### Enclosure 3 EPA's Information Gathering Authority Under Section 114 of the Clean Air Act
Under Section 114 of the Act (42 U.S.C. 7414), Congress has given the U.S. Environmental Protection Agency broad authority to secure informat ion needed "for the purpose of (i) developing or assisting in the development of any implementation pl an under Section 110 or 111(d), any standard of performance under Section 111, or any emission standard under Section 112, (ii) determining whether any person is in violation of any such standard of any requirement of such a plan, or (iii) carrying out any provision of this Act." Amount other things, S ection 114 authorizes EPA to make inspections, conduct tests, examine records, and require owners or operators of emission sources to submit information reasonably required for the purpose of developing such st andards. In addition, the EPA Office of General Counsel has interpreted Section 114 to include authority to photograph or require submission of photographs of pertinent equipment, emissions, or both.
Under Section 114, EPA is empowered to obtain information described by that section even if you consider it to be confidential. You may, how ever, request that EPA treat such information as confidential. Information obtained under Section 114 and covered by su ch a request will ordinarily be released to the public only if EPA determines that the information is not entitled to confidential treatment. 1 

### Procedures to be used for making c onfidentiality determinations, substantive criteria to be used in such determinations, and special rules governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the Federal Register on September 1, 1976 (40 FR 36902).
Pursuant to § 2.204(a) of EPA's Freedom of Information Act (FOIA) regulation, in the event a request is received, or it is determined that a request is likely to be received, or EPA desires to determine whether business information in its possession is entitled to confidential treatment even though no request for release of the information has been received, plea se be advised that EPA will seek, at that time, the following information to support your claim as required by § 2.204(e)(4) of EPA's FOIA regulations:
1. Measures taken by your company to guard against undesired disclosure of the information to others;

2. The extent to which the information has been disclosed to others, and the precautions taken in connection therewith;

3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy of any such determinations, or reference to it, if available; and

4. Whether your company asserts that disclosure of the information would be likely to result in substantial harmful effects on the business' competitive position, and if so, what those harmful effects would be, why they should be viewed as s ubstantial, and an explanation of the causal relationship between disclosure and such harmful effects. 1

1 

### Section 114 requires public availability of all emission data and authorizes disclosure of confidential information in certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976).


## 1 of 17042 

### Enclosure 4

Federal Register I Vol 56. No. 35 I Thursday, February 21, 1991 I Notices

[AD-FRL-3906-3]

Disclosure of Emission Data Claimed as Confidential Under Sections 110 and 114(c) of the Clean Air Act

AGENCY: Environmental Protection Agency (EPA) ACTION: Notice of policy on public release of certain emission data submitted under sections 110 and I l4(c) of the Clean Air Act (CAA).
SUMMARY: Section 114(c) of the CAA excludes emission data from the general definition of trade secret information. Certain classes of data submitted to the EPA under sections 110 and 114(a) of the CAA are emission data, and, as such, cannot be withheld from disclosure as confidential pursuant to section 1905 of title 18 of the United States Code. This notice clarifies EPA's current policy, and solicits comment regarding that policy and categories of data which it considers excluded from a trade secret definition. DATES: Written comments pertaining to this notice are requested by April 22, 1991. ADDRESSES: Submit comments to: Nancy D. Riley, U.S. Environmental Protection Agency, Emission Standards Division, Pollutant Assessment Branch (MD-I3), Research Triangle Park, NC 21111. FOR FURTHER INFORMAnON CONTACT: Timothy Mohin (telephone: (919) 541·5349 commercial/FTS 629-5349) or Karen Blanchard (telephone: (919) 541- 5503 commerciallFTS 629-5503), Pollutant Assessment Branch (MD-I3), Emission Standards Division; or Thomas Rosendahl (telephone: (919) 541-5404 commerciallFTS 629-5404), National Air Data Branch (MD-14), Technical Support Division; U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27111. SUPPLEMENTARY INFORMATION: The EPA routinely uses the authority of sections 110 and 114(a) of the CAA to gather technical information from industries involved in operations that lead to emission of pollutants to the ambient air. This information has been used, among other things, to better characterize emitting facilities and to evaluate the need for and impacts of potential regulation. Information requests under sections 110 and 114(a) of the CAA typically include questions on uncontrolled and controlled emission rates and emission parameters of the pollutant or group of pollutants of concern. The respondents sometimes claim that its response constitutes trade secret information, and thus, should be treated as confidential. Claims of confidentiality may be made under section 114(c) of the CAA, which states no 0 0 upon a showing satisfactory to the Administrator by any person that records, reports, or information, or a particular part thereof, (other than emission data) to which the Administrator has access under this section ifmade public, would divulge methods or processes entitled to protection as trade secrets of such person, the Administrator shall consider such 0 0 0 confidential in accordance with the purposes of section 1905 of title 18 of the United States Code 0 0 0." [fthe Administrator so determines, the information is not disclosable to the public. However, section 114(c) of the CAA provides that information claimed to be a trade secret but which constitutes emission data may not be withheld as confidential. Although typically the EPA evaluates whether information constitutes emission data on a case-by-case basis, it believes that some kinds of data will always constitute emission data within the meaning of section 114(c). The purpose of this notice is to describe, without attempting to be comprehensive, that information which the EPA generally considers to be emission data, and which cannot qualify as confidential under either section 114(c) or section 110 (as set forth in 41 CFR 51.321, 51.322, and 51.323) of the CAA. The EPA is issuing this notice to clarify its policy and procedures, to facilitate the use of these data in automated data systems and computer-based simulation models, and to expedite processing of claims for confidentiality or requests for disclosure. The EPA presently determines that data submitted to it as emission data does not qualify as confidential if it meets the following definition under 40 CFR 2.30 I(a)(2)(i): a. Definitions. For the purpose of this section, (I) Act means the Clean Air Act, as amended, 42 U.S.C. 1401 et seq. (2)(i) Emission data means, with reference to any source of emission of any substance into the air- (A) Information necessary to determine the identity, amount, frequency, concentration, or other characteristics (to the extend related to air quality) of any emission which has been emitted by the source (or of any pollutant resulting from any emission by the source), or any combination of the foregoing: (B) Information necessary to determine the identity, amount, frequency, concentration, or other characteristics (to the extent related to air quality) of the emission which, under an applicable standard or limitation, the source was authorized to emit (including, to the extent necessary for such purposes, a description of the manner or rate of operation of the source), or any combination of the foregoing. (C) A general description of the location and/or nature of the source to the extent necessary to identify the source and to distinguish it from other sources (including, to the extent necessary for such purposes, a description of the device, installation, or operation constituting the source). The table below lists the specific data fields which the EPA presently considers to constitute emission data and provides a brief description of what each data field describes. The descriptions are intended to provide general information. This list is not exhaustive, and, therefore, other data might be found, in a proper case, to constitute emission data.

