By Walter F. Roche Jr.
A Greene County chemical firm has filed a nine-page response to a recent report from state environmental officials citing deficiencies in its operations.
In the response from US Nitrogen, Plant Manager Dylan Charles wrote that revisions in operating procedures and changes in equipment have or will shortly correct all the deficiencies including missing records.
Charles said the the calibration of flow meters had been simplified "to avoid confusion" and the company will no longer rotate the two existing meters.
The state surveyors had noted that company records made it unclear which flow meter was in use at any given time.
Charles added that US Nitrogen had also hired a consultant to perform a second calibration review.
Tennessee Department of Environment officials, who made a limited on-site review, also had noted that the number of outfalls where stormwater runoff is monitored had been increased to 10.
In his response, Charles said the added outfalls were established to monitor runoff in areas where the company has begun applying sludge. The sludge is produced at a water treatment plant where Nolichucky River water is treated prior to its use in the manufacturing process.
He said US Nitrogen's Best Management Practices Plan had been update to include the additional outfalls.
Other items addressed in the letter include revisions in water sump pump management and replacement of riprap on the site to prevent erosion.
Contact: wfrochejr999@gmail.com
Friday, October 29, 2021
Tuesday, October 26, 2021
USN Submits Proposed Cure to Excess Runoff
By Walter F. Roche Jr.
US Nitrogen LLC has submitted a plan to state regulators to reduce the excess runoff of nitrogen products in the stormwater at its Midway manufacturing facility, but full implementation won't come for another year.
In a letter to the Tennessee Department of Environment and Conservation US Nitrogen's plant manager, Dylan Charles, wrote that the company believes the excess of nitrogen/nitrates and nitrites originates in a rail loading area.
A recent annual report from the company showed the nitrogen products in stormwater runoff in one area exceeded the benchmark level of .62 milligrams per liter by 20 milligrams or 30 percent.
Charles said that the company reviewed its operations in the rail loading area and don't believe that a change in procedures would solve the problem. Instead, he wrote, the company is planning to divert the water now running through a ditch and redirect it "into an underfow basin."
The timetable calls for design plans by Dec. 24 of this year and implementation by Oct. 25 of next year.
He said under the plan the company would discontinue using an existing outfall and redirect the runoff to a retention pond which will be re-lined to hold the stormwater.
"The stormwater will be further managed for re-use or discharge as effluent," the letter states.
Charles said the ditch now carrying the stormwater with excess nitrogen was installed in early 2019 to collect stormwater from the rail unloading area.
The excess nitrogen runoff was noted in earlier annual reports and in early 2020 the company said it would implement a plan to eliminate the excess.
The recent stormwater runoff report also reported magnesium levels exceeding the benchmark by more than 100 times, but US Nitrogen has attributed that to sources pre-existing the company's manufacturing process.
Contact: wfrochejr999@gmail.com
US Nitrogen LLC has submitted a plan to state regulators to reduce the excess runoff of nitrogen products in the stormwater at its Midway manufacturing facility, but full implementation won't come for another year.
In a letter to the Tennessee Department of Environment and Conservation US Nitrogen's plant manager, Dylan Charles, wrote that the company believes the excess of nitrogen/nitrates and nitrites originates in a rail loading area.
A recent annual report from the company showed the nitrogen products in stormwater runoff in one area exceeded the benchmark level of .62 milligrams per liter by 20 milligrams or 30 percent.
Charles said that the company reviewed its operations in the rail loading area and don't believe that a change in procedures would solve the problem. Instead, he wrote, the company is planning to divert the water now running through a ditch and redirect it "into an underfow basin."
The timetable calls for design plans by Dec. 24 of this year and implementation by Oct. 25 of next year.
He said under the plan the company would discontinue using an existing outfall and redirect the runoff to a retention pond which will be re-lined to hold the stormwater.
"The stormwater will be further managed for re-use or discharge as effluent," the letter states.
Charles said the ditch now carrying the stormwater with excess nitrogen was installed in early 2019 to collect stormwater from the rail unloading area.
The excess nitrogen runoff was noted in earlier annual reports and in early 2020 the company said it would implement a plan to eliminate the excess.
The recent stormwater runoff report also reported magnesium levels exceeding the benchmark by more than 100 times, but US Nitrogen has attributed that to sources pre-existing the company's manufacturing process.
Contact: wfrochejr999@gmail.com
Wednesday, October 20, 2021
TDEC Approves US Nitrogen Waivers
By Walter F. Roche Jr.
The Tennessee Department of Environment and Conservation has approved US Nitrogen's request to alow the use of two new pieces of equipment at its Greene County facility without the need to apply for permits.
In a letter sent today to Dylan Charles, USN's plant manager, James P. Johnson, a TDEC deputy, said the air compressor and portable water pump constitute insignificant pollution sources thus exempting them from permitting requirements.
USN had requested the exemptions in August.
TDEC responded by requesting additional data, which USN then supplied. Johnston said in his letter that each of the pieces of equipment would emit less than 1,000 pounds per year of each hazardous pollutant.
