01/03/92 SYNOPSIS: NITROGEN PRODUCTS, INC. (NPI) OWNS AND OPERATES A FERTILIZER PRODUCTION FACILITY LOCATED ON HWY 20 SOUTH, HELENA IN THE COUNTY OF PHILLIPS, ARK. ONE INACTIVE PHOSPHOGYPSUM STACK IS LOCATED AT THE FACILITY. THE PHOSPHOGYPSUM STACK WAS USED IN THE PRODUCTION OF PHOSPHORUS FERTILIZER DURING THE YEARS 1967-1977. THE PHOSPHOGYPSUM STACK HAS BEEN INACTIVE FROM 1977 TO THE PRESENT. THE INACTIVE PHOSPHOGYPSUM STACK EMITS RADON-222 TO THE AIR. THESE EMISSIONS ARE REGULATED BY THE NESHAPS FOR RADIONUCLIDES. SPECIFICALLY NIP IS SUBJECT TO 40 C.F.R. PART 61, SUBPART R, SET FORTH IN 40 C.F.R. 61.200-205. BY LETTER RECEIVED MARCH 26, 1990, EPA WAS NOTIFIED OF AN INACTIVE PHOSPHOGYPSUM STACK AT FIVE RIVERS NITROGEN CORPORATION (FRNC) LOCATED IN HELENA, ARK. IN ORDER TO DETERMINE THE APPLICABILITY AND COMPLIANCE STATUS OF THE INACTIVE PHOSPHOGYPSUM STACK, EPA SENT A LETTER TO FRNC REQUESTING INFORMATION. ON FEBRUARY 6, 1991 NPI RESPONDED TO EPA'S REQUEST FOR IN- FORMATION. IN THEIR RESPONSE, EPA WAS ADVISED THAT 3579 INVESTMENT CORPORATION (3579) ACQUIRED THE SUBJECT FACILITY BY DEED TRANSFER FROM FRNC. PURSUANT TO THIS TRANSFER IN OCTOBER, 1990, 3579 ENTERED INTO A CONTRACT WITH ROYSTER COMPANY TO MANAGE AND OPERATE THE FACILITY UNDER THE NAME OF NPI.