## MONTANA SULPHUR & 

## CHEMICAL COMPANY 627 ExxonMobii Road • POBox31118 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: "ReasonableProgress" for Montana Sulphur & 

### Chemical Company.
Dear Ms. Hinkle:
Montana Sulphur & Chemical Co. (MSCC) has received the Section 114 request postedJan 3 from the Environmental Protection Agency (EPA) asking for informationrelated 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 RHRFIP 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 onthese matters. The EPA 114 request letterto MSCC is dated December 30, 2011. However, MSCC did not receive the letter until January 6,2012. Itis not clearwhich date starts the 21 day clockthat 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-dayperiodhad passed.
Since it is the start ofanew year, ourfacility is engaged in many year-end monitoring and reporting requirements for numerous governmental agencies including EPA and the Montana Department ofEnvironmental Quality. In addition, MSCC has recently beenengaged in an OSHA inspectionthat is consuming considerable resources. All ofthese activities put a substantial strain on our small company. Further, it is clear in your letterthat the information you receive from MSCC and decisions to be made regarding MSCC could significantly affect the future operation ofMSCC. As a result, we are attempting to consider emission-reduction options and control costestimates carefully. This is complex and will clearly take more time than has beenprovided inthe 114 request. Regardless ofoureventual response, please note that MSCC has, after careful consideration, taken considerable steps to reduce emissions from our facility overthe past 10 or so years. In particular we note the following: (a) installation ofa SuperClausTM unit (b) installation ofa second redundant SuperClausTM unit; and (c) installation ofa secondredundant incinerator unit
Page 1of2These complex and difficult retrofits have already effectively addressed the preponderance of emissions from this small facility. MSCC has spent many millions ofdollars to achieve these emissionreductions, which have occurred in the period since the Regional Haze goals were established by Congress.
As a result ofthese 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 extensionto February 24, 2012.
We look forward to your earliestreply. Ifyou have questions onthis request, orcanprovide 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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