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June 3, 2025
1:45PM - 2:45PM
HON Fenceline Monitoring Pilot Study Lessons Learned
Richard Bergeron, OxyChem & Joe Espinosa, Enthalpy Analytical
This presentation will provide an overview of early Pilot Studies related to the HON MACT finalized in March 2024 in preparation of the July 2026 compliance date. The Environmental Protection Agency (EPA) has implemented Fenceline Monitoring (FLM) requirements under the Hazardous Organic NESHAP (HON) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and the Polymers and Resins (P&R) industries.
Enthalpy Analytical and OxyChem La Porte will summarize initial lessons learned and observations from pilot studies including: Sample placement strategies, significant lead time requirements for preparing and certifying sampling media; (canisters) in accordance with method 327; Review and discuss options for adhering to the one-hour canister deployment requirement; Weather and field sampling requirements; Initial observations/trends with concentrations of chemicals of concern; Strategies for gathering additional and faster data points for areas of concern (e.g. – analyzing for EDC by TO-15 (SIM) in addition to 325B; Root Cause Analysis and Site-Specific Sampling Monitoring (SSMP) strategies (Data driven decision making); Continuous Improvement Strategies – real time data options; Update on M327 certification (LADEQ as primary).
