BOSTON

BRUSSELS

CHICAGO

DETROIT JACKSONVILLE

LOS ANGELES

MADISON

MIAMI MILWAUKEE

NEW YORK

ORLANDO

SACRAMENTO SAN DIEGO

SAN DIEGO/DEL MAR

SAN FRANCISCO

SHANGHAI SILICON VALLEY

TALLAHASSEE

TAMPA
TOKYO WASHINGTON, D.C. 

### December 11, 2012

V IA 

### E-M AIL AND 

### U.S. M AIL ATTORNEYS AT LAW

WASHINGTON HARBOUR
3000 K STREET, N.W.

SUITE 600
WASHINGTON, D.C. 20007-5109

202.672.5300 TEL

202.672.5399 FAX foley.com

WRITER'S DIRECT LINE

202.295.4021 rstoll@foley.com EMAIL



### Scott Jordan, Esquire

Office of General Counsel

U.S. EPA 1200 Pennsylvania Avenue, N. W.

Mail Code: 2344A Washington, DC 20460

RE: Dyno Nobel Inc. Petition for Reconsideration of October 10, 2012

Dear Scott:

On behalf of my client Dyno Nobel Inc. (“ DNI”), I am responding to the questions from EPA program staffers you forwarded to me in your e- mail of November 14, 2012, as clarified by your email of November 26, 2012. I will reprint each question from your e-mail, then provide DNI’s response to each. In our responses below, I w ill use the same acronyms used in our October 10, 2012 administrative petition.

Question 1. What information and/or data doe s Dyno Nobel have to demonstrate that retrofitting an NSCR controlled plant to add an SCR is technically infeasible?

DNI does not claim that retrofitting an NSCR controlled plant to add an SCR is technically infeasible. We are, however, enclosing analyses performed by ERM-West, Inc. (ERM) on DNI’s behalf dated March 7 and July 31, 2012. (Attachments 1 and 2.) These analyses conclude that adding SCR technology to DNI’s Donora, PA NSCR plant would be economically infeasible. There

is no fundamental difference between the Donora NSCR plant and other NSCR plants that would alter the conclusion that adding SCR to an NSCR plant generally is economically infeasible.

But I should hasten to add that we believe Question 1 – whether dire cted to technical or economic infeasibility – appears to side-step a critical legal point regarding DNI’s pending judicial and administrative petitions regarding the final NA P Rule of August 14, 2012. As stressed in the TFI comments and our administrative petition, EPA in its rulemaking process undertook no evaluation of the compliance costs associated w ith the 0.5 lb/ton limit for NSCR plants undergoing modifications. This is despite comments in the record showing that NSCR plants have fundamentally different attributes, and CEMS data in the record sh owing that NSCR plants were not meeting the 0.5 lb/ton limit. We thus contend th at EPA had no basis to assume that NSCR NAPs undertaking a modification or reconstruction could co mply with the final NAP Rule consistent withFOLEY & LARDNER LLP



### December 11, 2012 Page 2

EPA’s compliance cost assumptions, and that this makes the final NAP Rule legally defective.

Question 2. What facility-specific cost analysis or other data does Dyno Nobel have showing that the costs of retr ofitting an NSCR controlled plant to add an SCR are substantially higher than the costs of retrofitting a previously uncontrolled plant?

Please see our response to Question 1. In a ddition, as stressed in our administrative petition, a basic point of the comments in the record is that NSCR is not an add-on control technology (like SCR). Rather NSCR is built into, and an integral part of the operation of the NAP. Accordingly, as the comments demonstrate (and the ERM analyses s how), adding an SCR to an NSCR plant (which has never been done) would be substantially more co mplex and costly than simply adding SCR to an uncontrolled plant.

This is demonstrated not only by the ERM anal yses referenced in our response to Question 1, but also by the State of Georgia’s BACT determination for a PCS NSCR NAP in Augusta, Georgia (Attachment 3). Please see especially pages 6-9 of Attachment 3, where the Georgia DNR explains how adding an SCR to an NSCR plant would not be cost-effective. The Georgia DNR analysis also notes that there are no known plants that operate both NSCR a nd SCR technologies.

We believe Question 2 also side-steps the basic legal issues in DNI’s judicial and administrative petitions. EPA did not evaluate modification costs in issuing the final NAP Rule, and EPA offered no response to the comments in the r ecord about the fundamental differences between NSCR and SCR plants. We believe this makes the final NAP Rule legally defective, and substantiates the grounds for the relief we s eek through our pending administrative petition.

Question 3. What information does Dyno Nobe l have to demonstrate that the J.R. Simplot (Helm, CA) plant that employs NSCR and meets the 0.5 lb/ton limit is not representative of the industry?

This question is phrased under the assump tion that the Helm plant “meets the 0.5 lb/ton limit.” We recognize that the preamble to the final NAP Rule states that monthly data from the Helm plant ranged under the 0.5 lb/ton limit. EPA concluded that even though the monthly data were not directly comparable to continuous hour-by-hour data, the He lm plant could probably comply with the limit. 77 FR at 48437, col. 1.

But Simplot has informed us that because the current NSPS (subpart G) only requires the CEMS to measure up to 500 ppm, the monthly data EPA has relied upon does not account for higher peaks in the averaging that would be measured by the dual-span CEMS that the new NSPS (subpart Ga) requires. The new subpart Ga , of course, requires that emi ssion peaks occurring during startup

and shutdown must be taken into account in determining compliance with the 0.5 lb/ton limit. 77 FR at 48435. Thus, any assumption that the Helm plant would meet the 0.5 lb/ton limit continuously throughout the year cannot be substantiated based on the monthly data cited by EPA.FOLEY & LARDNER LLP



### December 11, 2012 Page 3

As to the Helm plant’s representativeness, S implot personnel have informed us that they regard the Helm facility to be “a small facility” not representative of traditional NSCR plants. As we pointed out in our administrative petition, the Helm pl ant is rated at a mere 280 TPD and its average production is only 231 TPD.

Relating this information back to our ad ministrative petition, the only bases on which EPA claimed to justify its refusal to subcategorize NSCR modifications were the hourly-by-hourly data from the DNI St. Helens plant (the “Oregon NAP”) and the monthly data from the Simplot Helm plant. We have demonstrated in our administrative petition that the Oregon NAP is not representative of NSCR plants in the U.S. A nd the monthly Helm data to which EPA referred cannot be relied upon because it was taken from in struments which could not account for higher peaks that can be expected during startup and shutdown and at other times throughout a year. Moreover, the Helm plant is very sm all. We believe this underscores the legal defects in the final NAP Rule and the need for subcategorizati on as requested in our administrative petition.

Question 4. How would Dyno N obel define the subcategory for modified/reconstructed facilities currently using NSCR, keeping in mind that CAA 111(b )(2) provides that EPA may subcategorize based on cla sses, types, and sizes?

Our administrative petition requests that EPA establish a subcategory for NSCR NAPs undergoing modification or reconstruction. We belie ve EPA’s record already is replete with data and information establishing that NSCR plants are a distinct category of NAPs and are fundamentally different in design and operation from plants that do not incorporate NSCR. In fact, we note that EPA’s Question 6 below accurately depicts the subcategory we seek: “a subcategory of

modified/reconstructed NS CR controlled plants.”

Question 5. Does Dyno Nobel anticipate that any of their facilities that currently do not achieve the level of the standard will be modifi ed or reconstructed and trigger subpart Ga?

Yes. DNI plans to modify its Cheyenne, Wyoming NAP unit #3 in a manner that would trigger applicability of the new subpart Ga.

Question 6. What standard would be appropriate for a subcategory of modified/reconstructed NSCR controlled plants?

Based upon an analysis of all relevant data regarding NSCR plant performance, for this subcategory DNI could support a NOx limit of 2.0 lb /ton of nitric acid produced, as a 30-day

emission rate calculated based on 30 consecutive operating days. We note that this would require more than a 33% reduction off the current subpart G limit, especially when considering (as noted above) that the current subpart G limit does not requi re inclusion of startup and shutdown peaks to determine compliance (whereas the new s ubpart Ga does require such inclusion).FOLEY & LARDNER LLP



### December 11, 2012 Page 4

As I have mentioned in our phone conver sations, we remain hopeful that EPA’s consideration of the limited request in our administrative petition can result in amendments to the

final NAP Rule that will obviate the need for D.C. Circuit review. Please let me know when we can meet to discuss our petition and our responses to your questions.

Very truly yours,

Richard G. Stoll

Attachments (3)

# ATTACHMENT 1

# ATTACHMENT 2

# ATTACHMENT 3

### Prevention of Significant Air Quality Deterioration Review Of PCS Nitrogen Fertilizer

–Augusta Plant Located in Richmond County, Georgia

PRELIMINARY DETERMINATION SIP Permit Application No. 14213

June 2004

State of Georgia Department of Natural Resources

Environmental Protection Division

Air Protection Branch

Stationary Source Permitting Program

(SSPP)

Prepared by

Heather Cottrell

–Chemicals Unit

Modeling Approved by: Jim Stogner and Richard Monteith Data and Modeling Unit

Reviewed and Ap proved by:

Heather Abrams

–Chemicals Unit Coordinator

John Yntema

–Acting SSPP Manager

Ron Methier

–Chief, Air Protection Branch

### SUMMARY

................................ ................................ ................................ ................................ .... ii

1.0 INTRODUCTION

................................ ................................ ................................ .............. 1

2.0 PROCESS DESCRIPTION

................................ ................................ .............................. 3

Nitric Acid Manufacturing Process

................................ ................................ ..................... 3

3.0 REVIEW OF APPLICABLE RULES AND REGULATIONS

................................ ..... 5

State Rules

................................ ................................ ................................ ........................... 5

Federal Rule

- PSD

................................ ................................ ................................ .............. 5

Federal Rule

–40 CFR 60 Subpart G

................................ ................................ .................. 6

Federal Rule

–40 CFR 64

................................ ................................ ................................ ... 6

4.0 C ONTROL TECHNOLOGY REVIEW

................................ ................................ .......... 6

Nitrogen Oxides (NO X 

### )

................................ ................................ ................................ ....... 6

Summary

–NO X 

### Control Technology Review for the C

- 002 Nitric Acid Plant

................ 9

Carbon Monoxide (CO)

................................ ................................ ................................ ..... 10

Summary

–CO Control Technology Review for the C

- 002 Nitric Acid Plant

................. 12

5.0 TESTING AND MONITORING REQUIREMENTS

................................ .................. 12

6.0 AMBIENT AIR QUALITY REVIEW

................................ ................................ ........... 13

7.0 ADDITIONAL IMPACT ANALYSES

................................ ................................ .......... 20

8.0 EXPLANATION OF DRAFT PERMIT CONDITIONS

................................ ............. 21PSD Preliminary Determination Page 

### ii

SUMMARY

The Environmental Protection Division (EPD) has reviewed the PCS Nitrogen Fertilizer

–Augusta Plant (PCS

N itrogen) application for a permit for the construction and operation of modifications at the facility located in Augusta, Georgia. The plant produces ammonia, nitric acid, urea, carbon dioxide, ammonium nitrate, and

urea

- ammonium nitrate solutions. The p roposed physical changes will be to the C

- 002 Nitric Acid Plant.

