Reinforced plastic composites production mact summary

9. What are the notification, record keeping and reporting requirements?

The Initial Notification, Notification of Performance Tests, and Notification of Compliance Status reports must be submitted by the specified dates in the final NESHAP, which may vary depending on whether the affected source is new or existing. Facilities are also required to submit semiannual compliance reports.

If a facility takes action that is inconsistent with an approved startup, shutdown, and malfunction (SSM) plan, then they would need to submit SSM reports within 2 days of starting such action, and within 7 days of ending such action. EPA requires that they keep a copy of each notification and report, along with supporting documentation for 5 years. Of this time, the 2 most recent years must be on-site. Sources must keep records related to SSM, records of performance tests, and records for each continuous parameter monitoring system.

Under the final rule, if a source must comply with the work practice standards, they also need to keep records certifying that they are in compliance with the work practices for 5 years. If they use the HAP emissions factor equations to demonstrate compliance, they must keep all data, assumptions, and calculations used to determine their HAP emissions factors.

For new and existing continuous lamination/casting operations, sources must also keep the following records when complying with the percent reduction or pound per ton requirements: All data, assumptions, and calculations used to determine the percent reduction or pounds per ton, as applicable; a brief description of the rationale for the assignment of an equation or factor to each formula; all data, assumptions, and calculations used to derive facility-specific HAP emissions estimations and factors; identification and rationale for the worst-case scenario; and documentation that the appropriate regulatory agency has approved all HAP emissions estimation equations and factors.