P.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

29) ll-E-47 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:45 AM Sheet 29 of 86 
P.2 

V 

A-90-19 

ll-E-47 

MEMORANDUM 

DATE: July 17, 1992 

SUBJECT: Meeting with CMA on HON Monitoring, Reporting, and 

Recordkeeping Requirements 

On July 17, 1992, representatives of the Chemical 

Manufacturers Association (CMA) and the Environmental Protection 

Agency (EPA) met to discuss the monitoring, reporting, and 

recordkeeping requirements in the draft proposed hazardous 

organic national emission standards for hazardous air pollutants 

(NESHAP), commonly known as the HON. A list of participants is 

provided in Attachment A. The agenda for the meeting is provided 

in Attachment B. 

During the first two hours of the meeting, the participants 

discussed the ideas outlined by CMA in Attachment C. The 

following specific ideas were discussed: 

1) including cross references in the HON to clarify when 

there are requirements in other rules that also apply to HON 

sources (i.e., the General Provisions and the Operating Permits 

rule); 

2) reorganizing the HON by control methods between proposal 

and promulgation; 

3) allowing semi-annual reporting of all "exceedances" (or 

"deviations") and test results, with spot reports for events that 

are likely to be associated with unusual emissions; 

4) limiting recordkeeping to the periods of "exceedances", 

as well as those periods immediately before and after the 

"exceedances", but not requiring records to be kept from other 

periods not directly connected to an "exceedance"; 

5) establishing an incentive system that could be used to 

increase the recordkeeping and reporting burden for sources with 

bad performance records (i.e., numerous "exceedances" would lead 

to reporting more frequently than every six months); 
P.3 

6) allowing sources to keep records, but not submit reports, 

on design specifications, initial performance tests and other 

actions not related to routine compliance, with the understanding 

that the source would have to report the results of performance 

tests or TRE calculations, but not the whole documentation; and 

7) overriding Section 63.8(b)(2)(i) of the General 

Provisions requiring monitoring for each of multiple entry points 

into a control device since it is not necessary to show 

compliance with HON. 

In addition, the EPA agreed to research if it is appropriate 

to let the permitting authority (or other agencies with delegated 

enforcement authority) establish: 

1) alternative operating ranges for the parameters specified 

in the HON for reference controls; and 

2) alternative operating parameters and acceptable ranges 

for monitoring the effectiveness of a reference control. 

The CMA distributed two graphs (Attachment D) which show 

temperature variations of the outlet temperature of a condenser. 

The EPA and CMA agreed to table discussion of CMA's item D.l 

because it is already under review by the process vents work 

group. 

In the third hour of the meeting, Attachments E and F were 

used as guides for discussion. Attachment E was provided by CMA 

and was developed based on Attachment F. Attachment F had 

previously been supplied to CMA by the EPA. At this point in the 

meeting, the EPA agreed to research the following topics: 

1) the purpose for and utility of a maintenance plan for 

storage vessel controls; 

2) the need for a record of maintenance activities for 

storage vessels; 

3) the appropriateness and consistency with other 

regulations of the words "exceedance" and "deviation"; 

4) the need to maintain certain data for 5 years; 

5) the need for data on the duration of the loading for 

performance tests for transfer operations; and 
P.4 

6) the consistency between control requirements for process 

vents and transfer operations. 

The EPA also agreed to review the HON for redundancy between 

the implementation plan and the initial report. Such 

redundancies will be eliminated, if possible without reducing the 

usefulness of the report. 

The EPA also agreed to clarify exactly which situations do 

and do not require the calculation of a TRE for a process vent 

stream. 

