# Attachment I

Limited RACT Analysis1 

### Limited RACT/RACM Analysis for Point and Area Sources

40 CFR 51 Subpart Z states that SIPs must include provisions fo r reasonably available control measures (RACM), reasonably available contro l technology (RACT), and reasonable further progress (RFP), as necessary to demonstrate attainme nt. States must demonstrate that they have adopted all reasonably available control measur es (including RACT for stationary sources) necessary to demonstrate attainment as exped itiously as practicable and to meet any RFP requirements. The SIP revision must contain the list of control meas ures considered by the State, and information and analysis sufficient to suppor t the State's judgment that it has adopted all RACM, including RACT. In determining whether sp ecific control measures must be adopted as RACM, States must consider the cumulative imp act of implementing the available measures. Potential measures that are reasonably availabl e considering technical and economic feasibility must be adopted as RACM if, considered collec tively, they would advan ce the attainment date by one year or more.

The PM 2.5 

### Implementation Rule provides additional guidance for the identification of appropriate RACT and RACM. The guidance states that a St ate must consider RACT and RACM for all of its nonattainment areas, but that if the State projects that an ar ea will attain the standard within five years of designation as a result of existi ng national measures, then the State may conduct a limited RACT and RACM analysis that does not involve additional air quality modeling. A limited analysis of this type would involve:

• Review of reasonably available measures;

• Estimation of potential emissions reductions; and

• Evaluation of the time needed to implement these measures.

If the State cannot achieve sign ificant emissions reduc tions during 2008, due to time needed to implement the potential measures or other relevant factors, then the State may conclude that there are no further reasonably available contro l measures that would advance the attainment date by one year or more.

As indicated in Section 6.0 of the PM 2.5 

### SIP, Tennessee determined that there were no suitable RACT options for point and area sources of SO 2 

### and PM 2.5 

### , because the rule changes required prior to any RACT implementation would require more than one year to finalize. However, Tennessee did conduct a limited review of RACT op tions for area and point sources, as indicated below.

SO 2 

### RACT for Point Sources (>100 tons/year SO 2 

### Emissions)

As indicated in Section 4.0 and Table 4- 5 of the PM 2.5 

### SIP, point sources were responsible for 98% of SO 2 

### emissions in the nonattainment area in 2002, and “large” point sources (more than 100 tons/year SO 2 

### ) were responsible for 99.8% of total point source emissions (or 98.1% of all2 

### SO 2 

### emissions within the nonattainment area) 1 

### . Because the overwhelming majority of SO 2 

### in the nonattainment area is emitted from these “larg e” point sources, point sources with less than 100 tons per year of SO 2 

### emissions were eliminated from consideration for RACT analyses 2



### . The following measures were eval uated as potential RACT/RACM:

TVA Kingston : As indicated in Section 10.0 of the PM 2.5 

### SIP, TVA is currently installing wet scrubber controls to reduce SO 2 

### emissions from the Kingston Fossil Plant. While these reductions will occur by 2010, it would not be possibl e to further expedite installation of the wet scrubber. Therefore, this option wa s rejected as potential RACT.

Additional SO 2 

### Reductions from non-EGU Coal-Fired Boilers : Sulfur dioxide emissions from stationary source coal combustion (non-EGU) are summarized in Table 6- 1. Total SO 2 

### emissions from coal-fired boilers (area a nd point sources) were 6.8% of projected 2009 SO 2 

### emissions, and point source emissions were 6.5% of the total. Tabl e 6- 1 indicates that the bulk of non-EGU point source SO 2 

### is emitted from sources in Anderson and Loudon Counties. Tennessee’s permit log was reviewed to determine which Title V sources in these counties include coal-fired boilers (Table 6- 2).

