Reporting & Reporting & Recordkeeping Recordkeeping Requirements Requirements

§§63.1515 – 63.151763.1515 – 63.1517

Reporting and Recordkeeping Reporting and Recordkeeping RequirementsRequirements

• §§63.1515 – Notification requirements63.1515 – Notification requirements

• §§63.1516 – Reporting requirements63.1516 – Reporting requirements

• §§63.1517 – Recordkeeping requirements63.1517 – Recordkeeping requirements

Notification RequirementsNotification Requirements

§§63.151563.1515

NotificationNotification Requirements Requirements

• Initial Notification - Initial Notification - §§63.1515(a)63.1515(a)

• 1515 Notification of compliance status 1515 Notification of compliance status - - §§63. (b)63. (b)

Required Notices

Initial Notification Initial Notification RequirementsRequirements

• Must submit if:Must submit if:

– Area source becomes a major sourceArea source becomes a major source

– New or reconstructed affected or major New or reconstructed affected or major affected sourcesaffected sources

– Intends to construct or reconstruct affected Intends to construct or reconstruct affected sourcesource

• Must submit by:Must submit by:

– 120 days after effective date ( if startup 120 days after effective date ( if startup date precedes effective date), ordate precedes effective date), or

– Within 120 days of becoming subject to Within 120 days of becoming subject to rulerule

• Information that goes in initial notification Information that goes in initial notification per 63.9(b)(2)per 63.9(b)(2)

– Identity of relevant standardIdentity of relevant standard

– Owner/operatorOwner/operator

– Physical address of sourcePhysical address of source

– Nature, size, design, method of Nature, size, design, method of operation, capacityoperation, capacity

– Major or areaMajor or area

• In addition to initial notification,In addition to initial notification,

– Notice of special compliance obligations Notice of special compliance obligations (see 63.6(b)(3),(4))(see 63.6(b)(3),(4))

– Notice of performance tests and VE Notice of performance tests and VE teststests

– Additional notice requirements for Additional notice requirements for sources using CMSsources using CMS

• Notification of performance tests and Notification of performance tests and VE testsVE tests

– Performance test notice – 60 days Performance test notice – 60 days prior to testprior to test

– Opacity or VE test notice – 30 days Opacity or VE test notice – 30 days prior to testprior to test

• Additional information required in Additional information required in notices for sources using CMSnotices for sources using CMS

– Requirements defined in 63.9(g), Requirements defined in 63.9(g), e.g., date of CMS performance e.g., date of CMS performance evaluationevaluation

Notification of Compliance Notification of Compliance StatusStatus

• General requirements:General requirements:

– Required of each owner and operatorRequired of each owner and operator

– Within 60 days of compliance dates in Within 60 days of compliance dates in §§63.150163.1501

• General Requirements Cont’d.:General Requirements Cont’d.:

– Signed and accuracy certified by Signed and accuracy certified by responsible officialresponsible official

• May be submitted in following manner:May be submitted in following manner:

– In operating permit applicationIn operating permit application

• May be submitted in following manner May be submitted in following manner Cont’d.:Cont’d.:

– In amendment to operating permit In amendment to operating permit applicationapplication

– Separate submittalSeparate submittal

– Combination of aboveCombination of above

Notification of Compliance StatusNotification of Compliance Status

• All information required by 63.9, e.g., All information required by 63.9, e.g.,

– Method of determining complianceMethod of determining compliance

– Test resultsTest results

Required Information

Required Information Cont’d.Required Information Cont’d.

– Methods to determine continuous Methods to determine continuous compliancecompliance

– Statement as to complianceStatement as to compliance

• Approved site-specific test plan and CMS Approved site-specific test plan and CMS performance evaluation resultsperformance evaluation results

• Unit labeling per Unit labeling per §§63.1506(b)63.1506(b)

Required Information - continued

Required Information - continuedRequired Information - continued

• Operating parameter value (range) for Operating parameter value (range) for each affected source or emission uniteach affected source or emission unit

– Include supporting documentationInclude supporting documentation

– Procedure use to establish value Procedure use to establish value (lime, injection rate, flux rate, etc.)(lime, injection rate, flux rate, etc.)

