UNH & NHPPP Michael O’Connor Shelley Dougherty
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UNH & NHPPP Michael O’Connor Shelley Dougherty New Hampshire Army National Guard Pollution Prevention (P2 Plan October, 2003 Signature Page This Pollution Prevention (P2) Plan meets the provisions of E.O. 13148, and was written in accordance with requirements set forth by the Department of the Army and the National Guard Bureau Environmental Program (NGB-ARE) using the “Guidance for Developing Army Pollution Prevention Plans” template. Approving Officials Date ___________________________ JOHN E.BLAIR, Major General THE ADJUTANT GENERAL New Hampshire National Guard ________ ___________________________ STEPHEN C. BURRITT, Colonel Director of Installations Management New Hampshire Army National Guard ________ ___________________________ Eileen F. Chabot State Environmental Specialist / P2 Manager New Hampshire Army National Guard ________ ___________________________ Shelley Dougherty, Co-Author Intern - NH Pollution Prevention Partnership University of New Hampshire ________ ___________________________ Michael O'Connor, Co-Author Intern - NH Pollution Prevention Partnership University of New Hampshire ________ Michael O'Connor Page 4 UNH & NHPPP P2 Internship Program Shelley Dougherty TABLE OF CONTENTS P2 GOALS SUMMARY TABLE ................................................................................................. 9 P2 INITIATIVES SUMMARY TABLE .................................................................................... 10 LIST OF ACRONYMS ............................................................................................................... 11 CHAPTER 1: INTRODUCTION .............................................................................................. 12 1.1 STATEMENT OF PURPOSE ...........................................................................................................12 1.2 INSTALLATION LOCATION, BACKGROUND, AND MISSION ...............................................12 1.2.1 State Military Reservation.........................................................................................................12 1.2.2 NHNGTS ...................................................................................................................................14 1.2.3 Littleton OMS #2 .......................................................................................................................14 1.2.4 Somersworth OMS #3 ...............................................................................................................14 1.2.5 Manchester OMS #4 ..................................................................................................................15 1.2.6 Hillsboro OMS #5 .....................................................................................................................15 1.3 DEFINITION OF POLLUTION PREVENTION .............................................................................15 1.4 BENEFITS OF POLLUTION PREVENTION .................................................................................16 CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND ............... 18 2.1 ARMY REGULATIONS ..................................................................................................................18 2.1.1 AR 200-1 ...................................................................................................................................18 2.1.2 Army Pamphlet Pam 200-1 .......................................................................................................18 2.2 FEDERAL LEGISLATION ..............................................................................................................18 2.2.1 Resource Conservation and Recovery Act (RCRA) of 1976. .....................................................18 2.2.2 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. ..............................................................................................................................................................19 2.2.3 Hazardous and Solid Waste Amendments (HSWA) of 1984 ......................................................19 2.2.4 Pollution Prevention Act (PPA) of 1990 ...................................................................................19 2.3 STATE POLLUTION PREVENTION LEGISLATION ...................................................................19 2.3.1 Air Quality ................................................................................................................................19 2.3.2 Water .........................................................................................................................................20 2.3.3 Hazardous Materials .................................................................................................................20 2.4 PRESIDENTIAL EXECUTIVE ORDERS .......................................................................................21 2.4.1 EO 13101 ..................................................................................................................................21 2.4.2 EO 13123 ..................................................................................................................................22 2.4.3 EO 13148 ..................................................................................................................................23 2.4.4 EO 13149 ..................................................................................................................................23 