### 1



### Date: November 22 , 2010

Subject: Summary of Cost 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. 0210426.00 4 .0 03

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 was

more than 8 years ago. As a result of this, EPA has received a citizen suit from Sierra Club and

Environm ental Integrity Project prompting a review of the standards

.

The purpose of an NSPS review is to determine if the standards reflect the “degree of emissions

limitation achievable through application of the best system of emission reduction which (taking

i nto account the cost of achieving such reduction and any nonair quality health and

environmental impact and energy requirements) the Administrator determines has been

adequately demonstrated.”

EPA issued an Information Collection Request (ICR) under Secti on 114 authority to obtain NO X 

### emissions data using EPA Methods 7, 7A, 7B, 7C, 7D, 7E (modified version), or 320. The ICR

also collected cost data for NO X 

### CEMS and NO X 

### abatement technologies, including nonselective

catalytic reduction (NSCR), selective ca talytic reduction (SCR), and H 2 

### O 2 

### injection . Cost data

w ere received from 9 facilities with a total of 12 nitric acid production trains

.

The facilities reported information on capital costs and annual operation and maintenance

(O&M) costs. The annualized costs were estimated by multiplying the capital recovery factor

(CRF) by the capital costs and summing with the annual O&M costs. The capital recovery factor

for NO X 

### CEMS (0.1424) was calculated based on an interest rate of 7% and an equipm ent life of

10 years

. The capital recovery factor for NSCR

, SCR , and hydrogen peroxide injection (0.1098)

,

### 2



### the capital recovery factor was calculated based on an interest rate of 7% and an equipment life

of 15 years.

The supplied cost data were not based on the same year. As the value of money varies with

inflation, all annualized data were scaled to the second quarter of 2010 using the Marshall and

Swift Index as shown in Table 1.

The year on which the costs were based varied from 1973 to 2010 but was not supplied in most

cases. For capital costs, the year was not given for 38 of the 53 data points; for operation and

maintenance costs, the year was not given for 37 of the 53 data poin ts. For the data points

without specific years, we assumed that the capital costs were based on the year the equipment

was installed and that operation and maintenance costs were based on first quarter 2010 (when

the questionnaires were delivered). Usin g these assumptions, annualized costs were scaled to the

second quarter of 2010

.

The annualized cost data for monitoring and control devices are presented for the follo wing:

costs as reported in ICR responses (Section II); total facility costs (Section I II); and costs

normalized to production (Section IV) by plant size

. The data are summarized in Section V.

II

. Cost Data as Reported in the ICR

The respondents provided costs in various ways. Some data were divided into categories such as

testing , maintenance, or calibration; other data were provided as a total number, with no

explanation of the categories included. The following sections summarize the cost data as

reported by the respondents. The data are broken out by NO X 

### CEMS, NSCR, SCR , and

hydrogen peroxide (H 2 

### O 2 

### ) injection

.

a

. NO X 

### CEMS

As shown in Table 2 , cost for CEMS testing ranges from $ 7

, 7 00 to $ 3 1 ,000 per

facility

. As shown in Table 3 , cost for CEMS calibration ranges from $3,000 to

$24,000 per facility. As shown in Table 4 , cost for CEMS maintenance and parts

varies from $1, 600 to $ 6 1 ,000 per year

. As shown in Table 5 , CEMS equipment

costs range from $ 5

, 4 00 to $ 7 2,000 per year

.

All respondents were contacted for additional information on how the estimates

were determined and the type of information included in the ir estimates. No

additional information was received related to NO X 

### CEMS.

The data are analyzed on a facility basis in Section III to determine whether the

total cost of testing, calibration, maintenance, parts, and equipment have less

variation.

