VT Environmental Compliance News
Newsletter from the Vermont Department of Environmental Conservation's
Environmental Assistance Office
May 2013 
Do You Have Environmental Compliance Questions?
A Greener Look at Spring Cleaning
Recycling Fluorescent Bulbs
Getting Rid of Your Old Electronics?...Please Don't Throw Them in the Trash!
The VT Hazardous Waste Management Regulations Have Been Revised
What is Required When a Business that Generates Hazardous Waste Closes?
Do You Operate a Diesel Generator Even if it is Just for Emergency Backup?
Do You Operate a Boiler at a Location Other Than a Simple Residence?
Important Timetable for Changes to the Act 148 Solid Waste Law
New Air Requirements for Crematory Units
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In this issue... 
  In this issue we look at some of the relatively new state environmental product stewardship programs - electronic waste (e-waste) and fluorescent bulb recycling programs that are available to small businesses at no cost. We also summarize Vermont's Solid Waste Statutes that will eventually ban food residuals from landfills as well as summarize some recent federal EPA air pollution regulations that impact boilers and diesel generators. In our next issue, we will report on other new regulations such as Underground Injection Control (UIC) rules that will impact some subsurface discharges from business operations and showcase winners of the this year's Governor's Awards for Environmental Excellence.
Do You Have Environmental Compliance Questions? 
The Vermont Environmental Assistance Office (EAO) has the answers! The EAO provides no-cost, confidential compliance assistance to Vermont businesses and municipalities as well as guidance to permit applicants, recognition programs for green businesses in Vermont, and assistance to businesses, communities, state agencies, and others to identify effective and economical ways to reduce waste at the source. Contact us to ask a question or to arrange an on-site compliance review. You can check us out at:
A Greener Look at Spring Cleaning...

Environmentally preferable cleaners, including janitorial, household, and various industrial cleaners and degreasers are often readily available - the challenge is finding effective green cleaners that are also cost-effective. Many cleaners have been tested by independent third parties which can help narrow down appropriate choices. We have found the following resources helpful in identifying environmentally preferable cleaners as well as other types of products.


Design for the Environment - An EPA Partnership Program - helps consumers, businesses, and institutional buyers identify cleaning and other products that perform well, are cost-effective, and are safer for the environment.



SF Approved List - Products that meet the City of San Francisco's Health and Environmental Requirements: http://www.sfapproved.org/


EcoLogo - Canadian third-party product certifier: http://www.ecologo.org/en/


Green Seal - U.S. third party product certifier: http://www.greenseal.org/


Cleaner Solutions Data Base for industrial cleaning applications (MA Toxics Use Reduction Institute): http://www.cleanersolutions.org/?action=contaminant_search

Recycling Fluorescent Bulbs

Fluorescent bulbs provide excellent general and task lighting. They reduce lighting energy costs by as much as 75% and last up to 10 times longer than conventional incandescent bulbs. Although the market is likely to be taken over by LED lighting, we will still be using mercury-containing fluorescents well into the future. It is important to properly handle spent fluorescents because they contain trace amounts of mercury (milligrams) and many are classified as a universal hazardous waste. Fluorescents are banned from landfill disposal and the preferred handling method is recycling these through licensed recyclers who recover mercury and other non-hazardous components.


Where can I recycle my spent fluorescent bulbs?


Small businesses can bring limited quantities to many local hardware stores and retail lighting stores (limit of 10 linear or other non-compact fluorescent type) at no cost. For a list of participating retail stores see:


www.mercvt.org or www.newbulbintown.com  



Alternatively, businesses can check with their local solid waste district, alliance, or municipality for details on municipal collection programs. For a list of solid waste districts and alliances see:


Vermont Solid Waste Districts

Getting Rid of Your Old Electronics?...Please Don't Throw Them in the Trash!

Banned Electronic Devices, (whether generated by  businesses or households), cannot be disposed of in the trash. Electronic Devices banned from landfill disposal include:


Computers, peripherals, computer monitors, cathode ray tubes, televisions, printers, personal electronics such as personal digital assistants and music players, electronic game consoles, printers, fax machines, all telephones, answering machines, videocassette recorders, digital versatile disc players, digital converter boxes, stereo equipment, and power supply cords (as used to charge electronic devices). There are many other electronic devices that are not included in this list; therefore, it is recommended that devices that contain potentially hazardous components such as circuit boards and screens be managed in the same manner, even if they are not specifically banned from landfill disposal.


For more information and to find an e-cycle collection location, click on the link below:


Vermont E-Waste Recycling Program  

The VT Hazardous Waste Management Regulations Have Been Revised

Revised Vermont Hazardous Waste Management Regulations (VHWMR) became effective on March 15, 2013. While paper copies of the new VHWMR are not being published, an electronic version can be viewed and/or downloaded on-line at:




A summary of the significant changes made to the VHWMR as well as the Agency's response to comments received on the proposed rule are also available at the same on-line location.

What is Required When a Business that Generates Hazardous Waste Closes?

To ensure that all hazardous wastes have been properly managed when a business closes, the revised VHWMR require that "large quantity generators" and "small quantity generators" submit a "Pre-closure Notification" form at least 90 days prior to the commencement of closure activities. A copy of this form is available on-line at:




The Pre-Closure Notification form requires basic information about the generator's site of operations, a contact person for that site, the types of waste generated by the business that is closing, underground storage tanks (if applicable), and any spills of hazardous materials or hazardous waste that may have occurred at the site. Based on the information provided in the form, Vermont's Hazardous Waste Program will determine if a more detailed closure plan is necessary to ensure clean closure. The requirements for "generator closure" are included under section 7-309(c) of the VHWMR.


