Ref: 8P-AR UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595Wynkoop 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 3and 4 at Colstrip, Pursuant to Section 114(a) ofthe Clean AirAct (42 U.S.C- Section 74I4(a)) DearMr. 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) ofthe Clean AirAct (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 letteron potential additional controls for 

### NO.\ is required in supportofthe Regional Haze Federal Implementation Plan 

### (rIP) for Montana. We are required by 40

## erR 51.308(d)(3) to consideremissions from major stationary sources in developing our long term strategy lorthe FIP. We request that you submit an analysis. as we explained in ourNovember letter. ofadditional control options for 

### NOx for Units 3 and 4 postmarked within45 days ofthe date Oflhis letter. The analysis must address 'he four factors included in 40 CFR 51.308(d)(1 )(i)(A)

- the costs ofcompliance, the lime necessary for compliance. the energy and non-airquality environmental impacts ofcompliance and the remaining useful life ofthe potentially affected sources. The Best Available RetrofitTechnology (BART) Guidelines (see 40 eFR Part 51. Appendix Y) provide additional guidance on how to perform the cost ofcompliance portion ofthis analysis. Youranalysis must consider the full range ofavailable control technologies. and for each technology. you must also considerthe full range ofemission standards including the most stringent. We understand this is acomplicated endeavor. and we are available to answerany 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 ofthe CAA. 42 U.S.C. §7414. and underauthority 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 ofEnvironmental 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 particularrule EPA is implementing. Forexample. Section 114(a)(I) says that EPA may gather information from "any person who owns oroperates any emission source" or "who the Administrator believes may have information necessary for the purposes set forth in this subsection

... Aduly aUlhorized orficeror agent ofthe facility mustcertify as true, accurate. and complete the response to Ihis information by signing the enclosed Statement ofCertification and returning it with the response. Such officeroragent must have sufficient knowledge and authority to make such representations on behalfofPPL Montana. LLC. Please submit yourresponse 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) ofthe CAA. 42 U.S.c. §7414(c), and 40 C.F.R. Part2. ubpart B, I'I'L Montana LLC is entitled to asserta business confidentialityclaim covering any panofthe submitted information. The cnclosed Attachment B specifies the assertion and substantiation requirements for business confidentiality claims. Failure to assert such aclaim 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 abusiness confidentiality c1aimll1ay only be made available to the public in accordance with40 C.F.R. Part 2. Subpart B. A knowing submittal offalse information in response to this request may be actionable under Section 113(c)(2) ofthe CAA. as wel1 as 18 U.S.c. §§ 1001 and 1341. Failurc to comply with the terms ofthis request may subject PPL Montana LLC to enforcement action underSection 113 ofthe 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 ofthis letterare not subject to the Paperwork Reduction Act of 1980. 44 U.S.c. §3501 elseq.



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### We appreciate yourcooperation in this matter, Ifyou 

### have any questions pleasecall Vanessa Hinkle. of my stalT. at (303) 312-6561. 

### Sincerely.

Stephen S. Tuber 

### Assistant Regional Administrator Office

### ofPartnershipsand Regulatory Assistance

Enclosures

cc: John Bunyak. NPS Sandra Silva. USFWS 

### Thomas Dzomba. 

### USFS



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