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


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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 Plan

i.)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.

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