1997 New Hampshire Pollution Prevention Internship Program

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 Home Phone: (603)-868-3177

60 Madbury Rd. Apt #C Work Phone: (603)-749-8115

Durham, NH 03824 Fax: (603)-749-8174

E-mail:

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:

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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 This list, however, was out of date and in need of revision.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the information to create the these databases, and others, was collected other process information that had fallen out of date was corrected and updated.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.

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.

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.

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.

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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