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Information about recordkeeping

Published on February 12, 2008

Author: Matild


Reporting & Recordkeeping Requirements §63.1515 – 63.1517:  Reporting & Recordkeeping Requirements §63.1515 – 63.1517 Reporting and Recordkeeping Requirements:  Reporting and Recordkeeping Requirements §63.1515 – Notification requirements §63.1516 – Reporting requirements §63.1517 – Recordkeeping requirements Notification Requirements:  Notification Requirements §63.1515 Notification Requirements:  Notification Requirements Initial Notification - §63.1515(a) 1515 Notification of compliance status - §63. (b) Required Notices Initial Notification Requirements:  Initial Notification Requirements Must submit if: Area source becomes a major source New or reconstructed affected or major affected sources Intends to construct or reconstruct affected source Slide6:  Must submit by: 120 days after effective date ( if startup date precedes effective date), or Within 120 days of becoming subject to rule Slide7:  Information that goes in initial notification per 63.9(b)(2) Identity of relevant standard Owner/operator Slide8:  Physical address of source Nature, size, design, method of operation, capacity Major or area Slide9:  In addition to initial notification, Notice of special compliance obligations (see 63.6(b)(3),(4)) Slide10:  Notice of performance tests and VE tests Additional notice requirements for sources using CMS Slide11:  Notification of performance tests and VE tests Performance test notice – 60 days prior to test Opacity or VE test notice – 30 days prior to test Slide12:  Additional information required in notices for sources using CMS Requirements defined in 63.9(g), e.g., date of CMS performance evaluation Notification of Compliance Status:  Notification of Compliance Status General requirements: Required of each owner and operator Within 60 days of compliance dates in §63.1501 Slide15:  General Requirements Cont’d.: Signed and accuracy certified by responsible official May be submitted in following manner: In operating permit application Slide16:  May be submitted in following manner Cont’d.: In amendment to operating permit application Separate submittal Combination of above Notification of Compliance Status:  Notification of Compliance Status All information required by 63.9, e.g., Method of determining compliance Test results Required Information Required Information Cont’d.:  Required Information Cont’d. Methods to determine continuous compliance Statement as to compliance Slide20:  Approved site-specific test plan and CMS performance evaluation results Unit labeling per §63.1506(b) Required Information - continued Required Information - continued:  Required Information - continued Operating parameter value (range) for each affected source or emission unit Include supporting documentation Procedure use to establish value (lime, injection rate, flux rate, etc.) Slide22:  Capture/collection equipment design information Conformance with bag leak detection specifications Required Information - continued Slide23:  Documentation specifications for afterburner used on scrap dryer/delac/decoat kiln Documentation of specifications for sweat furnace afterburner – temperature/residence time Required Information - continued Required Information - continued:  Required Information - continued Approved OM&M Plan Startup, shutdown, and malfunction plan Reporting Requirements §63.1516 :  Reporting Requirements §63.1516 Required Reports:  Required Reports Startup, shutdown, and malfunction plan-§63.1516(a) Excess emissions/summary report- §63.1516(b) Required Reports Cont’d.:  Required Reports Cont’d. Annual compliance certifications- §63.1516(c) Startup, Shutdown, and Malfunction (SS&M) Plan:  Startup, Shutdown, and Malfunction (SS&M) Plan Develop/implement Plan according to 63.6(e)(3) Startup, Shutdown, and Malfunction (SS&M) Plan Cont’d.:  Startup, Shutdown, and Malfunction (SS&M) Plan Cont’d. For malfunctions, plan to also include: Procedures to determine and record cause Corrective actions to be taken Excess Emissions Summary Report:  Excess Emissions Summary Report Required semiannually (every 6 months) 60 days after end of 6-month period Must contain information on CMS performance per 63.10 (c) General Excess Emissions Summary Report Cont’d. General:  Excess Emissions Summary Report Cont’d. General When no deviations from parameters-report “No excess emissions” Slide35:  Corrective action, per OM&M Plan, not initiated within 1 hour for: Bag leak detection alarm COM deviation VE from aluminum scrap shredder Report required if . . . Slide36:  Report required if . . . Excursion from approved operating parameter value or range Action taken not consistent with SS&M Plan Report required if . . . :  Report required if . . . Affected source not operated according to this subpart Deviation from 3-day, 24 hr rolling avg. emission limit for SAPU Excess Emissions Summary Report:  Excess Emissions Summary Report Thermal chip dryer – Only unpainted aluminum chips used Dross-only furnace – Only dross used Required Certifications Slide40:  Required Certifications- continued Sidewell group 1 furnace, w/APCD- Molten metal level above top of hearth/ sidewell passage during reactive fluxing, and Required Certifications- continued:  Required Certifications- continued Reactive fluxing only in sidewell (or hearth) equipped with APCD for PM, HCI, D/F Group 1 melting/holding furnace, w/o APCD – Only clean charge used Slide42:  Required Certifications- continued Group 2 furnace Only clean charge used No reactive fluxing In-line fluxer using no reactive flux – Only nonreactive, non-HAP fluxes used Slide43:  Submit