particulate emissions generated during the transfer process 

are controlled by an 8,000 DSCFM Mikro-Pulsaire, Model 80F2, baghouse. 

EU No. 006.: The C30 Transfer Point C is used to transfer material from Conveyor Belt 

No. C30 to Conveyor Belt No. C12. Particulate matter emissions generated during the 

transfer operation are controlled by a 6,000 DSCFM Mikro-Pulsaire, Model 1215-8-80, 

baghouse. 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

B.1. Capacity. The maximum transfer rate of material shall not exceed 2300 TPH. 

[Rules 62-210.200, Definitions - (PTE) and 62-4.070(3), F.A.C. and Construction Permit 

No. 0570024-016-AC] 

Emission Limitations and Standards

B.2. The maximum allowable particulate matter emissions for each baghouse shall not 

exceed the following for any given hour and for any 12 consecutive month period: 

Regional Haze SIP for Florida 

Exhibit 2

Page 479 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 17 of 38

 a) EU No. 003 based on a design flow of 9,000 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 7.6 0.03 grains/dscf 6570 

 

 b) EU No. 005 based on a design flow of 8,000 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 2.3 0.01 grains/dscf 6570 

 

 c) EU No. 006 based on a design flow of 6,000 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 1.7 0.01 grains/dscf 6570 

[Rule 62-296.711(2)(b), F.A.C. and Permit No. 0570024-016-AC] 

B.3. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from each emission source and baghouse exhaust except where material is being 

discharged to the hold of a ship from a conveyor system. When the conveyor and/or 

hatch covering is moved, an opacity of 10 percent will be allowed. 

[Rule 62-296.711(2)(a), F.A.C.] 

B.4. In order to demonstrate compliance with the limits of Specific Condition Nos. B.2. 

and B.3., the following restrictions shall apply: [Rule 62-4.070(3), F.A.C.] 

a) All dust laden air from each transfer operation shall be vented to the 

corresponding baghouse, unless the material has been treated with a dust 

suppressant. 

b) The gantry dust suppression system shall be maintained in operable condition 

so that it can be operated at any time as necessary during the loading of 

material to maintain compliance with the permitted opacity limit. 

Test Methods and Procedures

B.5. Test the emissions from the following emission units for opacity once per federal fiscal 

year (October 1 - September 30) and submit two copies of test data to the Air Management 

Division of the Environmental Protection Commission of Hillsborough County within fortyfive days of such testing. Testing procedures shall be consistent with the requirements of 

Rule 62-297.310, F.A.C. [Rule 62-297.310, F.A.C.] 

a) The shiploading operation and baghouse - Emission Unit No. 003 

b) Shiphold opening- Emission Unit No. 013 

c) C12 Transfer Point A and baghouse exhaust - Emission Unit No. 005 

d) C30 Transfer Point C and baghouse exhaust - Emission Unit No. 006 

e) Test the shiphold opening and the shiploading operation and baghouse each 

time a new material is handled during the loading of the ship. 

Regional Haze SIP for Florida 

Exhibit 2

Page 480 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 18 of 38

B.6. Test each emission unit for particulate matter at least 120 days prior to the expiration 

date of this permit. In the event that dry phosphate pebble rock is handled at the facility, a 

particulate matter test shall be performed on Emission Units 003 and 013. Particulate test 

shall be conducted under the similar process rate and operating condition(s) as the visible 

emission test for the baghouse exhaust. If possible, the visible emission test shall be 

performed simultaneously with one of the test runs for the particulate matter emissions. 

[Rule 62-297.310(7)(a)3., F.A.C.] 

B.7. Compliance with the emission limitations of Specific Condition No. B.2. and B.3. shall 

be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A 

and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the 

source shall be thirty (30) minutes in duration, and the test shall be conducted concurrently 

on the control equipment exhaust and the transfer point. The minimum requirements for 

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule 

62-297, F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the 

gantry dust suppression system was operating during the visible emission readings. 

[Rule 62-297.310(4)(a)2., F.A.C.] 

B.8. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of handling 2300 TPH for all materials. If it is 

impracticable to test at capacity, then the source may be tested at less than capacity; in this 

case subsequent source operation is limited to 110% of the test load until a new test is 

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no 

more than fifteen days for purposes of additional compliance testing to regain the rated 

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates 

and actual operating conditions may invalidate the test. 

[Rules 62-297.310(2) and 62-4.070(3), F.A.C.] 

B.9. [Reserved] 

B.10. The use of dust suppressant in lieu of operating the current control system(s) 

during the handling of materials is allowed provided that the operation does not exceed 

the 5% opacity standard. [Rule 62-4.070(3), F.A.C.] 

Recordkeeping and Reporting Requirements

B.11. In order to demonstrate compliance with Specific Condition No. B.1., the permittee 

shall maintain a monthly recordkeeping system for the most recent five year period. The 

records shall be made available to the Environmental Protection Commission of 

Hillsborough County, state, or federal air pollution agency upon request. The records shall 

include, but not limited to, the following: [Rule 62-4.070(3), F.A.C.] 

a) Day, Month, year 

b) Hours of operation for each emission unit and baghouse 

c) Amount and type of material loaded into ships (tons) 

d) Rolling twelve month total of b) and c) above for each material handled 

Regional Haze SIP for Florida 

Exhibit 2

Page 481 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 19 of 38

Subsection C. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-007 C18 Conveyor Transfer Point D (C18 to C12) 

-009 C19 Conveyor Transfer Point G (C19 to C38) 

EU No. 007: The C18 conveyor transfer point D transfers material from Conveyor Belt 

No. C18 to Conveyor Belt No. C12. Particulate matter emissions generated during the 

transfer process are controlled by a 6000 ACFM Mikro-Pulsaire, Model 1215-8-80, 

baghouse. 

