2001 New Hampshire
Pollution Prevention Internship Program
Final Report
Project Title
UNH Intern Liaison and P2 Outreach Assistant
Intern
April Duhaime
E-mail: aprild@cisunix.unh.edu
Facility
New Hampshire Pollution Prevention Program (NHPPP)
New Hampshire Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
E-mail: nhppp@des.state.nh.us
Contact Person
Sara Johnson, M.S.
Pollution Prevention Program Manager
Phone: (603) 271-6460
Date
September 10, 2001
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I. EXECUTIVE SUMMARY
During the summer of 2001, I interned at the New Hampshire Department of Environmental
Services (DES), Pollution Prevention Program (NHPPP) in Concord, NH. I took on several tasks
over the ten-week period, yet my primary task was assisting P2 program staff. As P2 program
assistant, my tasks included attending on-site assessments, researching information, and creating
documents.
On-site assessments require much thought and time. First, information on the company’s
regulatory issues, such as permits or past enforcement, and waste streams or generation must be
researched. During the assessment, appropriate questions should be asked and answered, and
accurate information must be given to the client. Upon return to the office, a report is written and
information is researched for the client of the facility.
Internet searching is a useful tool because it is quick and easy to find P2 documents and
contact information. Many times research is conducted to find ideas or projects from other state
webpages. NHPPP can use this information to enhance the quality of their projects. At other times,
staff will search the internet to answer questions from companies or residents of NH about new
technologies or new regulations.
Creating documents can assist businesses and municipalities in New Hampshire in
understanding regulations, technologies and best management practices (BMPs). Over the summer
I created documents such as the DES Environmental Management Systems Fact-Sheet, the Loctite
Corporation Case-Study, and three on-site assessment reports. All of these documents reference
pollution prevention opportunities and how P2 relates to cost reduction.
II. NHPPP BACKGROUND
The New Hampshire Pollution Prevention Program (NHPPP) is a
confidential, non-regulatory assistance program that is available to New
Hampshire businesses and municipalities.
Their goal is to preserve
environmental integrity while assisting businesses and municipalities show a
profit. Staff members visit facilities, help evaluate the production and waste
generating processes, and offer suggestions about how to reduce, reuse, recycle, and eliminate
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wastes while cutting costs. NHPPP researches opportunities specific to the facility process and
provides P2 opportunities and contact information for problem areas. NHPPP allows each facility
to customize their own site visit. This is done to ensure that the facility obtains the information they
desire. NHPPP is currently involved in providing P2 education/outreach to the hospital, dental, and
marina sectors. NHPPP is assisting healthcare facilities reduce toxic materials which include
mercury, silver, lead, and PVC. NHPPP has also updated the 1995 DES “Best Management
Practices for NH Marinas”, by including P2 opportunities in multimedia areas (waste, air, and
water).
III. OBJECTIVES
My responsibilities at DES over the ten-week period varied immensely.
Along with being the intern liaison and assisting with pollution prevention
outreach, I created web pages and documents, attended workshops, and
researched many subjects. All of these projects have helped me learn more
about pollution prevention.
My goals for the summer were to research P2 questions, create outreach documents, assist
with on-site assessments, and learn some of the hazardous waste and air toxic rules and regulations.
My personal goals included learning how a state agency runs, gaining knowledge about NHPPP,
and becoming familiar with different engineering processes and procedures.
IV. ACCOMPLISHMENTS AND APPROACHES
My internship was not an engineering assignment that focused on one process for the entire
summer. Instead, I had the chance to learn about many different processes and how to improve my
research and writing skills. Since my tasks varied during my time at the DES, I changed the format
for the following section to better suit the internship tasks.
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On-Site Visits - Marinas
Accomplishment: Attended on-site visits at three marinas in the lakes region to review regulatory
issues and P2 opportunities.
Approach: The marinas requested NHPPP assistance through the P2 Incentives for States outreach
project for marinas.
The marinas were interested in becoming compliant with environmental
regulations and implementing P2 options. On-site visits consist of an opening
meeting, a facility walk, and a closing meeting with the facility coordinator and
staff. NHPPP staff assist each facility with identifying the waste streams and
offering best management practices and P2 options.
In addition, NHPPP
identifies items that companies need to address in order to comply with state
rules and regulations. For example, marinas use a test tank for engine repairs because the engines
use water as a coolant instead of antifreeze. At one marina, the test tank was located outside without
a lid. As a BMP, NHPPP suggested covering the test tank with a lid when not in use to limit
contamination. The wastewater in the tank is drained biannually onto the adjacent land. NHPPP
suggests discontinuing this practice because the wastewater might contain benzene or MtBE that
will eventually contaminate ground water.
The wastewater is subject to a hazardous waste
determination, and based on the results the marina will have to manage the waste appropriately.
On-Site Visit Follow-Up
Accomplishment: Wrote assessment reports for a municipality and a circuit
board manufacturer. Writing these reports made me review my notes, as
well as improve my writing skills.
Approach: The follow-up report for the municipality included information on what was noted at
the previous visit, such as used oil labels, storage, and floor drains. NHPPP suggested labeling used
oil drums, cleaning up the storage area, and either sealing their floor drains, connecting their floor
drains to a sewer line, or obtaining a groundwater discharge permit.
Upon return to the
municipality, used oil labels were in their proper places, most of the storage area had been cleaned,
and all floor drains had been sealed. At the circuit board manufacturer, NHPPP discussed their
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metal hydroxide sludge, wastewater closed-loop system, and their disposal of spent etching.
NHPPP recommended contacting the Small Business Technology Assistance Program (SBTAP)
and signing a compliance assistance policy because the facility was out of compliance with the Air
Toxics Program. This policy will protect the facility from an enforcement action if they follow the
guidelines set by the SBTAP. The follow-up assessments allow the NHPPP to measure
implementation of any P2 suggestions the facility may or may not have taken.
On-Site Visit Report and Calculations
Accomplishment: The Small Business Development Center (SBDC) requested NHPPP’s assistance
to assess an orthopedic plastics manufacturer. I attended the on-site assessment and wrote the
report for the facility. Based on the Air Toxics Regulations and material safety data sheets from the
facility, I calculated formaldehyde use found in the inks the facility used to determine if the facility
was in compliance.
Approach: During the visit, topics such as antifreeze, shop wipes, fluorescent light bulbs, and
generator status were discussed. In the report, NHPPP made suggestions on the proper handling of
these wastes, based on hazardous waste rules and BMPs.
Epoxy inks were also an issue for the plastics manufacturing company. NHPPP was concerned
with the amount of formaldehyde, which is a listed Air Toxic, being emitted into the air from the
inks. Based on the Material Safety Data Sheets (MSDSs) on the epoxy inks, amount of product
purchased per year, and percent of formaldehyde present in the inks, and then I performed an air
toxics calculation. It was determined that the facility emissions of formaldehyde were less than 2.89
lbs/yr. This falls below the limit of formaldehyde in the Env-A 1400 rules. If the usage amount
increases, the facility should recalculate to determine if they are still below the limit.
Case Study
Accomplishment: Wrote the Loctite Corporation case study for a Banker’s Forum that will be held
in September. Case studies are often used to help businesses and organizations learn about a
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specific process or success story. True situations are more appealing to the reader, thus making
case studies a great source of information.
Approach: Loctite Corporation is one winner of NHPPP’s 2001 Governor’s
Award for Pollution Prevention. I searched through Governor’s Award files at
DES, and searched the webpage for information about Loctite’s pollution
prevention goals. The case study shows the background of Loctite Corporation,
and how their pollution prevention techniques saved them money.