2.4.5 EO 13221 ..................................................................................................................................24 2.5 DOD DIRECTIVES AND INSTRUCTIONS ...................................................................................24 2.5.1 DOD Instruction 4715.4, “Pollution Prevention,” June 1996..................................................24 2.5.2 Department of Army (DOA) Memorandum, Ozone-Depleting Chemicals (ODCs) Elimination at Army Installations, February 1996 ...........................................................................................................25 2.5.3 DOD Memorandum, “New DOD P2 Measure of Merit (MOM),” May 1998 ..........................25 2.5.4 Memorandum, Assistant Secretary for Installations, Logistics, and Environment, “ODC Elimination at Army Installations,” 13 February 1996.................................................................................25 2.5.5 DOA Memorandum, Revised Clean Water Act MOM, May 1998 .............................................25 2.5.6 “Proposed Revisions to DOD Solid Waste Measures of Merit,” April 2002 ............................25 2.5.7 DOA Memorandum, Call for Calendar Year (CY) 2001 TRI Form Data, July 2002................26 Michael O'Connor Page 5 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 2.5.8 Affirmative Procurement Program (APP) Metrics ....................................................................26 CHAPTER 3: NHARNG POLLUTION PREVENTION PROGRAM .................................. 28 3.1 POLICY .............................................................................................................................................28 3.2 POLLUTION PREVENTION MANAGEMENT STRUCTURE .....................................................28 3.3 BASELINE DEVELOPMENT ..........................................................................................................29 3.4 POLLUTION PREVENTION GOALS .............................................................................................29 3.5 OPPORTUNITY ASSESSEMENTS.................................................................................................29 3.6 IMPLEMENTATION AND EVALUATION ...................................................................................30 3.7 P2 PROGRAM FUNDING ...............................................................................................................30 CHAPTER 4: COMPLIANCE THROUGH POLLUTION PREVENTION ........................ 32 4.1 DESCRIPTION OF COMPLIANCE THROUGH P2 .......................................................................32 4.2 COMPLIANCE SITES ......................................................................................................................32 4.2.1 Hazardous Waste Storage and/or Treatment Areas ..................................................................32 4.2.2 Air Emissions Sources ...............................................................................................................32 4.2.3 Solid Waste Facilities ................................................................................................................32 4.2.4 Storage Tanks ............................................................................................................................32 4.2.5 Waste Water Sites ......................................................................................................................33 4.2.6 Stormwater ................................................................................................................................33 4.2.7 Drinking Water Sites .................................................................................................................33 4.2.8 Pesticide Application Sites ........................................................................................................33 4.3 COMPLIANCE THRESHOLDS.......................................................................................................34 4.3.1 Hazardous Waste Generation ...................................................................................................34 4.3.2 TRI Form R Reporting ..............................................................................................................34 4.3.3 EPA Priority Chemical Use ......................................................................................................34 4.3.4 Pesticide Usage .........................................................................................................................35 CHAPTER 5: WASTE GENERATING PROCESSES ........................................................... 36 5.1 DESCRIPTIONS ...............................................................................................................................36 5.2 MATERIAL INPUTS AND WASTE STREAMS ............................................................................37 CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE ................................................... 