1997 New Hampshire Pollution Prevention Internship Program
Biweekly Internship Progress Reports
August 21, 1997
Project Title:
New Hampshire Air Toxics Law and Aboveground Storage Tank
Regulation Compliance
Intern:
Peter Sullivan
60 Madbury Rd. Apt #C
Durham, NH 03824
E-mail: sullivap@mtrsmtp.edc.ge.com
pws@hopper.unh.edu
Facility:
General Electric Meter and Control Business
130 Main Street
Somersworth, NH 03878
Contact Person:
Sherry Allen-Bucar
Environmental Health and Safety Manager
Phone: (603)-749-8550
E-mail: allans@mtrsmtp.edc.ge.com
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Home Phone: (603)-868-3177
Work Phone: (603)-749-8115
Fax: (603)-749-8174
Table of Contents
Page
Executive Summary...............................................................................................................................1
Introduction............................................................................................................................................2
Goals and Project Approach..................................................................................................................3
Results.....................................................................................................................................................4
Pollution Prevention Benefits and Recommendations........................................................................5
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Executive Summary:
The focus of my internship was to inventory the plant process units, chemicals used, and
emissions as well as identifying hazardous materials and safety requirements. As well, I
completed registration forms for all pertinent aboveground storage tanks in accordance with the
New Hampshire Aboveground Petroleum Storage Tank Regulation (4/25/97).
New Hampshire is in the process of writing new toxic air emission regulations; the NH
Air Toxics Law will be implemented around Jan ’98 upon final legislative completion. Once this
new set of laws is instituted New Hampshire industrial businesses will have three years to come
to code. Simply, the regulations state that all plant emissions in New Hampshire must be
inventoried and listed as low, medium, or high toxins. As of May 1997 the GE plant in
Somersworth had a list of all the process units. This list, however, was out of date and in need of
revision. With the help of Seth Forden, I covered the entire plant and with the aid of the existing
list I created a new system of databases for the plant that lists all vital process information.
One table in the database lists the process units. This list includes process identification
number, ventilation duct identification number, process name, description, and related chemical
usage. The second table includes a listing of associated chemicals used. It lists process chemicals,
hazardous materials, and operator safety requirements. While the information to create the these
databases, and others, was collected other process information that had fallen out of date was
corrected and updated. For instance, since 1994, the date of the last inventory, the plant has
changed some of the processes used and even eliminated others as a result of the elimination of
cyanide compound usage.
Another project I completed involved state regulations for the aboveground storage
tanks, 660+ gallons, used for petroleum product storage. The plant uses such storage tanks for
the heating oil used in the oil burners at the plant and spent process lubricating oils.
Evidently the main focus of my internship was the plant emissions inventory. The
generation of the database has enabled us to track specific processes which pose a threat of
violating air quality standards. For instance, the database has been used to identify processes
which vent silica so filters could be installed to reduce emissions.
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Introduction
The General Electric plant in Somersworth, NH is a large facility specializing in the
production of electric meters. If you were to examine the meter on the side of your home and see
the GE “bullet”, the chances of which are good, then that meter was manufactured here in
Somersworth. Every meter that GE constructs, be it for commercial, industrial, or residential use,
is produced here in their Eastern New Hampshire facility. The plant also manufactures other
electrical goods such as transformers of all sizes. Most of the metals used as components in the
meters are plated metals which pass through a number of plating tanks. If one considers this
process, as well as all the other finishing processes involved in meter production, the result is a
facility with high chemical usage and potential for chemical release.
In order to remain in compliance with state, federal, and local regulations it is necessary
to track chemical usage within the facility. In 1994 a plant wide inventory of the processes which
vent to the exterior of the building was conducted for this reason. However, since then the plant
has undergone many changes in the chemicals it uses in an effort to reduce the hazardous
materials it uses and emits. Thus the inventory needed to be updated and the project was
assigned to me. However, a system that could be easily updated and extremely flexible was
desired so that the information included could be used for more than just chemical tracking.