Lead Database Interpretation
Accomplishment: Organized the lead data for a proposed lead strategy. In 2001, EPA released
new Toxic Release Inventory (TRI) emission levels. Lead notification was changed from 10,000
lbs to 100 lbs. DES is anticipating a lead or metal strategy, and in order to get ahead on the project,
the P2 program is reviewing the Manifest Tracking System (MTS) data to determine if lead is a
common waste stream, and which types or sectors of industries are disposing it.
Approach: The MTS is a state database that is based on waste generation
and manifests. From the database, a report was generated based on lead
manifested in NH for 1998, 1999, and 2000. The database was enormous
and difficult to interpret. I first narrowed down the list by deleting the
facilities that only disposed of lead once, or did not dispose of over 100 lbs a year. This removed
one-time generators, which we have interpreted as a clean-out or lead-based paint removal. Then I
deleted the results from 1998, and split up the 1999 and 2000 data into separate databases. This
way I could work with more current data. Next I sorted by SIC code and calculated the total
amounts. This helped us determine which sector is consistently disposing lead. I also analyzed the
data from these two years to determine which companies repeatedly dispose large amounts of lead,
and which companies dropped their amount of lead disposal. Finally, I color-coded the databases so
that it is easy to find the facilities that need the most assistance. With this new data, NHPPP will
gear outreach to the sectors that generate lead consistently as part of their manufacturing process.
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P2 Partnership Intern Outreach
Accomplishment: Analyzed the P2 Internship Program by sending
out surveys and compiling data from past interns. The results are
shown through writing and graphical interpretation. With the results,
the P2 Internship Program hopes to measure the program’s success and
improve where needed.
Approach: Surveys were mailed to 12 past interns, emailed to 30, and 15 were called. Out of the
57 past P2 interns contacted, 22 responded. Results were entered into a database, and later tallied
and documented. One outcome is 86% of the interns that replied felt they were well-prepared for
their jobs because of the P2 Internship Program.
Fact Sheets
Accomplishment: Created a DES Fact Sheet about Environmental Management Systems (EMSs)
titled “Environmental Management Systems: Frequently Asked Questions”( CO-13). I also created
an EMS/ISO 14001 certification consultant list to include with CO-13 for companies that are
interested in creating an EMS, or becoming ISO certified. Finally, I developed a webpage to
consolidate Fact-Sheets, documents, and useful links about EMSs.
Approach: After reading material on EMSs and ISO 14001, I met with Bob
Minicucci from the Superfund section of DES. Bob is also the EMS coordinator
for DES. With Bob’s and NHPPP’s assistance, I wrote a Fact Sheet, which
includes information for small businesses to determine if an EMS/ISO 14001
certification is an option for them.
After numerous revisions, the Public
Information and Permitting (PIP) section of DES approved the Fact-Sheet.
I sent an email to a list of consultants I obtained from Site Investigation & Remediation.
The email requested their response to determine if the consultants wanted to be included on the
vendor list. After many replies, I created the consultant table and added this as an attachment to CO13.
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Finally, I created a web page that would host all EMS documents on-line at DES. I first
wrote introductory paragraphs generally describing an EMS and how they can benefit businesses.
Then, I made links to the current EMS Fact Sheets available at DES. Finally, I found and linked
some useful EPA websites, and a document that included four different case studies. This Word
document was forwarded to the web person who converted it into html format.
V. OTHER
CHEMICAL USAGE
None
RELEASES/WASTES GENERATED
None
VI. POLLUTION PREVENTION BENEFITS
The purpose of NHPPP is to assist businesses with compliance issues and
P2 opportunities while protecting the environment. Encouraging P2 has several
benefits such as saving money, reducing regulatory burden, improving production
efficiency, enhancing company image, and obtaining a healthier work place.
NHPPP would like to increase P2 awareness because by informing as many people as possible, our
environment will suffer less detrimental effects.
One example of P2 implementation took place at a marina we visited. The marina wrapped
each boat in shrink-wrap and stored the boats in a covered storage building. NHPPP suggested
discontinuing shrink-wrap since the boats are already stored under cover. By simply eliminating
shrink-wrap from their process, the marina could save valuable time, money, and space.
VII. RECOMMENDATIONS FOR FUTURE EFFORTS
Based on my time at DES, I believe that the individual employees should be more energy
conscious. Even though employees at DES work hard to better the environment there are many
places where electricity is wasted. I have audited some work areas and have found computers,
monitors, radios, and lights left on over night. Nearly every work station leaves their power strip on
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at all times. NHPPP is the only program that is consistent with shutting off all of their electronics
before going home at the end of the day.
One aspect that amazes me about this issue is that the DES and the
Department of Health and Human Services (DHHS) building has an Energy
Conservation and Efficiency Initiative.
This initiative encourages
employees to be more energy efficient at work and at home. The initiative
explains how burning fossil fuels causes most of the air pollution in New
Hampshire. It also describes that these air pollutants contribute to health
and environmental concerns, like ozone smog and global warming.
I suggest having an intern review all the sections in a work area, and record any energywasting units, such as computers, monitors, radios, lights, and power blocks. The intern could write
up the final results and route an awareness report around the building. It is important to get upper
management commitment with this issue, because without this, little improvement will be made.
Finally, the Commissioner or someone in the Commissioner’s office should send out reminder
messages of energy efficiency each week.
Throughout the summer, my title has been the “Intern Liaison.” As a “liaison” I received
two questions about an engineering project. Also, the emails from the P2 Intern Coordinator were
sent to me, and directed me to forward the message to the other interns. Unfortunately, I felt like I
was not doing my job as the “Intern Liaison.”
My expectations as liaison included working with other interns on
their engineering projects. I was disappointed to get only two questions about
a company process. The idea of having an intern as a contact is a great idea,
but it has to be known what kind of services the liaison can offer. Either
people are getting enough help from their facilities, or they do not think that
their peers can help them with complicated questions.
I recommend changing the title of the intern who works with DES to “P2 Program
Assistant.” NHPPP and the intern coordinator would still be available if the interns have any
questions. The intern coordinator could also send out emails to all the interns, instead of just the
representative at the DES.
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For the last month of my internship, the P2 program had difficulties finding work for me to
do. Sometimes my tasks would include filing, or labeling and stuffing envelopes. A list of projects
was given to me and all projects were completed; however, there was still not enough work for my
full internship.
It is a trend for the P2 program to have less work in August than in any other month. Most
of the time, August is the time when the staff can catch up with their workload. There were a lot of
projects that I could not take on by myself as an intern. My internship was not as valuable to
NHPPP when they did not have work for me, and it was not as valuable to me when I was not active
in a project.
I recommend cutting the hours of the NHPPP intern to 30 hours per week instead of 40.
Some students may prefer to work less hours over the summer for vacation purposes, or to work
another job. This would benefit to both the employer and the employee.
IX. APPENDICES
[1] Municipal (DPW) Follow-Up Report
[2] Circuit Board Manufacturer (ABC) Follow-Up Report
[3] Orthopedic Plastics Company (XYZ) On-Site Assessment Report
[4] Loctite Case Study
[5] Simplified Lead Database
[6] P2 Intern Survey Results
[7] CO-13 Fact Sheet and Vendor List
[8] Environmental Management Systems Web Page
[9] Project Proposal and Progress Reports
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VIII. REFERENCES

CO-11: Environmental Management Systems, 2000, http://www.des.state.nh.us/factsheets/
co/co-11.htm.

“Drivers, Designs, and Consequences of Environmental Management Systems; A Research
Compendium,” U.S. Environmental Protection Agency, http://63.241.172.178/isopilots/
NDEMS2000Compendium.pdf.

“State of New Hampshire Rules Governing Control of Air Pollution,” New Hampshire
Department of Environmental Services, May 8, 1998.

New Hampshire Pollution Prevention Program, August 13, 2001,
http://www.des.state.nh.us/nhppp/.