45 6.1 GOALS ..............................................................................................................................................45 6.2 BASELINE AND PROGRESS .........................................................................................................45 6.3 MAJOR HAZARDOUS WASTE STREAMS ..................................................................................45 6.4 MAJOR UNIVERSAL WASTE STREAMS ....................................................................................48 6.5 ENERGY RECOVERY STREAMS .................................................................................................48 6.6 CURRENT P2 INITIATIVES ...........................................................................................................48 6.6.1 Antifreeze ..................................................................................................................................48 6.6.2 Aerosol Cans .............................................................................................................................48 6.6.3 Aqueous Parts Washers.............................................................................................................48 6.6.4 Oil Filters ..................................................................................................................................48 6.6.5 Oil-Water Separators ................................................................................................................48 6.6.6 Secondary Containment Areas ..................................................................................................49 6.6.7 Used Oil Burners ......................................................................................................................49 6.7 POTENTIAL P2 INITIATIVES ........................................................................................................49 6.7.1 Antifreeze ..................................................................................................................................49 Michael O'Connor Page 6 UNH & NHPPP P2 Internship Program Shelley Dougherty TABLE OF CONTENTS 6.7.2 Product Replacement ................................................................................................................57 CHAPTER 7: SOLID WASTE .................................................................................................. 59 7.1 GOALS ..............................................................................................................................................59 7.2 BASELINE AND PROGRESS .........................................................................................................59 7.3 MAJOR SOLID WASTE STREAMS ...............................................................................................59 7.3.1 Recycled Waste Streams ............................................................................................................60 7.3.2 Non-Recycled Waste Streams ....................................................................................................61 7.4 CURRENT P2 INITIATIVES ...........................................................................................................65 7.4.1 Scrap Metal Recycling ..............................................................................................................65 7.4.2 Shop Rag Laundering with Alltex..............................................................................................65 7.4.3 One for One Battery Exchange with Exide ...............................................................................65 7.5 POTENTIAL P2 INITIATIVES ........................................................................................................66 7.5.1 Paper Recycling with Tobey School/Revamp Inc. .....................................................................66 7.5.2 Scrap Wood Recycling ..............................................................................................................67 7.5.3 Rechargeable Batteries .............................................................................................................67 CHAPTER 8: AIR EMISSIONS................................................................................................ 69 8.1 GOALS ..............................................................................................................................................69 8.2 BASELINE AND PROGRESS .........................................................................................................69 8.3 MAJOR AIR EMISSIONS SOURCES .............................................................................................69 8.3.1 Manchester NHARNG Installation Emissions Sources .............................................................69 8.3.2 SMR Emission Sources ..............................................................................................................70 8.4 POTENTIAL P2 INITIATIVES ........................................................................................................73 8.4.1 Alternative “Environmentally Friendly” Paints and Solvents ..................................................73 CHAPTER 9: WATER AND WASTEWATER ....................................................................... 75 9.1 GOALS ..............................................................................................................................................75 9.2 BASELINE AND PROGRESS .........................................................................................................75 9.3 CURRENT P2 INITIATIVES ...........................................................................................................75 9.4 POTENTIAL P2 INITIATIVES ........................................................................................................75 CHAPTER 10: EPA PRIORITY CHEMICAL REDUCTION AND TRI FORM R REPORTING ............................................................................................................................... 