USN Douthat NPDES Permit Combined[1]-1

a global professional services company creative thinking. custom solutions.

220 Athens Way, Suite 410 | Nashville, Tennessee 37228 | Telephone 615-255-9300 | Facsimile 615-255-9345 | www.ensafe.com

engineering | environment | health & safety | technology

January 28, 2014 Mr. Britton Dotson via email: [email protected] Division of Water Resources Tennessee Department of Environment and Conservation 312 Rosa L. Parks Avenue, 11th Floor Nashville, Tennessee 37243-1534 Re: NPDES Permit TN0081566

US Nitrogen, Greene County

Dear Britton: On behalf of our client, US Nitrogen LLC, and in response to the letter from Vojin Janji dated January 6, 2014, EnSafe is submitting the enclosed EPA Form 1, Form 2D and related attachments as the revised application for an NPDES permit for the discharge of wastewater to the Nolichucky River at approximate river mile 20.8. This application supersedes the one submitted via email on December 11, 2013. Based on preliminary evaluation, it is our opinion that the proposed discharge would meet the definition of de minimis degradation as found in the Tennessee water quality rules at 0400-04-03-.04(4) Furthermore, in the absence of directly applicable effluent guidelines, we believe the proposed discharge of ammonia is less than that representing the degree of effluent reduction attained by the application of the best available technology economically achievable, as defined by the Environmental Protection Agency under its guidelines for similar facilities (ammonia, nitric acid, and ammonium nitrate production plants under 40 CFR Part 418). If you have any questions or comments, or if further information is required, please let us know. Sincerely, EnSafe Inc.

By: Thomas B. Green, Jr., P.E. Senior Project Engineer cc: Vojin Janji, DWR

Justin Freeark, US Nitrogen LLC enclosures

Please print or type in the unshaded areas only. Form Approved. OMB No. 2040-0086.

I. EPA I.D. NUMBER S T/A C

F D

FORM

1 GENERAL

U.S. ENVIRONMENTAL PROTECTION AGENCY GENERAL INFORMATION

Consolidated Permits Program (Read the General Instructions before starting.)

1 2 13 14 15

LABEL ITEMS

I. EPA I.D. NUMBER

III. FACILITY NAME

V. FACILITY MAILING ADDRESS

VI. FACILITY LOCATION

PLEASE PLACE LABEL IN THIS SPACE

GENERAL INSTRUCTIONS If a preprinted label has been provided, affix it in the designated space. Review the information carefully; if any of it is incorrect, cross through it and enter the correct data in the appropriate fill-in area below. Also, if any of the preprinted data is absent (the area to the left of the label space lists the information that should appear), please provide it in the proper fill-in area(s) below. If the label is complete and correct, you need not complete Items I, III, V, and VI (except VI-B which must be completed regardless). Complete all items if no label has been provided. Refer to the instructions for detailed item descriptions and for the legal authorizations under which this data is collected.

II. POLLUTANT CHARACTERISTICS

INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer yes to any questions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark X in the box in the third column if the supplemental form is attached. If you answer no to each question, you need not submit any of these forms. You may answer no if your activity is excluded from permit requirements; see Section C of the instructions. See also, Section D of the instructions for definitions of bold-faced terms.

Mark X Mark X

SPECIFIC QUESTIONS YES NO FORM ATTACHED SPECIFIC QUESTIONS YES NO FORM

ATTACHED

A. Is this facility a publicly owned treatment works which results in a discharge to waters of the U.S.? (FORM 2A)

16 17 18

B. Does or will this facility (either existing or proposed) include a concentrated animal feeding operation or aquatic animal production facility which results in a discharge to waters of the U.S.? (FORM 2B) 19 20 21

C. Is this a facility which currently results in discharges to waters of the U.S. other than those described in A or B above? (FORM 2C)

22 23 24

D. Is this a proposed facility (other than those described in A or B above) which will result in a discharge to waters of the U.S.? (FORM 2D)

25 26 27

E. Does or will this facility treat, store, or dispose of hazardous wastes? (FORM 3)

28 29 30

F. Do you or will you inject at this facility industrial or municipal effluent below the lowermost stratum containing, within one quarter mile of the well bore, underground sources of drinking water? (FORM 4) 31 32 33

G. Do you or will you inject at this facility any produced water or other fluids which are brought to the surface in connection with conventional oil or natural gas production, inject fluids used for enhanced recovery of oil or natural gas, or inject fluids for storage of liquid hydrocarbons? (FORM 4) 34 35 36

H. Do you or will you inject at this facility fluids for special processes such as mining of sulfur by the Frasch process, solution mining of minerals, in situ combustion of fossil fuel, or recovery of geothermal energy? (FORM 4)

37 38 39

I. Is this facility a proposed stationary source which is one of the 28 industrial categories listed in the instructions and which will potentially emit 100 tons per year of any air pollutant regulated under the Clean Air Act and may affect or be located in an attainment area? (FORM 5) 40 41 42

J. Is this facility a proposed stationary source which is NOT one of the 28 industrial categories listed in the instructions and which will potentially emit 250 tons per year of any air pollutant regulated under the Clean Air Act and may affect or be located in an attainment area? (FORM 5)

