Enclosure 5a

Page 1 of 13

EPA Information Collection Request for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name Agrium Kennewick Fertilizer Operations (KFO)

Facility owner (ultimate parent owner) Agrium Inc

Plant Location - Address 227515 Bowles Road

Latitude/Longitude for Plant Latitude 46.1678 Longitude -119.0227

Describe location of latitude/longitude Semi-rural un-incorporated Benton County, SE of 

City, State, ZIP code Kennewick WA 99337

Year plant began operation

Plant 9 – 1977

Plant 7 – 1959 - has not operated since 2002

Information for Each Nitric Acid Production Line

(change names as needed and use the same names in the Excel spreadsheet)

Line 1 Line 2 Line 3

Year line began operation Plant 9 – 1977 Plant 7 – 1959

Production Rate (Tons/Day of 

100% Acid) 650 210

Production Rate Range (Tons/Day of 

100% Acid) 780 250

Subject to Subpart G? Yes No

Process Type (high/low pressure) High Pressure Medium Pressure

Oxidation pressure (psia) 153 psia ~120 (est.)

Absorption pressure (psia) 145 psia ~115 (est.)

% Acid strength Typically Produced 57% 57%

Operating Hours/Year Line 1 Line 2 Line 3

2009 3,360 0

2008 5,184 0

2007 5,256 0

2006 3,360 0

Control Technology 

(list as many as applicable)

Ext Absorption & Hydrogen 

Peroxide injection to 

absorption columns NSCR & SCR
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 2 of 13

Also, “Agrium is free to use 

either the H2O2 process or 

selective catalytic reduction to 

control NOx emissions from 

KFO’s Plant 9.”

We currently are opting to 

use hydrogen peroxide.

% Control Efficiency (based on most 

recent compliance test)

Line 1 Line 2 Line 3

NOX No current information

No current 

information

NO No current information

No current 

information

NO2 No current information

No current 

information

Permit Limits for Each Nitric Acid Production Line

(Fill in all applicable rows)

Line 1 Line 2 Line 3

NOX Emissions (tpy) 47 tons /in any consecutive 

12-month period 27 tons /12-month

NOX Emissions (lb/hr)

(lbs/day)

400 lbs /calendar day

? 140 lbs /day from 

11/1 to 4/30

? 190 lbs /day from 5/1 

to 10/31

NOX Emissions (lb/ton of 100% 

acid)

Average of 0.6 lbs /ton 100% 

acid in any continuous 12-

month period 0.524 lbs /ton

Permitted NOX control efficiency, if 

applicable

If your permit includes limits for 

other pollutants, please include as 

much detail as possible below:

Line 1 Line 2 Line 3
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 3 of 13

For each control device, please provide the key design parameters 

Extended Absorption (Nitric Acid Production Line Name)

Length Plant 9 -

Design Information

(gal/ 10 3acfm, etc)

Two absorption towers, 12 ft. diameter, 50 feet high each, containing 

50 absorption trays.

Operation and Maintenance required

(Last 10 years)

No significant maintenance required, other than cleaning the inside 

of the cooling coils.

Year absorption capacity was added

1977 – year built. Initial design included two absorption towers to 

meet NSPS 3.0 lbs/ton.

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen 

peroxide) Plant 9 – Hydrogen Peroxide

Concentration of additive (%): 50%

Explain the process:

H2O2 is added to the absorption water going to the towers 

continuously during operation of the acid plant.

Addition rate (gallons per hour): 8 – 15 gallons per hour

Ratio of additive to water: ~0.0063
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 4 of 13

SCR (Nitric Acid Production Line Name)

Type of Catalyst Plant 7 - NSCR, SCR

Is Catalyst New or Regenerated?

Note – Plant 7 is not currently in operation, and has not operated 

since 2002.

