Date: May 2012

Subject: Review of PCS Nitrogen NO X CEMS data

Nitric Acid NSPS Review
EPA Contract No. EP

- D

- 11

- 084; Work Assignment No. 0

- 0 1 RTI Project No. 02103199.000.001

From: Melissa Icenhour

To: Natha n Topham

OAQPS/SPPD/M IC G (D243

- 02) U. S. Environmental Protection Agency Research Triangle Park, NC 27711

In response to the teleconference detailed in the memo entitled Teleconference with The
Fertilizer Institute on March 15, 2012 dated May 2012, The Fertilizer Institute supp lied CEMS data from the PCS Nitrogen plant in Augusta, Georgia where t here are two nitric acid trains (C1 and C2) which were modifi ed in 2003 and 2009

.

T he CEMS data were not received until April 2, 2012, which was well past the time when it

could be thoroughly evaluated for the final rule. Given the court

- ordered signature date of May
14, 2012, there was insufficient time to analyze the data and to incorporate into the final rulemaking package.

The EPA gathered NO X CEMS data from nine nitric acid pla nts in early 2010 through a section 114 information collection request (ICR). The EPA solicited industry’s input on the selection of these plants and gave industry ample opportunities to voluntarily submit NO X CEMS data from other nitric acid plants. No ad ditional CEMS data were received from the PCS Augusta plant

before or during the public comment period. Had the EPA received these data from industry in a timely manner, the data would have been analyzed and incorporated into the rulemaking.

Despite th e de layed receipt of the data , the EPA conducted a preliminary review of the data,

which indicate d a few underlying issues that contribute to higher nitrogen oxide ( NO X )

emissions from this nitric acid plant . Neither of the nitric acid production trains employs extended absorption , although both units have NO X control. The C1 train is controlled by selective catalytic reduction ( SCR ) and the C2 train is controlled by nonselective catalytic reduction (NSCR).If further modifications are made to th ese train s such that the y become subject to Subpart Ga,

emissions reductions could be improved by employing extended absorption on both trains

.
Also, the SCR was designed to meet the Subpart G standard of 3.0 pounds of NO X per ton of 100% nitric acid (lb NO X /ton ac id) instead of the Subpart Ga standard of 0.50 lb NO X /ton acid.

There is no indication that th ese nitric acid production trains could not achieve the lower

emission limit if they were modified in the future through upgrades to existing control devices or

t he addition of further controls

.

# Part 70 Operating Permit Amendment

Permit Amendment No.: 

### 2873-245-0002-V-02-1 Effective Date: March 26, 2007

Facility Name: 

### PCS Nitrogen Fertilizer – Augusta Plant

Facility Address: 733 1⁄2 Laney Walker Blvd Extension Augusta, Georgia 30901, Richmond County

Mailing Address: P.O. Box 1483 Augusta, Georgia 30903

Parent/Holding Company: PotashCorp

Facility AIRS Number: 04-13

- 245-00002

In accordance with the provisions of the Georgia Ai r Quality Act, O.C.G.A. Section 12-9-1, et seq and the Georgia Rules for Air Quality Control, Chapter 391-3-1, ado pted pursuant to and in effect under the Act, the P ermittee described above is issued a construction permit for :

The modification of the C-001 Nitric Acid Plant an d the installation of a Selective Catalytic Reducti on (SCR) system to reduce NOx emissions.

This Permit Amendment shall also serve as a final a mendment to the Part 70 Permit unless objected to b y the U.S. EPA or withdrawn by the Division. The Division wil l issue a letter when this Operating Permit amendme nt is finalized.

This Permit Amendment is conditioned upon complianc e with all provisions of The Georgia Air Quality Ac t, O.C.G.A. Section 12-9-1, et seq, the Rules, Chapter 391-3-1, adopted and in effect under that Act, or any other condition of this Permit Amendment and Permit No. 2 873-245-0002-V-02-0. Unless modified or revoked, t his Permit Amendment expires upon issuance of the next Part 70 Permit for this source.

This Permit Amendment may be subject to revocation, suspension, modification or amendment by the Direc tor for cause including evidence of noncompliance with any of the above; or for any misrepresentation made in Application No. 16989 dated October 10, 2006; any other applica tions upon which this Permit Amendment or Permit No . 2873- 245-0002-V-02-0 are based; supporting data entered therein or attached thereto; or any subsequent subm ittal or supporting data; or for any alterations affecting t he emissions from this source.

This Permit Amendment is further subject to and con ditioned upon the terms, conditions, limitations, s tandards, or schedules contained in or specified on the attached 5 pages.

Director Environmental Protection DivisionTitle V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 i 

### Table of Contents

PART 1.0 FACILITY DESCRIPTION...............................

................................................... ................. 1 1.3 Process Description of Modification............

................................................... .....................................1 PART 3.0 REQUIREMENTS FOR EMISSION UNITS....................

................................................... .. 2
3.1.1 Modification to Emission Units ...............

