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Docket No . A-92-55 P

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Item No . I-D-448

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ALASKA INDUSTRIAL DEVELOPMEN T

AND EXPORT AUTHORITY

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ZD ENERGY AUTHORITY

480 WEST TUDOR ANCHORAGE, ALASKA 99503 907 / 269-3000 FAX 907 / 269-3044

May 7, 1999

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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 Mercury Testing at Healy, Alaska

Healy Clean Coal Project

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 part 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. Department 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

dryer absorber and fabric filters to control pa rticulate 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 retrofitted 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-equipment performance-Oper-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