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Miscellaneous Organic Chemical Manufacturing
NESHAP (MON) Summary
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5. What Are the Notification, Recordkeeping, and Reporting Requirements?
Recordkeeping and reporting requirements are outlined in the General
Provisions to part 63 (40 CFR part 63, subpart A),
as well as the requirements in referenced subpart
G (the HON), subpart
SS (National Emission Standards for Closed Vent Systems,
Control Devices, Recovery Devices and Routing to a Fuel Gas
System or a Process), subpart
TT (National Emission Standards for Equipment Leaks -
Control Level 1), subpart
UU (National Emission Standards for Equipment Leaks -
Control Level 2 Standards), and subpart
WW (National Emission Standards for Storage Vessels -
Control Level 2).  The
sections of subpart A that apply to the final rule are designated
in Table 12 to subpart FFFF of 40 CFR part 63 (MON). Additional
recordkeeping and reporting requirements are specific to the
final rule. For example, you are required to submit a precompliance
report if you choose to comply using an alternative monitoring
approach, use an engineering assessment to demonstrate compliance,
or comply using a control device handling less than 1 tpy
of HAP emissions. The final rule also references the SSM recordkeeping
and reporting requirements contained in 40
CFR part 63, subpart SS. Under these provisions, SSM records
are required only for events during which excess emissions
occur or events when the startup, shutdown, and malfunction
plan (SSMP) was not followed.
 Consistent
with the General Provisions, you must submit an initial notification, a notification
of compliance status (NOCS) report, and compliance reports. The initial notification
is required within 120 days of the effective date of 40 CFR 63, subpart FFFF
(MON). That brief notification serves to alert appropriate agencies (State agencies
and EPA Regional Offices) of the existence of your affected source and puts them
on notice for future compliance actions. The NOCS report, which is due 150 days
after the compliance date of the NESHAP, is a comprehensive report that describes
the affected source and the strategy being used to comply. The NOCS report is
also an important aspect of the title V permitting strategy for sources subject
to subpart FFFF. Compliance reports are required every 6 months.
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