From:        Bill Neuffer/RTP/USEPA/US 
To:        "Gershman, Lorraine" <Lorraine_Gershman@americanchemistry.com> 
Cc:        Chuck French/RTP/USEPA/US@EPA, mkicenhour@rti.org, Nathan Topham/RTP/USEPA/US@EPA, Nathan Frank/R5/USEPA/US@EPA 
Date:        01/11/2012 04:15 PM 
Subject:        Nitric acid NSPS - Information Needed 
                                       


 Hi Lorraine, 

        We appreciated talking with you and the other representatives from the American Chemistry Council today regarding the proposed nitric acid NSPS.  As we discussed, we welcome additional data that would help us better understand your written comments regarding the performance of the smaller single pressure units.  If you submit such data, please submit the data by Monday (1/16).   Moreover, in order for the data to be most useful for our analyses, please include the following information: 

        1. Process information 
                Design Production Rate of 100% nitric acid (in tons per day) 
                Typical Production Rate (tons per day) 
                Single Pressure - 
                        Oxidation pressure (in pounds per square inch area [psia]) - 
                        Absorption pressure (psia) - 

        2. Extended absorption         
                Length (ft) - 
                Gal/1,000 ft3  - 
                Additive?   
                    If yes - name of additive - 
                        Concentration (%) - 
                        Addition Rate(gallons/hr) - 

        2. NOx continuous emission data -  we would prefer to have this data for one year, for the most recent  year that such data exist.   To save your members time and also ours, 1 year of data is satisfactory.    These data should be in terms of lb of NOx/Ton of 100% nitric acid produced.   Preferably the data should be hourly, if possible.   NOx emissions (in lb/hr) should be determined by the procedure mentioned in Subpart G - Section 60.73. 

        3. For  units controlled by SCR, please provide the following parameters: 
                Design Catalyst life (years)         
                Actual Catalyst life  (life of catalyst for the 1 yr test period) - 
                Gas Flow rate (scfm) - 
                Ammonia injection rate (lb/hr) - 
                Catalyst volume (m3) - 
                Year operation began - 
                Location of SCR (before or after gas expander) - 

        4. For  units controlled by NSCR, please provide the following parameters: 
                reductant used ( methane, purge gas, etc) 
                Rate of reductant used (ft3/hr; etc) 
                Design Catalyst life (years)         
                Actual Catalyst life  (life of catalyst for the 1 yr test period) - 
                Gas Flow rate (scfm) - 
                Catalyst volume (m3) - 
                Year operation began - 
                Location of NSCR (before or after gas expander) - 


Thanks again, 
Bill Neuffer 
 Metals and Inorganic Chemicals Group 
Sector Policies and Programs Division 
Office of Air Quality Planning and Standards 
US EPA 
RTP, NC 27711 
(919) 541-2284 
FAX - (919) 541 - 3207 

