US Nitrogen in "Process" Change

By Walter F. Roche Jr.

US Nitrogen has informed Tennessee environmental officials that is making an unspecified change in the processes in place at its nitric acid manufacturing facility in Greene County Tennessee.
In a letter sent this week to the state Department of Environment and Conservation, the chemical company asked the agency to put on hold an exemption request it originally filed in 2017 pending the results of what it described as a "process change."
The company had asked for an exemption from a regulation limiting the opacity of emissions from its production in a request first submitted on Dec. 11, 2017. The request followed a series of missteps in the start up efforts at the nitric acid plant that resulted in large visible emissions. One such misstep prompted a response by area emergency management officials.
"Us Nitrogen continues to work on reducing opacity issues during startup of the nitric acid plant," Stephen Wallace of US Nitrogen wrote in the letter to Michele Walker Owenby, director of TDEC's division of air pollution control.
"Currently we are in the process of making a process change during the startup of the nitric acid plant that we believe will significantly improve the opacity situation," the letter continued.
As a result, Wallace continued, the company is asking that the agency "put on hold" its efforts to come up with an amendment to the state's implementation plan to accommodate the company.
He asked that work on revisions to the state plan to comply with the federal Clean Air Act be delayed "until we can evaluate the effectiveness of the changes we are making."
Requests to US Nitrogen for details of the process changes being implemented went unanswered.
The company is a subsidiary of Austin Powder, an Ohio based manufacturer of explosives. Its primary product is liquid ammonium nitrate which is used to produce explosives at other locations.
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US Nitrogen Seeks River Permit Renewal

By Walter F. Roche Jr.

A Greene County chemical firm is asking Tennessee officials to renew a highly controversial permit allowing it to pump millions of gallons of water per week from the Nolichucky River.
In a 19-page application including appendices, US Nitrogen contends it needs the continued use of the river water because other sources cannot meet company needs.
The manufacturer of liquid ammonium nitrate not only uses the river water in regular production but also discharges up to 500,000 gallons of wastewater back into the river through pipelines from its Midway plant. The discharges are also authorized under the permit.
The current permit with the Tennessee Department of Environment and Conservation expires on June 2, according to the application submitted by US Nitrogen Plant Manager Dylan Charles. The company, the application states, also has existing related permits from the Tennesseee Valley Authority and the U.S.Army Corps of Engineers.
"The water process demand of US Nitrogen is beyond the capability of the local public utility to supply without jeopardizing reliable service to its customers," the filing states, adding that the US Nitrogen discharges also would consume essentially all of the remaining capacity of the local wastewater treatment plant.
Acknowledging that the river at the point of connection to US Nitrogen's pipelines is categorized as an "exceptional water resource," the application cites the findings of two outside consultants hired by US Nitrogen.
The application contends that the effects of the river use meet the definition of "de minimus," thus negating the need for applying more stringent standards.
The application cites alternative water supply and discharge sources that the company considered but ultimately rejected in favor of using the Nolichucky. Those included the use of water from the Old Knox Utility District.
US Nitrogen, the application states, "determined that the Old Knox Utility District could not provide sufficient, reliable and/or economically viable water for facility production."
Other alternatives considered, the report states, included the Hinkle property and use of the Mosheim water treatment plant.
Use of the Hinkle property, the application states, would have required an additional stream crossing. Use of the Lick Creek, the filing continues would not have produced an adequate volume for company needs.
Alternative discharge points, the company, contends were also rejected making discharge to the Nolichucky "justifiable."

TDEC Cites US Nitrogen for Overflow

By Walter F. Roche Jr.

