Enclosure 5a

Page 1 of 11

EPA Information Collection Request for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name Dyno Nobel- St. Helens Plant

Facility owner (ultimate parent owner) Incitec Pivot Ltd. 

Plant Location - Address 63149 Columbia River Hwy 

Latitude/Longitude for Plant Latitude: 45.911389 Longitude: -122.824444

Describe location of latitude/longitude Administration Building 

City, State, ZIP code Deer Island, OR 97054

Year plant began operation 1966

Information for Each Nitric Acid Production Line

(change names as needed and use the same names in the Excel spreadsheet)

Line 1 Line 2 Line 3

Year line began operation 1968

Production Rate (Tons/Day of 

100% Acid) 40.6 

Production Rate Range (Tons/Day of 

100% Acid) 34.8-40.6

Subject to Subpart G? No 

Process Type (high/low pressure) Medium 

Oxidation pressure (psia) 120 psia 

Absorption pressure (psia) 120 psia 

% Acid strength Typically Produced 58% 

Operating Hours/Year Line 1 Line 2 Line 3

2008 8654

2007 8050

2006 8256

Control Technology 

(list as many as applicable)

NSCR

% Control Efficiency (based on most 

recent compliance test)

Line 1 Line 2 Line 3

NOX

There are no current 

Stack Testing Records 

NO

NO2
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Permit Limits for Each Nitric Acid Production Line

(Fill in all applicable rows)

Line 1 Line 2 Line 3

NOX Emissions (tpy) None 

NOX Emissions (lb/hr) None 

NOX Emissions (lb/ton of 100% 

acid) None 

Permitted NOX control efficiency, if 

applicable 200 ppm 

If your permit includes limits for 

other pollutants, please include as 

much detail as possible below:

Line 1 Line 2 Line 3
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters 

Extended Absorption (Nitric Acid Production Line Name)

Length NA 

Design Information

(gal/ 10 3acfm, etc)

Operation and Maintenance required

(Last 10 years)

Year absorption capacity was added

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen 

peroxide)

Concentration of additive (%):

Explain the process:

Addition rate (gallons per hour):

Ratio of additive to water:
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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SCR (Nitric Acid Production Line Name)

Type of Catalyst NA 

Is Catalyst New or Regenerated?

Catalyst Life (Design/Actual)

Catalyst Volume (m

3

)

Flow rate (scfm)

Ammonia injection rate (lb/hr)

Operation and Maintenance required

(Last 10 years)

Year began operation
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters

NSCR (Nitric Acid Production Line Name)

Reductant used (methane, H2, etc) Purge Gas from the Ammonia Plant 

(58% H2, 20% CH4, 18% N2, 3.6% Ar, 0.4% NH3)

Rate of reductant used 170 scfm

Type of catalyst Engelhard VOCAT 900H 

Catalyst Volume (m

3

) 0.076 m3

Flow rate (scfm) 4463 SCFM

Is Catalyst New or Regenerated? Catalyst was installed in June of 2006. It is not regenerative. 

Catalyst Life (Design/Actual) 8 years 

Operation and Maintenance required 

(Last 10 years) Catalyst was last installed in June of 2006. 

Year began operation 1968
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Cost Information by Control Technology

Production Line

Pollutant 

Controlled

Control 

Technology

Capital

(Yr of Cost basis)

Annual O & M

(Yr of cost basis)

Nitric Acid Plant NOx NSCR $1,560,000 $263,874

Please provide additional cost information, comments, or notes below:
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Continuous Emission Monitoring Systems

CEMS Information

Plant CEMS data recorded 

concurrent with test runs (i.e., 

concentration, etc.). NA 

CEMS Manufacturer Horiba Enda- 1120 NOx Analyzer 

CEMS Model Number CFA – 311A 

Description of sample extraction and 

conditioning or dew point 

maintenance systems

The sample is taken at a sample valve mounted on the Tail Gas Vent 

Stack downstream of the Tail Gas Combustor. The sample line is a 1⁄4”

stainless steel tube traced with a 1⁄4” steam heated line. The analyzer 

system contains a sample handling system and an analyzer unit packaged 

in a 19” rack mountable case. The entire system is enclosed in a steel 

cabinet for outdoor installation. When the sample gas enters the analyzer 

system, the temperature must be lower than 104 degrees F and not 

saturated with moisture. The gas passes through a sample handling 

system consisting of a mist catcher, a particulate filter, flow selector 

valves, a pump, a dehumidifier, and a pressure relief water trap before it 

is led into the analyzer unit. 

