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Pennsylvania Electric Company (Pennelec)

September 4, 1996


L. Nancy Birnbaum
U.S. Environmental Protection Agency
Office of Policy, Planning and Evaluation
401 M Street, SW
Stop 2129
Washington, DC 20460

RE: Homer City Station XL Demonstration Project; Request for a Meeting With EPA to Discuss the August 27, 1996 Revisions

Dear Ms. Birnbaum:

This letter will confirm our telephone conversation yesterday about the Homer City Station Owners' request for a meeting with EPA personnel to discuss the specifics of our August 27, 1996 revisions (enclosed) to the proposed Homer City Station XL Demonstration Project. A proposed agenda for the meeting is enclosed.

The meeting would enable the Owners to elaborate on the August 27 document, including explaining in detail why we believe the revisions constitute superior environmental performance and why the requirement for a 20 percent reduction from 1995 actual SO2 emissions as set forth in the EPA's July 12, 1996 letter is economically and operationally infeasible, as well as pursuing whether the 20 percent reduction could be achieved by a combination of coal cleaning faiclity modifications and the acquisition and retirement of SO2 allowances. The meeting also would offer the opportunity to clear up any uncertainties or misapprehensions that EPA may have regarding the Owners' commitment to their five-year business plan and its relationship to the proposal and its benefits, including a 19 percent reduction in projected actual SO2 emissions during 1997-1998 and reductions in hazardous air pollutants.

The Owners extend an invitation to hold the meeting at Homer City Station. A meeting at the Station would provide EPA personnel with a first hand opportunity to observe the operation of the coal cleaning facility and its relationship to the electric generating process, all of which will enable the Agency to understand more fully the basis and environmental benefits of their XL proposal. Regardless of the meeting place, a meeting at the earliest possible date is imperative.



cc: Vincent J. Brisini
David M. Gardiner
Christopher A. Knopes
Ronald P. Lantzy


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