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### STATEMENT OF BASIS Te nnessee Valley Authority Widow’s Creek Fossil Plant Jackson County 705

- 0008 This proposed Title V Major Source Operating Pe rmit is issued under the provisions of ADEM Admin. Code R. 335

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- 16. The above named applicant has requested authorization to pe rform the work or operate the facility shown on the application and drawings, plans and other documents attached hereto or on file with the Air Division of the Alabama Department of Environmental Management, in accordance with the terms and conditions of this permit. The significant sources of air pollutants at this facility are eight (8) pulverized coal

fired boilers Unit Nos. 1, 2 , 3, 4, 5 , 6, 7, and 8 that normally burn pulverized coal and utilize No.2 fuel oil during startup and non - ste ady states or low loads , as well as, three auxiliary boilers , solid fuel handling, limestone handling, and gypsum handling. Units 1 through 6 each have a maximum heat input capacity of 9,290 million Btu per hour and units 7 and 8 ha ve a maximum heat input capacity of 11,520 million Btu pe r hour. Units 1 through 6 burn low sulfur coal and are each controlled by an electrostatic precipitator (ESP) and exhausted to a common 10 00

- foot stack. Units 7 & 8 burn high sulfur coal , but may occasionally burn low sulfur coal. Unit 7 is controlled by an electrostatic precipitator (ESP), limestone scrubber, and Selective Catalytic Reduction (SCR). Unit 8 is controlled by a limestone scrubber. Coal is the normal fuel for the boiler units. In addition to No.2 fuel oil as a secondary fue l, the boiler units combined are pe rmitted to burn up to 100,000 gallons pe r year of used oil and non - hazardous solvents, as well as, other nonhazardous materials , except during startup and shutdown periods
. Widows Creek has three auxiliary boilers. O ne auxiliary boiler is at Powerhouse A for startup and heating for Units 1 through 6. Powerhouse B associated with Units 7 & 8 has separate auxiliary boilers for startup and heating. The solid fuel handling systems consist of a pe rmanent coal screening and crushing station, a temporary coal barge unloading facility, Bradford breakers, and a coal storage yard. The coal storage yard consists of stockpiles, unloading areas , and conveyor systems. Coal is re ceived by railcar, barge, and truck. The emissions from these systems are considered fugitive emissions and arecontrolled when necessary by water sprays . Thetemporary coal barge unloading facility is subject to the re quirements of 40 CFR 60 Subpart Y be cause it commenced constructed post October 24, 1974. Limestone is delivered by truck. Receiving by railcar is possible, but not currently utilized as a delivery system option. Limestone is transported from delivery to storage silos and on to ball mills . Wet suppression is used to as needed to suppress the fugitive emissions from unpaved haul roads.2

Limestone slurry reacts with SO 2 from Units 7 & 8 to form gypsum. The gypsum is transported to a gypsum settling pond. Uncovered dry material is wetted by a watering truck for suppression of fugitive emissions. 

### Power Boiler Units **1, 2, 3**  **, 4 , 5, & 6**  Emission Standards **Particulate Matter (PM):** 0.12 lb/MMBtu (ADEM Admin. Code R. 335

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- .03(1)). **Opacity:** 20% (ADEM Admin. Code R. 335

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- .01(1)(a)). **Sulfur Diox ide (SO**  **2 ):**  1.6 lb/MMBtu (ADEM Admin. Code R. 335

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. ) Units 1, 2 , 3, 4, 5, & 6 are allocated SO 2 allowances under Phase II of the Acid Rain Program (ADEM Admin. Code R. 335

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- .0 1 and 40 CFR Part 73). Units 1, 2 , 3 , 4, 5, & 6 shall hold sufficient allowances in their unit accounts to cover SO 2 emissions. Boiler Units 1

- 6, combined with Boiler Units 7 & 8, arepermitted to burn used oil, as well as, non- hazardous solvents and materials not to exceed 100,000 gallons per year. The oil and solvents burned in these units must meet all applicable re quirements and may not be burned during startup and shutdown periods. **Nitrogen Ox ide (NO** **x ):**  Units 1, 2, 3 , 4 , 5, & 6 participate in a NO x averaging plan pursuant to 40 CFR Part 76. Each plan is effective for one calendar year for the years 2000, 2001, 2002, 2003 and 2004. Under the plan the actual Btu

