adeq operating air permit · 2019-12-30 · the process consists of three major sections: steam...

ADEQOPERATINGAIR PERMIT

Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26:

Permit #: 232-AOP-R2

IS ISSUED TO:

Terra Nitrogen Limited Partnership6054 State Hwy. 18 EastBlytheville, AR 72315

Mississippi CountyCSN: 47-0012

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED IN THEPERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS VALIDBETWEEN:

1 May 1998 and 30 April 2003

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date Modified

SECTION I: FACILITY INFORMATION

PERMITTEE: Terra Nitrogen Limited PartnershipCSN: 470012PERMIT NUMBER: 232-AOP-R2

FACILITY ADDRESS: 6054 State Hwy. 18 East

COUNTY: Mississippi

CONTACT POSITION: Deryl BeairdTELEPHONE NUMBER: (501) 763-0800

REVIEWING ENGINEER: Richard Nissen

UTM North-South (X): 3976.9UTM East-West (Y): 791.0

Terra Nitrogen Limited Partnership May 10, 2002 (12:27PM)232-AOP-R2 C:\Adobe Output\Air\PermitsToDo\470012 R2.wpd470012

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SECTION II: INTRODUCTION

Terra Nitrogen, Limited Partnership (TNLP) operates a nitrogenous fertilizer manufacturing facilityin Blytheville, Arkansas. This facility manufactures three main products: ammonia, urea, and ureaammonium nitrate. This modification changes the requirement for having a person certified inMethod 9 opacity reading to having a person trained (but not certified).

The ammonia plant is a Bechtel design plant. It has a rated capacity of 1320 tons of anhydrousammonia per day. Ammonia is produced by the chemical combination of hydrogen produced fromnatural gas and nitrogen taken from the air. The process consists of three major sections: steammethane reforming, synthesis gas purification, and ammonia synthesis. Once the liquid ammoniahas been produced, the product is sold or routed to either the urea plant or the urea ammoniumnitrate plant for further processing.

The urea plant is a Stamicarbon design plant. It has a rated capacity of 1475 tons per day. Theprocess consists essentially of six sections: utilities, synthesis, recovery, evaporation, granulation,and storage. Urea is synthesized by reacting carbon dioxide and ammonia under elevatedtemperature and pressure. The urea is formed in a liquid solution which is then dried and granulatedin rotary granulators. After being produced, the urea is stored for later shipment by truck, rail, orbarge.

The urea ammonium nitrate (UAN) plant is a Terra design plant. It has a rated capacity of 300 tonsof approximately 32% UAN solution per day. Ammonia and nitric acid solution are reacted in theevaporator to form ammonium nitrate solution. The nitric acid required for production ofammonium nitrate is shipped from the Verdigris, Oklahoma plant, and stored in a 1400 ton storagetank. The produced ammonium nitrate and urea are mixed in the UAN batch tank. The resultingsolution is routed to a storage tank.


3

Regulations

This facility is subject to the following regulations:

Regulation 18, Arkansas Air Pollution Control Code.

Regulation 19, Regulations of The Arkansas Plan of Implementation for AirPollution Control.

Source SN-04, SN-11, SN-12, SN-13, SN-14, SN-15, SN-16, and SN-17 of thisfacility are not subject to the New Source Performance Standards (NSPS) of CFRPart 60 Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units.

The facility is a Major Source as defined by PSD (emission greater than 250tons/year). Changes in this permit are at less than insignificant levels.

The Urea Boiler (SN-13) was installed after 19 June 1984 and is therefor subject tothe New Source Performance Standards, 40 CFR Part 60, Subpart Db.


4

A summary of facility-wide emissions including the cross reference pages isprovided in the following table:

ALLOWABLE EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

Total Allowable Emissions PMPM10SO2

VOCCO

NOx Ammonia

Nitric AcidTRS***

Diethanolamine**Formaldehyde**

Methanol**

59.259.212.7

462.74262.3728.5668.7

0.13.00.2

0.0159.9

255.6255.648.5

390.0976.9

2745.72929.8

0.40.90.9

0.05250.5

SN-01 #1 Package Boiler PMPM10SO2

VOCCONOx

0.40.40.90.54.7

64.4

*

10

SN-02 #2 Package Boiler PMPM10SO2

VOCCONOx

0.50.51.20.66.2

85.8

*

10



SourceNo.


Pagelb/hr tpy

5

SN-03(A&B)

Primary ReformerFurnace

PMPM10SO2

VOCCONOx

2.42.45.63.130.0412.5

*

10

SN-04 Regeneration ofDesulfurization Bed

VOCCOTRS

396.0759.03.0

*18

SN-05Aand SN-05B

Ammonia Flare PMPM10SO2

VOCCONOx

0.20.20.20.20.20.2

*

19

SN-06 Ammonia PlantProcess Vent

CO 3345.0 * 20

SN-07 CO2 Vent VOCCO

AmmoniaMethanol**

Diethanolamine**

60.186.4142.359.90.2

*

22

SN-08 Emergency ReliefValve

InsignificantActivity

NA NA 40

SN-09 F-401 Waste HeatBoiler

PMPM10SO2

VOCCONOx

0.10.10.20.11.14.2

*

10



SourceNo.


Pagelb/hr tpy

6

SN-10 F-401 Bypass Stack PMPM10SO2

VOCCONOx

0.60.61.40.87.3

100.1

*

10

SN-11 Start-up Heater forAmmonia Converter

F-301

PMPM10SO2

VOCCONOx

0.10.10.10.10.51.9

*

10

SN-12ASN-12BSN-12C

Urea Granulation(3 Stacks)

PMPM10

AmmoniaFormalde-hyde

38.038.0200.00.01

*23

SN-13 Urea Boiler PMPM10SO2

VOCCONOx

4.04.03.01.121.859.2

*

10

SN-14 Urea ProductionCommon Stack

PM/PM10Ammonia

0.1295.0

* 25

SN-15 Urea ReactorEmergency Vent


NA NA 40

SN-16 Urea Plant ExcessCarbon Dioxide Vent


NA NA 40

SN-17 Fugitives fromPumps, Seals & Taps

Ammonia 23.4 * 27



SourceNo.


Pagelb/hr tpy

7

SN-18 Nitric Acid StorageTank

Nitric Acid 0.1 * 28



SourceNo.


Pagelb/hr tpy

8



SourceNo.


Pagelb/hr tpy

9


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SECTION III: PERMIT HISTORY

Permit #232-A was issued to Agrico Chemical Company in 1974 for the installation of a 1000 tonper day urea synthesis and granulation plant for the manufacture of fertilizer material. Thisproposed facility was an addition to the existing plant which produced anhydrous ammonia. An oilfired boiler was installed to supply process steam.

Permit #232-AR-1 was issued to Freeport-McMoRan Resource Partners on 6/7/88. This permitdocumented the change of ownership. No physical changes were made at the plant.

