Date: May 2012

Subject: Agrium North Bend Analyses

Nitric Acid NSPS Review

EPA Contract No. EP

RTI Project No. 02103199.000.001

From: Melissa Icenhour

To: Nathan Topham

OAQPS/SPPD/M

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

As described in the memo entitled 

Emission Standard (Updated Memo for F

maximum 30 day emission rate of

emissions were calculated based on 

average about 3 to 4 hours per month. 

operating time (i.e. 1% or less), but commenters indicated that 

frequently for some facilities.

Some facilities may undergo more periods of startup and shutdown compar

which we had emissions data. Even with an 

periods, these periods still make

EPA has performed hypothetical 

plant using the assumption that the number of periods of startup and shutdown 

other nitric acid plants. The number of startup/shutdown periods for Agrium North Bend 

compared to the highest number of startup

114 request. 

According to the information received in response to the Section 114 request, the highest number 

of hourly startup and shutdown periods per year was reported as 95 by 

Coffeyville, Kansas. 

1

Agrium North Bend Analyses

Nitric Acid NSPS Review

EPA Contract No. EP-D-11-084; Work Assignment No. 0-01 

RTI Project No. 02103199.000.001

OAQPS/SPPD/MICG (D243-02)

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

As described in the memo entitled Statistical Evaluation of CEMS Data to Determine the NO

ion Standard (Updated Memo for Final Standard, the long term CEMS data showed 

of 0.41 lb NOX/ton acid for the Agrium North Bend plant.

emissions were calculated based on data from Agrium that startup and shutdown events 

average about 3 to 4 hours per month. These periods make up an extremely small fraction of total 

operating time (i.e. 1% or less), but commenters indicated that these periods can occur more 

ome facilities may undergo more periods of startup and shutdown compared to the facilities for 

Even with an increase in the number of startup and shutdown 

up a very small fraction of total operating time. However, 

hypothetical calculations on the CEMS data from the Agrium North Bend 

using the assumption that the number of periods of startup and shutdown are lower than 

number of startup/shutdown periods for Agrium North Bend 

r of startup and shutdown periods reported through the Section 

According to the information received in response to the Section 114 request, the highest number 

shutdown periods per year was reported as 95 by the nitric 

Statistical Evaluation of CEMS Data to Determine the NOX

he long term CEMS data showed a

for the Agrium North Bend plant. These 

that startup and shutdown events occur on 

These periods make up an extremely small fraction of total 

these periods can occur more 

ed to the facilities for 

increase in the number of startup and shutdown 

up a very small fraction of total operating time. However, the 

the Agrium North Bend 

are lower than 

number of startup/shutdown periods for Agrium North Bend was

shutdown periods reported through the Section 

According to the information received in response to the Section 114 request, the highest number 

the nitric acid plant in 
2

Doubling the 67 hourly startup and shutdown periods reported by Agrium North Bend to 134 

hourly startup and shutdown periods places them above the highest number of startup and 

shutdown periods from any of our Section 114 respondents. The resulting maximum 30 day

emission rate is 0.47 lb NOX/ton acid. See Figure 1.

Commenters also noted that the Agrium North Bend plant uses hydrogen peroxide injection 

(HPI) during the summer months. Commenters argued that HPI can be used to lower NOX

emissions but HPI is not a viable option for all nitric acid plants. The EPA conducted further 

analyses. Hydrogen peroxide injection is only used during the summer months at the Agrium 

North Bend plant. Assuming that ozone season (May through September) coincides with the

summer months, the analyses shows the maximum 30 operating day emission rate for the year as 

0.41 lb NOX/ton acid, for the summer months as 0.40 lb NOX/ton acid and for the non-summer 

months as 0.39 lb NOX/ton acid. See Figure 2. The analysis of the data from the summer months 

is independent of the data from the non-summer months. Therefore, the first data point on the 

graph for summer occurs on May 30, the first 30 day period of the analysis.

The data from the Agrium North Bend plant indicated that the emission limit of 0.50 lb NOX/ton 

acid is achievable by a modified source that is using the best system of emission reduction. 
3

Figure 1. Agrium North Bend 30 Day Rolling NOX Emissions—Varying the Number of Startup and 

Shutdown Events

0

0.05

0.1

0.15

0.2

0.25

0.3

0.35

0.4

0.45

0.5

0.55

Jan-01-2010 Feb-20-2010 Apr-11-2010 May-31-2010 Jul-20-2010 Sep-08-2010 Oct-28-2010 Dec-17-2010

double 

number of 

periods

actual number 

of periods
4

Figure 2. Agrium North Bend 30 Day Rolling NOX Emissions—Use of Hydrogen Peroxide Injection

0

0.05

0.1

0.15

0.2

0.25

0.3

0.35

0.4

0.45

0.5

0.55

Jan-01-2010 Feb-20-2010 Apr-11-2010 May-31-2010 Jul-20-2010 Sep-08-2010 Oct-28-2010 Dec-17-2010

January-April

May-August

Sept-December