UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop Street DENVER, CO 80202-1129 Phone 800-227-8917 http://www.epa.gov/region08 

### NOV 0 5 1010 Rei' 8P-AR CERTIFIED MAIL

- RETURN RECEIPT REQUESTED James M. Parker Manager. Environmental Compliance Services PPL Monlana. LLC 303 N. Broadway. Suite400 Billings. Montana 59101 RE: Request for Additional Reasonable Progress 

### Information for PPJ. Montana. LLC. Units 3and 4 at Colstrip. Pursuant to Section 114(a) (lfthe Clean AirAct (42 U.S.c. Section 7414(a)) 

### DearMr. Parker: As you know. onJuly 19. 2006. the Environmental Protcction Agency (EPA) received a letter from the Montana DepartmentofEnvironmental Quality (MDEQ) that stated 

### it was \

....ithdrawing itsefforts to adopt a state implementation plan (SIP) for regional haze under EPA's Regional Haze Rule (RHR). found at40 CFR 51.308. Due to Montana's announcement that it would not be addressing the**requir~ments** under40 CFR 51.308. EPA Region 8 is moving forward with the technical and policy work needed to implement the requirements ofthe RHR under a Federal implementation plan (FIP). See Section IlO(c)( 1) ofthe Clean Air Act (CAA). 42 U.S.c. §7410(c)(I). As partofoureflortto address requirements under the RHR for rea'ionable progress (RP) goals and strategies (sec 40 CFR 51.308(d)(l) and 51.308(d)(3»). we previously requested infonnation regarding Colstrip Units 3 and 4. We have reviewed the information that you submitted dared March 31. 2009 in response to ourJanuary 29. 2009 CAA Section 11-1. infonnation request on Colstrip Units 3 and 4. Based on the emissions and currentcontrol technology information you submitted. Units 3 and 4 are sources that warrant furtheranalysis in considering and developing strategies for achieving the RP goal for Montana.
Please submit an analysis 

### 01"control ?ptions for these two units postmarked \vithin 60 days ofthe date ofthis letter. The analysis must address the four factors included in 40 CFR

# *51.308(d)(I)(i)(A)

- the costs ofcompliance. the lime neccssary for {,;ompliancc. the energy and non-airquality environmental impacts ofcompliancc. and the remaining uscfullifc o!" the potentially alTccted sources. We suggest that the Bcst Available Rctrolit Technology

## •
(BART) Guidelines (set.: 40 

### eFR Part 51 Appendix Y) provide additional guidance on how to 

### perform the costofcompliance portion ofthis analysis. Your analysis mustconsiderthe futl range ofavailable control technologies and for each technology. you must considerthe full range oremission standards induding"the most stringent.

We understand this is a complicated endeavor. and we arc available to answer any questions 

### that you may have on the 

### RrIR orthe RP analysis. We will assist you in any way we can and look t()fward to working with you. Pursuantto Section 114 ufthe Clean Air Act. 42 U.S.c. *7414. and under authority duly 

### delegated to the undersigned, you arc requiredto provide us with the information speciticd in this letter. This information will be used by EPA in developing a regional haze FIP. or in the event MDEQ resumes development oraregional haze 

### SIP, in assisting MDEQ in that effort and/or reviewing a regional haze SIP for Montana. Furthermore. information requests pursuant to Section 114 oftht: CAA are not limited to sources that are regulated by the particularrule EPA is implementing. Forexample. Section I I4(a)(I) says that EPA may gather information from "any person who owns or operates any emission source" or "who the Administratorbelieves may have information necessary for the purposes set forth in this**~ubsection.··** A duly authorized officeror agent ofthe facility must certify as true. accurate. and complete the response to this information by signing the enclosed Statement ofCertitication and returning it with the response. Such ofTiccr or agent must have sullicient knowledge and authority to make such representations on behalfof

### PPl Montana. LLC. Please submityourresponse to: U.S. Environmental Protection Agency Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Attention: Vanessa Ilinkle.**8p~AR** Pursuant to Section 114(e) ofthe CAA 42 USc. *7414(c), and 40 C.FK Part 2, Subpart B. PPL Montana LLC is entitled to assert a business confidentiality claim covering any part ofthe submitted information. Attachment B specified the assertion and substantiation requirements for business confidentiality claims. Failure to assert such a claim makes the submitted information subjectto public disclosurc upon request and without further notice to you. pursuantto the Freedom ofInformation Act. 5 U.S.c. Section 552. Information subject to a business conlidentiality claim may only be made available to the public in accordance with 4() C,LR, Part 2, Subpart 13,
A knowing submittal offalse information in response to this request may be actionable under Section lI3(c)(2) ofthe CAA. as well as 18 U.S.C. §§ 100I and 1341. Failure to comply with the terms ofthis request may subject PPJ. Montana LLC to enforcement action under Section 113 ofthe CAA. 42 U.S.c. §7413.Also enclosed with this Request for Information is a Small Business Regulatory**I~nforcemcnt** and Fairness Act (SI3REFA) infonnation shect. The requirements ofthis k:uer are not subject to the Paperwork Reduction Act of1980. 

### 44 lJ.S.c. *3501 el seq. We appn:ciah.:: your cooperation in 

### this maller. Ifyou have any questions ph.::ase call 

### V

ill1CSSa Hinklc ofmy staffat 

### 303·312-6561.Sincerely.

Stephen S. Tuber Assistant Regional Administrator Office ofPartnerships and Regulatory Assistance Enclosures

cc: John Bunyak. NPS Sandra Silva. lISFWS 

### Thomas Dzomba. USfS