Ref: 8P-AR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

1595 Wynkoop Street

DENVER, CO 80202·1129

Phone 800-227·8917

http://www.epa.gov/regionOB

MAY 18 2011

CERTIFIED MAIL - RETURN RECEIPT REQUESTED

James M. Parker

Manager. Environmental Compliance Services

PPL Montana. LLC

303 N. Broadway, Suite 400

Billings. Montana 59101

RE: Response to Request for Additional Reasonable

Progress Information for PPL Montana. LLC. Units 3 and 4

at Colstrip, Pursuant to Section 114(a) ofthe Clean Air Act

(42 U.S.C- Section 74 I4(a))

Dear Mr. Parker:

Thank you for your response to our request for additional Reasonable Progress (RP) information for

PPL Montana. LLC. Units 3 and 4 at Colstrip, pursuant to Section 1I..J(a) of the Clean Air Act (CAA)

(42 U.S.c. Section 7414(a».ln your response dated January 31. 2011. you suggest that no further

engineering assessment is warranted for nitrogen oxides ( o.~) at this time for Colstrip Units 3 and 4

because you have implemented control technology lhat satisfies your permit obligations. We appreciate

lhc information you provided on the controls that were installed to satisfy lhe permit condition; however.

lhe complete information requested in our November 5. 2010 letter on potential additional controls for

NO.\ is required in support of the Regional Haze Federal Implementation Plan (rIP) for Montana. We

are required by 40 erR 51.308(d)(3) to consider emissions from major stationary sources in developing

our long term strategy lor the FIP.

We request that you submit an analysis. as we explained in our November letter. of additional control

options for NOx for Units 3 and 4 postmarked within 45 days of the date Oflhis letter. The analysis must

address 'he four factors included in 40 CFR 51.308(d)(1 )(i)(A) - the costs of compliance, the lime

necessary for compliance. the energy and non-air quality environmental impacts of compliance and the

remaining useful life of the potentially affected sources. The Best Available Retrofit Technology

(BART) Guidelines (see 40 eFR Part 51. Appendix Y) provide additional guidance on how to perform

the cost of compliance portion ofthis analysis. Your analysis must consider the full range of available

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

standards including the most stringent.

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

may have un the Regional Ilaze Rule or the RP analysis. We will assist you in any way we can and look

forward to working with you.
Pursuant to Section 114 of the CAA. 42 U.S.C. §7414. and under authority duly delegated to the

undersigned, you are required to provide us with the information specified in this letter. This

information will be used by EPA in developing a regional haze FIP, or in the event the Montana

Department of Environmental Quality (MDEQ) resumes development ofa regional haze State

Implementation Plan (SIP). in assisting MDEQ in that etTort and/or reviewing a regional haze SIP for

Montana. Furthermore. information requests pursuant to Section 114 ofthe CAA arc notlimiled to

sources that are 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 information necessary for the purposes set forth in this

subsection...

A duly aUlhorized orficer or agent of the facility must certify as true, accurate. and complete the

response to Ihis information 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 PPL Montana. LLC.

Please submit your response to:

U.S. Environmental Protcction Agency Region VfII

1595 Wynkoop Street

Denver. CO 80202-1129

Attention: Vanessa Hinkle, 8P-AR

Pursuant to Section 114(c) of the CAA. 42 U.S.c. §7414(c), and 40 C.F.R. Part 2. ubpart B, I'I'L

Montana LLC is entitled to assert a business confidentiality claim covering any pan ofthe submitted

information. The cnclosed Attachment B specifies the assertion and substantiation requirements for

business confidentiality claims. Failure to assert such a claim makes the submitted information subject

to public disclosure 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 confidentiality c1aimll1ay only

be made available to the public in accordance with 40 C.F.R. Part 2. Subpart B.

A knowing submittal of false information in response to this request may be actionable under Section

113(c)(2) of the CAA. as wel1 as 18 U.S.c. §§ 1001 and 1341. Failurc to comply with the terms of this

request may subject PPL 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 Enforcement and

Fainless Act information sheet.

The requirements of this letter are not subject to the Paperwork Reduction Act of 1980.

44 U.S.c. §3501 el seq.

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We appreciate your cooperation in this matter, If you have any questions please call Vanessa Hinkle. of

my stalT. 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

Thomas Dzomba. USFS

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