Vol. 15 No. 2 Fall 2005

THE NORTHEAST WASTE MANAGEMENT OFFICIALS' ASSOCIATION (NEWMOA) NEWMOA is a non-profit, non-partisan interstate governmental association. The membership is composed of state environmental agency directors of the pollution prevention, hazardous and solid waste, and waste site cleanup programs in Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont. NEWMOA’s mission is to develop and sustain an effective partnership of states to explore, develop, promote, and implement environmentally sound solutions for the reduction and management of materials and waste, and for the remediation of contaminated sites, in order to achieve a clean and healthy environment. The group fulfills this mission by providing a variety of support services that facilitate communication and cooperation among member states and between states and EPA. NEWMOA's P2 program was established in 1989 to enhance the capabilities of the state and local environmental officials in the northeast to implement effective source reduction programs. The program is called the Northeast States Pollution Prevention Roundtable (NE P2 Roundtable). This program involves the following components: (1) NE P2 Roundtable meetings and workgroups; (2) regional P2 information resource center and databases of information; (3) source reduction research and publications; (4) training sessions; and (5) regional policy coordination and development.

Over the past five years, substantial progress has been made to address the many challenges associated with measuring results of environmental assistance and pollution efforts. These challenges are numerous and include:

• inadequate resources for programs to measure the results of their activities
• inherent difficulty measuring the prevention of an adverse event, outcome, or environmental impact
• reliance on voluntary reporting by small and medium-size entities that lack the capacity and resources to track results
• lack of baseline compliance rate data
• lack of an agreed upon national approach to measurement

• Demonstrate that publicly-supported programs deliver value for their clients, the public, and taxpayers;
• Assist policy makers and others in assessing and understanding which assistance and P2 efforts are effective as they set priorities, program goals, and objectives;
• Help government agencies and others evaluate progress and get perspective on what's working and what's not working;
• Create an essential feedback and learning mechanism to support management decisions and effectively apply future effort(s) and investments in environmental improvement;
• Help market the effectiveness of programs and opportunities; and
• Demonstrate the tangible environmental and economic benefits that are being achieved around the country.

Some of the Northeast states' activities, as well as regional and national initiatives, are described below along with a list of key web resources that provide further information on other projects underway around the country. This section of the newsletter also includes an interesting editorial sidebar that one contributor submitted. NE Assistance and P2 News welcomes contributions from other readers on the questions raised in this editorial for future issues.

Tracking the quantity of hazardous substances used over time can be a useful measure of pollution prevention progress, providing insights that cannot be seen through tracking wastes or releases alone. Regardless of the function of a chemical in manufacturing operations-whether it is consumed in a process, repackaged into a product, or used as a cleaning solvent that becomes a waste-tracking the quantity of substance used can help document pollution prevention achievements.

Facilities do not directly report chemical use on NJ DEP's Release and Pollution Prevention Report (RPPR). This report, however, contains facility level material accounting data, which can be used to calculate Chemical Use by adding three key data elements reported on the RPPR. These data elements are: Nonproduct Output (NPO, which is essentially the same as production-related waste), Shipped as (or in) Product, and Consumed. The NJ DEP has calculated Use quantities for each chemical record submitted by covered facilities.

Traditionally, environmental regulatory programs, including New Jersey DEP, have primarily focused on reducing pollution by controlling components of NPO, such as On-Site Releases or Wastes Managed On -Site. More recently other approaches, such as pollution prevention, have contributed to reducing pollution. New Jersey has done a remarkably good job in reducing NPO. A 1996 report by Mike Aucott, NJ DEP concluded that New Jersey likely realized a 50 percent reduction in NPO from 1987 to 1994. The report, "Industrial Pollution Prevention in New Jersey: A Trends Analysis of Materials Accounting Data From 1994 to 2001," shows an overall NPO reduction of 26 percent, and a 33 percent reduction when adjusted for production from 1994 through 2001. Many of the recent NPO reductions can be attributed to facilities improving efficiency and implementing pollution prevention measures.

Summary of Statewide Use Trends in New Jersey

New Jersey has clearly made progress in NPO reductions. However, to put these reductions into perspective with total statewide throughput of hazardous substances, NPO contributed to only 1 percent of total statewide Use in 2001 compared to 83 percent for Shipped as (or in) Product. Overall, facilities made less progress reducing the Use of hazardous substances compared to NPO. Facilities actually increased the Use of hazardous substances by 8 percent, when using unadjusted quantities. When quantities are adjusted for production, Use decreased by 2 percent.

The lack of progress in reducing Use is caused by increases in the quantity of toxics Shipped as (or in) Product. The quantity of hazardous substances shipped in product is the only component that increased during the period using both annual pounds and production-adjusted quantities, which increased by 15 percent using unadjusted quantities and 4 percent when adjusted for production.

Refinery products (i.e., gasoline and fuel oil) account for about 90 percent of the toxics in products and also account for most of the increases. If the refineries are subtracted out of the universe, Shipped as (or in) Product overall statewide increased 2 percent. However, when adjusted for production, a 27 percent decrease was realized and Use reductions overall were 15 percent and 27 percent when adjusted for production.

An important conclusion from this data is that New Jersey DEP is doing a good job in controlling and reducing NPO. Future challenges lie in reducing hazardous substances Shipped as (or in) Product. To be successful, this will require an educated consumer who is aware of what is in the products they are purchasing, innovative thinking and problem solving on the part of industry to substitute or use less toxic substances in their products, and/or a heavy reliance on regulatory agencies to ensure that less toxic chemicals end up in products.

For more information contact: Kenneth Ratzman or William Lowry, NJ DEP (609) 777-0518

Each year, the Massachusetts Department of Environmental Protection (DEP) issues an annual report on the use of toxic chemicals in Massachusetts. The 2003 report shows continued progress by Massachusetts facilities in reducing toxic chemical use and toxic byproducts.

Since the Toxics Use Reduction Act (TURA) reporting requirements have changed over time, TURA progress is best measured by using a consistent set of chemicals and reporting industries subject to reporting over a given timeframe (referred to as a "Core Group").

In 2003, the 2000 Core Group (industries and chemicals subject to reporting in 2000 and 2003) used 918 million pounds, or 93 percent of the total toxic chemicals reported (985 million pounds excluding trade secret data). Adjusting the data to account for an 11 percent decrease in production from 2000 to 2003, over that three-year period toxic chemical use among 2000 Core Group facilities remained level. However, the 2000 Core Group facilities reduced:

• toxic chemical by-products by 12 percent,
• toxics shipped in product by 11 percent,
• on-site releases of toxics to the environment by 26 percent, and
• transfers of toxics off-site for further waste management by 21 percent.

