Document eDbYRrO70RLKxxyG1GzLGERm

Comments at 23 (citing PM CEMS Technical Memo at 5). EPA was, thus, forced to address these issues in the final MATS RTR by loosening the QA criterion and correlation procedures. See 89 Fed. Reg. at 38,528-29. However, it has not yet been shown that these changes are enough to address the fundamental issue that PM CFMS has difficulty reliably measuring such low fPM levels due to the error rates of the instrument. See PUEN Comments at 23 (finding insurmountable the "uncertainties inherent the in the measurement device" and the "problems associated with relative size of the uncertainty to the limited data range of fPM concentrations and the confidence levels and tolerances"); sec al.w) Class of '85 Comments at 18. And, in reality, units would need to target emissions below 0.010 lb/MMbtu in order to ensure continuous compliance. See I'et'rs' Brief at 72. fherefore, the CEMS technology to demonstrate compliance with the revised !PM standard is unavailable. Second, there are significant costs and market limitations associated with PM CFMS, which make it "not available." Installing and operating CEMS is more costly than stack testing. See PGEN Comments at 25-26. Costs include purchasing and installation of CEMS, as well as potential modifications to the units to accommodate CFMS, extended correlation testing, and annual operational costs. Sec id. at 26; .see also Class of '85 Comments at 18 (estimating $180,000 to $400,000 for "site preparation and engineering analysis. analyzer equipment and installation costs, and initial PS-11 correlation testing"). fhis does not include the costs of maintaining a fulltime employee to operate PM CEMS and the costs of lost generation during testing events for CEMS. I.uminant Comments at 16-17. There are also market factors which limit the availability of installing and operating CEMS by the compliance deadline. There are a limited number of vendors for CEMS, as well as a limited number of professionals certified to install and test CEMS. Currently, two-thirds of facilities utilize stack testing and would need to install CF.MS by July 2027, which would overwhelm the current supply of CEMS and the availability of professionals certified to inspect and test the newly installed systems. See Class of '85 Comments at 16. III. It is in the Interest of National Security to Issue an Exemption for the Rule The requested exemptions from the MATS RTR are in the national security interests of the United States. The Rule adversely affects the nation's energy generation capacity and threatens grid stability and the supply of affordable, reliable energy. The Rule's stringent limits and the high costs associated with compliance, particularly in combination with other rulemakings impacting coal-fired ECUs, places a considerable burden on the operation of Miami Fort. And MATS rules have historically resulted in the loss of generation capabilities--the 2012 MATS rule resulted in the retirement of approximately 60,000 MW of coal-fired capacity. Pet'rs' Brief at 23. As explained in I.uminant's Comments., coal plants "continue to be of paramount importance for grid reliability during the transition to renewables." Id. at 29. Energy generation and grid reliability have been identified by the President as issues of national security and it is, therefore, in the interest ofthe nation to exempt sources from compliance with the MATS RTR. As set forth in President Trump's Executive Order ("F.0.") 14156, Declaring a :Valional Energy Emergency, the "generation capacity of the United States [is] ... far too inadequate to meet our Nation's needs" and "a reliable, diversified, and affordable supply of energy" is necessary to ensure "military preparedness." 90 Fed. Reg. 8,433, 8,433 (Jan. 29, 2025). The F.O. continues, "integrity . . . of our Nation's energy infrastructure--from coast to coast--is 4 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000163-00004 SC_EVERSPLIT0005938