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.
Affected Source Types
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
Will you need 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 Date(s):
For Existing Sources:
July 15, 2026Commence fenceline monitoring
July 15, 2027
Corrective action requirements
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2026Commence fenceline monitoring
July 15, 2027
Corrective action requirements
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Flares
New enhanced flare control device provisions.
Incorporation of new operating and monitoring requirements for flare control devices.
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2027
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Process Vents
Removal of the TRE Index, and more.
- 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, 2026EtO enhanced requirements
July 15, 2027
All other amendments
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2026EtO enhanced requirements
July 15, 2027
All other amendments
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Equipment Leaks
Plan ahead for revised equipment leak provisions.
- Enhanced requirements for equipment in EtO service
- New work practice standards for atmospheric PRDs
- Updated requirements for surge control vessels and bottoms receivers
Compliance Date(s):
For Existing Sources:
July 15, 2026EtO enhanced requirements
July 15, 2027
All other amendments
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2026EtO enhanced requirements
July 15, 2027
All other amendments
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Heat Exchange Systems
Changes to methods and requirements.
- Incorporation of the Modified El Paso Method
- Enhanced requirements for heat exchange systems in EtO service
Compliance Date(s):
For Existing Sources:
July 15, 2027
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2027
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Storage Vessels
Updates and new requirements.
- 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 Date(s):
For Existing Sources:
July 15, 2026EtO enhanced requirements
July 15, 2027
All other amendments
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2026EtO enhanced requirements
July 15, 2027
All other amendments
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Wastewater Streams
EPA's risk review impacts wastewater streams, too.
Incorporation of enhanced requirements for wastewater streams in EtO service.
Compliance Date:
For Existing Sources:
July 15, 2026
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
For Existing Sources:
July 15, 2026
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Transfer Racks
Does the pressure exemption update impact you?
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.
For Existing Sources:
July 15, 2027
For New Sources: Upon initial startup or on July 15, 2024, whichever is later.
Together. Proactively.
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.
One Place, All HON
Bookmark this HON at-a-Glance page to access continuous updates and expert support.
Have any HON Questions?
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 (Aboveground 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
Let Jill help you tackle your HON RTR implementation program.
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.