### Enclosure 5a

Page 1 of 11 

## EPA Information Collection R equest for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name Dyno Nobel Inc.

– Cheyenne Plant

Facility owner (ultimate parent owner) Dyno Nobel Inc.

P lant Location

- Address 8305 Otto Road

Latitude/Longitude for Plant N 41o 05’ 45”/ W104o 54’ 15”

Describe location of latitude/longitude Center of Plant ( Four miles west of Cheyenne, Wyoming )

City

, State

, ZIP code Cheyenne, Wyoming 82007

Year plant began operation 1964

Information for Each Nitric Acid Production Line

(c hange names as needed and use the same names in the Excel spreadsheet )

Line 1 Line 2 Line 3

Year line began operation 1964 1968

Production Rate (Tons/Day of

100% Acid) 125 125

Production Rate Range (Tons/Day of 100% Acid) 105

- 115 100

- 110

Subj ect to Subpart G? No No

Process T ype ( high/low pressure) high high

Oxidation pressure (psia) 151.7 151.7

Absorption pressure (psia) 131.4 131.4

% Acid strength Typically Produced 55

- 57% 55

- 57%

Operating Hour s

/Year Line 1 Line 2 Line 3

2008 7013 7003

2007 8424 8548

2006 7874 7976

Control Technology
(list as many as applicable) NSCR NSCR

% Control Efficiency (based on most

recent compliance test) Line 1 Line 2 Line 3

NO X 99% 99 %

NO NA NA

NO 2 NA NA

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

— Electronic Version

Page 2 of 11 Permit Limits for Each Nitri c Acid Production Line

(F ill in all applicable rows)

Line 1 Line 2 Line 3

NO X Emissions ( tpy) NA NA

NO X Emissions (lb/hr) 6.0 6.0

NO X Emissions (lb/ton of 100% acid) 1.15 1.15

Permitted NO X control efficiency, if applicable N A N A

If your permi t includes limits for other pollutants, please include as much detail as possible below: Line 1 Line 2 Line 3

Visible emissions

shall not exceed 40 percent opacity Visible emissions

shall not exceed 40 percent opacity

Production rate shall

not exceed 125 TPD Production rate shall

not exceed 125 TPD

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

— Electronic Version

Page 3 of 11 

## For each control device, please provide the key design parameter s

Extended Absorption (Nitric Acid Production Line Name )

Length NA

Design Information
(gal/ 10 3 acfm, etc)

O peration and M aintenance required

(Last 10 years)

Y ea r absorption capacity was added

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen

peroxide)

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)

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Page 4 of 11 SCR (Nitric Acid Production Line Name )

Type of Catalyst NA

Is Catalyst New or Regenerated?

Catalyst Life (Design/Actual)

Catalyst Volume ( m 3 )

Flow rate (scf m)

Ammonia i njection rate (lb/hr)

Operation and Maintenance required

(Last 10 years)

Y ea r began operation

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

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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) Ammonia Plant purge gas ( 50 % hydrogen )

Rate of reductant used #1 = 46000 SCFH; #2 = 45000 SCFH

Type of catalyst Johnson Matthey Low Light Off Honeycomb NOx Abatement Catalyst

Catalyst Volume ( m 3 ) #1 = 0.187; #2 = 0.190

Flow rate (scfm) #1 = 8276 (dscfm); #2 = 8294 (dscfm)

Is Catalyst New or Regenerated? N ew

Catalyst Life (Design/Actual) Design = NA; Installed 1999

Operation and Maintenance required

(Last 10 years) 10/09/2007 Maintenance replaced the bottom flange on #2 and photos

were taken of support grid. Observations were that the catalyst appeared to be in good condition.

Y ea r began operation 10/15/71 = #1 combustor placed online; 1968 = #2 combustor installed

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

— Electronic Version

Page 6 of 11 

## Cost Information by Control Technology

Pro duction Line Pollutant
Controlled Control

Technology Capital

(Yr of Cost basis) Annual O & M

(Yr of cost basis)

#1 Nitric Acid NOx NSCR $1, 700,981 $ 1,346,596

#2 Nitric Acid NOx NSCR $1, 606

, 264 $ 1,311,188



### Pl ease provide additional cost information, comments, or notes below: Comment [ mki 1 ]: What year?

### 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.). NA

CEMS Manufacturer

CEMS Model Number

Description of sample extraction and

conditioning or dew point maintenance systems

Ability to distinguish between NO

and NO 2 ?

I dentify all periods of startup,

s hutdown, and malfunction, regardless of whether the event

caused an exceedence (during the

past 3 years)

Capital costs

Operation and Maintenance costs

Cost of quarterly audits

Year began o peration

CEMS Data (Monthly and Annual)



### Include m

onthly and a nnual 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

Page 8 of 11 

## General Discussion

1. Please provide your thoughts on trends in nitric acid production as far as ty pe of process that is used; types of absorber used, trends in selecting control devices , improvements in control efficiency in existing control devices, energy efficiency

.

In the absence of new plants being built in the USA, it is difficult to point out a trend. New plants would most likely be high pressure with bubble cap trays in the absorber tower. Ammonia conversion efficiency of new plants would typ i cally be 0.286 to 0.288 tNH3/tHNO3. Energy consumption can range widely depending on plant design. W eatherly cites about 6 kWH per ton of acid with a steam turbine and Uhde cites about 13 kWh per ton of acid (with electric driven compressor ). Any new plant would likely be designed with DCS control

system. SCR seems to be the NOx control system most freq uently used on newer plants.

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 NSCR is very reliable; however operating costs are high for th e #1 and #2 Nitric Acid due

to the requirement for hydrogen rich purge gas necessary for NOx abatement

.

3

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

I would like the NSPS for Nitric Acid Plants to remain as is . Although the #1 and #2 Nitric Acid Plants are able to attain very low levels of NOx emissions. Most NSCR plants cannot, unless they have the availability of expensive hydrogen rich ammonia purge gas. NSCR is an integral part of the nitric acid plant o peration and a plant is unable to reach an arbitrary abatement number due to design constraints. NSCR is not an add on control such as SCR.

The addition of increased abatement catalyst has the potential to damage downstream equipment due to metallurgical heat limits and the resultant exotherm.

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

— Electronic Version

Page 9 of 11

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

— Electronic Version

Page 10 of 11 

## 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.

Startup, shutdown and malfunction events: #1 Ni tric Acid approximately 98 lb/hr; #2 Nitric Acid approximately 102 lb/hr

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

### or NH 3 

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

Startups approximately 1 hour in duration. Shutdowns approximately 30 minutes in duration. Malfunction events are more variable, but usually no longer than 2 hours.

3. Please describe any equipment or work practices 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.

Clear and concise Standard Operating Procedures, well trained operators and well maintained equipment minimize the duration of excess/elevated NOx emissions which occ ur during startup, shutdown and malfunction events. Flooding the absorber tower with clean condensate results in reduced emissions on startup.

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

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Page 11 of 11 

## Emission Testing

1

. Include emissions testing conducted during 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

follow ing modifications for nitric acid plants. Because of the propensity of NO 2 

### to be absorbed by water, the sampled gas must not contact any condensate, and the efficiency of any NO 2 

### 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 a nd 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 system bias checks. The alternative mentioned in Section 8.6 to follow the dynamic spike pro cedure 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 concent ration is at or below the applicable method’s detection level, then provide information about the method (title and source), t he 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

.