# D. Mosaic – New Wales

### 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 di fferently among the BART-eligible source, but both result in visibility improvement . Taking into consideration these emission reductions, Mosaic completed air quality model ing 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 s cenarios A and B for the controlling Chassahowitzka area, are shown below as taken from the complete modeling report su bmitted by Mosaic.

### 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 criter ion for exemption from the BART rule of 0.5 dv. Based on the emission changes made in this permit, f ollowing 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 exem pt from the BART rule requirements.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/saSECTION 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 systemSECTION 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 (SO 2 ).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 PlantsSECTION 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 1 st 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;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.]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% H 2 SO 4 (sulfuric acid) -003 SAP No. 2 3,400 TPD of 100% H 2 SO 4 -004 SAP No. 3 3,400 TPD of 100% H 2 SO 4 -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.]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 SO 2 Controls : This BART exemption determination does not require new, modified or additional air pollution control systems for sulfur dioxide (SO 2 ). To control emissions of SO 2 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/PM 10 ) 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 SO 2 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 SO 2
-002 No.1 Sulfuric Acid Plant --- 17 lb/hour a 496 lb/hour b

-003 No. 2 Sulfuric Acid Plant --- 17 lb/hour a 496 lb/hour b

-004 No. 3 Sulfuric Acid Plant --- 17 lb/hour a 496 lb/hour b

-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)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): SO 2 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. SO 2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO 2 CEMS to be used to demonstrate continuous compliance with the SO 2 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 SO 2 . 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% H 2 SO 4 values for SAP Nos. 1, 2, and 3 at design capacity for each SAP is 0.05 lb SAM/ton 100% H 2 SO 4 . 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 averageSECTION 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 SO 2 and sulfur trioxide (SO 3 ) 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 SO 2 and SO 3 , or Other Fugitive Process Emissions: Best operational practices to minimize leaks of SO 2 and SO 3 , 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 SO 2 Emissions from Stationary Sources 7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure)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 SO 2 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 SO 2 CEMS are required to demonstrate compliance on a continuous basis, therefore, no initial or annual compliance test for SO 2 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 SO 2 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.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.]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 SO 2 and SAM emissions rates from the three SAPs. The SAPs shall comply with the new BART exemption limits for SO 2 and SAM by April 30, 2013. Multifos A and B Kilns (EU-036) will continue to operate with lower SO 2 and PM emission rates. A new scrubber will be installed to meet the lower SO 2 emission limits for Multifos A and B Kilns. The Multifos A and B Kilns shall comply with the new BART exemption limits for SO 2 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% H 2 SO 4 -003 SAP No. 2 3,200 TPD of 100% H 2 SO 4 -004 SAP No. 3 3,200 TPD of 100% H 2 SO 4 -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 inSECTION 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 SO 2 Controls : This BART exemption determination does require new, modified or additional air pollution control systems for SO 2 . To control emissions of sulfur dioxide (SO 2 ) 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 H 2 SO 4 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 SO 2 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 SO 2 emission limits. [Rule 62-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. SO 2 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 SO 2 emission rates of 3.0 lb SO 2 /ton 100% H 2 SO 4 . 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/PM 10 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 SO 2 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 SO 2 -002 No.1 Sulfuric Acid Plant --- 16 lb/hour a 400 lb/hour b

-003 No. 2 Sulfuric Acid Plant --- 16 lb/hour a 400 lb/hour b

-004 No. 3 Sulfuric Acid Plant --- 16 lb/hour a 400 lb/hour b

-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/hour c

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.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): SO 2 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. SO 2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO 2 CEMS to be used to demonstrate continuous compliance with the SO 2 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 SO 2 . 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% H 2 SO 4 values for SAP Nos. 1, 2, and 3 at design capacity for each SAP is 0.05 lb SAM/ton 100% H 2 SO 4 . 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.}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 SO 2 and SO 3 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 SO 2 and SO 3 , or Other Fugitive Process Emissions: Best operational practices to minimize leaks of SO 2 and SO 3 , 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 SO 2 Emissions from Stationary Sources 7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure)
8 Determination of SAM and SO 2 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 methodsSECTION 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 SO 2 and PM emissions from Multifos A and B Kilns, Dryer and Blending Operation. The initial compliance test report for NOx, SO 2 , 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 SO 2 CEMS are required to demonstrate compliance on a continuous basis, therefore, no initial or annual compliance test for SO 2 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 SO 2 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.]

# E. Mosaic – Riverview

### Mosaic Riverview BART Exemption Modeling

Mosaic Riverview specifically made changes to reduce sulfur dioxide (SO2) and sulfur ic 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 wit h 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 kilomet ers). 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 sulf

ur 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.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/smsSECTION 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 PlantSECTION 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 PlantsSECTION 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 1 st of each year, thereafter. [Rule 62-210.370(3), F.A.C.]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.]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]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]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 (SO 2 ). The sulfur dioxide is catalytically oxidized to sulfur trioxide (SO 3 ) 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 SO 2 emissions is primarily by the process itself. Currently, a double conversion, double absorption plant efficiently converts SO 2 to SO 3 then SO 3 reacts in a mixture of water and sulfuric acid to produce sulfuric acid. In a double absorption system, the conversion efficiency from SO 2 to SO 3 is at least 99.7%. All three plants use a vanadium catalyst in the converters, except that in the 4 th 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 1 st pass, 112,000 liters in the 2 nd pass, 155,000 liters in the 3 rd pass, and 209,000 liters in the 4 th 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 SO 2 continuous emissions monitoring system (CEMS). The SO 2 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) - 1 st BACT for SAP No. 7, PSD-FL-315 (0570008-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) - 2 nd

BACT 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% H 2 SO 4 (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. SO 2 Controls : This BART exemption determination does require new, modified or additional air pollution control systems for SO 2 . To control emissions of sulfur dioxide (SO 2 ) 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 H 2 SO 4 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.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 SO 2 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. SO 2 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 SO 2 emission rates of 2.8 to 3.0 lb SO 2 /ton 100% H 2 SO 4 . 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/PM 10 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. SO 2 Emission Standards & Limitations : This BART determination specifies new SO 2 emission standards. Emissions of SO 2 shall not exceed the following as determined by certified CEMS data:

SAP No. lb/hour 7 400 8 315 9 425
Emissions of SO 2 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 SO 2 /ton 100% H 2 SO 4 values for SAP Nos. 7, 8 and 9 at design capacity are: 3.0 lb SO 2 /ton 100% H 2 SO 4 ; 2.8 lb SO 2 /ton 100% H 2 SO 4 ; and, 3.0 lb SO 2 /ton 100% H 2 SO 4 , 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 aSECTION 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. SO 2 Continuous Emissions Monitoring System (CEMS) : This BART exemption determination requires an SO 2 CEMS to be used to demonstrate continuous compliance with the SO 2 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 SO 2 . In accordance with PSD-FL-250 & PSD-FL-315, the permittee shall continue to use SO 2 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% H 2 SO 4 values for SAP Nos. 7, 8 and 9 at design capacity for each SAP is 0.05 lb SAM/ton 100% H 2 SO 4 . 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 caseSECTION 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 SO 2 and SO 3 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 SO 2 and SO 3 , or Other Fugitive Process Emissions: Best operational practices to minimize leaks of SO 2 and SO 3 , 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 SO 2 Emissions from Stationary Sources
8 Determination of SAM & SO 2 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 withinSECTION 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 SO 2 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 SO 2 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.]

# F. CF Industries

### CF Industries BART Exemption Modeling

CF Industries has made federally enforceable changes to its operating perm its 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 di fferently among the BART-eligible source, but both result in visibility improvement . Taking into consideration these emission reductions, CF Industries completed air qualit y 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 (2 61 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), th e “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 29 62 to 2600 tons per day (TPD) eac h 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 produc tion 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.

### 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 su bmitted 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 cr iterion for exemption from the BART rule of 0.5 dv. Based on the emission changes made in this per mit, 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 fro m the BART rule requirements.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/saSECTION 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 BaghouseSECTION 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 PlantsSECTION 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 1 st of each year. [Rule 62-210.370(3), F.A.C.]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.]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 SO 2 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% H 2 SO 4 (sulfuric acid) -003 B SAP 1,600 TPD of 100% H 2 SO 4 -007 C SAP 2,600 TPD of 100% H 2 SO 4 -008 D SAP 2,600 TPD of 100% H 2 SO 4 -010 A DAP/MAP Plant 29.53 TPH [tons per hour of phosphorus pentoxide (P 2 O 5 ) input] for DAP; 33.30 TPH of P 2 O 5 input for MAP -011 Z DAP/MAP Plant 48.7 TPH of P 2 O 5 input for DAP; 55.0 TPH of P 2 O 5 input for MAP -012 X DAP/MAP Plant 48.7 TPH of P 2 O 5 input for DAP; 55.0 TPH of P 2 O 5 input for MAP -013 Y DAP/MAP Plant 48.7 TPH of P 2 O 5 input for DAP; 55.0 TPH of P 2 O 5 input for MAPSECTION 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 SO 2 Controls : This BART exemption determination does not require new, modified or additional air pollution control systems for sulfur dioxide (SO 2 ). To control emissions of SO 2 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 SO 2 emissions from A and B SAPs. To control emissions of SO 2 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/PM 10 ) 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 SO 2 Standards : Particulate matter (PM), nitrogen oxides (NOx) and sulfur dioxide (SO 2 ) emissions shall not exceed the following emissions standards.

EU ID No. Emissions Unit

Description Emissions Standards

PM NOx SAM SO 2
-002 A Sulfuric Acid Plant --- 6.5 lb/hr a 1.43 lb/hr b 75.8 lb/hr c

-003 B Sulfuric Acid Plant --- 8.0 lb/hr a 1.8 lb/hr b 93.3 lb/hr cSECTION 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 SO 2
-007 C Sulfuric Acid Plant --- 11.9 lb/hr a 10.1 lb/hr b 303.3 lb/hr c

-008 D Sulfuric Acid Plant --- 11.9 lb/hr a 10.1 lb/hr b 303.3 lb/hr c
-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% H 2 SO 4 values for A and B SAP at design capacity is 0.027 lb SAM/ton 100% H 2 SO 4 . The equivalent lb SAM/ton 100% H 2 SO 4 values for C and D SAP at design capacity is 0.093 lb SAM/ton 100% H 2 SO 4 . 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): SO 2 emissions in lb/hour are equivalent to 1.4 lb/ton of 100% sulfuric acid for A and B SAPs at design capacity. SO 2 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]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. SO 2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO 2 CEMS to be used to demonstrate continuous compliance with the SO 2 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 SO 2 . 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 SO 2 Emissions from Stationary Sources 7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure)
8 Determination of SAM and SO 2 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.]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 SO 2 CEMS are required to demonstrate compliance on a continuous basis, therefore, no initial or annual compliance test for SO 2 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 SO 2 continuous emissions monitoring systems for continuous compliance demonstrations.} [Rules 62-296.402(5) and 62-213.440(1)(b)2., F.A.C.]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 SO 2 emissions rates from the four SAPs. A and B SAPs shall comply with the new BART exemption limit for SO 2 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% H 2 SO 4 -003 B SAP 1,600 TPD of 100% H 2 SO 4 -007 C SAP 2,900 TPD of 100% H 2 SO 4 -008 D SAP 2,900 TPD of 100% H 2 SO 4 -010 A DAP/MAP Plant 29.53 TPH of P 2 O 5 input for DAP; 33.30 TPH of P 2 O 5 input for MAP -011 Z DAP/MAP Plant 48.7 TPH of P 2 O 5 input for DAP; 55.0 TPH of P 2 O 5 input for MAP -012 X DAP/MAP Plant 48.7 TPH of P 2 O 5 input for DAP; 55.0 TPH of P 2 O 5 input for MAPSECTION 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 P 2 O 5 input for DAP; 55.0 TPH of P 2 O 5 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 SO 2 Controls : This BART exemption determination does require new, modified or additional air pollution control systems for SO 2 . To control emissions of SO 2 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 SO 2 emissions from A and B SAPs. To control emissions of SO 2 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 H 2 SO 4 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.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 SO 2 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. SO 2 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/PM 10 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 SO 2 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 SO 2
-002 A Sulfuric Acid Plant --- 6.5 lb/hr a 1.43 lb/hr b 81.3 lb/hr c

-003 B Sulfuric Acid Plant --- 8.0 lb/hr a 1.8 lb/hr b 100.0 lb/hr c

-007 C Sulfuric Acid Plant --- 13.3 lb/hr a 11.2 lb/hr b 241.7 lb/hr c

-008 D Sulfuric Acid Plant --- 13.3 lb/hr a 11.2 lb/hr b 241.7 lb/hr c
-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”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 SO 2 -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% H 2 SO 4 values for A and B SAP at design capacity is 0.027 lb SAM/ton 100% H 2 SO 4 . The equivalent lb SAM/ton 100% H 2 SO 4 values for C and D SAP at design capacity is 0.093 lb SAM/ton 100% H 2 SO 4 . 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): SO 2 emissions in lb/hour are equivalent to 1.5 lb/ton of 100% sulfuric acid for A and B SAPs at design capacity. SO 2 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. SO 2 Continuous Emissions Monitoring System (CEMS): This BART exemption determination requires an SO 2 CEMS to be used to demonstrate continuous compliance with the SO 2 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 SO 2 . 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.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 SO 2 Emissions from Stationary Sources 7E Determination of NOx Emissions from Stationary Sources (Instrumental Analyzer Procedure)
8 Determination of SAM and SO 2 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 SO 2 CEMS are required to demonstrate compliance on a continuous basis, therefore, no initial or annual compliance test for SO 2 is necessary on the SAPs.}

RECORDS AND REPORTSSECTION 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 SO 2 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.]