In the third discussion session, concerning exceedances and 

deviations, the EPA explained the relationship between the HON, 

the Enhanced Monitoring rule and the Operating Permit rule's 

requirement for an annual compliance certification. As part of 

that explanation, the EPA made it clear that, for purposes of the 

HON, an "exceedance" or "deviation" is not an automatic violation 

of the emissions standard. This is the case because the 

relationship between the operating parameters being monitored and 

the emissions from that emission point is not sufficiently 

documented. These operating parameters are monitored because 

they are generally indicative of the efficacy of the control 

device, however, there is not sufficient data to develop an 

explicit relationship between the operating parameters and 

emissions for enforcement purposes. As part of this discussion, 

the EPA agreed to attempt to clarify the role of the operating 

parameters in determining compliance with the operating 

conditions and requirements in the draft proposed HON. 

Finally, the deadline for submittal of the HON 

implementation plan was discussed. This discussion was a 

follow-up to previous discussions regarding the content of the 

HON implementation plan requirements, and how the plan will be 

used by implementing authorities like the EPA's Regional Offices 

and/or State air pollution control agencies. The implementation 

plan was originally included in the draft proposed HON as an 

early mechanism for informing implementation authorities of each 

source's plans for compliance with the HON. It was determined, 
P.5 

from various discussions with the EPA Regional and Headquarters 

staff, that other mechanisms would serve the purpose of 

initiating discussions regarding HON compliance methods. As a 

result, the EPA proposed having the plan due one and a half years 

prior to the compliance date for points included in emissions 

averages and one year prior to the compliance date for points not 

included in averages. The implementation plan would only be 

submitted in those situations when an operating permit 

application had not yet been submitted. The CMA supported these 

deadlines as likely to result in both a minimum of duplication of 

effort with the permitting system and implementation plan 

submittals that do not require numerous updates or changes prior 

to the compliance date. 

In conclusion, the group reviewed the commitments made by 

both groups. Most of the EPA's commitments are detailed above. 

The EPA and CMA both agreed to provide the EPA with ideas about 

events that might need to be reported within 10 days of their 

occurrence if there were regular semi-annual reporting for the 

HON. In addition, the EPA and CMA both agreed to develop ideas 

for an incentive system, including what would trigger stricter 

requirements, what the stricter requirements would be and how a 

source could regain their original status in terms of records and 

reports. The EPA and CMA agreed to meet by teleconference to 

report back to each other after researching the many issues and 

ideas raised in this meeting. 
P.6 

ATTACHMENT A 
CMA/EPA MEETING 

July 17, 1992 

Participant List 

P.7 

Name 

Kathy Bailey 

Ted Cromwell 

Amy Meyers 

John Ogle 

John Dege 

Linda Herring 

Daphne McMurrer 

Jan Meyer 

Norman Morrow 

Chuck Malloch 

Kimberly Perry 

Valerie Everette 

Ruth Mead 

Kimberly Caudill 

Joe Hovious 

Affiliation 

CMA 

CMA 

CMA 

Dow Chemical 

DuPont 

EPA/SDB 

EPA/SDB 

EPA/SDB 

Exxon Chemical 

Monsanto 

Monsanto 

Radian Corporation 

Radian Corporation 

Union Carbide 

Union Carbide 

Telephone Number 

202-887-1186 

202-887-1383 

202-887-1370 

409-238-2819 

302-773-4229 

919-541-5358 

919-541-0248 

919-541-5254 

504-359-7226 

314-694-8889 

618-482-6547 

919-541-9100 

919-541-9100 

304-747-3255 

203-794-5183 
P.8 

ATTACHMENT B 
P.9 

EPA/CMA MEETING ON HON MONITORING, 

RECORDKEEPING, AND REPORTING 

July 17, 1992 

Meeting Agenda 

9:00 - 10:00 Review CMA's Proposals 

10:00 - 11:00 Go Over CMA's Examples 

11:00 - 1:00 Work Through Current Requirements 

and Suggested Changes (Process 

Vents and Transfer) 

1:00 - 1:30 Lunch 

1:30 - 2:30 Tanks 

2:30 - 3:00 What is a Violation? 

