Enclosure 5a 

Page 1 of 11 

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

Plant Data 

Facility name Agrium North Bend Nitrogen Operations 

Facility owner (ultimate parent owner) Agrium Inc. 

Plant Location - Address 10743 Brower Rd. 

Latitude/Longitude for Plant 39.119656, 84.795184 

Describe location of latitude/longitude Extreme southwest corner of Ohio 

City, State, ZIP code North Bend, OH 45052 

Year plant began operation 1965 

 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 1965 

Production Rate (Tons/Day of 

100% Acid) 288 tpd 

Production Rate Range (Tons/Day of 

100% Acid) 175-288 tpd 

Subject to Subpart G? Yes 

Process Type (high/low pressure) Medium 

Oxidation pressure (psia) 115-150 

Absorption pressure (psia) 100-135 

% Acid strength Typically Produced 59-68% 

Operating Hours/Year Line 1 Line 2 Line 3 

2008 8078 

2007 8283 

2006 8643 

SCR 

Peroxide Control Technology 

(list as many as applicable) 

Extended Absorption 

% Control Efficiency (based on most 

recent compliance test) 

Line 1 Line 2 Line 3 

NOX Not Applicable 

NO Not Applicable 

NO2 Not Applicable 
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) 32.33 tpy 

 NOX Emissions (lb/hr) Not Applicable 

NOX Emissions (lb/ton of 100% 

acid) 

Permit Limits: 

 - 0.61 lb/ton 100% 

acid (365 day rolling 

avg, incl. SSM) 

 - 1.0 lb/ton 100% 

acid (3 hr rolling avg, 

excl. SSM) 

Permitted NOX control efficiency, if 

applicable Not Applicable 

If your permit includes limits for 

other pollutants, please include as 

much detail as possible below: 

Line 1 Line 2 Line 3 

Ammonia Emissions (MAGLC) 410 μg/m3 NH3 slip 

MAGLC 

 

 

 

 

 

 

 
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 144’ Tall, 11’10” Diameter 

Design Information 

(gal/ 10 3

 acfm, etc) 

Gas inlet 2000-3000 ACFM, ~120 psia, 70-90F. 

Liquid Inlet 10-20 gpm, 60-90F 

 

 

Operation and Maintenance required 

(Last 10 years) Internal inspection and resealed the transition doors.

 

 

Year absorption capacity was added 1975 

If you use an additive in your absorption column: 

Name of additive (i.e., hydrogen 

peroxide) Hydrogen Peroxide 

Concentration of additive (%): <50% 

Explain the process: 

Dilute peroxide is added to the absorbing tower through the feedwater 

system 

 

 

 

 

Addition rate (gallons per hour): 0-20 gph of <50% peroxide 

Ratio of additive to water: 0-5% of <50% peroxide to water by weight 
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 

Shell De-NOx - Titanium dioxide carrier base with a vanadium 

pentoxide active compound 

Is Catalyst New or Regenerated? New 

Catalyst Life (Design/Actual) 7-Year expected 

 

Catalyst Volume (m3) 25.2m3 total, 6 modules of 4.2m3 each 

 

Flow rate (scfm) 24,734 scfm 

Ammonia injection rate (lb/hr) 3-150 lb/hr 

Operation and Maintenance required 

(Last 10 years) None, new in 2009 

 

 

Year began operation 2009 
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 (m3) 

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) 

Line #1 NOx SCR ~$2.75mm 

(2009)USD 

~$105,000/yr NH3

Feed USD 

Line #1 NOx Hydrogen Peroxide ~$165,000 

(1997)USD 

~$189,000 USD 

Line #1 NOx Extended 

Absorption 

~$790,000 

(1975)USD 

~$25,000/yr USD 

 

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

O&M costs include costs associated with ancillary equipment necessary to operate the units (ie. valves, pumps, 

etc).
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.). 

