Document 0gzzv7QqJ4kMz9wEDQj52GpZR

Minnkota Power Cooperative, Inc. Milton R. Young Station Unit 1 and 2 A14559.013 Rev 2 May 22, 2024 Further analysis, engineering, testing and equipment modifications would be necessary to determine if these options would improve Hg control. However, it is clear that adding morebrominated PAC, as was assumed in the Final Rule, is not adequate, given the properties of lignite, compliance margin necessary, andimitation of mine mouth facilities in regards to fuel staging (i e. must use coal received from mine; unableto fire only certain coals that have a more ideal or predictable range of Hg content during a 30-day rolling average) It should be noted that the achievable Hg emission rate should not be construed to represent an enforceable regulatory or proposed permit limit. Corresponding permit limits must consider normal operaliig fluctuations and coal variability and take into account a minimum additional 20% margin for these fluctuations. Since a combination of new and/or upgraded control systems would be expected to be required, obtaining a guarantee from a single vendor to ensure that the unit achieves compliance below the permit limit will be challenging. Mercury Testing Results for the MATS Residual Risk and Technology Review Sierra Club FOIA 2025-EPA-04883 Sargent S Lundy 9 ED_Ol 8388_00000327-D0023 SC_EVERSPLIT0006332