MONTANA SULPHUR & CHEMICAL COMPANY

627 ExxonMobil Road • P O Box 31118

Billings, Montana 59101 • Billings, Montana 59107-1118

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

February 6, 2012

Vanessa Hinkle, 8P-AR

U.S. Environmental Protection Agency

Region 8

1595 Wynkoop Street

Denver, CO 80202-1129

Dear Ms. Hinkle:

The attached report is our response to EPA’s letter dated December 30, 2011, 

postmarked January 3, 2012, and received January 6, 2012, requesting additional 

Reasonable Progress information for the Montana Sulphur & Chemical Company

(MSCC) facility located near Billings, Montana. As requested, MSCC has (via Bison 

Engineering, Inc.) conducted an analysis of “control options” for the potentially affected 

sulfur plant at the MSCC facility. The work addresses “SCOT” type technology, as we 

understood from discussion that it was specifically of interest. This work included, to the 

extent feasible given severe time restraints for response, the four factors included in 40 

CFR §51.308(d)(1)(i)(A): the costs of compliance, the time necessary for compliance, 

the energy and non-air quality impacts of compliance, and the remaining useful life of 

the potentially affected sources.

On January 13, 2012, we requested an extension to the 21-day deadline to respond to 

the request. EPA granted MSCC an extension until February 6, 2012. Although we 

appreciate the extension, the February 6, 2012, deadline did not allow MSCC to 

conduct as thorough an analysis of potential emission control technologies as would 

have been ideal. We believe that the short timeframe provided to MSCC limited the 

scope of this analysis. Given more time, MSCC/Bison would have contacted more 

vendors that specialize in emissions control at sulfur recovery plants, and possibly 

received additional responses from vendors contacted. Nonetheless, the attached 

report represents our best effort to respond to EPA’s request, given the limitation. If, 

despite evidence to the contrary found in the attached report, EPA determines that 

MSCC will be required to further study alternatives or further control emissions from the 

facility, we do not wish to be limited to the two example technologies identified in the 

attached report. This is a reasonable request given MSCC’s previous efforts to reduce 

emissions, such as installing two SuperClaus systems at the plant, and due to the 

limited timeframe provided to MSCC to respond to EPA’s January 2012 request for 

information.
If you have any questions or need further information, please contact me at MSCC

(406-252-9324), or Hal Robbins or Grant Rodway at Bison Engineering, Inc. (406-442-

5768). Similarly, as this process progresses, I would appreciate the opportunity to hear 

from you regarding any ideas or proposals that may be under consideration.

Sincerely,

Larry Zink

President

Enclosure
STATEMENT OF CERTIFICATION

I certify under penalty of law that I have personally examined and am familiar with the 

information submitted in this document and all attachments and that, based on my 

inquiry of those immediately responsible for obtaining this information, I believe that the 

information is true, accurate and complete. I am aware that there are significant 

penalties for submitting false information, including the possibility of fine or 

imprisonment.

Signature: ___________________________________

Title: ______________________________________

Date: _______________________________________