The Environmental Protection Agency (EPA) recently issued an updated version of the Hazardous Organic NESHAP Maximum Achievable Control Technology (HON MACT) rule. A major objective of the new rule is to reduce fugitive/area source emissions of certain hazardous air pollutants, which EPA has determined pose an unacceptable risk to nearby communities.
This HON MACT requires certain covered facilities to perform ongoing fenceline monitoring using new and existing EPA Methods. The goal of fenceline monitoring is to measure the concentrations of hazardous pollutants, such as 1,3-butadiene; chloroprene; 1,2-dichloroethane; ethylene oxide; and, vinyl chloride.
The updated HON MACT rules affect covered facilities, including Synthetic Organic Chemical Manufacturing Industry (SOCMI) facilities (those with chemical manufacturing processes producing commodity chemicals) and Group I and II Polymers and Resins Industry facilities, including those that operate elastomers production processes and resin production processes that use epichlorohydrin feedstocks1. Many of these facilities will be required to perform ongoing fenceline monitoring using existing EPA Methods 325A/B and/or draft EPA Method 327. There will be costs associated with the sampling and analysis, as well as remedial actions that will be required when sample results indicate the presence of target compounds above the action levels specified in the HON MACT.
Actions to Take
It is essential that laboratory clients, their clients, and impacted facilities submit comments to EPA regarding both the HON MACT and EPA Method 327. Enthalpy plans to submit comments to the EPA regarding both the HON MACT, and EPA Method 327, and we encourage our clients to do the same. Preliminary monitoring to allow facilities to determine whether or not they are in compliance with action levels prior to the rule(s) implementation is advised.
What Happens Next?
The EPA will review stakeholder comments and make changes they deem appropriate based on the comments. Compliance with fenceline monitoring requirements will likely be required in early to mid-2024.
The draft EPA Method 327 is based on practices and procedures from method TO-15, but there are many key differences between TO-15 and M327.These differences are aimed at improving the quality and consistency of the data acquired from the M327 fenceline monitoring. However, these changes also vastly increase the QA/QC burden on not only laboratories but also the persons collecting the field samples. The table below lists some key differences between method TO-15 and draft Method 327.