US Nitrogen Nearly Doubles River Use

By Walter F. Roche Jr.

US Nitrogen LLC nearly doubled the amount of free water it pumped from the Nolichucky River in the month of March, according to a report filed today with the Tennessee Department of Environment and Conservation.
The report by the Greene County chemical firm shows a total of 18.65 million gallons were pumped from the river, nearly double the 9.9 million the company used in February.
In a related matter local environmental activist Park Overall has called on the U.S. Environmental Protection Agency to hold a public hearing on US Nitrogen's production of anhydrous ammonia at its Midway facility.
Her request was prompted by US Nitrogen's recent request for a clarification and amendment to its permit to produce anhydrous ammonia.
In her letter Overall wrote that long after it first announced plans to build an ammonium nitrate plant in Tennessee "US Nitrogen has still not decided what it's going to make."
She said a hearing was necessary because of the increased risk to the local community from anhydrous ammonia production.
In its monthly report to TDEC, US Nitrogen reported it drew over 1 million gallons from the Nolichucky on 10 separate days. On March 9 it drew 1.9 million gallons, the highest of the month.
On six days it drew a minimal amount from the river. On March 4 and March 6 no water was withdrawn.
The company report shows a total of 9.4 million gallons were discharged back into the river in March, compared to the 5.8 million discharged into the river in February.
On 11 days of March US Nitrogen discharged more than 400,000 gallons into the Nolichucky. On four days a minimal amount was discharged to the river.
Under its state permits US Nitrogen is required to file monthly reports on its river water use.
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US Nitrogen Seeks Permit Change

By Walter F. Roche Jr.

A Greene County chemical company has requested approval from Tennessee environmental officials for a change or clarification in one of its permits to operate a plant producing anhydrous ammonia.
In a recent letter to the Tennessee Department of Environment and Protecion, Stephen Wallace of US Nitrogen said the change was being sought to eliminate confusion over what emission standard the company must maintain.
The proposed change would make it clear that the standard is based on an initial performance test performed at the Midway facility on Nov. 21 and Nov. 22 of 2016.
The standard in question involves the levels of nitrous oxide allowable under the permit.
The apparent confusion surfaced when the chemical firm announced plans to undertake a series of performance tests.
In a separate but related action a TDEC official has notified US Nitrogen that it has reviewed recent submissions by the company detailing emissions for the last quarter of 2018 and 2019.
Bryan Parker of TDEC wrote that the records showed US Nitrogen did not exceed the emissions limits for nitrous oxides during the time periods in question.
Parker wrote that the data for the anhydrous ammonia plant and the nitric acid plant "achieved the required 95 percent operational availability level" for the time periods.

US Nitrogen Sets Compliance Tests

By Walter F. Roche Jr.

US Nitrogen has given state environmental officials 30 days notice of its plan to conduct tests to determine if its ammonium nitrate manufacturing facility is operating within the limits set in its state permits.
In a letter to the Tennessee Department of Environment and Conservation Stephen Wallace of US Nitrogen stated that the performance test will be performed on April 13 by a North Carolina firm, AMP-Cherokee Environmental Solutions.
In a 17-page attachment, the company gave details of how the test will be conducted on both of its ammonium train production units. Previously the company had indicated it might be testing only one of the two trains.
According to the protocol the tests will check the levels of carbon monoxide, ammonia and nitrous oxides emitted from the plants from start-up to full production to shutdown. US Nitrogen has experienced difficulties in prior start-ups.
The tests will also show whether the selective catalytic reduction mechanism is functioning properly. The SCR is designed to ensure emission limits for nitrous oxides are not exceeded.
Under its permit US Nitrogen is limited to producing 73 tons of anhydrous ammonia in any 12 month period.
According to the protocol the tests will establish a range of ammonia injection rates that will ensure that emissions do not exceed permit limits.

Two US Nitrogen Permits Expiring

By Walter F. Roche Jr.

Two of the state permits for a Greene County chemical firm will expire next month but state environmental officials say expected renewal requests will not be the subject of public hearings.
The two permits, one covering US Nitrogen LLC's water treatment plant and the other applying to its manufacturing operations, expire April 14.
The permits,known as Tennessee Stormwater Multi-Sector General Permits (TMSP), are not subject to public hearing requirements, according to Kim Schofinski of the Tennessee Department of Environment and Conservation.
The TDEC spokeswoman said the overall state permit for the stormwater program is expiring on the same date, April 14, and TDEC will be issuing a notice for a hearing on the renewal of the general permit.
"Issuing coverage to individual facilities is not subject to public notice or public hearing requirements," she added.
According to guidelines from TDEC, stormwater permits are required for nearly all industrial operations.
While certain industrial operations can opt to seek an individual stormwater permit, most seek coverage under the general permit.
In compliance with its permits US Nitrogen has submitted periodic reports on the stormwater runoff collected and analyzed from its Midway operations.
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US Nitrogen Reports 10 Dry Days

By Walter F. Roche Jr.

