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New Hampshire Army National Guard (NHARNG)
Pollution Prevention (P2) Plan
Summer 2003
Shelley DoughertyUniversity of New Hampshire
P2 Intern(207)384-4227
NHARNGEnvironmental Office
57 Regional Dr.Concord NH, 03301
Mrs. Eileen ChabotNHARNG Environmental Office
Environmental Specialist(603)225-1211
Shelly Dougherty Page 2 Summer 2003
Shelly Dougherty Page 3 Summer 2003
Table of Contents
LIST OF ACRONYMS......................................................................................................................................................5
I.) EXECUTIVE SUMMARY...........................................................................................................................................7
II.) INTRODUCTION........................................................................................................................................................7
A.) PURPOSE.....................................................................................................................................................................7
B.) NHARNG P2 BACKGROUND.....................................................................................................................................7
C.) SCOPE OF P2 PLAN.....................................................................................................................................................9
D.) OUTLINE OF P2 PLAN.................................................................................................................................................9
III.) GOALS AND OBJECTIVES..................................................................................................................................10
IV.) APPROACH..............................................................................................................................................................11
A.) DEVELOPMENT OF THE P2 PLAN..............................................................................................................................11i.) Site Visits..............................................................................................................................................................11ii.) Data Collection and Analysis..............................................................................................................................12iii.) Writing the P2 Plan............................................................................................................................................12
B.) ANTIFREEZE RECYCLING PROGRAM........................................................................................................................12i.) Baseline Development and Current Recycling Procedures..................................................................................12ii.) Investigation of On-Site Recycling Opportunities...............................................................................................13iii.) Investigation of Off-Site Recycling Opportunities..............................................................................................13iv.) Antifreeze Recycling Presentation......................................................................................................................14v.) New Off-Site Recycling Opportunity....................................................................................................................14
C.) PAPER RECYCLING PROGRAM 14i.) Previous Paper Recycling Program and Baseline Development.........................................................................14ii.) Investigation of Potential Recycling Opportunities.............................................................................................14iii.) Development of Awareness Poster and Presentation.........................................................................................15
D.) AUTHORIZED USE LIST............................................................................................................................................15
V.) CHEMICAL USAGE.................................................................................................................................................16
VI.) RELEASES/WASTES GENERATED...................................................................................................................18
A.) HAZARDOUS WASTE STREAMS................................................................................................................................18
B.) ENERGY RECOVERY STREAMS.................................................................................................................................19
C.) SOLID WASTE STREAMS...........................................................................................................................................20i.) Recycled Solid Waste Streams..............................................................................................................................20ii.) Non-Recycled Solid Waste Streams.....................................................................................................................20
D.) AIR EMISSIONS.........................................................................................................................................................23
VII.) PROJECT RESULTS.............................................................................................................................................26
A.) ANTIFREEZE RECYCLING PROGRAM RESULTS.........................................................................................................26i.) Current Antifreeze Recycling through DRMO.....................................................................................................26ii.) On-site Antifreeze Recycling...............................................................................................................................27iii.) Off-site Antifreeze Recycling..............................................................................................................................29iv.) Advanced Liquid Recycling, Inc.........................................................................................................................30v.) ARNE and NEES Partnership..............................................................................................................................31vi.) Economic Analysis Summary..............................................................................................................................32
B.) PAPER RECYCLING PROGRAMS RESULTS.................................................................................................................34
VIII.) FUTURE RECOMMENDATIONS.....................................................................................................................36
IX.) LIST OF CONTACTS..............................................................................................................................................37
X.) REFERENCES...........................................................................................................................................................40
XI.) APPENDICES...........................................................................................................................................................41
A.) NHARNG P2 EQUIPMENT.......................................................................................................................................43
B.) SITE VISIT CHECKLIST.............................................................................................................................................45
A.) Paper Recycling Awareness Poster.........................................................................................................................47
Table of Figures
FIGURE 1: HAZARDOUS WASTE CONTAMINATION 18FIGURE 2: TYPE AND QUANTITY OF BATTERIES DISPOSED 19FIGURE 3: SOLID WASTE STREAMS 23FIGURE 4: AIR EMISSIONS SOURCES 25FIGURE 5: ON-SITE ANTIFREEZE RECYCLING PROCESS, MATERIAL FLOW DIAGRAM 27FIGURE 7: ANTIFREEZE ANNUAL COST/SAVINGS COMPARISON 33FIGURE 8: ANTIFREEZE AVERAGE COST/SAVINGS PER GALLON COMPARISON 33FIGURE 9: POTENTIAL IMPACT OF PAPER RECYCLING 34FIGURE 10: ANTIFREEZE RECYCLING MACHINE 43FIGURE 11: AQUEOUS PARTS WASHER (INSIDE) 43FIGURE 12: SECONDARY CONTAINMENT AREA 43FIGURE 13: FILTER CRUSHER 43Figure 14: Aerosol Can Puncturing Machine 44
Shelly Dougherty Page 6 Summer 2003
List of Acronyms
AASF Army Aviation Support Facility
ALR Advance Liquid Recycling, Inc.
AOAP Army Oil Analysis Program
ARNE Antifreeze Recycling of New England
CSMS Combined Support Maintenance Shop
DRMO Defense Reutilization and Marketing Office
DRMS Defense Reutilization and Marketing Service
EO Executive Order
EPA Environmental Protection Agency
EMS Environmental Management System
IMPAC International Merchant Purchase Authorization Card
IRN Institution Recycling Network
NEES New England Environmental Service
NHDES New Hampshire Department of Environmental Service
NHNGTS New Hampshire National Guard Training Site
NSN National Stock Number
OA Opportunity Assessment
OMS Organizational Maintenance Shop
P2 Pollution Prevention
SMR State Military Reservation
USP&FO United States Property & Fiscal Office
I.) EXECUTIVE SUMMARY
The New Hampshire Army National Guard (NHARNG) needs to develop an updated Pollution Prevention (P2) Plan in accordance with Executive Order (EO) 13148, “Greening the Government through Leadership in Environmental Management” and ISO 14001.
The purpose of this internship was to develop a new P2 Plan for the NHARNG by analyzing the mission and the processes that take place at NHARNG facilities included in the scope of the P2 plan and brainstorming potential P2 initiatives that could help further NHARNG’s future P2 endeavors.
On August 1st, 2003 a rough draft of the new P2 Plan was given to Mrs. Eileen Chabot for review. After revisions are made, the final P2 Plan will be signed and turned in on or before October 15th, 2003.
The NHARNG has made arrangements to extend this internship through the 2003 – 2004 academic year in order that implementation of potential P2 initiatives recommended in the P2 plan may begin.
II.) INTRODUCTION
A.) Purpose
The purpose of a P2 plan is to outline a facility’s commitment to P2 by documenting, tracking, and managing practices and initiatives necessary to reduce the release of pollutants and decrease the use of hazardous materials.
As a federal facility, the NHARNG is required by EO 13148, “Greening the Government through Leadership in Environmental Management” to develop a P2 plan that addresses their P2 endeavors aimed toward achieving the goals prescribed by this EO as well as EO 13101, “Greening the Government through Waste Prevention, Recycling, and Federal Acquisition,” EO 13123, “Greening the Government through Efficient Energy Management,” and EO 13149, “Greening the Government through Federal Fleet and Transportation Efficiency.” The following sections describe NHARNG’s previous P2 plans as well as the scope and outline of the updated P2 plan.
B.) NHARNG P2 Background
NHARNG’s previous P2 plan was written in 1996 by Environmental Protection Specialist SFC Richard A. Laflamme. This plan was developed in order to comply with EO 12856, “Federal Compliance with Right-To-Know Laws and Pollution Prevention Requirements; August 1993.”
The P2 initiatives recommended for implementation by this plan resulted from an Opportunity Assessment (OA) conducted in June of 1993 by two Pollution Prevention Assessment Teams from the New Hampshire Department of Environmental Services (NHDES). All the P2 initiatives documented in this P2 plan were implemented, and are currently still being implemented with the
exception of on-site antifreeze recycling at the Combined Support Maintenance Shop (CSMS) in Concord.