43 44 45

III. NAME OF FACILITY C

1 SKIP

15 16 29 30 69

IV. FACILITY CONTACT A. NAME & TITLE (last, first, & title) B. PHONE (area code & no.)

C

2

15 16 45 46 48 49 51 52- 55

V. FACILTY MAILING ADDRESS A. STREET OR P.O. BOX

C

3 15 16 45

B. CITY OR TOWN C. STATE D. ZIP CODE C

4

15 16 40 41 42 47 51

VI. FACILITY LOCATION A. STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER

C

5 15 16 45

B. COUNTY NAME

46 70

C. CITY OR TOWN D. STATE E. ZIP CODE F. COUNTY CODE (if known) C

6

15 16 40 41 42 47 51 52 -54

EPA Form 3510-1 (8-90) CONTINUE ON REVERSE

Attachment to EPA Form 1

Part X. Existing Environmental Permits

D. Air permits issued for construction of the production facility are:

964650P

964706F

964707P

964708P

964709P

964710P

964711P

E. Other (ARAP permits issued for facility construction)

ARAP NR1206.274 GP Utility Line Crossing

ARAP NR1106.082 GP Minor Alterations to Wetlands

ARAP NR1106.083 GP Minor Road Crossings

ARAP NR1106.084 GP Utility Line Crossings

[p

!?!?

!?!?!?

!?!?!?

!?

!?!?

!?

!?

!?

!? !?

!?

!?

!?

!?

33-NRP

3-P (Pond Creek)5-SRP10-P (Pond Creek)

14-P (Pond Creek)

16-P (Mink Creek)18-P (Lick Creek)

20-P25-P (Potter Creek)

28-P

30-P

31-P

39-P (War Branch)

43-P (Lick Creek)

6-SRP

35-P (Black Creek)

51-SRP46-SRP

55-P

60-SRP

X:\U

S Nitro

gen\US

Nitroge

n_Nolic

hucky_

Withdr

awal_F

ishHatc

h.mxd

0 0.75 1.5 2.25 3Miles

FIGURE 1LOCATION OF US NITROGEN FACILITYAND PROPOSED PIPELINE, INTAKE AND OUTFALL STRUCTURES

1-800-588-7962WWW.ENSAFE.COM

B. MartinREQUESTED BY:

DATE: 1/3/20140888813456PROJECT NO:

M. SenneDRAWN BY:

Legend!? Stream Crossings[p

Approximate Location for WaterIntake and Outfall StructuresProposed Pipeline RouteApproximate US Nitrogen Boundary

Service Layer Credits: Copyright: 2013 National Geographic Society, i-cubed

Form Approved. OMB No. 2040-0086. Approval expires 8-31-98.

Please print or type in the unshaded areas only

EPA I.D. NUMBER ( )

Form

2D NPDES

New Sources and New Dischargers Application for Permit to Discharge Process Wastewater

I. Outfall Location For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.

Latitude Longitude Outfall Number ( ) Deg. Min. Sec. Deg. Min. Sec.

Receiving Water ( )

II. Discharge Date (When do you expect to begin discharging?)

III. Flows, Sources of Pollution, and Treatment Technologies A. For each outfall, provide a description of: (1) All operations contributing wastewater to the effluent, including process wastewater, sanitary

wastewater, cooling water, and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater. Continue on additional sheets if necessary. Outfall

Number 1. Operations Contributing Flow

( ) . Average Flow

) 3. Treatment

EPA Form 3510-2D (Rev. 8-90) PAGE 1 of 5

caustinRectangle

caustinRectangle

caustinRectangle

caustinTypewritten TextCooling Tower Blowdown

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinTypewritten TextProcess Condensate

caustinTypewritten TextBoiler Blowdown

caustinTypewritten TextCooling Tower Sidestream FilterBackwash

caustinTypewritten TextEquipment Washdown

caustinTypewritten TextStormwater from Process Area

caustinTypewritten TextTotal

caustinTypewritten TextIncluded in C.T. Blowdown Steam Stripping

caustinTypewritten Text6,000 gpd


caustinTypewritten Text1-U




caustinTypewritten Text1-U; oil-water separation

caustinTypewritten Text1-U, 2-K

caustinRectangle

caustinTypewritten Text22

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle

caustinRectangle



caustinTypewritten Text570 gpd




B. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units labeled to correspond to the more detailed descriptions in Item III-A. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures.

C. Except for storm runoff, leaks, or spills, will any of the discharges described in Items III-A be intermittent or seasonal? YES ( ) NO ( )

1. Frequency 2. Flow Outfall

Number a. Days

Per Week (

b. Months Per Year

( )

a. Maximum Daily Flow Rate ( )

b. Maximum Total Volume

( )c. Duration

)

IV. Production If there is an applicable production-based effluent guideline or NSPS, for each outfall list the estimated level of production (projection of actual production level, not design), expressed in the terms and units used in the applicable effluent guideline or NSPS, for each of the first 3 years of operation. If production is likely to vary, you may also submit alternative estimates (attach a separate sheet).

