On December 24, 2009 EPA received approval from the Office of Management and Budget (OMB) to carry out a massive information request (ICR).  According to EPA, the ICR is necessary to support the development of  a maximum achievable control technology (MACT) rulemaking for electric generating units (EGUs).  As a result, EPA has sent a slew of Clean Air Act (CAA) Section 114 letters to affected sources.  In addition, EPA has posted the Agency’s response to comments from the November 10, 2009 submission to OMB, along with additional EPA supporting materials in the public docket established by EPA for this ICR.  This docket is available for public viewing online at http://www.regulations.gov/ under Docket ID No. EPA-HQ-OAR-2009-0234.As mentioned in an earlier web post, this is a two-part ICR with the first part being a survey of all coal- and oil-fired EGUs.  EPA plans to allow owner/operators 90 days from the receipt of a Section 114 letter to respond to the survey. 

The second part is a major emission testing program.  This program requires owner/operators to complete the required emission testing and submit specified electronic reports to EPA within 6 to 8 months.  EPA’s final estimated cost for this ICR is approximately $76 million with approximately $67 million estimated to conduct the required emission testing.  RMB is uniquely qualified to provide technical support for virtually all aspects of the ICR, given our familiarity with the rule development process, EPA reference methods, and extensive experience with various EPA reporting requirements.  Since the vacature of the original IB MACT Rule in 2007, RMB has been participating as a stakeholder in the development of the new IB MACT Rule.  Recently, RMB has provided comments on the ICR guidance document that was submitted along with the Section 114 letter to affected sources and was a participant in several EPA webinars to address a number of issues associated with the IB MACT ICR.  RMB was intimately involved, on behalf of the Utility Air Regulatory Group (UARG), with reviewing and preparing technical comments on EPA’s electric utility ICR.  In addition, RMB personnel have years of field and review experience with the proposed test methods, and RMB has been retained by many utility and industrial clients to prepare and review source test protocols and reports for submittal to regulatory agencies. 

RMB’s ICR Services

• Parts I & II Preparation and Submittal

• Agency Notifications

• Test Protocol Development and Review

• Bid Specifications

• Bid Evaluation Guidelines

• Test Coordination and Observation

• Quality Assurance (QA) of Test Results

• Data Entry with EPA’s ERT Software

• Final Report Reviews