Surface Coating of Wood Building Products NESHAP (subpart QQQQ)

Summary of Final Rule

This document is intended to provide you a summary of requirements for the Surface Coating of Wood Building
Products maximum achievable control technology (MACT), which is based on the final version of the rule (68 FR
31746; May 28, 2003). This summary is intended for informational purposes, does not constitute final agency
action, and cannot be relied upon to create any rights enforceable by any party.

TABLE OF CONTENTS

Regulatory Overview

What is the background of this regulation?

Am I subject to subpart OOOO?

What is the definition of a wood building product?

Figure 1—Typical process flow diagram
What is a major source of HAP emissions?

How do I determine my potential to emit?

Table 1— Methods to determine your HAP emissions
What is an affected source?

What are the subcategories?

What are the emission limits?

Table 2—Emission Limits
What are my options for meeting the emission limits?

For each option, what am I required to do?

How do I calculate my HAP content and emission rate?

What are operating limits and how do I meet them?

What work practice standards must I meet?

What monitoring is required for my capture equipment and add-on control devices?

Figure 2—Typical thermal oxidizer
Figure 3—Typical catalytic oxidizer
When is the compliance date for subpart QQQQ?

When is the initial compliance period?

How do I demonstrate Initial Compliance with the standard?

How do I demonstrate Continuous Compliance with the standard?

What are the notification, recordkeeping, and reporting requirements?

How many sources will be affected and what are the estimated emission reductions and costs?

Figure 4—Costs to Implement subpart QOQO
What if I have questions?

Will implementation materials be available for this rule?

Table 3—Compliance Timeline for subpart QQQQ
Figure 5—Existing Source Compliance Timeline

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REGULATORY OVERVIEW

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CFR Location:

40 CFR 63 Subpart QQQQ

Regulatory Activity:

Proposal	June 21,2002 [67 FR 42400]

Promulgation May 28, 2003 [68 FR 31746]

Docket Number

OAR-2003-0002

Compliance and Reporting:	See Table 3 for information on compliance dates, performance

testing and reporting.

WHAT IS THE BACKGROUND OF THIS REGULATION?

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Pursuant to section 112 of the Clean Air Act (CAA), subpart QQQQ was added to 40 CFR Part 63.
Section 112 of the CAA requires the U. S. Environmental Protection Agency (EPA) to list categories of
major and area sources of Hazardous Air Pollutants (HAP) and to establish National Emission Standards
for Hazardous Air Pollutants (NESHAP) for the listed source categories. The Wood Building Products
(WBP) source category was originally listed as the "flatwood paneling" source category, but the name of
the source category was changed to "wood building products" to more accurately reflect the types of
products and manufacturing sources in the source category.

APPLICABILITY: AM I SUBJECT TO SUBPART QQQQ?	[back to topi

The final NESHAP applies to any new or existing affected source that performs surface coating
operations involving wood building products; uses at least 4,170 liters (1,100 gallons) of coatings per
year; and is a major source, is located at a major source, or is part of a major source of HAP emissions.
The following wood building products surface coating operations are not subject to the NESHAP:

•	Surface coating operations covered by the Plywood and Composite Wood Products
NESHAP upon promulgation (subpart DDDD);

•	Surface coating operations covered by the Wood Furniture Manufacturing NESHAP
(subpart JJ);

•	Surface coating operations occurring during the manufacture of prefabricated homes and
mobile/modular homes;

•	Surface coating operations occurring at research or laboratory facilities; janitorial,
building, and facility construction or maintenance operations; hobby shops that are
operated for personal rather than commercial purposes; non-commercial coating
operations or coating applications using handheld nonrefillable aerosol containers; and

•	Surface coating operations involving wood treatment or fire retardant operations located
at wood building products sources that involve impregnating the wood product with the
wood treatment chemicals or fire retardant by using a retort or other pressure vessel.

[§63.4681]

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If an affected source's surface coating operations are subject to the requirements of a subpart other than
QQQQ and those operations utilize at least 95% of the total annual coating usage, then the source may
demonstrate compliance with all the requirements, including all applicable emission limits, for that
subpart.

WHAT IS A WOOD BUILDING PRODUCT?	rback to topi

[§63.4681]

A wood building product is defined as any product that contains more than 50 percent by weight wood or
wood fibers excluding the weight of any glass components, and is used in the construction, either interior
or exterior, of a residential, commercial, or institutional building.

Figure 1 is a generalized process flow diagram for a wood building products surface coating operation.
Since products have different surface coating requirements, not all operations will have all steps
represented in Figure 1.

