plastic parts and products surface coating mact summary

9. What are the notification, recordkeeping and reporting requirements under this rule?

The owner/operator of an affected source is required to comply with the applicable requirements in the NESHAP General Provisions, Subpart A of 40 CFR Part 63. The General Provisions notification requirements include: initial notifications, notification of performance test if the facility is complying using a capture system and control device, notification of compliance status, and additional notifications required for affected sources with continuous monitoring systems. The General Provisions also require certain records and periodic reports.

Initial Notifications

The owner/operator of an existing affected source must send a notification to their EPA Regional Office and to your State agency no later than 1 year after publication of the final rule in the Federal Register. For new and reconstructed sources, the notification must be sent within 120 days after the date of initial startup or 120 days after publication of the final rule, whichever is later.

Additionally, a facility must also send a notification of planned construction or reconstruction of a source that would be subject to the final rule and apply for approval to construct or reconstruct.

Notification of Performance Test

If compliance is demonstrated by using a capture system and control device for which a liquid-liquid material balance is not conducted, a performance test must be conducted.  The performance test is required no later than the compliance date for an existing affected source. For a new or reconstructed affected source, the performance test is required no later than 180 days after startup or 180 days after Federal Register publication of the final rule, whichever is later. The owner/operator of the affected source must notify EPA (or the delegated State or local agency) at least 60 calendar days before the performance test is scheduled to begin and submit a report of the performance test results no later than 60 days after the test.

Notification of Compliance Status

A Notification of Compliance Status must be submitted within 30 days after the end of the initial 12-month compliance period. In the notification, the owner/operator must certify whether each affected source has complied with the final standards; identify the option(s) used to demonstrate initial compliance; summarize the data and calculations supporting the compliance demonstration; and provide information on any deviations from the emission limits, operating limits, or other requirements.

If a facility elects to comply with the standards by using a capture system and control device for which they conduct performance tests, the results of the tests must be provided with the notification.  The notification must also include the measured range of each monitored parameter, the operating limits established during the performance test, and information showing whether the source has complied with its operating limits during the initial compliance period.

If complying with a single emission limit representing the predominant surface coating activity, the facility must include all calculations and supporting documentation for the predominant activity determination. If complying with a facility-specific emission limit, i the calculation of the facility-specific emission limit and any supporting information must be included in the notification.

Recordkeeping Requirements

Records of reported information and all other information necessary to document compliance with the final rule must be kept for 5 years.  As required under the General Provisions, records for the 2 most recent years must be kept on-site or be readily accessible from the site (for example, by a computer network); records may be kept off-site for the remaining 3 years.  Records pertaining to the design and operation of the control and monitoring equipment must be kept for the life of the equipment. Depending on the compliance option chosen, a facility may need to keep records of the following:

• Organic HAP content or volatile organic matter content and coating solids content (for all compliance options).

• Quantity of the coatings, thinners and/or other additives, and cleaning materials used during each compliance period. If using the compliant material option for all coatings at the source, purchase records for each material used rather than a record of the volume used may be maintained.

• For the emission rate (with or without add-on controls) compliance options, calculations of emission rate for each 12-month compliance period.

• All documentation supporting initial notifications and notifications of compliance status. If  compliance is demonstrated by using a capture system and control device, the following records must be kept:

• All required measurements, calculations, and supporting documentation needed to demonstrate compliance with the standards.

• All results of performance tests and parameter monitoring.

• All information necessary to demonstrate conformance the plan for minimizing emissions from mixing, storage, and waste handling operations.

• All information necessary to demonstrate conformance with the affected source’s SSMP when the plan procedures are followed.

• The occurrence and duration of each startup, shutdown, or malfunction of the emission capture system and control device.

• Actions taken during startup, shutdown, and malfunction that are different from the procedures specified in the affected source’s SSMP.

• Each period during which a CPMS is malfunctioning or inoperative (including out-of-control periods). This rule requires facilities to collect and keep records for the CPMS. Failure to collect and keep the specified minimum data would be a deviation that is separate from any emission limits, operating limits, or work practice standards.

Deviations, as determined from these records, must be recorded and also reported.  A deviation is any instance when any requirement or obligation established by the final rule including, but not limited to, the emission limits, operating limits, and work practice standards, is not met.

If a facility uses a capture system and control device to reduce organic HAP emissions, they must make their SSMP available for inspection upon requests by the Administrator. The plan stays in their records for the life of the affected source or until the source is no longer subject to the final standards. If the plan is revised, the previous superseded versions must be kept on record for 5 years following the revision.

If a facility is using the predominant activity or facility-specific emission limit alternative, they must keep the records of the data and calculations needed to determine the predominant activity or to calculate the facility-specific emission limit for your facility.

Periodic Reports

Each reporting year is divided into two semiannual reporting periods. If no deviations occur during a semiannual reporting period, a facility must submit a semiannual report stating that the affected source has been in continuous compliance. If deviations occur, report them as follows:

• Report each deviation from the emission limit.

• Report each deviation from the work practice standards if an emission capture system and control device is used.

• Report each deviation from an operating limit and each time a bypass line diverts emissions from the control device to the atmosphere, if an emission capture system and control device is used, other than a solvent recovery system for which a liquid-liquid material balances is conducted.

• Report other specific information on the periods of time the deviations occurred.

An identification of the compliance option(s) used for each affected source and any time periods when the facility changed to another compliance option must also be included in each semiannual report.

Other Reports

Reports for periods of startup, shutdown, or malfunction of the capture system and control device must be submitted.  If the procedures followed during any startup, shutdown, or malfunction are inconsistent with the SSMP, those procedures are reported with the semiannual reports in addition to immediate reports required by 40 CFR 63.10(d)(5)(ii).