Document 6bvYe811XL7Gn1pDJ7bo3JVyo
r TALEN
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MONTANA
available during the comment period to further refine the feasibility and costs, and EPA rejected Palen Montana's request for more time to undertake additional efforts.:41
B&M's estimates for the two units combined are summarized below (sec Attachment C for the memorandum from B&M which contains a detailed summary of estimates). The first table is how B&M estimates costs, including cost escalation during construction. 'Ile second table is meant to be more aligned with how EPA estimates costs, which leads to underestimates:
See Palen Montana's Request for Extension of the Comment Period on the National Emissions Standards for Ila7ardous Air Pollutants: Coal- and Oil-Fired Electric Utility Stearn Generating Units Review of the Residual Risk and Technology Review, I)oc II). EPA-IIQ-OAR-20l 8-0794-5880, submitted May 25, 2023 (denied on June 12, 2023).
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Sierra Club FOIA 2025-EPA-04883
ED_018388_00000307-00019 SC_EVERSPLIT0006115