The current production rate at the C

- 002 Nitric Acid Plant is limited by air flow rate and pressure equipment restrictions. The modifications will allow the plant to increase acid productio n rate by operating at a higher air flow rate and slightly higher pressure. The pre

- modification acid capacity is 430,700 tons per year. The modification will add the ability to produce an additional 120 tons per day of nitric acid. After completion of the project the plant will operate at a total capacity of 474,500 tons per year of 100% nitric acid (1,300 tons per day). A portion of the additional nitric acid resulting from the proposed project will be sent to the C

- 002 Ammonia Nitrate (AN) Neutralize r. The C

- 001 Nitric Acid Plant will be unaffected by the proposed

modifications.

The modifications proposed in the PSD application are physical changes to several C

- 002 Nitric Acid Plant systems including multiple components of the air compressor system, inlet air cooler, air heater, air / ammonia mixer, converter elbow, and turbine gas heater. The facility will also install a new waste heat boiler, tail gas heater, platinum filter, oxidation vessel, low

- pressure water heat boiler, cooler condenser, and absorber. The air compressor system upgrades include a cooler for air entering the air compressor, upgrading the current air compressor, replacement of the intercooler, upgrading the tail gas expander, rerouting utility steam to the turbine, upgrading the surface condenser, upgrading the cooling towers, and installing a supplemental air supply.

PCS Nitrogen controls NO X emissions from the nitric acid process with a Non

- Selective Catalyst Reduction (NSCR) combustor (Source Code AP07), which reduces NO X to elemental nitrogen, CO 2 , CO, and water. PM

emissions from the C

- 002 AN Neutralizer are controlled with a venturi scrubber (Source Code VS02). The proposed modifications will result in increased PM, SO 2 , NO X , CO, and VOC emissions.

PCS Nitrogen will cont inue to operate a continuous emissions monitoring system (CEMS) for the C

- 002 Nitric

Acid Plant to monitor NO X . The facility will also continue to monitor the venturi scrubber pump pressure, scrubbant flow rate, and sump concentration for control of PM an d opacity from the C

- 002 AN Neutralizer. The facility will install a new CEMS to monitor CO from the C

- 002 Nitric Acid Plant.

PCS Nitrogen is located in Richmond County, which is classified as “attainment” or “unclassifiable” for SO 2 , PM 10 , NO X , CO, and ozone (VOC) in accordance with Section 107 of the Clean Air Act, as amended August

1977.

The EPD review of the data submitted by PCS Nitrogen related to the proposed modifications indicates that the project will be in compliance with all applicable state and federal air quality regulations.

It is the preliminary determination of the EPD that the proposal provides for the application of Best Available Control Technology (BACT) for the control of NO X and CO, as required by federal Prevention of Significant Deterioration (PSD) regulation 40 CFR 52.21(j).

It has been determined through approved modeling techniques that the estimated emissions will not cause or contribute to a violation of any ambient air standard or allowable PSD increment in the area surroun ding the facility (the nearest Class I area is located 230 km from the facility). It has further been determined that the proposal will not cause impairment of visibility or detrimental effects on soils or vegetation. Any air quality impacts produced by project

- related growth should be inconsequential.

This Preliminary Determination concludes that an Air Quality Permit should be issued to PCS Nitrogen

Fertilizer

–Augusta Plant for the construction and operation of the modifications to the C

- 002 Nitric A

cid Plant. Various conditions have been incorporated into the current Title V operating permit to ensure and confirm compliance with all applicable air quality regulations. A copy of the draft permit amendment is included in Appendix A.PSD Preliminary Determination Page 

### 1

1.0 INTRODUCTION

On January 2, 2003, PCS Nitrogen submitted an application for an air quality permit for modifications to
the C

- 002 Nitric Acid Plant. The modifications will be made at the plant located at 733 Laney Walker Blvd Extension, Augusta (Richmond County), Georg ia. The plant currently produces ammonia, nitric acid, urea, carbon dioxide, ammonium nitrate, and urea

- ammonium nitrate solutions. The application was considered complete on February 11, 2004.

PCS Nitrogen is located in an attainment area for all crite ria pollutants. Any proposed project at the plant is therefore required to undergo a PSD applicability analysis in order to determine if the project triggers a PSD review for any pollutant. If a plant’s operation is listed as one of 28 industrial categor ies specified in the PSD regulations and emits more than 100 tons per year of a PSD pollutant, the plant is considered a major source. Nitric acid plants fall under the list of 28 industrial categories and PCS Nitrogen emits in excess of 100 tons per year of NO X . The facility is therefore considered a major source under the PSD program. As a major source, any project that results in a significant increase of any PSD regulated compound triggers a PSD review. The first step in determining if a PSD increas e occurs is to calculate actual emissions for the two year period before the construction project (2000/2001) and compare this result to the future potential emissions after the completion of the project.



### Affected Units

The C

- 002 Nitric Acid Plant has a single emission point. The PSD applicability analysis must also include any emission sources elsewhere in the facility that may be debottlenecked by the proposed project. The additional nitric acid that will result from the proposed project will normally be sent to the

C

- 002 Ammonia Nitrate (AN) Neutralizer, which is a source of particulate matter. The resulting increase in particulate matter emissions from the C

- 002 AN Neutralizer is included in the PSD applicability analysis.

Based on the proposed pro ject, the estimated incremental increases of regulated pollutants from the facility are listed in Table 1.

Table 1: Emissions Increases from the C

- 002 Nitric Acid Plant Modification Project

Pollutant Potential Emissions Increase (tpy) PSD Significant Emi ssion Rate (tpy) Subject to PSD Review

PM 10 * 14.8 15 No

PM* 14.8 15 No

SO 2 0.027 40 No

NO X 297 40 Yes

CO 1,452 100 Yes

VOC 10.3 40 No *All particulate matter was assumed to be PM 10 in order to calculate a conservative emissions analysis. The partic ulate matter quantified here includes filterable and condensible particulate matter.

Emissions of NO X

from the C

- 002 Nitric Acid Plant were based on NO X stack testing that was completed on the unit during the baseline period. A deminimus amount of NO X al so comes from equipment leaks, truck loading, rail car loading, and the nitric acid tanks. Small amount of emissions of volatile organic compounds (VOC), sulfur dioxide (SO 2 ), and particulate matter (PM) from the C

- 002 Nitric Acid Plant

are associated wit h the combustion of natural gas. Emissions of SO 2 and PM are based on AP

- 42 emission factors for natural gas combustion. Emissions of CO and VOC are based on previous stack testing and natural gas usage during the baseline period. The only other emissio ns source included in the PSD applicability analysis is the C

- 002 AN Neutralizer, which is a source of PM emissions. PM emissions from this source were estimated based upon stack test results.PSD Preliminary Determination Page 

### 2

Table 2 details the emissions summary for the individual equi pment effected by the modification. The

calculations for the C

- 002 Nitric Acid Plant and the C

- 002 AN Neutralizer can be found in detail in the facility’s PSD submittal (see Exhibit A of Application No. 14213). These calculations have been

reviewed and a

pproved by the Division.

Table 2: Net Change in Emissions Due to the Major PSD Modification
Annual Emissions (tpy)

PM / PM

10 SO 2 NO X CO VOC Source Past

Actual Future

Potential Past

Actual Future

Potential Past

Actual Future

Potential Past

Actual Futu re

Potential Past

Actual Future

Potential

C

- 002
Nitric Acid

Plant Stack 1.31 1.65 0.104 0.130 210 507 5,666 7,118 65.95 76.22

C

- 002 AN

Neutralizer 36.6 51.0

-- -- -- -- -- -- -- --

Source PM 10 SO 2 NO X CO VOC

Net

Increase 14.8 0.027 297 1,452 10.3

Sig nificance

Level 15 40 40 100 40

PSD Applicable? No No Yes Yes No

As Table 2 shows, the modification to the C

- 002 Nitric Acid Plant will result in an increase in PM/PM 10 , SO 2 , and VOC emissions below the PSD significance level. As specified per Applicat ion No. 14213, the modification is classified as a major modification under PSD because the emissions increase for NO X is greater than 40 tpy and the increase for CO is greater than 100 tpy.

The facility has proposed to accept a federally enforceable limi t of 507 tpy NO X

(2.14 lb NO X

per ton 100% nitric acid) for the C

- 002 Nitric Acid Plant. This requirement limits the maximum net increase in

NO X emissions to 297 tpy. The facility will comply with this long

- term limit in conjunction with a short

term BAC T limit of 3.0 lb NO X per ton of 100% nitric acid. It should be noted that this is the same standard set by 40 CFR 60 Subpart G. The facility has also proposed to accept a federally enforceable limit 30.0 lb of CO per ton of 100% nitric acid. Compliance will be determined on a 12 month rolling average. This requirement limits the maximum net increase in CO emission to 1,452 tpy.



### Non

- Affected Units

The only other emission source from the process is particulate from the two ammonium nitrate prill

towers and the associated prill processing equipment. PCS currently operates these units at their maximum capacity; therefore any additional nitric acid that will be generated as a result of the proposed project will be manufactured into liquid ammonium nitrate solutions. Because the proposed project will not affect utilization of the prill towers they are not included in the PSD applicability analysis. Also, the nitric acid storage tanks are potential sources of a small amount of nitric acid emissions; howeve r, these tanks are controlled by an acid vent recovery scrubber system.

The C

- 002 Nitric Acid Plant is currently a net exporter of steam. The plant conducted an assessment of the proposed changes, which include modifications to the steam system (not to t he boilers themselves), and concluded that the plant will continue to be a net exporter of steam after the completion of the project. As a result the project will not result in an increased utilization of the utility boilers and, in fact, could potentiall y reduce emissions from the utility boiler although no credit is taken for a reduction.

Other than air, the major raw material in the nitric acid production process is ammonia. PCS Nitrogen’s ammonia plant operates at its maximum capacity and still does not meet the demand for the other units so ammonia is purchased. Therefore, the increase in ammonia demand will be met through additional off

site purchases and will not affect emissions from the on

- site ammonia production operations.PSD Preliminary Determination Page 

### 3

Through its new sour ce review procedure, EPD has evaluated PCS Nitrogen’s proposal for compliance with State and Federal requirements. The findings of the EPD have been assembled in this Preliminary
Determination.