Tennessee environmental officials have charged US Nitrogen LLC with multiple violations of one of its permits when a retention pond on its Greene County site overflowed for six days in a row.
In a letter dated March 15 a division manager in the state Department of Environment and Conservation wrote that the overflow began on Feb. 20 and ended on Feb. 25.
"This discharge consisted of process wastewater mixed with storm water and was stated to be caused by a large rain event," wrote Jessica Murphy, manager of the TDEC Compliance and Enforcement Unit.
"These unpermitted discharges are a violation of the Tennessee Water Quality Act of 1977 and the NPDES permit requirements," she added.
As the two-page letter noted, the chemical company had self-disclosed the violation in a letter dated Feb. 25, the last day of the overflow.
Murphy noted that the company could be liable for separate fines for each day of the violation. The TDEC letter did not indicate how large a daily fine could be imposed.
In the notice Murphy stated that the company must respond to the notice within 30 days giving exact details on the cause of the violations "as well as a thorough corrective action plan to prevent future occurrences of noncompliance."
She wrote that the company must also include any information relating to the violation previously disclosed to the state, the estimated quantity of the discharge in gallons, and should indicate if the discharge reached the waters of the state."
The letter was addressed to Dylan Charles, the plant manager for US Nitrogen and the official who authored the March 25 disclosure letter.
Charles told TDEC the overflows were first discovered at 1:30 a.m. on Feb. 20 and lasted until 2:15 p.m. on Monday Feb. 25.
Charles told TDEC the overflows in the company's North Retention Pond were triggered by "days of excessive rain."
The ammonia levels recorded ranged from 5.2 parts per million to 8.5 parts per million.
While the levels of nitrates in the spillover water ranged from 8.4 parts per million to a high of 11 parts per million. The pH level (a measure of acidity) of the spillover water ranged from 7.46 to 7.87, Charles reported to TDEC.
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12 Million Gallons + Discharged in Nolichucky

By Walter F. Roche Jr.

In an unusual report US Nitrogen said it dumped more than 12 million gallons of wastewater into the Nolichucky River in February topping by more than one million the amount it drew from the river during the same period.
The report marks one of only a few times that the discharges exceeded the intakes during a single month. It also marks the first month in which more than 12 million gallons were discharged into the river.
In a report filed today with the Tennessee Department of Environment and Conservation, the chemical firm reported discharging 12.9 million gallons into the river. During the same time period the ammonium nitrate manufacturer pumped a little under 11.5 million from the river for use in its operations in Midway, Greene County.
On one day alone during the month, Feb. 15, the company pumped a little over one million from the river. On nine other days during February US Nitrogen pumped minimal amounts from the Nolichucky.
Discharges back into the river ranged from some 700,000 per day on Feb. 25 to zero, which was reported for Feb. 10.
In its last report, covering the month of January, the company reported it pumped some 11.9 million gallons from the river while 5.9 million was discharged into the river.
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US Nitrogen Violated Permit Conditions

By Walter F. Roche Jr.

US Nitrogen violated the terms of one of its state permit for six days in a row due to an overflow in one of its retention ponds, the company has reported.
In a letter sent Monday to the Tennessee Department of Environment and Conservation, US Nitrogen Plant Manager Dylan Charles said the overflows started on Feb. 20 and continued for the next six days, ending on the date of the letter. He said the company was not yet sure of how to prevent a recurrence.
Charles told TDEC the overflows were first discovered at 1:30 a.m. on Feb. 20 and lasted until 2:15 p.m. on Monday.
He said the overflows in the North Retention Pond were triggered by "days of excessive rain."
He wrote that the company recorded the levels of ammonia and nitrates in the retention pond on the days of the overflows. The ammonia levels recorded ranged from 5.2 parts per million to 8.5 parts per million.
The levels of nitrates in the spillover water ranged from 8.4 parts per million to a high of 11 parts per million. The pH level (a measure of acidity) of the spillover water ranged from 7.46 to 7.87.
"The routine operation of the the retention pond is to keep the level low, approximately 15 to 20 percent, to reduce the the occurrence of a non-complying discharge," Charles wrote in the letter to Brian Carter of TDEC.
He added that the company monitors the weather and the retention pond levels several times per day "to ensure the pond has sufficient freeboard for rain events."
He said that normally the company pumps liquid from the retention pond to the raw water pond "for re-use or to the effluent ponds for discharge to Outfall 001."
He added that during the recent overflows "the water was being pumped continuously to reduce the amount of un-permitted flow."
But, he wrote, the company's permit limits the amount of retention pond water that can be transported to the effluent ponds.
"Furthermore, the amount of stormwater that was entering the retention pond was in excess of the amount of water that could be transported to the effluent or raw water ponds due to pipe and pump limitation," Charles wrote.
He said the company was "evaluating options to re-direct the stormwater runoff from outside the production area away from the retention pond."

Thallium in Nolichucky Puzzle Continues

By Walter F. Roche Jr.

Tennessee environmental officials say they have yet to identify the source of a potentially deadly chemical found in the the Nolichucky River, but there are no plans to do any further testing.
"A source has not been identified, but we have no evidence at this time to demonstrate any public health concerns," wrote Kim Schofinski, spokeswoman for the Tennessee Department of Environment and Conservation, in an email response to questions.
The presence of thallium in the eastern Tennessee river was reported by US Nitrogen in a recent filing with TDEC.
The company reported that water it discharged into the river had 10.3 parts per billion of thallium. That is some three times the level recommended for drinking water.
Subsequent tests by TDEC showed no detectable levels of thallium in the river, according to state officials
US Nitrogen pumps millions of gallons per month from the river for use in the manufacture of ammonium nitrate. Excess amounts of that water are discharged back into the river at milemarker 20.8.
Though the Nolichucky is a source of water for local consumers, officials of the Greeneville Water Commission say annual tests they performed showed no traces of thallium. The commission draws its water some 37 miles upstream of the US Nitrogen discharge point.
US Nitrogen officials have not responded to a series of questions about the test results, the level of thallium in the water the company draws from the river or how the company extracts thallium from the river water.
When first questioned about the data the company submitted to the state, Kim Ryans, an environmental expert for US Nitrogen said,"The US Nitrogen facility does not use thallium or substances containing thallium as a component of any manufacturing processes."
"The water sampled and discharged to the Nolichucky River does not come into direct contact with US Nitrogen’s processes," she added.
Schofinski said that while the agency has no current plans to do any further testing, "we will continue to monitor this issue closely."
She said that the agency has not requested any additional documentation from US Nitrogen "specific to thallium."
According to the U.S. Centers for Disease Control and Prevention "Thallium can affect your nervous system, lung, heart, liver, and kidney if large amounts are eaten or drunk for short periods of time. Temporary hair loss, vomiting, and diarrhea can also occur and death may result after exposure to large amounts of thallium for short periods."
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US Nitrogen Reports Higher Nolichucky Use

By Walter F. Roche Jr.

The use of water from the Nolichucky River by a Greene County chemical firm climbed in January to more than 11 million gallons, according to a report filed with the Tennessee Department of Environment and Conservation.
The report filed by US Nitrogen LLC today showed the firm pumped 11.9 million gallons from the waterway in January, up from 10.8 million gallons in December but lower than the 18.6 million reported in November.
The monthly report was filed as TDEC approved the transfer of a key permit from US Nitrogen to Praxair, a producer of liquefied carbon dioxide. Praxair operates on the same multi-acre Midway site and utilizes carbon dioxide produced by US Nitrogen in the production of ammonium nitrate.
Under the permit Praxair is limited to producing no more than 90.8 tons of liquified carbon dioxide in any 12 month period.
Praxair, which serves the beverage industry, must maintain detailed records on the amount of carbon dioxide it receives from US Nitrogen and the amount it then ships in liquefied form to its customers, according to the permit.
Initially the permit to operate a carbon dioxide liquefaction facility was granted to US Nitrogen, but a transfer was requested recently citing a U.S. Supreme Court ruling and policy changes from the U.S. Environmental Protection Agency.
The transfer of ownership in the permit was effective on June 29 of last year, according to the renewal notice.
The monthly river report filed by US Nitrogen shows the company discharged 5.9 million gallons of wastewater back into the river. The discharge point is at mile marker 20.8 on the river.
The report shows that US Nitrogen pumped in excess of 700,000 gallons of water from the river on 13 days of the month with the highest total coming on Jan. 28. On Jan. 10 no water was drawn from the Nolichucky.
On six days during January the company did not discharge any wastewater into the river.
The January discharge total was down from the 6.2 million gallons discharged in December.
The monthly river use reports are required under the state's permit.
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