### 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

NO X Not Applicable

NO Not Applicable

NO 2 Not Applicable

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

Page 2 of 11 Permit Limits for Each Nitric Acid Production Line (Fill in all applicable rows)

Line 1 Line 2 Line 3

NO X Emissions (tpy) 32.33 tpy

NO X Emissions (lb/hr) Not Applicable

NO X 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 NO X 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 pr ovide 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

Page 4 of 11 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/Ac tual) 7-Year expected

Catalyst Volume (m 3 ) 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

Page 5 of 11 

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

NSCR (Nitric Acid Production Line Name)

Reductant used (methane, H 2 , 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)

Line #1 NOx SCR ~$2.75mm (2009)USD ~$105,000/yr NH 3 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 inform ation, comments, or notes below:

O&M costs include costs associated with ancillary equipm ent necessary to operate the units (ie. valves, pumps, etc).

### 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., concentration, etc.). CEMS uses an AB Compact Logix controller to control and log data. All emissions values are output from th e 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 DC S 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 inse rted into the sampling system to remove the ammonia before the NOx analyzer without affecting the NOx whatsoever. Sample extraction: Sample is extr acted from the stac k 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 samp le into the enclosure and pushes the sample into the FTUV ammoni a 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 m easurement 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 NO 2 ? NO2 is converted to NO before th e 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 NO X 

### 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 se lecting control de vices, 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 th at can be used in different types and designs of acid plants. Energy efficiency process im provements will continue to recover heat for reduced fuel consumption and steam production.

2. Please describe your thoughts on th e air pollution controls that are used at your facility such as reliability, O&M costs in cluding energy penalty, etc.

The instantaneous compliance valu e 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. Ma y 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 pr ofitability.

3. Please provide recommendations on the revi sions 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 NO X 

### or NH 3 

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

NOx – 2300-2500ppm instantaneou sly, hourly average of 37 5ppm (7.5 lb/ton 100% acid) during SSM since SCR inception, with SSM events averaging 3 hours.

NH 3 

### – Negligible as the majority of NH 3 

### is being consumed. Potential of 250ppm.

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

### or NH 3 

### will typically occur during a startup, shutdown, and malfunction event.

Elevated emissions typically av erage 3 hours, but due to condi tions during the startup, could potentially take upwards of 8-10 hours.

3. Please describe any equipment or work practic es that are employed to minimize or eliminate the quantity or duration of ex cess/elevated emissions of NO X 

### or NH 3 

### during startup, shutdown, and malfunction events.

Peroxide is sometimes added to the absorbing to wer prior to startup to help reduce emissions during the startup. Additionally. procedures ha ve been developed thr ough 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 NH 3 

### to the SCR during startup have also been modified. We add NH 3 

### to the SCR at a faster rate to facilitate quicker reduction of the NOx in the tailgas. Per the catalyst manufacturer, we cannot add NH 3 

### to the SCR until the tailgas reaches 350 deg. F, thus we must wait to add ammonia during the startu p of the plant. During this time the NOx concentration in the tailgas is ri sing and we are unable to contro l 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 duri ng 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. Because of the propensity of NO 2 

### to be absorbed by water, the sampled gas must not co ntact any condensate, a nd the efficiency of any NO 2 

### to NO converter (if needed by the detecti on 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 accepta ble 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. NO 2 

### calibration gas must be substituted for NO calibration gas in the performance of sy stem bias checks. The alternative mentioned in Section 8.6 to follow the dynamic spike proc edure 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 appli cable 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 concen tration or mass rate, and the procedure for determining the detection level.

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