Attachment I 

Limited RACT Analysis 
1 

Limited RACT/RACM Analysis for Point and Area Sources 

40 CFR 51 Subpart Z states that SIPs must include provisions for reasonably available control 

measures (RACM), reasonably available control technology (RACT), and reasonable further 

progress (RFP), as necessary to demonstrate attainment. States must demonstrate that they have 

adopted all reasonably available control measures (including RACT for stationary sources) 

necessary to demonstrate attainment as expeditiously as practicable and to meet any RFP 

requirements. The SIP revision must contain the list of control measures considered by the State, 

and information and analysis sufficient to support the State's judgment that it has adopted all 

RACM, including RACT. In determining whether specific control measures must be adopted as 

RACM, States must consider the cumulative impact of implementing the available measures. 

Potential measures that are reasonably available considering technical and economic feasibility 

must be adopted as RACM if, considered collectively, they would advance the attainment date 

by one year or more. 

The PM2.5 Implementation Rule provides additional guidance for the identification of appropriate 

RACT and RACM. The guidance states that a State must consider RACT and RACM for all of 

its nonattainment areas, but that if the State projects that an area will attain the standard within 

five years of designation as a result of existing 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 significant emissions reductions 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 control measures that would advance the attainment 

date by one year or more. 

As indicated in Section 6.0 of the PM2.5 SIP, Tennessee determined that there were no suitable 

RACT options for point and area sources of SO2 and PM2.5, 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 options for area and point sources, as indicated 

below. 

SO2 RACT for Point Sources (>100 tons/year SO2 Emissions)

As indicated in Section 4.0 and Table 4- 5 of the PM2.5 SIP, point sources were responsible for 

98% of SO2 emissions in the nonattainment area in 2002, and “large” point sources (more than 

100 tons/year SO2) were responsible for 99.8% of total point source emissions (or 98.1% of all 
2 

SO2 emissions within the nonattainment area)1. Because the overwhelming majority of SO2 in 

the nonattainment area is emitted from these “large” point sources, point sources with less than 

100 tons per year of SO2 emissions were eliminated from consideration for RACT analyses2

. 

The following measures were evaluated as potential RACT/RACM: 

TVA Kingston: As indicated in Section 10.0 of the PM2.5 SIP, TVA is currently installing wet 

scrubber controls to reduce SO2 emissions from the Kingston Fossil Plant. While these 

reductions will occur by 2010, it would not be possible to further expedite installation of the wet 

scrubber. Therefore, this option was rejected as potential RACT. 

Additional SO2 Reductions from non-EGU Coal-Fired Boilers: Sulfur dioxide emissions from 

stationary source coal combustion (non-EGU) are summarized in Table 6- 1. Total SO2

emissions from coal-fired boilers (area and point sources) were 6.8% of projected 2009 SO2

emissions, and point source emissions were 6.5% of the total. Table 6- 1 indicates that the bulk 

of non-EGU point source SO2 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 SO2 Emissions from Coal Combustion (non-EGU) 

County 

SO2 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 nonattainment 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 SO2 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 SO2 reductions occur from point sources in 2009, point sources will continue to be 

responsible for 99.1% of total SO2 emissions in the nonattainment area. 

2 The breakdown of SO2 emissions from area sources, mobile sources, and point sources with less than 100 tons/year is as follows (percentage of 

nonattainment area SO2 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 SO2 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-fired units, and most sulfur dioxide emissions from 

this facility will be eliminated3. Because this source is in the process of replacing the coal-fired 

boilers at the site, no further options were considered for RACT. 

Viskase: The emission inventory indicates that this source emitted 257 tons of SO2 in 2002 

(0.2% of total nonattainment area emissions in 2002). The facility is required to comply with a 

coal sulfur content of 1.0% and to document compliance with this limit by monthly analysis of 

the coal burned (coal analysis results and SO2 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 sulfur content and SO2 emissions reported by the facility was reviewed to 

determine if lower sulfur coal was feasible (Table 6- 3). This table indicates that actual SO2

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 SO2 Reductions at Viskase With 0.5% Sulfur Coal 

Month and Year Tons of Coal 

Burned 

Coal % Sulfur 

Content* 

SO2 Emissions 

(tons) 

SO2 Emissions 

at 0.5% 

Sulfur (tons) 

Change in 

SO2 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 0.773 28.2 18.2 10.0 

 

3 At a design heat input capacity of 1,187 MMBtu/hr and an SO2 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 SO2 emissions from this source were 2,354 tons in 2002. 

Upon installation and startup of the four natural gas-fired boilers under construction at this facility, the coal-fired boilers will be taken out of 

service, and SO2 emissions from the fuel-burning installation will be limited to 39 tons per year. The construction permit application for this 

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 modeled 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 SO2 emissions is possible if the facility is 

restricted to a lower sulfur coal. However, when SO2 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 SO2 emissions from other facilities. The relative magnitude of 

estimated reductions from Viskase are readily observable 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 month to month. As indicated in Table 6- 4, the 

month-to-month increases and decreases in Bull Run’s actual SO2 emissions are higher than the 

total emissions from Viskase during a comparable month. If we assume 90% control of SO2

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 large 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 Comparison – Viskase and TVA Bull Run 

Month 

and Year

TVA Bull Run Viskase 

SO2

Emissions 

(tons) 

Month-toMonth 

Variation in 

SO2

Emissions 

(tons) 

SO2

Emissions 

Assuming 

90% 

Control 

(tons) 

Month-toMonth 

Variation in 

Controlled 

SO2

Emissions 

(tons) 

SO2

Emissions 

(tons) 

Month-toMonth 

Variation in 

SO2

Emissions 

(tons) 

SO2

Emissions 

at 0.5% 

Sulfur 

(tons) 

Month-toMonth 

Variation in 

SO2

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 SO2 emissions are based on monitoring data obtained from U. S. EPA Clean Air Markets. 