Permit #232-AR-2 was issued to Agricultural Minerals, Limited Partnership on 6/20/90. This permitdocumented the change of ownership, as well as the installation of an ammonia recovery scrubberon the urea plant process vent.

Permit #232-AR-3 was issued to Agricultural Minerals, Limited Partnership on 2/14/94. This permitwas for the installation of a nitric acid plant at the facility. The nitric acid plant was never built.

Permit #232-AR-4 was issued to Terra Nitrogen, Limited Partnership on 10/24/95. This permitdocumented the changed of ownership, as well as the installation of a new boiler (SN-13). Thispermit also raised the allowable emission rate from the urea production common stack for ammoniadue to stack test results.

Permit #232-AR-5 was issued to Terra Nitrogen, Limited Partnership on 11/12/96. The permitincluded increasing the VOC emission limit for the urea boiler based on stack test data, the additionof an ammonia emission limit for the UAN evaporator as a result of research conducted, installationof two vessels where nitric acid and ammonia condensate are combined prior to entering theevaporator, and grouping ammonia emission sources SN-07, SN-12, SN-14, and SN-19, togetherto have a collective ammonia emission limit.

Permit #232-AOP-RO was issued to Terra Nitrogen Limited Partnership on 5/1/98. This was thefirst permit under Title V for this facility. The permit reflected a change in emission factors and nota physical change in the plant. The permit incorporated a plant wide applicable limit (PAL) on theemission of each pollutant.

Permit #232-AOP-R1 was issued to Terra Nitrogen Limited Partnership on 8/2/2000. The MinorModification allowed for the installation of a second flare stack. The flare stack was similar to theexisting flare stack and is used only for extended power interruptions or in the event both the stand-by and the primary compressors fail simultaneously (the flares incidence of use averages less thanonce per year). Yearly emissions for the facility's predominate pollutant (ammonia) did not increase.The aggregate increase for all pollutants was less than 0.5 tons per year based on the pilot burneronly.


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SECTION IV: EMISSION UNIT INFORMATION

SN-01, SN-02, SN-03, SN-09, SN-10, SN-11, SN-13#1 and #2 Package Boilers, Primary Reformer Furnace, F-401 Waste Heat Boiler, F-401

Bypass Stack, Start-up Heater for Ammonia Converter, and Urea Boiler

Boiler #1 has a maximum rated heat input capacity of 117 MMBtu/hr which is supplied by naturalgas combustion. This boiler has one exhaust stack which is identified as SN-01. The permittedemission rates are based on rated capacity. This boiler is not subject to NSPS-Db since it wasconstructed, reconstructed, or modified before June 19, 1984.

Boiler #2 has a maximum rated heat input capacity of 156 MMBtu/hr which is supplied by naturalgas combustion. This boiler has one exhaust stack which is identified as SN-02. The permittedemission rates are based on rated capacity. This boiler is not subject to NSPS-Db since it wasconstructed, reconstructed, or modified before June 19, 1984.

The primary reformer furnace has a maximum rated heat input capacity of 750 MMBtu/hr which issupplied by natural gas combustion. This boiler has two exhaust stacks which are identified asSN-03. The permitted emission rates are based on rated capacity. This boiler is not subject toNSPS-Db since it was constructed, reconstructed, or modified before June 19, 1984.

The two Ammonia Flares have a combined maximum rated heat input capacity of 1.4 MMBtu/hrwhich is supplied by natural gas combustion. This source is identified as SN-05. The permittedemission rates are based on rated natural gas capacity. This source is not subject to NSPS-Dc sincethe burners are less than 10MMBtu/hr.

The F-401 Waste Heat Boiler has a maximum rated heat input capacity of 30 MMBtu/hr which issupplied by natural gas combustion. This boiler has one exhaust stack which is identified as SN-09.The permitted emission rates are based on rated capacity. This boiler is not subject to NSPS-Dcsince it was constructed, reconstructed, or modified before June 9, 1989.

The F-401 Bypass has a maximum rated heat input capacity of 182 MMBtu/hr which is supplied bynatural gas combustion. This source has one exhaust stack which is identified as SN-10. Thepermitted emission rates are based on rated capacity. The permitted annual emission rates are basedon 40 hours per year operation. This source is only used during startups. This source is not subjectto NSPS-Db since it was constructed, reconstructed, or modified before June 19, 1984.


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The Start-Up Heater for Ammonia Converter has a rated heat input capacity of 13 MMBtu/hr whichis supplied by natural gas combustion. This source has one exhaust stack which is identified asSN-11. The permitted hourly emission rates are based on rated capacity. The permitted annualemission rates are based on 252 hours per year operation. This source is only used during startups.This source is not subject to NSPS-Dc since it was constructed, reconstructed, or modified beforeJune 9, 1989.

The Urea Boiler has a maximum rated heat input capacity of 296 MMBtu/hr which is supplied bynatural gas combustion. This boiler has one exhaust stack which is identified as SN-13. This boileris subject to NSPS-Db. The permitted emission rates are based on rated capacity.

Specific Conditions

1. Pursuant to §19.501 et seq of the Regulations of the Arkansas State Implementation Plan forAir Pollution Control and 40 CFR Part 52, Subpart E, the permittee shall not exceed theemission rates set forth in the following table. These emission rates are based on ratedcapacity of the equipment. Compliance with this condition shall be demonstrated bycomplying with Specific Condition 4.

Source Pollutant lb/hr

SN-01 PM10SO2

VOCCONOx

0.40.90.54.764.4

SN-02 PM10SO2

VOCCONOx

0.51.20.66.285.8

SN-03 PM10SO2

VOCCONOx

2.45.63.130.0412.5

SN-04 VOCCO

396.0759.0


Source Pollutant lb/hr

13

SN-06 CO 3345.0

SN-07 VOCCO

60.186.4

SN-09 PM10SO2

VOCCONOx

0.10.20.11.14.2

SN-10 PM10SO2

VOCCONOx

0.61.40.87.3

100.1

SN-11 PM10SO2

VOCCONOx

0.10.10.10.51.9

SN-12 (A, B, C)

PM10 38.0

SN-13 PM10SO2

VOCCONOx

4.03.01.121.859.2

SN-14 PM10 0.1

SN-19 PM10 1.0

SN-25 PM10 11.7


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2. Pursuant

SN-03 (A&B)

PM

SN-04 TRS 3.0

SN-06 No NonCriteria

NA

SN-07 AmmoniaMethanol

Diethanolamine

142.359.90.2

SN-09 PM 0.1

SN-10 PM 0.6

SN-11 PM 0.1

SN-12 (A, B, C)

PMAmmonia

Formalde-hyde

38.0200.00.01

SN-13 PM 4.0

SN-14 PMAmmonia

0.1295.0


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SN-17 Ammonia 23.4

SN-18 Nitric Acid 0.1

SN-19 PMAmmonia

1.07.5

SN-20 Ammonia 0.2

SN-21 Ammonia 0.1

SN-22 Ammonia 0.1

SN-23 Ammonia 0.1

SN-25 PM 11.7


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3. Pursuant to §18.501 of the Arkansas Air Pollution Control Code (Regulation 18), the opacityat SN-01, SN-02, SN-03, SN-09, and SN-13, shall not exceed 5% as measured by ReferenceMethod 9. Compliance with this condition shall be demonstrated by complying withPlantwide Condition #12.

4. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19), and by §8-4-304 and §8-4-311, and 40 CFR Part 70.6, the permittee shallcombust only pipeline quality natural gas at SN-01, SN-02, SN-03, SN-05, SN-09, SN-10,SN-11, and SN-13.

5. Pursuant to §19.703 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19), and 40 CFR Part 52 Subpart E, and A.C.A §8-4-203 as referenced by§8-4-304 and §8-4-311, the permittee shall comply with all requirements of the ArkansasContinuous Emission Monitoring Systems Conditions, which are presented in Appendix Bof this permit for SN-13.

6. Pursuant to 40 CFR 60.40b, the urea boiler (SN-13) is subject to all applicable requirementsfound in NSPS Subpart Db.

7. Pursuant to 40 CFR 60.44b(a), the permittee shall not exceed a nitrogen oxide emission rateof 0.2 lb/million Btu (expressed as NO2) at SN-13.

8. Pursuant to 40 CFR 60.44b(h) and (i), the nitrogen oxide standards shall apply at all timesat SN-13 including periods of startup, shutdown, or malfunction. Compliance with thenitrogen oxide emission limits shall be determined on a 30-day rolling average basis.

9. Pursuant to 40 CFR 60.46b(3), the permittee shall determine compliance with the nitrogenoxides standards at SN-13 under Specific Condition 6 on a continuous basis through the useof a 30-day rolling average emission rate. A new 30-day rolling average emission rate iscalculated each steam generating unit operating day as the average of all of the hourlynitrogen oxides emission data for the preceding 30 steam generating unit operating days.

10. Pursuant to 40 CFR 60.48b, the permittee shall install, calibrate, maintain, and operate acontinuous monitoring system for measuring nitrogen oxides emissions discharged to theatmosphere at SN-13 and record the output of the system. The continuous monitoringsystem shall be operated and data recorded during all periods of operation of SN-13 exceptfor continuous monitoring system breakdowns and repairs. Data is recorded duringcalibration checks, and zero and span adjustments.


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11. Pursuant to 40 CFR 60.48b(d), and §19.705 of the Arkansas State Implementation Plan forAir Pollution Control (Regulation 19), and 40 CFR Part 52 Subpart E, and A.C.A §8-4-203as referenced by §8-4-304 and §8-4-311, the 1-hour average nitrogen oxides emission ratesmeasured at SN-13 shall be expressed in lb/million Btu heat input and shall be used tocalculate the average emission rates. At least 4 data points shall be used to calculate each1-hour average.

12. Pursuant to 40 CFR 60.48b(e)(2), the span value for the nitrogen oxides monitoring systemshall be 500 ppm.

13. Pursuant to 40 CFR 60.48b(f), and §19.703 of the Arkansas State Implementation Plan forAir Pollution Control (Regulation 19), and 40 CFR Part 52 Subpart E, and A.C.A §8-4-203as referenced by §8-4-304 and §8-4-311, when nitrogen oxides emission data are notobtained because of continuous monitoring system breakdowns, repairs, calibration checksand zero and span adjustments, emission data shall be obtained by using standby monitoringsystems, Method 7, Method 7A, or Method 7E, to provide emission data for a minimum of75 percent of the operating hours in each steam generating unit operating day, in at least 22out of 30 successive steam generating unit operating days (federal NSPS standard). Thepermittee shall also meet a 95% uptime requirement per calendar quarter, and a 95%compliance requirement per calendar quarter (state standard).

14. Pursuant to 40 CFR 60.49b(b), the permittee shall submit to the Department the performanceevaluation of the CEMS using the applicable performance specification in 40 CFR 60Appendix B.

15. Pursuant to 40 CFR 60.49b(d), the permittee shall record and maintain records of the amountof natural gas combusted at SN-13 during each day and calculate the annual capacity factorfor natural gas for each calendar quarter. The annual capacity factor is determined on a12-month rolling average basis with a new annual capacity factor calculated at the end ofeach calendar month.

16. Pursuant to 40 CFR 60.49b(g), the permittee shall maintain records of the followinginformation for each steam generating unit operating day at SN-13.

a. Calendar date.b. The average hourly nitrogen oxides emission rate (expressed as lb NO2 per million

Btu heat input) measured.c. The 30-day average hourly nitrogen oxides emission rates (lb/million But heat input)

calculated at the end of each steam generating unit operating day from the measuredhourly nitrogen oxide emission rates for the preceding 30 steam generating unitoperating days.


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d. Identification of the steam generating unit operating days when the calculated 30-dayaverage nitrogen oxides emission rates are in excess of 0.2 lb/million Btu, with thereasons for such excess emissions as well as a description of corrective actions taken.

e. Identification of the steam generating unit operating days for which pollutant datahave not been obtained, including reasons for not obtaining sufficient data and adescription of corrective actions taken.

f. Identification of the times when emission data have been excluded from thecalculation of average emission rates and the reasons for excluding data.

g. Identification of "F"factor used for calculations, method of determination, and typeof fuel combusted.

h. Identification of the times when the pollutant concentration exceeded full span of theCEMS.

i. Description of any modifications to the CEMS that could affect the ability of theCEMS to comply with Performance Specification 2 or 3.

j. Results of daily CEMS drift tests and quarterly accuracy assessments as requiredunder appendix F, Procedure 1.17.

18. Pursuant to 40 CFR 60.49b(i), the permittee shall submit a quarterly report to theDepartment containing the information recorded under Specific Condition 15. All quarterlyreports shall be postmarked by the 30th day following the end of each calendar quarter.

19. Pursuant to 40 CFR 60.49b(h), the permittee shall submit excess emission reports for anycalendar quarter during which there are excess emissions from SN-13. If there are no excessemissions during the calendar quarter, the permittee shall submit a report semiannuallystating that no excess emissions occurred during the semiannual reporting period.


19

SN-04Regeneration of Desulfurization Bed

Source Description

In the ammonia plant, ammonia is produced by the chemical combination of hydrogen producedfrom natural gas and nitrogen taken from the ambient air. The first step in this process is calledsteam methane reforming. In steam reforming, the feedstock source of hydrogen is natural gas. Thenatural gas is passed through the Desulfurization Unit (SN-04), which consists of two zinc oxide andtwo carbon drums, where sulfur is removed from the gas stream. The Desulfurization unit emitstotal reduced sulfur when the carbon drums are regenerated. Regeneration of carbon isaccomplished by passing superheated steam over the active carbon bed. The regeneration cycle isperformed every 15 days for approximately 16 hours.

