### Enclosure 5a

Page 1 of 22 

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

Plant Data

Facility name PCS Geismar

Facility owner (ultimate parent owner) PCS Nitrogen Fertilizer L.P.

P lant Location

- Address Hwy 30 & Hwy 3115

Latitude/Longitude for Plant N30.2 / W91.0

Describe location of latitude/longitude PCS Geismar

City

, State

, ZIP code 70734

Year plant began operation 1965

Information for Each Nitric Acid Production Line

(c hange names as needed and use the same names in the Excel spreadsheet )

Train III Train IV Train V

Year line began operation

1978 1970 in Gibbstown

, NJ moved to Geismar

, LA in 1996 1999

Production Rate (Tons/Day of

100% Acid) 650 550 1600

Production Rate Range (Tons/Day of

100% Acid) 400

- 650 400

- 550 1000

- 175 0

Subject to Subpart G? Yes No Yes

Process T ype ( high/low pressure) Mono

- high pressure Mono

- high pressure Dual Pressure

Oxidation pressure (psia) 160 150 75

Absorption pressure (psia) 145 140 160

% Acid strength Typically Produced 65 65 65

Operating Hour s /Year Train III Train IV Train V

2008 5639 7349 6821

2007 5991 7469 8554

2006 1140 5340 8317

Control Technology

(list as many as applicable) Extended absorption

(refrigerated)

& SCR NSCR SCR

% Control Efficiency (based on most

recent compliance test) Train III Trai n IV Train V

NO X 97% 96% 97.5%

NO 96%

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

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Page 2 of 22 NO 2 100%

Permit Limits for Each Nitric Acid Production Line

(F ill in all applicable rows)

Train III Train IV Train V

NO X Emissions ( tpy) 260.98 195.00 113.26

NO X Emissions (lb/hr) 59.58 (avg)

81.25 (max) 44.52 (avg)

135.42 (max) 25.86 (avg)

200.02 (max)

NO X Emissions (lb/ton of 100%

acid) 3.0 5.95 3.0

Permitted NO X control efficiency, if

applicable N/A N/A N/A

If your permit includes limits for

other pollutants, pl ease include as

much detail as possible below: Train III Train IV Train V

Ammonia average (lb/hr) 1.1 11.8 3.49

Ammonia maximum (lb/hr) 1.32 13.06 17.43

Ammonia (TPY)

4.82 51.68 15.27

CO average (lb/hr)

- 104.86

-

CO m aximum (lb/hr)

- 125.84

-

CO (TPY)

- 459.30

-

VOC average (lb/hr)

- 0.24

-

VOC maximum (lb/hr)

- 0.29

-

VOC (TPY)

- 1.07

-

SO2 average (lb/hr)

- 0.03

-

SO2 maximum (lb/hr)

- 0.03

-

SO2 (TPY)

- 0.12

-

PM 1 average (lb/hr)

- 0.34

-

PM 1 maximum (lb/hr )

- 0.40

-

PM 1 (TPY)

- 1.48

-

Nitric Acid average (lb/hr)

- - .01

Nitric Acid maximum (lb/hr)

- - .01

Nitric Acid (TPY)

- - .03

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## For each control device, please provide the key design parameter s

Extended Absorption ( Train III )

Length The absorpti on column in Train III is 167’ tall with the top 72’ of the

tower being e xtended absorption section

Design Information

(gal/ 10 3 acfm, etc) The top 72 feet of the absorption column is considered the extended

absorption section. It is refr igerated to a pproximately 40 F to enhance

NO2 absorption. The de

- mineralized feed water for the column is fed

into the top of the extended absorption section at a rate of 20

- 40 GPM.

This water f

low s down the 14 trays of the extended section of the

absorption column th en in to the conventional section of the absorption

section of the tower which has 20 trays

.

O peration and M aintenance required

(Last 10 years) - The refrigeration compressor that chills extended absorption section was

completely replace d in 1999 at a cost of $390,000.

- An internal inspection of the extended absorption column was

completed in 2009 at a cost of $85,000.

Y ea r absorption capacity was added The extended absorption was original to the plant design in 1978.

If you use an additive in your absorp tion column: NONE USED AT PCS Nitrogen, Geismar

Name of additive (i.e., hydrogen

peroxide)

-

Concentration of additive (%):

-

Explain the process:

-

Addition rate (gallons per hour):

-

Ratio of additive to water:

-

SCR ( Train III )

Type of Catalyst Shell CRI

- (low pressure

, located downstream of expander)

Is Catalyst New or Regenerated? New

Catalyst Life (Design/Actual) 4 years /still on first charge

Catalyst Volume ( m 3 ) 12.6

Flow rate (scfm) 45,000

Ammonia i njection rate (lb/hr) 242

Opera tion and Maintenance required

(Last 10 years) None (n ew in 2007 )

Year began operation 2007

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Page 4 of 22 SCR ( Train V )