Emission Data Fields
Facility Identification: The following data fields are needed to establish the identity and location of emission sources. This shall also include a description or an identifier of the device, installation, or operation constituting the source. These data are used to locate sources for dispersion evaluation and exposure modeling. Plant Name and related point identifiers Address City County AQCR (Air Quality Control Region) MSA, PMSA, CMSA (Metropolitan Statistical Areas) State Zip Code Ownership and point of contact information Locational Identifiers:Federal Register I Vol 56. No. 35 I Thursday, February 21, 1991 I Notices 7043

Latitude & Longitude, or UTM Grid Coordinates SIC (Standard Industrial Classification) Emission point, device or operation description information SCC (Source Classification Codes) Emission Parameters: The following data fields are needed to establish the characteristics of the emissions. This information is needed for the analyses of dispersion and potential control equipment. Emission type (e.g., nature of emissions such as CO 2 ). particulate or a specific toxic compound, and origin of emissions such as process vents, storage tanks or equipment leaks) Emission rate (e.g., the amount released to the atmosphere over time such as kglyr or Ibs/yr) Release height (e.g., height above ground level where the pollutant is emitted to the atmosphere) Description of terrain and surrounding structures (e.g., the size of the area associated with adjacent structures in square meters and terrain descriptions such as mountainous. urban, or rural) Stack or vent diameter at point of emissions (e.g., the inside diameter of vent at the point of emission to the atmosphere in meters) Release velocity (e.g., velocity ofrelease in m1sec) Release temperature (e.g., temperature of release at point of release in degrees Kelvin) Frequency of release (e.g., how often a release occurs in events per year) Duration of release (e.g., the time associated with a release to the atmosphere) Concentration (e.g., the amount of an emission stream constituent relative to other stream constituents expressed as parts per million (ppm), volume percent. or weight percent) Density of the emissions stream or average molecular weight (e.g., density expressed as fraction or multiple of the density of air: molecular weight in gig-mole) Boiler or process design capacity (e.g.•the gross heating value of fuel input to a boiler at its maximum design rate) Emission estimation method (e.g., the method by which an emission estimate has been calculated such asmaterial balance, source test, use of AP42 emission factors, etc.) Percent space heat (e.g., the percent of fuel used for space heating) Hourly maximum design rate (e.g., the greatest operating rate that would be expected for a source in a l-hour period)

The EPA has determined that these data are emission data and releasable upon request. This determination applies to data currently held by EPA as well as to information submitted to EPA in the future. Future requests for information under sections 110 and 114 of the CM will indicate that these emission data will not be held confidential. This determination applies only to the data listed in the table. Determinations will continue to be made on a case-by-case basis for data not specified in this generic determination. After consideration of comments on this policy, a revised policy/determination may be published. Dated: February 8, 1991. Michael Shapiro. Acting Assistant Administrator for Air and Radiation. [FR Doc. 91-4114 Filed 2-20-91: 8:45 am]

## Enclosure 6

Page 1 of 5 

# Summary of OAQPS Procedures for Safeguar ding Clean Air Act (CAA) Confidential Business Information (CBI)
January 2002

1. Purpose:

This me morandum describes policies and proced ures set forth by the Office of Air Quality Planning and Standards (OAQPS) for the handling of informa tion claimed as Confidential Business Information (CBI), whether submitted vol untarily or obtained under Section 114 of the Clean Air Act (CAA), and governed by U.S. Environmental Protection Agency (EPA) regulations in 40 Code of Federal Regulations (CFR), Part 2, Subpart B, and other EPA regulations.

