Enclosure 5a

Page 1 of 10

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

Plant Data

Facility name Coffeyville Resources Nitrogen Fertilizers, LLC

Facility owner (ultimate parent owner) CVR Energy, LLC

Plant Location - Address 701 East Martin Street

Latitude/Longitude for Plant 37.046472/-095.600750

Describe location of latitude/longitude Storage Tank

City, State, ZIP code Coffeyville, Kansas 67337

Year plant began operation 2000

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 2000

Production Rate (Tons/Day of 

100% Acid) 600 (Nominal)

Production Rate Range (Tons/Day of 

100% Acid) 520 - 640

Subject to Subpart G? Yes

Process Type (high/low pressure) High

Oxidation pressure (psia) 190

Absorption pressure (psia) 175

% Acid strength Typically Produced 54 -57

Operating Hours/Year Line 1 Line 2 Line 3

2008 7330

2007 6882

2006 7776

Control Technology 

(list as many as applicable)

SCR

% Control Efficiency (based on most 

recent compliance test)

Line 1 Line 2 Line 3

NOX NA

NO NA

NO2 NA
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) NA

NOX Emissions (lb/hr) NA

NOX Emissions (lb/ton of 100% 

acid) 0.6

Permitted NOX control efficiency, if 

applicable NA

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) NA

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 Cormetech Formed Ceramic (Tungsten Oxide & Vanadium Pentoxide)

Is Catalyst New or Regenerated? New

Catalyst Life (Design/Actual) 10 yrs/ 8 yrs

Catalyst Volume (m

3

) 1.41

Flow rate (scfm) 47,150

Ammonia injection rate (lb/hr) 56.4 (est.)

Operation and Maintenance required

(Last 10 years) Replaced initial catalyst charge in 2008. Added secondary Ammonia

addition line in 2008. Regularly scheduled predictive and preventative

maintenance.

Year began operation 2000
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) NA

Rate of reductant used

Type of catalyst

Catalyst Volume (m

3

)

Flow rate (scfm)

Is Catalyst New or Regenerated?

Catalyst Life (Design/Actual)

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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Cost Information by Control Technology

Production Line

Pollutant 

Controlled

Control 

Technology

Capital

(Yr of Cost basis)

Annual O & M

(Yr of cost basis)

# 1 Nitric Acid NOX SCR Catalyst $243,840 (2008) $91,000 (2009)

# 1 Nitric Acid NOX SCR Replacement $1,500,000 (2009) 

Est.

#1 Nitric Acid NOX Indirect Costs $154,000 (2009)

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

Catalyst cost is actual replacement cost in 2008. SCR replacement is estimated cost to replace existing 

system.

SCR replacement cost includes Equipment, Instrumentation, and Installation.

Indirect costs include Engineering, general facilities, startup and performance tests, and contingencies.
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.). Nitric Acid Tail Gas NOX (ppm)

CEMS Manufacturer AMETEK

CEMS Model Number 4610

Description of sample extraction and 

conditioning or dew point 

maintenance systems Tail gas sample is extracted from stack at approximately 300 F.

Sample line from point of extraction to analyzer is insulated and 

maintained at an elevated temperature prior to the analyzer.

Ability to distinguish between NO 

and NO2? No

Identify all periods of startup, 

shutdown, and malfunction, 

regardless of whether the event 

caused an exceedence (during the 

past 3 years) See attached document

Capital costs Estimated replacement cost of CEMS is $25,000

Operation and Maintenance costs $1,200

Cost of quarterly audits $5,800

Year began operation 2000

CEMS Data (Monthly and Annual)

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.

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.

SCR is reliable and gives good control.

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

Recommend the use of Method 7E for RATA and performance testing required by subpart.
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. 

Maximum anticipated NOX is about 1000 ppm. 

Emissions levels of ammonia during SSM events are not measured.

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

a startup, shutdown, and malfunction event. 

Typically, an SSM event will last about 1 hour or less. NH3 emissions are not regulated under

the permit.

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. 

The facility has standard procedures in place that are utilized during SSM eventsto minimize 

emissions.
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.