ADEQ OPERATING AIR PERMIT€¦ · The process consists of three major sections: steam methane reforming, synthesis gas purification, and ammonia synthesis. Once the liquid ammonia

ADEQOPERATINGAIR PERMIT

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

Permit #: 232-AOP-R1

IS ISSUED TO:

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

Mississippi CountyCSN: 470012

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-R1

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 October 11, 2001 (11:57AM)232-AOP-R1 C:\Adobe Output\Air\PermitsToDo\470012-R1.wpd470012 RA Nissen

2

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. The facility's application for a Minor Modification to their permit, allowing forthe installation of a second flare stack is approved. The flare stack is similar to the existing flarestack and is used only for extended power interruptions or in the event both the stand-by and theprimary compressors fail simultaneously (the flares incidence of use averages less than once peryear). Yearly emissions for the facility's predominate pollutant (ammonia) will not increase. Theaggregate increase for all pollutants is less than 0.5 tons per year based on the pilot burner only.

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 ammonium nitrateplant 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.

Dispersion modeling for all criteria pollutants and ammonia was performed using these permittedemission rates. The modeling analysis predicted the concentration of all criteria pollutants to bebelow the National Ambient Air Quality Standards. The modeling also predicted the concentrationof ammonia to be below the Presumptively Acceptable Impact Level (PAIL) of 170micrograms/cubic meter.

Permit 232-AOP-R0 was the first Title V operating permit for this facility. This permit increases


3

the facility emissions because of an additional ammonia flare. This permit continues to incorporatea plant wide applicable limit (PAL) on the annual emissions of each pollutant. Compliance with thisPAL will be demonstrated on a monthly basis by record keeping on production rates and natural gasusage rates, in conjunction with the emission factors found in Appendix A of this permit.

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.

A summary of facility-wide emissions including the cross reference pages is providedin the following table:


4

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

462.74262.3

728.5668.7

0.13.00.2

0.0159.9

255.6255.6

48.5390.0976.9

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

SN-03(A&B)

Primary ReformerFurnace

PMPM10SO2

VOCCONOx

2.42.45.63.1

30.0412.5

*

10



SourceNo.


Pagelb/hr tpy

5

SN-04 Regeneration ofDesulfurization Bed

VOCCOTRS

396.0759.0

3.0*

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 * 21

SN-07 CO2 Vent VOCCO

AmmoniaMethanol**

Diethanolamine**

60.186.4

142.359.90.2

*

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

SN-10 F-401 Bypass Stack PMPM10SO2

VOCCONOx

0.60.61.40.87.3

100.1

*

10



SourceNo.


Pagelb/hr tpy

6

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

38.038.0

200.00.01

*23

SN-13 Urea Boiler PMPM10SO2

VOCCONOx

4.04.03.01.1

21.859.2

*

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

SN-18 Nitric Acid StorageTank

Nitric Acid 0.1 * 28



SourceNo.


Pagelb/hr tpy

7



SourceNo.


Pagelb/hr tpy

8


9

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. This proposedfacility was an addition to the existing plant which produced anhydrous ammonia. An oil fired boilerwas 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. This nitric acid plant was never built,however.

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, together tohave 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.


10


11

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

0.40.90.54.7

64.4

SN-02 PM10SO2

VOCCONOx

0.51.20.66.2

85.8

SN-03 PM10SO2

VOCCONOx

2.45.63.1

30.0412.5

SN-04 VOCCO

396.0759.0


Source Pollutant lb/hr

12

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

4.03.01.1

21.859.2

SN-14 PM10 0.1

SN-19 PM10 1.0

SN-25 PM10 11.7


13

2. Pursuant

SN-03 (A&B)

PM

SN-04 TRS 3.0

SN-06 No Non Criteria 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


14

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


15

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 withSpecific Condition 4.

4.

-13.

