# B. Florida Power and Light

– Turkey PointTECHNICAL EVALUATION
&
PRELIMINARY DETERMINATION

PROJECT
Draft Permit No. 0250003-008-AC Best Available Retrofit Technology (BART) Turkey Point Fossil Plant Miami-Dade County, Florida

APPLICANT Florida Power & Light Company (FPL) 9700 SW 344 Street Homestead, Florida 33035

PERMITTING AUTHORITY
Title V Section Bureau of Air Regulation Division of Air Resource Management Florida Department of Environmental Protection

May 22, 2008 Revised October 16, 2008 Revised March 2, 2009TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 2 of 9 1. GENERAL PROJECT INFORMATION Facility Description and Location The applicant, Florida Power & Light Company, operates an existing oil and gas-fired power plant, which consists of two residual fuel oil and natural gas-fueled 440 MW fossil fuel steam electrical generators (Units 1 and 2), five fuel oil-fired black start 2.75 MW diesel peaking generators supporting Units 1 and 2, a natural gas-fueled 1,150 MW combined cycle unit (Unit 5), and associated equipment. The Standard Industrial Classification (SIC) code for this type of plant is SIC No. 4911. The facility is located at 9700 SW 344 Street, in Homestead, Miami-Dade County. The UTM coordinates are Zone 17, 567.4 km East and 2,813.5 km North. Regulatory Categories This project is subject to the applicable environmental laws in Section 403 of the Florida Statutes (F.S.). The Florida Statutes authorize the Department of Environmental Protection (Department) to establish rules regarding air quality in the Florida Administrative Code (F.A.C.). The facility is classified according to the following major regulatory categories.

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

• The facility operates 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.

• The facility operates BART-eligible units subject to Rule 62-296.340, F.A.C. Project Description Florida Power & Light Company submitted an application to satisfy the requirements of Rule 62-296.340 (BART), F.A.C., which addresses the following BART-eligible emissions units.
ID No. Description
-001 Fossil Fuel Steam Generator Unit 1
-002 Fossil Fuel Steam Generator Unit 2

This Technical Evaluation and Preliminary Determination details the project, provides the top-down BART analysis, and identifies the preliminary BART determinations. Processing Schedule 1/31/07 Department received the BART application for an air pollution construction permit. 2/26/07 Department requested additional information. 5/7/07 Department received additional information. Application remained incomplete. 5/16/07 Department sent letter granting additional time to respond. 6/6/07 Department requested additional information. 7/6/07 Department received additional information; application remained incomplete. 8/3/07 Department requested additional information. 9/13/07 Department received additional information; application remained incomplete. 10/13/07 Department requested additional information.TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 3 of 9 12/3/07 Department received waiver of permit processing clock. 1/31/08 Department received additional information and extension of processing clock waiver. 2/28/08 Department received revised application for a BART permit, application deemed complete. 5/23/08 Draft permit issued, Public Notice never published. 10/17/08 Prior draft permit withdrawn and revised draft permit issued. 11/4/08 Meeting at DEP with FPL.
11/14/08 Additional information received. 2/9/09 Meeting at DEP with FPL.
2/13/09 Additional information received. 3/2/09 Prior revised draft permit withdrawn and new revised draft permit issued.

2. APPLICABLE BART REGULATIONS Regulatory Authority This project is subject to the applicable regulatory requirements in the following Chapters of the F.A.C.: 62-4 (Permitting Requirements); 62-204 (Ambient Air Quality Requirements, PSD Increments, and Federal Regulations Adopted by Reference); 62-210 (Permits Required, Public Notice, Reports, Stack Height Policy, Circumvention, Excess Emissions, and Forms); 62-212 (Preconstruction Review, PSD Review and Best available Control Technology (BACT); 62-296 (Emission Limiting Standards); and 62-297 (Test Methods and Procedures, Continuous Monitoring Specifications, and Alternate Sampling Procedures). It is also subject to the applicable provisions in Title 40 of the Code of Federal Regulations (CFR) as adopted in Chapter 62-204 and 62-296, F.A.C. Specifically, this project is subject to Rule 62-296.340 (BART), F.A.C. for determining and applying the Best Available Retrofit Technology for each BART-eligible source as defined in 40 CFR 51.301. The Department previously identified all BART-eligible sources through a series of notifications, workshops, and rule making efforts. The state rule implements the federal provisions of Appendix Y in 40 CFR Part 51, “Guidelines for BART Determinations under the Regional Haze Rule”.
Affected Pollutants In accordance with Appendix Y in 40 CFR 51, the affected visibility-impairing pollutants include the following: nitrogen oxides, particulate matter, and sulfur dioxide. For electric utilities subject to CAIR, only particulate matter is subject to BART review. With respect to particulate emissions, Rule 62-210.200, F.A.C. defines PM as, “... all finely divided solid or liquid material, other than uncombined water, emitted to the atmosphere as measured by applicable reference methods, or an equivalent or alternative method ...” Particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers is defined as PM 10 and particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers is defined as PM 2.5 . Emissions of PM, PM 10 and PM 2.5 are all regulated pollutants. For the existing emissions units and air pollution control equipment, the control strategy specified in the BART determinations directly reduces PM emissions, which serves as a surrogate to also reduce PM 10 and PM 2.5 emissions.
BART Definition Pursuant to 40 CFR 51.301, Best Available Retrofit Technology (BART) means, “... an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant which is emitted by ... [a BART-eligible source]. The emission limitation must be established, on a case-by case basis, taking into consideration the technology available, the costs of compliance,TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 4 of 9 the energy and non-air quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.” In accordance with Rule 62- 296.340(3), F.A.C., the Department shall determine BART for each affected source in an air construction permit. BART Analysis Procedure There are five basic steps in the case-by-case BART analysis: Step 1 . Identify all available retrofit control technologies. A comprehensive list of available technologies for analysis must be identified that includes the most stringent option and a reasonable set of available options. It is not necessary to list all permutations of available control levels that exist for a given technology. The list is complete if it includes the maximum level of control each technology is capable of achieving. Step 2 . Eliminate technically infeasible options. Control technologies are technically feasible if either (1) they have been installed and operated successfully for the type of source under review under similar conditions, or (2) the technology could be applied to the source under review. “Availability” and “applicability” are two key concepts in determining whether a technology could be applied. A technology is considered “available” if the source owner may obtain it through commercial channels, or it is otherwise available within the common sense meaning of the term. An available technology is “applicable” if it can reasonably be installed and operated on the source type under consideration. A technology that is available and applicable is technically feasible. Step 3 . Evaluate control effectiveness of remaining control technologies. There are two key issues in thisprocess, including (1) expressing the degree of control in consistent terms to ensure an “apples-toapples” comparison of emissions performance levels among options, and (2) giving appropriate treatment and consideration of control techniques that can operate over a wide range of emission performance levels. Step 4 . Evaluate the impacts and document the results. The evaluation will consider the costs of compliance, energy impacts, non-air quality environmental impacts, and remaining useful life. Step 5 . Evaluate visibility impacts. Use CALPUFF or other appropriate dispersion model to determine the visibility improvement expected at a Class I area from the potential BART control technology applied to the source. Note that if the most stringent BART control option available is selected, it is not necessary to conduct an air quality modeling analysis for the purpose of determining its visibility impacts.
BART Determination : In making a final BART determination, the following will be considered: (1) technically feasible options; (2) the average and incremental costs of each option; (3) the energy and non-air quality environmental impacts of each option; (4) the remaining useful life; and (5) the modeled visibility impacts. A justification for selecting a technology as the “best” level of control must be provided and include an explanation of these factors that led to the BART determination. When a BART determination is made for two regulated pollutants on the same source, if the result is two different BART technologies that do not work well together, it may be reasonable to substitute a different technology or combination of technologies.

3. UNITS 1 AND 2 – BART DETERMINATION This section provides the control technology review and BART determination for the following emissions units.

ID No. Emission Unit Description -001 Unit 1 is a 4,000 MMBtu/hr fuel oil-fired boiler (4,150 MMBtu/hr when firing natural gas). -002 Unit 2 is a 4,000 MMBtu/hr fuel oil-fired boiler (4,150 MMBtu/hr when firing natural gas).TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 5 of 9 PM Control Technology Review Particulate matter is emitted from the stacks of Units 1 and 2 as a result of the firing of fuel oil and natural gas to generate electricity. Each unit is equipped with low excess air burners and Universal Oil Products (UOP) Air Correction Division multi-cyclones with reinjection. The multi-cyclones consist of two tubular mechanical dust collectors with 695 tubes per collector. Step 1 . Identify all available retrofit control technologies. The available retrofit control technologies for these boilers include the following:

• Add wet scrubbers following the existing multi-cyclones.

• Add electrostatic precipitators (ESP) following the existing multi-cyclones.

• Add baghouses following the existing multi-cyclones.

• Replace the existing multi-cyclones with new state-of-the-art multi-cyclones. Step 2 . Eliminate technically infeasible options. Baghouses and ESP are generally recognized as the top controls with removal efficiencies greater than 99%. Although feasible, wet scrubbers have not demonstrated equivalent levels of control for PM. Also, baghouses do not appear to be a good choice either, since tests conducted by FPL at the Sanford plant found that particles generated from the combustion of oil-based fuels caused considerable plugging of bags in pilot scale tests. Step 3 . Evaluate control effectiveness of remaining control technologies. Based on information submitted by the applicant, which includes proposals provided by air pollution control device vendors, the effectiveness of the potential control techniques and available options are as follows: Units 1 & 2: 4,000 MMBtu/hour each:
Control Technology Options Continuously Achievable

Emission Rate Emissions From Both Units tons/year Potential Reduction

tons/year Percent

Reduction*

Existing Multi-cyclones 0.1 lb/MMBtu 1,795 * 0 0
New ESP 0.03 lb/MMBtu 539 1,257 70% Multi-cyclone upgrade 0.070 lb/MMBtu 1,257 539 30% * Baseline / Historical Maximum Step 4 . Evaluate the impacts of the remaining technologies and document the results. Based on information submitted by the applicant (assuming a 20-year useful life and 7% annual interest rate), the following is a summary of the expected costs associated with the proposed control options:

Control Options Unit 1 Unit 2
Annualized Cost $/ton Removed Annualized Cost $/ton Removed New ESP (0.030 lb/MMBtu) $6,676,195 10,623 $6,676,195 10,623 Multi-cyclone upgrade & Reduced Fuel sulfur % $961,552 3,568 $961,552 3,568
It should be noted that the estimated cost does not include any changes in construction associated with the close proximity of the nuclear units (i.e., Turkey Point Units 3 and 4). According to the applicant:

• the location of the ESP construction for Units 1 and 2 would increase security requirements and potentially require approval from the Nuclear Regulatory Commission.TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 6 of 9 • the energy required to operate two ESPs would be about 4,370 MW-hr per year for both units, or about 0.13 percent of gross generation.

• ash collected by the ESP would require landfilling if it could not be recycled.

• it is estimated that 1,257 tons of ash would be generated from the ESPs requiring about 50 truck trips per year to remove it from the site.

• FPL has no plans to shut down either unit in the near future. However, Units 1 and 2 are typically operated as cycling units rather than base-loaded units. Step 5 . Evaluate visibility impacts. The CALPUFF modeling system (CALPUFF Version 5.756) was used to predict the maximum visibility impairment at the only PSD Class I area within 300 kilometers (km) of Florida Power and Light Turkey Point Power Plant. The nearest PSD Class I area is the Everglades National Park (ENP), which is located approximately 21 km from the facility. The CALPUFF modeling analysis followed the Visibility Improvement State and Tribal Association of the Southeast (VISTAS) common protocol, Version 3.2. The Department provided the applicant with 4 km “CALPUFF-ready” CALMET meteorological data. Class I receptor locations were obtained from the National Park Service (NPS) and a Lambert Conformal Conic (LCC) coordinate system was used. Maximum visibility impacts are based on the predicted 24-hour visibility impairment values for 2001 to 2003, the 8 th highest (98 th

percentile) for each year. These values are compared with a threshold of 0.5 deciview (dv). A dv is a standard visibility index. The Interagency Monitoring of Protected Visual Environments (IMPROVE) states that the dv scale is linear to humanly-perceived changes in visual air quality. For example, a dv near zero is considered a “pristine” atmosphere. Deciviews increase with visibility impairment. Turkey Point has two BART-eligible sources for particulate matter. These sources are Units 1 and 2, which are oil and gas-fired conventional stream 400 megawatt (MW) units. The visibility impact from the existing two units is greater than 0.5 dv therefore, the two units contribute to visibility impairment at the ENP and a BART determination is required. The initial BART determination analysis predicted visibility improvement with the addition of ESP’s to both Units 1 and 2. Initial emission rates were determined from stack test data and AP-42 emission factors to reflect the maximum 24-hour average normal operation. Emissions were speciated into six particulate species with regards to specific size categories and modeled. Results of this initial modeling predicted a visibility improvement of 0.1 dv. Subsequent modeling followed as part of a revised BART determination analysis. This analysis does not include ESP’s as BART and the initial modeling results with ESP’s are not comparable with this subsequent modeling due to differences in initial emission rates, although the emissions were speciated in the same matter. The subsequent BART determination analysis predicted visibility improvement based on particulate matter and percent sulfur fuel content. Base case emission rates for this modeling analysis were based on an emission rate of 0.1 lb/MMBtu with a sulfur fuel content of 1% or the allowable emission rates for Units 1 and 2. The base case was then compared to the proposed BART determination of 0.07 lb PM/MMBtu and a sulfur content of 0.7 percent. Further, modeling was done to show further reductions of particular matter with a fuel additive program (0.05 lb/MMBtu). The results of these analyses are shown in the table below.