### 3 

### b

. NSCR

As shown in Table 6 , NSCR equipment costs range from $ 5 0 ,000 to $ 1.4 million

per year

. As shown in Table 7 , gas costs for operating the NSCR range from

$24 6 ,000 to $1. 3 million per year

. As shown in Table 8 , NSCR catalyst costs

range from $68,000 to $20 7 ,000 per year. As shown in Table 9 , NSCR

maintenance costs range from $2 3 ,000 to $ 115 ,000 per year.

Variation s in costs are likely due to several differences among reporting facilities.

For example, annualized f uel costs are affected by the type of fuel reported,

market conditions, and differences in plant sizes. In the case of equipment costs,

not all plants reported annual O&M costs and not all plants reported capital costs

. Due to the CRF, a plant reporting capital costs greater than other plants would

have less of an impact on the annualized costs than a plant reporting O&M costs

greater than other plants.

The data are analyzed on a facility basis in Section III to determine whether the

total cost of testing, calibration, maintenance, parts, and equipment have less

variation.

c

. S CR

As shown in Table 10 , SCR equipment costs range from $ 1 48 ,000 to $ 586 ,000

per year

. As shown in Table 11

, SCR catalyst costs range from $ 5 5 ,000 to

$ 12 0 ,000 per ye a r

. As shown in Table 12

, SCR maintenance costs range from

$19,000 to $2 8 ,000 per year. As shown in Table 13

, ammonia costs range from

$25,000 to $ 413 ,000 per year.

The differences are explained by the fact that not all facilities with an SCR

reported each of the costs shown above as a separate entry. Also, variations can

be explained by plant size, the amount of ammonia required , and possibly the age

of the equipment.

The data are analyzed on a facility basis in Section III to determine wheth er the

total cost of equipment, ammonia costs, catalysts, and maintenance have less

variation.

d

. Hydrogen Peroxide Injection

As shown in Table 14

, h ydrogen peroxide injection costs between $2 16 ,000 and

$3 2 3 ,000 per year.

### 4



### III

. Total Facility Costs by Production Train

As shown in the previous section, information was not reported consistently by facilities

responding to the ICR. For example, t he ICR asked for the capital cost of equipment and

annual O&M costs. Some of the facilities divided the ir costs into subcategories such as

calibration, testing, gas costs, and maintenance. To possibly correct the variation in costs

among facilities , costs for each train and technology combination were combined into a

total facility capital cost and a total O& M cost and then annualized. The results are

shown in Table 15

.

a

. NO X 

### CEMS

The annualized costs for NO X 

### CEMS from 8 trains vary from $ 5

, 4 00 to $1 82 ,000

per year and average $5 8 ,000 per year. All respondents were contacted for

additional information on how the estimates were determined and the type of

information included in their estimates. No additional information was received

related to NO X 

### CEMS.

b

. NSCR

The annualized costs for NSCR from 6 trains vary from $ 266,000 to $ 1 .6 million

per year and average $1. 2 million per year. All respondents were contacted for

additional information on how the estimates were determined and the type of

information included in their estimates. However , the lowest cost is from the

smallest plant surveyed. The other annualize d costs have less variation, ranging

from $1.1 million to $1.6 million.

c

. SCR

The annualized costs for SCR from 5 trains are relatively consistent and vary

from $ 30 4 ,000 to $6 0 1 ,000 per year and average $4 34 ,000 per year

.

d

. Hydrogen Peroxide Injection

The hydrogen peroxide injection costs from 2 trains vary from $2 16 ,000 to

$32 3 ,000 per year and average $2 7 0 ,000 per year.

### 5



### IV

. Cost Data Normalized by Production

As shown in the previous two section s , the re can be considerable variation in costs. To account

for the effect of plant size on costs, costs were normalized using annual nitric acid production.

T he plants were grouped by those that produce less than 500 tons per day of nitric acid (tpd) and

those that produce greater than 501 tons per day of nitric acid.

a

. Plants producing less than 500 tpd

Five facilities ( 6 production trains) produc ing less than 5 0 0 tons per day (tpd) of

nitric acid reported cost information.

