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APPENDIX A

REPORTING REQUIREMENTS

I. Annual Reporting Requirements

Beginning six (6) months after the Effective Date of this Compliance Agreement, 

and continuing annually on April 30 each year thereafter, TVA shall submit annual 

reports to EPA, the States, and the Citizen Plaintiffs electronically as required by Section 

V.I (Periodic Reporting). EPA, the States, and the Citizen Plaintiffs reserve the right to 

request such information in hard copy. In such annual reports, TVA shall include the 

following information:

A. System-Wide Annual Tonnage Limitations for NOx and SO2

TVA shall report the following information: (1) the total actual annual tons of the 

pollutant emitted from each Unit or, for Units sharing a common stack, the total actual 

annual tons of the pollutant emitted from each combined stack, within the TVA System

and any New CC/CT Units during the prior calendar year; (2) the total actual annual tons 

of the pollutant emitted from the TVA System and any New CC/CT Units during the 

prior calendar year; (3) the difference, if any, between the System-Wide Annual Tonnage 

Limitation for the pollutant in that calendar year and the amount reported in subparagraph 

(2); and (4) for each pollutant, (a) the annual average emission rate, expressed as

lb/mmBTU, for each Unit within the TVA System and any New CC/CT Units in the prior 

calendar year and (b) the annual average emission rate, expressed as lb/mmBTU, for the 

entire TVA System and any New CC/CT Units during the prior calendar year. Data 

submitted pursuant to this subsection shall be based upon CEMS pursuant to Paragraphs

85 and 101. 

If TVA was subject to an adjusted System-Wide Annual Tonnage Limitation

specified in Paragraphs 72 and 87 in the calendar year covered by the annual report, it 

shall report the following: (1) the Units at which the adjusted System-Wide Annual 

Tonnage Limitations in Paragraphs 72 and 87 apply and (2) the adjusted aggregate 

System-Wide Annual Tonnage Limitation. 

B. Continuous Operation of Pollution Control Technology or Combustion 

Controls

TVA shall report the date that it commenced Continuous Operation of each SCR, 

FGD, PM Control Device, SNCR, LNB, OFA, and SOFA that TVA is required to 

Continuously Operate pursuant to this Compliance Agreement in the calendar year 

covered by the annual report.

TVA shall report, for any SCR, FGD, PM Control Device, SNCR, LNB, OFA,

and SOFA that TVA is required to Continuously Operate during the calendar year

covered by the annual report, the duration of any period during which that pollution 
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control technology or combustion control did not Continuously Operate, including the 

specific dates and times that such pollution control technology or combustion control did 

not operate, the reason why TVA did not Continuously Operate such pollution control

technology or combustion control, and the measures taken to reduce emissions of the 

pollutant controlled by such pollution control technology or combustion control.

TVA shall include a statement in each annual report describing the actions it took 

to optimize the PM Control Devices as required by Paragraph 102 in the relevant 

calendar year.

C. Installation of NOx, SO2, and PM Control Devices

TVA shall report on the progress of construction (including upgrades) of SCRs

and FGDs (and new PM Control Devices, if any) required by this Compliance Agreement 

including: (1) if construction is not underway, any available information concerning the 

construction schedule, including the dates of any major contracts executed during the 

prior calendar year, and any major components delivered during the prior calendar year; 

(2) if construction is underway, the estimated percent of installation as of the end of the 

prior calendar year, the current estimated construction completion date, and a brief 

description of completion of significant milestones during the prior calendar year, 

including a narrative description of the current construction status (e.g. foundations 

completed, absorber installation proceeding, all material on-site, new stack erection 

completed, etc.); (3) a list of all permits needed to construct and operate the device, the 

date TVA applied for such permits, and the status of the permit applications; and (4) once 

construction is complete, the dates the equipment was placed in service and any 

performance/emissions testing that was performed during the prior calendar year. For 

purposes of the FGD upgrade at Paradise Units 1 and 2, TVA shall demonstrate, with 

supporting documentation, that the construction activities performed to upgrade the 

FGDs at Paradise Units 1 and 2 were designed to upgrade the FGDs to a 93% removal 

efficiency. 

D. Unit Retirements

Beginning on April 30 of the year following TVA’s obligation pursuant to this 

Compliance Agreement to Retire a TVA System Unit, and continuing annually thereafter 

until all TVA System Units required to be Retired have been Retired, TVA shall report 

the date it Retired such Unit and a description of the actions TVA took to Retire such 

Unit within the meaning of Paragraph 55. 

