### Enclosure 5a

Page 1 of 11 

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

Plant Data

Facility name El Dorado Nitrogen, L. P.

Facility owner (ultimate parent owner) LSB Chemical Corporation

Plant Location

- Address PO Box 2469

Latitude/Longitude for Plant 29 ° 45’ 46” / 094° 54’ 36”

Describe location of latitude/longitude Center of Plant

City, State, ZIP code Baytown, TX 77522

Year plant began operation 1999

Information for Each Nitric Acid Production Line

(change names as needed and use the same names i n the Excel spreadsheet)

Line 1 Line 2 Line 3

Year line began operation 1999 N/A N/A

Production Rate (Tons/Day of

100% Acid) 1,515 N/A N/A

Production Rate Range (Tons/Day of 100% Acid) 1,400

– 1,600 N/A N/A

Subject to Subpart G? Yes N/A N/A

Process Type ( high/low pressure) dual N/A N/A

Oxidation pressure (psia) 74.2 N/A N/A

Absorption pressure (psia) 150.7 N/A N/A

% Acid strength Typically Produced 65 N/A N/A

Operating Hour s /Year Line 1 Line 2 Line 3

2008 2009 7,410 N/A N/A

2007 2008 7,638 N/A N/A

2006 2007 8,045 N/A N/A

Control Technology
(list as many as applicable) Extended Absorption

w/ SCR Unit N/A N/A

N/A N/A

% Control Efficiency (based on most

recent compliance test) Line 1 Line 2 Line 3

NO X 97.6 (design basis) N/A N/A

NO 96.5 (design basis) N/A N/A

NO 2 99.2 (design basis) N/A N/A

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

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Page 2 of 11 Permit Limits for Each Nitric Acid Production Line

(F ill in all applicable rows)

Line 1 Line 2 Line 3

NO X Emissions (tpy) 70.2 N/A N/A

NO X Emissions (lb/hr) 23.0 N/A N/A

NO X Emissions (lb/ton of 100% acid) 3.0 (NSPS Subpart G)
2.0 (30 TAC Chapter 17) N/A N/A

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

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

NH 3 Emissions (tpy) 25.6 N/A N/A

NH 3 Emissions (lb/hr) 5.9

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

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Page 3 of 11 

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

Extended Absorption (Nitric Acid Production Line Name )

Length 164 feet

Design Information
(gal/ 10 3 acfm, etc) Inlet gas

– 102,966.3 scfm

Inlet water

– 19,352.7 lb/hr

Inlet weak acid

– 83,484.4 lb/hr

Operation and Maintenance required

(Last 10 years) See Attachment A

.

Year absorption capacity was added None added; plant operating per o riginal design.

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen

peroxide) N/A , n o additive used.

Concentration of additive (%): N/A

Explain the process: N/A

Addition rate (gallons per hour): N/A

Ratio of additive to water: N/A

### 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 Grand Paroisse

– GP RN 15

Is Catalyst New or Regenerated? New

Catalyst Life (Design/Actual) 10 years/actual unknown

Catalyst Volume (m 3 ) 6.0

Flow rate (scfm) 95,676 (design); actual maximum ~ 119,595

Ammonia injection rate (lb/hr) 100 lb/hr

– 300 lb/hr

Operation and Maintenance required

(Last 10 years) Replaced catalyst in 2002 due to overheating; added catalyst periodically

due to settling; performed inspec tions.

Year began operation 1999

### 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) N/A, plant does not use NSCR.

Rate of reductant used N/A

Type o f catalyst N/A

Catalyst Volume (m 3 ) N/A

Flow rate (scfm) N/A

Is Catalyst New or Regenerated? N/A

Catalyst Life (Design/Actual) N/A

Operation and Maintenance required

(Last 10 years) N/A

Year began operation N/A

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

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Page 6 of 11 

## Cost Informa tion by Control Technology

Pro duction Line Pollutant
Controlled Control

Technology Capital

(Yr of Cost basis) Annual O & M

(Yr of cost basis)

Nitric Acid Plant NO

x SCR $933,243 (2009) $467,979 (2008)



### Plea se provide additional cost information, comments, or notes below:

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

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Page 7 of 11 

## Continuous Emission Monitoring Systems

CEMS Information

? Plant CEMS data recorded concurrent with test runs (i.e.,

concentration, etc.). RATA results are included in Attachments B1 through B5 for 2005

through 2009, respectively. Results compare RATA reference method

data to CERMS data. RATA reference method approved by EPA and TCEQ (documentation included in Attachment C ).

