# Appendix L6

Summary of BART Modeling ExemptionsFacility ID OWNER COMPANY NAME SITE NAME Meets Model

Exemption Meets

Model Rule

Exemption Max Vis Impact

(deciviews)

0010006 CITY OF GAINESVILLE, GRU DEERHAVEN GENERATING STATION xxx 0.205

0050009 STONE CONTAINER CORPORATION PANAMA CITY MILL xx 0.498

0050014 GULF POWER COMPANY LANSING SMITH PLANT c 0.06

0090196 RELIANT ENERGY INDIAN RIVER, L.L.C. INDIAN RIVER PLANT - RELIANT c 0.178

0110036 FLORIDA POWER & LIGHT (PPE) PORT EVERGLADES POWER PLANT c 0.462

0310045 JEA NORTHSIDE/SJRPP c 0.402

0310071 IFF CHEMICAL HOLDINGS, INC. IFF CHEMICAL HOLDINGS, INC. x 0.269

0330040 SOLUTIA INC. SOLUTIA INC. x

0330042 INTERNATIONAL PAPER COMPANY PENSACOLA MILL x 0.057

0330045 GULF POWER COMPANY CRIST ELECTRIC GENERATING PLANT c 0.21

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

0570005 CF INDUSTRIES, INC., PLANT CITY PHOS CF INDUSTRIES, INC., PLANT CITY PHOSP xx 0.498

0570008 MOSAIC RIVERVIEW xx 0.494

0610029 CITY OF VERO BEACH CITY OF VERO BEACH MUNICIPAL UTILITIES xxx 0.17

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

0810010 FLORIDA POWER & LIGHT (PMT) MANATEE POWER PLANT c 0.458

0850001 FLORIDA POWER & LIGHT (PMR) FPL / MARTIN POWER PLANT c 0.449

0890003 SMURFIT STONE CORPORATION (US) JSC-FERNANDINA BEACH PAPERBOARD MILL xx 0.495

0990016 ATLANTIC SUGAR ASSOCIATION ATLANTIC SUGAR MILL x 0.49

0990019 OSCEOLA FARMS OSCEOLA FARMS x 0.302

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

0990045 LAKE WORTH UTIL. TOM G. SMITH PLANT xxx 0.11

1010017 FLORIDA POWER CORP. ANCLOTE POWER PLANT c 0.488

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

1050046 MOSAIC - BARTOW BARTOW x 0.144

1050053 MOSAIC - GREEN BAY GREEN BAY PLANT x 0.219

1050055 I MC PHOSPHATES COMPANY SOUTH PIERCE x 0.494

1050059 MOSAIC - NEW WALES NEW WALES xx 0.496

1070005 GEORGIA-PACIFIC CORP. PULP/PAPER MILL GEORGIA-PACIFIC CORP. xx 0.48

1070014 FLORIDA POWER & LIGHT (PPN) PUTNAM POWER PLANT xxx 0.491

1130003 STERLING FIBERS, INC. STERLING FIBERS, INC. x

1130005 EXXONMOBIL PRODUCTION COMPANY ST REGIS TREATING FAC AND JAY GAS PLANT x 0.39

1230001 BUCKEYE FLORIDA, LIMITED PARTNERSHIP BUCKEYE FLORIDA, LIMITED PARTNERSHIP x 0.284

c - PM only; relies on CAIR 31 2

xx - obtained federally enforceable permit condition for exemption

xxx - considers SO2, NOx, and PM; does not rely on CAIR

Highlighted sources are new to this revision

### BART Modeling Review

Atlantic Sugar

– units 1, 2, 3, and 4

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

based on maximum stack test data for NOx and PM (bagasse), and for SO2

(bagasse) from industry test data; AP-42 was used for NOx and SO2 emissions

when firing fue l oil; maximum allowable permitted PM for fuel oil; condensable

emissions from AP-42

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOS T

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.490 dv

(Everglades NP)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Buckeye

–

units 7, 11, 22, and 23 (No.’s 3 and 4 recovery boilers, and No.’s 3 and 4 smelt

dissolving tanks)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

SO2 and NOx emissions based on maximum permitted process rate and NCASI

emission factors developed for the industry; PM emissions based on maximum

stack test data

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

–

in puts correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.284 dv (St.