In 2003, the 1990 Core Group (industries and chemicals subject to reporting in 1990 and 2003) used 573 million pounds, or 58 percent of the total toxic chemicals reported (985 million pounds excluding trade secret data). Adjusting the data to account for a 21 percent increase in production from 1990 to 2003, over that 13-year period the 1990 Core Group facilities reduced:

• toxic chemical use by 38 percent,
• toxic chemical by-products by 68 percent,
• toxics shipped in product by 61 percent,
• on-site releases of toxics to the environment by 92 percent, and
• transfers of toxics off-site for further waste management by 58 percent.

TURA defines three types of toxic chemical use: manufacturing (producing a toxic chemical), processing (incorporating a toxic chemical into a product), and "otherwise use" (all other uses). The reported data show that little chemical manufacturing occurred in Massachusetts (only 9 percent of total use), and a significant amount of this chemical manufacturing was incidental to some other industrial process (e.g., acid gases created from fuel combustion at power plants). Most of the reported chemicals used (about 73 percent) were processed or incorporated into a product (such as plastics, paints, and automotive parts). About 18 percent of chemical use was "otherwise use" attributed to uses ancillary to production processes, such as parts cleaning and waste treatment.

Colleges and universities are participating as a sector under the National Center for Environmental Innovation at EPA's Office of Policy, Economics and Innovations (OPEI) Sector Strategies Program. As part of this effort, the group is exploring creative ways to measure sector-wide environmental and economic progress using performance indicators, success stories, and other tools.

The EPA program has developed a collaborative approach with six national organizations (known as the Coordinating Committee) to develop sector-specific approaches to assist colleges and universities in measuring their environmental progress as well as advancing the use of environmental management systems and reducing regulatory performance barriers. The partners include the American Council on Education (ACE), the Howard Hughes Medical Institute (HHMI), the Association of Higher Education Facilities Officers, the Campus Consortium for Environmental Excellence (C2E2), the Campus Safety Health and Environmental Management Association (CSHEMA), and the National Association of College and University Business Officers (NACUBO).

The Performance Measurement Work Group (made up of 16 colleges and universities) of the colleges and university sector is interested in how the participating schools are doing and identifying appropriate metrics to show improvement. Early in the process, the Work Group explored the viability of specific environmental indicators - energy use, solid waste/recycling, hazardous waste, and water use - and the ease of collecting the data on these measures using existing tools.

The Work Group developed a database tool to gather four years of retrospective data on energy use, hazardous waste, solid waste/recycling, and water consumption as key environmental indicators. The goal of this effort has been to explore the challenges of data collection and the potential value of the information. If this database is successful, the group may continue adding data on an annual basis. Schools can use the database tool to identify and analyze trends in their data in an easy-to-use format.

The database also allows colleges and universities to track and benchmark their environmental indicators against aggregated data from other schools of similar size and type. School names are kept confidential. All colleges and universities are invited to input data and provide suggestions for improvement of this tool.

Environmental indicators (or metrics) can help track performance, manage compliance, shape the future, and inspire action. They can measure outputs or impacts, such as pounds of trash or gallons of water used. Other indicators measure proactive efforts, such as the number of training classes. Others may include waste generation or utility usage, which are items central to continuous improvement efforts. Condition indicators measure water or soil quality, which are factors important to the community.

Assistance and P2 Measurement Web Resources

The following is a list of useful web resources focused on environmental assistance and pollution prevention measurement.

CONNECTICUT

Connecticut Department of Environmental Protection (CT DEP)

Boat shrink-wrap, made of low-density polyethylene, is a recyclable material that can be remanufactured into composite lumber, agricultural sheeting, and even the spacers on highway guardrails. About half of the boats in Connecticut are shrink-wrapped over the winter, and more than 50 percent of the shrink-wrap plastic is sent to landfills or trash-to-energy plants. Many boaters and marinas can purchase "mail back bags" large enough to hold the wrap of a 26-foot vessel and send the plastic directly to a recycler, but facilities claim that using such a recycling option is not always practical.

In order to increase the boat wrap recycling options for marinas, the CT DEP established a pilot recycling program for boat wrap involving the Trex Company, a manufacturer of composite lumber. This spring, participating marina operators collected boat wrap at their facilities for their waste hauler to transport to one of two facilities in Connecticut where it was baled and stored before being hauled to Trex in Virginia. In all, eight marinas participated in this pilot project, and a total of 34,020 pounds of shrink wrap was collected. The company will test the use of the boat shrink-wrap in their manufacturing process to determine whether they can continue to use it to make their recycled boards in the future.

For more information contact: CT DEP Recycling Office (860) 424-3237

Connecticut hospitals learned more about environmentally preferable and bio-based products at a workshop held on March 30 at the Hospital of St. Raphael in New Haven. The workshop was co-sponsored by the CT Hospital Environmental Roundtable (CHER), New Uses Council, Bio-based Manufacturers Association, Mt. Wachusett Community College, US Department of Energy, and the Northeast Regional Biomass Program. The purpose of the workshop was to make hospitals aware of health and environmental effects of toxic cleaning products, teach about "green" alternatives for cleaning and food service, and assist hospitals in making the switch to these products at their hospitals.

Experts from the Toxics Use Reduction Institute (TURI) and INFORM presented technical data and discussed the benefits of these products. Environmental Services Directors from the William Backus Hospital in Norwich, CT and Jacobi Medical Center in the Bronx, NY talked about their practical experiences implementing green products at their facilities. Vendors were also available to answer questions and to distribute samples of their products. Workshop attendees even had refreshments on plates made from sugarcane, grass, and reed plasma.

As a result of the workshop, hospital representatives learned that using environmentally preferable and bio-based products can improve employee health and patient and visitor comfort, and can significantly cut operating costs.

For more information contact: CT DEP Office of Pollution Prevention (860) 424-3297

The fall meeting of the CT Hospital Environmental Roundtable featured pharmaceutical management in a health care setting, focusing on RCRA listed wastes and best management practices. The September 8th workshop included an activity and discussion where participants were given a list of drugs to determine what the best/legal disposal options would be. Target audience was Health & Safety, Environmental Services, Pharmacists, Infection Control, and Nursing Administrators.

