Enclosure 5a

Page 1 of 10

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 Hours/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

NOX

NO

NO2

Control Efficiency is

not determined in

compliance tests.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Permit Limits for Each Nitric Acid Production Line

(Fill in all applicable rows)

Line 1 Line 2 Line 3

NOX Emissions (tpy) 42.00

NOX Emissions (lb/hr) No permit limit

specified

NOX Emissions (lb/ton of 100%

acid) 3.0

Permitted NOX 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)—Electronic Version

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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 3acfm, etc) N/A

Operation and Maintenance required

(Last 10 years) N/A

Year 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)—Electronic Version

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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 (m

3

) N/A

Flow rate (scfm) N/A

Ammonia injection rate (lb/hr) N/A

Operation and Maintenance required

(Last 10 years) N/A

Year began operation N/A
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters

NSCR (Nitric Acid Production Line Name)

Reductant used (methane, H2, 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 (m

3

) 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)—Electronic Version

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Cost Information by Control Technology

Production Line

Pollutant

Controlled

Control

Technology

Capital

(Yr of Cost basis)

Annual O & M

(Yr of cost basis)

1 NOX & 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)—Electronic Version

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Continuous Emission Monitoring Systems

CEMS Information

 Plant CEMS data recorded

concurrent with test runs (i.e.,

concentration, etc.). NOX & CO by CEMS. Acid flow rate and strength by Site.

CEMS Manufacturer Siemens Moore

CEMS Model Number Ultramat 6E multi-gas; NOX and CO

Description 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 includes ammonia scrubber using phosphoric acid on ceramic

pellets.

Teledyne Model 501X Thermal Converter:

Designed to convert high levels of NO2 (upto 250 ppm) to NO. Consists

of high temperature stainless steel converter with a downstream

molybdenum converter.

Ability to distinguish between NO

and NO2? No

Identify all periods of startup,

shutdown, 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 NOX-only CEMS in service prior

CEMS Data (Monthly and Annual)

Include monthly and annual NOX 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)—Electronic Version

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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)—Electronic Version

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Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NOX or NH3 expected during a startup,

shutdown, and malfunction event.

Three hour averages: NOX 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 NOX or NH3 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 NOX or NH3 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)—Electronic Version

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Emission Testing

1. Include emissions testing conducted during the last five years. Include tests for NOX, and

NH3. 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 NOX) data can be submitted, but only if the testing was performed with the

following modifications for nitric acid plants. Because of the propensity of NO2 to be

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

any NO2 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 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 performance tests and documentation required

by the method, both prior to and following sampling. NO2 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 NO2 spike gas. The dynamic spiking procedure is strongly recommended.

4. If you do not have emission test data for NOX 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

NOX emissions following one of the approved methods above.

5. If you do not have emission test data for NH3, 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 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.