UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

1595 Wynkoop Street

DENVER, CO 80202·1129

Phone 800-227-8917

hllp:flwww.epa.gov/region08

NOV 0 5 2010

Ref: 8P-AR

CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Tracy Carter

Regional Vice President

Devon Gas Services. LP

20 North Broadway

Oklahoma Cily. Oklahoma 73 I02

RE: Request for Additional Reasonable Progress

Infonnation for the Devon Energy Production

Company I.P. Blaine County #1 Compressor

Station. Pursuant to Section I 14(a) ofthe Clean Air

Act (42 U.S.C. Scetion 74 I4(a»

Dear Mr. Carter:

As you know. on July 19.2006. the Environmental Protection Agency (EPA) received a

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

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

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

would not be addressing the requirements under 40 CFR 51.308. EPA Region 8 is moving

forward with the technical and policy work needed to implement the requirements ofthe RIIR

under a Federal implementation plan (FIP). Sec Section I 10(e)(I) ofthe Clean Air Act (CAA).

42 U.S.C §7410(e)(I).

As part of our elTort to address requirements under the RHR for reasonable progress (RP)

goals and strategies (see 40 CFR 51.308(d)( I) and 5 I.308(d)(3». we previously requested

infonnation regarding Devon Energy Production Company LP. Blaine County #1 Compressor

Station. We have reviewed the infonnation that you submined dated June 18.2009 in response

to our January 29. 2009 CAft. Section 114 infonnation request on the emission units at your

facility. Based on the emissions and current control technology information you submitted.

emission units I and 2 {5500 horse power. Ingersoll-Rand natural gas-tired compressor engines}

arc sources that warrant further analysis in considering and developing strategies for achieving

the RP goal for Montana.

Please submit an analysis of control options for these two units postmarked within 60

days of the date orthis kuer. The analysis must address the four factors included in
40 eFR § 51.308(dX I)(i)(J\). the costs of compliance. the time necessary for compliance. the

energy and non-air quality environmental impacts of compliance. and the remaining useful life of

the potentially affected sources. We suggest that the Best Available Retrofit Technology

(BART) Guidelines (see 40 erR Pan 51 Appendix Y) provide additional guidance on how to

pcrfonn the cost of compliance ponion ofthis analysis. Your analysis must consider the full

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

of emission standards including the mOSl stringent.

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

questions thal you may have on the RllR or the RP analysis. We will assist you in any way we

r.:an and look forward to working with you.

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

delegated to the undersigned. you are required to provide us with the infonnation speciJicd in this

letter. This infonnation will be used by EPA in developing a regional haze FIP, or in the event

MDEQ resumes development of a regional haze SIP. in assisting MDEQ in that effort and/or

reviewing a regional haze SIP for Monlana. Furthennorc. information requests pursuant to

Section 114 ofthe CAA are not limited to sources that arc regulated by the particular rule EPA is

implementing. For example. Section 114(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

infonnation necessary for the purposes set forth in this subsection:·

A duly authorized officer or agent of the facility must certify as true. accurate. and

complete the response to this infonnation by signing the enclosed Statement ofCertification and

returning it with the response. Such officer or agent must have sufficient knowledge and

authority to make such representations on behalf of Devon Energy Production Company LP.

Please submit your response to:

u.S. Environmental Protection Agency Region VlIl

1595 Wynkoop Street

Denver. CO 80202-1129

Attention: Vanessa Hinkle. 8P-AR

Pursuant to Section 114(e) ofthe CAA. 42 U.S.C. §7414(c). and 40 C.F.R. Part 2.

Subpart B. Devon Energy Production Company LP is entitled to assert a business confidentiality

claim covering any part of the submined infonnation. Attachment B specified the assertion and

substantiation requirements for business conlidentiality claims. Failure to assert such a claim

makes the submitted infonnation subject to public disclosure upon request and without further

notice to you. pursuant to the Freedom oflnfonnation Act. 5 U.S.c. Section 552. Infonnation

subject to a business cQnfidcntiality claim may only be made available to the public in

accordance with 40 C.F.R. Part 2. Subpart B.

.A knowing submittal of lalse information in response to this request may be actionable

lInder Section 113(e)(2) ufthe Ci\i\. as well as 18 U.S.c. §§ 1001 and 1341. Failure to comply

-2-
with thl.: terms of this request may subject Devon Energy Production Company LP to

enforcement action under Section 113 of the CAA. 42 U.S.C. §7413.

Also enclosed with this Request for Inlomlution is a Small Business Regulatory

Enforcement and Fairness Act (SBREFA) information sheet.

The requirements of this letter arc not subject to the Paperwork Reduction Act of 1980_

44 U.S.C. ~3501 ef self.

We appreciate your cooperation in this matter. If you have any questions pkasc call

Vanessa JIinkle 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. USFWS

'I'homas Dzomba. USFS

,

-y-