The P2 initiatives that are currently being implemented as a result of previous P2 plans and OAs include the following:
Organizational Maintenance Shops (OMSs) participate in the Army Oil Analysis Program (AOAP) to ensure that oil is changed only when necessary
“Used Oil for Recycle” is burned in Manchester for the Energy Recovery Program
Aqueous parts washers are used in place of petroleum based solvent parts washers
Maintenance shop rags are laundered by a contracted rag laundering service and reused
Oil filters are hot drained, crushed and the resulting scrap metal is recycled
Secondary containment areas are used for storage of tactical fueling truck tanks to capture any fuel spillage/leakage
An aerosol can puncturing system is used to puncture and drain aerosol cans; the resulting scrap metal from the empty cans is recycled
Oil-water separators are used to separate any oil from wastewater before wastewater is discharged to the sewer system
Scrap metal is collected and recycled; all the money acquired is placed in a fund site dedicated to the health and welfare of the troops as well as P2 equipment
Used tires are sent through the Defense Reutilization Marketing Service (DRMS) to New York to be ground up and reused in rubberized asphalt
Spend lead-acid batteries are recycled through a one-for-one exchange program with Exide, and
Antifreeze is recycled through the Defense Reutilization Marketing Office (DRMO).
Pictures of NHARNG’s P2 equipment utilized to implement many of the P2 initiatives described above can be found in the Appendices.
The majority of the P2 initiatives implemented by NHARNG in the past have remained successful over the years. As can be expected, however, some were terminated due to either a decrease in effectiveness or lack of interest and participation. These problems plagued both NHARNG’s on-site antifreeze recycling program as well as the paper recycling program.
In the mid 90s, an antifreeze recycling machine was purchased and an on-site antifreeze recycling program was established at the CSMS in Concord. CSMS mechanics were trained to operate the machine and the recycling program ran smoothly for several years. Approximately two years ago, however, accumulation of excess recycled antifreeze became a problem and use of the machine stopped. Upon termination of the on-site antifreeze recycling program, NHARNG began recycling antifreeze through the DRMS, a very costly alternative.
A paper recycling program was also established at the State Military Reservation (SMR) a couple years ago with Tobey School, a nonprofit organization, in partnership with Revamp Inc. Recycling totes were placed in various locations on the SMR and Tobey School/Revamp would empty and replace all the totes and recycle the paper free of charge. Due to lack of awareness and participation on behalf of SMR staff, the paper recycling program was terminated by Tobey School/Revamp shortly after it began.
The new P2 plan will not only help maintain the successfulness and effectiveness of the currently implemented P2 initiatives, but will also address the problems of the unsuccessful ones as well in an attempt to overcome the obstacles encountered in the past.
C.) Scope of P2 Plan
National Guard facilities function jointly as state and federal establishments. Do to the fact that only federal funds were allocated to the development of this P2 plan, the scope extends across only federally owned and operated NHARNG facilities.
The SMR, located in Concord NH, serves as the NHARNG headquarters. The facilities included in the P2 plan that reside on the SMR include the CSMS, the CSMS Annex, the Army Aviation Support Facility (AASF), the United States Property & Fiscal Office (USP&FO) Warehouse, and the State Maintenance Shop. In general these facilities perform a variety of activities which contribute to the overall maintenance and repair of tactical vehicles, field artillery equipment, construction equipment, and Blackhawk helicopters as well as the dispensing of JP-8 fuel.
In addition to the SMR facilities, the P2 plan also addresses NHARNG’s 4 OMSs located in Littleton, Somersworth, Manchester, and Hillsboro. The OMSs perform routine maintenance on tactical vehicles and field artillery equipment. Typical processes involved in the routine maintenance include fluid, battery, and filter changes, parts cleaning and replacement, brake servicing, and vehicle washing.
Aside from the maintenance facilities, the P2 plan also includes the New Hampshire National Guard Training Site (NHNGTS), located in Center Strafford. The NHNGTS is the primary training facility for NHARNG and an auxiliary training facility for the NH Air National Guard, and serves as a basis for the majority of training operations.
D.) Outline of P2 Plan
The P2 Plan is comprised for 14 chapters. The first 5 chapters are dedicated to introductory and background information relating respectively to pollution prevention, P2 regulations, NHARNG P2 program, compliance sites and thresholds, and NHARNG’s waste generating processes.
Chapters 6 – 14 of the P2 plan focus specifically on the establishment of potential P2 initiatives that will help NHARNG achieve all the P2 goals instituted by EOs. These chapters respectively address the following areas:
Hazardous/Universal Waste
Solid Waste
Air Emissions
Water and Wastewater
EPA Priority Chemical Reduction and TRI Form R Reporting
Ozone Depleting Substance
Vehicle Fuel Conservation
Energy Conservation
Affirmative Procurement
Each chapter is comprised of four major sections which include goals, baseline and progress, current P2 initiatives, and potential P2 initiatives. The goals section states the source, baseline year, and target year of the goal in addition to the goal itself. The baseline and progress section is comprised of information regarding data collection and techniques/sources utilized to approximate quantities. It also includes a table for tracking progress beginning with the baseline year. The current P2 initiatives section describes all P2 initiatives that are currently being implemented as a result of previous P2 plans and past opportunity assessments. Finally, the potential P2 initiatives section details all P2 initiatives that were developed as a result of this internship and recommended for future implementation.
III.) GOALS AND OBJECTIVES
The primary goal and overall purpose of this P2 internship was to develop a new, updated, P2 plan for the NHARNG that specifically addressed the goals and requirements of EO 13148. Embedded in the development of the P2 plan were specific P2 objectives that NHARNG wished to have addressed. These objectives became the primary focus of the “Potential P2 Initiatives” portions of the P2 plan and included the following projects:
research and evaluation of re-establishing a paper recycling program
research and evaluation of an antifreeze recycling program, as an alternative to the DRMS, and
investigation and development of an authorized use list
Aside from the actual development and writing of the P2 plan, the internship focused on initializing the implementation of the projects listed above.
IV.) APPROACH
A.) Development of the P2 Plani.) Site Visits
Ultimately the first course of action taken upon beginning the internship was the scheduling of site visits to all the facilities that were to be included in the scope of the P2 plan. Having been given a list of the facilities and their corresponding contact person, several phone calls were made as well as E-mails sent, and within the first week the majority of the site visits had been scheduled and confirmed.
It was decided that for timing purposes all site visits would be scheduled and completed by the end of June. The remainder of internship would be allocated to data analysis and the writing/revising of the P2 plan.
Table 1: Site Visit Itinerary
Facility Point of Contact Date/Time of Site Visit
Manchester OMS #4 CW2 Michael Tkacz Tuesday June 10, 8:30am
State Maintenance Shop Mr. Joe Sampson Thursday June 12, 8:30am
USP&FO Warehouse 1SG Kevin Reynolds Monday June 16, 9:00am
Littleton OMS #2 SSG Randy Dockham Wednesday June 18, 10:00am
AASF SGT Roger Prive Thursday June 19, 8:30am
Hillsboro OMS #5 SFC Dennis MacKenzie Friday June 20, 9:00am
CSMS and CSMS Annex (OMS #1) CW4 Tom LaPierre Tuesday June 24, 8:30am
NHNGTS CW2 George Spaulding Wednesday June 25, 9:00am
Somersworth OMS #3 MSG Mike Dignard Monday June 30, 8:30am
In order to ensure that site visits would run as smoothly and as efficiently as possible, a site visit checklist was developed and E-mailed to the contact person of each facility. The checklist included all documentation we wanted to acquire as well as the equipment/processes we wanted to view and evaluate. In addition to E-mailing this checklist to the facilities, a copy of the checklist was brought to each visit to serve as a reminder of what needed to be accomplished. A copy of the site visit checklist can be found in the Appendices.
ii.) Data Collection and Analysis
Data was collected primarily through site visits and phone calls/E-mails. All people who were contacted over the course of this internship have been referenced in a list of contacts. In addition, other previously drafted plans were utilized as well. Examples of such plans include Air Emissions Inventories, Integrated Contingency Plans, Energy Audits, etc.
Attempts were made to collect data dating back to the baseline years developed for the goals established by the EOs. For the most part these efforts were made in vain. Typically the oldest data that could be acquired was for FY 2000, which consequently restricted data analysis to a mere 3 years at most.
Data analysis consisted of the creation of Excel spreadsheets and charts corresponding to the specific chapters addressed in the outline of the P2 plan (i.e. hazardous/universal waste, solid waste, air emission, etc.). These spreadsheets and charts were utilized to analyze trends and develop appropriate goals for NHARNG based on their personal progress in regards to federal requirements.
iii.) Writing the P2 Plan
The P2 plan was written jointly by Michael O’Connor and me. Essentially the plan was written chapter by chapter as separate documents and merged into one final document upon completion of all 14 chapters. Responsibility for researching and writing specific chapters were divided equally between us. In particular, I focused on the following chapters: P2 Regulatory Background, Solid Waste, Air Emissions, Ozone Depleting Substances, and Vehicle Fuel Conservation.
