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New Hampshire Army National Guard (nharng) Pollution Prevention (P2) Plan Summer 2003


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New Hampshire Army National Guard (NHARNG)

Pollution Prevention (P2) Plan

Summer 2003


Shelley Dougherty

University of New Hampshire

P2 Intern

(207)384-4227

NHARNG


Environmental Office

57 Regional Dr.

Concord NH, 03301

Mrs. Eileen Chabot

NHARNG Environmental Office

Environmental Specialist

(603)225-1211

Table of Contents


New Hampshire Army National Guard (NHARNG) 1

Pollution Prevention (P2) Plan 1

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




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.

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