Document NDwoLg25zvdKw47pdY10BQaR

controls, and programming to tic the existing carbon injection skid to the mercury process monitor so emissions levels can be managed at the low standard. Healy Unit 1 does not have a mercury emissions control system nor a mercury process monitor and uses annual source testing as its compliance demonstration method. In order to meet the new MATS mercury emissions limit on f scaly Unit 1, GVEA expects that it will need to budget for, engineer, procure, install, and commission a mercury control system on Unit 1. Given the experience with Unit 2. GVEA timber expects that it will need to install a mercury process monitor for real-time emissions data and establish the controls and programming to equip the system to respond rapidly to real-time mercury emissions levels and maintain emissions consistently below the new standard. GVEA's experience installing and maintaining comparable equipment elsewhere makes it clear to GVEA that it is not technically feasible for GVEA to complete this work by July 6, 2027. The additional time provided by the Presidential Exemption would allow GVEA a reasonable time frame to design and install control systems suited to the unique conditions of the I I ealy Power Plant. GVEA appreciates your consideration of this request. Please contact Naomi J. Morton Knight, GVEA Chief Power Supply Officer, e at or (907)458-4557 with any questions. Thank you, Toni Cicroy Environmental Specialist PO Box 71249 Fairbanks, AK 99707 758 Illinois St Fairbanks, AK 99701 Office: (907) 451-5673 Mobile (208) 275-9785 tperove,gvea corn www gvea.com ( 'I'VE:\ Safety: :' This message including all attachments is intended only for the use of the individual or entity to whom it is addressed. and may contain information that is privileged confidential or otherwise exempt from disclosure Any unauthorized +evieliv use. disciosive or distribution of this message is prohibited if you have received this message in error please contact rhe sender by reply e-mail and delete rhe e-marl and any attachments without retaining any copies. Yee Sierra Club FOIA 2025-EPA-04883 ED_018388_00000056-00005 SC_EVERSPLIT0005600