# Reasonable Progress
Determinations and Permits

A. Florida Crushed StonePERMITTEE

F lorida Power Development (FPD)
, LLC 700 Louisianan, Suite 1000 Houston, Texas 34601 Authorized Representative: Mr. Daniel A. Hopkins DEP File s No. 0530 380

- 0 01

- AC PSD

- FL -90E Expires: December 31, 2014 Brooksville Power Plant Woody Biomass Conversion Project Hernando County
PROJECT Florida Power Development, LLC, an affiliate of Arroyo Energy and J.P. Morgan Chase, proposes to convert the existing Brooksville Power Plant , aka Central Power and Lime (CP&L) , from an approximate 150 megawatts, g ross (MWg) coal

- fueled steam

- electric generating power plant to a 70 to 80 MWg woody biomass-fueled power plant. T he Brooksville Power Plant is co

- located with a CEMEX Portland cement plant. The Brooksville Power Plant is categorized as an electrical ser vices facility with aStandard Industrial Classification (SIC) No. of 4911. The Brooksville Power Plant is located in unincorporated Hernando County at 10311 Cement Plant Road approximately 2.5 mile northwest of Brooksville, Florida. The Brooksville Powe r Plant and the CEMEX Portland cement plant have a common Facility identification number of 0530021. After this permitting action, the Brooksville Power Plant will have a new Facility ID No. of 0530380. The UTM coordinates of the Brooksville Power Plant are Zone 17 ; 380.03 kilometers (km) East and 3,162.56 km North. This final permit is organized into the following sections: Section 1 (General Information); Section 2 (Administrative Requirements); Section 3 (Emissions Unit Specific Conditions); and, Se ction 4 (Appendices). Because of the technical nature of the project, the permit contains numerous acronyms and abbreviations, which are defined in Appendix CF of Section 4 of this permit. As noted in the Final Determination provided with this final perm it no changes were made to the draft permit.

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 Florid a Administrative Code (F.A.C.). The permittee is authorized to conduct the proposed work in accordance with the conditions of this permit. This project is subject to the general preconstruction review requirements in Rule 62-212.300, F.A.C. Upon issuance of this final permit, any party to this order has the right to seek judicial review of it under Section 120.68 of the F.S. by filing a notice of appeal under Rule 9.110 of the Florida Rules of Appellate Procedure with the clerk of the Department of Envir onmental Protection (Department) in the Office of General Counsel (Mail Station #35, 3900 Commonwealth Boulevard, Tallahassee, Florida, 32399-3000) and by filing a copy of the notice of appeal accompanied by the applicable filing fees with the appropriate District Court of Appeal. The notice must be filed within 30 days after this order is filed with the clerk of the Department.
Executed in Tallahassee, Florida Electronic SignatureCERTIFICATE OF SERVICE

The undersigned duly designated deputy agency clerk hereby certifies that this Final Air Permit package (including the Final Determination and Final Permit with Appendices) was sent by electronic mail, or a link to these documents made available electronically on a publicly accessible server, with received receipt requested before the close of business on the date indicated below to the following persons.

Daniel A. Hopkins, Authorized Representative, FPD: tony.d.hopkins@jpmorgan.com James Daniel, Plant Manager, CEMEX: jdaniel@cemexusa.com Gary Perko, Esq., HG&S: Scott Osbourn, P.E., Golder: gperko@hgslaw.com

Cindy Mulkey, DEP Siting Office: sosbourn@golder.co m cindy.mulkey@dep.state.fl.us Cindy Zhang- Torres, DEP SWD: cindy.zhang-torres@dep.state.fl.us Kathy Forney, EPA Region 4: Heather Ceron , EPA Region 4 : forney.kathleen@epa.gov ceron.heather@epa.gov Anne Harvey , Earthjustice: aharvey@earthjustice.org Barbara Friday, DEP OPC: barbara.friday@dep.state.fl.us Lynn Scearce, DEP OPC: lynn.scearce@dep.state.fl.us

Clerk Stamp

FIL ING AND ACKNOWLEDGMENT FILED

, on this date, pursuant to Section 120.52(7), Florida Statutes, with the designated agency clerk, receipt of which is hereby acknowledged. Electronic SignaturePROPOSED PROJECT The project involves the conversion of the exi sting 1 50 MW g Brooksville Power Plant that currently utilizes a pulverized coal

- fired boiler to a 70 to 80 MWg power plant utilizing clean woody biomass as fuel in a grate -suspension boiler. Consequently, the project will require internal structural modif ications to the pulverized coal boiler to convert it to a biomass

- fired grate -suspension boiler . The electrical generating unit building will also be modified. The existing steam turbine electric generator will be retained to generate electrical power. The project will include new fuel storage and handling systems and the construction of a new multi-pollutant control system. Emission from the multi -pollutant control system will be emitted to the atmosphere through a new exhaust stack separate from the o ne currently shared with the CEMEX cement plant . The existing emergency generator and emergency ditch pump engine will be retained . The fuel feedstock for the project will consist of clean woody biomass and will be delivered by truck to the project site. Ultralow sulfur distillate fuel oil and natural gas will be used for grate -suspension boiler startup, shutdown and bed stabilization. Ultralow sulfur distillate fuel oil fuel oil will also b e used in the emergency equipment. Following conversion, the p ower plant will no longer be permitted to fire coal. The project will incorporate the following pollution control equipment and measures:

**•** Efficient combustion in the grate -suspension boiler and emergency equipment to minimize formation of particulate matte r (PM), PM with a mean diameter of 10 microns or less ( PM 10 ), PM with a mean diameter of 2.5 microns or less ( PM 2.5 ), nitrogen oxides (NO X ), carbon monoxide (CO) and volatile organic compounds (VOC);

**•** Limitation of fuel to clean woody biomass to minimize su lfur dioxide (SO 2 ) and hazardous air pollutant (HAP) formation, including hydrogen chloride (HCl) and hydrogen fluoride (HF) ;

**•** Use of inherently clean fossil fuel s for startup , shutdown and bed stabilization of the grate -suspension boiler and the operation of emergency equipment ;

**•** An oxidation catalyst to reduce CO, VOC and organic HAP ;

**•** Ammonia (NH 3 ) injection into a selective catalytic reduction (SCR) reactor to destroy NO X and help in the reduction of organic HAP and dioxin/furan (D/F);

**•** An in -duct sorbent i njection system (IDSIS) utilizing milled trona, lime or sodium bicarbonate to control SO 2 , H Cl , HF and other acid gas HAP ;

**•** An electrostatic precipitator (ESP) to further control PM/PM 10 /PM 2.5 , including metal HAP, and to

remove injected sorbents; and,

**•** Reas onable precautions and best management practices to minimize emissions from biomass handling, storage and processing, ash (bottom and fly) handling, storage and shipment and sorbent handling and storage

. The project will incorporate the following emission measurement systems:

**•** Continuous emission monitoring systems (CEMS) for CO , SO 2 and NO X ; and,

**•** A continuous opacity monitoring system (COMS) for opacity (visible emissions, VE ). The existing facility consists of the CEMEX cement plant with two kilns and the coal

- fired power p lant

. The power p lant is addressed by this permitting action. Cement kiln No. 1 and the power p lant currently share a common baghouse to control PM emissions along with a stack . The baghouse and stack are identified as Emission Unit ( EU) 020 at the existing facility . As shown in the table below, t his project involves the following EU at the existing facility (Facility ID 0530021). As a result of this project the new EU numbers identified in the table will be used at the power plant w ith a new f acility ID of 0530380.One totally new EU results from this project, EU 001 which involves the receiving, handling and storage of the biomass fuel for the converted grate

- suspension boiler

. As seen from the table, new EUs were defined for the ash (fly and bottom) handling storage and shipment systems , IDSIS sorbent handling and storage systems and the emergency equipment.
Facility 05300380 EU ID No. Emissions Unit Description Facility 05300021 EU ID No.
001 Biomass Handling, Storage and Proces sing (New EU)

---

002 Woody Biomass-Fueled Grate -Suspension Boiler (Formerly Coal -Fired Boiler) 018

003 Ash and Handling, Storage and Shipment

---

Consists of old EU s: Contaminated Fly Ash & Filter Dust Bin 036
Filter Dust Bin 001
004 IDSIS Sorbent H andling and Storage

--- Limestone Fines Storage 038

Lime Dust Storage Bin 039
005 Emergency Equipment 500 kilowatt (kW) Emergency Generator No EU # 250 kW Emergency Ditch Pump No EU #
Facility Regulatory Classification

**•** The existing facility is a major source of hazardous HAP . The new converted facility will also be a major source of HAP.

**•** The existing facility operate s units that are not subject to the acid rain provisions of the Clean Air Act (CAA). The new converted facility will also not oper ate units that are subject to the acid rain provisions of the CAA

.

**•** The existing facility is a Title V major source of air pollution in accordance with Chapter 62-213, F.A.C. The new converted facility will also be a Title V major source of air pollution i n accordance with Chapter 62-213, F.A.C.

**•** The existing facility is a major stationary source in accordance with Rule 62 -212.400 for the Prevention of Significant Deterioration (PSD) of air quality , F.A.C. The new converted facility will also be a major sta tionary source in accordance with Rule 62-212.400(PSD), F.A.C.

**•** The existing facility is subject to the provisions of the Clean Air Interstate Rule (CAIR), including applicable portions of Chapters 62 -204, 62-210 and 62-296, F.A.C.

**•** The new facility is subje ct to the provisions of the Cross State Air Pollution Rule ( CSAPR) as specified in 40 Code of Federal Regulations ( CFR ) Parts 51, 52, 72, 78, and 97.

**•** The existing facility along with the converted facility are subject to Chapter 62 -204-800, F.A.C for New S ource Performance Standards (NSPS) under Section 111 of the Clean Air Act (CAA) and National Emissions Standards for Hazardous Air Pollutants (NESHAP) under Section 112 of the CAA.1. Permitting Authority

2. : The Permitting Authority for this project is the O ffice of Permitting and Compliance (OPC) in the Division of Air Resource Management of the Department of Environmental Protection (Department) . The mailing address for the OPC is 2600 Blair Stone Road, MS #5505, Tallahassee, Florida 32399-2400. All docu ments related to applications for permits shall be submitted to the OPC and the Air Resource Section of the Department’s Southwest District Office at: 13051 North Telecom Parkway, Temple Terrace, Florida 33637-0926 (Ph: 813-632-7600). Compliance Authority

3. : All documents related to compliance activities such as reports, tests, and notifications shall be submitted to the Air Resource Section of the Department’s Southwest District Office at: 13051 North Telecom Parkway

, Temple Terrace , Florida 33637-0926 (Ph: 813-632-7600). Appendices

a. Appendix ASME: American Society of Mechanical Engineers (ASME) Form for Abbreviated Effici ency Test; : The following Appendices are attached as a part of this permit and the permittee must comply with the requirement of the appendices :

b. Appendix BMP : Best Management P ractices Plan ;

c. Appendix CC: Common Conditions; d. Appendix CEMS: Continuous Emissions Monitoring System (CEMS) Requirements;

e. Appendix CF: Citation Formats and Glossary of Common Terms; f. Appendix CSAPR: Federal Implemen tation Plans: Interstate Transport of Fine Particulate Matter and Ozone and Correction of SIP Approvals;

g. App endix CTR: Common Testing Requirements; h. Appendix Db: NSPS, 40 CFR 60, Subpart Db – Standards of Performance Small Industrial

Commercial

- Institutional Steam Generating Units; i. Appendix DDDDD : NESHAP, Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters and Commercial and Industrial Solid Waste In cineration ; j. Appendix F: 40 CFR 75, Appendix F, Section 5 - Measurement of Boiler Heat Input Rate ; k. Appendix GC: General Conditions; and l. Appendix GP: Identification of General Provisions - NSPS 40 CFR 60, Subpart A and NESHAP 40 CFR 63, Subpart A.
4. Applicable Regulations, Forms and Application Procedures

5. : 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 all applicable provisions of: Chapter 403, F.S.; and Chapters 62-4, 62-204, 62-210, 62-212, 62-213, 62-296 and 62-297, F.A.C. Issuance of this permit does not relieve the permittee from compliance with any applicable federal, state, or loc al permitting or regulations.

New or Additional Conditions

6. : For good cause shown and after notice and an administrative hearing, if requested, the Department may require the permittee to conform to new or additional conditions. The Department shall allow the permittee a reasonable time to conform to the new or additional conditions, and on application of the permittee, the Department may grant additional time. [Rule 62- 4.080, F.A.C.]

Modifications : No emissions unit shall be constructed or modified without obtaining an 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.]7. Source Obligation (a) 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. :

(b) A t 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. [Rul e 62 -212.400(12), F.A.C.]

8. Objectionable Odors Prohibited

{Note: An objectionable odor is defined in Rule 62-210.200(Definitions), F.A.C., as any odor present in the outdoor atmosphere which by itself or in combination with other odors, is or may be harmful or injurious to human health or welfare, which unreasonably interferes with the comfortabl e use and enjoyment of life or property, or which creates a nuisance.} : No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute to an objectionable odor. [Rule 62-296.320(2), F.A.C.]

9. Unconfined Emissions of Particulate Matter

(a) Paving and maintenance of roads, parking areas and yards; : No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from any activity, including vehicular mo vement; transportation of materials; construction, alteration, demolition or wrecking; or industrially related activities such as loading, unloading, storing or handling; without taking reasonable precautions to prevent such emissions. Any permit issued t o a facility with emissions of unconfined particulate matter shall specify the reasonable precautions to be taken by that facility to control the emissions of unconfined particulate matter. Appendix BMP of this permit provides a Best M anagement Plan (BMP) of reasonable precautions specific to the Brooksville Power Plant facility to control fugitive PM emissions

. General r easonable precautions include the following:

(b) Application of water or chemica ls to control emissions from such activities as demolition of buildings, grading roads, c onstruction, and land clearing; (c) Application of asphalt, water, oil, chemicals or other dust suppressants to unpaved roads, yards, open stoc k piles and similar activiti es; (d) Removal of particulate matter from roads and other paved areas under the control of the owner or operator of the facility to prevent re-entrainment, and from buildings or work areas to prevent part iculate from becoming airborne; (e) Landsca ping or planting of vegetation; (f) Use of hoods, fans, filters, and similar equipment to contain, capture and/or vent particulate matter; (g) Confining abrasive blasting where possible; and (h) Enclosure or covering of conveyor systems. In determining what constitutes reasonable
pr ecautions for a particular facility, the Department shall consider the cost of the control technique or work practice, the environmental impacts of the technique or practice, and the degree of reduction of emissions expected from a particular technique or practice.[Rule 62 -296.320(4)(c), F.A.C.]