Specific Conditions

20. Pursuant to §19.501 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall not exceed the emissionrates in the following table at SN-04. These emission rates are based on the rated hourlycapacity of the ammonia plant and AP-42 factors. Compliance with these emission ratesshall be demonstrated by complying with Specific Condition 29.

Pollutant lb/hr

VOCCO

TRS*

396.0759.03.0

*Total Reduced Sulfur


20

SN-05Emergency Ammonia Flares

Source Description

The two ammonia flares are installed to provide a means of ammonia thermal destruction duringemergencies such as extended periods of electrical power interruption. The on-site ammonia productstorage tanks are cooled by electrically powered units. The vapor pressure within the tanks arerequired to be maintained below one (1) psi. Pressure relief valves vent to the ammonia flares beforethe tank pressure exceeds one (1) psi. Each flare is equipped with two separate pilots that aresupplied with 50 scfh of natural gas. The maximum feed rate per flare is 12,000 lbs/hr. Theammonia destruction efficiency of the flare is 99%. NOx generated by the thermal destruction is0.5% by weight of the ammonia introduced. Emissions permitted represent the pollutants from theflares pilots only. Emissions as a result of flares being used during emergencies shall be reportedseparately (Special Condition #22).

Specific Conditions

21. Pursuant to §19.501 et seq. of the Arkansas State Implementation Plan for Air PollutionControl (Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall not exceed theemission rates in the following table at SN-05. These emission rates are based on the ratedhourly natural gas usage by the flares for their pilots and AP-42 factors. Compliance withthese emission rates shall be demonstrated by complying with Specific Condition 4.

Pollutant tons/yr

PM10SO2

VOCCONOx

0.20.20.20.20.2


21

22. Pursuant to §19.705 of the Arkansas Plan of Implementation for Air Pollution Control(Regulation 19), the permittee shall record data regarding the use and testing of the flarestacks. The following information shall be logged:

a. Event causing the flare(s) to be used.b. The date and time that the flare usage started.c. The length of time that the flare(s) were used.d. The identification of material and the estimated pounds of material

being flared.e. The legible name of the person logging the information.

23. Pursuant to §19.705 of the Arkansas Plan of Implementation for Air Pollution Control(Regulation 19), any use of the flares shall be reported in accordance with GeneralProvisions #7 and #8 (within 24 hours of the use and every six months). This does notinclude the time when only the pilot is operating.

24. Pursuant Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-05. Compliance with thiscondition shall be demonstrated by complying with Condition 4.

Pollutant tons/yr

PM 0.2

25. Arkansas Plan of Implementation for Air Pollution Control(Regulation 19), the Department reserves the right to evaluate the use of the flares andrequire permitting of flaring events if the Department deems that emissions from the flaresare substantial or predictable; or if the use of the flares is not for emergencies and upsetconditions.


22

SN-06Ammonia Plant Start-Up Process Vent

Source Description

This source vents carbon monoxide emissions during startups and shutdowns of the ammonia plant.In addition, this source is utilized during unplanned outages where the synthesis section of theammonia plant is shut down, but the front end (reformer and purifications sections) of the plantremains on line to provide carbon dioxide feedstock to the urea plant. The potential lb/hr emissionrate is based on a phase I startup which lasts 1 to 4 hours typically. The phase I startup period iswhen the CO concentration is the greatest (1.8%). During this period the plant rate will be 50% orless.

Specific Conditions

26. Pursuant to §19.501 et seq of the Arkansas State Implementation Plan for Air PollutionControl (Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall not exceed thefollowing emission rates at SN-06. Compliance with this condition shall be demonstratedby complying with Specific Condition #27.

Pollutant lb/hr

CO 3345

27. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall keep recordsdemonstrating that the ammonia plant production rate is 27.5 tons per hour or less duringstartups of the ammonia plant.


23

SN-07CO2 Vent for Ammonia Manufacturing Process

Source Description

Emissions occur at this source from the combined regeneration of carbon dioxide scrubbing solutionand steam stripping of process condensate. Pollutants associated with this source include Methanol(VOC), CO, Ammonia, Methane, and Diethanolamine. This source has been stack tested on severaloccasions and the emission rates presented here are the results of these tests.

Specific Conditions

28. Pursuant to §19.501 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall not exceed the followingemission rates at SN-07. Compliance with this condition shall be demonstrated bycomplying with

Pollutant lb/hr

VOCCO

57.486.4

29.

30. Arkansas State Implementation Plan for Air Pollution Control(Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall keep records on site andreadily available of the ammonia production during each day. The permittee shall divide thedaily production by the daily hours of operation to calculate the hourly production rate.

31. Pursuant to §18.8 01 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-07. Compliance with thiscondition shall be demonstrated by complying with Specific Condition 27.

Pollutant lb/hr

AmmoniaMethanol*

Diethanolamine*

142.357.20.2

*Volatile HAP


24

SN-12Urea Granulation

Source Description

This source is located in the urea plant. This source has three identical exhaust stacks (A,B,C). Inthis section, concentrated urea is injected into the drum granulators which contain seed granules andthe solution builds on the seed granules. The particulate emissions are controlled by three wetscrubbers. A urea-formaldehyde resin is injected into the urea solution as an additive before solidsformation. The formaldehyde reacts with urea to form methylenediurea, which is a conditioningagent. This agent reduces solids caking during storage and urea dust formation during loading. Thissource has been stack tested several times and the following emission rates are based upon thosetests.

Specific Conditions

32. Pursuant

Pollutant lb/hr

PM10 38.0

33. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19), A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, and 40 CFR Part70.6, the permittee shall not exceed a urea production rate of 66 ton/hr.

34. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall keep records on site andreadily available of the urea production during each day. The permittee shall divide the dailyproduction by the daily hours of operation to calculate the hourly production rate.

35. Pursuant to §18.501 of the Arkansas Air Pollution Control Code (Regulation 18), the opacityat SN-12 shall not exceed 5% as measured by EPA Method 9. Compliance with thiscondition shall be demonstrated by complying with Plantwide Condition #12.


25

36. Pursuant to §19.303 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19), the permittee shall maintain the urea liquor strength in the three granulationscrubbers at a concentration not to exceed 57% at all times urea is being granulated. Thesereadings shall be taken at least once per day on each scrubber.

37. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall maintain daily recordsof the urea liquor strength in each granulation scrubber. These records shall be kept on siteand made available upon request.

38. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-12. Compliance with thiscondition shall be demonstrated by complying with Specific Condition 33.

Pollutant lb/hr

PMAmmonia

Formaldehyde*

38.02000.01

*HAP


26

SN-14Urea Production Common Stack

Source Description

This source is located in the urea production process in the synthesis section. In the synthesissection, ammonia and carbon dioxide are reacted to form ammonium carbamate. The ammoniumcarbamate is retained under high pressure and temperature and in an excess ammonia atmosphereto form urea and water. Ammonia emissions from the synthesis operation are controlled with apressurized ammonia scrubber (T-107) on the vent feeding into SN-14.

