US Nitrogen has submitted permit applications for what its officials hope will be an answer to a question that has plagued the project since its inception: How will the plant gather and discharge water needed for its manufacturing process?
The newest proposed answer: the Nolichucky River.
As of last week, US Nitrogen, which will produce liquid ammonium nitrate, has applied for permits with the Tennessee Department of Environment and Conservation (TDEC) to both gather water from the Nolichucky River and discharge used water back into the river.
The water would be discharged back into the river at a point about 10 miles southwest of US Nitrogen's 500-acre site along Pottertown Road.
US Nitrogen still plans to use potable water from Old Knoxville Highway Utility District for restrooms, showers and other sanitary, non-manufacturing uses.
Effluent water from those uses will be sent to the Town of Mosheim's wastewater treatment plant, known as Lick Creek Valley Wastewater Treatment Plant, and treated as normal sewage.
According to Aquatic Resource Alteration Permit (ARAP) applications submitted to TDEC, US Nitrogen officials anticipate using an average of 1.45 million gallons of water per day when fully operational.
The bulk of US Nitrogen's water needs will be for the plant's three cooling towers to cool off the extreme heat generated in the manufacturing process.
In all, the towers will use 33,000 gallons of water per minute, or 47 million gallons per day, according to US Nitrogen's ARAP applications.
Those numbers include all water circulating through the cooling towers at any one time, not just new water taken in each day.
The new water needed per day for the cooling towers is about 620,000 gallons, according to the ARAP applications.
At maximum output, 500 gallons of water per minute will evaporate off the cooling towers, according to US Nitrogen Environmental Manager Hollie Binkley.
Some river water would also be used for other parts of the manufacturing process, Binkley said.
Earlier plans had called for US Nitrogen to get all its water from Old Knoxville Highway Utility District and discharge all effluent water -- both sanitary and manufacturing water -- through the Lick Creek Valley Wastewater Treatment Plant.
"The water solution has changed over time," Binkley said in interviews last week.
When it became clear that neither Old Knox nor Mosheim could respectively provide for US Nitrogen's intake and discharge needs, company officials at one time considered buying water from the Greeneville Water Commission, but "no consensus could be reached," according to an ARAP application filed on Jan. 24.
"The only reliable, large body of water is the Nolichucky River," Binkley told The Greeneville Sun.
GETTING, DISCHARGING WATER
Binkley said US Nitrogen is proposing to build an intake station on the Nolichuckey with a pump station, pipe the water 10 miles to the plant along state right-of-way on McDonald Road to the back of US Nitrogen's property, then treat the water on site at a reverse osmosis station.
One of US Nitrogen's ARAP applications estimates that US Nitrogen will consume .5 percent of the Nolichucky River's overall volume in the area where company officials hope to take in water.
At the site where the intake station is planned, the river is about 230 feet wide, according to the application.
Binkley said the water US Nitrogen needs for its manufacturing process has to be cleaner even than drinking water the plant would have bought from a public utility.
"We cannot have any contaminants in the water," she said.
Minerals in drinking-grade water would build up over time in US Nitrogen's turbines and pipes and cause major damage, she said.
So even if US Nitrogen brought in water from a utility district, the company would have to treat it before it could be used in the manufacturing process.
Water that has processed through US Nitrogen's system would then be piped back out to the Nolichucky River, Binkley said -- about 570,000 gallons per day.
Some ammonia would be discharged back into the river, according to US Nitrogen's applications.
The company is requesting TDEC to allow it to discharge an average of about 20 pounds of ammonia per day back into the river, an amount which US Nitrogen says is below standards set by the EPA.
A PROBLEM REMAINS
Besides the sanitary water in restrooms and showers, some water used in the manufacturing process will be sent to the Lick Creek Valley Wastewater Treatment Plant.
But there are several obstacles in doing that.
Binkley said that, because of the level at which US Nitrogen will have to clean the river water before it uses the water in its own manufacturing processes, sending that water straight to a wastewater treatment plant such as Lick Creek Valley would actually damage the treatment plant.
The reason, she said, is that the effluent water coming from the plant would lack minerals that are needed for the breakdown of sewage at wastewater treatment plants. The organisms that wastewater treatment plants use to break down sewage would essentially starve, she said.