Control Technology PM Emission Rate Sulfur Fuel

Content 8 th highest

impairment (2001) 8 th highest

impairment (2002) 8 th highest

impairment (2003) Existing Base Case 0.1 lb/MMBtu 1% 2.2 dv 1.8 dv 1.9 dv Multi-Cyclones 0.7 lb/MMBtu 0.7% 1.6 dv 1.3 dv 1.4 dvTECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 7 of 9 Fuel Additive Program 0.5 lb/MMBtu 0.7% 1.3 dv 1.1 dv 1.2 dv
The results predict a 29 and 41 percent visibility benefit for the proposed sulfur reduction and PM reductions of 0.7 and 0.5 lb/MMBtu respectively.

Preliminary PM BART Determination The purpose of the BART regulations is to reduce regional haze by requiring air pollution emitting facilities to reduce the amount of visibility-impairing pollutants that are emitted. For many sources, this will require the installation of new control devices. Other sources may be able to reduce emissions by upgrading existing pollution control equipment. For comparison, units subject to the revisions to NSPS Subpart Da, for units constructed, reconstructed or modified after February 28, 2005, must meet a PM standard of 0.015 lb/MMBtu. The BART analysis for the Turkey Point project shows that a guarantee to meet an emissions standard of 0.015 lb/MMBtu appears to be quite difficult to receive from the ESP vendors. The guarantee for this project was only for 0.03 lb/MMBtu and that was at a cost of over $10,000 per ton of PM removed. In addition, that only provides a visibility improvement of 0.1 dv. Based on the high cost for such a small improvement in visibility, the company claims it is economically inappropriate to add an ESP to Units 1 and 2. As an alternative emission reduction strategy, the company has proposed the use of low sulfur (0.7 percent) residual oil (current limit is for 1% sulfur oil) and a reduction in the PM limit from the current allowable emission rate of 0.1 lb/MMBtu down to 0.07 lb/MMBtu, which is achievable with the installation of new state-of-the-art multi-cyclones. At a comparative cost of less than $3,600/ton of PM removed, this option is considered economically appropriate and will produce a larger visibility improvement of 0.6 dv (i.e., 29 percent reduction in visibility impacts from base case). The company is also proposing to research the viability of implementing a fuel additive program with the goal of further reducing PM emissions down to 0.05 lb/MMBtu, which could provide an additional 0.27 dv visibility improvement (i.e., 41 percent reduction in visibility impacts from base case) when combined with the 30% decrease in fuel sulfur. The addition of ESPs for these units would appear to be the logical choice to satisfy the BART requirements for emissions of PM. However, considering the large cost per ton of PM removed and the very small improvement in modeled visibility impacts, it is reasonable to consider FPL’s proposed alternative. Reducing the amount of sulfur in the fuel by 30%, in addition to the possibility of an eventual 50% reduction in the allowable PM emissions rate, leads to a much greater improvement in modeled visibility impacts at about a third of the cost. The Department believes that this is a reasonable alternative that better serves the overall intent of the BART regulations. However, it should be noted that this proposal to provide sulfur reductions now instead of spending more money to control PM emissions to an even lower rate, will in no way effect the Department’s ability to address further sulfur reductions and/or SO 2 controls during the implementation of the Reasonable Progress Control Technology (RPCT) requirements contained in Rule 62-296.341, F.A.C. The RPCT rule requires that a proposal and air construction permit application be submitted to the Department by January 31, 2012.
To satisfy the requirements of BART, the draft permit includes the following primary requirements:

• As soon as practicable, but not later than December 31, 2013, the permittee shall replace the existing multi-cyclones on Units 1 and 2 with new state-of-the-art multi-cyclones.

• The permittee shall conduct a study of fuel additives designed to reduce the formation of PM and/or improve the collection efficiency of the PM emissions in the multi-cyclones. Included with this study is the authorization to inject different types of fuel additives and to perform stack tests to demonstrate the results. Not later than December 31, 2010, the permittee shall submit a report to the Permitting Authority describing the potential benefits of each of the different fuel additives tested and making aTECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 8 of 9 recommendation as to which additives should be used, (if any), in order to reduce PM emissions to the applicant proposed limit of 0.05 lb/MMBtu. .

• As soon as practicable, but not later than December 31, 2013, the sulfur content of the fuel oil fired in Units 1 and 2 shall not exceed 0.7%, by weight. SO 2 emissions from Units 1 and 2 shall not exceed 0.77 lb/MMBtu on a 3-hour rolling average.

• As soon as practicable, but not later than December 31, 2013, the PM emissions from Units 1 and 2 shall not exceed 0.07 lb/MMBtu (3-hour average). Based on the results of the fuel additive tests and the information contained in the report, the Applicant will make a recommendation as to which additive(s) shall be used (if any) in order to reduce the PM emissions to the goal of 0.05 lb/MMBtu.

• As soon as practicable, but not later than December 31, 2013, the PM emissions from Units 1 and 2 due to soot blowing and load change operations shall not exceed an average of 0.2 pound per million Btu heat input during the 3 hours in any 24-hour period of excess emissions allowed for boiler cleaning (soot blowing) and load change.

• As soon as practicable, but not later than December 31, 2013, the visible emissions (VE) from Units 1 and 2 shall not exceed 20% opacity, based on a 12-month rolling average of all valid 6-minute opacity readings as recorded by the COMS. Authorized excess emissions during periods of malfunction shall be excluded. In calculating the 12-month rolling opacity average, the permittee may exclude up to one percent of the total number of 6-minute averages over the relevant 12-month period.

• During each federal fiscal year (October 1 st to September 30 th ), the permittee shall conduct tests on Units 1 and 2 to demonstrate compliance with the BART standards for particulate matter and sulfur dioxide. Initial compliance tests for PM and sulfur dioxide shall be conducted during federal fiscal year 2012/2013 and a test report demonstrating compliance with the new BART standards shall be submitted before October 1, 2013. Emissions of SO 2 shall be determined continuously with data from the existing continuous emissions monitoring systems (CEMS). Information obtained during the annual CEMS Relative Accuracy Test Audit (RATA) may be used to satisfy the testing requirements for SO 2 . Compliance with the 20% rolling 12-month average opacity limit shall be calculated and recorded on site by the 15 th

of each month, based on the arithmetic average of all 6-minute readings documented by the COMS during the previous 12 calendar months, excluding allowable periods of documented excess emissions as the result of a malfunction. If necessary to demonstrate compliance with the 20% average, up to 1% of the total number of 6-minute averages over the previous 12-month period may also be excluded. A summary of these calculations shall be provided with the semi-annual monitoring reports, which are required by the Title V permit.

• As an alternative to the new BART SO 2 and PM limits, not later than 12/31/2011, FPL may submit an application requesting to either: repower Units 1 and 2 with natural gas-fired combustion turbines, burn only natural gas in units 1 and 2 and meet a PM emissions limit of 0.05 lb/MMBtu, or permanently shut down Units 1 and 2.

• In the event that CAIR is vacated by the  ral courts, the Department reserves the right to require the submission of a BART application for SO 2 and NO X within 60 days of notification by the Department. Nothing herein shall constitute a BART determination for SO 2 or NO X nor affect the Department’s obligations to address Reasonable Further Progress at this facility.

• Unless otherwise specified by this permit, the permittee shall continue to comply with all specific conditions of the current Title V air operation permit.

• Provide proper notifications and stack test reports.TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 9 of 9 4. PRELIMINARY DETERMINATION The Department makes a preliminary determination that the proposed project will comply with all applicable state and federal air pollution regulations regarding BART as conditioned by the draft permit. This determination is based on a technical review of the complete application, all available information, reasonable assurances provided by the applicant, and the conditions specified in the draft permit. This determination is a case-by-case determination based solely on the facts and circumstances relating to this application and is not a precedent for any other project. Jonathan Holtom, P.E., is the project engineer responsible for reviewing the application and drafting the permit. Deborah Nelson is the project meteorologist responsible for reviewing the modeling analysis for visibility.PERMITTEE

Florida Power & Light Company 9700 SW 344 th

Street Homestead, Florida 33035
Authorized Representative: Rudy Sanchez, Plant Manager Air Permit No. 0250003-008-AC Expiration Date: 07/01/2014 Turkey Point Fossil Plant BART Project

PLANT AND LOCATION Florida Power & Light Company (FPL) operates the Turkey Point Fossil Plant, which is a located at 9700 SW 344 th Street, Homestead, Miami-Dade County, Florida. The UTM coordinates are Zone 17, 567.4 km East and 2,813.5 km North. The facility is an existing oil and natural gas-fired power plant, which is identified by Standard Industrial Classification code No. 4911.

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.). Specifically, this project is subject to Rule 62-296.340, F.A.C., which requires a determination of the Best Available Retrofit Technology (BART) for each BART-eligible source as defined in 40 CFR 51.301. The state rule implements the federal provisions of Appendix Y in 40 CFR Part 51, “Guidelines for BART Determinations Under the Regional Haze Rule”. The affected visibility-impairing pollutants include only particulate matter (PM) for electric utilities subject to CAIR. Pursuant to Rule 62-296.340, F.A.C., the permittee shall install or modify the air pollution control equipment to achieve the specified BART standards.

EFFECTIVE DATE Unless otherwise specified by this permit, the BART-eligible sources shall demonstrate compliance with the conditions of this permit no later than December 31, 2013. [Rule 62-296.340(3)(b)2, F.A.C.] Executed in Tallahassee, Florida

___________________________________ _______________ Joseph Kahn, Director (Date) Division of Air Resource Management

JK/tlv/jhSECTION 1. GENERAL INFORMATION

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 2 of 6 FACILITY DESCRIPTION FPL operates the existing Turkey Point Fossil Plant, which consists of:

• Two residual fuel oil and natural gas-fueled 440 MW fossil fuel steam electrical generators (Units 1 and 2) with low-nitrogen oxides (low NO X ) burners and mechanical cyclone dust collectors;

• Five fuel oil-fired black start 2.75 MW diesel peaking generators supporting Units 1 and 2;

• One natural gas-fueled 1,150 MW combined cycle unit (Unit 5);

• One 4.2 million gallon distillate fuel oil tank that serves Unit 5;

• One 22 cell mechanical cooling tower that serves Unit 5;

• Two 2.25 MW emergency diesel generators that serve Unit 5; and

• Unregulated and/or insignificant emissions units and activities. The separate collocated Turkey Point Nuclear Plant (Units 3 and 4) is licensed by the Nuclear Regulatory Commission and includes several diesel-fueled emergency generators that are addressed in a separate Title V permit (DEP File No. 0250003-004-AV).

FACILITY REGULATORY CLASSIFICATIONS

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

• The facility operates 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.

• The facility operates BART-eligible units subject to Rule 62-296.340 (BART), F.A.C.

BART-ELIGIBLE EMISSIONS UNITS This permitting action affects the following BART-eligible emissions units at the plant.