Year A. Quantity Per Day B. Units Of Measure c. Operation, Product, Material, etc. )

EPA Form 3510-2D (Rev. 8-90) Page 2 of 5 CONTINUE ON NEXT PAGE

CONTINUED FROM THE FRONT EPA I.D. NUMBER ( ) Outfall Number

V. Effluent Characteristics A and B: These items require you to report estimated amounts ( ) of the pollutants to be discharged from each of your outfalls. Each part of this item addresses a different set of pollutants and should be completed in accordance with the specific instructions for that part. Data for each outfall should be on a separate page. Attach additional sheets of paper if necessary. General Instructions Each part of this item requests you to provide an estimated daily maximum and average for certain pollutants and the source of information. Data for all pollutants in Group A, for all outfalls, must be submitted unless waived by the permitting authority. For all outfalls, data for pollutants in Group B should be reported only for pollutants which you believe will be present or are limited directly by an effluent limitations guideline or NSPS or indirectly through limitations on an indicator pollutant.

1. Pollutant 2. Maximum Daily

Value

3. Average Daily Value

4. Source

EPA Form 3510-2D (Rev. 8-90) Page 3 of 5 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT EPA I.D. NUMBER ( )

C. Use the space below to list any of the pollutants listed in Table 2D-3 of the instructions which you know or have reason to believe will be discharged from any outfall. For every pollutant you list, briefly describe the reasons you believe it will be present.

1. Pollutant 2. Reason for Discharge

VI. Engineering Report on Wastewater Treatment A. If there is any technical evaluation concerning your wastewater treatment, including engineering reports or pilot plant studies, check the

appropriate box below. Report Available No Report

B. Provide the name and location of any existing plant(s) which, to the best of your knowledge resembles this production facility with respect to production processes, wastewater constituents, or wastewater treatments.

Name Location

EPA Form 3510-2D (Rev. 8-90) Page 4 of 5 CONTINUE ON NEXT PAGE

caustinRectangle

caustinTypewritten TextHSAAP (BAE Systems) Holston River, Hawkins County, TN

EPAForm2DPartV.EffluentCharacteristics(Estimated)Parameter Intake Parameter

gpm MGD gpm MGDFlow,average 1010 1.45 398 0.573 1.45 398 0.573 Flow,averageFlow,maximumday 1234 1.78 731 1.052 1.78 731 1.052

Conc Mass Conc Mass Mass Conc Mass Conc Mass(mg/L) (Lb/day) (mg/L) (Lb/day) (Lb/day) (mg/L) (Lb/day) (mg/L) (Lb/day)

Table2D2GroupABOD 2 24.3 6 31 24 1 7 6 57 BOD intake,treatmentchemicals 4COD 5 60.6 54 259 61 41 198 54 475 COD intake,treatmentchemicals 4TOC 2 24.3 16 75 24 11 50 16 137 TOC intake,treatmentchemicals 4TSS 20 243 17 83 243 33 160 17 152 TSS intake 4Ammonia(asN) 0.05 0.6 4.2 19.9 0.6 4.0 19 8.3 73 Ammonia(asN) intake,process 2,4Temperature(winter) 15 20 15 20 22 Temperature(winter) process 4Temperature(summer) 26 28 26 28 30 Temperature(summer) process 4pH 7.5 7.8 7.5 7.8 8.2 pH process,treatmentchemicals 4

GroupB GroupBBromide 0.2 2.4 1.9 8.9 2.4 1.35 6.5 1.9 16 Bromide intake,treatmentchemicals 4T.R.Chlorine 0 0.0 0.00 0.01 0.00 0.00 0.01 0.00 0.01 T.R.Chlorine treatmentchemicals 4Color 6 72.8 21.9 104.5 72.8 6.6 31.7 21.9 192 Color intake 4FecalColiform present present present present present present present present present FecalColiform intake 4Fluoride 0.14 1.7 0.51 2.4 1.7 0.16 0.7 0.5 4.5 Fluoride intake 4NitrateNitrite(asN) 0.42 5.1 6.77 32.4 5.1 5.70 27.3 6.8 59 NitrateNitrite(asN) intake,process,spills 4Oil&Grease 0 0.0 0.39 1.9 0.0 0.39 1.9 0.4 3.4 Oil&Grease operatingequipment 4Phosphorus(asP) 0.03 0.4 0.38 1.8 0.4 0.30 1.4 0.4 3 Phosphorus(asP) intake,treatmentchemicals 4Sulfate(asSO4) 7.8 94.6 41 194 95 21 100 41 357 Sulfate(asSO4) intake,treatmentchemicals 4Sulfite(asSO3) 0 0.0 0.00 0.0 0.0 0.00 0.0 0.0 0.0 Sulfite(asSO3) treatmentchemicals 4Surfactants 0 0.0 3.49 16.7 0.0 3.49 16.7 3.5 31 Surfactants treatmentchemicals 4Aluminum 0.03 0.4 2.96 14.2 0.4 2.89 13.8 3.0 26 Aluminum intake,treatmentchemicals 4Barium 0.03 0.4 0.11 0.5 0.4 0.03 0.2 0.1 1.0 Barium intake 4Boron 0.02 0.2 0.07 0.3 0.2 0.02 0.1 0.1 0.6 Boron intake 4Iron 0.04 0.5 0.17 0.8 0.5 0.07 0.3 0.2 1.5 Iron intake,stormwater 4Magnesium 5.6 67.9 20.4 97.7 67.9 6.23 29.8 20 179 Magnesium intake,stormwater 4

