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Date: December 15, 2010 (Updated July 27, 2011)

Subject: Impacts of Nitric Acid NSPS Review—NOX

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

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 

Environmental 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 

into 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 Section 114 authority to obtain NOX

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

also collected cost data for NOX abatement technologies, including nonselective catalytic 

reduction (NSCR), selective catalytic reduction (SCR), and H2O2 injection. Cost data were

received from 9 facilities with a total of 12 nitric acid production trains. This information was 

summarized in Summary of Cost Data Received from Section 114 ICR (NOX Summary) dated 

November 22, 2010. The capital recovery factor was based on 7% interest and 15 year useful 

life.

The purpose of this memo is to calculate the expected cost impacts for new sources to meet a 

standard of 0.5 lb NOX/ton nitric acid or 1.9 lb NOX/ton nitric acid.
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The NOX Summary memo contained production data ranging from 40 tons per day (tpd) to 1,600 

tpd of nitric acid. The data supports the use of two model plants to represent the nitric acid 

production industry. The first model plant is 300 tpd and the second model plant is 1,000 tpd. In 

the NOX Summary memo, the cost data were normalized based on the production rate at the 

facility (cost per ton of nitric acid produced). Table 1 shows the results of the cost data analysis 

for NOX control.

Table 1. Normalized NOX Control Costs by Model Plant

Control 300 tpd ($/ton) 1,000 tpd ($/ton)

NSCR $20.02 $7.80

SCR $3.93 $1.10

H2O2 $2.06 $1.36

Nitric acid production was estimated for 2006 (TSD for Greenhouse Gas Reporting Rule), using 

the production growth of 6.5% from 2006 to 2007 (ICIS) and the predicted production growth 

rate of 3% for 2007 through 2016 (ICIS). These estimates are shown in Table 2. In the period 

from 2010 through 2016, the growth was approximately 1.6 million tons of nitric acid. 

Assuming 350 days per year, this equals approximately 4,586 tpd of nitric acid production. 

Using the model plants, the estimate of 4,586 tpd equals 2 production trains that produce 300 

tpd, and 4 production trains that produce 1,000 tpd over the five year period after promulgation.

Table 2. Nitric Acid Production Growth

Year

Nitric acid 

produced 

(metric tons)

Nitric acid 

produced (tons)

Increase

(tons)

2006 6,446,767 7,107,560 461,991

2007 6,865,806 7,569,552 227,087

2008 7,071,781 7,796,638 233,899

2009 7,283,934 8,030,537 240,916

2010 7,502,452 8,271,453 248,144

2011 7,727,526 8,519,597 255,588

2012 7,959,351 8,775,185 263,256

2013 8,198,132 9,038,441 271,153

2014 8,444,076 9,309,594 279,288

2015 8,697,398 9,588,882 287,666

2016 8,958,320 9,876,548 -------
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For the 6 new production trains predicted from 2011 to 2016, the annualized costs of controlling 

NOX emissions for the 3 types of control equipment outlined in The NOX Summary were 

calculated using the costs in Table 1. The control costs are shown in Table 3. These are the 

costs for each of the control devices in the 5th year after promulgation of these standards.

Table 3. NOX Control Costs for All New Production Trains in 2016

Model Plant (tpd)

Number of 

Plants Nitric Acid (tons) NSCR SCR H2O2

300 2 210,000 $4,204,200 $825,300 $432,600

1,000 4 1,400,000 $10,920,000 $1,540,000 $1,904,000

The production trains could use any of the three control types to control NOX emissions, as 

shown by the control efficiencies in Table 4, but we assumed that SCR would be universally 

applied. While hydrogen peroxide injection has the lowest potential costs, this control may not 

be feasible for all new production trains.

Table 4. NOX Control Efficiencies

Control Efficiency

NSCR 99%

SCR 98%

H2O2 95%

Emission Limit of 0.5 lb NOX/ton

Using the control efficiency for SCR, the potential NOX emission reductions were calculated in 

Table 5. The baseline emissions were calculated as 3.0 lb NOX/ton acid (the level of the existing 

NSPS). The controlled emissions were calculated as 0.5 lb NOX/ton acid.

