INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
July 2019

FOR:
TVA Southaven Combined Cycle Plant
2882 State Line Road West
Southaven, MS 38671    

FACILITY DESCRIPTION
Tennessee Valley Authority’s Southaven Combined Cycle Plant is an existing 900 megawatt (MW) natural gas fired electrical power generating station located in Southaven, Mississippi (Desoto County).  Operations at the facility fall within SIC Code 4911, Electric Services and NAICS Code 221112, Fossil Fuel Electric Per Generation.  The purpose of this permit action is to renew the facility’s Title V Operating Permit (TVOP) and Phase II Acid Rain Permit which were previously issued June 30, 2014.  A detailed list of the permitted emission sources is included in the table below.

Emission Point	Description	
AA-001	Nominal 1,700 MMBTU/hr GE Model PG7241FA  natural gas-fired combustion turbine with a heat recovery steam generator (HRSG) equipped with a 265 MMBTU/hr duct burner.  The turbine is equipped with dry low NOx burners and a selective catalytic reduction (SCR) system using aqueous ammonia as a reducing agent to control NOx emissions from the exhaust stream of the combined cycle system. (Ref. Generating Unit 001)	
AA-002	Nominal 1,700 MMBTU/hr GE Model PG7241FA  natural gas-fired combustion turbine with a heat recovery steam generator (HRSG) equipped with a 265 MMBTU/hr duct burner.  The turbine is equipped with dry low NOx burners and a selective catalytic reduction (SCR) system using aqueous ammonia as a reducing agent to control NOx emissions from the exhaust stream of the combined cycle system. (Ref. Generating Unit 002)	
AA-003	Nominal 1,700 MMBTU/hr GE Model PG7241FA  natural gas-fired combustion turbine with a heat recovery steam generator (HRSG) equipped with a 265 MMBTU/hr duct burner.  The turbine is equipped with dry low NOx burners and a selective catalytic reduction (SCR) system using aqueous ammonia as a reducing agent to control NOx emissions from the exhaust stream of the combined cycle system. (Ref. Generating Unit 003)	
AA-005	8.4 MMBTU/hr (1,109 HP) diesel-fired backup emergency generator used to provide emergency power for critical plant systems.	
AA-006	2.0 MMBTU/hr (240 HP) diesel-fired emergency fire water pump.	
AA-013	17.085 MMBTU/hr natural gas-fired auxiliary boiler with combustion gases vented to the atmosphere (Ref. Auxiliary Boiler AB-1)	

PERMIT CHANGES
The proposed permit incorporates the following changes:
•	Increased level of detail for existing requirements;
•	Addition of requirements addressing 40 CFR 97, Subpart EEEEE, Cross-State Air Pollution Rule (CSAPR) NOx Ozone Season Group 2 Trading Program;
•	The facility is replacing the existing auxiliary boiler, Emission Point AA-004 (20.0 MMBTU/hr) with one of similar size, Emission Point AA-013 (17.085 MMBTU/hr). The new boiler was not considered a like-kind replacement. The applicable requirements of the new boiler are similar to the one it is replacing.  The new boiler was evaluated using 8,760 hours of operation; therefore, the hours of operation restriction has been removed.
•	Addition of language to address additional applicable requirements of 40 CFR 63, Subpart ZZZZ; and

TITLE V PROGRAM APPLICABILITY BASIS
The facility’s potential to emit exceeds the Title V threshold limits of 100 tons/year (TPY) for each of the following criteria air pollutants: Particulate Matter (PM/PM10/PM2.5), Carbon Monoxide (CO), Nitrogen Oxides (NOx), and Sulfur Dioxide (SO2).  The facility is not considered a major source for hazardous air pollutants (HAP).

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The Southaven Combined Cycle Plant is not one of the 28 listed source categories in the PSD regulations of 40 CFR 52.21, which are adopted by reference in 11 Miss. Admin. Code Pt. 2, Ch. 5.  Therefore, the PSD major source threshold is 250 tons/year for each regulated NSR pollutant, and fugitive emissions are not considered when determining the potential emissions.  Potential emissions of PM/PM10/PM2.5, NOx, and CO exceed 250 tons/year; therefore, the facility is considered a major stationary source.  However, no modifications are proposed with the renewal of the TVOP that trigger the PSD requirements.