Type of Catalyst G rand P aro isse

Is Catalyst New or Regenerated? New (installed as first charge after plant construction in 1999)

Catalyst Li fe (Design/Actual) 10 y ea r s / 11years

Catalyst Volume (m 3 ) 6

Flow rate (scfm) 140 ,000

Ammonia injection rate (lb/hr) 200 to 400 (winter vs. summer)

Operation and Maintenance required

(Last 10 years) Added 4 drum s of catalyst at a cost of $60,000 US D

Year began operation 1999



## For each control device, please provide the key design parameters

NSCR ( Train IV )

Reductant used (methane, H 2 , etc) Methane

Rate of reductant used 12,000. lbs/hr

Type of catalyst P recious metal on honey comb monolith subst rate ( EnProSol )

Catalyst Volume ( m 3 ) 1.02

Flow rate (scfm) 42 ,000

Is Catalyst New or Regenerated? New Catalyst

Catalyst Life (Design/Actual) 4 / 5

Operation and Maintenance required

(Last 10 years) Catalyst replaced every 4 years ($250,000 per cataly st charge + $20,000.

for installation)

Y ea r began operation 1970 (original to plant)

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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)

Train III NOx E xtended

A bsorption

(refrigerated) $ 3 ,000,000.

(2010 approx 1 ) E lectricity = $ 76,000 ./ yr

Maintenance cost= $ 15,000./yr

TOYAL = $ 91,000./yr

Train III NOx SCR $ 1,235,000.

(project cost in 2007) Maintenance= $ 18 ,500./yr

A mmonia 2

= $ 2 5,000./yr

SCR Catalyst 3

= $ 71,735. /yr

TOTAL= $ 115,260. /YR

Train IV NOx NSCR $ 1, 495,000.

(2010 approx 1 ) Maintenance= $ 22,425./yr

Methane 4

= $ 1,300,000 ./yr

NSCR Catalyst 5

= $ 67,60 0. /yr

TOTAL = $ 1,390,000 ./YR

Train V NOx SCR 1,820,000.

(2010 approx 1 ) Maintenance= $27,300./yr

A mmonia= $ 315,000 ./yr

SCR Catalyst 6

= $ 54,300 ./yr

TOTAL = $ 396,583 ./YR



### Please provide additional cost information, comme nts, or notes below:

Notes:

1. Cost estimate d etermine from past projects +/

- 50 %

2. Ammonia price of $300/ ton

3. SCR catalyst life of 4 years (CRI

- Guarantee)

4. Natural gas price of $5/mmbtu

5. NSCR Catalyst life of 4 years

6. SCR catalyst life of 10 years (GP design)

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

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## Continuous Emission Monitoring Systems

CEMS Information

- Train III

? Plant CEMS data recorded

concurrent with test runs (i.e.,

concentration, etc.). All data from CEMS is recorded on electronic historian system along

with plant production rates

CEMS Manufacturer Ametek

CEMS Model Number 400/461 serial # 4612

Descriptio

n of sample extraction and

conditioning or dew point

maintenance systems A 1⁄4” sample probe is used on the stack. The p robe is connected to a 1⁄4”

electrically traced tubing from the stack to the analyzer heated to 220 F.

Ability to distinguish between NO

a nd NO 2 ? The analyzer samples every 10 minutes. After 170 seconds the NO2

concentration can be seen. Five seconds after, oxygen is injected to

convert all NO to NO2. This sample converts for 7.5 minutes which

gives us our total NOx ppm reading at the end of the sample period. The

subtraction of the final reading from the reading after 170 seconds from

the start gives the NO concentration in the stack. Only the total NOx

concentration is electronically recorded for the CEMS data.

I dentify all periods of startup,

s hutdown, and malfunction,

regardless of whether the event

caused an exceedence (during the

past 3 years) See table at end of document

Capital costs Estimate $50,000 to $100,000.

Operation and Maintenance costs Calibration gas=$3,000/yr, Parts and Maintenance=$5,000/yr

Cost of quarterly audits RATA cost= $8,000/yr CGA=$1,000

Year began operation 1994



## Continuous Emission Monitoring Systems

TRAIN III

- 

### SECOND ANALYZER TO MEASURE N2O with ability to measure NO and NO2

(Note

- not used for CEMS reporting data due to analyzer not being certified)

? Plant CEMS data recorded

concurrent with test runs (i.e.,

concentration, etc.). All data from CEMS is recorded on electronic historian system along

with plant production rates

CEMS Manufacturer Ecochem

CEMS Model Number MC3 s

- serial SN282

Description of sample extraction and

conditioning or dew point

maintenance systems A 1⁄4” sample probe is used on the stack. The probe is connected to a 1⁄4”

electrically traced tubing from the stack to the analyzer heated to 365 F.