Since the reaction is only partially complete in the synthesis section, the ammonium carbamate andurea solution is subjected to lower pressure and higher temperature in the recovery section, toconvert the unreacted ammonium carbamate back to ammonia and carbon dioxide. The ammoniaand carbon dioxide are returned to the high pressure system for further processing. Ammoniaemissions from the recovery section are controlled by T-105 and T-109, ammonia scrubbers inseries, which feed into the urea production stack (SN-14).

Specific Conditions

39. Pursuant to §19.501 et seq.of the Arkansas State Implementation Plan for Air PollutionControl (Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall not exceed thefollowing emission rates at SN-14. Compliance with this condition shall be demonstratedby complying with Specific Condition 40.

Pollutant lb/hr

PM10 0.1

40. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air Pollution Control(Regulation 19), A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, and 40 CFRPart 70.6, the permittee shall not exceed a urea production rate of 66 ton/hr.

41. Pursuant to §18.501 of the Arkansas Air Pollution Control Code (Regulation 18), the opacityat SN-14 shall not exceed 5% as measured by EPA Method 9. Compliance with thiscondition shall be demonstrated by complying with Plantwide Condition #12.


27

42. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-14. Compliance with thiscondition shall be demonstrated by complying with

Pollutant lb/hr

PM 0.1

Ammonia 295


28

SN-17Fugitives from Pumps, Seals & Taps

Source Description

Ammonia emissions occur from the pumps, seals, and taps at the facility. The emissions are

Specific Conditions

43. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-17. These rates arebased on the number of components presently at the facility. Calculations assumecontinuous throughput through components.

Pollutant lb/hr

Ammonia 23.4


29

SN-18Nitric Acid Storage Tank

Source Description

57% Nitric Acid is shipped to the facility by railcar and unloaded in the storage tank (230,000gallon). The nitric acid is used in the production of urea ammonium nitrate solution. Emissionswere estimated using AP-42, Section 7.1 factors for organics and by inserting Nitric Acid storageconditions to produce the worst case emissions. Maximum annual throughput is limited to 9.43million gallons. The lb/hr emissions were calculated for worst case conditions assuming that eachturnover takes one hour or less and taking the total annual working loss and dividing by the numberof turnovers per year to get a lb/turnover figure.

Specific Conditions

44. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-18.

Pollutant lb/hr

Nitric Acid 0.1


30

SN-19UAN Evaporator

Source Description

The process for the manufacture of ammonium nitrate solution (UAN) consists of neutralizingammonia with nitric acid under controlled conditions. Ammonia vapor and ammonia contaminatedcondensate from tank T-102, ammonia vapor from scrubber (T-109), and nitric acid are introducedto T-211, a pre-neutralizer for pH control. The vapors from T-211 and T-212 are returned to T-203.The ammonium nitrate solution is further reacted in T-212. The solution is concentrated in theevaporator (SN-19) and ammonia vapors from the H.P. Scrubber T-107, the L.P. Scrubber T-109,and tanks TK101 and TK102 are added. The evaporator functions by introducing ammonium nitratesolution at the bottom of T-203. A recirculating pump moves the water to the top of the packed bedin the tower, where it flows downward across the packing media back to the bottom of the tower.Air supplied by a blower, flowing upward through a packed tower allows for the evaporation ofwater, but leaves the ammonium nitrate in a concentrate solution. The emissions from theevaporator consist of particulates and are controlled by a Koch demister and Koch filter system.Emissions from SN-19 are emitted to the atmosphere. Ammonia emissions are based on AP-42factors found in Section 8.3.5, Table 8.3.2.

The ammonium nitrate solution and urea from the urea plant are combined in the shift tanks andcorrosion inhibitor is added. The final product is then sent to storage (SN-34). 32% UAN is shippedby truck, rail, and barge. The nitric acid required for the production of UAN will be shipped by railcar or truck from the Verdigris, OK plant, and stored in a 1400 ton nitric acid tank (SN-18).

Specific Conditions

45. Pursuant to §19.501 et seq. of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and , the permittee shallnot exceed the following emission rates at SN-19. Compliance with this limit shallbe demonstrated by complying with Specific Condition 46.

Pollutant lb/hr

PM10 1.0


31

46. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air PollutionControl (Regulation 19), A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311,and 40 CFR Part 70.6, the permittee shall not exceed a UAN production rate of 12.5tons per hour.

47. Pursuant to §19.705 of the Arkansas State Implementation Plan for Air PollutionControl (Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall keeprecords on site and readily available of the UAN production during each day. Thepermittee shall divide the daily production by the daily hours of operation tocalculate the hourly production rate.

48. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rates at SN-19. Compliance withthis limit shall be demonstrated by complying with Specific Condition 46.

Pollutant lb/hr

PM 1.0

Ammonia 7.5


32

SN-20Urea Tank (TK-101)

Source Description

This is a 22,500 gallon vertical tank which is used to store 60% liquid urea for use in the UAN plant.The ammonia emissions from this tank are used in the urea ammonium nitrate plant to make 32%UAN. The only time ammonia emissions from this source are emitted to the atmosphere is whenthe UAN plant is down. Emissions were calculated using the fixed roof breathing loss equation fromEPA document 560/488-002 "Estimating Releases and Waste/Treatment Efficiencies For the ToxicChemical Release Inventory Form". The following emission rates represent breathing losses as ifthe tank was vented to the atmosphere.

Specific Conditions

49. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rate at SN-20. Compliance withthis limit shall be demonstrated by complying with Specific Condition 46.

Pollutant lb/hr

Ammonia 0.2


33


Source Description

This is a 66,000 gallon vertical tank which is used to store ammonia contaminated condensate (6-8%) for use in the UAN plant. The ammonia emissions from this tank are used in the ureaammonium nitrate plant to make 32% UAN. The only time ammonia emissions from this sourceare emitted to the atmosphere is when the UAN plant is down. Emissions were calculated using thefixed roof breathing loss equation from EPA document 560/488-002 "Estimating Releases andWaste/Treatment Efficiencies For the Toxic Chemical Release Inventory Form". The followingemission rates represent breathing losses as if the tank was vented to the atmosphere.

Specific Conditions


Pollutant lb/hr

Ammonia 0.1


34


Source Description

This is a 25,000 gallon vertical tank which is used to store 0.043% ammonia contaminatedcondensate which is generated at the urea plant. The ammonia emissions from this tank are ventedto the atmosphere. Emissions were calculated using the fixed roof breathing loss equation from EPAdocument 560/488-002 "Estimating Releases and Waste/Treatment Efficiencies For the Toxic Chemical Release Inventory Form".