Table 6- 1: Summary of SO 2 

### Emissions from Coal Combustion (non-EGU)

County SO 2 Emissions in Tons Per Year

2002 Area 2009 Area 2002 Point* 2009 Point Anderson 185 186 2,354 2,266 Blount 13 14 0 0 Knox 0 0 677 689 Loudon 4 4 3,262 3,140 Roane** 2 2 0 0 Totals 203 206 6,293 6,096

*2002 emissions are identical in actual and typical inventories

**Adjusted area source emissions for the partial county nona ttainment area: Census Block Group 2 of Tract 307 had a population of 737 in 2000; a total Roane County Population of 51,910 produces an adjustment factor of 1.42% of total county emissions.



### Table 6- 2: Coal-Fired Boilers (non-EGU) in Anderson and Loudon Counties

Company Name Number County Description Total Heat Input (MMBtu/hr) Current SO 2 Emission Limit U.S. Department of Energy (Y-12 Plant) 01-0020 Anderson National Security 1,187 4.0 lb/MMBtu

1 The emission inventory indicates that, although large SO 2 reductions occur from point sources in 2009, point sources w ill continue to be responsible for 99.1% of total SO 2 emissions in the nonattainment area.

2 The breakdown of SO 2 emissions from area sources, mobile sources, and point sources with less than 100 tons/year is as follows (percentage of nonattainment area SO 2 emissions, based on 2002 actual emissions): 0.3% from area sources; 1.3 % from mobile sources; and 0.2% from point sources with less than 100 tons/year of SO 2 emissions.3 Viskase Corporation 53-0003 Loudon Plastic Products 148 (94MMBtu/hr

from Coal Combustion) 189 lb/hr. Sulfur content of the coal must not exceed 1.0% by weight (monthly average)

Tate & Lyle Ingredients Americas, Inc. 53-0081 Loudon Corn and Ethanol 580 NSPS limit of 1.2 lb/MMBtu for each boiler (3-hour average) and 686 lb/hr from each boiler



### U. S. Department of Energy Y-12 Plant : This source is in the process of replacing coal-fired boilers at the Y-12 facility with natural gas-fire d units, and most sulfur dioxide emissions from this facility w ill be eliminated 3 

### . Because this source is in the pr ocess of replacing the coal-fired boilers at the site, no further op tions were considered for RACT.

Viskase : The emission inventory indicates th at this source emitted 257 tons of SO 2 

### in 2002 (0.2% of total nonattainment area emissions in 2002). The facility is requi red to comply with a coal sulfur content of 1.0% a nd to document compliance with this limit by monthly analysis of the coal burned (coal analysis results and SO 2 

### emissions must be reported in the facility’s Title V Semiannual Report). To investigate the use of lower sulfur coal as a potential RACT option would be, the actual su lfur content and SO 2 

### emissions reported by the facility was reviewed to determine if lower sulfur coal was feasible (Tab le 6- 3). This table indicates that actual SO 2 

### emissions could be reduced by 72 tons per year on average if the facility’s coal-burning operation was limited to 0.5% sulfur.

Table 6- 3: Estimated SO 2 

### Reductions at Viskase With 0.5% Sulfur Coal

Month and Year Tons of Coal Burned Coal % Sulfur Content* SO 2 Emissions (tons) SO 2 Emissions at 0.5% Sulfur (tons) Change in SO 2 Emissions (tons) October 2005 1,288 0.728 18.8 12.9 5.9 November 2005 1,540 0.734 22.6 15.4 7.2 December 2005 1,504 0.673 20.2 15.0 5.2 January 2006 1,574 0.758 23.9 15.7 8.1 February 2006 1,538 0.730 22.5 15.4 7.1 March 2006 1,642 0.754 24.8 16.4 8.3 April 2006 1,433 0.705 20.2 14.3 5.9 May 2006 1,242 0.652 16.2 12.4 3.8 June 2006 1,319 0.705 18.6 13.2 5.4 July 2006 1,336 0.718 19.2 13.4 5.8 August 2006 1,333 0.776 20.7 13.3 7.4 September 2006 1,394 0.680 19.0 13.9 5.0 October 2006 1,588 0.575 18.3 15.9 2.4 November 2006 1,595 0.664 21.2 16.0 5.2 December 2006 1,823 0.7 73 28.2 18.2 10.0