Additional information about Vermont's Hazardous Waste Program is available on-line at:



Do You Operate a Diesel Generator Even if Just for Emergency Backup? 

You may be subject to recent federal EPA regulations covering these engines...


Newer engines manufactured after April 1, 2006 are subject to 40 CFR Part 60 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. Older engines installed before June 12, 2006 may be subject to 40 CFR Part 63 Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. Basically, all newer engines subject to Subpart IIII must be certified to meet appropriate Tier emission standards even if they are to be used just for emergency backup. These engines will have a plate affixed to them on the engine (not the generator end) providing the certification information. The requirements for older engines subject to Subpart ZZZZ are more complicated. These engines may be subject to various requirements ranging from an elapsed hour meter and routine maintenance to retrofitting with an oxidation catalyst. While emergency units at residential, commercial and institutional (schools, hospitals,...) facilities are exempt, the definition of emergency is very important and does not include most electric peak shaving programs (but it does include limited hours for ISO New England Emergency Demand Response under OP4, Action 6). Units over 300 bhp and 500 bhp are subject to progressively more stringent requirements. The rule requires you to notify EPA for several items. If your engine is required to be retrofitted with an oxidation catalyst, it needs to be installed by May 3, 2013 unless you obtain and extension from EPA. For more information please see the EPA websites:





Do You Operate a Boiler at a Location Other Than a Simple Residence?

If so, you may be subject to a recent federal EPA regulation covering most boilers. Natural gas and propane fired units are both exempt from the regulation. Most boilers are subject to biennial tune-ups and new boilers greater than 10 million BTU input are subject to particulate matter emission limits and testing.  Oil fired boilers less than 5 million BTU and any boiler with oxygen trim boiler controls can extend tune-ups to every five years.  The first tune-up is due March 21, 2014.  Facilities with one or more boilers greater than 10 million BTU input are also subject to a one-time energy assessment audit.  The energy assessment audit must be completed by March 21, 2014. The rule also requires you also notify EPA for several items. For more information please see the EPA website:



Important Timetable for Changes to the Act 148 Solid Waste Law

On July 1, 2014:

  • Certified solid waste facilities will collect mandated recyclables* without charging an extra fee.

On July 1, 2014:

  • Generators of more than 104 tons per year of food residuals, who are located within 20 miles of a certified organics management facility, will manage food residuals separately from other trash.

On July 1, 2015:

  • Generators of more than 52 tons per year of food residuals, who are located within 20 miles of a certified organics management facility, will manage food residuals separately from other trash.
  • Certified solid waste facilities must collect leaf and yard waste (may charge a fee)
  • Public buildings/public lands that provide a trash container must provide a container for recycling also.
  • All solid waste facilities must introduce variable weight pricing based on volume of weight for trash

On July 1, 2016:

  • Generators of more than 26 tons per year of food residuals, who are located within 20 miles of a certified organics management facility, will manage food residuals separately from other trash.
  • Ban on the knowing disposal of leaf and yard waste, licensed haulers must offer collection of leaf and yard waste.

On July 1, 2017:

  • All certified solid waste facilities will collect food residuals (may charge a fee)
  • Generators of more than 18 tons per year of food residuals, who are located within 20 miles of a certified organics management facility, will manage food residuals separately from other trash.
  • Licensed haulers must offer food residual collection.

On July 1, 2020:

  • Generators of any amount per year of food residuals, who are located within 20 miles of a certified organics management facility, will manage food residuals separately from other trash.
  • Ban on knowing disposal of food residuals


* "Mandated recyclable" means the following source separated materials: aluminum and steel cans; aluminum foil and aluminum pie plates; glass bottles and jars from foods and beverages; polyethylene terephthalate (PET) plastic bottles or jugs; high density polyethylene (HDPE) plastic bottles and jugs; corrugated cardboard; white and colored paper; newspaper; magazines; catalogues; paper mail and envelopes; boxboard; and paper bags.



New Air Requirements for Crematory Units

The US EPA recently amended on February 7, 2013 regulations for Commercial and Industrial Solid Waste Incineration Units (see 40 CFR Part 60 Subpart CCCC) installed after November 30, 1999.  EPA also made revisions to the regulations for Hospital/Medical/Infectious Waste Incinerators (see 40 CFR Part 60 Subpart Ec) in 2011.   Crematory units that burn strictly human or animal remains for cremation purposes are exempt from these regulations.  If anything else is burned in the unit or remains are burned for disposal the unit may be subject to one or both of these regulations.  The Subpart CCCC rule does include a partial exemptions if the following are met:

(1) pathological waste must comprise 90% or more by weight of the material burned each calendar quarter,

(2) you must notify the EPA Administrator (attn: Director, Office of Ecosystem Protection, U.S. Environmental Protection Agency, 5 Post Office Square-Suite 100, Boston, MA 02109-3912) that your unit meets this criteria and provide a courtesy copy to the State Air Pollution Control Division along with the date the unit was installed, and

(3) you must  keep records on a calendar quarter basis of the weight of pathological waste burned and the weight of all other fuels and wastes burned in the unit.  You must maintain these records and are not required to submit them unless requested. 


Units installed prior to November 30, 1999 are subject to the same restrictions and requirements however the notification need only go to the State Air Pollution Control Division (attn: Director, Air Pollution Control Division, Davis Building 2nd Floor, One National Life Drive, Montpelier, VT 05620-3802).


For more information please see the following EPA websites:


Subpart CCCC:  www.epa.gov/ttn/atw/129/ciwi/ciwipg.html

Subpart Ec:  www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html  

 Contact Us
Questions? Need assistance? Feel free to contact the Environmental Assistance Office at anr.wmeaoinfo@state.vt.us.