Ever wondered if the cleaning products under your sink are hazardous to your health and the environment? DEP has partnered with regional and local household hazardous waste coordinators on a project to inform the public about the potential dangers of these products and to help people choose environmentally preferable alternatives. Ten suitcase-size exhibits were produced which showcase empty containers listing toxic or hazardous ingredients against the backdrop of a sink and workbench. Alternative products, both store-bought and homemade, are also part of the display.

In May 2005, CT DEP's Bureau of Waste Management began the task of updating the State's Solid Waste Management Plan. DEP has contracted with R.W. Beck, one of the nation's leading consulting engineering firms to assist in the effort.

In developing the plan, the Agency will look for opportunities to reduce the amount of waste generated in CT and increase the amount of recycling and reuse in an environmentally protective manner.

There are several major tasks that have been completed or are well underway:

• A statewide Stakeholder Forum was held on June 29th and approximately 200 people attended, representing non-profits, businesses, institutions, and the public. All shared their visions and opinions about solid waste issues, such as reducing municipal solid waste, disposal of electronics, and recycling.
• An External Stakeholder Working Group has been established and is currently meeting.
• The first phase of the project - data gathering, verification and validation - was completed in September.
• DEP has created a website to keep the public informed about the process - www.dep.state.ct.us/wst/solidw/swplan/index.htm.

MAINE

Maine Department of Environmental Protection (ME DEP)

The current activities of the Pollution Prevention Program in Maine DEP's Office of Innovation and Assistance include:

• Working with facilities in Maine to track greenhouse gas emissions for the Governor's Carbon Challenge, a voluntary program that is encouraging goal setting for reduction of emissions that contribute to climate change;
• Planning a hotel/motel/inn state environmental certification;
• Working with small businesses that report to the Toxics and Hazardous Waste Reduction Program and assisting them with tracking their toxics and hazardous waste reduction, pollution prevention planning, and future reductions;
• Partnering technical assistance with the Public Utilities Commission's small business energy assistance program and Department of Labor Safetyworks Program, and other small business providers including Small Business Administration (SBA), Small Business Development Center (SBDC), and Coastal Enterprises Inc.;
• Providing outreach and assistance to SBDCs and small business counselors;
• Establishing further partnerships with other business assistance providers;
• Establishing partnerships within the energy efficiency sector and promoting their services to Maine businesses;
• Assisting five companies with the implementation of an environmental management system;
• Conducting on-site compliance assistance utilizing Maine's Small Business Compliance Incentive Policy (SBCIP);
• Continuing to provide assistance to the Green Campus Consortium in their efforts to move towards sustainability;
• Working in conjunction with the Climate Change Steering Committee on the New England Governors' and Eastern Canadian Premiers' initiative to reduce green house gas levels 10 percent under 1990 levels by 2012;
• Continuing to provide assistance to a number of industry sectors;
• Revitalizing the Compliance Advisory Panel (CAP) as an effective tool to weigh in on OIA activities; and
• Hosting ISO 14001 EMS Internal auditor training.

For more information contact: Peter Cooke, ME DEP (207) 287-7100

MASSACHUSETTS

Massachusetts Department of Environmental Protection (MA DEP)

Beyond ERP

In these times of limited resources, the Massachusetts "Beyond ERP" effort is designed to assess regulated groups before using resources to implement compliance and enforcement measures. The assessment also measures whether DEP's compliance and enforcement efforts (i.e., permits, inspections, and ERP certifications) are yielding environmental benefits and pollution prevention. The assessment consists of a personal visit with a standard questionnaire and a "walk through" to determine environmental awareness and compliance. MA DEP launched its "Beyond ERP" (Environmental Results Program) initiative with an assessment of several targeted groups, including industrial wastewater dischargers in un-sewered areas.

MA DEP chose industrial wastewater dischargers as a target group because of its size, potential risk to the environment, and the Department's need for recent environmental data. There are several thousand facilities that have potential discharges in un-sewered areas. An evaluation of Standard Industrial Classification (SIC) codes revealed six facility types: vehicle-related, manufacturing, contractors, medical/laboratories, general service, and agriculture. These facilities may be discharging industrial wastewater through floor drains and stormwater drains into septic systems or surface water without a permit, or have a variety of other water-related issues associated with their operations.

In the summer of 2005, staff from the MA DEP Boston Office and four DEP regions visited a randomly selected and statistically significant representative sample of over 200 facilities in non-sewered areas. Using a standard questionnaire the "inspectors" interviewed the facility manager and performed a "walk through," focusing on where industrial and sanitary wastewater was being discharged. An informational letter was left with the facility owner containing compliance assistance information including a referral to the MA Office of Technical Assistance.

The emphasis of the project is assessment first, with a few follow-up compliance inspections and enforcement for egregious violations. A significant outcome will be to determine the nature and extent of industrial wastewater discharges in environmentally sensitive areas of Massachusetts. The results of the assessment will determine program needs for regulatory changes, compliance assistance, and enforcement for industrial wastewater discharges in the future.

For more information contact: Helen Waldorf, MA DEP (617) 292-5819 or Suzie Peck, MA DEP (617) 292-5870

MA DEP and HealthAlliance Hospitals, Inc. of Leominster have entered into an Administrative Consent Order to resolve environmental violations. The hospital was assessed a $11,022 penalty for violations of MA DEP's Air Quality Control, Environmental Results Program, and Hazardous Waste Management Regulations.

In addition to complying with all applicable regulations and paying all past due annual compliance fees, HealthAlliance has agreed to pay a $4,100 civil administrative penalty; switch to cleaner fuel for their boilers, reducing SOx emissions by 80 percent; and complete a Supplemental Environmental Project (SEP). The SEP consists of installing uninterrupted electric power to six ambulance bays, allowing drivers to turn off their engines while the ambulance is idle. This project will cost at least $6,922. Exhaust fumes from idling engines contribute to respiratory diseases, such as asthma and lung cancer, and have been linked to heart disease. This SEP will have an immediate positive health impact to ambulance operators and hospital staff, and especially to emergency room patients.

For more information contact: Maria L'Annunziata, MA DEP (508) 367-2748

MA DEP found that 25 percent of the MA companies subject to the Toxics Use Reduction Act (TURA) completed and submitted their 2004 reporting forms electronically, using the Agency's eDEP online interface. A total of 167 TURA filers took advantage of Web-based reporting, a 55 percent increase from the previous year's electronic submissions.

