Area Source Boiler MACT Reminder

The Area Source Boiler MACT (ASBM) rule became effective on May 20, 2011, with a compliance date of March 21, 2014 for all existing boilers located at area sources of hazardous air pollutant (HAP) emissions.  Initial notifications were due on September 17, 2011, and all boilers subject to the rule’s tune-up and work practice standards were required to tune up the boiler by no later than March 21, 2012.  If you haven’t tuned up your boiler yet, don’t worry.  U.S. EPA issued a No Action Assurance letter on March 13, 2012.  The letter states that U.S. EPA will not take enforcement action against anyone who fails to tune up their boiler by March 21, 2012.  However, if you failed to submit your initial notification by September 17, 2011, you might find yourself with a Notice of Violation (NOV).  ALL4 is aware of a number of facilities that have received NOVs after missing the initial notification deadline.

On December 23, 2011, U.S. EPA published proposed changes to the ASBM in the Federal Register.  What changed, you ask?  Not much.  If adopted, most of the proposed changes consist of clarifications to the rule along with a few new definitions.  The proposed changes to the rule will not affect rule applicability.  There are now less than two years left to comply with the ASBM rule.  ALL4 strongly suggests that facilities that are subject to the ASBM rule take a hard look at the requirements that may affect their boiler operations and to begin planning for compliance.