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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