Date: May 2012

Subject: Review of PCS Nitrogen NOX CEMS data

Nitric Acid NSPS Review

EPA Contract No. EP-D-11-084; Work Assignment No. 0-01 

RTI Project No. 02103199.000.001

From: Melissa Icenhour

To: Nathan Topham

OAQPS/SPPD/MICG (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 supplied CEMS 

data from the PCS Nitrogen plant in Augusta, Georgia where there are two nitric acid trains (C1 

and C2) which were modified in 2003 and 2009.

The 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 NOX CEMS data from nine nitric acid plants 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 NOX CEMS data from 

other nitric acid plants. No additional 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 the delayed receipt of the data, the EPA conducted a preliminary review of the data, 

which indicated a few underlying issues that contribute to higher nitrogen oxide (NOX) 

emissions from this nitric acid plant. Neither of the nitric acid production trains employs 

extended absorption, although both units have NOX 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 these trains such that they 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 NOX per ton of 

100% nitric acid (lb NOX/ton acid) instead of the Subpart Ga standard of 0.50 lb NOX/ton acid. 

There is no indication that these 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 

the 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 Air Quality Act, O.C.G.A. Section 12-9-1, et seq and the Georgia 

Rules for Air Quality Control, Chapter 391-3-1, adopted pursuant to and in effect under the Act, the Permittee 

described above is issued a construction permit for: 

 The modification of the C-001 Nitric Acid Plant and the installation of a Selective Catalytic Reduction (SCR) 

system to reduce NOx emissions. 

This Permit Amendment shall also serve as a final amendment to the Part 70 Permit unless objected to by the U.S. 

EPA or withdrawn by the Division. The Division will issue a letter when this Operating Permit amendment is 

finalized. 

This Permit Amendment is conditioned upon compliance with all provisions of The Georgia Air Quality Act, 

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. 2873-245-0002-V-02-0. Unless modified or revoked, this 

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 Director 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 applications 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 submittal or 

supporting data; or for any alterations affecting the emissions from this source. 

This Permit Amendment is further subject to and conditioned upon the terms, conditions, limitations, standards, or 

schedules contained in or specified on the attached 5 pages. 

 

Director 

Environmental Protection Division 
Title 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 Collection) ............................... 4

5.2 Specific Monitoring Requirements ......................................................................................................4 

PART 6.0 OTHER RECORD KEEPING AND REPORTING REQUIREMENTS ................................. 5

6.1 General Record Keeping and Reporting Requirements.......................................................................5 

6.2 Specific Record Keeping and Reporting Requirements.......................................................................5 
Title 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 pieces of equipment in the C-001 Nitric Acid Plant 

and install a Selective Catalytic Reduction (SCR) system as a control device to reduce NOx 

emissions. 

Phase 1 of this project will be to install two Steinmueller converters with a higher pressure rating and 

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 modifications for the C-001 Nitric Acid Plant in Phase 2: 

install a new process condenser, modify the absorber water chiller system, upgrade the absorption 

system, replace the packing in the absorption system, upgrade of the plant instrumentation, upgrade 

of the ammonia evaporation system, upgrade of the air filtration system, upgrade of the cooler 

condenser, upgrade or replace the air compressor, repack the bleaching column, increase process air 

supply, install a washing system on the air compressor, upgrade of the ammonia-air mixer, and 

upgrade the tail gas heaters. The facility expects to start construction on Phase 2 of the project within 

24 months after issuance of the permit. 

This application is being processed as a significant modification with construction because the 

proposed project constitutes a modification under provisions 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-001 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-001 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 specifically 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 this permit may also apply to emission units listed above. 

 ** AN = Ammonium Nitrate 

 

 For determination of 391-3-1-.02(2)(e) the following 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 requirements 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 atmosphere 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 Deleted
Title 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 conducted an annual performance test for 

emissions of NOX and CO during the month of July or August as follows: 

a. NOX in the C-001 Nitric Acid Plant (Source Code N101).

[40 CFR 60 Subpart G] 

b. NOX 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 N201). 

[40 CFR 52.21] 

4.2.14 Within 60 days after the completion of all of the projects and achieving the maximum 

production rate of nitric acid from the C-001 Nitric 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 particulate matter from the C-001 AN 

Neutralizer. If necessary, the Permittee shall submit an application, within 90 days after 

submittal of the test report, to revise the excursion 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 Data Collection) 

5.2 Specific Monitoring Requirements 

5.2.2 The Permittee shall install, calibrate, maintain, and operate a system to continuously 

monitor and record the indicated parameters on the following equipment. Where such 

performance specification(s) exist, each system shall meet the applicable performance 

specification(s) of the Division's monitoring requirements. 

[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 performance criteria listed in the table below for the 

NOx emissions from the C-001 Nitric Acid Plant (Source Code N101). 

[40 CFR 64.6(c)(1)(iii)]

Performance Criteria 

[64.4(a)(3)] 

Indicator No. 1 

NOX Concentration 

Data Representativeness 

[64.3(b)(1)] NOX 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)] 

NOX concentration (ppm) will be converted to lb NOX per 

ton 100% nitric acid using the conversion factor calculated 

from the most recent NOX stack test. NOX emissions will 

be calculated hourly by multiplying the actual production 

rate by the lb NOX per ton 100% nitric acid emission rate. 

Averaging Period 

[64.3(b)(4)] 

3.0 lb NOX per ton 100% nitric acid – 3 hour average 

5.2.18 Within 60 days of issuance of this permit, the Permittee shall submit a monitoring plan for 

ammonia emissions on the Selective Catalytic Reduction (SCR) System (Source Code: 

C101). This plan will also determine appropriate excursion 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 REQUIREMENTS 

6.1 General Record Keeping and Reporting Requirements 

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 emissions, 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 this 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 applicable requirement) 

2. For the C-001 Nitric Acid Plant, Nitrogen Oxide emissions, expressed as NO2, 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 Requirements 

6.2.22 The Permittee shall provide written notice of 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 within 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