Area Source Boiler MACT Notification of Compliance Status (NOCS) Due

Area sources were required to complete most of their initial compliance obligations for the Area Source Boiler MACT Rule back in March 2014; however, there is just one (1) last obstacle that facilities need to navigate (at least as far as initial compliance requirements go).  Most existing area source boiler operators must submit their Notification of Compliance Status (NOCS) report by July 19, 2014.  The purpose of the NOCS is to indicate that compliance with the initial tune-up requirements, energy assessment requirements, and/or emissions limits, as applicable, was achieved.  If subject to emission limits and required to conduct a performance test, compliance does not have to be demonstrated until September 17, 2014.  The NOCS for demonstrating compliance is due within 60 days following the performance test.  The NOCS must be submitted through the Compliance and Emissions Data Reporting Interface (CEDRI) on U.S. EPA’s Central Data Exchange (CDX).

Based on ALL4’s experience, CEDRI requires eight (8) questions to be answered regarding initial compliance with the Area Source Boiler MACT Rule.  The questions are as follows, where applicable:

1. What were the methods that were used to determine compliance?
2. What methods will be used for determining continuous compliance, including a description of monitoring and reporting requirements and test methods?
3. Has the source complied with the relevant standard or other requirements?
4. Has the facility complied with the requirements to conduct an initial tune-up?
5. Has the facility performed an energy assessment according to the rule?
6. Does the facility comply with the bag leak detection system requirements?
7. Do you certify that no secondary materials that are solid wastes were combusted in any affected unit?
8. What was the date of the performance test that demonstrates compliance with the emissions standards and operating limits?

In addition to these questions, CEDRI also allows the user to upload any performance test results and provide supporting information or clarification as necessary.  The NOCS must be signed by a responsible official.  

CEDRI is a web-based application for the electronic reporting of various reports required by 40 CFR Parts 60 and 63.  If facilities have not previously used CEDRI, they will need to make sure that they allow enough time to register.  U.S. EPA has provided a number of helpful tools to assist facilities with registering with CEDRI for the first time, including a video and user’s guide.  U.S. EPA has also provided facilities with a video tutorial to assist with submitting the NOCS.

For more information on the Area Source Boiler MACT, view our webinar or contact Chuck Doyno at 678.460.0324 x204 or cdoyno@all4inc.com.