From: <French.Chuck@epamail.epa.gov>

To: <sarnold@doerun.com>

CC: Danny Greene <Danny.Greene@erg.com>, "Steinwurtzel, Robert N." 

<Robert.Steinwurtzel@bingham.com>, Donna Lazzari <Donna.Lazzari@erg.com>, 

<Fairchild.Susan@epamail.epa.gov>, <Billy_Nichols@URSCorp.com>

Date: 7/2/2010 3:22 PM

Subject: Secondary Lead Smelters - Testing ICR

Attachments: SIGNED Doe Run.pdf; ICR TEST PLAN - Doe Run.doc; 2nd lead - Enclosures 2 through 

7.pdf

Dear Mr. Arnold,

 Please find attached below a letter from EPA requesting

testing at the Secondary Lead Facilities owned by your company along

with several enclosures. This testing request reflects the overall

industry test protocol that was developed after considerable

consultation and communications with ABR members over the past couple

months. Please complete the testing and submit data according to the

methods and schedule outlined in the letter and enclosures. We also

mailed a hard copy of the materials today, which you should receive

within a few days. Please let me know if you have questions.

 Thank You.

 Chuck French,

 Project Manager

 U.S. EPA, Office of Air Quality Planning and Standards

 Sector Policies and Program Division

 Metals and Minerals Group

 Phone: 919-541-7912

(See attached file: SIGNED Doe Run.pdf)(See attached file: ICR TEST PLAN

- Doe Run.doc)(See attached file: 2nd lead - Enclosures 2 through 7.pdf)




Enclosure 1 

Doe Run Company. 1 of 10

Test Procedures, Methods, and Reporting Requirements for the 

Information Collection Request for the Secondary Lead Smelting 

Source Category

Doe Run Company

This document provides an overview of approved methods, target pollutants, units of measure, 

and reporting requirements for the secondary lead smelting source category. All recipients must 

complete the testing and submit preliminary emissions test data and results no later than 

September 30, 2010 to the applicable address specified below. Please submit final test reports no 

later than October 18, 2010 to the applicable address specified below, and submit data using the 

Electronic Reporting Tool no later than November 1, 2010. This document will be referred to as 

the “Secondary Lead Smelting test program.” This document is organized as follows:

1.0 Sampling and Testing Procedures and Methods

2.0 How to Report Data

3.0 How to Submit Data

4.0 Contact Information for Questions on Test Plan and Reporting

1.0 Sampling and Analyses Procedures and Methods 

The EPA Secondary Lead Smelting test program requires you to conduct emissions tests for 

several pollutants. You must perform new stack tests that are representative of current operations 

at each emission point described in this enclosure. In lieu of conducting new tests for an 

emissions source(s), existing and well-documented test data from your operations that you 

consider representative of current operations, and that used the recommended test methods 

identified in Table 1.2 in Enclosure 1 can be submitted if the test data were collected within the 

previous 5 years. 

If you intend to submit existing test data for current operations, please submit the data within 30 

days of receiving this ICR to the applicable address specified in Section 3.0. Prior EPA approval 

is required if you desire to test an emissions source other than those specified in Table 1.1 of 

Enclosure 1. Please note that if EPA determines that any of the existing data that you submit or 

any proposed substitutions of your operations to be tested are not representative, you will need to 

conduct the testing required by this ICR and submit the test results within 90 days of receiving a 

request from EPA. If, after review of the data collected, EPA determines that the data requested 

from the industry is insufficient to conduct the review of the existing emission standard, 

additional testing could be required. 

You must submit the results of certain stack tests using EPA’s Electronic Reporting Tool (ERT) 

Version 3. Section 2.1 of this enclosure indicates which EPA methods require reporting using the 

ERT. You need not use the ERT to submit reports of previously-conducted testing but those 

reports must be complete including clear documentation of the process operations during the 
Enclosure 1 

Doe Run Company. 2 of 10

testing period, summaries of results, fuels and raw materials descriptions, field sample collection 

records and data sheets, analytical data sheets, and discussions of the emissions calculations.

The stack testing procedures are summarized below. 

1.1 Stack Testing Procedures and Methods

You must conduct stack sampling for the sources listed in Table 1.1 using methods as described 

in Table 1.2 of this enclosure. 