Ability to distinguish between NO

and NO 2 ? NO, NO2 and N2O are measured separately by the analyzer. NO and

NO2 are added together in the an alyzer and the sum total is sent to the

DCS and historian as a NOx reading

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

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Page 7 of 22 I dentify all periods of startup,

s hutdown, and malfunction,

regardless of wh ether the event

caused an exceedence (during the

past 3 years) N/A (see CEMS description)

Capital costs $92,000.

Operation and Maintenance costs Calibration gas=$4,000./yr, Parts and Maintenance=$5,000./yr

Cost of quarterly audits RATA cost= $8,000/yr CGA=$1,000

Year began operation 2008



## Continuous Emission Monitoring Systems

CEMS Information

- Train IV

? Plant CEMS data recorded

concurrent with test runs (i.e.,

concentration, etc.). All data from CEMS is recorded on electronic historian system along

with plant production rates

CEMS Manufacturer Ametek

CEMS Model Number 400/461 serial # 7969

Descriptio

n of sample extraction and

conditioning or dew point

maintenance systems A 1⁄4” sample probe is used on the stack. The probe is connected to a 1⁄4”

electrically traced tubing from the stack to the analyzer heated to 220 F.

Ability to distinguish between NO

a nd NO 2 ? The analyzer samples every 10 minutes . After 170 seconds the NO2

concentration can be seen. Five seconds after, oxygen is injected to

convert all NO to NO2. Thi s sample converts for 7.5 minutes which

gives us our total NOx pp m reading at the end of the sample period . The

subtraction of the final reading from the reading after 170 seconds from

the start gives the NO concentration in the stack. Only the total NOx

concentration is electronically recorded for the CEMS data.

I dentify all periods of startup,

s hutdown, and malfunction,

regardless of whether the event

caused an exceedence (during the

past 3 years) See table at end of document

Capital costs Estimate $50,000 to $100,000.

Operation and Maintenance costs Calibration gas=$3,000/yr, Parts and Maintenance=$5,000/yr

Cost of quarterly audits RATA cost= $8,000/yr CGA=$1,000

Year began operation 1997

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## Continuous Emission Monitoring Systems

CEMS Information

- Train V

? Plant CEMS data recorded

concurrent with test runs (i.e.,

concentration , etc.). All data from CEMS is recorded on electronic historian system

CEMS Manufacturer Ametek

CEMS Model Number 920 NOx serial AZ

- 920GPSP

- 89982

Description of sample extraction and

conditioning or dew point

maintenance systems A 1⁄4” sample probe is use d on the stack. The probe is connected to a 1⁄4”

electrically traced tubing from the stack to the analyzer heated to 220 F.

Ability to distinguish between NO

and NO 2 ? NO2 and NO reading s are measured separately by the analyzer. Both

readings are sent to t he DCS. The total of both reading s are added

together for a total NOx concentration and stored in the historian for

CEMS data

.

I dentify all periods of startup,

s hutdown, and malfunction,

regardless of whether the event

caused an exceedence (during the

p ast 3 years) See table at end of document

Capital costs $55,000 in 2000

Operation and Maintenance costs Calibration gas=$2,400/yr, Parts and Maintenance=$5,000/yr

Cost of quarterly audits RATA cost= $8,000/yr CGA=$1,000

Year began operation 2000



## Continuous Emission Monitoring Systems

TRAIN V

- 

### SECOND ANALYZER TO MEASURE N2O with ability to measure NO and NO2

(Note

- not used for CEMS reporting data due to analyzer not being certified)

? Plant CEMS data recorded

concurrent with test runs (i.e.,

conc entration, etc.). All data from CEMS is recorded on electronic historian system along

with plant production rates

CEMS Manufacturer Ecochem

CEMS Model Number MC3 s

- serial SN282

Description of sample extraction and

conditioning or dew point

maintenanc e systems A 1⁄4” sample probe is used on the stack. The probe is connected to a 1⁄4”

electrically traced tubing from the stack to the analyzer heated to 365 F.

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

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Page 9 of 22 Ability to distinguish between NO

and NO 2 ? NO, NO2 and N2O are measured separately by the analyzer

. NO and

NO2 are added together in the an alyzer and the sum total is sent to the

DCS and historian as a NOx reading

.

I dentify all periods of startup,

s hutdown, and malfunction,

regardless of whether the event

caused an exceedence (during the

past 3 yea rs) N/A (see CEMS description)

Capital costs $101,000.

Operation and Maintenance costs Calibration gas=$4,000./yr, Parts and Maintenance=$5,000./yr

Cost of quarterly audits RATA cost= $8,000/yr CGA=$1,000

Year began operation 2008

CEMS Data (Monthl y and Annual)



### Include m

onthly and a nnual NO X 

### CEMS data for the last 3 years. Please submit the CEMS

data electronically

.

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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; type s of absorber used, trends in selecting control devices , improvements in control

efficiency in existing control devices, energy efficiency

.