The data are shown in Table 16

.

i

. NO X 

### CEMS

The normalized costs per ton of nitric acid for NO X 

### CEMS from 4

facilities vary from $0. 3 7 to $1. 73 and average $ 1.03

.

ii

. NSCR

The normalized costs per ton of nitric acid for NSCR from 4 facilities vary

from $1 2

. 84 to $ 29.75 and average $ 20.0 2

.

iii

. SCR

The normalized costs per ton of nitric acid for SCR per ton of nitric acid

from one facility are $ 3.93

.

iv

. Hydrogen Peroxide Injection

N ormalized costs of h ydrogen peroxide injection per ton of nitric acid

from one facility are $2. 06

.

### 6 

### b

. Plants producing greater than 5 01 tpd

Four facilities ( 6 production trains) with nitric acid production greater than 5 01

tpd reported cost information.

The data are shown in Table 17

.

i

. NO X 

### CEMS

The normalized costs per ton of nitric acid for NO X 

### CEMS from 4

facilities vary from $0. 0 7 to $0.2 6 and average $0. 1 3

.

ii

. NSCR

The normalized costs per ton of nitric acid for NSCR per ton of nitric acid

from one facility are $ 7.80

.

iii

. SCR

The normalized costs per ton of nitric acid for SCR from 3 facilities vary

from $1. 03 to $1. 39 and average $1. 10

.

iv

. Hydrogen Peroxide Injection

Normalized costs of h ydrogen peroxide injection from one facility are

$1. 39

.

c

. Data from Alternative Control Techniques Document

— Nitric Acid and

Adipic Acid Manufacturing Plants (ACT) published in 199 1

Table 18 shows the costs for SCR and NSCR as they were published in the ACT

in 1991. The annualized and normalized costs were scaled to 2010 dollars. No

data were available for NO X 

### CEMS or hydrogen peroxide injection.

### 7



### V

. Summary

a

. Total Facility Annualized Costs

Annualized costs are summarized in Table 19

.

i

. NO X 

### CEMS

The overall average total facility annualized cost of NO X 

### CEMS is

$5 8 ,000 per year.

ii

. NSCR

The average total facility annualized cost of NSCR is $ 1. 1 1 million per

year for plants producing less than 500 tpd and $1.6 million for plants

producing greater than 501 tpd

. The overall average is $1.1 8 million.

The average NSCR costs for plants producing less than 500 tpd are

consistent with the ACT costs for 200 and 500 tpd plants, which fall

between $800,000 and $1.6 million.

The average NSCR costs for plants producing greater than 500 tpd are

lower than the ACT costs for 1,000 tpd plants , which are $ 2.9 million.

iii

. SCR

The average total facility annualized cost of SCR is $ 413 ,000 per year for

plants producing less than 500 tpd and $ 385 ,000 for plants producing

greater than 501 tpd

. The overall average is $4 34 ,000.

The SCR costs for plants producing less than 500 tpd are consistent with

the ACT costs for 200 and 500 tpd pl ants, which fall between $ 302,000

and $709 ,000.

The SCR costs for plants producing greater than 50 1 tpd are lower than

the ACT costs for 1,000 tpd plants, which are $ 1.1 million.

iv

. Hydrogen Peroxide Injection

The average total facility annualized cost of H 2 

### O 2 

### injection is $ 2 16 ,000

per year for plants producing less than 500 tpd and $ 32 3 ,000 for plants

producing greater than 501 tpd. The overall average is $ 27 0 ,000. No data

were published in the ACT.

### 8 

### b

. Normalized Costs

Normalized costs are summarized in Table 2 0

.

i

. NO X 

### CEMS

The average total facility normalized cost of NO X 

### CEMS is $ 1.03 for

plants producing less than 500 tpd and $ 0.0 8 for plants producing greater

than 501 tpd. The overall average is $ 0. 20

. No data were published in the

ACT. The costs of NO X 

### CEMS are most likely independent of plant

production rate.

ii

. NSCR

The N SCR costs for plants producing less than 500 tpd ($1 2.84 to $29.75)

are much higher (a factor of 2. 8 ) than the ACT costs for 200 and 500 tpd

plants, which fall between $3.95 and $4.51.

