May 26, 2005 

Jeff Briggs 

Smurfit-Stone Container Enterprises 

Missoula Mill 

P.O. Box 4707 

Missoula, MT 59806-4707 

Dear Mr. Briggs: 

Under 40 CFR 51.308(e)( 1), the federal Regional Haze Rule requires states to identify all major 

stationary sources of air pollution that are eligible for Best Available Retrofit Technology (BART). In 

preparation of the upcoming Regional Haze State Implementation Plan (SIP), the Department of 

Environmental Quality (Department) has been reviewing all facilities in Montana to determine which 

sources may be subject to the BART regulations. 

To assist with this determination, the Department is requesting information regarding all new or 

reconstructed emissions units that were in existence between August 7, 1962 and August 7, 1977. Please 

provide the date the unit could be deemed "in existence", the Potential to Emit (PTE) for the unit, and 

whether the unit is still in operation. Please note the following definitions: 

•	 In existence means "that the owner or operator has obtained all necessary preconstruction 

approvals or permits required by Federal, State, or local air pollution emissions and air quality 

laws or regulations and either has (1) begun, or caused to begin, a continuous program ofphysical 

on-site construction of the facility or (2) entered into binding agreements or contractual 

obligations, which cannot be cancelled or modified without substantial loss to the owner or 

operator, to undertake a program of construction of the facility to be completed in a reasonable 

time (40 CFR 51.301)." 

•	 Reconstruction has taken place if "the fixed capital cost of the new component exceeds 50 

percent of the fixed capital cost of a comparable entirely new source." In addition, the regulation 

states, "any final decision as to whether reconstruction has occurred must be made in accordance 

with the provisions of §60.15(f)(1) through (3) of this title," referring to the New Source 

Performance Standards definition of reconstruction. To qualify as reconstruction, the 

reconstruction activity must have been "in existence" as defined in 40 CFR 51.30 I." 

Based on the above criteria, please provide information regarding any new or reconstructed emissions 

units to the Department by July 26, 2005. If you have any questions regarding this request, please contact 

me at (406) 444-3403 or Debbie Skibicki (in the Air Permitting Section) at (406) 444-1472. 

Sincerely, 

Trista Glazier 

Air Quality Specialist 
November 22, 2005 

Jon Nickel 

ASARCO 

East Helena 

P.O. Box 1230 

E. Helena, MT 59620 

Dear Mr. Nickel: 

The Department of Environmental Quality (Department) thanks you for your recent submittal of 

requested information regarding stationary sources, including reconstructed emission units, that were in 

existence on August 7, 1962, and operating on August 7, 1977. As previously discussed, under 40 CFR 

5l.308(e)( I), the federal Regional Haze Rule requires states to identify all major stationary sources of air 

pollution that are eligible for Best Available Retrofit Technology (BART). In preparation of the 

upcoming Montana Visibility Protection Plan, the Department has been reviewing all facilities in 

Montana to determine which sources may be subject to the BART regulations. 

The Department is requesting additional information to assist in the next phase ofthe BART-eligible 

determination. Please fill out the attached spreadsheet with the required information that has not 

previously been submitted for the potential BART-eligible units. The information in the column 

requesting actual highest 24-hour S02, NOx, and PM 10 emissions for the years 200 1,2002, and 2003, 

will be used to conduct modeling to determine ifthe facility and the associated units impact visibility in 

any mandatory class I federal area. When compiling the actual highest 24-hour emissions, please 

disregard periods of start-up, shutdown, and/or maintenance. Ifthis information is not sUbmitted, the 

Department will use the estimated allowable emissions for those units. 

Based on the above criteria, please provide the requested data to the Department by December 22,2005. 

If you have any questions regarding this request, please contact me at (406) 444-3626 or Bob Jeffrey at 

(406) 444-5280. 

Sincerely, 

Julie Merkel 

Air Quality Specialist 

Air Resources Management Bureau 

jmerkel@mt.gov 
BART-eligible Emitting Unit Data for Air Quality Dispersion Modeling
 

Emitting 

Unit Pollutant 

24·Hour 

Maximum 

Emission Rate 

Value Units1 

Year of 

24-Hour 

Maximum 

Emission 

Rate 

2001·2003 

Stack Coordinates 

X Y Datum2 

Stack Height' 

Value Units· 

Stack Inside 

Diameter 

Value Units· 

Gas Exit 

Temperature 

Value Units5 

Gas Exit 

Velocity 

Value Units' 

Unit A NOx 

802 

PM,o 

Unit B NOx 

802 

PM10 

Unit C, D, E, (etc.): The previous 3 rows are repeated for each BART-eligible emitting unit located at the same facility. 

