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Icenhour, Melissa K.

From: Neuffer.Bill@epamail.epa.gov

Sent: Tuesday, October 12, 2010 1:06 PM

To: Icenhour, Melissa K.; Frank.Nathan@epamail.epa.gov

Subject: Fw: NSPS - Nitric Acid - Use of Hydrogen Peroxide

Bill Neuffer

Metals and Minerals Group

Office of Air Quality Planning and Standards (D 243-02) US Environmental Protection Agency 

Research Triangle Park, NC 27711

Phone - 919-541-5435

Fax - 919 - 541-3207

E-mail - neuffer.bill@epa.gov

Office Location: 109 TW Alexander Drive RTP, NC (D 231C)

Overnight mail address:

US EPA

Mail Code D243-02

109 TW Alexander Drive

RTP, NC 27709

----- Forwarded by Bill Neuffer/RTP/USEPA/US on 10/12/2010 01:05 PM

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 |"Klein, Thomas" <TKlein@agrium.com> 

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 |Bill Neuffer/RTP/USEPA/US@EPA 

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| Date: |

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 |10/11/2010 12:18 PM 

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| Subject: |
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 |RE: NSPS - Nitric Acid - Use of Hydrogen Peroxide 

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Bill:

Below are our comments on your three areas of discussion.

1. Agrium's Plant 9 has the option of using H2O2 or SCR as the

control. Please explain in detail why H2O2 was selected.

BACT was determined to be 0.6 lb/t or about 40 ppm. The BACT analysis showed SCR as a control 

technology that could achieve these levels.

During the technology review H2O2 was identified as a known technology for controlling NOx. 

At the time of permitting in 2005 the long term operation of the facility was uncertain. 

Treatment with hydrogen peroxide had a substantially lower initial capital cost, but a higher 

on-going operating cost for reagent H2O2. We made a business decision to go with the lowest 

possible initial capital cost and demonstrate through the innovative control technology 

provisions that H2O2 can meet the 40 ppm limit.

2. Please discuss your operating experience with H2O2 - good and

bad.

Good

? Peroxide provides a certain level of NOx control during startup and shutdown control not 

provided by SCR.

? The capital costs for peroxide are lower that for SCR.

Bad

? Hydrogen peroxide requires close monitoring and adjustment by the operators.

? For peroxide to achieve 0.6 lbs NOx/ton of acid, the following conditions are required:

 a. high absorber pressure

 b. chilled water to reduce the process gas temperature

 c. higher oxygen content in the absorbing towers

 Many nitric acid plants would not be able to meet the required process conditions to 

enable successful NOx control with hydrogen peroxide. The Agrium KFO nitric acid plant meets 

the above mentioned process conditions and H2O2 control is a viable control for our site.

3. If a new nitric acid process line is installed, which NOx

control would you select to achieve your permit limit of 0.6 lb/T?

Please explain the reasons.

SCR would probably be more economic over a longer time period. Any new nitric acid line 

would probably be based on an extended operating lifetime. Operation of an existing facility 

with a business plan that extended out beyond the economic break point between SCR and 
3

peroxide would favor SCR. A new nitric acid process line would require a new BACT review. 

We would need to use the BACT determination to identify the optimal control technology/limit.

Thank you,

Tom Klein

Agrium US Inc - Kennewick Fertilizer Operations (KFO)

227515 Bowles Rd

Kennewick, WA 99337

509-586-5488

tklein@agrium.com

-----Original Message-----

From: Neuffer.Bill@epamail.epa.gov [mailto:Neuffer.Bill@epamail.epa.gov]

Sent: Wednesday, September 15, 2010 12:03 PM

To: Klein, Thomas

Subject: NSPS - Nitric Acid - Use of Hydrogen Peroxide

Tom,

 Thanks for talking with me today. As we discussed we are interested in obtaining more 

information on the use of this control.

The information you supplied in the ICR and subsequent emission test results for Plant 9 at 

Kennick, WA indicate that H2O2 is a control that we should evaluate as part of this NSPS. 

Please provide information on the following:

 1 -Agrium's Plant 9 has the option of using H2O2 or SCR as the control. Please 

explain in detail why H2O2 was selected.

 2 - Please discuss your operating experience with H2O2 - good and bad

 3- If a new nitric acid process line is installed, which NOx control would you select 

to achieve your permit limit of 0.6 lb/T?

Please explain the reasons.

 If you have questions, please call or email.

 Thanks again.

Bill Neuffer

Metals and Minerals Group

Office of Air Quality Planning and Standards (D 243-02) US Environmental Protection Agency 

Research Triangle Park, NC 27711

Phone - 919-541-5435

Fax - 919 - 541-3207

E-mail - neuffer.bill@epa.gov

Office Location: 109 TW Alexander Drive RTP, NC (D 231C)

Overnight mail address:

US EPA

Mail Code D243-02

109 TW Alexander Drive
4

RTP, NC 27709

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