Document 93br7yBOqV0gvQjDnQOVBdoE6

Ebensburg Power Company 2840 New Germany Road Box 845 rbensburg, PA 15931 . 'rel (814) 472-1140 Fax: (814) 472-1143 March 28, 2025 President Donald J, 'frump The White House Office of the President 1600 Pennsylvania Avenue, N.W. Washington, DC 20500 RE: Presidential Exemption: National Emission Standards for I lazardous Air Pollutants: Coal- and OilFired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review" (89 FR 38508; May 7, 2024) (MATS Rule): Ebensburg Power Company" Dear President Trump: In accordance with the terms of your Executive Orders and to Power the Great American Comeback, Ebensburg Power Company (EPC) here by requests a Presidential exemption for the EPC generating station with respect to compliance with the MATS Rule for a period of two years because the technology to implement the standard is not available and it is in the national security interests of the United States to do so. Emissions standards or limitations subject to the request This request is for exemption from compliance with 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" Length of compliance period being requested 'I'wo years. EPC notes that the two-year period will cover sources beyond the original compliance date of July 2027, allowing an extension to July 2029 and that the statute allows for potential renewal, Justification to support the request As is shown below the ITC facility is a Low Emitting EGU (LEE) affected MATS facility. Mercury testing occurs annually, and particulate testing is conducted every three years in accordance with the Title V Operating Permit. The plant continues to meet LEE criteria and are in compliance with not only the current PM emission limit of 0.030 lbs/mmbtu and would also be in compliance with "new" compliance limit of 0.010 lbs/mmbtu. FACILITY PADEP LIMIT PM EPA MATS PM LIMIT EPA MATS LIMIT PROPOSED RECENT TEST1D PM EMISSION VALUE Ebensburg Power 0.10 lbs/mmbtu 0.030 lbs/mmbtu 0.010 lbs/mmbtu 0.00188 lbs/mmbtu Sierra Club FOIA 2025-EPA-04883 ED_018388_00000269-00001 SC_EVERSPLIT0012725 Under the MATS Rule, there is a requirement to install PM CEMS.KPC submits that the technology to implement such standard is not available, installing relevant upgrades that arc needed to comply by the Rule's Compliance Deadline is not feasible, converting to Gas-fired Boilers is not feasible by the rule's compliance deadline, and that there are various issues with PM CIMS that demonstrate a lack of technical availability by of means of demonstrating compliance with the rule. EPC believes that EPA significantly underestimated costs associated with a PM CIMS, Installation of a PM GEMS at a single unit, including site preparation and engineering activities, analyzer equipment and installation cost, and initial PS-I1 correlation testing is estimated to range from $180,000 to over $400,000 (depending on vendor and brand). However, EPC estimates that the installation of PM CEMS at all three plants could exceed 5350,000-$550,000.00 and would include analyzers, engineering stack studies/port installation, upgraded umbilical collection lines, revise DAHS programming, daily calibrations, semi-annual RATA certifications, and annual maintenance. Another factor is that the CIWS parts need to be replaced over time. Manufacturers have stopped making CEMS replacement parts, making it necessary to replace an entire PM CEMS system more often. In addition, EPA did not account in its MATS Rule for the fact that PM CIMS needed to be replaced every 10 years or the cost of the replacement (S180,000 to over $400,000). ITC notes that ongoing PM CEMS correlation testing with injection of media in the effluent to artificially raise emission levels costs at least $250,000 per test evolution at one source, and testing is required by MATS once every three years. For some Kills, annual costs associated with PM CI-:MS are estimated to range from $92,900 to over $154,600, whereas annual costs associated with stack testing are estimated to range from $24,000 to $32,000. During the comments period on the proposed MA'I'S Rule, many commenters provided data showing that, by eliminating the LEE provisions which allow once per three-year emissions testing as an incentive to he a low emitter, EPA is forcing massive cost increases by the requirement of continuous emissions monitoring, record keeping, and reporting on the lowest emitting affected EG-Us, ITC believes that PM CEMS cannot be used to demonstrate compliance with the new MATS Rulc, The fPM standards were lowered by 2/3rds. Starting in 2027, sources will be required to demonstrate compliance with a PM CEMS on the more stringent 11.31V1 standards which arc 0.010 Ihs/MMBtu. Demonstrating compliance with emissions standards this low utilizing a PM CEMS is not a viable option. Some units have used PM CEMS for many years and have encountered problems with operating their PM ChMS with regard to (i) meeting the Quality Assurance-Quality Control (QA-QC) criteria; and (ii) establishing the correlation curve. PM also fail to meet the QA/QC criteria. When a PM CEMS fails to meet the QA-QC criteria, the collected data arc considered out-of-control and are no longer considered valid, An owner/operator has no real time indication that its EGU might have failed the required QA-QC criteria until several weeks after the testing has been completed. This could result in hundreds of hours of monitor downtime being created retroactively after the QA-QC criteria failure has been identified and is required to be reported as a deviation under the MATS rule. Sierra Club FOIA 2025-EPA-04883 ED_018388_00000269-00002 SC_EVERSPLIT0012726 Most states have minimum data availability requirements that could result in enforcement actions. At the more stringent fl'M standard of 0.010 lb/MMBtu, the likelihood of out-of-control periods increases. This downtime is not reflective o f' poor maintenance or operation but rather the difficulties associated with the quality assurance procedure at such low emission levels and is not accounted for in the EPA analysis. Iinally, there currently is no calibration procedure available that can accurately verify continuous measurements o ffi'M at levels as low as 0.010 lb/MMBtu. Moreover, PM (TINS is not a direct measure of compliance with the applicable emission limitation; rather, emissions are correlated and as such can be in error as much as +/- 25% when having to correlate to standards as low as 0.010 lbs/MMIku. National security interests of the United States to provide the exemption Several of President Trump's Executive orders support the national security interest in granting this exemption, including: E0 14156, Declaring a National Energy Emergency o "Our nation's current inadequate development of domestic energy resources... poses an imminent and growing threat to the United States' ,,. national security." o "The United States' in sufficient energy production, transportation, refining, and generation constitutes an ... extraordinary threat to our... national security." E014154, Unleashing American Energy o "It is the policy of the United States... to protect the (Nation's) economic and national security... by ensuring that an abundant supply of reliable energy is readily accessible." o "High energy costs... weaken our national security." Executive Order 14213 - - "Establishing the National Energy Dominance Council" Accordingly, ITC believes that a Presidential Exemption is in the national security interests of the United States. There is growing demand for electricity to support the grid. Many states need additional electricity supply due to data centers, artificial intelligence, and manufacturing. To illustrate, the Department of Energy recently released a new report indicating that domestic energy usage (and therefore demand) from data centers is expected to double, or even triple, by 2028. The power sector also continues to break daily peak load records due to extreme weather events and generation shifting. In sum, there is significant demand for electricity and a concomitant need to reinforce system reliability and capacity. Sierra Club FOIA 2025-EPA-04883 ED_018388_00000269-00003 SC_EVERSPLIT0012727 Conclusion For the foregoing reasons 1.PC respectfully requests a two-year Presidential Ixemption from compliance with tir MATS Rule for the lilensburg Power Company. / Aa,e, At/ __ Mar Cra.wford Environmental Mffliger Sierra Club FOIA 2025-EPA-04883 ED_018388_00000269-00004 SC_EVERSPLIT0012728