AM-93-13 IMPACT OF THE “HON” RULE ON THE PETROCHEMICALS AND REFINING

Description:

Since the amendment of Clean Air Act in 1990, EPA has issued a number of rules, proposed rules and guidance documents that begin to define the control requirements and operational restrictions that will apply to refineries and petrochemical plants. The most sweeping of these is a massive proposal known as the “HON,” the Hazardous Organic NESHAP (National Emissions Standard for Hazardous Air Pollutants). The final HON will almost certainly be the template for all future rules for toxic air pollutants. The paper provides an overview of this rule its interaction with the rules for modification of the sources of toxic air pollutants, controls on volatile organic compound emissions in nonattainment areas, and the EPA’s new operating permit rule. It concludes that unless there are significant changes in the regulations, administration and probably the Act itself, the process faces collapse.