agrium u.s., inc. kennewick fertilizer operations · 2020-03-27 · technical support document for...

Technical Support Document for Prevention of Significant Deterioration Permit No. 04-01, Amendment 2 Preliminary Determination

Agrium U.S., Inc. Kennewick Fertilizer Operations

March 2020

Publication and Contact Information For more information contact:

Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 Phone: 360-407-6800

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https://www.ecology.wa.gov/

Technical Support Document for Prevention of Significant Deterioration

No. 04-01, Amendment 2

Agrium U.S., Inc. Kennewick Fertilizer Operations

Air Quality Program

Washington Department of Ecology

Olympia, Washington

This page is purposely left blank

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Table of Contents Page

List of Tables ................................................................................................................................. vi 1. Executive Summary .............................................................................................................1

2. Prevention of Significant Deterioration in Washington .......................................................3

3. Project and Site Description.................................................................................................4

A. Project description .............................................................................................................4

B. Site description ..................................................................................................................4

C. PSD permit history ............................................................................................................5

D. PSD applicability – PSD 04-01 and PSD 04-01, Amendment 1 .......................................7

E. New source performance standards ...................................................................................8

F. State regulations ................................................................................................................8

4. Determination of Best Available Control Technology (PSD 04-01) ...................................9

A. Definition and policy concerning BACT ..........................................................................9

B. KFO’s sources requiring BACT analysis ........................................................................11

C. NOX emissions from nitric acid Plant 9 ..........................................................................11

5. Ambient Air Quality Analysis ...........................................................................................16

A. Modeling results (June 9, 2008 Technical Support Document) ......................................16

B. Modeling methodology ...................................................................................................16

C. Modeling Results .............................................................................................................16

6. Discussion of Permit Conditions Revision ........................................................................18

7. State Environmental Policy Act .........................................................................................19

8. Environmental Justice Review ...........................................................................................20

9. Public Involvement ............................................................................................................21

10. Conclusion and Agency Contact ........................................................................................22

Acronyms and Abbreviations ........................................................................................................23

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List of Tables Page

Table 1: Emissions History ..............................................................................................................6

Table 2: Design Capacity .................................................................................................................7

Table 3: Project Emissions Increase ................................................................................................7

Table 4: BACT Candidates for NOX Reduction from Nitric Acid Manufacturing .......................11

Technical Support Document for PSD 04-01, Amendment 2 March 30, 2020 Kennewick Fertilizer Operations Preliminary Determination

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1. Executive Summary Agrium U.S., Inc. (Agrium) owns and operates a nitrogen-based fertilizer plant in Kennewick, Washington: the Kennewick Fertilizer Operations (KFO). The plant makes or has the ability to make nitric acid (HNO3) (Plants 7 & 9), urea ammonium nitrate (trade name UAN-32), granulated ammonium nitrate (NH4NO3, trade name GAN) (Plant 10), and calcium ammonium nitrate (trade name CAN-17) (Plant 8).

Agrium has requested to make minor changes to its Prevention of Significant Deterioration (PSD) permit. The changes include:

• Plant 9 currently controls NOX emissions by the use of hydrogen peroxide (H2O2) during normal start-up and shutdown operations.

• The original permit allowed for controls by selective catalytic reduction (SCR) or H2O2.

• Agrium installed H2O2 controls.

• Agrium is proposing to add a SCR with ammonia addition to control NOx during normal operations. H2O2 will be used during lower temperature operations during start-up and shutdown.

• Added start-up and shutdown emission limit of 1,800 lb NOX per day to Plant 9 based on historical start-up and shutdown of 498 to 1,221 lb per 24 hours.

• Clarify NOx CEMS requirements to allow the use of FTIR using. (CEMS for NOX shall satisfy the requirements contained in CFR 40 Part 60, Appendix B, Performance Specification 2, 6, or 15 (as applicable) and CFR 40 Part 60, Appendix F, Quality Assurance Procedures.)

• Ecology took this opportunity to delete outdated requirements and address short-term start-up and shutdown emissions.

Ecology’s assessment of Agrium’s request:

• Approves the addition of SCR as the main NOX controls.

• Added start-up and shutdown emission limit of 1,300 lb NOX per day to Plant 9 based on historical start-up and shutdown of 498 to 1,221 lb per 24 hours. Agrium is required to report any deviation to their startup and shutdown procedures.

• Ecology clarified the Relative Accuracy Test Audit required to include both EPA Method 320 and Method 7E.

• Amendment deletes obsolete requirements.

Agrium operates four plants at three sites (Kennewick Fertilizer Operations) at 227515 E. Bowles Road, Kennewick, WA 99337.


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After reviewing Agrium’s request, Ecology proposes to approve this request. This technical support document shows Ecology’s review and more a detailed explanation of the revisions.