results of any performance test documenting: Test methods and procedures Process operations Monitoring parameters ranges/values for each test Annual Compliance Certifications:  Annual Compliance Certifications Required by 40 CFR part 70 or 71 Certify continuing compliance, for the year, based upon: Any period of excess emissions reported as required Annual Compliance Certifications Cont’d.:  Annual Compliance Certifications Cont’d. Met all monitoring, recordkeeping, and reporting requirements Recordkeeping Requirements §63.1517:  Recordkeeping Requirements §63.1517 Recordkeeping Requirements:  Recordkeeping Requirements General requirements for keeping records Subpart RRR General Provisions (63.10(b)) • Specific requirements of subpart RRR General Recordkeeping Requirements Subpart RRR:  General Recordkeeping Requirements Subpart RRR Retain records for 5 years – most recent 2 yrs onsite, remaining 3 yrs offsite Subpart RRR Cont’d.:  Subpart RRR Cont’d. Retain on microfilm, computer disks, magnetic tape, microfiche Report information on paper or on disk General Provisions § 63.10(b):  General Provisions § 63.10(b) Process SS&M’s APCD malfunction and maintenance on APCD Required Records Required Records Cont’d.:  Required Records Cont’d. Information necessary to show conformance with SS&M Plan, e.g., checklist Each period during which CMS malfunctions or is inoperative Slide54:  Required Records - continued Results of performance/ VE/opacity tests, CMS performance evaluations CMS calibrations, adjustments, maintenance Slide55:  Documentation of notifications - initial and compliance status Keeps records supporting applicability determination that source is not subject to standard Required Records - continued Subpart RRR Recordkeeping Requirements :  Subpart RRR Recordkeeping Requirements For affected sources/emission units controlled by fabric filter Required Records Slide57:  If bag leak detection system used, keep records of: Total operating hours of source Each alarm Time of corrective actions Cause of alarm, corrective actions taken Slide58:  If COM used, keep records of: Opacity measurement data Explanations for periods when 6 minute opacity exceeds 5%, including Cause and time of emissions and corrective action taken Time of corrective actions Slide59:  Affected sources controlled by afterburner, keep records of 15-minute average operating temperatures (cont’d on next page) Slide60:  Periods when 3-hr average temperature < established minimum Explanation of cause, corrective actions Annual Inspections Slide61:  For scrap dryer/delacq/decoat kiln and group 1 furnace Subject to D/F and HCI emission standards, and Controlled by lime-injected fabric filter Slide62:  Keep records of: 15-minute average inlet temperatures 3-hr block average temperature > established max (+25F) Explanation of cause, corrective actions Slide63:  Sources controlled by lime-injected fabric filter, keep records of: Inspections of feeder hopper to verify presence/flow of lime (Cont’d. on next page) Slide64:  For flow monitors, pressure drop sensors or load cells--monitor and sensor output If blockages occurred, cause and corrective actions Slide65:  Daily inspection of lime feeder setting, if monitored For deviations cause of blockage and corrective actions Sources controlled by lime-injected fabric filter - continued Slide66:  Noncontinuous lime injection system Monitored per approved alternative monitoring requirements (63.1510(v)), record: Details of each lime addition Average lime addition rate Slide67:  Group 1 furnaces, or in-line fluxers, keep records of: 15-minute block average flux injection Total flux injection rate Slide68:  Calculations Periods when rate > established operating parameter value Corrective actions taken Slide69:  CMS, keep records required by 63.10(c ), e.g.: All CMS measurements Date/time CMS was inoperative Nature of repairs to CMS Procedures for CMS quality control program Slide70:  Each affected source/emission unit subject to standard in lb/ton of feed/charge Records of feed/charge (or throughput) weights For each operating cycle or Slide71:  Time period used in performance test For group 1 furnace w/o APCD Approved site-specific monitoring plan Document conformance with plan Slide72:  For thermal chip dryer, dross-only furnace, group 1 melting/holding furnaces w/o APCD keep records of: All charge materials Slide73:  Group 1 sidewell furnace w/APCD Maintain operating logs documenting Level of molten metal during fluxing Fluxing only to sidewell or hearth w/ APCD Slide74:  For in-line fluxer using no reactive flux Maintain operating logs documenting each flux used For group 2 furnaces, records of All charge materials All fluxing materials Slide75:  For each affected source/emission unit subject to labeling requirements Records of monthly inspections for proper unit labeling Slide76:  For emission capture/collection and closed vent system Records of annual inspections Records for any approved alternative monitoring or test procedure Slide77:  Copy of all required plans, including SS&M Plan OM&M Plan (major and area sources) Site-specific SAPU emission plan Slide78:  For each SAPU Total charge weight, or Total aluminum produced for each 24-hr period Calculations of 3-day, 24-hr rolling average emissions Documents a Facility Must Submit:  Documents a Facility Must Submit Initial notification (1time) Notification of compliance status (after any req’d performance/opacity/VE test) Slide81:  OM&M Plan (1 time, updates as needed) Excess emission/summary report (1/6 mo) Slide82:  Annual compliance certification (1/yr) Site specific test plan (Prior to performance tests)

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