19. In the guidelines for the statistical evaluation it states: If two quarterly evaluations back-to -back (i.e., total over a 6-month period) meet target, then analyses may be relaxed to every twelfth shipment. Assume that they have 3 analysis per quarter. When I do this computation, do I do two separate computations, one for each quarter, using 3 data points, or do I do just one computation using all 6 data points?

Two separate computations, one for each quarter, using 3 data points should be done. At no time during the coal sampling program should you average more than the three months worth of data at a time (i.e., January/February/March, April/May/June, July/August/September, and October/November/December).

20. EPA's response to the question 4 in Part I of EPA's FAQ (referring to question 9 in Part I of EPA's ICR) states that EPA is only going to require mercury and chlorine analysis for coal. So analysis is not required for tire derived fuel?

Part I question 9, of EPA's ICR, refers to light-off fuels only. Part I of EPA's FAQ, question 1, subquestion 7 addresses fuel mixtures (in that case, petroleum coke; in your case, tire-derived fuel). We feel that, for the purposes of this information gathering effort, fuels co-fired with coal (e.g., petroleum coke, tire-derived fuel) should be included in the analyses because they are integral parts of the fuel mix (i.e., used all or most of the time as opposed to oils used for light-off or flame stabilization only). Thus, mercury and chlorine analyses should be obtained on the tire-derived fuel.

21. What analyses do I need to provide if I co-fire coal with another fuel?

The full range of analyses required for coal (i.e., moisture, ash, Btu, sulfur, mercury, and chlorine content) are also required for all fuels co-fired with coal. Examples of such fuels are petroleum coke and tire-derived fuel, but may include others. These analyses are being required because these fuels are integral parts of the fuel mix and are fired continually (or nearly continually) with the coal, even if the portion of the total Btu input provided by these fuels is small. Analyses of these co-fired fuels should be taken on the same frequency required for coal (i.e., every sixth shipment to start) and are subject to the same statistical analysis requirements. Fuels used only for light-off or for flame stabilization (e.g., oil) are not required to be analyzed because they are not integral parts of the fuel mix.

22. Why do I have to sample and analyze my petroleum coke and tires?

The EPA's information gathering effort focuses on fossil-fuel fired units, and specifically on coal-fired units (i.e., those units that utilize coal for all or part of their heat input). Solid fuels mixed, and fired, with coal were included in the information gathering effort early on (i.e., EPA is not just now asking for information on these fuels; questions relating to such fuels came up before the January 1, 1999 initiation of analyses). In the FAQ for Part I, question 1, subquestion 7 addressed the EPA's requirements related to fuel mixtures. The EPA feels that, for the purposes of this information gathering effort, fuels (particularly solid fuels) co-fired with coal (e.g., petroleum coke, tire-derived fuel) should be included in the analyses because they are integral parts of the fuel mix (i.e., used all or most of the time as opposed to oils used for light-off or flame stabilization only), are fired like coal, and are within the spirit and intent of the program approved by the Office of Management and Budget. Thus, mercury and chlorine analyses should be obtained on such fuels.

23. When will the fuel usage portion of the webpage be available for data entry?

The fuel usage part of the ICR webpage is now available for uploading monthly unit fuel consumption data (for instructions on use please download the website users guide). The unit fuel consumption data cannot be entered using the bulk data file spreadsheets as they are unit-based and not facility-based, so you must manually enter the fuel usage tonnages in the Fuel Usage webpage.