Marks NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

CF Industries

– units 2,3,7,8,10,11,12,13,15, and 18 (A, B, C, and D sulfuric acid plants,

A, Z, X, and Y DAP/MAP plants, and, A and B shipping baghouses.

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP

Comments were appropriately responded to by the applicant

Protocol includes the evaluation of three scenarios for emission reductions

sufficient to meet the exemption criteria. Only scenarios A and B have been

evaluated beca use scenario C was not deemed consistent with current permit

conditions and was dismissed by the department. A federally enforceable permit

requiring the implementation of either A or B scenarios is being issued.

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

Two emission reduction scenarios evaluated

– CFI has the option of choosing

either .

Scenario A

– SO2 emissions are reduced from the “A” SAP 250 lb/hr to 75.8 lb/hr

(24- hr average), from the “B” SAP 233.3 lb/hr to 93.3 lb/hr, from the “C” SAP

401.1 lb/hr to 303.3 lb/hr, and from “D” SAP 401.3 lb/hr to 303.3 lb/hr.

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

reductions in production.

Scenario B

– SO2 emissions are reduced from the “A” SAP 250 lb/hr to 81.3

lb/hr, from the “B” SAP 233.3 lb/hr to 100 lb/hr, from the “C” SAP 401.1 lb/hr to

241.7 lb/hr, and from “D” SAP 401.1 lb/hr to 241.7 lb/hr. Again, min or

reductions from NOx and sulfuric acid mist will occur resulting from production

decreases.

All data input correctly and consistent with protocol

Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.498 dv

(Chassahowitzka NWA) for scenario A, and 0.432 dv (Chassahowitzka NWA) for

scenario B from modeling report

b ased on new IMPROVE equation

### Department recommendation: Either scenario meets BART exemption criteria, source

exempt.Gainesville Regional Utilities (GRU) Deerhaven

– Exemption Report

Introduction

The GRU Deerhaven BART

- eligible source was determined to be exempt based on modeling of PM

emissions only in the August 2010 regional haze SIP submittal. The BART

- eligible source consists of one

75 MW oil/gas

- fired boiler (boiler 1, emissions unit ID 3). The modeling for this exemption was

completed by the source based on the VISTAS modeling protocol.

This facility relied on the Clean Air Interstate Rule (CAIR) to satisfy the BART requirement for SO2 and

NOx. With CAIR no longer applicable, GRU has reevaluated the ex emption modeling by including all

three visibility

- impairing pollutants SO2, NOx, and PM. The CALPUFF model was used to determine if

the BART

- eligible source could meet the modeling exemption based on having a less than 0.5 desiview

impact on any Class I area. The GRU followed their original approved protocol (based on the general

VISTAS modeling protocol ) to complete this analysis, with the following exceptions:

1. The current regulatory version of the CALPUFF modeling system is being used.

2. The FLM

- derive d meteorological input data set for 2001

- 2003 is being used, in lieu of the

original VISTAS dataset.

3. The maximum actual 24

- hour average emission rates for SO2 and NOx are included and are

derived from the most recent three years (200 9- 2011 ) of CEMS data for each unit.

Results

The GRU Deerhaven facility is located within 300 km of four Class I areas: 91 km from Okefenokee NWA,

113 km from Chassahowitzka NWA, 158 km from St. Marks NWA, and 200 km from Wolf Island NWA

. The new IMPROVE algorithm was used t o establish the 98 th percentile change (8 th high value) in visibility

for each Class 1 area and for each year. A value less than 0.5 desiviews is deemed to be exempt from

BART. As can be seen in the table below, the 8 th high value is less than this valu e at all Class I areas and

for all years. The source did not add in the NOx concentration for the purpose of determining the

visibility degradation due to NO2, however, such an addition would not significantly change the results.