, Typical emission rate units are tons per day and pounds per day 

2 Typical stack coordinates are latitude/longitude or Universe Transverse Mercator (for both, the datum must be specified, e.g., NAD27 or NAD83) 

3 Supply both stack height above ground level and the elevation of the stack base 

4 Typical units for stack heights and inside stack diameters are feet and meters 

5 Typical units for gas exit temperatures are degrees Fahrenheit, Centigrade or Kelvin 

6 Typical units for gas exit velocity are feet per second and meters per second 

In the absence of company-reported data, the Department will obtain stack parameters from previous modeling 

demonstrations, stack tests, Title V permit applications, etc. The stack elevations will be estimated using Digital Elevation 

Models derived from USGS 1:24,000 topographic maps. Building wake effects (downwash) will not be considered. 

15 March 2006 BART_Source_EUnit_ModeUnputs_Table.doc 
-Habeck, Bob­ To Laurel Dygowski/P2/R8/USEPAlUS@EPA 

<bhabeck@mt.gov> 

cc 

06/211200601 :36 PM 

bee 

Subject FW: CFAC BART CALPUFF Modeling Data Request 

This is what I call "BART Letter #3" it was only e-mailed • no hard copy. I believe 

there was only 3 BART letters in total· all asking for information. We have 

company responses, but will hold onto them upon your request. 

From: Jeffrey, Robert 

Sent: Wednesday, June 21, 2006 1:29 PM 

To: Habeck, Bob 

Subject: FW: CFAC BART CALPUFF Modeling Data Request 

Importance: High 

From: Jeffrey, Robert 

Sent: Wednesday, April 12, 2006 12:07 PM 

To: Steve Wright 

Cc: Merkel, Julie; cain, cyra; Coefteld, John; Gallagher, Robert 

Subject: CFAC BART CALPUFF Modeling Data Request 

Importance: High 

Hi Steve, 

As discussed during the stakeholder's meetings for the Montana Visibility Protection Plan, the Montana 

Department of Environmental Quality (DEQ) intends to conduct trial runs of the CALPUFF model for 

BART screening purposes. As explained at the stakeholders meetings, submission of the requested 

information is voluntary at this time but DEQ would greatly appreciate Columbia Falls Aluminum's (CFAC) 

cooperation in the early submission of this data. DEQ believes that CFAC will benefit from the results of 

these screening runs, since the company will have early access to modeling results that could be used in 

future planning for potential BART scenarios. 

I've attached an example table that shows the facility-specific data needed for CALPUFF modeling of 

BART-eligible emitting units in the Regional Haze program. Please complete this table (expand it as 

needed) for all of the potential BART-eligible units at your facility. If your facility has any area sources that 

are potential BART-eligible units, you do not need to include them on this modeling data form. 

If possible, please submit the requested information to Julie Merkel or me by COB on Thursday, 27 April 

2006. The information does not have to be submitted in the exact format of the attached file - an 

alternative format is acceptable as long as it contains the necessary information. If you have questions 

that are specific to dispersion modeling, please contact John Coefield (444-5272) or Cyra Cain (444-3441) 

Please confirm receipt of this email. Thanks in advance for the cooperation! Bob 
BART-eligible Emitting Unit Data for Air Quality Dispersion Modeling
 

Year of 

24-Hour 24-Hour Stack Inside Gas Exit Gas Exit Maximum Maximum Stack Coordinates Stack Height' Emitting Diameter Temperature Velocity Pollutant Emission Rate Emission Unit 

Rate 

Unlts6 

Unit A 

Value Value Units Value Value 4 Units5 Units1 2001-2003 X Y Datum2 Value Units4 

NOx 

S02 

PMlO
 

Unit B
 NOx 

S0 2 

PM,o
 

Unit C, 0, E, (etc.): The previous 3 rows are repeated for each BART-eligible emitting unit located at the same facility.
 -

1 Typical emission rate units are tons per day and pounds per day 

2 Typical stack coordinates are latitude/longitude or Universe Transverse Mercator (for both, the datum must be specified, e.g., NAD27 or NAD83) 

3 Supply both stack height above ground level and the elevation of the stack base 

4 Typical units for stack heights and inside stack diameters are feet and meters 

5 Typical units for gas exit temperatures are degrees Fahrenheit, Centigrade or Kelvin 

6 Typical units for gas exit velocity are feet per second and meters per second 

In the absence of company-reported data, the Department will obtain stack parameters from previous modeling 

demonstrations, stack tests, Title V permit applications. etc. The stack elevations will be estimated using Digital Elevation 

Models derived from USGS 1:24,000 topographic maps. Building wake effects (downwash) will not be considered. 

