Date: May 2012

Subject: Impacts of Nitric Acid 

Nitric Acid NSPS Review

EPA Contract No. EP

RTI Project No. 0210

From: Melissa Icenhour

To: Nathan Topham

OAQPS/SPPD/M

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

The EPA is required by section 111(b)(1)(B) of the Clean Air Act (CAA) to review and, if 

appropriate, revise existing New Source Performance

The nitric acid NSPS (part 60, subpart G) has been reviewed in the past but the last review was 

more than 8 years ago. As a result of this, 

and Environmental Integrity Project prompting 

The purpose of an NSPS review is to determine if the standards reflect the “degree of emissions 

limitation achievable through application of the best system of emission reduction which (taking 

into account the cost of achieving such reduction and any nonair quality health and 

environmental impact and energy requirements) the Administrator determines has been 

adequately demonstrated.”

The EPA requested information from companies operating nitric acid 

114 authority to obtain short term 

7E (modified version), or 320 and

emissions monitoring systems (CEMS)

technologies, including nonselective catalytic reduction (NSCR), selective catalytic reduction 

(SCR), and H2O2 injection. Cost data w

production trains. This information was summarized in 

Section 114 ICR (NOX Summary) 

based on 7% interest and 15 year useful life.

1

Impacts of Nitric Acid NSPS Review—NOX (Updated Memo for Final NSPS)

Nitric Acid NSPS Review

EPA Contract No. EP-D-11-084; Work Assignment No. 0-01 

RTI Project No. 02103199.000.001

OAQPS/SPPD/MICG (D243-02)

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

The EPA is required by section 111(b)(1)(B) of the Clean Air Act (CAA) to review and, if 

appropriate, revise existing New Source Performance Standards (NSPS) at least every 8 years.

The nitric acid NSPS (part 60, subpart G) has been reviewed in the past but the last review was 

more than 8 years ago. As a result of this, the EPA has received a citizen suit from Sierra Club 

tegrity Project prompting a review of the standards.

The purpose of an NSPS review is to determine if the standards reflect the “degree of emissions 

limitation achievable through application of the best system of emission reduction which (taking 

unt the cost of achieving such reduction and any nonair quality health and 

environmental impact and energy requirements) the Administrator determines has been 

requested information from companies operating nitric acid plants under CAA

short term NOX emissions data using EPA Methods 7, 7A, 7B, 7C, 7D, 

and long term NOX emissions data using NOX continuous 

emissions monitoring systems (CEMS). The EPA also collected cost data for NO

technologies, including nonselective catalytic reduction (NSCR), selective catalytic reduction 

. Cost data were received from 9 facilities with a total of 12 nitric acid 

. This information was summarized in Summary of Cost Data Received from 

Summary) dated November 22, 2010. The capital recovery factor was 

based on 7% interest and 15 year useful life.

(Updated Memo for Final NSPS)

The EPA is required by section 111(b)(1)(B) of the Clean Air Act (CAA) to review and, if 

Standards (NSPS) at least every 8 years.

The nitric acid NSPS (part 60, subpart G) has been reviewed in the past but the last review was 

EPA has received a citizen suit from Sierra Club 

The purpose of an NSPS review is to determine if the standards reflect the “degree of emissions 

limitation achievable through application of the best system of emission reduction which (taking 

unt the cost of achieving such reduction and any nonair quality health and 

environmental impact and energy requirements) the Administrator determines has been 

plants under CAA Section 

Methods 7, 7A, 7B, 7C, 7D, 

continuous 

NOX abatement 

technologies, including nonselective catalytic reduction (NSCR), selective catalytic reduction 

with a total of 12 nitric acid 

Summary of Cost Data Received from 

apital recovery factor was 
2

The purpose of this memo is to calculate the expected cost impacts for new and modified sources 

to meet a standard of 0.50 lb NOX/ton nitric acid.