Catalyst Life (Design/Actual)

Catalyst Volume (m

3

)

Flow rate (scfm)

Ammonia injection rate (lb/hr)

Operation and Maintenance required

(Last 10 years)

Note – Plant 7 is not currently in operation, and has not operated 

since 2002.

Year began operation Plant 7 NSCR was installed in 1977, Plant 7 SCR was added in 2001.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 5 of 13

For each control device, please provide the key design parameters

NSCR (Nitric Acid Production Line Name)

Reductant used (methane, H2, etc) Plant 7 – natural gas (methane)

Rate of reductant used Note – Plant 7 is not currently in operation, and has not operated 

since 2002.

Type of catalyst

Catalyst Volume (m

3

)

Flow rate (scfm)

Is Catalyst New or Regenerated?

Catalyst Life (Design/Actual)

Operation and Maintenance required 

(Last 10 years)

Note – Plant 7 is not currently in operation, and has not operated 

since 2002.

Year began operation Plant 7 NSCR was installed in 1977, Plant 7 SCR was added in 2001.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 6 of 13

Cost Information by Control Technology

Production Line

Pollutant 

Controlled

Control 

Technology

Capital

(Yr of Cost basis)

Annual O & M

(Yr of cost basis)

Plant 9 NOx Extended 

Absorption, H2O2

addition to 

absorbing towers

~ $150,000

(2004)

~ $300,000

(2010)

Plant 7 NOx NSCR Capital cost data 

not available (1973)

No current data 

available

Plant 7 NOx SCR Capital cost data 

not available 

(~2000)

No current data 

available

Please provide additional cost information, comments, or notes below:
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 7 of 13

Continuous Emission Monitoring Systems

CEMS Information

? Plant CEMS data recorded 

concurrent with test runs (i.e., 

concentration, etc.).

Plant 9 - GASMET FXS FTIR Gas Analyzer since June 2009. 

Previously an AMETEK 920 UV Photometric Analyzer.

Plant 7 has an AMETEK 920 UV Photometric Analyzer

CEMS Manufacturer Plant 9 – GASMET

Plant 7 – AMETEK

CEMS Model Number Plant 9 - FTIR FXS

Plant 7 – 920 UV Photometric Analyzer

Description of sample extraction and 

conditioning or dew point 

maintenance systems

Plant 9 – (GASMET) – Sample is extracted by an eductor through 

the analyzer. Temperature is maintained ~350 deg. F by heat 

tracing.

Plant 7 – (AMETEK) - Sample is extracted by a sample pump 

through the analyzer. Temperature is maintained ~350 deg. F by 

heat tracing.

Ability to distinguish between NO 

and NO2? Plant 9 – GASMET – YES

Plant 7 – AMETEK – YES

Identify all periods of startup, 

shutdown, and malfunction,

regardless of whether the event 

caused an exceedence (during the 

past 3 years)

Plant 9 – see table inserted at the end of this questionnaire.

Plant 7 – AMETEK Plant 7 is not currently in operation, and has 

not operated since 2002.

Capital costs Plant 9 - $75,000

Operation and Maintenance costs Plant 9 - ~ $50,000 /yr

Cost of quarterly audits

Quarterly Cylinder Gas Audits are performed by in-house 

technicians. Cost is for calibration gas and man-hours. 

Year began operation

Plant 9 – GASMET – 2009

Plant 9 – AMETEK - from ~1997 to 2009

Plant 7 – AMETEK – from ~2001 to 2002, plant not currently in 

operation.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 8 of 13

CEMS Data (Monthly and Annual)

Include monthly and annual NOX CEMS data for the last 3 years. Please submit the CEMS 

data electronically.

The following information and data will be submitted before June 2nd, 2010:

Monthly NOx data reduction /calculation sheets for 2009, 2008, 2007 (36 documents).

December NOx Report spreadsheet with rolling average for all 12 months for 2009, 2008, 

2007 (3 documents).

Sampling plan and Stack test report for 2010 Plant 9 stack testing –Method 7E (currently 

scheduled for late March 2010).

