Transcript Secondary Aluminum - Illinois Environmental Protection Agency

Reporting &
Recordkeeping
Requirements
§63.1515 – 63.1517
Reporting and Recordkeeping
Requirements
• §63.1515 – Notification requirements
• §63.1516 – Reporting requirements
• §63.1517 – Recordkeeping requirements
Notification Requirements
§63.1515
Notification Requirements
Required Notices
• Initial Notification - §63.1515(a)
• 1515 Notification of compliance
status - §63. (b)
Initial Notification
Requirements
• Must submit if:
– Area source becomes a major source
– New or reconstructed affected or major
affected sources
– Intends to construct or reconstruct affected
source
• Must submit by:
– 120 days after effective date ( if startup
date precedes effective date), or
– Within 120 days of becoming subject to
rule
• Information that goes in initial notification
per 63.9(b)(2)
– Identity of relevant standard
– Owner/operator
– Physical address of source
– Nature, size, design, method of
operation, capacity
– Major or area
• In addition to initial notification,
– Notice of special compliance obligations
(see 63.6(b)(3),(4))
– Notice of performance tests and VE
tests
– Additional notice requirements for
sources using CMS
• Notification of performance tests and
VE tests
– Performance test notice – 60 days
prior to test
– Opacity or VE test notice – 30 days
prior to test
• Additional information required in
notices for sources using CMS
– Requirements defined in 63.9(g),
e.g., date of CMS performance
evaluation
Notification of Compliance
Status
• General requirements:
– Required of each owner and operator
– Within 60 days of compliance dates in
§63.1501
• General Requirements Cont’d.:
– Signed and accuracy certified by
responsible official
• May be submitted in following manner:
– In operating permit application
• May be submitted in following manner
Cont’d.:
– In amendment to operating permit
application
– Separate submittal
– Combination of above
Notification of Compliance Status
Required Information
•
All information required by 63.9, e.g.,
– Method of determining compliance
– Test results
Required Information Cont’d.
– Methods to determine continuous
compliance
– Statement as to compliance
Required Information - continued
•
•
Approved site-specific test plan and CMS
performance evaluation results
Unit labeling per §63.1506(b)
Required Information - continued
• Operating parameter value (range) for
each affected source or emission unit
– Include supporting documentation
– Procedure use to establish value
(lime, injection rate, flux rate, etc.)
Required Information - continued
•
•
Capture/collection equipment design
information
Conformance with bag leak detection
specifications
Required Information - continued
• Documentation specifications for
afterburner used on scrap
dryer/delac/decoat kiln Documentation
of specifications for sweat furnace
afterburner
– temperature/residence time
Required Information - continued
• Approved OM&M Plan
• Startup, shutdown, and malfunction
plan
Reporting Requirements
§63.1516
Required Reports
• Startup, shutdown, and malfunction
plan-§63.1516(a)
• Excess emissions/summary report§63.1516(b)
Required Reports Cont’d.
• Annual compliance certifications§63.1516(c)
Startup, Shutdown, and
Malfunction (SS&M) Plan
• Develop/implement Plan according to
63.6(e)(3)
Startup, Shutdown, and
Malfunction (SS&M) Plan Cont’d.
• For malfunctions, plan to also include:
– Procedures to determine and record
cause
– Corrective actions to be taken
Excess Emissions Summary
Report
General
• Required semiannually (every 6 months)
• 60 days after end of 6-month period
• Must contain information on CMS
performance per 63.10 (c)
Excess Emissions Summary
Report Cont’d.
General
• When no deviations from parametersreport “No excess emissions”
Report required if . . .
• Corrective action, per OM&M Plan, not
initiated within 1 hour for:
–Bag leak detection alarm
–COM deviation
–VE from aluminum scrap shredder
Report required if . . .
• Excursion from approved operating
parameter value or range
• Action taken not consistent with SS&M
Plan
Report required if . . .
• Affected source not operated according to
this subpart
• Deviation from 3-day, 24 hr rolling avg.
emission limit for SAPU
Excess Emissions Summary
Report
Required Certifications
Thermal chip dryer – Only unpainted
aluminum chips used
• Dross-only furnace – Only dross used
Required Certifications- continued
• Sidewell group 1 furnace, w/APCD– Molten metal level above top of hearth/
sidewell passage during reactive fluxing,
and
Required Certifications- continued
– Reactive fluxing only in sidewell (or
hearth) equipped with APCD for PM,
HCI, D/F
• Group 1 melting/holding furnace, w/o
APCD – Only clean charge used
Required Certifications- continued
• Group 2 furnace
– Only clean charge used
– No reactive fluxing
• In-line fluxer using no reactive flux – Only
nonreactive, non-HAP fluxes used
• Submit results of any performance test
documenting:
• Test methods and procedures
• Process operations
• Monitoring parameters ranges/values
for each test
Annual Compliance Certifications
• Required by 40 CFR part 70 or 71
• Certify continuing compliance, for the
year, based upon:
– Any period of excess emissions
reported as required
Annual Compliance
Certifications Cont’d.