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

7. Pursuant to permittee shall not exceed a nitrogen oxide emission rateof

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 monitoring systemshall be operated and data recorded during all periods of operation of SN-13 except forcontinuous monitoring system breakdowns and repairs. Data is recorded during calibrationchecks, and zero and span adjustments.


16

11. Pursuant

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.

(2) The average hourly nitrogen oxides emission rate (expressed as lb NO2 per millionBtu heat input) measured.

(3) 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 measured hourlynitrogen oxide emission rates for the preceding 30 steam generating unit operating days.

(4) Identification of the steam generating unit operating days when the calculated 30-day


17

average nitrogen oxides emission rates are in excess of 0.2 lb/million Btu, with the reasonsfor such excess emissions as well as a description of corrective actions taken.

(5) Identification of the steam generating unit operating days for which pollutant datahave not been obtained, including reasons for not obtaining sufficient data and a descriptionof corrective actions taken.

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

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

(8) Identification of the times when the pollutant concentration exceeded full span of theCEMS.

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

(10) Results of daily CEMS drift tests and quarterly accuracy assessments as requiredunder appendix F, Procedure 1.

permittee shall submit a quarterly report to the Departmentcontaining the information recorded under All quarterly reports shallbe postmarked by the 30th day following the end of each calendar quarter.

18. Pursuant to 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.


18

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 is accomplishedby passing superheated steam over the active carbon bed. The regeneration cycle is performed every15 days for approximately 16 hours.

Specific Conditions

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 28.

Pollutant lb/hr

VOCCO

TRS*

396.0759.0

3.0

*Total Reduced Sulfur


19

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 is 0.5%by weight of the ammonia introduced. Emissions permitted represent the pollutants from the flarespilots only. Emissions as a result of flares being used during emergencies shall be reported separately(Special Condition #21.

Specific Conditions

Pollutant tons/yr

PM10SO2

VOCCONOx

0.20.20.20.20.2


20

21. 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 materialbeing flared.

E. The legible name of the person logging the information.

22. 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.

23. 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

24. 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.


21

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

25. 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 #26.

Pollutant lb/hr

CO 3345

26. 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.


22

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

27. 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

28.

29. 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.

30. Pursuant 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

Pollutant lb/hr

AmmoniaMethanol*

Diethanolamine*

142.357.20.2

*Volatile HAP


23

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

31. Pursuant

Pollutant lb/hr

PM10 38.0

32.


24

35.

Pollutant lb/hr

PMAmmonia

Formaldehyde*

38.02000.01

*HAP


25

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

38. Pursuant to 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


26

41. of Regulation 19 and 40 CFR 52, Subpart E, the permittee shall conductweekly observations of the opacity from SN-14, and keep a record of these observations. Ifvisible emissions are detected, then the permittee shall conduct a 6-minute opacity readingin accordance with EPA Reference Method 9. The results of these observations shall be kepton site and made available for inspection upon request.

42. 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


27

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 (Regulation 18), thepermittee shall not exceed the following emission rates at SN-17. These rates are based onthe number of components presently at the facility. Calculations assume continuousthroughput through components.

Pollutant lb/hr

Ammonia 23.4


28

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 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


29

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 the evaporatorconsist of particulates and are controlled by a Koch demister and Koch filter system. Emissions fromSN-19 are emitted to the atmosphere. Ammonia emissions are based on AP-42 factors found inSection 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

of the Arkansas State Implementation Plan for Air PollutionControl (Regulation 19) and , the permittee shall not exceed thefollowing emission rates at SN-19. Compliance with this limit shall be demonstrated bycomplying with

Pollutant lb/hr

PM10 1.0


30

46.

Pollutant lb/hr

PM 1.0

Ammonia 7.5


31

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

Pollutant lb/hr

Ammonia 0.2


32


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 "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


33


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 EPA

Specific Conditions

Pollutant lb/hr

Ammonia 0.1


34


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

Pollutant lb/hr

Ammonia 0.1


35

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.

