EPA-450/3-79-013
     A Review of Standards
          of  Performance
for  New Stationary Sources  -
         Nitric Acid  Plants
                     by

                 Marvin Drabkin

               The MITRE Corporation
                 Metrek Division
             1820 Dolley Madison Boulevard
               McLean, Virginia 22102
              Contract No. 68-02-2526


            EPA Project Officer: Thomas Bibb

         Emission Standards and Engineering Division



                  Prepared for
        U.S. ENVIRONMENTAL PROTECTION AGENCY
            Office of Air, Noise, and Radiation
         Office of Air Quality Planning and Standards
        Research Triangle Park, North Carolina 27711

                  March 1979

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  This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use.  Copies of this report
are available through the Library Services Office  (MD-35),
U.S.  Environmental Protection Agency, Research Triangle Park,
N.C.  27711; or, for a fee, from the National Technical Information
Services, 5285 Port Royal Road,  Springfield, Virginia 22161.
                 Publication No. EPA-450/3-79-013
                                ii

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                              ABSTRACT
     This report reviews the current Standards of Performance for
New Stationary Sources:  Subpart G - Nitric Acid Plants.   It  includes
a summary of the current standards, the status of current  applicable
control technology, and the ability of plants to meet  the  current
standards.  Information used in this report are based  upon data
available as of June 1978.   The recommendations state  that no change
be made at this time in the NOX NSPS for nitric acid plants,  but  that
a study be made of the NOX control capability of the extended
absorption process.
                                iii

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                         TABLE OF CONTENTS                       Page


LIST OF ILLUSTRATIONS                                            vii
LIST OF TABLES                                                   viii

1.0  EXECUTIVE SUMMARY                                           1-1

1.1  Best Demonstrated Control Technology                        1-1
1.2  Current NOX NSPS Levels Achievable with Best
     Demonstrated Control Technology                             1-2
1.3  Economic Considerations Affecting the NOX NSPS              1-3
1.4  Impact of Projected Growth of the Nitric Acid
     Industry on NOX Emissions                                   1-4
1.5  Problems Encountered by the Extended Absorption
     Process in Meeting the NO,. NSPS                             1-4
                              X

2.0  INTRODUCTION                                              •  2-l

3.0  CURRENT STANDARDS FOR NITRIC ACID PLANTS                  .  3_]_

3.1  Background Information                            .       .   3_^
3.2  Facilities Affected                                         3_2
3.3  Controlled Pollutants and Emission Levels                .   3.3
3.4  Testing and Monitoring Requirements                         3_4

     3.4.1  Testing Requirements                                 3_4
     3.4.2  Monitoring Requirements                              3_5
                                                                 4-1
4.0  STATUS OF CONTROL TECHNOLOGY

4.1  Status of Nitric Acid Manufacturing Industry Since
     the Promulgation of the ,NSPS                                4_]_

     4.1.1  Geographic Distribution                              4_1
     4.1.2  Production                                           4_3
     4.1.3  Trends                                               4_8

4.2  Nitric Acid Manufacture                                     4_g

     4.2.1  Single Pressure Process                              4-12
     4.2.2  Dual Pressure Process                                4-16

4.3  Emissions from Nitric Acid Plants                           4-18
4.4  Control Technology for NOX Emissions from
     Nitric Acid Plants                                          4-19

     4.4.1  Catalytic Reduction                                  4-20
     4.4.2  Extended Absorption                                  4-28
     4.4.3  Molecular Sieves                                     4-32
     4.4.4  Wet Scrubbing                                        4-35

                                  v

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                    TABLE OF CONTENTS (Concluded)
5.0  INDICATIONS FROM NSPS COMPLIANCE TEST RESULTS

5.1  Test Results from EPA Regional Sources
5.2  Analysis of NSPS Test Results

     5.2.1  Control Technology Used to Achieve Compliance
     5.2.2  Comparative Economics of the Catalytic
            Reduction and Extended.Absorption Processes
            for NOX Abatement

5.3  Indications of the Need for a Revised Standard

6.0  ANALYSIS OF THE IMPACTS OF OTHER ISSUES ON THE NSPS

6.1  Effect of Projected Nitric Acid Plant Construction
     .on Emissions
6.2  Problems Encountered by the Extended Absorption
     Process in Controlling NOX Emissions

7.0  FINDINGS AND RECOMMENDATIONS    •       ....

7.1  Findings
7.2  Recommendations

8.0  REFERENCES
Page

5-1

5-1
5-1

5-4


5-5

5-7

6-1


6-1

6-2

7-1

7-1
7-2

8-1
                                  vi

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                        LIST OF ILLUSTRATIONS

Figure Number                                                   pa  e

     4-1          Nitric Acid Plants  Built  or Under
                  Construction After  1971                        4-2

     4-2          Growth of the Nitric Acid Industry             4-6

     4-3          Nitric Acid Consumption in the U.S.
                  by Major Uses, 1970 (in Millions  of
                  Tons  of 100% Nitric Acid)                      4-7

     4-4          Single Pressure Nitric Acid  Manufacturing
                  Process                                       4-14

     4-5          Dual  Pressure Nitric Acid Manufacturing
                  Process                                       4-17

     4-6          Acid  Plant  Incorporating  Catalytic
                  Reduction for NOX Abatement                   4-23

     4-7          Extended Absorption System for NO
                  Emissions Control                X            4-30

     4-8          Two-Bed Purasiv N Process  (Vessel A
                  Under Adsorption and Vessel B Under
                  Regeneration Heating)  for  Control of
                  NOX in  Nitric Acid Plant Tail Gas             4-33

     5-1          Nitric  Acid Plants NSPS Test Results
                  NOX Emissions                                 5_3
                                 vii

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                           LIST OF TABLES
Table Number

    4-1


    4-2


    4-3

    4-4


    4-5


    4-6



     4-7



     5-1


     5-2




      6-1



      6-2


      6-3
Nitric Acid Plant Completions Subject
to NSPS

Nitric Acid Plants Planned or Under
Construction

U.S. Nitric Acid Production

Nitric Acid Plants Completed Since
Promulgation of the NSPS

NOX Abatement Methods  for Nitric Acid
Plants

Typical  Nitric Acid Plant Tail Gas
Emission Compositions  (Percent by
Volume)

 Operating Conditions  for Treating Nitric
 Acid Plant Tail  Gas by Catalytic
 Reduction
 NSPS Compliance Test Results for
 Plants
 Cost of Producing Nitric Acid Using
 Catalytic Reduction and Extended
 Absorption NOX Control Methods for a
 500-Ton/Day Plant

 Projected Cumulative NOX Emissions from
 New  & Replacement Nitric Acid Plants
 Added Between 1980 and 1983

 Excess Emissions Data from Extended
 Absorption Nitric Acid Plant Operations

 Excess Emissions Data from Extended
 Absorption Nitric Acid Plant Operations
4-3


4-4

4-5


4-13


4-21



4-22



4-26


 5-2




 5-6



 6-3


 6-5


 6-6
                                    viii

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1.0  EXECUTIVE SUMMARY

      The objective of this report is to review the New Source Perfor-

mance Standard (NSPS) for nitric acid plants in terms of developments

in control technology, economics and new issues that have evolved

since the original standard was promulgated in 1971.  The need for

possible revisions to the standard is analyzed in the light of com-

pliance test data available for plants built since the promulgation

of the NSPS.  The NSPS review includes the NOX emission standard for

the nitric acid plant production unit.  While included in the nitric

acid plant NSPS, the opacity standard is not reviewed separately

since it is directly related to the NOX standard.  The following

paragraphs summarize the results and conclusions of the analysis,

as well as recommendations for future action.

1.1  Best Demonstrated Control Technology

      A mixture of nitrogen oxides (NOX) is present in the tail gas

from the ammonia oxidation process for the production of nitric acid.

In modern U.S. single pressure process plants producing 50 to 60

percent acid, uncontrolled NOX emissions are generated at the rate

of about 21 kg/Mg* of 100 percent acid (42 Ib/ton) corresponding to

approximately 3000 ppm NOX (by volume) in the exit gas stream.  The

catalytic reduction process** has been largely supplanted by the ex-

tended absorption process as the control technology of choice for
 *Mg - Metric tons.
**The process used in the rationale for the present NOX NSPS as best
  demonstrated control technology.
                                 1-1

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controlling NOX emissions from new nitric acid plants to the level

required by the standard of performance.*  The latter control system

has apparently been chosen by the nitric acid industry due to the

increasing cost and danger of shortages of the principal fuel (natural

gas) used in the catalytic reduction process.  Since the energy crisis

of the mid-1970s, over 50 percent of the nitric acid plants that have

come on stream through mid-1978, and almost 90 percent of the plants

scheduled to come on stream through 1979, use the extended absorption

process for NOX control.

1.2  Current NOY NSPS Levels Achievable with Best Demonstrated
     Control Technology

      Fourteen of the new or modified operational nitric acid pro-

duction units subject to NSPS showed compliance with the current NOX

control level of 1.50 kg/Mg (3 lb/ton).**  The average of seven sets

of test data from catalytic reduction-controlled plants is 0.22 kg/Mg

(0.44 lb/ton), and the average of six sets of test data from extended

absorption-controlled plants is 0.91 kg/Mg (1.82 lb/ton).***  All of

the plants tested were in compliance with the opacity standard.  It
  *It should be noted that standards of performance for new sources
   established under Section 111 of the Clean Air Act reflect emission
   limits achievable with the best adequately demonstrated technolog-
   ical system of continuous emission reduction (taking into consider-
   ation the cost of achieving such emission reduction, as well as any
   nonair quality health and environmental impacts and energy require-
   ments) .
 **Five units had not been tested for compliance as of mid-1978.  No
   additional data have been obtained for this report since mid-1978.
***0ne set of data covers a nitric acid plant using a combination of
   chilled absorption and caustic scrubbing for NOX control.  This
   plant is in compliance.