EU No. 009: The C19 Conveyor Transfer Point G transfers material from Conveyor Belt 

No. C19 to Conveyor Belt No. C38. Particulate matter emissions generated during the 

transfer process are controlled by a 5000 ACFM Mikro-Pulsaire, Model 1215-8-80, 

baghouse. 

 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

C.1. Capacity. The maximum transfer rate of material shall not exceed 1800 tons/hour. 

 [Rules 62-210.200, Definitions - (PTE) and 62-4.070(3), F.A.C. and Permit No. 

0570024-016-AC] 

Emission Limitations and Standards

C.2. The maximum allowable particulate matter emissions from each baghouse shall 

not exceed the following for any given hour and for any 12 consecutive month period: 

 a) EU No. 007 based on a design flow of 6,000 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 1.7 0.01 grains/dscf 6570 

 

 b) EU No. 009 based on a design flow of 4,200 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 1.2 0.01 grains/dscf 6570 

[Rule 62-296.711(2)(b), F.A.C. and Permit No. 0570024-016-AC] 

C.3. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from each emission unit and baghouse exhaust. [Rule 62-296.711(2)(a), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 482 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 20 of 38

C.4. In order to demonstrate compliance with the limits of Specific Condition Nos. C.2. 

and C.3., all dust laden air from each transfer operation shall be vented to the 

corresponding baghouse, unless the material has been treated with a dust suppressant. 

[Rule 62-4.070(3), F.A.C.] 

Test Methods and Procedures

C.5. Test the emissions from each emission unit and baghouse exhaust for opacity once per 

federal fiscal year (October1 - September 30) and submit two copies of test data to the Air 

Management Division of the Environmental Protection Commission of Hillsborough 

County within forty-five days of such testing. Testing procedures shall be consistent with 

the requirements of Rule 62-297.310, F.A.C. [Rule 62-297.310(7)(a)4., F.A.C.] 

C.6. Test each emission unit for particulate matter at least 120 days prior to the expiration 

date of this permit. Particulate test shall be conducted under similar process rate(s) and 

operating condition(s) as the visible emission test for the baghouse exhaust. If possible, the 

visible emission test shall be performed simultaneously with one of the test runs for the 

particulate matter emissions. [Rule 62-297.310(7)(a)3., F.A.C.] 

C.7. Compliance with the emission limitations of Specific Condition No. C.2. and C.3. 

shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix 

A and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be thirty 

(30) minutes in duration, and the test shall be conducted concurrently on the control 

equipment exhaust and the corresponding transfer point. The minimum requirements for 

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule 

62-297, F.A.C. and 40 CFR 60, Appendix A. [Rule 62-297.310(4)(a)2., F.A.C.] 

C.8. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of the maximum unloading rates of 1800 TPH. If it is 

impracticable to test at capacity, then the source may be tested at less than capacity; in this 

case subsequent source operation is limited to 110% of the test load until a new test is 

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no 

more than fifteen days for purposes of additional compliance testing to regain the rated 

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates 

and actual operating conditions may invalidate the test. 

[Rules 62-297.310(2) and 62-4.070(3), F.A.C.] 

C.9. The permittee is allowed to handle dust suppressant oiled DAP product with the 

control device turned off provided that: [Rule 62-4.070(3), F.A.C.] 

a) Visible emissions at each transfer point shall be less than 5 % opacity. 

b) The product shall be sufficiently treated with a non-hazardous oil or dust 

suppressant to meet the opacity limit in Specific Condition No. C.3. 

C.10. [Reserved] 

Regional Haze SIP for Florida 

Exhibit 2

Page 483 of 501
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Tampaplex Terminal Project: Bulk Material Handling 

Page 21 of 38

Recordkeeping and Reporting Requirements

C.11. In order to demonstrate compliance with Specific Condition No. C.1., the permittee 

shall maintain a monthly recordkeeping system for the most recent five year period. The 

records shall be made available to the Environmental Protection Commission of 

Hillsborough County, state or federal air pollution agency upon request. The records shall 

include, but not limited to, the following: 

[Rule 62-4.070(3), F.A.C.] 

a) Day, Month, Year 

b) Hours of operation for each emission unit and baghouse 

c) Amount and type of material transferred on each conveyor system (tons) 

d) Rolling twelve month total of b) and c) above. 

Regional Haze SIP for Florida 

Exhibit 2

Page 484 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 22 of 38

Subsection D. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-008 Material Handling and Storage Silos 

The material handling and storage operation consists of a truck unloading station, three 

storage silos, and a transfer conveyor system. Material is conveyed from the truck 

unloading station to three storage silos using Conveyor Belt No. C92. Material is 

unloaded from the silos and conveyed to Conveyor Belt No. C12 using Conveyor Belt 

No. C93 when it is ready for ship loading. 

Particulate matter emissions generated during the loading of any silo are controlled by a 

common 3,565 ACFM Mikro-Pulsaire, Model 49S-8-20, baghouse. Particulate matter 

emissions from the conveyor transfer points and the truck unloading station are controlled 

through the use of partial enclosures. 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

D.1. D.1. Capacity. The maximum material handling rate shall not exceed 120 tons per 

hour and 300,000 tons per year for any 12 consecutive month period. 