The 2004 reporting year was the third year TURA companies could file online. In cooperation with the EPA and the MA Office of Technical Assistance (OTA), DEP conducted five electronic filing training sessions across the state attended by some 250 TURA filers and planners.

The Office of Technical Assistance (OTA) is offering an opportunity for local schools to improve chemical management practices. As part of this effort, OTA works with companies that are interested in becoming mentors to local schools.

For more information contact: Susan Lanza, MA OTA (617) 626-1068.

MA OTA has completed the final report for the 2004 conference, "Promoting Clean Jobs and Neighborhood Change: Building Economic and Environmental Justice." The white paper from this conference is available at http://www.mass.gov/envir/ota. The conference broke new ground as the first conference to establish a connection between cleaner production practices and community revitalization.

Biotechnology

Biotechnology is an important industry in Massachusetts. The MA Executive Office of Environmental Affairs (EOEA), in partnership with the Executive Office of Economic Development and the Massachusetts Biotech Council, has launched an initiative to assist this industry. As part of the initiative, MA OTA will offer workshops to help local regulators understand the industry's environmental impacts. The workshops will be developed around two matrices based on existing industrial experience on permitting in Massachusetts.

For more information contact: Paul Richard, MA OTA (617) 626-1042

Water Conservation

Water is becoming a scarcer resource and a bigger cost for businesses. As a result of a study conducted by the MA EOEA Water Policy Task Force, MA OTA will host a workshop in Spring 2006 to help businesses in the Interstate 495 area conserve water.

For more information contact: Susan Lanza, MA OTA (617) 626-1068

Chlorinated Solvents Workshop

The Massachusetts Toxics Use Reduction Act (TURA) Program identified chlorinated solvents as High Priority Substances and emphasized reducing the use of these chemicals. As part of the initiative, OTA and the Toxics Use Reduction Institute (TURI) hosted a workshop in June to discuss regulations on using chlorinated solvents and safer cleaning alternatives and to present information on companies that eliminated the use of chlorinated solvents.

Medical Device Sector

In June a meeting was convened on "The Business Case for Design for the Environment (DfE) for Medical Device Manufacturers," co-sponsored by MassMEDIC, Associated Industries of Massachusetts, Greater Boston Chamber of Commerce, the Executive Office of Environmental Affairs, and the Office of Technical Assistance. This half-day workshop was designed to enhance the competitiveness of medical device manufacturers by assisting them in anticipating and proactively responding to marketplace pressures to enhance the environmental attributes of products.

The event introduced business models that have successfully integrated DfE principles and identified the benefit of DfE in product design. The agenda included a 45-minute executive session, led by Dr. Patrick Eagan of the University of Wisconsin-Madison, followed by a technical session that included multiple speakers and case studies.

For more information contact: John Raschko, MA OTA (617) 626-1093

Plastics/Rubber Sector

As a result of its work with the plastics sector, OTA, in partnership with Pure Strategies, Inc., identified opportunities to assist the industry on several fronts. The following actions will be taken: development of a guidance document for companies in this sector on more successful negotiation strategies with certification organizations; development of a fact sheet on the benefits of greener wire and cable (W & C) products highlighting Massachusetts companies that manufacture them; a presentation on the industry to the Executive Office of Economic Development, and efforts to promote greener wire and cable products through the state's procurement process and possibly the Green Roundtable (an organization of architects, builders, engineers).

For more information contact: Scott Fortier, MA OTA (617) 626-1090

Marine Technology Sector

The Office of Technical Assistance with the help of a contractor, Marine and Oceanographic Technology Network, will research and collect data on the Marine Technology Industry. The collected data and information will pertain to sub-sectors within the industry and issues, particularly regulatory issues that affect the industry. OTA is tentatively planning a focus group meeting for the fall.

For more information contact: Jim Cain, MA OTA (617) 626-1081

Barriers to TCE Reduction

To support efforts to reduce or eliminate the use of chlorinated solvents such as Trichloroethylene (TCE), MA OTA has hired SAK Environmental to conduct a survey of TCE usage in industry. The purpose of the survey is to identify the barriers to eliminating the use of chlorinated solvents.

For more information contact: MA OTA (617) 626-1070

Toxics Use Reduction Institute

The Toxics Use Reduction Institute at the University of Massachusetts Lowell received $250,000 from the Commonwealth of Massachusetts to assess alternatives to five toxic or hazardous chemicals. TURI will deliver the "Five Chemicals Study" to the legislature in June 2006.

The Massachusetts legislature commissioned the Five Chemicals Study to carefully consider whether suitable alternatives are available for the following chemicals: lead, formaldehyde, perchloroethylene, hexavalent chromium, and di-(2 ethylhexyl) phthalate (DEHP).

The Five Chemicals Study will be limited to industries and applications where the use of the chemical is most significant in Massachusetts and where alternatives exist. Companies, government, non-government organizations, and industry associations will help TURI identify significant uses, both in manufacturing and in products, and prioritize alternatives to be assessed. TURI will create an alternatives assessment methodology that will be used to consistently evaluate the prioritized alternatives for each chemical.

The report for the Massachusetts legislature will also be available to industry and the public in June 2006.

Complying with the European Union WEEE and RoHS Directives is essential for any company that supplies to original equipment manufacturers selling in Europe. TURI will host a training session on December 7th in Norwood, Massachusetts to help companies achieve compliance with RoHS and to learn strategies to deal with the various compliance schemes associated with WEEE. This workshop will also provide an update on similar regulatory efforts in other countries as well as in various US States.

Massachusetts Representatives and Senators joined the Toxics Use Reduction Institute on June 16th to honor leaders in Massachusetts communities and companies for reducing toxic chemical use across the state.

Community leaders included the Massachusetts Coalition for Occupational Safety and Health (MassCOSH), Dorchester, who introduced safer green cleaners into the Boston School System; New Ecology, Inc., Cambridge, and Lower Pioneer Valley Education Collaborative, East Longmeadow, who worked to make hair and nail salons safer; the Westford Water Department, who raised awareness in their region to reduce pesticide use on lawns; and the Manomet Center for Conservation Sciences, who compiled existing knowledge of pesticide impacts on humans and wildlife and brought Massachusetts researchers and advocates together for the first time.

Industry leaders included Toxics Use Reduction Planners Frank Marino, Raytheon Company, Waltham, and Lucille C. Servidio, Capaccio Environmental Engineering, Inc., Marlborough. The Environmental Management System Peer Mentor Matching Grant Recipient and honoree was Solutia, Inc., Springfield. Industry Supply Chain Leaders included AlphaGary, Leominster, for their work in the wire and cable industry and M/A-COM, Lowell, for their contributions to the lead-free electronics consortium.