The N SCR costs for plants producing greater than 501 tpd ($ 7.80 ) are

much higher (a factor of 2.5) than the ACT costs for 1,000 tpd plants,

which are $3.19.

The overall average total facility normalized cost of NSCR is $1 4.88

.

iii

. SCR

The SCR costs for plants producing less than 500 tpd ($ 3.93 ) are a bit

lower than the ACT costs for 200 , 250, and 500 tpd plants, which fall

between $3 .95 and $4.51

.

The SCR costs for plants producing greater than 501 tpd ($1. 03 to $1. 39 )

are lower (a factor of 3.0 ) than the ACT costs for 1,000 tpd plants, which

are $ 3.19

.

The overall average total facility normalized cost of SCR is $1.45

iv

. Hydrogen Peroxide Injection

The average total facility normalized cost of hydrogen peroxide injection

is $2. 06 f or plants producing less than 500 tpd and $ 1.3 6 for plants

producing greater than 501 tpd. The overall average is $1. 58

. No data

were published in the ACT.

### 9



### Table 1. Marshall and Swift Indices

Period Year Index

2nd quarter 2010 1493.5 1

1st quarter 2010 1481.8 1

annual 2009 1468.6 1

annual 2008 1449.3 1

annual 2007 1373.3 1

annual 2006 1302.3 1

annual 2005 1244.5 1

annual 2004 1178.5 1

annual 2003 1123.6 1

annual 2002 1104.2 1

annual 2000 1089 2

annual 1999 1068.3 2

annual 1997 1056.8 2

annual 1994 993.4 3

annual 1991 930.6

annual 1980 659.6

annual 1975 444.3

annual 1973 344.1

annual 1971 321.3

annual 1968 273.1

1 Marshall and Swift Index. Chemical Engineering. August 2010.

2 Marshall and Swift Index. Chemical Engineering . April 2001.

3 McKetta, John J. Encyclopedia of Chemical Processing and Design . Volume 61. 1997. Page xix.

### 10



### Table 2 . NO X 

### CEMS testing costs

Company City Production

Line Description Annual O &

M Cost Year of

Cost Basis Annualized Costs

($2010

— 2 nd quarter) Nitric Acid

Production (tpd)

El Dorado

Nitrogen Baytown Nitric Acid

Plant CGAs and RATAs $7,605 $7,665 1,515

Agrium North Bend Line #1 audit labor and gases for

RATA $10,000 2009

$10,170 288

JR Simplot Helm #1 Nitric Acid annual tests $10,950 $11,036 231

Coffeyville Coffeyville #1 Nitric Acid quarterly audits $23,200 $23,383 600

Agrium North Bend Line #1 RATA $30,000 2009 $30,509 288

PCS Nitrogen Geismar All trains CGAs and RATAs $1,000 $1,008 2,800

PCS Nitrogen Geismar All trains RATA $8,000 $8,063 2,800



### Table 3 . NO X 

### CEMS calibration costs

Company City Production Line Annual O & M Cost Year of Cost Basis Annualized Costs

($2010

— 2 nd quarter) Nitric Acid Production (tpd)

Agrium North Bend Line #1 $24,000 2009 $24,407 288

PCS Nitrogen Geismar All trains $3,000 $3,024 2,800



### Table 4 . NO X 

### CEMS maintenance and parts costs

Company City Production

Line Capital Cost Year of

Cost Basis Annual O &

M Cost Year of

Cost

Basis Annualized Costs

($2010

— 2 nd

quarter) Nitric Acid

Production

(tpd)