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2. Prevention of Significant Deterioration in Washington

PSD permitting requirements in Washington are established in Washington Administrative Code (WAC) 173-400-700 through 750. Washington implements its PSD program as a State Implementation Plan (SIP)-approved program. This SIP-approved program became effective May 29, 2015.1

The objective of the PSD program is to prevent significant adverse environmental impact from emissions into the atmosphere by a proposed new major source, or major modification to an existing major source. The program limits degradation of air quality to that which is not considered “significant.” PSD rules require the utilization of Best Available Control Technology (BACT) for certain new or modified emission units, which is the most effective air pollution control equipment and procedures that are determined to be available after considering environmental, economic, and energy factors.

PSD rules are designed to keep an area with “good” air in compliance with the National Ambient Air Quality Standards (NAAQS). The distinctive requirements of PSD are BACT, air quality analysis (allowable increments and comparison with the NAAQS), and analysis of impacts of the project on visibility, vegetation, and soils.

1 80 FR 23721, April 29, 2015.


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3. Project and Site Description

A. Project description Agrium proposes to replace the nitrogen oxides (NOX) emission control for Plant 9 Nitric Acid Plant. Agrium proposes to control NOX with SCR instead of absorption method using hydrogen peroxide (H2O2) injection installed under original PSD permit No. 04-01. Absorption control will still be used to control NOX emission during start-up operation. Ecology is revising PSD permit No. 04-01, Amendment 1 to include SCR for Plant 9 - Nitric acid plant. The new controls will allow the plant to produce more nitric acid than in the past (additional downstream production) while maintaining the current emission limits. The proposed changes are not a major modification, but require the permit be modified to allow for the SCR for NOX control. The resulting emission increases is a minor modification. The applicability analysis determined that NOX and PM emissions from this change would not result in a significant net emissions increase.

On January 6, 2020, Ecology received the original application to modify PSD No. 04-04, Amendment 1. Agrium supplemented the application on February 10 and 24, 2020. On March 17, 2020, Ecology deemed the application complete.

B. Site description KFO occupies three non-contiguous areas, about 6.5 kilometers (km) southeast of the Richland-Kennewick-Pasco area, each east of and adjacent to the Columbia River:

• Kennewick area located at the east end of Bowles Road (227515 East Bowles Road).

• Finley area located at the east end of Game Farm Road (231610 East Game Farm Road).

• Hedges area located at the east end of Perkins Road (227108 East Hedges Road).

KFO is located within the Wallula PM10 (particulate matter less than 10 microns in aerodynamic diameter) maintenance area (8/26/2005 Re-designation to attainment – 70 FR 50212). This is a Class II area that straddles the Columbia River from just west of Hedges and Finley to just east of Reese and just north of Burbank and Humorist to an east-west line between Wallula Junction and Port Kelley. The area is currently designated in attainment or unclassified for all other national and state air quality standards (NAAQS). KFO is about 25 km from the Washington-Oregon border, about 175 km from the Washington-Idaho border, and 55 km from the Yakama Tribal Nation.


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C. PSD permit history In 2004, Ecology issued a PSD permit2 to Agrium to install emission controls in KFO to satisfy obligations required under a United States Environmental Protection Agency (EPA) compliance order (EPA Docket No. CAA-10-2003-0108, September 24, 2003).

The compliance order required Agrium to install Best Available Control Technology (BACT) for NOX emissions from the Plant 9 HNO3 unit. Plant 9 is designed to produce a maximum of 277,000 tons per year (tpy) of nitric acid. Ecology’s detailed BACT analysis for Plant 9 is given in the technical supplement document (TSD) for PSD-04-01.3 Based on Agrium’s proposal, Ecology agreed that BACT was an emission level of 20 parts per million dry basis (ppmdv), achievable using selective catalytic reduction (SCR).

Agrium further proposed that they be allowed to develop an alternative control process under the provisions of 40 CFR 52.21(b)(19), Innovative Technology. The alternative control technology would use hydrogen peroxide (H2O2) addition to the HNO3 absorption column. Ecology agreed.

Under the provisions of 40 CFR 52.21(b)(19), Agrium was allowed up to four years from the date of start-up of the NOX emitting process or seven years from the date of issuance of the PSD permit to achieve BACT-equivalent emission levels. If Agrium is unable to achieve BACT-equivalent emission levels within the allocated time allowed, Agrium must in any event achieve BACT-equivalent emission levels not later than three years after termination of the Innovative Technology allowance.

After three years of testing and modification of the innovative technology, Agrium believes they had reached an impasse. They believe the innovative control technology cannot comply with a NOX emission limit of less than 20 ppmdv.

Agrium proposed amending PSD 04-01 to increase allowable short-term NOX emissions for the Plant 9 HNO3 unit to 40 ppmdv. This required Ecology to review the BACT determination. Annual NOX emissions were unchanged by that amendment. The amendment involves no emissions unit modification or change in the method of operation. No other emission units at KFO would be affected by the amendment.