10. Previous Construction Permits PSD- FL -090, PSD

- FL -091 and Title V Permit No. 0530021-029- AV

a. Upon initiation of actual construction of the grate within the existing furnace, this permit prohibits the Brooksville Power Plant from firing coal and from sharing a fabric filter baghouse

an d an exhaust stack with Cement Line 1 of the CEMEX Brooksv ille South Cement Plant. : This project will convert the existing 150 MW coal

- fired electric utility steam generating unit utilizing a pulverized c oal boiler at the Brooksville Power Plant to a 70 to 80 MW biomass- fired
steam

- electrical generating unit utilizing a grate -suspension boiler. The enforceable requirements within this permit establish two separate facilities not under common control. Fur ther:

b. Upon initiation of actual construction of the grate within the existing furnace, t he conditions contained in the original air construction permits PSD- FL -090 (power plant) and PSD

- FL -091 (cement plant) issued by the EPA on March 24, 1984, related to the operation of a coal- fired power plant alone, or in combination with Cement Line 1, are obsolete. This includes any modified versions of those permits through the date of issuance of this permit for the biomass conversion project.

c. Upon initiation of actual construction of the grate within the existing furnace, the conditions contained in the current Title V permit No. 0530021-029- AV , related to the operation of a coalfired power plant alone, or in combination with Cement Line 1, are obsolete. { Permitting Note: As a separate action, once construction on the biomass conversion project has commenced, the Department intends to issue a separate construction permit for the Brooksville South Cement Plant to remove all references to th e coal -fired power plant operating individually or in combination with the cement plant. Thereafter, the current Title V permit No. 0530021- 029

- AV will be revised accordingly. } [Rules 62-4.070(3); 62-210.200(PTE); and 62-212.400 (PSD).) F.A.C.]
11. Title V Pe rmit for New Facility I.D. No. 0530380 : This permit authorizes specific modifications and/or new construction on the affected emissions units as well as initial operation to determine compliance with conditions of this permit. A Title V operation permit is required for regular operation of the permitted emissions unit. The permittee shall apply for a Title V 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 appro priate Permitting Authority with copies to the Compliance Authority. [Rules 62-4.030, 62-4.050, 62-4.220, and Chapter 62-213, F.A.C.]This section of the permit addresses the following new EU

. EU ID No. 001 EU Description
Biomass Handling, Storage and Processing

**•** : This EU will consist of three primary components: Biomass Receiving and Conveyance System

**•** : The biomass fuel (i.e., feedstock) will be delivered by truck to the project site generally on a 5 -7 days per week, 12-hours per day schedule. At t he project site, the fuel will be unloaded by trucks with a self -unloading, walking floor design, to three receiving hoppers and conveyed to a magnetic separator, sizing screen, and mill, for reduction of oversize biomass. Fuel trucks will have an average load of 25 tons of biomass. The fuel will then be conveyed, via an enclosed conveying system, to the biomass ( fuel ) storage pile. Biomass Storage Pile

**•** : The fuel storage pile will be designed to accommodate approximately 40,000 tons of biomass fuel at a nominal 60 foot height . The fuel pile will be managed using a combination of automated stackers and mobile equipment, such as front-end loaders.
Biomass Boiler Feed System

EQUIPMENT : From the fuel storage pile, the fuel will be unloaded by up to three reclaim ho ppers. All conveyors will be covered to reduce particulate emissions. The fuel will then be transferred, via enclosed conveyors, to a secondary screen and a secondary magnet and then to the day

bins within the boiler structure. All conveyors will be cov ered to reduce PM emissions.

1. Equipment

a. A Biomass Receiving and Conveyance Syste m Consisting of: : The permittee is authorized to construct EU 001, which consists of a biomass receiving and conveyance, storage pile and boiler feed systems containing the following components classified as potential sour ces of PM/PM 10 /PM 2.5 emissions hence forth called PM :

**•** A truck unloading area consisting of t hree open hoppers each designed to receive 150 tons per hour ( TPH ) of biomass fuel

.

**•** An u nloading conveyor to convey the woody biomass fuel from the unloading area to a covered conveyor system . T he unloading conveyor system shall be open to allow inspection of the woody biomass fuel to ensure the fuel meets the specifications stipulated in this permit. The un loading conveyor system shall have a designed capacity of 450 TPH

.

**•** A c overed conveyor to convey the biomass fuel to the storage pile . Th is conveyor system shall be enclosed and fugitive emissions controlled by fabric or bin vent filters where technically feasible. The design capacity of the covered conveyor system is 450 TPH.

b. Biomass Storage Pile Consisting of: An open storage pile with a design capacity of 40,000 tons of biomass fuel and be approximately 60 feet in height . The biomass storage pile will be managed by a combination of automated stackers and front- end loaders.

c. Biomass Boiler Feed System Consisting of:

**•** Two reclaim hoppers each designed to process 100 TPH of biomass fuel.

**•** A conveyor system to convey the woody biomass fuel to the sizing screen. This conveyor system shall be enclosed and fugitive emissions controlled by fabric or bin vent filters where technically feasible. The conveyer system has a design capacity of 200 TPH.

**•** A sizing screen, magnetic separator and hog mill designed to process 200 TPH of biomass fuel. The sizing screen, magnetic separator and hog mill shall be contained in an enclosure with the associated PM emissions controlled by a baghouse

**•** A conveyor system to convey the biomass fuel from the sizing screen , magnetic separator and hog mill to the grate -suspension boiler day bins. The conveyor system shall be enclosed andfugitive emissions controlled by fabric or bin vent filters where technically feasible. The conveyer system has a design capacity of 200 TPH.

**•** Boile r day bins to provide biomass fuel to the grate -suspension boiler at a design rate of 200 TPH. [Application No. 0530380-001-AC; and Rules 62- 4.070(3) and 62

- 210.200(PTE), F.A.C.]

2. Baghouse

[Application No. 0530380-001-AC; and Rules 62- 4.070(3) and 62

- 210.200(PTE), F.A.C.] : Based on the preliminary design, the permittee shall install a bag house to control PM emission s from the sizing screen, magnetic separator and hog mill enclosure. The baghouse shall be designed and maintained to achieve an outlet dust loading rate of 0.020 grains per dry standard cubic feet (gr/dscf) in its exhaust. Based on the final engineering design needs, additional baghouses may be installed as necessary to control fugitive dust from biomass handling, storage and processing EU

. The Compliance Authority shall be notified 180 days before Brooksville Power Plant bec omes operational of any final engineering design changes. Should the preliminary design change, the permittee shall provide final design details for all baghouses in the application for a Title V air operation permit along with a concurrent modification o f this air construction permit.

3. BMP Plan

{Permittin g Note: As part of that final BMP, technical information may be provided by Brooksville Power Plant to the Compliance Authority based on the final engineering of the biomass fuel conveyance system s that describes methods or equipment designed to control f ugitive PM emissions from the conveyor tra nsfer drop points. These methodologies and equipment designs may obviate the requirement to install dust collectors on the conveyor transfer drop points. Acceptance of the final BMP by the Compliance Authority wi th the reference to the specific design of the conveyor transfer drop points may satisfy the require ment to install dust collectors. PM emissions from this EU during operation of the Brooksville Power Plant facility are estimated to be approximately 4.6 t ons in any consecutive twelve month period; of this amount approximately 0.9 tons are PM 10 .} : A BMP plan shall be utilized to minimize fugitive PM emissions from biomass handling, storage and processing of woody biomass. B est management practices shall be utilized to reduce the potential for spontaneous combustion of stored woody biomass and odors . A preliminary BMP plan is contained in Appendix BMP of this permit. This plan also includes quality assurance and quality

con trol (Q A/QC ) procedures to ensure woody biomass delivered by vendors and suppliers to the Brooksville Power Plant facility meet the requirements given in the BMP plan

. No later than 180 days before the Brooksville Power Plant becomes operational, a final BMP plan shall be filed with the Compliance Authority to reflect the final engineering designs of the biomass receiving, handling, storage and processing systems . The final BMP plan will also be incorporated into the Title V operating permit.

[Application No. 0530380-001- AC; Rule 62 -4.070, F.A.C. Reasonable Assurance, and Rule 62-296.320, F.A.C.]

PERFORMANCE RESTRICTIONS

4. Hours of Operation

5. : The hour s of operation of this unit are not limited (i.e., unrestricted at 8,760 hours per year). [Application No. 0530380-001-AC; and Rules 62- 4.070(3) and 62

- 210.200(PTE), F.A.C.] Clean Woody Biomass : The fuel to be received, handled, stored and processed sha ll consist of woody biomass as defined in the Appendix BMP of this permit

. Municipal Solid Waste (MSW)

, other than pre- processed yard waste, is prohibited from use at this facility. Inspection and testing procedures described in Appendix BMP shall be followed to ensure that appropriate woody biomass is used as fuel and that prohibited MSW is not used as fuel. [Application No. 0530380-001- AC and Rules 62-4.070(3) F.A.C., and 40 CFR 60.51b.]6. Woody Biomass Storage Area : The woody biomass storage area s hall be designed for approximately 40,000 tons of woody bioma ss at a height of approximately 60 feet . Biomass placed in the pile will be largely managed by mechanical means . The storage pile shall be on level, impervious ground and contoured to minimize wind erosion. The biomass in the pile shall be managed on a first

- in

- first -out (FIFO) basis. The biomass will then be taken by covered conveyors to the boiler day bins and from there to the grate

- suspension boiler

. Wet suppression shall only be used as necessary to control fugitive dust emissions otherwise it shall be maintained dry for use as a fuel

. [Application No. 0530380-001- AC ]

7. Paved Roadways and Gravel Areas : Fugitive dust emissions from the plant ’s paved roadways and gravel areas shall be cont rolled in accordance with Condition 10 of Section 2 of this permit and the BMP plan . [ Rule 62 -4.070, F.A.C. Reasonable Assurance, and Rule 62- 296.320, F.A.C. ]
EMISSIONS STANDARDS

8. General Opacity : As determined by EPA Method 9, there shall be no visible e missions greater than 10 % opacity , except for one 6 minute period no greater than 20% from the outlets of the drop points, transfer point s , vent screen s and dust collectors associated with this EU

. [Application No. 0530380-001- AC and Rule 62-4.070, F.A.C . Reasonable Assurance ].

9. Opacity from Baghouses : Opacity from the baghouses of this EU shall not exceed 5% opacity based on EPA Method 9. [ Rule 62 -4.070(3) F.A.C., Reasonable Assurance]

TESTING AND MONITORING REQUIREMENTS

10. Initial VE Compliance Tests : Th e outlets of the drop points , transfer points, the silo vent screens associated with the fuel bins and the baghouses of this emissions unit shall be tested to demonstrate initial compliance with the emissions standards for opacity . The initial tests shall be conducted within 60 days after achieving permitted capacity, but not later than 180 days after initial operation of the EU . [Rules 62-4.070(3) and 62-297.310(7)(a)1, F.A.C.]

11. Annual VE Compliance Tests : During each federal fiscal year (October 1 st to September 30 th ), the outlets of the drop points, transfer points, the silo vent screens associated with the fuel bins and the baghouses of this emissions unit shall be tested to demonstrate compliance with the emissions standards for opacity . [Rule 62-297.310(7)(a)4, F.A.C.]

12. Test Requirements : The permittee shall notify the Compliance Authority in writing at least 15 days prior to any required tests. Tests shall be conducted in accordance with the applicable requirements specified in Appendix CTR (Common Testing Requirements) of this permit. [Rule 62 -297.310(7)(a)9, F.A.C.]

13. Test Methods : Required tests shall be performed in accordance with the following reference method

. Method Description of Method and Comments
9 Visual Determination of the Opacity o f Emissions from Stationary Sources

The above method is described in Appendix A of 40 CFR 60 which is included as Appendix GP of this permit and as adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. [Rules 62- 204.800 and 62 -297.100, F.A.C.; and Appendix A of 40 CFR 60]

RECORDS AND REPORTS

14. Test Reports : The permittee shall prepare and submit reports for all required tests in accordance with the requirements specifie d in Appendix CTR (Common Testing Requirements) of this permit. For each test run, the report shall also indicate the overall biomass feed rate to the boiler during the period of testing . [Rule 62-297.310(8), F.A.C.]This section of the permit addresse s the following emission unit.