EU No. Emission Unit Description
-001 Fossil Fuel Steam Generator Unit 1 -002 Fossil Fuel Steam Generator Unit 2

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 RequirementsSECTION 2. ADMINISTRATIVE REQUIREMENTS

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 3 of 6 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 Miami-Dade County Department of Environmental Resources Management (DERM), Air Quality Management Division. The mailing address and phone number for DERM is: 701 Northwest 1 st Court, Suite 400, Miami, Florida 33136-0926, telephone: 305/372-6925, Fax: 305/372-6954.
3. Appendices : The following Appendices are attached as an enforceable part of this permit: Appendix A (Citation Formats), Appendix B (General Conditions), and Appendix C (Standard Testing Requirements).
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, Florida Statutes (F.S.); Chapters 62-4, 62-204, 62-210, 62-212, 62-213, 62-296 and 62-297, Florida Administrative Code (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 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 operation permit is required for regular operation of the permitted emissions unit. The permittee shall apply for a Title V operation permit revision on or before April 1, 2014 . 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 Bureau of Air Regulation with copies to the Compliance Authority. [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 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 : 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 st

of 2009 and April 1 st

of each year, thereafter. [Rule 62-210.370(3), F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS Emissions Units 1 and 2 (EU-001 & -002)

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 4 of 6 This subsection addresses the following affected emissions units. ID No. Emissions Unit Description -001
and
-002 Description : Two Foster-Wheeler 400 MW Class (440 MW gross capacity) Steam Generating Units.
Fuels : The fuels allowed to be burned in these units are a variable combination of: natural gas, used oil from FPL operations, No. 6 and No. 2 fuel oils, and propane. Capacity Limits : 4,150 MMBtu/hr for gaseous fuels, 4,000 MMBtu/hr for liquid fuels.
Controls : Emissions of particulate matter are controlled from each unit by multi-cyclones with fly ash reinjection. Emissions of NO X are controlled with the use of low-NO X burners.
Monitors : Continuous opacity monitor systems (COMS) are used to measure opacity in conformance with 40 CFR Part 75. Nitrogen oxide (NO X ) and sulfur dioxide (SO 2 ) continuous emissions monitoring systems (CEMS) are used to demonstrate compliance with the existing NO X and SO 2 emissions limits
Unit 1 Stack Parameters : Exhaust gas exits at 287° F and 1,241,257.5 acfm through an 18.1-foot diameter stack that is 400 feet tall.
Unit 2 Stack Parameters : Exhaust gas exits at 287° F and 1,241,257.5 acfm through an 18.1-foot diameter stack that is 400 feet tall.

Pursuant to Rule 62-296.340 (BART), F.A.C., the following standards represent the Best Available Retrofit Technology. These standards apply to each BART-eligible unit and are in addition to, and supplement, all other applicable standards.

CONTROL EQUIPMENT
1. Particulate Controls : As soon as practicable, but not later than December 31, 2013, the permittee shall replace the existing multi-cyclones on these units with new state-of-the-art multi-cyclones. [Rule 62-296.340 (BART), F.A.C. and Application No. 0250003-008-AC]
2. 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.]
3. Fuel Additives : The permittee shall conduct a study of fuel additives designed to reduce the formation of PM and/or improve the collection efficiency of the PM emissions in the multi-cyclones. Included with this study is the authorization to inject different types of fuel additives and to perform stack tests to demonstrate the results. [Application No. 0250003-008-AC]

BART EMISSIONS STANDARDS
4. Fuel Oil Sulfur and Sulfur Dioxide Standard : As soon as practicable, but not later than December 31, 2013, the sulfur content of the fuel fired in Units 1 and 2 shall not exceed 0.7%, by weight. Upon reduction of the sulfur content of the fuel oil, SO 2 emissions from Units 1 and 2 shall not exceed 0.77 lb/MMBtu, on a 3-hour rolling average. The sulfur dioxide emission limitation shall apply at all times including startup, shutdown, and load change. Compliance shall be demonstrated through the use of the existing continuous emissions monitoring systems (CEMS). [Rule 62-296.340 (BART), F.A.C. and Application No. 0250003-008-AC]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS Emissions Units 1 and 2 (EU-001 & -002)

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 5 of 6 5. Particulate Matter Emissions Standard : As soon as practicable, but not later than December 31, 2013, the PM emissions from Units 1 and 2 shall not exceed 0.07 lb/MMBtu of heat input on a 3-hour average, as determined by EPA Method 5 or 17. Based on the results of the fuel additive tests and upon agreement from the applicant, this limit may be further reduced to 0.05 lb/MMBtu. [Rule 62-296.340 (BART), F.A.C. and Application No. 0250003-008-AC]
6. Particulate Matter - Soot Blowing and Load Change : As soon as practicable, but not later than December 31, 2013, particulate matter emissions shall not exceed an average of 0.2 pound per million Btu of heat input, as determined by EPA Method 5 or 17, during the 3 hours in any 24-hour period of excess emissions allowed for boiler cleaning (soot blowing) and load change. [Rule 62-210.700(3) & (5), F.A.C.]
7. Opacity Standard : As soon as practicable, but not later than December 31, 2013, the visible emissions (VE) from Units 1 and 2 shall not exceed 20% opacity, based on a 12-month rolling average of all valid 6-minute opacity readings as recorded by the COMS. Excess emissions during periods of malfunction shall be excluded. In calculating the 12-month rolling opacity average, the permittee may exclude up to one percent of the total number of 6-minute averages over the relevant 12-month period. [Rules 62-4.070(3), 62-296.340 (BART) and 62-296.405(1)(a), F.A.C.]
MONITORING REQUIREMENTS
8. Continuous Emissions Monitoring Systems : Compliance with the new emissions limits for SO 2 and VE shall be demonstrated through the use of the existing acid rain required SO 2 CEMS and COMS. [Rules 62- 296.340 (BART) and 62-4.070(3), F.A.C.]

EMISSIONS PERFORMANCE TESTING
9. Testing Requirements : In addition to the following conditions, these emissions units are also subject to the requirements contained in the attached Appendix C. Standard Testing Requirements. [Rules 62-296.320 and 62-297.310, F.A.C.]
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 or 17 Determination of PM Emissions from Stationary Sources 19 Determination of SO 2 Removal Efficiency and PM, SO 2 , and NO X Emission Rates EPA Methods 1, 2, 3, 3A, 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]
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 Demonstrations : During each federal fiscal year (October 1 st to September 30 th ), the permittee shall conduct tests on Units 1 and 2 to demonstrate compliance with the BART standards for particulate matter and sulfur dioxide. Initial compliance tests for PM shall be conducted during federal fiscal year 2012/2013 and a test report demonstrating compliance with the new BART standards shall be submittedSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS Emissions Units 1 and 2 (EU-001 & -002)

Florida Power & Light Company Air Permit No. 0250003-008-AC Turkey Point Fossil Plant BART Project Page 6 of 6 before October 1, 2013. Emissions of SO 2 shall be determined continuously with data from the existing continuous emissions monitoring systems (CEMS). Information obtained during the annual CEMS Relative Accuracy Test Audit (RATA) may be used to satisfy the testing requirements for SO 2 . Compliance with the 20% rolling 12-month average opacity limit shall be calculated and recorded on site by the 15 th of each month, based on the arithmetic average of all 6-minute readings documented by the COMS during the previous 12 calendar months, excluding allowable periods of documented excess emissions as the result of a malfunction. If necessary to demonstrate compliance with the 20% average, up to 1% of the total number of 6-minute averages over the previous 12-month period may also be excluded. A summary of these calculations shall be provided with the semi-annual monitoring reports, which are required by the Title V permit. [Rules 62-204.800, 62-296.340(3)(b)2 and 62-297.310(7)(a)4, F.A.C.; and 40 CFR 60, Appendix A, Method 9]
NOTIFICATIONS, RECORDS, REPORTS AND APPLICATIONS
13. Fuel Additives Test Report : Not later than December 31, 2010, the permittee shall submit a report to the Permitting Authority describing the potential benefits, the resulting emissions increases and decreases, and the manufacturer’s safety data sheets (MSDS) for each of the different additives tested. Based on the information contained in the report, the Applicant will make a recommendation as to which additive(s) shall be used (if any) in order to reduce the PM emissions to the goal of 0.05 lb/MMBtu. [Application No. 0250003-008-AC]
14. Plant Operation - Problems : If temporarily unable to comply with any of the conditions of the permit due to breakdown of equipment or destruction by fire, wind or other cause, the permittee shall notify each Compliance Authority as soon as possible, but at least within one working day, excluding weekends and holidays. The notification shall include: pertinent information as to the cause of the problem; steps being taken to correct the problem and prevent future 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 the conditions of this permit or the regulations. [Rule 62-4.130, F.A.C.]
15. BART Alternative Permit Application : As an alternative to the SO 2 and PM limits in conditions 4 and 5, above, not later than 12/31/2011, FPL may submit an application requesting to either: repower Units 1 and 2 with natural gas-fired combustion turbines, burn only natural gas in units 1 and 2 and meet a PM emissions limit of 0.05 lb/MMBtu, or permanently shut down Units 1 and 2. [Rule 62-296.340, F.A.C.]
16. Reasonable Progress Control Technology (RPCT ): Nothing in this permit shall affect the Department’s obligations to address Reasonable Further Progress at this facility. [Rule 62-296.341, F.A.C.]
17. BART Permit Application for SO 2 and NO X : In the event that CAIR is vacated by the Federal courts, the Department reserves the right to require the submission of a BART application for SO 2 and NO X . [Rule 62- 296.340, F.A.C.]

# C. PCSREVISED TECHNICAL EVALUATION
&
PRELIMINARY DETERMINATION

PROJECT
Revised Draft Permit No. 0470002-055-AC Best Available Retrofit Technology (BART) White Springs Agricultural Chemicals, Inc. Hamilton County, Florida

APPLICANT White Springs Agricultural Chemicals, Inc.

P.O. Box 300 White Springs, Florida 32096

PERMITTING AUTHORITY
New Source Review Section Bureau of Air Regulation Division of Air Resource Management Florida Department of Environmental Protection

July 22, 2009REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 2 of 30 1. GENERAL PROJECT INFORMATION Facility Description and Location The applicant, White Springs Agricultural Chemicals, Inc., operates an existing phosphate complex, which processes phosphate rock to produce several products at the Suwannee River/Swift Creek Complex (two plants). The facility consists of one rock grinder, two phosphoric acid plants, two defluorinated phosphate (DFP) plants, one dical process, two diammonium phosphate (DAP) plants, one monoammonium (MAP)/DAP storage building, one MAP/DAP screen/shipping building, four sulfuric acid plants (SAP), two phosphoric acid filters, four superphosphoric acid plants, one green superphosphoric acid plant, the Swift Creek Mine rock dryer, and one acid clarification plant. The facility also has storage silos associated with the Swift Creek Mine and the DFP plant. The sulfuric acid is produced on-site by burning elemental sulfur, converting the resulting sulfur dioxide (SO 2 ) to sulfur trioxide (SO 3 ), and absorbing it into a recirculating sulfuric acid (H 2 SO 4 ) solution. Phosphoric acid is made by acidulation of phosphate rock with sulfuric acid. Waste gypsum is produced and stacked. The phosphoric acid is reacted with ammonia to make MAP and DAP. The phosphoric acid is reacted with limestone and other raw materials to make animal feed ingredients. The Standard Industrial Classification (SIC) code for this type of plant is SIC No. 2874. The facility is located at 15843 SE 78 th

Street, White Springs, Hamilton County. The project site is located about 25 kilometers from the Okefenokee National Wilderness Area, a Class I Area. The UTM coordinates of this facility are Zone 17; 328.3 km E; 3368.8 km N. Regulatory Categories This project is subject to the applicable environmental laws in Section 403 of the Florida Statutes (F.S.). The Florida Statutes authorize the Department of Environmental Protection (Department) to establish rules regarding air quality in the Florida Administrative Code (F.A.C.). The facility is classified according to the following major regulatory categories.

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

• The facility does not operate 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.

• The facility operates units subject to Rule 62-296.340 (BART), F.A.C., which requires a determination of the Best Available Retrofit Technology for each BART-eligible source as defined in 40 Code of Federal Regulations (CFR) 51.301. Project Description White Springs Agricultural Chemicals, Inc. submitted an application to satisfy the requirements of Rule 62- 296.340 (BART), F.A.C., which addresses the following BART-eligible emissions units (EU).