[Rules 62-210.200, Definitions - (PTE) and 62-4.070(3), F.A.C. and Construction Permit 

AC29-22822] 

D.2. Hours of Operation. The hours of operation for this emissions unit shall not exceed 

2,500 hours/year. 

[Rules 62-210.200, Definitions - (PTE) and 62-4.070(3), F.A.C.] 

Emission Limitations and Standards

D.3. The maximum allowable particulate matter emissions from the common MikroPulsaire, Model 49S-8-20, baghouse shall not exceed the following for any given hour 

and for any 12 consecutive month period: 

 a) EU No. 008 based on a design flow of 3,200 DSCFM: 

 Pollutant tons/yr. Emission Limitation

 Particulate Matter 0.6 0.02 grains/dscf 

[Rule 62-4.070(3), F.A.C. and Construction Permit Nos. AC29-22822 and 0570024-016-

AC] 

D.4. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from each emission unit and baghouse exhaust. [Rule 62-296.711(2)(a), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 485 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 23 of 38

D.5. In order to demonstrate compliance with the limits of Specific Condition No. D.3., 

all dust laden air from the transfer operation shall be vented to the corresponding 

baghouse, unless the material has been treated with a dust suppressant. 

[Rule 62-4.070(3), F.A.C.] 

Test Methods and Procedures

D.6. Test the emissions from the emission unit and baghouse exhaust for opacity once per 

federal fiscal year (October1 - September 30) and submit two copies of test data to the Air 

Management Division of the Environmental Protection Commission of Hillsborough 

County within forty-five days of such testing. Testing procedures shall be consistent with 

the requirements of Rule 62-297.310, F.A.C. [Rule 62-297.310(7)(a)4., F.A.C.] 

D.7. Test the emission unit for particulate matter at least 120 days prior to the expiration 

date of this permit. Particulate test shall be conducted under similar process rate(s) and 

operating condition(s) as the visible emission test for the baghouse exhaust. If possible, the 

visible emission test shall be performed simultaneously with one of the test runs for the 

particulate matter emissions. [Rule 62-297.310(7)(a)3., F.A.C.] 

D.8. Compliance with the emission limitations of Specific Condition No. D.3. and D.4. 

shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix 

A and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval shall be 

thirty (30) minutes in duration, and the test shall be conducted concurrently on the control 

equipment exhaust and the corresponding transfer point. The minimum requirements for 

stack sampling facilities, source sampling and reporting, shall be in accordance with Rule 

62-297, F.A.C. and 40 CFR 60, Appendix A. [Rule 62-297.310(4)(a)2., F.A.C.] 

D.9. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of the maximum handling rate of 120 tons per hour of 

material. If it is impracticable to test at capacity, then the source may be tested at less than 

capacity; in this case subsequent source operation is limited to 110% of the test load until a 

new test is conducted. Once the unit is so limited, then operation at higher capacities is 

allowed for no more than fifteen days for purposes of additional compliance testing to regain 

the rated capacity in the permit, with prior notification to the EPC. Failure to submit the 

input rates and actual operating conditions may invalidate the test. [Rules 62-4.070(3) and 

62-297.310(2), F.A.C.] 

Recordkeeping and Reporting Requirements

D.10. In order to demonstrate compliance with Specific Condition Nos. D.1. and D.2., the 

permittee shall maintain a monthly recordkeeping system for the most recent five year 

period. The records shall be made available to the Environmental Protection Commission of 

Hillsborough County, state or federal air pollution agency upon request. The records shall 

include, but not limited to, the following: 

[Rule 62-4.070(3), F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 486 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 24 of 38

a) Day, Month, Year 

b) Hours of operation of the emission unit and baghouse 

c) Amount and type of material unloaded from trucks (tons) into the silos 

d) Rolling twelve month total of b) and c) above. 

Regional Haze SIP for Florida 

Exhibit 2

Page 487 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 25 of 38

Subsection E. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-012 Railcar Transfer to Storage Silos 

 

Material unloaded at the railcar unloading station can either be conveyed to sixteen outer 

storage silos (Silo Nos. 1 – 16) using a series of conveyor belts, Conveyor Belt Nos. C27, 

C44, and C28, or to seven smaller inner storage silos (Silo Nos. 17 -23) using a series of 

conveyor belts, Conveyor Belt Nos. C19, C38, and C29. All silos are unloaded using 

Conveyor Belt No. 30. 

Particulate matter emissions generated by this material handling operation are controlled by 

a 23,100 DSCFM Ducon Venturi Oriclone, VVO, 36/84 scrubber located at ground level 

directly north of the storage silos. The scrubber has three vents which pickup on: (1) outer 

silos 9-16, inner silos 21-23, and conveyor 27; (2) outer silo 7, inner silo 20, conveyors 38 

and 44; (3) and outer silos 1-6, 8 and inner silos 17-19. 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

E.1. Capacity. The maximum railcar unloading and transfer rate of material shall not 

exceed 1800 TPH. 

[Rules 62-210.200, Definitions - (PTE) and 62-4.070(3), F.A.C. and Permit No. 

0570024-016-AC] 

Emission Limitations and Standards

E.2. The maximum allowable particulate matter emissions for the scrubber shall not 

exceed the following for any given hour and for any 12 consecutive month period: 

 a) EU No. 012 based on a design flow of 23,100 DSCFM: 

 Pollutant tons/yr. Allowable Emissions Hours of Operation/Yr

 Particulate Matter 6.5 0.01 grains/dscf 6570 

[Rule 62-296.711(2)(b), F.A.C. and Permit No. 0570024-016-AC] 

E.3. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from the emission unit and scrubber exhaust. [Rule 62-296.711(2)(a), F.A.C.] 