2. Reference Documents:

a. Clean Air Act as amended. b. 40 CFR, Chapter 1, Part 2, Subpart B - Confidentiality of Business Information. c. EPA Information Security Manual 2195A1 d. Office of Air Quality Planning and St andards Confidential Business Information Security Manual (January 2009) 3. Exception: This document was prepared as a summary of da ta gathering a nd handling procedures used by the OAQPS, EPA. Nothing in this document shal l be construed as superseding or being in conflict with any applicable regulations, statutes, or policies to wh ich EPA is subject.

4. Definition:

Confidential Business Inform ation (CBI) - In formation claimed by the provider to be confidential. This information may be identified with such titles as trade secret, secret, administrative secret, company secret, secret pr oprietary, privileged, admi nistrative confidential, company confidential, confiden tial proprietary, or proprietary . NOTE: These markings should not be confused with the classi fication markings of National Secu rity information identified in Executive Order 11652.

## Page 2 of 5 5. Background:
Section 114 (c) of the Clean Air Act as amended reads as follows: “Any records, reports, or information obtained under subsection (a) shall be available to the public, except that upon satisfactorily showing to the Adm inistrato r by any person that records, reports, or information, or partic ular part thereof (other than emission data), to which the Administrator has access under this section if made public, would divulge methods or processes entitled to protection as trade secrets of such person, the Admi nistrator shall consider such records, report, or information or particular portion thereof conf idential in accordance with the purposes of Section 1905 of Title 18 of the United States Code, except that such record, report, or information may be disclosed to other officers, employees, or authorized representatives of the United States concerned with carrying out this Ac t or when relevant in any proceeding under this Act.” The treatment of CBI by EPA, including data obtain ed under Section 114 of the Clean Air Act, is governed by 40 CFR, Part 2. These regulations requi re EPA offices to include a notice with each request for information to inform the business of: (1 ) its right to assert a claim of confidentiality covering part or all of the information, (2) the me thod for asserting a claim, and (3) the effect of failure to assert a claim at time of submi ssion. In addition, the regulations: (1) set forth procedures for the safeguarding of confidential information; (2) contai n provisions for providing confidential information to authorize representati ves; (3) contain provisio ns for the release of information to the Congress, Comptroller Gene ral, other Federal agen cies, State and local governments, and Courts; (4) permit the disclosure of information within EPA to employees with an official need for the information; and (5) pr ohibit wrongful use of such information and cite penalties for wrongful disclosure. Further, the regulations contain the Agency’s basic rule concerning the treatment of requests for info rmation under the Freedom of Information Act (5 U.S.C. 552).

6. Procedures: a. Request for Information Each request for information m ade under the provisions of Section 114(a) is signed by the Division Director. The request include s standard enclosure “EPA’s Information Gathering Authority under Section 114 of the Clean Air Act,” which was designed to meet the requirement of 40 CFR Part 2 discussed above. b. Receipt of CAA Confiden tial Business Information Upon receiptof information for which confid ential treatment has been requested, the OAQPS Document Control Officer (DCO) logs in the material and a permanent file is established. If part of the ma terial is claimed to be conf idential, that portion should be marked “Subject to Confid entiality Claim.” In complian ce with Sections 2.204 and 2.208 of 40 CFR Part 2, the Group Leader responsible for the requested information reviews the information to determine the validity of th e confidentiality claim as prescribed by the sections. If the information is clearly not c onfidential, the Group Lead er prepares a letter

## Page 3 of 5 for the signature of the responsible Divisi on Director to notify the business of this finding.

Information claimed as confidential is ha nd carried to the OAQPS CBI Office to be logged into the OAQPS CAA CBI tracking sy stem and filed for safekeeping. The OAQPS CAA CBI tracking system provides a brief description of the material (submitter, subject, number of pages, etc.), identifies it with the correct project number, or work assignment number, and lists those pe rsons who are authorized to have access to the information. record of personnel accessing the information (Attachment A) is also kept on filed. By regulation, confidential info rmation must be so marked or designated by the originator. EPA takes additional measures to ensure that the propr ietary designation is uniformly indicated and immediately observable. All unmarked or undesignated information (except as noted below) ma y be authorized for public release. c. Storage of CAA Confidential Business Information
Folders, documents, or material con taini ng CAA CBI (as defined) shall be secured, within the confines of the in structions listed in the OAQPS Security Manual. In addition, the CBI storage area has been identified specif ically for this purpose and is equipped with supplementary locking devices. The storage areaand files are under th e direct control of the OAQPS DCO. Access to the storage area is limited to th e Document Control Officer DCO, Document Control Officer Assistant (DCOA) and the minimum number of persons required to effectively maintain normal business operations as directed by the Director, Central Operations and Resources (CORE). Files may be issued upon confirmation that the requesting individua l is authorized to receive the information. All c onfidential files must be returned no la ter than close of business on the same day. The intended user must sign the CBI Control Record when checking out files. Individuals signing out confiden tial files are respons ible for their safekeeping. Files must never be left unattended. The information mustnot be disclosed to any non-authorized personnel. Storage procedures for CAA CBI by an authorized representative of EPA (see Section d. below) must be, at a minimum, as secure as those established for EPA offices within OAQPS. Whenever CBI is removed from the EPA files to be transmitted to an authorized representative, a notatio n is made in the file’s control record and transf er log indicating what information was transmitted, the date, and the recipient. The authorized representative returns a si gned receipt to the DCO.

