Document 3e4KmjXZymJewKMK6J6D3XK83

TALEN ENERGY NorthWesteni Enemy March 28, 2025 To: U.S. Environmental Protection Agency VIA E-MA1L (A1RACT1ON(aEPA.CiOV) From: Ialcn Montana, LLC. NorthWestern Corporation d/b/a NorthWestern Energy Subject: Request for Presidential Exemption from National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 Fed. Reg. 38508 (May 7, 2024): Colstrip Steam Electric Station, Units 3 and 4 Docket ID No.: EPA-HQ-OAR-2018-0794 1. EXECUTIVE SUMMARY The emission standard subject to this Request for Presidential Exemption (Request) is the National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of. the Residual Risk and Technology Review, 89 Fcd. Reg. 38508 (May 7, 2024) (2024 MATS Rule, or Rule). The 2024 MATS Rule set an emission limit of. 0.010 lb/MMBtu limit for filterable particulate matter (fPM) emissions. Id. at 38530; see also 40 C.F.R. Pt. 63, Subpt. UUUUU, Tbl. 2 ("On or after July 6, 2027: 1.0E-2 lb/MMBtu"). The affected source is the Colstrip Steam Electric Station, Units 3 and 4, located in Rosebud County, Montana (Colstrip). Talon Montana, I.I.C (Talon), the operator and part owner of Colstrip, and NorthWestern Corporation d/b/a NorthWestern Energy (NorthWestern), part owner of Colstrip, jointly request that Colstrip be exempt from the 2024 MATS Rule for two years running from the later of the Rule's compliance deadline of July 6, 2027, or July 6, 2028, if. the State of Montana grants a oneyear extension permissible under Section 112 of the CAA. The President should grant this request under Section 112(i)(4) of the Clean Air Act (CAA) because (1) the technology to implement the standard is not available, and (2) the extension is in the national security interests of the United States. Technology. The technology to implement the 2024 MATS Rule for Colstrip is "not available" from an engineering, cost, and timing standpoint. As applied to Colstrip, the Rule requires an untested and unproven sequencing of emission control technologies. Colstrip already employs wet venturi scrubbers, which presently achieve 99.6% control of fPM. The Biden EPA's 2024 MATS Rule would require control 'This t``o-year exemption may be extended for more than one additional period. 42 U.S.C. 7412(1)(4). Sierra Club FOIA 2025-EPA-04883 ED_018388_00000306-00001 SC_EVERSPLIT0006085