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APPENDIX B

EMISSION LIMITATIONS FOR NEW CC/CT UNITS

This Appendix B sets forth emission limitations for certain regulated NSR pollutants for the 

purpose of constructing New CC/CT Units pursuant to Paragraph 121 of the Compliance 

Agreement. The emission limitations set forth in this Appendix serve solely as the minimum 

stringency for emission limitations to be determined by the relevant permitting authority for such 

New CC/CT Units as described in Paragraph 121, and shall not be presumed to be BACT or 

LAER. Although the permitting authority as part of the permitting action described in Paragraph 

121 of the Compliance Agreement shall not determine BACT or LAER to be less stringent than 

the emission limitations set forth herein, nothing in the Compliance Agreement or this Appendix 

shall prevent the permitting authority from establishing more stringent emission limitations than 

those set forth in this Appendix. For purposes of the permitting action described in Paragraph 

121 of the Compliance Agreement, TVA shall not assert that the Compliance Agreement 

(including this Appendix) supports imposing a BACT or LAER emission limitation that is no 

more stringent than the emission limitations set forth herein.

The permitting authority will determine BACT and LAER, as appropriate, for NOx, SO2, VOC, 

PM, PM10, and PM2.5 for all periods of operation, including startup, shutdown, combustion 

tuning, and fuel switching as part of the minor NSR permitting action described in Paragraph 

121. The emission limitations only for NOx and VOC described in this Appendix do not apply 

during startup, shutdown, combustion tuning, and fuel switching. For purposes of startup and 

shutdown, the permitting authority will consider appropriate technologies, methodologies, and 

other practices to reduce or minimize emissions during such events (such as the use of an 

auxiliary boiler to preheat the catalyst, the use of Rapid Start Process, and by limiting the number 

and duration of startups and shutdowns, among other things) as part of the BACT/LAER 

analysis. In addition to any other limitations determined by the permitting authority, combustion 

tuning shall be limited to no more than four (4) hours per event and the total event hours in a 

calendar year shall not exceed twenty (20) hours. The permitting authority shall require TVA to 

include advance notice of the details of such combustion tuning event and the proposed tuning 

schedule. An event, for purposes of the 4-hour event limit, shall begin to run when TVA first 

commences the combustion tuning process at a unit and shall conclude once TVA has completed 

all tuning-related activities and returns the unit to normal operation. For purposes of this 

Appendix, and in addition to any other limitations determined by the permitting authority, the 

type of fuel switching for which the NOx and VOC emission limitations described in this 

Appendix do not apply shall be for oil-to-gas switching not to exceed thirty (30) minutes per 

each oil-to-gas fuel switch and gas-to-oil switching not to exceed fifteen (15) minutes per each 

gas-to-oil fuel switch.

The New CC/CT Units constructed pursuant to Paragraph 121 of the Compliance Agreement 

shall combust Natural Gas as the primary fuel, which shall contain no more than one (1) grain 

sulfur per one hundred (100) standard cubic feet (“Gr S/100 SCF”). Ultra-Low Sulfur Diesel 

(“ULSD”) Fuel Oil containing no more than 0.0015% sulfur by weight may be used as an 

alternate fuel, provided that the use of such fuel is limited to no more than five hundred (500)
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hours during any calendar year or one hundred (100) hours during any calendar year, as specified 

in the Tables below. Units subject to an ULSD Fuel Oil operational limitation of 100 hours 

during any calendar year shall only combust ULSD Fuel Oil for either Testing or during periods 

of Natural Gas Curtailment. For purposes of this Appendix, the term “Testing” shall mean the 

infrequent start-up of a unit not for purposes of generating electricity but to ensure that the unit is 

physically capable of operating. For purposes of this Appendix, the term “Natural Gas 

Curtailment” shall mean a restriction or limitation imposed by a third-party beyond TVA’s 

control on TVA’s ability to obtain or use Natural Gas. If TVA Retires one or more of the Units 

at the Allen Fossil Plant identified in Paragraph 67 of the Compliance Agreement and seeks to 

construct a New CC/CT Unit co-located at the Allen Fossil Plant pursuant to Paragraph 121 of 

the Compliance Agreement, then, in addition to Natural Gas and ULSD Fuel Oil, TVA may also 

request that the permitting authority authorize it to co-fire biogas from the Memphis Public 

Works waste treatment plant at such New CC/CT Units, which is the same biogas that TVA cofires at the Allen Fossil Plant as of the Effective Date of this Compliance Agreement. 

