US Nitrogen Seeks Nolichucky Permit Renewal

By Walter F. Roche Jr.

US Nitrogen LLC, the Greene County chemical firm, is seeking to renew the permit that allows the company to discharge some 500,000 gallons of wastewater per day into the Nolichucky River.
The 45-page submission, including several appendices, lists dozens of pollutants, some of which the application states, are believed to be present when the wastewater is pumped into the river.
The permit is one of two highly controversial to be granted by the Tennessee Department of Environment and Conservation.
The permit that allows the company to draw some 1.9 million gallons of water per day from the Nolichucky was renewed last year following a sparsely attended public hearing.
The discharge renewal application was submitted along with a one-page cover letter from Dylan Charles, US Nitrogen's plant manager. The current permit expires Oct. 31.
As the application states, the company's primary product is ammonium nitrate, which is used by US Nitrogen's parent company, Ohio based Austin Powder, in the production of explosives. The explosives are manufactured at a different site.
According to the application some 573,000 gallons of wastewater per day will be pumped from US Nitrogen's Midway manufacturing facility to mile marker 20.8 on the Nolichucky. In its latest monthly report to TDEC, the company reported discharging 9.4 million gallons into the Nolichucky in March
Among the chemicals the company says it believes to be present in the wastewater are bromide, fecal coliform, chlorine and molybdenum.
Copper, according to the application, is believed to be present because it is used as a treatment chemical.
In a past report the company reported that it believed that thallium was present in the water. A subsequent investigation by TDEC, however, found no trace of the chemical.
The application states that the company had two different tests performed by an outside laboratory for acute or chronic toxicity. The tests were submitted on April 30, 2017, but the application does not indicate the outcome.
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US Nitrogen Files Compliance Report

By Walter F. Roche Jr.

US Nitrogen LLC has told Tennessee officials it fully complied with the provisions of its permit in the production of tons of nitric acid at its Greene County manufacturing facility.
The massive Annual Permit Compliance Report, complete with hourly reports on emission levels, shows that on nearly 100 days between January and August in 2019, no nitric acid was produced.
In fact, the daily production report shows that in many months, there was no nitric acid production on 20 or more days.
In March of 2019, for instance, there was no nitric acid production from March 7 to March 29. In June there was no nitric acid production from June 4 to June 24.
The data was sent as an attachment to a letter from US Nitrogen Plant Manager Dylan Charles to Michelle Owenby, head of the air pollution control division of the Tennessee Department of Environment and Conservation.
In the letter Charles disclosed that there was only a four period in February where emissions monitoring equipment was not in operation. The Feb. 25 gap, according to the letter, was due to routine maintenance.
According to Charles, the company complied with various limits set out in the permit, including limiting nitric acid production to 600 tons per day. Other limits include the emission of no more than 54.8 tons of nitrous oxides per year.
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US Nitrogen Tests to Begin

By Walter F. Roche Jr.

Tennessee environmental officials have disclosed key tests at a Greene County chemical firm will take place next week with state officials due to be in attendance.
According to an email from an official of the state Department of Environment and Conservation the tests will get under way on Monday with preparatory work by AMP Cherokee, the company brought in by US Nitrogen. The tests will be conducted on the company's two ammonia trains, key elements in the production of ammonium nitrate, one of the company's main products.
According to the email sent to Park Overall, a local environmental activist, actual tests on the first ammonia train will begin at mid-morning on Tuesday. Overall has been pressing state officials for details on the timing of the tests.
Tests on the second ammonia train will take place Wednesday.
A critical part of the tests will be the startups of the two trains and the level of emissions recorded during each step of that process. The company has encountered problems in some previous start ups.
In a related development Overall has challenged the methodology proposed by US Nitrogen in setting standards for the production of anhydrous ammonia, a separate product produced by the Midway firm.
In a April 7 letter to TDEC official Michelle Owenby Overall wrote that the method proposed by US Nitrogen could result in the company underestimating the projected emissions.
The company has proposed that the standard be based on the results of a test conducted on Nov. 21 and 22 of 2016.
Overall, however, proposed that TDEC should also consider the latest test results and apply the higher standard, either the 2016 test results or the latest tests.
The higher factor should apply, Overall wrote.
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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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