• Capture/collection equipment design Capture/collection equipment design informationinformation

• Conformance with bag leak detection Conformance with bag leak detection specificationsspecifications

Required Information - continued

• Documentation specifications for Documentation specifications for afterburner used on scrap afterburner used on scrap dryer/delac/decoat kiln Documentation dryer/delac/decoat kiln Documentation of specifications for sweat furnace of specifications for sweat furnace afterburner afterburner

– – temperature/residence timetemperature/residence time

Required Information - continued

Required Information - continued

• Approved OM&M PlanApproved OM&M Plan

• Startup, shutdown, and malfunction Startup, shutdown, and malfunction planplan

Reporting RequirementsReporting Requirements

§§63.151663.1516

Required ReportsRequired Reports

• Startup, shutdown, and malfunction Startup, shutdown, and malfunction plan-plan-§§63.1516(a)63.1516(a)

• Excess emissions/summary report- Excess emissions/summary report- §§63.1516(b)63.1516(b)

Required Reports Cont’d.Required Reports Cont’d.

• Annual compliance certifications- Annual compliance certifications- §§63.1516(c)63.1516(c)

Startup, Shutdown, and Startup, Shutdown, and Malfunction (SS&M) PlanMalfunction (SS&M) Plan

• Develop/implement Plan according to Develop/implement Plan according to 63.6(e)(3)63.6(e)(3)

Startup, Shutdown, and Startup, Shutdown, and Malfunction (SS&M) Plan Cont’d.Malfunction (SS&M) Plan Cont’d.

• For malfunctions, plan to also include:For malfunctions, plan to also include:

– Procedures to determine and record Procedures to determine and record causecause

– Corrective actions to be takenCorrective actions to be taken

Excess Emissions Summary Excess Emissions Summary ReportReport

• Required semiannually (every 6 months)Required semiannually (every 6 months)

• 60 days after end of 6-month period60 days after end of 6-month period

• Must contain information on CMS Must contain information on CMS performance per 63.10 (c)performance per 63.10 (c)

General

Excess Emissions Summary Excess Emissions Summary Report Cont’d.Report Cont’d.

GeneralGeneral

• When no deviations from parameters-When no deviations from parameters-report “No excess emissions”report “No excess emissions”

• Corrective action, per OM&M Plan, not Corrective action, per OM&M Plan, not initiated within 1 hour for:initiated within 1 hour for:

–Bag leak detection alarmBag leak detection alarm

–COM deviationCOM deviation

–VE from aluminum scrap shredderVE from aluminum scrap shredder

Report required if . . .

ReportReport required if . . .

• Excursion from approved operating Excursion from approved operating parameter value or rangeparameter value or range

• Action taken not consistent with SS&M Action taken not consistent with SS&M PlanPlan

Report required if . . .Report required if . . .

• Affected source not operated according to Affected source not operated according to this subpartthis subpart

• Deviation from 3-day, 24 hr rolling avg. Deviation from 3-day, 24 hr rolling avg. emission limit for SAPUemission limit for SAPU

Excess Emissions Summary Excess Emissions Summary ReportReport

Thermal chip dryer – Only unpainted Thermal chip dryer – Only unpainted aluminum chips usedaluminum chips used

• Dross-only furnace – Only dross usedDross-only furnace – Only dross used

Required Certifications

Required Certifications- continued

• Sidewell group 1 furnace, w/APCD-Sidewell group 1 furnace, w/APCD-

– Molten metal level above top of hearth/ Molten metal level above top of hearth/ sidewell passage during reactive fluxing, sidewell passage during reactive fluxing, andand

Required Certifications- continuedRequired Certifications- continued

– Reactive fluxing only in sidewell (or Reactive fluxing only in sidewell (or hearth) equipped with APCD for PM, hearth) equipped with APCD for PM, HCI, D/FHCI, D/F

• Group 1 melting/holding furnace, w/o Group 1 melting/holding furnace, w/o APCD – Only clean charge usedAPCD – Only clean charge used

Required Certifications- continuedRequired Certifications- continued

• Group 2 furnaceGroup 2 furnace– Only clean charge usedOnly clean charge used– No reactive fluxingNo reactive fluxing

• In-line fluxer using no reactive flux – OnlyIn-line fluxer using no reactive flux – Only nonreactive, non-HAP fluxes usednonreactive, non-HAP fluxes used

• Submit results of any performance test Submit results of any performance test documenting:documenting:

• Test methods and proceduresTest methods and procedures• Process operationsProcess operations• Monitoring parameters ranges/values Monitoring parameters ranges/values

for each testfor each test

Annual Compliance CertificationsAnnual Compliance Certifications

• Required by 40 CFR part 70 or 71Required by 40 CFR part 70 or 71

• Certify continuing compliance, for the Certify continuing compliance, for the year, based upon:year, based upon:

– Any period of excess emissions Any period of excess emissions

reported as requiredreported as required

Annual Compliance Annual Compliance Certifications Cont’d.Certifications Cont’d.

