The final EPA Risk and Technology Review (RTR) amendments for Hazardous Organic NESHAP (HON) became effective on July 15, 2024.
It’s important to know what, when and how to plan for your course of action. Keep this page handy to quickly find critical compliance dates, requirements, and advice as you begin your implementation programs.
What’s Changing? When’s Your Compliance Deadline?
For every affected source—it’s wise to act early so you’ll have the foresight to understand where moderations and capital costs may be needed, and how to strategize the scheduling.
Expand the tiles for key HON RTR facts at a glance. Our experts will soon be updating their areas with tips and advice. For immediate questions, contact our HON team for answers.
Fenceline Monitoring
New fenceline monitoring requirements for affected sources that use, produce, store, or emit:
benzene
1,3-butadiene
ethylene dichloride
vinyl chloride
ethylene oxide (EtO)
chloroprene
Compliance Due:
For Existing Sources:
July 15, 2026 or July 15, 2027
Depending on the requirement.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Flares
Incorporation of new operating and monitoring requirements for flare control devices.
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup, or by
July 15, 2024, whichever is later.
Process Vents
Updated definition of Group 1 Process Vent, including removal of TRE as the basis for determination
Enhanced requirements for process vents in EtO service
New maintenance venting provisions
New D/F standard for halogenated Group 1 Process Vents
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Equipment Leaks
Enhanced requirements for equipment in ethylene oxide (EtO) service
New work practice standards for atmospheric PRDs
Updated requirements for surge control vessels and bottoms receivers
Compliance Due:
For Existing Sources:
July 15, 2026
EtO driven compliance amendments.
July 15, 2027
All other amendments.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
At Alliance Technical Group, our consultants and other subject matter experts review regulations that affect our clients. They are dedicated to knowing your industry needs and delivering tailored, best-in-class solutions. We encourage you to get familiar with the most recent HON amendments here.
Heat Exchange Systems
Incorporation of the Modified El Paso Method
Enhanced requirements for heat exchange systems in EtO service
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Storage Vessels
Updated definition of Group 1 Storage Vessel
New requirements for internal floating roof tanks
Enhanced requirements for storage vessels in EtO service
New degassing requirements for Group 1 Storage Vessels
Removal of pressure vessel exemption from the definition of storage vessel
New monitoring requirements for pressure vessels
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Wastewater Streams
Incorporation of enhanced requirements for wastewater streams in EtO service.
Compliance Due:
For Existing Sources:
July 15, 2026
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Transfer Racks
Transfer operations that load “at an operating pressure greater than 204.9 kilopascals” are no longer exempted from the definition of transfer operation.
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Jill Martin, Project Director, Environmental Consulting
Jill’s extensive experience with the Chemical Manufacturing Sector, including her expertise with HON, makes her your trusted partner.
Compliance Program Implementation Support | Gap Analyses | Technical Support
Jill’s Proficiencies:
Air Compliance
Initial Compliance and Other Applicability Determinations (Chemical Manufacturing Sector NSPS and NESHAP regulations & Petroleum Refinery Sector NSPS and NESHAP regulations)
Comprehensive Compliance Program Development (Above ground Storage Tanks, RICE, CEMS, Flares)
Reporting
Greenhouse Gas Mandatory Reporting Requirements
Emissions Inventory
Toxic Release Inventory
Title V Compliance Reporting
Consent Decree Compliance Reporting
Periodic NSPS Compliance Reporting
Periodic MACT Compliance Reporting
Air Permitting
Title V Permitting
Miscellaneous Permitting Actions
Public Notice Coordination
Miscellaneous
RCRA Permitting and Compliance
Stack Test Observation
Ambient Air Monitoring
Wastewater Streams
Incorporation of enhanced requirements for wastewater streams in EtO service.
Compliance Due:
For Existing Sources:
July 15, 2026
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Transfer Racks
Transfer operations that load “at an operating pressure greater than 204.9 kilopascals” are no longer exempted from the definition of transfer operation.
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Heat Exchange Systems
Incorporation of the Modified El Paso Method
Enhanced requirements for heat exchange systems in EtO service
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Storage Vessels
Updated definition of Group 1 Storage Vessel
New requirements for internal floating roof tanks
Enhanced requirements for storage vessels in EtO service
New degassing requirements for Group 1 Storage Vessels
Removal of pressure vessel exemption from the definition of storage vessel
New monitoring requirements for pressure vessels
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Partners in Proactive Implementation
Quelling Concerns. Answering Questions.
With so many details to know about HON RTR amendments, is your path to compliance clear for you? What’s the impact going to be, and how do you get started? Tap into Jill’s expertise and Alliance resources for your solutions.
Between Jill and our other subject matter experts at Alliance, clients receive the most premium end-to-end environmental services from expert consulting services to testing, monitoring, and laboratory services available.
Get reliable and prompt solutions for whatever regulatory challenges you may have. It’s the better way to ensure compliance.
Process Vents
Updated definition of Group 1 Process Vent, including removal of TRE as the basis for determination
Enhanced requirements for process vents in EtO service
New maintenance venting provisions
New D/F standard for halogenated Group 1 Process Vents
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Equipment Leaks
Enhanced requirements for equipment in ethylene oxide (EtO) service
New work practice standards for atmospheric PRDs
Updated requirements for surge control vessels and bottoms receivers
Compliance Due:
For Existing Sources:
July 15, 2026
EtO driven compliance amendments.
