### Enclosure 5 a

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## EPA Information Collection Request for Nitric Acid NSPS (Subpart G) Plant Data Facility name Sacramento Nitrogen Operations Facility owner (ultimate parent owner) Agrium US Inc.

Plant Location
- Address 3961 Channel Drive Latitude/Longitude for Plant 38.558333, - 121.575833 Describe location of latitude/longitude Center of Facility by Interpolation

– Photo

City , State , ZIP code West Sacramento, CA 95691 Year plant began operation 1982

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 1982 Production Rate (Tons/Day of

100% Acid) 235.7 Production Rate Range (Tons/Day of 100% Acid) 182

– 260 full
- day

operations Subject to Subpart G? Yes Process Type (high/low pressure) Low Oxidation pressure (psia) 90

– 135 Absorption pressure (psia) 70

– 110 % Acid strength Typically Produced 54 - 57

Operating Hour s/Year Line 1 Line 1 cont. Line 3

2008 8 , 018.22 2007 8 , 017.15 2006 6 , 306.40 2009 - 5,137.77 Control Technology (list as many as applicable) NSCR % Control Efficiency (based on most

recent compliance test) Line 1 Line 2 Line 3

NO X NO N O 2 Control Efficiency is not determined in compliance tests.

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

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Page 2 of 10 Permit Limits for Each Nitric Acid Production Line

(Fill in all applicable rows) Line 1 Line 2 Line 3 NO X Emissions (tpy) 42.00 NO X Emissions (lb/hr) No permit limit specified NO X Emissions (lb/ton of 100% acid) 3.0 Permitted NO X control efficiency, if applicable N/A If your permit includes limits for other pollutants, please include as much detail as possible below: Line 1 Line 2 Line 3

Yolo
- Solano Air Quality Management District Permit to Operate P
- 37 - 82(a2) & Title V Operating Permit F
- 00470 - 6 CO: Daily; 1,000 lb Q1; 90,000 lb Q2; 91,000 lb Q3; 92,000 lb Q4; 92,000 lb Annual, 168.00 tons

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

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## For each control device, please provide the key design parameters Extended Absorption (Nitric Acid Production Line Name) Length N/A Design Information (gal/ 10 3 acfm, etc) N/A
Operation and M aintenance required

(Last 10 years) N/A

Y ear absorption capacity was added N/A If you use an additive in your absorption column: Name of additive (i.e., hydrogen

peroxide) N/A Concentration of additive (%): N/A

Explain the process: N/A

Addition rate (gallons per hour): N/A Ratio of additive to water: N/A

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

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Page 4 of 10 SCR (Nitric Acid Production Line Name) Type of Catalyst N/A Is Catalyst New or Regenerated? N/A Catalyst Life (Design/Actual) N/A Catalyst Volume ( m3 ) N/A Flow rate (scfm) N/A Ammonia i njection rate (lb/hr) N/A Operation and Maintenance required

(Last 10 years) N/A

Y ear began operation N/A

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

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## For each control device, please provide the key design parameters NSCR (Nitric Acid Production Line Name) Reductant used (methane, H 2 , etc) Methane ( natural gas )

Rate of reductant used 2009 - 41,336,643 cf 2008 - 81,641,084 cf 2007 - 69,813,182 cf Type of catalyst Platinum (majority composition) , palladium, rhodium, Catalyst Volume ( m3 ) 31.27 ft3 ≡ 0.8855 m3 Flow rate (scfm) 18,000 cfm Is Catalyst New or Regenerated? New in October 2009 Catalyst Life (Design/Actual) Design & expected: 4
- 7 years Operation and Maintenance required

(Last 10 years) Please see detail on enclosed SAP system printout. Path on page footer

includes “decomposer”

Year began operation 1982

– NSCR was installed when the Nitric Acid Plant was constructed.

