Document EvdDrvvQwY5VJea4ndY27Dd5V

LISIDA.ACOase#441.1280 Dtdoturreah##00626@3 Fffile1d00t22722944 PFIgge4416 of g28 15. Colstrip would need to undertake a massive and complex construction project to install, test, and implement these new controls the costs of which are estimated to exceed S350 million. 16. If the only feasible compliance option for the Final Rule is found to be retirement, then the investment in IPM controls for just over four years (late 2027 to the end of 2032) would be even less justifiable than otherwise. Indeed, a return period of four years on a greater than S350 million investment in f-PM controls would be extremely difficult to justify, thus likely requiring Colstrip to shut down by the MATS Rule's compliance deadline of July 2027. CCS is Not Achievable at Colstrip 17. CCS is impracticable and infeasible at Colstrip. The Final Rule allows affected ECills to remain in operation beyond 2038 only if they can achieve 90% capture of carbon using CCS by 2032. However, this is not possible at Colstrip for the following reasons. 18. The technology to reliably achieve 90% capture of CO2 using CCS is not adequately demonstrated or readily available. As described above, CC'S is an emerging technology that remains unreliable, as well as prohibitively expensive. And there is not enough time to undertake all of the evaluations and studies, design, engineering, and construction of a CCS system at Colstrip. Talen would not invest hundreds of millions of dollars in a technology that is at best uncertain to work and that, in fact, I glen believes will not work as EPA claims it would by the Rule's deadline. 6 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000309-00056 SC_EVERSPLIT0006219