Most nitric acid plant s are design ed to produce acid at a maximum stre ngth of 65

- 67 %. The

azetrop e (constant

– boi ling mixture) of nitric is 68 % which set s the maximum concentration

that can be achieved with convention al absorption towers

. Acid strength s are typically limited

to 65 % to give flexibility and allow for lower NOx slip out of the absorber. Acid strengt hs

above 6 8 % involve plant designs that are significantly more complicated, have much higher

capital and much higher operation al cost and suffer from many corrosion challenges

. Due to

the complexity and cost of producing nitric acid above 68 %, most down stream process es that

require nitric acid have been design ed to opera te with an acid strength of 65 % or less.

Train V Nitric Acid was commissioned in 1999 and was state of the art technology when

installed and to this date still is

. It is a dual pressure

, G rand Paroisse design with a SCR for

NOx abatement and control. With the dual

- pressure process

, the oxidati on of ammonia takes

place at a medium pressure of 60 to 90 psia as this has advantages for the efficiency of the

ammonia combustion and the consump tion of the precious metal catalyst. The absorption step

is operated at the higher pressure of 130

- 200 psia which enhances the efficiency of the

absorption. The capital cost of a dual pressure plant is high er since it has an addional NOx

compressor and add itional process equipment. However , with a large plant, typically greater

than 1000 TPD, the addi ti onal capital cost can be justified by the future savings in efficiency

over that of a m ono

- pressure plant.

When designing an absorption column, the goal is to reduce the NOx slip out the absorb er as

much as possible since any NOx slip from the absorber results in less acid production and

more reagent required in the NOx abatement technology (ie; ammonia to SCR or methane to

NSCR) The efficiency of the absorp tion column is determine d by the following:

1) Size of tower and number of absorption trays

2) The a mount of cooling in the tower is very important in plant efficiency as the lower the

temperature the more efficient the absorption . Tower cooling removes the heat of reaction

fro m NO2 absorbing into the water forming nitric acid and from the exothermic reac tion of NO

converting to NO2.

3) The o xidation state of the NOx gas entering the tower is important for plant efficiency. NO

is produced by the oxidati on reaction of ammonia and oxygen on the platinum gauze. After

the gauze, the NO reacts with excess oxygen to form NO2. This is a slow reaction that requires

residence time and favors lower temperatures. T he more NO that has reacted to NO2 prior to

introd uction into the absorption column, the more efficient the tower will be. If th ere is not

enough residence time or excess oxygen available to al low for NO to react to NO2 then the

exothermic reaction will occur in the tower and reduce the tower efficiency

. Oxidation

chambers or long runs of piping are typically designed into plant to allow for this reaction prior

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### to the absorption column.

4) The higher the pressure of the absorption column the higher the efficiency as t he absorption

efficiency relation shi p to pressure is tertiary (tower efficiency ~ pressure 3 

### )

.

NOx Abatement

For NOx abatement SCR is typically the most viable technology on a new plant or on most

plant upgrades. SCR s can control do wn to very low NOx levels and have a wide temperature

oper abi lity ra n ge which allows for easy integration into many process designs

.

NSCR operate at high temperature s; typically above 1000 deg. F

. Acid plants designed with a

NSCR typically have th e “back end” design ed around the NSCR system to take advantage of

the heat generated from the reaction of methane or other fuel in the catalyst bed . The hot gas

exit ing the NSCR is typically fed directly into the hot gas expander and is responsible for a

large portion of the power used to drive the air compressor. The reagent costs are high on a

NSCR but most of the energy is recovered in the hot gas expander. With high efficiency

expander s

, the NSCR plant can be just as efficient as a plant with SCR catalyst and the plant s

are typically large exporter s of steam.

Oth er Improvements in Modern Plants

There are many other improvements that have m ade modern plant s more efficient. Some of

these are:

- Improved efficiency of large rotating equipment such air compressors , steam turbine and hot

gas expander s

.

- Better energy in tegration , recovery of low level heat and loss of less heat in to the cooling

water system.

- Forced circulation boiler downstream of the oxidation catalyst . These boilers efficiently

recover the heat from burning the ammonia and have proven to be very reli able.

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### 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.

Reliability and Operability

The four technologies that are used to control NOx at PCS Gei smar are well developed

technologies that are very reliable . SCR with automatic control of ammonia injection tied into

a continually updating analyzer allow s for very p recise control and ease of operation

. Extended absorption is quite simple and thus rel iable but is dependent o n the reliability of a

refrigeration compressor . Installation of a rotary screw refrigeration compressor has proven to

be very reliable

. The NSCR runs very reliably and allow s for Train IV to be a large exporter of

steam which is u sed through out the complex.

Efficiency

SCR s are efficient as long as the inlet concentration of NOx is reasonable. High c oncentration s

of inlet NOx result in high ammonia consumption and slight reduction in acid production

which is a cost to the plant wit h no economic return.