I. PSD 04-01 Agrium was concerned that and emission limit of 20 ppmdv NOX for Plant 9 would be at levels lower then achieved in recent permits. Since 1999, two other nitric acid plants were permitted with NOX emission limits of 40 to 45 ppmdv: Coffeyville Resources, (Kansas, 2007) and the above-mentioned Royster Clark/Agrium (Ohio, 2007) EPA compliance order determination.

2 Permit No. PSD 04-01, August 27, 2004. 3 Technical Supplement Document for Prevention of Significant Deterioration Permit No. PSD 04-01, Agrium U.S., Inc., Kennewick, Washington, July 25, 2004.


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II. PSD 04-01, Amendment 1 Agrium proposed that a re-evaluated BACT for NOX emissions from Plant 9 is 40 ppmdv (or its equivalent, 0.6 lb NOX/ton nitric acid). Ecology agrees. This re-evaluation will allow Agrium to permanently institute the H2O2 process for NOX emissions control for Plant 9. Ecology agrees that the preponderance of evidence points to the conclusion that BACT for NOX emissions from nitric acid production is 0.6 lb NOX/ton nitric acid (the approximate equivalent of 40 ppmdv NOX). Agrium proposes to retain the 47 ton per 12-month period NOX emission limit.

Table 1: Emissions History

Permit No. Issuance Date Description

EPA Compliance Order (EPA Docket No. CAA-10-2003-0108)

September 24, 2003 Install emission controls in KFO. Post construction emission increases: 342 tpy NOX and 10.1 tpy PM.

04-01

August 27, 2004

The original PSD permit allows for the controls of NOX in Plant 7 (SCR) and Plant 9 (H2O2). Plant 9 proposed to use H2O2 peroxide based on the Innovative NOX Control Technology regulations. Plant 8 limited the use of HNO3 to control NOX. Plant 10 PM emissions are limited by the use of a hardening agent. Post permit: -669.2 tpy NOX and 22.7 tpy PM.

04-01, Amendment 1 July 11, 2008

PSD permit No. 04-01, Amendment 1 revision. The revision raised the daily emissions limit from 330 lb of NOX/day to 400 lb of NOX/day. Annual limit stayed at 47 tpy.

III. Fertilizer Manufacturing Processes In Plants 7 and 9, nitric acid is made by oxidizing NH3 in the presence of a platinum/rhodium catalyst to form nitrogen dioxide (NO2) which is then hydrolyzed to aqueous HNO3. The finished aqueous product is between 56 and 60 percent HNO3 by weight. The hydrolysis process takes place in an absorption column. Unabsorbed NO2 is the source of nitric acid process NOX emissions. In Plant 8, nitric acid is used at any given time to make either UAN-32 or CAN-17. UAN-32 is an aqueous nitrous fertilizer formed by neutralizing nitric acid with NH3 and mixing in urea. CAN-17 is an aqueous nitrous fertilizer formed by neutralizing nitric acid with crushed limestone and NH3 in a two-step process. UAN-32 uses the same equipment required by CAN-17's second step. Consequently, UAN-32 and CAN-17 cannot be produced at the same time. The initial mixing of nitric acid with crushed limestone in the production of CAN-17 results in NOX emissions by trace oxidation and/or NOX evaporation/entrainment mechanisms.

In Plant 10, nitric acid is neutralized with NH3. The resulting aqueous NH4NO3 solution is concentrated by evaporation, and pelletized to granular form through a spray drum granulator. The exhaust from the granulator is passed through a wet scrubber and mist eliminator to remove


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entrained particles of granular NH4NO3. Entrained granular NH4NO3 not captured by the scrubber/mist eliminator is a source of particulate matter (PM) emissions from Plant 10.

Table 2: Design Capacity

Emission Unit Description

Design Capacity Estimated Emissions

New/Modified

Plant 7 103,053 tons/yr of nitric acid Currently shutdown

0.52 lb NOX/ton HNO3 152 lb NOX/day Based on 27 tpy

No change

Plant 8 164,250 tons/yr of CAN-17 (450 tons/day)

--- No change

Plant 9 277,000 tons/yr of nitric acid 0.34 lb NOX/ton HNO3 265 lb NOX/day Based on 47 tpy

Control changes and start-up and shutdown

Plant 10 255,500 tons/yr of ammonium nitrate (700 tons/day)

--- No change

D. PSD applicability – PSD 04-01 and PSD 04-01, Amendment 1

KFO is a “major source”, as defined in PSD regulations (CFR 40 Part 52.21(b)(1)(i)(a)) because it is a nitric acid production facility, and has the potential to emit more than 100 tpy each of NOX and PM. Both are pollutants that are subject to the federal Clean Air Act. Therefore, emission increases of each regulated pollutant from the facility resulting from new construction or modifications must be compared to the corresponding PSD significant emission rate (SER) threshold in order to determine if major new source review (NSR) is required. Any criteria pollutant expected to have an emissions increase in excess of its SER threshold is subject to PSD permitting. Agrium’s proposal in this action does not include an increase in annual NOX emissions. Therefore, Agrium’s proposal requires a minor amendment to Permit No. PSD 04-01.