3 At a design heat input capacity of 1,187 MMBtu/hr and an SO 2 emissions limit of 4.0 lb/MMBtu, potential emissions from this fuel-burning installation would be 4,748 tons/year. The emission inventory indicates that actual SO 2 emissions from this source were 2,354 tons in 2002. Upon installation and start up of the four natural gas-fired boilers under construction at this facility, the coal-fired boilers will be taken out of service, and SO 2 emissions from the fuel-burning installati on will be limited to 39 tons per year. The construction permit application for thi s source indicates that the project is expected to be complete in 2009. These projected reductions were not included in the Base G2 emissions inventory for 2009 and were not m odeled as part of the attainment demonstration for Knoxville.4 January 2007 1,479 0.678 20.1 14.8 5.3 February 2007 1,510 0.743 22.4 15.1 7.3 March 2007 1,575 0.593 18.7 15.8 2.9 Average 1,484 0.702% 20.9 14.8 6.0 * Average of four weekly samples.



### Table 6- 3 does indicate that some reduction in SO 2 

### emissions is possible if the facility is restricted to a lower sulfur coal. However, when SO 2 

### emissions from this facility are compared to other sources in the nonattainment area, it is apparent that additional reductions from Viskase would be negligible compared to SO 2 

### emissions from other facilities . The relative magnitude of estimated reductions from Viskase are readily obse rvable when the facility’s monthly emissions are compared to the monthly emissions from TVA Bull Run (Table 6- 4). This table compares monthly emissions for the two facilities based on uncontrolled emissions, monthly controlled emissions, and the change in emissions from mont h to month. As indicated in Table 6- 4, the month-to-month increases and de creases in Bull Run’s actual SO 2 

### emissions are higher than the total emissions from Viskase during a comparable month. If we assume 90% control of SO 2 

### emissions from Bull Run, we still find that the change in emissions due to normal variation in operating conditions is typically greater than the total emissions from Viskase. Tennessee expects that similar comparisons to other larg e facilities (e. g., TVA Kingston, Alcoa, Tate & Lyle) would yield a similar result. Thus, use of lower sulfur coal at Viskase is rejected as a RACT option.

Table 6- 4: Emission Compar ison – Viskase and TVA Bull Run

Month and Year TVA Bull Run Viskase

SO 2 Emissions

(tons) Month-toMonth Variation in SO 2 Emissions

(tons) SO 2 Emissions Assuming

90% Control (tons) Month-toMonth Variation in Controlled SO 2 Emissions

(tons) SO 2 Emissions

(tons) Month-toMonth Variation in SO 2 Emissions

(tons) SO 2 Emissions at 0.5% Sulfur (tons) Month-toMonth Variation in SO 2 Emissions at 0.5% Sulfur (tons) Oct-05 3,778 378 19 13 Nov-05 2,738 -1,040 274 -104 23 4 15 3 Dec-05 3,162 424 316 42 20 -2 15 0 Jan-06 2,529 -633 253 -63 24 4 16 1 Feb-06 1,159 -1,370 116 -137 22 -1 15 0 May-06 823 -335 82 -34 16 -6 12 -3 Jun-06 3,117 2,293 312 229 19 2 13 1 Jul-06 2,432 -685 243 -69 19 1 13 0 Aug-06 2,643 212 264 21 21 2 13 0 Sep-06 2,490 -153 249 -15 19 -2 14 1 Oct-06 3,507 1,017 351 102 18 -1 16 2 Nov-06 4,877 1,370 488 137 21 3 16 0 Dec-06 4,408 -469 441 -47 28 7 18 2 Total 37,664 3,766 269 191 Avg. 2,897 53 290 5 21 1 15 0.4 Std Deviation 1,133 1,068 113 107 3 4 2 1 TVA actual SO 2 emissions are based on monitoring data obtai ned from U. S. EPA Clean Air Markets. Viskase SO 2 emissions are based on coal combustion and su lfur content from Title V semiannual reports. March and April 2006 are deleted, since TVA Bull Run did not operate during these months5 

### The only remaining RACT option for the Viskase f acility would be the us e of an add-on control device, such as a wet scrubber. This option wo uld require more than 12 months to complete design, installation, and startup, and is therefore rejected as RACT.