3:00 - 3:30 Implementation Plan 
P.10 

ATTACHMENT C 
P.11 

za 

CHEMICAL MANUFACTURERS ASSOCIATION 

CMA ALTERNATES TO REDUCE MONITORING, RECORDKEEPING, AND REPORTING 

BURDENS WITHOUT SACRIFICING COMPLIANCE DATA 

A. HON and preamble allow sources to propose alternative monitoring, 

reporting, and recordkeeping systems and for these to be easily 

approved by permitting agency. 

B. Clarify monitoring, recordkeeping, and reporting requirements 

between overlapping or conflicting Subparts 

Clearly state all monitoring, recordkeeping 

and reporting requirements that impact HON 

sources in the HON and clearly specify in 

the HON which items in General Provisions, 

Enhanced Monitoring, etc. do not apply 

Example 63.103(a)(1) 

Greatly simplified 

compliance, better 

understanding for 

regulated community 

Greatly simplified 

compliance 

2. Separate monitoring, recordkeeping, and 

reporting provisions in HON according to 

type of control device rather than type of 

emission point. For example, put all items 

covering flares in one place, all on incinerators 

in one place, etc. 

C. Minimize recordkeeping and reporting requirements as follows 

1. One semiannual report of all deviations 

(including Subpart H) included in report at 

times to be selected by permit holder. All 

other required reports would be included in 

the semiannual report. 

2. Keep records of applicable data, defined as 

periods of deviations, plus periods when 

monitoring systems are not working. 

Reporting is 

simpler, burden 

reduced 50+% 

Reduces recordkeeping burden 

by 90+% 

3. Disincentives for poor performance, i.e., if 

number of exceptions is excessive, require all 

records for that control or monitor to be retained 

for one year. 

Do not submit reports on design, initial 

performance tests, or similar items not 

related to routine performance. Keep data 

on site for inspection on demand. 

Number of reports 

greatly reduced 

2501 M Street. NW. Washington. OC 20037 202-887-1100 Panafax 202-887-1237 Telex 89617 (CMA WSH) 
P.12 

D. Minimize unnecessary performance tests and continuing monitoring 

requirements 

1. Do not require performance tests or ongoing 

monitoring where acceptable data such as 

design calculations, engineering data or 

material balances would indicate low 

probability of Group 2 sources actually being 

Group 1 sources. 

Significantly 

reduces Group. 2 

monitoring 

2. Do not require multiple monitoring requirements for multiple entry points to a control 

device. Sample and monitor aggregate entry 

stream only. 

Provides compliance 

data with greatly 

reduced monitoring 

needs 
ATTACHMENT D 
P.14 

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P.15 

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P.16 

ATTACHMENT E 
P.17 

Details: Ref: EPA Summary 

Storaae Tanks 

63.120(d) 

2&3 

122 (a-d) 

124(e)(3) 

123 (a-c) 

0 

0 

0 

0 

0 

Process Vents 

117(a) 

117(a) 

117(c) 

117(d) 

117(b) 

117(b) 

0 

0 

0 

0 

0 

0 

Operating plan Ok 

Maintenance plan unnecessary 

Describing controls in an initial report is redundant since it 

will be required in the compliance plan and in permit. 

Maintenance plan superfluous along with record of 

maintenance activities 

(Inspections) - should be a report and should be included in 

6 month report. 

(compliance method) delete; included in permit 

conduct performance test -add "where appropriate" 

initial report w/schematic - delete since this will be part of 

permit submitted 

Revise to "alternate compliance plan can be submitted to 

Administrator for approval" 

Performance test as appropriate - redundant since it will be 

part of permit 

No initial report of performance test should be required. 

Records should be maintained. If report is mandated, should 

have 90-180 days to report. 