JR Simplot Helm #1 Nitric Acid $1,567 $1,57 9 231

Agrium North Bend Line #1 $31,000 2009 $ 4

, 489 288

Agrium North Bend Line #1 $24,000 2009 $24,407 288

Agrium North Bend Line #1 $60,000 2009 $61,017 288

PCS

Nitrogen Geismar All trains $5,000 $5,039 2,800

### 11



### Table 5 . NO X 

### CEMS equipment costs

Company City Production Line Capital

Cost Year of

Cost

Basis Annual O &

M Cost Year of

Cost Basis Annualized Costs

($2010

— 2 nd

quarter) Nitric Acid

Production (tpd)

Dyno Nobel St. Helens Nitric Acid Plant $15,000 1991 $2,000 $5,443 41

Coffeyville Coffeyville #1 Nitric Acid $25,000 2000 $1,200 $6,091 600

JR Simplot Helm #1 Nitric Acid $49,894 1980 $11,700 $27,877 231

Agrium North Bend Line #1 $187,000 2009 $27,076 288

El Dorado

Nitrogen Baytown Nitric Acid Plant $94,000 1999

$13,448 $32,265 1,515

Agrium Kennewick Plant 9 $75,000 2009 $50,000 $61,254 650

Agrium Sacramento Line #1 $125,338 2003 $44,200 2007 $71,789 236



### Table 6 . N SCR equipment costs

Company City Production Line Capital Cost Yr of Cap

Cost Annual

O & M Cost Annualized Costs

($2010

— 2 nd quarter) Nitric Acid Production

(tpd)

JR Simplot Helm #1 Nitric Acid $450,000 2010 $ 49,798 231

PCS Nitrogen Geismar Train IV $1,495,000 2010 $1 65

, 439 550

Dyno Nobel St. Helens Nitric Acid Plant $1,560,000 1968 $263,874 $ 265,957 41

Dyno Nobel Cheyenne #2 Nitric Acid $1,606,264 1968 $1,311,188 $ 1,321,541 125

Dyno Nobel Cheyenne #1 Nitric Acid $1,700,981 1971 $1,346,596 $ 1

, 357,228 125



### Table 7 . N SCR fuel cost data

Company City Production

Line Fuel Annual O & M

Cost Yr of cost

basis Annualized Costs

($2010

— 2 nd quarter) Nitric Acid Production

(tpd)

Agrium Sacramento Line #1 natural gas $242,050 2009 $246,154 236

JR Simplot Helm #1 Nitric Acid butane $1,025,000 2010 $1,033,093 231

PCS Nitrogen Geismar Train IV methane $1,300,000 $1,310,265 550

### 12



### Table 8 . N SCR catalyst costs

Company City Production

Line Annual O & M Cost Yr of cost basis Annualized Costs

($2010

— 2 nd quarter) Nitric Acid Production (tpd)

PCS Nitrogen Geismar Train IV $67,600 $68,134 550

Agrium Sacramento Line #1 $203,400 2009 $206,849 236



### Table 9 . N SCR maintenance costs

Company City Production Line Annual O & M

Cost Yr of cost basis Annualized Costs

($2010

— 2 nd quarter) Nitric Acid

Production (tpd)

PCS Nitrogen Geismar Train IV $22,425 $22,602 550

Agrium Sacramento Line #1 $86,500 2003 $114,977 236



### Table 10

. SCR equipment costs

Company City Production

Line Capital

Cost Yr of Cap

Cost Annual

O & M

Cost Yr of

O&M

cost Annualized Costs

($2010

— 2 nd quarter) Nitric Acid

Production (tpd)