The Tables in this Appendix do not contain emission limitations for filterable or condensable 

PM10 or condensable PM2.5. The permitting authority will determine BACT and LAER, as 

appropriate, for all fractions of PM that are regulated NSR pollutants as of the time of the 

permitting action, including filterable and condensable PM10 and filterable and condensable 

PM2.5, as part of the permitting process required pursuant to Paragraph 121 of the Compliance 

Agreement.

The NOx emission limitations in Sections B, C, and D do not require the installation of selective 

catalytic reduction (SCR) technology. However, the Parties recognize that SCR is technically 

feasible for CT units.

Tables A.1 and A.2 set forth the minimum stringency emission limitations for New CC Units. 

Tables B.1, B.2, C.1, C.2, D.1, and D.2 set forth the minimum stringency emission limitations 

for New CT Units. As set forth in Tables B.1 and C.1, New CT Units located in an attainment 

area shall either be subject to an overall hours of operation limitation of no more than thirteen 

hundred (1,300) hours in a rolling twelve-month (12-month) period or have no overall hours of 

operation limitation. As set forth in Tables A.2, B.2, C.2, and D.2, all New CC/CT Units 

(whether in attainment or nonattainment areas) will have a limitation on the use of ULSD. 

A. Emission Limitations for New CC Units

As part of the minor NSR permitting action described in Paragraph 121 of the Compliance 

Agreement, the permitting authority shall establish emission limitations that are no less stringent 

than those set forth in Table A.1 for New CC Units firing Natural Gas and Table A.2 for New 

CC Units firing ULSD Fuel Oil. Additionally, as part of the minor NSR permitting action 

described in Paragraph 121 of the Compliance Agreement, the permitting authority shall impose 

a condition that limits the New CC Units to firing no more than 500 hours of ULSD Fuel Oil in a 

calendar year.
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Table A.1 – Emission Limitations for Natural Gas-fired operation

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 2.0 parts per million 

(ppm) at 15% O2

8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 1 Gr S/100 SCF 12-month rolling 

average

All periods of operation are 

subject to the emission 

limitation set forth in this Table 

(hereinafter referred to as 

“NA”)

Filterable 

PM2.5

0.005 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA

VOC 1.5 ppm at 15% O2

without duct firing 

2.0 ppm at 15% O2

with duct firing

Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching

Table A.2 – Emission Limitations for ULSD Fuel Oil-fired operation (not to exceed 500 hours 

during any calendar year)

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 8.0 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 15 ppm S NA NA

Filterable 

PM2.5

0.015 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA

VOC 4.0 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching
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B. Emission Limitations for New CT Units Located in Attainment Areas Subject to an

Operational Limitation of 1,300 Hours in a 12-Month Period

As part of the minor NSR permitting action described in Paragraph 121 of the Compliance 

Agreement, the permitting authority shall establish emission limitations that are no less stringent 

than those set forth in: (i) Table B.1 for New CT Units firing Natural Gas if they are located in 

an attainment area and are subject to an overall hours of operation limitation of no more than 

1,300 hours in a rolling 12-month period and (ii) Table B.2 for New CT Units firing ULSD Fuel 

Oil if they are located in an attainment area and are subject to an overall hours of operation 

limitation of no more than 1,300 hours in a rolling 12-month period, and which must be subject 

to an operational limitation for ULSD Fuel Oil that limits the New CT Units to firing no more 

than 500 hours of ULSD Fuel Oil in a calendar year. 

Table B.1 – Emission Limitations for Natural Gas-fired Operation

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 9.0 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 1 Gr S/100 SCF 12-month rolling 

average

NA

Filterable 

PM2.5

0.005 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA

VOC 3.0 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching

Table B.2 – Emission Limitations for ULSD Fuel Oil-fired Operation (not to exceed 500 hours 

during any calendar year)

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 42 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 15 ppm S NA NA

Filterable 0.015 lb/mmBTU Average of three 1- NA
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Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

PM2.5 hour runs from stack 

test in accordance with 

reference method

VOC 5.0 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching

C. Emission Limitations for New CT Units Located in Attainment Areas with No Hours of

Operation Limit 

As part of the minor NSR permitting action described in Paragraph 121 of the Compliance 