EU ID No. 002 EU Description
Description : existing boiler will be converted to a woody biomass fueled grate

- suspension boiler with
water -cooled movable grates. The heat from the exhaust will be recovered to generate superheated steam to generate 70 to 80 MW g of electricity in a n existing steam electric generator

. Fuels : The primary fuel will be c lean w oody b iomass

. Ultra low Sulfur distillate fuel oil and natural gas will be use d for startup , shutdown and bed stabilizatio n of the grate -suspension boiler. Capacity : The maximum heat input capacity is 900 million British thermal units per hour ( MM Btu/hr) on a 4-hour average basis . The steam production capability will be approximately 490,000 pounds per hour ( lb/ hour) at 1,887 pounds per square inch ( psi ) and 9 50 degrees Fahrenheit (°F). Controls : Efficient combustion of woody biomass in the grate -suspension boiler to minimize formation of PM , NO X , CO and VOC; limitation of biomass to woody biomass to minimize SO 2 and HA P formation; use of an inherently clean fuels for startup , shutdown and bed stabilization ; a oxidation catalyst to further control CO, VOC, and HAP ; NH 3 injection into SCR reactor to destroy NO X and help in the reduction of VOC , HAP and D/F; an I DSIS to fu rther control SO 2 and acid gas HAP, including HCl and HF ; and, an ESP with a design efficiency of 99.9% to further control PM and VE, (i.e. opacity) and remove injected sorbents

. Stack Parameters : The stack will be approximately 12.0 feet in diameter (max imum) and 165 feet tall (minimum). Exhaust flue gas will exit the stack at the following approximate conditions: an exit temperature of 3 34 °F and a volumetric flow rate of 312 ,668 actual cubic feet per minute (acfm).
CEMS and COMS : E missions of CO , SO 2 and NO X will be monitor ed and record ed by CEMS. Opacity will be monitored and recorded by a COMS. Applicability of NSPS 40 CFR Subpart Db : This unit is subject to NSPS Subpart Db – for IndustrialCommercial

- Institutional Steam Generating Units because it has a maximum heat in put capacity greater than 100 MMBtu/hr from all combusted fuels and is not subject to NSPS Subpart Da because it has a maximum heat input capacity of less than or equal to 250 MM Btu/hr from the combustion of fossil fuels. Applicability of NESHAP 40 CFR 63 Subpart DDDDD : This unit is subject to NESHAP Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters and Commercial and Indus trial Solid Waste Incineration . Subpart DDDDD has been delayed by EPA until the proceedings for judicial review of the rules are completed or the EPA completes its reconsideration of the rule . If and when Subpart DDDDD comes into force

, the biomass boile r at the Brooksville Power Plant must meet the applicable requirements for existing units

.
PROJECT RESTRICTIONS

1. Biomass Conversion Project : The purpose of this project is to convert the existing 150 MW coal

fired electric utility steam generating unit utilizing a pulverized boiler to a 70 to 80 MW biomass

fired steam generating unit utilizing a grate -suspension boiler. Upon initiation of actual construction of the grate within the existing furnace, this permit prohibits the Brooksville Power Plant from firing coal and from sharing a fabric filter baghouse and an exhaust stack with Cement Line 1 of the CEMEX Brooksville South Cement Plant. [Application No. 0530380-001-AC; Design; and Rules 62- 4.070(3) and 62 -212.400(12), F.A.C.] EQUIPMENT

2. Boiler Conversion : The permittee is authorized to convert the existing boiler to one grate

- suspension boiler with startup burners, overfire air ports, steam drum, superheater, economizer, air heater, ashhoppers, ducts, fuel feeding equipment, water -cooled condensing u nit , air pollution control equipment and other associated equipment . Existing equipment may be reused from the pulverized coal boiler during the conversion such as : the existing boiler furnace and convection pass, including primary and secondary superheat ers, re -heater, and economizer; the existing air heaters, dust collectors, and forcedand induced draft fans; the existing CEMS equipment; the balance of plant feed water heating, deaerator pumps, and condensate collection equipment; the existing main ste am -piping and reheat piping; the steam turbine electrical generator , etc. New construction may include , but is not limited
to : modification of the elec trical generating unit building; the removal of the lower boiler ash hopper and modification to allow installation of new water -cooled stoker grate s; an ash conveyor ; the removal of the existing pulverized coal burners and installation of new biomass fuel distributors; fuel metering bins; and a fuel conveyor . [Application No. 0530380-001- AC ]

3. Air Pollution C ontrol Equipment : To comply with the emission standards of this permit, the permittee shall install the following add-on air pollution control equipment comprising a multi

pollutant control system on the grate -suspension boiler.

a. ESP : The permittee shall design, install, operate and maintain an ESP to control PM and VE. The ESP shall be designed to achieve the PM emissions standards specified in this subsection

. [Application No. 0530380-001- AC and Rule 62-4.070(3), F.A.C.]

b. S CR System : The permittee sha ll design, install, operate, and maintain a n NH 3 - based S CR system including reagent storage tank, pumps, metering system, injection grid, reactor and catalyst to reduce NO X emissions in the flue gas exhaust and achieve the NO X emissions standards specified in this subsection . The S CR shall be brought on line and functioning properly whenever the boiler is in operation in accordance with the manufacturer’s procedures and guidelines. [Application No. 0530380-001- AC and Rule 62-4.070(3), F.A.C.]

c. IDSIS : An I DSIS shall be installed that consist s of the pumps, the metering and injection equipment required to inject the sorbent(lime, milled trona or sodium bicarbonate) into the grate

suspension boiler duct work to control SO 2 and HAP acid gas emissions

. The so rbent injection rate shall be adjusted as necessary (lb/hr) to control SO 2 emissions to the standa rd specified in this subsection. [Application No. 0530380-001- AC and Rule 62 -4.070(3), F.A.C.] d. Oxidation Catalyst : The permittee shall design, install, oper ate and maintain an oxidation catalyst to control CO and VOC emissions to the emission standards specified in this section. The oxidation catalyst will also help control organic HAP emissions. [Application No. 0530380-001- AC and Rule 62-4.070(3), F.A.C.]

e. Circumvention : The permittee shall not circumvent the air pollution control equipment or allow emissions in excess of the emission standards of this subsection without this equipment operating properly. [Rule 62 -210.650, F.A.C.]
4. Ultra Low Sulfur Distill ate Fuel Oil Storage Tank : The permittee is authorized to utilize an exi s ting 150,000 gallon tank to store ultra low sulfur distillate fuel oil for use as a grate -suspension boiler fuel for startup , shutdown and bed stabilization

. Pipeline natural gas may also be used in the grate

suspension boiler as a startup, shutdown and bed stabilization fuel

. [62

- 4.070(3), Reasonable Assurance] {Permitting Note: The ultra low sulfur distillate fuel oil storage tank at the Brooksville Power Plant facility is not s ubject to NSPS Subpart Kb because it is larger or equal to 40,000 gallons (151 cubic meters) and store liquids ( ultra low sulfur distillate fuel oil ) with a maximum true vapor pressure less than 3.5 kilo Pascals (0.51 psi)). Accordingly they are unregulat ed emissions unit s .} [40 CFR 60.110b(a) and (c); Rule 62-204.800(7)(b), F.A.C.]PERFORMANCE REQUIREM ENTS 5. Authorized Fuels : The grate

- suspension boiler is authorized to combust as its primary fuel clean woody biomass as defined in Appendix BMP of this permit . In addition, the grate

- suspension boiler is authorized to combust ultra low sulfur distillate fuel oil and pipeline natural gas for startup

, shutdown and bed stabilization. [Application No. 0530380-001- AC; Rules 62 -4.070(3), 62-296.410, 62-210.200(PTE), F.A.C., and NSPS, Subpart Db ]

6. Heat Input Rat e from all Fuels : The maximum heat input capacity from all fuel combinations to the grate -suspension boiler is 900 MM Btu /h r on a 4-hour average basis

. The permittee shall use the thermal efficiency method to calculate the boiler heat input rate, using the steam rate, steam pressure, and steam temperature measurements required per Specific Condition 19 of this subsection, and feedwater temperature and pressure, to determine net enthalpy. The design boil er efficiency shall be used provided the boiler efficiency test required in Specific Condition 20 of this subsection is at least 90% of the design boiler efficiency. The procedure given in Appendix ASME of this permit shall be used to measure the boiler ef ficiency. As an alternative, the procedures given in Appendix F of this permit may be used to calculate boiler heat input. [Application No. 0530380-001- AC; Rules 62

- 4.070(3) and 62-210.200(PTE), F.A.C.]

7. Heat Input from Fossil Fuels : The maximum heat inp ut capacity to combust ultra low sulfur distillate fuel oil and natural gas singly or in combination in the grate -suspension boiler , as determined by the physical design and characteristics of the boiler burners

, shall be less than 250 MM Btu/hr so as to be exempted from the requirements of NSPS, Subpart Da. [Application No. 0530380-001- AC; NSPS Subpart D a; Rules 62-4.070(3) and 62-210.200(PTE), F.A.C.]

8. Fossil Fuel Quantity Limit : Flow meters shall be installed to record the amount of ultra low sulfur distillate fuel oil (FO) in gallons (gal) and natural gas (NG) in standard cubic feet (scf) that is fired in the fossil fuel burners in the grate

- suspension boiler . The maximum amount of fossil fuels ( ultra low sulfur distillate fuel oil and natural gas) that shall be fired in the boiler in any 12 -month consecutive period is limited by the equation given below.

[Application No. 0530380-001- AC; Rules 62 -4.070(3) and 62-210.200(PTE), F.A.C.; 40 CFR 98]

9. Operational Hours : The hours of operation of this emission unit are not restricted (8 ,760 hours/year). [Application No. 0530380-001- AC; Rules 62 -4.070(3) and 62-210.200(PTE), F.A.C.]

NSPS APPLICABILITY

10. Subpart Db : The biomass boiler must meet all applicable requirements of NSPS 40 CFR 60, Subpart Db – Industrial- Commercial

- Institutional Steam Generating Units . Subpart Db is contained in Appendix Db of this permit. For the biomass boiler , NSPS Subpart Db contains limits for SO 2 , NO X , PM and opacity. [Application No. 0550063-001-AC and 40 CFR 60, NSPS Subpart Db]

NESHAP APPLICABILITY

11. Subpart DDDDD : The biomass boiler is subject N ESHAP 40 CFR 63, Subpart DDDDD – Industrial, Commercial, and Institutional Boilers and Process Heaters and Commercial and Industrial Solid Waste Incineration for major sources of HAP. Subpart DDDDD is contained in Appendix DDDDD of this permit. Currently Subpart DDDDD has been delayed by EPA until the proceedings for judicial review of the rules are completed or the EPA completes its reconsideration of the rule. If andwhen Subpart comes into force, the biomass boiler must meet all applicable requirements for existing units. Currently, Subpart DDDDD contains emission limits for PM, CO, HCl, mercury (Hg) and D/F that would apply to the grate

- suspension boiler at the Brooksville Power Plant . [Application No. 0530380-001-AC and NESHAP Subpart DDDDD ]
CROSS

- STATE AIR POLLUTION RULE (CSAPR)

12. CSAPR Applicability : The Brooksville Power Plant grate -suspension boiler falls under the requirements of CSAPR and must meet all its applicable requirements. [40 CFR Parts 51, 52, 72, 78, and 97 , CSAPR and Rule 62-4.070(3), F.A.C. ]
EMISSIONS STANDARDS

13. Emission Limits : Emissions from grate -suspension boiler shall not exceed the following standards.

Pollutant Stack Test CEMS/COMS Based Averages

NO X a Not applicable 135 lb/hour 12-month, rolled monthly 0.20 lb/MM Btu 30-day basis
SO 2 b Not applicable 135 lb/hour,12-month, rolled monthly
CO c Not applicable 40.5 lb/hr, 12- mo nth, rolled monthly
Opacity d Not applicable 10 percent ( %) opacity (6-minute blocks) 20% opacity (one 6- minute block per hour)

PM/PM 10 e 11.7 lb/hr Not applicable

VOC f 9.0 lb/hr Not applicable
SAM g 2.2 lb/hr Not applicable
NH 3 Slip h 10 ppmvd @ 7 % O 2 Not applicable

a. NO X limit in lb/ MM Btu on a 30

- day basis is pursuant to NSPS Subpart Db. Mass emission rate limit in pounds per hour is per applicant’s request

. Mass emission rate limit in tons per year (TPY) per applicant’s request and to avoid PSD

. b. Use of low sulfur fuels including wood, ultra low sulfur distillate fuel oil and pipeline natural gas ensure that uncontrolled SO 2 em issions are less than 0.32 lb/MM Btu . Therefore

, no specific limit from NSPS Subpart Db applies

. Mass emission rate li mit in TPY per applicant’s request and to avoid PSD

. Use of natural gas and ultra low sulfur distillate fuel oil meet s the SO 2 BACT requirements of Rule 62

- 296.406, F.A.C.

c. Mass rate CO emission limit per applicant’s request and insures annual emissions wi ll be less than the PSD threshold in TPY. d. Visible Emissions. Opacity of 10% provides reasonable assurance of continuous compliance with PM/PM 10 and is a reasonable expectation given catalyst

- based NO X , CO, VOC controls. During startups, shutdowns and malfunction the following limits apply: 20% opacity (6

- minute blocks) except for one 6

- minute block per hour of 27% opacity. Use Opacity limit ensures that the requirement of Rule 62

- 296.406, F.A.C is met

.
e. Compliance with the filterable (f) PM/PM 10 mass emi ssion limit approximately equals a concentration emission limit of 0.013 lb/MMBtu which insures compliance with the 40 CFR 60, Subpart Db limit of 0.030 lb PM/MM Btu (filterable PM only ). Use of natural gas and ultra low sulfur distillate fuel oil meet s th e PM BACT requirements of Rule 62

- 296.406, F.A.C. PM mass emission rate limit in pounds per hour per applicant’s request and to avoid PSD

. f. VOC mass emission rate limit in pounds per hour per applicant’s request and to avoid PSD

. Only initial stack test

r equired to verify emission rate.
g. SAM mass emission rate limit in pounds per hour per applicant’s request and to avoid PSD

. Only initial stack test required to verify emission rate. h. Ammonia (NH 3 ) slip in parts per million by dry volume at 7% oxygen (ppmvd @ 7% O 2 ) per applicant’s request

. [Application No. 0530380-001- AC ; Rul es 62 -210.200(PTE), 62-296.406, 62-296.410, and 62-4.070(3) (Reasonable Assurance)

, F.A.C. to avoid triggering PSD Requirements under Rule 62-212.400, F.A.C.; 40 CFR 60, Subpart Db]C ONTINUOUS EMISSION MONITORS

14. Continuous Monitoring Requirements : The permittee shall install, calibrate, maintain and operate CEMS and a diluent monitor to measure and record the emissions of SO 2 , NO X and CO from the b oiler stack in a manner sufficient to demonstrate continuous compliance with the CEMS- based emission standards in Condition 13 above (see Appendix CEMS for further information). The permittee shall install, calibrate, maintain and operate COMS to measure and record the opacity to demonstrate compliance with the COMS-based emission standard in Condition 13 above. Each CEMS and COMS shall be installed, calibrated and properly functioning within 60 calendar days of achieving permitted capacity as defined in Rule 62 -297.310(2), F.A.C., but no later than 180 calendar days after initial startup . Within one working day of discovering emissions in excess of the CEMS or COMS based SO 2 , NO X , CO and opacity standard, the permittee shall notify the Compliance Authority.

a. SO 2 CEMS : The SO 2 CEMS shall be c ertified, operated, and maintained in accordance with the requirements of 40 CFR 75. Record keeping and reporting shall be conducted pursuant to Subparts F and G in 40 CFR 75.

b. NO X CEMS : The NO X CEMS shall be certified, operated, and maintained in accordance with the requirements of 40 CFR Part 75. Recordkeeping and reporting shall be conducted pursuant to Subpart Db in 40 CFR 60 and Subparts F and G in 40 CFR 75.

