Enclosure 5a

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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 in 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 Hours/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

NOX 97.6 (design basis) N/A N/A

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

NO2 99.2 (design basis) N/A N/A
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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Permit Limits for Each Nitric Acid Production Line

(Fill in all applicable rows)

Line 1 Line 2 Line 3

NOX Emissions (tpy) 70.2 N/A N/A

 NOX Emissions (lb/hr) 23.0 N/A N/A

NOX Emissions (lb/ton of 100% 

acid)

3.0 (NSPS Subpart G)

2.0 (30 TAC Chapter 17) N/A N/A

Permitted NOX 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

NH3 Emissions (tpy) 25.6 N/A N/A

NH3 Emissions (lb/hr) 5.9
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters 

Extended Absorption (Nitric Acid Production Line Name)

Length 164 feet

Design Information 

(gal/ 10 3acfm, 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 original design.

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen 

peroxide) N/A, no 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)—Electronic Version

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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 (m3) 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 inspections.

Year began operation 1999
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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For each control device, please provide the key design parameters

NSCR (Nitric Acid Production Line Name)

Reductant used (methane, H2, etc) N/A, plant does not use NSCR.

Rate of reductant used N/A

Type of catalyst N/A

Catalyst Volume (m3) 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)—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)

Nitric Acid Plant NOx SCR $933,243 (2009) $467,979 (2008)

Please provide additional cost information, comments, or notes below:
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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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-02445

Description of sample extraction and 

conditioning or dew point 

maintenance systems Extraction with heated sample line.

Ability to distinguish between NO 

and NO2? Yes

Identify all periods of startup, 

shutdown, 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)—Electronic Version

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CEMS Data (Monthly and Annual)

Include monthly and annual NOX CEMS data for the last 3 years. Please submit the CEMS 

data electronically. 

CERMS data for NOx (2007 through 2009) and NH3 (2005 through 2009) 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) dated 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 control 

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 fluctuations 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 principle 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 provide recommendations on the revisions you would like to see in this NSPS.
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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No comment.

Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NOX or NH3 expected during a startup, 

shutdown, and malfunction event. 

*NOx – the maximum level of NOx emissions during a startup, shutdown, or malfunction event 

is not expected to exceed the permitted limit of 23.0 lb/hr.

NH3 - the maximum level of NH3 emissions during a startup, shutdown, or malfunction event 

is not expected to exceed 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 NOX or NH3 will typically occur during 

a startup, shutdown, and malfunction event. 

See note above. Excess/elevated NOx and NH3 emissions do not typically occur during SSM 

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

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3. Please describe any equipment or work practices that are employed to minimize or eliminate 

the quantity or duration of excess/elevated emissions of NOX or NH3 during startup, 

shutdown, and malfunction events. 

As stated in response to Questions 1 and 2 above, excess/elevated NOx and NH3 emissions do 

not typically 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

008 Operation at 60% Rates

009 Acid Truck Loading

010 Acid Truck Unloading

011 Acid Mixing 98%

012 Transfer Between Trucks

013 Product Delivery

014 NOx Scrubber

015 Waste Water Neutralization

2016 NH3 Truck/Skid Unloading Operation
EPA Information Collection Request for Nitric Acid NSPS (Subpart G)—Electronic Version

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In response to the EPA’s request for Emission Testing data below, RATA results comparing 

reference method data to CERMS data is included in Attachment B1 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 NOX, and 

NH3. 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 NOX) data can be submitted, but only if the testing was performed with the 

following modifications for nitric acid plants. Because of the propensity of NO2 to be 

absorbed by water, the sampled gas must not contact any condensate, and the efficiency of 

any NO2 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 and documentation required 

by the method, both prior to and following sampling. NO2 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 in Section 16.1 is acceptable, but only 

with NO2 spike gas. The dynamic spiking procedure is strongly recommended.

4. If you do not have emission test data for NOX 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 

NOX emissions following one of the approved methods above.

5. If you do not have emission test data for NH3, 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 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 

determining the detection level.

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