To: Bill Neuffer/RTP/USEPA/US@EPA
From: Larry Fitzwater <LFitzwater@lsb-okc.com>
Date: 01/16/2012 04:00PM
Cc: "Gershman, Lorraine" <Lorraine_Gershman@americanchemistry.com>
Subject: Nitric Acid 30-Day Rolling Average Data for NSPS Background
(See attached file: El Dorado Weak Acid Air Permit Section.pdf)
(See attached file: Cherokee Weak Acid Air Permit Section.pdf)
(See attached file: 2011 Cherokee Nitrogen #2 Acid Plant NOx Background Data for EPA NSPS.xlsx)
(See attached file: DMW hourly data with 30 day rolling 2011 FINAL (LP) (2).xlsx)
(See attached file: East hourly data with 30 day rolling 2011 FINAL BP.xlsx)
(See attached file: EPA 011312 Extended absorbtion.pdf)
(See attached file: Nitric Acid Info to Bill Neuffer at EPA 1-16-2012.docx)

Bill,

Here are the data files we promised to provide as background to our comments for the proposed nitric acid NSPS standard.

*         Excerpts of the current Title V air permits for the referenced units are included.

*         The Cherokee No.2 nitric acid unit and the El Dorado DMW nitric acid unit are Weatherly technology mono-pressure plant with extended absorption but no tertiary NOx abatement.   

*         The El Dorado East and West nitric acid units are C&I Girdler Technology mono-pressure units with SCRs.  The NOx data for these units are emission levels after SCR treatment.  The NOx levels prior to the SCR are typically in excess of 3,000 ppmv.

*         The data are for tail gas stack emissions only and do not include the fugitives, storage and shipment facilities, etc.

*         We did not submit data for our No.1 Cherokee acid unit (idle in 2011), the El Dorado Direct Strong Nitric (DSN) acid plant which uses Uhde technology to produce 98+% nitric acid, the Pryor Chemical Facility or the El Dorado Nitrogen Facility in Baytown, TX which EPA cites in the proposed NSPS.

*         The Cherokee facility only had time to do daily data.  PPMV NOx to pounds conversions are estimated by factor based on the most recent RATA test stack flow factor.  They do not have a stack flow meter.

*         The El Dorado facility has volumetric flow rate monitoring in the nitric acid tail gas stacks and used that data to convert from PPMV NOx to pounds.  They had hourly data readily available.

Please call me if you have any questions.   We appreciate your willingness to consider this additional data.

Larry



CONFIDENTIALITY NOTICE:  This e-mail message and any attachments may contain confidential and privileged information intended solely for the addressee.  Please do not open any attachments or read, copy, disclose or disseminate this e-mail or any attachments unless you are the addressee.  If you have received this transmission in error, please call immediately at (314) 991-2853 and ask to speak with the message sender.  Also, please forward the message and any attachments back to the message sender and delete this transmission from your system.  No waiver of any attorney-client or work product privilege is intended by the transmission of this message or any attachments.