EU No. Emission Unit Description 001 # 2 Phosphate Rock Grinder 003 “A” DFP Plant 004 “X” Train (Dical Process) 008 “Y” Train - #1 MAP/DAP Plant 010 #1 MAP/DAP - Storage Building 015 MAP/DAP Shipping and Screening FacilityREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 3 of 30 EU No. Emission Unit Description 021 “C” SAP 022 “D” SAP 032 “Z” Train - #2 MAP/DAP Plant 038 “B” DFP Plant 042 DFP Feed Prep 044 “A” and “B” DFP Coolers 054 Molten Sulfur System 062 DFP Silos 064 Swift Creek Mine Rock Dryer 065 Swift Creek Mine Silos This Revised Technical Evaluation and Preliminary Determination details the project, provides the top-down BART analysis, and identifies the BART determinations. Processing Schedule 02/01/07: Department received the BART application for an air pollution construction permit. 02/13/07: Department issued 1 st Incompleteness letter. 05/01/07: Applicant requested additional 60 days to respond to Department’s 1 st Incompleteness letter. 07/03/07: Department received response to the 1 st Incompleteness letter. 07/26/07: Department issued 2 nd Incompleteness letter. 08/16/07: Department received response to the 2 nd Incompleteness letter. 09/04/07: Department received additional information; application complete. 11/13/07: Department mailed Intent to Issue and Public Notice Package. 11/16/07: Applicant requested extension of time for 30 days to file a petition for administrative hearing. 12/04/07: Department granted the applicant extension of time of 30 days to file a petition for administrative

hearing. 12/11/07: Department received substantial comments on the draft permit as well as the technical evaluation

and preliminary determination from the applicant. 01/02/08: Applicant requested second extension of time for 60 days to file a petition for administrative

hearing. 01/09/08: Department denied applicant extension of time for 60 days and provided applicant 15 days to file a

petition for administrative hearing. 01/23/08: Applicant filed a petition for formal administrative hearing. 02/04/08: Environmental Protection Agency (EPA) Region 4 submitted comments on the proposed BART

evaluation for PCS. 04/03/08: Meeting held between the Department, the applicant and their consultant to address the proposed

particulate matter limits in the BART draft permit. 05/27/08: Visit to PCS for gathering information on the BART SAP.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 4 of 30 06/03/08: Department requested information in an e-mail concerning BART SAP. 07/10/08: Applicant submitted information on the BART SAP. 09/18/08: Conference call between the Department and the applicant to further discuss the particulate matter

limits in the BART draft permit. 09/25/08: Department received applicant’s proposal for the particulate matter limits in the BART draft permit. 10/24/08: Department received proposal letter from Holland and Knight (applicant’s attorney) regarding

BART particulate matter limits and SAP. 11/05/08: Department received corrections on the 10/24/08 correspondence from Holland and Knight. 12/18/08: Department received final proposal letter from Holland and Knight on the agreement reached with

the Department for all outstanding issues related to the BART draft permit. 12/23/08: Department requested information in an e-mail concerning the applicability of Compliance

Assurance Monitoring (CAM) to the emissions units and Continuous Emission Monitoring Systems (CEMS) for the SAP. 01/20/09: Department received letter from Holland and Knight on CAM and CEMS issues. All issues related

to BART draft permit were resolved.
Comments The public notice was not published by the applicant, but comments were provided by the applicant when the draft permit package was issued by the Department. The comments were related to the Technical Evaluation and Preliminary Determination and the Draft Permit. The comments were substantial such that the Department revised certain conditions of the draft permit package. Most of the issues related to the applicant’s comments were resolved and this revised draft permit package will incorporate the agreed upon particulate matter emission limits for MAP/DAP and DFP Plants and CEMS issues concerning the sulfuric acid plants. EPA Region 4 submitted comments on draft permit which can be summarized as follows: “Department did not consider several control options for the sulfuric acid plants in the top-down BART Technical Analysis. The consideration of these control options may result in a different conclusion of an appropriate BART SO 2 emission limits for the sulfuric acid plants. In performing a BART evaluation at a sulfuric acid plant choosing to use dual absorption technology, the combination of a variety of factors including the use of cesium catalyst, catalyst loading, installation of a 5 th catalyst bed, and improving the oxygen/SO 2 ratio should be considered. Furthermore, several different scrubber options should also be considered.” Department’s Response : BART determinations are conducted on certain emission units constructed between 1962 and 1977, during which time top/down case-by-case determinations for best available control technology (BACT) were not conducted. BACT is a requirement for projects subject to the rules for the prevention of significant deterioration (PSD) promulgated by EPA in January 1975. However, since 1977 and most recently (2002-2007) sulfuric acid plants at other facilities have been subjected to reviews that resulted in the installation of control equipment or inclusion of federally enforceable emission limits characteristic of BACT. The BART process is described in 40 CFR Part 51, Appendix Y as follows: Step 1 - Identify all available retrofit control technologies; Step 2 - Eliminate technically infeasible options; Step 3 - Evaluate control effectiveness of remaining control technologies; Step 4 - Evaluate impacts and document the results; andREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 5 of 30 Step 5 - Evaluate visibility impacts. According to 40 CFR 51, Appendix Y, paragraph IV.D.9, there are circumstances under which it is not necessary to comprehensively complete each step of the BART analysis. Under such circumstances, it is allowable to skip the remaining analyses in this section, including the visibility analysis in Step 5. Furthermore, according to 40 CFR 51, Appendix Y, paragraph II.A.2, for an emissions unit which began operation within the 1962–1977 time window, but was modified (major) after August 7, 1977 such that controls were installed, the State will take this into account during the review process and may find that the level of controls already in place are consistent with BART. The applicant submitted the application on the basis of the original design and the subsequent PSD/BACT review of similar emissions units at other facilities, like CF Industries B, C and D (2004-2007) sulfuric acid plants. The Department finds that the levels of controls already in place are consistent with BART. The SAP emissions limits for SO 2 can be further reduced by slight modifications to the converter as explained in the technical document accompanying the BART permit. EPA’s comments are appreciated and duly noted, however, for future BACT determinations.

2. APPLICABLE BART REGULATIONS Regulatory Authority This project is subject to the applicable regulatory requirements in the following Chapters of the F.A.C.: 62-4 (Permitting Requirements); 62-204 (Ambient Air Quality Requirements, PSD Increments, and Federal Regulations Adopted by Reference); 62-210 (Permits Required, Public Notice, Reports, Stack Height Policy, Circumvention, Excess Emissions, and Forms); 62-212 (Preconstruction Review, PSD Review and BACT, and Non-attainment Area Review and LAER); 62-296 (Emission Limiting Standards); and 62-297 (Test Methods and Procedures, Continuous Monitoring Specifications, and Alternate Sampling Procedures). It is also subject to the applicable provisions in Title 40 of the Code of Federal Regulations as adopted in Chapter 62-204 and 62- 296, F.A.C. Specifically, this project is subject to Rule 62-296.340 (BART), F.A.C. , which requires a BART determination for each BART-eligible source as defined in 40 CFR 51.301. The state rule implements the federal provisions of Appendix Y in 40 CFR Part 51, “Guidelines for BART Determinations Under the Regional Haze Rule”. In accordance with Appendix Y in 40 CFR 51, the affected visibility-impairing pollutants include the following: nitrogen oxides (NO X ), particulate matter (PM) and sulfur dioxide (SO 2 ). With respect to particulate emissions, Rule 62-210.200, F.A.C. defines PM as, “... all finely divided solid or liquid material, other than uncombined water, emitted to the atmosphere as measured by applicable reference methods, or an equivalent or alternative method ...” Particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers is defined as PM 10 and particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers is defined as PM 2.5 . Emissions of PM, PM 10 and PM 2.5 are all regulated pollutants. For the existing emissions units and air pollution control equipment, the control strategy specified in the BART determinations directly reduces PM emissions, which serves as a surrogate to also reduce PM 10 and PM 2.5 emissions.
BART Definition Pursuant to 40 CFR 51.301, Best Available Retrofit Technology (BART) means, “... an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant which is emitted by ... [a BART-eligible source]. The emission limitation must be established, on a case-by case basis, taking into consideration the technology available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.” In accordance with Rule 62-REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 6 of 30 296.340(3), F.A.C., the Department shall determine BART for each affected source in an air construction permit. BART Analysis Procedure There are five basic steps in the case-by-case BART analysis: Step 1 . Identify all available retrofit control technologies. A comprehensive list of available technologies for analysis must be identified that includes the most stringent option and a reasonable set of available options. It is not necessary to list all permutations of available control levels that exist for a given technology. The list is complete if it includes the maximum level of control each technology is capable of achieving. Step 2 . Eliminate technically infeasible options. Control technologies are technically feasible if either (1) they have been installed and operated successfully for the type of source under review under similar conditions, or (2) the technology could be applied to the source under review. “Availability” and “applicability” are two key concepts in determining whether a technology could be applied. A technology is considered “available” if the source owner may obtain it through commercial channels, or it is otherwise available within the common sense meaning of the term. An available technology is “applicable” if it can reasonably be installed and operated on the source type under consideration. A technology that is available and applicable is technically feasible. Step 3 . Evaluate control effectiveness of remaining control technologies. There are two key issues in thisprocess, including (1) expressing the degree of control in consistent terms to ensure an “apples-toapples” comparison of emissions performance levels among options, and (2) giving appropriate treatment and consideration of control techniques that can operate over a wide range of emission performance levels. Step 4 . Evaluate the impacts and document the results. The evaluation will consider the costs of compliance, energy impacts, non-air quality environmental impacts, and remaining useful life. Step 5 . Evaluate visibility impacts. Use CALPUFF or other appropriate dispersion model to determine the visibility improvement expected at a Class I area from the potential BART control technology applied to the source. Note that if the most stringent BART control option available is selected, it is not necessary to conduct an air quality modeling analysis for the purpose of determining its visibility impacts.
BART Determination : In making a final BART determination, the following will be considered: (1) technically feasible options; (2) the average and incremental costs of each option; (3) the energy and non-air quality environmental impacts of each option; (4) the remaining useful life; and (5) the modeled visibility impacts. A justification for selecting a technology as the “best” level of control must be provided and include an explanation of these factors that led to the BART determination. When a BART determination is made for two regulated pollutants on the same source, if the result is two different BART technologies that do not work well together, it may be reasonable to substitute a different technology or combination of technologies. Revised BART-Eligible Source List The Department previously identified all BART-eligible sources through a series of notifications, workshops, and rule making efforts. To be considered BART eligible, a unit must have been constructed prior to August 7, 1977. During the processing of this application, the applicant provided additional supporting documentation that showed some of the previously identified BART-eligible emissions units were constructed after this deadline. Documentation included permit applications, correspondence, aerial photographs, etc. The following emissions units were removed from the BART-eligible source list for this facility. Emissions Units Removed from the BART-Eligible Source List for White Springs Agricultural Chemicals, Inc.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 7 of 30 EU No. Emission Unit Description 020 ‘B’ Phosphoric Acid Plant: This plant emits fluoride, which is controlled by two packed wet scrubbers. The plant is not a source of nitrogen oxides, particulate matter or sulfur dioxide emissions. Therefore, this plant should have been exempted from BART review. 034 South Phosphoric Acid Filters: This plant was constructed in 1979 and is not a BART-eligible source by definition. 035 North Phosphoric Acid Filters: This plant was constructed in 1979 and is not a BART-eligible source by definition.036 “A” and “B” Superphosphoric Acid Plants: This plant was constructed in 1978 and is not a BARTeligible source by definition. 039 “C” Auxiliary Boiler: This plant was constructed in 1979 and is not a BART-eligible source by definition. 040 “D” Auxiliary Boiler: This plant was constructed in 1979 and is not a BART-eligible source by definition. 066 “E” SAP: This plant was constructed in 1979 and is not a BART-eligible source by definition. 067 “F” SAP: This plant was constructed in 1979 and is not a BART-eligible source by definition. 068 “E” Auxiliary Boiler: This plant was constructed in 1979 and is not a BART-eligible source by definition. 069 “D” Phosphoric Acid Plant: This plant was constructed in 1978 and is not a BART-eligible source by definition.070 “C” and “D” Superphosphoric Acid Plants: This plant was constructed in 1979 and is not a BARTeligible source by definition. 071 Acid Clarification Plant: This plant was constructed in 1979 and is not a BART-eligible source by definition. 072 Molten Sulfur System for “E” and “F” Sulfuric Acid Plants: This plant was constructed in 1979 and is not a BART-eligible source by definition.