## Page 4 of 5 d. Access to CAA Confidential Business Information Only authorized EPA employees may open or distribute CAA CBI. Only employees who require, have a need to know and are authorized access to CAA CBI in the performance of their official duties are permitted to review documents and, upon receiving a confidential document, mu st sign and date the form shown in Attachment A to certify their access to the document. The Group Leader having primary respons ibility for the CAA CBI provides a memorandum to the DCO designating those pe rsonnel authorized to access specific CBI. NO person is automatically entitled to access ba sed solely on grade, position, or security clearance. The names of pers ons granted access to CAA CBI are placed on the CAA CBI access list. The CAA CBI access list indicates the “specific” CBI each person is permitted to see. The Access List is reviewed and updated periodically. Companies under contract to perform work for the EPA may be designated authorized representatives of EPA. As authorized repr esentatives, contractors may be granted access to CAA CBI. The following conditions apply when it has been determined that disclosure is necessary: (1) The contractor designate d as a representative and its employees (a) may use such confidential information only for the purpos e of carrying out the work required, (b) must refrain from disclosing the info rmation to anyone other than EPA without having received from EPA prior written appr oval of each affected business or of an EPA legal office, and (c) must return to EPA all copies of the information (and any abstracts or excerpts there from) upon reque st or whenever the information is no longer required for the performance of the work. (2) The authorized contractor designated as a representative must obtain a written confidentiality agreement from each of its employees who will have access to the information. A copy of each employee agreement (Attachment B) must be furnished to EPA before access is permitted. (3) The contractor designate d as an authorized represen tative must agree that the conditions in the contract concerning the use and disclosu re of CAA CBI are included for the benefit of, and shall be enforceable by, both EPA and any affected business having a proprietary in terest in the information. Information may be released to or accesse d by EPA employees other than OAQPS employees only upon approval of the Director, CORE. Requests for CAA CBI from other Federal agencies , Congress, the Comptroller General, Courts, etc., are processed in accordance with 40 CFR 2, Subpart B.

## Page 5 of 5 Requests under the Freedom of Information Ac t (FOIA) are handled in accordance with 40 CFR 2, Subpart A. The Freedom of Information Act Coordinator must be consulted prior to responding to any request for information if a cla im of confidentiality has been asserted or if there is reason to believe that a claim might be made if the business kne w release was intended.

e. Use and Disclosure of CAA Confidential Business Information The CAA CBI as defined may not be usedin publications, supporting docum ent, memoranda, etc., that become a part of th e public domain, except as provided for in 40 CFR 2 Subpart B. CAA CBI may not be summarized without the approval of the Group Leader responsible for the CAA CBI. Any authorized reproductions must be logged into the CAA CBI document tracking system and treated according to the same procedures applicable to the original confidential material. Documents, materials, or extracts of information generated by EP A which contain CAA CBI must be stamped “Subject to Confidentiality Claim” and a cove r sheet must be attached to identify the material as CBI. f. Handling of Other Information Reports, memoranda, docum ents, etc., prepared by EPA or its authorized representatives are not normally circulated outside EPA fo r comment or review prior to publication except in such cases as described in secti on 6 above. However, because industrial-datagathering visits, plant inspections, and source testing can in volve inadvertent receipt of CAA CBI, it is the policy of OAQPS to prot ect all parties involved in the following
manner: (1) Prior to or at the inception of a plant inspection, data-gathering visit, or source test, EPA or its authorized repres entative discusses with a re sponsible industry official the information sought, how it is to be used, and how it is to be protected. A copy of this summary is usually provided to th e industry official being consulted. (2) Following an inspection, visit, or test, a trip report is prep ared to include, as practicable, all information received by EPA or its authorized representative during the visit or test. The report may be pr epared by either EPA or its authorized representative. The draft report is clearly identified, withan attached, yellow cover sheet. A second copy of the dr aft trip report is forwarde d by EPA to the responsible industry official for review. The responsible industry official is requested by cover letter to review the report, clearly mark any information considered to be confidential, and return the marked up -report to the responsible EPA employee within the time specified. The original draft is kept in the CBI file until the markedup copy is returned by the business firm. (3) When the reviewed copy of the report, as marked by the responsible plant official, is received by EPA, information designated confidential is placed in the CBI files as described above. The original draft of the trip report is edited to delete the confidential information and the trip report is authorized for release.