-weighted annual average NO x emission rate for the unit in the plans shall beless than or equal to the Btu

-weighted annual average NO x emission rate for the same unit had they each been operated, during the same pe riod of time, in compliance with the applicable emission limitations under 40 CFR 76.5, 76.6, or 76.7. These units arealso subject to the NO x Budget Trading Program pursuant to ADEM Admin. Code R. 335

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- .05 and will bereq uired to hold sufficient allowances to cover their ozone season NO x emissions beginning in 2004
. Expected Emissions **Particulate Matter (PM) and Opacity:** During annual testing, Units 1, 2 , 3 , 4 , 5, & 6 have consistently operated at levels well below the applicable 0.12 lb/MMBtu particulate matter standard and the 20% opacity standard.3 **SO 2**  **:** Units 1, 2 , 3 , 4 , 5, & 6 are allocated annual SO 2 allowances through the Acid Rain Program, which re quires an SO 2 Continuous Emissions Monitoring System (CEMS). C EMS data indicates that SO 2 emissions from the boilers are well below the applicable 1.6 lb/MMBtu standard. **NO x**  **:** Units 1, 2 , 3, 4, 5, & 6 are required to monitor NO x with a CEMS. CEMS data indicates that NO x emissions from the boilers arebelow the emission limit established in the NO x averaging plan. Periodic monitoring **Particulate Matter (PM) and Opacity:** The particulate matter emission rate for each unit will bedetermined annually by 40 CFR Part 60, Appendix A, Method 5 or 17. Annual particulate matter te sting over the last 10 years indicates these units operate well within the applicable standard. Continuous Opacity Monitoring Systems (COMS) will beu sed to provide an indication of opacity. Summary opacity data will besubmitted quarterly to ADEM for review. Upon ADEM’s assessment of these data, additional stack testing for particulate matter could be required. The pe rmittee will be re quired to take corrective me asures to re duce the opacity if the COMS indicates a six

- minute average opacity of greater than 20%. Also, as stated previously, the Department could require additional stack testing based on its review of the quarterly COMS data. These units’ past particulate matter and opacity pe rformance, the expectation of continued comparable pe rformance, annual testing for particulate matter, continuous opacity monitoring, and ADEM’s review of quarterly opacity data provide re asonable assurance of compliance with the particulate matter and opacity standards. **Sulfur Diox ide (SO**  **2 ):**  SO 2 emissions will be monitored by the Acid Rain Continuous Emissions Monitoring System (CEMS). D ata acquisition will be used to compute a rolling 24

- hour emission rate in lb/MMBtu. A summary report will be submitted to ADEM quarterly. **Nitrogen Ox ides (NO** **x ):**  NO x emissions will be monitored by the Acid Rain Continuous Emissions Monitoring System (CEMS). D ata will be reported pe r the provisions of 40 CFR 75.4



### Power Boiler Unit **7** Emission Standards **Particulate Matter (PM):** 0.12 lb/MMBtu (ADEM Admin. Code R. 335

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- .03(1)). **Opaci ty:**  20% (ADEM Admin. Code R. 335

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- .01(1)(a)). **Sulfur Diox ide (SO**  **2 ):**  0.9 lb/MMBtu (ADEM Admin. Code R. 335

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- .12 ). Unit 7 is allocated SO 2 allowances under Phase II of the Acid Rain Program (ADEM Admin. Code R. 335

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- .01 and 40 CFR Part 73). Unit 7 shall hold sufficient allowances in its unit account to cover SO 2 emissions. Boiler Unit 7, combined with Boiler Units 1

- 6 & 8, are permitted to burn used oil, as well as, non - hazardous solvents and materials not to exceed 100,000 gallons pe r year. The oil and solvents burned in these units must meet all applicable re quirements and may not beburned during startup and shutdown periods. **Nitrogen Ox ide (NO** **x ):**  Unit 7 participate s in a NO x averaging plan pursuant to 40 CFR Part 76. Each plan is effective for one calendar year for the years 2000, 2001, 2002, 2003 and 2004. Unde r the plan the actual Btu

-weighted annual average NO x emission rate for the unit in the plans shall beless than or eq ual to the Btu

