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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

J anuary 28, 2014




Mr. Britton Dotson via email: britton.dotson@tn.gov
Division of Water Resources
Tennessee Department of Environment and Conservation
312 Rosa L. Parks Avenue, 11
th
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, J r., P.E.
Senior Project Engineer


cc: Vojin J anji, DWR
J ustin 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
US NITROGEN LLC
FREEARK, JUSTIN, PLANT MANAGER (4?) 4??-?040
4II POTTERTOWN ROAD
MIDWAY TN I809
4II POTTERTOWN ROAD
GREENE
MIDWAY TN I809
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


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!?
!? !?
!?
!?
!?
!?
!?
!?
!?
!? !?
!?
!?
!?
!?
33-NRP
3-P (Pond Creek)
5-SRP
10-P (Pond Creek)
14-P (Pond Creek)
16-P (Mink Creek)
18-P (Lick Creek)
20-P
25-P (Potter Creek)
28-P
30-P
31-P
39-P (War Branch)
43-P (Lick Creek)
6-SRP
35-P (Black Creek)
51-SRP
46-SRP
55-P
60-SRP

X
:\U
S
N
itro
g
e
n
\U
S
N
itro
g
e
n
_
N
o
lic
h
u
c
k
y
_
W
ith
d
ra
w
a
l_
F
is
h
H
a
tc
h
.m
x
d
0 0.75 1.5 2.25 3
Miles
FIGURE 1
LOCATION OF US NITROGEN FACILITY
AND PROPOSED PIPELINE, INTAKE
AND OUTFALL STRUCTURES
1-800-588-7962
WWW.ENSAFE.COM
B. Martin REQUESTED BY:
DATE: 1/3/2014
0888813456 PROJECT NO:
M. Senne DRAWN BY:
Legend
!? Stream Crossings
[ p
Approximate Location for Water
Intake and Outfall Structures
Proposed Pipeline Route
Approximate 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