## ATTACHMENT A

EXAMPLE RECORD FORM FOR CBI ACCESS

# CAA CONFIDENTIAL BUSINESS INFORMATION CONTROL RECORD

DATE RECEIVED: RESPONSIBLE GROUP: CONTROL NUMBER:

DOCUMENT AUTHOR: DATE OF DOCUMENT:

DESCRIPTION (PROVIDING ORGANIZATION, TITLE, SU BJECT, NUMBER OF COPI ES, NUMBER OF PAGES)

RETURN DATE: DESTRUCTION DATE: INITIALS:

EACH PERSON WHO IS GIVEN ACCESS TO THIS DOCUMENT MUST FILL IN THE INFORMATION BELOW.

SIGNATURE DATE SIGNATURE DATE 

# CHECK-OUT CHECK-IN

TIME TIME

C A A Form 1 (Re v
. 0 1 / 0 2 )

## ATTACHMENT B

EXAMPLE RECORD FORM FOR CBI ACCESS

### CAA CBI Security Manual (Appendix A)



## I. AUTHORIZATION FOR ACCESS TO CAA CBI FOR FEDERAL EMPLOYEES

FULL NAME POSITION
SSN OFFICE It is the responsibility of each Authorizing Official* to ensure that the employees under his/her supervision who require access to CAA CBI: 1. Sign the Confidentiality Agreement for Federal Employees 2. Are fully informed regarding their security responsibilities for CAA CBI. 3. Obtain access only to that CAA CBI required to perform their official duties

SIGNATURE OF AUTHORIZING OFFICIAL* TELEPHONE NO. DATE

TITLE LOCATION


## II. CONFIDENTIALITY AGREEMENT FOR FEDERAL EMPLOYEES I understand that, in accordance with my official dutie s, I will have access to certain Confidential Business Information submitted under the Clean Ai r Act (CAA) (42 U.S.C. 7401 et seq.) I understand that, under 18 U.S.C. 1905 and 18 U.S.C 1924I am liable for a possible fine of up to $1,000 and/or imprisonment for up to one year, if I willfully disclose CAA Confidential Business Information to any person not authorized to receive it. Additionally, I understand that, I may be subject to disciplinary action for violation of this agreement with penalties ranging up to and including dismissal.
I am aware that, I may be subject to criminal penalties under 18 U.S.C. 1001 if I have made any statement of material facts knowing that such statement is fals e or if I willfully conceal any material fact.
I agree that, upon the termination of my duties, transfer or departure from the Environmental Protection Agency, I will return all materials containing CAA Confidential Business Information in my possession to the OAQPS CBI Office.
I certify that I have read and understand these procedur es and those outlined in the CAA CBI Security Manual.

SIGNATURE TELEPHONE NO. DATE



## III. THE UNDERSIGNED CERTIFIES THE ALL TRAINING AND TEST REQUIREMENTS HAVE BEEN MET BY THE EMPLOYEE.

SIGNATURE CBI MANAGER/DCO TELEPHONE NO. DATE



## IV. ANNUAL RE-CERTIFICATION : I certify that, in conjunction with my duties, I require access to CAA CBI. I am current with all CBI handling procedur es and security guidelines as outlined in the CCA CBI Security Manual.

Date Date Date Date Date Date
Initial Initial Initial Initial Initial Initial

Date Date Date Date Date Date
Initial Initial Inital Initial Initial Initial CAA CBI From 2 (Rev. 01/ 02) * Must be Division Director (or equivalent) or above. A-1

## Enclosure 7

Site-Specific Test Plan Development Guidance
This information collection request (ICR) provides specific additional instructions for each prescribed test method to ensure that the collected data will meet the objectives of the ICR. To ensure that all data submitted in fulfillment of this ICR are of sufficient and known quality, EPA believes it is highly advisable for each facility (subject to emissions te sting under the ICR) to prepare a site-specific test plan prior to testing. A s ite-specific test plan addresses the planning and quality assurance and quality control procedures and acceptance criteria for all of the testing, including the collection of process and fuel data.
You may find guidance for developing such a site-specific test plan at http://www.epa.gov/ttn/emc/guidlnd/gd-042.pdf . Such a test plan would provide a means for you to verify that the quality assu rance protocols, contained in the various test methods, are met. You need not submit the test plan to EPA; however, much of the information in a complete sitespecific test plan consists of data that are used for required fields in Version 3 of the EPA Electronic Reporting Tool (ERT) (see Enclosure 8).

### Test Plan

Facility Information: Enter the name of the facility

Enter physical Address

Enter physical city
Contact: Person to contact for more detail
Phone: Of above person
Fax: Of above person
Email: Of above person Testing Company: Name of primary testing organization

US postal address of above

US postal address of abov
e Contact: Field test leader
Phone: Of above person
Fax: Of above person
Email: Of above person

Air Permit Number:

This is the State or Fed Permit Number Permitted Source ID/Name:

Permitted Maximum Process Rate:

As listed in Title V or State Permit Max. Normal Operation Process Rate: From previous years operations Target Process Test Rate

1. What is the specific purpo se for the proposed testing?

The primary reasons for performing this emissions test is to satisfy the EPA's Section 114 Letter requiring this testing.

3. Will the test results be used for other reg ulatory purposes (e.g., emission inventories, permit applications, etc.) beyond that stated above? If yes, explain.

