UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8

1595 Wynkoop Street

DENVER, CO 80202·1129

Phone 800-227·8917

hllp:/Iwww.epa.gov/regionOB

Ref: 8P-AR

CERTIFIED MAli. - RETlJR RECEIPT REQUESTED

Kenneth Cole

Plant Manager

Roseburg Forest Products Company

P.O. Box 4007

Missoula. Montana 59806

RE: Request for Additional Reasonable Progress

Information for the Roseburg Forest Products

Company - Missoula Particleboard Facility

Pursuant to Section I 14(a) of the Clean Air Act

(42 U.S.C. Section 7414(a»)

Dear Mr. Cole:

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 stale implementation plan (SIP) for regional haze under EPA's

Regional Haze Rule (RHR), found at 40 eFR 51.308. Due to Montana's announcement that it

would not be addressing the requirements under 40 CFR 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). See Section IlO(c)( I) ofthe Clean Air Act (CAA).

42 U.s.C. §7410(c)(I).

As part of our effort to address requirements under the RHR for reasonable progress (RP)

goals and strategies (see 40 CFR 51 J08(d)( I) and 51.308(dX3)). we previously requested

infonnaLion regarding the Roseburg Forest Products Company's Missoula Particleboard Facility.

We have reviewed the infonnaLion that you submittcd dated April 14. 2009 in response to OUT

January 29. 2009 CAt\. Section 114 information request on the emission units at your facility.

Based on the emissions and current control technology infonnation you submitted. the sander

dust boiler and sander dust burners are sources that warrant further analysis in considering and

developing strategies tor achieving the RP goal for MonLana.

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)· the costs of compliance. the time necessary for compliancc. the
energy and non-air quality environmental impacts of compliance. and th~ remaining useful Ii fc of

the potentially atfected sources. We suggest that the Best Available Retrotit Technology

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

perfonll the cost of compliance portion of this analysis. Your analysis lllust consider the full

range of avuilable control technologies and for each technology. you lllust 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 thm you may have on the RHR or the RP analysis. We will assist you in any way we

can and look forward to working with you.

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

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

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

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

reviewing a regional haze SIP [or Montana. Furthennore. infonnation requests pursuant to

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

implementing. For example. Section 114(a)(1) says that EPA may gather infonnation from '·any

person who owns or operates any emission source" or "who the Administrator bdieves may have

infonnation necessary for the purposes set forth in this subsection."

A duly authorized officer or agent ofthe facility must certify as true. accurate, and

complete the response to this infonnation by signing the enclosed Statement of Certification and

returning it with the response. Such officer or agent must have sufficient knowledge and

authority to make such representations on behalf ofthe Roseburg Forest Products Company.

Please submit your response to:

U.s. Environmental Protection Agency Region VII1

1595 Wynkoop Street

Denver. CO 80202-1129

Attention: Vanessa Ilinkle, 8P-AR

Pursuant to Section 114(e) ofthe CAA. 42 U.S.c. §7414(c). and 40 C.F.R. Part 2.

Subpart B. Roseburg Forest Products Company is entitled to assert a business confidentiality

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

substantiation requirements f()r 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 oflnfonnation Act. 5 U.S.c. Section 552. Information

su~ject to a business confidentiality claim may only be made available to the public in

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

A knowing submittal of false infonnation in response to this request may be actionable

under Section I 13(c)(2) ofthe CAi\. as well as 18U.S.C. §§IOOI and 1341. Failure to comply

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with the terms of this request may subject Roseburg Forest Products Company to enforcement

action under Seetion 113 orthe CAlL 42 U.S.c. §7413.

Also enclosed with this Request for Information is a Small Business Regulatory

Enforcement and Fairness Aet (SBREFA) information sheet.

The requirements of this letter are nol subject to the Paperwork Reduction Act of 1980.

44 U.S.c. *35(1l el seq.

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

Vanessa f linkle of my starr at 303-312-6561.

Sincerely.

\ \\ . Lv"-

" r..-"'-

t- Stephen S. Tuber

Assistant Regional Administrator

Office of Partnerships and Regulatory Assistance

Enclosures

cc: John Bunyak. NPS

Sandra Silva. USFWS

Thomas Dzomba. USFS

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