The NOX Summary memo contained production data ranging from 40 tons per day (tpd) to 1,600 

tpd of nitric acid. The data supports the use of two model plants to represent the nitric acid 

production industry. The first model plant size is 300 tpd and the second model plant size is 

1,000 tpd. In the NOX Summary memo, the cost data were normalized based on the production 

rate at the facility (cost per ton of nitric acid produced). Table 1 shows the results of the cost data 

analysis for NOX control. These cost estimates are based on the installation costs gathered 

through the Section 114 request for information. They are shown here for comparison. Their 

inclusion is not an indication of the level of control that can be achieved with these control 

devices. CEMS data, as summarized in Statistical Evaluation of CEMS Data to Determine the 

NOX Emission Standard (Updated Memo for Final Standard), indicate that SCR and some NSCR 

units achieve a 30 day rolling emission rate of 0.50 lb NOX/ton acid. Available CEMS data from 

1 facility using H2O2 injection indicate that the unit has emissions greater than 0.50 lb NOX/ton 

acid, However, due to the limited data set (only from 1 facility), installing H2O2 injection may

meet 0.50 lb NOX/ton acid.

Table 1. Normalized NOX Control Costs by Model Plant for New Sources 

Control 300 tpd ($/ton) 1,000 tpd ($/ton)

NSCR $20.02 $7.80

SCR $3.93 $1.10

H2O2 Injection $2.06 $1.36

The conclusion that selective catalytic reduction (SCR) is BSER has not changed from proposal. 

The justification includes the following reasons: (1) SCR is the only known NOX control 

technology being installed in new NAPUs; (2) SCR has been determined to be BACT; (3) SCR 

technology is less expensive and more cost-effective than NSCR for control of NOX emissions; 

and (4) SCR produces minimal secondary environmental impacts.

Table 2 shows the control device cost (annual cost per ton of acid) for an SCR installed at 

Agrium North Bend as part of a modification to the nitric acid plant. The plant produces 288 tons 

acid per day. SCR costs associated with a modification of a 1,000 tpd plant were not supplied. 

Table 2. Normalized SCR Costs by Model Plant for Modified or Reconstructed Sources

Control

288 tpd

($/ton acid)

1,000 tpd

($/ton acid)

SCR $3.52 -----

 

Nitric acid production was estimated beginning with 2006 production data (TSD for Greenhouse 

Gas Reporting Rule), using the production growth of 6.5% from 2006 to 2007 (ICIS), the 

predicted production growth rate of 3% for 2007 through 2017 (ICIS), and the exclusion of 
3

plants that were not operating in 2010. These estimates are shown in Table 3. In the period from 

2012 through 2017, the growth is expected to be approximately 1.48 million tons of nitric acid. 

Assuming 365 days per year, this equals approximately 4,000 tpd of nitric acid production. 

Using the model plants, the estimate roughly equals 3 production trains that produce 300 tpd, and 

3 production trains that produce 1,000 tpd over the five year period after promulgation.

For purposes of this cost assessment, the growth will consist of five newly constructed 

production trains and one modification of an existing production train. These six production 

trains will become subject to the Subpart Ga limit of 0.50 lb NOX/ton acid between 2012 and 

2017.

Table 3. Nitric Acid Production Growth

Year

Nitric acid 

produced 

(metric tons)

Nitric acid 

produced (tons)

Increase 

(tons)

2010 6,729,836 7,419,644 -----------

2011 6,931,731 7,642,233 222,589

2012 7,139,683 7,871,500 229,267

2013 7,353,873 8,107,645 236,145

2014 7,574,489 8,350,874 243,229

2015 7,801,724 8,601,401 250,526

2016 8,035,776 8,859,443 258,042

2017 8,276,849 9,125,226 265,783

For the five new production trains predicted from 2012 to 2017, the annualized costs of 

controlling NOX emissions for the 3 types of control equipment outlined in The NOX Summary

were calculated using the costs in Table 1. The control costs are shown in Table 4. These are the 

costs for each of the control devices in the 5th year after promulgation of these standards.

