### Enclosure 5a

Page 1 of 13 

## EPA Information Collection R equest for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name Agrium Kennewick Fertilizer Operations (KFO)

Facility owner (ultimate parent owner) Agrium Inc

P lant 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

– 197 7

Plant 7

– 19 5 9

- has not operated since 2002

Information for Each Nitric Acid Production Line

(c hange 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 T ype ( 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 Hour s /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

Pero xide 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 H 2 O 2 process or

selective catalytic reduction to

control NOx emissions from

KFO’s Plant 9.”

We currently are opting to

use hydrogen peroxide.

% Control Efficien cy (based on most

recent compliance test) Line 1 Line 2 Line 3

NO X No current information No current

information

NO No current information No current

information

NO 2 No current information No current

information

Permit Limits for Each Nitric Acid P roduction Line

(F ill in all applicable rows)

Line 1 Line 2 Line 3

NO X Emissions ( tpy) 47 tons / in any consecutive

12

- month period 27 tons /12

- month

NO X 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

NO X Emissions (lb/ton of 100%

acid) Average of 0.6 lbs /ton 10 0 %

acid in any continuous 12

- month period 0.524 lbs /ton

Permitted NO X 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)

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Page 3 of 13 

## For each control device, please provide the key design parameter s

Extended Absorption (Nitric Acid Product ion Line Name )

Length Plant 9

-

Design Information

(gal/ 10 3 acfm, etc) Two absorption towers, 12 ft. diameter, 50 feet high each, containing

50 absorption trays.

O peration and M aintenance required

(Last 10 years) No significant maintenance re quired, other than cleaning the inside

of the cooling coils.

Y ea r 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 a dditive (i.e., hydrogen

peroxide) Plant 9

– Hydrogen Peroxide

Concentration of additive (%): 50%

Explain the process: H 2 O 2 is added to the absorption water going to the towers

continuously during operation of the acid plant.

Addition rate (gall ons 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 opera ted

since 2002.

Catalyst Life (Design/Actual)

Catalyst Volume ( m 3 )

Flow rate (scfm)

Ammonia i njection rate (lb/hr)

Operation and Maintenance required

(Last 10 years) Note

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

since 2 002

.

Y ea r 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, H 2 , etc) Plant 7

– na tural 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.

Y ea r 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 Inform ation by Control Technology

Pro duction Line Pollutant

Controlled Control

Technology Capital

(Yr of Cost basis) Annual O & M

(Yr of cost basis)

Plant 9 NOx Extended

Absorption, H 2 O 2

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 not es 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 AM E TEK 920 UV Photometric Analyzer

.

Plant 7 has an AM E TEK 920 UV Photometric Analyzer

CEMS Manufactu rer Plant 9

– GASMET

Plant 7

– AM E TEK

CEMS Model Number Plant 9

- F TIR 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

– ( AM E TEK )

- 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 NO 2 ? Plant 9

– GASMET

– YES

Plant 7

– AM E TEK

– YES

I dentify all periods of startup,

s hutdown, 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 question n aire.

Plant 7

– AM E TEK 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 per formed 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

– AM E TEK

– 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 m

onthly and a nnual NO X 

### CEMS data for the last 3 years. Please submit the CEMS

data electronically

.

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

### , 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,

2 007 (3 documents).

Sampling plan and Stack test report for 2010 Plant 9 stack testing

– Method 7E (currently

scheduled for late Mar ch 2010)

.

Note: W e are w aiting for information from our stack sampling contactor regarding the

stack testing methodology for 200 5, 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 

## Gen eral 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 th is 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 o 

### F . Condensation in the sampling train is a very minor concern.

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

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Page 10 of 13 

## Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NO X 

### or NH 3 

### expected during a startup,

shutdown, and malfunction event.

Plant 9

– SU emission s vary from as high as ~1,000 ppm to as low as 3 00 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 the y could be as high as 3,000 to 4,000 ppm.

2. Please describe how long excess/elevated emissions NO X 

### or NH 3 

### 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 exce ss/elevated emissions of NO X 

### or NH 3 

### during startup,

shutdown, and malfunction events.

Plant 9

– Begin hydrogen peroxide feed to the towers a head of start

- up.

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

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Page 11 of 13 

## Emission Testing

1

. Include emissions testing conducted during the last five years. Includ e tests for NO X 

### , and

NH 3 

### . 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 NO X 

### ) data can be submitted, but only if the testing was performed with the

following modifications for nitric acid plants. Because of the propensity of NO 2 

### to be

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

any NO 2 

### to NO converter (if needed by the detection principle of the i nstrument) 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 perf ormance tests and documentation required

by the method, both prior to and following sampling. NO 2 

### 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 dy namic spike procedure in Section 16.1 is acceptable, but only

with NO 2 

### spike gas. The dynamic spiking procedure is strongly recommended.

4

. If you do not have emission test data for NO X 

### using a method in note 2 or using Method 7E

according to the modified pro tocol in note 3

, you must conduct a stack test to determine NO X 

### emissions following one of the approved methods above.

5

. If you do not have emission test data for NH 3 

### , you must conduct a stack test to determine the

emissions using the procedures of Method 32 0.

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 S D

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 a ttempt

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

7/6/200 7 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)

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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 S U

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

5/3 0/2009 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