Table 1.1: Summary of Emissions Stack Testing Locations and 

Pollutants for Secondary Lead Smelting Facilities

Doe Run Company

Facility Emissions Source Pollutant(s) to Test

Doe Run, Boss, MO Main Baghouse 

(Reverberatory and 

Blast furnace)

Metals (Arsenic compounds, Beryllium compounds, 

Cadmium compounds, Chromium compounds, Lead 

compounds, Manganese compounds, Mercury 

compounds, Nickel compounds), Particulate matter 

(filterable), Total hydrocarbons, Speciated organics 

(Benzene, 1,3-Butadiene, Naphthalene), Dioxins/ 

Furans, Hydrogen Chloride

Refinery Baghouse Metals (Arsenic compounds, Beryllium compounds, 

Cadmium compounds, Chromium compounds, 

Hexavalent chromium, Lead compounds, Manganese 

compounds, Mercury compounds, Nickel compounds), 

Particulate matter (filterable)

Reverberatory hygiene 

baghouse

Metals (Arsenic compounds, Beryllium compounds, 

Cadmium compounds, Chromium compounds, Lead 

compounds, Manganese compounds, Mercury 

compounds, Nickel compounds), Particulate matter 

(filterable)

Rotary baghouse 

(Refining kettles and 

dross screw)

Metals (Arsenic compounds, Beryllium compounds, 

Cadmium compounds, Chromium compounds, Lead 

compounds, Manganese compounds, Mercury 

compounds, Nickel compounds), Particulate matter 

(filterable)

Ceilcote scrubber 

(battery breaker 

scrubber)

Metals (Arsenic compounds, Beryllium compounds, 

Cadmium compounds, Chromium compounds, Lead 

compounds, Manganese compounds, Mercury 

compounds, Nickel compounds), Particulate matter 

(filterable)

Note: Testing for the metal groups (such as “arsenic compounds”) includes the base metals and 

metal component of metal compounds (e.g., arsenic compounds = elemental arsenic, arsenic ions, 

plus the arsenic in arsenic compounds). 

1.2 How to Select Emissions Sample Location and Gas Composition Analysis Methods
Enclosure 1 

Doe Run Company. 3 of 10

If your emissions measurement location is in a stack or duct, use EPA Method 1 of Appendix A 

of Part 60 to select the locations and number of traverse points for sampling. See 

http://www.epa.gov/ttn/emc/methods/method1.html for a copy of the method and guidance 

information. If your emissions measurement location is the outlet of a positive pressure fabric 

filter (i.e., roof monitor or multiple short stacks), use EPA Method 5D, sections 8.1 and 8.2 to 

determine the measurement site and the sample traverse points locations (see 

http://www.epa.gov/ttn/emc/promgate/m-05d.pdf). 

1.3 Stack Test Methods

Conduct the emissions testing at the outlet to the atmosphere of each emissions control system 

(e.g., baghouse, thermal oxidizer, afterburner, gas scrubber) listed in Table 1.1. The test results 

should indicate on which control device the testing was performed using the emission point 

identifications corresponding to Forms C-1 through C-8 of the survey and the control device 

identifications corresponding to Forms D-1 through D-9 of the survey, as applicable. For 

emissions testing, Table 1.2 presents a summary of the recommended emission test methods for 

each pollutant and possible alternative methods. 

If you would like to use a method not on this list, please contact EPA for approval of an 

alternative method. Please direct test method and reporting questions to Chuck French at (919) 

541-7912 or french.chuck@epa.gov.

Each test should include three test runs at the sampling location. Testing is to be performed for 

the identified pollutants on a one-time basis after the last control device (i.e., stack or other point 

representing the composition of the gases at the exit to the atmosphere). All testing should be 

performed on the outlet of the last control device. All testing should be conducted during typical 

process unit and control operating conditions. All pollutant concentrations should be corrected to 

7% oxygen and should be reported on a dry basis. The recommended units of concentration for 

each pollutant vary, and are listed in Table 1.2. Report the results of the stack tests according to 

the instructions in Section 2.0 of this enclosure. Include the corresponding emissions point 

identification designated in Forms C-1 through C-8 of the survey and the control device 

identifications corresponding to Forms D-1 through D-9 of the survey, as applicable, with the test 

results. In addition to the stack emissions test data, we also require a report of the applicable 

process information taken at the time of the emissions test, depending on the emission point being 

sampled, as outlined in Table 1.3. 

