Part 1: Technical

Presentation 1:
Updates on EPA’s Proposed Revisions to Several Chemical Industry Air Rules – Provide background on EPA’s proposed and finalized changes to several chemical sector rules including the consolidated reconsideration of RSR, MON, EMACT, and OLD, and the recently proposed changes to the HON and NSPS rules. This introduction will summarize the changes and will discuss EPA’s rationalization of the revisions, including those for ethylene oxide. Major industry and non-governmental organization comments that may impact final rules will also be covered.

Presentation 2:
Strategies to Comply with the Earliest New HON Requirements at Petrochemical Plants and Refineries This presentation offers a “nuts & bolts” outline for implementing the proposed new HON provisions. “In ethylene oxide service” determinations and requirements involving non-environmental staff and long lead times are examples of tasks needing early attention. The presentation will also include a high-level introduction to fenceline monitoring pilot studies as part of the overall compliance strategy.

Part 2: Fenceline Monitoring
Progression of Fenceline Monitoring: More Sources, More Methods – This presentation will cover the current state of affairs for refinery fenceline monitoring (FLM): when it started, trend in sample results, number of facilities currently above the action level (on annual basis), investigation methods, and general lessons learned. The HON FLM program requirements and how the HON FLM program differs from the refinery FLM program will be discussed. The details of the two HON monitoring methods, passive tubes and evacuated canisters, will be provided and compared/contrasted side-by-side, to illustrate the complexity and challenges of this proposed monitoring program. A summary of the industry group concerns regarding the HON FLM program expressed in the initial proposed rule comments and subsequent interactions with the agency, up until the conference, will also be provided.

Speakers: Amy Marshall, Gary Daves, Patricia Sorensen, Derek Reese

Moderator: Mary Bachynsky