Table 4. Annualized Control Costs for New Production Trains in 2017

Model Plant (tpd)

Number of 

Plants Nitric Acid (tons) NSCR SCR H2O2

300 2 220,000 $4,400,000 $860,000 $450,000

1,000 3 1,100,000 $8,500,000 $1,200,000 $1,500,000

For the 1 production train that will undergo modification or reconstruction from 2012 to 2017, 

the annualized costs of controlling NOX emissions for SCR were calculated using the costs in 

Table 2. The control costs are shown in Table 5. The capacity, emission reductions, and control 

costs for the modified plant are based on actual data submitted to the EPA by a modified facility.

These are the costs for each of the control devices in the 5th year after promulgation of these 

standards.
4

Table 5. Annualized Control Costs for Reconstructed or Modified Trains in 2017

Plant (tpd) Number of Plants Nitric Acid (tons) SCR

288 1 105,000 $370,000

The production trains could use any of the three control types to control NOX emissions but we 

assumed that SCR would be universally applied as this is BSER. While hydrogen peroxide 

injection has the lowest potential costs, this control may not be feasible for all production trains.

Also, some H2O2 and NSCR installations may not be able to achieve emissions less than or equal 

to 0.50 lb NOX/ton acid.

The potential NOX emission reductions were calculated in Table 6. The baseline emissions were 

calculated as 3.0 lb NOX/ton acid (the level of the existing NSPS). The controlled emissions were

calculated as 0.50 lb NOX/ton acid.

Table 6. NOX Emission Reductions for All New, Modified, or Reconstructed Production 

Trains with SCR Control in 2017

Plant 

Type

Model 

Plant 

(tpd)

Days 

per 

year

Number 

of Plants

Nitric 

Acid 

(tons)

Baseline

NOX

(tons NOX)

Controlled 

NOX

(tons NOX)

NOX

Emission 

reductions 

(tons)

New 300 365 2 220,000 355 55 300

New 1,000 365 3 1,100,000 1,779 274 1,506

Modified 288 365 1 105,000 315 17 299

TOTALS 2,449 345 2,104

The last step in calculating impacts for sources to meet the revised standard of 0.50 lb NOX/ton 

acid is to calculate the costs and reductions per year over the 5 year period after promulgation. In 

addition to control equipment, each modified or reconstructed production train will be required 

to install the following: a stack gas flow monitor and a dual range NOX concentration monitor.

The capital costs are $39,000 and $23,000, respectively. The annualized costs are $15,000 and 

$9,000, respectively. These costs were calculated using the CEMS Cost Model.

In addition to these costs, each new or modified production train will be required to perform an 

annual stack test according to Appendix F to Part 60. These testing costs were inadvertently 

excluded from the proposed rule. These tests are estimated at $12,000 per test.
5

The costs for monitoring and testing are consistent with comments received from The Fertilizer 

Institute (TFI). The requirement of a NOX CEMS was included in the existing NSPS so its cost is 

not included in this analysis.

The SCR is already being used to control NOX emissions to the current NSPS level of 3.0 lb 

NOX/ton acid. As shown in Statistical Evaluation of CEMS Data to Determine the NOX Emission 

Standard (Updated Memo for Final Standard), there are at least 3 production trains using SCR 

that already meet the revised NSPS level of 0.50 lb NOX/ton acid. The control device costs are 

based on current usage where sources are only required under an NSPS to meet 3.0 lb NOX/ton. 

Sources are not likely to have spent additional money to meet a limit of 0.50 lb NOX/ton acid

when they were only required to meet a limit of 3.0 lb NOX/ton. Therefore, we believe that the 

lower limit is achievable without additional cost impacts.

Accordingly, there is no incremental control cost to control NOX emissions for a facility that 

triggers Subpart Ga compared to the controls that would likely be installed if that same facility

triggered Subpart G. The costs of monitors and operation and maintenance costs in the 5th year 

after promulgation are shown in Table 7 and Table 8.