List any secondary purposes that you will use the data from this emissions test to address. If known list those pollutants that are of secondary interest. Some examples are: Determine emissions of CO, THC, VOC and condensable PM emissions for use in emissions inventory reporting and determination of fees. Industry NAICS: 56221

4a. Enter the process data to be documented during testing. AFS #: FRS #: http://www.epa.gov/envi

SCC / Description 50100516 Waste Disposal - Solid Waste Disposal - Government - Other Incineration - Sludge: Fluidized Bed

2. List all state and federal regulations that apply to the proposed testing:

Process Parameter Units Target Value Comments Dried Sludge Fed Tons/hr 0 Provide estimated process rate for the test. Moisture % 0 Oil Firing Rate gal/hr 0 Provide typical value. Gas Firing Rate Ft^3/min 0 Provide typical value Scrubber outlet temp deg F 0 Provide max or target temp. Scrubber water flow Gal/min 0 Provide min or target flow. Scrubber Pressure Drop in H2O 0 Provide min or target pressure drop across each component.



### Thursday, April 08, 2010 Page 1 of 7 Test Plan

### Test Plan

5a. Please give a brief description of the sou rce (including control equipment) and attach source or process flow diagram:

This description should describe the process and associated controls to differentiate this facility from, or document similarity with others of same SCC.
5b. Control Devices:

7. Please provide the following in formation for each test parameter. 6. Please enter samplin g location information. 4b. Enter the process lab data to be documented during testing.

Control Device Name List all emissions control devices in order of process flow. Choose from drop down lists. If not on list add description and provide detailed desription in section 5a.

Target Parameter Test Method Number of Test Runs Test Run Duration Sample Points Comments Location Carbon Monoxide Method 10 3 240 0 Stack Exit 2,3,7,8-TCDD Method 23 3 240 0 Stack Exit 1,2,3,7,8-PeCDD Method 23 3 240 0 Stack Exit 1,2,3,4,7,8- HxCDD Method 23 3 240 0 Stack Exit

1,2,3,6,7,8- HxCDD Method 23 3 240 0 Stack Exit

1,2,3,7,8,9- HxCDD Method 23 3 240 0 Stack Exit

1,2,3,4,6,7,8- HpCDD Method 23 3 240 0 Stack Exit

OCDD Method 23 3 240 0 Stack Exit 2,3,7,8-TCDF Method 23 3 240 0 Stack Exit 1,2,3,7,8-PeCDF Method 23 3 240 0 Stack Exit 2,3,4,7,8-PeCDF Method 23 3 240 0 Stack Exit Location Round Duct Diam. Distance from upstream dist. Distance from downstream dist. Number of Traverse Ports Equiv. Diam Min.Travers Points Rect. Duct Length /Width Stack Exit 0 0 0 2 0 2 4 00 Incinerator Exhaust Gas Temp deg F 0 Provide min or target temp.

Analysis Required Units Comments Sludge moisture content % Sludge mercury content ug/kg dry sludg Sludge lead content ug/kg dry sludg Sludge cadmium content ug/kg dry sludg Ultimate/Proximate Analysis Use ASTM D3172, D5373 Sludge Nickel content ug/kg dry sludg Sludge Arsenic content ug/kg dry sludg Sludge Chromium content ug/kg dry sludg Sludge Beryllium content ug/kg dry sludg



### Thursday, April 08, 2010 Page 2 of 7 Test Plan

### Test Plan

1,2,3,4,7,8- HxCDF Method 23 3 240 0 Stack Exit

1,2,3,6,7,8- HxCDF Method 23 3 240 0 Stack Exit

2,3,4,6,7,8- HxCDF Method 23 3 240 0 Stack Exit

1,2,3,7,8,9- HxCDF Method 23 3 240 0 Stack Exit

1,2,3,4,6,7,8- HpCDF Method 23 3 240 0 Stack Exit

1,2,3,4,7,8,9- HpCDF Method 23 3 240 0 Stack Exit

OCDF Method 23 3 240 0 Stack Exit Other TCDD Method 23 3 240 0 Stack Exit Other PeCDD Method 23 3 240 0 Stack Exit Other HxCDD Method 23 3 240 0 Stack Exit Other HpCDD Method 23 3 240 0 Stack Exit Other TCDF Method 23 3 240 0 Stack Exit Other PeCDF Method 23 3 240 0 Stack Exit Other HxCDF Method 23 3 240 0 Stack Exit Other HpCDF Method 23 3 240 0 Stack Exit Total Dioxins Method 23 3 240 0 Stack Exit Total Furans Method 23 3 240 0 Stack Exit 3,3',4,4'-TCB (PCB77) Method 23 3 240 0 Stack Exit