NEW HAMPSHIRE

Mercury switches are small metal casings that contain approximately one gram of mercury located in vehicle trunks and hoods where they operate convenience lights. If switches are not removed prior to vehicle crushing, their mercury is emitted as an air pollutant during the final smelting process. At the urging of the NH Auto & Truck Recyclers Association, about 30 of New Hampshire's 200 salvage facilities are voluntarily collecting switches and turning them over to the NH Pollution Prevention Program which pays for their recycling.

Since collections started in 2003, the New Hampshire Pollution Prevention Program has collected and recycled a little over 3,500 switches. On April 22, NHPPP sponsored an Earth Day award ceremony to show the State's appreciation for the New Hampshire Auto and Truck Recyclers Association (NHATRA) for their promotion of the mercury switch recycling program.

Governor Lynch, DES Commissioner Nolin, NHPPP, NH DES Green Yards Program staff, members of the NHATRA, and ONYX Special Services (mercury recycler) attended the ceremony at Central Auto Sales in Concord, NH. At the event, the Governor personally removed a mercury switch from a vehicle and helped transfer the 3,500 switches to the recycler's transport container.

This past June, the NH DES adopted a regulation requiring all dental facilities to install an approved amalgam separator by October 1, 2005. Under this new rule, dental practitioners have to install an amalgam separator meeting ISO 11143 standards and manage the trapped amalgam as a hazardous waste, although amalgam can be managed in a similar fashion to a Universal Waste due to an exemption for recycled amalgam in the Hazardous Waste Rules.

In mid-June, the NHPPP sent a mass mailing to all 1,260 NH licensed dentists reminding them of their obligation under the new requirements. The mailing included a certification statement indicating an approved amalgam separator has been installed as well as a form the dentist may sign indicating he/she is exempt or qualifies for a de-minimis waste generation waiver. To date, about 10 percent of the dentists have returned signed certification forms or exemption statements.

On June 20, NHPPP staff and NH DES Green Yards Program Manager Pam Sprague hosted a NH Green Yards Inspector Training class for DES staff. Over 25 DES staff members from each media participated in the day long training. The training covered what auto recycling involves; key environmental concerns; the nature of NH's auto recycling industry; applicable local, state, and federal requirements; best management practices; and how to conduct a multi-media Green Yards certification inspection.

Based on requests from the June 20 training, additional training was provided to review inspection procedures and compliance assistance. This training consisted of viewing a set of photographs of actual salvage facilities as a "Virtual Junkyard" tour. Using a newly-created inspection form, participants "inspected" the facility in the slide show, filling out the form as they would during actual in-field inspections.

In cooperation with the New Hampshire Marine Trades Association, the NHPPP hosted a workshop titled "Stay Afloat - Don't Rock the Boat - Proper Procedures for Boat Washing and Winterization" for NH marinas. The workshop focused on current compliance issues revolving around boat washing and winterization, aboveground storage tanks, and community right- to-know requirements.

NEW JERSEY

New Jersey Department of Environmental Protection (NJ DEP)

Readoption of the P2 Planning Regulations

In New Jersey, all regulations are required to be readopted every five years. The Office of Pollution Prevention and Right to Know is currently readopting the Pollution Prevention (P2) Planning Program rules with the changes described below.

The new requirements would exempt facilities from having to conduct pollution prevention planning for hazardous substances if the sum of the amount of the hazardous substance generated as nonproduct output (NPO) and shipped in product is 500 pounds or lower, as indicated on Section B of the Release and Pollution Prevention Report (RPPR). NPO is a term used in New Jersey to represent all waste from a production process. This term is similar to the term production-related waste used for Toxic Release Inventory (TRI) reporting. The RPPR is the mechanism used in New Jersey to collect state-level TRI information (see page 2 Feature Article).

As a result of the proposed changes, the NJ DEP will still collect information on all TRI reporters but exempt from P2 planning those facilities that are most efficient and do not ship large quantities of hazardous substances in their products and/or generate significant amount of NPO.

The new rules will make electronic reporting of the P2 Plan Summary mandatory beginning with reporting year 2005, except if a facility is making a confidentiality or hardship claim.

In order to foster greater implementation of P2 techniques, NJ DEP is also going to require that:

• all processes or sources at covered facilities that use or generate persistent, bio-accumulative, toxic (PBT) substances be targeted for in-depth P2 planning;
• treatment systems that use hazardous substances or generate NPO not generated elsewhere at the facility be included in a facilities P2 Plan;
• hazardous waste data be included in the P2 Plan annually instead of every five years;
• materials accounting inputs and outputs be balanced within 5 percent.

NJ DEP hopes to publish their rule readoption in the New Jersey Register in September 2005.

For more information contact: Alan Bookman, NJ DEP (609) 777-0518

Pollution Reduction Opportunity Evaluation

The Facility-wide Permit Program within the Office of Pollution Prevention and Right to Know has outlined a new initiative called Pollution Reduction Opportunity Evaluation (PROE). The PROE will focus on integrating P2 concepts into single media programs through fact-sheets that will highlight successful P2 stories and provide suggestions on other P2 methods and opportunities. The steps of this program include: 1) identifying sectors, 2) data collection/analysis, 3) developing and writing the PROE reports, and 4) conducting outreach.

The PROE reports are designed to be sector specific; therefore, the first step of the program will be to target an industry sector where successful source reduction strategies have been implemented. This will involve researching different SIC/NAICS codes and/or MACT source categories. The next step of the program will be to collect and analyze the Department's data to determine how many facilities have reduced their emissions or non-product output (NPO) and conduct site visits to determine how and why the reductions took place.

Once successful case studies have been identified, the third step of the program will be to develop and write the PROE reports, which will include site-specific examples of successful pollution reduction case studies, pollution reduction opportunities, questions permit writers should ask to determine if P2 is feasible, and the benefits of implementing the P2 method. These benefits will include compliance with federal and state regulation, elimination or reduction of solvent storage and handling and compliance costs, and reduction of emissions. The last step of the program will be to conduct outreach to permitting and enforcement staff that will involve such actions as: contacting permit writers and encouraging them to incorporate the P2 suggestions into permits, creating a list of enforcement actions to determine whether or not a P2 method could be used to resolve the violation, and conducting site visits to facilities where several options were identified but not implemented.