Test Methods and Procedures

E.4. Test the emissions from the emission unit and scrubber exhaust for opacity once per 

federal fiscal year (October1 - September 30) and submit two copies of test data to the Air 

Management Division of the Environmental Protection Commission of Hillsborough 

Regional Haze SIP for Florida 

Exhibit 2

Page 488 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 26 of 38

County within forty-five days of such testing. Testing procedures shall be consistent with 

the requirements of Rule 62-297.310, F.A.C. [Rule 62-297.310(7)(a)4., F.A.C.] 

E.5. Test the emission unit for particulate matter at least 120 days prior to the expiration 

date of this permit. Particulate test shall be conducted under similar process rate(s) and 

operating condition(s) as the visible emission test for the scrubber exhaust. If possible, the 

visible emission test shall be performed simultaneously with one of the test runs for the 

particulate matter emissions. [Rule 62-297.310(7)(a)3., F.A.C.] 

E.6. Compliance with the emission limitations of Specific Condition No. E.2. and E.3. shall 

be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A 

and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be thirty (30) 

minutes in duration, and the test shall be conducted concurrently on the control equipment 

exhaust and the corresponding transfer point. The minimum requirements for stack 

sampling facilities, source sampling and reporting, shall be in accordance with Rule 62-297, 

F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the dust 

suppression system was operating during the visible emission readings. 

[Rule 62-297.310(4)(a)2., F.A.C.] 

E.7. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of the maximum material handling rate of 1800 tons/hour. 

If it is impracticable to test at capacity, then the source may be tested at less than capacity; in 

this case subsequent source operation is limited to 110% of the test load until a new test is 

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no 

more than fifteen days for purposes of additional compliance testing to regain the rated 

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates 

and actual operating conditions may invalidate the test. 

[Rules 62-4.070(3) and 62-297.310(2), F.A.C.] 

Recordkeeping and Reporting Requirements

E.8. In order to demonstrate compliance with Specific Condition No. E.1., the permittee 

shall maintain a monthly recordkeeping system for the most recent five year period. The 

records shall be made available to the Environmental Protection Commission of 

Hillsborough County, state or federal air pollution agency upon request. The records shall 

include, but not limited to, the following: 

[Rule 62-4.070(3), F.A.C.] 

a) Day, Month, Year 

b) Hours of operation of the emission unit and scrubber 

c) Amount and type of material loaded into the silos (tons) 

d) Rolling twelve month total of b) and c) above. 

Regional Haze SIP for Florida 

Exhibit 2

Page 489 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 27 of 38

Subsection F. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-100 Truck and Railcar Unloading Station No. 2 and Transfer Points (C2, C3, C4, 

C7, C11, C94) in Storage Building Nos. 1 and 2 

 

Trucks and railcars are driven into a partially enclosed structure and unload material through 

grates in the floor of the structure. The material is conveyed into three storage silos using a 

series of conveyor belts, Conveyor Belt Nos. C2, C4, C7, and C94, and a bucket elevator, 

No. C3. Material is transferred from Conveyor Belt No. C2 to Bucket elevator No. C3 and 

then to Conveyor Belt No. C4. Conveyor Belt No. C4 transfers the material to either 

Conveyor Belt No. C7 or C11. Conveyor Belt No. C7 transfers material to Conveyor Belt 

No. C94 which loads the three storage silos associated with EU 008. Conveyor Belt No. 

C11 transfers material to Conveyor Belt No. C18 using the C18 Transfer Point D. 

Conveyor Belt Nos. C4 and C7 are completely enclosed in Storage Building Nos. 1 and 2. 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

F.1. Capacity. The maximum unloading rate shall not exceed 250 tons per hour. 

[Rules 62-210.200, Definitions - PTE and 62-4.070(3), F.A.C. and Permit No. 0570024-

016-AC] 

Emission Limitations and Standards

F.2. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from any emission point associated with this emission unit. 

[Rule 62-296.711(2)(a), F.A.C.] 

Test Methods and Procedures

F.3. Test the emissions from each transfer point for opacity once per federal fiscal year 

(October1 - September 30) and submit two copies of test data to the Air Management 

Division of the Environmental Protection Commission of Hillsborough County within fortyfive days of such testing. Testing procedures shall be consistent with the requirements of 

Rule 62-297.310, F.A.C. [Rule 62-297.310(7)(a)4., F.A.C.] 

F.4. Compliance with the emission limitations of Specific Condition No. F.2. shall be 

determined using EPA Method 9 contained in 40 CFR 60, Appendix A and adopted by 

reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be thirty (30) minutes in 

duration. The minimum requirements for stack sampling facilities, source sampling and 

reporting, shall be in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A. 

[Rule 62-297.310(4)(a)2., F.A.C.] 

Regional Haze SIP for Florida 

Exhibit 2

Page 490 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 28 of 38

F.5. Testing of emissions shall be conducted with the source operating at capacity. Capacity 

is defined as 90-100% of the maximum material transfer rate of 250 tons/hour. If it is 

impracticable to test at capacity, then the source may be tested at less than capacity; in this 

case subsequent source operation is limited to 110% of the test load until a new test is 

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no 

more than fifteen days for purposes of additional compliance testing to regain the rated 

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates 

and actual operating conditions may invalidate the test. 

[Rules 62-4.070(3) and 62-297.310(2), F.A.C.] 

