VT Environmental Compliance News
Newsletter from the Vermont Department of Environmental Conservation's
Environmental Assistance Office
August 2013 
Do You Have Environmental Compliance Questions?
Pollution Prevention Paul Says...
Pollution Prevention Case Study: FiberMark
How Can you Save Money and Help the Environment?
Do You Have Hazardous Waste? Collection Events Coming Up!!
Hazardous Waste Compliance Alert! Do You Treat Your Hazardous Waste Onsite?
Hazardous Waste Compliance Alert! Do You Remember to Send Copies of Manifests to the State?
EPA's New "Solvent-Contaminated Wipes" Rule
New State Law Sets Deadline for Single-Wall Underground Tanks
New Recycling Law!
On the Horizon: Paintcare Program to be Implemented in a Year
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In this issue... 
This issue focuses mainly on hazardous waste, solid waste, and underground storage tank management issues of general interest, including new laws and regulations. Look for pollution prevention case studies in this and future editions of the newsletter. This newsletter features FiberMark in Brattleboro as a case study. If you have a pollution prevention project that has reduced waste or raw materials at the source and has saved your facility money, please send it along to us.
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:
Pollution Prevention Paul Says...

To all manufacturers: Are you aware that using more than 1,000 pounds/year of certain chemicals in your process(es) will require that you develop a Pollution Prevention Plan? The Plan is essentially a chemical use reduction plan in which you are asked to establish voluntary goals for any reduction opportunities that are identified as part of the planning process. The focus is on minimizing use through steps like material substitution, equipment changes and improved operation and maintenance. The Environmental Assistance Office can provide help with developing a Plan. The list of chemicals, arranged alphabetically or by CAS#, can be found here

Please call Paul Van Hollebeke at 802-522-0219 or e-mail him at paul.vanhollebeke@state.vt.us, if you have questions.

Pollution Prevention Case Study: FiberMark

FiberMark in Brattleboro is a specialty paper and fiberboard manufacturer specializing in high quality cover materials for books, notebooks, boxes and other fiberboard packaging, often with a textured surface finish. If you have ever been in a paper manufacturing plant you know it can be a noisy place with all sorts of machinery from the pulping process to the huge papermaking machines that turn the pulp into paper using water and heat and turning it into large paper rolls, which may then be further processed, such as physically adding a texture or special finish on the paper. In one area of the plant, the paper is given a finished glaze by huge metal rollers moving over the paper which is fed to the so-called Glazers on a huge roll of paper. The plant operates 5 Glazers machines, 24 hours per day, 5 days per week; it is staffed with 1 operator for each 8-hour shift. There are overhead bearings for each Glazer unit which need ongoing lubrication. The old lubrication method required the operator, every 8 hour shift, to manually go to each Glazer with an oil cart and fill the overhead reservoirs. This method led to safety issues, oil leaking on finished product, high labor costs, and hazardous waste generation. Glazer operators at the plant helped devise a new method using automatic grease dispensers - eliminating waste oil generation, spills on the paper product, and reducing labor costs and maintenance. This project is a classic pollution prevention project - where FiberMark engaged the people on the floor to help identify and solve the problem, finding a way to eliminate the waste at the source, saving time and money - again showing that pollution prevention pays.


How Can You Save Money and Help the Environment?


Food scraps account for nearly ONE THIRD of most people's trash. You can "recycle" these scraps by composting.


Composting is the process by which microorganisms decompose organic material like food scraps and yard debris, producing a nutrient-rich soil amendment for your garden or house plants.


Composting organic material instead of bringing it to the landfill with your trash is an easy way to help the environment and save money.

  • Composting reduces greenhouse gas emissions (some people estimate that composting a 5 gallon bucket equals 1 gallon of gasoline saved).
  • Composting reduces costs and energy associated with managing waste.
  • Compost is a better use of organic matter and nutrients than sending food scraps to the landfill.

Read more here...

