US Nitrogen Clarifies "Insignificant" Request

By Walter F. Roche Jr.

Officials of US Nitrogen have told Tennessee regulators that two rail cars that will be utilized in processing millions of gallons of a new chemical on its Green County site should not be considered as stationary sources under state and federal air pollution regulations.
In a letter sent to the Tennessee Department of Environment and Conservation, newly appointed US Nitrogen plant manager Dylan Charles said the rail cars were not a stationary source but should be considered as "rolling stock."
Previously, however, the company had told TDEC that the rail cars would be on site 24-hours-a-day and seven-days-a-week as part of a new process to produce a volatile chemical called RDT-8.
In the prior letter to TDEC the company disclosed that the new production operation would involve the mixing of oil and an emulsifier and would require the use of four tanks with a combined capacity of 128,400 gallons.
According to the original request, the company plans to produce some 43.8 million gallons per year of RDT-8.
Disclosure of US Nitrogen's plans brought protests from some area residents who have called on the state to hold public hearings on what they consider to be an entirely new operation.
In the latest letter the company said that classifying the rail cars as "rolling stock" rather than a stationary source is part of their contention that the new operation should be considered an insignificant source not needing a permit.
The most recent notice, the letter continues, "was not intended to be an application but to notify the state of the intent for constructing stationary sources and request a concurrence that the activity is considered insignificant."
Charles wrote in the letter to Doug Wright of TDEC's air pollution control that inclusion of information on rail car emissions was meant only to provide the "most information" to the agency but should not be considered as an application.
In another development TDEC informed US Nitrogen that its application to have limits on greenhouse gas limitations is now considered complete. The company is asking that the limits be eliminated in light of a U.S. Supreme Court ruling and a subsequent new policy statement issued by the U.S. Environmental Protection Agency.
TDEC had previously advised the company its application was considered incomplete, but now the agency says sufficient information has been submitted and the application will be processed.
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US Nitrogen Names Another Manager

By Walter F. Roche Jr.

For the fourth time since locating in eastern Tennessee in 2012, a major chemical company has named a a new manager at its $200 million facility in Midway.
In a letter to officials of the Tennessee Department of Environment and Conservation the ammonium nitrate manufacturer disclosed that Dylan Charles has been named plant manager and the "responsible person" under a series of state permits.
According to the letter dated Oct. 16, Andrew Velo, the former plant manager, now has the title of director of manufacturing. Velo replaced Justin Freeark, who left in late 2015.
Freeark became the "responsible person" after Shawn Rana left the company. Rana held a different title than Freeark, vice president.
US Nitrogen also this week responded to questions raised by TDEC over a proposal by the company to amend one of its permits to enable the company to disable a burner now used in the manufacturing process.
TDEC had asked for further information on whether the burner already had been disabled and, if not, when it was planned and how it would be accomplished.
In his written response for US Nitrogen Charles said they planned to remove part of the piping that delivers natural gas to the burner and then cap the remaining pipe.
The company said the capping had not yet taken place and would be delayed until the state acted on a modification to a pending construction permit.
In a related development, Yara International, which is constructing a facility on the same site as US Nitrogen, submitted a $50 application fee requested by TDEC before the agency will act on a request to eliminate a limit on greenhouse gases in its current permit .
The company has cited a U.S. Supreme Court ruling and a related new U.S. Environmental Agency policy directive to justify the change.
Yara, US Nitrogen and a third company, Praxair LLC originally operated under one permit as a so-called "single source," but they are now seeking to operate as separate sources due to the changes in EPA policy.
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Another US Nitrogen Application Incomplete

By Walter F. Roche Jr.

For the second time in two weeks state environmental regulators have turned back a request for a permit change by US Nitrogen because the information provided was deemed incomplete.
In a letter sent today to US Nitrogen, a section manager at the Tennessee Department of Environment and Conservation, wrote that the application cannot be processed without more detail on how the the company plans or already has disabled auxillary burners in the ammonium nitrate production process.
"Please specify the method of disabling the burner and the dates the burners were disabled," Douglas Wright of TDEC wrote.
He added that if the burners have not yet been disabled, the company should specify the date they will be.
Today's letter follows an Oct. 4 letter to Velo on the company application to begin a new production procedure requiring the use of large tanks for storage and mixing of components.
In that letter TDEC Deputy Director James P. Johnston told US Nitrogen that nine additional forms would have to be submitted for the application to be considered.
The missing items include eight forms providing additional data on the four tanks the Midway firm wants to locate on its property.
The application seeks approval for the company to produce 43.8 million gallons per year of RDT-8, a flammable substance used in the production of explosives. The four tanks would have a combined capacity of 128,400 gallons.
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US Nitrogen Draws 13+ Million Gallons

By Walter F. Roche Jr.

