POLLUTION PREVENTION GUIDEBOOKS

New Jersey Technical Assistance Program
New Jersey Institute of Technology
138 Warren Street
Newark, New Jersey 07102-1982
Phone: 973-596-5864
Fax: 973-596-6367
e-mail: njtap@megahertz.njit.edu

The traditional approach to environmental protection has been to control pollution (e.g., hazardous waste, air emissions, wastewater discharges) in the various media after it is generated and to minimize its impacts on the environment through proper handling, treatment, and disposal. Experience has shown, however, that this end-of-pipe approach has had limited effectiveness in protecting the environment. In many instances, this approach has only served to transfer pollution from one medium to another, resulting in no net improvement in environmental quality.

It is now apparent that the best way to protect the environment is not to generate pollution in the first place. This new approach to environmental protection is called pollution prevention, and it is synonymous with source reduction. Pollution prevention consists of any activity that eliminates or proportionately reduces the use of toxic substances, or the generation of nonproduct output (NPO), hazardous waste, air emissions, wastewater, or the release of pollutants into the environment.

Pollution prevention includes:

• Good operating practices (e.g., waste segregation)
• Improved housekeeping (e.g., keep containers covered)
• Inventory control (e.g., minimize expired shelf-life materials)
• Spill and leak prevention (e.g., preventative maintenance)
• Material substitution (e.g., water-soluble or no-clean fluxes)
• Product redesign (e.g., design for the environment)
• Product reformulation
• Process or equipment modification
• In-process recycling
• Energy conservation
• Water conservation

In addition to improved environmental protection, there are a multitude of other benefits that provide considerable incentives for implementing pollution prevention. In fact, as thousands of businesses, institutions, and government facilities throughout the U.S. have already realized, pollution prevention is just good business. By implementing pollution prevention, they have:

• Reduced raw material and energy costs
• Reduced waste handling, treatment, and disposal costs
• Reduced long-term liability
• Reduced regulatory burden and improved compliance
• Improved worker health, safety, and morale
• Improved public image
• Improved product quality

There are a number of obstacles that prevent facilities from implementing pollution prevention, including:

• Capital requirements
• Available time/technical expertise
• Concern about maintaining product quality
• Fear of making matters worse and falling out of compliance
• Overall inertia

Air pollution is one of the nation's principal health and environmental concerns. Most air pollution comes either from stationary sources such as factories, power plants and smelters, or from mobile sources which include cars, buses, planes, trucks, and trains. Air pollution had already reached dangerous levels in many areas when the first major federal Clean Air Act became law in 1970. Major amendments to strengthen the Act were added in 1977, and again in 1990. The act and its amendments are designed to "protect and enhance the nation's air resources so as to promote the public health and welfare and the productive capacity of the population." The CAA consists of six sections, known as Titles, which direct EPA to establish national standards for ambient air quality and for EPA and the States to implement, maintain, and enforce these standards through a variety of mechanisms. CAA regulations appear in 40 CFR Parts 50-99.

Title I

• EPA has established national ambient air quality standards (NAAQSS) to limit levels of "criteria pollutants," including carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur dioxide.
• Authorizes EPA to establish New Source Performance Standards (NSPSs), which are nationally uniform emission standards for new stationary sources falling within particular industrial categories. NSPSs are based on the pollution control technology available to that category of industrial source but allow the affected industries the flexibility to devise a cost-effective means of reducing emissions.
• EPA establishes and enforces National Emission Standards for Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented towards controlling particular hazardous air pollutants (HAPs).

Title II

• Pertains to mobile sources, such as cars, trucks, buses, and planes. Reformulated gasoline, automobile pollution control devices, and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses to regulate mobile air emission sources.

Title III

• Further directed EPA to develop a list of sources that emit any of 189 HAPS, and to develop regulations for these categories of sources. The emission standards will be developed for both new and existing sources based on "maximum achievable control technology" (MACT). The MACT is defined as the control technology achieving the maximum degree of reduction in the emission of the HAPS, taking into account cost and other factors.