### 2.0 PROCESS DESCRIPTION

Nitric Acid Manufacturing Process

PCS Nitrogen operates two nitric acid plants, C

- 001 Nitric Acid Plant and C

- 002 Nitric Acid Plant. The proposed project involves changes to only the C

- 002 Nitric Acid Plant, the newer of the two plants. The production of nitric acid occurs in three steps : ammonia oxidization, nitric oxide (NO) oxidation, and

NO 2 absorption.

The process begins with the compression of ambient air in a two

- stage compressor. An intercooler between the two stages allows for temperature reduction and improved compression. A steam turbine and tail gas expander provide the mechanical energy used for the air compression. The steam for the turbine is currently provided by a waste heat boiler via superheater.

The compressed air is then combined with ammonia in a mixer. The mix ed ammonia

- air mixture is routed to a converter reactor where the gases cross a platinum catalyst mesh that oxidizes ammonia to NO. Due to the high cost of the catalyst used in this operation a filter is installed downstream of the heat exchangers to coll

ect platinum that has been removed from the catalyst mesh. The oxidization process is an exothermic reaction and some of the heat generated is recovered in the waste heat boiler and two tail gas heat exchangers. The tail gas heat exchangers transfer heat from the process gas to the tail gas, which is exiting the nitric acid production process.

The gases next enter an oxidation vessel, which further oxidizes the NO to NO 2 . The low

- pressure waste heat boiler recovers additional heat generated in this oxid ation step. Next, the NO / NO 2 goes through a cooler condenser to lower the temperature of the gases. A nitric acid solution is also condensed out. The gases exit the cooler and are routed to the bottom of an absorber where they travel up through vertic ally stacked trays. Water runs countercurrent from the top of the absorber and reacts with NO 2 to form nitric

acid. The formation of nitric acid results in the formation of NO that must be reoxidized to NO 2 prior to being absorbed. For this reason, cool ed air is also added to the bottom of the absorber to aid in the oxidation that occurs between the individual trays in the absorption column. The nitric acid is collected at the bottom of the absorber column and sent to a storage tank.

The gases exiting the absorber go through several steps aimed at the reduction of any residual NO X emissions and the recovery of energy from the tail gas. This includes a mist eliminator to remove any remaining liquid in the stream, a tail gas pre

- heater, and other heat ex changers for recovery of heat from the ammonia oxidation steps. Natural gas is then mixed with tail gas prior to entering a steam superheater.

After the superheater, the gases enter a Non

- Selective Catalyst Reduction (NSCR) combustor where

several chemic al reactions take place to reduce the NO X in the exhaust gas. The oxygen and natural gas are combusted, and secondly, the NO X and natural gas are reacted. The products of these reactions are elemental nitrogen, CO 2 , CO, and water.

When the cleaned gases

exit the combustor, they are routed through a tail gas expander to generate mechanical energy that is used to operate the air compressor. The gas exiting the expander is routed through two heat exchangers to recover any residual heat prior to being vente d to the atmosphere through

Stack ST

- 19.PSD Preliminary Determination Page 

### 4

C

- 002 AN Neutralizer Process

The nitric acid from the C

- 002 Nitric Acid Plant is first reacted with ammonia vapor in the first stage neutralizer. The liquid from the first stage neutralizer overflows into a secon d stage neutralizer where additional ammonia is added. The gases from the first stage vent to a venturi scrubber. The scrubber is in place to collect any ammonium nitrate particulate matter that is emitted from the first stage. The liquid

ammonium nitra te solution exiting the neutralizer goes to a buffer tank prior to being sent to the solutions blending plant or one of the two prill towers.



### Project Description

The proposed project involves modifying several systems in the C

- 002 Nitric Acid Plant in or der to increase the pressure rating of the system and thereby increase the air flow through the system. This air flow determines the amount of nitric acid produced. The amount of air flow rate is limited by the air compression system and the pressure rat ing of the equipment in the plant. System pressure is the limiting factor during the winter months and the air

- compression system is the limiting factor during the summer

months.

PCS Nitrogen will be installing an air cooler for the ambient air entering the air compressor. The air cooler will drop the temperature of the air entering the air compressor and thereby allow for increased air throughput and thereby increase production. The intercooler, which is part of the main air compressor, will be replace d with an improved design that will solve current leakage problems and slightly improve performance.

PCS Nitrogen also plans modifications to increase power from the steam turbine for additional air compression. This will include physical modifications t o the turbine itself as well as the rerouting of steam from the utility boilers to the steam turbine. Currently, steam from the nitric acid plant boiler and steam superheater is routed to the steam turbine. However, by utilizing superheated steam directl y from the utility boilers, which is at a higher temperature, the plant will be able to generate additional compression from the steam turbine. The lower temperature superheated steam generated at the C

- 002

Nitric Acid Plant will be utilized at other area s of the site. The surface condenser and cooling tower at C

002 Nitric Acid Plant will be upgraded to meet the additional cooling demands.

Finally, PCS Nitrogen plans to install a separate air supply entering directly at the absorber. Currently,

this a ir stream is supplied by the main air compressor, and therefore utilizes some of the available compressor capability. By utilizing a separate air supply for this air stream, the plant can utilize the entire capacity of the existing compressor to compress air that enters the heat train and thereby increase production.

PCS Nitrogen also plans to replace the air heater, the ammonia / air mixer, the converter elbow, the turbine gas heater, waste heat boiler, the tail gas heater, the platinum filter, the oxi dation vessel, the low pressure waste heat boiler, the cooler condenser, the absorption tower, and non

- selective catalytic reduction combustor. All of these modifications will allow the units to operate at a higher pressure.

Neither the utility boilers o r the ammonia plant at the site will be debottlenecked by the proposed expansion of the C

- 002 Nitric Acid Plant. The C

- 002 Nitric Acid Plant is a net exporter of steam, thus the project will not increase steam demand for the site. Instead the boiler load at the site should decrease due to these proposed modifications. PCS operates an ammonia production plant on site; however, it is currently operating at a maximum capacity. Additional ammonia demand will therefore be met through purchased ammonia.PSD Preliminary Determination Page 

### 5

As r equired by 40 CFR 60 Subpart G, and to assure compliance with the BACT/PSD permit limits, PCS Nitrogen will continue to monitor NO X emissions from the C

- 002 Nitric Acid Plant. The facility is also required to develop a conversion factor through performanc e testing for calculating pounds NO X per ton 100% nitric acid from the CEMS output. This information, along with production rate data, will allow the facility to calculate the 12

- month rolling total. The facility will use the same CEMs / conversion

facto r strategy for monitoring the emissions of CO.



### 3.0 REVIEW OF APPLICABLE RULES AND REGULATIONS

State Rules

Georgia Rule (b) [391

- 3

- 1

- .02(2)(b)] and Georgia Rule (e) [391

- 3

- 1

- .02(2)(e)] are general rules limiting the opacity and PM emissions from the C

- 00 2 AN Neutralizer. Georgia Rule (b) limits the opacity of emissions from the unit to 40%. Georgia Rule (e), commonly known as the process weight rule, limits PM emissions based on either of the following equations:

For P 3 30 ton/hr, E = 4.1P 0.67

For P > 30 ton/hr, E = 55P 0.11

- 40

where E = emission rate (lb/hr) and P = process input rate (ton/hr). The second equation applies to the C

002 AN Neutralizer.



### Federal Rule

- PSD

The regulations for PSD in 40 CFR 52.21 requ ire that any new major source or modification of an existing major source be reviewed to determine the potential emissions of all pollutants subject to regulations under the Clean Air Act. The PSD review requirements apply to any new or modified source

wh ich belongs to one of 28 specific source categories having potential emissions of 100 tons per year or more of any regulated pollutant, or to all other sources having potential emissions of 250 tons per year or more of any regulated pollutant. They also a pply to any modification of a major stationary source which results in a significant net emission increase of any regulated pollutant.

The PSD regulations require that any major stationary source or major modification subject to the regulations meet the f

ollowing requirements:

1. Application of BACT for each regulated pollutant that would be emitted in significant amounts;

2. Analysis of the ambient air impact;

3. Analysis of the impact on soils, vegetation, and visibility;

4. Analysis of the impact on Cl ass I areas; and
5. Public notification of the proposed plant in a newspaper of general circulation.



### Definition of BACT

Sources undergoing a PSD review must apply Best Available Control Technology (BACT) to any new or

modified emission unit that emits a PSD triggered pollutant. Under 40 CFR 52.21, the federal PSD regulations define BACT as “an emission limitation (including a visible emission standard) based on the maximum degree of reduction of each pollutant subject to regulation under the Clean Air A ct, emitted from or which results from any major emitting facility, which the permitting authority, on a case

- by

- case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such facility through application of production processes and available methods, systems, and techniques, including cleaning or treatment or innovative fuel combustion techniques for control of each such pollutant.” No BACT determination may be less stringent that the applica ble NSPS, National Emissions Standards for Hazardous Air Pollutants (NESHAPS) or State Implementation Plan (SIP) limits.PSD Preliminary Determination Page 

### 6

On December 1, 1987, the US EPA Assistant Administrator for Air and Radiation issued a memorandum that implemented certain program init iatives designed to improve the effectiveness of the New Source Review (NSR) programs within the confines of existing regulations and SIPs. Among these was the “top

down” method for determining BACT. The “top

- down” process begins by identifying all avail able control technologies. Next, the technically infeasible options are eliminated. The remaining control technologies are then ranked by their control effectiveness. Next, the most stringent or “top” alternative is evaluated. This top alternative repr esents BACT, unless it can be demonstrated, and the permitting authority agrees, that technical considerations, energy, environmental, or economic impact justify a conclusion that the most stringent technology is not “achievable” in a particular case. If the most stringent technology is eliminated in this fashion, then the next most stringent alternative is 

### considered, and so on, until the most appropriate control strategy is selected for each source.

Federal Rule

–40 CFR 60 Subpart G

The C

- 002 Nitric A cid Plant is subject to NSPS Subpart G, Standards of Performance for Nitric Acid
Plants. Subpart G establishes a NO X emission limit of 3.0 lb NO X per ton of 100% nitric acid produced. The Permittee is required to monitor these emissions using a nitrogen oxide CEMS in conjunction with a conversion factor (ppm to pounds NO X per ton nitric acid) determined through a performance test conducted once every year. The subpart also establishes an opacity limit of less than 10%. No monitoring is required for the opacity limit. The NO X emission limit is low enough to keep opacity below

10%.