E. Repower to Renewable Biomass

If TVA elects the Repower to Renewable Biomass option for a TVA System Unit,

in the next annual report following such election, and continuing annually thereafter, 

TVA shall report on the progress of its efforts to Repower such TVA System Unit 

including: (1) if construction is not underway, any available information concerning the 

construction schedule, including the dates of any major contracts executed during the 
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prior calendar year, and any major components delivered during the prior calendar year; 

(2) if construction is underway, the estimated percent of installation as of the end of the 

prior calendar year, the current estimated construction completion date, and a brief 

description of completion of significant milestones during the prior calendar year, 

including a narrative description of the current construction status; (3) a list of all permits 

needed to construct and operate the Repowered Unit, the date TVA applies for such 

permits, and the status of the permit applications; and (4) once construction is complete, 

the dates the Repowered Unit was placed in service and any performance/emissions

testing that was performed during the prior calendar year.

F. PM Emission Control Optimization Study

Beginning on April 30 of the year following TVA’s obligation to implement the 

EPA-approved recommendations required by Paragraph 103, TVA shall include a 

statement describing how it maintained each PM Control Device in accordance with the 

EPA-approved PM emission control optimization study. 

G. Reporting Requirements for NOx and SO2 Allowances

1. Reporting Requirements for NOx and SO2 Surrendered Allowances

TVA shall report the number of NOx and SO2 Allowances that were allocated to it 

under any programs and the number of NOx and SO2 Allowances surrendered pursuant to 

Paragraphs 79 and 95 for the prior calendar year. TVA shall include the mathematical 

basis supporting its calculation of NOx and SO2 Allowances surrendered.

2. Reporting Requirements for NOx and SO2 Super-Compliance 

Allowances

TVA shall report any Super-Compliance NOx or SO2 Allowances that it generated 

as provided in Paragraphs 82 and 98 for the prior calendar year. TVA shall include the 

mathematical basis supporting its calculation of Super-Compliance NOx or SO2

Allowances. TVA shall also specifically identify the amount, if any, of SuperCompliance NOx and SO2 Allowances that TVA generated from Retiring a TVA System 

Unit that TVA did not utilize for purposes of Paragraph 121 (New CC/CT Units).

H. New CC/CT Units

TVA shall report all information necessary to determine compliance with 

Paragraphs 121-123. In particular, TVA shall report whether it has applied for a minor 

NSR permit as described in Subparagraph 121.b and 123.c to construct a New CC/CT 

Unit, and shall confirm that it timely provided a copy of the permit application to EPA, 

the States, and the Citizen Plaintiffs as required by Subparagraph 121.c and Paragraph 

155. TVA shall report the amount of emission reductions of NOx and the amount of 

emission reductions of SO2 resulting from Retiring a TVA System Unit that TVA utilized 

as netting credits as provided in Paragraph 121. TVA shall report the amount of emission 
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reductions of Greenhouse Gases resulting from Retiring a TVA System Unit that TVA 

utilized as netting credits as provided in Paragraph 123. TVA shall describe how the

emissions decreases on which it is relying in order to construct a New CC/CT Unit as 

provided in Paragraph 121 and 123 are both contemporaneous and otherwise creditable 

within the meaning of the Clean Air Act and the applicable SIP. In making these 

demonstrations, TVA shall provide unit-by-unit explanations and calculations. TVA 

shall include a description of the emission limitations determined by the relevant 

permitting authority as described in Subparagraph 121.b, and how such emission 

limitations are consistent with this Compliance Agreement and Appendix B. TVA shall 

provide all relevant information, including an appropriate mathematical calculation, to 

demonstrate that any emission decrease upon which it relied for purposes of Paragraph 

121 was not used to generate a Super-Compliance NOx or SO2 Allowance in the calendar 

year in which TVA relies upon such emission reduction and all calendar years thereafter. 

TVA shall provide all information necessary to determine compliance with the conditions 

established in Paragraphs 123.b-123.c.

I. NOx, SO2, and PM CEMS Malfunction, Repair, or Maintenance

TVA shall report all periods when a CEMS required by this Compliance 

Agreement was not operating, including periods of monitor malfunction, repair, or 

maintenance in the prior calendar year.

J. PM CEMS Data

In an electronic, spreadsheet format, TVA shall submit the data recorded by the 

PM CEMS, expressed in lb/mmBTU, on a three-hour (3-hour) rolling average basis and a 

twenty-four-hour (24-hour) rolling average basis, and shall include identification of each 

3-hour average and 24-hour average above the 0.030 lb/mmBTU PM Emission Rate for 

Bull Run Unit 1, Colbert Unit 5, and Kingston Units 1-9, for the prior calendar year. If 

TVA locates a PM CEMS at another Unit in the TVA System pursuant to Paragraph 114, 

and such Unit is also subject to a PM Emission Rate pursuant to Paragraph 104, TVA 

shall also include identification of each 3-hour average exceededance for such Unit. 

