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Premium member Presentation Transcript Reporting & Recordkeeping Requirements §63.1515 – 63.1517: Reporting & Recordkeeping Requirements §63.1515 – 63.1517Reporting and Recordkeeping Requirements: Reporting and Recordkeeping Requirements §63.1515 – Notification requirements §63.1516 – Reporting requirements §63.1517 – Recordkeeping requirements Notification Requirements: Notification Requirements §63.1515Notification Requirements: Notification Requirements Initial Notification - §63.1515(a) 1515 Notification of compliance status - §63. (b) Required NoticesInitial 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 sourceSlide6: Must submit by: 120 days after effective date ( if startup date precedes effective date), or Within 120 days of becoming subject to ruleSlide7: Information that goes in initial notification per 63.9(b)(2) Identity of relevant standard Owner/operatorSlide8: 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 testSlide12: Additional information required in notices for sources using CMS Requirements defined in 63.9(g), e.g., date of CMS performance evaluationNotification of Compliance Status: Notification of Compliance Status General requirements: Required of each owner and operator Within 60 days of compliance dates in §63.1501Slide15: General Requirements Cont’d.: Signed and accuracy certified by responsible official May be submitted in following manner: In operating permit applicationSlide16: 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 InformationRequired 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 - continuedRequired 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 - continuedSlide23: Documentation specifications for afterburner used on scrap dryer/delac/decoat kiln Documentation of specifications for sweat furnace afterburner – temperature/residence time Required Information - continuedRequired 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) GeneralExcess 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 PlanReport 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 CertificationsSlide40: Required Certifications- continued Sidewell group 1 furnace, w/APCD- Molten metal level above top of hearth/ sidewell passage during reactive fluxing, andRequired 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 usedSlide43: Submit results of any performance test documenting: Test methods and procedures Process operations Monitoring parameters ranges/values for each testAnnual 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 requiredAnnual Compliance Certifications Cont’d.: Annual Compliance Certifications Cont’d. Met all monitoring, recordkeeping, and reporting requirements Recordkeeping Requirements§63.1517: Recordkeeping Requirements §63.1517Recordkeeping Requirements: Recordkeeping Requirements General requirements for keeping records Subpart RRR General Provisions (63.10(b)) • Specific requirements of subpart RRRGeneral 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 RecordsRequired 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 inoperativeSlide54: Required Records - continued Results of performance/ VE/opacity tests, CMS performance evaluations CMS calibrations, adjustments, maintenanceSlide55: Documentation of notifications - initial and compliance status Keeps records supporting applicability determination that source is not subject to standard Required Records - continuedSubpart 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 actionsSlide59: 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 InspectionsSlide61: 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 actionsSlide65: Daily inspection of lime feeder setting, if monitored For deviations cause of blockage and corrective actions Sources controlled by lime-injected fabric filter - continuedSlide66: Noncontinuous lime injection system Monitored per approved alternative monitoring requirements (63.1510(v)), record: Details of each lime addition Average lime addition rateSlide67: Group 1 furnaces, or in-line fluxers, keep records of: 15-minute block average flux injection Total flux injection rateSlide68: 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 programSlide70: 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 orSlide71: 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 materialsSlide73: 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 labelingSlide76: For emission capture/collection and closed vent system Records of annual inspections Records for any approved alternative monitoring or test procedureSlide77: Copy of all required plans, including SS&M Plan OM&M Plan (major and area sources) Site-specific SAPU emission planSlide78: For each SAPU Total charge weight, or Total aluminum produced for each 24-hr period Calculations of 3-day, 24-hr rolling average emissionsDocuments 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) You do not have the permission to view this presentation. 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