“Profile of the Plastic Resin and Man-made Fiber Industry,” U.S. Environmental Protection
Agency, September 1997.

P2 Tech E-mail List Archive, 2001, http://www.great-lakes.net/lists/p2tech/.

“State of New Hampshire Hazardous Waste Rules,” New Hampshire Department of
Environmental Services, August 1, 2001.

Thomas Register of American Manufacturers, http://www.thomasregister.com/.

U.S. Environmental Protection Agency, Volume 2, Issue 9.9.7, August 2001,
http://www.epa.gov.
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FOLLOW-UP REPORT
New Hampshire Department of Environmental Services
Pollution Prevention Program
Report Date:
June 15, 2001
Company:
Department of Public Works and Water and Sewer
Purpose:
The purpose of the site visit was to assess how the Department of Public
Works implemented previously suggested pollution prevention strategies.
Attendees:
Sara Johnson, New Hampshire Department of Environmental Services,
Pollution Prevention Program, 603-271-6460, sjohnson@des.state.nh.us
Jen Drociak, New Hampshire Department of Environmental Services,
Pollution Prevention Program, 603-271-0878, jdrociak@des.state.nh.us
April Duhaime, New Hampshire Department of Environmental Services,
Pollution Prevention Intern
Background:
At the request of the DPW, a site visit was scheduled and conducted on
September 19, 2000. NHPPP visited two sites; Water and Sewer (WS) and
Department of Public Works (DPW). Both locations had numerous materials
(products and waste), scattered around the property.
Assessment:
The following observations were made by the NHPPP during the meeting and
walk through assessment on June 7, 2001.
Absorbents
Findings: On the initial visit, Speedy-Dry was disposed of as solid waste.
NHPPP suggested reducing the use of absorbents through the use of drip pans
or wringable pans. The DPW is still using Speedy-Dry, however, the drip
pans have been re-arranged and are more readily available.
Aerosol Cans
Findings: On the initial visit, aerosol cans were emptied and disposed of as
solid waste. NHPPP suggested recycling all empty aerosol cans with a scrap
metal dealer. The DPW has a scrap metal dealer, however, they do not
accept any pressurized aerosol cans.
Battery Storage
Findings: Used batteries are regularly recycled off-site. NHPPP suggested
storing the used batteries on an acid-resistant, impermiable surface. NHPPP
also suggested storing batteries under cover, away from flammable liquids,
ignition sources, and floor drains. Observed on June 7, 2001, DPW has
implemented these pollution prevention suggestions.
Parts Washing Solvent
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Findings: On the initial site visit, the lid to the parts washer was left open.
NHPPP suggested keeping the parts-washer closed when not in use. NHPPP
further suggested pre-cleaning parts with wire brushers or scrapers to extend
the solvent’s use. Observed on June 7, 2001, the parts-washer was closed,
and all parts are now wiped down before being placed into the parts washer.
Waste solvent is still picked up annually by a hazardous waste transporter.
Shop Wipes
Findings: On the initial visit, rags were collected and sent out for laundering.
NHPPP suggested storing the rags in a labeled metal container with a tightfitting lid. Observed on June 7, 2001, DPW had implemented these pollution
prevention suggestions.
Used Oil
Findings: During the initial site visit, many used oil tanks were not labeled.
Also, a small spill had occurred when one tank was filled over capacity.
NHPPP suggested labeling used oil containers with the words “Used Oil for
Recycle.” Observed on June 7, 2001, DPW had implemented this pollution
prevention suggestion and NHPPP found that the oil tub had been cut up for
scrap metal.
Used Oil Filters
Findings: On the initial site visit, DPW drained and recycled used oil filters
with a scrap metal dealer. NHPPP suggested applying for a grant from the
DES Used Oil Program to purchase an oil filter crusher. Observed on June 7,
2001, DPW had implemented this pollution prevention suggestion.
Storm Water
Findings: On the initial visit, the DPW was working on the EPA Phase II
Small MS4 federal storm water permits. The facility will be moving to a new
location by the year 2002, and will not be included for Phase II permits.
Outside Storage
Findings: On the initial visit, some spreaders were not under cover. Scrap
metal, solid waste, and unknown waste was also scattered throughout both
locations. NHPPP suggested keeping all spreaders under cover and on an
impervious surface. NHPPP also suggested storing scrap metal in one area,
away from any nearby water bodies. All hazardous waste should be stored in
the waste storage area. Observed on June 7, 2001, most of the waste and
metals were moved into a covered storage area. Drip pans and concrete were
not a reasonable solution for the spreaders because of the future change in
location, so hydraulics were bagged and capped to prevent leakage.
According the DPW, covering the spreaders will be the next project for the
facility.
Sumps and Floor Drains
Findings: On the initial site visit, WS had one floor drain that was assumed
to discharge to a stream at the back of the property. NHPPP suggested a)
permanently sealing the floor drain, b) connecting the floor drain to a
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municipal sewer in accordance with DES and local regulations, or c)
obtaining a groundwater discharge permit. Observed on June 7, 2001, the
floor drain was filled with cement and no longer in use.
Safety
Findings: On the initial visit, there were no “no smoking” signs or
emergency numbers posted at either the DPW or WS. Fire extinguishers had
not been tested and small containers of kerosene were stored on open shelves
at WS. At the DPW, several flammable cans were stored on an open shelf.
NHPPP suggested posting these signs, storing flammables in an explosionproof cabinet, and testing the fire extinguishers. Observed on June 7, 2001,
“no smoking” signs were properly placed, fire extinguishers had been tested,
and the kerosene and flammable cans were placed in fire proof cabinets.
Emergency numbers were still not posted next to phones.
Housekeeping
Findings: On the initial visit, the NHPPP found leaking drums, stained
flooring, unmarked bottles, and a fair amount of clutter in the form of old
parts, empty drums and debris during the first inspection. There were also
several 5-gallon containers about 1/3 full of an unknown liquid. NHPPP
suggested to mark all containers, whether it is filled with product of waste,
and organize a waste storage area with proper signage. Observed on June 7,
2001, there were no unmarked bottles or containers of unknown liquids, and
the clutter had been moved from the outside pile to a covered storage area.
Only two small leaking drums were found, and oil-saturated soil was seen in
a truck’s parking stall.
Overall, the DPW worked hard on their environmental issues and took most
of the suggestions made by the NHPPP. The DPW should be commended for
the excellent job they completed in meeting our recommendations. If you
need further assistance, or would like us to visit your new facility, please do
not hesitate to contact the NHPPP at (603) 271-6460.
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FOLLOW-UP REPORT
New Hampshire Department of Environmental Services
Pollution Prevention Program
Report Date:
July 31, 2001
Company:
ABC Inc.
Purpose:
The purpose of the site visit was to assess how ABC Inc. implemented
previously suggested pollution prevention strategies.
Attendees:
Sara Johnson, New Hampshire Department of Environmental Services,
Pollution Prevention Program, 603-271-6460, sjohnson@des.state.nh.us
Andrea O’Brien, New Hampshire Small Business Development Center,
(603) 634-2622, aob@cisunix.unh.edu
Heidi Marshall, CLD Consulting Engineers Inc., (603) 668-8223,
heidijm@cldengineers.com
April Duhaime, New Hampshire Department of Environmental Services,
Pollution Prevention Intern
Background:
ABC manufactures flexible printed circuit boards for a variety of
applications. They occupy two buildings at their site. One building is used
primarily for administration and the other building for manufacturing. A
follow-up meeting was scheduled, and the facility walk is to be rescheduled.
Assessment:
The following observations were made by the NHPPP during the meeting on
June 28, 2001.
Hazardous Waste
Findings: On the initial visit, ABC did not have a waste analysis plan.
The NHPPP suggested outlining each waste stream with corresponding
parameters to be measured. ABC is currently working on a waste analysis
plan. Some lines, such as the tin, copper and solder strip lines were complete
as of June 28, 2001.