### Federal Rule

–40 CFR 64

The C

- 002 Nitric Acid Plant is subject to 40 CFR 64

– Compliance Assurance Monitoring (CAM). CAM applies because the plant is located at a major sou rce with a Title V permit, the plant is subject to an emission limit, and the facility uses a control device to achieve compliance with the limit. CAM has been triggered because the facility is making a significant modification to a unit with potential co ntrolled NO X emissions of at least 100 percent of the major source threshold. CAM requires the facility to submit a plan containing the following information: 1) indicators of emission control performance; 2) indicator ranges; 3) performance criteria; 4) indicator ranges and performance criteria for CEMs, COMs, and PEMs; 5) monitoring justification; 6) test data, if necessary; and 7) implementation and schedule for equipment installation, testing, and other activities, if necessary. The facility has subm itted the CAM Plant as required and the Division has approved the plan. The facility will continue to monitor NO X emissions with a CEMs.



### 4.0 CONTROL TECHNOLOGY REVIEW

The purpose of this section is to provide details of the steps taken in evaluating the “top down” BACT analysis for NO X

and CO emissions from the C

- 002 Nitric Acid Plant. Several pieces of process equipment in the C

- 002 Nitric Acid Plant are being physically modified as part of the proposed project. All the units operate in series as part of the plant and, in turn, vent through a single emission point.



### Nitrogen Oxides (NO X 

### )

The first reaction in the production of nitric acid is the oxidation of ammonia to NO. Next, the NO is

further oxidized to NO 2 . The NO 2 gases are routed through a w ater absorber to create nitric acid. A portion of the NO X

gases are not absorbed and exit the control device. These gases must be treated to

reduce emissions of the unreacted NO X released to the atmosphere.PSD Preliminary Determination Page 

### 7

Step 1: Identify all control technologies

T here are two NO X

emission reduction technologies that are utilized at nitric acid plants. These technologies are non

- selective catalyst reduction (NSCR) and selective catalytic reduction (SCR). The PCS Nitrogen C

- 002 Nitric Acid Plant currently utilizes the NSCR technology for NO X emission control.

The first step of the BACT analysis was a review of the NO X emission rates that are currently being achieved by other nitric acid plants in the industry. These emission rates were determined through a

revie w of the EPA BACT / LAER Clearinghouse. In addition, a review of other recently permitted nitric acid plants was also completed. The results of this review are summarized in Table 3.

Table 3: Permitted NO X Emission Levels for Nitric Acid Plants Listed in BACT / LAER Database

Plant Location Unit NO X Emissions Control Technology lbs NO X / ton

100% Nitric Acid Terra Nitrogen Ltd Partnership (1998) Woodward,

Oklahoma Nitric Acid Plant SCR 3.0

Arcadian Fertilizer LP

– Geismar Facility (1997) Geismar,

Louis iana Nitric Acid Train 4 NSCR 2.14 (primary) 3.0 secondary* Apache Nitrogen Products, Inc. (1991) Arizona Nitric Acid Plant NSCR 3.0

Wycon Chemicals (1984) Wyoming Nitric Acid Plant #1

Nitric Acid Plant #2 None Noted 6.0

Wycon Chemicals (1984) Wyoming N itric Acid Plant #3 Catalytic NO X Abator 3.0

California Ammonia (1981) California Nitric Acid Plant Extended Absorption

Column 210 ppm (primary)

3.0 (secondary) *BACT was established at 3 lb/ton for the unit. In addition the plant took a 195 tpy NO X lim it (2.14 lb NO X per ton 100% nitric acid) for its 500 T/D nitric acid plant in order to comply with the NAAQS.

The control technology options are as follows:

Option 1: Non

- Selective Catalytic Reduction (NSCR) Option 2: Selective Catalytic Reduction (SC R)

– Method 1 (Replacing current NSCR unit with SCR unit) Option 3: Selective Catalytic Reduction (SCF)

– Method 2

(SCR as add

- on controls).



### Step 2: Eliminate technically infeasible options

Options 1 and 3 are considered technically feasible. Option 2 is technically infeasible as explained

below:



### Option 2

–Selective Catalytic Reduction (SCR)

–Method 1

SCR uses a catalyst bed and ammonia injection to (1) consume the free oxygen in the absorber tail gas, (2) convert the NO 2 to NO (decolorization), a nd (3) reduce NO to elemental nitrogen, CO 2 , CO, and water. The catalyst is termed selective because the ammonia preferentially reacts with NO X in the absorber tail gas.

Two plants (BP Chemicals in Lima, Ohio which is owned by PCS Nitrogen and El Dorado Nitrogen in Baytown, Texas) both utilize only SCR technology and both have a lower NO X emission limit than the proposed 3.0 lb/ton short term limit (1.4 lb/ton and 0.38 lb/ton respectively). While these plants represent Option 1, it must be noted that the se plants are able to achieve these lower levels because they are of a more modern design (the BP Chemicals plant was built in 1991 and the El Dorado Nitrogen plant was built in 1999), which is crucial in being able to utilize SCR technology. By compariso n, the PCS Nitrogen project in Augusta, Georgia is a modification of an existing plant built in 1977.PSD Preliminary Determination Page 

### 8

SCR is most effective at temperatures near 600 °F. Currently, at PCS Nitrogen and other old design plants, the gases entering the combustor are roughly 900 °F. Therefore, in order for the SCR to work, the temperature of the gases entering the SCR would need to be cooled by roughly 300 °F. This could be achieved by bypassing the turbine gas heater and the steam superheater; however, the effect of this

c hange would be to derate the heat efficiency of the system. Secondly, the gases entering the combustion catalyst are raised to approximately 1250 °F. This increase in energy is removed and utilized in the C

002 Nitric Acid Plant tail gas expander. If th e inlet temperature of the tail gas expander was 600 °F instead of 1250 °F the tail gas expander would be ineffective in supplying power to the air compressor. The tail gas expander provides roughly 75% of the horsepower for the air compressor that runs t he nitric acid plant. This loss in power would therefore have to be made up by some other source. This would require a new steam or combustion turbine, which would increase NO X emissions.

On the other hand, plants built around SCR technology are designe d to recover heat generated from the ammonia and NO oxidation stages to generate steam. This steam is utilized to provide mechanical energy in a steam turbine. The steam turbine, in turn, powers the air compressor. In the case of an older plant designed around NSCR technology, the excess heat generated in the heat train is utilized to pre

- heat the gases exiting the absorber prior to entering the combustor. This gas is next routed through the tail gas expander to generate mechanical energy. The tail gas expander in turn provides most of the power for the air compressor. A steam turbine is used at plants with NSCR technology, but only to power the air compressor during startup and to provide a small fraction of the power needing during normal operation. In a plant designed with SCR technology, the power to operate the air compressor is provided by the steam turbine, where as in the case of NSCR technology based plants, the power to compress the air is provided primarily by the tail gas expander and only secondarily by a team turbine. To modify the production process so that SCR could be used would require a complete redesign of the existing plant and is therefore not considered practical or economical.



### Step 3: Rank remaining control technologies by con trol effectiveness

Table 4: Ranking of Control Technology
Control Technology Ranking Control Technology Control Efficiency

1 Non

- Selective Catalytic Reduction 94.7

- 99.1%*

2 Selective Catalytic Reduction 97.2%*
*US EPA and BACT Clearinghouse



### Step 4: Evaluate most effective controls and document

Option 1

–Non

- Selective Catalytic Reduction (NSCR)

NSCR uses a catalyst bed and fuel to (1) consume the free oxygen in the absorber tail gas, (2) convert the

NO 2 to NO (delecolorization), and (3) reduce NO to elemental nitrogen, CO 2 , CO, and water. This process can utilize natural gas, propane, or hydrogen gas as the fuel. PCS Nitrogen utilizes natural gas as the primary fuel, however, hydrogen is utilized during startup of the plant.

The facility current ly uses this control method, therefore it is feasible for control of the emissions following the proposed modifications. According to data taken from the EPA document “Alternative Control Techniques Document

- Nitric and Adipic Acid Manufacturing Plants”, a review of numerous plants utilizing the available control technologies found that on average, NSCR technology NO X control efficiency was higher than that of SCR technology control efficiency.

As shown in Table 4

- 1, there are 5 listed units with NO X BACT limits of 3.0 lb/ton. The Arcadian Fertilizer (now PCS Nitrogen) nitric acid plant located in Geismar, Louisiana, has a second NO X permit limit of 195 tpy (2.14 lb NO X per ton 100% nitric acid). This limit is lower than its 3.0 lb/ton BACT limit
on a tpy basis (assuming maximum production) and was taken for modeling compliance purposes.PSD Preliminary Determination Page 

### 9

PCS proposes to meet a 507 tpy NO X emission limit for the 1,300 tpd plant which is equivalent to the 195 tpy NO X limit which was taken for the 500 tpd Arcadian Fertilizer plant. The proposed BACT level is therefore 3.0 lb/ton along with a 12

- month rolling limit of 507 tpy NO X (2.14 lb NO X per ton 100% nitric acid). Compliance with both levels will be demonstrated with the existing continuous NO X emissions

monitor. Becau se the effectiveness of the NSCR unit is dependent upon the use of natural gas as a reducing agent, the reduction in the annual NO X limit may require the increased utilization of natural gas,

which is accounted for in the emission calculations.



### Option 2

–Selective Catalytic Reduction (SCR)

–Method 2

The use of SCR technology as an add

- on control for the tail gases of the process, rather than a process conversion, was considered. The exhaust gases exiting the nitric acid plant are about 300 °F. In orde r for the SCR to be effective, the exhaust temperatures must be about 600 °F. The exhaust gases would therefore need to be raised by 300 °F in order for the SCR system to be effective. This temperature rise could be achieved through one of two methods: bypassing the economizer or adding a natural gas burner to add heat. Either approach would require additional energy consumption that would result in additional combustion emissions. A cost analysis was completed in order to determine the potential effec tiveness of installing an SCR add

- on control to the existing NSCR control system. This cost analysis is summarized

in Table 5.

Table 5: Cost Effectiveness of SCR Retrofit

Variable Value Basis

NO X Emissions at Proposed BACT Level 507 tpy NO X Proposed An nual BACT Level

NO X Emissions at SCR Controlled Level 90 tpy NO X Based on vendor estimated emissions with SCR (0.38

lb/ton) and a production rate of 474,500 tpy

NO X Emissions Reduction with Add

- on SCR 417 tpy NO X Difference

Total Annualized Cost of SCR (including additional natural gas costs) $4,330,000/yr Annualized Cost Estimate for Add

- on SCR System*

Cost Per Ton NO X Reduction $10,384/ton Divided Annual Costs by Maximum NO X Reduction *See Exhibit C of the permit application for the cost analysis for the installation of add

- on SCR technology.

