Document M4VDB9n7NBMRGLYKyvGYD9OLz

The plant continues to meet LEE criteria and are in compliance with not only the current PM emission limit of 0.030 lhs/mmhtu and would also be in compliance with "new" compliance limit of 0.010 lbs/mmbtu. F'ACILI'TY FADE!' PM ',WI'. Culver(been Energy 0.10 Ihs/inmhtu EPA MATS PM 0.030 lbsicurnbtu PA MATS LIMIT PROP()SIM 0.010 Ibs/nunbtu RECENT CESTI;.1) PM EMISSION VALUE (1.000313 lbs/minhtu Under the MATS Rule, there is a requirement to install PM CEMS. Colvcr 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 arc various issues with PM CEMS that demonstrate a lack of technical availability by of means of demonstrating compliance with the rule. Colver believes that EPA significantly underestimated costs associated with a PM CEMS. Installation of a PM CEMS at a single unit, including site preparation and engineering activities, analyzer equipment and installation cost, and initial PS-1 1 correlation testing is estimated to range from $180,000 to over $400,000 (depending on vendor and brand). I Towever, Colver estimates that the installation of I'M GEMS 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 DAHS programming, daily calibrations, semi-annual RATA certifications, and annual maintenance. Another factor is that the CEMS 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 CEMS needed to he replaced every 10 years or the cost of the replacement ($180,000 to over $400,000). Colver 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 EGUs, annual costs associated with PM CEMS 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 MATS Rule, many commenters provided data showing that, by eliminating the LEE provisions which allow once per three-year emissions testing as an incentive to be 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 EGUs. Colvcr believes that PM CEMS cannot be used to demonstrate compliance with the new MATS Rule, The f-PIVI standards were lowered by 2/3rds. Starting in 2027, sources will be required to demonstrate compliance with a I'M CEMS on the more stringent IPM standards which are 0.010 lbs/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 Sierra Club FOIA 2025-EPA-04883 ED_Ol 8388_00000272-00002 SC_EVERSPLIT0006072