US Nitrogen drew no water from the Nolichucky River for a total of 10 days during the month of February, according to a report filed with the Tennessee Department of Environment and Conservation.
The one-page monthly report showed that from Feb. 11 to Feb. 18 and from Feb. 23 to Feb. 25 the chemical firm pumped no water from the river. It marks the most days without river water use since the company began using the waterway in its production of ammonium nitrate and other related chemicals.
Overall in February the company reported it pumped 9.9 million gallons from the Nolichucky and it also discharged 5.8 million gallons back in to the river. On only one day, Feb. 16, the company reported no water was discharged into the river.
The report states that US Nitrogen withdrew some water from the river on 19 days of the month but on six of those days only a minimal amount was withdrawn.
The report comes after US Nitrogen told state officials it was considering at least a partial shutdown of its operations in March to conduct compliance testing. US Nitrogen officials did not respond to questions about its shutdown and testing plans.
The February totals show declines in both the water pumped from the river and the amount discharged compared to January. In that month US Nitrogen pumped 13 million gallons from the river and discharged 7.7 million back into the Nolichucky.
In a related development Yara North America, which operates on the same Greene County site, reported that it complied with the limits in its state permit, because the company has yet to begin production.
Contact: wfrochejr999@gmail.com

Whoops!! TDEC Permit Has Typo

By Walter F. Roche Jr.

A recently granted permit to a Greene County chemical firm has a typographical error and apparently will have to be amended.
The seven-page permit issued by the Tennessee Department of Environment and Conservation on Jan. 30 to Praxair, Inc. leaves out a key verb, Shall.
In an internal TDEC memo posted today, an official of the agency's air pollution control division, asked a colleague about the procedure to be followed for such a change.
Praxair, a supplier of liquid carbon dioxide to the beverage industry, is one of three firms occupying a multi-acre site in Midway.
"The operating permit for Praxair Inc. needs to be amended," Shawn Auth wrote in the email to the Air Permit Control permitting section and TDEC employee Doug Wright.
The word "shall" was apparently omitted in the following sentence: "Visible emissions from this facility not exhibit greater than 20 percent."
Under the permit Praxair was given the right to produce up to 90,789 tons of carbon dioxide in any 12 month period. Once amended it will limit visible emissions to 20 percent. The permit expires April 1, 2029. The other firms operating on the same site are US Nitrogen and Yara Inc.
US Nitrogen was issued a new conditional major operating permit in December. It expires on April 1, 2029.
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Tennessee environmental officials have issued a separate permit to Praxair, Inc. a major supplier of liquefied carbon dioxide to the soft drink industry.
Praxair, which operates on the same Green County site as US Nitrogen, will get carbon dioxide in gas form from US Nitrogen LLC, and then liquefy it before shipping to customers.
The permit, which was issued Thursday by the Air Pollution Control Division of the Tennessee Department of Environment and Conservation, will be effective until April 1, 2029.
Praxair initially did not have a separate permit but was covered under a permit issued to US Nitrogen.
The seven-page permit sets annual limits on the amount of carbon dioxide the company can produce and also limits some of the air pollutants it can emit.
Under the permit Praxair must limit opacity at 20 percent for any six minutes in a one hour period and to four six minute periods in any 24 hour period. The company must also maintain records of emissions in any start ups or shutdowns.
The permit limits the company's water use to 2,400 gallons per minute and limits the amount of liquefied carbon dioxide produced to 90,789 tons per any 12 month period.
Finally the company must maintain logs showing the amount of carbon dioxide received from US Nitrogen and the amount of liquefied carbon dioxide shipped out.
Yet another permit is expected to be issued to Yara, Inc. which also operates on the same Midway site and previously was covered under a US Nitrogen permit.
Contact: wfrochejr999@gmail.com

US Nitrogen Disables Auxiliary Burners

By Walter F. Roche Jr.

US Nitrogen LLC has sent photographic proof to Tennessee environmental officials that they have disabled two pipes feeding natural gas to auxiliary burners in its manufacturing operations.
The chemical company was required to submit the photos under the provisions of a revised permit from the Tennessee Department of Environment and Conservation.
The submission was one of several developments this week at the Greene County facility which produces ammonium nitrate and related products for use by its Ohio parent, Austin Powder.
The company also submitted a report showing that it withdrew 13.1 million gallons of water from the Nolichucky River during the month of January.
In a third development TDEC officials sent a letter to Park Overall, a local resident and environmental activist, stating that after an investigation the agency concluded that a large visible plume emanating from US Nitrogen on Jan. 18 did not violate the company's opacity limits set in one of its state permits.
"There was no finding of non-compliance," Ron Wilhoit wrote in the letter to Overall, who had sent photos of the plume to the agency.
Wilhoit added that the plume consisted of water vapor and "such a plume would not be considered a visible emission subject to this permit's opacity limit."
In yet another development, US Nitrogen has recommended a language change in one of its state permits to clarify the limits on carbon monoxide emissions and the requirements for compliance testing to confirm compliance.
The apparent confusion surfaced recently when the company and TDEC officials exchanged emails about the upcoming performance testing.
The permit change would limit carbon monoxide emissions to 8.32 pounds per hour or 36.44 tons in any 12 month period.
The river water report submitted to TDEC shows that the company pumped more than 800,000 gallons from the Nolichucky River on nine days during January, with the highest amount on Jan. 22. On eight days only a minimal amount was pumped from the river.
The company discharged 7.7 million gallons of water back in to the river. On nine days in the month the discharges totaled more than 400,000 gallons. On five days including Jan. 1 and Jan. 2 only a minimal amount was discharged.
In its last report covering the month of December US Nitrogen reported drawing 12.7 million gallons from the river and discharging about 6 million. The monthly reports are required under one of the company's permits.
Contact: wfrochejr999@gmail.com