PCS Nitrogen Geismar Train III $1,235,000 2007 $147,465 650

Coffeyville Coffeyville # 1 Nitric

Acid $1,654,000 2009 $184,679 600

PCS Nitrogen Geismar Train V $1,820,000 2010 $201,404 1,600

El Dorado

Nitrogen Baytown Nitric Acid

Plant $933,243 2009 $467,979 2008 $586,454 1,515



### Table 11

. SCR catalyst costs

Company City Production Line Capital

Cost Yr of Cap

Cost Annual

O & M Cost Yr of

O&M

cost Annualized Costs

($2010

— 2 nd

quarter) Nitric Acid

Production (tpd)

PCS Nitrogen Geismar Train V $54,300 $54, 729 1,600

PCS Nitrogen Geismar Train III $71,735 $7 2

, 301 650

Coffeyville Coffeyville # 1 Nitric Acid $243,840 2008 $91,000 2009 $12 0

, 1 32 600

### 13



### Table 12 . SCR maintenance costs

Company City Production Line Technology Capital

Cost Yr of Cap Cost Annual

O & M Cost Yr of

O&M cost Annualized

Costs

($2010

—

2 nd

quarter) Nitric Acid

Production

(tpd)

PCS Nitrogen Geismar Train III SCR $18,500 $18,646 650

PCS Nitrogen Geismar Train V SCR $27,300 $27,516 1,600



### Table 13 . SCR ammonia costs

Company City Production

Line Technology Capital

Cost Yr of Cap

Cost Annual

O & M Cost Yr of

O&M cost Annualized

($2010

— 2 nd

quarter)Costs Nitric Acid

Production

(tpd)

PCS

Nitrogen Geismar Train III SCR $25,000 $25,197 650

PCS

Nitrogen Geismar Train V SCR $315,000 $317,487 1,600

Agrium North

Bend Line #1 SCR $2,750,000 2009 $105,000 $ 412,884 288



### Table 14

. Hydrogen Peroxide Injection

Company City Production

Line Technology Capital Cost Yr of

Cap

Cost Annual

O & M

Cost Yr of

O&M

cost Annualized

Costs

($2010

— 2 nd

quarter) Nitric Acid

Production

(tpd)

Agrium North Bend Line #1 H 2 O 2 Injection $165,000 1997 $189,000 $2 16,095 288

Agrium Kennewick Plant 9 H 2 O 2 Injection $150,000 2004 $300,000 2010 $32 3

, 240 650

### 14



### Table 15

. Summary of Annualized Costs per Nitric Acid Train by Technology

Company City Production Line Technology Capital Cost Annual O & M Cost Annualized Costs

($2010

— 2 nd quarter) Nitric Acid

Production (tpd)