................................................... .........................................2 3.3 Equipment Federal Rule Standards...............

................................................... ....................................2 3.5 Equipment Standards Not Covered by a Federal or SIP Rule and Not Instituted as an Emission Cap or Operating Limit.................................

................................................... ............................................2 PART 4.0 REQUIREMENTS FOR TESTING ...........................

................................................... ........ 3 4.2 Specific Testing Requirements ..................

................................................... .......................................3 PART 5.0 REQUIREMENTS FOR MONITORING (Related to Data Collec tion) ............................... 4 5.2 Specific Monitoring Requirements ...............

................................................... ....................................4 PART 6.0 OTHER RECORD KEEPING AND REPORTING REQUIREMENTS .... ............................. 5 6.1 General Record Keeping and Reporting Requiremen ts................................................. ......................5 6.2 Specific Record Keeping and Reporting Requireme nts................................................ .......................5Title V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 Page 1 of 5 PART 1.0 FACILITY DESCRIPTION

1.3 Process Description of Modification

The facility proposes to install or modify some pie ces of equipment in the C-001 Nitric Acid Plant and install a Selective Catalytic Reduction (SCR) s ystem as a control device to reduce NOx
emissions.

Phase 1 of this project will be to install two Stei nmueller converters with a higher pressure rating a nd to install the Selective Catalytic Reduction (SCR) system. The installation of the SCR unit will greatly reduce NOx emissions from the C-001 Nitric Acid Plant.

The facility will perform the following modificatio ns for the C-001 Nitric Acid Plant in Phase 2: install a new process condenser, modify the absorbe r water chiller system, upgrade the absorption system, replace the packing in the absorption syste m, upgrade of the plant instrumentation, upgrade of the ammonia evaporation system, upgrade of the a ir filtration system, upgrade of the cooler condenser, upgrade or replace the air compressor, r epack the bleaching column, increase process air supply, install a washing system on the air compres sor, upgrade of the ammonia-air mixer, and upgrade the tail gas heaters. The facility expects to start construction on Phase 2 of the project wit hin 24 months after issuance of the permit.

This application is being processed as a significan t modification with construction because the proposed project constitutes a modification under p rovisions of New Source Performance Standards. The facility is replacing or modifying most of the process units in the Nitric Acid Plant, and it will qualify as a reconstruction under NSPS. Thus, the C -001 Nitric Acid Plant will become subject to 40 CFR 60 Subpart G.

The pre-modification production capacity of the C-0 01 Nitric Acid Plant is 585 tpd 100% nitric acid. The post-modification capacity will be 700 tpd 100% nitric acid.

This proposed project only affects equipment in C-0 01 Nitric Acid Plant, and no changes will be
made in C-002 Nitric Acid Plant.Title V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 Page 2 of 5 PART 3.0 REQUIREMENTS FOR EMISSION UNITS

Note: Except where an applicable requirement specif ically states otherwise, the averaging times of any of
the Emissions Limitations or Standards included in this permit are tied to or based on the run time(s) specified for the applicable reference test method(s) or procedures required for demonstrating compliance.

3.1.1 Modification to Emission Units

Emission Units Specific Limitations/Requirements Air Pollution Control Devices

ID No. Description Applicable Requirements/Standards Corresponding Permit
Conditions ID No. Description

N101 C-001 Nitric Acid Plant 40 CFR 60 Subpart G

40 CFR 64 3.3.4, 3.3.5, 4.2.2, 4.2.8, 4.2.14, 5.2.1, 5.2.2, 5.2.5, 5.2.8, 5.2.18, 6.1.7, 6.2.22 C101 Selective Catalytic Reduction (SCR) System

AN01 C001 AN Neutralizer 391-3-1-.02(2)(b) 391-3-1-.02(2)(e)†

40 CFR 64 3.4.2, 3.4.6, 4.2.14

, 5.2.3. 5.2.5, 5.2.11, 6.1.7 VS01 Venturi Scrubber

* Generally applicable requirements contained in t his permit may also apply to emission units listed above.
** AN = Ammonium Nitrate

For determination of 391-3-1-.02(2)(e) the followi ng Emission Units are to be grouped: Group † A103, A104, A105 & AN01 Group ‡ A201, A202, A204 & AN02

3.3 Equipment Federal Rule Standards

3.3.4 The C-001 Nitric Acid Plant (Source Code N101 ) and the C-002 Nitric Acid Plant (Source Code N201) are subject to all applicable requiremen ts of the Federal Standards of Performance for New Stationary Sources, 40 CFR Part 60, Subpart G - “Standards of
Performance for Nitric Acid Plants”. [40 CFR 60 Subpart G]

3.3.5 The Permittee shall not discharge into the at mosphere from the C-001 Nitric Acid Plant (Source Code N101) and the C-002 Nitric Acid Plant (Source Code N201) any gases which contain nitrogen oxides in excess of 3.0 pounds per ton of 100% nitric acid and which exhibit 10 percent opacity, or greater. [40 CFR 60 Subpart G, 40 CFR 52.21]