Alcoa : Large point sources at this facility emitted 4,097 tons of su lfur dioxide in 2002. Alcoa submitted an extensive analysis of Best Availa ble Retrofit Technology (B ART) to comply with Regional Haze requirements. The BART analyses fo r this facility indica ted that add-on control devices such as wet scrubbers were feasible fo r some unit operations. However, these options are not suitable as RACT, due to the time required to implement the measures. Use of low sulfur coke was investigated a nd found to be technically feasible, but reduction of the sulfur content below the existing level of 3.0% was rejected due to availability concerns. This option is rejected as RACT for the same reason.

Tate & Lyle : The remaining facility (Tate & Lyle) is subject to an agreed order to reduce emissions (Table 6- 5), and no additional cont rol measures were considered as RACT. Tennessee also notes that boilers at this facility are required to meet an NSPS limit.

Table 6- 5: Tate & Ly le Emissions Reductions

Pollutant Allowable Emissions from Title V Operating Permit (tons/year) Post-Project Allowable Emissions (tons/year) PM/PM 10 466.8 305.2 Sulfur Dioxide 3,881 1,690 Nitrogen Oxides 1,733 932 Carbon Monoxide 450 392 Volatile Organic Compounds 694 335 Agreed order 04-0202 was issued August 10, 20 05, by the Tennessee Air Pollution Control Bo ard to resolve a citizens’ appeal of a construction permit issued for this facility (constructi on permit number 956292P, issued April 16, 2004). The facility is required to compl y with the postproject allowable emissions upon completion of the construction project expanding th e facility’s milling and alcohol finishing capacity. A new construction permit 958558P was issued January 10, 2006, to inco rporate the revised limits, and startup of the expansion projec t occurred in October 2006.



### SO 2 

### Reductions from Knox County Point Sources : Table 6- 6 was provided by the Knox County Department of Air Quality Management and summarizes SO 2 

### RACT options for large point sources in the county. These options were reject ed as potential RACT, because it would not be possible to implement these reductions in 2008.

Table 6- 6: RACT Anal ysis for Knox County SO 2 

### Point Sources

Source Description SO 2 Control Measure Time Required to Implement Estimated Emissions Reduction (tons) Cement Kilns -Preheater/Precalciner KilnCemex Wet Gas Scrubber (90% ctrl) 12 250 Cement Kilns -Preheater/Precalciner KilnCemex Spray Dryer Absorber (90% ctrl) 12 250 ICI Boilers-Coal--Low Sulfur -UT In duct Sorbent Injection (40% ctrl) 12 2806 ICI Boilers-Coal--Low Sulfur -UT Flue Gas Desulfurization ( 90 % ctrl) 12 415 ICI Boilers-Residual Oil Flue Gas Desulfurization 12 unknown



### SO 2 

### RACT for Area Sources

As indicated previously, area sources ar e responsible for only 0.3% of total SO 2 

### emissions within the nonattainment area. B ecause the fraction of SO 2 

### emissions from area sources is negligible compared to emissions from large point sources, this category was eliminated from consideration as potential RACT.

