Everything You Need to Know About the HON Rule

The Hazardous Organic National Emission Standards for Hazardous Air Pollutants (HON Rule) is a pending, yet critical regulation for chemical manufacturing facilities in the United States. To help navigate its complexities, we sat down with Mariah Peronto, Air Program Manager, to answer some of the most pressing questions about the HON Rule. Read on to gain valuable insights and practical advice on how to get ahead.  

Q1: What is the HON Rule and why is it important? 

Mariah Peronto: The HON Rule, or Hazardous Organic National Emission Standards for Hazardous Air Pollutants, is a set of regulations established by the Environmental Protection Agency (EPA) to control emissions of hazardous air pollutants (HAPs) from chemical manufacturing plants. It targets 6 compounds: ethylene oxide, benzene, 1,3-butadiene, chloroprene, ethylene dichloride, and vinyl chloride. The rule is important because it aims to reduce the release of these harmful pollutants into the atmosphere, thereby protecting public health and the environment. 

Q2: Who will be impacted by the HON Rule? 

Mariah Peronto: The HON Rule affects approximately 220 chemical manufacturing facilities across the United States. These include plants involved in the production of plastics, resins, synthetic fibers, pharmaceuticals, and other chemical products. Essentially, any facility that produces, processes, emits, or uses the 6 compounds is subject to the HON Rule. 

Q3: What are the key requirements of the HON Rule? 

Mariah Peronto: The HON Rule sets forth several key requirements for affected facilities: 

• Continuous Monitoring: Facilities must install and operate continuous emission monitoring systems to track pollutant levels. Samples collected in the process are sent to a laboratory for analysis.  

• Routine Reporting: Facilities subject to the HON Rule are required to submit quarterly emissions reports to the Environmental Protection Agency (EPA). This process begins one year after the facility's initial compliance date. The reports must be submitted using the EPA's Compliance and Emissions Data Reporting Interface (CEDRI) system, which is an online platform designed to streamline the reporting process. After the first year, facilities are required to submit additional reports within 45 days at the end of each quarter. 

• Emission Limits: Specific emission limits for specific pollutants must be adhered to, with stringent penalties for exceedances. 

Q4: What challenges do chemical manufacturers face in complying with the HON Rule? 

Mariah Peronto: Compliance with the HON Rule presents several challenges for chemical manufacturers, namely:  

• Keeping up with regulatory updates, such as the HON Rule, in real-time can be difficult, requiring dedicated resources and expertise to address the changes.  

• Enhanced monitoring systems and procedures can be costly, involving significant investments in technology and infrastructure. 

• Installing and calibrating monitoring equipment can disrupt normal operations, requiring careful planning to minimize impact. 

Q5: How can pilot studies help in HON Rule compliance? 

Mariah Peronto: Pilot studies are incredibly valuable for developing effective emission control strategies. They involve small-scale testing of monitoring systems and control measures before full-scale implementation. Pilot studies help identify best practices, optimize monitoring systems, and refine control measures, ultimately reducing costs and improving efficiency. By conducting pilot studies, facilities can proactively address compliance requirements and minimize the risk of non-compliance. 

Q7: What advice would you give to chemical manufacturers preparing for HON Rule compliance? 

Mariah Peronto: My advice would be to start early and invest in thorough planning. Understand the specific requirements of the HON Rule and assess your facility's current capabilities. Conduct pilot studies to test and refine your monitoring systems and control measures. Stay informed about regulatory updates and changes, in addition to seeking expert guidance when needed. By taking a proactive approach, you can ensure compliance, protect public health, and minimize financial strain.  

--

Proactive compliance with the HON Rule is a way for chemical manufacturers to protect public health, ensure upcoming regulatory adherence, and minimize environmental impact. By understanding the requirements and challenges of the rule, and leveraging the expertise of Pace®, facilities can implement effective monitoring and control measures before the rule goes into effect. Stay informed, plan ahead, and take advantage of the resources available to achieve compliance and contribute to a healthier environment.