3.5 Equipment Standards Not Covered by a Federal or SIP Rule and Not Instituted as an Emission Cap or Operating Limit

3.5.1 DeletedTitle V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 Page 3 of 5 PART 4.0 REQUIREMENTS FOR TESTING

4.2 Specific Testing Requirements

4.2.2 The Permittee shall conduct or cause to be co nducted an annual performance test for
emissions of NO X and CO during the month of July or August as follo ws:

a. NO X in the C-001 Nitric Acid Plant (Source Code N101). [40 CFR 60 Subpart G]

b. NO X in the C-002 Nitric Acid Plant (Source Code N201). [40 CFR 60 Subpart G, 40 CFR 52.21]

c. CO in the C-002 Nitric Acid Plant (Source Code N 201). [40 CFR 52.21]

4.2.14 Within 60 days after the completion of all o f the projects and achieving the maximum production rate of nitric acid from the C-001 Nitri c Acid Plant, but no later than 180 days after startup of the C-001 Nitric Acid Plant after the completion of all of the projects, the Permittee shall conduct a performance test for part iculate matter from the C-001 AN Neutralizer. If necessary, the Permittee shall sub mit an application, within 90 days after submittal of the test report, to revise the excursi on values for the VS01 Venturi Scrubber. [391-3-1-.02(3), 391-3-1-.03(2)(c)]Title V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 Page 4 of 5 PART 5.0 REQUIREMENTS FOR MONITORING (Related to Da ta Collection)

5.2 Specific Monitoring Requirements

5.2.2 The Permittee shall install, calibrate, maint ain, and operate a system to continuously monitor and record the indicated parameters on the following equipment. Where such performance specification(s) exist, each system sha ll meet the applicable performance specification(s) of the Division's monitoring requi rements. [391-3-1-.02(6)(b)1 and 40 CFR 70.6(a)(3)(i)]

f. Nitric Acid production rate for the C-001 Nitric Acid Plant (Source Code N101).

5.2.8 The Permittee shall comply with the performan ce criteria listed in the table below for the NOx emissions from the C-001 Nitric Acid Plant (Sou rce Code N101). [40 CFR 64.6(c)(1)(iii)]

Performance Criteria [64.4(a)(3)] Indicator No. 1

NO X Concentration

Data Representativeness [64.3(b)(1)] NO X Continuous Emissions Monitor. The CEM is located
in the C-001 Nitric Acid Stack.

Verification of Operational Status (new/modified monitoring equipment only) [64.3(b)(2)] N/A.

QA/QC Practices and Criteria [64.3(b)(3)] Calibrate, maintain, and operate CEM per equipment
manufacturer.

Monitoring Frequency [64.3(b)(4)] Continuous.

Data Collection Procedures [64.3(b)(4)] NO X concentration (ppm) will be converted to lb NO X per ton 100% nitric acid using the conversion factor ca lculated
from the most recent NO X stack test. NO X emissions will be calculated hourly by multiplying the actual prod uction rate by the lb NO X per ton 100% nitric acid emission rate.

Averaging Period [64.3(b)(4)] 3.0 lb NO X per ton 100% nitric acid – 3 hour average

5.2.18 Within 60 days of issuance of this permit, t he Permittee shall submit a monitoring plan for ammonia emissions on the Selective Catalytic Reduct ion (SCR) System (Source Code: C101). This plan will also determine appropriate ex cursion values for the operating parameters (inlet temperature, outlet temperature, etc.) for the proper operation of the SCR.Title V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 Page 5 of 5 PART 6.0 OTHER RECORD KEEPING AND REPORTING REQUIRE MENTS

6.1 General Record Keeping and Reporting Requiremen ts

6.1.7 For the purpose of reporting excess emissions , exceedances or excursions in the report required in Condition 6.1.4, the following excess e missions, exceedances, and excursions shall be reported: [391-3-1-.02(6)(b)1 and 40 CFR 70.6(a)(3)(i)]

a. Excess emissions: (means for the purpose of thi s Condition and Condition 6.1.4, any condition that is detected by monitoring or record keeping which is specifically defined, or stated to be, excess emissions by an ap plicable requirement)

2. For the C-001 Nitric Acid Plant, Nitrogen Oxide emissions, expressed as NO 2 , in excess of 3 pounds per ton of 100% nitric acid produced for greater than 3 hours. [40 CFR 60 Subpart G]

6.2 Specific Record Keeping and Reporting Requireme nts

6.2.22 The Permittee shall provide written notice o f the date of completion of the Phase I projects and the Phase II projects. The notifications shall include a list of the projects completed during each phase. The notices shall be provided w ithin 30 days of the completion of each phase.Title V Permit Amendment PCS Nitrogen Fertilizer – Augusta Plant Permit No.: 2873-245-0002-V-02-1

Printed: March 29, 2007 Appendix Page 1 of 1