Table 3: Project Emissions Increase

Pollutant Emission Rate (tpy) Subject to PSD Past Actual* Potential Increase Significant

Emission Rates

NOX 45.8 55.8 10.0 40 Not triggered


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Pollutant Emission Rate (tpy) Subject to PSD Past Actual* Potential Increase Significant

Emission Rates

PM --- 8.0 --- 25 Not triggered

PM10 --- 6.0 --- 15 Not triggered

PM2.5 --- 6.0 --- 10 Not triggered

∗ Past actual baseline emission rate based on Jan. 2017 to Dec. 2018 (204,355 tons of nitric acid per year.

E. New source performance standards The United States Environmental Protection Agency (EPA) has established performance standards for a number of air pollution sources in CFR 40 Part 60. These “New Source Performance Standards” (NSPS) represent a minimum level of control that is required on a new source. Emissions of NOX to ambient air from nitric acid manufacturing are regulated by the NSPS under CFR 40 Part 60 Subpart G - Standards of Performance for Nitric Acid Plants. KFO’s nitric acid Plant 9 is subject to the requirements under Section 60.70. This limits NOX emissions from the facility to 3.0 lb/ton of nitric acid produced (lb NOX/Tacid) as measured by the USEPA Method 7 test. The limit proposed for NOX emissions from KFO’s nitric acid Plant 9 is 0.35 lb NOX/Tacid (start-up and shutdown – 1.65 lb NOX/Tacid).

This is more restrictive than the limit required under 40 CFR Part 60.70. The rule requires the operations of a CEMS and daily logging of nitric acid production. Agrium stated that they are not subject to NSPS Ga. Ecology is using 40 CFR 60.74(a) requirement for documenting startup and shutdown event as being reasonable.

F. State regulations KFO is also subject to Notice of Construction requirements under Ecology regulations, Chapters 173-400 and 173-460 WAC for the increase in ammonia emissions.


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4. Determination of Best Available Control Technology (PSD 04-01)

A. Definition and policy concerning BACT All new sources are required to use Best Available Control Technology (BACT). BACT is defined as an emissions limitation based on the maximum degree of reduction for each pollutant subject to regulation, emitted from any proposed major stationary source or major modification, on a case-by-case basis, taking into account cost effectiveness, economic, energy, environmental and other impacts (CFR 40 52.21(b)(12)).

The “top down” BACT process starts by considering the most stringent form of emissions reduction technology possible, then analyzing all reasonably available information to determine whether the related control method is technically feasible and economically justifiable.4 If proven technically infeasible or economically unjustifiable, then the next most stringent level of reduction is considered in the same manner. The most stringent emission reduction (lowest emission level) that can be achieved by at least one control technology that is technically feasible and economically justifiable is determined to be BACT. The emission level and its related control technology are usually interchangeably referred to as the “BACT” of the permit decision. However, only the emission level is mandated in the permit. The source is generally free to apply any control technology with the requirement that it demonstrate BACT-level performance capability and not have unacceptable collateral environmental impacts.

I. Technical feasibility Frequently, a PSD applicant will propose that a given emission control technology is infeasible for the proposed new source or modification unless it has been previously used in exactly the situation under consideration. This is insufficient evidence to conclude that the control technology is technically infeasible. EPA’s NSR guidance5 suggests, “The control alternatives should include not only existing controls for the source category in question, but also (through technology transfer) controls applied to similar source categories and gas streams.” EPA guidance also indicates that in order for such a “technology transfer” to be judged technically feasible, its application should be relatively seamless and free of technical speculation.6 In the

4 Other factors are also subject to consideration, e.g., energy consumption (regardless of short-term unit cost of the energy source) and local/regional community values. However, these are rarely considered in such a manner that would trump technical feasibility and economic justifiability. 5 USEPA New Source Review Workshop Manual, Chapter B §IIIA, October, 1990. 6 Court Decision on Steel Dynamics, Inc., PSD Appeals 99-04 and 99-05 before the USEPA Appeals Board, June 22, 2000.


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BACT determination for this permit, technical feasibility was judged subject to the following criteria:

• The control technology was previously applied to emission streams sufficiently similar to the one being proposed.7 Any differences from the previous applications should not impact the control technology performance. The control technology and emission limit should not cause deterioration of the related process equipment, or irretrievably affect product quality.

• The emission limit associated with the BACT determination, including consideration for normal and reasonable control variability, was shown to be consistently achievable under normal and conscientious operating practices.8

• It is not in the interests of the source, the regulatory agency, or the public to set emission limits that will result in frequent violations even though the control technology was well designed, installed, and conscientiously operated by the source. Such situations increase costs to the source and regulatory agency (and consequently the public) for investigation, litigation, and reconstruction without benefit to the environment.