As such, DEP finds tha t the GRU Deerhaven BART

- eligible source is exempt from BART.Class I Area Rank 2001 2002 2003

Okefenokee NWA Δdv Δdv Δdv

1 0.323 0.249 0.348

2 0.319 0.244 0.293

3 0.307 0.230 0.247

4 0.251 0.216 0.241

5 0.213 0.201 0.202

6 0.173 0.187 0.202

7 0.167 0.168 0.190

8 0.152 0.168 0.190

Chassahowitzka NWA

1 0.526 0.220 0.263

2 0.341 0.215 0.249

3 0.304 0.186 0.160

4 0.268 0.172 0.150

5 0.268 0.165 0.148

6 0.244 0.163 0.130

7 0.207 0.163 0.127

8 0.197 0.156 0.122

St. Marks NWA

1 0.282 0.289 0.275

2 0.263 0.275 0.182

3 0.195 0.272 0.157

4 0.168 0.250 0.144

5 0.156 0.250 0.139

6 0.152 0.224 0.135

7 0.142 0.209 0.133

8 0.131 0.205 0.131

Wolf Island

NWA

1 0.164 0.146 0.190

2 0.145 0.130 0.129

3 0.112 0.115 0.119

4 0.109 0.113 0.101

5 0.095 0.109 0.096

6 0.086 0.100 0.095

7 0.081 0.099 0.086

8 0.072 0.097 0.075

### BART Modeling Review

City of Tallahassee Hopkins

– units 1 and 4

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data, using maximum rated heat input

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.522 dv (St.

Marks NWA), based on the old IMPROVE equation

maximum 8 th 

### highest daily visibility value at any Class I area = 0.444 dv (St.

Marks NWA), based on new IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.Vero Beach Utilities

– Exemption Report

Introduction

In the original Florida SIP submittal Vero Beach utilities, units 2, 3, and 4, satisfied the modeling

exemption criteria by considering only the particulate matter (PM) emissions. Units 2, 3, and 4 are

relatively small oil/gas

‐ fired boilers with generation capacities of 17 MW, 34 MW, and 56 MW,

respectively. Uni t 2 has not operated since 1999, and the other two units operate less than 8% of the

year. The CALPUFF modeling used for establishing the exemption followed the protocol originally

submitted by the source operator. This protocol was based on the general VISTAS modeling protocol

and was revi ewed by DEP, EPA, and the FLM’s.

This facility relied on the Clean Air Interstate Rule (CAIR) to satisfy the BART requirement for SO2 and

NOx. With CAIR no longer applicable, the DEP has reevaluated the exemption modeling by including all

three visibility

‐ impairing pollutants SO2, NOx, an d PM

. In co mpleting this evaluation, the DEP followed

the original protocol with a few exceptions that we believe are appropriate. These changes are:

1. The current regulatory version of the CALPUFF modeling system is being used.

2. The FLM

‐ derived meteorological input data set for 2001

‐ 2003 is being used, in lieu of the

original VISTAS dataset.

3. The maxim um actual 24

‐ hour average emission rates for SO2 and NOx are included and are

derived from the most recent three years (2008

‐ 1010) of CEMS data for each unit. The original

PM emission rates were used based on maximum allowable limi ts.

Further, where th e origina l modeling modeled each unit separately and added the visibility impacts, the

new modeling simply modeled all three sources together.

Results

The Vero Beach source is located within 300 kilometers of two Class 1 areas: Chassahowitzka National