Manufactured
Panels

Surface
Preparation
(Sanding)

Apply filler
(reverse roll
coater)

Cut Grooves in
Panels

Apply
Groove Coat
(spray gun)

Apply Stain

Apply
Basecoat
(direct roll coater)



Cure Coatings in



Apply Wood
Grain Print
(rotogravure)



Apply Top Coat



Cure coatings in



Oven





(direct roll coater)



Oven

Packing,
Storage, and
Shipment

Figure 1. Typical Process Flow Diagram

WHAT IS A MAJOR SOURCE OF HAP EMISSIONS?

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A major source of HAP emissions is any stationary source or group of stationary sources located within a
contiguous area and under common control that has the potential to emit at least 9.07 Mg/yr (10 tons/yr)
of any single HAP or 22.68 Mg/yr (25 tons/yr) of any combination of HAP as defined in the NESHAP
General Provisions (40 CFR part 63, subpart A) pursuant to section 112 of the CAA.

HOW DO I DETERMINE MY POTENTIAL TO EMIT?	rback to topi

[Adapted from Potential to Emit: A Guide for Small Businesses, EPA-456/B-98-003, October 1998]

Potential to emit is determined by your maximum capacity. When calculating the potential to emit,
include all HAP emission sources located within the contiguous area and under common control, even if
the sources are unrelated to the surface coating of wood building products. To determine the potential to
emit, follow these steps.

1.	Identify all sources of emissions.

2.	Identify all HAPs that your business emits.

3.	Select a method to use to determine your HAP emissions. (See Table 1)

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4.	For each HAP, determine the maximum amount that each production process or piece of
equipment in your business can emit in one year.

5.	Add the maximum emissions from all production processes/equipment.

TABLE 1. METHODS TO DETERMINE YOUR HAP EMISSIONS	rback to topi

Method

Instructions

Test data

Conduct onsite measurements of HAP emissions.

Material-balance
calculations

Estimate HAP emissions by comparing types and quantities of inputs to
types and quantities of outputs.

Source-specific models

Formulas for HAP emissions using source-specific parameters such as types
and quantities of inputs, operating hours, and physical characteristics of
equipment.

Emission factors

Use average HAP emission rates (provided by EPA, other agencies, or
equipment vendors), multiplied by time or frequency of operation, to obtain
emissions. HAP emission factors specific to your business can be used but
should be approved by the state air pollution control agency.

WHAT IS AN AFFECTED SOURCE?	rback to topi

[§63.4682]

The regulation applies to each new, reconstructed, and existing affected source( a new affected source is

one on which construction commenced after June 21 ,2002). The affected source is the collection of all of

the items listed below that are used for surface coating of wood building products:

(1)	All coating operations as defined in §63.4781;

(2)	All storage containers and mixing vessels in which coatings, thinners, and cleaning materials are
stored or mixed;

(3)	All manual and automated equipment and containers used for conveying coatings, thinners, and
cleaning materials; and

(4)	All storage containers and all manual and automated equipment and containers used for conveying
waste materials generated by a coating operation.

WHAT ARE THE SUBCATEGORIES?	rback to topi

[§63.4681]

(1)	Doors, windows and miscellaneous. Any affected source that applies a coating to doors; finished
doorskins; windows; door and window components, such as millwork, moulding, or trim; and other
miscellaneous wood building products (including, but not limited to, moulding, trim, shingles and
shutters).

(2)	Flooring. Any affected source that applies a coating to solid wood flooring, engineered wood
flooring, or wood laminate flooring.

(3)	Interior wall paneling and tileboard. Any affected source that applies a coating to interior wall
paneling products. Tileboard is a premium interior wall paneling product.

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(4)	Other interior panels. Any affected source that applies a coating to panels that are sold for uses
other than interior wall paneling, such as coated particleboard, hardboard and perforated panels.

(5)	Exterior siding and primed door skins. Any affected source that applies a coating to panel siding,
trimboard, lap siding, and primed doorskins. A doorskin coated with more than primer is included in
the "doors, windows and miscellaneous" subcategory.

WHAT ARE THE EMISSION LIMITS?	rback to topi

[§63.4690 and Tables 1 and 2 to subpart QQQQ]

The emission limits for existing sources cannot be less stringent than the average emission limit achieved
by the best-performing 12 percent of existing sources in the category or subcategory (or the best-
performing five sources for categories or subcategories with fewer than 30 sources). Emission limits for
new or reconstructed sources are established by the best-controlled existing similar source in each of the
subcategories.