Specific Conditions


Pollutant lb/hr

Ammonia 0.1


35


Source Description

This is a 27,900 gallon vertical tank which is used to store 0.043% ammonia contaminatedcondensate which is generated at the urea plant. The ammonia emissions from this tank are ventedto the atmosphere. Emissions were calculated using the fixed roof breathing loss equation from EPAdocument 560/488-002 "Estimating Releases and Waste/Treatment Efficiencies For the ToxicChemical Release Inventory Form".

Specific Conditions

52. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the following emission rate at SN-23. Compliance withthis condition shall be demonstrated by complying with Specific Condition 40.

Pollutant lb/hr

Ammonia 0.1


36

SN-25Urea Loading

Source Description

The urea produced at the urea plant is bulk loaded into barges, railcars, and trucks. Emissions wereestimated using AP-42 factors for urea bagging (Section 8.2-4, Table 8-2.1). There are no specifiedemissions for loading operations according to the statement on 8.2-5, which states "nationwideapproximately 90% of urea produced is bulk loaded. Few plants control their bulk loadingoperations. Generation of visible emissions is negligible." To be conservative, factors for ureabagging were used. The urea bagging factor is 0.19 lb/ton of product produced.

Specific Conditions

53. Pursuant to §19.501 et seq. of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shallnot exceed the following emission rates at SN-25. Compliance with this conditionshall be demonstrated by complying with Specific Condition 33.

Pollutant lb/hr

PM10 11.7

54. Pursuant to §18.501 of the Arkansas Air Pollution Control Code (Regulation 18), theopacity at SN-25 shall not exceed 15% as measured by EPA Method 9. Compliancewith this condition shall be demonstrated by complying with Plantwide Condition#12.


Pollutant lb/hr

PM 11.7


37

SECTION V: COMPLIANCE PLAN AND SCHEDULE

Terra Nitrogen Limited Partnership is in compliance with the applicable regulations cited in thepermit application. Terra Nitrogen Limited Partnership will continue to operate in compliancewith those identified regulatory provisions. The facility will examine and analyze futureregulations that may apply and determine their applicability with any necessary action taken on atimely basis.


38

SECTION VI: PLANTWIDE CONDITIONS

1. Pursuant to §19.704 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, the Director shall be notified in writing withinthirty (30) days after construction has commenced, construction is complete, theequipment and/or facility is first placed in operation, and the equipment and/or facilityfirst reaches the target production rate.

2. Pursuant to §19.410(B) of Regulation 19, 40 CFR Part 52, Subpart E, the Director maycancel all or part of this permit if the construction or modification authorized herein isnot begun within 18 months from the date of the permit issuance if the work involved inthe construction or modification is suspended for a total of 18 months or more.

3. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any equipment that is to betested, unless stated in the Specific Conditions of this permit or by any federallyregulated requirements, shall be tested with the following time frames: (1) Equipment tobe constructed or modified shall be tested within sixty (60) days of achieving themaximum production rate, but in no event later than 180 days after initial start-up of thepermitted source or (2) equipment already operating shall be tested according to the timeframes set forth by the Department. The permittee shall notify the Department of thescheduled date of compliance testing at least fifteen (15) days in advance of such test. Compliance test results shall be submitted to the Department within thirty (30) days afterthe completed testing.

4. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permittee shall provide:

a. Sampling ports adequate for applicable test methodsb. Safe sampling platforms c. Safe access to sampling platformsd. Utilities for sampling and testing equipment

5. Pursuant to §19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C. A. §8-4-304 and §8-4-311, the equipment, control apparatus and emission monitoringequipment shall be operated within their design limitations and maintained in goodcondition at all times.


39

6. Pursuant to Regulation 26 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311,this permit subsumes and incorporates all previously issued air permits for this facility.

Title VI Provisions

7. The permittee shall comply with the standards for labeling of products using ozonedepleting substances pursuant to 40 CFR Part 82, Subpart E:

a. All containers containing a class I or class II substance stored or transported, allproducts containing a class I substance, and all products directly manufacturedwith a class I substance must bear the required warning statement if it is beingintroduced to interstate commerce pursuant to §82.106.

b. The placement of the required warning statement must comply with therequirements pursuant to §82.108.

c. The form of the label bearing the required warning must comply with therequirements pursuant to §82.110.

d. No person may modify, remove, or interfere with the required warning statementexcept as described in §82.112.

8. The permittee shall comply with the standards for recycling and emissions reductionpursuant to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:

a. Persons opening appliances for maintenance, service, repair, or disposal mustcomply with the required practices pursuant to §82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliancesmust comply with the standards for recycling and recovery equipment pursuant to§82.158.

c. Persons performing maintenance, service repair, or disposal of appliances must becertified by an approved technician certification program pursuant to §82.161.

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances mustcomply with record keeping requirements pursuant to §82.166. (“MVAC-likeappliance” as defined at §82.152.)

e. Persons owning commercial or industrial process refrigeration equipment mustcomply with leak repair requirements pursuant to §82.156.

f. Owners/operators of appliances normally containing 50 or more pounds ofrefrigerant must keep records of refrigerant purchased and added to suchappliances pursuant to §82.166.

9. If the permittee manufactures, transforms, destroys, imports, or exports a class I or classII substance, the permittee is subject to all requirements as specified in 40 CFR part 82,Subpart A, Production and Consumption Controls.

10. If the permittee performs a service on motor (fleet) vehicles when this service involves


40

ozone-depleting substance refrigerant (or regulated substitute substance) in the motorvehicle air conditioner (MVAC), the permittee is subject to all the applicablerequirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle AirConditioners.

The term “motor vehicle” as used in Subpart B does not include a vehicle in which finalassembly of the vehicle has not been completed. The term “MVAC” as used in SubpartB does not include the air-tight sealed refrigeration system used as refrigerated cargo, orthe system used on passenger buses using HCFC-22 refrigerant.

11. The permittee shall be allowed to switch from any ozone-depleting substance to anyalternative that is listed in the Significant New Alternatives Program (SNAP) promulgatedpursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program.

12. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, weekly observationsare required for sources with a permitted opacity of 15% or less and daily for sources witha permitted opacity greater than 15%. The observations shall be conducted by personnelfamiliar with the permittee’s visible emissions. The permittee shall maintain personneltrained (not certified) in EPA Reference Method #9. When visible emissions which appearto be in excess of the permitted opacity are detected, the permittee shall immediately takeaction to identify the cause, implement corrective action, and record the following items:

a. The date and time of the high opacity observation. b. The apparent opacity and the allowed opacity. c. The cause of the exceedance of the opacity limit, the corrective action taken, and

if the visible emissions appeared to be below the permitted limit after the correctiveaction was taken.

d. The name of the person conducting the opacity observations.

These records shall be updated within one day of the high opacity observation, kept on sitefor a minimum of five years, made available to Department personnel upon request.