K. SO2 Emission Rate at Shawnee

TVA shall submit all data necessary to determine whether emissions of SO2 from 

Shawnee Units 1-10 exceeded 1.2 lb/mmBTU in the prior calendar year.

L. PM Stack Tests & PM Emission Rates

TVA shall submit the complete report for the stack tests performed pursuant to 

Paragraphs 105 and 106 in the prior calendar year. TVA shall separately identify the 

stack test reports for the TVA System Units subject to a PM Emission Rate under this 

Compliance Agreement. 

M. Environmental Mitigation Projects
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1. State Mitigation Projects 

TVA shall report funds disbursed to the States pursuant to Paragraphs 122-124 

and 126 of the Consent Decree in the prior calendar year. 

2. Appendix C Projects

TVA shall report on the progress of the Mitigation Projects as provided in 

Appendix C.

N. Other Unit at Shawnee Becomes Improved Unit

If TVA decides to make an Other Unit at the Shawnee Plant an Improved Unit, 

TVA shall so state in the next annual report it submits after making such decision, and 

shall comply with the reporting requirements specified in Section I.C of this Appendix 

and any other reporting or notice requirements in accordance with the Compliance 

Agreement.

O. Projects Performed at Improved Units

TVA shall submit a list of all projects performed at an Improved Unit and an 

Other Unit that increase the maximum hourly emission rate of that Unit for NOx or SO2

as described in Paragraphs 142 and 143.a, as measured by 40 C.F.R. §§ 60.14(b) and (h).

P. Capital Projects at Shawnee

TVA shall submit a list of all Capital Expenditures performed on the Boiler 

Islands at each Unit at the Shawnee Plant in order to determine whether TVA has 

exceeded the thresholds established in Paragraph 143.b.

Q. Emission Reductions Greater than those Required Under this Compliance 

Agreement

TVA shall report whether, in the relevant calendar year, it claimed to have 

achieved emission reductions at a particular TVA System Unit that are greater than those 

emission reductions required under this Compliance Agreement for the particular TVA 

System Unit as provided in Paragraph 120. If TVA did not claim to have achieved 

emission reductions at a particular TVA System Unit that are greater than those emission 

reductions required under this Compliance Agreement, it shall so state. If TVA did, for 

any purpose, claim to achieve emission reductions at a particular TVA System Unit that 

are greater than those required under this Compliance Agreement for that particular TVA 

System Unit, TVA shall include a description of how it achieved such emission 

reductions, including a mathematical calculation in support of the claimed emission 

reductions, an explanation of how such emission reductions are greater than those 

required under this Compliance Agreement, and the manner in which such emission 
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reductions were either relied upon or used for purposes of permitting actions, nonpermitting actions, or otherwise.

II. Deviation Reports

TVA shall report all deviations from the requirements of the Compliance

Agreement that occur during the calendar year covered by the annual report, identifying 

the date and time that the deviation occurred, the date and time the deviation was 

corrected, the cause of any corrective actions taken for each deviation, if necessary, and 

the date that the deviation was initially reported under Paragraph 156.

III. Submission Pending Review

In each annual report, TVA shall include a list of all plans or submissions made 

pursuant to this Compliance Agreement during the calendar year covered by the annual 

report and all prior calendar years since the Effective Date of the Compliance Agreement, 

the date(s) such plans or submissions were submitted to EPA for review or approval, and 

shall identify which, if any, are still pending review and approval by EPA upon the date 

of the submission of the annual report. 

IV. Other Information Necessary to Determine Compliance 

To the extent that information not expressly identified herein is necessary to 

determine TVA’s compliance with the requirements of this Compliance Agreement for 

the calendar year covered by the annual report, and such information has not otherwise 

been submitted, TVA shall provide such information as part of the annual report required 

pursuant to Section V.I (Periodic Reporting) of the Compliance Agreement and TVA 

shall provide such other information that is deemed necessary by EPA in consultation 

with the States.

V. Information Previously Submitted under Title V Permitting Requirements

In any periodic progress report submitted pursuant to Section V.I (Periodic 

Reporting) of the Compliance Agreement and this Appendix, TVA may incorporate by 

reference information previously submitted under its Title IV or Title V permitting 

requirements, provided that TVA attaches the Title IV and/or Title V permit report, or the 

relevant portion thereof, and provides a specific reference to the provisions of the Title 

IV and/or Title V permit report that are responsive to the information required in the 

periodic progress report.