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


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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)





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 Recycling

Technical 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. 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:


A
Figure 6: Off-Site Recycling "Cradle-to-Grave" Trail
dvanced 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 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 Partnership

technical 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

  • 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 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.



Figure 7: Antifreeze Annual Cost/Savings Comparison



Figure 8: Antifreeze Average Cost/Savings per Gallon Comparison

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