As shown above the costs associated with installing an add

- on SCR to the existing NSCR system well
exceeds levels which are considered cost effective for the control of NO X . Note that in order to be effective, the ammonia to NO X ratio must be greater than stoichiometry (1 to 1). Some of the ammonia injected will therefore be emitted unreacted (ammonia slip). It should also be noted that no known nitric acid plants operate both NSCR and SCR technologies.



### Step 5: Select BACT

Based on the above evaluation, BACT requires the plant to continue to use Non

- Selective Catalytic

Reduction to control NO X from the modified C

- 002 Nitric Acid Plant.



### Conclusion

–NO X 

### Control

The Division has determined that PCS Nitrogen’ s proposal to use NSCR to minimize NO X emissions

constitutes BACT. The BACT emission limits have been established as 3.0 lb NO X per ton 100% nitric acid and 507 total tons per year of NO X (an annual average of 2.14 lb NO X per ton 100% nitric acid).



### Summa ry

–NO X 

### Control Technology Review for the C

- 002 Nitric Acid Plant

To fulfill the PSD permitting requirements for NO X , a BACT analysis was conducted for the modified

C

- 002 Nitric Acid Plant. The BACT selection for the plant is summarized in Table 6. T he emission limit selected is representative of previous PSD BACT determination levels published in U.S. EPA’s RACT/BACT/LAER Clearinghouse (RBLC) for plants of the similar type.PSD Preliminary Determination Page 

### 10

Table 6: BACT Summary for the Proposed Modified C

- 002 Nitric Acid Plant

Poll utant Control Technology Proposed BACT Limit Averaging Period

NO X NSCR 3.0 lb NO X per ton 100% nitric acid 3 hours

NO X NSCR 507 tpy NO X (2.14 lb NO

X per ton acid) 12 months



### Carbon Monoxide (CO)

The CO emissions from the nitric acid plant result from combustion of natural gas in the NSCR combustor. This increase in CO is considered justifiable because regionally NO X is of greater concern that CO. By injecting natural gas the unit consumes all the available oxygen, and simultaneously but at a

slower k inetic rate, the NSCR system reduces the natural gas and NO X to nitrogen, CO 2 , CO, and H 2 O.

CO emissions from the plant tend to increase in the stoichiometric ratio of natural gas to oxygen and NO X going to the combustor. For most catalysts, effectivenes s degrades slowly over time, requiring an entire bed change approximately every two years. Therefore, keeping all other variables constant, NO X emissions would tend to increase over time if nothing else was done. To counter this effect the amount of

natu ral gas fed to the combustor is increased over time, which in turn raises the natural gas stoichiometric ratio, and ultimately CO emissions. This effect is represented by the “R

- factor,” which governs the proper operation of the combustor.

The R

- factor i

s the ratio of the actual amount of natural gas feed to the combustor versus the stoichiometric amount of natural gas needed to reduce the NO X to water and elemental nitrogen. The goal is to keep the R

- factor as close to one as possible. If the factor is less than one then unreacted NO X can leave the system and can cause non

- compliance with the facility’s short

- term limits. A very high R

- factor

can drive NO X

emission down, however this condition indicates that too much fuel is being fed to the

combustor. This can result in higher than necessary CO emissions and wasted natural gas.

The facility conducted a series of performance tests on June 19, 2002. The tests were conducted with the guidance of the equipment vendor. The facility monitored NO X , CO, O 2 , CO 2 , and natural gas concentrations at various combustor conditions which included starving the system of natural gas, normal operation, and flooding the system with natural gas. The starvation, normal operation, and flooding

conditions simulated the be ginning, middle, and end of catalyst life. Based on testing conducted on the

C

- 002 Nitric Acid Plant, CO emissions ranged from between 3.1 to 43.0 lb CO/ton of 100% nitric acid produced, and averaged 27.7 lb per ton of 100% nitric acid during the testing that represented the last 12 months of operation before the catalyst is replaced. The facility has proposed a BACT limit of 30.0 lb CO per ton of 100% nitric acid based on these results.

As with the NO X

BACT evaluation, a review of the EPA clearinghouse and the available permits for other recently permitted nitric acid plants was performed for CO emission limits. The facility stated that the PCS Nitrogen Geismar facility is the only site with CO limits for nitric acid plants. A review of the

Geismar PSD permit documents shows that the facility netted out for CO during the PSD analysis. The net increase was 21.66 tpy. Because the net increase did not equal or exceed the PSD significance threshold of 100 tpy a BACT analysis was not performed. In additio n, the Division has reviewed the EPA BACT / LAER Clearinghouse and no limits for CO emissions from a nitric acid plant were found.



### Step 1: Identify all control technologies

No known nitric acid plants operate emission controls for CO emissions. The fac ility examined the use of a Regenerative Thermal Oxidizer (RTO) or a catalytic system for CO control as used in other manufacturing industries.

Option 1: Regenerative Thermal Oxidizer Option 2: Catalytic System Option 3: Good Design and OperationPSD Preliminary Determination Page 

### 11

Step 2: Eliminate technically infeasible options

Options 1 and 3 are considered to be technically feasible. Option 2 is technically infeasible as explained
below:



### Option 2

–Catalytic System

At sufficient temperatures, CO can be converted to CO 2 across a catalyst. As with an RTO, additional oxygen would be required to allow for the conversion of CO to CO 2 . Discussions with vendors indicate that roughly 15% O 2

would be required for a catalyst system to be effective. The addition of sufficient air

to rais e the oxygen content to 15% O 2 would result in a 2.5 fold increase in the total flow of the exhaust stream. This dilution of the exhaust stream of ambient air would drop the temperature of the exhaust gases to well below minimum temperatures which are req uired for a catalyst system to operate (350 °F). A catalyst system is not therefore considered technically feasible.



### Step 3: Rank remaining control technologies by control effectiveness

Table 7: Ranking of Control Technology
Control Technology Rankin g Control Technology Control Efficiency

1 Regenerative Thermal Oxidizer 40%

- 98%

2 Good Design and Operation N/a

Step 4: Evaluate most effective controls and document

Option 1

– Regenerative Thermal Oxidizer

The most common means for CO control is oxidation. Oxidation completes the combustion process by converting CO into CO 2 . The most practical combustion control device for a high flow application would be a RTO. In order for the combustion process to occur air would need to be added to the exha ust because the NSCR system consumes all available oxygen. The increase in oxygen content would, in turn, increase the operating exhaust flow rate and increase the operating costs associated with operating a RTO.

Discussions with RTO vendors indicate that the oxygen content would need to be a minimum of 3% to ensure high combustion efficiency in an RTO. To achieve this minimum oxygen level, the RTO would need to bleed in an additional 17,000 acfm to the exhaust gas stream, which would result in a total

ex haust flow rate to be treated of 117,000 acfm.

In order to determine the costs of installing an RTO, an economic evaluation was completed. This evaluation was based on the EPA cost estimating spreadsheets for RTOs. This evaluation concluded that

an RTO sized to handle this exhaust stream would cost roughly $3,900,000 and require roughly $1,100,000 in operating costs per year. This would therefore result in a cost of $250 per ton of CO

reduced.

However, the operation of an RTO or any combustion control device for CO would also create NO X emissions, which is the pollutant that is originally being abated by the NSCR. It is estimated that an

increase in NO X

of about 30 tpy would result from the installation of a RTO. As shown in Section 6.0 of

this docume nt, the modeling for CO emissions indicated that concentrations were only about 21% of the PSD Significance Level for a 1

- hour average and 38% of the significance level on an 8

- hour average. No additional modeling was required for the pollutant. The mode led NO X concentration did exceed the significance level on an annual basis. Further modeling indicated that NO X concentrations were 73.6% of the Class II PSD Increment and 77.1% of the NAAQS. Considering the small environmental benefit of reducing CO ver sus the environmental impact of a RTO (increased NO X in an ozone sensitive area), the increased energy demands (increased natural gas and electrical usage in the RTO), and moreover because this control has never been demonstrated in this process applicatio n, the use of a RTO is not considered practical for the C

- 002 Nitric Acid Plant.PSD Preliminary Determination Page 

### 12

Option 3

–Good Design and Operation

The formation of CO is minimized by proper NSCR combustor design and operation. Good operation includes replacing the catalyst as needed and injecting natural gas to the system in the proper amounts.



### Step 5: Select BACT

BACT requires that the plant continue to use good design and operation to control CO from the modified

C

- 002 Nitric Acid Plant.



### Conclusion

–CO Control

The Division ha s determined that PCS Nitrogen Fertilizer’s proposal to use good design and operation to

minimize CO emissions constitutes BACT. The BACT emission limit has been established as 30.0 lb CO per ton 100% nitric acid on a 12 month rolling average.



### Summary

– CO Control Technology Review for the C

- 002 Nitric Acid Plant

To fulfill the PSD permitting requirements for CO, a BACT analysis was conducted for the modified C

002 Nitric Acid Plant. The BACT selection for the plant is summarized in Table 8.

Table 8: BACT Summary for the Proposed Modified C

- 002 Nitric Acid Plant

Pollutant Control Technology Proposed BACT Limit Averaging Period

CO Good Design and Operation 30.0 lb CO per ton 100% nitric acid 12 month rolling average



### 5.0 TESTING AND MONITORING REQUI REMENTS

Testing Requirements:

The facility will have to conduct performance testing for NO X and CO from the C

- 002 Nitric Acid Plant. The facility will also be required to conduct performance testing for PM emissions from the C

- 002 AN

Neutralizer.



### Monit oring Requirements:

The Permittee is currently required to monitor NO X emissions from the C002 Nitric Acid Plant using a CEMS. This requirement will continue to be applicable. The CEMS will provide a reasonable assurance of compliance with the NSPS and PSD permit limits. The facility must also operate the NO X monitor in

accordance with the CAM Plan.

The Permittee will now be required to monitor CO emissions from the C002 Nitric Acid Plant using a CEMS. The CEMS will provide a reasonable assurance of c ompliance with the PSD permit limit.

The facility will continue to monitor the C

- 002 AN Neutralizer scrubber. The monitoring data will provide a reasonable assurance of compliance with Georgia Rules (b) and (e).