                                  1-2

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appears  that  the  extended  absorption process,  while  it  has  become  the




preferred control technology  for  NOX control,  cannot control  these




.emissions as  efficiently as the catalytic  reduction  process.   In




fact, over half of  the  test results  for  extended  absorption,  while




in  compliance, were within 20 percent of the NOX  standard.  A prin-




cipal vendor  of the extended  absorption  process only provides a  7




to   8 percent safety  factor (in terms of absorber tray  count) in




the performance guarantee.  Thus,  the extended absorption process




appears  to have limitations with  respect to NOX control, and  com-




pares unfavorably with  catalytic  reduction in  its ability to  reduce




NOX emissions much  below the  present NSPS  level.   However,  the




overriding consideration which leads to  the recommendation  of no




change  in the NOX NSPS  at  the present time, is the sharply  escalat-




ing cost and  developing long-term shortages of natural  gas  which have




caused  the present  pronouced  trend to the  extended absorption process




for NOX  control in  new  plants. It is also recommended  that an in-




depth, EPA study  be carried out to completely  define the NOX  control




capability of this  process before  any future consideration  can be




given to making the current NOX NSPS more  stringent.




1.3 Economic Considerations  Affecting the NOY NSPS




     Nitric acid  plant  operators  opting  for the extended absorption




process  for NOX control for new plants (rather than  catalytic




reduction) would  not  be penalized  from an  economic standpoint, since




the annualized costs  of these two  NOX control  methods appear  to  be







                                  1-3

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comparable.  This is especially true now with the cost of fuel

(natural gas) for the catalytic reduction process experiencing sharp
                                                                                      *
rises.  Capital cost, however, for this process is appreciably higher

than that for catalytic reduction, .thus, making the latter process

less capital intensive.  Making the NOX standard more stringent at                    ^

this time would severely impact the investment cost of the extended                  ^

absorption process, since much larger absorption towers would have to

be incorporated in new plants in order to meet performance guarantees.                ?

1.4  Impact of Projected Growth of the Nitric Acid Industry on NOY                    ,
     Emissions

     Based on an estimated nitric acid plant growth rate of four new                  ,

production lines per year between 1980 and  1983, a 50-percent reduc-

tion of  the present NOX NSPS  level—from 1.5 kg/Mg (3 Ib/ton) to 0.75

kg/Mg  (1.5 Ib/ton)—would result in a drop  in the estimated percentage

NOX contribution of these new nitric acid plants to the total na-                     |

tional NOV emissions,  from 0.02 to 0.01 percent.           .                           ,
         A                                               •                             ' .,
                                                                                      i'r-
1.5  Problems Encountered by  the Extended Absorption Process in                       t'
     Meeting the NOV NSPS                                                             f
     i    i .-...V  ... ii-     A. i —... i . .                                                             tf
                                                                                      V
     Based on  limited  data, problems are encountered with the ex-

tended absorption process in  meeting the NOX standard during cer-
                                                                                      t
tain  startup periods and unscheduled shutdowns.  During these periods,
                                                                                      'u<
process  conditions  are unstable and NOX concentrations tend to be

high while nitric acid production  is low or nonexistent so that 3-hour

averaging  is  insufficient to  bring  the  average NOX level below 1.5

kg/Mg (3 Ib/ton).


                                   1-4

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2.0   INTRODUCTION

      In Section  111 of the Clean Air Act,  "Standards  of Performance

for New Stationary Sources," a provision  is set  forth which  requires

that  "The Administrator shalls at least every 4  years, review and, if

appropriate, revise such standards  following the procedure required

by this subsection for promulgation of such standards."  Pursuant

to this requirement, the MITRE Corporation, under EPA Contract No.

68-02-2526, is to review 10 of the promulgated NSPS including the

nitric acid plant production unit.

      The main purpose of this report is to review the current nitric

acid  standards for NOX and opacity and to assess the  need for revi-

sion  on the basis of developments that have occurred  or are expected

to occur in the near future.  This report addresses the following

issues:

      1.  A review of the definition of the present standards.

      2.  A discussion of the status of the nitric acid industry and
         the status of applicable control technology.

      3.  An analysis of NOX and opacity test results and review of
         levels of performance of best demonstrated control technol-
         ogies for emission control.

      4.  An analysis of the effect of projected nitric acid plant
         construction on NOX emissions.

      5.  A study of problems encountered by recently developed
         NOX control technology with the NSPS.

      Based on the information contained in this report,  conclusions

are presented and specific  recommendations are  made with respect  to

changes in the NSPS.


                                 2-1

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 3.0  CURRENT STANDARDS FOR NITRIC ACID PLANTS



 3.1  Background Information




      Prior to the promulgation ;of the NSPS in 1971, only 10 of the



 existing 194 weak nitric acid C50 to 60 percent acid) production



 facilities were specifically designed to accomplish NOY abatement.
                                                       A-


 Without control equipment, total NOX emissions from nitric acid



 plants can range from 1000 to 6000 ppm by volume.  In a typical




 plant, total NOX emissions are approximately 3,000 ppm in the stack



 gas,  equivalent to a release of 21.5 kg/Mg (43 Ib/ton) of 100 percent



 acid  produced (EPA,  1971).




      At the  time of  the  NOX  NSPS promulgation there were no state



 or  local  NOX emission abatement  regulations  in effect  in the  U.S.



 which applied specifically to  nitric acid  production plants.   Ventura



 County, California, had enacted  a  limitation  of 250 ppm  NOX to



 govern nitric acid plants  as well  as  steam generators  and other



 sources (EPA, 1971).




      In 1971, NOX emission decolorization was practiced  at  52



nitric acid plants by a method which also permitted maximum power



recovery  from the pressurized absorber tail gas.  The uncontrolled  .



NOX tail gas emission consisted of approximately 50 percent nitro-



gen dixoide 
-------
colorless NO in a highly exothermic reaction, with the heated exhaust




gas from the catalytic treatment being then passed through an ex-




pander to recover power for driving the air-compressor turbine used




in the nitric acid manufacturing process.




     Stack gas decolorization enabled nitric acid plants in many




areas to meet visible emission regulations (with equivalent opacity




provisions), even though the catalytic decolorization technique has




little effect on the total NOX emissions (EPA, 1971).




     It  is estimated that NOX emissions  from nitric acid plants




totalled 163,000 Mg (179,000 tons) in 1971 and 137,000 Mg  (150,000




tons)  in 1976  (Mann, 1978).  This  represented a  16 percent drop  in




NOV  emissions  in the first  5 years after the promulgation  of the
   it



NSPS and implementation of  State  Implementation  Plans  (SIPs) for this




pollutant.   By the end  of  1977, nitric acid  plants, in compliance




with NSPS,  represented  an  estimated  23 percent of  the  industry capac-




 ity.



 3.2  Facilities Affected



     The NSPS regulates nitric  acid  plants  that  were  planned or  under




 construction or modification as of August 17,  1971.   Each nitric acid




 production unit (or "train") is the  affected facility.   The  standards




 of performance apply to new facilities producing so-called "weak




 nitric acid" (defined as 50 to 70 percent strength).   The standards




 do not  apply to the various processes used to produce strong acid by




 extraction or evaporation of weak acid,  or by the direct strong acid




 process.



                                   3-2

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      An existing nitric acid plant is subject to the NSPS if:  (1)

it is modified by a physical or operational change in an existing

facility thereby causing an increase in the emission rate to the

atmosphere of any pollutant to which the standard applies, or (2) if

in the course of reconstruction of the facility, the fixed capital

cost of the new components exceeds 50 percent of the cost that would

be required to construct a comparable entirely new facility that

meets the NSPS.                                              •     ,

3.3  Controlled Pollutants and Emission Levels

     Total nitrogen oxide emissions from nitric acid plants are

controlled under the NSPS, as defined by 40 CFR 60, Subpart G (as

originally promulgated  in 36 FR 24881 with subsequent modifications

in 39 FR  20794):

     (a)  On  and after  the date on which the performance  test
          required  to be conducted ... is completed, no owner or
          operator  subject to the provisions of this subpart shall
          cause  to  be discharged in to  the atmosphere from any
          affected  facility any gases which:

          (1) Contain  nitrogen oxides, expressed as N02, in excess
               of  1.5 kg per metric ton of acid produced; (3.0 Ib per
               ton), the production being expressed as 100 percent
               nitric acid.

           (2) Exhibit  10 percent  opacity, or greater.

      This standard  was  based on inspections and stack tests of

existing  nitric  acid facilities; consultations with plant operators,

designers,  and state local  control officials; and a review of the

 literature.   Investigation  of  nitric  acid  plant  control  technology

 showed that catalytic reduction systems could successfully control

 tail gas  nitrogen oxide emissions  to  levels within  the proposed

                                  3-3

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standard of 1.5 kg N0x/metric ton of .100 percent acid (3 Ib/ton).


A survey of 10 U.S. plants equipped with catalytic reduction systems


showed that all plants either consistently achieved that NOX level


or could be operated or repaired to meet the proposed standard (EPA,


1971).

     All of the facilities equipped with catalytic NOX reduction


devices were  found to operate with no visible emissions.  Thus, any


facility meeting the mass NOX limit will produce no visible emis-


sions  from the  stack and  therefore meet the promulgated opacity


standard  (EPA,  1971).

      Section  4.0 dicusses alternative NOX  control  technologies that
    t

have  come into  use by  the nitric  acid industry  since the promulgation


 of the standard,  or  are  under  development.  Chief  among these  new


 technologies, and  one  that has  been widely used since  the mid-1970s,


 is the extended absorption process.


 3.4  Testing and Monitoring  Requirements


      3.4.1  Testing Requirements


      Performance tests to verify compliance with the NOX standard


 must be conducted within 60 days after the plant has reached its  full


 capacity production rate, but not later than 180 days  after the  ini-


 tial  start-up of  the facility  (40 CFR 60.8).   The EPA reference


 methods  (40  CFR 60, Appendix A) to be used in conjunction with NOX


 compliance testing include:


       1.  Method 7 for the concentration of NOX


       2.  Method 1 for sample and velocity transverses


                                   3-4

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     3.  Method 2 for velocity and volumetric flow rate; and




     4.  Method 3 for gas analysis.




Each performance test consists of 3 runs, each consisting at least




four grab samples taken at approximately 15-minute intervals.  The




arithmetic mean of the runs constitutes the value used to determine




whether the plant is in compliance.