c. CO CEMS : T he CO CEMS shall be certified pursuant to 40 CFR 60, Appendix B, Performance Sp ecification 4 or 4A . Quality assurance procedures shall conform to the requirements of 40 CFR 60, Appendix F, and the Data Assessment Report of Section 7 shall be made each calendar quarter, and reported semiannually to the Compliance Authority. The rela tive accuracy testing audits ( RATA ) tests required for the CO monitor shall be performed using EPA Method 10 in Appendix A of 40 CFR 60. The CO monitor span values shall be set, considering the allowable
met hods of operation and corresponding emission standards.

d. COMS : In accordance with 40 CFR 60 .48b(a) the permittee shall install, calibrate, operate and maintain a COM to continuously monitor and record opacity from the steam generating unit. The COMS shall be certified pursuant to 40 CFR 60 Appendix B, Performance Specification 1.

e. Diluent Monitor : The oxygen (O 2 ) or CO 2 content of the flue gas shall be monitored at the location where SO 2 , CO and NO X are monitored . Each monitor shall comply with the performance and quality assurance requirements of 40 CFR 75. [Application No. 0530380-001- AC; Rule 62 -4.070(3), F.A.C.; 40 CFR 60, Subpart Db and Appendices] STARTUP, SHUTDOWN, A ND MALFUNCTION REQUI REMENTS

15. Malfunction Notifications : In case of excess emissions resulting from malfunctions, each owner or ope rator shall notify the Compliance Authority . If the permittee is temporarily unable to comply with any of the conditions of the permit due to breakdown of equipment or destruction by hazard of fire, wind or by other cause, the permittee shall immediately (within one working day) notify the Compliance Authority. Notification shall include pertinent information as to the cause of the problem, and what steps are being taken to correct the problem and to prevent its recurrence, and where applicable, the owner’s intent toward reconstruction of destroyed facilities. Such notification does not release the permittee from any liability for failure to comply with Department rules. If requested by the Compliance Authority, the owner or operator shall submit a quart erly written report describing the malfunction. [Rules 62- 210.700(6) and 62 -4.130, F.A.C.]16. Operating Procedures : The emission standards established by this permit rely on “good combustion practices” to reduce emissions. Therefore, all operators and su pervisors shall be properly trained to operate and maintain the steam generating unit and pollution control systems in accordance with the guidelines and procedures established by each manufacturer. The training shall include good combustion practices as well as methods of minimizing excess emissions. [Rule 62 -4.070(3), F.A.C.]

17. 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.]

18. Emission Limit Compliance and Excess Emission : Because of the long- term nature of all of the SO 2 , NO X , and CO CEMS

- based mass emission rate limits, all emissio ns data for these pollutants

, including periods of startup, shutdown and malfunction, shall be included in any compliance determinations based on CEMS data. [Rules 62-210.700(4), 62-210.200(PTE) and 62-4.070(3), F.A.C.]

19. Excess Emissions Allowed – Opacity Requirements : As provided by the authority in Rule 62- 210.700(5), F.A.C., the following conditions supersede the provisions in Rule 62-210.700(1), F.A.C.

a. Opacity : During startup, shutdown and malfunctions , the stack opacity shall not exceed 20% based on 6- minute block average s, except for one 6-minute block per hour that shall not exceed 27% opacity. [Rule s 62-210.700(5), 62-210.200(PTE) and 62-4.070(3), F.A.C.] TESTING REQUIREMENTS

20. Boiler Performance Test : Within 180 days of first fire on biomass with u ltra low sulfur distillate fuel oil or natural gas used for flame stabilization

, the permittee shall conduct a test to determine the boiler thermal efficiency. The test shall be conducted in general accord with ASME PTC 4, 1998. See Appendix ASME of this permit . The abbreviated test procedure shall be agreed upon by all parties. The test shall be conducted for at least three hours when firing only the fuels types with heating values representative of the boiler design fuel as practical . The boiler stea m conditions and production rate shall be monitored and recorded during the test. The primary fuel firing rate (in tons per hour , gallons per hour or cubic feet per hour as appropriate) shall be calculated and recorded based on the steam parameters. S amp le s of the as

- fired biomass shall be analyzed for the heating value (Btu/lb) and moisture content (%). The actual heat input rate (MM Btu/ hr) shall be determined using the method given in Specific Condition 21 below . Results of the test shall be submitted to the Compliance Authority within 45 days of completion. The boiler thermal efficiency test shall be repeated during the 12-month period prior to renewal of any operation permit. If the tested boiler thermal efficiency is less than 90% of the design bo iler thermal efficiency, then the tested thermal efficiency shall be used in any future calculations of the heat input rate until a new test is conducted. [Rule 62 -4.070(3), F.A.C.]

21. Boiler Heat Input Rate Calculation : The permittee shall use one of the f ollowing methods to determine the heat input rate to the biomass boiler: (a) Design Thermal Efficiency

, the boilers’ design thermal efficiency along with steam production and steam characteristics can be used if actual tested thermal efficiency is within 90% o f the design value. (b) Actual Tested Thermal Efficiency , the actual tested thermal efficiency must be used if this level is less than 90% of the design value. The procedure given in Appendix ASME of this permit shall be used to measure the boiler efficiency (c) A lternative Method , in lieu of the procedures given in Appendix ASME, the procedures given in Appendix F of this permit may be used to calculate boiler heat input. If used, Section 5 ofAppendix F of 40 CFR 75 provides a methodology for calculation of th e heat input rate to a boiler using F-Factors. The applicable portions of 40 CFR 75 for the calculation of the heat input rate to the biomass boiler at the Florida Power Development facility is contained in Appendix F of this permit. This procedure may be used to calculate the heat input rate in MMBtu/hr to the biomass boiler

. [Rule 62 -4.070(3), F.A.C. Reasonable Assurance]

22. Initial and Annual Stack Tests : In accordance with test methods specified in this permit, the boiler stack shall be tested to demo nstrate initial compliance with the emission standards for NH 3 slip , PM, SAM and VOC

. The tests shall be conducted within 60 days after achieving the maximum heat input
rate to the boiler, but not later than 180 days after the initial startup of the boile r. Subsequent compliance stack tests for NH 3 slip and PM shall also be conducted during each federal fiscal year (October 1 st to September 30 th ). Tests shall be conducted between 90 and 100% of the maximum heat input rate when firing only the primary fue ls . CEMS data for SO 2 , CO and NO X along with COMS data for opacity shall be reported for each run of the required tests for VOC, SAM
, NH 3 slip and PM

. The Department may require the permittee to repeat some or all of these initial stack tests after major replacement or major repair of any air pollution control or process equipment. [Rules 62

- 212.400(5)(c) and 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] {Permitting Note: All initial tests must be conducted between 90% and 100% of permitted capacity of the boiler; otherwise this permit shall be modified to reflect the true maximum boiler capacity as constructed.}

23. Test Methods : Any required stack tests shall be performed in accordance with the following methods or updates thereof.

EPA Method Descript ion of Method and Comments

CTM -027 Measurement of NH 3 Slip

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content {Notes: Methods shall be performed as necessary to support other methods.} 5, 5B, 17 Measurem ent of PM 6C Measurement of SO 2 Emissions (Instrumental)
7E Measurement of NO X Emissions (Instrumental)

8 Determination of Sulfuric Acid and Sulfur Dioxide Emissions from Stationary Sources 9 Visual Determination of the Opacity

10 Measurement of CO Emissions (Instrumental) {Note: The method shall be based on a continuous sampling train.}

18 Measurement of Gaseous Organic Compound Emissions (Gas Chromatography) { For concurren t use with EPA Method 25A to deduct emissions of methane and ethane from the total hydrocarbon emissions measured by Method 25A.} 19 Calculation Method for NO X , PM, and SO 2 Emission Rates 25 Determination of Total Gaseous Nonmethane Organic Emissions as Carbon 25A Measurement of Gaseous Organic Concentrations (Flame Ionization) Method CTM-027 is published on EPA’s Technolog y Transfer Network Web Site at http://www.epa.gov/ttn/emc/ctm.html . The other methods are specified in Appendix A of 40 CFR 60, adopted by reference in Rule 62-204.800, F.A.C. [Rules 62-204.800, F.A.C. and 40 CFR 60, Appendix A]OTHER MONITORING REQUIREMENTS

24. Operating Parameters : In accordance with the manufacturer’s recommendations, the permittee shall install, calibrate, operate and maintain continuous monitoring and recording devices for the following pa rameters: steam temperature (°F), steam pressure (psig ), steam production rate (lb/hr) and heat rate (4 hour averages) . Records shall be maintained on site and made available upon request. [Rules 62- 4.070(3) and 62 -210.200(PTE), F.A.C.]

25. SCR Ammonia Injection : In accordance with the manufacturer’s specifications, the permittee shall install, calibrate, operate and maintain a flow meter to measure and record the ammonia injection rate for the S CR syste m for the steam generating unit. The permittee shall document the general range of NH 3 flow rates required to meet the NO X standard over the range of load conditions by comparing NO X emissions with ammonia flow rates. During NO X CEMS downtimes or malfunc tions, the permittee shall operate at a n NH 3 flow rate that is consistent with the documented flow rate for the given load condition. Records shall be maintained on site and made available upon request. [Rule 62 -4.070(3), F.A.C.]

RECORDS AND REPORTS

26. Sta ck Test Reports : In addition to the information required in Rule 62-297.310(8), F.A.C., each stack test report shall also include the following information: steam production rate (lb/hour), heat input rate (MM Btu/ hr ), calculated fuel firing rate (tons/ho ur, gallons per hour and millions of scf per hour as appropriate ) and emission rates ( NH 3 slip in ppmvd @ 7 % O 2 ; PM, VOC, SAM and in lb/h r). SO 2 , CO and NO X CEMS data along with COMS opacity data during stacking testing shall also be included the each sta ck test report. [Rule 62- 4.070(3), F.A.C.]

27. Monthly Operations Summary : By the tenth calendar day of each month, the permittee shall record the following for each fuel used in the biomass boiler in a written or electronic log for the previous month of ope ration: hours of operation ; tons of clean woody b iomass

, gallons of ultra low sulfur distillate fuel oil ; millions of scf of pipeline natural gas ; pounds of steam per month; total heat input
rate ; and the updated 12- month rolling totals for each of these operating parameters. In addition, the 4 hour average heat input rate to the biomass boiler shall be recorded and reported. The Monthly Operations Summary shall be maintained on site and made available for inspection when requested by the Department. [Rules 62-4.070(3) F.A.C. Reasonable Assurance]

28. Quarterly SO 2 , CO, NO X and Opacity Emissions Report : Within 30 days following the end of each quarter, the permittee shall submit a report to the Comp liance Authority summarizing SO 2 , CO, NO X and o pacity emis sions including periods of startups, shutdowns, malfunctions, and CEMS and COMS systems monitor availability for the previous quarter. If opacity COMS data is excluded from a compliance determination during the quarter due to a malfunction, the permittee shall include a description of the malfunction, the actual emissions recorded, and the actions taken to correct the malfunction in the quarterly report

. After the first full four quarters of operation, the permittee may request approval from the Complianc e Authority to submit these reports on a semiannual basis. See Appendix CTR of this permit for the reporting format. [Rules 62-4.070(3), 62- 4.130, and 62

- 210.400(5)(c), F.A.C.]This section of the permit addresses the following EU

. EU ID No. 003 EU Des cription
Ash Handling, Storage and Shipment :

**•** The combustion of biomass in the converted boiler will result in the formation of bottom and fly ash. Bottom ash will be collected from the boiler by a submerged drag

- chain conveyor, which will deliver the w et ash to a storage area. The storage area will be on a level and impervious surface surround on three sides by retaining walls. The bottom ash will be handled in the storage area using mechanical means such as front -end loaders. The bottom ash will be sent daily to the co

- located cement plant for use in its kilns or shipped off site for disposal.

**•** The fly ash is the entrained exhaust PM captured by the ESP. An enclosed conveyor will be used to transport the fly ash from the ESP to the ash storage bins

. The storage bins will be equipped with a bin vent filters to minimize any PM emissions from the transfer operation s. Ash from the storage bins will be loaded via truck s for shipment to the co

- located cement plant for use in its kilns or for removal of th e ash off

- site.

EQUIPMENT

1. Equipment : The permittee is authorized to construct EU 003 , which consists of ash (fly and bottom) handling, storage and shipment systems containing the following equipment:

a. Fly Ash Handling : The fly ash handling s ystem consisting of enclosed hoppers, drop p oints and conveyors associated with the collection and transfer of fly ash to two storage bins from the ESP used to control PM emissions from the biomass boiler

. b. Fly Ash Storage : A fly ash storage system consisting of two s torage bins with bin vent filters to control PM emissions

. The permittee may use the former contaminated fly ash and f ilter dust bin (EU 036) and the fly ash storage bin (EU 001) of the combined facility (cement and power plants)

.
c. Fly Ash Shipment : The fly ash shipment system consisting of the d rop p oints and c hutes associated with the transfer of the fly ash from the storage bins to trucks for shipment to the cement plant or off- site for disposal

. d. Bottom Ash Handling and Shipment : T he bottom ash handl ing and shipment system consisting of the hoppers, drop points, and submerged drag- chain conveyor associated with the collection and transfer of bottom ash from the biomass boiler to the walled, flat, impervious storage area

. From the storage area, the bo ttom ash will either be sent to the cement plant or be designated for removal off- site

. [Application No. 0530380-001- AC]

2. Air Pollution Control Equipment : To comply with the emission standards of this subsection , the permittee shall install and operate the following air pollution control equipment on the ash (fly and bottom) handling, storage and shipment EU

.
a. Enclosures and Dust Collectors : To minimize fugitive PM, bottom and fly ash conveyors shall be covered

. Where practical, d ust collectors shall be installed on the bottom ash and fly ash transfer points, drop points , hoppers and chutes. [Application No. 0530380-001- AC and Rule 62-4.070, F.A.C. Reasonable Assurance].

b. Fly Ash Storage Bins : Bin vent filters shall be installed and maintained to remove PM from the fly ash storage bins exhaust. The filters shall be installed and operational before the bins are operated. [ Applica tion No. 0530380-001- AC; Rule s 62 -4.070(3) and 62 -210.200(PTE), F.A.C.]c. Bottom Ash Storage Area : The procedures described i n the BMP plan provided in Appendix BMP of this permit regarding the bottom ash storage area shall be followed to minimize fugitive dust emission s and odors from the bottom ash storage area.
d. Dust collectors, bin vent filters and baghouses shall be designed to achieve a PM emission rate of 0.020 gr/dscf or less

. [Application No. 0530380-001- AC; Rules 62 -4.070(3) and 62-210.200(PTE), F.A.C.]