77 10.1 EPA PRIORITY CHEMICALS ......................................................................................................77 10.1.1 GOAL ......................................................................................................................................77 10.1.2 BASELINE AND PROGRESS .................................................................................................77 10.2 TRI FORM R REPORTING............................................................................................................77 10.2.1 Goal.........................................................................................................................................77 10.2.2 Baseline and Progress.............................................................................................................77 CHAPTER 11: OZONE DEPLETING SUBSTANCES .......................................................... 79 11.1 GOAL ..............................................................................................................................................79 11.2 BASELINE AND PROGRESS .......................................................................................................79 11.3 DESCRIPTION OF ODS-CONTAINING EQUIPMENT ..............................................................79 11.4 CURRENT P2 INITIATIVES .........................................................................................................81 11.5 POTENTIAL P2 INITIATIVES ......................................................................................................81 11.5.1 Research ..................................................................................................................................81 Michael O'Connor Page 7 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan CHAPTER 12: VEHICLE FUEL CONSERVATION............................................................. 83 12.1 GOALS ............................................................................................................................................83 12.2 BASELINES AND PROGRESS .....................................................................................................83 12.3 CURRENT P2 INITIATIVES .........................................................................................................84 12.4 POTENTIAL P2 INITIATIVES ......................................................................................................85 12.4.1 Coordinated Site Visits ............................................................................................................85 CHAPTER 13: ENERGY CONSERVATION.......................................................................... 87 13.1 GOAL ..............................................................................................................................................87 13.2 BASELINE AND PROGRESS .......................................................................................................87 13.3 ENERGY ASSESSMENT SUMMARY .........................................................................................88 13.4 POTENTIAL P2 INITIATIVES ......................................................................................................88 CHAPTER 14: AFFIRMATIVE PROCUREMENT ............................................................... 93 14.1 BACKGROUND .............................................................................................................................93 14.2 CURRENT STATUS .......................................................................................................................93 14.3 POTENTIAL EXPANSION ............................................................................................................93 14.3.1 Authorized Use List (AUL) ......................................................................................................93 APPENDIX I: EPA WASTE MINIMIZATION PRIORITY CHEMICALS ........................ 95 APPENDIX II: NHARNG HAZARDOUS MATERIALS INVENTORY ............................. 97 APPENDIX III: PERMITS ...................................................................................................... 101 A.) OIL-WATER SEPARATOR PERMITS .........................................................................................101 B.) STORMWATER PERMITS............................................................................................................101 C.) UNDERGROUND STORAGE TANK PERMITS .........................................................................101 D.) GENERATOR (SICE) PERMITS ...................................................................................................101 APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE ..................................................................................................................................................... 