     3.4.2  Monitoring Requirements




     The NOX levels in the tail gas from new nitric acid plants are




required to be continuously monitored to provide:  (1) a record of




performance and (2) information to plant operating personnel such




that suitable corrections can be made when the system is out of ad-




justment.  Plant operators are required to maintain the monitoring




equipment in calibration and to furnish records of excess NOX




emission values to the Administrator of EPA or to the responsible




State agency as requested.




     Measurement principles used in the continuous gas analysis




instruments for NOX are (Apple, 1978):




     1.  Photometric




     2.  Nondispersive infrared absorption




     3.  Ultraviolet absorption




     4.  Electrochemical




     5.  Chemiluminescent emission




     6.  On-stack  (in—situ) absorption
                                 3-5

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     A continuous NOX analyser in wide use in the nitric acid




industry is based on the principle of photometric analysis.  This




analyzer consists of a split-beam design in which the difference in




light absorption by nitrogen dioxide (Np2) is measured at two




different wavelengths (a measuring wavelength and reference wave-




length).  A basic requirement for this measurement principle is that




all the NO, which is transparent in the visible and ultraviolet




regions, is quantitatively converted to N0£ in the measuring




instrument (Dupont, 1974).




     The continuous monitoring system is calibrated using a known air




NOo gas mixture as a calibration standard.  Performance evaluation




of the monitoring system is conducted using the EPA Method 7.  In




general, the system in use should satisfy the specifications as shown




in 40 CFR 60, Appendix B, Performance Specification 2.




     Excess NOX emissons are required to be reported to EPA (or ap-




propriate state regulatory agencies) for all 3-hour periods of excess




emissions (or the arithmetic average of three consecutive 1-hour




periods).  Periods of excess emission are considered to occur when




the  integrated (or arithmetic average) plant stack NOX emission




exceeds the 1.5 kg/Mg (3 Ib/ton) standard.
                                 3-6

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4.0  STATUS OF CONTROL TECHNOLOGY



4.1  Status of Nitric Acid Manufacturing Industry Since the Promul-

     gation of the NSPS



     4.1.1  Geographic Distribution



     In 1972 there were approximately 125 nitric acid units in
                              i


existence, exclusive of government-owned units at ordnance plants



(Manderson, 1972).  About 75 percent of these units were 10 years old



or older and, in general, had capacities of 270 Mg/day (300 tons/



day) or less.  The remaining 25 percent of the units were of more



recent and larger design, having capacities exceeding 270 Mg/day (300



tons/day).  The Bureau of the Census reported that there were 72



plants (involving one or more units) in 1972 producing nitric acid in



the U.S. and that by 1977 the ,net number of plants in production had



increased by only one.



     As of June, 1978, 19 nitric acid units subject to NSPS had come



on stream.  Table 4-1 summarizes data presented later in Table 4-4



for these 19 units and their design tonnage  by EPA region.  Figure



4-1 shows the geographic distribution of these units as well as the



locations of eight units still under construction.  The latter units



are described in Table 4-2.  The heaviest concentration of new or



modified nitric acid unit construction since 1971 appears in EPA



Regions IV and VI—along the coast of the Gulf of Mexico and within



the Mississippi River delta.  Additionally, about half of the total



number of nitric acid plants are located in the southern tier of



states.  The distribution of nitric acid, as shown in Figure 4-1



displays a spacial pattern similar to that of the major fertilizer



                                 4-1

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                              TABLE 4-1




            NITRIC ACID PLANT COMPLETIONS SUBJECT TO NSPS

EPA
Region
III
IV
VI
IX
X
Total
Average
New or Modified
Units
in Production
(1971-1977)
1
7
7
2
2
19
New or Modified
Plant
Design Capacity
(100% HN03)
Mg/day (tons/day
164(180)
3936(4325)
3265(3588)
319(350)
549(603)
8319(9046)
Percent of Total
New or
Modified
Design Capacity
2.0
47.8
39.6
3.9
6.7
100.0
Design Capacity/Unit: 438(476)
production centers (Chapman, 1973).  Since the bulk of all nitric




acid produced is consumed captively in the manufacture of nitrogen




fertilizer used mainly in the Midwest cornbelt, the South Central




states, and the Southwest, the similarity in spacial patterns between




nitric acid plants and fertilizer manufacturing plants is to be




expected.




     4.1.2  Production




     EPA predicted the start-up of five new nitric acid units per




year for several years after promulgation of the NSPS (EPA, 1971).




The actual average rate of start-up between 1971 and 1977 has been




between two and three units per year.




     In 1971, U.S. production of 100 percent nitric acid totalled




6,951,000 metric tons and increased at an average annual rate of 0.7




                                 4-3

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percent to 7,167,000 metric tons in 1977.  Figure 4-2 shows the




growth of nitric acid production from 1939, and Table 4-3 shows the




percent change per year.




     Major end uses for nitric acid are shown in Figure 4-3.  The




largest consumer of nitric acid is the fertilizer industry which




consumes 70 percent of all nitric acid produced; industrial explo-




sives use 15 percent of acid produced (Manderson, 1972).  Other




end uses of nitric acid are gold and silver separation, military




munitions, steel and brass pickling, photoengraving, production of




nitrates, and the acidulation of phosphate rock.




                              TABLE 4-3




                     U.S. NITRIC ACID PRODUCTION
Year
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Sources :
Production of
100% 'Acid (106 Mg)
2.4
2.5
2.8
3.0
3.1
3.3
3.6
4.3
4.7
5.0
5.8
6.2
6.6
6.8
6.9
7.2
7.6
7.3
6.8
7.1
7.1
Bureau of the Census, 1965; 1977.
Annual
Change (%)

4.1
12.0
7.1
3.3
6.4
9.0
19.4
9.3
6.3
1(5.0
6.8
6.4
3.0
1.4
4.3
5.5
-3.9
-6.8
4.4
0

                                  4-5

-------
        8.0
        7.0
      t>0
      S

     vO
      O
        6.0
        5.0
      I
      4J
      |  4.0
         3.0
      4J
      •H
         2.0
         1.0
           1935     1945
1955      1965

    Year
1975     1980
Sources:   Bureau of the  Census, 1965; 1977.
                               FIGURE 4-2
                 GROWTH OF THE NITRIC ACID INDUSTRY
                                   4-6

-------
PRODUCT FORM END USE
7





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-


-* — "
Organic
Chemicals
Military
Munitions
Nitrophosphate
Based Fertilizers








Ammonium
Nitrate
(Solid & Liquid)











Potassium
•»-*• • *>•».
NitrateT
0.1
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Organ. Chem. Mfg.
Steel Pickling
Other
Military
Munitions
Industrial
Explosives
(Largely
Ammonium Nitrate)
~-^
Nitro-
Phosphate

Liquid
Ammonium
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Nitrogen
Solutions)



Solid
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Nitrate





F
E
R
T
I
L
I

Z
E
R
S



1
[0.5
\
Jo,
1.0
J (15%)
\























4.5
(70%)







Source:  Manderson, 1972.
                          FIGURE 4-3
        NITRIC ACID CONSUMPTION IN THE U.S. BY MAJOR
              USES, 1970(IN MILLIONSOFTONS OF
                      100% NITRIC AC ID)
                              4-7

-------
    4.1.3  Trends
     The average rate of production increase for nitric acid fell



from 9 percent/year in the 1960-1970 period to 0.7 percent from 1971



to 1977.  The decline in demand for nitric acid parallels that for



nitrogen-based fertilizers during the same period (Bureau of the



Census, 1977).


     Nitric acid production shows an increasing trend towards plant/



unit location and growth in the southern tier of states.  In 1971, 48



percent of the national production was in the south.  This figure



increased to 54 percent in 1976 (Bureau of the Census, 1977).



     About 50 percent of plant capacity in 1972 consisted of small to



moderately sized units (50 to 300-ton/day capacity).  Because of the



economics of scale  some producers are electing to replace their



existing units with new, larger units (Manderson, 1972).  Also, the



trend  toward reduction of NOX emissions is stimulating the shutdown



and replacement of  older units.  New nitric acid production units



have been built as  large as 910 Mg/day (1000 tons/day).  The average



size of new units is approximately 430 Mg/day (500  tons/day).


                            4?
4.2  Nitric Acid Manufacture



     Nitric acid is manufactured in the U.S. by the high temperature



catalytic oxidation of ammonia.  The essential components of an



ammonia oxidation nitric acid plant are:
 *Process  information in Sections  4.2,  4.3  and  4.4 is  taken  from

  Acurex/Aerotherm,  1977,  unless otherwise  noted.



                                  4-8

-------
     1.  Converter or oxidation section where the ammonia vapor and
         air are mixed and reacted catalytically to oxidize the
         ammonia.

     2.  Cooler-Condenser section where the nitrogen dioxide is pro-
         duced by cooling the reaction gases and weak nitric acid is
         formed.

     3.  Absorber section where the cool nitrogen dioxide is absorbed
         in water to form nitric acid.

In the first step of this process one volume of anhydrous ammonia is

mixed with nine volumes of preheated air and passed through a multi-

layered, silk fine platinum-rhodium gauze catalyst at 750° to 800°C.

Under these conditions, the oxidation of ammonia to nitric oxide pro-

ceeds in an exothermic reaction with a 95 percent yield:

                    4NH3 + 502 -> 4NO + 6H20>                       (1)

     The second step involves the oxidation of the nitric oxide to

nitrogen dioxide:

                   2ND + 02 -»2N02 -»N204                         (2)

The forward rate of reaction (2), which is rather slow compared with

reaction (1), is favored at lower temperatures and higher pressures.

Hence, reaction (2) is always carried out after cooling the gas to

38°C or less and, depending on the process design, at pressures up to

500 kPa* (73 psig).

     In the final step, the nitrogen dioxide/dimer mixture is cooled

further and passed to an absorber where it reacts with water to pro-

duce an aqueous solution of 50 to 60 percent nitric acid, the concen-

tration depending on the temperature, pressure, number of absorption
*Kilopascal - 100 kPa = approximately 1 atm.