The PROE is envisioned to be a tool to facilitate discussions between regulators and the regulated community to begin integrating P2 concepts in their decisions.

It should be noted that implementation of the PROE initiative is currently being reviewed by NJ DEP upper management.

For more information contact: Kenneth Ratzman or Jennifer Noblejas, NJ DEP (609) 777-0518

Auto Body Spray Coating

In 2004 the NJ DEP adopted rules governing volatile organic compound (VOC) emissions from vehicle refinishing. Part of the VOC rule requires the use of high volume low pressure (HVLP) spray guns for applying surface coatings on mobile equipment. The NJ DEP Small Business Assistance Program (SBAP) has been working closely with NJ DEP's Air Permitting and Enforcement Programs to develop a process for approving paint spray guns that are not HVLP.

The NJ DEP's rules for approving non-HVLP spray guns for use at automobile refinishing facilities require the owner or operator to submit information to the NJ DEP and the EPA that demonstrates non-HVLP spray gun emissions do not exceed HVLP spray gun emissions. Approvals by other States or a California Regional Air District may be accepted by the NJ DEP as evidence that the tested spray gun meets New Jersey's air emission criteria. Additionally, the automobile refinishing facility must then receive written approval from the NJ DEP and the EPA to use a compliant non-HVLP spray gun. Currently, New Jersey's air regulations specify that each approval is facility-specific.

For more information contact: Ky Asral, NJ DEP (609) 292-3600

Dental Amalgam

Several best management practices for the reduction of dental amalgam waste will be included in an upcoming draft of the revised NJ DEP New Jersey Pollutant Discharge Elimination System (NJPDES) rules. The draft rule will require dentists to install amalgam separators and to adhere to amalgam waste handling Best Management Practices (BMPs) similar to those established by the American Dental Association. The NJ Small Business Assistance Program (SBAP) will be taking the lead on conducting outreach to dentists on this upcoming rule requirement.

For more information contact: Ky Asral, NJ DEP (609) 292-3600

Dry Cleaners

Recently the NJ DEP Air Enforcement Program has increased penalty fees assessed to dry cleaners and is strictly enforcing permit limits. The SBAP has been working with New Jersey's dry cleaners to make sure that their air permits accurately depict the operational conditions at their facilities. This outreach activity has resulted in a number of facilities requesting permit modifications to increase perchloroethylene consumption rates. Air Permitting and Air Enforcement are scheduled to discuss how to deal with higher perchloroethylene consumption rates; meanwhile, the SBAP has been encouraging dry cleaners to reduce their perchloroethylene consumption by wet cleaning when appropriate, operating their machines for maximum solvent recovery, and considering alternative dry cleaning solvents.

For more information contact: Ky Asral, NJ DEP (609) 292-3600

NEW YORK

New York State Department of Environmental Conservation (NYS DEC)

New York Environmental Leaders

NYS DEC continues to work on the development of the Environmental Leaders Program to encourage Environmental Management Systems (EMSs) and beyond compliance achievement by the regulated community. A design team with representatives from the Department's Divisions and Regions has been convened. This group met on August 9, 2005 for the purpose of providing comments on the draft program design. The meeting was focused on reviewing the NY Environmental Leaders Enforcement Response policy. Numerous concerns were raised regarding this policy and, staff subsequently met on August 18th to discuss the comments. A revised enforcement response has been developed and is being distributed to the design team for further review and comment. After reviewing comments, the group will develop a draft Commissioner's Policy for consideration by executive staff.

Environmental Excellence Awards

NYS DEC is working on the 2nd Annual Environmental Excellence Awards (EEA) program. The EEA recognizes applicants for going beyond compliance and on their development of projects that exemplify innovation, sustainability, or partnerships. The Agency received applications from 25 entities in early July 2005. The Internal Review Committee (IRC) reviewed the applications and determined that all of the applications met EEA eligibility criteria. The applications were then screened by designated DEC programs, along with regional, legal, and environmental enforcement staff, to determine the applications' technical acceptability and the applicants' compliance record. This review included a determination as to whether or not an application demonstrated tangible environmental benefits beyond regulatory requirements, a check on the compliance history of the applicant or facility, and the status of any enforcement action taken or being considered against the applicant or facility.

Reviewers were also encouraged to share their perspective regarding the project, the application, or the applicant. The IRC analyzed all technical and compliance comments, and 22 applications were packaged in binders and sent to the External Review Committee (ERC) on August 19, 2005 for their consideration. The ERC will convene workgroup evaluation sessions during the first several weeks of September 2005. The awards ceremony will be held later in the year.

Green Buildings Tax Credit (GBTC) Program

NYS DEC's will receive an additional $25 million in tax credits in the governor's budget bill for the 2005 session. Credits will be given to qualified buildings that meet the requirements of the new legislation. A major change in the legislation is that an eligible building is now limited to a $2 million tax credit.

Since the original legislation was passed, changes have occurred in the state energy and building codes. In addition, the DEC is making changes regarding the eligibility of refrigerants for the refrigerant component credit. The applicable regulations are being updated to reflect these changes. In its rulemaking, the Agency will reference the 2002 NYS Energy Construction Conservation Code, which prescribes higher energy efficiency requirements; reference the 2003 NYS Uniform Fire Protection and Building Code in order to more accurately identify building classifications as they pertain to the GBTC program; clarify language regarding carbon monoxide alarms; clarify eligibility for the refrigerant tax credit component, informed by language from the US Green Business Council LEED Green Building Rating System; and include any other changes as the Department deems necessary. The Department's website will reflect this language before the end of August 2005.

Reducing Mercury in Schools

NYS DEC, along with NEWMOA staff, is coordinating development of a curriculum for workshops to be held in Albany, Rochester, Syracuse, Metropolitan New York City, and Long Island on mercury cleanout of schools. The first series of workshops will be held at the Syracuse and Rochester Board of Cooperative Educational Services (BOCES) facilities on October 18 and 19, respectively. The second series will be held in Long Island and New York Metro Area on November 8 and 9, respectively, and in Albany on November 15.

NYS DEC staff is also actively working on a program with the Orange Ulster County BOCES to conduct a mercury inventory of at least 30 schools in the County and to conduct workshops to inform school leaders of the risks of having mercury in their schools.