117 (b)(IV) o TRE records requirement should add "operating parameters" 

or calculations" 
P.18 

TyftA^t 

117(b)(IV) o No report of TRE should be required. Records would be 

available 

117(b)(v) 

118(a) 

118(d) o 

118(d) &(e) o 

118(c) o 

118(d)(5) o 

Transfer 

129(d) 

130(e)(f) 

129 (a) 

o Record only TRE calculation data 

o For seals on diversion, record date inspected and any 

deviations. 

fuel 

129(a)(7) 

129(a) 

129(b) 

130(a) 

130(b) 

0 

0 

0 

0 

0 

130(d) 

Change "exceedance" to deviation; include deviations in 

six month report 

Deviations would be in six month report 

TRE calculation is being addressed 

TRE code should be recorded only. 

Revise to maintain up-to-date description of vent system 

delete - DOT regs apply 

delete "duration of loading cycle" - Performance test should 

be representative of loading conditions. 

Should only maintain up-to-date records. Include primary 

exemption 

Keep up-to-date records only 

Keep performance test records only 

Performance tests records only 

Same as process vents 

Include deviations in six month report 

Include deviations in six month report 

jad0713c 
P.19 

ATTACHMENT F 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT 

Records 

• or 

Reports 

Report 

Report 

Record 

Report 

Record 

Report 

Record 

Requirement 

Category 

Initial 

Report 

Initial 

Report 

Initial 

Record 

Initial 

Report 

Unspecified 

Unspecified 

Performance 

Test 

Emissipn 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.117(a) 

63.117(a) 

63.117(c) 

63.117(c) 

63.117(d) 

63.117(d) 

63.117(b) 

Control 

Technique 

Any control 

device 

Any control 

device 

Any combustion 

device 

Any combustion 

device 

Alternative 

compliance 

method 

Alternative 

compliance 

method 

Any control 

device 

Incinerators, 

scrubbers, and 

boiler/process 

heater <44 MW 

and vent 

stream is not 

the primary 

fuel 

Requirement Summary 

Report selected compliance 

method 

Report change in selected 

compliance method 

Conduct performance test 

Schematic diagram of vent, 

collection system, fuel system, 

combustion device, and bypass 

system 

Submit schematic diagram from 

63.117(c) 

Administrator will specify 

recordkeeping requirements 

Administrator will specify 

reporting requirements 

Operating parameters from 

Table 3 averaged over test and 

Percent reduction or outlet 

concentrat ion 

Timeframe 

Due with 

implementation 

plan 

Due 90 days 

before change 

Due within 

180 days of 

completion of 

change 

Maintain for 

life of the 

equipment 

Due with 

implementation 

plan 

Unknown 

Unknown 

Maintain for 

5 years 

rrsumn.pv 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT (CONTINUED) 

Records 

Reports 

Report 

Record 

Report 

Record 

Report 

Report 

:Requirement 

Category 

Performance 

Test 

TRE 

Calculation 

TRE 

Calculation 

TRE 

Calculation 

TRE 

Calculation 

TRE 

Calculation 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 2 

N&E, Group 2 

N&E, Group 2 

N&E, Group 2 

N&E, Group 2 

with TRE 

>8.0 

-Regulation 

Reference 

63.117(b) 

63.117(b)(iv) 

63.117(b)(iv) 

63.117(b)(iv) 

63.117(b)(iv) 

63.117(b)(v) 

Control 

Technique 

Any boiler/ 

process heater 

Flare. 

Any control 

device 

Any product 

recovery 

device 

Any product 

recovery 

device 

None 

None 

None 

Requirement Summary 

Description of where vent stream 

is introduced 

Flare design and periods of 

visible emissions 

Submit all data from 63.117(b) 

for initial test and any 

subsequent tests (subsequent 

test required for combustion 

device efficiency or outlet 

concentration) 

Operating parameters from 

Table 4 averaged over test 

Report monitored operating 

parameter test data from 

63.117(b)(iv), Table 4 for 

initial and any subsequent TRE 

calculations 

TRE calculation data 

TRE calculation data for initial 

and any subsequent TRE 

calculations 

Initial TRE calculation data 

Timeframe 

Initial report 

due within 

30 days of test 

(63.7); 

subsequent 

report timeframe 

unknown 

Maintain for 

5 years 

Initial report 

due within 

30 days of TRE 

calculation; 

subsequent 

report timeframe 

unknown 

Maintain for 

5 years 

Initial report 

due within 

30 days of TRE 

calculation; 

subsequent 

report unknown 

Due within 

30.days of TRE 

calculation 

rrsumm.DV 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT (CONTINUED) 