Recordkeeping and Reporting Requirements

F.6. In order to demonstrate compliance with Specific Condition No. F.1., the permittee 

shall maintain a recordkeeping system for the most recent five year period. The records 

shall be made available to the Environmental Protection Commission of Hillsborough 

County, state or federal air pollution agency upon request. The records shall include, but not 

limited to, the following: [Rule 62-4.070(3), F.A.C.] 

a) Day, Month, Year 

b) Hours of operation 

c) Amount and type of material unloaded by truck and railcar (tons) 

d) Rolling twelve month total of c) above 

Regional Haze SIP for Florida 

Exhibit 2

Page 491 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 29 of 38

Subsection G. This section addresses the following emissions unit(s). 

E.U. 

ID No. Brief Description

-102 Truck Unloading Station No. 1 and Transfer Point (C82 to C83) 

-103 Transfer Points (C83, C84 and C104) in Storage Building No. 3 

 

Trucks are driven into a partially enclosed structure and unload material through grates in 

the floor of the structure. The materials are dropped onto Conveyor Belt No. C82, which 

transfers the material from the truck unloading Station No. 1 to Conveyor Belt No. C83. 

This transfer point is entirely enclosed. Conveyor Belt No. C83 transfers the material to 

Conveyor Belt No. C84, which is located inside Storage Building No. 3. Inside the building 

there is a movable tipper which allows the storage piles to be placed at different locations 

within the building. Materials are moved within the building with a front end loader, which 

is also used to transfer the material out of the building to a hopper located on the side of the 

storage building. The hopper feeds Conveyor Belt No. C104, which transfers material to 

Conveyor Belt No. C12, using the C12 Transfer Point A associated with EU 005. Storage 

Building No. 3 is solely associated with Truck Unloading Station No. 1. 

Particulate matter emissions are controlled through the use of dust suppressants (oiling) and 

enclosures. 

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

G.1. Capacity. The maximum truck unloading rate shall not exceed 400 tons per hour. 

[Rules 62-210.200, Definitions – PTE and 62-4.070(3), F.A.C. and Permit No. 0570024-

016-AC] 

G.2. Hours of Operation. This emissions unit is allowed to operate continuously, i.e., 

8,760 hours/year. [Rules 62-210.200, Definitions – PTE and 62-4.070(3), F.A.C.] 

Emission Limitations and Standards

G.3. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from any emission point associated with the Truck Unloading Station No. 1 and 

the Storage Building No. 3. [Rule 62-296.711(2)(a), F.A.C.] 

G.4. [Reserved] 

G.5. In order to exempt the material transfer equipment referenced above from 40 CFR 

60, Subpart X, the permittee shall not handle or store at the facility GTSP which is less 

than or equal to 72 hours old. 

[40 CFR 60.241(a) and (d) and Construction Permit No. 0570024-016-AC] 

Regional Haze SIP for Florida 

Exhibit 2

Page 492 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 30 of 38

Test Methods and Procedures

G.6. Test each transfer point associated with Emission Unit Nos. 102 and 103 once per 

federal fiscal year (October1 - September 30) for opacity and submit two copies of test data 

to the Air Management Division of the Environmental Protection Commission of 

Hillsborough County within forty-five days of such testing. Testing procedures shall be 

consistent with the requirements of Rule 62-297.310, F.A.C. 

[Rule 62-297.310(7)(a)4., F.A.C.] 

G.7. Compliance with the emission limitations of Specific Condition No. G.3. shall be 

determined using EPA Method 9 contained in 40 CFR 60, Appendix A and adopted by 

reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be thirty (30) minutes in 

duration. The minimum requirements for stack sampling facilities, source sampling and 

reporting, shall be in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A. 

[Rule 62-297.310(4)(a)2., F.A.C.] 

G.8. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of the maximum handling rate of 400 tons/hour. If it is 

impracticable to test at capacity, then the source may be tested at less than capacity; in this 

case subsequent source operation is limited to 110% of the test load until a new test is 

conducted. Once the unit is so limited, then operation at higher capacities is allowed for no 

more than fifteen days for purposes of additional compliance testing to regain the rated 

capacity in the permit, with prior notification to the EPC. Failure to submit the input rates 

and actual operating conditions may invalidate the test. 

[Rules 62-4.070(3) and 62-297.310(2), F.A.C.] 

Recordkeeping and Reporting Requirements

G.9. In order to demonstrate compliance with Specific Condition Nos. G.1. and G.2., the 

permittee shall maintain a monthly recordkeeping system for the most recent five year 

period. The records shall be made available to the Environmental Protection Commission of 

Hillsborough County, state or federal air pollution agency upon request. The records shall 

include, but not limited to, the following: 

[Rule 62-4.070(3), F.A.C.] 

a) Day, Month, Year 

b) Hours of operation of each emission unit 

c) Amount and type of material unloaded from trucks (tons) 

d) Amount and type of material transferred from the Storage Building No. 3 to 

the Conveyor No. 12 Transfer Point A (tons) 

e) Written documentation, which may include shipping trails, showing the GTSP 

stored at the site is more than 72 hours old. 

f) Rolling twelve month total of c) and d) above. 

Regional Haze SIP for Florida 

Exhibit 2

Page 493 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 31 of 38

Subsection H. This section addresses the following emissions unit(s). 