The other project that I was assigned separate from the database was the registration of
all aboveground storage tanks at the facility that are covered under the New Hampshire
Aboveground Petroleum Storage Tank (AST) Regulation, implemented on April 25, 1997. The
state passed the regulation to increase state knowledge of potential spill sites. By registering the
appropriate tanks the state is aware of facilities where spills could occur. Part of the registration
process, however, is that spill prevention control and countermeasure (SPCC) plans be
implemented to help reduce the risk of petroleum releases. The main benefit of registering the
tanks with the state is that in the event of a spill, a facility can apply for state clean-up funds with
quick and desirable results.
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Goals and Project Approach
My main goal of the summer was to create a database system that can produce the
desired results quickly and effectively. Taking the right approach to the project was the most
important planning step. I needed to consider the database from a number of perspectives: 1)
the design perspective, 2) the new user perspective, 3) the experienced user perspective, and 4)
the data updating perspective. I needed a system that was easy to design, use, and update.
Accomplishing all of these goals was easy done by talking with different plant personnel that
were experienced in using the system I had decided to create the database with. By looking at the
data I had, and the form that the different types of data were in, I was able to design a series of
tables that could be linked through common fields. This provided the best way to produce the
database with the properties I wanted.
The goal I had set for the registration of the ASTs was simple; register the tanks by the
end of August. The registration of the tanks was, by law, not required to be completed for three
years from the implementation of the regulation because the tanks at our facility existed before
the regulation was passed into law. Thus, I not only saw my goal as reachable, but desirable to
promote General Electric as a cooperative industry leader.
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Results
The result of my database project is that I have designed and created a database that has
numerous uses for chemical tracking, operator safety requirements, maintenance of equipment,
and more. It was decided to include processes which vent within the plant through a filter, dust
collector, etc. as well. This way we could track service of these separatory devices in order to
maintain the equipment and the air quality they produce. The database has proven to be
extremely easy to use and very flexible in its uses. I have already used the database for tracking
silica use in the plant so filters could be installed where they had not been. Currently I am using
the database to prepare a report on Hazardous Air Pollutant for submittal to the state.
The database itself will, in a sense, never be fully complete. The plant operations are
constantly changing. These changes range from a change in the chemical used at the process, to
relocation or even removal of the process. This is a system which is in constant need of updating.
I wanted to make the system easy to update, though, so that the information could be kept
accurate. I not only feel, but I know, that I have accomplished this requirement. I have already
had to go back and change information in the database to reflect recent plant changes.
When I presented the database to my supervisor, Sherry Allen, she expressed her
satisfaction with the job I had. She saw the database as a useful tool for current and future
reporting of safety issues, chemical tracking and reporting, and general plant knowledge.
The AST registration was completed and sent to Concord by mid August. The forms
gave detailed information regarding the tanks construction, secondary containment, location, and
contents. The tanks at our facility mainly included the two heating oil tanks and a number of
tanks holding lubricating oils that were to be recycled either on or off site. In the information sent
to Concord we included our SPCC plans as well.
It is my feeling that of the main tasks assigned to me I have completed them timely, and
in an above satisfactory manor.
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Pollution Prevention Benefits and Future Recommendations
When considering my projects you can see that they have basic similarities with pollution
prevention. The projects I worked on had no direct pollution prevention benefits, but the
information collected does relate. We can use the database to identify sources of specific types of
pollution and registration of the ASTs included plans that detailed preventative measures for
potential pollutants.
For the future I recommend a few things. I first recommend that the database I created
be kept in a state of updated information. Because I will continue on as a part time intern at the
plant I will be able to maintain the database as a system detailing current information. As well, I
recommend that New Hampshire industrial facilities try to do the same if they have not done so
already. I have seen the importance of having a source of current information and the extent to
which it is used. When you couple this with the ease of use and flexible nature of the system you
have means of producing fast and accurate results. It is capabilities like these which help to
establish a company as not only an environmental advocate, but an industry leader.
Cooperative business ethics is also a practice I recommend. When completing the
registration forms for the ASTs I perceived that no one expected a large company like GE to
complete the registration process this soon into the three year grace period. The attitude behind
this was that why would a company with so much to do worry itself with something so small that
does not even need to be worried about for at least two years. However, by completing the forms
two and three-quarter years in advance we have set an example for others and shown that we do
care about the little things. Sometimes it is the little things that can produce the large problems.
By not only being cooperative, but by being willing we have shown our dedication to helping to
protect and prevent our state from environmental disasters.
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