-weighted annual average NO x emission rate for the same unit had they each been operated, during the same pe riod of time, in compliance with the applicable emission limitations under 40 CFR 76.5, 76.6, or 76.7. The unit is also subject to the NO x Budget Trading Program pursuant to ADEM Admin. Code R. 335

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- .05 and will bereq uired to hold sufficient allowances to cover the ozone season NO x emissions beginning in 2004. Expected Emissions **Particulate Matter (PM) and Opacity:** During annual testing, Unit 7 has consistently operated at levels well below the applicable 0.12 lb/MMBtu particulate matter standard and the 20% opacity standard.5 **SO 2**  **:** Unit 7 is allocated annual SO 2 allowances through the Acid Rain Program, which re quires an SO 2 Continuous Emissions Monitoring System (CEMS). C EMS data indicates that SO 2 emissions from the boiler is well below the applicable 0.9 lb/MMBtu standard. **NO x**  **:** Unit 7 is re quired to monitor NO x with a CEMS. C EMS data indicates that NO x emissions from the boiler is be low the emission limit established in the NO x averaging plan
. Periodic monitoring **Particulate Matter (PM) and Opacity:** The particulate matter emission rate for this unit will bedetermined annually by 40 CFR Part 60, Appendix A, Method 5 or 17. Annual particulate matter testing over the last 10 years indicates this unit operate s well within the applicable standard. Continuous Opacity Monitoring Systems (COMS) will beu sed to provide an indication of opacity. Summary opacity data will besubmitted quarterly to ADEM for review. Upon ADEM’s assessment of these data, additional stack testing for particulate matter could be required. The pe rmittee will be re quired to take corrective me asures to re duce the opacity if the COMS indicates a six

- minute average opacity of greater than 20%. Also, as stated previously, the Department could require additional stack testing based on its review of the quarterly COMS data. This unit’s past particulate matter and opacity pe rformance, the expectation of continued comparable pe rformance, annual testing for particulate matter, continuous opacity monitoring, and ADEM’s review of quarterly opacity data provide re asonable assurance of compliance with the particulate matter and opacity standards.
**Sulfur Diox ide (SO**  **2 ):**  SO 2 emissions will be monitored by the Acid Rain Continuous Emissions Monitoring System (CEMS). D ata acquisition will be used to compute a rolling 24

- hour emission rate in lb/MMBtu. Asummary report will be submitted to ADEM quarterly. **Nitrogen Ox ides (NO** **x ):**  NO x emissions will be monitored by the Acid Rain Continuous Emissions Monitoring System (CEMS). D ata will be reported pe r the provisions of 40 CFR 75.6



### Power Boiler Unit **8** Emission Standards **Particulate Matter (PM):** 0.12 lb/MMBtu (ADEM Admin. Code R. 335

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- .03(1)). **Opacity:** 20% (ADEM Admin. Code R. 335

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- . 01(1)(a)). **Sulfur Diox ide (SO**  **2 ):**  0.9 lb/MMBtu (ADEM Admin. Code R. 335

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- .12). Unit 8 is allocated SO 2 allowances under Phase II of the Acid Rain Program (ADEM Admin. Code R. 335

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- .01 and 40 CFR Part 73). Unit 8 shall hold sufficient allowances in their unit accounts to cover SO 2 emissions. Boiler Unit 8, combined with Boiler Units 1

- 6 & 7, are permitted to burn used oil, as well as, non - hazardous solvents and materials not to exceed 100,000 gallons pe r year. The oil and solvents burned in these units must meet all applicable re quirements and may not beburned during startup and shutdown periods. **Nitrogen Ox ide (NO** **x ):**  Unit 8 participate s in a NO x averaging plan pursuant to 40 CFR Part 76. Each plan is effective for one calendar year for the years 2000, 2001, 2002, 2003 and 2004. Unde r the plan the actual Btu

-weighted annual average NO x emission rate for the units in the plans shall be less than or eq ual to the Btu

-weighted annual average NO x emission rate for the same units had they each been operated, during the same period of time, in compliance with the applicable emission limitations under 40 CFR 76.5, 76.6, or 76.7. Unit 8 is also subject to the NO x Budget Trading Program pursuant to ADEM Admin. Code R. 335

