TDEC Rejects EPA Recomendations On USN

By Walter F. Roche Jr.

Tennessee environmental regulators have rejected a series of recommendations from the U.S. Environmental Protection to require additional, montoring, reporting and record-keeping by US Nitrogen LLC, a major Greene County chemical firm.
In a seven-page document made public this week, the Tennessee Department of Environment and Conservation stated that the EPA recommendations are neither required or necessary. The disclosure comes following the issuance late last week of a new permit that allows the company to continue operations through April of 2029.
The EPA from its Atlanta regional office had made five suggestions to TDEC "to ensure compliance with Title V of the Clean Air Act."
Those suggestions included monitoring that would ensure the visible emissions from US Nitrogen's nitric acid plant did not exceed opacity limits during start-ups and shut-downs.
Concerns about the visible emissions from the plant have recently been voiced by Park Overall, a local activist who sent pictures to TDEC showing visible emissions from the Midway plant recorded recently.
"The division sees no need for additional opacity monitoring for the nitric acid plant during start-up or shut-down," TDEC official James Johnston wrote in response to the EPA recommendation. Stating that emissions were expected to decrease dramatically due to a recent "process change," Johnson wrote, "There is no need for additional monitoring."
EPA also had suggested that US Nitrogen be required to record the amount of natural gas used and to set an annual limit on natural gas used.
TDEC rejected that suggestion contending that EPA was using the wrong standard in its analysis.
EPA also had urged that the state permit require US Nitrogen to record the heat input for the anhydrous ammonia plant but TDEC said that also was unnecessary. However the agency stated that they did add new language to the permit to ensure overall compliance.
A fourth EPA recommendation, that the permit require monitoring of visible emissions for flares used in the production process, was judged "unnecessary."
A final recommendation for additional monitoring and record-keeping on the nitric acid plant was similarly rejected.
"There are no federal or state standards for ammonia emissions that apply to this facility," the TDEC response states.
TDEC did state that a provision was added to the permit requiring that US Nitrogen adjust the ammonia injection rate if emission limits were exceeded.
TDEC previously issued responses rejecting other additional monitoring and record-keeping requirements proposed by an environmental consultant brought on by Overall. The agency similarly rejected suggestions from the Sierra Club.
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