Wilderness Area (247 km) and Everglades National Park (209 km). The new IMPRO VE algorithm was

used to establish the 98 th percentile change (8 th high value) in visibility for each Class 1 area and for each

year. A value less than 0.5 desiviews is deemed to be exempt from BART. As can be seen in the table

below, the 8 th high value is less than this value at both Class 1 areas and for all years. As such, DEP finds

that the Vero Beach BART

‐ eligible source is exempt from BART.Class 1 Area 2001 2002 2003

Chassahowitzka

NWA Δ dv Δ dv Δ dv

1 0.26 0.41 0.22

2 0.24 0.26 0.19

3 0.22 0.23 0.17

4 0.20 0.22 0.16

5 0.18 0.20 0.16

6 0.17 0.18 0.14

7 0.17 0.18 0.15

8 0.17 0.17 0.14

Everglades NP

1 0.31 0.20 0.24

2 0.14 0.18 0.24

3 0.14 0.16 0.22

4 0.14 0.16 0.20

5 0.11 0.14 0.18

6 0.11 0.14 0.16

7 0.10 0.13 0.16

8 0.10 0.13 0.15

### BART Modeling Review

Exxon Mobil

– unit 34 (sulfur recovery plants)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

SO2 based on stack test data; PM and NOx based on annual operation reports; PM

and NOx emissions are very small and variations of these values would not be

expected to significantly change the results

input correctly and consistent with protocol

default speciation used correctly (all PM is fine and is organic carbon)

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

output for 2002 inconsistent with values listed in the report, other years are

consistent; the model output takes precedence, and no further action is necessary

maximum 8 th 

### highest daily visibility value at any Class I area = 0.390 dv (Breton

NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

FPL Martin

– units 1 and 2

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

–

PM only

based on maximum stack test data

input correctly and consistent with the revised protocol.

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent wi th applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.449 dv

(Everglades NP)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

FPL Manatee

– units 1 and 2

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data

input correctly and is consistent with the revised protocol.

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.458 dv

(Chassahowitzka NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

FPL Port Everglades

–

units 3 and 4

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum permitted emission rates from the Title V permit and actual

maximum heat input rates based on stack tests.

input correctly and consistent with the protocol.

speciation correctly input and consistent with protocol

Results from CAL POST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.594 dv

(Everglades NP), based on old IMPROVE equation

new IMPROVE equation was used correctly, giving a maximum 8 th 

### highest daily

visibility value of 0.462 dv

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Progress Energy Anclote

– units 1 and 2

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were considered in the final report

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test emission rates

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applican t’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.576 dv

(Chassahowitzka NWA), based on the old IMPROVE equation

maximum 8 th 

### highest daily visibility value at any Class I area = 0.488 dv

(Chassahowitzka NWA), based on the new IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.FPL Putnam

– Exemption Report

Introduction

The FPL Putnam BART

‐ eligible source was determined to be exempt based on modeling of PM emissions

only in the August 2010 regional haze SIP submittal. The BART

‐ eligible source consists of four

combustion turbines each with an associated heat recovery steam generator equipped with duct

burners id entified as HRSG11, HRSG12, HRSG21, and HRSG22. The modeling for this exemption was

completed by the VISTAS contractor TRC, Inc., using a conservative implementation of the VISTAS

modeling protocol. A more specific modeling protocol following the VISTAS protocol was submitted by

FPL for the Putnam BART

‐ eligible source and include d in th e state’s SIP submiss ion, but was not

implemented for the Putnam facility because the conservative TRC modeling had shown that it met the

exemption criteria.

This facility relied on the Clean Air Interstate Rule (CAIR) to satisfy the BART requirement for SO2 and

NOx. With CAIR no longer appli cable, FPL has reevaluated the e x emption modeling by including all three

visibility

‐ impairing pollutants SO2, NOx, and PM. In fact, FPL had originally evaluated the Putnam BART

‐

eligible source with the appropriate emissions for all three visibility impairing pollutants, and had

determined that it would meet the modeled exemption criteria. This original modeling wa s not

submitted be cause it was unnecessary in lieu of the TRC results. FPL has reproduced this modeling using

the approved modeling protocol and the emissions applicable at the time of the original submission.

Correspondence with EPA Region 4 confirmed that the use of the original protocol modeling was

acceptable. The DE P agrees since, had FPL submitted this analysis for the original SIP submittal, it would

have been acceptable and an exemption would have been granted.

