Document gDRX8aDXpLze12eE1a5LQ3OMJ

TALEN I'll MONTANA cost EPA attributes for Colstrip to comply with 0.015 lb/MM13tu, 0.010 lb/MMBtu, and 0.006 lb/MM13tu f-PM limits: Table 1: Annual Costs 13) Potential fPNI Standard Annualized Casts Total of All Facilities41 Colstrip`12 0.015 lb/NIMBtu $13-9-519.3M Unit 3: $843,600 Unit 4: $843,600 Total: S1,687,200 PotentialIPM Standard 0.010 lb/NIMBtu 0.006 lb/MNIBto $77.3-593.2M $633M Unit 3: $18,992,866 Unit 3: $18,992,866 Unit 4:519,058,306 Unit 4: $19,058,306 Total: $38,051,172 Total: 538,051,172 As reflected by EPA's own numbers, the annualized cost for Colstrip to comply with the proposed 0.010 lb/MMBtu fPM limit is approximately $38M, which represents 41-49% of the total annualized cost of the Proposed Rule. This means that EPA is asking the owners of one facility representing 0.7% of EGUs subject to the Proposed Rule -- to bear nearly 50% of the costs associated with the proposed amendment.'1'his result is grossly unreasonable, unwarrantcd, and inconsistent with EPA's rationale for the Proposed Rule and should not be finalized. EPA's cost effectiveness analysis isflawed Additionally, EPA's proposal to tighten the f-PM standard is arbitrary and capricious because the Agency's cost-benefit analysis is flawcd. First, EPA overestimated the benefits attributed to Colstrip if Colstrip were to comply with the 0.010 lb/MMBtu fPM limit. Below is a table summarizing the total fPM omission reductions calculated by EPA and the fPM emission reduction from Colstrip (as calculated by EPA) if Colstrip were to comply with a 0.015 lb/MM13tu, 0.010 lb/MMBtu, and 0.006 lb/MM13tu f-PM limits. 4- 'Fable 7, Technical Memo at p 12 Appendix I), id. at PI)F p 80 (total annuali7ed costs for Colstrip is calculated by summing the annuali7ed costs for Units 3 and 4). See ni. at PI)F p 2 (evaluating rates from a total of 275 individuals with Colstrip representing two of those 14 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000307-00015 SC_EVERSPLIT0006111