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D. Mosaic – New Wales 

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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. 

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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