1 Docket No . A-92-55 P . Item No . I-D-448


# ~ ALASKA INDUSTRIAL DEVELOPMEN T AND EXPORT AUTHORITY / ZD ENERGY AUTHORITY 480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 269-3000 FAX 907 / 269-3044
May 7, 1999 r _ - - -- ---- ;
s .. G i Mr. William H . Maxwell, P .E . Office of Air Quality Planning and Standard s U .S . Environmental Protection Agency - MD-13 ---- - -J Research Triangle Park, N .C . 2771 1 RE : Speciated Mercu ry Testing at Healy, Alaska Healy Clean Coal Projec t Dear Mr. Maxwell : EPA's Office of Air and Radiation (OAR) is collecting information to assist the Administrator of EPA in determining, under section 112(n)(1)(A) of the Clean Air Act, whether it is appropriate and necessa ry to regulate emissions of hazardous air pollutants ( HAPs) by electric utility steam generating units . The Healy Clean Coal Plant (HCCP) was selected randomly by your office to perform speciated mercu ry testing as pa rt of this project . The HCCP asks to be excused from the project at this time, for the following reasons . 1 .) HCCP is a Clean Coal Technology demonstration project funded in pa rt under the U .S . Depa rt ment of Energy Clean Coal Technology Program . Two technologies are being demonstrated at this plant - slagging combustors used to control NO, emissions, and the integrated system of the slagging combustors, limestone injection in the boiler, a spray d ry er absorber and fabric filters to control pa rt iculate and SO2 emission . The project is still in the demonstration phase . 2 .) The efficacy of the slagging combustors is still being determined and there is a chance that this technology will be retrofi tt ed with standard low-NOX burners . If this retrofit takes place, construction will most likely begin within the next 12 months, making it difficult to guarantee completion of the Hg stack test within your project period . 3 .) Many operational and physical changes are taking place at the plant to a ttempt to optimize-the
-bo+ler-and--polltltion
-control-equipm ent performance -Ope r-atiens-now-- are---- not considered commercial and are subject to changing test conditions . 4 .) Data has been and is currently being collected for the Hg and Cl content of the Usibelli Coal . This coal has little or no Hg and Cl is not detected above the detection limit .p . 2

Mr . William H . Maxwell, P .E
. May 7, 1999 Page 2 5 .) The unit employs a one-of-a-kind technology and is very small compared with other units selected for the study . The data from the speciation testing may not be universally applicable
. We understand that the Agency intends to collect data for one year . For the reasons listed above, data from the HCCP facility over the next year is unlikely to contribute to the research goals set by the Agency : to collect information on the amount, speciation, and controllability of mercury emitted from electric utility steam generating units, to evaluate potential mercury control technologies . We ask the Agency to excuse HCCP from this program . We will continue to collect samples and report the amount of Hg and Cl in our coal under the second phase of your project
. Sincerely,
arm Dennis V . McCrohan, P .E
. Deputy Director - Project Development and Operations cc : Kate Lamal, Golden Valley Electric Association Frank Abegg, Golden Valley Electric Association Walt Lawson, Golden Valley Electric Association Bob Kornosky, U .S . Department of Energy