Results

The FPL Putnam facility is located 119 km from Okefenokee NWA, 141 km from Chassahowitzka NWA,

and 236 km from St. Marks NWA. The new IM PRO VE algorithm was used to establish the 98 th percentile

change (8 th high value) in visibility for each Class 1 area and for each year. A value less than 0.5

desiviews is deemed to be exempt from BART. As can be seen in the table below, the 8 th high value is

less than this value at both Class 1 areas and for all years. As such, DEP finds that the FPL Putnam

BART

‐ eligible source is exempt from BART.Class I Area Rank 2001 2002 2003

Okefenokee NWA Δ dv Δ dv Δ dv

1 1.096 1.182 0.594

2 0.904 0.758 0.541

3 0.754 0.567 0.541

4 0.670 0.551 0.545

5 0.656 0.508 0.483

6 0.561 0.486 0.429

7 0.558 0.448 0.409

8 0.491 0.438 0.381

Chassahowitzka NWA

1 1.412 0.575 0.498

2 0.753 0.515 0.474

3 0.475 0.433 0.413

4 0.451 0.410 0.333

5 0.450 0.399 0.316

6 0.450 0.387 0.309

7 0.391 0.336 0.303

8 0.320 0.295 0.258

St. Marks NWA

1 0.706 0.671 0.506

2 0.660 0.398 0.482

3 0.400 0.395 0.421

4 0.288 0.333 0.339

5 0.294 0.305 0.335

6 0.263 0.261 0.321

7 0.250 0.223 0.308

8 0.220 0.217 0.262

### BART Modeling Review

Georgia Pacific

– units 15, 16, 17, 18, and 19 (No. 5 power boiler, No. 4 combination

boiler, No. 4 lime kiln, No. 4 recovery boiler, No. 4 smelt dissolving tank)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were not completely responded to by the applicant, additional

information showing the data and calculations for the maximum 24-hour

emissions is necessary

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

SO2, NOx, and PM emissions from units 17 and 18 based on maximum stack test

data; more information requested

Some errors in the input files for summing concentrations; re-runs requested

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.489 dv

(Okefenokee NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Gulf Power Lansing Smith

– units 1 and 2

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data and maximum heat input derived from CEMS

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.06 dv (St.

Marks NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Gulf Power Crist

– units 6 and 7

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum stack test data and maximum heat input derived from CEMS

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is con sistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.21 dv (Breton

NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

IFF Chemicals - unit 3 (boiler 2)

Requests exe mption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx and PM emissions

PM emissions based on maximum allowable permitted; NOx emissions based on

maximum AP-42 emission factors, SO2 emissions based on maximum potential

hourly rate for fuel burning plus the maximum actual 24-hour average due to CST

(crude sulfate terpentine) vapor incineration.

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.269 dv

(Okefenokee NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Mosaic South Pierce

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

sulfuric acid plants, No. 2 ball mill, GTSP production plant, GTSP east storage building

north and south scrubbers, GTSP rock hopper, molten storage tanks, and molten storage

pits)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

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

indicates stack height is 3.05 m

– this is judged an insignificant error because

these sources have very small emissions.

Otherwise, all stack parameters are consistent with the protocol

Emissions

– SO2, NOx, and PM

SO2 and H2SO4 emissions from units 4 and 5 based on maximum allowable

permitted with maximum actual 24-hour production; SO2, NOx, and H2SO4

emissions from the GTSP production plant based on AP-42 emission factors; SO2

emissions from the molten sulfur storage and transfer units based on maximum

allowable permitted; PM emissions from all sources based on maximum

allowable permitted

input correctly and consistent with protocol

Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.642 dv

(Chassahowitzka NWA) using the old IMPROVE equation ; = 0.494 dv using the

new IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

International Paper Pensacola

– units 29, 30, 32, and 38 (No. 1 Recovery Furnace, No. 1

Smelt Dissolving Tank, No. 2 Recovery Furnace, No. 2 Smelt Dissolving Tank)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

SO2 and NOx emissions based on NCASI technical bulletin 884; speciated PM

emissions based on AP-42 table 10.2-3, based on data from the maximum stack

test value

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

used RH-varying natural visibility

maximum 8 th 

### highest daily visibility value at any Class I area = 0.057 dv (Breton

NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

JEA Northside unit 3

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum AP-42 emission factors (oil/gas), daily measured oil/gas heat

input (CEM), and monthly heating values. Note: cross-checked with the actual

maximum stack test data and found the applicant’s method provided higher

emission rate.