Section1 Section1Cadmium 0.01 0.1 0.04 0.2 0.1 0.01 0.1 0.0 0.3 Cadmium intake,stormwater 4Chromium 0.02 0.2 0.07 0.3 0.2 0.02 0.1 0.1 0.6 Chromium intake,stormwater 4Copper 0.03 0.4 0.14 0.6 0.4 0.06 0.3 0.1 1.2 Copper intake,treatmentchemicals 4Lead 0.05 0.6 0.18 0.9 0.6 0.06 0.3 0.2 1.6 Lead intake,stormwater 4Nickel 0.01 0.1 0.04 0.2 0.1 0.01 0.1 0.0 0.3 Nickel intake,stormwater 4Zinc 0.01 0.1 0.06 0.3 0.1 0.03 0.1 0.1 0.5 Zinc intake,stormwater 4

Table2D3 Table2D3None NA NA NA NA NA NA NA None NA 4

Table2D4 Table2D4Ammonia Ammonia intake,process 4Chlorine Chlorine treatmentchemicals 4Cupricsulfate 0 0.0 0.1 0.24 0.0 0.1 0.2 0.1 0.4 Cupricsulfate treatmentchemicals 4EDTA 0 0.0 0.0 0.1 0.0 0.0 0.1 0.0 0.1 EDTA treatmentchemicals 4Phosphoricacid 0 0.0 2.0 9.7 0.0 2.0 9.7 2.0 18 Phosphoricacid treatmentchemicals 4Phosphorus Phosphorus intake,treatmentchemicals 4Sodiumbisulfite 0 0.0 1.5 7.1 0.0 1.5 7.1 1.5 13 Sodiumbisulfite treatmentchemicals 4Sodiumhydroxide 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Sodiumhydroxide treatmentchemicals 4Sodiumhypochlorite 0 0.0 21 103 0.0 21 103 21 188 Sodiumhypochlorite treatmentchemicals 4Sulfuricacid 0 0.0 61 292 0.0 61 292 61 536 Sulfuricacid treatmentchemicals 4

Avg.Day,NetAvg.Day,Gross

AttachmentVtoEPAForm2D

seeaboveseeabove

seeabove

OriginorSuspectedSource(s)ofConstituent Information

SourceCode

Max.Day,Gross

SeeaboveSeeabove

Seeabove

IntakeWater

01/24/2014

AttachmentIIIBtoEPAForm2D

5 A10 D15 E115 F120 B25 C30 E235 F250 G60 H70 J80 K90 L

001

LimitedavailabilitySubjecttointerruption

RecoveredAmmonia FireProtectiontoProcess

AmmoniaPlantProcessCondensate ProcessUses

SteamAntiscalant

Process 35Antiscalant Condensate Bisulfite

Polymer SaltBisulfite CoolingTower

Coagulant Chlorine ChemicalsJ

pHAdjust

15 20 25 30 80 50 60 7010

A D F1 E1 B C F2 E2 G&H

MosheimWWTPWater Solids L Headworks

(toLandfill)

90 TMSP

5 Water Held,Tested,ReleasedK

NolichuckyRiverOutfall 001

ReverseOsmosis2CleaningReverseOsmosis2RejectSoftenerBackwashSoftenerBrineBoilerBlowdownSWHeld,Tested,ReleasedEquipmentWashdownTotalEffluent

Roughing&MultiMedia

Filters

f

r

o

m

C

o

o

l

i

n

g

W

a

t

e

r

U

s

e

s

2MGStorageTankfor

ClarifiedWater

CleaninPlaceSystem

ReverseOsmosis

SteamStripper

EffluentFlowsName

DAFSolidsMultiMediaFilterBackwashReverseOsmosis1CleaningReverseOsmosis1RejectCoolingTowerBlowdownC.TowerFilterBackwash

0.3 430 368 8,600204 293,400 300 432,000

1,130,000 996 1,434,000 815 1,174,000 1200 1,728,000ReverseOsmosis1Product 589 848,000 747 1,076,000 611 880,000 900 1,296,000ProcessCondensate 76 109,000

SolidsHandling

24731

C.TowerSidestreamFilter 19801980 2,851,000 2,851,000

ReverseOsmosis2Feed 330224 323,000 475,00090

SoftenerProduct50

EffluentHoldingBasin&PumpStation

StormWater

EquipmentWashdown

10 15,000 20,000398 573,000 1,052,000

1/24/2014

BrineTank

ReverseOsmosis

NolichuckyRiverIntake

Filters

IncomingWaterStorageBasin

Boilers

SoftenersDemineralizedWaterTank

PumpStation

Strainer/Screen

t

o

C

o

o

l

i

n

g

W

a

t

e

r

U

s

e

s

(overflowtoSevenSprings)