– Met all monitoring, recordkeeping, Met all monitoring, recordkeeping, and reporting requirementsand reporting requirements

Recordkeeping Recordkeeping RequirementsRequirements§§63.151763.1517

Recordkeeping Recordkeeping RequirementsRequirements

• General requirements for keeping recordsGeneral requirements for keeping records– Subpart RRRSubpart RRR– General Provisions (63.10(b))General Provisions (63.10(b))

• Specific requirements of subpart RRRSpecific requirements of subpart RRR

General Recordkeeping General Recordkeeping Requirements Requirements

Subpart RRRSubpart RRR

• Retain records for 5 years – most recent Retain records for 5 years – most recent 2 yrs onsite, remaining 3 yrs offsite2 yrs onsite, remaining 3 yrs offsite

Subpart RRR Cont’d.Subpart RRR Cont’d.

• Retain on microfilm, computer disks, Retain on microfilm, computer disks, magnetic tape, microfichemagnetic tape, microfiche

• Report information on paper or on diskReport information on paper or on disk

General ProvisionsGeneral Provisions §§ 63.10(b) 63.10(b)

• Process SS&M’sProcess SS&M’s

• APCD malfunction and maintenance on APCD malfunction and maintenance on APCDAPCD

Required RecordsRequired Records

Required Records Cont’d.Required Records Cont’d.

• Information necessary to show Information necessary to show conformance with SS&M Plan, e.g., conformance with SS&M Plan, e.g., checklistchecklist

• Each period during which CMS Each period during which CMS malfunctions or is inoperativemalfunctions or is inoperative

Required Records - continuedRequired Records - continued

• Results of performance/ VE/opacity Results of performance/ VE/opacity tests, CMS performance evaluationstests, CMS performance evaluations

• CMS calibrations, adjustments, CMS calibrations, adjustments, maintenancemaintenance

• Documentation of notifications - initial Documentation of notifications - initial and compliance statusand compliance status

• Keeps records supporting applicability Keeps records supporting applicability determination that source is not subject determination that source is not subject to standardto standard

Required Records - continuedRequired Records - continued

Subpart RRR Recordkeeping Subpart RRR Recordkeeping RequirementsRequirements

For affected sources/emission units For affected sources/emission units controlled by fabric filtercontrolled by fabric filter

Required RecordsRequired Records

• If bag leak detection system used, keep If bag leak detection system used, keep records of:records of:

–Total operating hours of source Total operating hours of source –Each alarmEach alarm–Time of corrective actionsTime of corrective actions–Cause of alarm, corrective actions Cause of alarm, corrective actions

takentaken

• If COM used, keep records of:If COM used, keep records of:– Opacity measurement dataOpacity measurement data– Explanations for periods when 6 minute Explanations for periods when 6 minute

opacity exceeds 5%, includingopacity exceeds 5%, including–Cause and time of emissions and Cause and time of emissions and

corrective action takencorrective action taken–Time of corrective actionsTime of corrective actions

• Affected sources controlled by Affected sources controlled by afterburner, keep records ofafterburner, keep records of

– 15-minute average operating 15-minute average operating temperaturestemperatures

(cont’d on next page)(cont’d on next page)

– Periods when 3-hr average Periods when 3-hr average temperature < established minimumtemperature < established minimum

–Explanation of cause, corrective Explanation of cause, corrective actions actions

– Annual InspectionsAnnual Inspections

• For scrap dryer/delacq/decoat kiln For scrap dryer/delacq/decoat kiln and group 1 furnaceand group 1 furnace– Subject to D/F and HCI emission Subject to D/F and HCI emission

standards, andstandards, and

– Controlled by lime-injected fabric filterControlled by lime-injected fabric filter

• Keep records of:Keep records of:– 15-minute average inlet temperatures15-minute average inlet temperatures

– 3-hr block average temperature > 3-hr block average temperature > established max (+25F)established max (+25F)

– Explanation of cause, corrective actionsExplanation of cause, corrective actions

• Sources controlled by lime-injected Sources controlled by lime-injected fabric filter, keep records of:fabric filter, keep records of:– Inspections of feeder hopper to verify Inspections of feeder hopper to verify

presence/flow of limepresence/flow of lime

(Cont’d. on next page)(Cont’d. on next page)

