ROBERTJ. MARTINEAU, JR. COMMISSIONER September 

### 16, 2015 STATE 

### OFTENNESSEE DEPARTMENT OF ENVIRONMENTAND CONSERVATION NASHVILLE, TENNESSEE 37243-0435

Heather McTeerToney, 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. McTeerToney: BILL HASLAM GOVERNOR

Tennessee currently has one area in the state identified through monitoringas not meetingthe 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 ofthe S02 standards underthe "Round 1" designations.
Tennessee is now required to make "Round 

### 2" designation recommendations based on any new monitored violations ofthe 1 HrS02 standard and on theareas in the US in which the 

### 68fossil 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 laterthan 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 thatTVA Gallatin will submit a modeling demonstration based on future allowable emissions that show the facility is meetingthe 1 Hr 

### SOz NAAQS and will not elect to conduct air monitoring for

### SOz in the area near this facility. ThereforeTennessee will recommend a "Round 

### 2" designation as follows:

Area orSource Basis for Recommendation Recommendation VicinityoftheTVA Gallatin Attaining modeling Attainment Fossil Plant located In demonstrationapproved (See attached SumnerCounty,TN within a and submittedto EPA on or recommendationgraphic) 50 Km radius ofthefacility beforeJanuary 22, 2016. In Tennessee andcentered onthefollowing

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 proposingto further reduce the S02 emissions from their combined facility sources in such a manner as to insurethatthe future emissionsfrom this facilitydo notcontributeto aviolation ofthe 1 HrS02 NAAQS

. The attainment modeling demonstration will be based on future controls at the Gallatin Fossil Plant. TVA is currently in the process ofinstallingflue gas desulfurization (FGD) systems on all fourelectricgenerating 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 orderforthe 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 ofthe FGD system

. Currently, two FGD systems are on-line and operating, with the two other systems projected forstart-up in early2016. 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 ofthe 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 forthe boundary ofthe recommended attainmentarea. 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 appropriatetimes. I believe these recommendations will enable Tennessee to attain the sulfur dioxide standard within the deadlines established bythe Clean AirAct and its implementation regulations. Your favorable review ofthese revised recommendations will be appreciated.



# Jr**.** Commissioner Enclosures Copyw/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 ...

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