E.U. ID 

No. Brief Description

-104 Clamshell to Hopper(s) RH-01 and RH-02 

-105 RH-01 and RH-02 to Conveyor BC-01 

-106 Conveyor BC-01 to Radial Stacker RS-01 

-107 RS-01 to Conveyor BC-02 or Conveyor PC-01 

-108 Conveyor BC-02 to Conveyor BC-03 or PC-01 to Conveyor PC-02 

-109 Conveyor BC-03 to Stacker Wing or PC-02 to Radial Stacker RS-02 

-110 Stacker Wing to Storage Pile or RS-02 to Storage Pile 

-111 Front End Loader to Truck 

-112 Stevedoring at Other Berths 

The stevedoring operation involves the loading and unloading of various bulk materials 

that include fertilizer materials, coal, limestone, granite, bauxite, etc., onto and from 

marine vessels, which can utilize up to three portable clamshell cranes. Material can also 

be unloaded by self unloading vessels. These materials are divided into different group 

categories. These operations are authorized for the Tampaplex facility and at numerous 

berths in Hillsborough County and include the use of hoppers, belt conveyors, radial 

stackers and a front-end loader. 

Particulate matter (PM) emissions from these facility operations are controlled by the use of a 

water spray system and partial enclosures, and or dust suppressants. The facility also operates a 

truck wheel wash to wash particulate material from truck tires prior to the trucks leaving the site. 

These emission units are regulated under Rule 62- 296.711, F.A.C., and Chapter 1-3.52, 

Rules of the EPC, which limit the visible emissions to a 5% opacity standard for all of the 

material handling operations. 

The following specific conditions apply to the emissions unit(s) listed above: 

Essential Potential to Emit (PTE) Parameters

H.1. In order to limit the potential to emit, the total potential particulate matter emissions 

from the Stevedoring operation shall not exceed 198 tons per twelve consecutive month 

period. [Rules 62-210.200(244), 62-4.070(3), and 62-212.300, F.A.C. and Permit No. 

0570024-016-AC] 

H.2. In order to ensure compliance with Facility Wide and Specific Condition Nos. 21 

and H.1., respectively, the following limitations shall apply per any twelve consecutive 

month period: [Rule 62-4.070(3), F.A.C. and Permit No. 0570024-016-AC] 

 A) The Stevedoring operation is permitted to handle the following materials 

only: 

Regional Haze SIP for Florida 

Exhibit 2

Page 494 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 32 of 38

Group I – Dusty Fertilizers 

Ammonium Sulfate Granular Sulfate of Potash Animal Feed 

Ingredients 

Standard Muriate of Potash Standard Sulfate of Potash Standard Potassium 

Nitrate 

Granular Muriate of Potash Granular Sulfate of PotashMagnesium Standard Sulfate of 

Potash-Magnesium 

Group II – Phosphate Rock 

Phosphate Products Rock 

Group III – Minimally Dusty Fertilizers 

Ammonium Nitrate Sodium Potassium Nitrate MAP 

Calcium Ammonium Nitrate Compound Fertilizers DAP 

Potassium Nitrate Dried Sludge GTSP

Calcium Nitrate Urea Kieserite 

Group I V – Millscale 

Millscale 

Group V– Moderately Dusty Non-Fertilizer Products 

Coal Syngypsum Clay 

Petcoke Iron Ore Magnetite/Ferrous 

Oxides 

Group VI – Minimally Dusty Non-Fertilizer Products 

Gypsum Alumina Hydrate Filler Materials 

Pumice Vermiculite Peanut Hulls 

Wood Chips Dolomite Salt (solar) 

Ferrous Sulfate Glass Bio-Mass 

Ferro Alloys Iron Scrap (including 

shredded scrap metal) 

Granulated Furnace 

Slag 

Clinker (treated or screened) Prilled Sulfur 

Group VII – Coal Slag 

Coal Slag

Group VIII – Agricultural Products 

Grains Grain Meals Seeds 

Soybeans Grain Byproducts Peas 

Wheat, Rye, Barley Citrus Pellets 

Group IX – Bauxite/Alumina and similar Dusty Cement-like Products 

Bauxite Alumina Slag Cement 

Group X - Aggregate 

Limestone Granite Rocks 

Regional Haze SIP for Florida 

Exhibit 2

Page 495 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 33 of 38

Group X – Aggregate - continued

Gravel Stone 

Group XI – Sand and Similar Materials 

Sand Soil Limestone Fines 

Dirt 

B) When calculating particulate matter emissions in order to demonstrate 

compliance with Facility Wide Condition Nos. 10 and 20 and Specific 

Condition No. H.1., the emission factors and control efficiencies listed below for 

each group of material shall be used. 

Group Number Emission Factor Control Efficiency 

for Water Sprays 

Max. Number of 

Transfer Points 

I 0.016 0.9 8 

II 0.24 0.9 8

III 0.01 0.9 8

IV 6.8 0.9 8

V 0.2 0.9 8

VI 1.1 0.9 8

VII 0.067 0.9 8

VIII 0.086 0.9 8

IX 1.1 0.9 8

X 0.004 0.9 8

XI 0.31 0.9 8

 

 C) Millscale shall be treated with water or a dust suppressant at the first material 

transfer point and subsequent material transfer points as necessary to meet 

the 5% opacity standard. 

D) All materials in Group IX shall be treated with a dust suppressant at the first 

material transfer point and subsequent material transfer points as necessary to 

meet the 5% opacity standard. 

Conditions Specific to the Operation at Kinder Morgan’s Tampaplex Berth

H.3. In order to ensure compliance with Specific Condition Nos. H.1., H.2., and H.8., the 

following limitations and restrictions shall apply: [Rule 62-4.070(3), F.A.C.] 

A) The maximum throughput of the conveying system shall not exceed 1000 tons 

per hour of material. 