Agreement, the permitting authority shall establish emission limitations that are no less stringent 

than those set forth in: (i) Table C.1 for New CT Units firing Natural Gas if they are located in 

an attainment area and are not subject to an overall hours of operation limitation of no more than 

1,300 hours in a rolling 12-month period and (ii) Table C.2 for New CT Units firing ULSD Fuel 

Oil if they are located in an attainment area and are not subject to an overall hours of operation 

limitation of no more than 1,300 hours in a rolling 12-month period, and which must be subject 

to an operational limitation for ULSD Fuel Oil that limits the New CT Units to firing no more 

than 100 hours of ULSD Fuel Oil in a calendar year, and further limiting the use of ULSD Fuel 

Oil at such New CT Units for purposes of Testing or during periods of Natural Gas Curtailment

only. If the permitting authority, as part of the minor NSR permitting action for a New CT Unit

firing ULSD Fuel Oil to be located in an attainment area with no overall hours of operation 

limitation, requires TVA to install and operate an SCR and achieve a NOx emission rate of no 

greater than 6.0 ppm at 15% O2 over an eight-hour (8-hour) rolling average rather than 42 ppm at 

15% O2 over an 8-hour rolling average as specified in Table C.2 below, then the 500 hour 

calendar year operational limitation described in Section B shall apply instead of the 100 hour 

calendar year operational limitation specified in this Section C.

Table C.1 – Emission Limitations for Natural Gas-fired Operation

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 5.0 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 1 Gr S/100 SCF 12-month rolling 

average

NA
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Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

Filterable 

PM2.5

0.005 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA

VOC 1.5 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching

Table C.2 – Emission Limitations for ULSD Fuel Oil-fired Operation (not to exceed 100 hours 

during any calendar year, and only for either Testing or Natural Gas Curtailment)

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 42 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 15 ppm S NA NA

Filterable 

PM2.5

0.015 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA

VOC 4.0 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching

D. Emission Limitations for New CT Units Located In Nonattainment Areas With or

Without an Hours of Operation Limit

As part of the minor NSR permitting action described in Paragraph 121 of the Compliance 

Agreement, the permitting authority shall establish emission limitations that are no less stringent 

than those set forth in: (i) Table D.1 for New CT Units firing Natural Gas if they are located in a 

nonattainment area and (ii) Table D.2 for New CT Units firing ULSD Fuel Oil if they are located 

in a nonattainment area and which must be subject to an operational limitation for ULSD Fuel 

Oil that limits the New CT Units to firing no more than 100 hours of ULSD Fuel Oil in a 

calendar year, and further limiting the use of ULSD Fuel Oil at such New CT Units for purposes 

of Testing or during periods of Natural Gas Curtailment only. If the permitting authority, as part 
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of the minor NSR permitting action for a New CT Unit firing ULSD Fuel Oil to be located in a 

nonattainment area, requires TVA to install and operate an SCR and achieve a NOx emission rate 

of no greater than 6.0 ppm at 15% O2 over an 8-hour rolling average rather than 42 ppm at 15% 

O2 over an 8-hour rolling average as specified in Table D.2 below, then the 500 hour calendar 

year operational limitation described in Section B shall apply instead of the 100 hour calendar 

year operational limitation specified in this Section D.

Table D.1 – Emission Limitations for Natural Gas-fired Operation

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 5.0 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 1 Gr S/100 SCF 12-month rolling 

average

NA

Filterable 

PM2.5

0.005 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA

VOC 1.5 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching

Table D.2 – Emission Limitations for ULSD Fuel Oil-fired Operation (not to exceed 100 hours 

during any calendar year, and only for either Testing or Natural Gas Curtailment)

Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

NOx 42 ppm at 15% O2 8-hour rolling average Startup, shutdown, combustion 

tuning, fuel switching

SO2 15 ppm S NA NA

Filterable 

PM2.5

0.015 lb/mmBTU Average of three 1-

hour runs from stack 

test in accordance with 

reference method

NA
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Pollutant Emission Rate Averaging Period Periods of Operation Subject to 

an Alternate BACT/LAER 

Emission Limitation to Be 

Established by the Permitting 

Authority as Part of the 

Permitting Process

VOC 4.0 ppm at 15% O2 Average of three 1-

hour runs from stack 

test in accordance with 

reference method

Startup, shutdown, combustion 

tuning, fuel switching