                                 4-9

-------
stages, and concentration of the nitrogen dioxide entering the




absorber




                    3N02 + H20 -»2HN03 + NO




     This reaction is also favored by low temperature and high pres-




sure, because the gases involved are more soluble at lower tempera-




tures and absorption results in a reduction in volume.  In fact, some




processes utilize the low temperature/high pressure conditions to




increase yields.



     The formation of nitric acid in Equation (3) involves the dis-




proportionation of nitrogen dioxide to form two moles of nitric acid




for  every mole of nitric oxide.  In order to reoxidize the nitric




oxide  during absorption, secondary air (also known as bleacher air)




is introduced into the absorber  along with the nitrogen dioxide.




However, the reaction  to form nitric acid is never quite complete —




the  overall process  is 95 percent efficient, so  that  a small quantity




of nitrogen oxides,  NOX  (N02 and NO),  is  inevitably present in




the  waste  gas discharged from the absorption column.  The NOX in




these  waste gases  is the target  for  air  pollution regulations and




control.



     Acid  product  is withdrawn  from  the  bottom  of the tower in  con-




centrations  of  55  to 65  percent. The  air entering  the bottom of the




 tower serves  to strip N02  from the product  and  to supply  oxygen for




reoxidizing the NO formed  in making  nitric  acid (Equation 3).
                                  4-10

-------
     The oxidation and absorption operations can be carried out at




low pressures (100 kPa),  medium pressures (400 to 800 kPa) or high




pressures (1000 to 1200 kPa).  Both operations may be at the same




pressure or different pressures.




     Before corrosion-resistant materials were developed (precluding




the use of high pressures) the ammonia oxidation and absorption oper-




ations were carried out at essentially latmospheric pressure.  The




advantages over higher pressure processes were longer catalyst life




(about 6 months) and increased efficiency of ammonia combustion.




However, because of the low absorption and NO oxidation rates, much




more absorption volume was required, and several large towers were




placed in series.  Some of these low pressure units are still in




operation, but they represent less than 5 percent of the current U.S.




nitric acid capacity.




     Combination pressure plants carry out the ammonia oxidation pro-




cess at low or medium pressure and the absorption step at medium or




high pressure.  The increased pressure for the oxidation reaction




shortens the catalyst's lifetime (1 to 2 months) and lowers the




ammonia oxidation conversion efficiency.  Thus, lower pressures in




the oxidation process are preferred.  On the other hand, higher




pressures in the absorption tower increase the absorption efficiency




and reduce NOX levels in the tail gas.  The advantages of higher




absorber pressures must be weighed against the cost of pressure




vessels and compressors.
                                  4-11

-------
     The choice of which combination of pressures to use is very site




specific and is governed by the economic tradeoffs such as costs of




raw materials, energy and equipment and process efficiency.  In the




1960s combination low pressure oxidation/medium pressure absorp-




tion and single pressure (400 to 800 kPa) plants were preferred.




Since the  1970s the trend has been toward medium pressure oxi-




dation/high  pressure absorption plants  in Europe and single pressure




(400 to 800  kPa)  plants in  the U.S.



     The  two types  of weak  nitric acid  production  processes in  use in




new U.S.  plants,  i.e.,  single  pressure  and  dual  pressure  process,  are




described in the  following  sections.   Table 4-4  lists  all of  the new




and modified nitric acid  plants  subject to  NSPS,  together with  their




 capacities and the production and NOX abatement  processes used.




      4.2.1  Single Pressure Process




      In the single pressure process both the oxidation and absorption




 are carried out at the same pressure—either low (atmospheric)  or




 medium pressures of 400 to 800 kPa (60 to 120 psig).  Single pressure




 plants are  the most common type in the U.S.  Figure 4-4 is a




 simplified  flow  diagram of a single pressure process.  A medium




 pressure  process will be described in  the  following paragraphs.




      Air  is compressed, filtered, and  preheated to about 300°C




 (592°F) by  passing through a heat exchanger.  The air is then mixed




 with anhydrous ammonia, previously vaporized  in a continuous-steam
                                   4-12

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-------
evaporator.  The resulting mixture, which contains about 10 percent

ammonia by volume, is passed through the reactor.  The reactor

contains a platinum-rhodium (2 to 10 percent rhodium) wire-gauze

catalyst (e.g., 80 mesh and 75-mm diameter wire, packed in layers of

10 to 30 sheets) so that the gas travels downward through the gauze

sheets.  Catalyst operating temperature is about 750°C (1382°F).

Contact time with the catalyst is about 3 x 10"^ second.

     The hot nitrogen oxides and excess air mixture (about 10 percent

nitrogen oxides) from the reactor are partially cooled in a heat ex-

changer and further cooled in a water cooler.  The cooled gas is

introduced into a stainless-steel absorption tower with additional

air for the further oxidation of nitrous oxide to nitrogen dioxide.

Small quantities of water are added to hydrate the nitrogen dioxide

and also to scrub the gases.  The overhead gas from the tower is re-

heated by  feed/effluent heat exchangers and then expanded through a

power recovery turbine/compressor used to supply the reaction air.*

The bottom of  the tower yields nitric acid of 55 to 65 percent

strength.  Fifteen of the 19 U.S. nitric acid plants subject to NSPS,

employ a single pressure process.
*In  those plants using catalytic reduction as NOX abatement
method, the tail gas is first passed through the catalytic reduction
system and then expand ed through a power recovery turbine/compressor
used to supply the  reaction air.
                                  4-15

-------
     4.2.2  Dual Pressure Process




     In order to obtain the benefits of increased absorption (with




greater product yield) and reduced NOX emissions, some dual pres-




sure plants are in use in the U.S.  Four of these plants subject to




NSPS have been built in the U.S.  Recent trends favor moderate




pressure oxidation and high pressure absorption.




     A simplified process flow diagram for a dual pressure plant is




shown in Figure 4-5.  In the Uhde version of this process, liquid am-




monia is vaporized by steam, heated and filtered before being mixed




with air from  the air/nitrous oxide compressor at from 300 to 500 kPa




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                                      4-17

-------
4.3  Emissions from Nitric Acid Plants




     The main source of atmospheric emissions from the manufacture of




 nitric acid is the tail gas from the absorber tower.  The emissions




are primarily nitric oxide and nitrogen dioxide with trace amounts of




nitric acid mist.  Each of these pollutants has an effect on the




color and opacity of the tail gas plume.  The presence of nitrogen




dioxide is indicated by a reddish-brown color.  Since nitric oxide is




colorless, the intensity of the color and, therefore, plume opacity,




is directly proportional to the nitrogen dioxide concentration  in the




plume.  Concentrations of greater than 0.13 percent  by volume of ni-




trogen  dioxide produce a definite reddish-brown color in  the exit




plume,  whereas effluent gases  containing less than 0.03 percent ni-




trogen  dioxide are  colorless.




      The  opacity of the plume  is also a function of  the amount  of




nitric  acid mist in the  tail  gas, which  is  dependant on the  type  of




process used, the extent  of mist entrainment  and the efficiency of




 entrainment separators.   For  those  acid processes  operated above  at-




mospheric pressure, the  tail  gases  are  reheated  and  expanded for




 power recovery purposes  and discharged to  the atmosphere  at 200°  to




 250°C.   At this  temperature,  any acid mist present is converted to




 the vapor state.  In atmospheric pressure processes, however,  the




 temperature of the tail gas is below the dew point of nitric acid.




•As a result, the acid is emitted as a fine mist which increases the




 plume opacity.






                                  4-18

-------
     The average emission factor for uncontrolled acid plants is 20




to 28 kg N0x/Mg of acid, with typical uncontrolled tail gas concen-




trations on. the order of 3000 ppm NOX.  This concentration would be




experienced in a low pressure plant.  The NOX concentration in the




tail gas of medium pressure plants ranges from 1000 to 2000 ppm.




     Nitrogen oxide emissions vary considerably with changes in plant




operation.  Several operating variables have a more significant ef-




fect on increasing NOX  emissions.  These include:  (1) insufficient




air  supply to the oxidizer and absorber; (2) low pressure, especially




in the absorber;  (3) high temperatures in the cooler-condenser and




absorber;  (4) production of  an excessively high-strength  product




acid; and  (5) operation at high  throughput rates.  Finally,  faulty




equipment, such as  compressors or  pumps, lead to  lower pressures  and




leaks which  decrease  plant efficiency and increase emissions.




4.4   Control  Technology for  NOY  Emissions from  Nitric  Acid Plants




      Nitric  acid plants can  be  designed  for  low NOX  emission levels




without any  add-on control  equipment.  Such  plants are usually equip-




 ped with high efficiency absorbers,  i.e.,  those having high inlet gas




 pressures and effective cooling of the absorber solution.  However,




 all new U.S.  plants built since the promulgation of  the  NSPS are




 designed to meet the low NOX emissions required by the present




 standards with some form of NOX abatement  equipment.




      A number of methods are available for reducing NOX emissions




 from new nitric acid plants.  These methods include catalytic
                                   4-19

-------
reduction with certain fuels, extended ubuorptiott, wet butuhhtng,

chilled adsorption, and molecular sieve adsorption.  The methods are

summarized in Table 4-5 and described in greater detail in the fol-

lowing paragraphs.  Table 4-6 summarizes typical tail gas analyses

from uncontrolled plants and from plants incorporating the two most

important NOX abatement methods in use in new nitric acid plants

(catalytic abatement and extended absorption).

     4.4.1  Catalytic Reduction

     Catalytic reduction has been widely used as an NOX abatement

system installed on new nitric acid plants built since 1971.  Cataly-

tic reduction was also used as a method of NOX decolorization on

over 50 percent of nitric acid plants built prior to the NSPS.  The

reasons for the prevalance of this control technology until 1975*

were:

     (1)  Its relative ease and flexibility of operation

     (2)  The recovery of waste heat

     (3)  High NOX removal efficiencies.

