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. Suite 400

Billings. Montana 59101

RE: Request for Additional Reasonable Progress

Information for PPJ. Montana. LLC. Units 3 and 4

at Colstrip. Pursuant to Section 114(a) (lfthe

Clean Air Act (42 U.S.c. Section 7414(a))

Dear Mr. Parker:

As you know. on July 19. 2006. the Environmental Protcction Agency (EPA) received a

letter from the Montana Department of Environmental Quality (MDEQ) that stated it was

\....ithdrawing its efforts to adopt a state implementation plan (SIP) for regional haze under EPA's

Regional Haze Rule (RHR). found at 40 CFR 51.308. Due to Montana's announcement that it

would not be addressing the requir~ments under 40 CFR 51.308. EPA Region 8 is moving

forward with the technical and policy work needed to implement the requirements of the 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 part of our eflortto 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 our January 29. 2009 CAA Section 11-1.

infonnation request on Colstrip Units 3 and 4. Based on the emissions and current control

technology information you submitted. Units 3 and 4 are sources that warrant further analysis 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 of the date of this letter. The analysis must address the four factors included in

40 CFR*51.308(d)( I)(i)(A) - the costs of compliance. the lime neccssary for {,;ompliancc. the

energy and non-air quality environmental impacts of compliancc. 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 cost of compliance portion of this analysis. Your analysis must consider the futl

range of available control technologies and for each technology. you must consider the full range

or emission 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 Rr IR or the RP analysis. We will assist you in any way we

can and look t()fward to working with you.

Pursuant to Section 114 ufthe Clean Air Act. 42 U.S.c. *7414. and under authority duly

delegated to the undersigned, you arc required to 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 ora regional 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 particular rule EPA is

implementing. For example. Section I I4(a)( I) says that EPA may gather information from "any

person who owns or operates any emission source" or "who the Administrator believes may have

information necessary for the purposes set forth in this ~ubsection.··

A duly authorized officer or agent of the 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 behalf of PPl Montana. LLC.

Please submit your response 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 of the submitted information. Attachment B specified the assertion and substantiation

requirements for business confidentiality claims. Failure to assert such a claim makes the

submitted information subject to public disclosurc upon request and without further notice to

you. pursuant to the Freedom of Information 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 of false information in response to this request may be actionable

under Section lI3(c)(2) of the CAA. as well as 18 U.S.C. §§ 100 I and 1341. Failure to comply

with the terms of this request may subject PPJ. Montana LLC to enforcement action under

Section 113 of the 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 of this k:uer are not subject to the Paperwork Reduction Act of 1980.

44 lJ.S.c. *3501 el seq.

We appn:ciah.:: your cooperation in this maller. If you have any questions ph.::ase call

Vill1CSSa Hinklc of my staff at 303·312-6561.

Sincerely.

Stephen S. Tuber

Assistant Regional Administrator

Office of Partnerships and Regulatory Assistance

Enclosures

cc: John Bunyak. NPS

Sandra Silva. lISFWS

Thomas Dzomba. USfS