Friday, December 29, 2017

Faulty Data Submitted by US Nitrogen


By Walter F. Roche Jr.

Prompted by concerns from the U.S. Environmental Protection Agency, Tennessee regulators have determined that US Nitrogen under reported the amount of nitric acid produced at its Midway plant in reports filed with the Tennessee Department of Environment and Conservation.
According to a letter issued today by a TDEC official from the Division of Air Pollution Control, the ammonium nitrate manufacturer submitted reports showing an unexplained dip in acid production on April 27.
After learning that a measuring device had been "inadvertently reset" and the totals listed for the day covered only a 12 hour period and not the full day of production, the state requested revised data..
"The original data on nitric acid production represented only the production for the 12 hour period after the acid production totalizer was reset," Jeryl Stewart wrote in the letter to US Nitrogen.
According to the letter US Nitrogen when first asked about the apparent discrepancy, they revised the estimate to 298 tons for that day.
In his letter Stewart said the revised estimate had a "low bias" and the actual production was 376 tons.
Stewart said the data was originally accepted by the state on June 15 based on assurances from US Nitrogen.
Subsequently, however, EPA officials expressed concern about the low reported acid production rate for that date of only 187 tons.
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Friday, December 22, 2017

US Nitrogen Draws Nearly 15 Million Gallons


By Walter F. Roche Jr.

US Nitrogen drew just shy of 15 million gallons of water from the Nolichucky River in November, according to a monthly report filed with the Tennessee Department of Environment and Conservation.
The report shows a total of 14.9 million gallons were withdrawn from the river while 8.2 million were discharged into the Nolichucky in Greene County.
That compares with 14.6 million gallons withdrawn by the Midway chemical firm from the river in October. The company discharged .9 million gallons to the river during the same month.
The report from Kimberly Ryans, a US Nitrogen environmental official, shows just under 1 million gallons were withdrawn from the river on Nov. 18, Nov. 19 and Nov. 2.
There were no discharges to the river on Nov. 1-3, the report states.
The company uses the river water in the production of ammonium nitrate which is then shipped to US Nitrogen's parent, Austin Powder, an Ohio explosives manufacturer.
The use of the river water has drawn opposition from some local citizens who contend the withdrawals threaten the river's existence. The water is withdrawn and discharged to the river through 12 miles of pipeline under a permit from the Tennessee Department of Transportation. The permit is under a legal challenge in a suit pending in Davidson Chancery Court.
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Sunday, December 17, 2017

Overall Calls for US Nitrogen Hearing


By Walter F. Roche Jr.

A local activist and opponent of the US Nitrogen's Greene County operations is calling on Tennessee officials to combine a series of recent requests from the chemical company and hold a public hearing so local citizens can voice their concerns.
In a letter sent last week to an official of the Tennessee Department of Environment and Conservation, Park Overall of Afton said US Nitrogen's history has shown that the company is not capable of running the ammonium nitrate plant safely.
Noting a flurry of recent requests for amendments to its permits or exemption from existing regulations, Overall wrote that the agency needs to consider the combined impact of all those proposed changes.
The most recent request submitted to TDEC asks that the company be exempted from limits on visible emissions during start-up and shut-down operations. Other pending requests include an extension of a permit for a carbon dioxide liquefaction operation and an amendment to a flare permit.
One US Nitrogen request regarding a 52,000 gallon storage tank was approved just as Overall submitted her letter.
"Excess emissions that are caused by poor maintenance, careless operations or other preventable conditions do not qualify for any exemptions," Overall wrote in the letter to Michelle Owenby, a TDEC director.
Citing concerns of local residents over the health impact of US Nitrogen's operations, Overall asked that all the pending requests be combined and considered looking at their cumulative impact.
"To those living near the plant site, US Nitrogen's flurry of recent requests only reinforces the notion that serious problems exist with the construction and operation of the facility," the letter continues.
Stating that "history is also littered with uncontrolled accidental releases that show an inability to  safely operate this facility," Overall asked the agency to hold a public hearing in Midway, where US Nitrogen is located, before acting on any of the pending requests.
Overall also requested a series of TDEC records regarding US Nitrogen's existing and requested permits. She also questioned why the company did not previously report the excess emissions during start-up or shut-down procedures.
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Wednesday, December 13, 2017

US Nitrogen Seeks Emissions Easement


By Walter F. Roche Jr.