B.) Antifreeze Recycling Programi.) Baseline Development and Current Recycling Procedures
Waste manifests from FY 2002 were analyzed to determine a baseline quantity for the approximate amount of antifreeze used by NHARNG and to investigate the costs associated with the current antifreeze recycling procedures through the DRMO. Results of the analysis are given in the following table which details the location, condition (recycled vs. contaminated), quantity (lbs), and processing cost ($1.30/lb recycled, $1.08/lb contaminated) of the manifested waste antifreeze.
Table 2: FY 2002 Waste Antifreeze Data
Based on the data given in the table above and the approximation that 1 gallon of antifreeze weighs 9lbs, a baseline of 550 gallons of antifreeze used/disposed of per year was developed. This baseline was used to analyze and compare the annual costs associated with alternative antifreeze recycling programs. This baseline was purposefully over-estimated such that cost analyses would project maximum annual costs or, in other words, the “worst-case-scenario.”
ii.) Investigation of On-Site Recycling Opportunities
Investigation of on-site recycling opportunities began with a trip to the CSMS to view antifreeze recycling machine, the BG Cool’r Clean’r, currently owned by NHARNG. We questioned several mechanics in the CSMS about the potential of using the machine again. In general, we received a negative response. The only positive response received was from an interview with MSG Jim Muhnisky, the man who previously operated the machine before being transferred to a new job outside the CSMS.
Following the CSMS visit and interview, the BG Cool’r Clean’r company was contacted to receive information regarding specific procedures for operating the machine and any new product information and pricing.
iii.) Investigation of Off-Site Recycling Opportunities
Investigation of off-site recycling opportunities was already being conducted prior to this internship. Mrs. Muriel Lajoie, the NHARNG’s Hazardous Waste Manager began researching and contacting off-site recycling companies. These responsibilities were transferred to us upon the beginning of our internship.
The primary opportunity that Muriel was investigating was Advanced Liquid Recycling Inc. She had only made the initial phone contact with the company. We took the next step and set up a meeting with a representative of the company to inquire about the details and costs associated with their services.
iv.) Antifreeze Recycling Presentation
An antifreeze power point presentation including technical and economic evaluations of both on-site and off-site recycling opportunities was developed and presented on July 8th, 2003. The presentation was given to environmental office staff, CSMS staff, and other SMR personnel with the intent of emphasizing the need for an alternative antifreeze recycling program. Overall, feedback indicated that there was indeed interest in perusing an alterative. However, no final decisions regarding the recycling program chosen for implementation were made, or have been made since.
v.) New Off-Site Recycling Opportunity
An off-site recycling opportunity with Antifreeze of New England, which was initially deemed unfeasible due to inadequate payment options, was recently brought back the circle of potential recycling opportunities. Through E-mail correspondence with USP&FO staff member Spencer Wilber, it was determined that a payment method could be arranged to suite NHARNG’s needs.
C.) Paper Recycling Programi.) Previous Paper Recycling Program and Baseline Development
In order to facilitate the implementation of a new successful paper recycling program, it was essential to understand the problems associated with the original program and to emphasize the need for such a program through the development of a baseline and goals.
The previous paper recycling program was established by SFC Richard Laflamme through a non-profit organization called Tobey School. SFC Laflamme purchased recycling bins and Tobey School provided large recycling totes for the buildings on the SMR. Tobey School would empty the totes both on a set schedule or an as needed basis. The program functioned as expected for a short period of time and then gradually began to deteriorate due to lack of participation. Tobey School eventually terminated their relationship with NHARNG when totes were not adequately filled on a bi-weekly basis. The primary problem associated with the original paper recycling program was a combination of inadequate enforcement and awareness which resulted in a lack of participation.
A baseline for the amount of waste paper generated by NHARNG annually was developed according to testimonials regarding the results of the original program. During the initial success of the original recycling program approximately 11 totes were filled and emptied bi-weekly. Assuming that the totes weighed an average of 200lbs each, NHARNG could potentially generate an estimated 52,800lbs of waste paper annually.
ii.) Investigation of Potential Recycling Opportunities
Extensive online research was conducted in search of paper recycling opportunities that could meet the needs of NHARNG. Unfortunately, since NHARNG is a relatively small establishment, its waste paper generation isn’t significant enough to utilize many of the opportunities that were researched online. For this reason the majority of the opportunities were not pursued beyond the initial internet research stage.
INSTITUTION RECYCLING NETWORK
The only opportunity which was extensively researched was with Institution Recycling Network (IRN). A meeting was scheduled with Mr. Mark Lennon, a representative from IRN on July 9th, 2003. In addition to Mr. Lennon, Mike and I, this meeting was attended by SFC Richard Laflamme and a representative from the USP&FO. It was determined from this meeting that IRN could not provide a cost effective recycling program and it was suggested that NHARNG re-establish relations with Tobey School, which is now in partnership with Revamp Inc.
TOBEY SCHOOL/REVAMP INC.
Ms. Wanda Kula, a representative from Revamp Inc. was contacted via SFC Richard Laflamme. A short visit to the Tobey School/Revamp facility was conducted and the feasibility of re-establishing the paper recycling program was discussed. To summarize, Tobey School/Revamp was willing to service the SMR provided that participation on behalf of NHARNG was guaranteed.
iii.) Development of Awareness Poster and Presentation
In order to increase the participation of NHARNG Mike created an awareness presentation and poster. Prospectively, an awareness presentation will be given prior to the re-implementation of the recycling program. The posters will be utilized during the initial implementation to ensure that paper is sorted appropriately. A copy of the awareness poster is given in the Appendices.
D.) Authorized Use List
Development and implementation of the Authorized Use List has not yet begun. Potentially this project will be one of the major focuses of this internship, should it be extended through the fall. The following steps outline the proposed approach that may be taken to develop and implement the Authorized Use List:
Analysis of hazardous waste laboratory test results to determine what chemicals are contaminating NHARNG’s waste streams
Analysis of NHARNG’s hazardous material inventory to determine what products contain the chemicals identified to be contaminants of NHARNG’s waste streams
Research of environmentally friendly alternatives to the targeted products
Identification of what products are required to be used by mechanics due to military specifications and/or operating manuals and are not subject for replacement
Meet with shop chiefs/mechanics to develop a list of products that may be purchased/used that will satisfy both shop chiefs/mechanics as well as the Environmental Office Staff.
V.) CHEMICAL USAGE
NHARNG’s Hazardous Material Inventory is reflective of the products typically used on a routine basis by NHARNG maintenance shops. Analysis of these products would reveal their specific
ingredient composion, which would be representative of the chemicals used by NHARNG. Although this analysis has not yet been conducted, it will potentially be one of the initial steps of the development and implementation of the Authorized Use List. A copy of NHARNG’s Hazardous Material Inventory is given below.
The following inventory includes all products kept in flammable storage cabinets in NHARNG facilities addressed in the scope of the P2 plan. This inventory only details the type of product stored in the flammable cabinets and is not representative of the quantity or frequency of product use. The products are listed in ascending order according to National Stock Number (NSN).
