MONTANA SULPHUR & CHEMICAL COMPANY 

627 ExxonMobii Road • POBox 31118 

Billings, Montana 59101 Billings, Montana 59107-1118 

Phone: (406)-252-9324 • Fax: (406) 252-8250 

January 13, 2012 

Vanessa Hinkle 

u.s. Environmental Protection Agency 

Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

RE: Request for Extension: "Reasonable Progress" for Montana Sulphur & Chemical 

Company. 

Dear Ms. Hinkle: 

Montana Sulphur & Chemical Co. (MSCC) has received the Section 114 request posted Jan 3 

from the Environmental Protection Agency (EPA) asking for information related to the Regional 

Haze Rule (RHR). We are not clear as to why this request has been issued at this time since we 

have understood that a proposed RHR FIP is to be issued quite soon; However, we want to 

cooperate with EPA's request and to provide information available to us, and to have 

constructive dialog with EPA on these matters. 

The EPA 114 request letter to MSCC is dated December 30, 2011. However, MSCC did not 

receive the letter until January 6,2012. It is not clear which date starts the 21 day clock that was 

stated in your letter. However, by the time MSCC received your letter, a full week had gone by 

and a good share ofthe stated 21-day period had passed. 

Since it is the start of a new year, our facility is engaged in many year-end monitoring and 

reporting requirements for numerous governmental agencies including EPA and the Montana 

Department of Environmental Quality. In addition, MSCC has recently been engaged in an 

OSHA inspection that is consuming considerable resources. All of these activities put a 

substantial strain on our small company. 

Further, it is clear in your letter that the information you receive from MSCC and decisions to be 

made regarding MSCC could significantly affect the future operation of MSCC. As a result, we 

are attempting to consider emission-reduction options and control cost estimates carefully. This 

is complex and will clearly take more time than has been provided in the 114 request. 

Regardless of our eventual response, please note that MSCC has, after careful consideration, 

taken considerable steps to reduce emissions from our facility over the past 10 or so years. In 

particular we note the following: 

(a) installation of a SuperClausTM unit 

(b) installation of a second redundant SuperClausTM unit; and 

(c) installation of a second redundant incinerator unit 

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These complex and difficult retrofits have already effectively addressed the preponderance of 

emissions from this small facility. MSCC has spent many millions of dollars to achieve these 

emission reductions, which have occurred in the period since the Regional Haze goals were 

established by Congress. 

As a result of these considerations, we hereby request an extension oftime to assemble 

information that EPA is seeking in your Section 114 request. MSCC is working with Bison 

Engineering in assembling information for this request. Specifically, we request an extension to 

February 24, 2012. 

We look forward to your earliest reply. If you have questions on this request, or can provide 

further guidance on what is actually sought and what specific further "options" EPA believes are 

available, please contact me at 406-252-9324, or Hal Robbins at Bison at 406-442-5768. I may 

also be r~ached by email atlarry@montanasulphur.com. . \ 

Sincerely, _, ' 

,~7 t~ {,Larry Zi U L. Preside 

Cc: Hal Robbins, Bison Engineering, Inc. 

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