EPA Expands Area Source No Action Assurance to Include Tune-Up Compliance Notification; Extends NAA Deadline to Year-end
On July 18, 2012, the EPA issued a No Action Assurance (NAA) Extension
Memo regarding the Area Source Boiler Rule to include the
requirement that facilities file notification of an initial tune-up. The EPA’s
latest action also extends
the NAA until December 31, 2012, or until the effective date of a final rule,
whichever comes first. This means the EPA will exercise its discretion not to
pursue enforcement action against facilities that fail to complete the boiler
tune-up and file notification by the compliance dates listed in the Area Source
credits a labor shortage as the reason it initially issued the NAA pertaining
to the Area Source Rule on March 13, 2012. The agency said there were not enough
qualified individuals to prepare boilers for tune-ups and then conduct those
tune-ups by the regulatory deadline of March 21, 2012. In addition, the EPA stated there is
uncertainty surrounding the pending reconsideration of the Area Source Rule.
to the expanded NAA, the EPA recognizes that facilities that have not completed
a tune-up cannot verify that they conducted one. The Area Source Rule requires facilities to
submit notification of compliance of the tune-up requirement by July 19, 2012.
The NAA extends this deadline to December 31, 2012.
“Regardless of the impending regulations, routine boiler
maintenance is recommended to ensure a boiler continues to operate at peak
efficiency year after year,” said Welch Goggins, president and CEO of Cleaver-Brooks. “To reduce fuel and operating costs,
high-pressure steam boilers that do not have a full-time boiler operator should
be serviced at least once a month and have a tune-up annually. Maintenance on a heating boiler should be
conducted at the seasonal start-up and shut-down, at the minimum.”
The expansion of the NAA applies only to the requirement
to submit a Notification of Compliance Status regarding the initial tune-up by
July 19, 2012, and it does not affect or apply to other provisions in the Area
Area source facilities subject to the tune-up requirement
include: existing coal units with heat input capacity of less than 10 million
BTU per hour and existing biomass or oil units.
For more information about Area Source Rule requirements by fuel type,
consult the decision tree available at cleaverbrooks.com/epa.
If a facility emits 10 or more tons per year of
any single air toxic or 25 tons or more per year of any combination of air
toxics, it is considered a major source facility subject to Boiler MACT
requirements. For more information about the Boiler
MACT (also known as the Major Source Rule), visit cleaverbrooks.com/epa.
“Knowing that stricter emissions levels were imminent,
our R&D team has been engineering boiler room solutions that minimize
emissions while achieving best-in-class efficiency,” said Goggins. “We have a dedicated network of
representatives who have the knowledge, experience, and tools necessary to help
facilities determine the most cost-efficient way to maintain compliance with
the newly enforced regulations.”
has a dedicated alliance of representatives throughout the world who can be
tapped for consultation, sales, maintenance, and aftermarket support. To locate a representative, visit
cleaverbrooks.com or call (800) 250-5883.
world-renowned provider of boiler room products and systems, is
committed to providing efficient solutions that help its customers and
the industry reduce energy usage, cost and environmental impact. As the
pioneer of packaged firetube and watertube boilers, Cleaver-Brooks is
the only manufacturer in the world to offer an entirely integrated
boiler room solution for any size application. Its products are backed
by a world-class representative network offering superior aftermarket
service and solutions.