Johnston concluded by stating that since the original request was dated Aug. 20, the 30 day notice provision has also been met.
USN's previous requests for an exemption for three 20,000 gallon sump pump water tanks was also okayed. Contact:wfrochejr@gmail.com
The Tennessee Department of Environment and Conservation has approved US Nitrogen's request to alow the use of two new pieces of equipment at its Greene County facility without the need to apply for permits.
In a letter sent today to Dylan Charles, USN's plant manager, James P. Johnson, a TDEC deputy, said the air compressor and portable water pump constitute insignificant pollution sources thus exempting them from permitting requirements.
USN had requested the exemptions in August.
TDEC responded by requesting additional data, which USN then supplied. Johnston said in his letter that each of the pieces of equipment would emit less than 1,000 pounds per year of each hazardous pollutant.
Johnston concluded by stating that since the original request was dated Aug. 20, the 30 day notice provision has also been met.
USN's previous requests for an exemption for three 20,000 gallon sump pump water tanks was also okayed. Contact:wfrochejr@gmail.com
Tuesday, October 19, 2021
US Nitrogen Owner Has Long TN History
By Walter F. Roche Jr.
When Austin Powder, the Ohio based explosives manufacturer, first proposed building a chemical plant in Green County, most area residents had never heard of it, but records show the company actually has had a presence in Tennessee for nearly 50 years.
Records also show some of the company's state permits indicate manufacturing of explosives may be one of the company's Tennessee activites.
The company did not respond to a series of questions about its activities in Tennessee including whether or not explosives are being manufactured at its facilities within the state boundaries.
The company which owns Midway based US Nitrogen LLC, first purchased property in Davidson County in 1972 when it purchased over 500 acres in Pegram from a machinery company. Additional adjoining acreage was purchased in 1976 and yet another 75 acres were purchased in 1989.
The little noticed Davidson facility recently drew the attention of state and federal environmental regulators who cited the company for mutiple violations including unauthorized logging and blocking or obstructing waterways. The state issued a cease and desist order. The company has filed a corrective action plan.
In Lafollette Campbell County Austin Powder purchased a 401 acre site in 1991 followed by two additional purchases.
State permits show the company has listed the Lafollette site on Austin Powder Road as a storage and distribution center, but the application to the state Department of Environment and Conservation has a box for manufacturing checked off as one of the facility activities.
In addition a schematic submitted by the company in 2020 shows a mixing plant on the property.
US Nitrate produces ammonium nitrate which is then mixed with other ingredients at another site to manufacture the actual explosives, which are Austin Powder's major product.
In announcing the plans for US Nitrogen, company officials indicated the ammonium nitrate would be shipped out of state for the final mixing process, but Lafollette and Pegram are much closer.
From Midway to Pegram is about 260 miles, a straight shot on Route I-40. Lafolette is only 98.4 miles from Midway.
Contact: wfrochejr999@gmail.com
When Austin Powder, the Ohio based explosives manufacturer, first proposed building a chemical plant in Green County, most area residents had never heard of it, but records show the company actually has had a presence in Tennessee for nearly 50 years.
Records also show some of the company's state permits indicate manufacturing of explosives may be one of the company's Tennessee activites.
The company did not respond to a series of questions about its activities in Tennessee including whether or not explosives are being manufactured at its facilities within the state boundaries.
The company which owns Midway based US Nitrogen LLC, first purchased property in Davidson County in 1972 when it purchased over 500 acres in Pegram from a machinery company. Additional adjoining acreage was purchased in 1976 and yet another 75 acres were purchased in 1989.
The little noticed Davidson facility recently drew the attention of state and federal environmental regulators who cited the company for mutiple violations including unauthorized logging and blocking or obstructing waterways. The state issued a cease and desist order. The company has filed a corrective action plan.
In Lafollette Campbell County Austin Powder purchased a 401 acre site in 1991 followed by two additional purchases.
State permits show the company has listed the Lafollette site on Austin Powder Road as a storage and distribution center, but the application to the state Department of Environment and Conservation has a box for manufacturing checked off as one of the facility activities.
In addition a schematic submitted by the company in 2020 shows a mixing plant on the property.
US Nitrate produces ammonium nitrate which is then mixed with other ingredients at another site to manufacture the actual explosives, which are Austin Powder's major product.
In announcing the plans for US Nitrogen, company officials indicated the ammonium nitrate would be shipped out of state for the final mixing process, but Lafollette and Pegram are much closer.
From Midway to Pegram is about 260 miles, a straight shot on Route I-40. Lafolette is only 98.4 miles from Midway.
Contact: wfrochejr999@gmail.com
Saturday, October 9, 2021
US Nitrogen Issues River Use Report
By Walter F. Roche Jr.
US Nitrogen LLC pumped a little over 14 million gallons of water from the Nolichucky River in September, a 6 million gallon drop from the month before, according to a report filed this week with the Tennessee Department of Environment and Conservation.