Viskase SO2 emissions are based on coal combustion and sulfur content from Title V semiannual reports. 

March and April 2006 are deleted, since TVA Bull Run did not operate during these months 
5 

The only remaining RACT option for the Viskase facility would be the use of an add-on control 

device, such as a wet scrubber. This option would 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 sulfur dioxide in 2002. Alcoa 

submitted an extensive analysis of Best Available Retrofit Technology (BART) to comply with 

Regional Haze requirements. The BART analyses for this facility indicated that add-on control 

devices such as wet scrubbers were feasible for 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 and 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 control measures were considered as RACT. 

Tennessee also notes that boilers at this facility are required to meet an NSPS limit. 

Table 6- 5: Tate & Lyle Emissions Reductions 

Pollutant Allowable Emissions from Title V 

Operating Permit (tons/year) 

Post-Project Allowable Emissions 

(tons/year) 

PM/PM10 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, 2005, by the Tennessee Air Pollution Control Board to resolve a citizens’ appeal of a construction 

permit issued for this facility (construction permit number 956292P, issued April 16, 2004). The facility is required to comply with the postproject allowable emissions upon completion of the construction project expanding the facility’s milling and alcohol finishing capacity. A new 

construction permit 958558P was issued January 10, 2006, to incorporate the revised limits, and startup of the expansion project occurred in 

October 2006. 

SO2 Reductions from Knox County Point Sources: Table 6- 6 was provided by the Knox County 

Department of Air Quality Management and summarizes SO2 RACT options for large point 

sources in the county. These options were rejected as potential RACT, because it would not be 

possible to implement these reductions in 2008. 

Table 6- 6: RACT Analysis for Knox County SO2 Point Sources 

Source Description SO2 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) 12 280 
6 

ICI Boilers-Coal--Low Sulfur 

-UT Flue Gas Desulfurization ( 90 % ctrl) 12 415 

ICI Boilers-Residual Oil Flue Gas Desulfurization 12 unknown 

SO2 RACT for Area Sources

As indicated previously, area sources are responsible for only 0.3% of total SO2 emissions within 

the nonattainment area. Because the fraction of SO2 emissions from area sources is negligible 

compared to emissions from large point sources, this category was eliminated from consideration 

as potential RACT. 

PM2.5 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 emissions and about 47% of total direct PM2.5 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 PM2.5 emissions may occur as the wet scrubbers currently under construction 

at these facilities become operational. The only additional control option for direct PM2.5

emissions is a baghouse4, and replacement of the existing electrostatic precipitators with a 

baghouse would require more than 12 months to complete engineering, construction, and startup. 

Therefore, additional PM2.5 reductions from these sources are not suitable as RACT options. 

Other Point Sources: RACT options for other large point sources in the Knoxville area were not 

reviewed due to time constraints.

PM2.5 RACT for Area Sources

The 2002 area source emission inventory was reviewed to determine which source categories 

were responsible for most area source PM2.5 emissions5

. 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 PM2.5 emissions in the nonattainment area. 

Table 6- 7: PM2.5 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 typical control efficiency of a baghouse, when used to control particulate 

emissions from coal combustion, is about 99.9%. By comparison, the control efficiency of an electrostatic precipitator is typically about 99%. 

These numbers suggest that replacement of the existing particulate controls at TVA’s two coal-fired facilities with baghouses would have only a 

marginal effect upon direct PM2.5 emissions from these sources. 

5 Since Roane County’s area source emissions (from the nonattainment portion) were estimated to be only 13 tons, and since most Roane County 

area sources are expected to be located outside of the nonattainment area, this county’s area source emissions were excluded from 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 PM2.5 SIP, and we 

explain in that section why we believe that emissions from these source categories do not 

contribute significantly to PM2.5 nonattainment in the Knoxville area. Open burning of most 

wastes is prohibited by Rule 1200-3-4 of the Tennessee Air Pollution Control Regulations 

(TAPCR), and the Tennessee Department of Environment and Conservation is prohibited by 

State law from regulating the open burning of certain wood wastes. Likewise, burning of wood 

in residential stoves is exempt from construction 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 dust regulations of TAPCR 1200-3-8. Adoption of 

additional control measures for open burning, construction, or mining would 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 PM2.5 area source emissions that would advance 

the attainment date by one year. 

RACT Options for Sources Adjacent to the Nonattainment Area

SO2 and PM2.5 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 maximum impact of an 

adjacent source upon the nonattainment area’s annual PM2.5 concentration was 0.08 μg/m3

.