WHAT RECORDKEEPING AND REPORTING
WILL I NEED TO
DO?
RECORDKEEPING
The regulation requires that
you keep records to document compliance status with the regulation.
These records include:
The recordkeeping requirements
are described below.
Inspection and maintenance
records. Table 43
lists the various work practice standards that apply to air pollution
control systems and monitoring equipment and the frequency with
which these practices are to be conducted. Records must be maintained
to show that the work practices were conducted on schedule. The
records can take the form of a checklist; an example checklist
for a composite mesh-pad system is provided in Appendix E
of this guidebook. Also, records of all maintenance performed
on the process, air pollution control system, and monitoring equipment
must also be maintained; these records could take the form of
contractor invoices that describe the work or simply handwritten
descriptions of the maintenance performed.
Malfunction records.
Records of the occurrence, duration, and cause of any malfunction
of the process, air pollution control device, and monitoring equipment
must be maintained. If the actions required to correct the malfunctions
were consistent with those described in the operation and maintenance
(O&M) plan, then records of these actions need not be maintained.
However, records of the actions taken to correct the malfunction
when the actions are inconsistent with the O&M plan must be
maintained, and the plan must be revised accordingly.
An example of a control device
malfunction is the settling of packing material in a packed-bed
scrubber. After the initial installation of the unit, the packing
material settles which sometimes opens up a gap in the top of
horizontal flow units. Settling of the packing material should
be indicated by a loss in pressure drop across the unit because
the air flow is following the path of least resistance and bypassing
the packed bed. To correct this problem, additional packing material
should be added to the top of the packed bed.
Performance test results.
Test reports documenting the results of performance tests conducted
on the affected source must be maintained. The test report must
contain process and air pollution control system operating parameter
measurements obtained during testing as described in Table 51.
Any additional measurements required for those facilities using
a common control system to reduce emissions from multiple sources
at a facility should also be included in the test report.
Monitoring data records.
Records of the monitoring data used to determine compliance with
the emission limits must also be maintained. Table 53
lists the monitoring requirements for each of the air pollution
control systems. Monitoring data can be recorded on a simple form
that identifies the control system, the monitored parameter(s),
the value of the monitored parameter(s), and the time and date
when the parameter was monitored. An example of a monitoring data
form developed for a packed-bed scrubber is provided in Appendix E
of this guidebook.
Excess emissions records.
Excess emissions occur when the values of the monitored parameters
exceed the value or range of values established under the performance
test. You must record the start and end times and dates of each
period of excess emissions, regardless of the cause of the excess
emissions. The example monitoring data form in Appendix E
of this guidebook provides a space to record the start and end
times of excess emissions episodes.
Process records.
All tanks. The process operating time for each chromium
electroplating or chromium anodizing tank must be recorded. For
those tanks using fume suppressants, the date and time of each
addition of fume suppressants must be recorded.
Hard chromium tanks.
If you are using the actual rectifier capacity to demonstrate
that your facility is "small" (for purposes of the emission
limits), then the actual rectifier capacity expended by month
and the total capacity expended for the reporting period (semiannual
for major sources and annual for area sources) must be recorded.
Decorative chromium tanks.
For decorative chromium electroplating tanks using a trivalent
chromium bath, records of the bath components purchased must be
maintained with the wetting agent clearly identified as a bath
constituent contained in one of the bath components. These records
may be invoices showing the bath components (including the wetting
agent), quantities purchased, and date of purchase.
Miscellaneous records.
You are required to keep a copy of your O&M plan on record.
Records that support the reporting requirements described below
and that support any petitions to the EPA (e.g., requests to waive
the recordkeeping or reporting requirements of the regulation)
must also be maintained.
REPORTING
The regulation requires that
sources submit reports and notifications, which include:
All reports must be submitted
to the Administrator. The Administrator is the appropriate Regional
Office of the U. S. EPA (as listed in Table 10-1 of this
guidebook) or the delegated State or local authority. You may
contact the appropriate EPA Regional Office to identify those
State or local agencies with delegated authority. The required
reports may be sent by U. S. mail, fax, or by another courier
(including electronic submission). The reporting requirements
and deadlines are described below and illustrated in Figure 61.
Initial notifications.
