Date: August 25, 2010 (Updated December 17, 2010)

Subject: Summary of Test Data Received from Section 114 ICR

Nitric Acid NSPS Review

EPA Contract No. EP-D-06-118; Work Assignment No. 4-3 

RTI Project No. 0210426.004.003

From: Melissa Icenhour

To: Bill Neuffer

OAQPS/SPPD/MMG (D243-02)

U. S. Environmental Protection Agency

Research Triangle Park, NC 27711

I. 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 took 

place in 1984. As a result of this, EPA has received a citizen suit from Sierra Club and 

Environmental Integrity Project prompting review of the standards.

II. Test Data Review

EPA issued an Information Collection Request (ICR) under Section 114 authority to obtain NOX

emissions data using Methods 7, 7A, 7B, 7C, 7D, or 320. The industry was also allowed to use a 

modified version of Method 7E that contains provisions for addressing the loss of NO2 in 

condensate (see memorandum entitled “Using EPA Method 7E for Measuring NOX Emissions 

from Nitric Acid Production Facilities” dated December 16, 2009).

The ICR also allowed EPA to collect NH3 and N2O emissions data; nitric acid production rates; 

startup, shutdown, and malfunction (SSM) provisions; continuous emission monitoring system 

(CEMS) data; N2O and NOX abatement technologies; and industry opinions on the NSPS 

Review.
2

III. NOX Test Data 

EPA plans to use the test data to determine if the NOX emission limit in the Nitric Acid NSPS

should be changed.

A. Overall NOX data

All NOX emission test data are shown in Table 1. The emission limit for the NSPS will 

most likely stay in units of pound NOX per ton of nitric acid (lb/ton), so those numbers 

were evaluated. The data ranged from 0.01 lb/ton to 1.84 lb/ton and averaged 0.43 lb/ton 

for the 12 nitric acid trains.

The NOX emission data was further evaluated by production pressure, abatement 

technology, and age to show any variations in NOX data. The NOX emission data 

originates from single pressure trains (high pressure, medium pressure, and low pressure) 

and dual pressure trains.
3

B. Single pressure

All NOX emission test data from single pressure trains are shown in Tables 2 through 4. 

The data ranged from 0.01 lb/ton to 1.84 lb/ton and averaged 0.47 lb/ton for the 10 nitric 

acid trains.

1. High pressure

All NOX emission test data from high pressure trains are shown in Table 2. The 

data ranged from 0.01 lb/ton to 1.84 lb/ton and averaged 0.55 lb/ton for the 6 

nitric acid trains. Only two of the six were greater than the average of 0.55 lb/ton: 

Train 4 (0.86 lb/ton) and Train 3 (1.84 lb/ton) at the PCS Nitrogen facility. 

2. Medium pressure

All NOX emission test data from medium pressure trains are shown in Table 3. 

The data ranged from 0.35 lb/ton to 0.46 lb/ton and averaged 0.40 lb/ton for the 2

nitric acid trains.

3. Low pressure

All NOX emission test data from low pressure trains are shown in Table 4. The 

data ranged from 0.06 lb/ton to 0.52 lb/ton and averaged 0.29 lb/ton for the 2

nitric acid trains.
4

C. Dual pressure

All NOX emission test data from dual pressure trains are shown in Table 5. The results 

were 0.20 lb/ton and 0.23 lb/ton and averaged 0.22 lb/ton for the 2 nitric acid trains..

D. Control devices

The NOX emission data are from trains controlled by nonselective catalytic reduction 

(NSCR), selective catalytic reduction (SCR), extended absorption, and peroxide injection 

into the absorption tower.

1. Hydrogen Peroxide Injection

All NOX emission test data from trains controlled by hydrogen peroxide 

injection (into the absorption tower) are shown in Table 6. The data show

0.53 lb/ton and 0.46 lb/ton for the 2 nitric acid train. The average of the 2 

trains is 0.50 lb/ton. 

2. NSCR

All NOX emission test data from trains controlled by nonselective catalytic 

reduction (NSCR) are shown in Table 7. The data ranged from 0.01 lb/ton 

to 0.86 lb/ton and averaged 0.32 lb/ton for the 6 nitric acid trains.