Suggestion: Continue to have all the waste analyzed.
Lead
Findings: On the initial visit ABC was looking into replacing their lead
plating process. As of June 28, 2001, ABC has found a replacement and will
be planning or scheduling the equipment in late December 2001 during the
down time of the holidays. The new process will be a tin-plating process,
and will eliminate lead and metal hydroxide outputs.
Metal Hydroxide Solids
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Findings: On the initial visit, Envirite was the transporter for ABC’s metal
hydroxide sludge. The certification provided by Envirite does not relieve
ABC from its responsibility for the metal sludge. The NHPPP suggested to
further research the final use or disposal of the sludge. As of June 28, 2001,
Envirite is still ABC’s transporter for the waste sludge.
The sludge is a lead and copper mixture, and should be disposed as hazardous
waste. It is possible that changing the lead line to a tin line will classify the
sludge as non-hazardous. This should be looked into when ABC makes their
change from lead plating to tin plating.
Waste Storage
Findings: On the initial visit, ABC had some unlabeled drums, one
mislabeled drum, one beyond the 90-day storage limit, and another
containing a corrosive liquid in a rusted metal drum. There were no
emergency postings near phones or a map showing the location to the nearest
spill kit. The metal hydroxide sludge was being stored in a plastic sack with
a label that was easily pulled off the packaging. The NHPPP suggested
determining the contents of the drums, label them all correctly, ship out the
over-due drum as soon as possible, and transfer the corrosive liquid into a
container suitable for corrosives. It was also recommended to secure all
labels, post emergency numbers, and clearly mark spill control equipment.
Weekly inspections and reviewing of their contingency plans as well as spill
training were also suggested. As of June 28, 2001, ABC had shipped out
their over-due waste, purchased better tape for labeling, and posted
emergency phone lists. ABC also has weekly storage logs, training for spills,
and has reviewed their contingency plans.
Satellite Storage of Etching Fluid
Findings: During the initial visit, ABC had a pipe/tube connecting from the
etch tank to a drum of spent etching fluid. The NHPPP informed ABC that
the spent etching fluid fell under Env-Wm 509.03, and they should tend to it
in this way. As of June 28, 2001, the satellite storage of etching fluid had not
been changed.
Spent Etching
Findings: On the initial visit, ABC’s spent etching was sent off-site for
recycling, and the waste was not manifested. The NHPPP informed ABC
that the spent etching was a hazardous waste and should be manifested. As
of June 28, 2001, the situation has not changed. ABC should conduct a
hazardous waste determination test on the spent etching and include the
results with the waste analysis plan.
Air Emissions
Findings: On the initial visit, ABC had two exhaust hoods. As of June 28,
2001, ABC has undergone an air quality evaluation, and is monitoring the air
in the room on a monthly basis, based on OSHA regulations. The NHPPP
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notified ABC about the new state air emissions regulation, Env-A 1400,
which requires companies to evaluate their emissions by May 8, 2001. The
NHPPP recommends to undergo the environmental air emissions calculations
to make sure they are in compliance with Env-A 1400.
Plating Water Usage
Findings: On the initial visit, water from the rinse tanks continuously
discharged and was treated even when the plating line was not operating.
The NHPPP suggested trying evaporation techniques, since the water running
out of the rinse tanks is necessary for the system. As of June 28, 2001, ABC
has reduced their plating water usage. All systems are shut off during
weekends, which reduces water use.
Non-Contact Water Usage
Findings: On the initial visit, ABC was not permitted to discharge their noncontact cooling waster to the sewer system; however, ABC was working on a
close loop system for the water through underground storage tanks. The
NHPPP suggested getting the recycling system in place by October (their
personal deadline) since they do not have a permit to discharge to the sewer.
As of June 28, 2001, ABC is still working on the close loop system, because
they are over their sewer permit with their city.
Storm Water
Findings: On the initial visit, drums had been stored near the loading dock,
and there was a berm on one side of the catch basin. The NHPPP suggested
looking into Phase I documentation, since circuit board manufacturers fall
under these federal storm water regulations. As of June 28, 2001, ABC has
done a storm water analysis and has discovered that they do not need a
permit. The berm has been replaced with a temporary berm that is only used
when loading or unloading at the dock. ABC also removed all the drums
being stored outside near the loading dock.
Used Oil
Findings: On the initial visit, Hope Air was transporting the waste oil from
the compressor. The waste oil was being labeled as hazardous waste. The
NHPPP suggested running a profile test to see if the oil is actually hazardous
waste. If the test shows that the used oil is non-hazardous, ABC can use a
bill of lading and attach the profile documentation to prove that it is nonhazardous.
Speedy-Dry Waste
Findings: On the initial visit, speedy-dry was used for spills and drips, and
then disposed of as solid waste. The NHPPP informed ABC that speedy-dry
is subject to a hazardous waste determination test. As of June 28, 2001, ABC
is testing the speedy-dry after every usage.
17
Fluorescent Lamps Findings: On the initial visit, the fluorescent lamps were sent out of house;
however, it was unsure if they were being recycled of disposed of as a
hazardous waste. The NHPPP suggested contacting their vendor to find out
how the lamps were being disposed. As of June 28, 2001, ABC is still unsure
if the bulbs are recycled or not.
Non-hazardous Waste
Findings: On the initial visit, Draghi Environmental was ABC’s nonhazardous waste hauler. The NHPPP warned ABC after the first visit that
Draghi Environmental was not a registered hazardous waste transporter at the
time. ABC will investigate if Draghi is a hazardous or non-hazardous waste
transporter.
House Keeping
Findings: On the initial visit, the floors in the plating area were found wet.
The NHPPP suggested reducing or eliminating the drag out and the amount
of fluids that ends up on the floor. As of June 28, 2001, ABC is changing the
format of the process in the plating area to cut down on the transporting of
wet racks.
Conclusions and Recommendations
Overall, ABC Inc. worked hard on their environmental issues and took some
of the suggestions made by the NHPPP. If you need further assistance, or
would like us to visit your new facility, please do not hesitate to contact the
NHPPP at (603) 271-6460.
18
ON-SITE REPORT
New Hampshire Department of Environmental Services
Pollution Prevention Program
Report Date:
July 30, 2001
Company:
XYZ Incorporated
Purpose:
The purpose of the site visit was to assess XYZ’s regulatory and pollution
prevention options. XYZ is pursuing ISO 14001 by November, 2001. The
NH Pollution Prevention Program (NHPPP) and the Small Business
Development Center (SBDC) gave information and suggestions for pollution
prevention along with regulatory compliance advice.
Attendees:
Sara Johnson, New Hampshire Department of Environmental Services,
Pollution Prevention Program, 603-271-6460, sjohnson@des.state.nh.us
Andrea O’Brien, New Hampshire Small Business Development Center,
(603) 634-2622, aob@cisunix.unh.edu
April Duhaime, New Hampshire Department of Environmental Services,
Pollution Prevention Intern
Background:
At the request of XYZ, a site visit was scheduled and conducted on June 11,
2001.
Assessment:
The following observations were made by the NHPPP and NHSBDC during
the meeting and walk through assessment on June 11, 2001.
Antifreeze
Findings: Antifreeze is stored in five 55-gallon drums and is labeled 95%
water, 5% propylene glycol. The storage area was not labeled as hazardous
waste storage area. One area is located near the injection molding station,
and the other area is along the wall behind the machine department.
Suggestions: Waste antifreeze must be evaluated to determine if they are
hazardous wastes and, if so, managed in accordance with the requirements of
the NH Hazardous Waste Rules. These requirements may include use of a
hazardous waste manifest, New Hampshire registered hazardous waste
transporter, and delivery to an authorized hazardous waste facility. DES
believes that recycling is the preferred option for managing waste antifreeze.