PERFORMANCE RESTRICTION
3. Hours of Operation : The hours of operation of this emission unit are not limited (i.e., unre stricted at 8,760 hours per year). [Application No. 0530380-001- AC; Rules 62 -4.070(3) and 62-210.200(PTE), F.A.C.]

EMISSIONS STANDARDS
4. VE Standard : As determined by EPA Method 9, there shall be no visible emissions greater than 10 % opacity , except for o ne, 6- minute period no greater than 20% from the bottom and fly ash conveyor s, transfer points, drop points , hoppers, chutes and dust collectors

. As determined by EPA Method 9, there shall be no visible emissions greater than 5 % opacity from the ash storage bin vent filters

. [ Rule 62 -4.070, F.A.C. Reasonable Assurance and Rule 62 -212.400(5)(c), F.A.C.]

5. Best Management Practices to Control Unconfined Emissions of PM : To ensure the emission standards with regard to opacity and PM of this subsection are co mplied with, the procedures set forth in Condition 10 of Section 2 of this permit , “ Unconfined Emissions of Particulate Matter ,” shall be adhered to where practical and cost effective . In addition, the procedures set forth in Appendix BMP of this permit w ith regard to fugitive emissions shall be adhered to. [Application No. 0530380-001- AC ; Rule 62-4.070, F.A.C. Reasonable Assurance , and Rule 62-296.320 F.A.C.] TESTING AND MONITORING REQUIREMENTS

6. Initial Compliance Tests : The bottom and fly ash conveyor s, transfer points, drop points , hoppers, chutes, dust collectors and fly ash storage bins vent filters associated with this EU shall be tested to demonstrate initial compliance with the VE standards specified in Condition 4 of this subsection

. The initia l test s shall be conducted within 180 days after initial operation. [Rule 62 -297.310(7)(a)1., F.A.C. and Rule 62-4.070(3), F.A.C.]

7. Annual Compliance Tests : During each federal fiscal year (October 1 st to September 30 th ), the bottom and fly ash conveyors, transfer points, drop points, hoppers, chutes and dust collectors and ash storage bins vent filters associated with this EU shall be tested to demonstrate compliance with the VE emissions standards specified in Condition 4 of this subsection

. [Rule 62 -297.310(7)(a)4, F.A.C. and Rule 62-4.070(3), F.A.C.]

8. Test Methods : Any required tests shall be performed in accordance with the following methods.

Method Description of Method and Comments

EPA 9 Method 9 - Visual Determination of the Opacity of Emissions from Stationary Sources

RECORDS AND REPORTS

9. Test Reports : The permittee shall prepare and submit reports for all required tests in accordance with the requirements specified in Appendix CTR (Common Testing Requirements) of this permit. For each test ru n, the report shall also indicate the operating rate. [Rule 62-297.310(8), F.A.C.]

10. Dust Collector Design Specification : To demonstrate compliance with the dust outlet loading specification, the permittee shall maintain records from the vendor. [Rule 62-4.070(3), F.A.C.]This section of the permit addresses the following emissions unit.

EU ID No. 00 4 EU Description
IDSIS Sorbent Handling and Storage : To control acid gas emissions from the boiler, consisting primarily of SO 2 , HCl and HF , an IDSIS will be used. In this system, sorbent (hydrated lime, milled trona or sodium bicarbonate) will be injected in the flue g as duct work prior to the ESP. T he sorbent will be stored in two storage bins prior to

use. The sorbent will be withdrawn from the bins an d pneumatically conveyed to the duct work upstream of the ESP. PM emissions from the bins will be controlled by bin vent filters

. The spent sorbent will be collected from the ESP when the fly ash is collected as described in Subsection III -C. The sorbent will be disposed of with the fly ash.

EQUIPMENT

1. Equipment : The permittee is authorized to construct EU 004 , which consists of the IDSIS sorbent handling and s torage systems containing the following equipment:

a. Sorbent Loading : A sorbent loading s ystem consisting of enclosed hoppers and covered conveyors associated with the transfer of the sorbent to two storage bins. b. Sorbent Storage : A sorbent storage system consisting of two s torage bins with bin vent filters to control PM emissions. These storage bins were formerly the limestone fines storage (EU 03 8 ) and the lime dust storage bin (EU 039 ) of the combined facility (cement and power plants).

c. Sorbent Conveyance : A sorbent conveyance system consisting of an enclosed pneumatic conveyor to transport t he sorbent from the storage bins to the flue gas duct work upstream of the ESP. The conveyance system also includes the necessary nozzles and metering equipment required to inject the sorbent into the duct work. d. Dust collectors, bin vent filters and bagho uses shall be designed to achieve a PM emission rate of 0.020 gr/dscf or less. [Application No. 0530380-001- AC; Rules 62 -4.070(3) and 62-210.200(PTE), F.A.C.] [Application No. 0530380-001- AC]

2. Air Pollution Control Equipment : To comply with the emission standards of this subsection , the permittee shall install and operate the following air pollution control equipment on IDSIS sorbent handling and s torage EU

.
a. Enclosures and Dust Collectors : To minimize fugitive PM, sorbent conveyors shall be covered

. Whe re practical, d ust collectors shall be installed on the sorbent transfer points, drop points, hoppers and chutes

. [Application No. 0530380-001- AC and Rule 62-4.070, F.A.C. Reasonable Assurance].

b. Sorbent Storage Bins : Bin vent filters shall be installed and maintained to remove PM from the sorbent storage bins exhaust. The vent filters shall be installed and operational before the storage bins are operated. [Application No. 0530380-001- AC; Rule s 62-4.070(3) and 62-210.200(PTE), F.A.C.]

PERFORMANCE RESTRICTION
3. Hours of Operation : The hours of operation of this EU are not limited (i.e., unrestricted at 8,760 hours per year). [Application No. 0530380-001- AC; Rules 62 -4.070(3) and 62-210.200(PTE), F.A.C.]EMISSIONS STANDARDS
4. VE Standard : As determined by EPA Method 9, there shall be no visible emissions greater than 10 % opacity, except for one 6 minute period no greater than 20% from the sorbent conveyor s, transfer points, drop points , hoppers, chutes and dust collectors. As determined by EPA Method 9, there shall be no visible emissions greater than 5 % opacity from the bin vent filters

. [Rule 62 -4.070, F.A.C. Reasonable Assurance and Rule 62 -212.400(5)(c), F.A.C.]

5. Best Management Practices to Control Unconfined Emissions of PM : To ensure the emission standards with regard to opacity and PM of this subsection are complied with, the procedures set forth in Condition 10 of Section 2 of this permit , “ Unconfined Emissions of Particulate Matter,” shall be adhered to where practical and cost effective

. In a ddition, the procedures set forth in Appendix BMP of this permit with regard to fugitive emissions shall be adhered to. [Application No. 0530380-001- AC; Rule 62 -4.070, F.A.C. Reasonable Assurance, and Rule 62- 296.320 F.A.C.] TESTING AND MONITORING REQUIRE MENTS

6. Initial Compliance Tests : The sorbent conveyor s, transfer points, drop points, hoppers, chutes, dust collectors and sorbent bins vent filters associated with this EU shall be tested to demonstrate initial compliance with the VE standards specified in Condition 4 of this subsection . The initial test s shall be conducted within 180 days after initial operation. [Rule 62 -297.310(7)(a)1., F.A.C. and Rule 62-4.070(3), F.A.C.]

7. Annual Compliance Tests : During each federal fiscal year (October 1 st to Sept ember 30 th ), the sorbent ash conveyor s, transfer points, drop points, hoppers, chutes and dust collectors and sorbent bins vent filters associated with this EU shall be tested to demonstrate compliance with the VE emissions standards specified in Condition 4 of this subsection

. [Rule 62 -297.310(7)(a)4, F.A.C. and Rule 62-4.070(3), F.A.C.]

8. Test Methods : Any required tests shall be performed in accordance with the following methods.

Method Description of Method and Comments

EPA 9 Method 9 - Visual Determi nation of the Opacity of Emissions from Stationary Sources

RECORDS AND REPORTS

9. Test Reports : The permittee shall prepare and submit reports for all required tests in accordance with the requirements specified in Appendix CTR (Common Testing Requirements) of this permit. For each test run, the report shall also indicate the operating rate. [Rule 62-297.310(8), F.A.C.]

10. Dust Collector Design Specification : To demonstrate compliance with the dust outlet loading specification, the permittee shall maintain r ecords from the vendor. [ Rule 62 -4.070(3), F.A.C.]This section of the permit addresses the following EU

.
EU ID No. EU Description

005 One emergency diesel generator with a maximum design rating of 500 kilowatt ( kW ) and one emergency ditch pump with a m aximum design rating of 250 kW.

NSPS AND NESHAP APPLICABILITY

1. NSPS Subpart IIII Applicability : Th e emergency generator was manufactured in 1963 while the emergency ditch pump was manufactured in 1961. Consequently, while both are s tationary compression i gnition i nternal combustion engine, the provisions of 40 CFR 60, Subpart IIII, including emission testing or certification do not apply. [40 CFR 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines]

2. NESHAPS Subpart ZZZZ Applicability : The emergency generator and emergency ditch pump are subject to the applicable provisions of 40 CFR 63, Subpart ZZZZ.

a. Change oil and filter every 500 hours of operation or annually, whichever comes first; b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.
Minimize the engine's time spent at idle and minimize the engi ne's startup time at startup to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the

non- startup emission limitations apply. [ §§63.6600 and 63.6640 ] If you own or operate an existing emergency stat ionary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions or an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non

- resettable hour meter if one is not already installed. [§ 63.6625 (f)] [40 CFR 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Int ernal Combustion Engines] EQUIPMENT

3. Emergency Generator : The permittee is authorized to continue to oper ate, and maintain one emergency generator with a maximum design rating of 500 kW. [Application No. 0530380-001-AC and Rule 62-210.200 (PTE), F.A.C.]

4. Emergency Ditch Pump : The permittee is authorized to continue to operate, and maintain one emergency ditch pump with a maximum design rating of 250 kW ( 335 hp). [Application No. 0530380-001-AC and Rule 62-210.200 (PTE), F.A.C.]

5. Fuel Storage Tank : The permittee is authorized to continue to use one 400 gallon tank to store fuel oil for use in the emergency generator. The emergency ditch pump has an integral fuel tank which holds approximately 25 gallons of fuel oil. [Application No. 0530380-001-AC and Rule 62-210.200 (PTE), F.A.C.]

PERFORMANCE RESTRICTIONS

6. Hours of Operation : The emergency generator and t he emergency ditch pump may each operate up to 100 hours per year for maintenance and testing purposes. Operation during emergency conditions is unlimited. [ Application No. 0530380-001-AC and Rule 62-210.200 (PTE), F.A.C.]7. Authorized Fuel : The emergency generator and emergency ditch pump shall fire ultra low sulfur distillate fuel only

. The ultra low sulfur distillate fuel oil fired in the generator and ditch pump shall have a vendor certification indicating its sulfur content is 0.0015% or less . [Application No. 0530380-001-AC and Rule 62-210.200 (PTE), F.A.C. ]
RECORDS AND REPORTS

8. Notification, Recordkeeping and Reporting Requirements : The permittee shall maintain records demonstrating fuel usage and quality along with the hours of operation for testing and maintenance purposes for both the emergency generate and ditch pump . [Rule 62-4.070(3), F.A.C.]

# B

. JEA - Northside

# Verification of Shut

- down (BART & Reasonable Progress)

A. U.S. Sugar – Bryant (BART)

Items included: Letter from Florida Department of Environmental Protection to the facility confirming the permanent shut

- down of the facility. Also included are the Notice of Expiration of Title V Air Operation Permit and the Statement of Basis.

# B. IMC Port Sutton (currently Kinder Morgan)

Emission Units shut

- down: 1. EU001 – Phosphate Rock Dryer (BART)

Items included: 1 . Previous Title V operating permit (0570024

- 003

- AV) showing the Phosphate Rock Dryer as a valid unit.

2 . Current Title V operating permit (0570024

- 014

- AV) showing that the Phosphate Rock Dryer is no longer included.

### Robert H. Kinsey/IMC-Agrico Port Sutton Terminal Facility ID No.: 0570024 Hillsborough County

Initial Title V Air Operation Permit FINAL Permit No.: 0570024-003-AV

Permitting Authority: Environmental Protection Commission of Hillsborough County 1410 N. 21 st 

### Street Tampa, FL 33605 Telephone: (813) 272-5530 Fax: (813) 272-5605

[electronic file name: 0570024f.doc]

### Initial Title V Air Operation Permit FINAL Permit No.: 0570024-003-AV

Table of Contents

Section Page Number

Statement of Basis........................................................................................................ ii

Placard Page................................................................................................................... 1

I. Facility Information ............................................................................................. 2 - 3 A. Facility Description. B. Summary of Emissions Unit ID No(s). and Brief Description(s). C. Relevant Documents.

II. Facility-wide Conditions .................................................................................... 4 - 6

III. Emissions Unit(s) and Conditions...................................................................... 7 - 30

A. -001 Phosphate Rock Dryer B. -002 Railcar Unloading Scrubber -004 C17 transfer point E C. -003 Shiploading baghouse (C13 to C14 and C14 to Shiphold) -005 C12 transfer point A -006 C30 transfer point C -013 Shiphold Opening D. -007 C18 transfer point D -009 C19 transfer point G E. -008 Animal Feed Ingredient Handling F. -012 Conveyor transfer points from railcar unloading and rock dryer to storage silos G. -100 DAP Truck Unloading Station No.2Permittee: FINAL Permit No.: 0570024-003-AV Robert H. Kinsey/IMC-Agrico Facility ID No.: 0570024 P.O. Box 2000 SIC Nos.: 51 Mulberry, FL 33860-1100 Project: Initial Title V Air Operation Permit

This permit is for the operation of the Port Sutton Terminal. This facility is located at Port Sutton, Tampa, Hillsborough County; UTM Coordinates: Zone 17,360.1 km East and 3087.5 km North; Latitude: 27 ° 54’ 24” North and Longitude: 82 ° 25’ 18” West.