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.402 dv

(Okefenokee NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Lakeland McIntosh

– units 1 and 5 (boilers 1 and 2)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were addressed within the final report

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum allowable permit limit

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.215 dv

(Chassahowitzka NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.Lake Worth Utilities –Exemption Report

Introduction

The Lake Worth Utilities Tom G. Smith BART

‐ eligible source consists of the 27 MW fossil fuel steam

generator 3 (S3) and the 30 MW gas turbine 1 (GT1). This source was originally determined to be

exempt from BART following the model rule exemption, having less than 1000 tons of PM emissions and

being more than 100 ki lometers from the nearest Cl ass I area. With CAIR being replaced by CSAPR, and

with Florida no longer subject to CSAPR for the purpose of SO2 emissions, the model rule exemption

must apply to the total of SO2, NOx, and PM emissions. As a res u lt, the Lake Worth BART

‐ eligible source

does not satisfy the exemption criteria of the model rule exemption.

In lieu of the model rule exemption, the DEP has evaluated the Lake Worth BART

‐ eligible source for

meeting the modeling exemption based on having a less than 0.5 desiview impact on any Class I area

using the CALPUFF model. The DEP followed the general VISTA S modeling pro tocol to complete this

analysis, with the following exceptions:

1. The current regulatory version of the CALPUFF modeling system is being used.

2. The FLM

‐ derived meteorological input data set for 20 01

‐ 2003 is be ing used, in lieu of the

original VISTAS dataset.

3. The maximum actual 24

‐ hour average emission rates for SO2 and NOx are included and are

derived from the most recent three years (2008

‐ 1010) of CEMS data for each unit. The PM

emission rates were used based on ma ximu m allowable limits.

Results

The Lake Worth source is located within 300 km of one Class I area: the Everglades National Park (106

km). The new IMPROVE algorithm was used to establish the 98 th percentile change (8 th high value) in

visibility for each Class I area and for each year. A value less than 0.5 desiviews is deemed to be exempt

from BART. As can be seen in the table below, the 8 th high value is less than this value at both Class 1

areas and for all years. As such, DEP finds that the Lake Worth BART

‐ eligible source is exempt from

BART.

Class I Area Rank 2001 2002 2003

Everglades NP ∆ dv ∆ dv ∆ dv

1 0.14 0.17 0.14

2 0.12 0.14 0.14

3 0.12 0.11 0.13

4 0.11 0.11 0.13

5 0.11 0.11 0.13

6 0.10 0.10 0.12

7 0.09 0.11 0.12

8 0.09 0.10 0.11

### BART Modeling Review

Mosaic Riverview

– units 4, 5 , 6, 63, 66, 67, and 68 (No.’s 7, 8, and 9 sulfuric acid plants,

molten sulfur storage tanks 1, 2, and 3, and molten sulfur storage and handling pits 7, 8,

and 9)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

For sulfuric acid plants based on maximum allowable permitted for SO2 and

H2SO4, reduced specifically to meet the BART exemption criteria. These

decreased emissions in the sulfuric acid plants will result from increased

vanadium catalyst. NOx emissions based on data from a PSD permit application.

No changes to the emissions (PM) from the molten sulfur storage tanks or pits,

and are based on data from a PSD permit application.

