EPA Form 5900-86 

 OMB No. 2060-0336, Approval Expires 04/30/2012

Federal Operating Permit Program (40 CFR Part 71) 

INITIAL COMPLIANCE PLAN AND COMPLIANCE CERTIFICATION (I-COMP)

SECTION A - COMPLIANCE STATUS AND COMPLIANCE PLAN 

Complete this section for each unique combination of applicable requirements and emissions units at the 

facility. List all compliance methods (monitoring, recordkeeping and reporting) you used to determine 

compliance with the applicable requirement described above. Indicate your compliance status at this time 

for this requirement and compliance methods and check “YES” or “NO” to the follow-up question. 

Emission Unit ID(s): 

Applicable Requirement (Describe and Cite) 

Compliance Methods for the Above (Description and Citation): 

Compliance Status: 

___ In Compliance: Will you continue to comply up to permit issuance? ____Yes ____No 

___ Not In Compliance: Will you be in compliance at permit issuance? ___Yes ___No 

___ Future-Effective Requirement: Do you expect to meet this on a timely basis? ____Yes ____No 

Emission Unit ID(s): 

Applicable Requirement (Description and Citation): 

Compliance Methods for the Above (Description and Citation): 

Compliance Status: 

___ In Compliance: Will you continue to comply up to permit issuance? ____Yes ____No 

___ Not In Compliance: Will you be in compliance at permit issuance? ___Yes ___No 

___ Future-Effective Requirement: Do you expect to meet this on a timely basis? ____Yes _____No 
I-COMP 

EPA Form 5900-86 

2

B. SCHEDULE OF COMPLIANCE 

Complete this section if you answered “NO” to any of the questions in section A. Also complete this 

section if required to submit a schedule of compliance by an applicable requirement. Please attach 

copies of any judicial consent decrees or administrative orders for this requirement. 

Unit(s)____________________ Requirement_____________________________________________ 

Reason for Noncompliance. Briefly explain reason for noncompliance at time of permit issuance or 

that future-effective requirement will not be met on a timely basis: 

Narrative Description of how Source Compliance Will be Achieved. Briefly explain your plan for 

achieving compliance: 

Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable 

sequence of actions with milestones, leading to compliance, including a date for final compliance. 

 Remedial Measure or Action Date to be 

Achieved 

 

C. SCHEDULE FOR SUBMISSION OF PROGRESS REPORTS 

Only complete this section if you are required to submit one or more schedules of compliance in section B or if an 

applicable requirement requires submittal of a progress report. If a schedule of compliance is required, your 

progress report should start within 6 months of application submittal and subsequently, no less than every six 

months. One progress report may include information on multiple schedules of compliance. 

Contents of Progress Report (describe): 

First Report____/____/___ Frequency of Submittal_______________ 

Contents of Progress Report (describe): 

First Report____/____/___ Frequency of Submittal_______________ 

D. SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS 

This section must be completed once by every source. Indicate when you would prefer to 

submit compliance certifications during the term of your permit (at least once per year). 

 

Frequency of submittal______________________ Beginning____/____/____ 

 
I-COMP 

EPA Form 5900-86 

3

E. COMPLIANCE WITH ENHANCED MONITORING & COMPLIANCE CERTIFICATION REQUIREMENTS 

 

This section must be completed once by every source. To certify compliance with these, you 

must be able to certify compliance for every applicable requirement related to monitoring and 

compliance certification at every unit. 

Enhanced Monitoring Requirements: ____ In Compliance ____ Not In Compliance 

Compliance Certification Requirements: ____ In Compliance ____ Not In Compliance 
I-COMP 

EPA Form 5900-86 

4

INSTRUCTIONS FOR I-COMP 

INITIAL COMPLIANCE PLAN AND COMPLIANCE CERTIFICATION 

Section A (Compliance Status and Compliance Plan) 

Description of Applicable Requirement: Complete Section A for each unique combination of applicable 

requirements (emission limitations, standards or other similar requirements of federal rules, SIP, TIP, FIP, or 

federally-enforceable permits) that apply to particular emissions units. You will likely have to complete this 

section numerous times to include all requirements at all emission units. 

The emissions unit ID(s) should be the ones defined in section I of form GIS. If the requirement, including 

compliance method, applies in the same way to multiple emission units, you may list multiple units for a 

particular requirement. 

The descriptions here should be detailed to the individual requirement level, rather than the standard level (if 

a MACT applies to you, describe each requirement of the MACT, rather than just a citation to the MACT as a 

whole). If the requirement imposes a particular numerical limit or range, include that in your description. 

Citations to the requirements should unambiguously identify the requirement to the lowest level necessary. 

Compliance Methods: List all compliance methods (monitoring, recordkeeping and reporting) you used to 

determine compliance with the applicable requirement described above. Such methods may be required 

by the applicable requirements or performed for other reasons. List all compliance methods required by 

applicable requirements, whether you used them to determine compliance or not. 

