INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
April 2025

GENERAL FACILITY INFORMATION
Facility Name:  Tennessee Valley Authority, TVA, Kemper Combustion Turbine Plant
Facility Address: 1363 Mark Cobb Road, Dekalb, MS 39328    
County: Kemper
SIC Code(s): 4911
NAICS Code(s): 221112  

APPLICATION SUMMARY 
Permit No.: 1380-00015
Permit Action: Renewal 
Permit Folder: PER20230002
Application Receipt Date: October 30, 2023
Application Deemed Complete: {Use administrative completeness date}
CBI Submitted? No	NSPS (Part 60): GG, IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): ZZZZ
112(r) / RMP: No
Other: Acid Rain Regulations, CSAPR	
FACILITY DESCRIPTION
Tennessee Valley Authority (TVA), Kemper Combustion Turbine Plant is an existing 450 megawatt (MW) natural gas and fuel oil fired electrical power generating station located in DeKalb, Mississippi. The table below contains a detailed list of the significant emission points contained in the proposed permit.

Emission Point	Description	
AA-001	1,278 MMBtu/hr (112.7 MW) natural gas/No. 2 diesel fuel fired simple-cycle GE Combustion Turbine (CT-1) equipped with NOx controls which include evaporative inlet fogging, dry low-NOx burners for firing with natural gas, and water injection for firing with fuel oil.	
AA-002	1,278 MMBtu/hr (112.7 MW) natural gas/No. 2 diesel fuel fired simple-cycle GE Combustion Turbine (CT-2) equipped with NOx controls which include evaporative inlet fogging, dry low-NOx burners for firing with natural gas, and water injection for firing with fuel oil.	
AA-003	1,278 MMBtu/hr (112.7 MW) natural gas/No. 2 diesel fuel fired simple-cycle GE Combustion Turbine (CT-3) equipped with NOx controls which include evaporative inlet fogging, dry low-NOx burners for firing with natural gas, and water injection for firing with fuel oil.	
AA-004	1,278 MMBtu/hr (112.7 MW) natural gas/No. 2 diesel fuel fired simple-cycle GE Combustion Turbine (CT-4) equipped with NOx controls which include evaporative inlet fogging, dry low-NOx burners for firing with natural gas, and water injection for firing with fuel oil.	
AA-005	7.78 MMBtu/hr natural gas-fired GTS Energy Gas Heater (GH-1)	
AA-006	7.78 MMBtu/hr natural gas-fired GTS Energy Gas Heater (GH-2)	
AA-010	327 HP (244kW / 2.352 MMBtu/hr) diesel-fired Emergency Fire Pump (Model Year 2017)	

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit (PTE) exceeds the Title V major source threshold of 100 tons per year (tpy) for each of the following criteria air pollutants: Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Sulfur Dioxide (SO2). The facility’s potential-to-emit hazardous air pollutants (HAP) does not exceed the major source threshold of 25 tpy of total HAP and 10 tpy for any individual HAP.
Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	54.40	
2PM10	90.30	
2PM2.5	90.30	
Sulfur Dioxide (SO2)	118.10	
Nitrogen Oxides (NOx)	547.00	
Carbon Monoxide (CO)	323.80	
Volatile Organic Compounds (VOC)	36.80	
Total Reduced Sulfur (TRS)	0.00	
Lead	0.03	
CFC/HCFC	0.00	
Total HAP 	3.94	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.
2 The PM10 and PM2.5 values listed above include both filterable and condensable emissions.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the PSD threshold for a major source is 250 tpy. The facility has the potential to emit more than 250 tons per year of VOC and CO; therefore, the facility is considered a major stationary source. This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no modifications to the facility or other significant permit changes proposed as part of this permitting action. The previous permit contained a generic requirement as Condition 5.B.1 which addressed general NOx CEMS requirements from 40 CFR 75. The general Part 75 monitoring requirements are included in the Acid Rain Phase II Permit (see Application attached in permit); therefore, this condition was removed from Section 5.B of the permit.  

