1 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 12 1 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 se t forth herein, n othing 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 Par agraph 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 permitt ing authority will determine BACT and LAER, as appropriate, for NO x , SO 2 , VOC, PM, PM 10 , and PM 2.5 for all periods of operation, including startup, shutdown, combustion tuning, and fuel switching as part of the minor NSR permitting action described in Para graph 121 . The emission limitations only for NO x 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 tec hnologies, 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 startup s and shutdo wn s , 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 eve nt, 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 NO x and VOC emission limitations describe d in this Appendix do not apply shall be for oil

- to

- gas switching not to ex ceed 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 Natu ral Gas as the primary fuel, whic h 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 alt ernate fuel, provided that the use of such fuel is limited to no more than five hundred ( 500 )2 hours during any calendar year or one hundred ( 100 ) hours during any calendar year, as specified in the Tables below. Units subject to a n ULSD Fuel Oil operation al 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 pu rposes 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 p lant at such New CC/CT Units, wh ich is the same biogas that TVA co

fires 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 PM 10 or condensable PM 2.5 . The permit ting 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 PM 10 and filterable and condensable PM 2.5

, as part of the p ermitting process required pursuant to Paragraph 121 of the Compliance Agreement.

The NO x 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 f orth 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 o f 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 per mitting 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 U nits 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 imp ose a condition that limits the New CC Units to firing no more than 500 hours of ULSD Fuel Oil in a calendar year.3 Table A.1

– Emission Limitations for Natural Gas

- fired operation

Pollutant Emission Rate Averaging Period Periods of Operation Subject to

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 2.0 parts per million (ppm) at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 1 Gr S/100 SCF 12

- month rolling
average All periods of operation are subje ct to the emission limitation set forth in this Table (hereinafter referred to as

“ NA”) Filterable PM 2.5 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% O 2 without duct firing

2.0 ppm at 15% O 2 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 hou rs during any calendar year)

Pollutant Emission Rate Averaging Period Periods of Operation Subject to

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 8.0 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 15 ppm S NA NA Filterable PM 2.5 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% O 2 Average of three 1

- hour runs from stack test in accordance with reference method Startup, shutdown, combustion tuning, fuel switching4 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 Fue l 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 N ew 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

a n Alternate BACT/LAER Emission L imitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 9.0 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 1 Gr S/100 SCF 12

- month rolling
average NA

Filterable PM 2.5 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% O 2 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

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 42 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 15 ppm S NA NA Filterable 0.015 lb/mmBTU Average of three 1

- NA5 Pollutant Emission Rate Averaging Period Periods of Operation Subject to

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process PM 2.5 hour runs from stack test in accordance with reference method VOC 5.0 ppm at 15% O 2 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 limi tations 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 rollin g 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 F uel 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 NO x emission rate of no greater than 6.0 ppm at 15% O 2 over an eight

- hour ( 8

- hour ) rolling average rather than 42 ppm at 15% O 2 over an 8

- hour rolling average as specified in Table C.2 below , then the 500 hour

c alendar 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 Aver aging Period Periods of Operation Subject to

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 5.0 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 1 Gr S/100 SCF 12

- month rolling
average NA6 Pollutant Emission Rate Aver aging Period Periods of Operation Subject to

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process Filterable PM 2.5 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% O 2 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

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 42 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 15 ppm S NA NA Filterable PM 2.5 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% O 2 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 Natur al 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 t o 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 Un its for purposes of Testing or during periods of Natural Gas Curtailment only. If the permitting authority, as part7 of the minor NSR permitting act ion 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 NO x emission rate of no greater than 6.0 ppm at 15% O 2 over an 8

- hour rolling average rather than 42 ppm at 15% O 2 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

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he P ermitting Process NO x 5.0 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 1 Gr S/100 SCF 12

- month rolling
average NA

Filterable PM 2.5 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% O 2 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

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process NO x 42 ppm at 15% O 2 8

- hour rolling average Startup, shutdown, combustion tuning, fuel switching SO 2 15 ppm S NA NA Filterable PM 2.5 0.015 lb/mmBTU Average of three 1

- hour runs from stack test in accordance with reference method NA8 Pollutant Emission Rate Averaging Period Periods of Operation Subject to

a n Alternate BACT/LAER Emission Limitation to Be Established by t he Permitting Authority as Part of t he Permitting Process VOC 4.0 ppm at 15% O 2 Average of three 1

- hour runs from stack test in accordance with reference method Startup, shutdown, combustion tuning, fuel switching