Records 

or 

Reports 

Record 

Report 

Record 

Report 

Requirement 

Category 

Monitoring 

and 

Exceedances 

Exceedances 

Monitoring 

and 

Exceedances 

Exceedances 

Emission 

Points' 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 2 

with TRE 

<8.0 

N&E, Group 2 

with TRE 

<8.0 

Regulation 

Reference 

63.118(a) 

63.118(d) 

63.118(b) and 

63.113(e) 

for TRE 

exclusion 

63.118(d) and 

63.113(e) 

for TRE 

exclusion 

Control 

Technique 

Any combustion 

device 

Any combustion 

device 

Any recovery 

device 

Any recovery 

device 

Requirement Summary 

- Operating parameters from 

Table 3, 63.117 

- Periods when parameters 

exceeded 

- Continuous flow and 

periods when flow 

diverted; if seal used, 

monthly inspection records 

- Exceedances of operating 

parameters 

- Periods when vent stream 

diverted 

Periods when flare pilot 

flame is out 

- Operating parameters from 

Table 4, 63.117 

- Periods when parameters 

exceeded 

Exceedances of operating 

parameters 

Timeframe 

Up-to-date and 

for the past 

5 years 

Due each 

quarter; initial 

report due 

within 6 months 

Up-to-date and 

for the past 

5 years 

Due each 

quarter; initial 

report due 

within 6 months 

rrsuaxD.uv 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT (CONTINUED) 

Records 

or 

Reports 

Record 

Report 

Requirement 

Category 

TRE 

Calculation 

TRE 

Calculation 

Emission 

Points 

Affected 

N&E, Group 2 

N&E, Group 2 

Regulation 

Reference 

63.118(c) 

63.118(d)(5) 

Control 

Technique 

None 

None 

Requirement Summary 

For a process unit change 

(capacity, feedstock, catalyst, 

recovery equipment) 

Description of change 

- TRE calculation data per 

63.115(c) 

For TRE <8.0, recovery 

device performance test 

data from TRE calculation 

- Description of process 

unit change 

TRE calculation data 

Timeframe 

Up-to-date and 

for the past 

5 years 

Due each 

quarter; initial 

report due 

within 6 months 

rcsumn.cv 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: STORAGE VESSEL 

Records 

or 

Reports 

Record 

Record 

Report 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Initial 

Record 

Initial 

Report 

Monitoring 

Inspections 

Emission 

Points 

Affected 

N&E, Group 1 

and 2 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.124(a) 

63.124(e)(1) 

63.122(a)-(d) 

63.124(e)(2) 

63.124(b)-(d) 

Control 

Technique 

None 

Closed Vent 

Systems with 

Control 

Device 

Tank 

Modifications 

or Closed 

Vent System 

with Control 

Device 

Closed Vent 

Systems with 

Control 

Device 

Internal 

Floating Roof 

with Fixed 

Roof or When 

Converting 

External 

Floating to 

Internal 

Floating Roof 

Requirement Summary 

Record dimensions and capacity 

of vessel 

Keep detailed operating and 

maintenance plans required in 

63.120(d)(2) & (3) 

Describe controls applied to 

attain compliance (different 

formats specified for closed 

vent systems depending upon 

control device used) 

Record operating parameters 

selected and described in the 

operating plan required by 

63.120(d)(2) 

Record inspections specified in 

63.120(a), includes inspections 

prior to filling and annual 

visual inspections; for external 

floating roof: seal gap 

measurements data as specified 

in 63.120(b) 