For copies of the recommended U.S. EPA methods and additional information, please refer to 

EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/.

Table 1.2: Summary of Test Methods and Alternative Methods

Pollutant or 

Parameter

Recommended Method

Alternate Method

Test Runs and 

Duration

Reported 

Units of 

Measure

Flow rate EPA Method 2 for single stacks 

or ducts; 

EPA Method 5D, section 8.3 

for positive pressure fabric 

filters

SCAQMD* Methods 

2 through 4

Simultaneous with 

each pollutant test run

dscm/min
Enclosure 1 

Doe Run Company. 4 of 10

O2 and CO2 EPA Method 3A or Method 3B Continuous emissions 

monitoring system 

(CEMS), SCAQMD 

Methods 100.1 or 

integrated sample 

analyzed according to 

SCAQMD Methods 

3.1 or 10.1, as 

applicable

Simultaneous with 

each pollutant test run

Volume 

percent dry

Moisture 

content

EPA Method 4 SCAQMD Methods 2 

through 4

Simultaneous with 

each pollutant test run

Volume 

percent

HAP metals 

(including 

mercury, 

arsenic, 

cadmium, 

chromium, 

beryllium, and 

nickel), and 

PM (filterable)

EPA Method 29 - Determine 

total filterable PM emissions 

simultaneously according to 

section 8.3.1.1. Use ICAP / 

ICP MS (Inductively Coupled 

Plasma Mass Spectrometry) for 

the analytical finish. Report all 

metals results.

CARB Method 436, 

(For mercury, use 

CARB Method 101, 

or Method 101 A if 

sulfates are present) 

At least 3 runs with a 

minimum sample 

volume of 3.4 m3 and 

minimum time of 2 

hours per run.**

mg/dscm @ 7 

percent O2

Hexavalent 

Chromium 

(Cr+6)

EPA SW-846 Method 0061 If you are performing 

new stack tests, use 

the recommended 

EPA method only. 

Previously collected 

data using CARB 

Method 425 may be 

submitted if results 

are above the limit of 

detection.

At least 3 runs with a 

minimum sample 

volume of 3.4 m3and 

minimum time of 2 

hours per run.**

μg/dscm @ 

7percent O2

Total 

hydrocarbons

EPA Method 25A SCAQMD Method 

25.3, (two runs are 

performed), 

And CARB Method 

429 for PAH

At least 3 runs 

simultaneous with 

and for the same 

duration as the 

Method 23 test runs.

ppmvd as 

propane @ 

7 percent O2

Benzene, 1,3-

Butadiene, 

and 

Naphthalene

EPA SW-846 Method 0031 

combined with SW-846 

Method 5041A for recovering 

the sample and 8260B for the 

analyzing the sample.

CARB Method 

422.102 and EPA 

Methods TO-14 and 

TO-15

For EPA SW-846 

methods, conduct at 

least 3 runs with a 

minimum sample 

volume of 0.04 m3

per 

4 tube pairs and 

minimum time of 2 

hours per run. For 

CARB Method 

422.102, conduct 3 

runs (volumetric 

sample collected for 

direct injection for 

each run)

mg/dscm @ 7 

percent O2
Enclosure 1 

Doe Run Company. 5 of 10

Dioxins/Furan

s (for blast 

furnaces and 

collocated 

blast and 

reverberatory 

furnaces 

only)

EPA Method 23 CARB Method 428, 

using high 

resolution mass 

spectrometry 

analysis 

For EPA Method 

23, conduct at least 

three test runs with 

a minimum sample 

volume of 3.4 m3

and a minimum time 

of 2 hours per run.** 

For CARB Method 

428, conduct three 

test runs, 8 hours 

per run with a 

minimum sample 

volume of 9.5 m3

per run

ng/dscm @ 

7percent O2

Hydrogen 

Chloride 

(HCl)

EPA Method 26 or 26A

CARB Method 421

At least 3 runs with 

a minimum sample 

time of 2 hours per 

run. Minimum 

volume of 1.5 m3 for 

Method 26 and 

nominal sample 

rate of 2 L/min for 

Method 26A

mg/dscm @ 

7 percent O2

*SCAQMD = South Coast Air Quality Management District.

**Note: Sample volumes at or above 2.3 m3are acceptable provided each test run provides measured results at or 

above the method detection level.