TABLE 2. EMISSION LIMITS FOR AFFECTED SOURCES

If the affected source
applies coating to products
in the following
subcategory...

Then, for existing sources, the
organic HAP emission limit in
grams HAP/L solids
(lb HAP/gal solids) is:

Or, for new or reconstructed
sources, the organic HAP
emission limit in grams HAP/L
solids (lb HAP/gal solids) is:

Doors, windows and
miscellaneous

231 (1.93)

57 (0.48)

Flooring

93 (0.78)

0 (0.00)

Interior wall paneling or
tileboard

183 (1.53)

5 (0.04)

Other interior panels

20(0.17)

0 (0.00)

Exterior siding and primed
doorskins

7 (0.06)

0 (0.00)

WHAT ARE MY OPTIONS FOR MEETING THE EMISSION LIMITS?	rback to topi

[§63.4691]

To meet the applicable emission limit(s), one of the three compliance options listed in paragraphs (1)
through (3) below must be used for each coating operation (you can use different options on different
coating operations and on the same coating operation at different times).

(1)	Compliant material option. Demonstrate that the organic HAP content of each coating used in the
coating operation(s) is less than or equal to the applicable emission limit and that each thinner and
each cleaning material used contains no organic HAP.

(2)	Emission rate without add-on controls option. Demonstrate that, based on the coatings, thinners,
and cleaning materials used in the coating operation(s), the rolling 12-month average organic HAP
emission rate for the coating operation(s) is less than or equal to the applicable emission limits.

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(3) Emission rate with add-on controls option. Demonstrate that, based on the emission capture and
add-on control efficiencies achieved and the coatings, thinners, and cleaning materials used in the
coating operation(s), the rolling 12-month average organic HAP emission rate for the coating
operation(s) is less than or equal to the applicable emission limits. You must also demonstrate that
all capture equipment and control devices for the coating operation(s) meet specified operating
limits. Affected sources utilizing add-on controls must also meet work practice standards.

FOR EACH OPTION, WHAT AM I REQUIRED TO DO?	rback to topi

If you do not use capture equipment and control devices, Subpart QQQQ requires you to do all of the
following:

~	Meet emission limits

~	Submit notifications and reports and keep records

~	Comply with 40 CFR 63, Subpart A (General Provisions)

If you use capture equipment and control devices, Subpart QQQQ requires you to do all of the following:

~	Meet emission limits

~	Meet operating limits

~	Comply with work practice standards

~	Conduct monitoring

~	Submit notifications and reports and keep records

~	Develop and implement a Start-up. Shutdown and Malfunction Plan (SSMP)

~	Comply with 40 CFR 63, Subpart A (General Provisions)

HOW DO I CALCULATE MY HAP CONTENT AND HAP EMISSION RATE? rback to topi
[§§63.4741, 63.4751, and 63.4761]

For the compliant material option, determine the mass of organic HAP and volume fraction of coating
solids for each coating. Use these values to calculate the organic HAP content of each coating (mass of
organic HAP divided by the volume fraction of the coating solids). The result must be equal to or less
than the established emission limit listed in Table 2 and each thinner and cleaning material used must
contain no organic HAP.

The emission rate without add-on controls option and the emission rate with add-on controls option
require you to use the collected coating, thinner, and cleaning material data to calculate a rolling 12-
month average organic HAP emission rate (total mass of organic HAP emitted divided by total volume of
coating solids used) on a monthly basis. Data collected from the current month is combined with the
previous 11 months' data to calculate the rolling 12-month average emission rate. The rolling 12-month
emission rate is then documented and used to demonstrate compliance with the applicable HAP emission
limit. The emission rate must be equal to or less than the established emission limit listed in Table 2.

The rule contains detailed instructions for these calculations.

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WHAT ARE OPERATING LIMITS AND HOW DO I MEET THEM?

[§63.4692]

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The operating limits are the site-specific parameter limits (e.g., temperature, flow rate) you determine for
your capture equipment and control device(s) during the performance test. Your operating limits must be
monitored by a continuous parameter monitoring system (CPMS).