Timeframe 

Life of equipment 

Life of equipment 

Existing: for 

flare, due within 

3 years of 

effective date; 

for device other 

than flare, due 

with 

implementation 

plan 

New: depends on 

control device 

and start-up date 

As required; 

depends on plan 

Variable; at 

least annually 

rrsumn.st 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: STORAGE VESSEL (CONTINUED) 

Records 

or 

Reports 

Record 

Record 

Report 

Report 

Requirement 

Category 

Inspections 

Exceedances 

Exceedances 

Exceedances 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.124(e)(4) 

and (5) 

63.124(e)(3) 

63.123(a)-(c) 

63.123(d) 

Control 

Technique 

Closed Vent 

System with 

Control 

Device 

Closed Vent 

System with 

Control 

Device 

Internal 

Floating 

Roof, 

External 

Floating 

Roof, or 

Conversion of 

External to 

Internal 

Closed Vent 

System with 

Control 

Device 

Requirement Summary 

Identify, explain why, and 

provide plan for inspection of 

parts of control equipment that 

are unsafe or difficult to 

inspect 

Record maintenance activities to 

include all periods when control 

equipment is out of 

specification with 63.119(e) 

Describe inspections where 

failures found; detail provided 

defining a failure and required 

information about failure and 

subsequent repair for each type 

of inspection 

Report occurrences of excess 

emissions as evidenced by: 

1) monitored-parameters 

2) measurements made for flames, 

or 3) control system malfunction 

(required contents of report 

described) 

Timeframe 

Unspecified; can 

assume for life 

of equipment 

As required by 

maintenance 

activities 

Due within 

60 days of 

inspections; 

within 15 days of 

repair if 

extension granted 

Quarterly; no 

report due if no 

excess emissions 

[63.123(d)(4)] 

rrsuxnn. st 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER 

Records 

or 

Reports 

Record 

Record 

Record 

Requ i rement 

Category 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Emission 

Points 

Affected 

N&E, Group 1 

and 2 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.129 (c) 

63.129 (d) 

63.130 (e)(f) 

Control 

Technique. 

None 

Any control 

device 

None 

Requirement Summary 

Design of loading rack and 

analysis showing throughput, 

weight percent organic HAP, and 

average vapor pressure. 

Describe vent system used to 

vent to control device. 

Vapor tightness documentation 

[63.126 (e)j for vehicles. 

Timeframe 

Up-to-date and 

for the past 

5 years 

Up-to-date and 

for the past 

5 years 

On file at 

loading rack in 

permanent form 

available for 

inspection; 

update annually. 

rcsumn.tr 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER (CONTINUED) 

Records 

or 

Reports 

Record 

Requirement 

Category 

Performance 

Test 

Emission 

Points' 

Affected 

N&E, Group 1 

Regulation 

Reference 

63.129 (a) 

Control 

Technique 

Incinerator 

Flare 

Boiler or 

Process Heater 

Absorber 

Requirement Summary 

- average firebox 

temperature 

percent reduction or 

outlet concentration 

duration of loading cycles 

- all visible emissions, 

heat content 

determinations, etc., made 

during performance test 

- continuous pilot flame 

measurements 

duration of all loading 

cycles 

all cycles when pilot 

flame is out 

- where vent stream 

introduced 

average combustion 

temperature for capacity 

<44 MW 

duration of loading cycle 

exit specific gravity or 

alternative parameters 

- percent reduction or 

outlet concentration 

- duration of loading cycle 

Timeframe 

Up-to-date and 

for the past 

5 years 

rrsunxo.tr 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER (CONTINUED) 

Records 

..'or/ 

Reports 

Record 

Report 

Requirement 

Category 

Performance 

Test 

Performance 

Test 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.129 (a)(7) 

63.129 (a) 

Control 

Technique 

Condenser 

Carbon 

Adsorber 

Scrubber 

Any Recovery 

Device 

Incinerator, 

Flare, Boiler, 

Process 

Heater, 

Absorber, 

Condenser, 

Carbon 

Adsorber, 

Scrubber 

Requirement Summary 

average exit temperature 

percent reduction or 

outlet concentration 

duration of loading cycle 

total steam mass flow, 

temperature of carbon bed 

after regeneration and 

duration of carbon bed 

steaming cycle 

percent reduction or 

outlet concentration 

duration of loading cycle 

percent reduction or 

outlet concentration 

average pH of scrubber 

effluent 

average L/G 

Allowed concentration level 

monitoring 

Report performance test data as 

specified in 63.129 (a)(l)-(8); 

varies for different control 

devices. 