3. SCR

All NOX emission test data from trains controlled by selective catalytic 

reduction (SCR) are shown in Table 8. The data ranged from 0.04 lb/ton 

to 1.84 lb/ton and averaged 0.58 lb/ton for the 4 nitric acid trains. Only 

one train had emissions greater than the average value of 0.58 lb/ton (1.84 

lb/ton from train 3 at the PCS Nitrogen facility).
5

E. Age

All NOX emission test data, along with the years that the trains became operational are 

shown in Table 9. The ages ranged from 10 to 46 years with a median age of 33 years. 

To evaluate whether differences in emissions were correlated by age of the nitric acid 

train, 4 age ranges were analyzed. 

1. 10-20 years

All NOX emission test data from trains that began operation 10 to 20 years ago 

ranged from 0.04 lb/ton to 0.23 lb/ton and averaged 0.16 lb/ton for the 3 nitric 

acid trains.

2. 21-30 years

All NOX emission test data from trains that began operation 21 to 30 years ago 

ranged from 0.06 lb/ton to 0.52 lb/ton and averaged 0.29 lb/ton for the 2 nitric 

acid trains.

3. 31-40 years

All NOX emission test data from trains that began operation 31 to 40 years ago 

ranged from 0.53 lb/ton to 1.84 lb/ton and averaged 1.08 lb/ton for the 3 nitric 

acid trains.

4. 41-50 years

All NOX emission test data from trains that began operation 41 to 50 years ago 

ranged from 0.23 lb/ton to 0.46 lb/ton and averaged 0.23 lb/ton for the 5 nitric 

acid trains.
6

F. NOX Conclusions

The NOX emissions from these test results are below the NSPS emission limit of 3.0 

lb/ton. 

The lowest NOX emissions (0.01 lb/ton) originated from two high pressure trains that 

began operation 41-50 years ago and are controlled by an NSCR. The highest NOX

emissions (1.84 lb/ton) originated from a high pressure train that began operation 31-40 

years ago and is controlled by a combination of SCR and extended absorption. However, 

even the highest emissions are 60% of the current NSPS NOX emission limit.

When comparing production pressures, both the highest and lowest emissions originate 

from high pressure trains. Therefore, the type of train does not necessarily result in 

higher NOX emissions.

As far as controls are concerned, the lowest emissions originate from two trains 

controlled by NSCR. The highest emissions originate from a train controlled by SCR. 

But, as shown by the data, the third lowest emissions originated from a train controlled 

by SCR. Both abatement technologies are capable of emitting less than 0.05 lb/ton of 

NOX. Therefore, the type of abatement does not necessarily result in higher NOX

emissions.

When comparing age of the process trains, the lowest emissions originate from 2 trains 

that are 41 to 50 years of age, while the highest emissions originate from a more recently 

built train from 31-40 years ago. Three of the four age groups had similar averages of 

0.16, 0.29, and 0.23 lb/ton, while the age group with the highest emissions (aged 31-40 

years) averaged 1.08 lb/ton. A newer train does not necessarily translate to lower NOX

emissions.

The analysis of NOX emissions shows that there are no great differences in emissions 

resulting from the choice of control device, the production pressure, or the age of the 

nitric acid trains. The data received as part of the ICR support a lowering of the NSPS

NOX emission limit. Only the highest two of the 12 nitric acid trains emit at rates above 

0.62 lb/ton: train 4 at PCS Nitrogen (0.86 lb/ton), and train 3 at PCS Nitrogen (1.84 

lb/ton).. 

State operating permits limit the emissions of NOX to 0.6 lb/ton for Coffeyville and

Agrium-Kennewick and 0.61 lb/ton for Agrium-North Bend.
7

IV. N2O Test Data 

EPA did not request N2O test data as part of the ICR but received this information from 5 nitric 

acid trains. The data are shown in Table 10. The N2O emissions ranged from 0.43 lb/ton to 

18.11 lb/ton and averaged 9.44 lb/ton. The data were also given in parts per million. The data 

ranged from 32.52 ppm to 1,261.94 ppm and averaged 639.94 ppm.

Only the lowest emission rate is controlled by an NSCR. All other trains are controlled by SCR.

The amount of N2O data was more limited than the NOX data and the data vary much more 

significantly. This can be explained by the fact that none of these nitric acid trains currently 

have limits on N2O emissions. 