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS
The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 6.), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (11 Miss. Admin. Code Pt. 2, Ch. 1.) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (11 Miss. Admin. Code Pt. 2, Ch. 2.), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1. and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 7.)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 11 Miss. Admin. Code Pt. 2, Ch. 6. or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
Only the combined cycle combustion turbines (CTs) are equipped with a control device and are potentially subject to the provisions of CAM.  The provisions of the CAM rule do not apply to the combustion turbines since the NOx emissions controlled by a selective catalytic control system (SCR) are determined by use of a continuous emissions monitoring system (CEMS), thereby meeting the exemption in 40 CFR 64.2(b)(1)(vi).  The TVOP requires the facility to continuously monitor emissions from the combustion turbines in accordance with the applicable requirements of the Acid Rain Program to demonstrate compliance with the ppm, lbs/hr, lb/MWh, and tons/year emission limits established in the PSD Construction Permit.  The CTs are also potentially subject to the provisions of CAM for PM/PM10 and CO; however, there are no controls for either pollutant.  As such, the provisions of CAM are not applicable for these pollutants.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANT SOURCES (NESHAP) APPLICABILITY
•	40 CFR 63, Subpart YYYY, NESHAP for Stationary Combustion Turbines – The provisions of Subpart YYYY are applicable to stationary combustion turbines located at major sources of HAP emissions.  The facility is not a major source of HAPs; therefore, the provisions of Subpart YYYY are not applicable to the combustion turbines.
•	40 CFR 63, Subpart ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines – The provisions of Subpart ZZZZ are applicable to stationary reciprocating internal combustion engines located at area and major sources of HAP emissions.  The facility is an area source of HAPs and has two existing emergency engines (Emission Points AA-005 and AA-006) that are subject to Subpart ZZZZ.  These engines are required to comply with the applicable maintenance and operating provisions.  The permittee shall perform all required maintenance activities in accordance with the schedule in the permit and keep detailed operating records in order to comply with the Subpart ZZZZ requirements.
•	40 CFR 63, Subpart JJJJJJ, NESHAP for Industrial, Commercial, and Institutional Boilers at Area Sources – The provisions of Subpart JJJJJJ are applicable to boilers that are located at area sources of HAPs.  Each combustion turbine is equipped with a heat recovery steam generator (HRSG) that provides steam to the steam turbine and generator. The facility also has a small auxiliary boiler (Emission Point AA-013).  The HRSGs and small auxiliary boiler are fired with natural gas; therefore, they are not subject to the provisions of Subpart JJJJJJ per 40 CFR 63.11195(e).
NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
•	40 CFR 60, Subpart GG, Standards of Performance for Stationary Gas Turbines – The provisions of Subpart GG are applicable to stationary gas turbines with a heat input at peak load in excess of 10 MMBtu/hr that are constructed after October 3, 1977.  The combustion turbines at the facility are subject to the requirements of Subpart GG since they were constructed after this date and have a rated heat input in excess of 10 MMBtu/hr. Emission Points AA-001, AA-002, and AA-003 are subject to NOx and SO2 requirements under 40 CFR 60, Subpart GG.  The facility will use the CEMS required under Part 75 to demonstrate compliance with the NOx limit and fuel purchase records to demonstrate compliance with the fuel sulfur content requirement.
•	40 CFR 60, Subpart Da, Standards of Performance for Electric Utility Steam Generating Units – The provisions of Subpart Da are applicable to electric utility combined cycle gas turbines with a HRSG duct burner capable of combusting more than 250 MMBtu/hr heat input.  The HRSG duct burners at the facility have a rated heat input of 265 MMBtu/hr; therefore, the duct burners are subject to the applicable provisions of Subpart Da. Emission Points AA-001, AA-002, and AA-003 are subject to PM, SO2, NOx, and Opacity requirements of 40 CFR 60, Subpart Da.  Since the units are fired with natural gas, they meet the exemptions in 60.42Da and are not required to meet the PM or Opacity limits.  The facility will comply with the SO2 limit by keeping fuel purchase records that detail the sulfur content of the fuel being fired.  The information collected using the NOx CEMS required under Part 75 will be used to demonstrate compliance with the Subpart Da limit on NOx.
•	40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units – The provisions of Subpart Dc are applicable to steam generating units that were constructed after June 9, 1989, and have a maximum heat input capacity of 100 MMBTU/hr or less but greater than or equal to 10 MMBTU/hr.  The auxiliary boiler at the facility (Emission Point AA-013) was constructed after this date and has a rated capacity of 17.085 MMBTU/hr. While the boiler is subject to the requirements of Subpart Dc, the unit is fired with natural gas only; therefore, the only applicable requirement for the unit is to monitor and record the monthly fuel usage. 
•	40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines – The provisions of Subpart IIII are applicable to stationary CI engines that commenced construction after July 11, 2005, and the engine was manufactured after April 1, 2006.  Emission Points AA-005 and AA-006 were constructed and/or manufactured prior to the applicability dates so they are considered existing engines that are not subject to the requirements of Subpart IIII.  
ACID RAIN PROGRAM
Emission Points AA-001, AA-002, and AA-003 are subject to the applicable provisions of the Acid Rain Program found in 40 CFR 72-78.  The permittee shall comply by installing and operating a CEMS on each unit to monitor/record emissions of NOx.  The facility’s Acid Rain Permit will be reissued concurrently with the TVOP and is included as Appendix C of the TVOP.
CROSS-STATE AIR POLLUTION RULE (CSAPR)
Emission Points AA-001, AA-002, and AA-003 are subject to the applicable requirements of 40 CFR 97, Subpart EEEEE, Cross-State Air Pollution Rule NOx Ozone Season Group 2 Trading Program.