All data input correctly and consistent with protocol

Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.494 dv

(Chassahowitzka NWA) from modeling report

based on new IMPROVE equation

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

### BART Modeling Review

Mosaic Bartow

– unit 54 (No. 3 sulfuric acid plant)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

–

SO2

based on maximum allowable permitted for SO2 and H2SO4

input correctly and consistent with protocol

No PM emissions

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.144 dv

(Chassahowitzka NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Mosaic Green Bay

– units 4, 7, and 29 (No. 4 sulfuric acid plant, South AP fertilizer plant,

and North MAP/DAP fertilizer plant)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

based on maximum allowable permitted for PM, for all units; SO2 and H2SO4 for

unit 4 based on maximum allowable permitted; NOx for unit 4 based on

maximum allowable permitted limit for unit 3 sulfuric acid plan; for other units,

NOx based on AP-42; NOx, SO2, and H2SO4 for units 7 and 29 based on AP-42

Unit 7 dryer NOx emissions were input to the model based on fuel oil burning

(8.9 lb/hr)

– protocol indicated a maximum of 12.6 lb/hr based on LPG; this

difference is not considered significant in this case and no re-run is deemed

necessary

Otherwise, input correctly and consistent with protocol

Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is inconsistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.241 dv

(Chassahowitzka NWA) from modeling report; = 0.219 dv from model output

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Mosaic New Wales

– units 2,3,4,9,11,27,36,15,23-28,29-35,38,52,55,63, and 66- 68 (No.’s

1, 2, and 3 sulfuric acid pl ants, DAP plant No. 1, MAP plant, AFI plant, multifos A and B

kilns, dryer and blending operation, and various low emitting particulate-only sources

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP

Comments were appropriately responded to by the applicant

Protocol includes the evaluation of two scenarios for emission reductions

sufficient to meet the e xemption criteria. A federally enforceable permit requiring

the implementation of one or the other of these scenarios is being issued.

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

Two emission reduction scenarios evaluated

– Mosaic New Wales has the option

of choosing either .

Scenario A

– Sulfuric acid mist emissions from SAP’s No. 1,2, and 3 are reduced

from 14.0 to 7.1 lbs/hr; DAP plant No. 1 and AFI plant dryers are fired using only

natural gas; mult ifos plant kilns A and B are shut-down; DAP plant No. 1 PM

emissions are reduced from 28.6 to 15 lbs/hr; and, MAP plant PM emissions are

reduced from 15 to 7 lbs/hr.

Scenario B

– SO2 emissions from SA P’s 1, 2, and 3 each are reduced from 496 to

400 lbs/hr; sulfuric acid mist emissions from the SAP’s reduced from 14.0 to 6.7

lbs/hr; NOx emissions from the SAP’s reduced from 17 to 16 lbs/hr; DAP plant

No. 1 and AFI plant dryers are fired using only natural gas; multifos A and B

kilns dryer is fired with only natural gas and PM emissions are reduced from 29.8

to 25 lbs/hr; SO2 emissions from the multifos A and B kilns dryer reduced from

316 to 25 lbs/hr; PM emissions from DAP plant No. 1 reduced from 28.6 to 16

lbs/hr; and, MAP plant PM emissions are reduced from 15 to 7 lbs/hr.

All PM emissions from sources not requiring a reduction via scenario A or B use

maximum actual values.

All data input correctly and consistent with protocol

Assumed all PM are fine particles and are organic compounds

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

### maximum 8 th 

### highest daily visibility value at any Class I area = 0.490 dv

(Chassahowitzka NWA) for scenario A, and 0.496 dv (Chassahowitzka NWA) for

scenario B from modeling report

based on new IMPROVE equation

Department recommendation: Either scenario meets BART exemption criteria, source

exempt.

### BART Modeling Review

Osceola Farms

– units 2 and 4 (mill boilers No.’s 2 and 4)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

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

condensable emissions.

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.302 dv

(Everglades NP)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Reliant Indian River

–

units 2 and 3

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– PM only

based on maximum allowable rate considering both normal operation and soot

blowing

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.178 dv

(Chassahowitzka NWA)

based on old IMPROVE equation

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Smurfit Stone Container Fernandina Beach

– units 6, 7 and 13 (No. 5 power boiler, No. 4

recovery boiler, and No. 4 smelt dissolving tank)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

SO2 and NOx emissions from the recovery boilers and smelt dissolving tanks are

based on maximum permitted process rate and NCASI emission factors developed

for the industry, and by AP-42; A new SO2 emissions limit of 550 lb/hr (24-hour

average) is being requested by the applicant on the No. 5 power boiler to limit

their visibility impact to less than 0.5 dv.

