  SEQ CHAPTER \h \r 1 Date:		May 2012

Subject:	Teleconference with American Chemistry Council on January 11,
2012

		Nitric Acid NSPS Review

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

RTI Project No. 0213199.000.001

From:			Melissa Icenhour

				

To:			Nathan Topham

OAQPS/SPPD/MICG (D243-02)

U. S. Environmental Protection Agency

Research Triangle Park, NC  27711

A conference call was held on January 11, 2012 to discuss monopressure
nitric acid plants and how they differ from the dual pressure plants
used in EPA’s review of the New Source Performance Standards (NSPS)
for Nitric Acid plants (40 CFR Part 60, Subpart G). The meeting
attendees included:

EPA

Chuck French, EPA, OAQPS, SPPD, Metals and Inorganic Chemicals Group

Nathan Topham, EPA, OAQPS, SPPD, Metals and Inorganic Chemicals Group

Bill Neuffer, EPA, OAQPS, SPPD, Metals and Inorganic Chemicals Group

Nathan Frank, EPA, Region V

American Chemistry Council (ACC)

	Lorraine Gershman, ACC

	Larry Fitzwater, LSB Industries

	David Emerson, Air Products

	Desi Chari, Dow

	Rick Vickery, DuPont

EPA Support Contractor:

Melissa Icenhour, RTI International

Purpose:  	

The purpose of the meeting was to listen to concerns from ACC
representatives as to whether the proposed standard is achievable by
monopressure plants and discuss the data that ACC voluntarily offered to
supply. 

Discussion:

	According to the ACC members, monopressure plants are smaller than dual
pressure plants and are not usually controlled. The nitric acid from
monopressure plants is usually used as intermediaries for other chemical
processes instead of being used to manufacture fertilizer.

	The ACC reiterated the comments of ACC and some of its individual
member companies on a number of topics, including the achievability of
the standard for small monopressure plants and the potential problems
associated with hydrogen peroxide injection. The ACC member companies
stated that they would provide the EPA with data from small,
monopressure nitric acid facilities. The ACC member companies indicated
that they would attempt to provide those data by January 16, 2012.

	

   