3,4,4',5-TCB (PCB81) Method 23 3 240 0 Stack Exit

2,3,3',4,4'-PeCB (PCB105) Method 23 3 240 0 Stack Exit

2,3,4,4',5-PeCB (PCB114) Method 23 3 240 0 Stack Exit

2,3',4,4',5-PeCB (PCB118) Method 23 3 240 0 Stack Exit

2',3,4,4',5-PeCB (PCB123) Method 23 3 240 0 Stack Exit

3,3',4,4',5-PeCB (PCB126) Method 23 3 240 0 Stack Exit

2,3,3',4,4',5/2,3,3', 4,4',5'-HxCB (PCBs156/157) Method 23 3 240 0 Stack Exit

2,3',4,4',5,5'- HxCB (PCB167) Method 23 3 240 0 Stack Exit

3,3',4,4',5,5'- HxCB (PCB169) Method 23 3 240 0 Stack Exit

2,3,3',4,4',5,5'- HpCB (PCB189) Method 23 3 240 0 Stack Exit

Other Mono-CBs Method 23 3 240 0 Stack Exit Other Di-CBs Method 23 3 240 0 Stack Exit Other Tri-CBs Method 23 3 240 0 Stack Exit Other Tetra-CBs Method 23 3 240 0 Stack Exit Other Penta-CBs Method 23 3 240 0 Stack Exit Other Hexa-CBs Method 23 3 240 0 Stack Exit Other Hepta-CBs Method 23 3 240 0 Stack Exit



### Thursday, April 08, 2010 Page 3 of 7 Test Plan

### Test Plan

Other Octa-CBs Method 23 3 240 0 Stack Exit Other Nona-CBs Method 23 3 240 0 Stack Exit DeCB Method 23 3 240 0 Stack Exit Total PCBs Method 23 3 240 0 Stack Exit Total TEQ Method 23 3 240 0 Stack Exit Naphthalene** Method 23 3 240 0 Stack Exit 2- Methylnaphthalene Method 23 3 240 0 Stack Exit
Acenaphthylene** Method 23 3 240 0 Stack Exit Acenaphthene** Method 23 3 240 0 Stack Exit Fluorene** Method 23 3 240 0 Stack Exit Phenanthrene** Method 23 3 240 0 Stack Exit Anthracene** Met hod 23 3 240 0 Stack Exit Fluoranthene** Method 23 3 240 0 Stack Exit Pyrene** Method 23 3 240 0 Stack Exit Benzo(a)anthracen e* Method 23 3 240 0 Stack Exit
Chrysene* Method 23 3 240 0 Stack Exit Benzo(b)fluoranth ene* Method 23 3 240 0 Stack Exit
Benzo(k)fluoranth ene* Method 23 3 240 0 Stack Exit
Benzo(e)pyrene Method 23 3 240 0 Stack Exit Benzo(a)pyrene* Method 23 3 240 0 Stack Exit Perylene Method 23 3 240 0 Stack Exit Indeno(1,2,3- cd)pyrene* Method 23 3 240 0 Stack Exit
Dibenzo(a,h)Anthr acene* Method 23 3 240 0 Stack Exit
Benzo(ghi)perylen e** Method 23 3 240 0 Stack Exit

Total 7*PAH Method 23 3 240 0 Stack Exit Total 16*/**PAH Method 23 3 240 0 Stack Exit Hydrogen Chloride Method 26A 3 240 0 Stack Exit Hydrogen Fluoride Method 26A 3 240 0 Stack Exit Filterable Particulate OTM - 27/28 3 240 0 Use only for dry stacks. Delete Method 5/OTM28 tests. Stack Exit

Total Particulate OTM - 27/28 3 240 0 Use only for dry stacks. Delete Method 5/OTM28 tests. Stack Exit

Total PM2.5 OTM - 27/28 3 240 0 Use only for dry stacks. Delete Method 5/OTM28 tests. Stack Exit
Organic Condensible Particulate OTM - 27/28 3 240 0 Use only for dry stacks. Delete Method 5/OTM28 tests. Stack Exit

Filterable PM2.5 OTM - 27/28 3 240 0 Use only for dry stacks. Delete Method 5/OTM28 tests. Stack Exit
Inorganic (Aqueous) Condensible Part. OTM - 27/28 3 240 0 Use only for dry stacks. Delete Method 5/OTM28 tests. Stack Exit

Lead Method 29 3 240 0 Stack Exit Arsenic Method 29 3 240 0 Stack Exit Beryllium Method 29 3 240 0 Stack Exit Antimony Method 29 3 240 0 Stack Exit


### Thursday, April 08, 2010 Page 4 of 7 Test Plan

### Test Plan

7b. Please select the Emissions / Concentrations for each location. Cadmium Method 29 3 240 0 Stack Exit Chromium Method 29 3 240 0 Stack Exit Cobalt Method 29 3 240 0 Stack Exit Manganese Method 29 3 240 0 Stack Exit Mercury Method 29 3 240 0 Stack Exit Nickel Method 29 3 240 0 Stack Exit Phosphorus (yellow or white) Method 29 3 240 0 Stack Exit

Filterable Particulate Method 29 3 240 0 Stack Exit

Selenium Method 29 3 240 0 Stack Exit Total Particulate Method 5/OTM-28 3 240 0 Use only for wet stacks. Delete OTM27/OTM28 test. Stack Exit
Organic Condensible Particulate Method 5/OTM-28 3 240 0 Use only for wet stacks. Delete OTM27/OTM28 test. Stack Exit

