The date should be maintained on-site at the facility and made available upon request. The Demonstration Summary would substantiate compliance with the Pollution Prevention Alternative. NPPR recommends that U.S. EPA identify the data required to substantiate compliance with the Pollution Prevention Alternative, particularly data requirements to develop the baseline consumption factor. In order to provide adequate incentive for facilities to choose the Pollution Prevention Alternative, U.S. EPA should ensure that data requirements are reasonable and protect confidential chemical formulation data. One approach would be for the facility to develop a brief description of the pollution prevention methods that were used to facilitate the reduction in HAP consumption.
Data quality is an important factor to help demonstrate reductions.
Option 1 entails demonstrating a 75 percent reduction in the consumption and production factor from a baseline year of 1987. Process level information, however, may be difficult to document all the way back to 1987. However, cleaning of reaction vessels and other process equipment can be a source of HAP emissions at a pharmaceutical manufacturer, particularly when batch manufacturing is used. There are several methods that can be used to reduce the quantity of solvents used to clean reaction vessels and other process equipment. The cleaning standard should apply to all facilities and processes.