Document wKzBqVGbwv1vDpV9Zm371O81B

47. Minnkota is harmed by having to comply with a New Mercury Limitation that is not achievable and is based on flawed and unsupported technical conclusions. THE NEW fPM LIMITATION WILL CAUSE IMMEDIATE AND IRREPARABLE HARM TO THE NORTH DAKOTA UTILITIES AND TO MINNKOTA 48. EPA's new fPM limit of 0.010 lb/MMBtu will require either the installation of a baghouse (fabric filter technology) or complete retrofit of electrostatic precipitators at MRY. Sec Sargent & Lundy, "Particulate & Mercury Control Technology Evaluation & Risk Assessment for Proposed MATS Rule Report," EPA-HQ-OAR-2018-0794-5978 (June 2023) [hereinafter MATS 2023 Study], Attachment E. 49. ESP improvements may result in fPM reductions. These upgrades would require substantial modifications, including structural support modification, and would represent substantial expenditures in cost per ton removed. Attachment E, at Section 2.3. -25- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000327-00077 SC_EVERSPLIT0006386