• For flow monitors, pressure drop For flow monitors, pressure drop sensors or load cells--monitor and sensors or load cells--monitor and sensor outputsensor output

• If blockages occurred, cause and If blockages occurred, cause and corrective actionscorrective actions

– Daily inspection of lime feeder setting, if monitoredDaily inspection of lime feeder setting, if monitored• For deviations cause of blockage and corrective For deviations cause of blockage and corrective

actionsactions

• Sources controlled by lime-injected fabric Sources controlled by lime-injected fabric filter - continuedfilter - continued

– Noncontinuous lime injection system

• Monitored per approved alternative monitoring requirements (63.1510(v)), record:

–Details of each lime addition

–Average lime addition rate

• Group 1 furnaces, or in-line fluxers, keep Group 1 furnaces, or in-line fluxers, keep records of:records of:

– 15-minute block average flux injection15-minute block average flux injection

– Total flux injection rateTotal flux injection rate

– CalculationsCalculations

– Periods when rate > established Periods when rate > established operating parameter valueoperating parameter value

• Corrective actions takenCorrective actions taken

• CMS, keep records required by CMS, keep records required by 63.10(c ), e.g.:63.10(c ), e.g.:– All CMS measurementsAll CMS measurements– Date/time CMS was inoperativeDate/time CMS was inoperative– Nature of repairs to CMSNature of repairs to CMS– Procedures for CMS quality control Procedures for CMS quality control

programprogram

• Each affected source/emission unit Each affected source/emission unit subject to standard in lb/ton of subject to standard in lb/ton of feed/chargefeed/charge

– Records of feed/charge (or throughput) Records of feed/charge (or throughput) weightsweights

• For each operating cycle orFor each operating cycle or

• Time period used in performance Time period used in performance testtest

• For group 1 furnace w/o APCDFor group 1 furnace w/o APCD– Approved site-specific monitoring planApproved site-specific monitoring plan– Document conformance with planDocument conformance with plan

• For thermal chip dryer, dross-only For thermal chip dryer, dross-only furnace, group 1 melting/holding furnace, group 1 melting/holding furnaces w/o APCD keep records of:furnaces w/o APCD keep records of:– All charge materialsAll charge materials

• Group 1 sidewell furnace w/APCDGroup 1 sidewell furnace w/APCD– Maintain operating logs documentingMaintain operating logs documenting

• Level of molten metal during fluxingLevel of molten metal during fluxing• Fluxing only to sidewell or hearth w/ APCDFluxing only to sidewell or hearth w/ APCD

• For in-line fluxer using no reactive fluxFor in-line fluxer using no reactive flux

– Maintain operating logs documenting Maintain operating logs documenting each flux usedeach flux used

• For group 2 furnaces, records ofFor group 2 furnaces, records of

– All charge materialsAll charge materials

– All fluxing materialsAll fluxing materials

• For each affected source/emission For each affected source/emission unit subject to labeling requirementsunit subject to labeling requirements– Records of monthly inspections for Records of monthly inspections for

proper unit labelingproper unit labeling

• For emission capture/collection and closed For emission capture/collection and closed vent systemvent system

– Records of annual inspectionsRecords of annual inspections

• Records for anyany approved alternative monitoring or test procedure

• Copy of all required plans, includingCopy of all required plans, including

– SS&M PlanSS&M Plan

– OM&M Plan (major and area OM&M Plan (major and area sources)sources)

– Site-specific SAPU emission planSite-specific SAPU emission plan

• For each SAPUFor each SAPU

– Total charge weight, orTotal charge weight, or

– Total aluminum produced for each Total aluminum produced for each 24-hr period24-hr period

– Calculations of 3-day, 24-hr rolling Calculations of 3-day, 24-hr rolling average emissionsaverage emissions

Documents a Facility Must Documents a Facility Must SubmitSubmit

• Initial notification (1time)Initial notification (1time)

• Notification of compliance status (after Notification of compliance status (after any req’d performance/opacity/VE any req’d performance/opacity/VE test)test)

• OM&M Plan (1 time, updates as OM&M Plan (1 time, updates as needed)needed)

• Excess emission/summary report (1/6 Excess emission/summary report (1/6 mo)mo)

• Annual compliance certification (1/yr)Annual compliance certification (1/yr)

• Site specific test plan (Prior to Site specific test plan (Prior to performance tests)performance tests)