Surface coating of wood building products mact

9. What are the Notification, Recordkeeping and Reporting requirements?

Initial and Other Notification Requirements

If a facility has an existing affected source, the initial notification must be submitted no later than 120 days after May 28, 2003. If the facility has a new or reconstructed affected source, initial notification musts be submitted no later than 120 days after either the date of initial startup or May 28, 2003, whichever is later.             

Depending upon the method of demonstrating compliance, affected sources may have to conduct performance tests.  Prior to conducting these performance tests, facilities must notify EPA or the delegated State or Local agency at least 60 days before the performance test is scheduled to begin.

Affected facilities are also required to send a notice of compliance status within 30 days after the compliance date as specified in the General Provisions. This report must include the compliance certification, the results of any performance tests and monitoring, and a description of how the facility will demonstrate continuing compliance.  The notification must also identify whether low-HAP materials, emission capture and control or a combination of both systems were used to comply with the standard.

Recordkeeping Requirements

Records of the organic HAP, volatile organic content and solids content of each coating applied, and the amount of coatings, thinners, and cleaning equipment used during each compliance period must be recorded to comply with the standards based on organic HAP content or organic HAP emissions on a mass basis.

If capture and control technology is used, facilities are required to keep records of the equipment monitoring parameter measurements as specified in the final rule. Facilities must also develop a start-up, shutdown, and malfunction plan and have the plan available for inspection by the Administrator upon request.

Periodic Reporting Requirements

Each reporting year is divided into two semiannual reporting periods. A facility would report on whether or not deviations for established operating limits occurred. A deviation in is any instance in which any requirement or obligation of the standard or any terms or condition adopted to meet the standard was not met.

If no deviations occurring during a semi annual reporting period, the semiannual compliance report would be submitted stating that the affected source had been in compliance.

If deviations occurred during the semi annual reporting period, the semiannual compliance report would be submitted detailing all deviations from established operating parameters for any systems used to meet compliance with the standard.

Additional information required during semiannual reporting, as applicable, includes description or discussion of the following:

• Identification of the compliance option(s) for each affected source and any time there was a change to a different compliance option
• A deviation from the emission limit
• A change from what the work practice standards if using a emission capture system and add on control device.
• If using an emission capture and add-on control device other than a solvent recovery system, a deviation from an operating limit and each time a bypass line diverts emissions from the add-on control device to the atmosphere
• A report on specific information on the periods of times the deviations occurred.
• A facility had a startup, shutdown or malfunction of an emission control device during the semiannual period and the actions taken were consistent with your startup, shutdown, and malfunction plan.