CEMS Manufacturer Kurz Instruments (Thermal Resistance Mass Flow)

AQA, dba Gasmet

- USA (FTIR) CERMS

CEMS Model Number Kurz Flow Monitor

– 155A
AQA, dba Gasmet

- USA FTIR CERMS

– FXS

- 024 45

Description of sample extraction and

conditioning or dew point maintenance systems Extraction with heated sample line.

Ability to distinguish between NO

and NO 2 ? Yes

I dentify all periods of startup,

s hutdown, and malfunction, regardless of whether the event

caused an exceedence (during the

past 3 years) 2007

– 39.55 hours

2008

– 8.77 hours

2009

– 37.26 hours

Capital costs $94,000

Operation and Maintenance costs $13,448 per year

Cost of quarterly audits $7,605 per year (includes CGAs and RATAs)

Year began operation 1999

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

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Page 8 of 11 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

.

CERMS data for NO

x 

### (2007 through 2009) and NH 3 

### (2005 through 200 9) is included on compact disk in Attachments D1 and D2 , respectively. TCEQ air permit conditions for operating the CERMS are included in Attachment E1 , including an example copy of EDN’s AQA Monthly Inspection form (i.e., CERMS Maintenance Checklist) dat ed December 8, 2009 (included as Attachment E2 ).



## 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 co ntrol efficiency in existing control devices, energy efficiency

.

Demand for nitric acid has been up and down. Projects have been installed to lower operating turndown production capability and to increase production capability; observed business

related f luctuations over the last 3 years; significant production variability on a day by day

basis.

Generally, because no new nitric acid plants have been slated to be built in over 10 years, the age of existing plant technology/equipment has been the principl e factor in developing control strategies.

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.

Plant continues to perform projects and purchase spare equipment to increase reliability. Maintenance cost change based on scheduled versus nonscheduled repairs. Over the last 3 years: cost for 2007 and 2008 was generally flat; cost doubled for 2009 primarily due to

increased ammonia costs.

3

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

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

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Page 9 of 11 

### No comment

.



## 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.

*NO

x 

### – th e maximum level of NO

x 

### emissions during a startup, shutdown, or malfunction event is not expected to exceed the permitted limit of 23.0 lb/hr.

NH 3 

### - the maximum level of NH 3 

### emissions during a startup, shutdown, or malfunction event is not expected to exc eed the permitted limit of 5.9 lb/hr.

*Based on actual data. Steam is available to EDN from industrial park sources. An Excess amount of steam is always available to support startup and shutdown operations including those that are unplanned. That is, excess steam ensures that the SCR Unit remains fully operational during SSM events. This unique circumstance limits the potential for emissions above permit limits, as well as the duration, during SSM events.

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

### or NH 3 

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

See note above. Excess/elevated NO

x 

### and NH 3 

### emissions do not typically occur during SSM

events.

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

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Page 10 of 11 

### 3. Please describe any equipment or work practices that are employed to minimize or eliminate the quantity or duration of excess/elevated emissions of NO X 

### or NH 3 

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

As stated in response to Questions 1 and 2 above, excess/elevated NO

x 

### and NH 3 

### emissions do
not ty pically occur during SSM events due to the consistent availability/operation of the SCR Unit. In addition to the operation of the add

- on control unit, EDN has implemented standard operating procedures (SOP), which work to minimize elevated emission levels during SSM events. These SOPs are listed in the following table.

SOP

Number SOP Title

001 General

002 Acid Plant Startup

003 Planned Shutdown

003 Emergency Shutdown

005 Normal Operation

006 List of Alarm and Deviations

007 Turnaround Shutdown

00 8 Operation at 60% Rates

009 Acid Truck Loading

010 Acid Truck Unloading

011 Acid Mixing 98%

012 Transfer Between Trucks

013 Product Delivery

014 NO

x 

### Scrubber

015 Waste Water Neutralization

2 016 NH 3 

### Truck/Skid Unloading Operation

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

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Page 11 of 11 

### In response t o the EPA’s request for Emission Testing data below, RATA results comparing

reference method data to CERMS data is included in Attachment B 1 through B5 for 2005 through 2009. Additionally, EDN is providing the complete RATA reports for 2005 through 2009, as discussed with Bill Neuffer (EPA Emission Standards Division) on March 23, 2010. The RATA reports are included in Attachments F1 through F5

.


## 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 following modi fications 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

dete rmined 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 extr active 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 docum entation 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 procedure i n 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 mu st 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 i s 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

deter mining the detection level.

7

. Additional stack testing guidance is contained in Enclosure 7

.