For the second time in less than a week, US Nitrogen, a Midway, Tenn. chemical company, is asking Tennessee environmental for an easement, this time in the allowable level of visible emissions from its nitric acid plant.
In a two-page letter to Michelle Owenby, a director at the Tennessee Department of Environment and Conservation, US Nitrogen's plant manager Andrew Velo said the excess emission "are necessary or unavoidable due to routine startup and shutdown conditions at our nitric acid plant."
The request comes just five days after the company asked for an extension on yet another state permit related to a carbon dioxide liquefaction operation on the site.
In his letter dated Dec. 11, Velo cited more than a year's worth of observations of startups and shutdowns conducted in conjunction with TDEC officials.
"In addition we have made numerous process and equipment changes during that time to reduce the opacity of emissions during startups and there has been considerable improvement," Velo wrote, adding that the company has succeeded in reducing by 20 percent the length of time that emissions are exceeded during startups.
Velo cited similar easements granted previously by the state to Eastman Chemical and the Tennessee Valley Authority.
He also cited a provision in state regulations allowing for limits to be exceeded during periods of startup, shutdown or malfunction.
"Therefore it seems the intent of the above referenced sub-part should be applicable and allow for opacity during startups, shutdowns and malfunctions," Velo concluded.
Are residents have registered frequent complaints about emissions from the ammonium nitrate manufacturing facility, but TDEC officials have thus far labeled the complaints unfounded
US Nitrogen officials did not respond to a request for comment.
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Wednesday, December 6, 2017

US Nitrogen Seeks Permit Extension


By Walter F. Roche Jr.

US Nitrogen is asking Tennessee officials for a six month extension on a construction permit for a new carbon dioxide liquefaction facility that is slated for use by a separate company.
In a letter sent this week to an official of the state Department of Environment and Conservation, US Nitrogen Plant Manager Andrew Velo said that while the facility is "almost complete," additional time may be necessary. The current permit expires at the end of the calendar year.
Velo said that a startup is expected before Dec. 31 but additional time could be needed for start-up and to confirm operations are going as expected following start-up."
The liquefaction facility will be used by Praxair, a company that sells carbon dioxide to beverage and other users. The extension, if approved, would run till June 30 of next year.
The request is the second sought by US Nitrogen following a critical inspection report issued by TDEC officials. Earlier this week the company also sought a ninth amendment to a permit for a flare system used in the production of ammonium nitrate, the Greene County company's primary product.
The inspection report was the result of a nearly month-long on-site inspection of the Midway manufacturing operation.
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Tuesday, December 5, 2017

US Nitrogen Seeks Flare Permit Change


By Walter F. Roche Jr.

On the heels of a violation notice from Tennessee environmental officials, US Nitrogen is seeking  approval for yet another change in one of its permits for the Greene County ammonium nitrate manufacturing facility.
In a three-page letter to the Department of Environment and Conservation US Nitrogen is asking for a change in the permit issued for three flares used to vent gas emissions. In the letter, US Nitrogen Plant Manager Andrew Velo states that the changes would actually result in a decrease in emissions.
'This amendment affects all three flares covered by the open flares permit," Velo wrote in the Dec. 4 letter.
The amendment request was filed just days after TDEC issued a notice of violation to the company following a nearly one month inspection of the Midway operation.
Velo states that two of the flares are located at the two existing ammonia plants, while a third is "outside the battery limits."
The amendments would change the maximum heat capacities and result in an "overall reduction of emissions," according to the letter.
The amendment would also change the gas streams vented to each flare.
The request, the letter continues, is based on the assumption that 98 percent of the ammonia will be converted to elemental nitrogen and water. One percent will remain unconverted and one percent will convert to NO/NO2, according to the Velo letter.
The 16-page notice of violation was issued late last week and it requires the company to file a schedule for completion of needed changes by Jan. 10. The letter faults the company for not informing the state of a change in production and for not reporting "an operational mishap" that caused contamination of the steam system.
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Monday, December 4, 2017

State Inspection Cites Multiple USN Deficiencies



By Walter F. Roche Jr.