### CAM Applicability:

The permit amendment includes the CAM Plan submitted by PCS Nitrogen for monitoring NO X emissions from the C

- 002 Nitric Acid Plant. The plan summarizes the CEMS requirements already in place at the facility.PSD Preliminary Determination Page 

### 13

6.0 AMBIENT AIR QUALITY REVIEW

An air quality analysis is required to determine the ambient impacts associated with the construction and operation of the proposed modifications to the C

- 002 Nitric Acid Plant. The main purpose of the air quality analysis is to demonstrate that emissions emitted from the proposed modified major stationary source, in conjunction with other applicable emissions from existing sources (including secondary emissions from growth associated with the new project), will not cause or contribute to a violation of any applicable National Ambient Air Q uality Standard (NAAQS) or PSD increment in a Class II or Class I area. NAAQS exist for NO 2 , CO, PM 10 , SO 2 , Ozone (O 3 ), and lead. PSD increments exist for SO 2 , NO 2 , and PM 10

.

A separate air quality analysis is required for each pollutant emitted in an a mount over the PSD significant emission rate threshold. As was shown in Table 1, NO X and CO are to be emitted in amounts over the respective PSD significant threshold. Thus, an air quality analysis must be performed for these two air pollutants.

Complia nce with any NAAQS is based upon the total estimated air quality, which is the sum of the ambient estimates resulting from existing sources of air pollution (modeled source impacts plus measured background concentrations) and the modeled ambient impact cau sed by the applicant’s proposed emission increase and associated growth. It is important to note that the air quality cannot be allowed to deteriorate beyond the concentration allowed by the applicable NAAQS, even if not all of the PSD increment is

consum ed.



### Modeling:

In general, EPD assesses the ambient impact of a source through the use of mathematical dispersion models. The models are based on the assumption that the dispersion of pollutants is primarily a function of wind speed and direction, atmosp heric stability conditions, and the characteristics of the effective point discharge of the exhaust plume. To predict ambient air concentrations, the models simulate the plume exhausting from the stack, rising a certain distance in the atmosphere, levelin g off, and continuing downwind over relatively flat terrain. The concentrations of the pollutants are assumed to have Gaussian distribution about the downwind axis centerline of the plume.

The modeling was performed with the latest version of the Industr ial Source Complex Short

- Tem Version 3 (ISCST3). ISCST3 is a Gaussian plume dispersion model that estimates hour

- by

- hour ground

- level concentrations of emissions from an elevated source. The model provides maximum 24

- hour and annual average concentration s for receptors located on many grid types around the source for various downwind distances. The model also takes into account the effect of downwash caused by nearby buildings and

structures.

The only NO X

and CO emission point included in the analysis i s the C

- 002 Nitric Acid Plant stack because it is the only source impacted by the proposed project. Stack conditions are not expected to change significantly as a result of the project; therefore, the source was modeled as a single stack. The

emission ra te modeled was the difference in the future potential after the project is completed (maximum production at the established BACT emission level) minus the emission rate from the C

- 002 Nitric Acid Plant during the baseline period (2000/2001). Baseline emis sions were based on the average of the CO

and NO X stack tests completed during the baseline periods and the average ton/yr production during the baseline period. Table 9 summarizes the emission rate and modeling parameters that were used for the

stack.PSD Preliminary Determination Page 

### 14

Table 9: Modeled Stack Parameters

Source Location

Parameter UTM

Northing (m) UTM

Easting (m) Temp

(K) Flow Rate

(m/s) Dia.

(m) Stack Height (m) Increase in

CO Emissions (g/s) Increase in

NO X Emissions (g/s)

C

- 002

Stack 3700684 413532 447 32.83 1. 52 21.0 41.77 8.57

For this review of the proposed PCS Nitrogen facility, the models utilized preprocessed hourly meteorological data based on surface measurements made in Augusta, Georgia and upper air measurements made in Athens, Georgia for the period of 1974

- 1978. EPA’s Building Profile Input Program (BPIP) was used to calculate building dimensions for the required flow vectors for the short term ISC model in order to allow for building downwash. The BPIP developed results for 36 possible wind

direc tions.

A Cartesian receptor grid was used for the model runs, with receptors spaced at 100 meters along the fence line and out to a distance of 1 kilometer from the center of the facility, with receptors spaced at 500

meters from 1 kilometer to 5 kilomete rs, and with receptors used in the ISC modeling. Digital Elevation Model (DEM) data obtained from the U.S. Geological Survey was used to determine receptor heights using the EPA AERMAP computer program. These heights were spot checked against topographic maps to ensure program accuracy.



### PSD Screening Results:

The PSD regulations establish specific maximum allowable increases in ambient concentrations (or increments) for PM 10 , NO X , and SO 2 for all areas in compliance with the NAAQS. All areas of the

cou ntry are categorized as a function of overall use. The regulations were designed to prevent significant air quality deterioration by specifying allowable incremental changes in PM 10 , NO X , and SO 2 concentrations within each area category. The area categor ies are defined below:

Class I

– Those areas where almost any deterioration of current air quality is undesirable, and little or no industrial development would be allowed (e.g., national parks, wilderness areas).

Class II

– Those areas where moderate, w ell

- controlled energy or industrial growth is desired without air quality deterioration up to the national standards (all attainment areas not categorized as Class I were initially designated Class II).

Class III

– Those areas where substantial energy or industrial development is intended, and where modest increases in ambient concentrations above Class II increments, but below national standards, would be allowed (designation to Class III must follow strict redesignation procedures).

The Richmond County area and all other attainment areas in Georgia not designated as Class I areas are Class II areas. No Class I areas are located within 230 km of the PCS Nitrogen site. The first step in the air quality analysis was to determine whether the incremental am bient impacts due to the new emissions from the project were greater than U.S. EPA

- prescribed Modeling Significance Levels. The “significance analysis” determined whether PCS Nitrogen could forgo a full

- scale impact analysis to demonstrate compliance with

the NAAQS and PSD Class II Increments for the C

- 002 Nitric Acid Plant.

The results of the significance analysis for the modified C

- 002 Nitric Acid Plant are summarized in Tables 10 and 11. The impacts due to the total projected emissions of NO X and CO w

ere calculated in this analysis using the ISCST3 dispersion model.PSD Preliminary Determination Page 

### 15

Table 10 shows the modeled concentration increases for CO from the C

- 002 Nitric Acid Plant following the proposed modifications are below the Significant Impact Level. The PCS Nitrogen p roject can reasonably be assumed to have an insignificant impact on the air quality surrounding the plant, and per U.S. EPA modeling procedures, no NAAQS or PSD Class II increment analyses are required for CO

emissions.

Table 10: Results of CO Modeling Si gnificance Analysis

Pollutant Averaging

Period PSD Significant

Impact Level (μg/m 3 ) Significant Monitoring

Concentration (μg/m 3 ) Modeled

Concentration (μg/m 3 ) Notes

CO 1

- Hour 2,000 575 421 No Additional Modeling Needed

CO 8

- Hour 500 575 192 No Additional Modeling Needed

As shown in Table 11, modeled concentration increases for NO X from the C

- 002 Nitric Acid Plant following the proposed modifications are above the Significant Impact Level. Additional NAAQS and PSD Class II increment analyses are therefo re required for NO X . Contributing nearby sources must be

included in the model.

Table 11: Results of NO X Modeling Significance Analysis

Pollutant Averaging

Period PSD Significant

Impact Level (μg/m 3 ) Significant Monitoring

Concentration (μg/m 3 ) Modeled

C oncentration (μg/m 3 ) Notes

NO X Annual 1 14 1.42 Additional Modeling

Needed



### Refined NO X 

### Analysis:

The refined modeling analysis determines compliance with the PSD increment standard and the National Ambient Air Quality Standards (NAAQS). In PSD increme nt modeling, ambient air quality within a predetermined Significant Impact Area (SIA) is evaluated through modeling to determine whether or not the total emissions from all sources, both onsite and offsite (within a 50

- km radius extending outward

from the SIA), could cause an exceedance of the allowable NO X PSD Increment. The PSD Increment is the allowable incremental increase of ground

- level concentration of a pollutant over the baseline level.

The baseline for NO X

emissions is the NO X

emission level mod eled for this area using September 1988

data.

The NAAQS Model also utilizes all off

- site sources as well as PCS Nitrogen sources. Again, ambient air quality within the SIA is also evaluated to determine if an exceedance of the NAAQS standard occurs.

The NAAQS standard is the maximum concentration of a pollutant allowed at ground level.

The first step in the analysis was to determine the project’s maximum Area of Impact (AOI) for NO X emissions. The AOI’s critical distance is defined as the greatest dist ance from the facility at which the

increase in NO X

emissions from the screen model exceeds the significant impact level (1 μ g/m 3 for NO X ).

The AOI is defined as the entire area within a radius of the AOI’s critical distance. This evaluation was completed

for all five years of NO X

screen models and is summarized in Table 5

- 4 of the permit application. This analysis determined that the farthest point which exceeds the significant impact level is 4.35 km from the plant site and occurred during the 1977 mode led year. Figure 5

- 3 of the permit application provides a plot of the results of the 1977 screen model, which identifies the level of 1 μ g/m 3

NO X concentration and the AOI. Per EPA guidance, all sources located within 50 km of the AOI (54.35 km) were inc luded in the modeling analysis.PSD Preliminary Determination Page 

### 16

The AOI includes sources in both Georgia and South Carolina. A request was therefore made for both Georgia (EPD) and South Carolina (Department of Health and Environmental Control

– DHEC) to provide data for NO X

emission sources within the project’s area of impact. DHEC provided a current emission inventory for all counties located within the project’s area of impact. The inventory identified

NO X emission rates, stack locations and parameters, as well as the status of ea ch source as a baseline source, increment consumer, or increment expander. None of the South Carolina sources were identified as increment consumers, therefore the South Carolina off

- site sources were only included in the NAAQS

model.

The impact of these off

- site sources on the air quality models is largely determined by the emission rates and the distance between the emission source and the PCS Nitrogen plant. The EPA “20D Rule: screening technique was utilized to reduce the large number of sources iden tified by the EPD and DHEC to those which could potentially impact the project. The “20D Rule” allows for the elimination of any sources for which emissions (tpy) are less than 20 times the distance (km) from the sources to the PCS
site.

The 20D rule was

only applied to sources for NAAQS modeling. All sources identified as increment consumers or expanders were included in the PSD increment analysis. Table 5

- 5 and 5

- 6 of the permit application provide a list of all plants identified by the EPD and DHEC, respectively, which are within the projects area of impact and are sources of NO X . The tables identify the total emissions of NO X from each site and the distance from the site to the PCS Nitrogen plant. The final column identifies those sites that

were s creened out using the 20D rule. Table 5

- 7 of the permit application identifies all off site emission points in South Carolina and Georgia that were not screened out and are therefore included in the NAAQS modeling analysis.