B) The conveyors shall have 180 degree covers except for BC-01 and BC-03. 

C) The receiving hoppers shall be equipped with wind shields and water sprays 

and the material drop height shall be minimized to the extent practicable. In 

no case shall the drop height be greater than 5 feet or above the top of the 

wind shields. 

Regional Haze SIP for Florida 

Exhibit 2

Page 496 of 501
Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 34 of 38

D) The number of transfer points shall not exceed eight. 

E) The permittee shall operate a maximum of two ship unloading cranes. 

F) In order to determine the optimum dust suppression system settings during 

material unloading, Kinder Morgan shall develop and maintain a Dust 

Suppression System Operation Plan. This Plan shall be developed on a permaterial basis and shall include, but is not be limited to the recording of the 

following data: the material being transferred, moisture content of material, 

material transfer rate, weather conditions, and the water flow rate at each 

material transfer point, along with the number of nozzles required for 

operation at each transfer point to ensure compliance with the 5% opacity 

standard. Visible emission testing shall be performed during the 

development of this Plan to determine and record the specific flow rates and 

number of nozzles required for operation at each material transfer point to 

ensure compliance with the 5% opacity standard. The results of the visible 

emission testing performed during the development of the Operation Plan do 

not need to be submitted for review by the Environmental Protection 

Commission but shall be kept on-site and made available upon request. The 

Operation Plan shall be updated as material unloading conditions warrant to 

ensure visible emission compliance. Once an Operation Plan has been 

developed for a material, it shall be followed when unloading that material. 

The plans shall be maintained onsite and shall be made available upon 

request to any local, state, or federal air pollution agency. 

G) The permittee shall install, calibrate, and maintain flow meters for Emission 

Unit Nos. 104 through 110. 

H) The haul road down the middle of the storage pile area and to the north of the 

storage pile area shall be paved and maintained. 

I) A truck wash station shall be installed so that each truck leaving the facility 

exits through a washing station. 

J) No blowers shall be used in the vessel holds. 

K) Vehicles shall be completely enclosed by design or shall be enclosed with tarps 

prior to leaving the facility. 

L) The unbound (sorbed) moisture percent in petroleum coke shall not be less than 

4%. 

H.4. The permittee shall perform the following observations and checks on the schedule 

specified below. The permittee shall perform any necessary maintenance work in order to 

keep the equipment in good working order to minimize fugitive particulate emissions. 

[Rules 62-296.700(6), 62-4.070(3) and 62-213.440(1)(b)2.b., F.A.C.] 

 

 A) Daily (when in operation)

1) Inspect the water sprinkler system for proper operation, including, but 

not limited to, leaks and adequate wetness of material. 

 B) Each day of Hauling (when in operation)

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

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1) Inspect the unpaved areas to ensure they are adequately wet. 

2) Inspect the paved haul areas to ensure they are free of dust and debris. 

3) Inspect the truck wheel wash station for proper operation. 

 

 C) Each Marine Vessel Unloading Operation (when in operation)

 1) Record the maximum throughput rate for each marine vessel as 

measured by Belt Scale, BSC-01, in tons per hour. 

 

D) Records of inspections, maintenance, and performance parameters shall be 

retained for a minimum of five years and shall be made available to any local, 

state, or federal air pollution control agency upon request. 

Conditions Specific to Operation at the Other Berths in Hillsborough County

H.5. In order to ensure compliance with Specific Condition No. H.1., H.2., and H.8., the 

following restrictions and limitations shall apply during any twelve consecutive month 

period: [Rules 62-296.711(2)(a) and 62-4.070(3), F.A.C.] 

A) The maximum transfer rate shall not exceed: 

Transfer Point Description Maximum Average Transfer Rate 

Ship Loading 500 tons/hour 

Ship Unloading using Hopper 

(ship to hopper to truck) 

500 tons/hour 

B) The permittee shall not cause, permit, or allow any visible emissions (five 

percent opacity) from any emissions point. 

H.6. In order to demonstrate compliance with Specific Condition No. H.1., H.2., and 

H.8., the following restrictions and limitations shall apply: [Rule 62-4.070(3), F.A.C. and 

Permit No. 0570024-016-AC] 

A) The hopper shall be equipped with wind shields and water spray system and the 

material drop height minimized to the extent practicable. In no case shall the 

drop height be greater than 5 feet or above the top of the wind shields. 

B) Water or a dust suppressant shall be applied as needed to control visible 

emissions from the shiphold, receiving hopper, truck loading, or stockpiling. 

Regardless of whether or not water is used, the spray nozzles shall be set up and 

shall be in an operational mode during the material transfer process. 

C) The permittee may operate a maximum of three cranes at a maximum of three 

berths simultaneously. 

D) The hours of operation are not restricted. 

E) No blowers shall be used in the vessel holds. 

F) The number of transfer points shall not exceed eight. 

G) The unbound (sorbed) moisture percent in petroleum coke shall not be less than 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 36 of 38

4%. 

H) Material shall not be stockpiled at the dock for more than 24 hours. 

H.7. The permittee shall perform the following observations and checks on the schedule 

specified. The permittee shall perform any necessary maintenance work in order to keep the 

equipment in good working order to minimize fugitive particulate emissions. [Rules 62-

296.700(6), 62-4.070(3), and 62-213.440(1)(b)2.b., F.A.C.] 

A) The hopper wind shields and water spray system shall be inspected prior to use. 

