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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

^5)II-B-19 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 25 of 132 
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Jhified Air Toxics Regulations: Hazardous Organic NESHAP 

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Toxics Website 

Final Rule Controlling Air Toxics Emissions from 

Synthetic Organic Chemical Manufacturing Industry 

"HON" 

March 1,1994 

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EPA AIR DOCKET 

WHAT IS THE "HON"? 

The HON is one ofthe most sweeping regulations issued under the Clean Air Act Amendments of 1990. 

"HON" stands for Hazardous Organic NESHAP (National Emission Standards for Hazardous Air 

Pollutants). 

The HON will reduce organic hazardous air pollutant (HAP) emissions from chemical manufacturing 

processes in the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and from several 

non-SOCMI processes. 

WHAT ARE THE HEALTH AND ENVIRONMENTAL BENEFITS? 

The final rule will result in significant reductions in organic HAP emissions and is expected to reduce 

emissions more than any other single standard that will be issued under Section 112 of the Clean Air 

Act. 

It is anticipated that the standard will reduce HAP emissions by approximately 460,000 megagrams/year 

(510,000 tons/year). An added benefit is that emissions of volatile organic compounds (VOC) will be 

reduced by 950,000 megagrams/year (1,000,000 tons/year). This is equivalent to taking about 38 million 

vehicles off of the road. 

Application ofthe required control levels will result in approximately 90 percent reduction of HAP 

emissions and 80 percent reduction of VOC emissions. 

The resulting emission reductions of HAP are expected to reduce human death and illness. In addition, 

other ecological concerns including habitat destruction and impacts on the survivability of endangered 

species may be reduced. Increases in agricultural crop yields and improvements in forestry and fishery 

ecosystems may also be expected to result. 

HOW MUCH WILL THE RULE COST? 

National cumulative capital costs will be about $450 million through the first five years. By 1999, the 

national "annualized" cost ofthe rule is estimated to be about $230 million. 

Various provisions in the rule have been structured to encourage product savings through pollution 

prevention. These savings would significantly reduce the estimated costs ofthe rule. 

WHO MUST COMPLY WITH THE HON? 

The rule applies to production of 386 out of approximately 660 chemical substances produced by 

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United Air Toxics Regulations: Hazardous Organic NESHAP wysiwyg://21/http://www.epa.gov/ttauatwl/fshon_html 

SOCMI as commercial products. To be subject to the rule, a chemical process must be located at a major <? 

source (a plant site that collectively emits more than 10 tons per year of any one hazardous air pollutant 

(HAP) or more than 25 tons per year of multiple HAPs). In addition, to be subject, this process must also 

manufacture one or more SOCMI chemicals listed in the rule and have an organic HAP as either: (1) a 

product, by-product, co-product, or intermediate; or (2) a reactant. 

A SOCMI source includes five kinds of emission points: process vents; wastewater operations; storage 

vessels; transfer operations; and equipment leaks. These points must be in a contiguous area under 

common control to be considered part ofthe source. 

The rule also includes certain equipment leak provisions that apply to non-SOCMI facilities, such as 

styrene/butadiene rubber production (butadiene and styrene emissions only); polybutadiene rubber 

production (butadiene emissions only); production of certain agricultural chemicals (butadiene, carbon 

tetrachloride, methylene chloride, and ethylene dichloride emissions only); certain polymers/resins or 

other chemical processes (carbon tetrachloride, methylene chloride, tetrachloroethylene, chloroform, 

ethylene dichloride, and butadiene emissions only); and pharmaceutical processes using carbon 

tetrachloride or methylene chloride (carbon tetrachloride and methylene chloride emissions only). 

About 370 facilities in roughly 35 states are affected by the requirements in this rule. The majority of 

these faciUties are located in Texas, Louisiana and New Jersey. 

WHAT ARE THE CONTROL REQUIREMENTS? 

With the exception of equipment leaks, the final rule requires the source to limit emissions of organic 

HAP to the level that would be achieved by applying a "reference control technology" to each emission 

point that meets certain applicability criteria. Each technology was selected based on its meeting the 

statutory requirements for maximum achievable control technology (MACT) and being universally 

applicable to the particular emission point. 

Compliance can be demonstrated by applying the reference control or an equivalent technology. In 

addition, sources have the option to use an alternative means of compliance called emissions averaging. 

Emissions averaging allows a source to balance emissions from two or more points to achieve the same 

overall emission reduction that would be achieved if the reference controls were applied. 

In the case of equipment leaks, the provisions are equipment and work practice requirements. The rule 

applies to equipment that is in HAP service for 300 or more hours per year. To be in this service is to be 

in contact with or containing fluid that is five percent or more of a chemical on the list of 189 hazardous 

air pollutants. 

The equipment leaks portion ofthe rule applies to the SOCMI and the several non-SOCMI processes 

described above. The regulated chemical production processes are categorized into five groups. 

Staggered implementation is required; the first group must comply six months after the final rule is 

issued; the last group must comply eighteen months after the final rule is issued. 

WHAT IS EMISSIONS AVERAGING 

Emissions Averaging is an alternative means of compliance designed to provide regulatory flexibility for 

sources faced with unusually high cost compliance scenarios. Applications of emissions averaging must 

be reviewed on a case-by-case basis, including a review ofthe potential hazard associated with the 

alternative controls. 

Emissions Averaging is available as an alternative only for process vents, transfer operations, storage 

vessels and wastewater streams not treated in bio-units. Emissions from these kinds of points can be 

quantified to calculate the "credits" and "debits" used as an accounting mechanism for averages. This 

accounting mechanism allows the source to balance "over-control" (control more stringent than the rule 

requires) at some points, with "under-control" at others. 

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{* The emissions averaging provisions in the proposed rule were the subject of significant public comment 

In response to public comment, EPA revised elements ofthe averaging policy to reduce complexity. 

Several requirements have also been added to ensure the enforceability of averages, including a limit on 

the number of points that can be averaged. Finally, a discount factor was chosen to create extra 

emissions reductions and encourage pollution prevention. 

WHO TOOK PART IN THE DEVELOPMENT OF THE STANDARD? 

The EPA has made widespread use of consultation with outside groups in developing the proposed and 

final rule. These discussions were documented in memorandum to the HON docket. 

Groups who were involved in developing the rule include: major industry associations (e.g., Chemical 

Manufacturing Association and American Petroleum Institute); State and local air pollution control 

agencies (STAPPA/ALAPCO); the National Governors Association; and environmental groups (Natural 

Resources Defense Council). 

EPA used a formal regulatory negotiation process to develop the equipment leaks portion ofthe HON. 

In the regulatory negotiation process, vested parties negotiate and sign a formal agreement that becomes 

the basis for the proposed rule. Parties involved in this negotiation included representatives from the 

petroleum, chemical and pharmaceutical industries, state and local agencies, and environmental groups. 

The negotiations were concluded in November 1990. 

FOR FURTHER INFORMATION 

... contact the HON hotline on (919) 541-5299. 

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