CleaninPlaceSystem

SedimentationBasins1A/1B

CoolingTowersSumpDissolvedAirFlotation

10 15,000 20,0000.02 30 740

90 1,88016

0.04

240163 235,000 346,00025

65 93,800 129,600

251,00060

4 6,000 12,000ReverseOsmosis2Product 240163 235,000 346,000

203,400MultiMediaFilterFeed 1300918 1,322,000 1,872,000

1350.1 140 2,880CoolingTowerMakeup 1100430 619,000 1,584,000

42071 101,700

138,200DAFEffluent 1300918 1,322,000 1,872,000

2000.8 1,200 2,400

DAFFeed 1300926 1,333,000 1,872,000

9624 34,560ReverseOsmosis1Feed 785

568.1 11,600 80,600gpmgpm gpd gpd gpmgpm gpd

ID#ID# AverageFlow MaximumFlow

SimplifiedWaterSupply,Treatment,UseandEffluentFlowDiagramPRELIMINARYUSNitrogen

WaterDistrict

Name Normal MaximumDailyFlowgpm gpd1234 1,777,0001175 1,692,0001165 1,678,000

500 720,000

gpdRawWaterSupplyfromRiver 1350972 1,400,000 1,944,000

76 109,000

1165 1,678,000

330 475,000240 346,000240 346,000

76 109,000

954 1,373,000

239 344,000174 251,0001741980 2,851,00035 50,000

DesignCapacityWaterSupply

HarvestedStormWater1980 2,851,000

2,500,000

AverageFlowgpm gpd1010 1,454,000962 1,385,000954 1,373,000

440 634,000

US Nitrogen LLC Attachment VII January 24, 2014 to EPA Form 2D

1

Project Description

US Nitrogen LLC, a subsidiary of Austin Powder Company, is currently in the process of

constructing a production facility for nitric acid, ammonia, and liquid ammonium nitrate solution.

The investment is a central element of Austins vertical integration strategy as it will significantly

reduce the companys dependence on a shrinking base of third-party suppliers of ammonium

nitrate solution. The plant will become a key part of Austin Powders supply chain for raw

materials that are critical for its operations in the eastern and Midwestern regions of the United

States. It also appears likely that secondary operations to produce calcium nitrate and liquefied

carbon dioxide from primary products and byproducts will be co-located at the facility. The

total estimated capital investment is in excess of $200 million. With projected employment of

80 to 100 persons, the facility will inject more than $5 million in direct payroll into the local

economy on an annual basis. Indirect economic benefits are projected to approach $10 million

per year.

The facility is located on approximately 500 acres at 471 Pottertown Road in Midway, Tennessee.

General aquatic resource alteration permits (ARAPs) have been issued for its construction.

Water and Wastewater Requirements

US Nitrogen water supply needs and effluent flows are based on design production at the

facility of 200 tons per day (TPD) of ammonia, 600 TPD of nitric acid, and 840 TPD of

ammonium nitrate solution. Potable water usage by the facilitys employees is estimated to

average about 3,000 gallons per day (gpd) and will be provided by Old Knoxville Highway Water

Utility District (OKHWUD). The corresponding flow of sanitary sewage from facility restrooms

and employee showers will be discharged to the local publically owned treatment works

(POTW), which is the Town of Mosheims sanitary sewerage system and Lick Creek Valley

wastewater treatment plant (WWTP).

A process flow diagram is included as Attachment III-B and provides a summary of the

industrial water needs for process and cooling. The industrial water demand of US Nitrogen is

estimated to average 1.45 million gallons per day (MGD), which is beyond the capability of

OKHWUD without jeopardizing reliable service to its existing customers. Similarly, the projected

average daily effluent flow of 0.57 MGD would consume essentially all of the remaining capacity

of the local POTW, which has a current average daily flow of 0.6 MGD compared to a permitted

average daily design flow of 0.975 MGD.

Therefore, after evaluating these and other alternatives for its primary water supply and

effluent disposal, US Nitrogen is seeking permits to construct a water intake structure and an


2

outfall discharge structure on the Nolichucky River at approximate river mile 20.8 and to

discharge effluent via the outfall. The proposed location is approximately 10 miles southwest of

the US Nitrogen production facility. Applications for ARAPs for the construction of the water

intake and outfall structures and the supply and effluent pipelines between the US Nitrogen

facility and the river are being submitted to Tennessee Department of Environment and

Conversation Division of Water Resources (TDEC-DWR). Corresponding applications are

being submitted to Tennessee Valley Authority (TVA) and US Army Corps of Engineers (USACE)

for the associated 26a permits.

Based on interpolation of USGS stream flow data, the 7-day, 10-year (7Q10) low flow in the

Nolichucky River at the proposed intake and outfall location is approximately 360 cubic feet per

second (cfs), or about 233 MGD. The mean annual flow is estimated to exceed 2,000 cfs, or

1,290 MGD.