STATEMENT OF BASIS: This Title V air operation permit is issued under the provisions of Chapter 403, Florida Statutes (F.S.), and Florida Administrative Code (F.A.C.) Chapters 62-4, 62-210, and 62-213. The above named permittee is hereby authorized to perform the work or operate the facility shown on the application and approved drawing(s), plans, and other documents, attached hereto or on file with the permitting authority, in accordance with the terms and conditions of this permit.

Referenced attachments made a part of this permit: Appendix I-1, List of Insignificant Emissions Units and/or Activities Appendix O-1, Operation and Maintenance Plans for Particulate Control APPENDIX TV-3, TITLE V CONDITIONS (version dated 4/30/99) APPENDIX SS-1, STACK SAMPLING FACILITIES (version dated 10/07/96)

Effective Date: June 26, 2000 Renewal Application Due Date : December 28, 2004 Expiration Date: June 26, 2005

Environmental Protection Commission

of Hillsborough County

___________________________ Roger P. Stewart Executive Director RPS/AHH/sp

### Robert H. Kinsey/ IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 2

Section I. Facility Information.

Subsection A. Facility Description.

This facility consists of phosphate rock dryer, truck and railcar unloading operation for phosphate rock, animal feed ingredient (AFI) and chemicals (MAP, DAP, GTSP), product storage, and ammonia handling and storage.

The facility can dry phosphate rock using a single dryer firing natural gas or fuel oil. Wet phosphate rock can be trucked or delivered by railcar to the facility and stored outside until processed. The dried phosphate rock is stored within enclosed storage silos until transported off site by ship or barge. The majority of the dry phosphate rock handling operations are enclosed to control fugitive dust emissions.

Additionally, the terminal does receive dry phosphate rock, AFI and MAP, DAP, GTSP by railcar and truck. The products can be transferred directly to a shiphold or stored in silos (rock and AFI) or chemical storage buildings (MAP, DAP, GTSP). This facility is subject to PM-RACT and the monitoring requirements, along with daily visible emissions readings, fuel sampling, and annual PM and EPA Method 9 testing, have been determined by the Agency to satisfy the requirements of 40CFR70.6 and Chapter 62-296, F.A.C.

Also included in this permit are miscellaneous insignificant emissions units and/or activities.

Based on the initial Title V permit application received June 14, 1996, this facility is not a major source of hazardous air pollutants (HAPs).

Subsection B. Summary of Emissions Unit ID No(s). and Brief Description(s).

E.U. ID No. Brief Description -001 Phosphate Rock Dryer -002 Railcar Unloading Scrubber -003 Shiploading baghouse (C13 to C14 and C14 to Shiphold) -004 C17 transfer point E -005 C12 transfer point A -006 C30 transfer point C -007 C18 transfer point D -008 Animal Feed Ingredient Handling -009 C19 transfer point G -012 Conveyor transfer points from railcar unloading and rock dryer to storage silos -013 Shiphold Opening -100 DAP Truck Unloading Station No. 2

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 3
Please reference the Permit No., Facility ID No., and appropriate Emissions Unit(s) ID No(s). on all correspondence, test report submittals, applications, etc.

Subsection C. Relevant Documents.

The documents listed below are not a part of this permit, however, are specifically related to this permitting action.

These documents are provided to the permittee for information purposes only: Table 1-1, Summary of Air Pollutant Standards and Terms Table 2-1, Summary of Compliance Requirements Appendix A-1, Abbreviations, Acronyms, Citations, and Identification Numbers Appendix H-1, Permit History / ID Number Changes

These documents are on file with permitting authority: Initial Title V Permit Application received June 14, 1996.

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 4

Section II. Facility-wide Conditions.

The following conditions apply facility-wide:

1. APPENDIX TV-3, TITLE V CONDITIONS (version dated 4/30/99), is a part of this permit. {Permitting note: APPENDIX TV-3, TITLE V CONDITIONS, is distributed to the permittee only. Other persons requesting copies of these conditions shall be provided one copy when requested or otherwise appropriate.}

2. General Pollutant Emission Limiting Standards. Objectionable Odor Prohibited. The permittee shall not cause, suffer, allow, or permit the discharge of air pollutants which cause or contribute to an objectionable odor. [Rule 62-296.320(2), F.A.C.]

3. General Particulate Emission Limiting Standards. General Visible Emissions Standard. Except for emissions units that are subject to a particulate matter or opacity limit set forth or established by rule and reflected by conditions in this permit, no person shall cause, let, permit, suffer or allow to be discharged into the atmosphere the emissions of air pollutants from any activity, the density of which is equal to or greater than that designated as Number 1 on the Ringelmann Chart (20 percent opacity). EPA Method 9 is the method of compliance pursuant to Chapter 62-297. F.A.C.. [Rule 62-296.320(4)(b)1., F.A.C.]

4. Prevention of Accidental Releases (Section 112(r) of CAA). If required by 40 CFR 68, the permittee shall submit to the implementing agency: a. a Risk Management Plan (RMP) when, and if, such requirement becomes applicable; and b. certification forms and/or RMPs according to the promulgated rule schedule. [40 CFR 68]

5. Insignificant Emissions Units and/or Activities. Appendix I-1, List of Insignificant Emissions Units and/or Activities, is a part of this permit. [Rules 62-213.440(1), 62-213.430(6), and 62-4.040(1)(b), F.A.C.]

6. General Pollutant Emission Limiting Standards. Volatile Organic Compounds (VOC) Emissions or Organic Solvents (OS) Emissions. The permittee shall allow no person to store, pump, handle, process, load, unload or use in any process or installation, volatile organic compounds (VOC) or organic solvents (OS) without applying known and existing vapor emission control devices or systems deemed necessary and ordered by the Department.

A) 

### Maintain tightly fitting cover, lids, etc. on all containers when they are not being handled, tapped, etc.

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 5

B) 

### Where possible and practical, procure/fabricate a tightly fitting cover for any open trough, basin, etc. of VOC so that it can be covered when not in use. C) 

### Immediately attend to all spills/waste as appropriate.

[Rule 62-296.320(1)(a), F.A.C.; Proposed by applicant in the initial Title V permit application received June 16, 1996]

7. Reasonable precautions to prevent emissions of unconfined particulate matter at this facility in accordance with the provision in Rule 62-296.320, F.A.C. These provisions are applicable to any source, including, but not limited to, vehicular movement, transportation of materials, construction, alterations, demolition or wrecking, or industrial related activities such as loading, unloading, storing and handling. Reasonable precautions shall include, but not limited to, the following: A) Maintenance of parking areas and yards. B) Removal of particulate matter from paved areas, buildings and work areas under the control of the permittee. C) Reduce vehicular speed. Post limits, if necessary.

[Rule 62-296.320(4)(c)2., F.A.C.; Proposed by applicant in the initial Title V permit application received June 16, 1996]

8. The permittee shall notify the Air Compliance Section of the Environmental Protection Commission of Hillsborough County at least 15 days prior to the date on which each formal compliance test is to begin of the date, time, and place of each such test, and the contact person who will be responsible for coordinating and having such test conducted. [Rule 62-297.310, F.A.C]

9. Submit to the Environmental Protection Commission of Hillsborough County each calendar year on or before March 1, completed DEP Form 62-210.900(5), "Annual Operating Report for Air Pollutant Emitting Facility", for the preceding calendar year. [Rule 62-210.370(2), F.A.C.]

10. The permittee shall comply with Appendix O-1, Operation and Maintenance Plans for Particulate Control. In the event of a deviation from the monitoring parameters, the facility shall take corrective actions to remedy the situation. Notify the Environmental Protection Commission of Hillsborough County within 24 hours of the problem. The emission unit shall not be operated until the problem is corrected. A written explanation and the corrective actions implemented shall be submitted in the semi-annual report required in the TV-3 Condition Nos. 43, 44, 45. Records of inspections, maintenance, and performance parameters shall be retained for a minimum of five years and shall be made available to the Environmental Protection Commission of Hillsborough County upon request. [Rule 62-296.700(6)(e), F.A.C.]

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 6

11. When appropriate, any recording, monitoring or reporting requirements that are timespecific shall be in accordance with the effective date of this permit, which defines day

one. [Rule 62-213.440(1), F.A.C.]

12. The permittee shall submit all compliance related notifications and reports required of this permit to the Environmental Protection Commission of Hillsborough County at: Environmental Protection Commission Air Management Division 1410 North 21 st 

### Street

Tampa, FL 33605 Telephone: 813/272-5530, Fax: 813/272-5605

13. Any reports, data, notifications, certifications and requests required to be sent to the United States Environmental Protection Agency, Region 4, should be sent to: United States Environmental Protection Agency Region 4 Air EPCRA Enforcement Branch Air Compliance Section 61 Forsyth Street Atlanta, Georgia 30303 Telephone: 404/562-9099 Fax: 404/562-9095

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 7

Section III. Emissions Unit(s) and Conditions. Subsection A. This section addresses the following emissions unit(s).

E.U. ID No. Brief Description -001 Phosphate Rock Dryer

For the operation of a phosphate rock dryer designed for processing 393 TPH, annual average, of wet phosphate rock dried to approximately 2% moisture. Particulate matter emissions generated during drying operations are controlled by two Buell Dry Cyclones in parallel, followed in series by an Airetron, Model No. 261-1, Wet Cyclonic Scrubber. The rock dryer is fired on natural gas or No. 6 fuel oil with a maximum sulphur content not to exceed 2.0 % by weight.

{Permitting note(s): This emissions unit is regulated under Rule 62-296.320, F.A.C., General Pollutant Emission Limiting Standards and PM RACT under Rule 62-296.700, F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

A.1. Capacity. The maximum material handling rate of the dryer shall not exceed 575 tons/hr (TPH) in any given hour and 393 TPH on an annual average. [Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

A.2. Methods of Operation - (i.e., Fuels). The dryer shall be fired with natural gas or new fuel oil (grade No. 1 to grade No. 6 inclusive) only. The maximum sulfur content of the fuel oil shall not exceed 2.0% by weight. [Rules 62-4.160(2), F.A.C. and 62-213.440(1), F.A.C.]

A.3. Hours of Operation. This emissions unit is allowed to operate continuously, i.e., 8,760 hours/year. [Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms, summarizes information for convenience purposes only. This table does not supersede any of the terms or conditions of this permit.}

A.4. The maximum allowable particulate emission rate shall not exceed 43.8 lbs/hr and 191.8 tons per consecutive twelve month period when the process rate exceeds 333 TPH of phosphate rock. From 200 TPH to 333 TPH, the emission limit shall be set by the

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 8

Process Weight Rate formula E= 17.31 P 0.16 

### . For a production rate of less than 200 TPH, the maximum allowable particulate emission rate shall be 0.2 lb/ton of rock dried (equivalent to a maximum particulate emissions of 40lb/hr). [Rule 62-296.320, F.A.C.]

A.5. Visible emissions from the rock dryer scrubber shall not be equal to or greater than 20 % opacity. [Rule 62-296.320(4)(b), F.A.C.]

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes information for convenience purposes only. This table does not supersede any of the terms or conditions of this permit.}

A.6. Test the emissions for the following pollutant(s) annually during each federal fiscal year October1 - September 30 and submit two copies of test data to the Air Management Division of the Environmental Protection Commission of Hillsborough County within forty-five days of such testing. Testing procedures shall be consistent with the requirements of Rule 62-297.310, F.A.C.:

(X) Particulates (X) Sulfur Oxides * 

### (X) Opacity

* 

### Only required if fuel oil was used to fire the dryer for more than 400 hours in the last 12 months prior to the annual compliance test. Fuel oil analysis to determine sulfur content of the fuel shall be carried out in accordance with ASTM D129-64 and may be submitted for required sulfur dioxide emission test.

A.7. Compliance with the emission limitations of Specific Condition No. A.4. and A.5. shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A and adopted by reference in Rule 62-297, F.A.C. The minimum requirements for stack sampling facilities, source sampling and reporting, shall be in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A. [Rule 62-297, F.A.C]

A.8. Testing of emissions shall be conducted with the source operating at capacity. Capacity is defined as 90-100% of the maximum 575 TPH of wet phosphate rock processing rate . If it is impracticable to test at capacity, then the source may be tested at less than capacity; in this case subsequent source operation is limited to 110% of the test load until a new test is conducted. Once the unit is so limited, then operation at higher capacities is allowed for no more than fifteen days for purposes of additional compliance testing to regain the rated capacity in the permit, with prior notification to the EPC. Failure to submit the input rates and actual operating conditions may invalidate the test.

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 9

[Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

A.9. The visible emissions test shall be conducted by a certified observer and be a minimum of 60 minutes in duration. The test observation period shall include the period during which the highest opacity emissions can reasonably be expected to occur and shall coincide with the particulate testing. [Rule 62-297.310(4)(a)2.,F.A.C.]

A.10. If fuel oil of any grade (No 1 to No.6 inclusive) has been used in the rock dryer for a sum total of more than 400 hours from the date of the previous compliance test, then compliance testing shall be conducted while firing fuel oil. If a test is conducted while firing natural gas, and in the 12 month period following the test, oil of any grade is burned for a sum total of more than 400 hours, then an additional visible emission test per Condition A.5. shall be conducted, while burning oil in that source, within 30 days of having exceeded the 400 hour oil burning limit. A compliance test submitted using a lower grade number fuel oil than grade No. 6 fuel oil, will automatically amend this operation permit to allow subsequent operation on less than or equal grade numbers than that lower grade number oil. [Rule 62 -2 97.310(7), and 62-4.070(3), F.A.C.]

Recordkeeping and Reporting Requirements

A.11. In order to demonstrate compliance with Specific Condition Nos. A.1, A.2, A.4, A.6. and A.10., the permittee shall maintain monthly records of operations for the most recent five year period. The records shall be made available to the Environmental Protection Commission of Hillsborough County, state or federal air pollution agency upon request. The records shall include, but not limited to, the following: [Rule 62-296.320, F.A.C.] a) Month, year b) Hours of Operation c) Fuel Type and Usage (gal) d) Material throughput (TPH) e) Rolling twelve month total of d) above.

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 10

Subsection B. This section addresses the following emissions unit(s).