     In practice, the catalytic reduction unit is an integral part of

the plant (Figure 4-6).  The tail gas from the absorption tower is

preheated by heat exchange with the converter effluent gas.  Fuel is

added and burned  in the catalytic unit to generate heat and abate
 The advent of a proven alternate NOX control technology—the
 extended absorption process—together with the developing natural
 gas shortage at that time radically changed the entire nitric acid
 plant NOX control situation  (see Section 4.4.2).
                                 4-20

-------
                                      TABLE 4-5

                    NOX ABATEMENT METHODS FOR NITRIC ACID  PLANTS
      Method
                                Description
                                          Comments
Catalytic Reduction

    Nonselective
    Selective
Extended
  Absorption


Wet Scrubbing
Molecular Sieve
  Adsorption
Chilled
  Absorption
Reduction of NOX and 02
with CH^, CO or H2 over
a Pt or Pd catalyst to form
N2, C02 and H20; single-
stage unit reduces N02 to
NO  (decolorization); two-
stage unit or single-stage
with temperature control
reduces NO to N2 (full
abatement).
                        Reduction of NOX only
                        with NH3 over 'a Pt
                        catalyst to form N2.
Use of a second absorption
column to increase recovery
and yield of HN03.

Scrubbing absorber tail
gases with solution of
urea, ammonia, sodium
hydroxide, sodium carbonate,
or potassium permanganate.

Removal of NOX using
adsorbent/catalyst bed con-
taining a synthetic zeolite;
thermal regeneration
recovers N02 for conver-
sion to HNOj.

Chilling absorbing solution
to increase N02 solubility
and yields of HNOj.
 Prior  to  the promulgation  of
 NSPS,  decolorization  of  the
 absorber  tail gas  was often
 profitable  because of the
 energy recovered from the
 combustion  of methane; full
 abatement now requires addi-
 tional methane and represents
 a  fuel penalty; may be oper-
 ated at high or low pressure;
 may be used in conjunction
 with extended absorption.

 Energy recovery not possible;
 may be operated at high  or
 low pressures; often  used
 with extended absorption.

 Required  inlet pressure  of
 730 kPa may necessitate  ad-
 ditional  compressor unit.

 May be operated at  low or
high pressure, but NOX
 removal greater at higher
 pressures.
High energy and capital
requirements; achieves ex-
tremely low NOX emissions
«50 ppm).
Primarily used as retrofit
on existing plants; usually
cannot meet NSPS without
other controls or lowered
acid product concentration.
                                        4-21

-------
                              TABLE 4-6

      TYPICAL  NITRIC ACID  PLANT  TAIL  GAS  EMISSION  COMPOSITIONS
                         (Percent  by  Volume)
Component
or Tail Gas
NO
N02
N2
02
H20
C02
Plant
Uncontrolled3
0.10
0.15
96.15
3.00
0.60
"~
Control Method
Catalytic
Reduction
0.01
trace
94.20
trace
3.80
2.00

Extended
Absorption"
—
0.015
96..00
3.50
0.50
"
Conventional design has been 98 percent absorption efficiency
 (this composition is typical of the tail gas before catalytic
 reduction).
     control in this plant is done by increasing the absorption
 efficiency to 99.8 percent plus.

Source:  Wyatt, 1973.
                                 4-22

-------
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4-23

-------
 the  tail  gas.   The hot  gas  from this  unit passes  to an expander which




 drives  the  process air  compressor  for the ammonia converter.   A waste




 heat boiler removes the heat  from  the expander outlet  gas  in  the form




 of steam, and  the  treated tail  gas  is vented  to the atmosphere.  In




 some cases,  a  waste heat boiler is  required after the  catalytic unit




 to keep the  expander inlet  temperature below  its  design maximum -




 usually 677°C  (1250°F).




      Catalytic reduction processes  can be divided into  two categor-




 ies:  nonselective and  selective reduction.   In nonselective  reduc-




 tion, the tail  gases  from the absorber are heated to the necessary




 ignition  temperature and mixed  with a fuel such as  methane, carbon




monoxide, or hydrogen.   This mixture  is passed  to the catalytic  re-




duction unit,  where  the  fuel reacts with  both NOX and 02 to form




C02,  H20 and N2 over  a catalyst consisting of 0.5 percent Pt  or




Pd either in the form of spherical  pellets or deposited in a  honey-




comb  ceramic material.   When methane  (natural gas)  is used as the




fuel, the following  reactions take  place:




                     CH4  + 202 -»C02 +  2H20                        (6)




                CH4 + 4N02 -» 4NO +  C02 +  2H20                     (7)




                 CH4 + 4NO -> 2N2 + C02 +  2H20                     (8)




The first two of these reactions proceed rapidly with the evolution




of considerable heat which is recovered in a waste heat boiler.  In




the second reaction or decolorization step, the nitrogen dioxide is




converted to nitric oxide,  so the gas is colorless even though there







                                 4-24

-------
 has  been  no  decrease  in the  total  nitrogen oxides.   Only the  reaction




 with additional methane as shown in  the  last  reaction  results  in  the




 reduction of the  nitric oxide  to nitrogen.  The  final  reduction step




 must be limited to  an upper  temperature  of 843°C (1550°F),  due  to  the




 catalyst  thermal  limitation.   If reduction has to be carried out  in




 the  presence of high  oxygen  concentrations  (above 3.0  percent), it




 must be performed in  two stages to prevent  exceeding the  upper  tem-




 perature  limit.  When this last reaction is complete,  total NOX




 abatement  is achieved.




      For a given fuel,  there is a minimum  ignition temperature re-




 quired to  initiate  the  reaction.  Once reaction has started the heat




 of. reaction  will maintain the temperature.  Ignition temperature is




 lowest for hydrogen and carbon monoxide, 150° to 200°C, and highest




 for  natural  gas, 480° to 510°C.




      In practice,  90  to 95 percent of the nitrogen oxides in the tail




 gas  are decomposed by this process.  Typical operating conditions  are




 summarized in Table 4-7.  The particular process conditions chosen




 depend upon  the usefulness of recovering heat, the amount of capital




 available for the  cost of heat exchangers and  related equipment, and




 the availability and cost of  fuels.  Depending on the overall  plant




heat balance, significant economic  return can  be  realized through




recovery of heat generated in the abatement unit.




     In the selective  reduction process,  ammonia  is  used to catalyti-




cally reduce N02 to  N2 without simultaneously  reacting  with







                                 4-25

-------
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oxygen.  A ceramic-supported  (either  pellets  or  honeycomb)  platinum




catalyst is used to effect  the  following  reactions:




                  8NH3 +  6N02 -»7N2 +  12  H20                       (9)




                    4NH3  +  6NO  -»5N2 +  6  H20                      (10)




Both of these reactions occur at  relatively low  temperatures  (210°  to




270°C).  Typical operating  conditions  for selective reduction are




summarized in Table 4-7.




     The advantage of this  method is that less heat is evolved and




the installation of heat  removal  equipment is unnecessary.  However,




the platinum catalyst required  is more expensive and the ammonia cost




may not be competitive with other fuels even when less is required.




Close temperature control is required to prevent ammonia oxidation,




which would increase nitrogen oxide emissions.   Start-up and  shut-




down procedures must also be closely controlled  to avoid formation of




ammonium nitrite salts.




     Catalytic reduction  is particularly suited  to the pressure




ammonia oxidation process in which the absorption tower tail gas is




of uniform composition and  flow, is under pressure, and can be




reheated by heat exchange to the necessary reduction unit feed




temperature.   Of the 19 nitric acid plants subject to NSPS which are




currently on stream,  eight feature catalytic reduction as the NO,,
                                                                X



control mechanism.
                                4-27

-------
     4.4.2  Extended Absorption




     The most obvious method of reducing NOX emissions in the tail




gas of a nitric acid plant is to increase the absorption efficiency.




Emission control by absorption is somewhat misleading, since no add-




on emission control equipment is necessary if the plant is designed




and built with sufficient absorption capacity.  The majority of




nitric acid plants built since World War II have absorbers designed




for an absorption efficiency of 98 percent, allowing an emission




of 15 to 17.5 kg of NOX (as N02) per metric ton of nitric acid.




This design factor was established by economics and the lack of air




pollution regulations.  However, with present day economics and the




advent of the NSPS, designing absorption plants for higher NOX




recovery has received more consideration.  Nitric acid plants have




been constructed with absorption systems designed for 99.8 plus




percent NOX recovery.  This recovery efficiency assures compliance




with the NOX NSPS of 1.5 kg/Mg  (3.0 Ib/ton).




     In the extended absorption process, a second absorption tower  is




added in series to  the existing absorber.  The NOX is absorbed by




water and forms nitric acid.  The  economics of the extended absorp-




tion process generally require  the inlet gas  pressure at  the absorber




to be at  least  730  kPa (107 psig).  Also, cooling is  usually required




if the inlet NOX concentration  is  above 3000  ppm.  There  is normal-




ly no liquid effluent from extended absorption; the weak  acid  from
                                  4-28

-------
the secondary absorber is recycled to the first absorber, increasing

the yield of nitric acid.  Figure 4-7 is a schematic flow sheet of a

328 Mg/day (360 tons/day) nitric acid plant using extended

absorption.  Also shown on Figure 4-7 are the. operating conditions

and utility requirements in effect at this plant.  The system shown

is the Grande Paroisse* version of the extended absorption process.

     In the D.M. Weatherly Company version of the extended absorption

system, a smaller volume and number of trays in the absorption system

is required as compared with the Grande Paroisse absorption system

due to the use of mechanical refrigeration for chilling part of the

cooling water employed.  Two cooling water systems are used for

cooling the absorbers.  The first part of the absorption process is

cooled by the normal cooling water available at the plant site.

Approximately one-third of the trays are cooled by normal cooling

water.  The balance of the trays in the absorption system, are cooled

by cooling water at about 7°C (45°F), which is achieved by mechanical

refrigeration.  The refrigeration process is a part of the ammonia

vaporization section of the nitric acid plant (Weatherly, 1976).

     The extended absorption system operates without any problems as

long as design conditions are met.  This means that the absorber

pressure and oxygen content in the gas to the absorber must not be

below design level; and the temperature and NOX content in the gas

stream must not exceed design level.  With regard to temperatures,
^
 Licensed by the J.F. Pritchard Co., Kansas City, MO.