Lastly, NYS DEC staff is working on a demonstration project for the Rochester and Albany school districts to conduct mercury inventories, to remove and dispose of mercury that was identified, and to supply non-mercury alternatives for a select number of mercury devices that were identified, removed, and disposed of at the participating schools. The information obtained (types of mercury containing devices, quantity removed, cost of disposal, and cost of non-mercury replacement devices) during this project will be discussed at future workshops and will be distributed to schools throughout the state.

RHODE ISLAND

Rhode Island Department of Environmental Management (RI DEM)

After completing a stakeholder process that included governmental officials and industry representatives, the RI Department of Environmental Management implemented its Exterior Lead Paint Removal Certification Program in mid-April 2005. The design of this program is a partnership between the Rhode Island DEM and Department of Health (DOH), the EPA Region 1-New England, Rhode Island Housing Resources Commission, and the University of Rhode Island Center for Pollution Prevention & Environmental Health. In Rhode Island, exterior lead paint removal is regulated by RI DEM, and interior lead paint removal is regulated by RI DOH with separate regulations.

The new program takes an important step to address environmental concerns with the removal of exterior lead-based paint by contractors in Rhode Island. It is designed to improve compliance by painting contractors with environmental regulations that pertain to exterior lead paint removal in a simpler, more useful way, with participating contractors providing certification to their compliance with RI DEM Air Pollution Regulation # 24 (Removal of Lead-Based Paint from Exterior Surfaces) and with the federal Pre-Renovation Education Rule.

RI DEM began working on its Auto Salvage Yards Certification Program, meeting with project partners University of Rhode Island Center for Pollution Prevention & Environmental Health and the Narragansett Bay Commission. As with the other DEM certification programs, this one will employ a stakeholder process that includes governmental representatives as well as external stakeholders. It will be a multi-media program that addresses air and water pollution control, hazardous waste and other fluids, batteries, mercury switches, and tires. A checklist has been designed to perform baseline audits of facilities.

Rhode Island has 85 auto salvage yards licensed by the RI Department of Business Regulation (RI DBR). Licensing with RI DBR is required by law for these facilities to operate. It will be a three-year project from its beginning to the first certification round, and will be an ongoing RI DEM program, with certification being administered every three years.

Auto Body Repair Facilities Certification

RI DEM's Pollution Prevention Program Manager analyzed data from the first round of auto body repair facility certifications received in 2004. The results showed statistically significant improvement in hazardous waste management, air pollution control, pollution prevention measures, wastewater discharge, and worker health and safety. The range of improvement for statistically significant Environmentally Beneficial Performance Indicators (EBPI) was 23 percent to 47 percent, with an average improvement rate of 37 percent overall. Of the 171 shops that certified, 69 submitted a total of 234 Return-to-Compliance plans.

See the figure above for a summary of the compliance improvement rates for statistically significant EBPI's.

VERMONT

Vermont Department of Environmental Conservation (VT DEC)

VT DEC held a hospital roundtable meeting for Vermont hospitals in April that focused on pollution prevention and assistance resources with speakers from DEC, EPA, and Hospitals for a Healthy Environment (H2E). Another roundtable meeting is scheduled for this fall on the use of the H2E waste and mercury tracking software tools. Vermont hospitals and affiliated health care facilities are subject to mercury reduction planning requirements that passed as part of a comprehensive mercury products bill during this past legislative session. DEC will be developing the planning and assistance documents for hospitals.

VT DEC and the Vermont Small Business Development Center (VT SBDC) will be conducting their annual series of workshops for conditionally exempt generators this fall in Rutland, Springfield, Waterbury, Williston, and Newport. Topics covered include regulatory compliance, pollution prevention, and assistance resources.

Dental Best Management Practices

VT DEC is revamping dental best management practices and developing a self-certification process for dental clinics now required by statute. DEC is working with the Vermont State Dental Society and the National Wildlife Federation affiliate in Montpelier to develop the BMPs, which are expected to be completed this fall. BMPs will include requirements for amalgam separator installation, operation, and maintenance.

P2 for POTWs

VT DEC is working with two municipalities in a wastewater P2 outreach project to small businesses and homeowners connected to the municipal sewer. All homeowners on the municipal system have been mailed an educational brochure on wastewater treatment systems and what not to put down the drain. Businesses have been visited by DEC staff and some follow-up visits have been scheduled at businesses to provide further assistance. As the pilot project is completed, DEC will consider offering this program to other interested municipalities.

True Value Lamp Recycling Project

DEC implemented a fluorescent lamp recycling program at 32 True Value Hardware stores in Vermont in July. Homeowners, small businesses, and municipalities can recycle compact, linear, and other fluorescent lamps at no cost during this two-year program that is funded through a supplemental environmental project. Program users are surveyed on cost and convenience issues to assess future program direction. A media campaign program has been launched with other efforts to promote lamp recycling.

12th Annual Governor's Awards

DEC will be hosting its 12th Annual Governor's Awards for Environmental Excellence this fall at the Vermont State House. Notification of award winners will be going out in September.

Workshop on Bio-Based Fluids

DEC co-sponsored a workshop on September 20, 2005 on bio-based lubricants, hydraulic fluids, and degreasers. This topic is especially timely with rising petroleum prices and other environmental concerns. Other sponsors included Sustainable Step New England, Vermont Sustainable Jobs Fund, the Vermont Biodiesel Project, and the Vermont Department of Energy.

The Vermont SBDC is partnering with the VT DEC to develop an interactive online learning course for conditionally exempt generators (CEG), based on the VT CEG Handbook. The concept is to make the regulations more comprehensible (and hopefully more interesting) to small businesses owners, supervisors, and maintenance personnel, who can learn about these in plain English at their own pace.

The course is designed to take no more than 45 minutes to complete and will encourage users to supply generic demographics and answer quiz questions in order to receive a certificate. Users will be able to check their quiz answers and have course information partially customized for auto body, auto service, and printing businesses, plus maintenance personnel.

A "test your regulatory knowledge" pre-quiz will be encouraged in hopes of collecting some outcome data from the course. Additionally, registering will give the user the advantage of remembering quiz scores where they left off, and users will be providing data on 1st quiz results percent correct. Users will need to correct quiz answers until they have 100 percent on all five modules' 10 question quizzes in order to be able to print out a certificate of completion with their information on it. To date, the course format, function, and set-up are complete, and the course should be available at www.vtceg.org on or around October 1, 2005. This project is funded by the EPA.

