### Enclosure 5a

Page 1 of 11 

## EPA Information Collection R equest for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name Dyno Nobel

- St. Helens Plant

Facility owner (ultimate parent owner) Incitec Pivot Ltd.

P lant 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

(c ha nge 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 T ype ( high/low pressure) Medium

Oxidation pressure (psia) 120 psia

Absorption pressure (psia) 120 psia

% Acid strength Typically Produced 58%

Operating Hour s /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

NO X There are no current Stack Testing Records

NO

NO 2

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

— Electronic Version

Page 2 of 11 Permit Limits for Each Nitric Acid Productio n Line

(F ill in all applicable rows)

Line 1 Line 2 Line 3

NO X Emissions ( tpy) None

NO X Emissions (lb/hr) None

NO X Emissions (lb/ton of 100% acid) None

Permitted NO X control efficiency, if applicable 200 ppm

If your permit includes limi ts 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

Page 3 of 11 

## For each control device, please provide the key design parameter s

Extended Absorption (Nitric Acid Production Line Name )

Length NA

Design Information
(gal/ 10 3 acfm, etc)

O peration and M aintenance required

(Last 10 years)

Y ea r 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

Page 4 of 11 SCR (Nitric Acid Production Line Name )

Type of Catalyst NA

Is Catalyst New or Regenerated?

Catalyst Life (Des ign/Actual)

Catalyst Volume ( m 3 )

Flow rate (scfm)

Ammonia i njection rate (lb/hr)

Operation and Maintenance required

(Last 10 years)

Y ea r began operation

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

— Electronic Version

Page 5 of 11 

## For each control device, please provide the key design parameters

NSCR (Nit ric Acid Production Line Name )

Reductant used (methane, H 2 , etc) Purge Gas from the Ammonia Plant

(58% H 2 , 20% CH 4 , 18% N 2 , 3.6% Ar, 0.4% NH 3 )

Rate of reductant used 170 scfm

Type of catalyst Engelhard VOCAT 900H

Catalyst Volume ( m 3 ) 0.076 m 3

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.

Y ea r began operation 1968

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

— Electronic Version

Page 6 of 11 

## Cost Information by Control Technology

Pro duction Line Pollutant

Controlled Control

Technology Capital

(Yr of Cost basis) Annual O & M

(Yr of cost basis)

Nitric Acid Plant NO

x NSCR $1,560,000 $2 63,874



### Please provide additional cost information, comments, or notes below:

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

— Electronic Version

Page 7 of 11 

## Continuous Emission Monitoring Systems

CEMS Information

Plant CEMS data recorded concurrent with test runs (i.e.,

conce ntration, 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 Ven t

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 syst em 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 mi st 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 NO 2 ? The system converts all NO 2 to NO before the gas stream passes through

the IR detector

.

I dentify all periods of startup,

s hutdown, 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

Page 8 of 11 

### Include m

onthly and a nnual NO X 

### CEMS data for the las t 3 years. Please submit the CEMS

data electronically

.

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

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Page 9 of 11 

## 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 , improvemen ts 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

contro l 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 e nergy 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 great er 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

Page 10 of 11 

## Startup, Shutdown, an d Malfunction

1. Please describe the maximum emission levels of NO X 

### or NH 3 

### expected during a startup,
shutdown, and malfunction event.

The maximum theoretical yield for NOx is 3000 ppm v.

2. Please describe how long excess/elevated emissions NO X 

### or NH 3 

### 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

- u p,

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 NO X 

### or NH 3 

### 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

Page 11 of 11 

## Emission Testing

1

. Include emissions testing conducted during the last five years. Include tests for NO X 

### , and

NH 3 

### . 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 NO X 

### ) data can be submitted, but only if the testing was performed with the following modifications for nitric acid plants. Becau se of the propensity of NO 2 

### to be absorbed by water, the sampled gas must not contact any condensate, and the efficiency of any NO 2 

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

determined and documented as described in t he 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 p rior to and following sampling. NO 2 

### 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 NO 2 

### spike gas. The dynamic spiking procedure is strongly recommended.

4

. If you do not have emission test data for NO X 

### 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

NO X 

### emissions following one of the approved methods above.

5

. If you do not have emission test data for NH 3 

### , 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 d etection 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

.