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⚠️Who’s Affected by the HON Rule?
- Chemical Manufacturers: Facilities producing bulk synthetic organic chemicals for sale or further processing.
- Polymers & Resins (Groups I & II): Plants making materials like neoprene, often colocated with chemical facilities.
- Major HAP Sources: Sites with emissions from process vents, storage tanks, heat exchangers, and more.
🔧New Rules and Requirements
Changes to the National Emission Standard for Hazardous Air Pollutants (NESHAP) require manufacturers to monitor and control the emissions of hazardous organic chemicals.
1. Mandatory fenceline monitoring:
- Facilities must continuously monitor for six specific air toxics: ethylene oxide, chloroprene, benzene, 1,3-butadiene, ethylene dichloride, and vinyl chloride.
- If concentrations exceed EPA action levels, facilities are required to investigate the cause and implement corrective measures.
- All fenceline monitoring data will be made publicly available.
2. Stricter emission controls:
- Updated Standards: Updates to Maximum Achievable Control Technology (MACT) standards are required for major sources of HAPs.
- Stricter Controls: Existing facilities must comply with stricter EtO control requirements.
- Emissions Limits: The rule includes new emissions limits for dioxins and furans and is projected to significantly reduce benzene emissions from tanks and equipment leaks.
- Flare Efficiency: More stringent requirementss are mandated.
3. Operational adjustments:
- Regulations are enhanced for multiple emission points, including heat exchange systems, process vents, storage vessels, and wastewater systems.
- Emissions must be controlled during all operational phases, including startup, shutdown, and malfunction (SSM) events.
📅Compliance Deadlines
The EPA has set deadlines for plants and other facilities to be in compliance with the updated HON rules:
- July 15, 2026: Fenceline monitoring and EtO controls must be in place.
- July 15, 2027: Root cause analysis, corrective actions, and equipment upgrades required.
✅Don’t Wait—Start Preparing Now
These deadlines don't provide much time for manufacturers and processors to implement the necessary process and equipment changes. To ensure continued compliance and avoid disciplinary actions and fines, it's vital to work with an experienced, multi-disciplinary partner who can offer consulting, monitoring, testing, and analysis.
RJ Lee Group has the cost-effective real-time technology solutions to meet this highly impactful regulation. Our technologies are the most up-to-date and state-of-the-art solutions for emissions testing, fenceline and ambient monitoring, and advanced compliance strategies and thinking. We can quickly let you know where you stand today, and help you prepare for and fix any potential issues.