Table 1.3: Summary of Process Parameter Data to be Measured and Recorded with Stack 

Emissions Testing for the Process Units and Emissions Points Being Tested

Emission Point Being 

Sampled

Parameter Units Duration

Raw Material Storage Dimensions of storage pile 

(length, width, height)

Feet 3 hours before, during, 

and 3 hours after 

sampling

Face velocity at enclosure 

openings

Feet per second

Raw Material Processing Raw material throughput Tons/hr 3 hours before, during, 

and 3 hours after 

sampling Face velocity at enclosure 

openings

Feet per second

Charging Material Handling Charging material throughput Tons/hr 3 hours before, during, 

and 3 hours after 

sampling Face velocity at enclosure 

openings

Feet per second

Feed Dryer Feed material charge rate Tons/hr 3 hours before, during, 

and 3 hours after 

sampling Dryer operating temperature oF

Furnaces Feed material charge rate Tons/hr 3 hours before, during, 

and 3 hours after 

sampling
Enclosure 1 

Doe Run Company. 6 of 10

Furnace operating temperature oF

Lead production rate Tons/hr

Refining and Alloying 

Operations

Lead production rate Tons/hr 3 hours before, during, 

and 3 hours after 

sampling

Casting Operations Lead production rate Tons/hr 3 hours before, during, 

and 3 hours after 

sampling

2.0 How to Report Data

The methodology for reporting the results of any testing and monitoring requests depends on the 

type of tests and methods used to complete the test requirements. This section discusses the 

requirements for reporting the data.

2.1 Reporting Stack Test Data

If you conducted a stack test, or are submitting a previously-conducted stack test, using one of the 

methods listed in Table 2.1, you must report your data using the EPA ERT Version 3, in addition 

to submitting a complete test report. There are no ‘optional’ test data for this section 114 

response: all data fields in the EPA ERT are required fields. At present, only the methods 

identified in Table 2.1 below are supported by the ERT. ERT is a Microsoft® Access database 

application. Two versions of the ERT application are available. If you are not a registered owner 

of Microsoft® Access, you can install the runtime version of the ERT Application. Both versions 

of the ERT are available at http://www.epa.gov/ttn/chief/ert/ert_tool.html. The ERT supports an 

Excel spreadsheet application (which is included in the files downloaded with the ERT) to 

document the collection of the field sampling data. After completing the ERT, you will also need 

to attach an electronic copy of the emission test report (PDF format preferred) to the Attachments 

module of the ERT.

Table 2.1: List of Test Methods Supported by ERT

Test Methods Supported by ERT

Methods 1 through 4

Method 5

Method 6C

Method 7E

Method 10

Method 17

Method 23

Method 25A

Method 26A

Method 29

Method 101

Method 101A

Method 201A

Method 202

Conditional Test Method 40 (OTM 28)
Enclosure 1 

Doe Run Company. 7 of 10

Conditional Test Method 39 (OTM 27)

If you conducted testing using a method not currently supported by the ERT, you must report the 

results of this testing in your final test report. 

If you have a PM CEMS that meets Performance Specification 11 installed at your secondary lead 

smelting operation, and you used CEMS data to meet PM test requirements at your facility, you 

must report daily averages of CEMS data from 30 consecutive days for the period ending no 

earlier than July 1, 2010 (including those days where manual testing was conducted) of CEMS 

data in a Microsoft® Excel format. Include PM concentration (gr/dscf ), % O2 correction, 

temperature in degrees F, flue gas pressure in inches of water, and flue gas moisture content. 

Note periods of startup, shutdown, or malfunction and periods when the CEMS was not 

operational. 

2.2 Reporting Stack Test Measured Values Below the Detection Level

Identify the status of measured values relative to detection levels in your test report or in the ERT 

using the following descriptions:

• BDL (below detection level) – all analytical values used to calculate and report an in-stack 

emissions value are less than the laboratory’s reported detection level(s); 

• DLL (detection level limited) – at least one but not all values used to calculate and report an 

in-stack emissions value are less than the laboratory’s reported detection level(s); or

• ADL (above detection level) – all analytical values used to calculate and report an in-stack 

emissions value are greater than the laboratory’s reported detection level(s).

For each reported emissions value, insert the appropriate flag (BDL, DLL, or ADL) in your test 

report or in the Comments line of the ERT.