If XYZ will not have to add antifreeze to their generator status calculations if
they decide to recycle it. XYZ may purchase an antifreeze distillation or
filtration unit and recycle their own antifreeze on-site, hire a contractor to
come in with a mobile recycling unit, or ship the antifreeze to a recycling
facility.
19
The antifreeze used in the process is 95% water. Another option XYZ has is
to talk to the Manchester POTW to see if they would accept antifreeze in
their sewer permit, since it is mostly water.
It may be possible for XYZ to reuse the used antifreeze in the system. If the
antifreeze is still clean, and is still working properly, try using it over again
and see if you get the same results.
Antifreeze drums should be labeled with the words” waste antifreeze”, and
the area in which it is stored should be labeled hazardous waste storage area.
Silver
Findings: A photo fixer solution containing silver is used in designing
graphics. A silver drum was found unlabeled, but the drum was closed and
bermed. XYZ disposed about 56 gallons of D011 silver liquid as hazardous
waste in the year 2000.
Suggestions: The regulations in Part Env-Wm 808 are applicable to spent
fixer solutions that are reclaimed to recover economically significant amounts
of silver. Generators of recyclable materials would therefore not be subject
to the full standard of generators under Chapter Env-Wm 500. The generator
would, however, be required to notify DES if its activities and to ship the
wastes via a New Hampshire registered hazardous waste transporter, using a
uniform hazardous waste manifest, to a facility authorized to accept such
wastes. The resultant solution should be processed through a silver recovery
unit. Your photographic supplier should have more information on this
treatment unit. This would eliminate D011 waste from your facility.
Furthermore, the film can be handled as a silver scrap metal.
Inks
Findings: XYZ uses epoxy inks in their process. XYZ uses 167 pints of
Markem 4166 epoxy ink per year.
Suggestions: When this ink is used, formaldehyde is emitted into the air.
GZA has done calculations that prove the company is in compliance with the
rules. After our calculations, we confirmed the information, and XYZ can
continue with what they are doing, as long as they do not change the amount
of inks used.
Shop Wipes
Findings: Denatured alcohol and sometimes acetone is used to wipe
fingerprints off the plastic with the aid of rags. The rags are then put into red
airtight containers and the containers are cleaned out daily. The rags are
disposed of as solid waste.
Suggestions: Acetone is a regulated toxic air pollutant, and in order to have
this chemical on site, there are air toxic calculations that must be done (unless
GZA completed these calculations already). It is a possibility that the
acetone has fully evaporated from the rag before the rag is thrown in the
containers; however, in order to continue this process, the acetone rags will
20
have to undergo a hazardous waste determination test, as stated in Env-Wm
401.04. The NHPPP suggests to no longer use acetone, since denatured
alcohol can be used for the same purpose.
Xylene
Findings: A xylene container was found in a flammable cabinet at the first
cleaning station in the sheet cutting area. Xylene is used as a cleaning agent
to rid the plastic of fingerprints.
Suggestions: Xylene is a regulated toxic air pollutant, and in order to have
this chemical on site, there are air toxic calculations that must be done (unless
GZA completed these calculations already). Air toxic calculations are better
described in Env-A 1400. These rules can be found on our website at
http://www.des.state.nh.us/ard/enva1400.htm. The NHPPP suggests to
discontinue the use of xylene, since denatured alcohol can be used for the
same purpose.
Ethyl Acetate
Findings: Ethyl acetate is used as a cleaning agent in one of the final
cleaning stages, and is only used when necessary.
Suggestions: Ethyl acetate is another regulated air toxic pollutant, and the
air toxic calculations described in Env-A 1400 must be carried out to
continue having ethyl acetate on site. The NHPPP suggests to discontinue
the use of ethyl acetate, since denatured alcohol can be used for the same
purpose.
MEK
Findings: A bottle of MEK was found on a table in the photo processing lab
area. The usage of this chemical was undetermined.
Suggestions: MEK is also an air toxic pollutant, and the air toxic
calculations described in Env-A 1400 must be carried out to continue having
MEK on site. The NHPPP recommends finding the reason for using MEK.
If MEK is needed in the process, then it is suggested to find an alternative to
this chemical.
Fluorescent Bulbs
Findings: Fluorescent bulbs are disposed of as solid waste.
Suggestions: Fluorescent bulbs contain mercury and should be handled as
either a hazardous waste, or under the Universal Waste Policy and recycled.
If handled as a hazardous waste, the bulbs must be added to generator status.
If your local transfer station allows small businesses to dispose of the bulbs,
XYZ can self-transport the bulbs to the transfer station for recycling.
To recycle mercury-containing lamps, you should store the intact bulb in the
same boxes that they come in (or similar size), or in a fiber drum. Check
with your municipal transfer station to determine if they accept fluorescent
bulbs for recycling. If your transfer station does not accept lamps, there are
many vendors that will. For a list of mercury lamp recycling vendors, please
contact the DES Pollution Prevention Program at (603) 271-6460, or
21
nhppp@des.state.nh.us, or visit www.des.state.nh.us/factsheets/hw/ hw7.htm.
If broken, fluorescent bulbs are a RCRA hazardous waste and a source of
mercury emissions. Keep broken lamps in sealed, airtight containers and
dispose as hazardous waste. If using green tip lamps (lower in mercury
content, but pass TCLP tests), we recommend recycling, since they contain
mercury.
Used Oil
Findings: Every other year maintenance work is done on the machinery at
XYZ. The used oil is stored in 55-gallon drums, and disposed of as
hazardous waste.
Suggestions: Ensure that the waste oil that leaves your site has been
evaluated by performing an initial used oil determination. Used oil can be
recycled rather than manifested as a hazardous waste if the oil is proven to be
on-spec and shipped using a bill of lading. Copies of the Bills of Lading of all
used oil transfers should be kept on file. XYZ should also keep a copy of the
initial, one-time only test results on file. For more information, contact the
DES Used Oil Program at (603) 1-800 TAKE OIL.
Drums
Findings: Unlabled drums were found with unknown contents.
Suggestions: Label all containers appropriately (including date of
accumulation and EPA waste ID number) and keep them closed while not in
use. Make sure that the area is designated as “the hazardous waste storage
area”.
Aerosol Cans
Findings: Aerosol cans are disposed of as solid waste.
Suggestions: Empty aerosol cans can be collected and recycled by a scrap
metal dealer.
Storm Water
Findings: XYZ did not have a storm water permit as of June 11, 2001;
however, they had applied for one with their city.
Suggestions: XYZ should continue to pursue a storm water permit with their
city until they get a response.
Absorbents
Findings: Speedy dry is used as an absorbent. It is disposed of as a solid
waste.
Suggestions: A source reduction suggestion is to reduce the use of absorbent
through the use of drip pans. By using drip pans, the shop floor will remain
cleaner, and hence require less frequent cleaning. The material collected in
the drip pans can be reused or collected for recycling rather than disposed.
Speedy Dry is subject to a hazardous waste determination. The material
should be analyzed and then managed accordingly. If Speedy Dry is used to
22
clean up a hazardous material, it should be managed as a hazardous waste.
For further clarification on hazardous waste determination and management
of Speedy Dry, contact the RCRA hotline at (603) 271-2942.
Once the materials are tested, generators can use their knowledge of
disposing materials to continue it’s classification as long as the source
remains unchanged. If the absorbent materials contain mixed waste, a
hazardous waste determination will be necessary or the materials must be
disposed of as hazardous waste.
FQG Requirements Findings: During the opening meeting, the NHPPP was informed that XYZ
did not have a health and safety coordinator. XYZ is a full quantity generator
(FQG).
