Document k60B7qr7vn6R90MQgopgQxDQE

Minnkota Power Cooperative, Inc. Milton R. Young Station Unit 1 and 2 A14559.013 Rev 2 May 22, 2024 Figure 2-1 -- MRY Unit 1 Existing System Mercury Removal Performance Capabilities using Brominated PAC 1000 90 800 1 744 GO G a 11,c 1 .50 140 2 ft. 7 AO 3 0 Proneuted PAC Injection Rate. IbINMact This result is contrary to EPA's assumption that BPAC at a rate of 3.0 lb/MMacf can be used to result in a 90% removal efficiency. The plotted curve shown in the figure shows a leveling off such that increasing the amount of sorbent results in diminishing improvement in Hg control. The projected curve based on the test campaign results shows this leveling off taking place somewhere less than 80% capture. Although the plotted values do not support a conclusion that the new Hg 1.2 lb/TBtu limit can be met, f urther investigation into other Hg control options in combination with upgrading/optimizing existing Hg control equipment would be required to determine the lowest mercury emission rate in lb/TBtu that can be achieved on a long-term basis, considering the range of fuel Hg variabilityand other technological challenges hherent in capturing Hg resulting from lignite that have been documented to occur Some proposed options for additional Hg control include: Increased fuel additive rate Improved reliability of fuel additive concentrationin relation to real-time coal firing rates Implementation of inlet Hg monitor for improved feedback control of Hg control systems Improved lance design to achieve ideal distribution of PAC at all typical unit operating conditions Application of WFGD re-emission control additive Mercury Testing Results for the MATS Residual Risk and Technology Review Sierra Club FOIA 2025-EPA-04883 Sargent 15% Lundy 8 ED_018388_00000327-00022 SC_EVERSPLIT0006331