When reporting and calculating individual test run data:

• For analytical data reported from the lab as “nondetect” or “below detection level,”

− Include a brief description of the procedures used to determine the analytical detection 

and in-stack detection levels in your test report or in the Comments line of Lab Data tab in 

the Run Data Details in the ERT.

− Describe these procedures completely in a separate attachment including the 

measurements made, the standards used, and the statistical procedures applied.

− Calculate the in-stack emissions rate for any analytical measurement below detection level 

using the relevant detection level as the “reported” value.

− Report the calculated emissions concentration or rate result:

o As a bracketed “less than” detection level value (e.g., [<0.0105]) in your test report

and include the appropriate flag; or

o As a numerical value in the ERT with the appropriate flag in the Comments line.
Enclosure 1 

Doe Run Company. 8 of 10

− Report as numerical values (i.e., no brackets or “<” symbol) any analytical data 

measured above the detection level including any data between the analytical 

detection level and a laboratory-specific reporting or quantification level (i.e., flag 

as ADL).

• For pollutant measurements composed of multiple components or fractions (e.g., Hg and other 

metals sampling trains) where the result for the value for any component is measured below 

the analytical detection level: 

− Calculate the in-stack emissions rate or concentrations as outlined above for each 

component or fraction;

− Sum the measured and detection level values as outlined above using the in-stack 

emissions rate or concentrations for all of the components or fractions; and

− Report the sum of all components or fractions:

o As a bracketed “less than” detection level value (e.g., [<0.0105]) in your test report 

and include the appropriate flag; or

o As a numerical value in the ERT with the appropriate flag in the Comments line.

− Report also the individual component or fraction values for each run in your test report or 

in ERT. For the ERT, next to the sum reported as above, report on the Comments line the 

appropriate flag and the measured or detection level value for each component or fraction 

as used in the calculations (e.g., 0.036, [<0.069], 1.239, and [<0.945] for a four fraction 

sample):

• For measurements conducted using instrumental test methods (e.g., Method 3A):

− Record gaseous concentration values as measured including negative values and flag as 

ADL; do not report as BDL.

− Calculate and report in-stack emissions rates using these measured values

− Include relevant information relative to calibration gas values or other technical qualifiers 

for measured values in Comments line in the ERT.

• When reporting and calculating average emissions rate or concentration for a test when some 

results are reported as BDL:

− Sum all of the test run values including those indicated as BDL or DLL as measured 

values.

− Calculate the average emissions rate or concentration (e.g., divide the sum by 3 for a threerun test).

− Report the average emissions rate or concentration average:

o As a bracketed “less than” detection level value (e.g., [<20.06]) in your test report and 

include the appropriate flag.

o As a numerical value in the ERT and include the appropriate flag in the Comments

line.
Enclosure 1 

Doe Run Company. 9 of 10

3.0 How to Submit Data

Please submit your non-confidential emissions testing data and supporting documentation 

electronically as follows:

Open Microsoft •

® Windows Explorer ("My Computer" not Internet Explorer) on your 

computer.

• Type the following directory in the address bar and press the enter key: 

ftp://ftperg.com/outgoing/Secondary Lead Data/

• Enter the following user name and password at the prompt:

o User name = guestftp

o Password (for July) = ERG0710

o Password (for August) = ERG0810

o Password (for September) = ERG0910

• Copy your files to the "Secondary Lead Data" directory.

• Send Chuck French (french.chuck@epa.gov) an email noting that you have posted your 

information.

Alternatively, you can mail your non-confidential emissions testing data and supporting 

documentation on a CD-ROM or DVD-ROM disk to:

Chuck French

U.S. EPA Office of Air Quality Planning and Standards

Sector Policies and Program Division, Metals and Minerals Group

Mail Code D243-02

Research Triangle Park, NC 27711

If the process data or other information you are providing is considered confidential, please create 

a separate CD or DVD containing only the confidential portion of your data or prepare a copy of 

the hard copy materials containing only the pages that include the information you consider 

confidential. Clearly mark the disk and/or materials with the words “Confidential Business 

Information.” Send these confidential files under separate cover to the attention of Mr. Roberto 

Morales at the following address:

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn: Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales via 

Registered U.S. Mail using return receipt requested, Federal Express, or other method for which 
Enclosure 1 

Doe Run Company. 10 of 10

someone must provide a signature upon receipt. Do not electronically transmit confidential 

business information (CBI) to EPA. E-mail and facsimile are not secure forms of communication 

and should never be used to transmit CBI.