Pollutant lb/hr

PM10 11.7

54.

and 40 CFR 52, Subpart E, thepermittee shall conduct weekly observations of the opacity from SN-25, and keep a recordof these observations. If visible emissions are detected, then the permittee shall conduct a6-minute opacity reading in accordance with EPA Reference Method #9. The results of theseobservations shall be kept on site and made available for inspection upon request.

Pollutant lb/hr

PM 11.7


36

is in compliance with the applicable regulations cited in thepermit application. Terra Nitrogen Limited Partnership will continue to operate in compliance withthose identified regulatory provisions. The facility will examine and analyze future regulations thatmay apply and determine their applicability with any necessary action taken on a timely basis.


37

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 is notbegun within 18 months from the date of the permit issuance if the work involved in theconstruction 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 federally regulatedrequirements, shall be tested with the following time frames: (1) Equipment to beconstructed or modified shall be tested within sixty (60) days of achieving the maximumproduction rate, but in no event later than 180 days after initial start-up of the permittedsource or (2) equipment already operating shall be tested according to the time frames setforth by the Department. The permittee shall notify the Department of the scheduled dateof compliance testing at least fifteen (15) days in advance of such test. Compliance testresults shall be submitted to the Department within thirty (30) days after the completedtesting.

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.


38

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.

Acid Rain (Title IV)

7. Pursuant to §7(a) of Regulation #26 and 40 CFR 70.6(a)(4), the permittee is prohibitedfrom causing any emissions which exceed any allowances that the source lawfully holdsunder Title IV of the Act or the regulations promulgated thereunder. No permit revisionis required for increases in emissions that are authorized by allowances acquired pursuantto the acid rain program, provided that such increases do not require a permit revisionunder any other applicable requirement. This permit establishes no limit on the numberof allowances held by the permittee. The source may not, however, use allowances as adefense to noncompliance with any other applicable requirement of this permit or the Act. Any such allowance shall be accounted for according to the procedures established inregulations promulgated under Title IV of the Act.

Title VI Provisions

8. 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.

9. 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.


39

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.

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

11. If the permittee performs a service on motor (fleet) vehicles when this service involvesozone-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 Subpart Bdoes not include the air-tight sealed refrigeration system used as refrigerated cargo, or thesystem used on passenger buses using HCFC-22 refrigerant.

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


40

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 astate or federal applicable requirement applies is not insignificant even if this activity meets thecriteria of §3(d) of Regulation 26 or is listed below. Insignificant activity determinations relyupon the information submitted by the permittee in an application dated 16 November 1999.


41


42

Pursuant to §26.3(d) of Regulation 26, the following emission units, operations, or activities havebeen determined by the Department to be insignificant activities. Activities included in this list areallowable under this permit and need not be specifically identified.

1. Combustion emissions from propulsion of mobile sources and emissions from refueling thesesources unless regulated by Title II and required to obtain a permit under Title V of thefederal Clean Air Act, as amended. This does not include emissions from any transportableunits, such as temporary compressors or boilers. This does not include emissions fromloading racks or fueling operations covered under any applicable federal requirements.

2. Air conditioning and heating units used for comfort that do not have applicable requirementsunder Title VI of the Act.

3. Ventilating units used for human comfort that do not exhaust air pollutants into the ambientair from any manufacturing/industrial or commercial process.

4. Non-commercial food preparation or food preparation at restaurants, cafeterias, or caterers,etc.

5. Consumer use of office equipment and products, not including commercial printers orbusiness primarily involved in photographic reproduction.

6. Janitorial services and consumer use of janitorial products.

7. Internal combustion engines used for landscaping purposes.

8. Laundry activities, except for dry-cleaning and steam boilers.

9. Bathroom/toilet emissions.

10. Emergency (backup) electrical generators at residential locations.

11. Tobacco smoking rooms and areas.

12. Blacksmith forges.

13. Maintenance of grounds or buildings, including: lawn care, weed control, pest control, andwater washing activities.


1 Cleaning and painting activities qualify if they are not subject to VOC or HAP control requirements. Asphalt batch plant owners/operatorsmust get a permit.

