ROBERT J. MARTINEAU, JR. 

COMMISSIONER 

September 16, 2015 

STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

NASHVILLE, TENNESSEE 37243-0435 

Heather McTeer Toney, Regional Administrator 

USEPA, Region IV 

61 Forsyth Street, SW 

Mail Code: 9T25 

Atlanta, GA 30303-8960 

RE: Tennessee's Round 2- 2011 Sulfur Dioxide Designations Recommendations 

Dear Ms. McTeer Toney: 

BILL HASLAM 

GOVERNOR 

Tennessee currently has one area in the state identified through monitoring as not meeting the 1 Hr SOz NMQS 

(75 PPB). This area is the Kingsport S02 nonattainment area, a partial county area located in Sullivan County, TN 

designated nonattainment on October 4, 2013. This designation was made based on the 2009 to 2011 

monitored violations of the S02 standards under the "Round 1" designations. 

Tennessee is now required to make "Round 2" designation recommendations based on any new monitored 

violations of the 1 Hr S02 standard and on the areas in the US in which the 68 fossil fuel power plants are located 

subject to the "Consent Decree" in the court order of March 2, 2015. These recommendations are required to 

be made no later than Sept. 18, 2015. 

At this time the only electric power plant source located in Tennessee that is subject to the "Consent Decree" is 

the TVA Gallatin Fossil Plant with SOz emissions in excess of 21,000 TPY for 2012. At this time Tennessee 

believes that TVA Gallatin will submit a modeling demonstration based on future allowable emissions that show 

the facility is meeting the 1 Hr SOz NAAQS and will not elect to conduct air monitoring for SOz in the area near 

this facility. Therefore Tennessee will recommend a "Round 2" designation as follows: 

Area or Source Basis for Recommendation Recommendation 

Vicinity of the TVA Gallatin Attaining modeling Attainment 

Fossil Plant located In demonstration approved (See attached 

Sumner County, TN within a and submitted to EPA on or recommendation graphic) 

50 Km radius of the facility before January 22, 2016. 

In Tennessee and centered 

on the following 

coordinates: 

36.3165 Lat., -86.4033 Lon. 

RE: Tennessee's Round 2 - 2011 Sulfur Dioxide Designations Recommendations 

Page 2 

September 16, 2015 

TVA is also proposing to further reduce the S02 emissions from their combined facility sources in such a manner 

as to insure that the future emissions from this facility do not contribute to a violation of the 1 Hr S02 NAAQS. 

The attainment modeling demonstration will be based on future controls at the Gallatin Fossil Plant. TVA is 

currently in the process of installing flue gas desulfurization (FGD) systems on all four electric generating units at 

the plant. These FGD systems are required to be installed as the result of an enforceable Consent Decree with 

the Tennessee Valley Authority (State of Alabama et. al. v. TVA, Civil Action No. 3:11-cv-00170, filed April 14, 

2011, approved June 30, 2011). These systems will be operational on or before April 16, 2016, in order for the 

facility to comply with 40 CFR 63 Subpart UUUUU (National Emission Standards for Hazardous Air Pollutants: 

Coal- and Oil-Fired Electric Utility Steam Generating Units). The requirement to install and operate the FGD 

systems, along with appropriate enforceable emission limits, will be included in the Gallatin Fossil Plant Title V 

permit on or before April 8, 2016. Attached are an aerial photograph and an artist's rendering showing the 

location of the FGD system. Currently, two FGD systems are on-line and operating, with the two other systems 

projected for start-up in early 2016. 

Tennessee intends to supplement this recommendation with additional information on or before January 22, 

2016. This additional information may include: a test protocol for the dispersion modeling, the modeling 

results, an updated inventory of other sources of sulfur dioxide within the recommended attainment area 

boundary based on the 2014 National Emission Inventory, and analyses of the five factors (air quality/dispersion 

modeling data, emissions-related data, meteorology, geography/topography, and jurisdictional boundaries) as 

identified in EPA's March 20, 2015, memorandum entitled "Updated Guidance for Area Designations for the 

2010 Primary National Ambient Air Quality Standard". Based on this additional data, Tennessee may also revise 

its recommendation for the boundary of the recommended attainment area. 

Tennessee will also provide additional recommendations to EPA based on the requirements in the recently 

promulgated ORR under the "Round 3" and ,,Round 4" designation process timelines as required at the 

appropriate times. 

I believe these recommendations will enable Tennessee to attain the sulfur dioxide standard within the 

deadlines established by the Clean Air Act and its implementation regulations. 

Your favorable review of these revised recommendations will be appreciated. 

Jr. Commissioner 

Enclosures 

Copy w/enclosure: Scott Davis, EPA Region IV 

Carol Kemker, EPA Region IV 

Lynorae Benjamin, EPA Region IV 

TVA_@~(Iatin_FG0-....:Stack• 50 Km Modeling Domain and Attaining 502 Areas (Centered on 36.3165 Lat., -86.4033 Lon.) .... 9 ... 

,.. Mall~ n • ~~ 5.0 1\m Rad1us TVA Gallatin F.GD Stack 

Marshall Bedford 
Gallatin (sh ing FGDs & SCRs