Note: We are waiting for information from our stack sampling contactor regarding the 

stack testing methodology for 2005, 2006, 2007, 2008, and 2009. Stack testing done in the 

last 5-years may not qualify with the criteria in Enclosure 7.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 9 of 13

General Discussion

1. Please provide your thoughts on trends in nitric acid production as far as type of process 

that is used; types of absorber used, trends in selecting control devices, improvements in 

control efficiency in existing control devices, energy efficiency.

2. Please describe your thoughts on the air pollution controls that are used at your facility such 

as reliability, O&M costs including energy penalty, etc.

3. Please provide recommendations on the revisions you would like to see in this NSPS.

The nitric acid plant NSPS should allow Method 7E as a source testing method. Nitric 

acid gas streams are hot and very dry – usually 0.0 to 0.5% moisture and a temperature 

over 300 oF. Condensation in the sampling train is a very minor concern.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 10 of 13

Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NOX or NH3 expected during a startup, 

shutdown, and malfunction event. 

Plant 9 – SU emissions vary from as high as ~1,000 ppm to as low as 300 ppm.

Plant 9 – SD emission may be as high as ~1,000 ppm to as low as 300 ppm.

A malfunction is an uncontrolled event and the duration and ppm concentration cannot 

be predicted. If serious enough we would shut down the plant. If emissions were 

completely uncontrolled they could be as high as 3,000 to 4,000 ppm.

2. Please describe how long excess/elevated emissions NOX or NH3 will typically occur during 

a startup, shutdown, and malfunction event. 

Plant 9 – SU takes from 30 minutes to two hours.

Plant 9 – SD takes from 15 minutes to one hours.

A malfunction is an uncontrolled event and the duration and ppm concentration cannot 

be predicted. 

3. Please describe any equipment or work practices that are employed to minimize or eliminate 

the quantity or duration of excess/elevated emissions of NOX or NH3 during startup, 

shutdown, and malfunction events. 

Plant 9 – Begin hydrogen peroxide feed to the towers ahead of start-up. 
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 11 of 13

Emission Testing

1. Include emissions testing conducted during the last five years. Include tests for NOX, and 

NH3. Read and follow the guidance below.

2. Test method data of interest include those performed according to EPA Methods 7, 7A, 7B, 

7C, 7D, or Method 320.

3. Method 7E (for NOX) data can be submitted, but only if the testing was performed with the 

following modifications for nitric acid plants. Because of the propensity of NO2 to be 

absorbed by water, the sampled gas must not contact any condensate, and the efficiency of 

any NO2 to NO converter (if needed by the detection principle of the instrument) must be 

determined and documented as described in the method. For wet basis measurement systems, 

the tester must measure and report temperature data to show that the sample line and all 

sample transport components up to the inlet of the analyzer (and, for hot-wet extractive 

systems, also the analyzer) were maintained above the stack gas dew point. Use of a dilution 

probe to reduce the dew point is an acceptable procedure, if documented. Section 8 of 

Method 7E describes the measurement system performance tests and documentation required 

by the method, both prior to and following sampling. NO2 calibration gas must be substituted 

for NO calibration gas in the performance of system bias checks. The alternative mentioned 

in Section 8.6 to follow the dynamic spike procedure in Section 16.1 is acceptable, but only 

with NO2 spike gas. The dynamic spiking procedure is strongly recommended.

4. If you do not have emission test data for NOX using a method in note 2 or using Method 7E 

according to the modified protocol in note 3, you must conduct a stack test to determine NOX

emissions following one of the approved methods above.

5. If you do not have emission test data for NH3, you must conduct a stack test to determine the 

emissions using the procedures of Method 320.

6. If a concentration is at or below the applicable method’s detection level, then provide 

information about the method (title and source), the calculated detection level in units of the 

applicable raw material or emissions concentration or mass rate, and the procedure for 

determining the detection level.