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- .05 and will bereq uired to hold sufficient allowances to cover its ozone season NO x emissions beginning in 2004. Expected Emissions **Particulate Matter (PM) and Opacity:** During annual testing, Unit 8 has consistently operated at levels well below the applicable 0.12 lb/MMBtu particulate matter standard and the 20% opacity standard.7 **SO 2**  **:** Unit 8 is allocated annual SO 2 allowances through the Acid Rain Program, which re quires an SO 2 Continuous Emissions Monitoring System (CEMS). C EMS data indicates that SO 2 emissions from the boiler is well below the applicable 0.9 lb/MMBtu standard. **NO x**  **:** Unit 8 is re quired to monitor NO x with a CEMS. C EMS data indicates that NO x emissions from the boiler are be low the emission limit established in the NO x averaging plan. Periodic monitoring **Particulate Matter (PM) and Opacity:**  The particulate matter emission rate for the unit will be de te rmined annually by 40 CFR Part 60, Appendix A, Method 5 or 17. Annual particulate matter te sting over the last 10 years indicates these unit operates well within the applicable standard. Continuous Opacity Monitoring Systems (COMS) will beu sed to provide Continuous Opacity Monitoring Systems (COMS) will beu sed to provide an indication of opacity. Summary opacity data will besubmitted quarterly to ADEM for review. Upon ADEM’s assessment of these data, additional stack testing for particulate matter could be required. The pe rmittee will be re quired to take corrective me asures to re duce the opacity if the COMS indicates a six

- minute average opacity of greater than 2 0%. Also, as stated previously, the Department could require additional stack testing based on its review of the quarterly COMS data. This unit’s past particulate matter and opacity pe rformance, the expectation of continued comparable pe rformance, annual testing for particulate matter, continuous opacity monitoring, and ADEM’s review of quarterly opacity data provide re asonable assurance of compliance with the particulate matter and opacity standards. **Sulfur Diox ide (SO**  **2 ):**  SO 2 emissions will be monitored by the Acid Rain Continuous Emissions Monitoring System (CEMS). D ata acquisition will be used to compute a rolling 24

- hour emission rate in lb/MMBtu. Asummary report will be submitted to ADEM quarterly. **Nitrogen Ox ides (NO** **x ):**  NO x emissions will be monitore d by the Acid Rain Continuous Emissions Monitoring System (CEMS). D ata will be reported pe r the provisions of 40 CFR 75.8



### Auxiliary Startup and Heating Boiler for Powerhouse A Emission Standards **Particulate Matter (PM):** PM limited to that set by: E = 1.38H

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– ADEM Admin. Code R. 335

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- .03 where: E = emissions in lb/MMBtu heat input

H = Heat input in MMBtu/hr **Opacity:** 20% except one 6

- minute period per hour not to exceed 40% (ADEM Admin. Code R. 335

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- .01)
**Sulfur Diox ide (SO**  **2 ):**  1. 8 lb/MMBtu (ADEM Admin. Code R. 335

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- .01(1)(a)). Expected Emissions **Particulate Matter (PM) and Opacity:** Based on emission factors, the PM emission rate should be approximately 0.15 lb/hr and the particulate matter emission limit based on the above eq uation is 0.49 lb/hr. Visible emissions are not expected this unit
. **SO 2**  **:** Based on emission factors, the SO 2 emission rate should bewell below the 1.8 lb/MMBtu limit. Periodic monitoring **Particulate Matter (PM) and Opacity:** Based on the infrequent use and low expected emissions, no periodic monitoring for particulate or opacity is warranted. **SO 2**  **:** Sulfur content of the fuel oil being fired in the unit will have to be monitored and records of said analyses will be required to be kept.9



### Auxiliary Star**tup Boiler for Powerhouse B**  Emission Standards **Particulate Matter (PM):** PM limited to that set by: E = 1.38H

- 0.44

– ADEM Admin. Code R. 335

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- .03 where: E = emissions in lb/MMBtu heat input

H = Heat input in MMBtu/hr **Opacity:** 20% except one 6

- minute period per hour not to exceed 40% (ADEM Admin. Code R. 335

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- .01)
**Sulfur Diox ide (SO**  **2 ):**  1.8 lb/MMBtu (ADEM Admin. Code R. 335