4.0 Contact Information for Questions on Test Plan and Reporting 

For questions on how to report data using the ERT, contact:

Ron Myers (U.S. EPA)

(919) 541-5407

myers.ron@epa.gov

OR

Barrett Parker (U.S. EPA)

(919) 541-5635

parker.barrett@epa.gov

For questions on the test methods contact:

Peter Westlin (U.S. EPA)

(919) 541-1058

westlin.peter@epa.gov

OR

Gary McAlister (U.S. EPA)

(919) 541-1062

mcalister.gary@epa.gov

For questions on the secondary lead smelting test plan, including units selected to test and 

reporting mechanisms other than the ERT, contact:

Chuck French (U.S. EPA)

(919) 541-7912

french.chuck@epa.gov
Enclosure 2

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 information needed "for the purpose of (i) developing or 

assisting in the development of any implementation plan 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, Section 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 standards. 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, however, request that EPA treat such information as 

confidential. Information obtained under Section 114 and covered by such 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 confidentiality 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, please 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 substantial, and an explanation 

of the causal relationship between disclosure and such harmful effects. 

 

 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).
Enclosure 3 

7042 Federal Register / Vol 56. No. 35 / Thursday, February 21, 1991 / 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 114(c) of the Clean Air Act 

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- 13), 

Research Triangle Park, NC 27711. 

FOR FURTHER INFORMATION 

CONTACT: Timothy Mohin (telephone: 

(919) 541-5349 commercial/FTS 629-5349) 

or Karen Blanchard (telephone: (919) 541- 

5503 commercial/FTS 629-5503), Pollutant 

Assessment Branch (MD- 13), Emission 

Standards Division; or Thomas Rosendahl 

(telephone: (919) 541-5404 commercial/FTS 

629-5404), National Air Data Branch 

(MD- 14), Technical Support Division; 

U.S. Environmental Protection Agency, 

Research Triangle Park, North Carolina 

27711. 

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 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 if made public, 

would divulge methods or processes entitled 

to protection as trade secrets of such person, 

the Administrator shall consider such 

confidential in accordance with the purposes 

of section 1905 of title 18 of the United 

States Code *." If the 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 

2.301(a)(2)(i): 

a. Definitions. For the purpose of this 

section, (1) Act means the Clean Air Act, as 

amended, 42 U.S.C. 7401 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 / Vol 56. No. 35 / Thursday, February 21, 1991 / 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 CO2), 

particulate or a specific toxic 

compound, and origin of emissions 

such as process vents, storage tanks or 

equipment leaks) 

Emission rate 

(eg., the amount released to the 

atmosphere over time such as kg/yr or 

lbs/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 of release in m/sec) 

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 g/g-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 as 

material 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 CAA 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 4

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

RESEARCH TRIANGLE PARK, NC 27711

JAN -5 mT

OFFICE OF

AIR QUALITY PLANNING

AND STANDARDS

DESIGNATION OF AUTHORIZED REPRESENTATIVE

FOR STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES

(SECTION 1U), NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLLUTANTS (SECTION 112), SOLID WASTE COMBUSTION (SECTION 129),

AND FEDERAL OZONE MEASURES (SECTION 183)

Under contract EPD-06-118, Research Triangle Institute (RTI) (prime contractor)

and EC/R, Inc.; BCS, Inc.; Eastern Research Group, Inc.; Innovar Environmental, Inc.;

MACTEC Federal Programs, Inc. (subcontractors) are hereby designated Authorized

Representatives of the Administrator of the United States Environmental Protection

Agency for the purpose of assisting in the development of standards of performance for

new stationary sources under 42 U.S.c. 7411, national emission standards for hazardous

air pollutants under 42 U.S.c. 7412, solid waste combustion under 42 U.S.c. 7429, and

Federal ozone measures under 42 U.S.C. 7511 (b).

This designation is made pursuant to the Clean Air Act, 42 U.S.c. 7414. The

United States Code provides that, upon presentation of this credential, the Authorized

Representatives named herein: (1) shall have a right of entry to, upon, or through any

premises in which an emission source is located or in which records required to be

maintained under 42 U.S.c. 7414 (a) (1) are located and (2) may at reasonable times have

access to and copy any records, inspect any monitoring equipment or method required

under 42 U.S.C. 7414 (a) (1), and sample any emissions that the owner or operator of

such source is required to sample.