WHAT WORK PRACTICE STANDARDS MUST I MEET?	rback to topi

[§63.4693]

If you use capture equipment and control device(s), you must develop, implement and maintain a work
practice plan. The plan should include actions to:

~	Store all organic-HAP coatings, thinners, cleaning materials and waste materials in closed containers

~	Cover mixing vessels containing organic-HAP except when adding, mixing or removing contents

~	Minimize emissions of organic-HAP during cleaning of storage, mixing and conveying equipment

~	Minimize spills of organic -HAP coatings, thinners, cleaning materials and waste materials

~	Minimize emissions through careful handling and transfer (conveyed from one location to another in
closed containers or pipes) of organic-HAP-containing coatings, thinners, cleaning materials, and
wastes

WHAT MONITORING IS REQUIRED FOR MY CAPTURE EQUIPMENT AND ADD-ON
CONTROL DEVICES?	[back to topi

[§63.4768]

Continuous parameter monitoring is required for all capture equipment and add-on control devices.

Capture system bypass lines: Install one of the following devices to ensure the capture equipment is not
being bypassed:

~	Flow control position indicator

~	Car-seal or lock-and-key valve closures

~	Valve closure monitoring

~	Automatic shutdown system

Carbon adsorbers: Monitor total regeneration desorbing gas mass flow and carbon bed temperature.

Catalytic and thermal oxidizers: For a thermal oxidizer, monitor gas temperature in the firebox or in the
duct immediately downstream of the firebox. For a catalytic oxidizer, monitor gas temperature
immediately before the catalyst bed A typical thermal oxidizer and catalytic oxidizer are shown in
Figure 2 and Figure 3. respectively.

Condensers: Monitor outlet gas temperature.

Concentrators: Monitor temperature in the desorption gas stream and pressure drop.

Emission capture systems: Monitor air flow and pressure drop.

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AUXILIARY FUEL

AUXILIARY FUEL

Figure 2. A typical thermal oxidizer

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Figure 3. A typical catalytic oxidizer

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WHEN IS THE COMPLIANCE DATE FOR SUBPART QQQQ?

[§63.4683]

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For an existing affected source, the compliance date is May 28, 2006. For a new or reconstructed
affected source, the compliance date is the date of initial startup of your affected source or May 28, 2003,
whichever is later.

The effective date (May 28, 2003) is the date on which the final rule was published in the Federal
Register.

The compliance requirements for new, reconstructed, and existing sources are summarized in Table 3.
The reporting timeline for existing sources, shown relative to the effective date, is shown in Figure 5.

WHEN IS THE INITIAL COMPLIANCE PERIOD?	rback to topi

[§§63.4740, 63.4750, and 63.4760]

The initial compliance period is the 12-month period beginning on the compliance date. Since the
standard (e.g., emission limits) is based on a rolling 12-month average emission rate, sources are given a
12-month period to change their surface coating operations and monitor their monthly HAP emission
rates to ensure that their initial rolling 12-month emission rate complies with the applicable emission
limit(s).

If the compliance date occurs on any day other than the first day of a month, then the initial compliance
period extends through the end of that month plus the next 12 months.

HOW DO I DEMONSTRATE INITIAL COMPLIANCE WITH THE STANDARD? rback to topi
For the Compliant Material Option (Option 1): [§63.4741]

Determine the mass of organic HAP in all coatings, thinners, and cleaning materials used and the volume
fraction of coating solids in all coatings used. Demonstrate that the organic HAP content of each coating
used is less than or equal to the applicable emission limit and that each thinner and cleaning material used
contains no organic HAP.

For the Emission Rate Without Add-On Controls Option (Option 2): [§63.4751]

Determine the mass of organic HAP in all coatings, thinners, and cleaning materials used and the volume
fraction of coating solids in all coatings used. Demonstrate that the rolling 12-month average organic
HAP emission rate from the combination of all materials used is less than or equal to the applicable
emission limit.

For the Emission Rate With Add-On Controls Option (Option 3): [§63.4761]

Determine the mass of organic HAP in all coatings, thinners, and cleaning materials used and the volume
fraction of coating solids in all coatings used. Using your performance test, determine the operating
limits that will result in capture and control efficiencies that will reduce your organic HAP rate so that it
is less than or equal to the applicable emission limit. Operating limits must be continuously monitored by
a continuous parameter monitoring system. You must also develop and implement a Work Practice Plan
and a Startup, Shutdown, and Malfunction Plan (SSMP). Demonstrate that the rolling 12-month average
organic HAP emission rate from the combination of all materials used is less than or equal to the
applicable emission limit.

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HOW DO I DEMONSTRATE CONTINOUS COMPLIANCE WITH THE
STANDARD?

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For the Compliant Material Option (Option 1): [§63.4742]

To demonstrate continuous compliance, the organic HAP content in each coating you use during the
compliance period must be less than or equal to the applicable emission limit and all thinners and
cleaning materials you use during the compliance period must contain no organic HAP.

