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STATEMENT OF BASIS

Tennessee Valley Authority

Widow’s Creek Fossil Plant

Jackson County

705-0008

This proposed Title V Major Source Operating Permit is issued under the 

provisions of ADEM Admin. Code R. 335-3-16. The above named applicant has 

requested authorization to perform 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 coalfired 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-steady 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 have a maximum heat input capacity of 11,520 million 

Btu per hour. Units 1 through 6 burn low sulfur coal and are each controlled by 

an electrostatic precipitator (ESP) and exhausted to a common 1000-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 fuel, the boiler units combined are permitted to burn up to 100,000 

gallons per 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. One 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 permanent 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 received by railcar, barge, and truck. The 

emissions from these systems are considered fugitive emissions and are controlled 

when necessary by water sprays. The temporary coal barge unloading facility is 

subject to the requirements of 40 CFR 60 Subpart Y because 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.
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Limestone slurry reacts with SO2 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. 335-3-4-.03(1)).

Opacity:

20% (ADEM Admin. Code R. 335-3-4-.01(1)(a)).

Sulfur Dioxide (SO2):

1.6 lb/MMBtu (ADEM Admin. Code R. 335-3-1-.12.)

Units 1, 2, 3, 4, 5, & 6 are allocated SO2 allowances under Phase II of 

the Acid Rain Program (ADEM Admin. Code R. 335-3-18-.01 and 40 

CFR Part 73). Units 1, 2, 3, 4, 5, & 6 shall hold sufficient allowances in 

their unit accounts to cover SO2 emissions.

Boiler Units 1-6, combined with Boiler Units 7 & 8, are permitted 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 requirements and may not be burned 

during startup and shutdown periods.

Nitrogen Oxide (NOx):

Units 1, 2, 3, 4, 5, & 6 participate in a NOx 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 NOx emission rate for the unit in the plans 

shall be less than or equal to the Btu-weighted annual average NOx

emission rate for the same unit 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. 

These units are also subject to the NOx Budget Trading Program 

pursuant to ADEM Admin. Code R. 335-3-8-.05 and will be required to 

hold sufficient allowances to cover their ozone season NOx 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.
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SO2:

Units 1, 2, 3, 4, 5, & 6 are allocated annual SO2 allowances through the 

Acid Rain Program, which requires an SO2 Continuous Emissions 

Monitoring System (CEMS). CEMS data indicates that SO2 emissions 

from the boilers are well below the applicable 1.6 lb/MMBtu standard.

NOx:

Units 1, 2, 3, 4, 5, & 6 are required to monitor NOx with a CEMS. CEMS 

data indicates that NOx emissions from the boilers are below the 

emission limit established in the NOx averaging plan.

Periodic monitoring

Particulate Matter (PM) and Opacity:

The particulate matter emission rate for each unit will be determined 

annually by 40 CFR Part 60, Appendix A, Method 5 or 17. Annual 

particulate matter testing over the last 10 years indicates these units 

operate well within the applicable standard. 

Continuous Opacity Monitoring Systems (COMS) will be used to provide 

an indication of opacity. Summary opacity data will be submitted 

quarterly to ADEM for review. Upon ADEM’s assessment of these data, 

additional stack testing for particulate matter could be required.

The permittee will be required to take corrective measures to reduce 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 performance, the 

expectation of continued comparable performance, annual testing for 

particulate matter, continuous opacity monitoring, and ADEM’s review 

of quarterly opacity data provide reasonable assurance of compliance 

with the particulate matter and opacity standards.

Sulfur Dioxide (SO2):

SO2 emissions will be monitored by the Acid Rain Continuous Emissions 

Monitoring System (CEMS). Data 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 Oxides (NOx):

NOx emissions will be monitored by the Acid Rain Continuous Emissions 

Monitoring System (CEMS). Data will be reported per the provisions of 

40 CFR 75.
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Power Boiler Unit 7

Emission Standards

Particulate Matter (PM):

0.12 lb/MMBtu (ADEM Admin. Code R. 335-3-4-.03(1)).

Opacity:

20% (ADEM Admin. Code R. 335-3-4-.01(1)(a)).

Sulfur Dioxide (SO2):

0.9 lb/MMBtu (ADEM Admin. Code R. 335-3-1-.12).