15 March 2006 BART_Source_EUnil_ModeUnputs_Table.doc 
RHabeck, BobR 

<bhabeck@mt.goY> 

06/21/200601 :59 PM 

To 

cc 

bcc 

Laurel Dygowski/P2/R8/USEPAlUS@EPA 

Subject FW: BART info 

more stuff 

From: Merkel, Julie
 

Sent: Wednesday, June 21, 2006 1:48 PM
 

To: Habeck, Bob
 

Subject: BART info
 

Bob -­

The only thing I have in my files that is not on the web or in your files is the letter #3 to Montana
 

Sulpher and Chemical Company, which was different from the other #3 letters -- it is attached.
 

Let me know if I can help you find any additional information.
 

Julie MSCC BARTJellerJUdoc 
May 18,2006 

Larry Zink 

Montana Sulphur & Chemical Company 

P.O. Box 31118 

Billings, MT 59107 

Dear Mr. Zink: 

Thank you for submitting the requested information regarding stationary sources, including reconstructed 

emission units at the Montana Sulphur & Chemical Company (MSCC) facility as it related to the Best 

Available Retrofit Technology (BART) program found in 40 CFR 51.300, et seq. 

The Department of Environmental Quality (Department) has reviewed the information submitted by 

Bison Engineering, Inc. (Bison), on behalf of MSCC. Absent any additional information to the contrary, 

the Department concluded that the following units are BART eligible: 

• EU3 - 100-Meter ATS-SRU Stack (Claw Reactor) 

• EU4 - 30-Meter ATS-SRU Stack (Boilers and Process Units) 

• EU6 - Fuel Gas Boiler H-1 

• EU7 - Fuel Gas Boiler H1-A 

• EU9 - Fuel Gas Boiler Hl-2 

• EU11 a - Existing Incinerator 

The Department consulted with the U.S. Environmental Protection Agency (EPA) as to their 

interpretation of the word "reconstruction" as it relates to a relocated unit. EPA stated that the sourcerelated definitions in the BART program are to be interpreted consistent with those in the New Source 

Review (NSR) program. The NSR program treats a relocation as a new construction, and therefore, EU6 

and EU7 would be considered a new source installed in 1969. EPA explained that the underlying intent 

of the definitions is similar in both BART and NSR. NSR is concerned with the effects of stationary 

source emissions on ambient air, and similarly, in part, BART-requirements are based on visibility 

effects specific to particular source location. When a source moves from location to location, the ambient 

impacts change accordingly. 

The Department needs additional information to determine the reconstruction costs of the units. The costs 

presented in the September 2, 2005 letter are insufficient and not conclusive. The Department's position 

is that three ofthe five Clause units are BART eligible, and MSCC must submit a more convincing cost 

analysis to demonstrate otherwise. 

As discussed during the stakeholder's meetings for the Montana Visibility Protection Plan, the 

Department intends to conduct trial runs of the CALPUFF model for BART screening purposes. As 

explained at the stakeholders meetings, submission of the requested information is voluntary at this time 

but the Department would appreciate MSCC's cooperation in the early submission of this data. The 

Department believes that MSCC will benefit from the results of these screening runs, because the 

company will have early access to modeling results that could be used in planning potential BART 

scenarios. 
Attached is an example table that shows the facility-specific data needed for CALPUFF modeling of 

BART-eligible emitting units in the Regional Haze program. Please complete this table (expand it as 

needed) for all ofthe potential BART-eligible units at your facility. If your facility has any area sources 

that are potential BART-eligible units, you do not need to include them on this modeling data form. 

Ifpossible, please submit the requested information to Bob Jeffrey or me by June 16,2006. The 

information does not have to be submitted in the exact format of the attached file - an alternative format is 

acceptable as long as it contains the necessary information. If you have questions that are specific to 

dispersion modeling, please contact John Coefie1d (444-5272) or Cyra Cain (444-3441) 

Sincerely, 

Julie Merkel 

Air Quality Specialist 

Air Resources Management Bureau 

Email: jmerkel@mt.gov 
BART-eligible Emitting Unit Data for Air Quality Dispersion Modeling 

MSCC
 

Emitting 

Unit Pollutant 

24-Hour 

Maximum 

Emission Rate 

Valu Units! e 

Year of 

24-Hour 

Maximum 

Emission 

Rate 

2001-2003 X 

Stack Coordinates 

Y Datum2 

Stack Heighe 

Value Units4 

Stack Inside 

Diameter 

Value Units4 

Gas Exit 

Temperature 

Value Units5 

Gas Exit 

Velocity 

Value Units6 

NOx 

SOz 

Total PM 

PM 

Condensable 

PM