The Greene County chemical company, which uses the free water in its manufacturing processes, also reported discharging just shy of six million gallons of waste water back into the river.
That compares with the 20.8 million gallons pumped from the river in August and the 10.5 million gallons of wastewater pumped back to the Nolichucky in August.
The highest daily total of river water company drawn by the ammonium nitrate manufacturer came on Sept. 25 when a little under one million gallons were pumped to the Midway facility through a 13 mile pipeline.
Minimal amounts of water were discharged to the river on 11 days during the month including from Sept. 4 through Sept. 6. On four days more than five million gallons were discharged to the Nolichucky including Sept. 2 when 5.4 million gallons were discharged.
Daily totals of water pumped from the river and the amounts discharged are required under the company's permits from TDEC. The twin 13-mile pipelines along state highway rights of way were approved by the state transportation agency.
As a result of a long legal battle the company does pays a rental fee to two landowners who charged that the pipeline actually crossed into their properties.
US Nitrogen LLC pumped a little over 14 million gallons of water from the Nolichucky River in September, a 6 million gallon drop from the month before, according to a report filed this week with the Tennessee Department of Environment and Conservation.
The Greene County chemical company, which uses the free water in its manufacturing processes, also reported discharging just shy of six million gallons of waste water back into the river.
That compares with the 20.8 million gallons pumped from the river in August and the 10.5 million gallons of wastewater pumped back to the Nolichucky in August.
The highest daily total of river water company drawn by the ammonium nitrate manufacturer came on Sept. 25 when a little under one million gallons were pumped to the Midway facility through a 13 mile pipeline.
Minimal amounts of water were discharged to the river on 11 days during the month including from Sept. 4 through Sept. 6. On four days more than five million gallons were discharged to the Nolichucky including Sept. 2 when 5.4 million gallons were discharged.
Daily totals of water pumped from the river and the amounts discharged are required under the company's permits from TDEC. The twin 13-mile pipelines along state highway rights of way were approved by the state transportation agency.
As a result of a long legal battle the company does pays a rental fee to two landowners who charged that the pipeline actually crossed into their properties.
Thursday, October 7, 2021
TDEC Questions US Nitrogen Data
By Walter F. Roche Jr.
Tennessee environmental officials are questioning the calculations used by a Greene County chemical firm to justify a request to use new equipment without a permit.
In a series of email exchanges between an official of the Tennessee Department of Environment and Conservation and Kim Ryans, the environmental supervisor for US Nitrogen LLC James Johnston of TDEC states that he has been unable to replicate the data submitted by the Midway company.
"Can you please provide the formula you used," Johnston wrote in one recent email.
According to the emails, the data in question involves emissions from an air compresor and a pump engine. Specifically Johnston has asked where the company came up with a conversion factor for BTUs (British Thermal Units) used per horsepower produced.
US Nitrogen has asked the agency to agree that the new equipment is an "insignificant emissions unit" and thus exempt from permit requirement.
In an email sent today to Ryans, Johnston asked that the company provide the formula it used in calculating emission levels.
Ryans has responded to prior requests on the matter with a series of emission calculation spread sheets.
In seeking TDEC's approval in late August Dylan Charles, US Nitrogen's plant manager said each of the two new pieces of equipment would produce less than 1,000 pounds per year of hazardous pollutants.
Earlier this year US Nitrogen was granted an exemption from permit requirements for the use of three 20,000 gallon sump pump water tanks.
US Nitrogen has not disclosed what the new equipment will be used for.
Contact: wfrochejr999@gmail.com
Tennessee environmental officials are questioning the calculations used by a Greene County chemical firm to justify a request to use new equipment without a permit.
In a series of email exchanges between an official of the Tennessee Department of Environment and Conservation and Kim Ryans, the environmental supervisor for US Nitrogen LLC James Johnston of TDEC states that he has been unable to replicate the data submitted by the Midway company.
"Can you please provide the formula you used," Johnston wrote in one recent email.
According to the emails, the data in question involves emissions from an air compresor and a pump engine. Specifically Johnston has asked where the company came up with a conversion factor for BTUs (British Thermal Units) used per horsepower produced.
US Nitrogen has asked the agency to agree that the new equipment is an "insignificant emissions unit" and thus exempt from permit requirement.
In an email sent today to Ryans, Johnston asked that the company provide the formula it used in calculating emission levels.
Ryans has responded to prior requests on the matter with a series of emission calculation spread sheets.
In seeking TDEC's approval in late August Dylan Charles, US Nitrogen's plant manager said each of the two new pieces of equipment would produce less than 1,000 pounds per year of hazardous pollutants.
Earlier this year US Nitrogen was granted an exemption from permit requirements for the use of three 20,000 gallon sump pump water tanks.
US Nitrogen has not disclosed what the new equipment will be used for.
Contact: wfrochejr999@gmail.com
Saturday, October 2, 2021
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."
Contact: wfrochejr999@gmail.com
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."
Contact: wfrochejr999@gmail.com
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