Unit 7 is allocated SO2 allowances under Phase II of the Acid Rain 

Program (ADEM Admin. Code R. 335-3-18-.01 and 40 CFR Part 73). 

Unit 7 shall hold sufficient allowances in its unit account to cover SO2

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 per year. The oil and solvents burned in these units 

must meet all applicable requirements and may not be burned during 

startup and shutdown periods.

Nitrogen Oxide (NOx):

Unit 7 participates in a NOx 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 NOx emission rate for the unit in the plans shall be less than or 

equal to the Btu-weighted annual average NOx emission rate for the 

same unit 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.

The unit is also subject to the NOx Budget Trading Program pursuant to 

ADEM Admin. Code R. 335-3-8-.05 and will be required to hold 

sufficient allowances to cover the ozone season NOx 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.
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SO2:

Unit 7 is allocated annual SO2 allowances through the Acid Rain 

Program, which requires an SO2 Continuous Emissions Monitoring 

System (CEMS). CEMS data indicates that SO2 emissions from the 

boiler is well below the applicable 0.9 lb/MMBtu standard.

NOx:

Unit 7 is required to monitor NOx with a CEMS. CEMS data indicates 

that NOx emissions from the boiler is below the emission limit 

established in the NOx averaging plan.

Periodic monitoring

Particulate Matter (PM) and Opacity:

The particulate matter emission rate for this unit will be determined 

annually by 40 CFR Part 60, Appendix A, Method 5 or 17. Annual 

particulate matter testing over the last 10 years indicates this unit

operates well within the applicable standard. 

Continuous Opacity Monitoring Systems (COMS) will be used to provide 

an indication of opacity. Summary opacity data will be submitted 

quarterly to ADEM for review. Upon ADEM’s assessment of these data, 

additional stack testing for particulate matter could be required.

The permittee will be required to take corrective measures to reduce 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 performance, the 

expectation of continued comparable performance, annual testing for 

particulate matter, continuous opacity monitoring, and ADEM’s review 

of quarterly opacity data provide reasonable assurance of compliance 

with the particulate matter and opacity standards.

Sulfur Dioxide (SO2):

SO2 emissions will be monitored by the Acid Rain Continuous Emissions 

Monitoring System (CEMS). Data 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 Oxides (NOx):

NOx emissions will be monitored by the Acid Rain Continuous Emissions 

Monitoring System (CEMS). Data will be reported per the provisions of 

40 CFR 75. 
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Power Boiler Unit 8

Emission Standards

Particulate Matter (PM):

0.12 lb/MMBtu (ADEM Admin. Code R. 335-3-4-.03(1)).

Opacity:

20% (ADEM Admin. Code R. 335-3-4-.01(1)(a)).

Sulfur Dioxide (SO2):

0.9 lb/MMBtu (ADEM Admin. Code R. 335-3-1-.12). 

Unit 8 is allocated SO2 allowances under Phase II of the Acid Rain 

Program (ADEM Admin. Code R. 335-3-18-.01 and 40 CFR Part 73). 

Unit 8 shall hold sufficient allowances in their unit accounts to cover 

SO2 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 per year. The oil and solvents burned in these units 

must meet all applicable requirements and may not be burned during 

startup and shutdown periods.

Nitrogen Oxide (NOx):

Unit 8 participates in a NOx 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 NOx emission rate for the units in the plans shall be less than or 

equal to the Btu-weighted annual average NOx 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 NOx Budget Trading Program pursuant to 

ADEM Admin. Code R. 335-3-8-.05 and will be required to hold 

sufficient allowances to cover its ozone season NOx 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.
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SO2:

Unit 8 is allocated annual SO2 allowances through the Acid Rain 

Program, which requires an SO2 Continuous Emissions Monitoring 

System (CEMS). CEMS data indicates that SO2 emissions from the 

boiler is well below the applicable 0.9 lb/MMBtu standard.

NOx:

Unit 8 is required to monitor NOx with a CEMS. CEMS data indicates 

that NOx emissions from the boiler are below the emission limit 

established in the NOx averaging plan.

Periodic monitoring

Particulate Matter (PM) and Opacity:

The particulate matter emission rate for the unit will be determined 

annually by 40 CFR Part 60, Appendix A, Method 5 or 17. Annual 

particulate matter testing over the last 10 years indicates these unit 

operates well within the applicable standard. 

