May 26, 2005

JeffBriggs Smurfit-Stone Container Enterprises Missoula Mill P.O. Box4707 Missoula, MT 59806-4707 DearMr. Briggs: Under40 CFR 51.308(e)(1), the federal Regional Haze Rule requires states to identify all major stationary sources ofair pollution that are eligible for BestAvailable Retrofit Technology (BART). 

### In preparation ofthe upcomingRegional Haze State Implementation Plan (SIP), the Departmentof Environmental Quality (Department) hasbeen reviewing all facilities in Montana to determine which sources may be subject to the BARTregulations. 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 couldbe 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 "thatthe owneroroperatorhas obtained all necessary preconstruction approvals orpermitsrequired by Federal, State, or local air pollution emissions and air quality laws or regulations and either has (1) begun, or caused to begin, a continuousprogram ofphysical on-site construction ofthe facility or (2) entered into binding agreements or contractual obligations, which cannotbe cancelled or modified without substantial loss to the owner or operator, to undertake aprogram ofconstruction ofthe facility to be completed in a reasonable time (40 CFR 51.301)."


### • Reconstruction has taken place if"the fixed capital cost ofthe new component exceeds 50 percent ofthe fixed capital costofa 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) ofthis title," referring to the New Source Performance Standards definition ofreconstruction. To qualify as reconstruction, the reconstruction activity must have been "in existence" as defined in 40 CFR 51.30I." Based on the above criteria, please provideinformation regarding any new or reconstructed emissions units to the DepartmentbyJuly 26, 2005. Ifyou 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 SpecialistNovember 22, 2005
Jon Nickel ASARCO East Helena P.O. Box 1230 E. Helena, MT 59620 Dear Mr. Nickel: The Department ofEnvironmental 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 ofair pollution that are eligible for Best Available Retrofit Technology (BART). In preparation ofthe upcomingMontana Visibility Protection Plan, the Department has been reviewing all facilities in Montanato determine which sources may be subjecttothe BART regulations. The Department is requesting additional information to assist in the next phase ofthe BART-eligible determination. Please fill out the attached spreadsheetwith 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 PM10 emissions for the years 2001,2002, and 2003, will be used to conduct modelingto determine ifthe facility and the associated units impact visibility in any mandatory class I federal area. When compilingthe actual highest 24-hour emissions, please disregard periods ofstart-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. Ifyou have any questions regarding this request, please contact me at (406) 444-3626 orBob 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 ofthe 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 ofcompany-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, butwill hold ontothem 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 ofthe CALPUFF model for BART screening purposes. As explained at the stakeholders meetings, submission ofthe requested information is voluntary at this time but DEQ would greatly appreciate Columbia Falls Aluminum's (CFAC) cooperation in the early submission ofthis 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 ofthe potential BART-eligible units at your facility. Ifyour 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. Ifyou have questions that are specific to dispersion modeling, please contact John Coefield (444-5272) or Cyra Cain (444-3441) Please confirm receipt ofthis email. Thanks in advance for the cooperation! Bob

## BART-eligible Emitting Unit Data for Air Quality Dispersion Modeling

Year of 24-Hour 24-Hour Gas Exit Stack Inside Gas Exit Stack Height' Maximum Maximum Stack Coordinates Emitting Velocity Diameter Temperature Pollutant Emission Rate Emission Unit Rate Unlts6 Unit A Value Value Value Value Units4 Units5 Units1 2001-2003 X Y Datum2 Value Units4 NOx S02 PMlO Unit B NOx S02 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 ofthe 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 persecond and meters per second 

### In the absence ofcompany-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.docRHabeck, 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: Thankyou for submitting the requested information regarding stationary sources, includingreconstructed emission units at the Montana Sulphur & 

### Chemical Company (MSCC) facility as itrelated to the Best Available Retrofit Technology (BART) program found in40 CFR 51.300, 

### etseq. The Department ofEnvironmental Quality (Department) has reviewed the information submittedby BisonEngineering, Inc. (Bison), onbehalfofMSCC. Absent any additional informationto the contrary, the Departmentconcludedthatthe following units are BARTeligible:

• EU3

- 100-MeterATS-SRU Stack(Claw Reactor) • EU4

- 30-MeterATS-SRU Stack (Boilers and Process Units) • EU6

- Fuel Gas BoilerH-1 • EU7

- Fuel Gas BoilerH1-A • EU9

- Fuel Gas Boiler Hl-2 • EU11a - ExistingIncinerator The Department consulted with the U.S. Environmental Protection Agency (EPA) as to their interpretation ofthe word "reconstruction" as itrelates to arelocated unit. EPA statedthat the sourcerelated definitions inthe BARTprogram are to be interpreted consistent withthose inthe New Source Review (NSR) program. The NSRprogramtreats a relocation as a newconstruction, and therefore, EU6 and EU7 wouldbe considered a new source installedin 1969. EPA explained that the underlying intent ofthe definitions is similar inbothBARTandNSR. NSR is concerned with the effects ofstationary source emissions on ambient air, and similarly, inpart, BART-requirements are based on visibility effects specific to particular source location. When a source moves from locationto location, the ambient impacts change accordingly. The Departmentneeds additional informationto determine the reconstruction costs ofthe units. The costs presented in the September 2, 2005 letter are insufficient andnotconclusive. The Department'sposition is that three ofthe five Clause units are BARTeligible, andMSCC must submit a more convincing cost analysis to demonstrate otherwise. As discussed during the stakeholder's meetings for the MontanaVisibility Protection Plan, the Department intends to conducttrial runs ofthe CALPUFFmodel for BART screeningpurposes. As explained at the stakeholdersmeetings, submission ofthe requested information is voluntary at this time but the Departmentwould appreciate MSCC'scooperation in the early submission ofthis data. The Departmentbelieves that MSCC will benefit from the results ofthese screeningruns, because the company will have early access to modelingresults that couldbeused in planningpotential BART scenarios.

### Attached is an example table that shows the facility-specific dataneeded for CALPUFFmodeling of BART-eligible emitting units in the Regional Haze program. Please complete this table (expand it as needed) for all ofthepotential BART-eligible units atyour facility. Ifyour facility has any area sources that are potential BART-eligible units, you do notneed to include them on this modeling data form. Ifpossible, please submitthe requested information to BobJeffrey ormebyJune 16,2006. The information does nothave to be submitted in the exactformat ofthe attached file

- an alternative format is acceptable as long as it contains the necessary information. Ifyou 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 StackCoordinates

Y Datum2 Stack Heighe

Value Units4 StackInside Diameter
Value Units4 Gas Exit Temperature
Value Units5 Gas Exit Velocity
Value Units6 NOx SOz Total PM PM Condensable PM