2 “Moved by hand” means that it can be moved by one person without assistance of any motorized or non-motorized vehicle, conveyance,or device.

3 Brazing, soldering, and welding equipment, and cutting torches related to manufacturing and construction activities that emit HAP metalsare more appropriate for treatment as insignificant activities based on size or production thresholds. Brazing, soldering, and welding equipment,and cutting torches related directly to plant maintenance and upkeep and repair or maintenance shop activities that emit HAP metals are treatedas trivial and listed separately in this appendix.

4 Exemptions for storage tanks containing petroleum liquids or other volatile organic liquids are based on size and limits including storagetank capacity and vapor pressure of liquids stored and are not appropriate for this list.

43

14. Repair, up-keep, maintenance, or construction activities not related to the sources’ primarybusiness activity, and not otherwise triggering a permit modification. This may include, butis not limited to such activities as general repairs, cleaning, painting, welding, woodworking,plumbing, re-tarring roofs, installing insulation, paved/paving parking lots, miscellaneoussolvent use, application of refractory, or insulation, brazing, soldering, the use of adhesives,grinding, and cutting.1

15. Surface-coating equipment during miscellaneous maintenance and construction activities.This activity specifically does not include any facility whose primary business activity issurface-coating or includes surface-coating or products.

16. Portable electrical generators that can be “moved by hand” from one location to another.2

17. Hand-held equipment for buffing, polishing, cutting, drilling, sawing, grinding, turning, ormachining wood, metal, or plastic.

18. Brazing or soldering equipment related to manufacturing activities that do not result inemission of HAPs.3

19. Air compressors and pneumatically operated equipment, including hand tools.

20. Batteries and battery charging stations, except at battery manufacturing plants.

21. Storage tanks, vessels, and containers holding or storing liquid substances that do not containany VOCs or HAPs.4

22. Storage tanks, reservoirs, and pumping and handling equipment of any size containing soaps,vegetable oil, grease, animal fat, and no volatile aqueous salt solutions, provided appropriatelids and covers are used and appropriate odor control is achieved.

23. Equipment used to mix and package soaps, vegetable oil, grease, animal fat, and non-volatile


44

aqueous salt solutions, provided appropriate lids and covers are used and appropriate odorcontrol is achieved.

24. Drop hammers or presses for forging or metalworking.

25. Equipment used exclusively to slaughter animals, but not including other equipment atslaughter-houses, such as rendering cookers, boilers, heating plants, incinerators, andelectrical power generating equipment.

26. Vents from continuous emissions monitors and other analyzers.

27. Natural gas pressure regulator vents, excluding venting at oil and gas productionfacilities.

28. Hand-held applicator equipment for hot melt adhesives with no VOCs in the adhesive.

29. Lasers used only on metals and other materials which do not emit HAPs in the process.

30. Consumer use of paper trimmers/binders.

31. Electric or steam-heated drying ovens and autoclaves, but not the emissions from the articlesor substances being processed in the ovens or autoclaves or the boilers delivering the steam.

32. Salt baths using non-volatile salts that do not result in emissions of any air pollutant coveredby this regulation.

33. Laser trimmers using dust collection to prevent fugitive emissions.

34. Bench-scale laboratory equipment used for physical or chemical analysis not including labfume hoods or vents.

35. Routine calibration and maintenance of laboratory equipment or other analytical instruments.

36. Equipment used for quality control/assurance or inspection purposes, including samplingequipment used to withdraw materials for analysis.

37. Hydraulic and hydrostatic testing equipment.

38. Environmental chambers not using hazardous air pollutant gases.

39. Shock chambers, humidity chambers, and solar simulators.

40. Fugitive emissions related to movement of passenger vehicles, provided the emissions are


45

not counted for applicability purposes and any required fugitive dust control plan or itsequivalent is submitted.