Suggestions: Although health and safety personnel are not required, the
NHPPP suggests appointing someone to be in charge with this issue for the
size of the XYZ facility and with the ISO 14001 certification. Since XYZ is
an FQG, additional environmental requirements must be met. The required
plans that XYZ must maintain because of their generator status are as
follows: having weekly documented inspections of storage; yearly personnel
training; a preparedness and prevention plan; a contingency plan; and
emergency procedures. More information about these requirements can be
found under the hazardous waste rules on our website at
http://www.des.state.nh.us/hwrb/hwrules.pdf.
Conclusions and Recommendations
The NHPPP’s goal is to supply an accurate and beneficial report. However,
since the NHPPP is a non-regulatory assistance program, in depth
clarification of the environmental rules in this report should be referred to the
RCRA hotline at (603) 271-2942 or the appropriate program. If you have
any questions or comments about this report, or would like further assistance,
please do not hesitate to call.
The NHPPP would like to schedule a follow-up meeting and short assessment
six months from the completed report date. We will be contacting you in
January 2002 to set up an appointment. The goal of the follow-up is to
measure XYZ’s progress and address opportunities to better assist your
facility.
23
Pollution Prevention Case Study
Loctite Corporation
Seabrook, NH
SUMMARY
Loctite, formally Dexter Polymer Systems, is a manufacturer of adhesives and mold release
compounds. Through reducing, reusing, recycling and eliminating, Loctite was able to cut costs
and help the environment. Some of the projects Loctite has worked on are the elimination of ozonedepleting chemicals, the recycling of cardboard and shredded paper, the reuse of polyethylene
sleeves, the elimination of solvent-based parts washing, the elimination of lawn treatment
chemicals, the use of environmentally friendly cleaning agents, and the implementation of inventory
control. Loctite Corporation is now ISO 14001 certified, along with reducing their solid waste by
25%, reducing their toxic emissions by half, and reducing VOC emissions by process
improvements.
BACKGROUND
Loctite Corporation has had an environmental program for eleven years. They have used
management systems and teamwork to achieve their success. In addition to all the projects stated
above, Loctite has included a new water-based product line as an alternative to solvents, improved
their drying procedure to reduce the solvent found in by-products, eliminated the use of lawn
treatment chemicals, and eliminated the use of caustic cleaning agents in two of their three reactors
by using a grinder. Although implementation of all these projects required money and time from
the company, Loctite noticed the pay-backs (such as reduced waste disposal costs, raw material
costs, reduced liability, and improved company morale), and took advantage of implementing a
pollution prevention program.
RESULTS
The savings from reductions and eliminations in Loctite’s processes are shown below:
Project Implemented
Money Saved
Eliminated ozone-depleting chemicals
Eliminated caustic cleaning agent in 2 of 3
reactors by using a grinder
Recycled cardboard and shredded paper
Included a water-based product line
Improved drying to reduce solvents in byproducts
$17,000 annually
$105 of annual purchase savings
$15,000 per year
$10 per drum
$7,000 of annual cost savings
24
Loctite Corporation continues to explore cost savings and environmental improvement through
management and employees, and is currently working on some pollution prevention goals, such as
reducing their solid waste, toxic emissions, and VOC emissions.
25
P2 Intern Survey Results
 The P2 Internship program has had 57 interns since 1994. Out of the 57 past interns, 22
people took the time to fill out the survey.
Intern Job Length
Less than 1
year
1-3 years
More than 3
years
Graduate
Students
 64% of the interns that replied to the survey have been with the same company since they
graduated college, where 32% of the interns have changed jobs before.
Intern Recruitment Media
10
8
6
4
2
0
UNH
Recruiters Through
P2 Newspaper Word of
Current Program
Mouth
Job
Media
 Half of the past interns implement their P2 skills at their facilities now, while the rest of the
interns claim that their positions do not pertain to pollution prevention.
26
 86% of the interns that replied have been well-prepared for their jobs out of college because
of the P2 Internship Program.
CO-13
2001
Environmental Management Systems:
Frequently Asked Questions
Purpose
The New Hampshire Department of Environmental Services (DES) is interested in helping
companies with preventing pollution and saving money while helping the environment. An
Environmental Management System (EMS) is a system that shows a company
exceeds compliance with all regulations, and will continue to meet the requirements
while still improving their pollution prevention techniques. With an EMS, the
facility can easily save money and the environment at the same time, with no extra
work. This fact sheet further explains EMSs and their relationship to pollution
prevention.
What is an EMS?
Environmental awareness is shaping the actions of today’s leading corporations. One tool used
by corporations to manage and improve their environmental impacts, and improve their financial
performance, is an Environmental Management System (EMS). An EMS is a comprehensive,
organized, and documented system for an organization to manage all of its actions that affect the
environment. It is a system that requires planning, reviewing, revising and improving a company’s
method of maintaining compliance and reducing waste. When a company spends the time to work
towards an EMS, the results are tremendous for the environment and company
profits. An EMS encourages companies to get organized and look at pollution
prevention solutions for their waste streams. This also allows the company to
learn more about their waste streams, for example the effects it has on the
environment and how well it benefits both the Earth and the company when
27
pollution prevention steps are taken. The most commonly used EMS is the ISO 14001 system.
Is my business too small to have the resources for an EMS?
Many small businesses may feel they do not significantly impact the environment and do not
have the resources to significantly improve their impact. However, everyone impacts the
environment, and with proper planning and organization, even a small business can make a
tremendous impact on their profits while helping the environment. The standards for an EMS are
made so that any organization from any field or size can implement one. The only characteristics a
company needs for success is organization and a lot of planning. Pollution prevention planning can
be an important first step.
How does an EMS relate to Pollution Prevention (P2)?
Pollution prevention is the practice of reducing or eliminating wastes or pollutants at the source.
To do this, companies should take the following six steps:
1. Get Organized. Create a planning committee that is composed of workers from different
departments that can provide different expertise on the P2 topic.
2. Analyze Processes. Inspect each sub-process. Pinpoint energy and material inputs,
determine the sources of waste, calculate the total cost, set priorities, and start on the
projects.
3. Identify Alternatives. Create a variety of ideas for alternative methods to replace the current
processes.
4. Evaluate Alternatives. Determine whether the alternatives will be effective, implementable,
and economical to the company.
5. Implement Projects. Plan on when the projects will be started, start the project, and obtain
feedback from employees.
6. Measure Progress. Collect data to get information on how well the project is working.
These steps are simply the basis of an EMS. If a facility is involved with P2 practices,
then it is probably very close to obtaining an EMS. As a company finds ways to stop
pollution before it is created, it is also coming into compliance with regulations.
What will a company gain by getting an EMS?
Companies that have EMSs have found many cost saving opportunities, along with appealing to
customers, gaining a market advantage, and improving their public image. With an EMS,
28
companies have been able to control their liabilities, which makes both the
employers and employees happy, as well as their insurers. Facilities have less of a problem
maintaining compliance, which saves money, time and a lot of hassle. An EMS will also ultimately
make employees know all laws and regulations for their business. All company obligations will be
documented, so the material will be readily available at any time. Since environmental performance
and financial performance are connected with an EMS, companies can be assured success and
growth.
What does ISO certification (or registration) mean?
Any company can claim themselves to be ISO certified, or they can hire third-party registrars to
certify their system. For example, to be ISO 14001 certified, the business must have:






An environmental policy, where the business states its commitment to environmental
performance.
Planning, where the organization analyzes its impact on the environment.
Practicing, where the company uses the processes that will help reach environmental goals.
Monitoring, where the organization makes sure the goals are being met constantly.
Management Review, where the EMS is reviewed to ensure it is effective and being met.
Continual improvement, where the company regularly searches for new and improved ways
for eliminating waste streams.
What are the advantages of ISO 14001Certification?