EPA REGION 1 - NEW ENGLAND

EPA Region 1-New England recently sponsored a six-state meeting to develop plans for collaborative efforts in priority areas. The participants were selected by state commissioners and senior staff and proposed to pursue:

• implementing a regional Environmental Results Project (ERP);
• improving the NPDES permitting process; and
• evaluating ways to change RCRA programs to come more in line with the RCRA 2020 Vision (and RCC), which focus on changing RCRA to be more P2-oriented and less waste management oriented.

In response to long standing requests for change in the way RCRA is applied to college and university labs, EPA's Office of Solid Waste (OSW) convened a national workgroup to develop a new rule. Because of the Agency's experience with its Labs XL project, EPA Region 1-New England played a prominent part. The draft proposed rule has been reviewed by the Regions and EPA Headquarters Offices, and is now undergoing "full agency review." It should be proposed for public comment early in 2006. The draft rule is an opt-in, performance-based standard that gives colleges considerable flexibility in saying how their institution will meet the requirements. States will need to adopt the rule before individual colleges can join the program. EPA Region 1-New England will plan for informational sessions after the rule is proposed.

The process of determining equivalence for state regulations implementing new federal rules has been cumbersome and fraught with controversy. State rules, even those that might offer greater environmental protection, are not always deemed "equivalent," and are not allowed. The new process, two years in development, will create guidance for the EPA Regions to allow more flexibility in determining equivalence for state rules. The guidance is expected to be issued by the EPA Office of Solid Waste (OSW) in the fall of 2005.

For more information contact: George Frantz, EPA Region 1-New England (617) 918-1883

EPA REGION 2

Fertilizer & Pesticide Awareness

Long Islanders love their lawns and do their best to make them healthy. But studies suggest that many may be going overboard in their pursuit of an idealized lawn; especially in over-applying fertilizers in a way that overloads the local marine environment. EPA Region 2 and the Metropolitan Transit Authority (MTA) have teamed up to address the problem with a public awareness campaign that encourages homeowners to limit their use of lawn care products to reduce their impact on groundwater, local water bodies, and the aquatic life that inhabit them.

Many water bodies in and around Long Island, including the Long Island Sound, have water quality problems. Even the relatively pristine Peconic Estuary between the east end's north and south forks is showing the stresses of pollution. Fertilizers and pesticides can contribute to those problems. When homeowners over-apply or incorrectly apply fertilizers and pesticides, the rain washes them into groundwater, streams, lakes, the Sound, and the bays. Too much fertilizer in water can negatively impact the food web and cause nuisance algae to grow. The algae use up the oxygen that fish need to survive. Pesticides in water can directly harm fish and aquatic plants.

EPA Region 2 Director of Environmental Planning and Protection Walter Mugdan, the Nature Conservancy, and Mineola Mayor Jack Martins unveiled the new fertilizer and pesticide awareness posters at a ceremony in Mineola in late August. The posters will appear in all Long Island Railroad trains in September.

The key message in EPA's fertilizer and pesticide awareness campaign is to limit homeowner use of chemical lawn care products and, when they are used to ensure they are applied properly and effectively with minimum impact on the environment.

NORTHEAST P2 ROUNDTABLE

Moving Toward Sustainable Production

For over 15 years since the passage of the Pollution Prevention Act, manufacturers and government agencies have consistently faced the challenge of poor information systems for evaluating pollution prevention (P2) opportunities. Successful pollution prevention is based on an entity's ability to understand and improve its choice and use of materials and the associated financial impacts.

NEWMOA and the Massachusetts Office of Technical Assistance (OTA) for Toxics Use Reduction are currently collaborating to develop and pilot test a materials use and profitability software tool. The project builds upon the current application of environmental management accounting as a critical aspect of sustainable production and P2.

The primary beneficiaries of this project will be those companies and organizations that implement this environmental management accounting tool to aid them in setting P2 priorities, identifying value-added opportunities for sustainable production, and implementing other materials and energy efficiency improvements. State and local environmental and technical assistance programs and private sector consultants will also benefit by having the tool to help their client companies identify P2 opportunities and quantify the benefits and costs.

NEWMOA is a non-profit, non-partisan interstate governmental association. The membership is composed of state environmental agency directors of the pollution prevention, hazardous and solid waste, and waste site cleanup programs in Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont.

NEWMOA's mission is to develop and sustain an effective partnership of states to explore, develop, promote, and implement environmentally sound solutions for the reduction and management of materials and waste, and for the remediation of contaminated sites, in order to achieve a clean and healthy environment. The group fulfills this mission by providing a variety of support services that:

• facilitate communication and cooperation among member states and between the states and the US EPA; and
• support the efficient sharing of state and federal program resources to help avoid duplication of effort and to facilitate development of regional approaches to solving critical environmental problems in the region.

NEWMOA's Assistance and P2 Program was established in 1989 to enhance the capabilities of the state and local government environmental officials in the Northeast to implement effective multi-media source reduction and assistance programs to promote sustainability and improvement in public health and the environment. The program is called the Northeast Assistance & Pollution Prevention Roundtable (NE A & P2 Roundtable). This program involves the following components:

• NE A & P2 Roundtable meetings and workgroups
• Regional information resource center and online databases
• Source reduction research and publications
• Training events
• Regional policy coordination and development.

Northeast Assistance & Pollution Prevention News is published a few times per year by NEWMOA's program, called the Northeast Assistance & Pollution Prevention Roundtable (NE A & P2 Roundtable). The publication is provided free to the Northeast states, EPA, and other interested individuals and is supported by funds from EPA Region 1-New England and the Northeast States.

The NE A & P2 Roundtable would like to thank the following people for writing and producing this newsletter: Karen Angelo, MA TURI; Tom Armstrong, RI DEM; Peter Crawford, VT SBDC; Peter Cooke, ME DEP; Michael DiGiore, NJ DEP; George Frantz, EPA Region 1-NE; Tristan Gillespie, EPA Region 2; Rob Guillemin, EPA Region 1-NE; Gary Gulka, VT DEC; Sara Johnson, NH DES; Dennis Lucia, NYS DEC; Kim Trella, CT DEP; and Paul Walsh, MA DEP. Terri Goldberg managed production of the newsletter.

Please use the form at the back of this issue to request an address change, to add your name to the mailing list, or to request an electronic version of the newsletter. NEWMOA appreciates your cooperation in ensuring that the mailing list is correct.

The Northeast A & P2 Roundtable is a member of the Pollution Prevention Resource Exchange, P2R_x™, a national network of regional P2 information centers linked together to facilitate information retrieval from experts around the country. Current P2R_x™ projects include online Topic Hubs and a National Assistance Programs Database.