II. 4.1.2. Economic justifiability “Economic justifiability” does not mean “affordable by the source.”9 Nor does it mean the most any other source in the world has spent on air pollutant emissions control. In the BACT determination for this permit, economic justifiability was judged subject to the following criteria:10

• In order to eliminate a BACT candidate based on cost-effectiveness, the cost must generally be disproportionately high for the applicant when compared to the cost of control for the pollutant in recent BACT determinations in the applicant’s source category.

• A BACT candidate may also be eligible for elimination if it has been applied as BACT in only a very limited number of cases and there is a clear demarcation between the cost of that technology and control costs accepted as BACT in recent determinations in the applicant’s source category.

7 USEPA NSR Workshop Manual (1990), §IV.A.: “Add-on controls … should be considered based on the physical and chemical characteristics of the pollutant-bearing stream. Thus, candidate add-on controls (are those that) may have been applied to … emission unit types that are similar, insofar as emissions characteristics, to the emissions unit undergoing BACT review.” 8 USEPA NSR Workshop Manual (1990), §IV.A.1: “Technologies which have not yet been applied to (or permitted for) full scale operations need not be considered available …" and USEPA NSR Workshop Manual (1990), §IV.C.2.: “… the applicant should use the most recent regulatory decisions and performance data for identifying the emissions performance level(s) to be evaluated …” 9 USEPA NSR Workshop Manual (1990), §IV.D.2: “… applicants generally should not propose elimination of control alternatives on the basis of … affordability …” 10 USEPA NSR Workshop Manual (1990), §IV.D.2.c.


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B. KFO’s sources requiring BACT analysis Ecology revisited the NOX BACT determination conducted during 2004 for Plant 9 to determine appropriate NOX emission limit with SCR control. This section includes the information from the original BACT review and describes Ecology’s review for this control replacement project.

C. NOX emissions from nitric acid Plant 9 Several control technologies and processes might be applied to minimize the NOX emissions from nitric acid manufacturing.

Table 4: BACT Candidates for NOX Reduction from Nitric Acid Manufacturing

NOX Reduction Process

NOX Reduction Level

Exhaust NOX Concentration

Parts per Million Dry Volume Basis

(ppmdv)

Previous Applications

Uhde EnviNOX 98% 5 Nitric acid plants

Dry absorption 95-98% 2.7 to 9.3 Pilot tests on coal-fired boilers

SCONOxTM 90-95%

(combustion turbines)

2 Small natural gas-fired turbines

Hydrogen peroxide (H2O2 injection to the absorption column

96% 40 (3-hour average)

NOX removal from acid gas scrubbers. Proposed by Agrium as Innovative Technology alternative.

Molecular Sieve Adsorption 96% 50 None, but tested on nitric acid

plants.

Selective Catalytic Reduction (SCR)

98% 20 to 150 Nitric acid plants

90-95% 2 to 5 Large natural gas-fired turbines

Non-selective catalytic reduction (NSCR) 98%

75 NOX 350 ppmdv CO

Nitric acid plants

Urea scrubbing 97% 100 None, but intended for nitric acid plants.

Refrigerated extended absorption 95% 170 Nitric acid plants

Caustic scrubbing 94% 200 Nitric acid plants

Ammonia scrubbing 94% 209 None, but intended for nitric acid plants.


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With the exception of the Uhde EnviNOX process and an update for SCR, the technical feasibility discussion for each of the above-listed control technologies is given in the original TSD for PSD 04-01. The following is the result of the updated BACT analysis and determination.

In the original TSD, Ecology determined that the following NOX emission control technologies are not feasible for BACT-level emission control for HNO3 units.

• Dry absorption

• SCONOxTM

• Molecular sieve adsorption

• Urea scrubbing

• Refrigerated extended absorption

• Caustic scrubbing

• Ammonia scrubbing

As of the date of this proposed amendment to PSD No. 04-01, Ecology found no information on to alter that conclusion.

I. Uhde process In 2003, ThyssenKrupp Technologies (Dortmund, Germany) installed its Uhde EnviNOX process in a new nitric acid plant in Linz, Austria (Agrolinz Melamine International). The primary purpose for development of the Uhde EnviNOX process was to reduce nitrous oxide (N2O) emissions. N2O is a greenhouse gas, but is not a component of NOX. Pursuant to participation in the Kyoto Protocol, reductions in greenhouse gas emissions are significantly more important in Europe than in the United States (prior to 2010 greenhouse gas regulations).