NSCR s can be efficient as long as the hot exit gas is recovered in an efficient hot gas ex pand er.

With the proper configuration of a NSCR in conjunction with an efficient expander;

efficiencies will be comparable to co

- gen style gas turbine s. Typically

, addional heat recovery

is done down stream of the expander in the form of steam generation or boiler feed water pre

heat in order to ensure maximum efficiency of the plant.

Extended absorption is very efficient because it allow s for al l the NOx with the exception of

what is released to the stack to be recovered in the product acid. Ultra low emissions are

difficult to achieve with extended absorption

.

3. Please provide recommendations on the revisions you would like to see in this NSPS.

1. Maintain the current standard of 3 lb/ton

2. Provide an online adjustment period for plant malfunctions unless the adjustment period

emissions exceed start

- up/shut

- down emissions

3. If lower NOx emissions are required, reduce the long term emissi on rate (or provide a 12

- month rolling total mass cap) but allow the current standard as a short term emission rate to

provide greater operational flexibility

.

4. Clarify the monitoring and reporting requirements in Subpart A and Subpart G . Set up a

matri x identifying which sections of Subpart A are applicable to Subpart G affected sources so

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### that the regulated community does not have to go from Subpart to Subpart, section to section in

an attempt to identify all requirements.

5. Make the regulations gen erally more understandable and usable.



## 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.

The three acid trains at PCS Geismar respond differentl y during start up and their ability to

reduce NOx emissions

Train III

Train III has two NOx abatement technologies: 1) extended absorption and 2) SCR down

stream of the expander. During start up, the plant can be operated so that the NOx

concentration exi t ing the absorber can be controlled low enough as to not overwhelm the SCR

which allows the SCR to maintain and control NOx emission s below 3 lbs/ton during start up

. In addition, a feature that allow s for tight NOx control is a con tinually updating NOx an alyzer

. This allow s for precise automatic control of NOx emissions and help s prevent the overfeeding

of ammonia to the SCR. This continually updating analyzer was installed in 2009 and is part

of the analyzer used to measure N2O emissions. During a typica l start up the NOx emission

average between 2.0 to 3.0 lbs/ton for the first hour

. Then, a fter the first hour of operation NOx

can then be con trolled at the average emission range

. Shut down emission s are typically

controlled within the average range and malfunction or plant upset can typically be

compensated within the SCR in 15 minutes.

Train IV

Train IV uses NSCR abatement technology to reduce NOx. Natural gas can only be

introduced to the NSCR after ammonia feed has started to the oxidation catalyst ( platinum

gauze)

. Process control safety interlocks are designed in order prevent an e x plosive condition

of natural gas and air within the process piping

. For this reason, t hese controls do not permit

natural gas addition to the NSCR until commencement of a mmonia flow to the oxidation

catalyst.

In a single pressure plant with a NSCR

, two sources of energy drive the air compressor that

supplies air to the oxidation catalyst 1) Steam Turbine and 2) Hot Gas Expander downstream

of the NSCR. Prior to the i ntrod uction of ammonia to the oxidation catalyst, the only source of

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### en ergy to drive the air compressor is t he steam tu rbine which only is able to achieve a

moderate plant pressure resulting in reduced absorber efficiency. Once the ammonia feed is

started to t he oxidation catalyst

, then natural gas flow can be started to the NSCR. The heat

generated from burning the natural gas in the NSCR then drives the expander and quickly

bring s the compressor speed up. With the increasing speed of the air compr essor the p ressure

of the absorption column increases which improves efficiency and drops the NOx slip out of

the tower. However, for that short period of time before the expander drives the compressor

, the absorber efficiency is low which results in excess NOx slip from the absorber. Once the

plant is lined out and the oxidation reaction is up to temperature

, the n the NSCR is optimized

and the NOx emissions come into range. In the first 60 minutes after start up, NOx emissions

typically run between 5.5 and the maximu m permit limit of 6.5 lbs/ton . Occasionally the

maximum permit limit is exceeded but not typically. A f ter the first hour of operation, NOx

emissions drop to the normal average operating range. Shut down emission rates run higher

than average

, between 3.0 and 6.5 lbs/ton for approximately one hour. Plant malfunction and

swing s such as change in ammonia pressure or swing in oxidation catalyst temperature can

result in higher emission rates in the 3.0

- 5.0 lbs/ton range

.

Train V

Train V NOx is easil y controll ed within the maximum limit of 3 lbs/to n during start up / shut

down and most malfunctions. The maximum limit is much higher than t he normal operating

range of 0.3

- 0.4 lbs / ton which helps to prevent NOx slip over the maximum permit limit.

Many features of the plant allow for NOx to be controlled within permit limits during start up

and shut down . Some of these design features include:

- Dual pressure design with guide vane control on the air compressor and expander

which allows for greater control of the to wer pressure during various modes of

operation

- S tart up heater ups tream of the SCR that allows for the SCR catalyst bed temperatures

to be optimized before high l evels of NOx reduction is required

.

