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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 Clinker Production for Holcim, 

Pursuant to Section 114(a) of the 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 of Environmental Quality (MDEQ) that stated it was withdrawing its efforts to 

adopt a state implementation plan (SIP) for regional haze under the 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 of the RHR under a federal implementation plan (FIP). See 

.Section 110(c)(l) of the Clean Air Act (CAA), 42 U.S.c. §7410(c)(l). 

As part of our effort to address requirements under the 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 of S02 and NOx emissions (rolling 30-day averages and annual); 

b.	 Total production (tons) clinker (monthly and annual); and 

c.	 Emissions in pounds of S02 and NOx per ton of clinker produced on a rolling 30-day average 

basis. 

Also, describe the source of the 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. 
.. 

This information must be submitted and received by EPA within seven calendar days of receipt as 

indicated by the certified receipt for this letter. Electronic submission is preferred. There will be no 

extension ofthis due date. Please submit your response to Vanessa Hinkle at hinkle.vanessa@epa.gov 

Pursuant to Section 114 ofthe Clean Air Act, 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 

particular rule the EPA is implementing. For example, Section 114(a)(l) says that the 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 authorized officer or agent of Holcim must certify as true, accurate, and complete the response to 

this 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 Hokim. 

Pursuant to Section 114(c) of the 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 of the submitted information. 

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 claim may only be made available to the public in 

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

However, please note that emission data provided 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 clinker production 

information will likely not be entitled to confidential treatment due to the fact that EPA has acquired 

identical information from state agencies on similar facilities and the information obtained is publically 

available. If you do claim confidentiality, we request that you submit that portion of the 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 information required by this letter in developing a FIP for 

regional haze pursuant to the CAA, in assisting in development of, or in reviewing, a regional haze SIP, 

or in carrying out our other responsibilities or actions under the CAA as described in Section 114(a) of 

the CAA. 

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

113(c)(2) of the CAA, as well as 18 U.S.C. §§lOOI and 1341. Failure to comply with the terms of this 

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 subject to the Paperwork Reduction Act of 1980, 44 U.S.C. §3501 

et seq. 
We appreciate your cooperation in this matter. 1f you have any questions please call Vanessa Hinkle, of 

my staff, at 303-312-6561. 

Sincerely, " 

/ 1Zi;gg;i;J, L - '- :t:/o//fA. P 

Callie Videtich 

Acting Assistant Regional Administrator 

Office of Partnerships and Regulatory Assistance 

Enclosures 

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