A nearly month long inspection of US Nitrogen's sprawling Greene County facilities has turned up numerous deficiencies in meeting state permit requirements including the failure to inform the state of changes in production and an apparent mishap.
In a 16-page letter to US Nitrogen's plant manager, Andrew Velo, the Tennessee Department of Environment and Conservation said a proposed corrective action plan must be filed with the agency by Jan. 10, along with a schedule for completion of need changes.
According to the letter from, Chris Rhodes, TDEC's Water Resources Division Manager, the on site inspection began on Oct. 17 and was completed Nov. 15. Two TDEC officials led the review but an official from the U.S. Environmental Protection Agency was also on hand.
As Rhodes noted some of the same deficiencies were noted in an earlier inspection. In addition to the long list of deficiencies, the letter cites other observations which could lead to future deficiencies.
The state cited the company for failing to inform TDEC of either changes in manufacturing operations or apparent deficiencies.
"Facilities for production of an ammonium nitrate solution-fuel emulsion  were in place and operating. Plans to produce aqueous ammonia and a fertilizer product referred to as AN-20 were underway," the letter states, adding that on site facilities for Praxair, a separate company, were nearing completion.
"Changes to products produced at the site may impact the applicable (NPDES) permit limitations for facility discharges," the letter warns.
Also cited were apparent changes in the use of a retention pond.
"The division hereby requests updated information detailing all production facilities, associated products and retention pond operation in place or planned for the future in order to evaluate whether changes to the (NPDES) permit are needed," the letter continues.
The on site review also turned up evidence of an "operational mishap" in early 2016 which resulted in the contamination of the steam system by an ammonium nitrate solution. The letter states that the company attempted to eliminate the contamination by flushing the system.
"Note that this type of situation should be reported to the division so that any need for permit modification can be evaluated and to provide division staff an opportunity for technical support," the letter states.
Other deficiencies cited included failure to verify meter calibrations on an annual basis, failure to record and verify thermometer readings and failure of some employees to sign reports.
TDEC also faulted the company for not notifying the state about spills on the property.
"US Nitrogen must take care to ensure that appropriate spill notifications are being made to the Division of Water Resources and/or other TDEC divisions as necessary," the letter states.
Training certification was missing for one employee and employee signatures on other training records were illegible, the inspectors found. Finally, the report states,  the company had listed the wrong TDEC officials as the contacts for various state permits.
The 23-page report faults the company for not notifying TDEC of changes in the product production and failing to report a 2016 "operational mishap" that caused contamination of the steam system.
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Friday, December 1, 2017

Three Chemicals Exceed Limits at USN


By Walter F. Roche Jr.

Storm water runoff from the US Nitrogen site in Greene County exceeded benchmarks for three different pollutants, with one exceeding that limit by a factor of 12, according to a report filed today with Tennessee officials.
The report, required on an annual basis by the Tennessee Department of Environment and Conservation, showed the excesses were recorded at two different monitoring sites in the sprawling US Nitrogen complex. The chemicals identified were magnesium, nitrogen and aluminum.
The report dated Thursday marks the third year in a row that benchmark levels have been exceeded by the chemical manufacturing company.
In a letter accompanying the report, US Nitrogen Plant Manager Andrew Velo said the cause of the excesses was not known but "we suspect the source of the magnesium and aluminum detected in the storm water samples is from concentrations and/or form water flowing across rock."
He also noted that one of the monitoring sites was located in a "non-process area of the facility" that gets runoff from maintenance buildings.
The report states that magnesium levels at one of the monitoring points was 7.91 milligrams per liter compared to the benchmark of 0.0636 milligrams per liter.
Nitrogen and nitrite concentrations were reported at 1.33 milligrams per liter compared to the benchmark concentration of 0.68 milligrams per liter.
Aluminum levels were 3.58 milligrams per liter compared to the 0.75 milligrams per liter benchmark.
Velo stated that concentrations exceeding the benchmark level have been recorded elsewhere in the area in the Nolichucky River and other surface waters.
He also stated that nitrogen was present in fertilizer used on the company site "to encourage vegetative growth and prevent soil erosion."
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