Cheatham County Generation Site EIS Scoping Report
Appendix C Summary of Scoping Comments
Tennessee Valley Authority
The Tennessee Department of Environment and Conservation, Division of Air Pollution Control (APC) received TVA’s Notice of Intent to prepare an Environmental Impact Statement to address the potential environmental impacts associated with the proposed construction and operation of a simple cycle combustion turbine plant and battery energy storage system (BESS) on a 286-acre parcel of TVA-owned land in Cheatham County, Tennessee. The notice states that the Cheatham County Generation Site would generate approximately 900 MW and replace generation capacity for a portion of the Cumberland Fossil Plant retirement, and the proposed 400 MWh BESS could also help TVA maintain grid stability and reliability as generating assets with greater minute-by-minute variability (e.g. wind and solar) are integrated into TVA’s transmission system. APC offers the following comments: Tennessee Air Pollution Control Regulations (TAPCR) 1200-03-09-.01(1)(a) states that except as specifically exempted, no person shall begin the construction of a new air contaminant source that may result in the discharge of air contaminants without first having applied for and received from the Technical Secretary a construction permit for the construction of such air contaminant source. TAPCR 1200-03-09-.01(4) (Prevention of Significant Air Quality Deterioration) states that No new major stationary source or major modification shall begin actual construction unless the requirements of Tennessee’s PSD construction permit program, as applicable, have been met. These programs may cover multiple pollutants, including criteria pollutants, pollutants regulated by Sections 111 or 112 of the Clean Air Act, and greenhouse gases, and the Cheatham County Generation Site must comply with both regulations for preconstruction permitting, as applicable. • Tennessee’s New Source Review prohibit the construction of new major stationary sources that would have an adverse impact on visibility in Class I areas (national parks and wilderness areas). Any application for a PSD or nonattainment NSR permit for the proposed new source must address visibility protection. • TAPCR 1200-03-09-.01(5) (Growth Policy) regulates the construction of air contaminant sources in nonattainment areas. This program addresses preconstruction requirements for criteria pollutants and precursor emissions (VOC and nitrogen oxides for ozone, sulfur dioxide for PM2.5) in nonattainment areas. Cheatham County is currently designated as attainment for all criteria pollutants, but APC notes that the air quality criteria for ozone and PM2.5 are currently under review, and the attainment status of Cheatham County or the nearby metropolitan area may change in the future. TVA should also consider the impact of any proposed source on the nearby ozone maintenance areas in Montgomery County, Tennessee and Christian County, Kentucky. • All stationary gas turbines with a heat input at peak load equal to 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 Stationary Combustion Turbines). Affected facilities subject to Subpart KKKK are exempt from the requirements of 40 CFR 60 Subpart GG (Standards of Performance for Stationary Gas Turbines). • Stationary combustion turbines located at a major source of hazardous air pollutant (HAP) emissions are subject to the requirements of 40 CFR 63 Subpart YYYY (National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines). A major source of HAP emissions is a contiguous site under common control that emits or has the potential to emit any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year. • If disposal of trees or vegetation is necessary during construction, APC recommends that TVA evaluate alternatives to open burning. Additional information about Tennessee’s open burning requirements can be found at https://publications.tnsosfiles.com/rules/1200/1200-03/1200-03-04.pdf. • Truck traffic associated with construction projects generate emissions of PM, CO, NO2, SO2, VOC, and CO2, and APC recommends the operation of trucks with up-to-date emission control technologies and proper maintenance to minimize vehicle and equipment emissions. The Division of Air Pollution Control also recommends that TVA adopt best practices to minimize vehicle idling to minimize the impact of mobile source emissions on ambient air quality. • If fugitive dust will be generated from construction activities, APC recommends the use of wet suppression or other measures to minimize the generation of fugitive dust.
Response to Scoping Request, Cheatham County Generation Site
6/14/2023
neutral
Travis
Blake
37214
To Tennessee Valley Authority Board Chair Bill Kilbride, board members, and staff: After decades of operation, the Cumberland Fossil Plant is no longer cost effective or reliable, and it is one of the most polluting coal plants in the country. This is why I support the Tennessee Valley Authority’s decision to close the Cumberland Plant. I strongly encourage the Tennessee Valley Authority (TVA) to replace the plant’s capacity with a renewable electricity alternative that is cost effective, safe and reliable while bringing jobs and economic development to the region. “It is horrifying that we have to fight our own government to save the environment.” -- Ansel Adams
I firmly believe that the TVA should not invest in more fossil fuel by constructing a methane gas plant and 12-mile gas pipeline in Cheatham County to partially replace the capacity of one of the coal-fired units at Cumberland City. Building a gas plant is expensive and gas prices are volatile. The TVA would likely have to retire the gas plant before the end of its useful life because renewable energy options are cheaper and those prices continue to fall. TVA customers should not be forced to pay for a project that TVA CEO Jeff Lyash has called a “not-forever” solution. Furthermore, the public health impacts and environmental risks of building a gas plant are too big to ignore. Methane gas plants, compressor stations and pipelines release pollutants like nitrogen oxides, sulfur dioxides, carbon monoxide and particulate matter into the air. They are also at risk of dangerous explosions like the one that happened in Dickson County in 1992. In addition, the combined 44 miles of pipeline that the TVA would need to replace the two coal-fired units at Cumberland City would force landowners to sell easements on their property to the pipeline company, Kinder Morgan, while crossing more than 130 wetlands and streams, threatening our air and water quality. If the pipelines contaminate groundwater or surface water during construction, rural communities could lose access to clean water for drinking and farming. The TVA should invest in renewable energy sources like wind, energy efficiency, solar and storage to replace the capacity of both coal-fired units at the Cumberland City fossil plant. “The ultimate test of a moral society is the kind of world that it leaves to its children.” -- Dietrich Bonhoeffer Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources. negative Chris Lish
Reject the proposal to replace TVA’s Cumberland Fossil Plant with methane gas-powered plants and instead
6/26/2023
Please prepare a DEIS which accurately describes an array of alternatives. Documenting your demand projections to be met with facts and documented trends both up -- e.g. EV charging and down -- e.g. IRA cost sharing on distributed and community solar and energy efficiency. There will many mix and match combinations of renewable energy (wind and solar), storage (recognizing that utility scale solar farms now come with battery storage), distributed energy resources (DEI) e.g small scale solar or wind at residences, businesses and pubic facilities including schools. Of course, pumped storage offers flip of the switch back-up and time shifting. Revising TVA’s artificial limits on Local Power Company (LPC) DEI strengthen both TVA and LPC grid reliability. This is important in the face fo the ever increasing damage caused by climate disruption.
RE: Comments on the proposed Cheatham County Natural Gas Combustion Turbine Electricity Generating Plant and Pipeline NEPA EIS Scope_004
It is important the TVA shut down its aging and unreliable coal fired plants. But is equally important that any need for replacement power be filled by generation which is carbon emission free. TVA has available all the technology and policy elements to deal with the coal plant closings without resorting to gas fired generation and detailed analysis of these alternatives must be included. TVA should see this as an opportunity to show that you truly want a system that is carbon free and that future is now, before it is too late. Sincerely, Brian Paddock negative Brian Paddock 38501
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