Continuous Opacity Monitoring Systems (COMS) will be used to provide 

Continuous Opacity Monitoring Systems (COMS) will be used to provide 

an indication of opacity. Summary opacity data will be submitted 

quarterly to ADEM for review. Upon ADEM’s assessment of these data, 

additional stack testing for particulate matter could be required. 

The permittee will be required to take corrective measures to reduce 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 performance, the 

expectation of continued comparable performance, annual testing for 

particulate matter, continuous opacity monitoring, and ADEM’s review 

of quarterly opacity data provide reasonable assurance of compliance 

with the particulate matter and opacity standards.

Sulfur Dioxide (SO2):

SO2 emissions will be monitored by the Acid Rain Continuous Emissions 

Monitoring System (CEMS). Data 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 Oxides (NOx):

NOx emissions will be monitored by the Acid Rain Continuous Emissions 

Monitoring System (CEMS). Data will be reported per the provisions of 

40 CFR 75.
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Auxiliary Startup and Heating Boiler for Powerhouse A

Emission Standards

Particulate Matter (PM):

PM limited to that set by:

E = 1.38H-0.44 – ADEM Admin. Code R. 335-3-4-.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. 335-3-4-.01)

Sulfur Dioxide (SO2):

1.8 lb/MMBtu (ADEM Admin. Code R. 335-3-5-.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 equation is 0.49 lb/hr. Visible emissions are not 

expected this unit.

SO2:

Based on emission factors, the SO2 emission rate should be well 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. 

SO2:

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. 
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Auxiliary Startup Boiler for Powerhouse B

Emission Standards

Particulate Matter (PM):

PM limited to that set by:

E = 1.38H-0.44 – ADEM Admin. Code R. 335-3-4-.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. 335-3-4-.01)

Sulfur Dioxide (SO2):

1.8 lb/MMBtu (ADEM Admin. Code R. 335-3-5-.01(1)(a)).

Expected Emissions

Particulate Matter (PM) and Opacity:

Based on emission factors, the PM emission rate should be 

approximately 0.174 lb/hr and the particulate matter emission limit 

based on the above equation is 0.46 lb/hr. Slight visible emissions may 

be noted from the unit while firing fuel oil.

SO2:

Based on emission factors, the SO2 emission rate should be well 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.
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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. 335-3-4-.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. 335-3-4-.01)

Sulfur Dioxide (SO2):

1.8 lb/MMBtu (ADEM Admin. Code R. 335-3-5-.01(1)(a)).

Expected Emissions

Particulate Matter (PM) and Opacity:

Based on emission factors, the PM emission rate should be 

approximately 0.121 lb/hr and the particulate matter emission limit 

based on the above equation is 0.5 lb/hr. Slight visible emissions may 

be noted from the unit while firing fuel oil.

SO2:

Based on emission factors, the SO2 emission rate should be well 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.
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Solid Fuel 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 

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

Temporary Coal Barge Unloading Facility: 5.19 TPY

Coal Bradford Breakers: 12.8 TPY

Coal Storage Yard: 118 TPY

The Temporary Coal Barge Unloading Facility is subject to the 

requirements of the Federal New Source Performance Standards (NSPS) 

40 CFR 60 Subpart Y. 

The particulate emissions from the above processes are fugitive 

emissions and will be controlled as necessary with wet suppression to 

minimize the emissions.

Periodic Monitoring

Inspections will be required quarterly to ensure the proper operation of 

the wet suppression equipment.

Observation will be conducted semiannually in accordance with 40 CFR 

60, Appendix A, Method 22 to ensure compliance with ADEM Admin. 

Code R 335-3-4-.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.
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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 be required quarterly to ensure the proper operation of 

the wet suppression equipment.

Observation will be conducted semiannually in accordance with 40 CFR 

60, Appendix A, Method 22 to ensure compliance with ADEM Admin. 

Code R 335-3-4-.02(2) which prohibits emissions beyond the lot line. 

Gypsum 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 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 be required quarterly to ensure the proper operation of 

the wet suppression equipment.

Observation will be conducted semiannually in accordance with 40 CFR 

60, Appendix A, Method 22 to ensure compliance with ADEM Admin. 

Code R 335-3-4-.02(2) which prohibits emissions beyond the lot line.