Table 3: NHARNG Hazardous Material Inventory
2640-00-138-8324 Solution,Buffing2640-00-256-5526 Lubricant,Tire And Rim2640-00-256-5527 Lubricant,Tire And Rim2640-00-264-6642 Lubricant,Inner Tube2640-00-922-6917 Bonding Compound,Tire Repair2910-01-128-9537 Engine Starting Fluid (Diesel Start)3439-00-184-8960 Solder,Lead Alloy3439-00-255-4566 Flux,Soldering3439-00-255-4572 Flux,Brazing3439-00-262-2648 Electrode,Welding3439-00-262-2652 Electrode,Welding3439-00-262-2653 Electrode,Welding3439-00-262-2743 Electrode,Welding3439-00-288-0868 Flux,Soldering3439-00-640-3713 Flux,Brazing5970-00-962-3335 Insulating Varnish,Electrical6140-01-210-1964 Lead Acid Battery6140-01-431-1172 Battery,Storage6140-01-446-9506 Lead Acid Battery6505-00-104-9000 Denatured Ethyl Alcohol6505-00-174-2293 Nitrogen Compressed6630-01-011-5039 Test Kit,Antifreeze6810-00-201-0906 Alcohol,Denatured6810-00-249-9354 Sulfuric Acid,Electrolyte6810-00-264-6715 Molybdenum Disulfide,Technical6810-00-275-6010 Methanol,Technical6810-00-543-7415 Alcohol,Denatured6810-00-597-3608 Methanol,Technical6810-00-843-1640 Sulfuric Acid,Electrolyte6830-00-169-0800 Oxygen,Technical6830-00-584-3041 Propane6840-00-570-5299 Sanitizer-Detergent,General Purpose6850-00-001-4193 Water Indicating Paste6850-00-177-5094 Silicone Grease6850-00-181-7929 Fleet Charge Antifreeze & Coolant6850-00-274-5421 Cleaning Compound,Solvent6850-00-281-1985 Dry Cleaning Solvent6850-00-485-4697 Cleaning Compound,Optical Lens6850-00-598-7311 Leak Preventive Compound,Radiator6850-00-664-1257 Silicone Compound6850-00-823-7861 Fuel,Engine Primer6850-00-880-7616 Silicone Grease
6850-00-926-2275 Cleaning Compound,Windshield6850-01-063-4760 Cleaning Compound,Solvent6850-01-082-6783 Fuel,Engine Primer6850-01-085-1423 Carbon Removing Compound6850-01-246-6544 Stabilizer Additive,Diesel Fuel6850-01-377-5074 Inhibitor,Icing,Fuel System6850-01-441-3218 Antifreeze7510-00-183-7698 Ink,Marking Stencil7930-00-269-1272 Absorbent Material,Oil And Water7930-00-282-9699 Detergent,General Purpose7930-00-282-9700 Detergent,General Purpose7930-00-935-3794 Polish,Plastic7930-01-328-5959 Cleaning Compound,Solvent-Detergent7930-01-331-1507 Cleaning Compound,Solvent-Detergent7930-01-342-5316 Cleaning Compound,Solvent-Detergent7930-01-383-7926 Cleaning Compound,Solvent-Detergent7930-01-393-6664 Defoamer7930-01-423-1292 Cleaning Compound,Solvent-Detergent8010-00-079-3760 Enamel8010-00-141-2950 Enamel Yellow8010-00-160-5787 Thinner,Paint Products8010-00-181-8079 Thinner,Aliphatic Polyurethane Coating8010-00-181-8080 Thinner,Paint Products8010-00-251-6503 Lacquer8010-00-257-5377 Lacquer8010-00-286-7758 Enamel Yellow8010-00-286-7838 Enamel Interior Semi-Gloss8010-00-290-6983 Enamel White8010-00-290-6984 Enamel Black Spray8010-00-297-0547 Enamel Black8010-00-297-0567 Enamel, Lo Voc White8010-00-297-0585 Enamel Alkyde, Lo Voc Yellow8010-00-297-2105 Enamel Olive Drab8010-00-298-2302 Enamel Alkyd Gloss Lo Voc Blue8010-00-348-7715 Enamel, Brown8010-00-527-2053 Enamel Alkyd Gloss Lo Voc Black8010-00-527-3199 Enamel, Red Gloss8010-00-582-5382 Enamel, Lacquer, Flat Black8010-00-584-3150 Enamel Flat White8010-00-597-7862 Enamel Alkyd Lo Voc Brown8010-00-598-5460 Enamel Alkyd Lo Voc Brown8010-00-598-5464 Enamel Alkyd Lo Voc Green
8010-00-598-5936 Enamel Olive Drab8010-00-616-7503 Lacquer Spray Green8010-00-616-9143 Enamel, Black8010-00-616-9181 Primer Coating, Light Gray8010-00-721-9479 Enamel Spray Orange8010-00-721-9743 Enamel Spray Red Gloss8010-00-721-9744 Enamel, Yellow8010-00-846-5117 Enamel, Olive Drab8010-00-848-9272 Enamel Spray8010-00-852-9033 Enamel, Yellow8010-00-935-7079 Lacquer Spray Paint8010-01-115-7984 Enamel Alkyd Lo Voc Green8010-01-122-1969 Enamel Alkyd, Yellow8010-01-331-6108 Enamel Spray8030-00-051-4011 Sealing Compound8030-00-081-2328 Sealing Compound8030-00-081-2335 Sealing Compound8030-00-087-8630 Antiseize Compound8030-00-145-0151 Coating Compound,Plastisol8030-00-148-9833 Sealing Compound8030-00-252-3391 Sealing Compound8030-00-275-8111 Sealing Compound8030-00-290-5141 Coating Compound,Bituminous,Solvent 8030-00-537-7925 Sealing Compound8030-00-546-8637 Corrosion Preventive Compound8030-00-656-1426 Sealing Compound8030-00-664-4944 Preservative Coating,Canvas8030-00-764-6658 Antiseize Compound8030-00-835-0884 Antiseize Compound8030-00-850-7076 Coating Compound8030-00-926-2135 Filler,Dent,Metal Surface8030-01-025-1692 Sealing Compound8030-01-054-0740 Sealing Compound8030-01-087-3589 Sealing Compound8030-01-103-2868 Sealing Compound8030-01-155-3238 Sealing Compound8040-00-117-8510 Adhesive8040-00-181-7761 Adhesive8040-00-266-0850 Adhesive8040-00-728-3088 Silicone Sealant8040-00-833-9563 Adhesive8040-00-844-9707 Adhesive8040-00-851-0211 Silicone Sealant8040-00-938-6860 Rubber Adhesive8040-01-010-8758 Silicone Sealant8040-01-126-1422 Adhesive8120-00-268-3360 Cylinder,Compressed 8520-00-228-0598 Soap,Toilet9150-00-145-0268 Grease,Aircraft9150-00-181-7724 Grease,Aircraft9150-00-190-0918 Grease,Graphite9150-00-231-6689 Lubricating Oil,General Purpose9150-00-231-9071 Brake Fluid,Automotive9150-00-234-5197 Lubricating Oil,Exposed Gear9150-00-257-5370 Grease,Graphite
9150-00-273-2389 Lubricating Oil,General Purpose9150-00-458-0075 Lubricating Oil,General Purpose9150-00-657-4959 Hydraulic Fluid, AT9150-00-698-2382 Hydraulic Fluid, AT9150-00-753-4667 Lubricating Oil,Air Compressor9150-00-823-7860 Lubricating Compound,Dimethylsilicone9150-00-935-5851 Grease,Aircraft9150-00-935-9807 Hydraulic Fluid,Petroleum Base9150-00-935-9809 Hydraulic Fluid,Petroleum Base9150-00-944-8953 Grease,Aircraft9150-00-999-7548 Lubricant,Interlocking Slide Fastener9150-01-007-4384 Grease,Aircraft And Instrument9150-01-015-1542 Grease,Molybdenum Disulfide9150-01-035-5393 Lubricating Oil,Gear9150-01-053-6688 Cleaner,Lubricant And Preservative9150-01-054-6453 Cleaner,Lubricant And Preservative9150-01-079-6124 Cleaner,Lubricant And Preservative9150-01-102-9455 Brake Fluid,Automotive9150-01-126-4459 Lubricating Oil9150-01-177-3988 Lubricating Oil,Engine9150-01-178-4725 Lubricating Oil,Engine9150-01-197-7692 Grease,Automotive And Artillery9150-01-197-7693 Grease,Automotive And Artillery9150-01-198-3829 Gear Lubricant Additive,Limited Slip9150-01-260-2534 Lubricant,Solid Film9150-01-310-5762 Oil,Synthetic9150-01-351-9019 Lubricating Oil,Engine9150-01-353-4799 Hydraulic Fluid,Automatic Transmission9150-01-421-1427 Lubricating Oil,Engine
VI.) RELEASES/WASTES GENERATED
A.) Hazardous Waste Streams
Waste streams are hazardous when contaminated with heavy metals or regulated chemicals. The following chart shows the quantity and percentage of NHARNG’s hazardous waste streams contaminated by lead, other heavy metals, and other regulated chemicals found in solvents.
Metal Contamination
7,923 lbs31%
Lead Contamination816 lbs
3%
Other Contamination
16,594 lbs66%
Lead Contamination Other Metal Contamination Other Contamination
Figure 1: Hazardous Waste Contamination
The following list details the primary hazardous waste streams generated by the NHARNG:
CONTAMINATED USED OIL
Used oil that tests hot for dissolved metals and/or certain chemicals found in solvents is considered contaminated and cannot be burned for energy recovery. Rather, it must be disposed of as a hazardous waste.