Table 5. NOX Emission Reductions for All New Production Trains with SCR Control in

2016

Model 

Plant 

(tpd)

Days per 

year

Number 

of Plants

Nitric 

Acid 

(tons)

Baseline 

NOX

(lb/ton)

Controlled 

NOX

(lb/ton 

acid)

Controlled 

NOX

Emissions 

(tons)

NOX

Emission 

reductions 

(tons)

300 350 2 210,000 3.0 0.5 53 263

1,000 350 4 1,400,000 3.0 0.5 350 1,750

The last step in calculating impacts for new sources to meet the revised standard of 0.5 lb 

NOX/ton acid is to calculate the costs and reductions per year over the 5 year period after 

promulgation. In addition to control equipment, each new production train will also be required 

to install a stack gas flow monitor. The annualized cost of a stack gas flow monitor is $15,019 
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for 2nd quarter of 2010. The requirement of a NOX CEMS was included in the existing NSPS so 

its cost is not included in this analysis.

The SCR is already being used to control NOX emissions to the current NSPS level of 3.0 lb 

NOX/ton acid. As shown in Summary of Test Data Received from Section 114 ICR, dated August 

25, 2010, there are 5 production trains using SCR that already meet the proposed revised NSPS 

level of 0.5 lb NOX/ton acid. The control device costs are based on current usage where sources 

are only required to meet 3.0 lb NOX/ton. Sources are not likely to spend additional money to 

meet a limit of 0.5 lb NOX/ton acid that is not mandatory. Therefore, we believe that the lower 

limit is achievable without additional cost impacts.

Accordingly, there is no incremental control costs to control NOX emissions from the current 

NSPS limit of 3.0 lb NOX/ton acid to the proposed revised NSPS limit of 0.5 lb NOX/ton acid. 

The costs of adding stack flow monitors in the 5th year after promulgation are shown in Table 6. 

Table 6. Incremental Costs in 5th Year after Promulgation for All New Production Trains

Model 

Plant 

(tpd)

Number 

of Plants

SCR Cost

($2010-2

nd quarter)

Stack flow monitor cost

($2010-2

nd quarter)

Total Annualized Costs

($2010-2

nd quarter)

300 2 $0 $30,038 $30,038

1,000 4 $0 $60,076 $60,076

Using the total costs of SCR costs and monitoring costs, the cost effectiveness was also 

calculated. These numbers are shown in Table 7. 

Table 7. Incremental Cost Effectiveness in 5th Year after Promulgation for All New 

Production Trains

Model Plant 

(tpd)

Number of 

Plants

Total Annualized 

Costs

($2010-2

nd quarter)

NOX Emission 

reductions (tpy)

Cost

effectiveness

($/ton NOX)

300 2 $30,038 263 $114.21

1,000 4 $60,076 1,750 $34.33

For the 300 tpd model plant, total annualized costs in the 5th year after promulgation are $30,038. 

The amount of NOX reductions expected in the 5th year after promulgation is 263 tpy. This 

results in a cost effectiveness of approximately $115.

For the 1,000 tpd model plant, total annualized costs in the 5th year after promulgation are 

$60,076. The amount of NOX reductions expected in the 5th year after promulgation is 1,750 tpy. 

This results in a cost effectiveness of approximately $35.
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Emission Limit of 1.9 lb NOX/ton

Using the control efficiency for SCR, the potential NOX emission reductions were calculated in 

Table 8. The baseline emissions were 3.0 lb NOX/ton acid and the controlled level equals 1.9 lb 

NOX/ton acid.

Table 8. NOX Emission Reductions with SCR Control for All New Production Trains in 

2016

Model 

Plant 

(tpd)

Days per 

year

Number 

of Plants

Nitric 

Acid 

(tons)

Baseline 

NOX

(lb/ton)

Controlled 

NOX

(lb/ton 

acid)

Controlled 

NOX

Emissions 

(tons)

NOX

Emission 

reductions

(tons)

300 350 2 210,000 3.0 1.9 200 116

1,000 350 4 1,400,000 3.0 1.9 1,330 770

The last step in calculating impacts for new production lines to meet the revised standard of 1.9 

lb NOX/ton acid is to calculate the costs and reductions per year over the 5 year period after 

promulgation. In addition to control equipment, new sources will also be required to install a 

stack gas flow monitor. The annualized cost of a stack gas flow monitor is $15,019 per new 

production train for 2nd quarter of 2010. The requirement of a NOX CEMS was included in the 

existing NSPS so its cost is not included in this analysis.