Cooling Tower Blowdown


Process Condensate
Boiler Blowdown
Cooling Tower Sidestream Filter
Backwash
Equipment Washdown
Stormwater from Process Area
Total
Included in C.T. Blowdown Steam Stripping
6,000 gpd
1,200 gpd 1-U
15,000 gpd
15,000 gpd
342,000 gpd
1-U; oil-water separation
1-U, 2-K
22
11,600 gpd
102,000 gpd
570 gpd
387,000 gpd
34,600 gpd
573,000 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
HSAAP (BAE Systems) Holston River, Hawkins County, TN
EPAForm2D
PartV.EffluentCharacteristics(Estimated)
Parameter Intake Parameter
gpm MGD gpm MGD
Flow,average 1010 1.45 398 0.573 1.45 398 0.573 Flow,average
Flow,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)
Table2D2
GroupA
BOD 2 24.3 6 31 24 1 7 6 57 BOD intake,treatmentchemicals 4
COD 5 60.6 54 259 61 41 198 54 475 COD intake,treatmentchemicals 4
TOC 2 24.3 16 75 24 11 50 16 137 TOC intake,treatmentchemicals 4
TSS 20 243 17 83 243 33 160 17 152 TSS intake 4
Ammonia(asN) 0.05 0.6 4.2 19.9 0.6 4.0 19 8.3 73 Ammonia(asN) intake,process 2,4
Temperature(winter) 15 20 15 20 22 Temperature(winter) process 4
Temperature(summer) 26 28 26 28 30 Temperature(summer) process 4
pH 7.5 7.8 7.5 7.8 8.2 pH process,treatmentchemicals 4
GroupB GroupB
Bromide 0.2 2.4 1.9 8.9 2.4 1.35 6.5 1.9 16 Bromide intake,treatmentchemicals 4
T.R.Chlorine 0 0.0 0.00 0.01 0.00 0.00 0.01 0.00 0.01 T.R.Chlorine treatmentchemicals 4
Color 6 72.8 21.9 104.5 72.8 6.6 31.7 21.9 192 Color intake 4
FecalColiform present present present present present present present present present FecalColiform intake 4
Fluoride 0.14 1.7 0.51 2.4 1.7 0.16 0.7 0.5 4.5 Fluoride intake 4
NitrateNitrite(asN) 0.42 5.1 6.77 32.4 5.1 5.70 27.3 6.8 59 NitrateNitrite(asN) intake,process,spills 4
Oil&Grease 0 0.0 0.39 1.9 0.0 0.39 1.9 0.4 3.4 Oil&Grease operatingequipment 4
Phosphorus(asP) 0.03 0.4 0.38 1.8 0.4 0.30 1.4 0.4 3 Phosphorus(asP) intake,treatmentchemicals 4
Sulfate(asSO4) 7.8 94.6 41 194 95 21 100 41 357 Sulfate(asSO4) intake,treatmentchemicals 4
Sulfite(asSO3) 0 0.0 0.00 0.0 0.0 0.00 0.0 0.0 0.0 Sulfite(asSO3) treatmentchemicals 4
Surfactants 0 0.0 3.49 16.7 0.0 3.49 16.7 3.5 31 Surfactants treatmentchemicals 4
Aluminum 0.03 0.4 2.96 14.2 0.4 2.89 13.8 3.0 26 Aluminum intake,treatmentchemicals 4
Barium 0.03 0.4 0.11 0.5 0.4 0.03 0.2 0.1 1.0 Barium intake 4
Boron 0.02 0.2 0.07 0.3 0.2 0.02 0.1 0.1 0.6 Boron intake 4
Iron 0.04 0.5 0.17 0.8 0.5 0.07 0.3 0.2 1.5 Iron intake,stormwater 4
Magnesium 5.6 67.9 20.4 97.7 67.9 6.23 29.8 20 179 Magnesium intake,stormwater 4
Section1 Section1
Cadmium 0.01 0.1 0.04 0.2 0.1 0.01 0.1 0.0 0.3 Cadmium intake,stormwater 4
Chromium 0.02 0.2 0.07 0.3 0.2 0.02 0.1 0.1 0.6 Chromium intake,stormwater 4
Copper 0.03 0.4 0.14 0.6 0.4 0.06 0.3 0.1 1.2 Copper intake,treatmentchemicals 4
Lead 0.05 0.6 0.18 0.9 0.6 0.06 0.3 0.2 1.6 Lead intake,stormwater 4
Nickel 0.01 0.1 0.04 0.2 0.1 0.01 0.1 0.0 0.3 Nickel intake,stormwater 4
Zinc 0.01 0.1 0.06 0.3 0.1 0.03 0.1 0.1 0.5 Zinc intake,stormwater 4
Table2D3 Table2D3
None NA NA NA NA NA NA NA None NA 4
Table2D4 Table2D4
Ammonia Ammonia intake,process 4
Chlorine Chlorine treatmentchemicals 4
Cupricsulfate 0 0.0 0.1 0.24 0.0 0.1 0.2 0.1 0.4 Cupricsulfate treatmentchemicals 4
EDTA 0 0.0 0.0 0.1 0.0 0.0 0.1 0.0 0.1 EDTA treatmentchemicals 4
Phosphoricacid 0 0.0 2.0 9.7 0.0 2.0 9.7 2.0 18 Phosphoricacid treatmentchemicals 4
Phosphorus Phosphorus intake,treatmentchemicals 4
Sodiumbisulfite 0 0.0 1.5 7.1 0.0 1.5 7.1 1.5 13 Sodiumbisulfite treatmentchemicals 4
Sodiumhydroxide 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Sodiumhydroxide treatmentchemicals 4
Sodiumhypochlorite 0 0.0 21 103 0.0 21 103 21 188 Sodiumhypochlorite treatmentchemicals 4
Sulfuricacid 0 0.0 61 292 0.0 61 292 61 536 Sulfuricacid treatmentchemicals 4
Avg.Day,Net Avg.Day,Gross
AttachmentV
toEPAForm2D
seeabove
seeabove
seeabove
OriginorSuspectedSource(s)of
Constituent Information
SourceCode
Max.Day,Gross
Seeabove
Seeabove
Seeabove
IntakeWater
01/24/2014
AttachmentIIIB
toEPAForm2D
5 A
10 D
15 E1
15 F1
20 B
25 C
30 E2
35 F2
50 G
60 H
70 J
80 K
90 L
001
Limitedavailability
Subjecttointerruption
RecoveredAmmonia FireProtection
toProcess
AmmoniaPlant
ProcessCondensate ProcessUses
Steam
Antiscalant
Process 35
Antiscalant Condensate Bisulfite
Polymer Salt
Bisulfite CoolingTower
Coagulant Chlorine Chemicals
J
pHAdjust
15 20 25 30 80 50 60 70
10
A D F1 E1 B C F2 E2 G&H
MosheimWWTP
Water Solids L Headworks
(toLandfill)
90 TMSP
5 Water Held,Tested,Released
K
NolichuckyRiver
Outfall 001
ReverseOsmosis2Cleaning
ReverseOsmosis2Reject
SoftenerBackwash
SoftenerBrine
BoilerBlowdown
SWHeld,Tested,Released
EquipmentWashdown
TotalEffluent
Roughing&
MultiMedia
Filters
f
r
o
m