Summary of Applicant’s Initial Modeling Analysis The CALPUFF model (Version 5.756) was used to predict the maximum visibility impairment at four PSD Class I areas located within 300 kilometers (km) of the White Springs Agricultural Chemicals facility. The nearest PSD Class I area is the Okefenokee National Wilderness Area (NWA), which is located approximately 25 km from the facility at the closest point. The other three Class I areas are: the St. Marks NWA, which is located approximately 142 km from the facility; the Wolf Island NWA, which is located approximately 172 km from the facility; and the Chassahowitzka NWA, which is located approximately 202 km from the facility. The CALPUFF modeling analysis followed the Visibility Improvement State and Tribal Association of the Southeast(VISTAS) common protocol, version 3.2. The Department provided the applicant with 4-km “CALPUFFready” CALMET meteorological data for the period 2001-2003. Class I receptor locations were obtained from the National Park Service (NPS) and a Lambert Conformal Conic (LCC) coordinate system was used. For the BART-eligible sources, the PM/PM 10 , SO 2 , H 2 SO 4 and NO X emission rates were determined from either stack test data or from proposed permit limits to reflect the maximum 24-hour average normal operation for the most recent 3 to 5 years. Emission rates of SO 2 , H 2 SO 4 and NO X were input directly into the CALPUFF model while the six particulate species in specific size categories were modeled as a unit emission rate of 1 gram/second and then scaled for each source by using the POSTUTIL program. CALPOST method 6 was used to compute the extinction change (visibility impairment) in deciviews (dv) consistent with procedures outlined in the VISTAS modeling protocol.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 8 of 30 Based on the 24-hour visibility impairment values for 2001 to 2003, the 8 th highest (98 th

percentile) and the 22 nd highest values were determined. The Class I area with the highest predicted impacts is the Okefenokee NWA, which is the nearest to the facility. The maximum predicted impact is 3.065 dv. The 8 th highest visibility impairment value for each of the three years is over the comparison threshold of 0.50 dv. The 22 nd highest impairment is also over this value. In addition, there are 87, 93 and 91 days (2001 to 2003) predicted to have visibility impairment over 0.5 dv. These impacts may be higher because the applicant underestimated maximum SO 2 emission rates for the two BART-eligible sulfuric acid plants. The applicant conducted one set of CALPUFF modeling runs and did not compare pre-control with post-control permit limits.

3. BART ANALYSIS FOR PARTICULATE-ONLY EMISSIONS UNITS This section provides the control technology review for BART-eligible emissions units that only emit particulate matter. All of these emissions units at the Suwannee River/Swift Creek Complex have existing control equipment. Many of these types of controls have been identified as the “top control option” for similar units within this industry, which satisfies Steps 1 through 4 in the BART analysis. In addition, it is not necessary to determine the visibility impacts if the top control is selected as BART. Baghouse Controls Baghouses use fabric materials to mechanically filter out particulate from an exhaust stream. These devices are capable of control efficiencies greater than 99.9%. As discussed in EPA’s Air Pollution Control Technology Fact Sheet for Fabric Filters (EPA-452/F-03-025), “... Well-designed and operated baghouses have been shown to be capable of reducing overall particulate emissions to less than 0.05 grams/m 3 (0.010 grains/ft 3 ), and in a number of cases, to as low as 0.002 to 0.011 grams/m 3 (0.001 to 0.005 grains/ft 3 ).” With regard to controlling emissions of particulate matter, baghouses are generally considered the top controls along with electrostatic precipitators. Therefore, Steps 1 through 4 of the BART analysis are satisfied and it is not necessary to determine the visibility impacts. #2 Phosphate Rock Grinder (EU-001) The #2 phosphate rock grinder has a maximum 1-hour capacity of 45 tons/hour of rock. Emissions of particulate matter from this unit are currently controlled by a baghouse. From the original air construction permit and Rule 62-297.620, F.A.C., the current emissions standards are 22.03 lb/hour (96.5 tons per year) and less than 5% opacity from the baghouse exhaust. The initial test in 1976 showed actual emissions of 0.16 lb/hour based on the installed control equipment and the plant accepted a 5% opacity limit in lieu of annual stack testing. Based on the test data and unlimited operation (8760 hours per year), actual annual emissions are estimated to be 1.3 tons/year from the rock grinder. The baghouse is recognized as a top control option for controlling particulate matter. Therefore, the Department establishes the following BART determinations: Visible emissions from the baghouse exhaust shall not exceed 5% opacity as determined by EPA Method 9. Bags in the baghouse control system shall be selected based on a design outlet specification of 0.01 grains per actual cubic feet of exhaust. Compliance shall be demonstrated by conducting annual visible emissions tests and maintaining records of the vendor data sheets demonstrating compliance with the baghouse specification. At a maximum volumetric flow rate of 5533 actual cubic feet per minute (acfm), the potential emissions would be reduced from 96.5 to 2.1 tons/year. X-Train Dical Process (EU-004) In the X-Train dical process, limestone reacts with phosphoric acid in a pug mill. The resulting slurry is then dried in a direct contact rotary dryer fired with natural gas or fuel oil. The rotary dryer in the X-Train is controlled by a system of wet venturi and cyclonic scrubbers, which is discussed in a subsequent section. The dried solids are then screened to remove on-size product. The product size material is conveyed to storage. The over-sized and under-sized materials are crushed and recirculated to the pug mill. The following tableREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 9 of 30 summarizes the particulate matter emissions, controls and limits for each emissions point.
Summary of Emissions Points and Existing PM Limits for the X-Train Dical Process (EU-004) a

EU-004 EP No. Description Controls PM Emissions b Current Standards lb/hour tons/year 02 Dedust Bin Baghouse 3.2 11.6 5% opacity 03 Shipping Area Baghouse 2.3 8.4 5% opacity 04 Limestone Silo Baghouse 0.77 2.8 5% opacity 05 Reclaim Bin Baghouse 0.77 2.8 5% opacity 06 Material Handling Baghouse 5.1 18.0 5% opacity

a. This area also includes a direct contact rotary dryer with wet venturi and cyclonic scrubbers (EP-01), which is reviewed later in Section 4 with other combustion sources.

b. The potential PM emissions rates are based on Permit No. 0470002-039-AC. The baghouse is recognized as a top control option for controlling particulate matter. Therefore, the Department establishes the following BART determinations: Visible emissions from the baghouse exhaust shall not exceed 5% opacity as determined by EPA Method 9. Bags in the baghouse control system shall be selected based on a design outlet specification of 0.01 grains per actual cubic feet of exhaust. Compliance shall be demonstrated by conducting annual visible emissions tests and maintaining records of the vendor data sheets demonstrating compliance with the baghouse specification. DFP Feed Prep (EU-042) The DFP Feed Prep consists of: the feed prep area where the limestone, phosphate rock and other ingredients are mixed; the soda ash storage and handling system; and a limestone handling system. The soda ash system consists of a pneumatic transfer system that conveys soda ash from a vacuum railcar unloading hopper to a 330 ton storage silo. From this silo, soda ash is then transferred to a 20 ton soda ash bin/day tank. The limestone handling system consists of unloading limestone via truck into a 50 ton storage silo to a 3 ton limestone surge bin. These activities include the following emissions points (EP) and associated controls. Summary of Emissions Points and Existing PM Limits for DFP Feed Prep (EU-042)*

EU-042 EP No. Description Controls Hours/Year PM Emissions PTE, tons/year Current Standards
01 Rock Bin Baghouse 8760 < 1 5% opacity 02 Miscellaneous Baghouse 8760 < 1 5% opacity 03 Lime Silo Baghouse 8760 0.44 0.10 lb/hour and 5% opacity 04 Lime Bin Bin Filter 8760 0.44 0.10 lb/hour and 5% opacity 06 Soda Ash Silo Baghouse 1800 0.23 0.25 lb/hour and 5% opacity 07 Soda Ash Bin Bin Filter 2700 0.027 0.02 lb/hour and 5% opacity * The DFP Feed Prep also includes a dryer with wet scrubber (EP-05) that is reviewed later in Section 4 with other combustion sources. Although PM emissions standards are specified for EU-003, EU-004, EU-006 and EU-007, the plant has accepted a 5% opacity limit to avoid annual stack testing. As shown, the overall emissions from these activitiesREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 10 of 30 are relatively small based on the existing controls. The baghouse is recognized as a top control option for controlling particulate matter. Therefore, the Department establishes the following BART determination: Visible emissions from the baghouse exhaust shall not exceed 5% opacity as determined by EPA Method 9. Bags in the baghouse control system shall be selected based on a design outlet specification of 0.01 grains per actual cubic feet of exhaust. Compliance shall be demonstrated by conducting annual visible emissions tests and maintaining records of the vendor data sheets demonstrating compliance with the baghouse specification. DFP Product Silos (EU-062) Emissions of particulate matter from the DFP Product Silos are controlled by five baghouses at the followingemissions points: product sizing/crushing (EP-14); and silo A, silo B, silo C and the shipping operations (EP16). The total potential emissions of particulate matter from this emissions unit are 3.75 tons per year. The current emissions standard for all points is a limit of 5% opacity on the baghouse exhaust. The baghouse is recognized as a top control option for controlling particulate matter. Therefore, the Department establishes the following BART determinations: Visible emissions from the baghouse exhaust shall not exceed 5% opacity as determined by EPA Method 9. Bags in the baghouse control system shall be selected based on a design outlet specification of 0.01 grains per actual cubic feet of exhaust. Compliance shall be demonstrated by conducting annual visible emissions tests and maintaining records of the vendor data sheets demonstrating compliance with the baghouse specification. Wet Control Equipment for Particulate Matter No. 1 Storage/Shipping Building (EU-010) and MAP/DAP Shipping Facility (EU-015) Emissions of particulate matter are generated by the screening, handling and storage of products in the No. 1 Storage/Shipping Building and the MAP/DAP Shipping Facility. Each emissions unit is controlled by a wet scrubber due to the hygroscopic nature of the products (Monocal, Dical, DFP, DAP and MAP). These products absorb moisture and will plug the fabric materials used in a baghouse. Consequently, wet scrubbing is the appropriate control technology for these activities. The estimated control efficiency for the existing wet scrubbers is greater than 95%. The following table summarizes the emissions and controls for these units. Summary of Current PM Limits for EU-010 and EU-015

EU No. Controls Hours/Year PM Emissions tons/year Current Standards

010 wet scrubber 8760 158.42 36.17 lb/hour and 5% opacity 015 cyclone with wet venturi scrubber 8760 177.00 40.41 lb/hour and 5% opacity
The above emissions limits are very high and based on regulation by the process weight table in Rule 62- 296.320, F.A.C. However, annual testing is conducted to demonstrate compliance. The following table summarizes actual particulate matter emissions from these units based on recent stack test data.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 11 of 30 Summary of PM Test Data for EU-010 and 015

Date EU-010 Date EU-015

lb/hour lb/hour
9/21/1978 2.4 9/24/1976 0.29
4/26/1979 5.96 9/26/1980 1.48
1/15/1980 9.3 10/18/1984 0.3
5/15/1980 9 8/20/1987 0.52
6/26/1985 4.88 9/28/1988 0.59
8/19/1987 10.39 12/6/1989 1.08
10/12/1988 4.11 9/6/1990 1.16
10/19/1989 1.73 11/20/1991 1.15
9/28/1990 1.43 8/26/1992 0.24
11/7/1991 6.18 7/27/1995 1.28
11/12/1992 1.7 6/28/1996 1.15
2/15/1995 1.37 9/13/2000 0.27
6/28/1996 1.15 2/11/2005 0.6
7/18/1997 1.48
12/9/1998 0.44 12/9/1999 0.25
8/21/2000 0.45
9/26/2002 1.09
10/8/2003 0.85
11/10/2004 0.24
12/7/2005 0.35
3/29/2006 0.41
4/4/2007 0.38
A statistical analysis using the available data indicates the following emissions rate for the No. 1 Storage/Shipping Building (EU-010) based on a 99% confidence interval. No. 1 Storage/Shipping Building (EU-010): 4.7 lb/hour (equivalent to 20.6 tons/year) The PM emission rate for the MAP/DAP Shipping facility (EU-015) was negotiated with PCS (Holland and Knight Letter dated December 16, 2008) and the proposed limit was agreed to be: MAP/DAP Shipping Facility (EU-015): 1.46 lb/hour (equivalent to 6.45 tons/year) As shown, actual emissions are much lower than the permitted emissions limits and reflect good control by the installed wet scrubbers. Therefore, the Department will establish the above emissions rates as the BART determinations for these units. Potential emissions of particulate matter will be reduced: from 158 to 20.6 tons per year for the No. 1 Storage/Shipping Building (EU-010); and from 177 to 6.45 tons per year for the MAP/DAP Shipping Facility (EU-015). These units are not subject to the Compliance Assurance Monitoring (CAM) plan.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 12 of 30 ‘A’ and ‘B’ DFP Coolers (EU No. 044) Emissions of particulate matter from the ‘A’ and ‘B’ DFP Coolers are controlled by a cyclonic wet scrubber that exhausts through a common stack. For a wet gas stream, baghouse is not a feasible control technology because of plugging and blinding of the fabric bags. The current emissions limits for particulate matter are 25.04 lb/hr and 105.17 tons per year. Annual testing is conducted to demonstrate compliance with the standards. The following table summarizes actual particulate matter emissions from these units based on recent stack test data. Summary of PM Test Data for EU-044