119 A.) POLLUTION PREVENTION ASSESSMENT TEAM ..................................................................119 i.) PPAT Responsibilities and Members ...........................................................................................119 B.) CONDUCTING THE PPOA ...........................................................................................................120 i.) Selecting a Process or Activity for Evaluation ............................................................................120 i.) Identify P2 Alternatives ...............................................................................................................125 ii.) Select P2 Alternatives .................................................................................................................125 C) IMPLEMENTING THE SELECTED P2 ALTERNATIVES ..........................................................127 D) POSSIBLE BARRIERS PROHIBITING IMPLEMENTATION ....................................................127 E) DEFINITIONS ..................................................................................................................................133 Michael O'Connor Page 8 UNH & NHPPP P2 Internship Program Shelley Dougherty P2 GOALS SUMMARY TABLE Source of Goal Media Goal Hazardous Waste Continuous Annual Reduction Solid Waste Diversion of 40% of waste stream to recycle Air Emissions 10% Reduction Water Use Continuous annual reduction DOD Measure of Merit DOD Measure of Merit NHARNG Air Emissions Inventory N/A Baseline Year Target Year 2003 N/A 2003 2005 2002 2005 2003 N/A Wastewater Generation TRI Releases Not Yet Developed --- --- --- 50% Reduction overall, or 10% per year EO 13148 2001 2006 EPA Priority Chemicals 50% Reduction EO 13148 2000 2006 ODSs Eliminate Class I ODSs EO 13148 N/A 2010 Increase fleet fuel efficiency by 3 miles per gallon EO 13149 1999 2005 Reduce vehicle petroleum consumption by 20% EO 13149 1999 2005 Ensure that alternative fuels account for 50% of fuels used in dual-fuel vehicles EO 13149 2000 N/A Ensure that 75% of vehicles procured in the target year and beyond are alternative fuel vehicles EO 13149 2000 N/A Reduce facility energy consumption by 30% EO 13123 1985 2005 Reduce facility energy consumption by an additional 5% (from 30% to 35%) EO 13123 2005 2010 Train procurement officers and integrate AP into developing plans, work statements, and specifications EO 13101 1998 N/A Vehicle Fuel Energy Affirmative Procurement Michael O'Connor Page 9 Shelley Dougherty UNH & NHPPP P2 Internship Program P2 INITIATIVES SUMMARY TABLE Project Name Targeted Pollution Source Implementation Status Aerosol Can Crushing Hazardous Waste Fully Implemented Aqueous Parts Washing Fully Implemented 1995 6.6.3 Oil Filter Draining/Crushing Hazardous Waste Air Emissions Hazardous Waste Fully Implemented 1995 6.6.4 Oil-water Separators Wastewater Fully Implemented 1995 6.6.5 Secondary Containment Areas Stormwater Contamination Partially Implemented 1996 6.6.6 Used Oil Burner Hazardous Waste Fully Implemented 1996 6.6.7 Authorized Use List All Inclusive Pursuing Funding 2004 14.3.1 Exide Battery Recycling Hazardous Waste Fully Implemented 2002 7.4.3 Alltex Shop Rags Laundering Service Fully Implemented 1994 7.4.2 Scrap metal Recycling Hazardous Waste Solid Waste Solid Waste Fully Implemented 1995 7.4.1 Antifreeze Recycling Hazardous Waste In Progress 2004 6.7.1 Paper Recycling with Tobey School/Revamp Solid Waste In Progress 2004 7.5.1 Scrap Wood Recycling Solid Waste 2004 7.5.2 Rechargeable Batteries Solid Waste Requires Further Investigation Requires Further Investigation 2004 7.5.3 Tires Solid Waste Michael O'Connor Implementation Date Fully Implemented Page 10 UNH & NHPPP P2 Internship Program Shelley Dougherty Funding Source P2 Plan Section EPR 6.6.2 LIST OF ACRONYMS AAL Ambient Air Limit AASF Army Aviation Support Facility AFV Alternative Fueled Vehicle ALR Advanced Liquid Recycling, Inc. APP Affirmative Procurement Program AR Army Regulation ARNE Antifreeze Recycling of New England AUL Authorized Use List BMP Best Management Practice BTRY Battery C&D Construction and Demolition CERCLA CLP INF Infantry MACOM Major Army Commands MOM Measure of Merit MRE Meal Ready to Eat MNT Mountain NBC Nuclear, Biological, and Chemical NEES New England Environmental Services NGB National Guard Bureau NHARNG New Hampshire Army National Guard NHDES New Hampshire Department of Environmental Services Comprehensive Environmental Response, Compensation, and Liability Act NHNGTS New Hampshire National Guard Training Site Cleaning, Lubricating, and Penetrating Fluid ODC Ozone Depleting Chemical ODS Ozone Depleting Substance OMS Organizational Maintenance Shops P2 Pollution Prevention PBT Persistent, bio-accumulative, and toxic PPA Pollution Prevention Act PPAT Pollution Prevention Assessment Team PPOA Pollution Prevention Opportunity Assessment CoS Chief of Staff CSMS Combined Support Maintenance Shop CWA Clean Water Act CY Calendar Year DOA Department of the Army DOD Department of Defense DOIM DRMO Defense Reutilization and Marketing Office RCRA Resource Conservation and Recovery Act EO Executive Order RTAP Regulated Toxic Air Pollutant EQCC Environmental Quality Control Committee SICE Stationary Internal Combustion Engine EPA Environmental Protection Agency SMS State Maintenance Shop EPCRA Emergency Planning and Community Right-to-Know Act SMR State Military Reservation SSM State Safety Manager FY Fiscal Year TAG The Adjutant General HHB Higher Headquarters Battery TRI Toxics Release Inventory HQ Headquarters USP&FO United States Property and Fiscal Office HSWA Hazardous and Solid Waste Amendments UTES Unit Training Equipment Site IMPAC International Merchant Purchase Authorization Card VOC Volatile Organic Compound Michael O'Connor Page 11 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 1: INTRODUCTION 1.1 STATEMENT OF PURPOSE This Pollution Prevention Plan outlines the New Hampshire Army National Guard (NHARNG)’s commitment to pollution prevention (P2) by outlining practices and initiatives necessary to reduce the release of pollutants and decrease the use of hazardous materials. As a part of the government, the military is subject to increased public interest regarding its actions and policies. As such, the military has the responsibility to lead by example in pollution prevention practices. This Plan is designed to be utilized by the NHARNG for the documentation, implementation, tracking, and management of its pollution prevention efforts. This will help guide the NHARNG in achieving pollution prevention goals. 