Only two of the 5 trains emit at a higher rate than 10 lb/ton: Agrium-North Bend (14.90 lb/ton)

and train 5 at PCS Nitrogen (18.11 lb/ton).

Further information gathering will be performed if an N2O emission rate is to be determined for 

the NSPS.

V. NH3 Test Data 

To evaluate ammonia slip, we received information from 3 nitric acid trains with SCR control. 

The data are shown in Table 11. The NH3 emissions ranged from 0.02 lb/ton to 0.1 lb/ton and 

averaged 0.05 lb/ton; ranged from 5.85 ppm to 17.33 ppm and averaged 10.05 ppm; and ranged

from 0.57 pound NH3 per hour (lb/hr) to 2.3 lb/hr and averaged 1.44 lb/hr.

In addition to the data received, there are also two nitric acid trains that are subject to an NH3

emission limit. El Dorado Nitrogen has a limit of 25.6 tons per year and 5.9 lb/hr and AgriumNorth Bend has a limit of 410 micrograms per cubic meter (μg/m3

) of ammonia slip.

Only one of the trains with ICR test data emits at a higher rate than 2.30 lb/hr.
8

Table 1. ICR Test Data for NOX Emissions from Nitric Acid Trains

Company City State Production line

Production 

Pressure

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O Test Dates(s)

Dyno Nobel Cheyenne WY Acid Plant 1 high 57% NSCR 112.24 EPA 7E 0.01 3.70 April 14, 2010

Dyno Nobel Cheyenne WY Acid Plant 2 high 57% NSCR 89.04 EPA 7E 0.01 3.73 April 14, 2010

Coffeyville 

Resources Nitrogen 

Fertilizers, LLC Coffeyville KS #1 Nitric Acid high 54% SCR 546.43 EPA 320 0.04 0.68

March 24, 

2010

JR Simplot Helm CA Line 1 low 57% NSCR 242.00 EPA 7 0.06 2.27 April 8, 2010

PCS Nitrogen Geismar LA Line 5 (Train 5) dual 65% SCR 1,532.36 EPA 7A 0.20 0.30 April 21, 2010

El Dorado Nitrogen Baytown TX Line 1 dual 65%

SCR, extended 

absorption 1,306.00

ASTM 

6348-03 0.23 May 19, 2009

Dyno Nobel Deer Island OR Line 1 medium 58% NSCR 70.00 EPA 7A 0.35 3.80 May 5, 2010

Agrium North Bend OH Line 1 medium 

weak 

acid

SCR, Extended 

Absorption, 

H2O2 injection 281.74 EPA 7D 0.46 2.70

February 11, 

2010

Agrium Kennewick WA Plant 9 high 57%

extended 

absorption, 

H2O2 injection 566.40 EPA 320 0.53 0.18

March 31, 

2010

CA Agrium US, Inc

West 

Sacramento CA Line 1 low 53% NSCR 196.30 EPA 320 0.52 0.24 May 12, 2010

PCS Nitrogen Geismar LA Line 4 (Train 4) high 65% NSCR 504.48 EPA 7A 0.86 1.82 April 22, 2010

PCS Nitrogen Geismar LA Line 3 (Train 3) high 65%

SCR, Extended 

Absorption 461.04 EPA 7A 1.84 1.05 April 20, 2010
9

Table 2. NOX Emissions from Nitric Acid Trains Operated with High Pressure

Company City State

Production 

line

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test 

Dates(s)

Dyno Nobel Cheyenne WY Acid Plant 1 57% NSCR 112.24 EPA 7E 0.01 3.70

April 14, 

2010

Dyno Nobel Cheyenne WY Acid Plant 2 57% NSCR 89.04 EPA 7E 0.01 3.73

April 14, 

2010

Coffeyville 

Resources 

Nitrogen 

Fertilizers, 

LLC Coffeyville KS #1 Nitric Acid 54% SCR 546.43 EPA 320 0.04 0.68

March 24, 

2010

Agrium Kennewick WA Plant 9 57%

extended 

absorption, 

H2O2 injection 566.40 EPA 320 0.53 0.18

March 31, 

2010

PCS Nitrogen Geismar LA Line 4 (Train 4) 65% NSCR 504.48 EPA 7A 0.86 1.82

April 22, 

2010

PCS Nitrogen Geismar LA Line 3 (Train 3) 65%

SCR, Extended 

Absorption 461.04 EPA 7A 1.84 1.05

April 20, 

2010
10

Table 3. NOX Emissions from Nitric Acid Trains Operated with Medium Pressure

Company City State

Production 

line

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test 

Dates(s)