– Met all monitoring, recordkeeping,
and reporting requirements
Recordkeeping
Requirements
§63.1517
Recordkeeping
Requirements
• General requirements for keeping records
– Subpart RRR
– General Provisions (63.10(b))
• Specific requirements of subpart RRR
General Recordkeeping
Requirements
Subpart RRR
• Retain records for 5 years – most recent
2 yrs onsite, remaining 3 yrs offsite
Subpart RRR Cont’d.
• Retain on microfilm, computer disks,
magnetic tape, microfiche
• Report information on paper or on disk
General Provisions
§ 63.10(b)
Required Records
• Process SS&M’s
• APCD malfunction and maintenance on
APCD
Required Records Cont’d.
• Information necessary to show
conformance with SS&M Plan, e.g.,
checklist
• Each period during which CMS
malfunctions or is inoperative
Required Records - continued
• Results of performance/ VE/opacity
tests, CMS performance evaluations
• CMS calibrations, adjustments,
maintenance
Required Records - continued
• Documentation of notifications - initial
and compliance status
• Keeps records supporting applicability
determination that source is not subject
to standard
Subpart RRR Recordkeeping
Requirements
Required Records
For affected sources/emission units
controlled by fabric filter
• If bag leak detection system used, keep
records of:
–Total operating hours of source
–Each alarm
–Time of corrective actions
–Cause of alarm, corrective actions
taken
• If COM used, keep records of:
– Opacity measurement data
– Explanations for periods when 6 minute
opacity exceeds 5%, including
–Cause and time of emissions and
corrective action taken
–Time of corrective actions
• Affected sources controlled by
afterburner, keep records of
– 15-minute average operating
temperatures
(cont’d on next page)
– Periods when 3-hr average
temperature < established minimum
–Explanation of cause, corrective
actions
– Annual Inspections
• For scrap dryer/delacq/decoat kiln
and group 1 furnace
– Subject to D/F and HCI emission
standards, and
– Controlled by lime-injected fabric filter
• Keep records of:
– 15-minute average inlet temperatures
– 3-hr block average temperature >
established max (+25F)
– Explanation of cause, corrective actions
• Sources controlled by lime-injected
fabric filter, keep records of:
– Inspections of feeder hopper to verify
presence/flow of lime
(Cont’d. on next page)
• For flow monitors, pressure drop
sensors or load cells--monitor and
sensor output
• If blockages occurred, cause and
corrective actions
• Sources controlled by lime-injected fabric
filter - continued
– Daily inspection of lime feeder setting, if
monitored
• For deviations cause of blockage and
corrective actions
– 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
records of:
– 15-minute block average flux injection
– Total flux injection rate
– Calculations
– Periods when rate > established
operating parameter value
• Corrective actions taken
• CMS, keep records required by
63.10(c ), e.g.:
– All CMS measurements
– Date/time CMS was inoperative
– Nature of repairs to CMS
– Procedures for CMS quality control
program
• Each affected source/emission unit
subject to standard in lb/ton of
feed/charge
– Records of feed/charge (or throughput)
weights
• For each operating cycle or
• Time period used in performance
test
• For group 1 furnace w/o APCD
– Approved site-specific monitoring plan
– Document conformance with plan
• For thermal chip dryer, dross-only
furnace, group 1 melting/holding
furnaces w/o APCD keep records of:
– All charge materials
• Group 1 sidewell furnace w/APCD
– Maintain operating logs documenting
• Level of molten metal during fluxing
• Fluxing only to sidewell or hearth w/ APCD
• For in-line fluxer using no reactive flux
– Maintain operating logs documenting
each flux used
• For group 2 furnaces, records of
– All charge materials
– All fluxing materials
• For each affected source/emission
unit subject to labeling requirements
– Records of monthly inspections
for proper unit labeling
• For emission capture/collection and closed
vent system
– Records of annual inspections
• Records for any approved alternative
monitoring or test procedure
• Copy of all required plans, including
– SS&M Plan
– OM&M Plan (major and area
sources)
– Site-specific SAPU emission plan
• For each SAPU
– Total charge weight, or
– Total aluminum produced for each
24-hr period
– Calculations of 3-day, 24-hr rolling
average emissions
Documents a Facility Must
Submit
• Initial notification (1time)
• Notification of compliance status (after
any req’d performance/opacity/VE test)
• OM&M Plan (1 time, updates as
needed)
• Excess emission/summary report (1/6
mo)
• Annual compliance certification (1/yr)
• Site specific test plan (Prior to
performance tests)