Pollution Prevention in Air Quality

A Government Perspective

Pollution Prevention in Air Quality

A Government Perspective

H. Patrick Wong, ChiefAir Quality Management DivisionMiami-Dade County Department of Environmental Resources Management

What is Pollution Prevention?What is Pollution Prevention?

The use of materials processes or practices that reduce or eliminate the creation of pollutants or wastes at the source.

SOURCEREDUCTION

REUSERECYCLE

TREATMENT

DISPO SAL

EPA Pollution Prevention Act of 1990

An environmental management hierarchy that includes: 1. Source reduction/prevention, 2. recycling, 3. treatment, and then 4. disposal or release.

Sets prevention as the optimum form of waste management. Once all of the prevention options have been exhausted, then we can turn to recycling, then treatment, and finally disposal.

In the beginning……….In the beginning……….

Initial Resistance to “new” ideas

Regulatory vs. Voluntary – Where does P2 belong? Regulatory vs. Voluntary – Where does P2 belong?

Regulatory- EPA and State P2

Acts Clean Air Act - MACT

Standards

Voluntary- Voluntary inquiry into

source reduction Motivation:

• Escape permitting• Reduce costs and/or

liabilities associated with haz. Chemicals

Examples of P2 for Air EmissionsExamples of P2 for Air Emissions

Lower VOC/HAP content solvents, paints, etc.

Replacing harmful chemicals with non-VOC/HAP content chemicals

– i.e. perchloroethylene vs. citrus-based solvent in a vapor degreaser

Improving the efficiency of a process in order to reduce material usage or conserve energy/fuel consumption

Example of P2 in RegulationsExample of P2 in Regulations

Boat Manufacturing MACT:– Air Toxics content limits for resins and gel coats – Non-spray resin application techniques– <5% air toxics content cleaning solvents– Covers for large resin and gel coat mixing

containers Aerospace Manufacturing and Rework Facilities

MACT:– Cleaners must be free of HAP and ozone depleting

compounds.– Record keeping and monitoring requirements are

reduced for aqueous cleaners.

Local Success Stories-Bristol Eyeglass Manufacturer

Local Success Stories-Bristol Eyeglass Manufacturer

Problems:

Degreasing unit did not comply with design criteria required by the Halogenated Solvent Degreasing MACT standard.

Burdensome record keeping & reporting requirements

Methylene Chloride is a hazardous air pollutant – a

health risk for employees and liability for the company

$270.00 per drum

Additional variable disposal costs

Local Success Stories-Bristol Eyeglass Manufacturer (cont’d)

Local Success Stories-Bristol Eyeglass Manufacturer (cont’d)

Facility replaced degreaser with an ultrasonic cleaning line that uses a few drops of ordinary

dishwashing detergent.

Payback period was less than 2 years

Local Success Stories-Flexible Foam Inc. – Local Success Stories-Flexible Foam Inc. –

Replaced their blowing agent, methylene chloride, with carbon dioxide

HAP emissions decreased from 300 tpy to <5 tpy

Motivated by escaping the federal Maximum Achievable Control Standard – would require stringent controls on the process

Evaluated their waste stream and developed a re-bonding process that makes Carpet Padding produced from scrap foam cuttings.

a manufacturer of polyurethane-based foam used by the building industry for architectural detailing

BenefitsBenefits Reduced operating costs

MORE EFFECTIVE cleaning process in the case of Bristol Eyeglass Manufacturer

Minimize employee exposure to hazardous chemicals

Protect Natural Resources (drinking water, air, land)

Avoid Permitting: annual fees, possible violations and associated fines, burdensome record keeping & reporting requirements

Promoting P2 at Miami-Dade County Air Pollution Facilities

Promoting P2 at Miami-Dade County Air Pollution Facilities

Pre-permitting discussions

Electronic submission of applications and reports

Provide P2 resources during compliance inspections – i.e. Enviro$en$e database and Solvent Alternatives Guide (SAGE) website

Refer facilities to DERM’s P2 Program for free waste minimization audits

Promote Good Housekeeping and Handling Practices

Include P2 provisions in consent agreements when feasible

Air Toxics Reduction ProjectAir Toxics Reduction Project

2 air toxics monitoring sites (a third to be installed in 2003)

Analyze data to identify citizens’ long-term exposure risks to hazardous air pollutants (toxics)

Target problem chemicals/industries based on monitoring data and other resources

Work with local facilities to reduce emissions of air toxics

Realizing the benefitsRealizing the benefits

Questions & CommentsQuestions & Comments

http://www.co.miami-dade.fl.us/derm/AirQuality/

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