US Nitrogen, the Greene County chemical firm drew 13.84 million gallons of water from the Nolichucky River in August, down substantially from the prior month.
In a report filed today with the Tennessee Department of Environment and Conservation, the company reported that on six days during the month it drew a little more than 1 million gallons from the river for use in its manufacturing operations.
The September total was down by more than 20 percent or nearly five million gallons from the amount the company pumped from the river in August.
The monthly report shows that during the same period, the ammonium nitrate manufacturer discharged 5.83 million gallons back in to the river. That figure is slightly higher than the 5.7 million discharged into the river in August.
According to the new report there were no discharges into the Nolichucky on 17 days during September.
There were two periods during the month from Sept. 1 to Sept. 4 and from Sept. 27 to Sept. 30 when no water was discharged for four days in a row.
US Nitrogen is required to file the reports on river water usage every month under the terms of its permit. The latest report, unlike previous submissions, does not provide monthly totals for each category.
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US Nitrogen Application " Incomplete"

By Walter F. Roche Jr.

Tennessee environmental officials have concluded that the application recently submitted by US Nitrogen to begin a new operation in Greene County is incomplete and several additional documents must be filled out and submitted before it can be considered.
In a letter sent Thursday to US Nitrogen manager Andrew Velo, an official of the Tennessee Department of Environment and Conservation, wrote that the Sept. 11 application would be put on hold until additional data is submitted.
James P. Johnston, a TDEC deputy director, advised US Nitrogen that nine additional forms must be submitted for the application to be considered.
The missing items include eight forms providing additional data on the four tanks the Midway firm wants to locate on its property.
The application submitted by Velo seeks approval for the company to produce 43.8 million gallons per year of RDT-8, a flammable substance used in the production of explosives. The four tanks would have a combined capacity of 128,400 gallons.
Velo wrote in his letter that the new operation also would require the constant presence at the site of two rail cars which will be used for storage and oil from tankers will be transferred to a mixing tank where oil and an emulsifier will be combined. The end product will be an ammonium nitrate emulsion.
Disclosure of US Nitrogen's plans has prompted several area residents to protest the proposal. In emails to TDEC the area residents have asked for a thorough review of the proposal at both the state and county level.
In the letter to Velo, Johnston wrote, "If you fail to submit a complete application within the 180 day time period, all construction permits shall be denied and any fees forfeited."
He told Velo that if any additional deficiencies are found, the company will have the 180 day period to submit corrections or additional data.
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Residents Challenge New US Nitrogen Operation

By Walter F. Roche Jr.

Several Greene County residents are calling on Tennessee officials to hold a public hearing and fully investigate a new operation at US Nitrogen, the Midway firm which is a subsidiary of a major explosives manufacturer.
The calls for an investigation and a public hearing were registered recently with the Tennessee Department of Environment and Conservation, the agency being asked to approve US Nitrogen's recent application to begin producing RDR-8, a hazardous and flammable substance used in the manufacture of explosives.
Charging that the new production "constitutes a new use that has not been previously reviewed or approved," Robert Drake wrote that the new operation "only increases the quantities of hazardous materials produced and stored at US Nitrogen."
Bonnie Hilliard wrote in an email that a public hearing was needed before the company begins producing hazardous and flammable materials used in explosives.
"We are watching and aware," she concluded.
In a recent filing with TDEC US Nitrogen said it planned to produce some 43.4 million gallons of RDT-8 a year. The new operation will include four storage tanks with a combined capacity of 128,400 gallons.
The company told the state the operation will require the presence 365 days a year of two rail cars. The rail cars will be used for storage and the oil from tankers will be transferred to a mix tank where the oil and an emulsifier will be combined to produce a bulk ammonium nitrate emulsion.
Veronica Cox, another local resident, wasted no words in her email to TDEC.
"Stop this madness. Here's a news flash," she wrote,"Our lives mean more than a manufacturing plant. We need a detailed technical review."
Susan Craig, who also wrote to express her "vehement opposition" to the project wrote, "I have children and grandchildren who live within a five mile radius."
She said that she received a brief reply to her letter from a TDEC official who told her he would pass along her comments to TDEC's air pollution control branch.
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