Date: May 201 2

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 E miss ion 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 frequentl y for some facilities. S ome 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 hy

pothetical 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 numbe r 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 b y Coffey ville , Kansas . 1 Agrium North Bend Analyses Nitric Acid NSPS Review EPA Contract No. EP - D - 11 - 084; Work Assignment No. 0 - 0 1 RTI Project No. 02103199.000.001 OAQPS/SPPD/M IC G (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 0.4 1 lb NO X/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 compar ed 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, hy pothetical calculations o n 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 b y 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 in2

Doubling the 67 hourl y startup and shutdown periods reported b y 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 NO X/ton acid . See Figure 1. Commenters also noted that the Agrium North Bend plant uses hydrogen peroxide injection (HPI) during the summer months. Comm enters argued that HPI can be used to lower NO X emissions but HPIis not a viable option for all nitric acid plants . The EPA conducted further anal ys es . H ydrogen peroxide injection is only used during the summer months at the Agrium North Bend plant . Assum ing that ozone season (May through September) coincides with the summer months, the analyses shows the maximum 30 operating day emission rate for the ye ar as 0.4 1 lb NO X/ton acid, for the summer months as 0.40 lb NO X/ton acid and for the non - summer months as 0.39 lb NO X/ton acid. See Figure 2. The anal ys is 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 anal ys is. The data from the Agrium North Bend plant indicated that the emission limit of 0.50 lb NO X/ton acid is achievable b y a modified source that is using the best sy stem of emission reduction .3



### Figure **1 .**  **Agrium North Bend 30 Day**  **Rolling NO**  **X** 

### 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 periods4



### Figure 2. **Agrium North Bend 30 Day Rolling**  **NO X**  

### 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