Dyno Nobel St. Helens Nitric Acid Plant CEMS $15,000 $2,000 $5,443 41

Coffeyville Coffeyville #1 Nitric Acid CEMS $25,000 $24,400 $29,474 600

PCS Nitrogen Geismar Train III CEMS $ 75 ,000 $1 7 ,000 $3 3

, 188 2,80 0

El Dorado Nitrogen Baytown Nitric Acid Plant CEMS $94,000 $21,053 $39,930 1,515

JR Simplot Helm Nitric Acid Plant CEMS $49,894 $24,217 $40,493 231

Agrium Kennewick Plant 9 CEMS $75,000 $50,000 $61.254 650

Agrium Sacramento Line #1 CEMS $125,338 $44,200 $71,789 236

Agrium North Bend Line #1 CEMS $218,000 $148,000 $182,074 288

Average $57,956 All

Average (without the lowest and the highest) $46,021 All

Agrium Kennewick Plant 9 H 2 O 2 Injection $150,000 $300,000 $32 3

, 240 650

Agrium North Bend Line #1 H 2 O 2 Injection $165,000 $189,000 $2 16

, 095 288

Average $26 9

, 667 All

JR Simplot Helm #1 Nitric Acid NSCR $4 50,000 $1,0 49

, 217 $1,0 82

, 891 231

Dyno Nobel St. Helens Nitric Acid Plant NSCR $1,560,000 $263,874 $265,957 41

Agrium Sacramento Line #1 NSCR $1,418,803 $1,505,192 236

PCS Nitrogen Geismar Train IV NSCR 1,495,000 $1,390,025 $1, 5 6 6

, 439 550

Dyno Nobel Cheyenne #1 Nitric Acid NSCR $1,700981 $1,346,596 $ 1,357,228 125

Dyno Nobel Cheyenne #2 Nitric Acid NSCR $1606264 $1,311,188 $ 1,321,541 125

Average $ 1, 1 8 3

, 208 All

PCS Nitrogen Geismar Train III SCR $1,235,000 $115,235 $ 263

, 609 650

Coffeyville Coffeyville # 1 Nitric Acid SCR $1,897,840 $91,000 $304

, 811 600

Agrium North Bend Line #1 SCR $2,750,000 $105,000 $412

, 884 288

El Dorado Nitrogen Baytown Nitric Acid Plant SCR $933,243 $467,979 $586

, 454 1,515

PCS Nitrogen Geismar Train V SCR $1,820,000 $396,600 $601

, 135 1,600

Average $ 433,779 All

### 15



### Table 16

. Normalized Costs for Plant s producing less than 500 tons per day nitric acid

Company City Production

Line Technology Capital Cost Annual O & M

Cost Annualized Costs

($2010

— 2 nd quarter) Nitric Acid

Production (tp y ) Annualized Costs

per ton HNO 3 Dyno

Nobel St. Helens Nitric Acid

Plant CEMS $15,000 $2,000 $ 5

, 443 14,189 $0.37

JR Simplot Helm #1 Nitric Acid CEMS $49,894 $24,217 $40,493 8 4,315 $0.48

Agrium Sacramento Line #1 CEMS $125,338 $44,200 $ 71

, 789 86,031 $0.83

Agrium North Bend Line #1 CEMS $218,000 $148,000 $1 82 ,0 74 105,120 $1.73

Agrium North Bend Line #1 H 2 O 2 Injection $ 16 5,000 $ 189 ,000 $ 2 16

, 095 105,120 $2. 06

JR Simplot Helm #1 Nitric Acid NSCR $4 50,000 $1,049,217 $1, 0 82

, 891 84,315 $1 2

. 84

Dyno

Nobel St. Helens Nitric Acid

Plant NSCR $1,560,000 $263,874 $ 265,957 14,819 $17.95

Agrium Sacramento Line #1 NSCR $1,418,803 $1, 505

, 192 86,031 $17.50

Dyno

Nobel Cheyenne #1 Nitric Acid NSCR $1,700,981 $1,346,596 $ 1,357,228 45,625 $29.75

Dyno

Nobel Cheyenne #2 Nitric Acid NSCR $1,606,264 $1,311,188 $ 1,321,541 45,625 $28.97

Agrium North Bend Line #1 SCR $2,750,000 $105,000 $ 412,884 105,120 $ 3.93

### 16



### Table 17

. Normalized Costs for Plants producing greater than 50 1 tons per day nitric acid

Company City Production

Line Technology Capital

Cost Annual O & M

C ost Annualized Costs

($2010

— 2 nd quarter) Nitric Acid

Production (tp y ) Annualized Costs

per ton HNO 3

El Dorado

Nitrogen Baytown Nitric Acid

Plant CEMS $94,000 $21,053 $3 9

, 930 552,975 $0.0 7

Coffeyville Coffeyville #1 Nitric

Acid CEMS $25,000 $24,400 $2 9

, 474 219,000 $0.1 3

PCS Nitrogen Geismar All t rain s CEMS $75,000 $17,000 $3 3

, 188 1,022,000 $0. 03

Agrium Kennewick Plant 9 CEMS $75,000 $50,000 $6 1

, 254 237,250 $0.2 6

Agrium Kennewick Plant 9 H 2 O 2 Injection $150,000 $300,000 $32 3,000 237,250 $1. 36