Date Tested Emissions

lb/hour (EU-044)
2/13/1985 5.82
2/26/1986 8.76
2/25/1987 8.09
12/16/1987 2.79
2/23/1989 16.457*
3/10/1989 8.054
2/8/1990 5.114
8/14/1991 14.56
2/12/1992 8.28
4/7/1993 7.495
3/31/1994 5.94
3/8/1995 8.79
3/8/1996 9.65
3/7/1997 8.65
3/25/1998 7.33
3/29/2000 10.39
3/15/2001 12.77
4/3/2002 8.99
2/26/2003 16.11
4/28/2004 14.15
3/3/2005 20.9
* This test result appeared high and apparently failed. It was not included in the statistical analysis.
A statistical analysis using the available data indicates an emissions rate of 12.3 lb/hour (equivalent to 53.9 tons/year) based on a 99% confidence interval. As shown, actual emissions are much lower for most of the years than the permitted emissions limits and reflect good control by the installed wet scrubbers, but a limit of 12.3 lb/hour would result in non-compliance in four of the last five years. Therefore, the Department used Monte Carlo analysis as an alternate method in establishing an acceptable emission rate limit for the ‘A’ and ‘B’ DFP Coolers (EU-044). The Monte Carlo analysis is described further below. Monte Carlo AnalysisREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 13 of 30 As an alternate method to establishing an acceptable emissions rate limit, the probability distribution of the above results of actual PM emissions based on annual stack testing for Unit 44 at the plant was used as input into a Monte Carlo simulation over a 33-year time horizon. A Monte Carlo method is a computational algorithm that relies on repeated random sampling to compute its results. Monte Carlo methods are often used when simulating physical and mathematical systems. Cursory review of current scientific literature reveals common use of the technique in environmental studies. Department licensed Microsoft Excel software was used to do the computations. The results of the analysis follow.

Unit 44

0 1 2 3 4 5 6 7 8

2 4 6 8 10 12 1 4 1 6 1 8 2 0 Mo re

Pounds per Hour Frequency Unit 44 33 Year Simulation

0 1 2 3 4 5 6 7

2 4 6 8 10 12 14 16 1 8 2 0 M o re

Pounds per Hour Frequency

Conclusion Based on the Monte Carlo simulation exercise, the proposed limit for PM for EU 044 (‘A’ and ‘B’ DFP coolers) is determined as 17.5 lb/hr (equivalent to 76.7 tons/year). Therefore, the Department will establish this emissions rate as the BART determination for the ‘A’ and ‘B’ DFP Coolers. Potential emissions of particulate matter will be reduced from 105 to 76.7 tons per year. This unit is not subject to the CAM plan. Swift Creek Mine Silos (EU No. 065) The Swift Creek Mine silos store raw materials. A wet scrubber is used to control particulate matter emissions from the silos and conveyor system. The existing wet scrubber is the appropriate control technology for the nature of the material handled and the specific process design used to capture the raw material in the scrubber water. The permitted PM emissions limit is 46.40 lb/hour (equivalent to 203.20 tons/year). This emissions limit is based on regulation by the process weight table in Rule 62-296.320, F.A.C. However, annual testing is conducted to demonstrate compliance. The following table summarizes actual particulate matter emissions from these units based on recent stack test data.
Summary of PM Test Data for EU-065

Date Tested Emissions

lb/hour (EU-065)
7/1/1999 0.97
6/1/2000 0.67
5/30/2001 1.38
6/11/2002 2.13
5/14/2003 4.67
7/7/2004 3.08
2/9/2005 6.32 A statistical analysis using the available data indicates an emissions rate of 5.7 lb/hour (equivalent to 25 tons/year) based on a 99% confidence interval. The PM emission rate for the Swift Creek Mine Silos (EU-065)REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 14 of 30 was negotiated with PCS (Holland and Knight Letter dated December 16, 2008) and the proposed limit was agreed to be 6.27 lb/hour (equivalent to 27.5 tons/year).
As shown, actual emissions are much lower (except for one year) than the proposed emissions rate and reflect good control by the installed wet scrubbers. Therefore, the Department will establish 6.27 lb/hour as the PM BART determination for the Swift Creek Mine Silos (EU-065). Potential emissions of particulate matter will be reduced from 203 to 27.5 tons per year. This unit is not subject to the CAM plan.

4. BART ANALYSIS FOR COMBUSTION SOURCES ‘A’ DFP Plant (EU-003) and ‘B’ DFP Plant (EU-038) There are two existing plants (‘A’ and ‘B’) for the production of defluorinated phosphate (DFP). Emissions of particulate matter and sulfur dioxide from these plants are controlled by separate cross-flow packed wet scrubbers utilizing caustic solutions. Only natural gas is fired in these plants.
NOx Emissions Based on Annual Operating Reports from 2002 to 2006, the highest reported estimated NO X emissions, based on AP-42 and other factors, were 29 tons/year from the ‘A’ DFP Plant and 29 tons/year from the ‘B’ DFP Plant. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective non-catalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the BART determination is the current combustion design and the sole firing of natural gas.
PM Emissions The estimated particulate matter control efficiency for the cross-flow packed wet scrubber is greater than 95%. The current PM emissions limits for each plant are 14.05 lb/hour (equivalent to 59 tons per year). The following table summarizes actual particulate matter from each plant based on stack test data. Summary of Tested PM Emissions from ‘A’ and ‘B’ DFP Plants

‘A’ DFP Plant (EU-003) ‘B’ DFP Plant (EU-038)
Test Date lb/hour Test Date lb/hour
8/10/1978 4.7 5/31/1985 11.63
4/10/1985 11.82 10/9/1985 7.64
11/20/1985 7.12 5/12/1986 10.18
4/23/1986 7.16 4/1/1987 6.2
10/1/1986 14.46* 10/1/1987 10.72
3/11/1987 10.09 3/16/1988 10.05
5/6/1987 9.34 11/3/1988 8.04
10/14/1987 8.67 8/9/1989 7.89
6/8/1988 11.97 3/21/1990 5.24
12/7/1988 6.66 9/13/1990 8.66
8/3/1989 7.54 5/1/1991 9.6
6/5/1990 7.04 10/23/1991 6.46
12/12/1990 8.15 5/20/1992 7.47 5/1/1991 9.67 3/10/1993 11.51
9/26/1991 6.63 3/31/1993 9.25REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 15 of 30 ‘A’ DFP Plant (EU-003) ‘B’ DFP Plant (EU-038)
Test Date lb/hour Test Date lb/hour
3/20/1992 7.51 11/10/1993 6.47
9/23/1992 10.42 5/4/1995 13.14
5/12/1993 10.46 2/23/1996 11.84
4/27/1994 7.91 2/26/1997 7.04
3/1/1995 7.91 3/4/1998 10.88
2/14/1996 6.8 3/31/1999 10.55
11/21/1996 8.05 3/31/1999 1.7 #
11/19/1997 11.08 2/21/2001 6.43
10/7/1998 13.88 2/1/2002 7.82
10/7/1999 10.94 4/30/2003 9.46
2/24/2000 8.37 6/9/2004 7.94
11/15/2000 7.83 5/25/2005 11.06
3/21/2001 6.28
4/17/2002 13.26
5/7/2003 8.3
6/23/2004 8.12
6/15/2005 6.56
* This test result appeared high and apparently failed. It was not included in the statistical analysis. # This test result was obtained at less than permitted capacity and was not included in the statistical analysis. A statistical analysis using the available data based on a 99% confidence interval indicates an emissions rate of 9.8 lb/hour for the ‘A’ DFP Plant and 10.1 lb/hour for the ‘B’ DFP Plant. The Department considered an emission limit of 10.1 lb/hour for both the emission units. As shown, actual emissions are much lower for most of the years than the permitted emissions limits and reflect good control by the installed wet scrubbers, but a limit of 10.1 lb/hour would have resulted in non-compliance in quite a few years. Therefore, the Department used Monte Carlo analysis as an alternate method in establishing an acceptable emission rate limit for the ‘A’ and ‘B’ DFP Plant (EU-003 and EU-038, respectively). The Monte Carlo analysis is described further below. In addition, the following Best Available Control Technology (BACT) determinations were made within the last ten years for two similar animal feed supplement plants at other facilities in Florida.

• PSD-FL-315 issued on November 21, 2001 to Cargill Fertilizer Riverview facility for the animal feed ingredient plant (13 lb/hour);

• PSD-FL-244 issued on September 11, 1998 to IMC New Wales facility for the multifos plant (14.3 lb/hour); and

• PSD-FL-234 issued on June 12, 1997 to Cargill Fertilizer Riverview facility for the animal feed ingredient plant (6 lb/hour). In each of the above projects, cross-flow packed wet scrubbers were the basis of the BACT determinations for controlling emissions of fluorides and particulate matter. At the actual controlled emissions levels identified by the test data for these units, add-on controls are not believed to be cost effective. Monte Carlo AnalysisREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 16 of 30 As an alternate method to establishing an acceptable emissions rate limit, the probability distribution of the above results of actual PM emissions based on annual stack testing for Unit 3 and Unit 38 at the plant was used as input into a Monte Carlo simulation over a 33-year time horizon. The results of the analysis follow.

