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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 Minera ls 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

----- |

------------ > | From: | |

------ ------ > > ------------------------------------------------------------------------------------------

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

-------------------------------------------- | |

------------ > | To: | |

------------ > > --------------------------------------- ---------------------------------------------------

-------------------------------------------- | |Bill Neuffer/RTP/USEPA/US@EPA | > ----------------- -------------------------------------------------------------------------

-------------------------------------------- | |

------------ > | Date: | |

------------ > > ----------------------------------------------------------------------------------------- -

-------------------------------------------- | |10/11/2010 12:18 PM | > ------------------------------------------------------------------- -----------------------

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------------ > | Subject: |2 |

------------ > > ------------------------------------------------------------------------------------------

-------------------------------------------- | |RE: NSPS

- Nitric Acid

- Use of Hydrogen Peroxide | > ------------------------------------------------------------------------------------------

------------------------ -------------------- |

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 o f 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 demo nstrate 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 shu tdown 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 o ur 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 aci d 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 and3 peroxide would favor SCR. A new nitric acid process line would requ ire 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

- Pleas e 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, pl ease 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 Drive4 RTP, NC 27709

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