By being ISO 14001 certified, a company is sure to save money and the environment. That
company will also appeal to customers (some customers are requiring it), and can maintain good
public relations as well as government relations. It is possible to get insurance at a reasonable cost
and reduce incidents that may result in liability. Lastly, but not least, that company will not have to
worry as much about compliance with regulations, because they will always be improving their
status.
For More Information
If you have questions about Environmental Management Systems, please contact Bob Minicucci at
(603) 271-2941 or email rminicucci@des.state.nh.us. Any questions or interests about pollution
prevention opportunities can be emailed at nhppp@des.state.nh. us, or call (603) 271-6460.
ISO 14000 and EMS Consultants
New England Region
29
This is not a complete list of all consultants available, nor does it imply endorsement from
the New Hampshire Department of Environmental Services. August 2001
Company Information
Aries Engineering Inc.
46 South Main St.
Concord, NH 03301
(603) 226-2545
mdonahue@aries-eng.com
tomroy@aries-eng.com
Cahaly Environmental
111 Kendall Rd.
Lexington, MA 02421
(781) 860-5240 ; (781) 860-7261 Fax
cahalyr@ix.netcom.com
Camp Dresser & McKee Inc.
1001 Elm St.
Manchester, NH 03101
(603) 222-8300 ; (603) 645-6891 Fax
diercksje@cdm.com
www.cdm.com/Svcs/EMS/index.htm
Earth Tech
161 North State St.
Concord, NH 03301
(603) 226-0940 ; (603) 228-4233 Fax
tmarkey@earthtech.com
www.earthtech.com
Environmental Resources Management
399 Boylston St.
Boston, MA 02116
(617) 646-7826 ; (617) 267-6447 Fax
jim_Fitzgerald@erm.com
www.erm.com
Haley & Aldrich Inc.
340 Granite St.
Manchester, NH 03102
(603) 625-5353 ; (603) 624-8307 Fax
rrb@haleyaldrich.com
www.haleyaldrich.com
Harper Environmental Associates
1811 Hale Hollow Rd.
Bridgewater Corners, VT 05035
(802) 672-6112 ; (802) 672-6227 Fax
charper@sover.net
Atlantic Geoscience Corp.
PO Box 7407
Gilford, NH 03247
(603) 524-8866 ; (603) 524-9777 Fax
jdonohue@geo-science.com
www.geo-science.com
Camp Dresser & McKee Inc.
50 Hampshire St.
Cambridge, MA 02139
(617) 452-6338 ; (617) 452-8338 Fax
dentchmd@cdm.com
www.cdm.com
Continental Placer Inc.
PO Box 825
Laconia, NH 03247
(603) 524-0811 ; (603) 524-7476 Fax
jtarr@continentalplacer.com
www.continentalplacer.com
Environmental & Industrial Waste
Management
29 Rumford St.
Concord, NH 03301
(603) 224-0563 ; (603) 224-0540 Fax
eiwm@mediaone.net
GZA Geoenvironmental Inc.
380 Harvey Rd.
Manchester, NH 03103
(603) 623-3600 ; (603) 624-9463 Fax
bcote@gza.com
www.gza.net
Harding ESE Inc.
410 Amherst St. Suite 100
Nashua, NH 03063
(603) 889-3737 ; (603) 880-6111 Fax
WGWilson@mactec.com
HAZMATEAM Inc.
12 Kimball Hill Rd.
Hudson, NH 03051
(603) 882-1112 ; (603) 882-6512 Fax
30
www.harperenvironmental.com
hazmateam@earthlink.net
www.hazmateam.com
Jacques Whitford Co Inc.
75 Pearl St.
Portland, ME 04101
(207) 761-7790 ; (207) 761-7790 Fax
tcoffin@jacqueswhitford.com
www.jacqueswhitford.com
OccuHealth Inc.
44 Wood Ave.
Mansfield, MA 02048
(508) 339-9119 ; (508) 339-2893 Fax
occuhealthinc.com
Lexicon Environmental Assoc Inc.
925 Hempstead Turnpike
Franklin Square, NY 11010
(516) 488-8742 ; (516) 488-8743 Fax
lexiconli@aol.com
www.lexiconenvironmental.com
Smart
Association
Environmental
T. Quest Systems
139 Isinglass Rd.
Portland, CT 06480
(860) 342-1457 ; (203) 699-3321 Fax
jeffflynn9@aol.com
Consultants
72 North Main St.
Concord, NH 03301
(603) 224-7550 ; (603) 224-7890 Fax
lboutwell@smartenvironmental.com
www.smartenvironmental.com
WESTON
1 Wall St.
Manchester, NH 03101
(603) 656-5400 ; (603) 656-5401 Fax
goodwinp@wseinc.com
31
Environmental Management Systems
An environmental management system (EMS) is a comprehensive, organized and documented
system for an organization to holistically manage its activities that affect the environment. The EMS
most commonly followed in the United States is described in the international standard ISO 14001.
How does an EMS relate to pollution prevention (P2)? Pollution prevention is the
practice of reducing or eliminating wastes or pollutants at the source. This involves
thinking in a broad and comprehensive way about environmental impacts, making P2
planning and implementation the most common basis for an EMS. Even if a company
does not feel they are ready for an EMS, pollution prevention strategies are a great place
to start.
Currently, high-tech computer companies, the automotive industry, and foreign-owned (European
and Asian) companies are leading the way to EMS implementation. Automotive manufacturers are
requiring their parts suppliers to implement EMSs, and in Europe, ISO 14001 certification is
becoming a standard. Many companies in the United States sell products to Europeans, and in order
to compete with certified industries, certification is the only solution.
There are companies in other industries that have taken the initiative to become
ISO 14001 certified, and DES hopes that New Hampshire industries will
implement an EMS in their facility in the near future. Recently, two Governor’s
Award winners have become ISO 14001 certified. They are Loctite Corporation,
manufacturer of adhesives and mold release compounds, and Millipore, a
manufacturer of filtration devices for the high technology market.
DES Fact Sheets:
CO-11 Environmental Management Systems
CO-13 Environmental Management Systems: Frequently Asked Questions
New England EMS and ISO 14001 Consultants List:
EMS/ISO 14001 Consultants
32
a
EPA and related Links:
EPA’s Environmental Management Systems Page
Design for the Environment: Integrated Environmental Management Systems Page
EPA’s National Database for Environmental Management Systems
“Drivers, Designs, and Consequences of Environmental Management Systems: A Research
Compendium”
Case Studies Within the Document:
Case Study 1: Alpha Manufacturing (page 181)
Case Study 2: Beta Municipality (page 184)
Case Study 3: Delta Electronics (page 189)
Case Study 4: Epsilon Systems (page 198)
Publication:
Planning for Profits: A Guide to Pollution Prevention for New Hampshire Businesses
Contact nhppp@des.state.nh.us for a copy of our guide or for more information.
33
2001 Pollution Prevention Internship
Program
Internship Project Proposal
Date:
Wednesday, June 6th, 2001
Project Title:
Intern Liaison and P2 Outreaching
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Executive Summary: Along with answering all intern questions, the DES wants me to help out
with the hospital, dental and marina projects, update web pages, review newly created documents,
assist with on-site visits, research information requests, write articles for Wastelines, give out the
intern follow-up survey as well as the intern facility survey, and organize and research the lead
database. In short, I will be assisting with daily project tasks for the P2 program and researching for
my fellow interns.
Background: The Pollution Prevention Program at the NH DES is a confidential, non-regulatory
assistance program for New Hampshire businesses. They go on on-sites to the businesses and offer
suggestions for companies to come into compliance with regulations and help limit pollution into
the environment. The P2 Program works daily to reach out to businesses on how to prevent
pollution before it starts.