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.915 dv

(Okefenokee NWA) using the old IMPROVE equation and 1026 lb SO2/hr on PB

5, and 0.495 dv, using the new emissions limitation of 550 lb SO2/hr and the new

IMPROVE equation.

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Smurfit Stone Panama City

– units 16, 1, 19, 20, 21, 4 and 5 (No. 4 combination boiler,

No.’s 1 and 2 recovery boilers, and No.’s 1 and 2 smelt dissolving tanks, lime kiln, and

lime slaker)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

SO2 and NOx emissions from the recovery boilers and smelt dissolving tanks are

based on maximum permitted process rate and NCASI emission factors developed

for the industry, and by AP-42; A new SO2 emissions limit of 690 lb/hr (24-hour

average) is being requested by the applicant on the No. 4 combination boiler to

limit their visibility impact to less than 0.5 dv. The lime kiln SO2 and NOx

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

maximum stack test data

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.586 dv (St.

Marks NWA) using the old IMPROVE equation, and 0.498 dv, using the new

IMPROVE equation.

Department recommendation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

Sugarcane Growers

– units 1, 2, 4, and 5 (boilers 1,2,4, and 5)

Requests exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, SO4, NOx, and PM

Because of the seasonal nature of sugar cane operations, crop season (October

through April) and off-crop season emission scenarios were modeled.

SO2 emissions were based on industry test data and assumptions in the Title V

permit. PM and NOx emissions were based on stack test data. PM was speciated

using AP-42 factors for wood-fired boilers (no specific factors are available for

bagas se -fired boilers). Condensible PM emissions were based on AP-42 and

divided equally between organic and inorganic species.

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

modeling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.634 dv

(Everglades NP) using the old IMPROVE equation and 0.467 dv, using the new

IMPROVE equation.

Department recomm endation: Meets BART exemption criteria, source exempt.

### BART Modeling Review

U.S. Sugar Clewiston

– units 1 and 2

Reque sts exemption based on modeled impact less than 0.5 dv.

Protocol:

Followed VISTAS common protocol

Reviewed by DEP and EPA

Comments were appropriately responded to by the applicant

Exemption modeling:

Stack parameters

– input correctly and consistent with protocol

Emissions

– SO2, NOx, and PM

based on maximum stack test data for NOx and PM (bagasse and fuel oil), and for

SO2 (boiler 1) when firing bagasse (applied to boiler 2 since nearly identical);

AP -42 was used for PM and SO2 emissions when firing fuel oil and for

determining condensable emissions.

input correctly and consistent with protocol

speciation correctly input and consistent with protocol

Results from CALPOST

– inputs correct and consistent with protocol

mod eling output is consistent with applicant’s report

maximum 8 th 

### highest daily visibility value at any Class I area = 0.265 dv

(Everglades NP)

based on old IMPROVE equation

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

The following sources were determined to be exem pt from the BART rule in accordance with Rule 62-

296.340(5)(a)1. or Rule 62-296.340(5)(a)2, Florida Ad ministrative Code. These exemptions follow the

U.S. EPA “model rule” criteria whereby BART-eligible sources located greater than 50 (or 100) km from

any Class I area and having potential emissions of SO 2+NOx+PM less than 500 (or 1000) tons is exempt.

In making this determination, the PM emissions are speciated and an equivalent tonnage is calculated

based on each specie’s sulfate-equivalent extinction.

Facility ID BART-eligible Source Minimum Distance to

Any Class I Area (km) Total Potential

Emissions

SO2+NOx+PM (tpy)

0330040 Solutia 166 963

1130003 Sterling Fibers 177 828

The department has verified the distance and poten tial emissions data used to make these exemption

determinations.