Maintenance or repairs shall be performed before the start of the operation. Its 

components shall be repaired or replaced as needed to ensure that the materials 

handled are moist or wetted to the extent necessary to maintain compliance with 

the opacity standards specified in Specific Condition Nos. H.5.B) and H.8. 

B) Check to ensure the petroleum coke is sufficiently coated with a dust 

suppressant and/or water in order to meet the opacity standards specified in 

Specific Condition Nos. H.5.B) and H.8. 

C) Records of inspections, maintenance, and performance parameters shall be 

retained for a minimum of five years and shall be made available to any local, 

state, or federal air pollution control agency upon request. 

Emission Limitations and Standards

H.8. The permittee shall not cause, permit, or allow any visible emissions (five percent 

opacity) from any emission point or operation. [Rule 62-296.711(2)(a), F.A.C.] 

Test Methods and Procedures

H.9. Test all the emission units for visible emissions at the Tampaplex site, upon the 

first instance of handling a new material, and annually, once per federal fiscal year 

(October 1 – September 30), thereafter. Each VE observation shall be made at the point of 

highest opacity from each transfer point. Submit two copies of the test data to the Air 

Management Division of the Environmental Protection Commission of Hillsborough 

County within 45 days of such testing. Testing procedures shall be consistent with the 

requirements of Rule 62-297.310, F.A.C. [Rules 62-297.310(7)(a)4., 62-297.310(8)(b), and 

62-4.070(3), F.A.C.] 

H.10. Test the Stevedoring operation for opacity once per federal fiscal year (October 1 

– September 30) while operating at each berth other than the Kinder Morgan Tampaplex 

berth. Compliance with Specific Condition Nos. H.5.B) and H.8. shall be demonstrated 

by testing the dustiest material handled during the previous twelve months. Submit two 

copies of the test data to the Air Management Division of the EPC within forty-five days 

of such testing. Testing procedures shall be consistent with the requirements of Rule 62-

297, F.A.C. [Rules 62-297.310(7)(a)4., 62-297.310(8)(b), and 62-4.070(3), F.A.C.] 

H.11. Testing of emissions shall be conducted with the source operating at capacity. 

Capacity is defined as 90-100% of the rated capacity listed in Specific Condition Nos. 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

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H.3.A) and H.5.A). If it is impracticable to test at capacity, then the source may be tested 

at less than capacity; in this case subsequent source operation is limited to 110% of the 

test load until a new test is conducted. Once the unit is so limited, operation at higher 

capacities is allowed for no more than fifteen days for purposes of additional compliance 

testing to regain the rated capacity in the permit, with prior notification to the EPC. 

Failure to submit the throughput rates, moisture content of the material as received, and 

actual operating conditions may invalidate the test. [Rules 62-4.070(3) and 62-297.310, 

F.A.C.] 

H.12. Compliance with the emission limitations of Specific Condition Nos. H.5.B) and 

H.8. shall be determined using EPA Method 9 contained in 40 CFR 60, Appendix A and 

adopted by reference in Rule 62-297, F.A.C. The Method 9 test shall be at least 30 

minutes in duration. The minimum requirements for stack sampling facilities, source 

sampling and reporting, shall be in accordance with Rule 62-297, F.A.C. and 40 CFR 60, 

Appendix A. [Rules 62-297, 62-297.310(4)(a)2., and 62-296.711(3)(a) F.A.C.] 

H.13. The permittee shall notify the Air Compliance Section of the Environmental 

Protection Commission of Hillsborough County at least 15 days prior to the date on which 

each formal compliance test is to begin of the date, time, and place of each such test, and the 

contact person who will be responsible for coordinating and having such test conducted. 

[Rules 62-297.310(7)(a)9., F.A.C.] 

Recordkeeping and Reporting Requirements

H.14. In order to ensure compliance with Specific Condition Nos. H.1., H.2., and H.5., 

the permittee shall maintain a recordkeeping system. The records shall be maintained 

onsite for five years and shall be made available to any local, state, or federal air 

pollution agency upon request. The records shall include, but not limited to, the 

following: [Rule 62-4.070(3), F.A.C. and 62-213.440(1)(b)2.b., F.A.C.] 

 

 A) Operation at Kinder Morgan’s Tampaplex Berth

 I. Material Handling Records 

1) Day, Month, Year 

2) Amount, Group, and Type of each material received (tons) 

3) Amount Group, and Type of each material shipped offsite (tons) 

4) Monthly total of 2) and 3) above 

5) Rolling twelve month total of 4) above 

6) Monthly and twelve month rolling summary of particulate matter 

emissions from material handling. When calculating particulate 

matter emissions, the emission factors and control efficiencies listed in 

H.2.B) shall be used. 

7) Records as required by Specific Condition No. H.4. 

Regional Haze SIP for Florida 

Exhibit 2

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Kinder Morgan Terminals FINAL Permit No.: 0570024-014-AV 

Tampaplex Terminal Project: Bulk Material Handling 

Page 38 of 38

 B) When Operating at Other Berths

 I. Material Handling Records 

1) Day, Month, Year 

2) Berth No. or Location 

3) Amount, Group, and Type of each material received (tons) 

4) Amount Group, and Type of each material shipped offsite (tons) 

5) Monthly total of 3) and 4) above 

6) Rolling twelve month total of 5) above 

7) Monthly and twelve month rolling summary of particulate matter 

emissions from material handling. When calculating particulate 

matter emissions, the emission factors and control efficiencies listed in 

H.2.B) shall be used. 

8) Records as required by Specific Condition No. H.4. 

Regional Haze SIP for Florida 

Exhibit 2

Page 501 of 501