The Uhde EnviNOX process has two stages in two variants.11 In Variant 1, N2O is reacted with nitric oxide (NO) in an oxidation-reduction reaction over an iron zeolite catalyst to produce equimolar quantities of nitrogen and nitrogen dioxide (NO2). In the second stage, the NO2 and any unreacted NO (in other words, NOX) are reacted with ammonia over a second bed of iron zeolite catalyst to form nitrogen and water. In Variant 2, an iron zeolite catalyst bed is first used with ammonia to remove NOX. The N2O is then removed in a second iron zeolite catalyst bed by reacting it with natural gas to form nitrogen, carbon monoxide, and carbon dioxide. Uhde

11 Uhde brochure, “EnviNOX – Climate protection solutions for nitric acid plants,” ThyssenKrupp, FI 270e/2000 04/2006 (Germany).


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indicates that the NOX reduction step can be installed separately if N2O reduction is not an objective.12

Uhde promotional literature13 claims that NOX emissions consistently below five parts per million (ppm) have been demonstrated using the full Variant 1 process at the Agrolinz Melamine International nitric acid plant. Variant 1 and Variant 2 Uhde processes have been installed in four other nitric acid plants, three in South Korea and one in Egypt. Because none of the Uhde installations is in the United States, it is difficult to impossible for either Agrium or Ecology to verify Uhde’s claimed performance. Further, notwithstanding Uhde’s claim that the NOX removal capability would be the same with or without the N2O removal step, there has been no Uhde DeNOX process installed or demonstrated without the companion DeN2O unit.

Ecology concludes that while the Uhde process is promising and likely to be evaluated in the United States once global warming regulatory confusion is cleared up, at this time it is not sufficiently demonstrated to be considered technically feasible for the Agrium-KFO Plant 9 nitric acid unit.

II. Selective catalytic reduction Ecology’s overriding conclusion is that SCR demonstrated the lowest NOX emission levels for HNO3 units. Evaluations of demonstrated NOX emission control for SCR vary widely. There are at least 64 nitric acid plants in the United States,14 most of which are using SCR.15 Yet, only six nitric acid plants’ permit entries are in the EPA’s database. And excluding Agrium’s PSD No. 04-01, only one nitric acid manufacturing facility is listed in EPA’s database (RACT/BACT/LAER Clearinghouse) as using SCR.16 The associated NOX emission limit is about 200 ppmdv. Although EPA encourages agencies to enter all NSR determinations into the database, the EPA requires data only from major source NSR. Apparently, almost 90 percent of the nitric acid plants were either constructed before the onset of the PSD program in 1978, were minor sources after application of SCR, or failed to get required pre-construction permits. PSD permitting would not be triggered by the addition of NOX controls (unless required by a compliance order) because emissions would decrease. Consequently, information on the control levels at the non-PSD plants is difficult to obtain because it would have to come directly from the nitric acid facilities. The organization of air quality control agencies, STAPPA/ALAPCO,

12 Ibid. p. 8. 13 Ibid. p. 10. 14 Controlling Nitrogen Oxides Under the Clean Air Act, A Menu of Options, “Nitric Acid and Adipic Acid Plants,” STAPPA/ALAPCO (July 1994). 15 U.S. Adipic Acid and Nitric Acid N2O Emissions 1990-2020: Inventories, Projections and Opportunities for Reductions, http://www.epa.gov/nitrousoxide/projections.html (December 2001). 16 Terra Nitrogen Ltd Partnership Woodward Complex, Oklahoma Dept. of Env. Quality Air Quality Division, Permit Number 97-245-C PSD (2/20/98).


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reported in 1994 on three nitric acid plants using SCR.17 Source test data showed these plants were able to reduce NOX emissions to between 37 ppmdv and 200 ppmdv. These emission levels were performance levels, not permit limits. A report from the European Fertilizer Manufacturers Association18 in 2000 indicated SCR gave “a typical reduction from 1,000 ppmv to 200 ppmv.” A study reported to the Arab Fertilizer Association19 described nine nitric acid plants (4-USA, 1-South Africa, 1-Europe, and 3-SE Asia) demonstrating NOX emissions between 80 ppmdv and 410 ppmdv. In 1991, the EPA released a report indicating SCR was capable of NOX emissions below 60 ppmdv.20 Finally, in a recent compliance order,21 the U.S. District Court determined BACT for NOX emissions from nitric acid plants to be 0.61 lb NOX/ton nitric acid (the equivalent of 40 ppmdv).

In the original TSD for PSD 04-01, Ecology reported that no BACT determinations for nitric acid plants were found wherein the related NOX emission limit was lower than 40 ppmdv. In preparing their proposal for this permit amendment, Agrium found one nitric acid plant, El Dorado Nitrogen (Texas) permitted in 1999 with a NOX emission limit of 20 ppm.22 This facility is in an ozone nonattainment area, and cost-effectiveness was not a consideration. Agrium said the 1999 El Dorado Nitrogen plant design is not directly comparable to the 1976 Agrium design.