Authorized Representatives of the Administrator are subject to the provisions of

42 U.S.C. 7414 (c) respecting confidentiality of methods or processes entitled to

protection as trade secrets, as implemented by 40 CFR 2.301 (h) (41 FR 36912,

September I, 1976).

Designation Expires: March 31, 2011

l' Sincerely,

(~~~:~ (j~~,Je-.

Director

Office of Air Quality Planning

and Standards

.. Internel Add19SS(URL) • h",:llwww.epa.gov .

Aecycl.dlRecydable • Printed will v.~01 Based Inks on Recycled Paper (MInimum 25% Postconsumerj
Enclosure 5 

January 2002 

Summary of Procedures for 

Safeguarding Clean Air Act 

Confidential Business Information

1. Purpose 

 This memorandum describes U.S. Environmental Protection Agency (EPA), Office of 

Air Quality Planning and Standards (OAQPS) policy and procedures set forth for the handling of 

information claimed as Confidential Business Information (CBI), whether submitted voluntarily 

or obtained under Section 114 of the Clean Air Act (CAA), and governed by EPA regulations in 

40 Code of Federal Regulations (CFR), Part 2, Subpart B, and other EPA regulations and 

policies. 

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. 

 d. Clean Air Act Confidential Business Information Security Manual (January 2002). 

3. Exception: 

 This document was prepared as a summary of data gathering and handling procedures 

used by the OAQPS of the EPA. Nothing in this document shall be construed as superseding or 

being in conflict with any applicable regulations, statutes, or policies to which EPA is subject. 

4. Definition: 

 Confidential Business Information - Information claimed by the provider to be 

confidential. This information may be identified with such titles as trade secret, secret, 

administrative secret, company secret, secret proprietary, privileged, administrative confidential, 

company confidential, confidential proprietary, or proprietary. NOTE: These markings should 

not be confused with the classification markings of national security information identified in 

Executive Order 11652. 
2

5. Background 

 Section 114 (c) of the CAA, as amended, reads as follows: 

“Any records, reports, or information obtained under subsection (a) shall be available to the 

public, except that upon a showing satisfactory to the Administrator by any person that records, 

reports, or information, or particular 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 Administrator shall consider such 

record, report, or information or particular portion thereof confidential 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 Act or when relevant in any proceeding under this 

Act.” 

 The treatment of CBI by EPA, including data obtained under Section 114 of the CAA, is 

governed by 40 CFR Part 2. These regulations require 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 method for asserting a claim, and (3) the effect of 

failure to assert a claim at time of submission. In addition, the regulations: (1) set forth 

procedures for the safeguarding of confidential information, (2) contain provisions for providing 

confidential information to authorize representatives, (3) contain provisions for the release of 

information to the Congress, Comptroller General, other Federal agencies, 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) prohibit 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 information under the Freedom of Information Act 

(FOIA) (5 U.S.C. 552). 

6. Procedures: 

 a. Request for Information. 

 Each request for information made under the provisions of Section 114(a) is signed by 

the Division Director. The request includes 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 CBI. 

 Upon receipt of information for which confidential treatment has been requested, the 

OAQPS Document Control Officer (DCO) logs in the material and a permanent file is 

established. If part of the material is claimed to be confidential, that portion should be marked 

“Subject to Confidentiality Claim.” In compliance 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 the confidentiality claim as prescribed by the sections. If 

the information is clearly not confidential, the Group Leader prepares a letter for the signature of 
3

the responsible Division Director to notify the business of this finding. Information claimed as 

confidential is hand carried to the OAQPS CBI Office to be logged into the OAQPS CAA CBI 

tracking system 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 persons who are authorized to 

have access to the information. A record of personnel accessing the information (Attachment A) 

is also kept on filed. By regulation, confidential information must be so marked or designated by 

the originator. The EPA takes additional measures to ensure that the proprietary designation is 

uniformly indicated and immediately observable. All unmarked or undesignated information 

(except as noted below) may be authorized for public release. 

 c. Storage of CAA CBI. 

 Folders, documents, or material containing CAA CBI (as defined) shall be secured 

according to the instructions listed in the OAQPS Security Manual. In addition, the CBI storage 

area that has been identified specifically for that purpose is equipped with a supplementary 

locking device. The storage area and files are under the direct control of the OAQPS DCO. 