Dyno Nobel

Deer 

Island OR Line 1 58% NSCR 70.00 EPA 7A 0.35 3.80

May 5, 

2010

Agrium

North 

Bend OH Line 1

weak 

acid

SCR, Extended 

Absorption, 

H2O2 injection 281.74 EPA 7D 0.46 2.70

February 

11, 2010

Table 4. NOX Emissions from Nitric Acid Trains Operated with Low Pressure

Company City State

Production 

line

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test 

Dates(s)

JR Simplot Helm CA Line 1 57% NSCR 242.00 EPA 7 0.06 2.27

April 8, 

2010

CA Agrium US, Inc

West 

Sacramento CA Line 1 53% NSCR 196.30 EPA 320 0.52 0.24

May 12, 

2010
11

Table 5. NOX Emissions from Nitric Acid Trains Operated with Dual Pressure

Company City State

Production 

line

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test

Dates(s)

PCS 

Nitrogen Geismar LA

Line 5 (Train 

5) 65% SCR 1,532.36 EPA 7A 0.20 0.30

April 21, 

2010

El Dorado 

Nitrogen Baytown TX Line 1 65%

SCR, extended 

absorption 1,306.00

ASTM 

6348-03 0.23

May 19, 

2009

Table 6. NOX Emissions from Nitric Acid Trains Controlled by Extended Absorption

Company City State

Production 

line

Production 

Pressure

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test 

Dates(s)

Agrium Kennewick WA Plant 9 high 57%

extended 

absorption, 

H2O2 

injection 566.40

EPA 

320 0.53 0.18

March 

31, 

2010

Agrium North Bend OH Line 1 medium 

weak 

acid

SCR, Extended 

Absorption, 

H2O2 injection 281.74 EPA 7D 0.46 2.70

February 

11, 2010
12

Table 7. NOX Emissions from Nitric Acid Trains Controlled by NSCR

Company City State

Production 

line

Production 

process

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test 

Dates(s)

Dyno Nobel Cheyenne WY Acid Plant 1 high 57% NSCR 112.24 EPA 7E 0.01 3.70

April 

14, 

2010

Dyno Nobel Cheyenne WY Acid Plant 2 high 57% NSCR 89.04 EPA 7E 0.01 3.73

April 

14, 

2010

JR Simplot Helm CA Line 1 low 57% NSCR 242.00 EPA 7 0.06 2.27

April 8, 

2010

Dyno Nobel Deer Island OR Line 1 medium 58% NSCR 70.00 EPA 7A 0.35 3.80

May 5, 

2010

CA Agrium US, Inc

West 

Sacramento CA Line 1 low 53% NSCR 196.30

EPA 

320 0.52 0.24

May 12, 

2010

PCS Nitrogen Geismar LA

Line 4 

(Train 4) high 65% NSCR 504.48 EPA 7A 0.86 1.82

April 

22, 

2010
13

Table 8. NOX Emissions from Nitric Acid Trains Controlled by SCR

Company City State

Production 

line

Production 

process

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Test 

Dates(s)

Coffeyville 

Resources 

Nitrogen 

Fertilizers, 

LLC Coffeyville KS #1 Nitric Acid high 54% SCR 546.43 EPA 320 0.04 0.68

March 24, 

2010

PCS 

Nitrogen Geismar LA

Line 5 (Train 

5) dual 65% SCR 1,532.36 EPA 7A 0.20 0.30

April 21, 

2010

El Dorado 

Nitrogen Baytown TX Line 1 dual 65%

SCR, 

extended 

absorption 1,306.00

ASTM 

6348-03 0.23

May 19, 

2009

PCS 

Nitrogen Geismar LA

Line 3 (Train 

3) high 65%

SCR, 

Extended 

Absorption 461.04 EPA 7A 1.84 1.05

April 20, 

2010
14

Table 9. NOX Emissions and Age of the Plant

Company City State

Production 

line

Production 

Pressure

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Year began 

Operation Test 

Dates(s)

Dyno Nobel Cheyenne WY Acid Plant 1 high NSCR 112.24 EPA 7E 0.01 3.70 1964 April 14, 2010

