Wednesday, July 1, 2020

Consultant: US Nitrogen Violated Permit

By Walter F. Roche Jr.

An environmental consultant says US Nitrogen violated its state permit by emitting up to three times the allowable level of ammonia from its Greene County manufacturing facility.
In a three-page letter to Michelle Owenby of the Tennessee Department of Environment and Conservation the consultant called on the state to issue a notice of violation to US Nitrogen, order an immediate reduction of production at the Midway plant and impose "appropriate penalties to change USN's behaviour regarding the environment."
D. Howard Gebhart of Air Resource Specialists said that recent tests at US Nitrogen showed excess ammonia emissions were recorded under "each and every condition." He submitted the report in behalf of Park Overall and other local opponents of the company operations
Noting that the state permit caps the amount of ammonia the company can emit into the atmosphere at 3.5 tons over any continuous 12 month period, Gebhart found, based on data from US Nitrogen itself, that US Nitrogen was emitting some 10.6 tons of ammonia per year.
"There is credible evidence that USN has been operating in violation of Permit 47892 by releasing more than 3.5 tons of ammonia emissions into the atmosphere," the letter states.
He noted that "excess ammonia emissions are a concern for various reasons,"including a strong odor, irritation and burns of the skin, eyes and lungs.
Gebhart said data submitted by US Nitrogen to TDEC previously showed the company operated its two ammonia production trains "more or less continuously in 2019." He noted that a recent compliance report from the company omitted a notice of compliance with the ammonia limit.
In addition to calling for TDEC to issue a notice of violation and impose a fine, Gebhart said TDEC should order US Nitrogen to prepare and implement a corrective action plan, require the company to submit more frequent testing data and require that a third party be hired to audit the company's actions.

Friday, June 26, 2020

Consultant Questions USN Test Results

By Walter F. Roche Jr.

A consultant who reviewed recent test results from US Nitrogen LLC says the data indicate the company could exceed its permit limit for ammonia emissions.
Howard Gebhart of Air Resources Specialists, who analyzed the test data at the request of Greene County environmental advocate Park Overall, called the test results "concerning."
Gebhart said the data show that if the company's ammonia plant runs continuously it would exceed the 3.5 ton per year limit in the company's permit from the Tennessee Department of Environment and Conservation.
Even a single ammonia plant, (the company has two) could exceed that 3.5 ton limit, Gebhart concluded.
Overall noted that TDEC posted the results from a carbon monoxide test, but not the ammonia emissions test.
"Why is Bryan Carter of TDEC saying carbon monoxide is okay in the tests? Why does he not mention ammonia in the tests?"Overall asked."Is Midway their testing ground?"
The tests which Gebhart reviewed were conducted in April and TDEC officials have recently acknowledged they have obtained the results.
"The testing results are concerning because US Nitrogen cannot operate the ammonia plant on a continuous basis without exceeding the current ammonia emissions limit," Gebhart wrote.
US Nitrogen did not respond to requests for ccomment.

Thursday, June 25, 2020

TN Accepts US Nitrogen Test Results

By Walter F. Roche Jr.

Tennessee environmental officials have accepted the results of recent performance tests at a Greene County chemical firm's anhydrous ammonia production plant which showed the firm met the standards set forth in its state permit.
In a two-page letter to US Nitrogen, Bryan Parker a Tennessee Department of Environment and Conservation manager, wrote that his agency accepted the test results on carbon monoxide emissions which were performed April 14-15 by AMP Cherokee Environmental Solutions.
According to Parker's letter the tests were performed under four different sets of conditions and under each of those conditions carbon monoxide limits were met.
"The division agrees that US Nitrogen has fulfilled the performance test required" under its permit, the letter states.
"Based on this review, the division determined the report technically correct with regard to the test procedures employed," the letter states
He added that the tests also met the timeline requirements of its permit.
The letter notes that there are two ammonia production trains at the plant, each capable of producing 73 tons of ammonia over a 12 month period.

Tuesday, June 16, 2020

TDEC Seeks to Amend Praxair Permit

By Walter F. Roche Jr.

Tennessee environmental officials have issued a new and amended permit to a Greene County firm to correct a typographical error contained in the original permit issued several months ago.
The amended permit was issued by the Tennessee Department of Environment and Conservation to Praxair Inc, a company that supplies liquid carbon dioxide to the beverage industry.
The permit issued by TDEC in February left out the word "shall" in a section setting a limit on the allowable visible emissions from the company's Midway manufacturing operations. The omission had the effect of eliminating the limit.
"Visible emissions from this facility shall not exhibit greater than 20 percent," the amended permit states.
The permit limits Praxair to the production of 90,789 tons of liquefied carbon dioxide in any 12 month period.
Praxair is one of three firms occupying a Midway site. The original occupant, US Nitrogen, produces ammonium nitrate and related products for its parent company, Austin Powder, an Ohio based explosives manufacturer.
The third firm, which has yet to go into operation is Yara Inc., a manufacturer of calcium nitrate.