CONTAMINATED USED ANTIFREEZE
Antifreeze that tests hot for dissolved metals, other automotive fluids/oils, and/or certain chemicals found in solvents is considered contaminated and cannot be recycled through the DRMO. Rather it must be disposed of as a hazardous waste.
OIL-WATER SEPARATOR SLUDGE
Oil-water separator sludge is the sludge that is separated from wastewater before the wastewater is released into the water system. This sludge is composed of oils that are not miscible in water.
PARTS-WASHER SLUDGE
Parts-washer sludge is the sludge from inside the aqueous parts washer which could be contaminated with dissolved metals, automotive fluids, and/or chemicals from solvents.
BATTERIES
176 lbs
274 lbs
15 lbs
5 lbs9 lbs0 lbs 62 lbs61 lbs0 lbs
354 lbs
303 lbs
272 lbs
243 lbs
460 lbs
185 lbs
348 lbs
346 lbs
240 lbs
0
100
200
300
400
500
600
700
800
900
Wei
ght (
lbs)
Battery Type
2002 15 0 0 272 185 240
2001 274 9 61 303 460 346
2000 176 5 62 354 243 348
magnesium nicad mercury potassium hydroxide lithium lead-acid
Figure 2: Type and Quantity of Batteries Disposed
B.) Energy Recovery Streams
Some materials are exempt from being a regulated waste but are not considered a recycled material because they are burned for energy recovery. The NHARNG employs a used oil burner in the
Manchester OMS. Approximately 700-1,400 gallons per year are diverted from the waste stream for energy recovery.
C.) Solid Waste Streamsi.) Recycled Solid Waste Streams
Recycled solid waste streams “include all non-hazardous waste as defined by the Environmental Protection Agency (EPA) in the Solid Waste Disposal Act or by NH’s regulations that were recycled or composted, on-site or off-site, or otherwise diverted from incineration, energy recovery, or a landfill. NHARNG currently recycles scrap metal, used antifreeze, used shop rags, and spent lead-acid batteries. Following are descriptions of each of the recycled solid waste streams.
SCRAP METAL
An estimated 30,000lbs of scrap metal is generated annually by NHARNG and transported to the USP&FO Warehouse to be recycled. Currently NHARNG is receiving money for the scrap metal that is recycled. All money that is acquired through the recycling program is added to a fund site dedicated to the health and welfare of the troops as well as pollution prevention equipment.
TIRES
Approximately 47,600lbs of scrap tires are generated annually from routine maintenance of tactical vehicles. This estimate is based upon an interview with staff members of the USP&FO Warehouse, which is the collection site for all the scrap tires generated by the NHARNG. According to USP&FO Warehouse staff, the tires are sent by the DRMS to New York for recycle to be used for rubberized highway asphalt. Although the tires are currently being recycled, ideally a more local program would be beneficial to both NHARNG and the state of New Hampshire.
USED ANTIFREEZE
According to waste manifests, approximately 1919 lbs of used antifreeze is generated and recycled through DRMO per year. Please refer to the Hazardous and Universal Waste chapter for additional information regarding antifreeze and alternative recycling opportunities.
USED SHOP RAGS
A shop rags laundering service provided by Alltex is used to eliminate a potential hazardous waste stream. Instead of one-time-use cloth rags and paper towels, the laundering service delivers clean rags to the shops and removes soiled rags. They are then cleaned by the company and returned for reuse. Information regarding the quantity of shop rags laundered per year is not available.
SPENT LEAD-ACID BATTERIES
Spent lead-acid batteries are recycled through a one for one exchange program with Exide. Specific information regarding the quantity of batteries exchanged with Exide is not available.
ii.) Non-Recycled Solid Waste Streams
Non-recycled solid waste streams include all non-hazardous waste that is disposed of either by incineration, energy recovery, or landfill. Currently NHARNG’s non-recycled solid waste streams include cardboard, scrap wood, office paper, “regular” garbage, spent batteries, and non-regulated wastes.
CARDBOARD
An estimated 9,600lbs of cardboard are generated annually at the SMR as waste from shipments. This estimate is based upon the EPA’s approximation that 1 cubic yard of loose cardboard weighs 50lbs and the SMR could potentially fill 1 8cy dumpster twice per month. In the past an effective cardboard recycling program was in place. Unfortunately the program is currently not being utilized as it is no longer cost effective. Although is not being recycled, there still remains a “Cardboard Only” dumpster located outside Building F which is emptied once per month. It has been observed that the contents of this dumpster are emptied into the same disposal truck as the “regular” garbage, and according to the dumpster contract costs more than the “regular” dumpsters. New recycling opportunities are being investigated in hopes to divert cardboard from the waste stream.
SCRAP WOOD
Approximately 6,000lbs of scrap wood is generated annually as waste from shipments. This estimate is based upon an interview with staff members of the USP&FO Warehouse, which is the collection site for all the scrap wood generated by the NHARNG. Individual OMSs are encouraged to seek local recycling/reuse opportunities for scrap wood until such opportunities have been established at the SMR. In the future, scrap wood recycling/reuse options will be investigated.
OFFICE PAPER
Approximately 52,800lbs of office paper is generated annually by the SMR. This estimate is based upon a previous paper recycling program in which 11 totes, located in the various buildings across the SMR, were filled and emptied bi-weekly. Each tote was capable of holding 95 gallons, which weighed approximately 200lbs when full. Previous paper recycling programs were not successful do the lack of awareness and participation on behalf of the SMR staff. Potentially a new paper recycling program will be established.
“REGULAR” GARBAGE
For the purpose of this plan “regular” garbage is defined as any form of solid waste not previously mentioned that is disposed of in dumpsters. This may include but is not limited to packaging scraps, food wrappers, plastic bottles, and aluminum cans. An estimated 31,440lbs of “regular” garbage is generated and disposed of in dumpsters maintained through dumpster contracts funded by the State side of NHARNG. The facilities involved in solid waste management through the dumpster contracts include the SMR, NHNG-TS, OMS #3 and OMS #4. An estimated 9,600lbs of “regular” garbage is generated at the SMR alone. These estimates are based upon the evaluation of
solid waste found in both trash cans and dumpsters at the SMR and information obtained from dumpster contracts.
Table 4: Criteria for "Regular" Garbage Estimates from Dumpster Contracts
*Estimates are based upon a quarter cubic yard garbage bin found in the AASF filled with "regular" garbage which weighed 6.5lbs.
**The 84,240lbs estimate includes paper, as paper is not currently being recycling and was thus found in garbage bins and dumpsters across the SMR.
SPENT BATTERIES
As determined from waste manifests an average of 1,118 lbs of spent batteries are generated per year. Spent batteries include all types of batteries with the exclusion of the lead-acid batteries that are exchanged with Exide. Some such types include magnesium, potassium hydroxide, mercury, and lithium batteries.
NON-REGULATED WASTE
As determined from waste manifests, an average of 5,511lbs of non-regulated solid waste is generated per year. Non-regulated solid waste includes all non-hazardous wastes recorded on waste manifests with the exclusion of spent batteries. This includes such wastes as spill cleanup residue, asbestos, wash water, and aerosol can residue.
scrap metal30,000 lbs
16%
non-regulated waste5,511lbs
3%
spent batteries1,118 lbs
1%
"regular" garbage31,440 lbs
17%
paper52,800 lbs
28%
scrap wood6,000 lbs
3%
cardboard9,600 lbs
5%
spent lead-acid batteries
N/A
used shop ragsN/A
used antifreeze1919 lbs
1%
tires47,600 lbs
26%
NON-RECYCLED WASTE STREAMS
106,469 lbs57%
RECYCLED WASTE
STREAMS79,519 lbs
Figure 3: Solid Waste Streams
D.) Air Emissions
All air emissions information is based on an Air Emission Inventory conducted in April 2002. The scope of this inventory included only Manchester and Concord NHARNG facilities. Following are descriptions of the air emission sources discussed in the inventory.
DISTILLATE OIL BOILERS
There are two dual-fired boilers located in the Manchester and four dual-fired boilers and two oil-fired boilers located in Concord. The dual-fired boilers burn either No. 2 (distillate) fuel oil or natural gas while the oil-fired boilers burn only No. 2 (distillate) fuel oil.
