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 Clean Air Act (CAA) 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 Sierra 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]
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Options for NSPS review

The purpose of an NSPS review is to determine if the standards 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 requirements) 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 emission limits for additional pollutants (i.e., N2O)

EPA will collect and validate data to determine what changes to the NSPS may be needed. In 

discussions with industry, most of the NOX data collected by industry has been analyzed using 

Method 7E, “Determination of Nitrogen Oxides Emissions from Stationary Sources 

(Instrumental Analyzer Procedure).”

Multi-Pollutant Approach

As part of Nitric Acid NSPS Review, RTI was tasked with providing technical support for an 

integrated multi-pollutant approach for the inorganic chemical manufacturing sector. 

The work assignment specified that RTI would 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 would 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 energy efficiency levels in a postcontrol 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 assignment, EPA decided that the main objective 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 work on other 

inorganic industries was limited to a “scoping exercise” to determine and summarize emissions 

points and pollutants emitted (including HAP and GHG) and current regulations. 
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Scoping Exercise for Other Inorganic Chemical Industries

The scoping exercise identified six inorganic chemical industries. These chemicals are 

ammonium sulfate, sulfuric acid, lime, cyanide chemicals, hydrochloric acid, and phosphoric 

acid. Five of the six are already being controlled 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.
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Table 1. Scoping Exercise Results for Inorganic 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 (SO2), 

acid mist, opacity

Method 8 and 

Method 9

SO2 continuous 

monitoring system 

(CMS)

Lime part 60, subpart 

HH

rotary lime kiln particulate 

concentration and 

opacity

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 

NNNNN

storage tanks, transfer 

operations, process vents, 

equipment leaks, and 

wastewater operations

HAP Method 26A

Phosphoric 

acid

Phosphate Rock 

sector project in 

progress