New Hampshire Army National Guard (NHARNG)
Pollution Prevention (P2) Plan
University of New Hampshire
57 Regional Dr.
Concord NH, 03301
Mrs. Eileen Chabot
NHARNG Environmental Office
Table of Contents
New Hampshire Army National Guard (NHARNG) 1
Pollution Prevention (P2) Plan 1
Summer 2003 1
Table of Contents 5
Table of Figures 5
List of Acronyms 7
I.) Executive Summary 9
II.) Introduction 9
III.) Goals and Objectives 12
IV.) Approach 12
V.) Chemical Usage 17
VI.) Releases/Wastes Generated 20
VII.) Project Results 27
VIII.) Future Recommendations 36
IX.) List of Contacts 38
X.) references 41
XI.) Appendices 43
Table of Figures
Figure 1: Hazardous Waste Contamination 20
Figure 2: Type and Quantity of Batteries Disposed 21
Figure 3: Solid Waste Streams 25
Figure 4: Air Emissions Sources 27
Figure 5: On-Site Antifreeze Recycling Process, Material Flow Diagram 29
Figure 6: Off-Site Recycling "Cradle-to-Grave" Trail 31
Figure 7: Antifreeze Annual Cost/Savings Comparison 34
Figure 8: Antifreeze Average Cost/Savings per Gallon Comparison 34
Figure 9: Potential Impact of Paper Recycling 35
Figure 10: Antifreeze Recycling Machine 45
Figure 11: Aqueous Parts Washer (inside) 45
Figure 12: Secondary Containment Area 45
Figure 13: Filter Crusher 45
Figure 14: Aerosol Can Puncturing Machine 46
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
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.
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.