Table 7. Incremental Costs in 5th Year after Promulgation for All New Production Trains

Model 

Plant 

(tpd)

Number 

of

Plants

SCR Cost

($2010-2

nd

quarter)

Annual 

stack flow 

monitor cost

($2010-2

nd

quarter)

Dual range 

NOX

monitor cost

Annual 

stack 

testing 

cost

Total Annualized 

Costs

($2010-2nd

quarter)

300 2 $0 $30,000 $18,000 $24,000 $72,000

1,000 3 $0 $45,000 $27,000 $36,000 $108,000

Table 8. Incremental Costs in 5th Year after Promulgation for All Modified or 

Reconstructed Production Trains

Plant 

(tpd)

Number 

of Plants

SCR Cost

($2010-2

nd

quarter)

Annual 

stack flow 

monitor cost

($2010-2

nd

quarter)

Dual range 

NOX

monitor cost

Annual 

stack 

testing 

cost

Total Annualized 

Costs

($2010-2nd

quarter)

288 1 $370,000 $15,000 $8,900 $12,000 $406,000

Using the total monitoring costs, the cost effectiveness was also calculated. These numbers are 

shown in Table 9. 
6

Table 9. Total Incremental Cost Effectiveness in 5th Year after Promulgation for All New, 

Reconstructed, and Modified Production Trains

Plant (tpd) Type

Number 

of Plants

Total Annualized 

Costs

($2010-2

nd quarter)

NOX Emission 

reductions (tpy)

Cost 

effectiveness

($/ton NOX)

300 New 2 $72,000 300 $240

1,000 New 3 $108,000 1,500 $70

288 Mod 1 $406,000 300 $1,400

All ---- 6 $585,000 2,104 $280

For the new 300 tpd model plants, total annualized costs in the 5th year after promulgation are 

$72,000. The amount of NOX reductions expected in the 5th year after promulgation is

approximately 300 tpy. This results in a cost effectiveness of approximately $240.

For the new 1,000 tpd model plants, total annualized costs in the 5th year after promulgation are 

$108,000. The amount of NOX reductions expected in the 5th year after promulgation is 

approximately 1,500 tpy. This results in a cost effectiveness of approximately $70.

For the modified 288 tpd plant, total annualized costs in the 5th year after promulgation are 

$406,000. The amount of NOX reductions expected in the 5th year after promulgation is

approximately 300 tpy. This results in a cost effectiveness of approximately $1,400.

Overall, total annualized costs in the 5th year after promulgation are $585,000. The amount of 

NOX reductions expected in the 5th year after promulgation is approximately 2,104 tpy. This 

results in a cost effectiveness of approximately $280.
7

References

CEMS Cost Model. Updated March 2007. Accessed November 17, 2010.

Memorandum from W. C. Herz, Vice President of Scientific Affairs, The Fertilizer Institute. 

TFI Comments on New Source Performance Standards Review for Nitric Acid Plants, Docket 

No. EPA-HQ-OAR-2010-0750. Document number EPA-HQ-OAR-2010-0750-0098. November 

28, 2011.

Memorandum from M. Icenhour, RTI International, to B. Neuffer, EPA. Summary of Cost Data 

Received from Section 114 ICR. Document number EPA-HQ-OAR-2010-0750-0060. November 

22, 2010.

Memorandum from M. Icenhour, RTI International, to B. Neuffer, EPA. Statistical Evaluation of 

CEMS Data to Determine the NOX Emission Standard (Updated Memo for Final Standard). May

2012.

 

U. S. EPA. Technical Support Document for the Nitric Acid Production Sector: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases, January 22, 2009.

http://www.epa.gov/climatechange/emissions/archived/downloads/tsd/TSD%20Nitric%20Acid%

20_EPA%201-22-09.pdf.