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

All combustion turbines (Emission Points AA-001 through AA-004) have pre-control emissions that exceed the Title V major source threshold for NOx and each is equipped with a control device (i.e., water injection). As such, these units are potentially subject to the CAM provisions for NOx emissions. However, since compliance with the emission limits is determined using continuous emission monitoring systems (CEMS), the turbines meet the exemption in 40 CFR 64.2(b)(1)(vi) and are not subject to the CAM provisions. 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (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 HAP emissions. Therefore, the facility is not subject to the provisions of Subpart YYYY.

•	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 HAP emissions and has a new emergency engine (Emission Point AA-010) which is subject to Subpart ZZZZ. Per 40 CFR 63.6590(c)(1), the engine complies with the requirements of Subpart ZZZZ by complying with the applicable requirements of 40 CFR 60, Subpart IIII.

•	40 CFR 63, Subpart UUUUU, NESHAP for Coal and Oil-Fired Electric Utility Steam Generating Units - The provisions of Subpart UUUUU are applicable to coal or oil-fired electric utility steam generating units (EGU). The combustion turbines at the facility are considered EGUs; however, they meet the definition of a natural gas-fired EGU in 40 CFR 63.10042. Per 63.9983(b), these combustion turbines are not subject to the requirements of Subpart UUUUU.
NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
•	40 CFR 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 - The provisions of Subpart Kb are applicable to each storage vessel with a capacity greater than or equal to 75 cubic meters (19,813 gallons) that is used to store volatile organic liquids. The facility has two (2) 2,016,000-gallon fuel oil storage tanks; however, per 40 CFR 60.110b(b), Subpart Kb does not apply to storage vessels with a capacity greater than or equal to 151 cubic meters (39,890 gallons) storing a liquid with a maximum true vapor pressure less than 3.5 kilopascals (0.51 psi). Table 7.1-2 in AP-42, Section 7.1, indicates the maximum true vapor pressure of No. 2 fuel oil is 0.006 psi at 60°F. As such, the storage tanks are not subject to the requirements of Subpart Kb.

•	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 were constructed after October 3, 1977. All the turbines at the facility have a rated heat input in excess of the applicability threshold and they were all constructed after October 3, 1977. As such, the turbines are subject to the provisions of Subpart GG. The applicable requirements of Subpart GG are included in the proposed permit.

•	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. The fire pump engine at the facility (Emission Point AA-010) is a new CI engine that was manufactured and constructed after these dates; therefore, the engine is subject to the requirements of Subpart IIII. The applicable requirements of Subpart IIII are included in the proposed permit.

•	40 CFR 60, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines - The provisions of Subpart KKKK are applicable to stationary combustion turbines with a heat input at peak load equal to or greater than 10 MMBtu/hr that commenced construction, modification, or reconstruction after February 18, 2005. The combustion turbines (Emission Points AA-001 through AA-004) were constructed prior to the applicability date so they are not subject to the provisions of Subpart KKKK. 
•	40 CFR 60, Subpart TTTT, Standards of Performance for Greenhouse Gas Emissions for Electric Generating Units - The provisions of Subpart TTTT are applicable to stationary combustion turbines that commenced construction after January 8, 2014, or commenced modification or reconstruction after June 18, 2014. The stationary combustion turbines (Emission Points AA-001 through AA-004) were constructed prior to this date so they are not subject to the provisions of Subpart TTTT.