7. Additional stack testing guidance is contained in Enclosure 7.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 12 of 13

DATE TIME SU or 

SD MALFUNCTION NOTES

2007

2/8/2007 18:30 SU failed attempt

2/8/2007 20:05 SU failed attempt

2/8/2007 20:10 SD

2/8/2007 20:45 SU failed attempt

2/8/2007 21:00 SD

2/8/2007 22:20 SU

2/8/2007 23:46 SD

2/13/2007 18:30 SU

3/26/2007 18:05 SD trip - unknown cause 

3/26/2007 23:59 SU

4/30/2007 21:06 SD

6/4/2007 22:00 SU failed attempt

6/4/2007 23:10 SU

6/5/2007 1:40 SD

6/5/2007 22:00 SU

7/4/2007 14:22 SD trip - unknown cause 

7/4/2007 23:30 SU failed attempt

7/5/2007 22:00 SU failed attempt

7/5/2007 22:30 SU failed attempt

7/6/2007 2:50 SU

7/6/2007 4:30 SD

7/6/2007 22:00 SU failed attempt

7/7/2007 1:45 SU

8/9/2007 17:40 SD

9/6/2007 22:00 SU

9/22/2007 8:55 SD

11/1/2007 18:18 SU

12/18/2007 3:10 SD

12/18/2007 17:35 SU

12/28/2007 13:36 SD

12/29/2007 20:40 SU

2008

1/1/2008 7:10 SD trip - unknown cause

1/1/2008 20:57 SU

1/11/2008 1:53 SD NH3 compressor gasket leak

1/11/2008 19:25 SU

1/25/2008 3:10 SD Ran out of Urea for UAN-32

3/1/2008 19:10 SU

3/25/2008 22:30 SD trip - unknown cause

3/26/2008 20:45 SU

5/16/2008 18:50 SD trip - unknown cause

6/7/2008 22:10 SU

7/13/2008 10:56 SD trip - unknown cause

7/13/2008 21:54 SU failed attempt

7/18/2008 23:45 SU
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

Page 13 of 13

7/23/2008 16:25 SD trip - unknown cause

7/23/2008 17:30 SU failed attempt

7/23/2008 23:40 SU

8/18/2008 12:55 SD trip - unknown cause

8/24/2008 20:45 SU

8/24/2008 22:25 SD trip - unknown cause

8/25/2008 22:05 SU

8/25/2008 22:20 SD trip - unknown cause

8/26/2008 19:24 SU

8/27/2008 0:25 SD trip - unknown cause

10/7/2008 10:15 SU

10/7/2008 19:22 SD gradual warm-up of heat exchanger

10/7/2008 19:58 SU

11/1/2008 19:45 SD planned

12/13/2008 19:37 SU

12/13/2008 21:04 SD

12/13/2008 23:23 SU

12/26/2008 21:30 SD

12/27/2008 18:50 SU

2009

1/10/2009 04:05 SD Inventory control

2/11/2009 18:13 SU

3/4/2009 14:07 SD minor NOx leak

3/5/2009 19:41 SU

3/21/2009 19:30 SD Inventory control

5/10/2009 23:00 SU

5/30/2009 10:00 SD Trip

5/30/2009 22:00 SU

NEW CEMS INSTALLED

6/13/2009 01:00 SD Inventory control

7/27/2009 21:25 SU

8/3/2009 13:02 SD Trip

8/3/2009 23:05 SU

8/19/2009 10:10 SD Expander failure Expander damaged but working at reduced 

capacity - no exceedance of emission limits.

8/19/2009 21:10 SU

8/19/2009 23:00 SD NO GO

8/21/2009 21:15 SU

8/21/2009 22:00 SD NO GO

8/29/2009 20:40 SU Expander Replacement

9/4/2009 03:00 SD

10/10/2009 19:35 SU

10/18/2009 04:08 SD

11/12/2009 17:25 SU

11/23/2009 20:42 SD

12/26/2009 22:15 SU