Document nkpnv848vGwbG3y7B0ej41JDX

Minnkota Power Cooperative, Inc. Milton R. Young Station Unit 1 and 2 A14559.013 Rev 2 May 22, 2024 2 TEST CAMPAIGN SUMMARY The MRY Units 1 and 2 test campaign was completed in phases to control testing variables and to accommodate vendor availability, and scheduled outages Testing included: November 23, 2023 to November 24, 2023: Maximizing MRY Unit 1 capabilities of the existing MProve fuel additive system and non-halogenated PAC injection (at 100i feeder rate) to evaluate if the current system can meet 1.2 lb/TBtu December 19, 2023 to December 20, 2023: Maximizing MRY Unit 2 capabilities of the existing M Prove fuel additive system and non-halogenated PAC injection (at 100% feeder rate) to evaluate if the current system can meet 1 2 lb/TBtu. March 19, 2024 to March 23, 2024: Utilizing a rental bulk bag unloading (BBU) system provided by Motus Group tied into the existing MRY Unit 1 PAC conveying lines and injection lances to inject brominated PAC (or BPAC), ARQ's FastPAC Platinum", at varied injection rates ranging from 100 lb/hr (or 1.23 lb/MMacf) to a maximum of 185 lb/hr (2.28 lb/MMacf) to stay below the transport piping pluggage limit. The majority of this testing also included maximizing MRY Unit 1 capabilities of the existing M-Prove fuel additive system; however, test runs on March 22 and March 23 included BPAC injection with no fuel additive usage Individual coal samples were taken and analyzed by a 3d party lab for determination of inlet Hg coal content. March 28, 2024 to April 1, 2024: Individual coal samples were taken and analyzed by a 3" party lab for determination of inlet Hg coal content. This testing was not able to be completed during the proposed rule's short comment periodof only 60 days. Due to timing of boiler cleaning outages, time required to develop a test protocol and schedule, and coordination with multiple vendors, rental equipment availability, various site activities, and unplanned unit upsets/outages, a much longer duration was needed 2.1. INCREMENTAL HG REMOVAL TEST RESULTS The Hg emissions achievable based on maximizing current design capabilities using non-brominated PAC and M-Prove without any modifications is summarized below for both MRY Units 1 and 2. Table 2-1 -- MRY Units 1 and 2 Existing System Capabilities Parameter Unit Load during testing PAC Injection Rate Avg. Sorbent Trap Hg Emissions Units MWg lb/MMacf lb/TBtu MRY Unit 1 18 ppm M-Prove and 100% Non-brominated PAC 242 1.06 2.17 MRY Unit 2 18 ppm M-Prove and 100% Non-brominated PAC 469 1.12 1.61 Based on maximizing injection capabilities of the existing systems (without any modifications), the test resu is show that MRY Unit 1 and MRY Unit 2 cannot achieve the proposed MATS limit of 1.2 lb/TBtu. Mercury Testing Results for the MATS Residual Risk and Technology Review Sierra Club FOIA 2025-EPA-04883 Sargent 8 Lundy 3 ED_018388_00000327-00017 SC_EVERSPLIT0006326