The EPD provided data for NAAQ S sources from an EPA database. The data was validated by reviewing Title V permit applications and air quality files of the sources located within the area of impact. For the PSD increment modeling, the EPD maintains an up to date spreadsheet which iden tifies all NO X increment consumers and expanders in the area as well as all data required for modeling. The most recent version (August 2002) was used in this analysis. The sources identified in this spreadsheet which are within the projects area of impa ct were included in the PSD increment model. Table 5

- 8 provides the

emissions data for the off

- site PSD increment consuming sources which are included in the modeling analysis.

There are several on

- site operations which are sources of NO X emissions other

than the C

- 002 Nitric Acid

Plant. These sources include the C

- 001 Nitric Acid Plant, the Ammonia Plant, and three boilers (AB01, AB02, and AB03). Table 5

- 9 of the permit application summarizes the status of each of these sources as baseline, PSD increme nt consumers, and PSD increment expanders.

The BPIP model was also updated to include any downwash impacts site buildings would have on these

additional on site sources. This additional BPIP model run is included in both the PSD increment and NAAQS NO X

m odels.



### NO X 

### Class II PSD Increment Modeling:

As shown in Table 12, modeled impacts of NO X are below the PSD increment. Given this, the proposed modifications will comply with the PSD Class II increment. The nearest Class I area is located 230 km away fr om the facility, therefore the impacts from the proposed project were not evaluated for the Class I
PSD increment.

Table 12: Results of Class II PSD Increment Impact for NO X

Pollutant Averaging

Period PSD Increment

(μg/m 3 ) Modeled Conc.

(μg/m 3 ) Notes

NO X Annual 25 18.4 All significant sources within 54.35 kmPSD Preliminary Determination Page 

### 17

NAAQS NO X 

### Modeling:

The NAAQS are established as ambient ceilings applicable to the entire country, and they must be attained and maintained. PSD requires that any pollutant that has predicted sign ificant impacts due to the modification alone must be evaluated for NAAQS compliance. Table 5 shows that NO X impacts must be evaluated further. The ISCST3 model was run including all “significant sources” (as defined using the 20

- D Rule) within 54.35 km o f the plant. The background concentration for NO X is 26 ug/m 3 (annual). This concentration has been added to the modeled concentration to determine total impact. Table 13 below includes the modeled concentration (including the background concentration) in comparison to the NAAQS. As can be seen from the table, the modeled impact is below the associated NAAQS limit.

Table 13: Results of Ambient Air Quality Impact for NO X

Pollutant Averaging

Period NAAQS

(μg/m 3 ) Modeled Conc.

(μg/m 3 ) Additional Notes

NO X Annual 100 77.1 All significant sources within 54.35 km



### Complex Terrain Analysis:

Complex terrain (areas where the terrain is higher than the lowest stack height) has been identified in the areas surrounding the PCS Nitrogen plant. To determine if co mplex

- terrain modeling is necessary for these areas, a comparison between the results of the NO X screen modeling analysis in the default mode and the simple

- terrain mode was performed for the 26 receptors which are above the height of the lowest

stack and exceeded the NO X significant impact level. This comparison was performed in order to determine whether predicted impacts in intermediate terrain areas are controlled by complex terrain algorithms or simple terrain algorithms per the EPA guidance on comple x terrain modeling

– “Complex Terrain Modeling Procedures”

– May 19, 1999.

The results at each receptor for the default mode and the simple

- terrain mode were compared. Exhibit D provides the results of this analysis for all 5 years of model runs. At eac h receptor, the difference between the “simple” result and the “default” result was calculated. In all cases were the default value exceeds the significant impact level, the difference between the “default” and “simple” case was less than the correspondin g significance level for NO X (1 μg/m 3 ) . This indicates that either the simple

- terrain algorithm is controlling the analysis or that the complex

- terrain modeling algorithm demonstrates insignificant impacts at these locations. Based on this information, n o further complex terrain modeling is necessary.



### Georgia Toxics Analysis:

The C

- 002 AN Neutralizer scrubber is a potential source of both nitric acid and ammonia emissions that are considered toxic pollutants under Georgia state toxics policy. The ammon ium nitrate neutralizer is not being modified as part of this project, but its emissions will increase due to greater throughput. In order to assess the air toxics impact on the environment, emissions from the entire plant were included in a modeling anal

ysis. The results of these calculations are included in Exhibit A of the report.

Compliance with the toxic program was determined using the “Guideline for Ambient Impact Assessment

of Toxic Air Pollutant Emissions”

– June 21, 1998. The first step was to determine the Ambient Air Concentration (AAC) for each of the compounds. Priority is given to inhalation reference concentrations (RfC) and Risked Based Air Concentrations (RBAC) which are identified in the EPA IRS database. The listed RfC for Ammonia ( 0.1 mg/m 3 ) was used for the ammonia analysis. Ammonia also has a Short Term Exposure level (STEL) of 27 mg/m 3 , which was also evaluated. Nitric acid was not identified in the IRIS database; therefore, its AAC was based on its Occupational Safety and Heal th Administration (OSHA) Time Weighted Average (TWA) of 5 mg/m 3 and a STEL of 10 mg/m 3

.PSD Preliminary Determination Page 

### 18

The nitric acid TWA was corrected for exposure levels (assuming a continuous operation of 168 hr/wk). Per EPD guidance neither of the STELs was adjusted for exposure levels. Next, a safety factor was applied depending on the classification of the pollutant as a carcinogen (100 for non

- carcinogen, 300 for carcinogens). Per EPD guidance a safety factor of 10 was applied to the STELs. Nitric Acid is not

considered a ca rcinogen so a safety factor of 100 was applied to the TWA. Table 14 summarizes the AAC for each compound. RfC values taken from the IRIS database required no adjustment.

Table 14: AACs for Ammonia and Nitric Acid

Compound Toxicity

Data Adjustment for

E xposure Safety Factor

Adjustment AAC Basis

Ammonia

– RfC 0.1 mg/m 3 None None 100 μ g/m 3 EPA IRIS Database

Ammonia

– STEL 27 mg/m 3 None 2,700 μ g/m 3 2,700 μ g/m 3 EPA IRIS Database

Nitric Acid

– TWA 5 mg/m 3 1.3 mg/m 3 12 μ g/m 3 12 μ g/m 3 OSHA TWA

Nitric Acid

– STEL 10 mg/m 3 None 1,000 μ g/m 3 1,000 μ g/m 3 OSHA STEL

Next, The EPA Screen 3 model was run for the source with the shortest stack (C

- 002 Nitric Acid Plant). A copy of the model results is included in Exhibit E of the permit application. The results for this model indicate that at a 1 g/s emission rate the model would result in a worst

- case 1

- hour concentration of 3.3

μ g/m 3 . The concentration of ammonia and nitric acid were next determined by multiplying this value

times the actual emission rate of the specific pollutant in grams/second (55.82 g/s and 1.87 g/s respectively) from the entire plant. This analysis demonstrates the worst possible results by modeling all emission as coming from the worst

- case stack. This result, which is a 1

- hour average, wa s next converted to an annual, 24

- hour, and 15

- minute standard for comparison to the various AACs which were calculated using the correction factors (0.08, 0.4, and 1.32 respectively). Table 15 summarizes the results of this analysis. As shown, all compo unds are below their corresponding AACs; therefore compliance with the Georgia toxics programs is confirmed.

Table 15: Maximum Ground Level Concentration Comparison to AACs

Compound MGLC

- 1 Hour

Average ( μ g/m3) MGLC for Averaging Period ( μ g/m3) AAC ( μ g/ m3) Percentage of

Allowable Compliance

Ammonia

–RfC 184.1 14.7 100 14.7% Yes

Ammonia

–STEL 184.1 243.0 2,700 9.0% Yes

Nitric Acid

–TWA 6.2 2.5 12 20.8% Yes

Nitric Acid

–STEL 6.2 8.1 1,000 8.1% Yes



### Class I Areas:

A review was completed to determi ne the proximity of Class I areas to the site in order to determine if any evaluation of the project’s impact on a Class I area is required. The five closest Class 1 areas are the Shining Rock Wilderness, Cape Romain Wilderness, Smokey Mountains National Park, Joyce Kilmer

– Slickrock Wilderness, and the Cohutta Wilderness. Table 16 summarizes the distance between PCS Nitrogen and the Class I areas.

Table 16: Distance between PCS Nitrogen and the Class I Areas

Area Distance (km) Shining Rock Wilderness , NC 230 Cape Romain Wilderness, SC 255 Smokey Mountains National Park, NC 261 Joyce Kilmer

– Slickrock Wilderness, NC 283
Cohutta Wilderness, GA 349
Okefenokee Wilderness, GA 384
Wolf Island Wilderness, GA 402PSD Preliminary Determination Page 

### 19

All Class I areas are beyond 200 km from PCS Nitrogen, therefore no Class I evaluation was completed. Also, the Division notified representatives of the National Park Service and Fish and Wildlife Services of the emissions associated with the PCS Nitrogen application. No additional inform ation was requested from the Division by either service.



### Class II Visibility Analysis:

Emissions from certain sources can create visible, defined plumes that are noticeable to the casual observer. Therefore, an exhaust plume visibility analysis was perf ormed for this project to assure that the emission from the project to not create a noticeably visible plume in a local Class II area of interest, the Augusta Regional Airport. No visibility analyses were required for Class I areas.

The primary variables that effect whether a plume is visible or not at a certain location are (1) quantity of emissions, (2) type of emissions, (3) relative location of source and observer, and (4) background visibility range. For this exhaust plume visibility analysis, an an alysis was performed using the latest version of the EPA VISCREEN model according to the guidelines published in the Workbook for Plume Visual Impact Screening and Analysis

.

The default particulate size and density from the VISCREEN model were used for th e analysis. In order to determine the appropriate wind speed and stability class, an evaluation of meteorological data for the Augusta weather station located at the Augusta Regional Airport was completed. The meteorological information included the freq uency distribution of various dispersion conditions (wind speed and stability) for a 5

- year set of data (1974

– 1978). The PCS Nitrogen site is located north

- northeast of the airport, therefore the data was evaluated fro the frequency of wind coming only from that direction.

Table 17 below shows the results from the frequency distribution evaluation for the Augusta area weather data. The table lists each of the evaluated dispersion conditions, which are ranked in order of decreasing severity. EPA proced

ures (as outlined in the VISCREEN guide) for defining worst case meteorology for Level 1 VISCREEN modeling indicates that the modeled dispersion condition is selected such that the sum of all frequencies of occurrence of conditions worse than this conditio n totals 1 percent (i.e., about four days per year).