1.2 INSTALLATION LOCATION, BACKGROUND, AND MISSION The mission of the NHARNG is “to provide mission capable units to support the National Military Strategy and designated federal missions; respond as needed to state and local emergencies; add value to our communities in which we live, work, and serve.”1 This section outlines the location and function of the State Military Reservation, New Hampshire National Guard Training Site (NHNGTS) and Organizational Maintenance Shops (OMSs) in New Hampshire. 1.2.1 STATE MILITARY RESERVATION The State Military Reservation (SMR) is located at 4 Pembroke Road at the intersection of Pembroke Road and Airport Road in the city of Concord, Merrimack County. The SMR, which serves as the headquarters for the New Hampshire Army National Guard, occupies approximately 43 acres and employs roughly 230 state and federal personnel. Activities conducted at the various shops located at the SMR include the maintenance and repair of tactical vehicles, field artillery equipment, construction equipment, and Blackhawk (UH-60) helicopters and the dispensing of JP-8 fuel. The facilities where these activities are conducted include the Combined Support Maintenance Shop (CSMS); the CSMS Annex (formerly OMS #1); the Army Aviation Support Facility (AASF); the United States Property & Fiscal Office (USP&FO) Warehouse; and the State Maintenance Shop. 1 NHARNG FY03 Strategic Plan Michael O'Connor Page 12 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 1: INTRODUCTION CSMS Major vehicle maintenance and repair activities including engine and drive train servicing and replacement are performed at the CSMS. Tactical vehicles and field artillery and equipment are occasionally painted in a paint booth within the CSMS. The paint booth has been closed for the past two years due to ventilation and safety deficiencies. NHARNG plans to correct these deficiencies in FY 04. All maintenance, repair, painting, and vehicle washing activities conducted at the CSMS are performed indoors. Figure 1.1: Mechanic at work in the CSMS CSMS Annex Maintenance practices performed at the CSMS Annex include fluid and filter changes, parts cleaning and replacement, brake servicing, preventative maintenance and vehicle washing. All maintenance, repair, painting, and vehicle washing activities conducted at the CSMS Annex are performed indoors. AASF The Army Aviation Support Facility provides overall supervision, personnel administration and administrative support to aviation units within the state of New Hampshire. It also performs Aviation Unit Level Maintenance and limited Aviation Intermediate Level Maintenance on organic UH-60 Blackhawk helicopters. Provides training and standardization for aviation personnel and administers aviation safety programs. It provides aviation support to the State as required by the Adjutant General to include response to State emergencies. The existing Figure 1.2: Blackhawk at the AASF AASF located on the SMR will become the new Joint Forces Headquarters Readiness Center for the New Hampshire Army and Air National Guard, which will house administrative offices and several units upon the completion of the new AASF currently being constructed on Regional Drive. The new AASF is planned to be completed by spring of FY 2004. The new facility will perform and provide the same operations as the existing AASF. However, it will also have designated bays to store the Blackhawk helicopters inside the building. Michael O'Connor Page 13 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan USP&FO Warehouse The USP&FO Warehouse acquires, manages, and distributes logistical resources in support of federal and State missions. The primary activity conducted at the USP&FO warehouse includes the loading and unloading of trucks. Items customarily loaded and unloaded include military and maintenance supplies, parts, clothing, office supplies and hazardous materials. State Maintenance Shop Activities conducted at the State Maintenance Shop consist of the servicing of tractors and lawnmowers used by state maintenance personnel, minor woodworking, storage of state supplies for NHARNG’s armories, and the refueling of state equipment and vehicles with gasoline and diesel fuel. 1.2.2 NHNGTS NHNGTS is located on Route 126 in Center Strafford, Strafford County. It houses the Regional Training Institute (RTI) which conducts training courses for commissioned and non-commissioned officers. NHNGTS occupies approximately 100 acres. NHARNG is looking to acquire an additional 500 acres adjacent to the current site to meet its training mission. 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. Limited classroom and billeting functions associated with basic, advanced, and continuing training operations take place at the training site. 1.2.3 LITTLETON OMS #2 OMS #2 is located at 140 West Main Street in the town of Littleton, Grafton County. OMS #2 occupies approximately 20 acres. This shop services all of the 2nd Battalion. including HHS, A, B, and C batteries (BTRY). Activities conducted at the shop include the maintenance and repair of military tactical vehicles, field artillery equipment and processing of requests for repair or service of communications and electronics equipment. Maintenance practices performed at OMS #2 include fluid, battery, and filter changes, parts cleaning and replacement, brake servicing, preventative maintenance, and vehicle washing. All maintenance, repair, and vehicle washing activities conducted at OMS #2 are performed indoors. 