E.U. ID No. Brief Description -002 Railcar Unloading Scrubber -004 C17 transfer point E

EU No. 2 : For the operation of a railcar unloading operation. Railcars are pulled into a partially enclosed structure and unloaded through grates in the floor of the structure into six hoppers. Emissions from each hopper are vented to a dry cyclone. Butterfly valves in the riser pipe routed to each dry cyclone will be used to isolate or shut off air flow to hoppers not being used. Typically four of the six hoppers are used during unloading operations. Dry phosphate rock is transferred from the unloading hoppers to conveyor C17 for subsequent storage in silos via conveyors C19 and C38, or it is transferred for shiploading via conveyors C18, C12, and C13. Fertilizer products (Diammonium Phosphate (DAP), Monoammonium Phosphate (MAP), Animal Feed Ingredient (AFI), and Granular Triple Superphosphate (GTSP)) are transferred from the unloading hoppers to conveyor C17 for subsequent shiploading via conveyors C18, C12, and C13.

Particulate matter emissions generated from the railcar unloading of dry phosphate rock, MAP, GTSP, and AFI are controlled by six dry cyclones followed by a 100,000 ACFM Amerex Type C Venturi scrubber. Particulate matter emissions generated from the railcar unloading of DAP are controlled by the application of a dust suppressant oil applied to the product at the chemical processing facility prior to shipping. The scrubber will operate during the unloading of DAP as needed.

EU No. 4: For the operation of the C17 transfer point E. The system is used to transfer phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) from Conveyor C17 to either Conveyor C18 or C19. Maximum material transfer rate is 1250 TPH for the pebble phosphate rock and chemical products, and 1800 TPH for the concentrate phosphate rock.

Particulate emissions generated during the transfer process are controlled by a 6000 ACFM Poly-Con, Model Venturi 1506MS, scrubber.

{Permitting note(s): These emissions unit is regulated under Rules 62-296.320 and 62- 296.711, F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

B.1. Capacity. The maximum product unloading rates are limited as follows:

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 11

1. Concentrate rock (phosphate rock typically 69-72 BPL grade) 1800 TPH 2. Pebble rock (phosphate rock typically 66-68 BPL grade) 1250 TPH 3. Chemical Products: MAP, DAP, GTSP, AFI 1250 TPH

[Rule 62-4.160(2), F.A.C. , Rule 62-210.200, F.A.C., Definitions - (PTE), and Construction Permit AC29-237340]

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms, summarizes information for convenience purposes only. This table does not supersede any of the terms or conditions of this permit.}

B.2. The maximum allowable particulate emissions for the scrubbers shall not exceed the following for any given hour and any 12 consecutive month period: [Rules 62-4.070(3) and 62-296.711, F.A.C., Construction Permit AC29-237340, and Alternative RACT determination issued February 23, 1990]

a) EU. No. 2: based on a design flow of 100,000 ACFM: Pollutant lbs./hr. tons/yr. Emission Limitation Particulate Matter 25.7 112.6 0.03 grains/dscf Visible Emissions 20% opacity

b) EU No. 4 based on a design flow of 6000 DSCFM: Pollutant lbs./hr. tons/yr. Emission Limitation Particulate Matter 1.54 6.75 0.03 grains/dscf

B.3. Visible emissions from the railcar unloading structure, EU No. 4 scrubber exhaust and outside pick up points shall not be equal to or greater than 5 % opacity. [Rule 62-4.070(3) F.A.C., Construction Permit AC29-237340]

B.4. During the handling of DAP with the scrubber(s) turned off, the following conditions shall be met: [Rule 62-4.070(3) F.A.C., Construction Permit AC29-237340]

a) The opacity limitation in Specific Condition No. B.3. shall be monitored by a certified smoke reader or trained plant personnel. b) The product shall be sufficiently treated with a non-hazardous oil or dust suppressant to meet the opacity limit in Specific Condition No. B.3.

Test Methods and Procedures

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 12

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes information for convenience purposes only. This table does not supersede any of the terms or conditions of this permit.}

B.5. Test the 1)EU No. 2 scrubber exhaust and the railcar unloading enclosure concurrently and 2)EU No. 4 scrubber exhaust and outside pick up points for the following pollutant(s) ) annually during each federal fiscal year October1 - September 30 and submit two copies of test data to the Air Management Division of the Environmental Protection Commission of Hillsborough County within forty-five days of such testing. Testing procedures shall be consistent with the requirements of Rule 62-297.310, F.A.C.:

(X) Particulates * 

### (X) Opacity

* 

### Scrubber Exhaust Only

B.6. Compliance with the emission limitations of Specific Condition No. B.2. and B.3. shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test shall be conducted by a certified observer and be a minimum of sixty (60) minutes in duration for the scrubber exhaust and thirty (30) minutes in duration for the railcar enclosure. The minimum requirements for stack sampling facilities, source sampling and reporting, shall be in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A. [Rule 62-297, F.A.C]

B.7. Testing of emissions shall be conducted with the source operating at capacity. Capacity is defined as 90-100% of the maximum unloading rates of 1250 TPH for pebble rock and 1800 TPH for concentrate rock (note: If dry phosphate rock handling has been and is expected to remain minimal, testing may be conducted based on the maximum unloading rate of 1250 TPH for AFI). If it is impracticable to test at capacity, then the source may be tested at less than capacity; in this case subsequent source operation is limited to 110% of the test load until a new test is conducted. Once the unit is so limited, then operation at higher capacities is allowed for no more than fifteen days for purposes of additional compliance testing to regain the rated capacity in the permit, with prior notification to the EPC. Failure to submit the input rates and actual operating conditions of the scrubber such as inlet pressure drop and liquor feed rate, may invalidate the test. [Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

B.8. Test the emissions from the railcar enclosure for opacity at least 6 months prior to the expiration of this permit while unloading oiled DAP at 90 to 100 percent of the rate of 1250 TPH. During testing, the scrubber is not to be operated. Two copies of the test data are to be submitted to the Air Management Division of the Environmental Protection Commission of Hillsborough County. [Rule 62-297,F.A.C. and Rule 62-4.070(3), F.A.C.]

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 13

B.9. The use of dust suppressant in lieu of operating the scrubber for product other than DAP is allowed provided that IMC-Agrico Company (IMC) satisfies the following requirements: [Construction Permit AC29-237340]

a) IMC will notify the EPC prior to the deactivation of control devices for the purpose of conducting visible emission tests to demonstrate compliance with the standards. b) IMC shall conduct an initial compliance test for visible emissions at the railcar enclosure while handling each additional product. The deactivation of the control devices is limited to the time required to conduct these tests, until authorization by the EPC is issued. c) Testing shall be conducted within 90-100% of the maximum handling rate for each additional product. The actual handling rate and oil to product ratio (gallon/ton) shall be included with the test results. d) Two copies of the test results, along with the applicable permit amendment requests, shall be submitted to the Air Division of the EPC within 45 days of testing. e) The EPC shall acknowledge that the above conditions have been satisfied by amending the corresponding permits for approval and issuing.

Recordkeeping and Reporting Requirements

B.10. In order to comply with Specific Condition Nos. B.3., B.4., and B.9. the permittee shall maintain records for the most recent 5 year period. The recordkeeping shall be made available to the EPC of Hillsborough County, state or federal air pollution agency upon request. The records shall include, but are not limited to, the following: [Rule 62-4.070(3), F.A.C.]

a) Typical amount and type of dust suppressant applied (gallon/ton) for each product unloaded during the preceding month b) Certificate for smoke reader at the facility who monitored DAP or other fertilizer product unloading with the scrubber off and/or, c) Training program for trained plant personnel

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 14

Subsection C. This section addresses the following emissions unit(s).

E.U. ID No. Brief Description -003 Shiploading Baghouse -005 C12 transfer point A -006 C30 transfer point C -013 Shiphold Opening

EU No. 3 and No. 13: The operation of the a) shiploader telescopic chute and OBA chokefeeder, b) transfer of material from conveyor C14 to the shiphold, and c) final transfer point from conveyor C13 to conveyor C14. The system is used to transfer phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) to the shiphold. The maximum transfer rate is 2300 TPH.

Particulate emissions generated during the transfer operation are controlled by the use of a modified Mikro-Pulsaire, Model 1F2 baghouse and/or a gantry mounted dust suppression system. The dust suppression system consists of four (4) spray headers located throughout the gantry using a surfactant chemical mixed with water.

EU No. 5: For the operation of the C12 Transfer Point A. The system is used to transfer phosphate rock and chemical products (DAP, MAP, GTSP, and AFI) from conveyor C12 to conveyor C13 at a maximum transfer rate of 2300 TPH.

Particulate emissions generated during the transfer process are controlled by a 8000 ACFM Mikro-Pulsaire, Model 80F2 baghouse.

EU No. 6.: For the operation of the C30 Transfer Point C. The system is used to transfer various grades of phosphate rock or Animal Feed Ingredients (AFI) from conveyor C30 to conveyor C12 at a maximum transfer rate of 2300 TPH.

Particulate matter emissions generated during the transfer operation are controlled by a Mikro-Pulsaire, Model 1215 -8- 80 baghouse.

{Permitting note(s): These emission units are regulated under Rule 62- 296.711(2)(b), F.A.C.}

The following specific conditions apply to the emissions unit(s) listed above:

Essential Potential to Emit (PTE) Parameters

C.1. Capacity. The maximum transfer rate of material shall not exceed 2300 TPH. [Rule 62-4.160(2), F.A.C. and Rule 62-210.200, F.A.C., Definitions - (PTE)]

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 15

Emission Limitations and Standards

{Permitting note: Table 1-1, Summary of Air Pollutant Standards and Terms, summarizes information for convenience purposes only. This table does not supersede any of the terms or conditions of this permit.}

C.2. The maximum allowable particulate emissions for these baghouses shall not exceed the following for any given hour and for any 12 consecutive month period: [Rule 62-296.711(2)(a), F.A.C.]

a) EU No. 3 based on a design flow of 9000 DSCFM: Pollutant lbs./hr. tons/yr. Emission Limitation Particulate Matter 2.31 10.12 0.03 grains/dscf

b) EU No. 5 based on a design flow of 8000 DSCFM: Pollutant lbs./hr. tons/yr. Emission Limitation Particulate Matter 1.8 9.0 0.03 grains/dscf

c) EU No. 6 based on a design flow of 6000 DSCFM: Pollutant lbs./hr. tons/yr. Emission Limitation Particulate Matter 1.54 6.75 0.03 grains/dscf

C.3. The maximum opacity from the baghouse exhaust and outside pickup point shall not exceed 5% and the opacity from the discharge to the shiphold shall not exceed 10%. [Rule 62-296.711(2)(a) and (b), F.A.C.]

C.4. In order to show compliance with the limits of Specific Condition Nos. C.2. and C.3., the following restrictions shall apply: [Rule 62-4.070(3)] a) All dust laden air from the transfer operation shall be vented to the baghouse. b) The dust suppression system shall be maintained in operable condition so that it can be operated at any time as necessary during the loading of dry phosphate rock, as well as other products, to maintain compliance with the permitted opacity limit of 10% opacity from the discharge to the hold of the ship. Periods of operation may include, but are not limited to start-up, trimming, and during upset conditions.

Test Methods and Procedures

{Permitting note: Table 2-1, Summary of Compliance Requirements, summarizes information for convenience purposes only. This table does not supersede any of the terms or conditions of this permit.}

### Robert H. Kinsey/IMC-Agrico FINAL Permit No. 0570024-003-AV Port Sutton Terminal Page 16

C.5. Test the emissions from the 1) baghouse exhaust (EU No.3), shiphold, and C13 to C14 transfer point; 2) baghouse exhaust (EU. No.5) and the outside pick up point; and 3) baghouse exhaust (EU. No.6) and the outside pick up point for opacity annually during each federal fiscal year October1 - September 30 and submit two copies of test data to the Air Management Division of the Environmental Protection Commission of Hillsborough County within forty-five days of such testing. Testing procedures shall be consistent with the requirements of Rule 62-297.310, F.A.C..

C.6 . Test the baghouse exhaust for particulate matter at least 120 days prior to the expiration date of this permit while handling dry phosphate pebble rock of approximately 68 grade. Particulate test shall be conducted under similar process rate and operating condition(s) as the visible emission test for the baghouse exhaust. If possible, the visible emission test shall be performed simultaneously with one of the test run for the particulate matter emissions. [Rule 62-297.340(c), F.A.C.]

C.7. Compliance with the emission limitations of Specific Condition No. C.2. and C.3. shall be determined using EPA Methods 1, 2, 4, 5 and 9 contained in 40 CFR 60, Appendix A and adopted by reference in Rule 62-297, F.A.C. The EPA Method 9 test interval on the source shall be thirty (30) minutes in duration, and the test shall be conducted concurrently on the control equipment exhaust and the transfer point. The minimum requirements for stack sampling facilities, source sampling and reporting, shall be in accordance with Rule 62-297, F.A.C. and 40 CFR 60, Appendix A. The test report shall indicate whether the dust suppression system was operating during the visible emission readings. [Rule 62-297, F.A.C]

C.8. Testing of emissions shall be conducted with the source operating at capacity. Capacity is defined as 90-100% of 2300 TPH of handling rate for dry phosphate rock of approximately 68 grade (note: If dry phosphate rock handling has been and is expected to remain minimal, testing may be conducted based on the maximum material transfer rate of 2300 TPH for AFI). If it is impracticable to test at capacity, then the source may be tested at less than capacity; in this case subsequent source operation is limited to 110% of the test load until a new test is conducted. Once the unit is so limited, then operation at higher capacities is allowed for no more than fifteen days for purposes of additional compliance testing to regain the rated capacity in the permit, with prior notification to the EPC. Failure to submit the input rates and actual operating conditions may invalidate the test. [Rules 62-4.070(3) and 62-297.310(2)(b), F.A.C.]

C.9. The permittee is allowed to handle dust suppressant oiled DAP product with the control device turned off provided that: a) Visible emissions at the transfer point shall be less than 5 % opacity. b) The product shall be sufficiently treated with a non-hazardous oil or dust suppressant to meet the opacity limit in Specific Condition No. C.5. If a visible emission test is conducted at the transfer point, the test shall indicate