NATURAL GAS BOILERS/HEATERS
In addition to the dual-fired boilers and oil-fire boilers, there is a natural gas-fired hot water heater located in Manchester there are two natural gas-fired boilers, eleven natural gas heaters, and four natural gas hot water heaters located in Concord.
STATIONARY INTERNAL COMBUSTION ENGINES
Manchester only has one steam cleaner which is used occasionally to clean the floors of the OMS. Concord on the other hand has several stationary internal combustion engines which include an emergency generator at the AASF, a steam cleaner, an auxiliary ground powering unit, 5 helicopter heaters and a power washer.
WELDING OPERATIONS
Welding is performed on a periodic basis for repairing metal parts in both Manchester and Concord. Electric arc welding, metal inert gas (MIG) welding, tungsten inert gas (TIG) welding and oxygen-acetylene welding are performed using a variety of welding rods. In addition, oxygen-acetylene cutting and soldering are performed in Concord
WASTE OIL BOILER
Manchester has a used oil burner that is used to provide heat to the OMS building. This burner typically burns either used motor oil or used diesel fuel that is generated by the various OMSs throughout the state.
VEHICLE EXHAUST
The Manchester OMS and Concord CSMS and Annex are equipped with vehicle exhaust hoses that are placed on the tailpipes of the trucks to vent the exhaust fumes outside. In this case, these vehicles are acting as stationary sources. This emission category does not include the emissions from vehicles driving around the complex (mobile sources).
PAINTS AND SOLVENTS
Small painting operations occur throughout the Manchester and Concord NHARNG installations and typically include “spot” painting or touch-up operations, using aerosol spray cans, and/or brush painting. Solvents such as methanol and alcohols and spray cans containing other solvents are used as well. In addition, the Concord CSMS has a paint spray booth that is currently not being used do to ventilation deficiencies.
TANKS AND FUELING
Manchester has a 300 gallon used oil storage tank that is used in conjunction with the used oil burner and Concord has several aboveground fuel oil storage tanks in various locations reservation.
Table 5: Types and Sources of Air Emissions (tpy)
0.0000.2000.4000.6000.8001.0001.2001.4001.6001.800
2.000
Tons
Per
Yea
r
SOx NOx CO PM VOC's HAP's EmissionsType
Distillate Oil Boilers Waste Oil BoilerNatural Gas Boilers/Heaters Vechicle ExhaustStationary Internal Combustion Engines Paints and SolventsWelding Operations Tank and Fueling Emission
Figure 4: Air Emissions Sources
VII.) PROJECT RESULTS
Essentially the primary and most important result of this internship was the development of the P2 plan. Although the final draft of the P2 plan has not yet been completed, a copy of the rough draft can be found in the Appendices.
A.) Antifreeze Recycling Program Results
Although a particular antifreeze recycling program has not yet been chosen for implementation, it has been agreed upon by environmental office staff and shop chiefs alike that an antifreeze recycling program must be developed and implemented as an alternative to recycling through the DRMO for economic reasons.
i.) Current Antifreeze Recycling through DRMO
Recycling antifreeze through the DRMO costs NHARNG exorbitant amounts of money. The following rates are associated with the DRMO antifreeze recycling program:
$4.37/gallon to purchase new antifreeze through the military system
$12.14/gallon to recycle used antifreeze through the DRMO
$10.08/gallon to dispose of contaminated antifreeze not acceptable for recycle
Using 550 gallons (10 drums) as a basis for the amount of antifreeze used per year and the approximation that 58% of the used antifreeze will be contaminated1 and consequently not accepted by the DRMO for recycle the total annual cost and cost per gallon of purchasing and recycling/disposing of antifreeze were determined.
Total Annual Cost: $8,423.36
Average antifreeze cost: $15.32/gallon
Both on-site and off-site antifreeze recycling programs that were investigated proved to be highly cost effective in comparison to the current costs associated with DRMO recycling. The following sections discuss the results of the technical and economic evaluations of both the on-site and off-site antifreeze recycling programs.
ii.) On-site Antifreeze RecyclingTECHNICAL EVALUATION:
Antifreeze would be recycled using the BG Cool’r Clean’r Coolant Purification System, which already owned by NHARNG. A picture of this machine can be found in the Appendices. The recycling process begins with a settling step, in which the coolant settles for a period of time. This allows most of the oil to settle to the surface of the coolant and be removed with oil absorbing pads. This step is a modification to the manufacturer’s process that extends the life of the filters and resin.
1 Approximations are based on FY 2002 waste manifests.
The spent coolant is then filtered by a 15 micron, a 1 micron, and an activated charcoal filter. Two tanks of resin are then utilized to further purify the coolant. One tank targets cations, while the other targets anions. This removes dissolved metals or other charged material from the solution. A two part corrosion inhibitor is then added, as well as a KOH (potassium hydroxide) buffer solution to stabilize the pH. The freezing point is then tested using a refractometer, and new ethylene glycol (antifreeze) is added to lower the freezing point to the desired temperature. The following is a material flow diagram for the recycling process described above.
Figure 5: On-Site Antifreeze Recycling Process, Material Flow Diagram
As depicted in the material flow diagram above, the raw material inputs of this process include oil absorbent pads, filters, cation and anion resin, KOH buffer, inhibitor, and concentrated antifreeze. The wastes generated by this process include used oil absorbent pads, used filters, resin for regeneration, and unrecoverable antifreeze. The 15 and 1 micron filters can be dealt with in the same manner as regular oil filters, hot drained, crushed, and recycled for scrap metal. The used oil absorbent pads, charcoal filter, and unrecoverable antifreeze, which accounts for approximately 10% of the spent antifreeze fed into the process according to machine specification, must be disposed of as hazardous waste. The tanks of resin are regenerated by an approved facility. Currently, the closest facility approved by the manufacturer is in Maryland.
The major problem associated with this process is the accumulation of surplus recycled antifreeze, which was the cause of termination of the previous on-site antifreeze recycling program. The surplus is cause by the addition of concentrated antifreeze to lower the freezing point of the
recycled antifreeze. The amount of surplus generated varies depending upon the quality of the spent antifreeze being recycled.
ECONOMIC EVALUATION:Table 6: On-Site Cost Analysis
iii.) Off-site Antifreeze Recycling
Investigation of off-site antifreeze recycling opportunities focused primarily on one company, Advanced Liquid Recycling, Inc. Initially, all other potential companies were not able to meet the needs and/or requirements set for by NHARNG. However, new information regarding an antifreeze recycling partnership between Antifreeze Recycling of New England (ARNE) and New England Environmental Services (NEES) has proven to meet NHARNGs payment requirements, which had previously been the issue. Technical and economic evaluations of these off-site antifreeze recycling opportunities are discussed below.
iv.) Advanced Liquid Recycling, Inc. TECHNICAL EVALUATION:
Advanced Liquid Recycling, Inc (ALR) of Newington, NH works in conjunction with two other companies, United Industrial Services of Meriden, CT, and Consolidated Recycling of Troy, IN. These three companies function as a unit, each responsible for a particular step of the overall process. ALR serves as a holding facility for the used antifreeze, United Industrial Services provides the transportation, and Consolidated Recycling is the end destination of the antifreeze and the site where the actual recycling occurs. The diagram to the right illustrates the “cradle-to-grave” trail.
Although this recycling program utilizes three separate companies, NHARNG would only interact with ALR. Utilizing this program NHARNG would have two options:
1) purchase a premixed 50/50 blend of antifreeze from ALR and have equal amount taken for recycle at no additional cost
2) purchase concentrated antifreeze from ALR and have equal amount taken for recycle at no additional cost
Antifreeze that is already a 50/50 blend of ethylene glycol and water is ready to use without any mixing and would therefore be purchased more frequently than concentrate. Concentrated antifreeze would only be purchased occasionally according to specific need (i.e. - if a few vehicles need a more concentrated solution of antifreeze nearing the winter months).
In order for this recycling program to be utilized it would be necessary for NHARNG to have the National Guard Bureau (NGB) approve a waiver to use an alternative to the DRMO. Approval of a waiver requires audit information for all companies handling the NHARNG’s antifreeze. So far audit information has been received, however we’re still awaiting an environmental package from Consolidated Recycling Co. Inc which will contain specific information regarding their recycling procedures as well as permits and other documentation required to ensure compliance. In terms of
Advanced Liquid Advanced Liquid Recycling IncRecycling Inc
Newington, NHNewington, NH
United Industrial United Industrial Services IncServices IncMeriden, CTMeriden, CT
Consolidated Consolidated Recycling Co. Inc. Recycling Co. Inc.