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

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## Cost Information by Control Technology
Pro duction Line Pollutant Controlled Control

Technology Capital

(Yr of Cost basis) Annual O & M

(Yr of cost basis) 1 NO X & CO NSCR Fully depreciated Maintenance: ranges upto $ 86,500/yr (2003) Additionally: Catalyst: ranges upto $203,400/yr (2009) Natural Gas: 2009 $242,050 2008 $478,056 2007 $408,797



### Please provide additional cost information, comments, or notes below: Unit was installed in 1982 & is fully depreciated. Installation was by prior owners, financial data is not available at this time. Catalyst cost varies by year. Above cost was for a complete replacement. Natural gas usage depends on production demands, season etc.

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

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## Continuous Emission Monitoring Systems CEMS Information  Plant CEMS data recorded concurrent with test runs (i.e.,

concentration, etc.). NO X & CO by CEMS. Acid flow rate and strength by Site. CEMS Manufacturer Siemens Moore CEMS Model Number Ultramat 6E multi
- gas ; NO X and CO

Des cription of sample extraction and

conditioning or dew point maintenance systems Universal Analyzer combined sample conditioning system:

Includes a Model 560 sample cooler (thermoelectric) to remove moisture , designed to lower dew point to 5°C . Also inclu des ammonia scrubber using phosphoric acid on ceramic pellets. Teledyne Model 501X Thermal Converter: Designed to convert high levels of NO 2 (upto 250 ppm) to NO. Consists of high temperature stainless steel converter with a downstream molybdenum converter. Ability to distinguish between NO

and NO 2 ? No Identify all periods of startup, s hutdown, and malfunction, regardless of whether the event caused an exceedence (during the

past 3 years) Please see attached file “Plant Startups & Shutdowns ” for January 2007

through February 2010. Also see “Malfunctions Summary” for the same period. Capital costs $125,338 Operation and Maintenance costs Ranges from $14,400 (2005) to $44,200 (2007) Cost of quarterly audits Not separated Year began operation Siemens Moore in 2003 , Beckman NO X- only CEMS in service prior

CEMS Data (Monthly and Annual) 

### Include monthly and annual NO X 

### CEMS data for the last 3 years. Please submit the CEMS data electronically . See files on CD for 2007 through February 2010. Periods when the Plant are down have been omitted. Note that data relates to associated times going forward , e.g. NOx concentration recorded against 07:00 indicates from 07:00 through 08:00.

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

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## 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. Include Method 7E as an accepted method.

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

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## 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. Three hour averages: NO X 

### may infrequently increase beyond 3 lb/ton during a defined startup event but typically does not exceed 2

– 21⁄2 lb/ton

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

### or NH 3 

### will typically occur during a startup, shutdown, and malfunction event. Emissions in the 2 lb/ton range may occur for upto 4 hours. If the 3lb/ton level is exceeded, it is probably for a single 3
- hour period. Elevated emissions during shutdowns are minimal and may last for upto 1⁄2 hour. Elevated emissions during malfunctions are rare and minimal in duration, immediate actions are normally taken to rectify situation, possibly including shutdown if warranted. 3. Please describe any equipment or work practices that are employed to minimize or eliminate the quantity or duration of excess/elevated emissions of NO X 

### or NH 3 

### during startup, shutdown, and malfunction events. Preheating decomposer and startup burner used. Ensuring absorber tower trays are full of liquid prior to startup. Pre - startup equipment check list used. Standard Operating Procedures for startup, shutdown and emergencies . Close monitoring of decomposer temperature before and during startup.

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

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## Emission Testing 1. Include emissions testing conducted during the last five years. Include tests for NO X 

### , and NH3 

### . Read and follow the guidance below. 2. Test method data of intere st 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 instrument) must be determined and documented as described in the method. For wet basis me asurement 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 sampl ing. 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 dynamic 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 protocol in note 3 , you must conduct a stack test to determine NO X 

### emissions following one o f 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 320. 6. If a concentration is at or below the applicable method’s detection level, then provid e 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 .