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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