1. PSD 04-01, Amendment 2 Agrium is proposing to maintain current short-term and long-term emission limits. Agrium’s SCR supplier guarantees emissions of 10 ppm NOX. With the increase in throughput from historical about 205,000 tpy of nitric acid to 277,000 tpy (permitted), the expected production based emission rate would be 0.34 lb NOX/ton nitric acid, or about 20 ppm NOX. This is a minor modification of the PSD permit and BACT was not evaluated.

2. Process Description Plants 7 and 9, nitric acid is made by oxidizing NH3 in the presence of a platinum/rhodium catalyst to form nitrogen dioxide (NO2), which is then hydrolyzed to aqueous HNO3. The finished aqueous product is between 56 percent and 60 percent HNO3 by weight. The hydrolysis process takes place in an absorption column. Unabsorbed NO2 is the source of nitric acid process NOX emissions.

17 Controlling Nitrogen Oxides under the Clean Air Act, A Menu of Options, Op. cit. 18 Best Available Techniques for Pollution Prevention and Control in the European Fertilizer Industry, Production of Nitric Acid; European Fertilizer Manufacturers’ Association; Brussels, Belgium (2000). 19 Maaskant and Miggelbrink, “Reducing the Cost of Meeting Emission Levels in Nitric Acid Plants,” presented at the Arab Fertilizer Association 13th International Technical Annual Conference (June, 2000). 20 Alternative Control Techniques Document— Nitric and Adipic Acid Manufacturing Plants, EPA-450/3-91-026, EPA, Research Triangle Park, N.C. (Dec. 1991). 21 United States District Court Southern District of Ohio Western Division, United States of America vs Agrium U.S. Inc. and Royster-Clark, Inc., Civil Action No. 1:07CV089 (Filed 2/5/07). 22 This determination has not been entered into the EPA RACT/BACT/LAER database, and was found by state-by-state search.


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3. Request No. 1 Agrium has requested that NOX emissions be controlled during normal operations by SCR with ammonia injection. During start-up and shutdown, Agrium will control the NOX emissions with the current H2O2 system to 1,890 lb per day based on eight hours of start-up per day (2.4 lb NOX/ton nitric acid). Historical data has the maximum emissions during startup and shutdown of 1,212 lb per day based on four hours of startup/shutdown per 24 hours (1.65 lb NOX/ton nitric acid). Agrium expects four planned and four unplanned start-ups per year. Agrium proposes that the emissions limits are unchanged. This will allow the facility to produce more nitric acid within the same emission limits. The current limits are based on 277,000 tons of nitric acid per year of production.

Ecology’s Review

Generally, the emission rates during the start-up and shutdown period are greater than the emissions during steady-state operation and are highly variable. NOX emissions can be significantly higher during start-up/shutdown events for the following reasons.

• Uncontrolled ppm NOX emissions are elevated during start-up until the process is stabilized.

• The emissions are not controlled by the SCR because the ammonia is not injected in the SCR until the catalyst reaches the appropriate operating temperature for the catalyst.

• Agrium will use H2O2 during start-up to minimize emissions.

• Additional reporting requirements have been added to the permit.

Agrium only expects four planned and four unplanned start-ups per year. No other units will need to modify short-term emissions limits at this time due to start-up or shutdown. The current emissions during start-up and shutdown have been included in the permit.

Agrium has accommodated start-up and shutdown for Plant 9. Ecology has required that Agrium follow their start-up and shutdown procedure and document any deviation per WAC 173-400-109. Plant 7 start-up limits will be modified prior to start-up.

4. Request No. 2 Agrium has requested that NOX emissions be monitored by FTIR.

Ecology’s Review

Ecology has streamlined the NOX CEMS monitoring to follow the requirements in NSPS Ga, 40 CFR 60.73a, which allows for FTIR test methods.


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5. Ambient Air Quality Analysis An air quality analysis can include up to three parts: Significant Impact analysis, National Ambient Air Quality Standards (NAAQS) analysis, and PSD Increment analysis. The first step in the air quality analysis is to determine if emissions from the proposed project result in impacts greater than the modeling significance impact levels (SILs). Then, for those pollutants and averaging periods that have impacts greater than the SIL, a NAAQS analysis is used to determine if the proposed project will cause or contribute to an exceedance of a NAAQS. The PSD Increment analysis is used to determine if the change in the air quality since the applicable baseline dates is greater than the Class I and Class II PSD increment levels.

This project was not a major modification with no change to long-term emission limits. The inclusion of start-up and shutdown emissions was only documenting historical emissions. Start-up is only anticipated to happen less than 8 times per year; therefore, short-term impacts need not be evaluated. Therefore, this review did not require PSD modeling. Agrium did modeling for the exhaust stack for the SCR operations to confirm that impacts were less than prior configuration.