41. Process water filtration systems and demineralizers.

42. Demineralized water tanks and demineralizer vents.

43. Boiler water treatment operations, not including cooling towers.

44. Emissions from storage or use of water treatment chemicals, except for hazardous airpollutants or pollutants listed under regulations promulgated pursuant to Section 112(r) ofthe Act, for use in cooling towers, drinking water systems, and boiler water/feed systems.

45. Oxygen scavenging (de-aeration) of water.

46. Ozone generators.

47. Fire suppression systems.

48. Emergency road flares.

49. Steam vents and safety relief valves.

50. Steam leaks.

51. Steam cleaning operations.

52. Steam and microwave sterilizers.

53. Site assessment work to characterize waste disposal or remediation sites.

54. Miscellaneous additions or upgrades of instrumentation.

55. Emissions from combustion controllers or combustion shutoff devices but notcombustion units itself.

56. Use of products for the purpose of maintaining motor vehicles operated by the facility, notincluding air cleaning units of such vehicles (i.e. antifreeze, fuel additives).

57. Stacks or vents to prevent escape of sanitary sewer gases through the plumbing traps.

58. Emissions from equipment lubricating systems (i.e. oil mist), not including storage tanks,unless otherwise exempt.


46

59. Residential wood heaters, cookstoves, or fireplaces.

60. Barbecue equipment or outdoor fireplaces used in connection with any residence orrecreation.

61. Log wetting areas and log flumes.

62. Periodic use of pressurized air for cleanup.

63. Solid waste dumpsters.

64. Emissions of wet lime from lime mud tanks, lime mud washers, lime mud piles, lime mudfilter and filtrate tanks, and lime mud slurry tanks.

65. Natural gas odoring activities unless the Department determines that emissions constitute airpollution.

66. Emissions from engine crankcase vents.

67. Storage tanks used for the temporary containment of materials resulting from an emergencyreporting of an unanticipated release.

68. Equipment used exclusively to mill or grind coatings in roll grinding rebuilding, and moldingcompounds where all materials charged are in paste form.

69. Mixers, blenders, roll mills, or calenders for rubber or plastic for which no materials inpowder form are added and in which no organic solvents, diluents, or thinners are used.

70. The storage , handling, and handling equipment for bark and wood residues not subject tofugitive dispersion offsite (this applies to the equipment only).

71. Maintenance dredging of pulp and paper mill surface impoundments and ditches containingcellulosic and cellulosic derived biosolids and inorganic materials such as lime, ash, or sand.

72. Tall oil soap storage, skimming, and loading.

73. Water heaters used strictly for domestic (non-process) purposes.

74. Facility roads and parking areas, unless necessary to control offsite fugitive emissions.

75. Agricultural operations, including onsite grain storage, not including IC engines or grainelevators.


47

76. The following natural gas and oil exploration production site equipment: separators,dehydration units, natural gas fired compressors, and pumping units. This does not includecompressors located on natural gas transmission pipelines.


48

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 18 orthe Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the soleorigin of and authority for the terms or conditions are not required under the Clean Air Actor any of its applicable requirements, and are not federally enforceable under the Clean AirAct. Arkansas Pollution Control & Ecology Commission Regulation 18 was adoptedpursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.).Any terms or conditions included in this permit which specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority for the termsor 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 Operating AirPermit Program (Regulation 26), this permit shall be valid for a period of five (5) yearsbeginning 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 permit expiration.Permit expiration terminates the permittee's right to operate unless a complete renewalapplication was submitted at least six (6) months prior to permit expiration, in which casethe existing permit shall remain in effect until the Department takes final action on therenewal application. The Department will not necessarily notify the permittee when thepermit 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 more stringentthan an applicable requirement of regulations promulgated under Title IV of the Act, bothprovisions are incorporated into the permit and shall be enforceable by the Director orAdministrator.