As discussed above, the SCR is already being used to control NOX emissions to the current 

NSPS level of 3.0 lb NOX/ton acid. As shown in Summary of Test Data Received from Section 

114 ICR, dated August 25, 2010, there are 5 production trains using SCR that already meet the 

proposed revised NSPS level of 1.9 lb NOX/ton acid. Therefore, we believe that the lower limit 

is achievable without additional cost impacts.

Accordingly, there is no incremental control cost to control NOx emissions from the current 

NSPS limit of 3.0 lb NOX/ton acid to the proposed revised NSPS limit of 1.9 lb NOX/ton acid. 

The costs of adding stack flow monitors in the 5th year after promulgation are shown in Table 9. 

Table 9. Costs in 5th Year after Promulgation for All New Production Trains

Model 

Plant 

(tpd)

Number of 

Plants

SCR Cost

($2010-2

nd quarter)

Stack flow monitor 

cost

($2010-2

nd quarter)

Total Annualized 

Costs

($2010-2

nd quarter)

300 2 $0 $30,038 $30,038

1,000 4 $0 $60,076 $60,076

Using the total costs of SCR costs and monitoring costs, the cost effectiveness was also 

calculated. These numbers are shown in Table 10. 
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Table 10. Cost Effectiveness in 5th Year after Promulgation for All New Production Trains

Model 

Plant (tpd) Number of Plants

Total Annualized 

Costs

($2010-2

nd

quarter)

NOX Emission 

reductions (tpy)

Cost 

effectiveness

($/ton NOX)

300 2 $30,038 116 $258.95

1,000 4 $60,076 770 $78.02

For the 300 tpd model plant, total annualized costs in the 5th year after promulgation are $30,038. 

The amount of NOX reductions expected in the 5th year after promulgation is 116 tpy. This 

results in a cost effectiveness of approximately $260.

For the 1,000 tpd model plant, total annualized costs in the 5th year after promulgation are 

$60,076. The amount of NOX reductions expected in the 5th year after promulgation is 770 tpy. 

This results in a cost effectiveness of approximately $80.

Incremental New Source NOX Control Costs

The incremental cost of lowering the NOX emission limit from 1.9 to 0.5 is the difference in 

costs and emission reductions between the two options (Table 7 and Table 10). These are shown 

in Table 15. Our costs are only dependent on the type of control and the size of the production 

line. Both emission limits are believed to be achieved by using SCR so there is no difference in 

cost between the two options. In this case, the incremental costs between the two options are 

negligible so the lower emission limit of 0.5 lb NOX/ton is recommended.

Table 15. Incremental Cost from 1.9 lb NOX/ton to 0.5 lb NOX /ton for All New Production 

Trains

Emission Limit Cost

Emission reductions 

(NOX)

Cost effectiveness 

($/ton NOX)

0.5 $90,112 2,013 $44.78

1.9 $90,112 886 $101.76

DIFFERENCE $0 1,127 $0
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References

CEMS Cost Model. Updated March 2007. Accessed November 17, 2010.

Memorandum from M. Icenhour, RTI International, to B. Neuffer, EPA. Summary of Cost Data 

Received from Section 114 ICR. November 22, 2010.

Memorandum from M. Icenhour, RTI International, to B. Neuffer, EPA. Summary of Test Data 

Received from Section 114 ICR. August 25, 2010.

 

U. S. EPA. Technical Support Document for the Nitric Acid Production Sector: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases, January 22, 2009.

http://www.epa.gov/climatechange/emissions/archived/downloads/tsd/TSD%20Nitric%20Acid%

20_EPA%201-22-09.pdf