SPECIFIC APPLICABLE REQUIREMENTS
Emission Points AA-001 through AA-003 are subject to emission limits for Particulate Matter (PM/PM10), Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Opacity that were established in a PSD Construction Permit issued April 25, 2000.  The facility will demonstrate compliance with the emission limits for NOx and CO using a Continuous Emission Monitoring System (CEMS), and opacity by performing an annual visual observation that will include a Visible Emissions Evaluation (VEE) if any emissions are observed during the initial observation.  Since the combustion turbines are limited to combusting only natural gas, the margin of compliance for PM/PM10 and SO2 warrants no on-going monitoring.  

Emission Points AA-001 through AA-003 have operating requirements that address startup, shutdown, and tuning sessions.  The facility will keep records to demonstrate compliance with the various requirements for these operating scenarios.

Emission Point AA-013 is limited to burning natural gas only.

The PSD Construction Permit established an operating restriction on the boiler that the facility will comply with by monitoring and recording operating hours for the unit.

EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001 AA-002 AA-003	PM/PM10 (filterable only)	0.02 lb/MMBTU not to exceed 24 lbs/hr based on a 3-hr rolling average and 105 tons/year based on a 12-month rolling total	The margin of compliance is significant and warrants no additional monitoring	
	SO2	12 lbs/hr based on a 3-hr rolling average and 52.6 tons/year based on a 12-month rolling total		
	NOx	3.5 ppm @ 15% oxygen on a dry basis, not to exceed 24.1 lbs/hr, both limits based on a 3-hr rolling average and 105.6 tons/year based on a 12-month rolling total	CEMS	
	CO	17.4 ppm @15% oxygen on a dry basis, not to exceed 61 lbs/hr, both limits based on a 3-hr rolling average and 267 tons/year based on a 12-month rolling total		
	Opacity	10%	Annual visual observations/ VEE (if required)	
	Fuel Restriction	Natural gas only	Fuel records	
	NOx	Control emissions using SCR	Keep operations records 	
AA-001 AA-002 AA-003	NOx	STD = 0.0075*(14.4/Y) + F	CEMS	
	SO2	Fuel with sulfur ≤0.8 percent by weight (8,000 ppmw)	Fuel records	
AA-001 AA-002 AA-003	SO2	0.20 lbs/MMBTU	Fuel records	
	NOx	1.6 lb/MWh (30-boiler operating day rolling average)	CEMS	
AA-005 AA-006	HAP	Operating and maintenance requirements	Keep records documenting maintenance activities and hours of operation	
AA-001 AA-002 AA-003 AA-013	PM (filterable only)	E = 0.8808*I-0.1667	Monitoring not proposed since natural gas provides a large margin of compliance	
AA-013	SO2	4.8 lbs/MMBTU		
AA-005 AA-006	PM (filterable only)	0.6 lbs/MMBTU