UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGIONS

1595 Wynkoop Street

DENVER. CO 80202-1129

Phone 8QO.227-8917

http://INww.epa.gov/region08

NOV 1010

Ref: 8P-AR

CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Thomas Ray

Vice President Montana Opcmtions

Plum Creek Manufacturing

P.O. Box 5447

Kalispell. Montana 59903

RE: Request for Additional Reasonable Progress

Information for Plum Creek Manufacturing's

Evergreen Division and Columbia Falls Operations.

Pursuant to Section 114(a) of tile Clean Air Act

(42 U.S.c. Section 7414(a))

Dear Mr. Ray:

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 EPA's

Regional Haze Rule (RI-IR). found at 40 eFR 51.308. Due to Montana's announcement that it

would not be addressing the requirements under 40 eFR 51.308. 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). Sec Section 110(c)(I) of the Clean Air Act (CAA).

42 U.S.C. §741 O(c)(I).

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

goals and strategies (sec 40 CFR 51.308(d)(I) and 51.308(d)(3)). we previously requested

infonnation regarding Plum Creek Manufacturing's Evergreen Division and Columbia Falls

Operations. We have reviewed the infonnation that you submitted dated March 17. 2009 in

response to our January 29. 2009 eM Section 114 information request on the emission units at

your facilities. Based on the emissions and current control technology infonnation you

submitted. the Columbia Falls Operations' Riley Stoker Boiler and MDF Fiber Dryers and the

E~ergrL'Cn Division's Riley Stoker Boiler are sources that \\farrant further analysis in considering

and developing strategies for achieving the RP goal for Montana.

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

the date of this letter. The analysis must address the four factors included in
40 CFR § 51.308(d)( 1)(i)(A)· lhe costs of compliance. the lime necessary for compliance. lhe

~ncrgy and non-air quality environmental impacts of compliance. and the remaining uscfullife of

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

(BART) Guidelines (sec 40 CFR Part 51 Appendix Y) provide additional guidance on how 10

perform the cost of compliance ponioo of this analysis. Your analysis must consider the full

.range of available control technologies and for each technology. you must consider the full range:

of emission standards including the most stringent.

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

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

can ~nd look forward to working with you.

Pursuant to Section 114 of the Clean Air Act. 42 V.S.c. *7414. and under authority duly

delegated to the.undersigned. you arc required to provide us with the information specified in this

letter. This information will be used by EPA in dcveloping a regional haze FIP. or in the event

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

reviewing a regional haze SIP for Montana. Furthermore, information requcsts pursuant to

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

implementing. For example. Section 114(aXI) 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 subSt.'Ction:'

A duly authorized officer or agent of the facility must certify as truc. accuratc. 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 Plum Creek Manufacturing.

Please submit your response to:

U.S. Environmental Protection Agency Region VIII

1595 Wynkoop Street

Denver. CO 80202-1129

Attention: Vanessa Ilinkle. 8P-AR

Pursuant to Seelion I 14(e) of the CAA. 42 U.S.C. §7414(e). and 40 C.F.R. Part 2.

Subpart B. Plum Creek Manufacturing is entitled to assert a business confidentiality claim

covering any part ofthe submitted information. Attachment B specified the assertion and

substantiation requirements lor business confidentiality claims. Failure to assert such a claim

makes the submitted information subjcctlo public disclosure upon request and without further

notice to you. pursuant to [he 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 CF.R. Part 2. Subpart B.

A knowing submittal of false information in response to this requesl may be actionabk

under Section 113(c)(2) of the CAA. as well as 18 U.S.C §§1001 and 1341. Failure lo comply

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with thc tcrms of this request may subject Plum Creek Manufacturing to enforcement action

under Scction 113 oflhc CI\A. 42 U.S.c. §7413.

Also enclosed with this Request for Information is a Small Business Regulator)

Enforcement and Fairness Act (SBREFA) information shi..'Ct.

The requirements ofthis letter an: not subject to the Paperwork Reduction Act of 1980.

44 U.S.C. §3501 I!I seq.

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

Vanessa Hinkle army stalfat 303-312-6561.

Sincerely.

....- Stephen S. Tuber

Assistant Regional Administrator

Office of Partnerships and Regulatory Assistance

Enclosures

cc: John Bunyak. NPS

Sandra Silva. USFWS

Thnmas Ozomba. USFS

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