Factor
9:
Level
of
control
of
emission
sources
EPA's
decision
to
recommend
Roane
Count
for
nonattainment
status
is
based
on
a
9­
factor
analysis
that
did
not
take
into
account
that
large
sources
in
Roane
County
are
well
controlled.
The
largest
source
in
the
county,
TVA's
Kingston
Fossil
plant,
is
well
controlled,
having
made
significant
emission
reductions
since
2001,
the
date
of
the
emission
inventory
used
in
Factor
1
of
EPA's
9­
factor
test.
It
makes
little
sense
to
place
counties
with
monitored
attainment
and
wellcontrolled
coal­
fired
plants
into
nonattainment
status.

All
9
Kingston
units
have
NOx
controls.
Units
1­
8
have
low­
NOx
burners,
and
unit
9
has
boiler
optimization
controls.
Units
1,
2,
3,
4,
7
and
8
have
selective
catalytic
reduction
(
SCRs)
systems
in
use.
SCR
construction
on
Units
5
and
6
is
nearly
complete,
and
the
SCRs
will
be
in
operation
for
the
2005
ozone
season.
SCR
construction
on
unit
9
will
be
complete
for
ozone
season
2006.
These
SCRs
represent
state­
of­
the­
art
NOx
controls.
For
the
2004
ozone
season,
NOx
emissions
are
down
more
than
50
percent,
with
annual
reductions
on­
track
for
a
30
percent
reduction
of
emissions
compared
to
those
used
in
EPA's
analysis.
The
SCRs
represent
an
investment
of
more
than
a
$
250­
million
for
NOxreduction
control
equipment.

SO2
emissions
are
on­
track
to
be
around
13
percent
lower
this
year
than
in
2001
through
the
use
of
lower­
sulfur
coal.
A
planned
switch
to
even
lower­
sulfur
coal
should
result
in
reductions
of
36
percent
below
2001
levels
by
next
year.
These
fuel
switches
will
put
the
plant
near
a
1.2
lbs/
mmBtu
emission
rate.
These
SO2
reductions
will
proceed
in
advance
of
flue
gas
desulfurization
equipment
slated
for
installation
before
the
end
of
2010.

EPA
stated
in
its
8­
hour
ozone
implementation
rule
of
June
2,
2003,
at
Federal
Register
page
32839,
that
sources
subject
to
the
NOx
SIP
Call
are
deemed
to
meet
RACT
requirements
with
respect
to
ozone.
By
similar
logic,
sources
proposed
to
be
covered
by
the
more
stringent
SO2
requirements
of
the
Clean
Air
Interstate
Rule
should
be
RACT­
equivalent
for
SO2
with
respect
to
PM
2.5.
All
of
Kingston's
units
would
be
subject
to
the
rule
as
proposed.