To describe monitoring, indicate the monitoring device, the equipment, process, or pollutant monitored, 

averaging time, frequency, and a citation or cross-reference to the requirement. To describe 

recordkeeping, describe the records kept, the frequency of collection, and include a citation or crossreference to the requirement. Please indicate whether monitoring data, results, or other records kept for 

compliance purposes may be kept on-site rather than reported. To describe reporting requirements, 

describe what is reported, when it is reported, and cite or cross-reference the requirement. 

The citation or cross-reference here must unambiguously identify the requirement to the lowest level 

necessary. 

Note that Compliance Assurance Monitoring (CAM) under part 64 is also an applicable requirement that 

may impose compliance methods for title V sources and require the submittal of a CAM plan with this 

application. Also note that periodic monitoring (which may be monitoring or recordkeeping designed to 

serve as monitoring) under part 71 may be required in certain limited circumstances: when there is no 

monitoring required, monitoring is required but there is no frequency specified, or only a one-time test is 

required. You may propose periodic monitoring in your application, but the permitting authority will make 

the final decision. If you wish to propose periodic monitoring, please do so in an attachment that clearly 

identifies the requirements, the units they apply to, and what you propose for periodic monitoring. 

Compliance Status: For each requirement and associated compliance methods described above, indicate 

whether you are in compliance, not in compliance, or it is a future-effective requirement (only check one). 

This is with respect to your compliance status at the time of application submittal. You should consider all 

available information or knowledge that you have when evaluating your compliance status, including 

reference test methods and other compliance requirements that are required directly by a statute, 

regulation, or permit and Acredible evidence@ (e.g., non-reference test methods and other information 

Areadily available@ to you and already being utilized by you). For each compliance status indication, you 

must answer “YES” or “NO” as to your expectations for continuing (or future) compliance. If you answer 

“NO” to any of these questions, you will have to complete the schedule of compliance section (section B). 
I-COMP 

EPA Form 5900-86 

5

Section B (Schedule of Compliance) 

Complete this section if you answered ANO@ to any of the questions in section A. Regardless of how you 

answered the questions in section A, complete this section if required to have a schedule of compliance 

by an applicable requirement, or if a judicial consent decree or administrative order includes a schedule of 

compliance. 

Identify the applicable requirement using the same information you used in section A. Provide a brief 

explanation of the reason for noncompliance (either now or in the future). [e.g., “do not have control 

device required as BACT.”] Next, provide a brief description of what the schedule of compliance is trying 

to achieve. Then in the table provided, include a detailed schedule of remedial measures, including an 

enforceable sequence of actions with milestones, leading to compliance with the applicable requirement. 

This schedule shall resemble and be at least as stringent as that contained in any judicial consent decree 

or administrative order to which the source is subject. Any such schedule of compliance must be 

supplemental to, and not sanction noncompliance with, the applicable requirements on which it is based. 

For each remedial measure, provide the date by which the action will be completed. This schedule or one 

approved by the permitting authority will be included in the permit. 

Lastly, attach a copy of any judicial consent decrees or administrative orders for which you are providing a 

schedule of compliance. 

Section C (Schedule for Submission of Progress Reports) 

If you must submit one or more schedules of compliance (specified in section B), or if an applicable 

requirement requires submittal of a progress report, complete this section. Progress reports describe your 

progress in meeting the milestone dates for the remedial measures required by the schedule of 

compliance. Progress reports must be submitted at least every 6 months, but specific applicable 

requirements may require them more frequently. One progress report may include information on one or 

more schedules of compliance. Describe the contents of the progress report, including the date that your 

facility will begin submitting them and the frequency they will be submitted. 

Section D (Schedule for Submission of Compliance Certifications) 

All applicants must complete this section. Compliance certifications must be submitted at least every year 

unless the applicable requirement or EPA requires them more frequently. Provide the date when the first 

compliance certification will be sent. 

Section E (Compliance Status for Enhanced Monitoring and Compliance Certification) 

All applicants must complete this section. The completion of this section does not satisfy the requirement 

for the responsible official to submit a certification of truth, accuracy, and completeness (instead this is 

met by completing form CTAC and submitting it with the other forms you send to EPA). 

To certify compliance with “Enhanced Monitoring,” you must be in compliance at all emission units with 

CAM and “Periodic Monitoring” [required by '71.6(a)(3)(i)(B)], if they apply. “Compliance Certification 

Requirements” include requirements for compliance certification in title V applications and permits, and 

possibly through applicable requirements (e.g., certain MACT standards). If you have fully completed 

sections A - E of this form, you will be in compliance with the compliance certification requirement for 

applications. If you do not have a title V permit at this time, you can assume you are in compliance with 

the compliance certification requirements for permits and with periodic monitoring requirements. If you 

indicate you are “not in compliance” with either of these requirements, attach an explanation. 

END