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- .01(1)(a)).
Expected Emissions **Particulate Matter (PM) and Opacity:** Based on emission factors, the PM emissio n rate should be approximately 0.1 74 lb/hr and the particulate matter emission limit based on the above equation is 0.4 6 lb/hr. Slight visible emissions may be noted from the unit while firing fuel oil.
**SO 2**  **:** Based on emission factors, the SO 2 emission rate should bewell below the 1.8 lb/MMBtu limit.
Periodic monitoring **Particulate Matter (PM) and Opacity:** Based on the infrequent use and low expected emissions, no periodic monitoring for particulate or opacity is warranted.10



### Auxiliary Heating Boiler **for Powerhouse B** Emission Standards **Particulate Matter (PM):** PM limited to that set by: E = 1.38H

- 0.44

– ADEM Admin. Code R. 335

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- .03 where: E = emissions in lb/MMBtu heat input

H = Heat input in MMBtu/hr **Opacity:** 20% except one 6

- minute period per hour not to exceed 40% (ADEM Admin. Code R. 335

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- .01)
**Sulfur Diox ide (SO**  **2 ):**  1.8 lb/MMBtu (ADEM Admin. Code R. 335

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- .01(1)(a)). Expected Emissions **Particulate Matter (PM) and Opacity:** Based on emission factors, the PM emission rate s hould be approximately 0.121 lb/hr and the particulate matter emission limit based on the above eq uation is 0.5 lb/hr. Slight visible emissions may be noted from the unit while firing fuel oil. **SO 2**  **:** Based on emission factors, the SO 2 emission rate should bewell below the 1.8 lb/MMBtu limit. Periodic monitoring **Particulate Matter (PM) and Opacity:** Based on the infrequent use and low expected emissions, no periodic monitoring for particulate or opacity is warranted.11



### Solid Fuel Handling System**s** Emission Standards There are no emissions standards associated with these systems. The particulate matter emitted from the units associated with these systems is discharged as fugitive emissions. When necessary, wet suppression will be utilized in association with the operations associated with the solid fuel handling systems to minimize particulate matter emissions. Expected Emissions Based on the calculations presented in the application, the potential expected PM emissions are as follows: Permanent Coal Screening and Crushing Station: 7.14 TPY Te mporary Coal Barge Unloading Facility: 5.19 TPY Coal Bradford Breakers: 12.8 TPY Coal Storage Yard: 118 TPY The Te mporary Coal Barge Unloading Facility is subject to the requirements of the Fe de ral New Source Performance Standards (NSPS) 40 CFR 60 Subpart Y. The particulate emissions from the above processes aref ugitive emissions and will be controlled as necessary with wet suppression to minimize the emissions. Periodic Monitoring Inspections will berequired quarterly to ensure the proper operation of the wet suppression equipment. Observation will beconducted semiannually in accordance with 40 CFR 60, Appendix A, Method 22 to ensure compliance with ADEM Admin. Code R 335

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- .02(2) which prohibits emissions beyond the lot line. 

### Limestone Handling Systems Emission Standards There are no emissions standards associated with these systems. The particulate matter emitted from the units associated with these systems is discharged as fugitive emissions. When necessary, wet suppression will be utilized in association with the operation of the limestone handling systems to minimize particulate matter emissions.12 Expected Emissions Based on the calculations presented in the application, the potential expected PM emissions were estimated at approximately 125 lb/hr before wet suppression control
. Periodic Monitoring Inspections will berequired quarterly to ensure the proper operation of the wet suppression equipment. Observation will beconducte d semiannually in accordance with 40 CFR 60, Appendix A, Method 22 to ensure compliance with ADEM Admin. Code R 335

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- .02(2) which prohibits emissions beyond the lot line. 

### Gypsum Handling Systems Emission Standards There are no emissions standards ass ociated with these systems. The particulate matter emitted from the units associated with these systems is discharged as fugitive emissions. When necessary, wet suppression will be utilized in association with the operation of the gypsum handling systems to minimize particulate matter emissions. Expected Emissions Based on the calculations presented in the application, the potential expected PM emissions were estimated at approximately 44.3 lb/hr before wet suppression control. Periodic Monitoring Inspections will berequired quarterly to ensure the proper operation of the wet suppression equipment. Observation will beconducted semiannually in accordance with 40 CFR 60, Appendix A, Method 22 to ensure compliance with ADEM Admin. Code R 335

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- .02(2) which prohibits emissions beyond the lot line.