1. Pollution Prevention in Air Quality A Government Perspective H. Patrick Wong, Chief Air Quality Management Division Miami-Dade County Department of Environmental Resources Management

2. What is Pollution Prevention? The use of materials processes or practices that reduce or eliminate the creation of pollutants or wastes at the source. 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.

3. In the beginning………. Initial Resistance to “new” ideas

4. 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

5. Examples 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

6. Example 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.

7. 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

8. 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

9. 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

10. Benefits 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

11. 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

12. Air 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

13. Realizing the benefits

14. Questions & Comments http://www.co.miami-dade.fl.us/derm/AirQuality/ For up to date Air Quality information visit: