UPDATED: 10/20/2014 — see Change Log
OWNER: US Nitrogen (Austin Powder)
PROJECT: Greenfield ammonium nitrate plant
SUMMARY STATUS: Construction phase
Permits complete, September 2014, pending appeals and lawsuits. Broke ground in February 2012. Air permits issued (for the fourth time) and immediately appealed, July 2014. Water permits issued, and subject to numerous appeals, July 2014. Various lawsuits and restraining orders filed in August, September, and October 2014. Facing persistent local opposition (see Comments).
|Ammonia||200 short tons per day
73,000 short tons per year
|66,224 metric tons per year|
|Nitric Acid||600 short tons per day||198,637 metric tons per year|
|Ammonium Nitrate Solution||840 short tons per day
260,000 short tons per year
|139,071 metric tons per year|
|* Reported Capacity is in short tons (source: air permits). Adjusted Capacity for the Ammonium Nitrate plant is constrained to the publicized rate of 420 short tons per day, as this is roughly the maximum that can be produced given this site’s ammonia capacity. No such constraint is required for Nitric Acid. Adjusted Capacity is in metric tons assuming the plants operate for 365 days per year (see Methodology).|
FEEDSTOCK: Natural gas
END PRODUCTS: Ammonium Nitrate solution, Nitric Acid
US Nitrogen’s groundbreaking ceremony took place in February 2012; at that time, the company expected to start production in March 2014. Since then, the project became mired in planning snafus, creating a cascade of regulatory and legal disputes, most of which are now resolved.
Much of the plant has been constructed already, so it seems highly unlikely that US Nitrogen and its parent, Austin Powder, will walk away from their considerable investment. The issues still facing this site are primarily of a technical legal nature, and seem likely surmountable. That said, more construction has yet to begin on a CO2 liquefaction plant and Yara’s CAN plant, so it could yet prove cost-effective to relocate the plant to a less controversial site; the company likes to remind everyone that it is “keeping all options on the table.”
The issues surrounding US Nitrogen’s plant include:
- Water supply plans:
could triggera new lawsuit from the local water utility in August 2014.
- Air permit: appealed (no link available), July 2014.
- Water permits: NPDES permit appealed and ARAP appealed twice, July 2014. (As I understand the process, which I gather is new, the air and water permit appeals will be heard by an administrative law judge. If either party disagrees with the judgement, it can appeal to the relevant Board: air or water. If neither party likes the Board’s decision, it can be appealed again and return to the courts. The timeframe for this process doesn’t sound short: I hear that there’s a 180 day timeframe for the appeals to be heard, but if the decisions are appealed back and forth a few times, I should imagine it could be stretched out for well over a year. During all this process, construction can continue. US Nitrogen doesn’t need to be involved in these proceedings: the legal actions are against TDEC, however, I understand that US Nitrogen has filed to be a party to the appeals.)
- Right of way permit for water pipeline: denied by TDOT, June 2014, before being approved, August 2014.
- TDEC’s Water Quality Criteria: challenged by environmental groups through the EPA, June 2014 (potentially rendering all US Nitrogen’s water permits void).
- Site zoning: challenged in a lawsuit to be heard in October 2014.
- Land purchase: potential for litigation amid various ongoing accusations of fraud, bribery, perjury, corruption, and general abuse of office in September 2013 (apparently arising when the chairman, now retired, of the local utility district was supposed to be negotiating a price for the sale of public water, but instead negotiated the sale of personal land on the banks of the Nolichucky, where US Nitrogen now plans to withdraw water at no cost).
And finally:in July 2014, local officials of the Greene County Industrial Development Board sparked international outrage by arresting an individual at an open meeting who dared to ask them to speak up. The Tennessee Open Records Counsel is now flooded with public complaints, which will be passed on to the county attorney in due course. And finally:in September 2014, the Save the Nolichucky organization filed suit against US Nitrogen and the Industrial Development Board of Greeneville and Greene County (IDB), in an attempt to stop construction on the controversial water pipelines. And finally: in September 2014, another new lawsuit was filed, this time against TDOT, alleging that it was against state law to grant right of way for any entity other than a public utility.
- And finally: in October 2014, a number of residents secured a restraining order to stop US Nitrogen from trespassing – although US Nitrogen claims it hasn’t and doesn’t need to enter their properties to build the pipeline.
A large number of the problems facing US Nitrogen involve its plans to build a 12-mile dual pipeline, at a cost of “approximately $130,000 per mile.” The pipeline would take water from and discharge effluent into the Nolichucky River, crossing 20 streams on its way. This replaced the original plan, which would have involved paying to upgrade the local utility’s infrastructure as well as paying for water supply. It seems that US Nitrogen has solved this issue by developing a “split flow” plan for the plant’s water requirements, combining both the original plan to use the Town of Mosheim’s Lick Creek wastewater treatment plant as well as the double-pipeline, for which it received the final permits from the Tennessee Valley Authority and U.S. Army Corps of Engineers in September 2014.