Hazardous Waste Collection Events Coming Up



With Fall right around the corner, the solid waste distrists are holding their annual household waste (HHW) collection events. If you are a Conditionally Exempt Generator (CEG), you can take advantage of these events.


To find out when your solid waste district is holding a HHW collection event click here.

Haz Waste Compliance Alert: Do You Treat Your Hazardous Waste Onsite?

Notification of on-site hazardous waste treatment in containers and tanks by generators (VT Hazardous Waste Management Regulations (VHWMR) Section 7-502(o)): Under this provision, hazardous waste generators may treat hazardous waste on-site (in containers or tanks) without obtaining a hazardous waste facility permit provided 1) basic waste management standards are met (See VHWMR section 7-502(o)), and 2) the generator submits a one-time notification to the Vermont Hazardous Waste Program that includes information about the treatment activity. Through (unannounced) inspections, the Hazardous Waste Program frequently finds that generators meet the waste management standards but haven't submitted the notification. Common forms of "generator treatment" include solvent distillation, aerosol can puncturing, and compaction/volume reduction.

"Treatment" is defined as "...any method, technique, or process, including neutralization, designed to change the physical, chemical or biological character or composition of any hazardous or solid waste, so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste safer for transport, amenable for recovery, amenable for storage, or reduced in volume, or for hazardous wastes, so as to render such waste non-hazardous."


Please contact Steve Simoes at 802-522-0386, or by e-mail at steve.simoes@state.vt.us, if you have questions.

Haz Waste Compliance Alert: Do You Remember to Send Copies of Manifests to the State?

Please make sure that a completed copy of each Uniform Hazardous Waste Manifest is sent to the Secretary (VHWMR Section 7-702(b)(10)): Under this provision, Vermont-based hazardous waste generators are required to assure that Vermont's Hazardous Waste Program receives a copy of each completed manifest shipping document (i.e., a copy that has been completed by the generator/shipper, transporter and the facility designated on the manifest to receive the hazardous waste shipment).


The easiest way to check that the end facility is sending the required manifest copy to the Hazardous Waste Program is to access the "Waste Management Interactive Database" (WMID) here. Once at this location, enter your facility's EPA ID number and (once your facility-specific information appears) scroll to the bottom of the page, click "View Manifest Report," and enter the date range that you'd like to view. Compare this list of completed manifests (received by the Hazardous Waste Program) to the completed manifest copies in your records. If you have completed manifests that are not identified in the WMID, send copies to the Hazardous Waste Program. We also suggest that you contact the end facility (and your transporter or consultant) to remind them that sending the completed copy of each manifest to the Hazardous Waste Program is required for your compliance with the VHWMR.


Please contact Linda Joyal (Hazardous Waste Manifest Coordinator) at 802-522-0261, or by e-mail at linda.joyal@state.vt.us, if you have questions.

EPA's New "Solvent-Contaminated Wipes" Rule

EPA's "Conditional Exclusions from Solid Waste and Hazardous Waste for Solvent-Contaminated Wipes" final rule was published in the Federal Register on July 31, 2013. While the deparment supports the flexibility offered by this new federal rule, it will not become effective in Vermont until Vermont incorporates it into the Vermont Hazardous Waste Management Regulations (VHWMR). Since it's unlikely that Vermont's Hazardous Waste Program will be able to revise the VHWMR for a year or two (revised VHWMR just became effective on March 15, 2013), the Program plans to evaluate and potentially revise its current "Shop Rags Contaminated with Used Oil or Hazardous Waste" fact sheet policy to be more consistent with the new federal rule.


EPA's "Conditional Exclusions from Solid Waste and Hazardous Waste for Solvent-Contaminated Wipes" rule may be viewed here



Vermont's current "Shop Rags Contaminated with Used Oil or Hazardous Waste" fact sheet may be viewed at here

New State Law Sets Deadline for Single-Wall Underground Tanks


On May 30, 2013 Governor Shumlin signed House Bill 226 into law. This new law sets firm deadlines for the closure of single wall and combination systems, and after a phase-in period, it raises the PCF assessment fee and deductible for single-wall and combination category one underground tank systems. Note that this law applies only to category one, or permitted underground tank systems. This law does not apply to underground tanks that are used exclusively to heat a building.


