Date: November 12 , 2009

Subject: Summary of Other Inorganic Pollutants and Source Categories

Nitric Acid NSPS Review EPA Contract No. EP

- D

- 06

- 118; Work Assignment No. 3

- 22 RTI Project No. 0210426.003.022

From: Melissa Icenhour

To: Bill Neuffer

OAQPS/SPPD/MMG (D243

- 02) U. S. Environmental Protection Agency Research Triangle Park, NC 27711

Introduction

The EPA is required by section 111(b)(1)(B) of the C lean Air Act (C AA ) to review and, if appropriate, revise existing New Source Performance Standards (NSPS) at least every 8 years.

The nitric acid NSPS (part 60, subpart G) has been reviewed in the past but the last review was more than 8 years ago. As a result of this, EPA has received a citizen suit from Sier ra Club and Environmental Integrity Project prompting review of the standards before the end of the year 2010.

NSPS (40 CFR part 60) Promulgation date Previous review dates Nitric Acid (subpart G) December 23, 1971 (36 FR 24876) Reviews dated June 19, 1979; April 5, 1984. No changes. Minor testing/ monitoring changes made

- October 6, 1975 [40 FR 46258], April 22, 1985 [50 FR 15894], and February 14, 1989 [40 FR 6666]2

Options for NSPS review

The purpose of an NSPS review is to determine if the stand ards reflect the “degree of emissions limitation achievable through application of the best system of emission reduction which (taking into account the cost of achieving such reduction and any nonair quality health and environmental impact and energy requi rements) the Administrator determines has been adequately demonstrated.”

Potential outcomes of the review process include one or more of the following:

- No changes

- Clarifying amendments

- Changes to emissions limits or other rule requirements

- Add emi ssion limits for additional pollutants (i.e., N 2 O)

EPA w ill collect and validate data to determine what changes to the NSPS may be needed. In discussions with industry, most of the NO X data collected by industry has been analyzed using Method 7E, “ Determ ination of Nitrogen Oxides Emissions f rom Stationary Sources (Instrumental Analyzer Procedure) .”

Multi

- Pollutant Approach

A s part of Nitric Acid NSPS R eview, RTI was tasked with providing technical support for an integrated multi

- pollutant approach for t he inorganic chemical manufacturing sector.

The work assignment specified that RTI w ould review recent emission characterization studies
and will identify any data gaps or uncertainties that would affect projected air emissions for all inorganic chemical industries

. Also, RTI would review existing available information and consult with experts in relevant industries and trade associations in order to provide recommendations on the scope of this sector study. RTI w ould also review all existing US EPA
air regulations for these industries and if needed, review additional information collected by EPA for these air regulations. This information may include data on relevant pollution measurement technologies, pollution control technologies, production and ene rgy efficiency levels in a post

control environment, and control costs (capital and annual operating and maintenance) by pollutant for criteria air pollutants, hazardous air pollutants (HAP) and greenhouse gases ( GHG )

.
At the beginning of the work assign ment, EPA decided that th e main ob jective of the work assignment would be to review the Nitric Acid NSPS for potential updates , including emission standards, monitoring provisions, and any other areas of concern. Thus, the w ork on other inorganic industri es was limited to a “scoping exercise” to determine and summarize emissions points and pollutants emitted (including HAP and GHG) and current regulations.3

Scoping Exercise for Other Inorganic Chemical Industries

The scoping exercise identified six ino rganic chemical industrie s . These chemicals are ammonium sulfate, sulfuric acid, lime, cyanide chemicals, hydrochloric acid, and phosphoric acid. Five of the six are already being contr olled through other rulemakings. The sixth, phosphoric acid, will be regulated through the sector project for phosphate rock products that is currently in progress. Table 1 identifies the chemicals, subparts, emission points, pollutants, and testing already required for these five inorganic chemicals.4

Table 1. Scoping E xercise Results for Inor ganic Chemical Industries

Inorganic
Chemical Associated

Subpart Emission Points Pollutants Test Methods Other Requirements

Ammonium sulfate part 60, subpart

PP ammonium sulfate dryers particulate concentration and opacity Method 5 and

Method 9

Sulfuric acid part 60, subpart H sulfuric acid production unit sulfur dioxide (SO 2 ), acid mist, opacity Method 8 and

Method 9 SO 2 continuous

monitoring system (CMS)

Lime part 60, subpart

HH rotary lime kiln particulate concentration and

op acity Method 5,

Method 5D, Method 9
Cyanide chemicals part 63, subpart

YY storage vessels, process vents,

transfer racks, equipment leaks

, and wastewater streams hydrogen cyanide, total HAP, sodium cyanide Method 18

Hydrochloric acid part 63, subpart

N NNNN storage tanks, transfer

operations, process vents, equipment leaks, and wastewater operations HAP Method 26A

Phosphoric acid Phosphate Rock

sector project in

progress