Table 17: Wind Speed and Stability Class Frequency Distribution from NNE Direction

Dispersion Condition (Class, Wind Speed) Number of 1

- Hour Occurrences

in 5 Years of Data Frequency Cumulative Frequenc y F, 1 74 0.00169 0.00169
E, 1 27 0.00062 0.00230
D, 1 26 0.00059 0.00290
F, 2 145 0.00331 0.00621
E, 2 91 0.00208 0.00828
D, 2 123 0.00281 0.01109
F, 3 77 0.00176 0.01285
E, 3 85 0.00194 0.01479
F, 4 3 0.00007 0.01485

The frequency data indicat es that the 1% cumulative frequency is not reached until the D, 2 dispersion condition is reached in the NNE direction. Therefore, the VISCREEN model was run at a wind speed of 2 m/s and a stability category of 4, or D. In addition, the PM 10 and NO X emis sion increases associated with the expansion project were used as input to the model. As directed in the VISCREEN Workbook, a background visual range of 25 km was used for the Augusta area.PSD Preliminary Determination Page 

### 20

For both views inside and outside the Class II area, calculatio ns are performed by the model for the two assumed plume

- viewing backgrounds. The VISCREEN model output shows separate tables for inside and outside the Class II area. Each table contains several variables: theta, azi, distance, alpha, critical and

actual plume delta E, and critical and actual plume contrast. These variables are defined as:

1. Theta

– Scattering angle (the angle between direction solar radiation and the line of sight). If the observer is looking directly at the sun, theta equals zero de grees. If the observer is looking away from the sun, theta equals 180 degrees.

2. Azi

– The azimuthal angle between the line connecting the observer and the line of sight.

3. Alpha

– The vertical angle between the line of sight and the plume centerline.

4. Delta E

– Used to characterize the perceptibility of a plume on the basis of the color difference between the plume and a viewing background. A delta E of less than 2.0 signifies that the plume is not perceptible.

5. Contrast

– The contrast at a give n wavelength of two colored objects such as plume/sky or plume/terrain.

The analysis is generally considered satisfactory of delta E and contrast are less than critical values of 2.0 and 0.05 respectively, both of which are Class I, not Class II, area thr esholds.

The Division has reviewed the VISCREEN results presented in the supplement to the permit application dated January 5, 2004 and has determined that the visual impact criteria (delta E and contrast) inside the Augusta Regional Airport are not excee ded for the proposed project. Since the project passes the Level 1 analysis for a Class I area for the Class II area of interest, no further analysis of exhaust plume visibility is required as part of this air analysis.



### Preconstruction Monitoring:

The P SD regulations require that continuous preconstruction monitoring of regulated pollutants emitted in significant amounts be conducted to establish existing air quality concentrations in the vicinity of the proposed source or modification. However, no prec onstruction monitoring data are required if the ambient air quality of the project impact from the source is below a certain de minimis concentration.

In performing this analysis, the maximum impacts for both scenarios are determined to be less than the

c orresponding de minimis concentrations of as shown in Tables 10 and 11. No ambient monitoring study will be required by the Division based on this data.



### 7.0 ADDITIONAL IMPACT ANALYSES

PSD requires an analysis of impairment to visibility, soils, and vege tation that will occur as a result of a modification to the facility and an analysis of the air quality impact projected for the area as a result of the general commercial, residential, and other growth associated with the proposed project.



### Visibility:

V isibility impairment is any perceptible change in visibility (visual range, contrast, atmospheric color, etc.) from that which would have existed under natural conditions. Poor visibility is caused when fine solid or liquid particles, usually in the form of volatile organics, nitrogen oxides, or sulfur oxides, absorb or scatter light. This light scattering or absorption actually reduces the amount of light received from viewed objects and scatters ambient light in the line of sight. This scattered ambien t light appears as

haze.PSD Preliminary Determination Page 

### 21

Another form of visibility impairment in the form of plume blight occurs when particles and light

absorbing gases are confined to a single elevated haze layer or coherent plume. Plume blight, a white, gray, or brown plume clearly visible against a background sky or other dark object, usually can be traced to a single source such as a smoke stack.

PCS Nitrogen presented a visibility impact analyses for the expansion project discussed in this preliminary determination. The results of these analyses showed that the proposed project should have no perceptible impact on visibility within the Class II area of interest, the Augusta Regional Airport.



### Soils and Vegetation:

Since ground level concentration of NO X and CO are not expected t o increase by a significant degree as a result of this project, the impacts on soil and vegetation are predicted to be insignificant. There are currently no known adverse impacts on local environment from PCS Nitrogen’s emissions and no discernible change s are expected to results from the proposed modifications to PCS Nitrogen’s operations.



### Growth:

An increase in employment at PCS is not expected as a result of any proposed changes; therefore, there will be no permanent impact on the surround community w ith regard to demographics. All the plant modifications will occur on existing operations; therefore no grading will be required. The construction phase (being a small modification of an existing process) will not adversely impact air quality in the area

.



### 8.0 EXPLANATION OF DRAFT PERMIT CONDITIONS

The permit requirements for this proposed facility are included in draft Permit Amendment No. 2631

- 193

- 0013

- V

- 01

- 4.

Section 1.0 Facility Description

The facility description section describes the modificatio n to the C

- 002 Nitric Acid Plant.

Section 3.0 Requirements for Emission Units

Condition 3.3.5 limits the emission of nitrogen oxides from the C

- 002 Nitric Acid Plant to 3.0 pounds per ton 100% nitric acid and limits opacity from the source to less than 1 0%. The citation for the condition has been updated to include reference to 40 CFR 52.21. The citation is necessary to reflect the results of the PSD BACT review for nitrogen oxide emissions from the C

- 002 Nitric Acid Plant.

Condition 3.3.10 has been ad ded to the permit. The condition limits annual (12 consecutive month periods) nitrogen oxide emissions to 507 tons per year. This limit is a result of the PSD BACT analysis and represents an annual average of 2.14 pounds NO X per ton 100% nitric acid.

Co ndition 3.3.11 has been added to the permit. The condition limits the emission of carbon monoxide
from the C

- 002 Nitric Acid Plant to an average of 30.0 pound CO per ton 100% nitric acid on a 12 month rolling basis. This limit is the result of the PSD re view.PSD Preliminary Determination Page 

### 22

Section 4.0 Requirements for Testing

Condition 4.2.2 has been modified to increase the frequency of nitrogen oxide testing for the C

- 002 Nitric Acid Plant and to require carbon monoxide testing for the C

- 002 Nitric Acid Plant. Annual performance tests for carbon monoxide have also been added to the condition. The tests are to be conducted annually due to the variability in carbon monoxide emissions as the effectiveness of the catalyst in the nitrogen

oxide reduction device is lessened over time.

Condition 4.2.8 has been modified. The condition now requires the facility to calculate a conversion factor for converting carbon monoxide readings in ppm to pounds per ton 100% nitric acid in addition to calculating a conversion factor for nitrogen oxid e tests.

Condition 4.2.11 has been added to the permit. The condition requires the facility to conduct performance testing for NO X and CO upon completion of the modifications to the C

- 002 Nitric Acid Plant. The tests are necessary to establish the new c onversion factors.

Condition 4.2.12 has been added to the permit. The condition requires the facility to conduct a performance test for particulate matter on the C

- 002 AN Neutralizer following the completion of the C

002 Nitric Acid Plant modifications. This test is required because the expansion of the C

- 002 Nitric Acid Plant will allow additional nitric acid to be sent to the neutralizer. The condition allows the facility to modify the excursion parameters for the C

- 002 AN Neutralizer scrubber if nece ssary.

Section 5.0 Requirements for Monitoring

Condition 5.2.1.b has been added to the permit. The condition requires the facility to install, calibrate, maintain, and operate a carbon monoxide CEMS for the C

- 002 Nitric Acid Plant. The data recorded, in addition to the conversion factor determined in accordance with Condition 4.2.8, will be used to determine compliance with the PSD limit in Condition 3.3.11 of the permit.

Condition 5.2.2.e has been added to the permit. The paragraph requires the faci lity to continuously monitor nitric acid production rate. This information is necessary to calculate the NO X and CO

emissions.

Conditions 5.2.5 and 5.2.6 have been added the to permit. The conditions describe the CAM requirements for the C

- 002 Nitric Ac id Plant.

Section 6.0 Other Recordkeeping and Reporting Requirements

Condition 6.1.7.a(3) has been added to the permit. The condition defines as an excess emission any 12 consecutive month period during which the nitrogen oxides emission from the C

- 002 Nitric Acid Plant

exceeds 507 tons.

Condition 6.1.7.a(4) has been added to the permit. The condition defines as an excess emission any 12 consecutive month period during which average carbon monoxide emissions from the C

- 002 Nitric Acid

Plant exceeds 3 0.0 pounds CO per ton 100% nitric acid.

Condition 6.2.15 has been added the permit. The condition requires the Permittee to calculate and keep on record the monthly and 12

- month rolling totals for the emission of NO X from the C

- 002 Nitric Acid

Plant. Th ese records are necessary to determine compliance with the PSD limits found in Condition

3.3.10.PSD Preliminary Determination Page 

### 23

Condition 6.2.16 has been added the permit. The condition requires the Permittee to calculate and keep on record the average CO emissions (pounds per ton 10 0% nitric acid). The records should also include
the 12

- month rolling average. These records are necessary to determine compliance with the PSD limits

found in Condition 3.3.11.

Condition 6.2.17 has been added to the permit. The condition requires the Permittee to commence construction of the proposed modifications within 18 months of the effective date of the permit amendment. This is a requirement of PSD.

Section 8.0 General Provisions

Conditions 5.1.1., 7.1.1, 7.2.1, 7.10.1, 8.2.1, 8.5.1, 8.5.3, 8 .8.3, 8.10.1, 8.11, 8.14, 8.17.1, 8.20.1, and 8.22 have been modified. The conditions have been updated to reflect changes to the permit template.

Conditions 8.23, 8.24, 8.25, and 8.26 have been added to the permit. The conditions are now included in

al l Title V permits and have been included in this permit to bring the template conditions up to date.PSD Preliminary Determination

APPENDIX A

Draft Revised Title V Operating Permit PCS Nitrogen Fertilizer

– Augusta Plant

Augusta (Richmond County), GeorgiaPSD Preliminary Determination

APPENDIX B

PCS Nitrogen F

ertilizer

– Augusta Plant PSD Permit Application and Supporting Data

Contents Include:

1. PSD Permit Application No. 14213, December 30, 2002

2. Visibility Analysis for PSD Permit Application No. 14213, January 5, 2004PSD Preliminary Determination

APPENDIX C

EPD’S PSD Dispersion Modeli ng and Air Toxics Assessment Review