Document EdDvx1dMprGMoZOk8Y34ybqyj

FACILITY Seward Cieneration Seward (;onoration 595 Power Plant Road New Florence, PA 15944 814-446-7162 PADEP LIMIT PM EPA MATS PM LIMIT IPA MATS LIMIT PROPOSED RECINT TESTED I'M EMISSION VALUE 0.10 lbs/nunbtu 0.030 1bs/mmhtu I 0.010 lbs/mmbtu 0.00736 lbs/minhtu Under the MATS Rule, there is a requirement to install PM CEMS. Seward submits that the technology to implement such standard is not available, installing relevant upgrades that are 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 CEMS that demonstrate a lack of technical availability by of means of demonstrating compliance with the rule. Seward believes that EPA significantly underestimated costs associated with a PM CEMS. Installation of a PM GEMS at a single unit, including site preparation and engineering activities, analyzer equipment and installation cost, and initial PS-11 correlation testing is estimated to range from $180,000 to over $400,000 (depending on vendor and brand). However, Seward estimates that the installation of PM CEMS at all three plants could exceed $350,000$550,000.00 and would include analyzers, engineering stack studies/port installation, upgraded umbilical collection lines, revise DAI IS programming, daily calibrations, semi-annual RATA certifications, and annual maintenance. Another factor is that CEMS parts need to he replaced over' time. Manufacturers have stopped making CEMS replacement parts, making it necessary to replace an entire PM CEMS system more often. In addition, IPA. did not account in its MATS Rule for the fact that PM CEMS needing to be replaced every 10 years or the cost of the replacement ($180,000 to over $400,000). Seward 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 EOUs, annual costs associated with a PM CEMS are estimated to range from $92,900 to over $154,600, whereas annual costs associated with stack testing arc estimated to range from $24,000 to $32,000. Sierra Club FOIA 2025-EPA-04883 ED_018388_00000267-00002 SC_EVERSPLIT0006064