Pollution Reduction Opportunity Evaluation

The PROE reports are designed to be sector specific; therefore, the first step of the program will be to target an industry sector where successful source reduction strategies have been implemented. This will involve researching different SIC/NAICS codes and/or MACT source categories. The next step of the program will be to collect and analyze the Department's data to determine how many facilities have reduced their emissions or non-product output (NPO) and conduct site visits to determine how and why the reductions took place.

Once successful case studies have been identified, the third step of the program will be to develop and write the PROE reports, which will include site specific examples of successful pollution reduction case studies, pollution reduction opportunities, questions permit writers should ask to determine if P2 is feasible, and the benefits of implementing the P2 method. These benefits will include compliance with federal and state regulation, elimination or reduction of solvent storage and handling and compliance costs, and reduction of emissions. The last step of the program will be to conduct outreach to permitting and enforcement staff that will involve such actions as: contacting permit writers and encouraging them to incorporate the P2 suggestions into permits, creating a list of enforcement actions to determine whether or not a P2 method could be used to resolve the violation, and conducting site visits to facilities where several options were identified but not implemented. The PROE is envisioned to be a tool to facilitate discussions between regulators and the regulated community to begin integrating P2 concepts in their decisions.

It should be noted that implementation of the PROE initiative is currently being reviewed by NJ DEP upper management.