It is anticipated that US Nitrogens average gross water withdrawal rate from the Nolichucky

River will be approximately 1.45 MGD. The anticipated average effluent flow to the Nolichucky

River will be approximately 0.57 MGD. Therefore, the anticipated average net water usage will

be approximately 0.9 MGD, which is less than 0.5 percent of the rivers 7Q10 flow. The

projected maximum water withdrawal rate is 1,350 gallons per minute (gpm) or 1.9 MGD, still

less than one percent of the 7Q10 flow. The maximum daily effluent flow is estimated to be

1.05 MGD.

Cooling is the largest use of water at the US Nitrogen facility. To manage the heat generated in

the facilitys production processes, a cooling water flow of 33,000 gallons per minute (gpm), or

greater than 47 MGD, is required to be circulated from three cooling towers out to process

areas and back. Operating on 20 cycles with an average blowdown of 0.035 MGD, an average

evaporation rate of about 0.69 MGD, and recovery of process condensate at about 0.11 MGD,

the net water usage of the cooling towers is about 0.62 MGD. This is less than 2 percent of the

water that would be needed at once for cooling.

To reduce its need for river water and more effectively manage site storm water, US Nitrogen

intends to manage storm water runoff from industrial areas of its facility so as to allow

harvesting, storage, and use of this resource. On an annual basis, this storm water is estimated

to average about 50,000 gpd.


3

Alternatives Analysis

Several alternatives were considered to meet US Nitrogens requirements for wastewater

disposal. The alternatives have included discharge to the local POTW (Mosheim), discharge to

a regional POTW (Greeneville), direct discharge of all or part of the facilitys process wastewater

to Lick Creek, land application on facility property, zero liquid discharge, and direct discharge at

three Nolichucky River locations. The evaluations of these alternatives are summarized below.

Discharge to POTW

Treatment of sanitary sewage and limited flows of industrial wastewater in the area of the US

Nitrogen facility is provided by the Town of Mosheim through its WWTP. As mentioned above,

the Mosheim WWTP has a permitted average design flow of 0.975 MGD and has been receiving

an annual average daily flow of approximately 0.6 MGD. The discharge from this WWTP is to

Lick Creek and is regulated by National Pollutant Discharge Elimination System (NPDES) permit

TND0059366, which has an expiration date of April 30, 2015. The permit includes both

concentration and mass limits for carbonaceous biological oxygen demand (CBOD), total

suspended solids (TSS), and ammonia nitrogen, and mass limits for total nitrogen. The

impaired status of Lick Creek for nitrogen precludes additional loading of nitrogen to the creek,

thereby eliminating the WWTPs option to expand without adding costly, advanced treatment.

According to publically available documents, the WWTP has exceeded its permit limits for

ammonia nitrogen and total nitrogen numerous times in recent years. In an effort to mitigate

this problem, the WWTP in 2013 installed a new anoxic process in which nitrate nitrogen can be

biologically converted to elemental nitrogen and liberated to the atmosphere.

Discharge to Mosheim WWTPs Headworks

Projections indicate US Nitrogens total effluent stream would meet pretreatment limits

established currently by Mosheim for industrial discharges to its collection system, which

conveys wastewater to the headworks of the Mosheim WWTP. Consequently, US Nitrogen

made application to Mosheim WWTP for the discharge of industrial effluent and sanitary

sewage.

Unfortunately, discharge of US Nitrogens industrial effluent to the Mosheim WWTP via

conventional means, i.e., through the POTWs sewerage system to the headworks of the

WWTP, would effectively consume all remaining hydraulic capacity in the WWTPs biological

treatment process. Furthermore, the relatively high-flow, low-strength characteristics of the US

Nitrogen effluent would be generally incompatible with the Towns WWTP. Routing all the US

Nitrogen effluent to the WWTPs headworks could jeopardize the WWTPs ability to meet its


4

own effluent limits and performance requirements. The WWTP would be more susceptible to

washouts of its biological treatment processes, and the dilution of the WWTPs influent BOD and

TSS could make it difficult on many occasions to meet the 85% removal standards for these

parameters.

Split Flow Discharge to Mosheim WWTP

Wastewater generated by US Nitrogen is predominantly (approximately 90%) from industrial

water treatment and cooling uses, and the loadings of conventional pollutants in the aggregate

of these streams are projected to be at or below the WWTPs average effluent concentrations.

Therefore, splitting US Nitrogens flow to route this stream to a point downstream of the

WWTPs biological treatment processes appeared prudent. As a result, US Nitrogen revised its

application to the Town of Mosheim to reflect a split flow regime, under which the high-

volume, low-strength effluent would be routed as described in the previous sentence and the

balance - sanitary sewage and low-volume, high-strength streams (equipment washdown, etc.)

- would report to the headworks. The Town of Mosheim requested a modification of its NPDES

permit to accommodate this approach, and a draft permit to this effect has been put on public

notice by TDEC-DWR. As expected, Mosheims current mass limits for ammonia and total

nitrogen remain unchanged in the draft permit because Lick Creek is impaired for nitrogen.