C
o
o
l
i
n
g

W
a
t
e
r

U
s
e
s
2MGStorage
Tankfor
ClarifiedWater
CleaninPlace
System
Reverse
Osmosis
SteamStripper
EffluentFlows
Name
DAFSolids
MultiMediaFilterBackwash
ReverseOsmosis1Cleaning
ReverseOsmosis1Reject
CoolingTowerBlowdown
C.TowerFilterBackwash
0.3 430 368 8,600
204 293,400 300 432,000
1,130,000 996 1,434,000 815 1,174,000 1200 1,728,000
ReverseOsmosis1Product 589 848,000 747 1,076,000 611 880,000 900 1,296,000
ProcessCondensate 76 109,000
SolidsHandling
24
731
C.TowerSidestreamFilter 1980 1980 2,851,000 2,851,000
ReverseOsmosis2Feed 330 224 323,000 475,000
90
SoftenerProduct
50
EffluentHoldingBasin&
PumpStation
StormWater
Equipment
Washdown
10 15,000 20,000
398 573,000 1,052,000
1/24/2014
Brine
Tank
Reverse
Osmosis
Nolichucky
RiverIntake
Filters
IncomingWater
StorageBasin
Boilers
Softeners
Demineralized
WaterTank
PumpStation
Strainer/Screen
t
o

C
o
o
l
i
n
g

W
a
t
e
r

U
s
e
s
(overflowto
SevenSprings)
CleaninPlace
System
SedimentationBasins1A/1B
CoolingTowers Sump
DissolvedAir
Flotation
10 15,000 20,000
0.02 30 740
90 1,880
16
0.04
240 163 235,000 346,000
25
65 93,800 129,600
251,000
60
4 6,000 12,000
ReverseOsmosis2Product 240 163 235,000 346,000
203,400
MultiMediaFilterFeed 1300 918 1,322,000 1,872,000
135 0.1 140 2,880 CoolingTowerMakeup 1100 430 619,000 1,584,000
420 71 101,700
138,200
DAFEffluent 1300 918 1,322,000 1,872,000
200 0.8 1,200 2,400
DAFFeed 1300 926 1,333,000 1,872,000
96 24 34,560 ReverseOsmosis1Feed 785
56 8.1 11,600 80,600
gpm gpm gpd gpd gpm gpm gpd
ID# ID# AverageFlow MaximumFlow
SimplifiedWaterSupply,Treatment,UseandEffluentFlowDiagramPRELIMINARY
USNitrogen
Water
District
Name Normal MaximumDailyFlow
gpm gpd
1234 1,777,000
1175 1,692,000
1165 1,678,000
500 720,000
gpd
RawWaterSupplyfromRiver 1350 972 1,400,000 1,944,000
76 109,000
1165 1,678,000
330 475,000
240 346,000
240 346,000
76 109,000
954 1,373,000
239 344,000
174 251,000
174
1980 2,851,000
35 50,000
DesignCapacity
WaterSupply
HarvestedStormWater
1980 2,851,000
2,500,000
AverageFlow
gpm gpd
1010 1,454,000
962 1,385,000
954 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
US Nitrogen LLC Attachment VII
January 24, 2014 to EPA Form 2D
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.

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