July 15, 2027
All other amendments.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Fenceline Monitoring
New fenceline monitoring requirements for affected sources that use, produce, store, or emit:
benzene
1,3-butadiene
ethylene dichloride
vinyl chloride
ethylene oxide (EtO)
chloroprene
Compliance Due:
For Existing Sources:
July 15, 2026 or July 15, 2027
Depending on the requirement.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Flares
Incorporation of new operating and monitoring requirements for flare control devices.
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup, or by
July 15, 2024, whichever is later.
Fenceline Monitoring
New fenceline monitoring requirements for affected sources that use, produce, store, or emit:
benzene
1,3-butadiene
ethylene dichloride
vinyl chloride
ethylene oxide (EtO)
chloroprene
Compliance Due:
For Existing Sources:
July 15, 2026 or July 15, 2027
Depending on the requirement.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Flares
Incorporation of new operating and monitoring requirements for flare control devices.
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup, or by
July 15, 2024, whichever is later.
Process Vents
Updated definition of Group 1 Process Vent, including removal of TRE as the basis for determination
Enhanced requirements for process vents in EtO service
New maintenance venting provisions
New D/F standard for halogenated Group 1 Process Vents
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Equipment Leaks
Enhanced requirements for equipment in ethylene oxide (EtO) service
New work practice standards for atmospheric PRDs
Updated requirements for surge control vessels and bottoms receivers
Compliance Due:
For Existing Sources:
July 15, 2026
EtO driven compliance amendments.
July 15, 2027
All other amendments.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Process Vents
Updated definition of Group 1 Process Vent, including removal of TRE as the basis for determination
Enhanced requirements for process vents in EtO service
New maintenance venting provisions
New D/F standard for halogenated Group 1 Process Vents
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Equipment Leaks
Enhanced requirements for equipment in ethylene oxide (EtO) service
New work practice standards for atmospheric PRDs
Updated requirements for surge control vessels and bottoms receivers
Compliance Due:
For Existing Sources:
July 15, 2026
EtO driven compliance amendments.
July 15, 2027
All other amendments.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Fenceline Monitoring
New fenceline monitoring requirements for affected sources that use, produce, store, or emit:
benzene
1,3-butadiene
ethylene dichloride
vinyl chloride
ethylene oxide (EtO)
chloroprene
Compliance Due:
For Existing Sources:
July 15, 2026 or July 15, 2027
Depending on the requirement.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Flares
Incorporation of new operating and monitoring requirements for flare control devices.
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup, or by
July 15, 2024, whichever is later.
Process Vents
Updated definition of Group 1 Process Vent, including removal of TRE as the basis for determination
Enhanced requirements for process vents in EtO service
New maintenance venting provisions
New D/F standard for halogenated Group 1 Process Vents
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Equipment Leaks
Enhanced requirements for equipment in ethylene oxide (EtO) service
New work practice standards for atmospheric PRDs
Updated requirements for surge control vessels and bottoms receivers
Compliance Due:
For Existing Sources:
July 15, 2026
EtO driven compliance amendments.
July 15, 2027
All other amendments.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Fenceline Monitoring
New fenceline monitoring requirements for affected sources that use, produce, store, or emit:
benzene
1,3-butadiene
ethylene dichloride
vinyl chloride
ethylene oxide (EtO)
chloroprene
Compliance Due:
For Existing Sources:
July 15, 2026 or July 15, 2027
Depending on the requirement.
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Flares
Incorporation of new operating and monitoring requirements for flare control devices.
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup, or by
July 15, 2024, whichever is later.
Heat Exchange Systems
Incorporation of the Modified El Paso Method
Enhanced requirements for heat exchange systems in EtO service
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Storage Vessels
Updated definition of Group 1 Storage Vessel
New requirements for internal floating roof tanks
Enhanced requirements for storage vessels in EtO service
New degassing requirements for Group 1 Storage Vessels
Removal of pressure vessel exemption from the definition of storage vessel
New monitoring requirements for pressure vessels
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Wastewater Streams
Incorporation of enhanced requirements for wastewater streams in EtO service.
Compliance Due:
For Existing Sources:
July 15, 2026
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Transfer Racks
Transfer operations that load “at an operating pressure greater than 204.9 kilopascals” are no longer exempted from the definition of transfer operation.
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Wastewater Streams
Incorporation of enhanced requirements for wastewater streams in EtO service.
Compliance Due:
For Existing Sources:
July 15, 2026
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Transfer Racks
Transfer operations that load “at an operating pressure greater than 204.9 kilopascals” are no longer exempted from the definition of transfer operation.
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Heat Exchange Systems
Incorporation of the Modified El Paso Method
Enhanced requirements for heat exchange systems in EtO service
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
Storage Vessels
Updated definition of Group 1 Storage Vessel
New requirements for internal floating roof tanks
Enhanced requirements for storage vessels in EtO service
New degassing requirements for Group 1 Storage Vessels
Removal of pressure vessel exemption from the definition of storage vessel
New monitoring requirements for pressure vessels
Compliance Due:
For Existing Sources:
July 15, 2027
For New Sources:
Upon initial startup or on
July 15, 2024, whichever is later.