Timeframe 

Up-to-date and 

for the past 

5 years 

Initial report: 

30 days after 

test 

rrsunm. tr 

oo 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER (CONTINUED) 

Records 

or 

Reports 

Report 

Record 

Record 

Record 

Report 

Requirement 

Category 

Performance 

Test 

Monitoring 

Monitoring 

Monitoring 

Exceedance 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.129 (b) 

63.130 (a) 

63.130 (b) 

63.130 (c) 

63.130 (d) 

Control 

Technique 

Boiler or 

Process Heater 

> 44 MW 

Any Control 

Device 

Any Control 

Device 

Flare 

Any Control 

Device 

Requirement Summary 

Report location where vent 

stream introduced 

Equipment operating parameters 

(Table 7), periods of 

exceedances of parameters, and 

changes in vent stream location 

for boilers 

Continuous flow data or times 

when seal is broken when 

diverting stream from control 

device. (Table 7) 

Data on flare pilot flame or 

absence of flame during loading 

cycle. 

Report data on exceedances of 

monitored parameters, periods 

when vent stream is diverted, 

periods when flare pilot flame 

absent. 

Timeframe 

Initial report: 

30 days after 

test 

Up-to-date and 

for the past 

5 years 

Up-to-date and 

for the past 

5 years 

Up-to-date and 

for the past 

5 years 

Quarterly 

rrsuxnn.tr 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER 

Records 

or 

Reports 

Record 

Record 

Record 

Record 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Emission 

Points 

Affected 

N&E, 

Group 1 and 

Group 2 

N, 

Group 1 and 

Group 2 

N&E, 

Group 1 and 

Group 2 

N&E, 

Group 1 and 

Group 2 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.146(b) 

63.146(b)(1) 

63.146(b)(2) 

63.146(b)(3) 

63.146(b)(4) 

63.146(b)(5) 

Control 

Technique 

None 

Options under 

63.138(b) for 

streams 

identified by 

63.132(c) 

Options under 

63.138(c) for 

streams 

identified by 

63.132(d) 

Alternative 

standards in 

63.138(d) for 

streams 

identified by 

63.132(c) or 

(d) 

Treatment 

processes 

Residual 

treatment 

163.138(f)) 

Requirement Summary 

Flow diagram showing each 

Wastewater stream, point of 

generation, stream 

identification 

Per stream; VOHAP concentration, 

flow rate, controlled (Y or N), 

treatment process selected 

(Table 14) 

Per stream; VOHAP concentration, 

flow rate, point of generation 

mass flow rate, Group 1 or 2 

status, identify control method, 

treatment process, revised mass 

flow rate (Table 15) 

Per stream total VOHAP 

concentration, flow rate, 

controlled (Y or N), treatment 

process selected (Table 16) 

Description, identify streams 

treated, identify parameters to 

be monitored 

Per residual; control device 

description and efficiency 

:

:Ti«^fraiie-: 

Life of equipment 

Life of equipment 

Life of equipment 

Life of equipment 

Life of equipment 

Life of equipment 

rrsunm.ww 

TJ 

CO 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER (CONTINUED) 

c •. < 

Records 

or 

Reports 

Record 

Record 

Record 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Performance 

Test 

Performance 

Test 

Performance 

Test 

Exceedances 

Emission 

Points 

Affected 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.146(c) 

63.146(d) 

63.146(e) 

63.146(f) 

63.146(g) 