Wednesday, June 10, 2020

US Nitrogen Ups River Use

By Walter F. Roche Jr.

The amount of free water drawn from a Tennessee river by a Greene County chemical firm jumped to 17 million gallons in May, a more than 4 million gallon increase, according to a report filed with the Tennessee Department of Environment and Conservation.
The report filed today by US Nitrogen LLC shows the company pumped more than a million gallons per day from the Nolichucky River on seven days. The largest single day amount, 1.16 million gallons, was pumped to the Midway manufacturing facility on May 29. Minimal amounts were pumped from the Nolichucky on five days during the month.
Under its state permit, US Nitrogen is allowed to pump from the river at no charge. The permit does require the company to file monthly reports.
US Nitrogen uses the river water in the production of ammonium nitrate. The company has a separate permit which permits it to discharge unneeded water back in to the river.
During May the company discharged 6.4 million gallons back into the river. The largest amount, just shy of 500,000 gallons, was discharged on May 27. On 10 days the company discharged a minimal amount in to the river.
The May totals reflect a big jump from April when only 13 million gallons of water were pumped from the river, while 5.4 million was discharged back into the Nolichucky.

Tuesday, June 9, 2020

More US Nitrogen Tests Scheduled

By Walter F. Roche Jr.

US Nitrogen LLC, which has just completed one set of compliance tests, is about to undergo additional tests to ensure its operations comply with limits on ammonia and visible emissions ...and still other engineering tests are in the planning stages.
Under a plan submitted in May, a third party, AMP Cherokee Environmental Solutions, will, conduct emissions tests on June 14 and June 15.
In a 15-page filing with the Tennessee Department of Environment and Conservation, the Greene County chemical firm disclosed how the tests will be conducted in compliance with state and federal environmental requirements.
In new filings this week US Nitrogen told TDEC it is also be going to conduct engineering tests that "correlate nitrous oxide emissions with fuel combustion and ammonia injection."
According to the test protocol filed with the state, the tests will establish the rate of ammonia injections that ensure compliance with nitrous oxide limits "and do not result in ammonia slip that exceeds the ammonia emission limit."
According to the protocol, the company is proposing that it be allowed to exceed one condition of its current permit but that would occur only on the testing cycle.
Allowing the deviation, the protocol states would enable US Nitrogen "to collect valid operational data on nitrous oxide generation at various gas flows."
"US Nitrogen does not anticipate any permit emission limits to be exceeded," the protocol concludes.
The two upcoming tests follow additional emission tests performed at the Midway facility earlier this year. A TDEC spokeswoman said those tests were successfully completed.

Monday, May 18, 2020
US Nitrogen Submits Test Plans

By Walter F. Roche Jr.

A Greene County chemical firm has submitted a 15-page document detailing how tests will be conducted to determine if the Midway facility is operating in compliance with permits issued by the Tennessee Department of Environment and Conservation.
US Nitrogen LLC, which manufactures ammonium nitrate and related products, submitted the details of how tests will be conducted to show compliance limits for emissions of ammonia and visible emissions. The tests will be conducted by a third party, AMP Cherokee Environmental Solutions.
The US Nitrogen submission also provides a detailed description of the three step process of manufacturing nitric acid, a key component in the process.
According to the filing the test will determine if the company's pollution control equipment including a selective catalytic reduction unit adequately controls nitrous oxide and related emissions.
The testing document states that the process produces nitric acid by combining nitrogen dioxide and nitrogen tetroxide with water.
Under the permit US Nitrogen is limited to the production of 600 tons of nitric acid per day. Under the test protocol a minimum daily production level of 451 tons.
A series of charts and diagrams show where AMP Cherokee will collect samples to determine compliance.
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Wednesday, May 20, 2020

US Nitrogen Application Questioned

By Walter F. Roche Jr.

Tennessee environmental officials have raised questions about an application form recently submitted by a chemical manufacturing firm and are asking whether the company is producing chemicals for other purposes than those currently approved.
In an e-mail to US Nitrogen's Stephen Wallace, TDEC's Maybelle Sparks wrote that an application submitted by US Nitrogen on April 27 contained language that "seems to imply that some ANSOL (Ammonium Nitrate Solution) may be used for purposes other than the manufacture of explosives."
"Will ANSOL be used for any other purpose," the email concludes.
The April 27 US Nitrogen application was for the renewal of the permit that allows the Midway firm to discharge effluent back into the Nolichucky River.
The email also warns US Nitrogen that because of the notice of incompleteness, the agency may request additional submissions in the future.
The language sparking the inquiry refers to secondary operations that may also include production of calcium nitrate and compresed carbon dioxide gas.
Those products, according to prior filings, are actually to be produced by two companies, Praxair and Yara, sharing the Midway site with US Nitrogen.
In another development TDEC officials reported that US Nitrogen successfully completed testing of its operations on May 14 and 15.
TDEC spokeswoman said the results of the emissions factor test will be used to establish parameters to determine the company's continued compliance with its permits.