Title IV

• Establishes a sulfur dioxide emissions program designed to reduce the formation of acid rain. Reduction of sulfur dioxide releases will be obtained by granting to certain sources limited emissions allowances, which will be set below previous levels of sulfur dioxide releases.

Title V

• Created a permit program for all "major sources" (and certain other sources) regulated under the CAA. One purpose of the operating permit is to include in a single document all air emissions requirements that apply to a given facility. States are developing the permit programs in accordance with guidance and regulations from EPA. Once a State program is approved by EPA, permits will be issued and monitored by that State.

Title VI

• Is intended to protect stratospheric ozone by phasing out the manufacture of ozone-depleting chemicals and restrict their use and distribution. Production of Class I substances, including 15 kinds of chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000, while certain hydrochloro- fluorocarbons (HCFCS) will be phased out by 2030.

Reference: EPA Sector Notebook Project, September 1995

Pursuant to the national standards set forth in the federal Clean Air Act, the State of New Jersey and the NJ Department of Environmental Protection enforce the regulations of the Air Pollution Control Act - N.J.S.A. 26:2. There are four permits of concern with regard to air quality:

1. Control Apparatus/Equipment for the Storage and Transfer of Service Fuels Permit to Construct/Install/Alter and Certificate to Operate Regulations: Air Pollution Control Act - N.J.S.A. 26:2C-9.2 et seq. and N.J.A.C. 7:27-8.1 et seq.

2. Permit to Construct/Install/Alter Air Pollution Control Apparatus/Equipment Certificate to Operate Air Pollution Control Apparatus/Equipment Regulations: Air Pollution Control Act - N.J.S.A. 26:2C-9.2 et seq. and N.J.A.C. 7:27-8.1 et seq.

3. Registration of Toxic Volatile Organic Substances (TVOS) Applicable Sources: Anyone who stores, transfers or uses a toxic volatile organic substance must register with the department. Persons holding valid Air Pollution Permits for the particular activity are exempt from the registration requirements.The toxic volatile organic substances covered by the requirement are:

Benzene (Bensol) Ethylene dichloride (1,2-Dichloroethane)
Carbon Tetrachloride (Tetrachloromethane) Trichloroethylene (Trichloroethene)
Dioxane (1,4 - Diethylene dioxide) Tetrachloroethylene (Perchlroethylene)
Ethylenimine (Aziridine) 1,1,2 -Trichloroethane (Vinyl Trichloride)
1, 1,2,2 - Tetrachloroethane Ethylene dibromide (1,2-Dibromoethane)
(Sym Tetrachloroethane)

*No surface coating can contain more than 0.25% by weight of asbestos.

Regulations: Air Pollution Control Act - N.J.S.A. 26:2C-9.2 et seq. and N.J.A.C. 7:37-17.1 et seq.

4. Air Quality Permit - Title V

Summary: Title V of the federal Clean Air Act requires the States to develop regulations to implement a comprehensive Air Operating Permit Program (OPP). In response to the federal requirements, New Jersey adopted its operating permit rule in the October 3, 1994 New Jersey Register. Operating permits will consolidate all the multiple permits needed for smokestack discharges into a single facility-wide permit. Included in the emission points will be those that have preconstruction permits, those that are grandfathered from preconstruction permits, and fugitive emissions.

Regulations: Air Pollution Control Act - N.J.S.A. 26:2C et seq. and N.J.A.C. 7:27-22 et seq.

Reference: New Jersey Department of Environmental Protection Permits, Licenses, Approvals & Certificates, June 1995

• The EPA's Control Technology Center, at (919)-541-0800, provides general assistance and information on the federal CAA standards.
• For information regarding NJDEP permit application requirements and procedures, contact the Bureau of New Source Review at (609)-633-2753.
• For additional information, small businesses can contact NJDEP's Small Business Assistance Program's Office of Permit Information and Assistance at (609)-292-3600.

* Please note that this section merely introduces state and federal environmental regulations. The EPA and NJDEP should be consulted for particular obligations mandated by these laws.

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General Information


Food and Kindred Products: SIC Code 20


Textile Industry: SIC Code 22


Stone, Clay, Glass, and Concrete: SIC Code 32


Industrial Machinery and Equipment: SIC Code 35