TDEC Investigating USN Complaints

By Walter F. Roche Jr.

Tennessee environmental officials say they are investigating complaints of fire on July 23 at the US Nitrogen LLC facility in Greene County.
Sherry Cooper, a resident who lives near the chemical company complex in Midway, registered a complaint with the Tennessee Department of Environment and Conservation in which she described seeing bright orange flames at the ammonium nitrate facility.
"All at once I seen this big orange flames and gases flowing way above the treeline it looked like the building was on fire," Cooper wrote in an email to TDEC.
Kim Schofinski, a TDEC spokeswoman, acknowledged the complaint and said it was currently under investigation.
Park Overall, a local environmental activist, also reported the incident to TDEC and both Overall and Cooper provided photographs of the incident.
Cooper said in her email that she was alerted to the incident by a friend at 10:49 p.m. on July 23.
She wrote in the email that she had barely gone two tenths of a mile down Little Chuckey Road when she saw the flames.
She said when she called police to complain she was told "they were just burning off in the pipes. They do it every now and then."
Cooper said in her email that she has seen other such incidents but few were as bad as July 23.
Overall also registered a complaint with TDEC describing a heavy odor in the air. "It had odor. It was like a fog," she wrote in an email to TDEC. Contact: wfrochejr999@gmail.com

More US Nitrogen Testing OK'd

By Walter F. Roche Jr.

Tennessee environmental officials have approved plans for additional testing at a Greene County chemical firm after the results of April testing were judged inconclusive.
The testing at US Nitrogen LLC is now scheduled for July 30 and July 31.
Bryan Parker, environmental manager at the Tennessee Department of Environment and Conservation, notified US Nitrogen of the approval.
Parker also wrote a response to an environmental consultant who raised questions about the April testing results and whether US Nitrogen was in violation of its permit.
The two days of testing, according to Parker's letter, will "establish a range of ammonia injection rates at varying gas fuel rates that ensure compliance with nitrous oxide emission limits."
According to Parker the two days of testing will have 24 steps and include three different fuel injection rates.
"The division agrees with the test plan as written," Parker wrote in the letter to Stephen Wallace, a US Nitrogen manager.
Stating that TDEC will have a representative present to witness the testing, Parker added that any changes in the test plans will have to be approved by TDEC.
Parker, in a separate letter to D. Howard Gebhart, disputed the environmental consultant's conclusions about US Nitrogen's compliance with its permit.
Gebhart was retained by local opponents of the ammonium nitrate plant, including Park Overall.
"The bulk of your letter consists of extrapolating the ammonia emissions reported from these brief duration engineering tests. This is not a technically valid approach," Parker wrote, adding that the April tests were not intended to be official performance testing.
Parker charged that Gebhart's conclusion were based on the assumption that the plant would be in full operation all year.
"It is physically impossible for synthetic ammonia plants to operate continuously during a year," Parker concluded.
Parker did not address Gebhart's concerns that the April tests revealed that US Nitrogen was operating for an undetermined length of time with contaminated anti-pollution equipment.
Contact: wfrochejr999@gmail.com

Consultant: USN Violated Permit

By Walter F. Roche Jr.

An environmental consultant says that it appears state regulators will take no action against a Greene County chemical firm even though the company's own test results clearly show a violation.
D. Howard Gebhart of Air Resource Specialists said he does not expect that the Tennessee Department of Environment and Conservation will act on a detailed complaint he recently filed in behalf of local opponents of the US Nitrogen LLC operations.
Gebhart said a recent summary by a TDEC official of the April tests of emissions from the Midway company indicates that action by the agency is unlikely.
"TDEC appears to be ignoring the basic Clean Air Act principle of 'any credible evidence,'which allows any credible evidence to be used to establish compliance/noncompliance,"Gebhart said.
A TDEC official has issued a statement in which he stated that the April tests were not conducted to establish compliance and that the compliance was established in 2016.
Gebhart was also critical of the TDEC official's conclusion that the April tests were conducted under conditions that were not representative of the historical operation of the ammonium nitrate manufacturer.
He said that if the tests were not conducted under the usual conditions "then the results would be useless for establishing the appropriate conditions for future source operation, which was the stated purpose of the testing."
Gebhart noted that the TDEC report cites the fact that an anti-pollution device in use at US Nitrogen during the April test was contaminated.
"To me, this also implies that USN has not been properly operating and maintaining the (SCR) emissions control equipment,"Gebhart said.
The company has told TDEC that it plans to do additional testing later this month.

US Nitrogen Tests Inconclusive

By Walter F. Roche Jr.

Recent tests performed on a Greene County chemical company's ammonia plants were inconclusive and further testing to ensure compliance with its permit limits on ammonia emissions are being planned.
That was the conclusion of a state environmental official after receiving the test results from US Nitrogen.
The details on the tests which were performed in mid-April at US Nitrogen's Midway facility were spelled out in a three-page letter sent today from Bryan Parker of the Tennessee Department of Environment and Conservation to Stephen Wallace of US Nitrogen.
According to Parker's letter the test results showed that nitrous oxide limits were met but ammonia slip or ammonia emissions were present.
The tests which were performed by AMP Cherokee Environmental Solutions measured emissions from US Nitrogen's two ammonia trains at four different production rates ranging from a zero ammonia production rate to 100 tons per day.
The tests, according to Parker's letter, "indicate ammonia slip did occur especially with Train One."
He noted that the test plans were amended in the course of the testing.
Acknowledging that US Nitrogen did meet the testing requirements in its permits, Parker said the ammonia injection rates were "inconclusive."
"US Nitrogen did not determine an ammonia injection rate per production rate and furthermore an emission rate was not established," the letter states.
Citing the test results, Parker wrote that "the conditions under which the tests were conducted "do not represent historic operation of the source."
"The division does not consider that the results of this testing (should) be utilized as a basis for calculating compliance with the yearly nitrous oxide and ammonia limits set forth" in US Nitrogen's permit.
Parker noted that the company already has submitted a proposed protocol for the additional testing and said TDEC was still reviewing it. The test has tentatively been scheduled for July 21.
Contact: wfrochejr999@gmail.com

US Nitrogen Plans More Tests

By Walter F. Roche Jr.

Officials of a Greene County chemical firm are seeking Tennessee's approval for a protocol to test their facility for compliance with air emission standards during the production of ammonia and ammonium nitrate.
The tests at US Nitrogen in Midway are scheduled to take place on July 21, assuming that the state approves the testing plan.
The proposed test plan was submitted today by US Nitrogen Manager Stephen Wallace to Michelle Owenby of the Tennessee Department of Environment and Conservation.
According to the proposal the tests are being conducted to "establish a range of ammonia injection rates for the Selective Catalytic Reduction on both ammonia plants to ensure compliance with the nitrous oxide and ammonia emission limits."
The tests, which will be conducted by a separate company, AMP Cherokee Environmental Solutions, will also be used to establish compliance with those two emission limits "at three different fuel gas flow rates."
US Nitrogen also submitted to TDEC its monthly report on the amount of water it pumped from the Nolichucky River for use in the production of ammonium nitrate.
According to the report the company pumped 19.4 million gallons from the river through its 12 mile pipeline in June. On three days, June 1, June 28 and 29, no water was withdrawn from the river.
On two days, June 11 and 12, over 1 million gallons were pumped from the river.
The report also details the amount of water the company pumped back into the river. On eight days, including June 12 to June 14, a minimal amount was discharged. The highest discharge, 631,000 gallons, came on June 23.
The company is required to file the monthly reports under the terms of its TDEC permit.
Contact: wfroche999@gmail.com

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.
Contact: wfrochejr999@gmail.com