site remediation mact summary

10. What are the notification, recordkeeping and reporting requirements?

The final rule requires records and file reports to be consistent with the notification, recordkeeping, and reporting requirements in 40 CFR part 63, Subpart A. Two types of reports are required:

• Initial notification report
• Compliance reports (initial and semiannual)

The initial notification report report advises the appropriate regulatory authority of the applicability of this rule for existing sources or construction of new sources.

The initial compliance report demonstrates that compliance has been achieved. The report contains the results of the initial performance test or design evaluation; which also includes the determination of the reference operating parameter values or range and a list of the processes and equipment subject to the standards.

Subsequent compliance reports describe and deviations of monitored parameters from reference values, failures to comply with the startup, shutdown, and malfunction (SSMP) plan for control devices, and results of LDAR monitoring and control equipment inspections.

Records required by the standard must be kept for five years with at least the two most recent years being kept on the facilities premises. These records include copies of all reports that have been submitted to the responsible authority, control equipment inspection records, and monitoring data from control devices demonstrating that operating limits are being maintained.  Records from the LDAR program and storage vessel inspections, and records or startups, shutdowns and malfunctions of each control device are needed to ensure that the controls in place are continuing to be effective.