- SCR that can be put into service prior to introduction of ammonia to the oxidation

catalyst

- Efficient absorption column (greater than 200’ tall) which help reduce NOx slip. The

lower NOx concentration from the column then results in a redu ced load on the SCR

reactor.

- Continually updating NOx analyzer which allows for precise control of NOx and

prevent overfeeding of ammonia to the SCR

Start up emissions in Train V can be anywhere from 0.5

– 3.0 lbs/ton but rarely exceed the

maximum limit of 3 lbs/ton. Normal average emission rates are typically achieved one to two

hours after start up. Malfunction or plant upset typically don’t have a significant effect on

NOx and rarely cause emissions to go over 1.0 lbs/ton. Controlled shut downs have NOx

emissions within the average range. Trip outs result in emissions betwee n 1.0 and 3.0 lbs/ton.

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

### or NH 3 

### will typically occur during

a startup, shutdown, and malfunction event.

Train III

With two emission control technologies in Train III

, (e xtended absorption and SCR ) the

emission s are able to be controlled below the 3 lbs/ ton limit during nearly all startup,

shutdown or typical plant malfunctions. For example if the SCR unit was to fail on loss of

ammonia feed, adjustments can be made to the plant such as increased d emin eralized water

flow to the top of the absorber which would prevent the plant from exceeding the emission

limit. In Train III , the normal ( average ) NOx emission limit s are typically achieve d within 30

minutes after the ammonia is introduced to the oxid ation catalyst ( gauze )

. During shut down

el evated emissions rarely exceed one hour.

Train IV

During start up, Train IV typically operates with high emission for one hour after ammonia

flow has started to the oxidation catalyst

. T ypically the NOx can be co ntrolled down into the

normal operating range within one hour of start up. Most plant upset or small malfunctions

can be quick ly compensated for and NOx emissions can be retu r ned back to normal within 15

minutes. On shut down , elevated emission typically last NOx for 30 to 60 minutes.

T rain V

Elevated s tart up emissions can last from one to two hours. Most plant upsets or small

malfunction can be compensated within minutes and typically do not raise emissions above the

average. If the shut down result in elevated emission, which is not typical, these typically last

for less than on hour.

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, shu tdown, and malfunction events.

The following steps are taken in the each of the Geismar plants to lower emissions on start up

prior to commencing ammonia flow to the oxidation catalyst:

1 ) The pressure of the absorption tower is maximized. This is achieved by operating the

steam turbine that d rives the air compressor at 100 %.

2 ) The trays in the absorption column are filled with demineralized water. This is

determined by a pressure drop across the absorption tower along with a rising liquid

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Page 16 of 22 

### level i n the bottom of the absorption column.

3 ) Demineralized water is maximized to the top of the absorption column and weak acid

flow is maximized to the lower trays of the tower.

4 ) Cooling water is m aximized to the tower to optimize absorption efficiency and in T rain

3, the refrigeration compressor is put into service and the extended absorption section

of the tower is chilled down to 40F.

5 ) The SCRs are commissioned and put in service to be ready to immediately reduce NOx

emissions.

6 ) In Train V, the start up steam heater upstream of the SCR is put into service to bring

the SCR up to efficient operating temperature to ensure optimum conversion of NOx to

nitrogen and reduce ammonia slip.

Immediately after ammonia flow is started to the oxidation catalyst (gauze is li t), the following

step are made to reduce NOx emissions.

1 ) The NSCR is put into service in Train IV.

2 ) The air compressor is sped up with the additio nal energy from the hot gas expander that

comes from the heat that is generated from the oxidation reaction.

3 ) Th e oxidation catalyst is brought up to normal operating temperature and lined out very

quickly.

4 ) The absorber pressure is raise d to normal operating pressure in each of the plants.

TRAIN III

Duration of

DATE time Status Event

(ho urs)

1/15/2007 19:30 startup 1:00

1/31/2007 shutdown 1:00

2/27/2007 21:45 startup 0:45

3/6/2007 0:30 shutdown 1:45

3/9/2007 15:15 startup 2:00

3/30/2007 6:00 shutdown 1:30

3/31/2007 22:45 startup 0:30

4/8/2007 2:45 shutdown 0:45

4/12/2007 3:45 s tartup 1:00

5/20/2007 15:00 shutdown 0:30

5/31/2007 0:30 startup 1:00

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Page 17 of 22 7/8/2007 18:00 shutdown 1:45