41

SECTION VII: INSIGNIFICANT ACTIVITIES

Pursuant to §26.3(d) of Regulation 26, the following sources are insignificant activities.Insignificant and trivial activities will be allowable after approval and federal register noticepublication of a final list as part of the operating air permit program. Any activity for which a stateor federal applicable requirement applies is not insignificant even if this activity meets the criteriaof §3(d) of Regulation 26 or is listed below. Insignificant activity determinations rely upon theinformation submitted by the permittee in an application dated 16 November 1999.


42


43

SECTION VIII: GENERAL PROVISIONS

1. Pursuant to 40 C.F.R. 70.6(b)(2), any terms or conditions included in this permit whichspecify and reference Arkansas Pollution Control & Ecology Commission Regulation 18or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as thesole origin of and authority for the terms or conditions are not required under the CleanAir Act or any of its applicable requirements, and are not federally enforceable under theClean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 wasadopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101et seq.). Any terms or conditions included in this permit which specify and referenceArkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Waterand Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority forthe terms or conditions are enforceable under this Arkansas statute.

2. Pursuant to 40 C.F.R. 70.6(a)(2) and §26.7 of the Regulations of the Arkansas OperatingAir Permit Program (Regulation 26), this permit shall be valid for a period of five (5)years beginning on the date this permit becomes effective and ending five (5) years later.

3. Pursuant to §26.4 of Regulation #26, it is the duty of the permittee to submit a completeapplication for permit renewal at least six (6) months prior to the date of permitexpiration. Permit expiration terminates the permittee's right to operate unless acomplete renewal application was submitted at least six (6) months prior to permitexpiration, in which case the existing permit shall remain in effect until the Departmenttakes final action on the renewal application. The Department will not necessarily notifythe permittee when the permit renewal application is due.

4. Pursuant to 40 C.F.R. 70.6(a)(1)(ii) and §26.7 of Regulation #26, where an applicablerequirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) is morestringent than an applicable requirement of regulations promulgated under Title IV of theAct, both provisions are incorporated into the permit and shall be enforceable by theDirector or Administrator.

5. Pursuant to 40 C.F.R. 70.6(a)(3)(ii)(A) and §26.7 of Regulation #26, records ofmonitoring information required by this permit shall include the following:

1.The date, place as defined in this permit, and time of sampling ormeasurements;2.The date(s) analyses were performed;3.The company or entity that performed the analyses;4.The analytical techniques or methods used;5.The results of such analyses; and 6.The operating conditions existing at the time of sampling or measurement.


44

6. Pursuant to 40 C.F.R. 70.6(a)(3)(ii)(B) and §26.7 of Regulation #26, records of allrequired monitoring data and support information shall be retained for a period of at least5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all originalstrip-chart recordings for continuous monitoring instrumentation, and copies of allreports required by this permit.

7. Pursuant to 40 C.F.R. 70.6(a)(3)(iii)(A) and §26.7 of Regulation #26, the permittee shallsubmit reports of all required monitoring every 6 months. If no other reporting period hasbeen established, the reporting period shall end on the last day of the anniversary monthof this permit. The report shall be due within 30 days of the end of the reporting period.Even though the reports are due every six months, each report shall contain a full year ofdata. All instances of deviations from permit requirements must be clearly identified insuch reports. All required reports must be certified by a responsible official as defined in§26.2 of Regulation #26 and must be sent to the address below.

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector SupervisorPost Office Box 8913Little Rock, AR 72219

8. Pursuant to 40 C.F.R. 70.6(a)(3)(iii)(B), §26.7 of Regulation #26, and §19.601 and19.602 of Regulation #19, all deviations from permit requirements, including thoseattributable to upset conditions as defined in the permit shall be reported to theDepartment. An initial report shall be made to the Department by the next business dayafter the occurrence. The initial report may be made by telephone and shall include:

1.The facility name and location,2.The process unit or emission source which is deviating from the permit limit, 3.The permit limit, including the identification of pollutants, from whichdeviation occurs,4.The date and time the deviation started, 5.The duration of the deviation, 6.The average emissions during the deviation,7.The probable cause of such deviations,8.Any corrective actions or preventive measures taken or being taken to preventsuch deviations in the future, and 9.The name of the person submitting the report.


45

A full report shall be made in writing to the Department within five (5) business days ofdiscovery of the occurrence and shall include in addition to the information required byinitial report a schedule of actions to be taken to eliminate future occurrences and/or tominimize the amount by which the permits limits are exceeded and to reduce the lengthof time for which said limits are exceeded. If the permittee wishes, they may submit afull report in writing (by facsimile, overnight courier, or other means) by the nextbusiness day after discovery of the occurrence and such report will serve as both theinitial report and full report.

9. Pursuant to 40 C.F.R. 70.6(a)(5) and §26.7 of Regulation #26, and A.C.A.§8-4-203, asreferenced by §8-4-304 and §8-4-311, if any provision of the permit or the applicationthereof to any person or circumstance is held invalid, such invalidity shall not affect otherprovisions or applications hereof which can be given effect without the invalid provisionor application, and to this end, provisions of this Regulation are declared to be separableand severable.

10. Pursuant to 40 C.F.R. 70.6(a)(6)(i) and §26.7 of Regulation #26, the permittee mustcomply with all conditions of this Part 70 permit. Any permit noncompliance withapplicable requirements as defined in Regulation #26 constitutes a violation of the CleanAir Act, as amended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; forpermit termination, revocation and reissuance, or modification; or for denial of a permitrenewal application. Any permit noncompliance with a state requirement constitutes aviolation of the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.)and is also grounds for enforcement action; for permit termination, revocation andreissuance, or modification; or for denial of a permit renewal application.

11. Pursuant to 40 C.F.R. 70.6(a)(6)(ii) and §26.7 of Regulation #26, it shall not be a defensefor a permittee in an enforcement action that it would have been necessary to halt orreduce the permitted activity in order to maintain compliance with the conditions of thispermit.


46

12. Pursuant to 40 C.F.R. 70.6(a)(6)(iii) and §26.7 of Regulation #26, this permit may bemodified, revoked, reopened, and reissued, or terminated for cause. The filing of arequest by the permittee for a permit modification, revocation and reissuance, ortermination, or of a notification of planned changes or anticipated noncompliance doesnot stay any permit condition.

13. Pursuant to 40 C.F.R. 70.6(a)(6)(iv) and §26.7 of Regulation #26, this permit does notconvey any property rights of any sort, or any exclusive privilege.

14. Pursuant to 40 C.F.R. 70.6(a)(6)(v) and §26.7 of Regulation #26, the permittee shallfurnish to the Director, within the time specified by the Director, any information that theDirector may request in writing to determine whether cause exists for modifying,revoking and reissuing, or terminating the permit or to determine compliance with thepermit. Upon request, the permittee shall also furnish to the Director copies of recordsrequired to be kept by the permit. For information claimed to be confidential, thepermittee may be required to furnish such records directly to the Administrator alongwith a claim of confidentiality.