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

i.The date, place as defined in this permit, and time of sampling or measurements;ii.The date(s) analyses were performed;iii.The company or entity that performed the analyses;iv.The analytical techniques or methods used;v.The results of such analyses; and vi.The operating conditions existing at the time of sampling or measurement.

6. Pursuant to 40 C.F.R. 70.6(a)(3)(ii)(B) and §26.7 of Regulation #26, records of all required


49

monitoring data and support information shall be retained for a period of at least 5 years fromthe date of the monitoring sample, measurement, report, or application. Support informationincludes all calibration and maintenance records and all original strip-chart recordings forcontinuous monitoring instrumentation, and copies of all reports 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 month ofthis permit. The report shall be due within 30 days of the end of the reporting period. Eventhough the reports are due every six months, each report shall contain a full year of data. Allinstances of deviations from permit requirements must be clearly identified in such reports.All required reports must be certified by a responsible official as defined in §26.2 ofRegulation #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 and 19.602of Regulation #19, all deviations from permit requirements, including those attributable toupset conditions as defined in the permit shall be reported to the Department. An initialreport shall be made to the Department by the next business day after the occurrence. Theinitial report may be made by telephone and shall include:

i.The facility name and location,ii.The process unit or emission source which is deviating from the permit limit, iii.The permit limit, including the identification of pollutants, from which deviationoccurs, iv.The date and time the deviation started, v.The duration of the deviation, vi.The average emissions during the deviation,vii.The probable cause of such deviations,viii.Any corrective actions or preventive measures taken or being taken to preventsuch deviations in the future, and ix.The name of the person submitting the report.


50

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 length oftime for which said limits are exceeded. If the permittee wishes, they may submit a fullreport in writing (by facsimile, overnight courier, or other means) by the next business dayafter discovery of the occurrence and such report will serve as both the initial report and fullreport.

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 provision orapplication, and to this end, provisions of this Regulation are declared to be separable andseverable.

10. Pursuant to 40 C.F.R. 70.6(a)(6)(i) and §26.7 of Regulation #26, the permittee must complywith all conditions of this Part 70 permit. Any permit noncompliance with applicablerequirements as defined in Regulation #26 constitutes a violation of the Clean Air Act, asamended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; for permittermination, revocation and reissuance, or modification; or for denial of a permit renewalapplication. Any permit noncompliance with a state requirement constitutes a violation ofthe Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) and is alsogrounds for enforcement action; for permit termination, revocation and reissuance, ormodification; 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 defense fora permittee in an enforcement action that it would have been necessary to halt or reduce thepermitted activity in order to maintain compliance with the conditions of this permit.


51

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 a requestby the permittee for a permit modification, revocation and reissuance, or termination, or ofa notification of planned changes or anticipated noncompliance does not stay any permitcondition.

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 shall furnishto the Director, within the time specified by the Director, any information that the Directormay request in writing to determine whether cause exists for modifying, revoking andreissuing, or terminating the permit or to determine compliance with the permit. Uponrequest, the permittee shall also furnish to the Director copies of records required to be keptby the permit. For information claimed to be confidential, the permittee may be required tofurnish such records directly to the Administrator along with 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 in thispermit.

17. Pursuant to 40 C.F.R. 70.6(a)(9)(i) and §26.7 of Regulation #26, if the permittee is allowedto operate under different operating scenarios, the permittee shall, contemporaneously withmaking a change from one operating scenario to another, record in a log at the permittedfacility a record of the scenario under which the facility or source is operating.

18. Pursuant to 40 C.F.R. 70.6(b) and §26.7 of Regulation #26, all terms and conditions in thispermit, 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.


