Document NEXp5oBV0dEmK5dxgeONk770p

OLYMPUS Power, LLC. i. I \1.H n Mr. Lee Zeldin, Administrator US Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Mail Code 1101A airaction@epa.gov March 28, 2025 Subject: Presidential Exemption, National Emissions Standards for Hazardous Air Pollutants: Coaland Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review (89 FR 38508; May 7, 2024) (MATS Rule), for Northampton Generating Unit 1 located in Northampton, Pennsylvania. Dear Administrator Zeldin: Olympus Power, LLC (Olympus) is writing to request a Presidential two-year exemption from the revised MATS rule Filterable Particulate Matter (FPM) emissions standard for Northampton Generating Unit 1. In the revised MATS rule not only was the numerical limit reduced by 67% from 0.030 pounds FPM/million British thermal units (lbs. FPM/MMBtu) to 0.010 lbs. FPM/MMBtu, but the compliance methodology was also changed from: requiring filterable particulate matter source emissions testing using the average of three test runs, in accordance with Table 5 to Subpart UUUUU of Part 63 -- Performance Testing Requirements, 1. Filterable Particulate matter (PM), Emissions Testing, to determine the emissions from the unit; to requiring the use of continuous filterable particulate matter continuous emissions monitoring system (FPM CEMS). Requiring FPM CEMS as the compliance methodology also changes the compliance averaging period from testing once every three years as a Filterable Particulate Matter Low Emitting Electric Generating Unit (FPM LEE) to continuous monitoring, FPM CEMS. The abandonment of the methodologies specified in the current Title 40 Part 63, Subpart UUUUU changes the limit far more dramatically and is far more stringent than just a change in the Sierra Club FOIA 2025-EPA-04883 ED_018388_00000245-00001 SC_EVERSPLIT0006013