Agrium North Bend OH Line 1 medium 

SCR, Extended 

Absorption, 

H2O2 injection 261.18 EPA 7D 0.34 2.20

1965 February 

10, 2010

Agrium North Bend OH Line 1 medium 

SCR, Extended 

Absorption, 

H2O2 injection 281.74 EPA 7D 0.46 2.70

1965 February 

11, 2010

Dyno Nobel Cheyenne WY Acid Plant 2 high NSCR 89.04 EPA 7E 0.01 3.73 1968 April 14, 2010

Dyno Nobel Deer Island OR Line 1 medium NSCR 70.00 EPA 7A 0.35 3.80 1968 May 5, 2010

PCS Nitrogen Geismar LA

Line 4 

(Train 4) high NSCR 504.48 EPA 7A 0.86 1.82 1970 April 22, 2010

Agrium Kennewick WA Plant 9 high 

extended 

absorption, 

H2O2 injection 566.40 EPA 320 0.53 0.18

1977 March 31, 

2010

PCS Nitrogen Geismar LA

Line 3 

(Train 3) high 

SCR, Extended 

Absorption 461.04 EPA 7A 1.84 1.05

1978 April 20, 

2010

JR Simplot Helm CA Line 1 low NSCR 242.00 EPA 7 0.06 2.27 1980 April 8, 2010
15

Company City State

Production 

line

Production 

Pressure

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/ton)

% 

H2O

Year began 

Operation Test 

Dates(s)

Agrium

West 

Sacramento CA Line 1 low NSCR 196.30 EPA 320 0.52 0.24 1982 May 12, 2010

PCS Nitrogen Geismar LA

Line 5 

(Train 5) dual SCR 1,532.36 EPA 7A 0.20 0.30 1999 April 21, 2010

El Dorado 

Nitrogen Baytown TX Line 1 dual 

SCR, extended 

absorption 1,306.00

ASTM 

6348-03 0.23

1999 May 19, 

2009

Coffeyville 

Resources 

Nitrogen 

Fertilizers, LLC Coffeyville KS

#1 Nitric 

Acid high SCR 546.43 EPA 320 0.04 0.68

2000 March 24, 

2010
16

Table 10. ICR Test Data for N2O Emissions from Nitric Acid Facilities

Company City State

Production 

line

Production 

Pressure

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/hr) Emissions 

(lb/ton)

Emissions 

(ppm) 

@0% O2

Test 

Dates(s)

PCS Nitrogen Geismar LA

Line 4 

(Train 4) high 65% NSCR 504.48

EPA 

320 9.16 0.43 32.52

April 22, 

2010

Coffeyville 

Resources 

Nitrogen 

Fertilizers, 

LLC Coffeyville KS

#1 Nitric 

Acid high 54% SCR 546.13

EPA 

320

147

6.46 427.60

March 

24, 2010

PCS Nitrogen Geismar LA

Line 3 

(Train 3) high 65%

SCR, 

Extended 

Absorption 461.04

EPA 

320

127.12

7.28 462.69

April 20, 

2010

PCS Nitrogen Geismar LA

Line 5 

(Train 5) dual 65% SCR 1,532.36

EPA 

320 1,159.8 18.11 1,261.94

April 21, 

2010
17

Table 11. ICR Test Data for NH3 Emissions from Nitric Acid Facilities

Company City State

Production 

line

Production 

Pressure

Nitric 

acid 

type

Abatement 

technology

Nitric acid 

production 

(tons/day)

Test 

Method

Emissions 

(lb/hr) Emissions 

(lb/ton)

Emissions 

(ppm) 

@0% O2

Test 

Dates(s)

PCS 

Nitrogen Geismar LA

Line 5 

(Train 5) dual 65% SCR 1,532.36 EPA 320 1.43 0.02 5.85

April 21, 

2010

PCS 

Nitrogen Geismar LA

Line 3 

(Train 3) high 65%

SCR, 

Extended 

Absorption 461.01 EPA 320

0.57

0.03 6.96

April 20, 

2010

Coffeyville 

Resources 

Nitrogen 

Fertilizers, 

LLC Coffeyville KS

#1 Nitric 

Acid high 54% SCR 552.80 EPA 320

2.3

0.10 17.33

March 

24, 2010