PM 2.5 

### RACT for Point Sources

TVA Bull Run and Kingston : The emission inventory indicates that these two facilities are responsible for 64.7% of point source emi ssions and about 47% of total direct PM 2.5 

### within the nonattainment area. TVA’s Bull Run and Kingston facilities are currently required to meet particulate matter emission limits of 0.105 lb /MMBtu and 0.100 lb/MMBtu, respectively, and both facilities use electrostatic precipitators for particulate matter control. Some additional reduction in direct PM 2.5 

### emissions may occur as the wet sc rubbers currently under construction at these facilities become operational. The only additional control option for direct PM 2.5 

### emissions is a baghouse 4 

### , and replacement of the existing el ectrostatic precipitators with a baghouse would require more than 12 months to complete engineering, construction, and startup. Therefore, additional PM 2.5 

### reductions from these sources are not suitable as RACT options.

Other Point Sources : RACT options for other large point sources in the Knoxvi lle area were not reviewed due to time constraints.

PM 2.5 

### RACT for Area Sources

The 2002 area source emission inve ntory was reviewed to determ ine which source categories were responsible for most area source PM 2.5 

### emissions 5 

### . The largest area source categories are listed by Source Classification Code (SCC) in Table 6- 7. These source categories are responsible for about 83% of all area source PM 2.5 

### emissions in the nonattainment area.

Table 6- 7: PM 2.5 

### Area Source RACT

SCC Description Total Category Emissions (tons) 2294000000 Mobile Sources - Paved Roads - All Paved Roads - Total: Fugitives 597

2610030000 Waste Disposal, Treatment, and Recovery - Open Burning - Residential - Household Waste (use 26-10-000-xxx for Yard 271

4 EPA’s AP-42 emission factors (Section 1.1) indicate that the typi cal control efficiency of a ba ghouse, when used to control p articulate emissions from coal combustion, is about 99.9%. By comparison, the control efficiency of an electrostatic precipitator is typi cally about 99%. These numbers suggest that replacement of the existing particul ate controls at TVA’s two coal-fired facilities with baghouses w ould have only a marginal effect upon direct PM 2.5 emissions from these sources.

5 Since Roane County’s area source emissions (from the nonattainme nt portion) were estimated to be only 13 tons, and since most Roane County area sources are expected to be located outside of the nonattain ment area, this county’s area source emissions were excluded fr om the analysis.7 Wastes)

2104008010 Stationary Source Fuel Combustion - Residential - Wood - Woodstoves: General 191

2311020000 Industrial Processes - Construction: SIC 15 - 17 - Industrial/Commercial/Institutional - Total 176

2325000000 Industrial Processes - Mining and Quarrying: SIC 14 - All Processes - Total 172

2104008002 Stationary Source Fuel Combustion - Residential - Wood - Fireplaces: Insert; non-EPA certified 125

2296000000 Mobile Sources - Unpaved Roads - All Unpaved Roads - Total: Fugitives 121

Total 1,653



### Emissions from paved and unpaved roads are discussed in Section 7.0 of the PM 2.5 

### SIP, and we explain in that section why we believe that emissions from these source categories do not contribute significantly to PM 2.5 

### nonattainment in the Knoxvill e area. Open burning of most wastes is prohibited by Rule 1200-3-4 of th e Tennessee Air Pollution Control Regulations (TAPCR), and the Tennessee Department of E nvironment and Conservation is prohibited by State law from regulating the open burning of cer tain wood wastes. Likewise, burning of wood in residential stoves is exempt from construc tion and operating permit requirements pursuant to TAPCR 1200-3-9-.04. The two remaining sources (industrial/commercial construction and mining/quarrying) are subject to the fugitive dus t regulations of TAP CR 1200-3-8. Adoption of additional control measures for open burning, c onstruction, or mining w ould require regulatory and/or legislative changes that could not be finalized prior to January 1, 2009. Thus, Tennessee concludes that there are no RACT/RACM for PM 2.5 

### area source emissions that would advance the attainment date by one year.

RACT Options for Sources Adjacent to the Nonattainment Area

SO 2 

### and PM 2.5 

### RACT options were not examined for sources located in counties adjacent to the nonattainment area. The ASIP States conducted a limited assessment of the impacts of adjacent point sources upon various nonattainment areas. For Knoxville, the ma ximum impact of an adjacent source upon the nonattainment area’s annual PM 2.5 

### concentration was 0.08 μg/m 3



### .