EPA Extends the NAA for Boilers Applicable to the Area Source Boiler MACT Rule and Expands the NAA to the Notice of Compliance Status
Posted on September 17, 2012
On March 13, 2012 EPA issued a no action assurance (NAA) memorandum that no enforcement would be taken against boilers applicable to the area source Boiler MACT rule which would not complete the required initial boiler tune-up by March 21. The NAA expires either the effect date of the final rule or October 1, whichever comes sooner.
On July 18, EPA extended the NAA to December 31 and expanded it to include the required notice of compliance status that was due July 19. Therefore, boilers that have not completed the initial tune-up or notice of compliance status should do so out of an abundance of caution by December 31.
The most interesting part of the July NAA is that we can infer that the reproposed Boiler MACT rules for area and major sources along with the non-hazardous secondary material rule will not be finalized until after the November election. Once finalized the compliance clock starts and the first action required by sources will be to submit a new initial notification within 120 days of the rule.
For more information on how Environmental 360 can assist your facility with Boiler MACT compliance, please contact Dell Majure at Dell.Majure@environmental360.com
Source: E360 Old Site