Nor can US Nitrogen empty its discharged water back into Lick Creek, because the U.S. Environmental Protection Agency (EP A) considers the stream "impaired" and restricts any activity that would add more nitrogen to the creek. US Nitrogen's effluent discharge would do that.
As a way solve the problem, US Nitrogen has proposed:
* treating the effluent water that would eventually be discharged from the plant into Lick Creek,
* and piping that treated effluent water from the plant into Mosheim's wastewater treatment plant, bypassing the sewage treatment area,
* merging the treated effluent water with Mosheim's treated wastewater,
* and discharging the treated effluent water into Lick Creek along with the Mosheim Wastewater Treatment Plant's treated wastewater.
The "split flow" option would technically allow US Nitrogen to discharge its water into Lick Creek by piggybacking onto Mosheim's discharge and avoid introducing its own water directly into the creek.
There is, however, an additional obstacle.
Because of the problems Mosheim's wastewater treatment plant has faced, that discharge option may not be available in the long-term future, which is why US Nitrogen has proposed also discharging water into the Nolichucky River.
"To date, Mosheim has yet to indicate what discharge limits will be required for the 'split flow' from US Nitrogen," a US Nitrogen ARAP application says.
"Furthermore, Mosheim's permit is up for renewal in 2015, and its limits may be reduced, so the long-term variability of this approach and the consequences for US Nitrogen are uncertain."
Local actress and environmental activist Park Overall has lodged complaints against US Nitrogen's plan, particularly any attempt to put effluent water into Lick Creek.
In comments submitted to TDEC last week, Overall criticized TDEC for not setting total maximum daily loads (TMDL) -- numeric limits on nitrates that can be put into Lick Creek, which is already considered impaired because of its elevated nitrate levels.
"This provides the appearance that TDEC is arguing that the plant is OK, because this permit with all the alterations and overwhelming increase of discharges from US Nitrogen to Lick Creek and the [Lick Creek Valley Wastewater Treatment Plant] will not be adding to the load," she wrote to TDEC. "There is no evidence to support that [conclusion]."
PROBLEMS AT MOSHEIM PLANT
Overall also criticized TDEC and the EPA for taking four years to spot the fact that Mosheim's wastewater treatment plant was operating outside EPA regulations.
In July 2013, the EPA notified the Town of Mosheim that it was in violation because it wasn't operating sand filters at the plant, which are designed to help separate liquid from solid waste.
The filters had been offline for more than four years.
Mosheim Mayor Tommy Gregg said Monday in an interview with The Greeneville Sun that the plant had been running without the filters ever since the deaths of operator Ronnie Carmichael and co-worker Jeremy Goforth in 2008 at the plant.
The filters have now been fixed, at the EPA's request, Gregg said.
"The sand filters have been going for several months now," Gregg said Monday.
The EPA ordered the town to get the filters back in operation last summer and fined the town $20,000, according to the mayor.
Overall said in her comments to TDEC that the fact that the plant operated out of compliance for four years without being caught shows a lack of regulatory oversight.
"So where is the oversight?" Overall wrote to TDEC. "The regulation by TDEC? This particular action, or lack thereof, is suspect at the very least with the pending millions of gallons of wastewater being considered to go through this [wastewater treatment plant] and to be bypassed."
While speaking to an audience in Bulls Gap on Jan. 24, Overall said any plans that include the use of the Mosheim wastewater treatment plants are irresponsible.
"The Mosheim wastewater treatment plant isn't working," Overall told the crowd in remarks at the Veterans of Foreign Wars building at Bulls Gap. (Please see accompanying story, Page A-1.)
The permits that US Nitrogen has applied for will be subject to public comment periods and public hearings before any approval can be given.
Because waterways such as the Nolichucky River and Lick Creek are highly regulated, US Nitrogen must also get approval from the Tennessee Valley Authority (TVA), The U.S. Army Corps of Engineers, the United States Fish and Wildlife Services and the Tennessee Department of Transportation.
US Nitrogen said in the applications filed last week that it has submitted corresponding permit applications to TVA and the Army Corps of Engineers.