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

## 1'Q~2 20'2 Ref: 8P-AR CERTIFIED MAIL

- RETURN RECEIPT REQUESTED Mr. Greg Gannon Environmental Manager Holcim US, Inc. 4070 Trident Road Three Forks, Montana 59752 RE: Request for Additional Information Pertaining to Emissions and ClinkerProduction for Holcim, Pursuant to Section 114(a) ofthe Clean Air Act (42 U.S.C. Section 7414(a» Dear Mr. Gannon: As you know, on July 19, 2006, the Environmental Protection Agency (EPA) received a letter from the Montana Department ofEnvironmental Quality (MDEQ) that stated it was withdrawing its efforts to adopt a state implementationplan (SIP) for regional haze underthe EPA's Regional Haze Rule (RHR), found at 40 CFR 51.308. Due to Montana's announcement that it would not be addressing the requirements under 40 CFR 51.308, the 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 110(c)(l) ofthe Clean Air Act (CAA), 42 U.S.c. §7410(c)(l). As part ofour effort to address requirements underthe RHR for Best Available Retrofit Technology (BART) requirements (see 40 CFR 51.308(e», we are developing the BART requirements for the proposed rulemaking for the Montana FIP. Please submit the information requested below for the kiln for the most recent three years (2009-2011) for the Holcim facility near Three Forks, Montana:

a. Tons ofS02and NOx

### emissions (rolling 30-day averages and annual); b. Total production (tons) clinker (monthly and annual); and c. Emissions in pounds ofS02 and NOx

### perton ofclinker produced on a rolling 30-day average basis. Also, describe the source ofthe data and the methodology used in calculating items a through c. In addition, please submit documentation and results from the three most recent stack tests for particulate matter that were conducted while the kiln was operating at full capacity.

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This information mustbe submitted and received by EPA within seven calendar days ofreceipt as indicated by the certified receipt for this letter. Electronic submission is preferred. There will be no extension ofthis due date. Please submityourresponse to Vanessa Hinkle athinkle.vanessa@epa.gov Pursuant to Section 114 ofthe Clean AirAct, 42 U.S.C. §7414, and under authority duly delegated to the undersigned, you**l!re,J~quired** to provide us with the information specified in this letter. This information wiU,betlsed'15Vthe EPA in developing a regional haze FIP. Furthermore, information requests pursuant to Section 114 ofthe CAA are not limited to sources that are regulated by the particularrule the EPA is implementing. For example, Section 114(a)(l) says thatthe EPA may gather information from "anyperson who owns oroperates any emission source" or "whothe Administrator believes may have information necessary for the purposes set forth inthis subsection." A duly authorized officer or agent ofHolcim must certify as true, accurate, and complete the response to this information by signingthe enclosed StatementofCertification and returning it with the response. Suchofficer or agent must have sufficient knowledge and authority to make suchrepresentations on behalfofHokim. Pursuant to Section 114(c) ofthe CAA, 42 U.S.C. §7414(c), and 40 C.F.R. Part 2, Subpart B, Holcim is entitled to assert a business confidentiality claim covering any part ofthe submitted information. AttachmentB specifiesthe assertion and substantiation requirements for business confidentiality claims. Failure to assert such a claim makes the submitted informationsubject to public disclosure upon request and without further notice to you, pursuant to the Freedom ofInformation Act, 5 U.S.C. Section 552. Information subjectto a business confidentiality claim may only be made available to the public in accordance with40 C.F.R. Part 2, Subpart B. However, please note that emission dataprovided under Section 114 ofthe Act, 42 U.S.C. §7414, is not entitled to confidential treatment under 40 C.F.R. Part 2. EPA believes the monthly clinkerproduction information will likely not be entitled to confidential treatment due to the fact that EPAhas acquired identical information from state agencies on similar facilities andthe information obtained is publically available. Ifyou do claim confidentiality, we request that you submitthat portion ofthe response (only that specific portion for you are claiming confidential treatment) separately from all other information. The EPA has the authority to use any ofthe informationrequired bythis letter in developing a FIP for regional haze pursuantto the CAA, in assisting in development of, orinreviewing, a regional haze SIP, orin carrying out our otherresponsibilities or actions underthe CAA as described in Section 114(a) of the CAA. A knowing submittal offalse information in response to this request maybe actionable under Section 113(c)(2) ofthe CAA, as well as 18 U.S.C. §§lOOI and 1341. Failure to comply with the terms ofthis request may subject Holcim 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 Enforcement and Fairness Act (SBREFA) information sheet. The requirements ofthis letter are not subjectto the Paperwork Reduction Act of 1980, 44 U.S.C. §3501 

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### We appreciate your cooperation in this matter. 1fyou have any questions please call Vanessa Hinkle, of my staff, at 303-312-6561. Sincerely, " 

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# P Callie Videtich Acting Assistant Regional Administrator Office ofPartnerships and Regulatory Assistance Enclosures

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