For the Emission Rate Without Add-On Controls Option (Option 2): [§63.4752]

To demonstrate continuous compliance, the rolling 12-month average organic HAP emission rate
determined from all coatings, thinners, and cleaning materials you use during the compliance period must
be less than or equal to the applicable emission limit.

For the Emission Rate With Add-On Controls Option (Option 3): [§63.4763]

To demonstrate continuous compliance, the rolling 12-month average organic HAP emission rate
determined from all coatings, thinners, and cleaning materials you use during the compliance period,
along with the capture and control device efficiencies, must be less than or equal to the applicable
emission limit. You must also maintain continuous achievement of operating limits, and operate
according to your work practice plan and startup, shutdown, and malfunction plan.

WHAT ARE THE NOTIFICATION, REPORTING, AND RECORDKEEPING REQUIREMENTS?

[§§63.4710, 63.4720, and 63.4730]	[back to topi

These requirements are also summarized in Table 3.

Initial Notification: The initial notification states that your affected source is subject to the Wood
Building Products standards. You must submit this within 120 days after the effective date (i.e., the date
of startup or May 28, 2003, whichever is later).

Notification of Intent to Conduct a Performance Test: If your affected source is required to conduct a
performance test (e.g., because it uses add-on control equipment), you must submit a notification of intent
to conduct a performance test at least 60 days prior to the test.

Performance Test Report: If your affected source is required to conduct a performance test (e.g., because
it uses add-on control equipment), you must submit a performance test report within 60 days after
completing the performance test. The performance test is required to be conducted no later than 180 days
after the applicable compliance date for new or reconstructed sources, and no later than May 28, 2006 for
existing affected sources.

Notification of Compliance Status: If you own or operate an affected source, you must submit a
Notification of Compliance Status (NOCS) within 30 days after the initial compliance period (the first 12
months after the compliance date). The NCS certifies that your affected source has complied with the
standards, identifies the option(s) you used to demonstrate initial compliance, summarizes the data and
calculations supporting the compliance demonstration, and describes how you will determine continuous
compliance.

Semiannual Compliance Reports: After the initial compliance period, each affected source must submit
semiannual compliance reports due on July 31 and January 31.

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Startup. Shutdown, and Malfunction Reports: For sources using add-on controls, a startup, shutdown, and
malfunction report must be submitted immediately when there is a startup, shutdown, or malfunction of
the control device that is not consistent with the startup, shutdown, and malfunction plan.

Records: Affected sources are required to keep records of reported information and all other information
necessary to document compliance with the final rule for 5 years. As required under the General
Provisions, records for the 2 most recent years must be kept on-site; the other 3 years may be kept off-
site. Records pertaining to the design and operation of the control and monitoring equipment must be
kept for the life of the equipment. Depending on the compliance option that you choose, there may be
additional recordkeeping requirements, as described in the final rule.

HOW MANY SOURCES WILL BE AFFECTED, AND WHAT ARE THE ESTIMATED
EMISSION REDUCTIONS AND COSTS?	rback to topi

The EPA has estimated that there are approximately 215 major sources in the wood building products
(surface coating) source category and has identified these sources as major sources of HAP emissions
such as xylene, toluene, ethyl benzene, ethylene glycol monobutyl ether (EGBE), glycol ethers (not
including EGBE), methyl isobutyl ketone (MIBK), methanol, styrene, and formaldehyde.

This standard is estimated to reduce HAP emissions by 4,900 tons per year (tpy) (4,400 megagrams per
year (Mg/yr)) or by 63 percent.

The total annualized costs for the approximate 215 existing major sources are estimated at $22.5 million.
According to estimates, recordkeeping and reporting costs will contribute $5.6 million to the annualized
cost of this NESHAP, material costs will contribute $16.5 million, and performance testing will
contribute $308,300 (See Figure 4).

The economic impacts of the final rule are expected to be minimal, with price increases for affected wood
building products surface coating facilities expected to be only 0.04 percent.

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Figure 4. Costs to Implement Subpart QQQQ

n Material Costs

¦ Recordkeeping and Reporting Costs
D Computer Equipment Costs
~ Performance Testing Costs	

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WHAT IF I HAVE QUESTIONS?

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Mr. H. Lynn Dail is the EPA project leader and is part of the Coatings and Consumer Products Group of
EPA's Office of Air Quality Planning and Standards, Emission Standards Division. His office is located
in Research Triangle Park, North Carolina. He can be contacted via e-mail at dail.lynn@epa. gov.