 Access to the storage area is limited to the DCO, Document Control Assistant, and the 

minimum number of persons required to effectively maintain normal business operations as 

directed by the Director, Planning, Resources, and Regional Management Staff (PRRMS). 

 Files may be issued upon confirmation that the requesting individual is authorized to 

receive the information. All confidential files must be returned no later than close of business on 

the same day. The intended user must sign the CBI Control Record when checking out files. 

 Individuals signing out confidential files are responsible for their safekeeping. Files must 

never be left unattended. The information must not 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 

notation is made in the file’s control record and transfer log indicating what information was 

transmitted, the date, and the recipient. The authorized representative returns a signed receipt to 

the DCO. 

 d. Access to CAA CBI. 

 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, must sign and date the form shown in Attachment A to certify 

their access to the document. 

 The Group Leader having primary responsibility for the CAA CBI provides a 

memorandum to the DCO designating those personnel authorized to access specific CBI. No 
4

person is automatically entitled to access based solely on grade, position, or security clearance. 

The names of persons 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 representatives, contractors may be granted access to 

CAA CBI. The following conditions apply when it has been determined that disclosure is 

necessary: 

 (1) The contractor designated as a representative and its employees (a) may use such 

confidential information only for the purpose of carrying out the work required, (b) must refrain 

from disclosing the information to anyone other than EPA without having received from EPA 

prior written approval 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 request 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 designated as an authorized representative must agree that the 

conditions in the contract concerning the use and disclosure of CAA CBI are included for the 

benefit of, and shall be enforceable by, both EPA and any affected business having a proprietary 

interest in the information. 

 Information may be released to or accessed by EPA employees other than OAQPS 

employees only upon approval of the Director, PRRMS. 

 Requests for CAA CBI from other Federal agencies, Congress, the Comptroller General, 

Courts, etc., are processed in accordance with 40 CFR Part 2, Subpart B. 

 Requests under the FOIA are handled in accordance with 40 CFR Part 2, Subpart A. The 

FOIA Coordinator must be consulted prior to responding to any request for information if a 

claim of confidentiality has been asserted or if there is reason to believe that a claim might be 

made if the business knew release was intended. 

 e. Use and Disclosure of CAA CBI. 

 The CAA CBI, as defined, may not be used in publications, supporting documentation, 

memoranda, etc., that become a part of the public domain, except as provided for in 40 CFR Part 

2, Subpart B. The 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 

EPA which contain CAA CBI must be stamped “Subject to Confidentiality Claim” and a cover 

sheet must be attached to identify the material as CBI. 
5

 

 f. Handling of Other Information. 

 Reports, memoranda, documents, etc., prepared by EPA or its authorized representatives 

are not normally circulated outside EPA for comment or review prior to publication except in 

such cases as described in section 6 above. However, because industrial-data-gathering visits, 

plant inspections, and source testing can involve inadvertent receipt of CAA CBI, it is the policy 

of OAQPS to protect 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 representative discusses with a responsible 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 the industry official being consulted. 

 (2) Following an inspection, visit, or test, a trip report is prepared to include, as 

practicable, all information received by EPA or its authorized representative during the visit or 

test. The report may be prepared by either EPA or its authorized representative. The draft report 

is clearly identified with an attached yellow cover sheet. A second copy of the draft trip report is 

forwarded 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 edited copy to the responsible EPA employee within the time 

specified. The original draft is kept in the CBI file until the edited copy is returned by the 

business firm. 

 (3) When the reviewed copy is returned to 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. 

Attachments (2) 
 ATTACHMENT A 

EXAMPLE RECORD FORM FOR CBI ACCESS 
CAA CONFIDENTIAL BUSINESS INFORMATION 

CONTROL RECORD

DATE RECEIVED: RESPONSIBLE GROUP: CONTROL NUMBER:

DATE OF DOCUMENT: DOCUMENT AUTHOR:

DESCRIPTION (PROVIDING ORGANIZATION, TITLE, SUBJECT, NUMBER OF COPIES, 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

CAA Form 1 (Rev. 01/02)
 ATTACHMENT B 

EXAMPLE AUTHORIZATION 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 duties, I will have access to certain Confidential Business

Information submitted under the Clean Air 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 false 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 procedures 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 procedures 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 6 

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 testing under the ICR) to 

prepare a site-specific test plan prior to testing. A site-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 assurance 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).