CEMS uses an AB Compact Logix controller to control and log data. All 

emissions values are output from the CEMS PLC to the plant DCS via 4-

20ma signals. Data is output from the PLC to the DCS on a continual 

(live) bases. Plant DCS provides all data storage. Outputs include 

concentration (ppm) and I/O indicating validity of concentrations. 

CEMS Manufacturer Environment S.A. 

CEMS Model Number Topaze 32M 

Description of sample extraction and 

conditioning or dew point 

maintenance systems 

CEMS uses a hot/wet sampling system. Each analyzer NH3, NOx enlists 

a separate sampling system stream. The NOx analyzer sampling system 

has a heated ammonia scrubber inserted into the sampling system to 

remove the ammonia before the NOx analyzer without affecting the NOx 

whatsoever. 

Sample extraction: Sample is extracted from the stack using a heated 

filter box with probe tube inserted into stack. Sample is transported 

down a heated sample line (190c) into the CEMS enclosure. A heated 

sample pump (190c) pulls the NH3 sample into the enclosure and pushes 

the sample into the FTUV ammonia analyzer. The NOx measurement 

sample is also pulled into the CEMS enclosure through an identical 

heated filter box and sample line. The NOx sample is pulled through the 

NOx analyzer using an educator on the vent of the analyzer. NOx 

analyzer has a dedicated vacuum pump which pulls part of the stack gas 

sample through the NOx analyzer measurement chamber. All sample 

vents are vented outside the CEMS room. The entire sampling system is 

maintained at a temperature of 190c all the way through both analyzers. 

Ability to distinguish between NO 

and NO2? 

NO2 is converted to NO before the NOX measurement. NOx analyzer 

reads total (NO/NO2) NOx only. 

Identify all periods of startup, 

shutdown, and malfunction, 

regardless of whether the event 

caused an exceedance (during the 

past 3 years) See attached 

Capital costs 

~$187,000 Installed 

~$31,000 for Critical Spare Parts 

Operation and Maintenance costs 

~$5,000 per month for maintenance 

~$2,000 per month for parts 

~$2,000 per month for calibration gasses 

Cost of quarterly audits 

~$2,500 per quarter for labor and gasses 

~$30,000 per year for annual RATA 

Year began operation 2009 

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. 

Research should continue on catalysts to reduce NOx as well as N2O at lower temperatures. 

The methods that will be successful will be ones that can be used in different types and designs 

of acid plants. Energy efficiency process improvements will continue to recover heat for 

reduced fuel consumption and steam production. 

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. 

The instantaneous compliance value of ppm NOx is getting very low. Currently around 20 to 

70 ppm to reach lower emission requirements. To reduce readings further to say ~10 ppm or 

less makes getting the readings difficult. May need to continue investigating improved 

monitoring systems to get accurate readings at such low levels. The added costs of operation, 

documentation, and reporting will reduce profitability. 

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

Include Method 7E as an approved sampling method for Nitric Acid plants, with modifications 

as necessary. 
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. 

NOx – 2300-2500ppm instantaneously, hourly average of 375ppm (7.5 lb/ton 100% acid) 

during SSM since SCR inception, with SSM events averaging 3 hours. 

NH3 – Negligible as the majority of NH3 is being consumed. Potential of 250ppm. 

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

a startup, shutdown, and malfunction event. 

Elevated emissions typically average 3 hours, but due to conditions during the startup, could 

potentially take upwards of 8-10 hours. 

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. 

Peroxide is sometimes added to the absorbing tower prior to startup to help reduce emissions 

during the startup. Additionally. procedures have been developed through on-site experience 

to minimize the potential for the absorbing tower to not seal on initial run-up of the turbine. 

The procedures for adding NH3 to the SCR during startup have also been modified. We add 

NH3 to the SCR at a faster rate to facilitate quicker reduction of the NOx in the tailgas. Per the 

catalyst manufacturer, we cannot add NH3 to the SCR until the tailgas reaches 350 deg. F, thus 

we must wait to add ammonia during the startup of the plant. During this time the NOx 

concentration in the tailgas is rising and we are unable to control it other than with the addition 

of the peroxide. 

 
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.