                                  4-29

-------
4-30

-------
this system is particularly vulnerable to high summer ambient

temperatures in the southern tier of states, i.e., temperatures in

excess of 95° to 100°F.  Information from one extended absorption

nitric acid plant in Louisiana for the third quarter of 1978 seems to

confirm this problem.  In August there were 2 days when 4-hour

periods of excess NOX emissions occurred due to high ambient

temperatures (Carville, 1978).  Since the NOX vapor pressures can

be higher then the absorber can cope with during these periods of

excessive ambient temperatures, one extended absorption system vendor

will guarantee performance within the specified NOX emission limit

only 95 percent of the time (Russell, 1978).

     Of the 19 nitric acid plants currently subject to NSPS, nine

feature extended absorption as the NOX control mechanism.  It is

noteworthy that eight of these nine plants have come on stream since

the energy crisis of the mid-1970s.*   Additionally, seven of the

eight plants scheduled to come on stream by the end of 1979 (Table

4-2) feature extended absorption for NOX emission control.  It

appears that from a day-to-day operational standpoint, nitric acid

plant operators have decided that the increasing uncertainty of an

adequate natural gas supply, the principal fuel used in the catalytic

reduction units, together with the anticipated sharp increases in

natural gas price over the next few years,** have made extended
  One of these plants (a U.S. Army installation) operates inter-
  mittently and is currently down.

  Interstate natural gas price (old gas) is expected to be in the
  $1.50 to $2.00 per 1000 cubic feet range in the early 1980s, as
  compared with the present price of approximately $1.25 per 1000
  cubic feet (MITRE estimate).

                                  4-31

-------
                                                                            ;v
absorption the preferred process for NOX abatement in the future.

In cases where the new nitric acid plant is located in a fertilizer

complex* with an available contract at favorable prices an assured

low-price, long-term natural gas supply, catalytic reduction eco-

nomics are more attractive than extended absorption, provided that

fuel consumption is only slightly in excess of the stoichiometric

amount needed for NOX abatement (Byrne, 1978).
                            J.*.
     4.4.3  Molecular Sieves**

     Molecular sieves can selectively adsorb NOX from nitric acid

plant tail gas.  NOX removal is accomplished' in a fixed bed adsorp-

tion/catalyst system, providing recovery and recycle of the nitrogen

oxides back to the nitric acid plant absorption tower.  A flow dia-

gram for  a Purasiv*** control system is shown  in Figure 4-8. The

water-saturated nitric  acid  plant absorption tower overhead stream

is chilled to 7°  to  10°C  (45° to  50°F),. the  exact  temperature  level

being a  function  of  the NOX  concentration  in the tail  gas stream,

and passed through a mist eliminator  to remove entrained water and

acid mist.   The condensed water,  which  absorbs some  of the N02 in

 the tail gas  to  form a  weak  acid,  is  collected in  the  mist eliminator

and either recycled  to  the absorption  tower  or sent  to storage.  The

 dried  tail  gas  then  passes  through  a molecular sieve bed where the

 special properties  of  the NOX removal  grade  molecular sieve result

   *Where ammonia is  synthesized from natural gas.
  **This information is  taken from EPA,  1976,  unless  otherwise  noted.
 ***purasiv is the molecular  sieve system developed by Union Carbide
    Corp.

                                  4-32

-------
                                    902
4-33

-------
in the catalytic conversion of NO to N02-  This occurs in the




presence of the low concentrations of oxygen typically present in the




tail gas stream.  Nitrogen dioxide is then selectively adsorbed.  The




molecular sieve adsorbent/catalyst provides the most effective




performance and longest life when the tail gas is bone dry.  This is




accomplished by drying with a desiccant which exhibits very little




coadsorption of NOX during water removal.  The desiccant is located




in the same adsorber vessel as the NOX adsorbent/catalyst in a




compound bed arrangement.




     Regeneration is accomplished by thermal swinging (cycling) the




adsorbent/catalyst bed after  it completes  its adsorption step and




contains a high adsorption loading of N02-  The required regenera-




tion gas is obtained by heating a portion  of the  treated tail gas




stream which is then used to  desorb the  adsorbed  N0£  from the bed




for recycle back  to the nitric acid plant  absorption  tower.  The




treated tail gas  stream is passed through  an oil  or gas-fired heater




to provide heat for regeneration.  The NC^-loaded gas is recycled




to the nitric  acid absorption tower.  The  pressure drop in  the  sieve




bed averages 34 kPa and NOX outlet concentration  of the molecular




stack gas  averages 50  ppm.




     The  process  has been  successful  in  meeting NOX emission stan-




dards for  existing plants.  The  principal  criticisms  have been  high




capital  and  energy costs,  and the problems of  coupling  a cyclic sys-




tem to  a  continuous acid  plant  operation.   Furthermore, molecular
                                  4-34

-------
 sieves  are  not  considered  as  state-of-the-art technology (Acurex/




 Aerotherm,  1977).




      There  have been  no  nitric  acid  plants  built  and subject to NSPS




 which incorporate molecular sieves as  NOX control technology.




      4.4.4  Wet Scrubbing




      Wet  scrubbing involves treatment  of  the  absorber tail  gas  with




 solutions of  alkali hydroxides  or carbonates,  ammonia,  urea,  or po-




 tassium permanganate  to  absorb  NO and  N02 in  the  form of nitrate




 and/or  nitrite  salts  in  a  scrubbing  tower.  In the  case of  caustic




 scrubbing,  the  following reactions take place:




                 2NaOH +  3N02 ->2NaN03  + NO  +  H20                  (11)




                 2NaOH +  NO + N02 -»2NaN02 + H20                  (12)




 However, disposal of  the spent  scrubbing  solution presents  a serious




 water pollution  problem.  One nitric acid plant subject  to  NSPS




 employs a combination of chilled absorption and caustic  scrubbing to




 achieve NOX abatement.




     One of the more  novel scrubbing processes  uses a urea  solution




 to convert the nitrogen oxides, after oxidation to their respective




 acids,  to nitrogen and marketable ammonium nitrate:




          HN02 + CO(NH2)2 + HN03 -» N2 + C02 + NH4N03 + H20       (13)




 This process has been reported to reduce NOX emissions from 4000




 pptn to  100 ppm and can theoretically be designed  for no liquid efflu-




 ent; in practice, however,  some effluent is produced requiring waste-




water treatment.  Additionally, marketing of the ammonium nitrate is




not always possible,  creating an additional storage/disposal problem.




                                 4-35

-------

-------
5.0  INDICATIONS FROM NSPS COMPLIANCE TEST RESULTS




5.1  Test Results from EPA Regional Sources




     The MITRE Corporation, Metrek Division, conducted a survey of




all 10 EPA regions to gather ;available NSPS compliance test data for




each of the 10 industries under review (MITRE Corp., 1978);  This




survey yielded test data on two new nitric acid units.  Data included




average NOX emissions and 100 percent nitric acid production .rates




for these units in effect at the time of the test.  In both cases,




the nitric acid production rate was at the unit design maximum (the




actual production rates were within 5 to 10 percent of the nominal




design rates).  The two units were stated to be in compliance with




respect to the opacity standard.  Telephone contacts with EPA




regional personnel, nitric acid plant operators and a search of the




literature yielded NSPS compliance test data on an additional 12 new




nitric acid units.  Five new operational nitric acid units have not




been tested for compliance under NSPS as of August, 1978.  In all,




14 sets of data were obtained representing 14 new or modified nitric




acid units.




5.2  Analysis of NSPS Test Results




     The NOX emission results of the NSPS compliance tests obtained




for the 14 nitric acid units are tabulated in Table 5-1 and displayed




in Figure 5-1.  It should be noted that the data in Figure 5-1 are




displayed in terms of the three NOX control technologies used at all




of the plants subject to NSPS.
                                 5-1

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                Current EPA NSPS - Nitric Acid Plants
          Not Official NSPS  Tests
                D
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               200,       400       600       800


                     Plant  Production Rate, TPD
                                                       1000
                         1200
                            FIGURE 5-1

              NITRIC ACID PLANTS NSPS TEST RESULTS

                          NOX EMISSIONS
                                 5-3

-------
     5.2.1  Control Technology Used to Achieve Compliance

     All 14 units tested showed compliance with the NSPS NOX con-

trol level.  Of the 14 units tested, seven achieved compliance with

the NOV standard through use of the catalytic reduction process.*
      A

Of the remaining seven units, six use the extended absorption pro-

cess and one employs a combination of chilled absorption and caustic

scrubbing to meet the standard.  All of the new units meet the opac-

ity standard since opacity is directly related to NOX emissions.

     It is evident from Figure 5-1 that catalytic reduction is more

capable of control to lower NOX emission levels than extended ab-

sorption.  The arithmetic average  of  the NSPS NOX control results

is 0.22 kg/Mg of 100 percent acid  (0.44 Ib/ton) where catalytic re-

duction control  technology  is  employed, while  the arithmetic  average

of  the NSPS  test results  for  those plants using extended absorption,

is  0.91 kg/Mg of 100 percent  acid  (1.82 Ib/ton).   Thus,  both  tech-

nologies  can meet  the present  NSPS for NOX  emissions.   However, as

was  discussed  in Section 4.4.2,  it 'is likely that  the  great majority

of  nitric acid  plants built in the future will employ  extended  ab-

sorption  as  the NOX control technology.   Since extended absorption

absorption was  not in use in any U.S. nitric acid  plants at  the time
 *Most of these plants use the nonselective catalytic reduction pro-
  cess.  At least one plant uses the selective process (distinctions
  between these processes are discussed in Section 4.4.1).  All refer-
  ences to catalytic reduction in later sections of this report refer
  to the nonselective process.

                                  5-4

-------
of promulgation of the NOX NSPS, EPA had only described catalytic

reduction as the control technology capable of achieving compliance

with the standard.  With the demonstrated ability of extended ab-

sorption to control NOX emissions to within the present standard,

and the very pronounced trend to this technology for NOX control

in future plants, any changes in the NSPS must be considered in the

light of this newer technology.