PCS Nitrogen Geismar Train IV NSCR $1,495,000 $1,390,025 $1, 5 66

, 439 200,750 $ 7.80

El Dorado

Nitrogen Baytown Nitric Acid

Plant SCR $933,243 $467,979 $ 58 6, 454 552,975 $1. 0 6

PCS Nitrogen Geismar Train V SCR $1,820,000 $396,600 $6 01

, 135 584,000 $1. 03

PCS Nitrogen Geismar Train III SCR $1,235,000 $115,235 $ 263,609 237,250 $1. 11

Coffeyville Coffeyville # 1 Nitric

Acid SCR $1,897,840 $91,000 $3 04

, 8 11 219,000 $1. 39



### Table 18. Summary of Data from ACT

Plant size

(ton/day) Uncontrolled

NO X emissions

(tpy) Control

technique NO X

removed

(tpy) ACT

Annualized

C ost from

($1991) Cost

Effectiveness

($1991) Annualized costs

($2010

— 2 nd

quarter) Cost Effectiveness

($/ton NO

X )

($2010

— 2 nd

quarter) Normalized costs

($/ton HNO 3 )

($2010

— 2 nd

quarter)

200 718 NSCR 701 $501,000 $714 $804,044 $1,120 $11.20

500 1800 NSCR 1759 $1,020,000 $580 $1,636,976 $930 $9.12

1000 3590 NSCR 3507 $1,780,000 $507 $2,856,684 $815 $7.96

200 718 SCR 617 $188,000 $304 $301,717 $489 $4.20

500 1800 SCR 1548 $442,000 $286 $709,356 $460 $3.95

100 0 3590 SCR 3087 $714,000 $231 $1,145,883 $370 $3.19

250 898 SCR 873 $252,000 $289 $404,429 $465 $4.51

### 17



### Table 1 9

. Summary of Annualized Costs by Plant Size

Tech Overall

($2010

— 2 nd quarter) 0

- 500 tpd

($2010

— 2 nd quarter) >501 tpd

($2010

— 2 nd quarter) ACT

($2010

— 2 nd quarter)

min max avg min max avg min max avg min max avg

CEMS $5,400 $182,000 $58,000 $5,400 $182,000 $75,000 $29,000 $61,000 $41,000

---- ---- ----

NSCR $266,0 00 $1,570,000 $1,180,000 $266,000 $1,505,000 $1,110,000 $1,570,000 $1,570,000 $1,570,000 $804,000 $2,900,000 $1,770,000

SCR $264,00 0 $601,000 $434,000 $413,000 $413,000 $413,000 $264,000 $586,000 $385,000 $301,000 $1,150,000 $640,000

H 2 O 2 $216, 000 $323,000 $270,000 $216,000 $216,000 $216,000 $323,000 $323,000 $323,000

---- ---- ----



### Table 2 0 . Summary of Normalized Costs by Model Plant ($/ton nitric acid)

Tech Overall

($2010

— 2 nd quarter) 0

- 500 tpd

($2010

— 2 nd quarter) >5 01 tpd

($2010

— 2 nd quarter) ACT

($2010

— 2 nd quarter)

min max avg min max avg min max avg min max avg

CEMS $0.03 $1.73 $0. 20 $0.37 $1.73 $1.03 $0.03 $0.26 $0.0 8

---- ---- ----

NS CR $ 7.80 $29.75 $1 4.88 $1 2.84 $29.75 $20.0 2 $ 7.80 $ 7.80 $ 7.80 $7.96 $11.20 $8.68

SCR $1. 03 $ 3.93 $1. 28 $ 3.93 $ 3.93 $ 3.93 $1. 03 $1. 39 $1. 10 $3.19 $4.51 $3.65

H 2 O 2 $1.3 6 $2. 06 $1. 58 $2. 06 $2. 06 $2. 06 $1.3 6 $1.3 6 $1.3 6

---- ---- ----