7/29/2007 14:15 startup 1:45

8/2/2007 3:30 shutdown 2:00

8/2/2007 23:45 startup 1:45

8/7/2008 9:00 shutdown 2:30

8/23/2007 9:00 shutdown 0:30

8/23/2 007 21:30 startup 1:45

8/28/2007 18:45 shutdown 1:45

8/29/2007 0:00 startup 0:45

9/13/2007 11:00 shutdown 3:30

9/14/2007 18:15 startup 1:30

10/26/2007 5:00 shutdown 0:15

10/27/2007 6:30 startup 1:30

10/31/2007 14:15 shutdown 0:15

10/31/2007 14:45 s tartup 1:00

11/7/2007 20:15 shutdown 3:00

11/8/2007 14:20 startup

11/18/2007 6:10 shutdown 1:50

11/29/2007 6:45 startup 1:00

12/7/2007 5:30 shutdown 0:15

12/20/2007 startup 0:00

12/31/2007 shutdown 0:00

1/6/2008 18:30 startup 1:15

1/31/2008 9:30 malfunction 3:30

2/5/2008 1:00 shutdown 2:30

2/6/2008 21:00 startup 1:30

3/7/2008 13:30 shutdown 1:00

3/15/2008 startup 0:00

4/5/2008 15:15 shutdown 2:15

4/6/2008 14:00 startup 3:00

4/8/2008 4:15 shutdown

4/8/2008 15:15 startup 1:30

4/11/ 2008 6:15 shutdown 1:00

4/12/2008 19:30 startup 2:30

4/25/2008 0:00 shutdown 0:15

5/3/2008 14:00 startup 3:45

5/12/2008 shutdown

5/27/2008 18:40 startup 3:05

5/30/2008 9:20 shutdown 1:25

6/2/2008 2:00 startup 0:30

6/8/2008 19:15 shutdown 1:00

6/9/2008 9:15 startup 3:00

6/19/2008 shutdown

7/2/2008 14:45 startup 2:30

7/21/2008 11:00 shutdown 1:00

7/23/2008 1:30 startup

8/13/2008 18:45 shutdown 2:15

8/14/2008 11:30 startup 1:15

8/15/2008 10:00 shutdown 0:15

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Page 18 of 22 8/16/2008 0:00 startup 0:1 5

8/20/2008 3:30 shutdown 0:15

8/30/2008 13:30 startup 0:15

10/9/2008 15:45 shutdown 1:30

10/21/2008 12:00 startup 0:15

10/30/2008 2:45 shutdown 1:45

10/31/2008 22:15 startup 2:45

11/13/2008 21:00 startup 0:30

11/18/2008 22:15 shutdown 1:00

12/18/ 2008 19:45 startup 2:00

12/29/2008 10:45 shutdown 0:45

12/30/2008 21:45 startup 0:15

1/6/2009 6:15 shutdown 0:15

9/4/2009 14:30 startup 2:45

9/16/2009 10:00 shutdown 1:46

9/29/2009 22:30 startup 1:00

10/7/2009 21:15 shutdown 0:15

10/27/2009 17:30 s tartup 0:15

11/3/2009 21:00 shutdown 0:15

11/19/2009 11:15 startup 0:15

11/28/2009 8:45 shutdown 0:30



### TRAIN

IV Duration

Date Time Status of event

(hours)

2/7/2007 19:00 shut down 1:30

2/21/2007 7:35 startup 6:10

3/1/2007 7:45 s hutdown 2:15

3/2/2007 7:20 4:30 7:40

3/30/2007 0:15 shutdown 1:15

3/30/2007 22:00 startup 1:45

4/1/2007 15:00 malfunction 0:45

4/11/2007 17:15 malfunction 1:30

4/23/2007 13:30 shutdown

4/29/2007 10:00 startup 0:00

4/29/2007 15:00 malfunction 0:00

5/18/2007 20:00 shutdown 2:15

5/23/2007 15:00 startup 2:15

7/5/2007 2:00 shutdown 1:45

7/6/2007 5:00 startup 2:30

8/7/2007 0:00 shutdown 0:45

8/8/2008 1:00 startup 0:30

8/15/2007 14:00 malfunction

8/28/2008 18:45 shutdown 1:00

8/29/2007 1:01 st artup 1:14

9/25/2007 17:45 shutdown 1:30

9/26/2007 22:30 startup 4:00

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Page 19 of 22 11/2/2007 8:30 shutdown 0:15

