US Nitrogen Inspection Shows Compliance, Deficiencies

By Walter F. Roche Jr.

A delayed and limited state compliance inspection report on a Greene County chemical firm concluded the company was in compliance with its permits but also found a series of deficiencies including missing and deficient recordkeeping.
The inspections which were delayed and limited due to Covid-19 requirements concluded that US Nitrogen's activities "appear to address site operations adequately and accurately."
In a nine-page letter to US Nitrogen, Bryan Carter of the Tennessee Department of Environment and Conservation, acknowledged that the inspection included only a limited walkthrough because of social distancing requirements."
"The facility condition generally appeared good," the letter to US Nitrogen's Dylan Charles states.
Among the deficiencies was the failure of the company to record which one of two flow meters was operating at any given time.
In addition, the letter continues, calibration records for one of those meters "appear(s) to be missing."
Carter noted that such records are supposed to be retained for three years.
He stated that those records which were retained didn't show which meter was checked. The meters are required to show the volume of water pumped to the Nolichucky River.
"Complete documentation of calibration verifications must be maintained in order to support conclusions regarding flow meter accuracy," Carter wrote.
On laboratory issues the letter states that US Nitrogen "must revise applicable laboratory SOPs (Standard Operating Procedures) to ensure the requirements of updated approved analytical methods are satisfied," Carter wrote.
According to the report only one application of sludge on the company property had occurred at the time of the inspection. The sludge comes from the processing of Nolichucky water prior to its use in the company's production of ammonium nitrate.
The report notes that US Nitrogen has begun preparing a bio-assessment of the effect of its river water use on aquatic life. During the inspection. which was spread over several months, TDEC officials observed bio-assessment samples being drawn from the river on Sept. 13.
TDEC noted that a second bio-assessment must be collected by Jan. 30, 2025. TDEC only called for the bio-assessments after local environmental activist Park Overall pointed out they were not only overdue but totally absent.
Another deficiency listed was the failure to include in its best management practices plan the additional stormwater outfalls that have been added since the plant opened.
The TDEC inspectors also noted that drain valves were operating but unattended as required. Company logs also showed drainage water was processed even though contaminants, such as oil, exceeded allowable limits.
Additionally a white residue was noted near an ammonia flare site and one best management plan had an incomplete final sentence.
TDEC also stated that some land near one of the outfalls needed to be stabilized.
Carter wrote that US Nitrogen must submit a detailed corrective action plan along with an implementation schedule by Nov. 1.
Compliance with the permit, Carter's letter concluded, "helps ensure discharges ... are protective of downstream fish and aquatic life."
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