PCS Unit 3

0 1 2 3 4 5 6 7

Pound s per Hour Frequency Uni t 3 33 Y ear Si mul at i on

0 1 2 3 4 5 6 7

P o u n d s p e r H o u r Fr equency

PCS 38

0 1 2 3 4 5 6 7

1 3 5 7 9 11 13 More

lbs/hrfrequency Frequency PCS 38 33 year simulation

0 2 4 6 8 10 12

1 3 5 7 9 11 13 M o re

lbs/hrfrequency Frequency

Conclusion Based on the Monte Carlo simulation exercise, the proposed limit for PM for both EU 003 and EU 038 (DFP Plant) is determined as 12.8 lb/hr. Potential emissions of particulate matter will be reduced from 59 to 56 tons per year. SO 2 Emissions
The current SO 2 emissions limit for each plant is 8.0 lb/hour (equivalent to 35 tons per year). Annual testing is conducted to demonstrate compliance with the limits. The following table summarizes actual particulate matter from each plant based on stack test data. Summary of Tested SO 2 Emissions from ‘A’ and ‘B’ DFP Plants
‘A’ DFP Plant (EU-003) ‘B’ DFP Plant (EU-038)
Test Date lb/hour Test Date lb/hour
12/11/97 0.294 02/26/97 0.042
10/07/98 0.639 03/04/98 0.218 10/07/99 0.638 03/31/99 0.395
02/24/00 0.197 02/21/01 0.045
11/15/00 0.211 02/01/02 0.371
03/21/01 0.227 05/08/03 0.570
04/17/02 0.234 --- --- 05/09/03 0.477 --- ---REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 17 of 30 These emissions rates are much lower than the current SO 2 emissions limits based on the installed controls. Actual emissions are approximately one-tenth of the permitted levels. A statistical analysis using the available data indicates an emissions rate of 1 lb/hour based on a 99% confidence interval. The data indicates that the existing cross-flow packed wet scrubber utilizing caustic solutions is effective in controlling sulfur dioxide. As previously mentioned in the discussion regarding PM emissions, a BACT determination was made for the IMC New Wales facility in 1998, which also included an SO 2 BACT determination of 8.7 lb/hour (based on a cross flow packed wet scrubber utilizing caustic solution for greater than 98% SO 2 removal). This recent determination recognizes this technology as a top control. Based on the actual SO 2 emissions levels, add-on control equipment (e.g., wet flue gas desulfurization, hydrated lime injection, etc.) may be feasible, but would not be cost effective. Therefore, the Department establishes the following BART determinations for the ‘A’ and ‘B’ DFP Plants. Sulfur dioxide emissions shall not exceed 2.0 lb/hour as determined by EPA Method 6 or 6C. To minimize sulfur dioxide emissions, only natural gas shall be fired in these units. Potential emissions of sulfur dioxide will be reduced from 35 to 9 tons per year. X-Train Dical Process (EU-004), Rotary Dryer In the X-Train dical process, limestone reacts with phosphoric acid in a pug mill. The resulting slurry is then dried in a direct contact rotary dryer, which fires natural gas as the primary fuel and fuel oil with a maximum sulfur content of 1.5% by weight as a backup fuel. The X-Train produces dicalcium phosphate (Dical) in one of two modes: 18.5% phosphorous (Mode 1) and 21.0% phosphorous (Mode 2). The combustion of fossil fuels generates emissions of particulate matter, nitrogen oxides and sulfur dioxide.
NOx Emissions Based on Annual Operating Reports from 2002 to 2006, the highest reported estimated NO X emissions, based on AP-42 and other factors, were 18 tons/year. Only natural gas was fired. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective non-catalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the BART determination is the current combustion design and the firing of natural gas as the primary fuel.
PM Emissions Particulate matter emissions from the rotary dryer are controlled by a series of wet venturi and cyclonic scrubbers. The current PM emissions limits for the rotary dryer are 46.11 lb/hour (equivalent to 202 tons/year) for Mode 1 and 45.11 lb/hour (equivalent to 198 tons/year) for Mode 2. Annual testing is conducted to demonstrate compliance. The following table summarizes actual particulate matter emissions from these units based on recent stack test data in both modes. Summary of Tested PM Emissions from X-Train (EU-004), Rotary Dryer
Test Date lb/hour (EU-004)
8/30/1978 7.37
3/11/1982 12.33
5/23/1985 13.63
3/5/1987 2.65
2/25/1988 6.82
9/9/1988 6.82
3/15/1989 6.08REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 18 of 30 Test Date lb/hour (EU-004)
4/5/1990 8.02
7/26/1990 9.26
3/6/1991 9.98
3/6/1992 4.74
5/27/1992 8.57
6/9/1993 8.15
12/22/1993 11.27
6/15/1994 8.96
5/12/1995 7.74 12/19/1995 14.46
5/8/1996 7.13
7/17/1996 11.47
5/22/1997 9.77
10/22/1997 15.02
7/9/1998 6.91
11/18/1998 8.38
7/15/1999 6.78
4/11/2000 13.3
6/29/2000 6.78
2/14/2001 12.21
3/27/2002 10.01
3/13/2003 24.71
4/8/2004 10.8
5/5/2005 12.48
10/12/2006 16.01
2/14/2007 12.36
10/17/2007 6.44 In general, these emissions rates are lower than the current PM emissions limits and reflect the capabilities of the installed wet venturi and cyclonic scrubbers. A statistical analysis using the available data indicates an emissions rate of 11.8 lb/hour based on a 99% confidence interval. The PM emission rate for the X-Train rotary dryer (EU-004) was negotiated with PCS (Holland and Knight Letter dated December 16, 2008) and the proposed limit was agreed to be 18 lb/hour (equivalent to 78.8 tons/year). In November of 2000, the Department issued a BACT determination (PSD-FL-297) for this unit to increase the production rate of the X-Train from 45 to 55 tons per hour of product. Later, the applicant decided not to implement the production increase due to market conditions. However, in this determination, the Department considered the existing control equipment as the basis for a BACT standard of 22.04 lb/hour and 96.5 tons per year of particulate matter.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 19 of 30 Based on the recent BACT determination for this unit and the actual controlled emissions levels, the existing scrubbing system is recognized as a top control option for the rotary dryer. Therefore, the Department establishes the following PM BART determination. Particulate matter emissions from the X-Train rotary dryer (all modes) shall not exceed 18 lb/hour as determined by EPA Method 5. Potential emissions of particulate matter will be reduced from 400 to 79 tons per year. This unit is not subject to the CAM plan.
SO 2 Emissions
The current SO 2 emissions limits for the rotary dryer are 11.1 lb/hour (equivalent to 48.62 tons/year). Records based on the Annual Operating Reports show that only natural gas has been fired since 1985. Based on the actual SO 2 emissions levels, add-on control equipment (e.g., wet flue gas desulfurization, hydrated lime injection, etc.) may be feasible, but would not be cost effective. Therefore, the BART determination for SO 2 emissions is: Natural gas shall be fired as the primary fuel in the X-Train dryer. Fuel oil with a maximum sulfur content of 1.5% by weight shall only be fired as a backup fuel when the vendor is unable to provide natural gas. Y-Train No. 1 DAP/MAP Plant (EU-008) In the Y-Train DAP/MAP Plant, DAP fertilizer may be produced by two different modes and MAP fertilizer may be produced by three different modes. The plant operates in only one mode at a time. The plant is currently producing MAP by reacting ammonia and phosphoric acid in two pipe reactors. The plant consists of two separate pipe reactors, a tank reactor for other modes, two pug mills, a granulator, a dryer, a cooler, screens, mills, and other associated equipment. Natural gas is fired in the dryer as the primary fuel and fuel oil with a maximum sulfur content of 1.5% by weight may be fired as a backup fuel. Emissions of particulate matter, fluoride and SO 2 are controlled by cyclones, venturi scrubbers and cyclonic scrubbers. Emissions from the pipe reactors are vented to the reactor scrubber for ammonia removal and then to a pond water scrubber for fluoride control.
NOx Emissions Based on Annual Operating Reports from 2002 to 2006, the highest reported estimated NO X emissions, based on AP-42 and other factors, were 6 tons/year. Only natural gas was fired. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective non-catalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the BART determination is the current combustion design and the firing of natural gas as the primary fuel.
PM Emissions The current particulate matter emissions limits for the Y-Train No. 1 DAP/MAP Plant are:

• PM (DAP production): 33.33 lb/hour (equivalent to 146 tons/year); and

• PM (MAP production): 45.15 lb/hour (equivalent to 198 tons/year). The PM emissions limits are very high and based on regulation by the process weight table in Rule 62-296.320, F.A.C. However, annual testing is conducted to demonstrate compliance. The following table summarizes actual particulate matter emissions from these units based on recent stack test data. Summary of Tested PM Emissions from the Y-Train DAP/MAP Plant (EU-008)REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 20 of 30 Tested PM Emissions (EU-008), lb/hour
Test Date DAP MAP
2000 4.46 ---
2001 Down ---
2002 Down ---
2003 3.33 ---

2004 Down 3.44 4.26 5.70
2005 11.46 Down

2006 Down 3.2 3.81 4.37

2007 Down 1.18 1.96 2.22
These emissions rates are much lower than the current PM emissions limits based on the installed controls. Using all of the above data, a statistical analysis indicates an emissions rate of 6.5 lb/hour based on a 99% confidence interval. The PM emission rate for the Y-Train DAP/MAP Plant (EU-008) was negotiated with PCS (Holland and Knight Letter dated December 16, 2008) and the proposed limit was agreed to be 9.2 lb/hour (equivalent to 40 tons/year). The same limit was also established for the Z-Train DAP/MAP Plant (EU-038). In addition, several similar DAP/MAP Plants at other facilities in Florida have been subject to PSD preconstruction review. All of the BACT determinations were based on the use of venturi scrubbers and cyclonic scrubbers for particulate control. Therefore, the Department recognizes this equipment as a top control option and establishes the following BART standards. PM (MAP/DAP production): 9.2 lb/hour (equivalent to 40 tons/year) This limit would apply for all modes of operation. Total potential PM emissions will be reduced from 198 to 40 tons/year.
SO 2 Emissions
The current SO 2 emissions limits for the dryer are 11.1 lb/hour (equivalent to 49) tons/year, which appear to be based on fuel oil firing. However, no testing is required. Natural gas is fired as the primary fuel. Fuel oil with a maximum sulfur content of 1.5% by weight is authorized as a backup fuel. A review of the fuel usage for the years 2000-2006 for the Y-Train indicates that only natural gas was fired. Natural gas that contains negligible amounts of sulfur would generate little sulfur dioxide. Based on the actual SO 2 emissions levels, add-on control equipment (e.g., wet flue gas desulfurization, hydrated lime injection, etc.) may be feasible, but would not be cost effective. Therefore, the Department establishes the following BART determination. To control sulfur dioxide emissions from the Y-Train dryer, natural gas shall be fired as the primary fuel. If the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.5% by weight may be fired as a backup fuel. “C” and “D” Sulfuric Acid Plants (EU-021 and EU-022) The ‘C’ and ‘D’ sulfuric acid plants are sulfur-burning double absorption processes. This is the most common process for producing sulfuric acid in the U.S. phosphate fertilizer industry and it continues to be improved andREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 21 of 30 employed at both existing and new installations in the U.S. and throughout the world. These plants generate NO X and SO 2 emissions from the burning of sulfur.
NO X Emissions Based on Annual Operating Reports, estimated NO X emissions were last reported in 2000 as 60 tons/year for each of the sulfuric acid plants. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective non-catalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the Department establishes the following BART determination. Nitrogen oxides emissions (expressed as NO 2 ) from the ‘C’ and ‘D’ Sulfuric Acid Plants (EU-021 and EU022) shall not exceed 0.14 lb/ton of 100% acid produced as determined by EPA Method 7E upon request by the Department.
PM Emissions For regulated sulfuric acid plants, particulate matter is generally minimized by controlling sulfuric acid mist. For new sulfuric acid plants, Rule 62-296.402, F.A.C. and New Source Performance Standards (NSPS) Subpart H, limits sulfuric acid mist emissions to 0.15 lb/ton of 100% sulfuric acid produced and less than 10% opacity. The ‘C’ and ‘D’ Sulfuric Acid Plants (EU-021 and EU-022) are subject to these standards and a Brinks mist eliminator is used to reduce sulfuric acid mist emissions. Therefore, the Department establishes the following PM BART determination. Visible emissions from the ‘C’ and ‘D’ Sulfuric Acid Plants shall not exceed 10% opacity as determined by EPA Method 9.
SO 2 Emissions Permitted sulfur dioxide emissions are 4.0 lb/ton (383.33 lb/hour) based on a 3-hour CEMS average (equivalent to 1679 tons/year). The double absorption process controls SO 2 emissions and a high efficiency mist eliminator controls sulfuric acid mist emissions. There are four recent SO 2 BACT determinations for three similar plants at other facilities in Florida:

• PSD-FL-355 issued on July 23, 2007 to CF Industries, Inc. for the sulfuric acid and phosphoric acid plants (3.5 lb/ton, 3-hour CEMS average);

• PSD-FL-339 issued on June 1, 2004 to CF Industries, Inc. for the C & D sulfuric acid plants (3.5 lb/ton, 3- hour CEMS average);

• PSD-FL-325 issued on July 12, 2002 to IMC Phosphates, Inc. New Wales facility for Nos. 1, 2 and 3 sulfuric acid plants (3.5 lb/ton on a 24-hour CEMS average and 4.0 lb/ton on a 3-hour average); and