Inorganic (Aqueous) Condensible Part. Method 5/OTM-28 3 240 0 Use only for wet stacks. Delete OTM27/OTM28 test. Stack Exit

Filterable Particulate Method 5/OTM-28 3 240 0 Use only for wet stacks. Delete OTM27/OTM28 test. Stack Exit

Sulfur Dioxide Method 6C 3 240 0 Stack Exit Nitrogen oxides (NOx) Method 7E 3 240 0 Stack Exit

Test Method Emissions / Concentrations Corrected Analyte Corrected Percent Location Method 10 lb/hr 0 Stack Exit Method 10 mg/dscm 0 Stack Exit Method 10 mg/dscm corrected O2 7 Stack Exit Method 10 ppm 0 Stack Exit Method 10 ppm corrected O2 7 Stack Exit Method 23 lb/hr 0 Stack Exit Method 23 ng/dscm 0 Stack Exit Method 23 ng/dscm corrected O2 7 Stack Exit Method 26A lb/hr 0 Stack Exit Method 26A mg/dscm 0 Stack Exit Method 26A mg/dscm corrected O2 7 Stack Exit Method 29 lb/hr 0 Stack Exit Method 29 mg/dscm 0 Stack Exit Method 29 mg/dscm corrected O2 7 Stack Exit Method 5/OTM-28 lb/hr 0 Stack Exit Method 5/OTM-28 mg/dscm 0 Stack Exit Method 5/OTM-28 mg/dscm corrected O2 7 Stack Exit Method 6C lb/hr 0 Stack Exit Method 6C mg/dscm 0 Stack Exit Method 6C mg/dscm corrected O2 7 Stack Exit Method 6C ppm 0 Stack Exit Method 6C ppm corrected O2 7 Stack Exit Method 7E lb/hr 0 Stack Exit Method 7E mg/dscm 0 Stack Exit



### Thursday, April 08, 2010 Page 5 of 7 Test Plan

### Test Plan

8. Describe below or attach complete documentation of all modifications and/or deviations to the applicable test methods. If alternative methods requested, attach documentation of request

In this section, identify the promulgation date of any specified test method that you use for determining the procedures followed. This field is also used to document any modifications that are necessary to conduct the emissions test if they are outside the requirements of the cited method. If this modification was approved verbally by a regulatory agency, the name and date of approval should be included. Written formal approval should be attached to this file using the "Attach File" button. Test procedures that are different from those published in the Federal Register should be attached using the "Attach File" button. 9. Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites? Please list below or attach the supporting documentation.

In this section, provide documentation about the compliance of the sampling location to Method 1 criteria AND if the site meets these requirements, change the check box to "Yes". If the sampling location does not meet Method 1 requirements indicate the method used to make the sampling location representative of the emissions from the source. 10. Has absence of cyclonic flow been veri fied per EPA Method 1 (Section 2.4)? If no, absence of cyclonic flow must be verified prior to testing. If yes, please attach supporting documentation.

This field is for the documentation of the absence of cyclonic flow that is available at the time of the Test Plan generation. If this documentation is not available at this time, documentation is required during the performance of the emissions test. If cyclonic flow exists at the testing lo cation describe the procedures used to obtain representative samples. If there is an absence of cyclonic flow, check the "Yes" box. 11. Select the method that will determine the oxygen concentration :

13. Has all testing equipmen t been calibrated wi thin the past year? If no, please explain.

It is expected that the response to this question will be "Y es". This highlights the need to attach the documentation of the calibrations for all equipment used during the conduct of the emissions test. If all the equipment has been calibrated, check the "Yes" box. Yes No

Yes No

Yes No

Yes No

Yes No

14. Will all calibration gases be certified by EPA Traceability Protocol procedures? If No, describe certificatio n procedure below.

15. Is a dilution system (via EPA Method 205) proposed? Yes No N/A

Yes No N/A 16. If applicable, list the exp ected calibration gas co ncentrations for all proposed instrumental test methods. Include as much information as is known at this time. 12. Do any of the proposed test methods require analysis of EPA audit samples? If yes, notify Regional Office at least 45 days prior to testing to allow for audit sample preparation and shipment. Method 7E mg/dscm corrected O2 7 Stack Exit Method 7E ppm 0 Stack Exit Method 7E ppm corrected O2 7 Stack Exit OTM - 27/28 lb/hr 0 Stack Exit OTM - 27/28 mg/dscm 0 Stack Exit OTM - 27/28 mg/dscm corrected O2 7 Stack Exit



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### Test Plan

17. What is the proposed test schedule?

This field is primarily to advise the regulatory authority and facility the dates that emissions testing will be performed including any set up dates.
18. Additional comments:

Name: Title: Company: Sign Date: Name: Title: Company: Sign Date: Permitted Facility Representative Testing Company Representative Date Date 19. Required Personal Protection Equipment:

This field is primarily to advise the regulatory authority of the type of personal protective equipment that will be required for them to use to access the sampling location and any other locations that are associated with the performance of the test program. It will also serve to inform the facility of the source testers knowledge of the required protective equipment that they will use during the source test program.

Thursday, April 08, 2010 Page 7 of 7 Test Plan