Troy, INTroy, IN
NHARNGNHARNGConcordConcordLittletonLittleton
SomersworthSomersworthHillsboroHillsboro
ManchesterManchester
Advanced Liquid Advanced Liquid Recycling IncRecycling Inc
Newington, NHNewington, NH
United Industrial United Industrial Services IncServices IncMeriden, CTMeriden, CT
Consolidated Consolidated Recycling Co. Inc. Recycling Co. Inc.
Troy, INTroy, IN
NHARNGNHARNGConcordConcordLittletonLittleton
SomersworthSomersworthHillsboroHillsboro
ManchesterManchester
Figure 6: Off-Site Recycling "Cradle-to-Grave" Trail
their recycling procedures it is known that they recycle the antifreeze using a multi-stage system, and the steps employed in this system are:
Oil/Antifreeze Chemical Separation
Atmospheric Water Distillation\
Water/Ethylene Glycol Vacuum Distillation
Ethylene Glycol Concentrate Distillation
Ethylene Glycol Bottoms Evaporator
Salts Recovery and Re-Use System2
ECONOMIC EVALUATION:
The cost of off-site recycling with ALR offers an even larger savings over the current method than on-site recycling. Based on the approximation of 10 drums of antifreeze used per year, the following cost analysis has been developed for ALR’s antifreeze recycling program:
Table 7: ALR Off-site Cost Analysis
ALR will also remove waste antifreeze without the purchase of new antifreeze for a cost of $50.00 for the first 55 gallons (1 drum) removed and $0.65 for each additional gallon.
There are no implementation costs associated with this service. Recurring cost savings range between approximately $6,000 and $6,500 per year. This is an average cost savings of $11.72 per gallon (for purchase and disposal).
v.) ARNE and NEES PartnershipTECHNICAL EVALUATION
ARNE of Warner, NH works in conjunction with NEES of Smithfield, RI. ARNE functions as the transporter of the antifreeze, while NEES performs the actual recycling process. Initially in-depth research of this partnership was placed on hold due to the fact that ARNE does not accept credit cards, which is the only payment method acceptable for NHARNG to use based on the anticipated volume of antifreeze. However, recent information has yielded a compromise which will allow for this partnership to be utilized. The process will work as follows:
OMS International Merchant Purchase Authorization Card (IMPAC) cardholder will call ARNE to arrange for antifreeze pickup
2 List taken from Consolidated Recycling’s website: http://www.chem-group.com/consolidated.html
ARNE will swap recycled antifreeze for waste antifreeze drum for drum (minimum 1 drum at a time for Concord, Hillsboro, and Manchester and minimum 2 drums at a time for Littleton and Somersworth)
IMPAC cardholder will provide ARNE with credit card information and it will be included on the NEES invoice
NEES will process the payments3
Again, in order for this recycling program to be utilized it would be necessary for NHARNG to have the NGB approve a waiver to use this alternative to the DRMO. This does not pose any potential problems as NEES currently hold contracts with both RI and CT National Guards and has forwarded NHARNG copies of information regarding their business with them.
A “cradle-to-grave” diagram illustrating NEES’s recycling process was provided in their company’s brochure and can be summarized by the following steps:
1) Antifreeze is collected and transported in Department of Transportation (DOT) approved drums and totes
2) Antifreeze is remanufactured to O.E.M specifications and blended with Penray inhibitor
3) 50/50 premixed antifreeze is produced to service all fleets (Standard Green, Long Life, Red, and Heavy Duty)
ECONOMIC EVALUATION
Although off-site antifreeze recycling with ALR has already proven to be more cost effective than both the current recycling program through the DRMO and an on-site recycling program, ARNE has been found to provide the most cost effective recycling program.
ARNE will swap recycled antifreeze for waste antifreeze drum for drum for a total cost of $121.00 per drum. Based on the approximation of 10 drums of antifreeze used per year:
Total Annual Costs: $1,210
Average Antifreeze Cost: $2.20/gallon
In comparison with the current antifreeze recycling program through the DRMO, implementation of ARNE’s off-site antifreeze recycling program offers a potential recurring cost savings of approximately $7200.00 per year and an average cost savings of $13.12 per gallon.
vi.) Economic Analysis Summary
Based upon the economic analysis of both the potential on-site and off-site recycling programs, it is clear that an alternative to the DRMO antifreeze recycling program must be implemented. Implementing an alternative program could save the NHARNG as much as $7,200.00 per year and $13.12 per gallon of antifreeze (considering both purchasing and recycling) depending upon which
3 Wilber, Spencer. E-mail correspondence regarding Antifreeze Recycling, Friday, August 01, 2003
alternative program is chosen for implementation. The following charts illustrate the annual costs and savings of the on-site and off-site recycling programs in comparison with the current recycling program through the DRMO.
$-
$5,625.16$6,443.36
$7,213.36
$8,423.36
$2,798.20$1,980.00
$1,210.00
$-
$1,000.00
$2,000.00
$3,000.00
$4,000.00
$5,000.00
$6,000.00
$7,000.00
$8,000.00
Cos
ts/S
avin
gs p
er Y
ear
Recycling Method
Cost/Year $8,423.36 $2,798.20 $1,980.00 $1,210.00
Savings/Year $- $5,625.16 $6,443.36 $7,213.36
Current On-site Off-site with ALR Off-site with ARNE
Figure 7: Antifreeze Annual Cost/Savings Comparison
$-
$10.23 $11.72$13.12$15.32
$5.09$3.60
$2.20$-
$2.00
$4.00
$6.00
$8.00
$10.00
$12.00
$14.00
$16.00
Cos
t/Sav
ings
per
Gal
lon
Cost/Gallon $15.32 $5.09 $3.60 $2.20
Savings/Gallon $- $10.23 $11.72 $13.12
Current On-site Off-site with ALR Off-site with ARNE
Figure 8: Antifreeze Average Cost/Savings per Gallon Comparison
B.) Paper Recycling Programs Results
The implementation of a recycling program with Tobey School/Revamp is currently in progress. An initial meeting with Tobey School/Revamp has taken place and an awareness presentation and informative posters have been created. As soon as awareness has increased and participation by SMR staff has been guaranteed, this program will be ready for implementation. All that is required for this to being is a phone call to Tobey School/Revamp. Totes will then be delivered, and paper will be recycled.
TECHNICAL EVALUATION
An estimated 52,800 lbs of waste paper is generated annually and disposed of in the same manner are “regular” garbage (i.e. in dumpsters and transported to landfills or incinerators). Based on this estimate, recycling waste paper could potentially increase the percentage of solid waste diverted to recycle from 43% to 71%, which would place NHARNG far above the present goal required by the DoD. The potential impact of paper recycling is illustrated by the following chart.
Other Recycled Streams
79,519 lbs43%
Non-recycled Streams
53,669 lbs29%
Recycled Paper
52,800 lbs28%
Total RecycledStreams
132,319 lbs71%
Figure 9: Potential Impact of Paper Recycling
In order for this program to be successful absolute participation is required of all staff members working at the SMR. Participation is as simple as separating used paper into three categories, white office paper and envelopes, mixed colored paper and envelopes, and newspaper and magazines, and consciously placing it in the appropriate recycling bins. Different colored bins will be used to
indicate the appropriate type of paper to be place in that particular colored bin. In addition to small recycling bins, large recycling totes will utilized to collect the recycled paper from all the small recycling bins when they become full and must be emptied.
The distribution of large recycling totes in the various buildings on the SMR is given in the following table.
Table 8: Distribution of Recycling Bins
Building Number of Totes
Size (gal) Building Number
of TotesSize (gal)
USP&FO 1 75 Building B 1 75
Counterdrug 1 75 CSMS Annex 1 20
Building C 1 75 CSMS 1 75
Building T 4 95 AASF 1 20
Building 57 2 95 USP&FO Warehouse 2 95
Building F 1 95 Armory 1 95
ECONOMIC EVALUATION
Currently Tobey School/Revamp provides all the necessary large totes as well as their recycling services free of charge. All the small totes required to re-establish this program were purchased when paper recycling was previously implemented.
Implementation Costs: None.
Recurring Costs: None.
Recurring Cost Savings: Recurring cost savings are dependent upon the volume of paper that is diverted from the solid waste stream. The more paper recycled, the less contracted dumpsters needed for disposal.