     5.2.2  Comparative Economics of the Catalytic Reduction and
            Extended Absorption Processes for N0y Abatement

     Relative costs of new nitric acid plants equipped with either

catalytic reduction or extended absorption processes for NOX con-

trol, have been developed and .are shown in Table 5-2.  The costs

shown are in 1975 dollars.

     Study of Table 5-2 indicates that in terms of 1975 dollars,

the total annual operating cost ,of the catalytic reduction process

is approximately 98 percent of this cost for extended absorption.

Escalation to current costs would affect both catalytic abatement

and extended absorption in similar amounts for nearly all the items

shown in the determination of total annual operating cost.  However,

the fuel cost shown for catalytic reduction, i.e., $1.00/million BTUs

for natural gas, is not a realistic current cost.  A MITRE estimate

for a realistic volume price for interstate natural gas at present

would be in the neighborhood of $1.25/million BTUs.  This price is

likely to increase sharply in the near future.  On this basis, the
                                 5-5

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total annual operating cost (in current dollars) for the catalytic

abatement and extended absorption processes appears to be quite

comparable.  However, the investment cost for extended absorption

appears to be appreciably greater than that for catalytic abatement

based on data in Table 5-2.

5.3  Indications of the Need for a Revised Standard

     At this time, there is not sufficient justification for making

the present NOX NSPS (and the related opacity standard) moire strin-

gent, based on the following considerations:

     •  There are several alternative NOX control technologies
        available to the nitric acid industry, two of which have
        been the control systems of choice since the promulation
        of  the nitric acid plant NSPS.  These are catalytic re-
        duction and extended absorption

     •  Of  these two systems, NSPS compliance test data have clearly
        shown that catalytic reduction is the best demonstrated con-
         trol technology  (even though both NOX control systems meet
        the present NSPS), since this system of NOX control produces
        a much lower level of residual NOX in the exhaust gas than
        extended absorption (based on NSPS compliance test data).
        Additionally, catalytic reduction is a much more flexible
         system than extended absorption in that it can deal with
        upset conditions in the nitric acid plant which produce
         large NOX excursions in a much more efficient manner.*

     •  However,  the overriding consideration in determining choice of
         NOX control  systems at  the present time and in both near and
         long term, is the uncertainty of supply and sharply escalating
         cost of natural  gas—  the principal fuel used in the cataly-
         tic reduction process.  For this reason, nitric acid producers
         have opted for extended absorption NOX  control in about 50
         percent of the plants built in the last 4 years  (through mid-
         1978) and will have incorporated extended absorption NOX
         control in about 90 percent of new plants to be completed by


 *Section 6.2 presents data on NOX emissions resulting  from upset
  conditions.

                                  5-7

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        1980.  On the basis of annualized costs, the catalytic reduc-
        tion and extended absorption NOX control process appear to
        be comparable,  so that there would be minimal cost penalty for
        new nitric acid plants incorporating the extended absorption
        process.

     •   While  the extended absorption  process can maintain NOX
        emissions at  levels below  the  present standard, the emis-
        sion  levels achieved  do  not represent a very large margin
        of safety.  A principal  vendor of this equipment provides
        a normal performace guarantee  of 200 ppm of NOX in the
        nitric acid absorber  tail  gas  (equivalent to approximately
        3 Ib/ton) with  only a 7  to 8 percent margin of safety in
        terms  of absorber tray count.   The lowest performance
        guarantee which has been provided by this vendor, is 150
        ppm NOX  (equivalent to approximately 2.25 Ib/ton) in the
        latest plant  design.   Absorption towers get very large
        and costly  as the performance  guarantee on NOX emission
        level is  tightened  (Russell,  1978).  Thus,  limitations  in
        extended  absorption performance appear to preclude making
        the NSPS more stringent  at the present time.

     Other  considerations,  including  effect  of projected nitric acid

plant construction on NOX emissions  and unique features of extended

absorption which affect the NSPS,  are  discussed  in  Section 6.0.
                                  5-8

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6.0  ANALYSIS OF THE IMPACTS OF OTHER ISSUES ON THE NSPS




6.1  Effect of Projected Nitric Acid Plant Construction on Emissions




     Based on the information presented in Section 4.1, the rate of




completion of new or modified nitric acid plants during the 1971 to




mid-1978 period has been approximately two to three per year.  During




mid-1978 to 1980 period, the number of new nitric acid plants planned




or under construction continues to average about the same as the pre-




vious period.  Based on this information, and an anticipated slowdown




in nitrogen-based fertilizer exports during the early 1980^ (Chemical




and Engineering News, 1978), MITRE estimates a maximum of two new ni-




tric facilities added to existing U.S. production capacity during the




1980-1983 period.  This will result in a maximum of eight new nitric




acid production lines starting up during this 4-year period.  In




addition, replacement of older nitric acid plants during this period




is assumed to occur at  the same rate, i.e., eight replacement units




are anticipated to start-up during the 1980 to 1983 period.  Thus,




a  total of 16 nitric acid units subject to NSPS, are predicted to




come on-line during this period.  Based on data in Tables 4-2 and




4-6 these new units are expected to average about 423 Mg/day (465




tons/day) each.




     The total NOX emissions have been calculated at various NSPS




emission control levels for the 16 new units projected to be com-




pleted during the 1980-1983 period.  The results of these calcula-




tions are shown in Table 6-1.
                                  6-1

-------
     Table 6-1 indicates that halving the present NSPS control level

from 1.5 Kg/Mg (3.0 Ib/ton) to 0.75 Kg/Mg (1.5 Ib/ton) would have

a relatively small effect on total U.S. NOX emissions, considering ,

both the relation to total emissions from NSPS-controlled plants and

to total emissions from all stationary sources.  Approximately 1800

Mg/Yr ( 2000 tons/year) reduction in total NOX emissions from NSPS-

controlled plants, results from a 50-percent reduction in the NSPS

control level.  The relative national environmental impact of these

projected new nitric acid plants comparing the present NOX NSPS

control level and a 50 percent reduction of this level is very small

when considered against the total NOX emissions from all stationary

sources.

6.2  Problems Encountered by the Extended Absorption Process in
     Controlling NOY Emissions

      The extended absorption process appears to be capable of con-

trolling NOX emissions  from nitric acid plants subject to NSPS, to

less than 1.5 kg/Mg (3.0 Ib/ton) during normal operation, based on

NSPS compliance test results (see Section 5.0).  However, communi-

cation with extended absorption nitric acid plant operators indi-

cates  that problems are encountered during startup  (where process

malfunctions may exist  for several hours requiring  several rest-

arts)  and shutdown  (particularly unscheduled or emergency shut-

down).  During these periods process conditions are unstable, and

NOX emission concentrations tend to be high while production is low
                                  6-2

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or nonexistent.  No external control system is available in these




situations to reduce NOX emissions to below the control level (as




in the catalytic reduction process), and a period of excess emissions




occurs.  Limited data from two plants in their third quarter, 1978




excess emissions reports to EPA Region VI illustrate this problem




(Tables 6-2 and 6-3).
                                   6-4

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                                            TABLE 6-2

                         EXCESS EMISSIONS DATA FROM EXTENDED ABSORPTION
                                   NITRIC ACID PLANT OPEPATIONS
Plant:  CF Industries,  Donaldsonville,  LA
                                         a,b
Date
7/2/78
7/11/78
7/23/78
8/7/78-
8/16/78
8/20/78
8/22/78
8/24/78
8/25/78
8/29/78
Time Period
. 12-1 pm
1-2 pm
2-3 pm
3-4 pm
6-7 pm •
7-8 pm
8-9 pm
2-3 pm
3-4 pm
4 -5 pm
3-4 pm
4-5 pm
5-6 pm
6-7 pm
7-8 pm
6-7 pm
7-8 pm
8-9 pm
11-12 am
12-1 pm
1-2 pm
2-3 pm
11-12 am
12-1 pm
1-2 pm
2-3 pm
1-2 pm
2-3 pm
3-4 pm
1-2 pm
2-3 pm
3-4 pm
5-6 pm
6-7 pm
7-8 pm
Emissions
Lb. NOX Per
Ton of 100% HN03
3.83
4.52
4.26
3.52
5.89
4.99
4.15
5.71
6.65
3.76
4.27
4.23
3.27
5.20
3.48
4.25
5.65
2.32
2.81
3.29
3.40
3.07
2.88
3.23
3.24
3.00
5.49
4.17
3.74
4.25
2.89
2.46
3.23
2.63
3.55
Cause
Start up
Start up followed shutdown due
valve malfunction
to expander bypass
Start up
Start up followed shutdown due
temperature trip
Start up followed shutdown due
trip
to high guage
to NO compressor
Reduced absorption tower efficiency due to high
ambient temperature
Reduced absorption tower efficiency due to high
ambient temperatures
Start up followed shutdown due
trip
Start up followed shutdown due
Start up followed shutdown due
failure
to NO compressor
to mysterious trip
to electrical power
         a.  Increased  emissions occur during start ups due to lag time in establishing required
             absorption tower pressure and lowered circulating water temperature.  No external
             NO  abatement  system  is used at this acid plant.

         b.  Pounds  of  NO   are  calculated based on 225 ppm(v) equal to 3 Ibs/ton at 100 percent
             production rate.


 Source:  Carville,  1978.
                                               6-5

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7.0  FINDINGS AND RECOMMENDATIONS

     The primary objective of the report has been to assess the need

for revision of the existing NSPS for nitric acid plants, including

a review of the NOX standard.  The existing opacity standard is di-

rectly related to the NOX standard and is not reviewed separately.

The findings and recommendations developed in this area are presented

below.

7.1  Findings

     •  The best demonstrated NOX control technology used in the
        rationale for the original standard, the nonselective
        catalytic reduction process, has been largely supplanted
        in the last few years by a new control process—extended
        absorption—due to increasing cost and shortages of the
        principal fuel (natural gas) used in the former process.
        Based on this overriding consideration it appears that
        the NOx control process of choice by the nitric acid
        industry for at least the next few years will be the
        extended absorption process.