Objective: The objective is to research and answer intern questions, as well as doing follow-ups to
make sure they did use the information found. For the DES, I will be Compiling useful information
in the lead database for outreaching activities, updating and creating web pages for more
outreaching, and researching about past interns and collecting filled out surveys to analyze how the
internship program works.
Approach: My approach for accomplishing all of the above goals is to start with the long-term
items, and do the short-term items while waiting for the responses. When I get a question from an
34
intern, I will immediately use my resources to find a website, contact person, or a document at the
office to answer their problem. For my written assignments, I will research from other states to see
if it has been written before and read up on the subject I will have to do.
Chemical Usage/Equipment Needs/Releases/Wastes: Does Not Apply
Pollution Prevention Benefits: The pollution prevention benefit in this establishment is to
increase the awareness of pollution prevention around the state. Outreach is the most important tool
at the DES and by informing as many people as possible, our environment will be less polluted.
Writing web-pages, newsletters, factsheets and going to on-sites are the four main challenges for
this summer.
Total Hours worked this 2-week period: 72
35
2001 New Hampshire Pollution Prevention
Internship Program
Biweekly Internship Progress Report
Friday, June 1st, 2001
Intern Liaison and P2 Outreaching
Date:
Project Title:
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Accomplishments:
Beginning with my first day at the DES I have drafted three web pages and helped Dr. Farag
with the P2 internship web page. I emailed the other interns my phone number and email address
and asked them all to respond. I also did some research to find more information about past interns
so I could find where they are today. I went to a meeting on Metrics, which was a database
program that the P2 program was considering using. I created a rough copy of a fact sheet on
EMSs. There were two onsites I attended- one to a marina and another to a municipal. I also went
to a Pyrolysis Workshop to learn about an alternative to incinerating medical waste. Finally, I
created a database for companies disposing lead in NH and cleaned it up so it was easier to read and
analyze.
Future Plans:
In the future I plan on going on a few more on-sites and follow-ups. Scheduled for the next
couple of weeks is a printing company and a cooking manufacturing plant. I will be going to a
municipal workshop, also. On these on-sites and workshops I will be learning the process and
questions the DES asks and I will bring up new questions that I happen to see. I will be sending the
past P2 interns surveys to fill out so I can analyze how the program is working. In addition to all of
these projects, I will be preparing my presentation that will be performed at UNH on June 22nd,
2001.
Total Hours worked this 2-week period: 65
Total Hours worked since the start of the Internship: 80
36
2001 New Hampshire Pollution Prevention
Internship Program
Biweekly Internship Progress Report
Date:
Project Title:
Tuesday, June 26, 2001
Intern Liaison and P2 Outreaching
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Accomplishments:
My first project at the DES was to create a webpage for all of the Governor Award winners.
I recently finished the webpage, after the P2 team reviewed my work. I continued to get in touch
with past P2 interns to collect information about the program. I finished writing a fact sheet on
EMSs for the P2 program and Bob Minicucci. There were three onsites I attended- an orthopedic
plastics company, a printing company and a kitchenware manufacturer. I finished writing a followup report for one of the onsites we went on during my second week at work. I also went to a
Department of Public Works (DPW) Workshop to give pollution prevention information to DPWs
in New Hampshire.
Future Plans:
In the future I plan on getting in touch with some companies that are ISO 14001 certified
and that can be EMS consultants for other businesses that would like to be ISO certified. The
scheduled onsite for the next couple of weeks is a printing circuit board company. On this onsite, I
will be learning the more about the Print Steps project at the DES. I will be calling the past P2
interns about the surveys needed so I can analyze how the program is working. In addition to all of
these projects, I will be preparing a hospital manual for New Hampshire businesses.
Total Hours worked this 2-week period: 76.5
Total Hours worked since the start of the Internship: 156.5
37
2001 New Hampshire Pollution Prevention
Internship Program
Biweekly Internship Progress Report
Date:
Project Title:
Friday, July 6, 2001
Intern Liaison and P2 Outreaching
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Accomplishments:
Over this two-week period, I have put the final touches on my EMS fact sheet to get it ready
for printing and the webpage, written an onsite report, a follow-up report, compiled data for the P2
internship results, finished analyzing the lead data, made an EMS and ISO 14000 consultant list,
made the webpage for the consultant list and the fact sheet links, and I have been working on
retyping a document in word format. I have done some research on the web for both Sara Johnson
and Caitlin LaClair. I also attended an onsite at a circuit board manufacturer.
Future Plans:
In the future I plan to make a P2 facility survey and send it out to the appropriate companies
to further analyze the P2 program. The scheduled onsites for the next couple of weeks are a metal
plater company and a Department of Public Works. On these onsites, I will be learning more about
the DPWs and how to write onsite reports.
Total Hours worked this 2-week period: 56
Total Hours worked since the start of the Internship: 216
38
2001 New Hampshire Pollution Prevention
Internship Program
Biweekly Internship Progress Report
Date:
Project Title:
Friday, July 20, 2001
Intern Liaison and P2 Outreaching
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Accomplishments:
Over this two-week period, I have worked on a hospital outreach document and researched
many things, such as documents on mercury and dioxins (other than for hospitals or dentists),
environmentally preferable items for P2 week, information about future on-sites, and subjects of
interest from other P2 conferences. I also wrote some slides for a PowerPoint Presentation given to
Keene State College, finished a list of environmental contacts, created a webpage for my EMS
Factheet and Consultant list, answered a question from the environmental department in New
Mexico, wrote a case study for one of the Governor Award Winners, and found information about
asbestos in brake shoes (for trucks).
Future Plans:
In the future I plan to write my final report, work on my final PowerPoint presentation,
make a brochure for the final intern presentations, attend another marina on-site, shop for mercurycontaining thermometers in NH, and help one of our clients with making a flow sheet for their
process.
Total Hours worked this 2-week period: 48
Total Hours worked since the start of the Internship: 264
39
2001 New Hampshire Pollution Prevention
Internship Program
Biweekly Internship Progress Report
Date:
Project Title:
Friday, August 3, 2001
Intern Liaison and P2 Outreaching
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Accomplishments:
Over this two-week period, I have worked on the final presentation brochures, researched
information about amalgam traps, household hazardous waste issues, and printing issues. I created
a webpage for my EMS factsheet and vendor list, and I also found other useful links to add to the
page. I made a healthcare association list of contacts so the NHPPP can easily get and send out
information when needed. I have gone to another marina, and also went out looking for mercury
thermometers being sold in Concord. I started working on my final presentation and written report.
Future Plans:
In the future I plan to write my final report, work on my final PowerPoint presentation,
finish the brochures for the final intern presentations, and help one of our clients with making a
flow sheet for their process. I will be working hard to finish all of my projects I have started since
working with the DES.
Total Hours worked this 2-week period: 80
Total Hours worked since the start of the Internship: 344
40
2001 New Hampshire Pollution Prevention
Internship Program
Biweekly Internship Progress Report
Date:
Project Title:
Friday, August 17, 2001
Intern Liaison and P2 Outreach
Intern:
April Duhaime
Home Phone: (603) 622-2963
42 Whitehall Terr.
Work Phone: (603) 271-2902
Hooksett, NH 03106
E-mail: aduhaime@des.state.nh.us
Facility:
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
Contact Person:
Sara Johnson
Pollution Prevention Manager
Phone: (603) 271-6460
E-mail: sjohnson@des.state.nh.us
Accomplishments:
Over this two-week period, I made two signs for recycling thermostats, and delivered one
recycling bin with a sign to a company in Portsmouth. I also compiled a list of the past facilities that
have sponsored a P2 intern with their contact information and put the finishing touches on the Past
P2 Intern Results. Finally, I finished the final presentation brochure, the final presentation agenda,
my final presentation, and my final paper.
Total Hours worked this 2-week period: 56
Total Hours worked since the start of the Internship: 400
41