Ability to distinguish between NO 

and NO2?

The system converts all NO2 to NO before the gas stream passes through 

the IR detector. 

Identify all periods of startup, 

shutdown, and malfunction, 

regardless of whether the event 

caused an exceedence (during the 

past 3 years) See Attached

Capital costs $15,000

Operation and Maintenance costs $2,000

Cost of quarterly audits

Because we are not regulated under a Title V Air Permit we are not 

required to perform quarterly gas audits. 

Year began operation 1991

CEMS Data (Monthly and Annual)
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Include monthly and annual NOX CEMS data for the last 3 years. Please submit the CEMS 

data electronically.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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General Discussion

1. Please provide your thoughts on trends in nitric acid production as far as type of process that 

is used; types of absorber used, trends in selecting control devices, improvements in control 

efficiency in existing control devices, energy efficiency.

Since 1968 the basic design of a nitric acid plant has not changed tremendously. Newer 

facilities typically operate at higher pressures and make use of computerized distributed 

control systems. Most plants built today are much larger than our facility and produce Nitric 

Acid on a much larger scale. 

2. Please describe your thoughts on the air pollution controls that are used at your facility such 

as reliability, O&M costs including energy penalty, etc.

We are very satisfied with the NSCR technology we currently utilize. Because we use excess 

hydrogen from the Ammonia Plant purge gas, the atmosphere in the combustor is highly 

reductive. This highly reductive atmosphere allows for greater conversion efficiency and very 

low NOx emissions. 

3. Please provide recommendations on the revisions you would like to see in this NSPS.

I would not like to see any revisions made to the New Source Performance Standards. 
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NOX or NH3 expected during a startup, 

shutdown, and malfunction event. 

The maximum theoretical yield for NOx is 3000 ppmv.

2. Please describe how long excess/elevated emissions NOX or NH3 will typically occur during 

a startup, shutdown, and malfunction event. 

During start-up and shut-down most of the elevated emissions occur in the first 30 minutes.

There may be additional spiking when the expander generator comes online during start-up, 

but most of the emissions occur within the first 30 minutes. 

3. Please describe any equipment or work practices that are employed to minimize or eliminate 

the quantity or duration of excess/elevated emissions of NOX or NH3 during startup, 

shutdown, and malfunction events. 

Operators flood the absorber column with condensate to minimize NOx emissions during 

start-up and shut-down. If malfunctions occur during normal operations they are usually due to 

changes in the gauze temperature, changes in the oxygen ratio, changes in the source of the 

 purge gas, or problems with the system pressure.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Emission Testing

1. Include emissions testing conducted during the last five years. Include tests for NOX, and 

NH3. Read and follow the guidance below.

2. Test method data of interest include those performed according to EPA Methods 7, 7A, 7B, 

7C, 7D, or Method 320.

3. Method 7E (for NOX) data can be submitted, but only if the testing was performed with the 

following modifications for nitric acid plants. Because of the propensity of NO2 to be 

absorbed by water, the sampled gas must not contact any condensate, and the efficiency of 

any NO2 to NO converter (if needed by the detection principle of the instrument) must be 

determined and documented as described in the method. For wet basis measurement systems, 

the tester must measure and report temperature data to show that the sample line and all 

sample transport components up to the inlet of the analyzer (and, for hot-wet extractive 

systems, also the analyzer) were maintained above the stack gas dew point. Use of a dilution 

probe to reduce the dew point is an acceptable procedure, if documented. Section 8 of 

Method 7E describes the measurement system performance tests and documentation required 

by the method, both prior to and following sampling. NO2 calibration gas must be substituted 

for NO calibration gas in the performance of system bias checks. The alternative mentioned 

in Section 8.6 to follow the dynamic spike procedure in Section 16.1 is acceptable, but only 

with NO2 spike gas. The dynamic spiking procedure is strongly recommended.

4. If you do not have emission test data for NOX using a method in note 2 or using Method 7E 

according to the modified protocol in note 3, you must conduct a stack test to determine 

NOX emissions following one of the approved methods above.

5. If you do not have emission test data for NH3, you must conduct a stack test to determine 

the emissions using the procedures of Method 320.

6. If a concentration is at or below the applicable method’s detection level, then provide 

information about the method (title and source), the calculated detection level in units of the 

applicable raw material or emissions concentration or mass rate, and the procedure for 

determining the detection level.

7. Additional stack testing guidance is contained in Enclosure 7.