Cheatham County Generation Site EIS Scoping Report
• TVA must include GHG analysis that is complete, accurate, and that acknowledges federal climate policy. TVA must follow the CEQ’s March 2023 guidance on climate change in NEPA reviews. • TVA must analyze the GHG emissions of new gas plants in the context of EOs directing federal agencies to prioritize decarbonizing the electricity sector by 2035. TVA must clearly and completely explain the extent to which it has already taken steps toward building the facilities it has identified as its preferred alternative. 6.1.7 Tennessee Department of Environment and Conservation • TDEC’s Division of Air Pollution Control (APC) provided scoping comments to address the potential environmental impacts associated with the proposed project. Air Quality • Tennessee Air Pollution Control Regulations (TAPCR) require that construction permits for the discharge of air contaminants must be applied for prior to any modifications of the land. A Prevention of Significant Air Quality Deterioration (PSD) permit will need to be applied for in order to address multiple pollutants and must comply with Sections 111 or 112 of the Clean Air Act. • The PSD permit application for proposed project must also address visibility protection. • Cheatham County is designated as an attainment area for criteria pollutants (VOC and nitrogen oxides for ozone, sulfur dioxide for PM 2.5 ); however, the APC notes that the quality criteria for ozone and PM 2.5 are currently under review, and the attainment status of Cheatham County or the nearby area may change in the future. TVA should consider the impact of the proposed source on the nearby ozone maintenance areas in Montgomery Co., TN and Christian Co., KY. • All stationary gas turbines with a heat input at peak load equal or greater than 10 million BTU per hour of heat input, based on the lower heating value of the fuel fired, are subject to the requirements of 40 CFR 60 Subpart KKKK (Standards of Performance for CT’s). Affected facilities subject to Subpart KKKK are exempt from the requirements of 40 CFR 60 Subpart GG (Standards of Performance for Stationary Gas Turbines). • CTs located at a major source of hazardous air pollutant (HAP) emissions are subject to the requirements of 40 CFR 63 Subpart YYYY (Nation Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines). • The APC recommends: o TVA should utilize alternatives to open burning. o The APC recommends that trucks with up-to-date emission control technologies and proper maintenance be utilized at the site during construction. o The APC also recommends that TVA adopt best practices to minimize vehicle idling. o APC recommends the use of wet suppression to mitigate the generation of fugitive dust.
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