     •  Both catalytic reduction and extended absorption pro-
        cesses can achieve NOX emission control levels below the
        1.5 kg/Mg (3 Ib/ton) standard, based on NSPS compliance
        test results.  The average of seven sets of test data
        from catalytic reduction controlled plants is 0.22 kg/Mg
        (0.44 Ib/ton), and the average of six sets of test data
        from extended absorption controlled plants is 0.91 kg/Mg
        (1.82 Ib/ton).  Thus/.catalytic reduction appears to be
        capable of controlling NOX emissions to a level approx-
        imately four times lower than the extended absorption
        process based on NSPS compliance test results.   In all
        cases, the observed opacity was equal to or less than
        the opacity standard.

     •  Based on available information on the NOX emission con-
        trol capability of the extended absorption process and
        performance guarantees from a principal vendor of this
        process, there does not appear to be enough of a safety
        factor available in the extended absorption process to
        permit any substantial increase in stringency of the
        NOX standard at this time.

                                 7-1

-------
     •  While  use  of  the  extended  absorption  process  for
       NOX  control in new nitric  acid  plants will not  cause
       any  appreciable economic penalty  as compared  with  the
       use  of catalytic  reduction in meeting the present  NOX
       NSPS,  making  the  standard  more  stringent would  involve
       greatly increased capital  costs for the former  process
       since  much larger absorption towers would have  to  be
       incorporated  in the new plants  in order to meet tighter
       performance guarantees.  Investment cost  for  a  plant
       incorporating the extended absorption process may  be
       as much as 20 percent greater than that  for a nitric
       acid plant with a catalytic reduction NOX control  unit
        installed making  the catalytic  reduction  controlled plant
        less capital-intensive.

7.2  Recommendations

     At this time it  is recommended that no change be made in  the

NOV NSPS  for nitric acid  plants.   The overriding  consideration
  A

leading to this recommendation is that sharply escalating  cost and

developing long-term shortages of natural gas — the  principal fuel

used in the catalytic reduction process for NOX control — have

caused the nitric acid industry to switch to the extended absorption

process for NOX control.   Approximately 50 percent of nitric acid

plants subject to NSPS built in the  last 4 years and 90 percent of  '

plants to be  completed by  1980 will have incorporated the extended

absorption process for NOX control.

     It is further recommended that  an in-depth EPA  study be carried

out  to completely define the NOX  control capability  of the extended

absorption process before  any  future consideration can be given to

making the  current NOX NSPS more  stringent.
                                  7-2

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8.0  REFERENCES

Acurex Corporation/Aerothenn Division, 1977.  Control Techniques for
     Nitrogen Oxide Emissions from Stationary Sources.  Aerotherm
     Report TR-77-87 prepared for U.S. Environmental Protection
     Agency, Research Triangle Park, N.C.

Apple, G., 1978.  Personal communication.  Dupont Co., Glasgow,
     Del.

Baker, J., 1978.  Personal communication.  Apache Powder Co., Benson,
     Ariz.

Bain, R., 1978.  Personal communication.  IMC Corp., Fertilizer
     Group, Sterlington, La.

Berlant, M., 1978.  Personal communication.  South Coast Air Quality
     Management District, Anaheim, Calif.

Bland, J.,  1978.  Personal communication.  Allied Chemical Corp.,
     Newell, Pa.

Brown, M.L., 1976.  Nitric Acid Plant Emisson Control Grande Paroisse
     Extend Absorption.  Proc. Fertilizer Institute,  Env. Symposium,
     New Orleans, La.   January.

Byrne, D.,  1978.  Personal communications. •  D. M. Weatherly Co.,
     Altanta,  Ga.

Carville, T.E.,  1978.   Personal communications.  CF  Industries,  Inc.,
     Donaldonsville, La.

Chapman, J.D., 1973.   Oxford Regional Economic Atlas  United States
     and Canada.  Clarendon  Press,  Oxford.

Chemical and Engr.  News, August 21,  1978, p. 8.

Coop,  D.,  1978.   Personal communication.  N-Ren  Corp.,  Cincinnati,
      Ohio.

Dessert, W.,  1978.   Personal  communication.  Allied  Chemical Corp.,
      Geismar,  La.

Dezariac,  J.,  1978.  Personal  communication.  Rock  Island Arsenal,
      Rock Island,  111.

Dupont Co., 1974.   400 Series  Analyzer  Systems  Brochure.  A.D.
      Snyder,  et al.,  1971.

                                  8-1

-------
Gardner, R., 1978.  Personal communication.  U.S. EPA Region IV,
     Atlanta, Ga.

Giles, C., 1978.  Personal communication.  U.S.S. Agricultural Chem-
     icals, Crystal City, Mo.

Gillespie, G.R., et al., 1972.  Catalytic Purification of Tail Gas.
     Chemical Engineering Progress, Vol. 68, No. 4, April.

Kelly, M., 1978.  Personal communication.  Valley Nitrogen Producers,
     Inc., Fresno, Calif.

Manderson, N.C., 1972.  Nitric Acid:  the Demand/Supply Outlook for
     Nitric Acid.  Chemical Engineering Progress, 68:4,57.  April.

Mann, C., 1978.  Personal communication.  Requests and Information
     National Air Data Branch, U.S. Environmental Protection Agency,
     Research Triangle Park, N.C.

MITRE Corporation, 1978.  Regional Views on NSPS for Selected Cate-
     gories.  MTR-7772.  Metrek Division.  McLean, Va.

Murphy, D., 1978.  Personal communication.  Agrico Chemical Co.,
     Catoosa, Okla.

Read, M.J., 1978.  Personal communication.  Terra Chemicals, Inter-
     national.  Woodward, Okla.

Russell, C., 1978.  Personal communication.  J.F. Pritchard Co.,
     Kansas City, Mo.

Snyder, A.D., E.G. Eimutis, M.G. Konieek, L.V. Parts, and P.L.
     Sherman.  Instrumentation for the Determination of Nitrogen
     Oxides Content of Stationary Source Emissions, EPA Contract No.
     EHSD 71-30.

Spaniel, J., 1978.  Personal communication.  Chevron Chemical, Inc.,
     Kennewick, Wash.

Spruiell, S., 1978.  Personal communication.  U.S. EPA Region IV,
     Dallas, Texas.

Stark, J., 1978.  Personal communication.  Mississippi Chemical Co.,
     Yazoo City, Miss.

Thompson, J., 1978.  Personal communication.  Nitram, Inc., Tampa,
     Fla.
                                 8-2

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U.S. Dept. of Commerce, Bureau of the Census, 1965.  Statistical
     Abstracts of the United States, 1953-1964, Section on Chemical
     Products.  Washington, B.C.

U.S. Dept. of Commerce, Bureau of the Census, 1977.  Current Indus-
     trial Reports, Inorganic Fertilizer Materials and Related
     Products.  Washington, B.C.

U.S. Environmental Protection Agency, 1971.  Background Information
     for Proposed New Source Performance Standards.  Office of Air
     Programs.  U.S. Environmental Protection Agency.  Research
     Triangle Park, N.C.

U.S. Environmental Protection Agency, 1976.  Molecular Sieve NOX
     Control Process in Nitric Acid Plants.  EPA-600/2-76-015.
     Research Triangle Park, N.C.

U.S. Environmental Protection Agency, 1976a.  Priorities and Pro-
     cedures  for Development of Standards of Performance for New
     Stationary Sources of Atmospheric Emissions, EPA-450/3-76-020.
     Research Triangle Park, N.C.

Vick, J.J.,  1978.  Personal communication.  Monsanto Textile Co.,
     Escambia City, Fla.

Weatherly, B.M., 1976.  Catalytic Abatement and Absorption ,for NOX
     Removal  or Recovery  in Nitric Acid Plants.  Proc. Fertilizer
     Institute, Environmental Symposium, New Orleans, La.

Wolleson, W., 1978.  Personal communication.  J.R. Simplot Co.,
     Pocatello, Idaho.

Wyatt,  E.S.,  1973.  Technical Guide  for Inspection of New Source
     Nitric  Acid Plants,  Braft Report.  Prepared for Office of
     General  Enforcement,  U.S. Environmental Protection Agency,
     Washington, B.C.
                                  8-3

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
1. REPORT NO.
    EPA-450/3-79-013
                              2.
                                                             3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
    A Review  of Standards of Performance for
    New Stationary Sources — Nitric Acid Plants
                                                             5. REPORT DATE
                January  1979
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)

    Marvin  Drabkin
             8. PERFORMING ORGANIZATION REPORT NO.



               MTR-7911     -  -
9. PERFORMING ORGANIZATION NAME AND ADDRESS

  Metrek Division of the MITRE  Corporation
  1820 Do!ley  Madison Boulevard
  Me Lean, VA   22102
                                                             10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

                68-02-2526
12. SPONSORING AGENCY NAME AND ADDRESS
                                                             13. TYPE OF REPORT AND PERIOD COVERED
  DAM for Air  Quality Planning  and Standards
  Office of Air,  Noise, and  Radiation
  U.  S. Environmental Protection Agency
  Research Triangle Park, NC 27711	
             14. SPONSORING AGENCY CODE
                EPA  200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
   This  report reviews the  current Standards  of Performance for New Stationary
   Sources:   Subpart 6 -  Nitric Acid Plants.   It includes a summary of the: current
   standards, the status  of current applicable control technology, and the ability
   of plants to meet the  current standards.   Information used  in this report is
   based upon data available as of June  1978.   The recommendations state that no
   change be made at this time in the NOX  NSPS for nitric acid plants, but that
   a  study be made of the NOX control capability of the extended absorption process.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
a.
                   DESCRIPTORS
                                                b.lDENTIFIERS/OPEN ENDED TERMS
                            c.  COSATI Field/Group
                                                                              13B
18. DISTRIBUTION STATEMENT

  Release  Unlimited


EPA Fofm 2220-1 (Rev. 4-77}   PREVIOUS EDITION is OBSOLETE
19. SECURITY CLASS (ThisReport)
  Unclassified
                                                                            21. NO. OF PAGES
72
20. SECURITY CLASS (Thispage)
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                            22. PRICE

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