52

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 allow anauthorized representative of the Department, upon presentation of credentials, to perform thefollowing:

i.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;ii.Have access to and copy, at reasonable times, any records that must be kept underthe conditions of this permit;iii.Inspect at reasonable times any facilities, equipment (including monitoring and airpollution control equipment), practices, or operations regulated or required under thispermit; and iv.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 submit acompliance 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 the Department.All compliance certifications required by this permit shall include the following:

i.The identification of each term or condition of the permit that is the basis of thecertification; ii.The compliance status;iii.Whether compliance was continuous or intermittent;iv.The method(s) used for determining the compliance status of the source, currentlyand over the reporting period established by the monitoring requirements of thispermit; and v.Such other facts as the Department may require elsewhere in this permit or by§114(a)(3) and 504(b) of the Act.


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

i.The provisions of Section 303 of the Act (emergency orders), including theauthority of the Administrator under that section;ii.The liability of the permittee for any violation of applicable requirements prior toor at the time of permit issuance;iii.The applicable requirements of the acid rain program, consistent with §408(a) ofthe Act; oriv.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 permit authorizesonly those pollutant emitting activities addressed herein.

APPENDIX AAPPENDIX AAPPENDIX AAPPENDIX A

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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

56

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

57

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

58

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

59

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

60

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

APPENDIX BAPPENDIX BAPPENDIX BAPPENDIX B

APPENDIX CAPPENDIX CAPPENDIX CAPPENDIX C

APPENDIX DAPPENDIX DAPPENDIX DAPPENDIX D

Public Notice

Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 6(b), the AirDivision of the Arkansas Department of Pollution Control and Ecology gives the following notice:

Terra Nitrogen Limited Partnership, 6054 State Highway 18 East, Blytheville, Arkansas 72315manufactures ammonia, urea, and urea ammonium nitrate fertilizer. The facility is installing asecond flare stack. The new flare stack is similar to the existing flare stack and is used only forprotracted power interruptions or in the event both the stand-by and the primary compressors failsimultaneously (the flares incidence of use averages less than once per year). Yearly emissions forthe facility's predominate pollutant (ammonia) will not increase. The aggregate increase for allpollutants is less than 0.5 tons per year based on the pilot burners only. The facility is subject toregulation under the Arkansas Air Pollution Control Code (Air Code), the regulations of theArkansas Plan of Implementation for Air Pollution Control (SIP), and the regulations of theOperating Air Permit Program (Title V).

The application has been reviewed by the staff of the Department and has received the Department'stentative approval subject to the terms of this notice.

Citizens wishing to examine the permit application and staff findings and recommendations may doso by contacting Suzanne Carswell. Citizens desiring technical information concerning theapplication or permit should contact Richard Nissen. Both Suzanne Carswell and Richard Nissencan be reached at the Department's central office, 8001 National Drive, Little Rock, Arkansas 72209(501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy ofthe draft permit has also been placed at the Blytheville Public Library, 200 North Fifth, Blytheville,Arkansas 72315. This information may be reviewed during normal business hours.

Interested or affected persons may also submit written comments or request a hearing on the proposalto the Department at the above address - Attention: . In orderto be considered,

the comments must be submitted within thirty (30) days of publication of this notice. Although theDepartment is not proposing to conduct a public hearing, one will be scheduled if significantcomments on the permit provisions are received. If a hearing is scheduled, adequate public noticewill be given in the newspaper of largest circulation in the county in which the facility in questionis, or will be, located.

The Director shall make a final decision to issue or deny this application or to impose specialconditions in accordance with Section 2.1 of the Arkansas Pollution Control and Ecology'sCommission Administrative Procedures (Regulation #8) and Regulation #26.

Dated this

Randall Mathis Director

INVOICE REQUEST FORM

PDS-

X Air

NPDES

Stormwater

State Permits Branch

Solid Waste

CS

Documents

ADEQ OPERATING AIR PERMIT€¦ · The process consists of three major sections: steam methane reforming, synthesis gas purification, and ammonia synthesis. Once the liquid ammonia