A. Modeling results (June 9, 2008 Technical Support Document)

PSD rules require an assessment of ambient air quality impacts from any facility emitting pollutants in significant quantities. Limiting increases in ambient pollutant concentrations to less than the maximum allowable increments prevents significant deterioration of air quality.

B. Modeling methodology The dispersion modeling used three years of representative offsite meteorological data collected and approved for use by Ecology from Vista Airfield (1993, 1995, and 1996), and the Industrial Source Complex Short-term (ISCST3 version 02035) model was used to calculate ambient NOX concentrations at all receptors.

C. Modeling Results Modeled maximum NOX impacts resulting from this project were 0.425 micrograms per cubic meter (μg/m3) for BACT-equivalent emission levels and 0.57 μg/m3 for the highest emitting year projected under development of the H2O2 Innovative Technology. Both of these results are below the 1 μg/m3 threshold for modeling significance. Consequently, no further analysis is required for ambient NOX impacts.


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As noted in Section 1.3 in the 2008 review, Plant 10 never actually exceeded the PM-SER after the relevant modification, and Agrium’s proposed permit limit constrains Plant 10 PM emissions increase below the PM-SER. Consequently, no ambient air quality analysis is required under PSD regulations for PM emissions from Plant 10.


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6. Discussion of Permit Conditions Revision Summary of the permit conditions revision:

• No changes to normal emission limits were made.

• Start-up and shutdown emissions were added based on historical emissions for Plant 9.

• Initial compliance demonstration language for the emission limit is removed since it is obsolete.

• Other outdated requirements were removed.


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7. State Environmental Policy Act Benton County issued a State Environmental Policy Act (SEPA) Determination of Nonsignificant (DNS) on June 13, 2004, originally for the project. The proposal does not change the scope that was covered under the original SEPA determination. The revised permit conditions also is not expected to have additional environmental impact.

Ecology will incorporate the original SEPA DNS issued by reference for this action.


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8. Environmental Justice Review Environmental justice (EJ) is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Ecology conducts an EJ review to ensure no group of people bear a disproportionate share of the negative environmental consequences as the result of the permitting action.

The initial step in this review is to identify of any affected populations, or communities of concern. Ecology used EPA’s EJ screening and mapping tool, EJSCREEN, for this purpose. Ecology reviewed the Census summary report for 3- and 6-mile area. The 3-mile report has 84 percent white and 81 percent owner occupied. The 6-mile report has 64 percent white and 65 percent owner occupied.

EJSCREEN American Community Survey’s (ACS) report estimates that the selected area consists of approximately 24 percent minority population, with approximately two percent of the total population speaking English “less than well.” A copy of the ACS report will be filed as part of the supporting document of the project.

Because the project will have a minor emission increase, Ecology did not conduct a more extensive review of the potential for disproportionate high and adverse effects on an EJ community.

It also appears that a majority of the population in the selected area can understand and speak English proficiently. Ecology is not expecting a communication barrier and determines that an enhance outreach effort is not needed due to the nature and scope of this project.


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9. Public Involvement This PSD permitting action was subject to a minimum 30-day public comment period under WAC 173-400-740. Ecology posted the public notice on Ecology’s website for a minimum of 30 days. Day one of the public comment period begins on the next calendar day after Ecology posts the public notice. The public comment period started on [insert date] and closed on [insert date], at 5 PM PDT.


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10. Conclusion and Agency Contact The amendment action will have no significant adverse impact on air quality or air quality- related values. Increment will be unchanged because short- and long-term emission limits are unchanged.

The Washington Department of Ecology finds that the applicant, Agrium, has satisfied all requirements for approval of PSD 04-01, Amendment 2.

For additional information, please contact:

Scott Inloes, P.E. Air Quality Program Washington Department of Ecology P.O. Box 47600 Olympia, WA 98504-7600 360-407-6812 [email protected]

mailto:[email protected]


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Acronyms and Abbreviations Agrium Agrium U.S., Inc.

BACT Best Available Control Technology

CEMS Continuous Emissions Monitoring System

CFR Code of Federal Regulations

Ecology Washington Department of Ecology

EJ Environmental Justice

EPA United States Environmental Protection Agency

FR Federal Register

H2O2 hydrogen peroxide

H2SO4 sulfuric acid mist

HNO3 nitric acid

KFO Kennewick Fertilizer Operations

km kilometers

kW kilowatt

lb pound(s)

lb/hr pound(s) per hour

lb NOX/Tacid pound(s) of nitrogen oxides per ton of acid produced

NAAQS National Ambient Air Quality Standards

NH3 ammonia

NH4NO3 ammonium nitrate

NOX nitrogen oxides

NSR New Source Review

PM particulate matter

PM10 particulate matter less than 10 micrometers in diameter

ppm parts per million


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ppmdv parts per million on a dry volumetric basis

PSD Prevention of Significant Deterioration

SCR selective catalytic reduction

SEPA State Environmental Policy Act

tpy tons per year

WAC Washington Administrative Code

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