The new law defines single wall tank systems as a single wall tank connected to single wall pressurized piping. A combination tank system is a single wall tank with double-wall piping, or single-wall intrinsically safe suction piping.   A double wall tank system is a double wall tank with double-wall piping, or single-wall intrinsically safe suction piping.


Under the new law, single wall tank systems must be permanently closed by January 1, 2016. Combination tank systems must be permanently closed by January 1, 2018, except that combination tank systems in which the tank has been lined shall be closed by January 1, 2018 or by ten years from the date by which the tank was lined, whichever is later. The new law also prohibits lining of single-wall or combination tank systems after January 1, 2014.


Yet another major change this new law has created is a much more complicated formula for Petroleum Cleanup fund assessments. Because the fee schedule is more complicated than before, the UST Program will no longer expect tank permittees to figure out their assessment fee. Instead, the program will send out invoices that will be calculated based on the information on file.  


For more information please contact Ted Unkles at 802-522-0488 or email him at ted.unkles@state.vt.us.

  NEW Recycling Law to Take Effect by July 2014

Universal Recycling (Act 148), passed by the Vermont legislature last year, is a law committed to increasing the convenience and consistency of services for the collection of recyclables, food scraps and yard debris in the state. The Universal Recycling law will move Vermont in the direction of giving businesses and residents more choices to manage their discarded materials in a sustainable manner. With a phased in timetable for implementation that begins next year, big changes will soon be arriving in how we handle recyclables and organic residuals (food scraps and yard debris).


By July 2014, large generators of food residuals (2 tons per week or more) that are within 20 miles of an organics management facility will need to separate them from their normal trash. The timetable phases in smaller generators until July 2020, when all Vermonters will need to be separating out food and yard residuals for proper management.


This is exciting news for many reasons. The need to properly handle food and yard wastes will provide opportunities for new business start-ups focused on providing organics hauling, composting and sales of materials. This new infrastructure will provide "green jobs" for Vermonters which yield numerous benefits to local communities, and landfill capacity will be reserved for non-recyclable materials. The proper management of food scraps, and yard debris will result in the production of significant quantities of compost; materials that typically have been lost to landfills. This will allow the opportunity to reclaim nutrients and utilize them in the landscape for agricultural purposes, boosting crop yields and improving soil structure.


If your business handles food, or leaf and yard debris, this law will apply to you and how you manage your waste. Please call your Solid Waste Management District for more information on Act 148 found by going here. Or, refer to the information available on the VT Agency of Natural Resources - Solid Waste Program webpage.


For additional information you may also contact Josh Kelly with the Agency of Natural Resources by calling 802-522-5897 or emailing him at

On the Horizon: Paintcare Program for Paint Recycling


On average, 2.3 gallons of paint is sold per person per year in the United States, of which, 10% is unused leftovers. Less than half of that is collected for proper disposal or recycling. Part of the reason for this is that up until now convenient, year round proper paint disposal has not been available. Improper paint disposal has negative impacts on our environment and is a waste of resources. Through Vermont's new paint stewardship legislation, paint recycling and disposal will be handled by a paint stewardship organization funded by paint manufacturers. The cost of transportation and recycling/disposal will be paid for by a fee at the point of purchase. All manufacturers of architectural paint who wish to sell paint in Vermont will have to participate in an approved paint stewardship program plan. Architectural paint is defined as interior and exterior architectural coatings. This includes interior and exterior water and oil based coatings, primers, sealers and wood coatings that are sold in containers of five gallons or less. This program will begin in July 2014; however, manufacturers must submit a Paint Stewardship Program Plan to the Agency of Natural Resources by December 1, 2013.


For a more details and a complete timeline click here.


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