Sampling analysis of various wastewater streams for compliance w ith the HON rule

摘要

This paper will discuss the sampling and analysis methods 25D and 305 which are referenced in the HON Rule to determine compliance. The HON Rule requires the owner or operator of a Synthetic Organic Chemical Manufacturing Industry facility to determine if they will be required to control hazardous air pollutants (HAPs) from several points. Wastewater streams are considered to be a potential air emission point at these facilities, and EPA has established Mehtods 25D and 305 as reference methods for this determination. Samples were collected at a petrochemical facility to determine if their emissions of volatile organics would classify their wastewater streams as a Group I (requiring controdls) or as Guoup II (requiring no control devices). As with any new sampling and analysis procedure, errors will occur initially in understanding the applicability, in interpreting the results, and in following the methods as intended by the EPA. The methods may not have addressed all of the possible problem that could occur. The authors have been using these methods for several months, and have enconuntered many issues. These issues were brought to the attenton of EPA for clarity and recommendations.