If your source has an initial startup date before January 25,
1995 (this would include all existing tanks), you must submit
an initial notification to the Administrator on or before July 24,
1995 (180 days after promulgation of the final rule). An
example initial notification is provided in Appendix E of
this guidebook.
If your source is new or reconstructed
and has an initial startup after January 25, 1995, you must
submit an initial notification to the Administrator that provides:
A notification of the actual
startup date of the source must be submitted within 30 calendar
days after that startup date.
Notification of construction/reconstruction.
After January 25, 1995, no one may begin construction or
reconstruction of new or reconstructed sources without submitting
a notification of construction/reconstruction to the Administrator.
Construction or reconstruction may begin as soon as the notification
of construction/reconstruction has been submitted; approval by
the Administrator is not required. If construction or reconstruction
commenced before January 25, 1995, but startup did not occur,
then a notification of construction/ reconstruction must be submitted
by March 26, 1995. An example form for notification of construction/reconstruction
is provided in Appendix E of this guidebook.
Notification of initial
performance test.
You must notify the Administrator in writing of intent to conduct
an initial performance test at least 60 calendar days before
the scheduled date of the test to allow the Administrator to have
an observer present at the test. The Administrator may or may
not choose to have an observer present. An example form for notification
of initial performance test is provided in Appendix E of
this guidebook.
If the scheduled date for the test is changed for unforeseen reasons, you must inform the Administrator within 5 calendar days of the originally scheduled test date and must specify the date of the rescheduled test.
Notification of compliance
status. You must
submit a notification of compliance status within 90 days
after your initial performance test (if testing is required) or
no later than 30 days after your compliance date (if testing
is not required). If testing is required, a copy of the test report
must be submitted as support for the test results shown (see Table 51
for a list of items to be included in the test report). If a title V
permit has not been issued to your source, you should send the
notification of compliance status to the Administrator. If a title V
permit has been issued, you should send the notification of compliance
status to the appropriate permitting authority. An example form
for notification of compliance status is provided in Appendix E
of this guidebook.
Ongoing compliance status
reports for major sources.
If your source is located at a major source site, you must submit
ongoing compliance status reports to the Administrator every six
months. The Administrator may decide on a case-by-case basis to
require a source to submit ongoing compliance status reports more
frequently. Additionally, if a source experiences exceedances
of the emission limits as indicated by ongoing monitoring of air
pollution control system operating parameters, then the source
will be required to submit quarterly reports. An example form
for reporting ongoing compliance status is provided in Appendix E
of this guidebook.
Reduced reporting frequency.
A source that is required to submit ongoing status reports on
a quarterly or more frequent basis may reduce the frequency of
reporting to semiannual if the following conditions are met:
To reduce the reporting frequency,
the source must notify the Administrator of its intention to make
the change. This notification can take the form of a simple letter
to the Administrator that describes the initial exceedance (that
caused the source to have to report more frequently), any actions
taken to address the exceedance, the subsequent period of compliance
(at least 1 year), and the intention of the owner/operator
to reduce the frequency of submittals of ongoing compliance status
reports. The Administrator may review all previously submitted
reports or records kept by the source to make a judgement on whether
the reduced frequency request should be approved. Approval is
automatically granted if the Administrator does not issue a notice
of disapproval within 45 days after the request is submitted.
Ongoing compliance status
reports for area sources.
The owner/operator of an affected area source must also prepare
ongoing compliance status reports that contain the same information
described above for major sources. The reports must be prepared
annually and retained onsite and must be made available to the
Administrator on request. The example form for an ongoing compliance
status report provided in Appendix E of this guidebook may
be used to fulfill this requirement.
However, if both of the following
conditions are met, then semiannual reports must be prepared and
submitted to the Administrator:
Regardless if these conditions
are met, the Administrator or the permitting authority may choose
to require that ongoing compliance status reports be completed
more frequently (e.g., semiannually) and be submitted.
An area source may petition the
Administrator (as described above for major sources) to reduce
the frequency of reporting and/or retain the required reports
onsite.
Reports associated with
trivalent chromium baths.
If you use a trivalent chromium bath, you must submit the following
reports instead of the reports described above:
If you decide to change your
process (e.g., from using a trivalent chromium process to using
a hexavalent chromium process because of problems with the plating
quality), you must submit a report within 30 days after the
change that includes:
In addition, you must submit
all other applicable notifications described above according to
the schedules shown.