To date Mosheim has yet to indicate what discharge limits will be required for the split flow

from US Nitrogen. Furthermore, Mosheims permit is up for renewal in 2015, and its limits may

be reduced, so the long term viability of this approach and the consequences for US Nitrogen

are uncertain.

Discharge to Greeneville POTW

US Nitrogen facilitated several meetings among officials of Mosheim, Greeneville, Greene

County, and potential funding agencies in an effort to find a mechanism whereby Mosheim

would abandon its WWTP and enter into an agreement to convey its wastewater, including that

of US Nitrogen, to the City of Greenvilles POTW. In spite of US Nitrogens commitment to

provide significant funding for this endeavor, no consensus could be reached.

Land Application

Given the relatively low pollutant concentrations in US Nitrogens effluent, it would appear to be

amenable to disposal via land application. A review of topographic and geological maps

reveals, however, that after allowing for regulatory buffers at property lines and water features,

a very limited portion of the site is classified as unlimited or fully suitable for irrigation and

less than 20% or 100 acres of US Nitrogens 500-acre site appears to be somewhat limited for

this purpose. Preliminary evaluation in accordance with guidelines published by the TDEC-DWR


5

indicates that over 200 acres of land somewhat suitable for irrigation and a storage basin of

approximately 60 million gallons would be required to manage and dispose of the RO reject,

cooling tower blowdown and boiler blowdown effluents via this alternative. This amount of

suitable land is not available to US Nitrogen; therefore, this option is not viable.

Direct Discharge to Lick Creek

US Nitrogen has explored the option of discharging its relatively dilute effluent streams directly

to Lick Creek in the general vicinity of the Mosheim WWTPs outfall. The regulatory

classification of Lick Creek as an impaired stream for nitrogen restricts any permitted discharge

that would add nitrogen to the creek. Consequently, TDECDWR has indicated it is not

possible to issue a direct discharge permit to US Nitrogen for a stream or streams that would

add any nitrogen to Lick Creek. It would appear, however, that discharge of filter backwash,

reverse osmosis reject, and related water treatment plant (WTP) wastewaters could be

discharged to Lick Creek via the general permit for WTP filter backwash, provided no nitrogen

were added.

On this presumption, in August 2013 US Nitrogen submitted an application to TVA and USACE

for a Joint 26A Permit for the installation of a wastewater outfall structure (and a water intake)

on Lick Creek on property used by the Town of Mosheim and adjacent to the existing Mosheim

WWTP outfall. Parallel applications for a state 401 permit, ARAP and a notice of intent (NOI)

for coverage under the WTP filter backwash general permit were submitted to TDECDWR in

September 2013. At the time US Nitrogen had planned to construct an intake structure and

associated pipeline using Mosheim property/easement. Subsequently it was determined that US

Nitrogen could not use the proposed pipeline corridor at Mosheims WWTP, and in October 2013

the Lick Creek applications were revised to locate the proposed structures one mile downstream

on the Hinkle property.

Under this approach, it has been assumed that cooling tower blowdown, equipment washdown,

and other non-WTP wastewaters would be routed to the Mosheim WWTP under the split flow

arrangement.

Zero Liquid Discharge

US Nitrogen has evaluated options that would enable it to recover and re-use its effluent using

a combination of advanced treatment technologies. These technologies require higher and

higher energy inputs as the liquid residuals become more concentrated. Ultimately,

concentrated brine solutions are typically transported to an offsite hazardous waste treatment,

storage and disposal facility (TSDF), or further processed on-site to dry salts, which, in turn, are


6

likely destined for a TSDF. Preliminary evaluation indicates that a zero liquid discharge system

would have a capital cost on the order of $15 million and annual operating costs in excess of

$2 million. Such costs would make the US Nitrogen facility non-competitive and uneconomical.

Direct Discharge to Nolichucky River

Given the obstacles of the above alternatives and the characteristics of US Nitrogens effluent,

discharge to the Nolichucky River appears to be the most viable alternative. US Nitrogen

recognizes that portions of the Nolichucky River are classified by TDEC as an exceptional

water resource that could contain critical habitat for certain freshwater species. As a result, US

Nitrogen contracted with Dinkins Biological Consulting, LLC (Dinkins) for a freshwater mussel

survey at alternative locations in the Nolichucky River. To alleviate potential concerns about

other natural and cultural resources US Nitrogen has also retained Water Resources, Inc. (WRI)

for evaluation of streams and wetlands, and Cultural Resources Analysts (CRA) for a cultural

resources evaluation. Copies of the Dinkins, WRI and CRA reports have been submitted to

TDEC, TVA and USACE as attachments to ARAPs and 26a applications. CRA also performed a

Phase II National Register Assessment and report will be compiled and submitted.

Based upon the several alternatives evaluated (outlined above) and the findings of cultural and

natural resource investigations, US Nitrogen proposes to construct water intake and outfall

structures on the Nolichucky River at Nolichucky River Mile (NRM) 20.8 (Douthat property). The

project will involve construction of approximately 12 miles of pipeline, primarily along existing

road right-of-way, with a pump station for the intake at the Nolichucky River and an

equalization basin with pump station at the US Nitrogen site conveying effluent though the

pipeline to the outfall structure.