• PSD-FL-315 issued on November 21, 2001 to Cargill Fertilizer Riverview facility for #8 and 9 sulfuric acid plants (3.5 lb/ton on a 24-hour CEMS average and 4.0 lb/ton on a 3-hour average). In Permit No. PSD-FL-355 above, the BACT determination was for a single absorption plant where the plant accepted the BACT standard based on a double absorption process. The remaining projects concluded BACT to be the use of double absorption process for SO 2 emissions. Therefore, the Department recognizes this equipment as a top control option. In addition, the Department reviewed CEMS data for the two plants for the period 1/1/2006 through 12/31/2006. The CEMS data indicates that the plants consistently achieved an emissions rate of 3.5 lb/ton with few excursions above this level while operating near the permitted production rates. Therefore, the Department establishes the following BART standard based on the use of double absorption process for each plant. Sulfur dioxide emissions from the ‘C’ and ‘D’ Sulfuric Acid Plants shall not exceed 3.5 lb/ton (335.4 lb/hour) based on a 24-hour CEMS rolling average.
Since the CEMS data indicates that there were some instances of SO 2 emissions greater than 3.5 lb/ton, theREVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 22 of 30 applicant may need to modify the plants (e.g., add catalyst, replace catalyst, increase the size of the converter, etc.). However, with an effective date of 2013, this is readily achievable. Potential SO 2 emissions will be reduced from 1679 to 1469 tons/year. Z-Train No. 2 DAP/MAP Plant (EU-032) In the Z-Train DAP/MAP Plant, DAP fertilizer may be produced by two different modes and MAP fertilizer may be produced by two different modes. The plant is currently producing only DAP. The Z-Train has two emissions points. Emissions from the granulator and dryer are controlled by a venturi scrubber and cyclonic scrubbers followed by a tail-gas packed scrubber and exhaust through a stack. Emissions from the cooler exit a separate stack after control by a wet scrubber. All the scrubbers are wet scrubbers with phosphoric acid andpond water acting as the scrubbing medium. Process fuels include natural gas and fuel oil (including onspecification used oil) with a maximum sulfur content of 1.0% by weight.
NOx Emissions Based on Annual Operating Reports from 2002 to 2006, the highest reported estimated NO X emissions, based on AP-42 and other factors, were 7 tons/year. Only natural gas was fired. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective non-catalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the BART determination is the current combustion design and the firing of natural gas as the primary fuel.
PM Emissions The current PM emissions limit is 47.37 lb/hour (equivalent to 207 tons/year) from the dryer for DAP/MAP production. The PM emissions limits are very high and based on regulation by the process weight table in Rule 62-296.320, F.A.C. However, annual testing is conducted to demonstrate compliance. The following table summarizes actual particulate matter emissions from these units based on recent stack test data. Summary of Tested PM Emissions from the Z-Train DAP/MAP Plant (EU-032)
Tested PM Emissions (EU-032)
Test Date lb/hour
7/20/1978 24.2
1/4/1979 19.76
8/25/1980 5.77
6/24/1981 4.11
7/6/1981 7.75
4/29/1985 12.99
6/26/1986 10.59
7/23/1987 34.4
1/27/1988 5.74
8/3/1988 5.81
2/8/1989 1.06
9/20/1989 4.7
4/25/1990 10.29
10/24/1990 3.33
4/11/1991 3.8REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 23 of 30 Tested PM Emissions (EU-032)
Test Date lb/hour
12/18/1991 5.99
6/17/1992 5.72
4/29/1993 4.01
12/9/1993 7.38
7/14/1994 3.6
4/26/1995 3.16
10/19/1995 47.37*
4/25/1996 4.23
10/17/1996 3.99
4/16/1997 2.59
6/10/1998 3.45 12/16/1998 1.55
6/15/1999 7.48
6/18/1999 3.61
6/14/2000 6.69
12/4/2001 3.47
1/15/2003 1.79
1/21/2004 2.09
1/27/2005 4.84
6/10/2005 2.19
4/6/2006 2.81
5/5/2006 3.18
6/9/2006 2.37
6/14/2006 1.43
5/3/2007 5.95
* This test result appeared high and apparently failed. It was not included in the statistical analysis.
These emissions rates are much lower than the current PM emissions limits and reflect the installed controls. A statistical analysis using the available data indicates the following emissions rate based on a 99% confidence interval: PM (DAP/MAP production): 9.2 lb/hour (equivalent to 40 tons/year) As previously discussed, several similar DAP/MAP Plants at other facilities in Florida have been subject to PSD preconstruction review. These BACT determinations were based on the use of wet venturi scrubbers and cyclonic scrubbers for particulate control. Therefore, the Department recognizes this equipment as a top control option and establishes the following PM BART determination. PM (DAP/MAP production): 9.2 lb/hour (equivalent to 40 tons/year) The proposed standard is near the range determined to be BACT for this process. Based on the BART determinations, potential PM emissions will be reduced from 207 tons/year to 40 tons/year.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 24 of 30 In addition to the dryer, this emissions unit includes a small cooler that was a later addition to the Z-Train. Particulate matter emissions are controlled by a wet scrubber. The application for air construction permit (No. 0470002-032-AC), indicated that potential controlled PM emissions are less than 15 tons/year. The current permit limits visible emissions from the cooler to no more than 20% opacity. There is no actual emissions data for this unit. Based on the amount of potential emissions, the wet scrubber will be considered a top control for the cooler. The Department establishes the following PM BART determination for the cooler. Visible emissions from the Z-Train dryer and cooler shall not exceed 20% opacity as determined by EPA Method 9.
SO 2 Emissions
The current SO 2 emissions limits for the plant are 11.80 lb/hour (equivalent to 52 tons/year). However, no testing is required. Compliance is demonstrated by firing natural gas and achieving the fuel sulfur limitation of 1.5% by weight for fuel oil. A review of the fuel usage for the years 2000-2006 for the Y Train indicates that only natural gas was fired, which would generate negligible amounts of SO 2 emissions. Based on primary fuel fired and the actual SO 2 emissions levels, add-on control equipment (e.g., wet flue gas desulfurization, hydrated lime injection, etc.) may be feasible, but would not be cost effective. Therefore, the Department establishes the following SO 2 BART determination: Natural gas shall be fired as the primary fuel in the Z-Train dryer (EU-032). If the vendor is unable to provide natural gas, fuel oil or on-specification used oil with a maximum sulfur content of 1.0% by weight may be fired as a backup fuel. DFP Feed Prep (EU-042) - Dryer (EP-05) To provide the heat necessary to dry raw materials, the dryer in the DFP Feed Prep fires natural gas or fuel oil with a maximum sulfur content of 1.50% by weight. Emissions from the dryer include NO X , PM and SO 2 from fuel combustion and additional PM from the materials being dried.
NOx Emissions Based on Annual Operating Reports from 2002 to 2006, the highest reported estimated NO X emissions, based on AP-42 and other factors, were 7 tons/year from the combustion of natural gas. No fuel oil was fired. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective noncatalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the BART determination is the current combustion design and the firing of natural gas as the primary fuel.
PM Emissions Particulate matter emissions from the dryer are controlled by an existing wet scrubber with an estimated control efficiency of greater than 95%. For the construction of this emissions unit, the plant did not consider a baghouse appropriate for the high-moisture exhaust, which may cause plugging and blinding of the fabric materials. As a result, a wet scrubber was installed. Currently, the particulate matter emissions limit for the dryer is 31.99 lb/hour (equivalent to 134 tons/year). Again, the particulate matter emissions limits are very high and based on regulation by the process weight table in Rule 62-296.320, F.A.C. Annual testing is conducted to demonstrate compliance with the limits. The following table summarizes actual particulate matter emissions from the dryer based on recent stack test data. Summary of PM Test Data for Dryer in DFP Feed Prep (EU-042, EP-05)

Date Tested Emissions

lb/hour (EU-042, EP-05)
11/8/1984 4.72
11/13/1985 9.35REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 25 of 30 Date Tested Emissions

lb/hour (EU-042, EP-05)
10/23/1986 1.15
10/8/1987 3.14
10/26/1988 4.43
10/26/1989 11.51
12/10/1990 2.49
10/31/1991 3.87
10/7/1992 1.54
10/20/1993 0.75
12/1/1994 0.64
12/12/1995 0.59
11/12/1997 1.25
10/1/1998 0.83
9/30/1999 0.42
8/16/2000 1.33
8/15/2001 1.11
8/14/2003 1.11
8/27/2003 0.84
8/26/2004 0.98 As shown, the actual emissions rates based on the installed controls are much lower than the permitted emissions limit. A statistical analysis using the available data indicates an emissions rate of 4.5 lb/hour based on a 99% confidence interval. At the currently controlled emissions levels, add-on controls are not believed to be cost effective. Therefore, the Department establishes the following PM BART determination for the dryer. Particulate matter emissions from the DFP Feed Prep Dryer (EU-042, EP-05) shall not exceed 4.5 lb/hour as determined by EPA Method 5. Potential emissions of particulate matter will be reduced from 134 to 20 tons per year. Based on the new standard, it will be necessary to develop new excursion levels for the scrubber parameters in the CAM plan.
SO 2 Emissions
The current SO 2 emissions limits are 4.9 lb/hour (equivalent to 21 tons per year), which are based on the firing of fuel oil. Records based on the Annual Operating Reports show that only natural gas has been fired since 1985, which would generate minimal SO 2 emissions. Based on the actual SO 2 emissions levels, add-on control equipment (e.g., wet flue gas desulfurization, hydrated lime injection, etc.) may be feasible, but would not be cost effective. Therefore, the Department establishes the following BART determination for the dryer. Natural gas shall be fired as the primary fuel in the DFP Feed Prep Dryer (EU-042, EP-05). If the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.5% by weight may be fired as a backup fuel. Swift Creek Mine (SCM) Rock Dryer (EU No. 064) The Swift Creek Mine operates a fluidized bed phosphate rock dryer fired primarily with natural gas. When natural gas is not available, the rock dryer may fire fuel oil with maximum sulfur content of 1.3% by weight or on-specification used oil with maximum sulfur content of 1.0% by weight.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 26 of 30 NO X Emissions Based on Annual Operating Reports from 2002 to 2006, the highest reported estimated NO X emissions, based on AP-42 and other factors, were 2 tons/year. Only natural gas was fired. Based on the estimated NO X emissions levels, add-on control equipment (e.g., selective catalytic reduction, selective non-catalytic reduction, flue gas recirculation, etc.) may be feasible, but would not be cost effective. Therefore, the NO X BART determination is the current combustion design and the firing of natural gas as the primary fuel.
PM Emissions Particulate matter emissions are controlled by a two-stage wet cyclonic scrubber with two stacks. The control efficiency is estimated as greater than 95%. Most of the recent BACT determinations reflect wet scrubber control technology for phosphate rock dryers. The permitted PM emissions limits are 46.4 lb/hour (equivalent to 203 tons/year). The mass emissions limit appears high and is based on the regulation by the process weight table in Rule 62-296.320, F.A.C. However, annual testing is conducted to demonstrate compliance. The following table summarizes actual particulate matter emissions from these units based on recent stack test data. Summary of Tested PM Emissions from the Phosphate Rock Dryer (EU-064)
Tested PM Emissions (EU-064)
Test Date lb/hour
2000 16.55
2001 12.65
2002 6.34
2003 7.19
2004 5.86
2005 16.55
2006 3.86 A statistical analysis using the available data indicates 17.3 lb/hour PM emissions rate based on a 99% confidence interval. As shown, the actual emissions rates based on the installed controls are much lower than the permitted emissions limit. Therefore, the Department recognizes this equipment as a top control option and establishes the following PM BART determination. Particulate matter emissions from the Phosphate Rock Dryer (EU-064) shall not exceed 17.3 lb/hour as determined by EPA Method 5. Potential emissions of particulate matter will be reduced from 203 to 76 tons/year.
SO 2 Emissions The permitted SO 2 emissions limit for the rock dryer is 38.1 lb/hour (equivalent to 166.88 tons/year), which appears to be based on the firing of fuel oil. Records of the fuel usage of the rock dryer based on Annual Operating Reports indicate that only natural gas was fired since 1999. Emissions of SO 2 from firing natural gas in the rock dryer are negligible. Based on the actual SO 2 emissions levels, add-on control equipment (e.g., wet flue gas desulfurization, hydrated lime injection, etc.) may be feasible, but would not be cost effective. Therefore, the Department establishes the following BART determination. Natural gas shall be fired as the primary fuel in the phosphate rock dryer. When the vendor is unable to provide natural gas, fuel oil with a maximum sulfur content of 1.5% by weight may be fired as a backup fuel.REVISED TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

White Springs Agricultural Chemicals, Inc. Revised Air Permit No. 0470002-055-AC Suwannee River/Swift Creek Complex BART Project Page 27 of 30 Molten Sulfur System for ‘C’ and ‘D’ Sulfuric Acid Plants (EU-054) The molten sulfur system for the ‘C’ and ‘D’ sulfuric acid plants consists of a rail and truck unloading system with transfer point venting, receiving pit, supply pit, and storage tank. These activities are regulated by the work practice standards specified in Rule 62-296.411(1), F.A.C. for molten sulfur storage and handling facilities. Potential emissions from these activities are estimated to be 2.2 tons per year of particulate matter and 3.4 tons per year of sulfur dioxide. Similar molten sulfur systems throughout Florida do not currently use add-on control equipment because of such relatively low emissions rates. It is unlikely that add-on control equipment would be cost effective at these levels. Therefore, the Department establishes the applicable work practice standards of Rule 62-296.411(1), F.A.C. as the PM and SO 2 BART determinations for this unit, which includes: enclosing piping systems where feasible and practical; minimizing spillage; paved containment areas; and a visible emissions standard of no more than 20% opacity.