15. Pursuant to 40 C.F.R. 70.6(a)(7) and §26.7 of Regulation #26, the permittee shall pay allpermit fees in accordance with the procedures established in Regulation #9.

16. Pursuant to 40 C.F.R. 70.6(a)(8) and §26.7 of Regulation #26, no permit revision shall berequired, under any approved economic incentives, marketable permits, emissions tradingand other similar programs or processes for changes that are provided for elsewhere inthis permit.

17. Pursuant to 40 C.F.R. 70.6(a)(9)(i) and §26.7 of Regulation #26, if the permittee isallowed to operate under different operating scenarios, the permittee shall,contemporaneously with making a change from one operating scenario to another, recordin a log at the permitted facility a record of the scenario under which the facility orsource is operating.

18. Pursuant to 40 C.F.R. 70.6(b) and §26.7 of Regulation #26, all terms and conditions inthis permit, including any provisions designed to limit a source's potential to emit, areenforceable by the Administrator and citizens under the Act unless the Department hasspecifically designated as not being federally enforceable under the Act any terms andconditions included in the permit that are not required under the Act or under any of itsapplicable requirements.


47

19. Pursuant to 40 C.F.R. 70.6(c)(1) and §26.7 of Regulation #26, any document (includingreports) required by this permit shall contain a certification by a responsible official asdefined in §26.2 of Regulation #26.

20. Pursuant to 40 C.F.R. 70.6(c)(2) and §26.7 of Regulation #26, the permittee shall allowan authorized representative of the Department, upon presentation of credentials, toperform the following:

1.Enter upon the permittee's premises where the permitted source is located oremissions-related activity is conducted, or where records must be kept under theconditions of this permit;2.Have access to and copy, at reasonable times, any records that must be keptunder the conditions of this permit;3.Inspect at reasonable times any facilities, equipment (including monitoring andair pollution control equipment), practices, or operations regulated or requiredunder this permit; and 4.As authorized by the Act, sample or monitor at reasonable times substances orparameters for the purpose of assuring compliance with this permit or applicablerequirements.

21. Pursuant to 40 C.F.R. 70.6(c)(5) and §26.7 of Regulation #26, the permittee shall submita compliance certification with terms and conditions contained in the permit, includingemission limitations, standards, or work practices. This compliance certification shall besubmitted annually and shall be submitted to the Administrator as well as to theDepartment. All compliance certifications required by this permit shall include thefollowing:

1.The identification of each term or condition of the permit that is the basis of thecertification; 2.The compliance status;3.Whether compliance was continuous or intermittent;4.The method(s) used for determining the compliance status of the source,currently and over the reporting period established by the monitoringrequirements of this permit; and 5.Such other facts as the Department may require elsewhere in this permit or by§114(a)(3) and 504(b) of the Act.


48

22. Pursuant to §26.7 of Regulation #26, nothing in this permit shall alter or affect thefollowing:

1.The provisions of Section 303 of the Act (emergency orders), including theauthority of the Administrator under that section;2.The liability of the permittee for any violation of applicable requirements priorto or at the time of permit issuance;3.The applicable requirements of the acid rain program, consistent with §408(a)of the Act; or4.The ability of EPA to obtain information from a source pursuant to §114 of theAct.

23. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permitauthorizes only those pollutant emitting activities addressed herein.

APPENDIX A

50

Source

Pollutant EmissionFactor

Throughput orhours ofoperationduringlast 12monthperiod

Emissions (tpy)

PM SO2 VOC CO NOx NH3 Methanol

NitricAcid

Diethanolamine

Formaldehyde

TRS

SN-01

PM/PM10 3.2 lb/MMFt3

SO2 7.5 lb/MMFt3

VOC 4.1 lb/MMFt3

CO 40 lb/MMFt3

NOx 550 lb/MMFt3

SN-02


SO2 7.5 lb/MMFt3

VOC 4.1 lb/MMFt3

CO 40 lb/MMFt3

NOx 550 lb/MMFt3

SN-03


SO2 7.5 lb/MMFt3

VOC 4.1 lb/MMFt3

CO 40 lb/MMFt3

NOx 550 lb/MMFt3

Source



Emissions (tpy)


NitricAcid

Diethanolamine

Formaldehyde

TRS

51

SN-05


SO2 0.6 lb/MMFt3

VOC 5.28lb/MMFt3

CO 21 lb/MMFt3

NOx 100 lb/MMFt3

SN-09


SO2 7.5 lb/MMFt3

VOC 3.7 lb/MMFt3

CO 35 lb/MMFt3

NOx 140 lb/MMFt3

SN-10


SO2 7.5 lb/MMFt3

VOC 3.7 lb/MMFt3

CO 40 lb/MMFt3

NOx 550 lb/MMFt3

Source



Emissions (tpy)


NitricAcid

Diethanolamine

Formaldehyde

TRS

52

SN-11 PM/PM10 3.2 lb/MMFt3

SO2 7.5 lb/MMFt3

VOC 4.1 lb/MMFt3

CO 35 lb/MMFt3

NOx 140 lb/MMFt3

SN-13

PM/PM10 3.125lb/MMFt3

SO2 6.75lb/MMFt3

VOC 3.7 lb/MMFt3

CO 31.25lb/MMFt3

NOx 104.7lb/MMFt3

Source



Emissions (tpy)


NitricAcid

Diethanolamine

Formaldehyde

TRS

53

SN-04

VOC (396)(hr/yr)/2000

CO (759)(hr/yr)/2000

TRS (3)(hr/yr)/2000

SN-06

CO Calculated byfacility usingdurations ofstartups andshutdowns

SN-07

VOC 0.996 lb/tonNH3

CO 1.5 lb/ton NH3

Ammonia 2.47 lb/tonNH3

Methanol 0.993 lb/tonNH3

Source



Emissions (tpy)


NitricAcid

Diethanolamine

Formaldehyde

TRS

54

Diethanolamine

80.64 lb/tonused

SN-12

PM/PM10 0.57 lb/tonurea

Ammonia 3.03 lb/tonurea

Formaldehyde .00002 lb/lbresin

SN-14

PM/PM10 .0015 lb/tonurea

Ammonia 4.47 lb/tonurea

SN-17

Ammonia Fixed Factor n/a 102.5

SN-18

Nitric Acid 0.08 lb/kgalused

SN-19

PM/PM10 0.08 lb/tonUAN

Source



Emissions (tpy)


NitricAcid

Diethanolamine

Formaldehyde

TRS

55

Ammonia 0.6 lb/tonUAN

SN-25

PM/PM10 0.19 lb/tonurea

TOTAL FACILITY EMISSIONS (TPY)

PERMIT LIMIT (TPY) 255.5

48.4 389.9

976.8

2745.6

2929.8

250.5

0.4 0.9 0.05 0.9

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