11/4/2007 7:00 startup 1:30

11/15/2007 19:30 shutdown 1:00

12/6/2007 19:15 startup 1:45

1/28/2008 0:10 shutdown 1:50

2/8/2008 12:10 startup 1:05

3/1 3/2008 0:00 shutdown 2:45

3/16/2008 22:00 startup 1:30

3/27/2008 10:00 shutdown 1:30

3/27/2008 23:30 startup 1:15

4/18/2008 11:45 shutdown 1:15

4/18/2008 20:25 startup 1:50

5/11/2008 20:00 shutdown 1:00

5/23/2008 22:45 startup 4:00

7/29/2008 0:00 shutdown 0:45

7/229/2008 19:00 startup 0:30

8/13/2008 6:15 shutdown 4:00

8/13/2008 12:00 startup 0:15

8/15/2008 19:00 malfunction 1:00

8/23/2008 3:30 malfunction 12:00

8/31/2008 5:00 shutdown 0:00

9/18/2008 startup

10/17/2008 shutdown

10/2 6/2008 startup

10/27/2008 0:15 malfunction 18:00

10/30/2008 2:45 shutdown 0:00

10/31/2008 17:50 startup 0:00

12/2/2008 5:00 shutdown 0:00

12/12/2008 19:30 startup 1:45

12/15/2008 13:00 malfunction 0:00

12/18/2008 8:00 malfunction 0:00

1/6/2009 6:00 shutdown 1:30

6/10/2009 12:00 startup 4:00

6/16/2009 10:00 shutdown 2:00

7/29/2009 11:00 startup 3:00

7/30/2009 0:00 malfunction 2:00

8/4/2009 2:00 shutdown 1:00

8/5/2009 0:00 startup 1:00

8/18/2009 9:00 malfunction 0:00

9/22/2009 17:00 malfun ction 0:00

9/23/2009 0:00 malfunction 2:00

9/28/2009 6:00 shutdown 1:00

10/24/2009 startup

10/27/2009 shutdown

10/27/2009 startup

11/28/2009 11:00 shutdown 2:00



### TRAIN V Duration of

Date time Status Event

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Page 20 of 22 (hours)

3/8/2007 2 1:30 startup 1:15

4/14/2007 1:15 shutdown 1:30

4/14/2007 10:30 startup 1:30

4/20/2007 5:00 shutdown 4:00

4/20/2007 14:15 startup 1:45

5/14/2007 11:45 shutdown 2:15

8/11/2007 21:30 startup 1:30

8/29/2007 3:00 shutdown 0:30

8/29/2008 6:15 startup 0:1 5

9/11/2007 10:45 shutdown 2:45

9/13/2007 11:30 startup 2:15

10/30/2007 3:00 shutdown 0:30

10/31/2007 9:00 startup 2:00

1/3/2008 10:15 shutdown 0:15

1/4/2008 1:30 startup 1:15

3/3/2008 15:15 shutdown 0:15

3/6/2008 0:00 startup 1:30

3/16/2008 18:00 shutdown 0:30

3/20/2008 13:00 u startup 4:45

3/19/2008 12:00 shutdown 1:00

5/24/2008 3:00 startup 2:00

5/29/2008 16:00 shutdown 3:30

6/13/2008 7:15 startup 1:00

7/23/2008 14:00 shutdown 0:15

7/23/2008 17:15 startup 1:45

8/13/2008 6:00 shutdown 1:0 0

8/13/2008 16:00 startup 1:15

8/16/2008 5:00 shutdown 0:30

8/16/2008 11:45 startup 0:45

8/26/2008 3:15 shutdown 0:30

8/30/2008 9:30 startup 2:30

8/31/2008 shutdown 0:00

9/8/2008 6:00 startup 3:15

9/23/2008 20:00 repair SCR 0:30

10/30/2009 1:25 shutdown 9:35

10/30/2008 14:00 startup 4:45

10/31/2009 4:45 shutdown 0:15

11/2/2008 4:00 startup 0:45

11/13/2008 15:45 shutdown 0:15

12/1/2008 21:30 startup 1:00

12/11/2009 7:45 shutdown 1:45

1/5/2009 13:45 startup 4:15

1/29/2009 22:00 shutdown 3:0 0

1/30/2009 5:00 startup 4:45

3/3/2009 11:30 startup 0:30

3/29/2009 20:00 shutdown 2:45

4/7/2009 10:45 startup 1:15

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Page 21 of 22 5/11/2009 20:00 shutdown 0:30

5/18/2009 15:45 startup 4:00

6/1/2009 5:00 shutdown 0:45

6/8/2009 10:45 startup 0:15

6/29/2009 11:30 shutdown 0:30

7/2/2009 11:15 startup 1:00

8/15/2009 4:00 shutdown 1:15

8/16/2009 11:30 startup 0:30

9/21/2021 21:30 shutdown 1:00

9/23/2009 8:45 startup 0:30

10/21/2009 16:30 shutdown 0:15

10/22/2009 22:30 startup 0:15

11/9/2009 19:45 shutdown 0:15

11/17/2009 6:30 startup 1:00

11/17/2009 21:15 shutdown 0:30

11/26/2009 13:45 startup 0:15

12/13/2009 15:00 shutdown 1:00

12/15/2009 17:00 startup 1:00

12/22/2009 8:00 shutdown 1:00

12/29/2009 22:00 startup 1:59

12/30/2009 0:00 shutdown 1:00

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Page 22 of 22 

## Emis sion Testing

1

. Include emissions testing conducted during the last five years. Include tests for NO X 

### , and

NH 3 

### . 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 32 0.

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 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. 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

. I f 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 of 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 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

.