Payback Period: Immediate
VIII.) FUTURE RECOMMENDATIONS
The recommendations that I would make for NHARNG arise directly from the difficulties encountered throughout the course of this internship. The most challenging aspect of writing the P2 plan for the NHARNG was collecting data, specifically quantities. Attempting to collect data was frustrating and often unrewarding, like not finding a pot of gold at the end of a rainbow. NHARNG records were very difficult and sometimes impossible to attain. Often direct contact to NHARNG contractors was the only affective means to acquire the necessary data. For instance, when researching the non-tactical fuel usage, NHARNG did not have any traceable internal records regarding the amount of fuel used or even the cost. GSA had to be directly contacted to ascertain this information. In situations where there were no records at all, very crude approximations were necessary to quantify certain waste streams, such as the amount of “regular” garbage generated annually.
In regards to these difficulties, my primary recommendation for NHARNG is to establish a set of procedures to ensure that records of the waste streams addressed in the P2 plan are kept up to date. This will enable NHARNG to recognize trends in their environmental practices and establish the necessary P2 programs to achieve their goals.
I would imagine that the future development of an Environmental Management System (EMS) will facilitate NHARNG’s endeavors. In conclusion, it is my hope that the P2 plan developed as a result of this internship will become a “living” document that is continuously referenced, updated, and allowed to grow as NHARNG improves their environmental practices through pollution prevention.
IX.) LIST OF CONTACTSEileen ChabotState Environmental SpecialistNHARNG – Environmental Office57 Regional DriveConcord, NH 03301Phone: 603-225-1211e-mail: [email protected]: Supervisor, office check-in, point of contact
MSG Richard LaFlammeEnvironmental Protection Specialist NHARNG – Environmental Office57 Regional DriveConcord, NH 03301Phone: 603-225-1333e-mail: [email protected]: office staff, TRI, EPA priority chemicals info
Mr. Jason WeaverETSSNHARNG – Environmental Office57 Regional DriveConcord, NH [email protected]: office staff, computer information
Ms. Muriel LajoieHazardous Waste ManagerNHARNG – Environmental Office57 Regional DriveConcord, NH [email protected]: office staff, hazardous waste info
Mr. Zachary BoyajinEnvironmental Program ManagerNHARNG – Environmental Office57 Regional DriveConcord, NH [email protected]: office staff, pesticide use
SPC Stephanie RobertsNHARNG-HQSMR Building F - DCISMConcord, NH 03301603-228-1135 [email protected]: ID cards
SPC Matthew DupuisNHARNG – USPFOState Military [email protected]: Computer logon, e-mail capabilities
SGT Roger [email protected]: AASF site contact
Ms. Karen HallenborgNHARNG – [email protected]: State Maintenance Shop Site Contact
1SG Kevin ReynoldsNHARNG – USPFO [email protected]: USPFO Warehouse Site Contact
SSG Randy DockhamNHARNG – OMS #2Littleton, [email protected]: OMS #2 Site Contact
MSG Mike DignardNHARNG – OMS #3Somersworth, [email protected]: OMS #3 Site Contact
CW2 Michael TkaczNHARNG – OMS #4Manchester, [email protected]: OMS #4 Site Contact
SFC Dennis MacKenzieNHARNG – OMS #5Hillsboro, NH603-464-0226
[email protected]: OMS #5 Site Contact
CW2 George SpauldingNHARNG – NHNGTS MgrCenter Strafford, [email protected]: NHARNG Training Site Contact
SFC Spence WilberNHARNG – USPFOConcord, [email protected]: Affirmative Procurement
MSG Jim MuhniskyJoint OperationSMR – Concord, NH(603) [email protected]
Dave NylundAir National Guard – Environmental ManagerPortsmouth, NH(603) [email protected]: Antifreeze Recycling
Colleen SchwalbeP2 Specialist – NHDESConcord, NH 03301(603) 271-0878Re: Contaminated Antifreeze
Tom Phenix Advanced Liquid Recycling, Inc.Newington, NH(603) 817-0591Re: Off-Site Antifreeze Recycling
Ken HermanKFM CorporationAnderson, SC [email protected]: On-Site Antifreeze Recycling
Judy ChenSMR – AccountingConcord, NH 03301(603) [email protected]: Dumpster contract
Linda McCormackSMR – AccountingConcord, NH [email protected]: Wastewater informationMAJ Wayne KreiensieckCSMS Foreman – CSMS, SMRConcord, NH 03301(603) 228-1135 [email protected]: CSMS Site Visit
CW4 Thomas LaPierreCSMS – SMRConcord, NH 03301(603) 228-1135 [email protected]: CSMS Site Visit
SGT Brian McKayAASF – SMRConcord, NH 03301(603) 228-1135 [email protected]: AASF Site Visit
LTC Daniel SaucierCSMS – SMRConcord, NH 03301(603) 228-1135 [email protected]: Antifreeze Recycling Presentation
CW2 David ClemonsCMSMSMR – Concord, NH(603) [email protected]
SFC Wesley RandCSMSSMR – Concord, NH(603) 228-1135 [email protected]
SFC Stephen DymentCSMSSMR – Concord, NH(603) 228-1135 [email protected]
Wanda KulaRevamp, Inc.Concord, NH(603) 228-5211
CW5 Richard PlanteUSPFO Purchasing & Contracting OfficeConcord, NH(603)[email protected]
Mr. Duane ValleeGSAHooksett, NH(603)666-7956Re: Non-tactical fuel usage
Tom PhoenixRegional RepresentativeAdvanced Liquid Recycling, Inc.Meriden, CT(800) [email protected]
Bill GreenJim WelchTerritory ManagerW. H. Shurtleff CompanySouth Portland, [email protected]
Mark LennonThe Institution Recycling NetworkConcord, [email protected]
Richard Smith Maintenance ManagerNHNGTS (603)228-1135, x4703Center Strafford, NHRE: Training Site Visit
X.) REFERENCES
1) Air Emissions Inventory and Air Toxics Compliance Determination: Concord and Manchester, New Hampshire submitted by AMEC Earth & Environmental Westford, Massachusetts April 2002.
2) Army Environmental Center, P2 Program, AP – http://aec.army.mil/usaec/p2/app00.html
3) Consolidated Recycling. http://www.chem-group.com/consolidated.html
4) Energy Audit of Army National Guard Facilities: State of New Hampshire, performed by AMEC Lakewood, Colorado July 2003.
5) Environmental Policy, 2 April 2003. John J. Weeden BG, NHARNG Assistant Adjutant General.
6) GSA Affirmative Procurement Program (3/18/03) http://www.gsa.gov/Portal/offerings_content.jsp?channelID=-13905&programID=10905
7) GSA Fleet Inventory, prepared by Duane Vallee July 16, 2003
8) Guide to Preparing Ozone-Depleting Chemical Elimination Plans for Installations prepared by Mr. David A. Koehler, Senior Pollution Prevention Engineer and Army ODC Elimination Project Manager Alexandria, Virginia. January 1999.
9) Johnson, Sarah. E-mail correspondence P2 Program Manager, NH DES
10) Luther, Robert. Email correspondence, NGB-ARE P2 Program Manager July 16, 2003
11) New Hampshire Army National Guard Ozone-Depleting Chemical Elimination Certification prepared by Roy F. Weston, inc. December 2000.
12) NHARNG-FM-EV Website – Pest Management Program
13) NHARNG FY03 Strategic Plan
14) NHARNG Waste Manifests CY 2000-2003
15) Wilber, Spencer. E-mail correspondence regarding Antifreeze Recycling, Friday, August 01, 2003
16) U.S. Environmental Protection Agency, Waste Minimization: Priority Chemicals http://www.epa.gov/epaoswer/hazwaste/minimize/chemilist.htm
XI.) APPENDICES
A.) NHARNG P2 Equipment
Figure 10: Antifreeze Recycling Machine
NHARNG owns one Antifreeze Recycling Machine which resides at the CSMS.
Figure 11: Aqueous Parts Washer (inside)
All maintenance shops are equipped with Aqueous Parts Washers.
Figure 12: Secondary Containment Area
Only Littleton OMS #2 and Hillsboro OMS #5 are currently equipped with secondary containment area for storage of their fueling truck tanks.
Figure 13: Filter Crusher
All maintenance shops are equipped with Filter Crushers, with the exception of Hillsboro OMS #5.
Figure 14: Aerosol Can Puncturing Machine
All maintenance shops are equipped with Aerosol Can Puncturing Machines.
B.) Site Visit Checklist
C.) Paper Recycling Awareness Poster