Description of Existing Aquatic Characteristics

The channel of the Nolichucky River at the proposed outfall location (NRM 20.8) is

approximately 230 feet wide. Using StreamStats to interpolate stream flow at this location from

data at upriver and downriver gaging stations, the estimated 7Q10 flow at this location is about

360 cfs. At this flow the corresponding depth on the northern bank of the river is estimated to

be approximately two feet. Based on observations during the mussel survey, the Nolichucky

River channel at this location and for a few hundred feet downstream consists primarily of

bedrock with limited areas of sand and gravel primarily near the banks.

Description of Proposed Aquatic Characteristics

The estimated characteristics of the US Nitrogen effluent are given in Attachment V.

Preliminary calculations indicate State of Tennessee in-stream, acute and chronic water quality


7

standards for each constituent known or believed to be present in the effluent would be

satisfied under prescribed, low-flow conditions (7Q10 or 30Q5, as applicable).

Based on preliminary discussions with TDEC-DWR, ammonia appears to be the constituent of

principal concern. Additional calculations show that the quantity of ammonia estimated in the

permit application represents less than five percent (5%) of the rivers available capacity

relative to Tennessees in-stream water quality standard for this parameter. Furthermore,

results of modeling using CORMIX show compliance with the Environmental Protection Agencys

(EPAs) proposed but not yet final revised water quality standard for ammonia can be achieved

within approximately 15 to 50 feet of the discharge point(s), depending upon the final

configuration of the discharge structure.

In searching for technology-based standards, US Nitrogen finds that the EPA categorical

effluent guidelines for neither Inorganic Chemicals Production (40 CFR 415) nor Explosives

Manufacturing (40 CFR 457) include applicable provisions. Although its products are intended

for use as raw materials in explosives rather than fertilizers, US Nitrogen has reviewed the EPA

categorical effluent guidelines of 40 CFR Part 418 Fertilizer Manufacturing as a benchmark for

evaluating the ammonia content of its effluent. Review of publically available permits confirms

that TDEC-DWR has applied similar logic in other permitting decisions in Tennessee, notably at

the Holston Army Ammunition Plant in Hawkins County. The appropriate benchmark appears to

be, in aggregate, the guidelines representing the degree of effluent reduction attainable by

application of the best available technology economically achievable (BATEA) for ammonia,

ammonium nitrate, and nitric acid production at fertilizer plants. These production-based

guidelines are found at 40 CFR 418.23, 418.43, and 418.53, respectively. Estimating that actual

production will be 80% of design capacity, these BATEA guidelines indicate an allowable

monthly average ammonia discharge of approximately 62 pounds per day (PPD) and a daily

maximum of approximately 128 PPD.

In its application, US Nitrogen is requesting an NPDES permit that would allow it to discharge

up to 20 PPD of ammonia on a monthly average basis and 73 PPD as a daily maximum. Each

of these values is less than its respective BATEA benchmark. US Nitrogen believes it can

achieve these levels through best management practices (BMPs) and by controlling the amount

of ammonia in the process condensate streams from the ammonia production plants, which are

the principal sources of ammonia in its effluent. To control the discharge of ammonia, US

Nitrogen will operate a steam stripper on each of the two ammonia process condensate lines.

This process will reduce the ammonia concentration in the condensate stream from about 1,500

ppm to about 35 ppm and return approximately 700 PPD of ammonia to production. At this


8

lower ammonia concentration the process condensate streams can be used as part of the

make-up water for the facilitys cooling towers, reducing overall water usage. And finally, the

cooling towers themselves provide stripping of a portion of the entrained ammonia. Other

process considerations do not allow the cooling towers to be operated for extended periods at

high pH levels optimum for ammonia stripping, but the high water recirculation rate and air flow

through the towers will promote significant ammonia removal even in the target pH range of

7.4 to 7.8.

Other BMPs will include capture and re-use of storm water and equipment wash water from

process areas. This will include administrative, operational, and structural measures to control

releases of raw materials, products and byproducts within the facility.

See Exhibit 1 for a typical cross section of the Nolichucky River at the project site. See Exhibit 2

for a general site plan of the proposed outfall structure. Note that this design is preliminary and

final design will be based on permitting and other requirements.

Exhibit 1 Nolichucky River Section

Exhibit 2 Intake/Outfall Structures

I:\2013 Projects BST\13456 US Nitrogen\GIS\To GIS\13456 - US Nitrogen Layout Nolichucky - 1.24.14.dwg, 1/

24/2014 5:00:46 PM

012414 Cover LetterNPDES Form 1 - 012414Cover page for Attachment to EPA Form 1 - Parts X and EFigure 1NPDES Form 2D - 012414Attachment V to EPA Form V - Revised 012414Attachment III-B to EPA Form 2D 012414Attachment VII to Form 2D Revised 24 January 2014 ca13456 - US Nitrogen Section Exhibit 1 - 1.09.1413456 - US Nitrogen Layout Nolichucky EXHIBIT 2 - 01.24.14

Documents

USN Douthat NPDES Permit Combined[1]-1