SPECIFIC APPLICABLE REQUIREMENTS
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001 AA-002 AA-003 AA-004	Operating Requirements	Definition of startup and shutdown	Monitor and record hours of operation	
		Fuel switching requirements		
	Fuel Restriction	Natural gas or No. 2 fuel oil only	Fuel records	
	Fuel Oil Sulfur Content	Sulfur content ≤ 0.05% by weight		
	Fuel Firing Restrictions	Natural gas may be fired during Base Mode and must be fired during Peak Mode Operation. Fuel oil may be fired only during Base Mode Operation.	Monitor and record operating mode and fuel being fired	
	PM/PM10 (filterable)	While firing natural gas, emissions limited to ≤ 7.35 lbs/hr (each turbine)
While firing fuel oil, emissions limited to ≤ 15.80 lbs/hr (each turbine)
Total from all four turbines ≤ 54.40 tons/year for both fuels combined and all operating modes	Performance test once every five years for each fuel being fired	
	SO2	While firing natural gas, emissions limited to ≤ 4.35 lbs/hr (each turbine)
While firing fuel oil, emissions limited to ≤ 59.0 lbs/hr (each turbine)
Total from all four turbines ≤ 118.10 tons/year for both fuels combined and all operating modes	Monitor sulfur content of fuels	
	NOx	While firing natural gas, emissions limited to ≤ 12 ppm at 15% oxygen on a dry basis, not to exceed 82.4 lbs/hr (each turbine), both limits are based on a 24-hour operating period
While firing fuel oil, emissions limited to ≤ 42 ppm at 15% oxygen on a dry basis, not to exceed 204.0 lbs/hr (each turbine), both limits based on a 24-hour operating period
Total from all four turbines ≤ 546.0 tons/year for both fuels combined and all operating modes	CEMS	
	CO	While firing natural gas, emissions limited to ≤ 25 ppm at 15% oxygen, not to exceed 64.2 lbs/hr (each turbine), both limits are based on a 24-hour operating period
While firing fuel oil, emissions limited to ≤ 20 ppm at 15% oxygen, not to exceed 51.60 lbs/hr (each turbine), both limits are based on a 24-hour operating period
Total from all four turbines ≤ 323.3 tons/year for both fuels combined and all operating modes	CEMS	
AA-001 AA-002 AA-003 AA-004	VOC	While firing natural gas, emissions limited to ≤ 7.0 lbs/hr (each turbine), based on a 24-hour operating period
While firing fuel oil, emissions limited to ≤ 7.0 lbs/hr (each turbine), based on a 24-hour operating period
Total from all four turbines ≤ 36.8 tons/year for both fuels combined and all operating modes	Performance test once every five years for each fuel being fired	
	Opacity	≤ 10%	Annual visual observations	
	Operating Restriction	Total heat input ≤ 12,950,784 MMBtu per year with no more than 4,306,426 MMBtu heat input per year provided from firing fuel oil, both determined on a 12-month rolling total	Monitor and keep records of heat inputs and fuels	
	NOx	STD = 0.0075*(14.4/Y) + F	CEMS	
	SO2	Sulfur content in fuel ≤ 0.8 % by weight (8,000 ppmw) 	Fuel records	
	PM 
(filterable)	E = 0.8808*I-0.1667	The margin of compliance with the state standard is expected to be significant and warrants no additional monitoring	
AA-005 AA-006	Fuel Restriction	≤ 42,900,000 scf of natural gas per year on a 12-month rolling total for both heaters combined	Monitor and record fuel usage	
AA-010	NMHC+NOx
CO
PM (filterable)	3.0 g/HP-hr
2.6 g/HP-hr
0.15 g/HP-hr	Keep records documenting engine is certified to meet standards	
	SO2
(Diesel fuel requirements)	Sulfur content of 15 ppm max AND
Minimum cetane index of 40 OR maximum aromatic content of 35 volume percent	Keep records detailing fuel characteristics	
	NMHC+NOx
PM
(filterable)
CO
SO2	Operating requirements	Monitor and record hours of operation and reason for operation	
	PM (filterable)	0.6 lbs/MMBtu	The margin of compliance with the state standard is significant and warrants no additional monitoring	
OTHER REQUIREMENTS:
Emission Points AA-001 through AA-004 are subject to the provisions of the Acid Rain Program found in 40 CFR 72-78. The permit addresses the provisions of the Acid Rain program in Section 8 of the TVOP and the proposed Phase II Acid Rain Permit is in Appendix C of the facility’s TVOP.

Emission Points AA-001 through AA-004 are subject to the applicable requirements of 40 CFR 97, Subpart EEEEE, Cross-State Air Pollution Rule (CSAPR) NOx Ozone Season Group 2 Trading Program. The provisions of Subpart EEEEE are included in Section 9 of the TVOP.