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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)