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

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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.

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.


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 Streams

i.)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.


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.


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.

Figure 3: Solid Waste Streams
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