US Nitrogen’s “state-of-the-art, environmentally friendly” plant sits on 50 acres, within a 450-acre tract, near Midway, in rural Greene County, Tennessee.
The greenfield project consists of two ammonia plants each with a capacity of 100 short tons per day (stpd), a nitric acid (NA) plant with capacity 600 stpd, and an ammonium nitrate solution (ANSOL) plant with capacity 840 stpd. The site’s ANSOL capacity will be constrained by the amount of ammonia it produces (US Nitrogen can not produce enough ammonia to make 840 stpd of ANSOL on a continuous basis; the company’s publicized ANSOL production rate of 420 stpd is more realistic).
US Nitrogen has altered and expanded its plans a number of times, adding to the complexity of the issues facing the project. The most significant additions to the site are a calcium ammonium nitrate (CAN) plant, to be owned and operated by Yara, and a carbon dioxide (CO2) liquefaction plant, whose owner and operator has not yet been decided (US Nitrogen is presently “in negotiations with multiple companies” to run the CO2 plant).
Yara’s 72,000 short ton per year (stpy) CAN plant will purchase its nitric acid feedstock from US Nitrogen and limestone “from nearby quarries,” the latter delivered by “a maximum of three trucks per day.” CAN solution, the finished product, will be shipped out by a maximum of “10 tankers per day.” The plant’s continuous process will consume up to 2.8 short tons (5,600 pounds) of milled limestone and 3.5 short tons (7,006 pounds) of nitric acid every hour.
The 90,000 stpy CO2 plant will liquefy “concentrated CO2 off-gas generated by the ammonia reforming process,” for sale to industrial consumers.
US Nitrogen’s air permits reflect the project’s torturous planning process: the initial air permit application was submitted in June 2011, revised in August 2011, approved in January 2012, extended in May 2013, extended again in December 2013, and the latest revised air permit was approved in June 2014. The air permit caps emissions at 215,044 stpy of greenhouse gases (CO2e) and 95.26 stpy of nitrogen oxides (NOx).
This latest permit incorporates the Yara and CO2 plants because “from a regulatory standpoint, they are likely considered a single ‘stationary source.'” The addition of the Yara plant increases site-wide emissions somewhat but the CO2 plant causes “a reduction of approximately 80%” of the (previously approved) CO2 emissions from the ammonia plant. Ammonia and VOC emission have increased, compared to the previous permit, “due to increased use of natural gas plus … new information from the catalyst manufacturer and the design engineer.” US Nitrogen gives no reason why these fundamental design details were changed so far into the construction phase, nor any indication that they won’t request still more changes as construction continues.
Regarding possible future modifications of the permits, the shortfall between permitted ammonia capacity and permitted ANSOL capacity is noteworthy: it would not surprise me if another air permit modification was coming around the corner. A ~75% expansion of the ammonia lines, to roughly 127,000 stpy, will be required before both US Nitrogen’s ANSOL plant and Yara’s CAN plant can operate at their permitted capacitites (see the math below).
US Nitrogen’s end product, ANSOL, a concentrated solution of ammonium nitrate in water, will be shipped to Austin Powder’s “manufacturing sites in Ohio and elsewhere,” where it will be used to manufacture blasting agents for the industrial explosives market. ANSOL is stored and shipped in “specially designed trucks” as a hot liquid. Depending on the strength of the solution, “hot” means a temperature of (for example) more than 225°F or 135 to 140°C. The company estimates that “30-40 truckloads per day will leave the plant.” It appears that local opposition groups have not questioned the safety implications of transporting this quantity of hot ANSOL by truck, nor has US Nitrogen provided any details.
MATH: US Nitrogen’s ammonia (NH3) feedstock consumption
One ton ANSOL requires 0.80 tons NA and 0.22 tons NH3.
One ton NA requires 0.29 tons NH3.
ANSOL production: 260,000 stpy
NA required for ANSOL (x0.80) = 208,000 stpy
… and NH3 required for NA (x0.29) = 60,320 stpy
NH3 required for ANSOL (x0.22 ) = 57,200 stpy
… so total NH3 required for ANSOL = 117,520 stpy (60,320 + 57,200)
CAN production: 72,000 stpy
NA input rate given as 7,006 pounds per hour = 30,686 stpy
… and NH3 required for NA (x0.29) = 8,899 stpy
Total site NH3 requirement (US Nitrogen + Yara) = 126,419 stpy (117,520 + 8,899)
Permitted site NH3 capacity = 73,000 stpy
A ~75% expansion of the ammonia lines is therefore required for all on-site plants to operate at permitted capacity. However, even this might underestimate the installed ANSOL capacity, as the 840 short tons per day capacity plant is permitted for 260,000 short tons per year. Operating for 365 days per year, an 840 stpd plant would produce 306,600 stpy, a ~20% expansion above the currently permitted ANSOL capacity and a ~100% expansion above the currently permitted ammonia capacity.
View larger map with all ammonia plants.