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Dear __. _______:

The U.S. Environmental Protection Agency (EPA) has undertaken a program to acquire additional information related to emissions of mercury from electric utility steam generating units. As part of this activity, we have obtained general generating unit information from all known coal- fired electric utility steam generating units. From this universe of units, a subset has been selected for emissions testing to characterize speciated mercury emissions and the effectiveness of available control measures on such emissions.

This letter is to notify you that unit ____ at your __________ facility in _____, ____, has been selected to perform speciated mercury emissions testing at the inlet and outlet of the last emission control device installed on the selected unit. Such testing is described more fully in enclosure 1.

Selection of one of the above noted units was based on information provided by your company with regard to the method of sulfur dioxide (scrubber type) and particulate matter (electrostatic precipitator [ESP] type) control and the type of coal burned, which placed ____ in one of the matrix categories described in the material approved by the Office of Management and Budget (OMB) for this information collection effort. The information provided by your company lists for _____ _____ the following controls:

Scrubber type:	____________

Coal type:	____________

ESP type:	____________

In the event that you have, at this site, multiple units meeting the same classification (i.e., scrubber type, coal type, and ESP type), you may select for speciated mercury emissions testing whichever unit you feel to be most suitable for testing. If another unit at this site is selected, please provide supporting rationale in the site-specific test plan.

As noted in enclosure 1, a site-specific test plan and a Quality Assurance Program Plan (QAPP) must be developed for each unit to be tested. Information on the preparation of the site- specific test plan may be found in the EPA document entitled "Preparation and Review of Site- specific Test Plans" (see enclosure 2 or the Internet at http://www.epa.gov/ttn/emc/guidlnd.html). Requirements for the QAPP may be found in the EPA document entitled "EPA Requirements for Quality Assurance Project Plans for Environmental Data Operations; EPA QA/R-5" (see enclosure 3 or the Internet at http://es.epa.gov/ncerqa/qa/qa_docs.html). Further guidance on the preparation of QAPPs may be found in the document entitled "EPA Guidance for Quality Assurance Project Plans; EPA QA/G-5" which may also be found on the Internet at http://es.epa.gov/ncerqa/qa/qa_docs.html. Both the site-specific test plan and QAPP for each unit to be tested should be submitted by June 1, 1999 to:

Mr. William Grimley/Ms. Lara Autry

Emission Measurement Center (MD-19)

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Attn: Electric Utility Steam Generating Unit Mercury Test Program

The EPA will review and approve the site-specific test plan and QAPP, or provide comments for revision if necessary, within 30 days of receipt. The site-specific test plan must include proposed test dates. The testing should not begin until EPA has approved the test plan and QAPP, so please plan for EPA's 30-day review period in scheduling test dates. The EPA would prefer to have test data submitted as soon as it is convenient for owners/operators to do so, but in any event owners/operators should complete all testing such that all final emission test reports are received at the above address within 90 days of completion of testing but no later than May 31, 2000.

If the unit noted above (or one of the same classification) has been tested since January 1, 1996, and the following conditions are met, the owner/operator may elect to submit the report of that testing in lieu of conducting additional testing. The conditions that must be met for the substituted test report to be accepted include:

1. Use of the "Standard Test Method for Elemental, Oxidized, Particle-Bound, and Total Mercury in Flue Gas Generated from Coal-Fired Stationary Sources (Ontario Hydro Method)" (see enclosure 4 or the Internet at http://www.epa.gov/ttn/emc/guidlnd.html).

2. Use of quality assurance/quality control (QA/QC) procedures equivalent to those required in the QAPP.

3. Use of the report format presented in the EPA document entitled "Preparation and Review of Emission Test Reports" (see enclosure 5 or the Internet at http://www.epa.gov/ttn/emc/guidlnd.html).

4. Concurrent analyses for the mercury content of the coal fired during the test period.

As noted in previous correspondence, the authority for EPA's information gathering is included in section 114 of the Clean Air Act (CAA) (42 U.S.C. 7414). Enclosure 6 contains a summary of this authority. The EPA is requiring this information under an information collection request (ICR) approved by the Office of Management and Budget (OMB) under the Paperwork Reduction Act (OMB Control No. 2060-0396).

All information submitted to the EPA as part of this request shall be made available to the public unless a satisfactory showing is made that public access to such information would divulge methods or processes entitled to protection as trade secrets. If you believe that disclosure of specific pieces of information you submit would reveal a trade secret, you should clearly identify such pieces of information. Please do not label an entire response "confidential" if only certain portions consist of trade secret information. Refer to enclosure 6 for the information the EPA may require, at a later time, to support your confidentiality claims. Any information determined to constitute a trade secret will be protected under 18 U.S.C. 1905 and section 114 of the CAA (42 U.S.C. 7414). If no claim of confidentially accompanies the information when it is received by the EPA, it may be made available to the public by the EPA without further notice (40 CFR part 2.203, September 1, 1976). Because section 114(c) of the Act exempts emission data from claims of confidentiality, the emission data you provide may be made available to the public. A clarification of what the EPA considers to be emissions data is contained in enclosure 7. You should not mark the emissions section as confidential business information.

The EPA has contracted with Research Triangle Institute (RTI) (Contract No. 68D60014) to obtain information pertinent to the industry. Thus, as noted in enclosure 8, RTI has been designated by the EPA as an authorized representative of the Agency. Therefore, RTI has the rights discussed above and in enclosure 6. Accordingly, RTI will have access to information provided to the EPA in response to this request. As a designated representative of the Agency, RTI is subject to the provisions of 42 U.S.C. 7414(c) respecting confidentiality of methods or processes entitled to protection as trade secrets.

Enclosure 9 summarizes Agency and Emission Standards Division policies and procedures for handling privileged information and describes the EPA's contractor commitments and procedures for use of confidential materials. It is the EPA's policy that compliance by an authorized representative with the requirements detailed in enclosure 9 provides sufficient protection for the rights of submitters of privileged information.

If you have any questions regarding this authority or this letter, please contact Mr. William Maxwell at (919) 541-5430 or Mr. William Grimley at (919) 541-1065. Questions may also be directed to the Internet site established specifically for this effort at http://utility.rti.org. As questions are received, a list of "frequently asked questions" with responses will be posted on the website.

Sincerely,

Sally L. Shaver

Director

Emission Standards Division

9 Enclosures

cc:	EPA Region rep (w/o enclosures)

State rep (w/o enclosures)

William Grimley, EPA/EMAD (w/o enclosures)

William Maxwell, EPA/ESD (w/o enclosures)