WILL IMPLEMENTATION MATERIALS BE AVAILABLE FOR THIS RULE? rback to topi

Implementation materials (i.e. brochures, Q&A, example report forms, etc.) have been developed for this
rule. You can keep informed of the implementation activities planned by EPA's Office of Air Quality
Planning and Standards (OAQPS) by periodically checking the rule's implementation Plan. For Wood
Building Products, that address is www, epa. gov/ttn/atw/wbldg/wbldgplan.html

For additional information on implementation tool development activities for this rule or other surface
coating rules, you may contact Ingrid Ward of the Program Implementation and Review Group (PIRG).
Her office is also located in Research Triangle Park, North Carolina. She can be contacted via e-mail at
ward.ingrid@epa. gov.

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TABLE 3—COMPLIANCE TIMELINE FOR SUBPART QQQQ

Note: Timeline is organized by "due " date.

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Requirement...

If you are an existing source, then
requirement is due on...

If you are a new or
reconstructed source, then
requirement is due on...

Effective Date of subpart QQQQ

May 28, 2003

May 28, 2003

Initial Notification

[§63.4710(b), 63.9(b)]

September 25, 2003 - Submit 120
days after effective date

If initial startup is before the
effective date, submit by
September 25,2003, 120

days after effective date; if
initial startup is after
effective date, submit within
120 days after startup

Notification of Special
Compliance Requirements

[§63.9(d), §63.6(b)]

NA

Applies only to new sources subject
to §63.6(b)(3)-(b)(4)

Submit with Initial
Notification required under
§63.9(b)

Compliance Extension Request

May 28, 2005

NA

[§63.9(c), §63.6(1)]

Submit in accordance with §63.9(c)
- submit 12 months prior to
compliance date

Applicable only to existing
sources

Notification of Intent to Conduct
A Performance Test

[§63.9(e)]

Submit in accordance with §63.7
and §63.9(e) - 60 days prior to
beginning the test

Submit in accordance with
§63.7 and §63.9(e)- 60 days
prior to beginning the test

Performance Test

[§63.7(a)(2), §63.4760]

Complete by compliance date

Complete as required in
§63.7(a)(2)- within 180
days after compliance date

Applies only if you use a control
device





Compliance Dale

| 4(iN3|

May 28, 2006 - 3 years after
olVocli \ o dalo

l-!flocli\o dalo (\la> 2S.
2<>(i3) or upon suirliip.
\\lucho\oi' is kiior

Performance Test Reports

[§63.4720(b)]

Applies only if you use a control
device

Submit in accordance with
§63.10(d)(2)- within 60 days after
the performance test is completed

Submit in accordance with
§63.10(d)(2)- within 60 days
after the performance test is
completed

Notification of Compliance
Status (NOCS)

[§63.4710(c)]

June 30,2007

Submit 1 year and 30 days after the
Compliance Date (30 days after
Initial Compliance Period ends)

Submit 1 year and 30 days
after your Compliance date
(30 days after Initial
Compliance Period ends)

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Requirement...

If you are an existing source, then
requirement is due on...

If you are a new or
reconstructed source, then
requirement is due on...

First Semi-annual Compliance
Report

[§63.4720(a)]

July 31,2007

The initial semi-annual report
covers the period between 6/01/07
to 6/30/07

Submit by July 31 or January
31, whichever date is after
the end of the calendar half
(e.g., Jan-June and July-Dec)
that immediately follows
your initial compliance
period.

Subsequent Semi-annual
Compliance Reports

[§63.4720(a)]

Submit by July 31 (covering
January 1 through June 30) and
January 31 (covering July 1 through
December 31) of every year.

Submit by July 31 (covering
January 1 through June 30)
and January 31 (covering
July 1 through December 31)
of every year.

Periodic Start-up, Shutdown,
and Malfunction (SSM) Reports

[§63.4720(c), 63.10(d)(5)(i)]

Applies only if you use a control
device

Submit in accordance with
§63.10(d)(5), and include in your
semi-annual compliance report.

Submit in accordance with
§63.10(d)(5), and include in
your semi-annual
compliance report.

Immediate SSM Reports

[§63.4720(c), 63.10(d)(5)(h)]

Applies only if you use a control

device

[back to top]

Submit within 2 working days by
phone or fax and within 7 working
days by letter.

Submit within 2 working
days by phone or fax and
within 7 working days by
letter.

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Reporting Timeline
Existing Sources

Option 1
Option 2

Figure 5. Reporting Timeline For Existing Sources

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