Control 

Technique 

Wastewater 

Transfer 

[63.132(e) 1 

Cover 

Any control 

device 

Waste 

Management 

Unit 

(63.138) 

Any control 

device 

(63.139) 

Waste 

Management 

Unit (63.138) 

Requirement Summary 

Date, quantity, identification 

of receiver, copy of notice 

Description, materials, 

dimensions, openings, seals 

63.146(f) 

If engineering calcs, complete 

design analysis [63.146(e)(1)] 

If performance test, description 

of equipment, test protocol, 

operating conditions, test 

results 

if control device used, 

63.146(f) 

For engineering calcs, control 

device description, vent stream 

characteristics, and other 

specifics for each device ((A) 

through (G)) 

For performance test, 

documentation that Waste 

Management Unit is at peak mass 

flow rate, control device 

description, sampling and 

monitoring, test results 

For startup and shutdown, 

periods when equipment not 

operated as desiqned and from 

Table 19 but not text 

problems found in quarterly 

inspections, test results and 

problems from annual equipment 

sniffing 

Timefrejiie"'^' 

Up-to-date and 

for 2 years 

Life of equipment 

Life of equipment 

Life of equipment 

Up-to-date and 

for 2 years 

rrsunm.ww 

TJ 

CO 
Record* 

or 

Report* 

Record 

Record 

Record 

Report 

Report 

Report 

rr&i 

Requirement 

Category 

Monitoring 

and 

Exceedances 

Unspecified 

Monitoring 

and 

Exceedances 

Initial 

Report 

Initial 

Report 

Monitoring 

and 

Exceedances 

jam.ww 

REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER (CONTINUED) 

Emission 

Point* 

Affected 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.146(h) 

63.146(i) 

63.146(j) 

63.147(a) and 

(b) 

63.147(c)(1) 

63.147(c)(2) 

Control 

Technique 

Any control 

device 

Tank controls 

(63.141) 

Oil water 

separator 

(63.142) 

None 

Biological 

treatment 

unit 

Waste 

Management 

Unit 

Waste 

Management 

Unit 

Treatment 

processes 

3 

Requirement Summary 

For startup and shutdown, 

periods when not operated as 

designed, periods when flare 

pilot flame is out, raw data 

from continuous recording 

devices, records from Table 19 

(different for each control 

device) 

For wastewater tanks using 

40 CFR 60.115, keep required 

records from that rule 

Visual inspections when problems 

found, seal gap measurements 

Process unit flow diagram as 

recorded for 63.146(b); update 

when process unit change occurs 

Describe and justify selection 

of alternative monitoring 

parameters 

Table 19 provides more detail 

Visual leak inspection results 

Results of equipment sniffing 

Monitoring exceedances 

t '. 

Timeframe 

Up-to-date and 

for 2 years 

Unknown 

Up-to-date and 

for 2 years 

Existing: due 

within 90 days of 

promulgation 

new: due by 

initial startup 

Due with 

implementation 

plan 

Initial and 

quarterly 

Initial and 

annual 

Initial and 

quarterly 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER (CONTINUED) 

Records 

or 

Reports 

Report 

Report 

Report 

Requirement 

Category 

Initial 

Report 

Unspecified 

Exceedances 

Emission 

Points 

Affected 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.147(d) 

63.147(e) 

63.147(f) 

Control 

Technique 

Any 

combustion 

device 

Any control 

device 

Tank controls 

or oil water 

separators 

(63.141 or 

142) 

Tank controls 

(63.141) 

Oil/water 

separators 

(63.142) 

Requirement Summary 

Diverting vent stream 

Monitoring exceedances 

Notify Administrator of plans 

for complying with alternative 

provisions of 63.141 or 63.142 

For wastewater tanks using 

40 CFR 60.115, submit reports 

required under that rule 

Seal gap measurements 

Timeframe 

Quarterly 

Initial and 

quarterly 

Due with 

implementat ion 

plan 

Unknown 

Initial and 

quarterly 

cisuma.m