1.2.4 SOMERSWORTH OMS #3 OMS #3 is located at 15 Blackwater Road in the city of Somersworth, Strafford County. OMS #3 occupies approximately 6 acres and employs four personnel. This shop services 5 units, the C BTRY 1/172 FA, HQ 195th Regiment, 744th Transportation Company Detachment 2, NHNGTS, and OMS #3. Activities conducted at the shop include the maintenance and repair of military tactical vehicles and field artillery equipment, and processing requests for repair or Figure 1.3: Somersworth OMS Michael O'Connor Page 14 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 1: INTRODUCTION service of communications and electronics equipment. Maintenance practices performed at OMS #3 include fluid, battery, and filter changes, parts cleaning and replacement, brake servicing, preventative maintenance and vehicle washing. All maintenance, repair, and vehicle washing activities conducted at OMS #3 are performed indoors. 1.2.5 MANCHESTER OMS #4 OMS #4 is located at 1059 Canal Street in the city of Manchester, Hillsborough County. OMS #4 occupies approximately 8 acres and employs five personnel. This shop services 6 units, the Higher Headquarters Brigade, 197th FA Brigade, HHS 1/172nd FA Battalion, A and B BTRY 1/172nd, 39th Army Band, and 114th PAD. Activities conducted at the shop include the maintenance and repair of military tactical vehicles and field artillery equipment, and processing requests for repair or service of communications and electronics equipment. Maintenance practices performed at OMS #4 include fluid, battery, and filter changes, parts cleaning and replacement, brake servicing, preventative maintenance and vehicle washing. All maintenance, repair, and vehicle washing activities conducted at OMS #4 are performed indoors. 1.2.6 HILLSBORO OMS #5 OMS #5 is located at 140 West Main Street in the town of Hillsboro, Hillsborough County. OMS #5 occupies approximately 8 acres and employs nine personnel. This shop services the 744th Transportation Company, the 210th Engineers Detachment, and the C Company 3/172 INF (MTN). Activities conducted at the shop include the maintenance and repair of military tactical vehicles, field artillery equipment, and processing of requests for repair or service of communications and electronics equipment. Maintenance practices performed at OMS #5 include fluid, battery, and filter changes, parts cleaning and replacement, brake servicing, preventative maintenance and vehicle washing. All maintenance, repair, and vehicle washing activities conducted at OMS #5 are performed indoors. 1.3 DEFINITION OF POLLUTION PREVENTION Pollution prevention focuses primarily on process adaptability rather than “end of the pipe” or stack treatments. It is the use of materials or practices that reduce or eliminate both hazardous or toxic pollutants and non-hazardous wastes released to the environment. In cases where source reduction is not feasible, waste minimization is achieved through the reuse or recycling of materials. Reuse is defined as the “use of a material at least twice, without changing its original form” and recycling is defined as the “collection, separation and recovery of materials which cannot be directly reused or would otherwise be discarded as waste.” Reuse can take many forms. Direct reuse is when a material is captured and reintroduced into the original process. Indirect reuse when a product is captured and introduced into another process. Recycling can be accomplished on-site, off-site by an outside entity, or can be utilized by another company or organization in a waste exchange program. These examples show some of the methods by which waste minimization practices can help reduce pollution. Michael O'Connor Page 15 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Pollution prevention is implemented through P2 projects which successfully and cost-effectively prevent or reduce pollution from an installation’s processes, operations, and other routine activities by utilizing methods of source reduction, reuse, or recycling. 1.4 BENEFITS OF POLLUTION PREVENTION As concern for the environment has risen in our society, increased environmental regulation and public awareness have raised the standards, costs, and potential liabilities of waste management practices. Waste and resource management programs that adopt P2 principles can realize benefits on many different fronts: Reduced costs associated with the procurement and storage of hazardous materials and subsequent disposal of hazardous waste Reduced costs associated with the management, treatment, and disposal of hazardous wastes Decreased use of energy and water resources Enhanced relations with the public, neighboring communities, and regulators Reduced costs of complying with environmental and hazardous materials regulations, and diminished risk of non-compliance Reduced future compliance liability Improved long-term environmental quality and prevention of environmental degradation Michael O'Connor Page 16 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 1: INTRODUCTION Michael O'Connor Page 17 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND The Army’s pollution prevention policies originate in legislation enacted by the U.S. Congress. Executive Orders (EOs) direct federal agencies, including the Department of Defense (DOD), to conform to Federal legislation and may impose non-legislated requirements as well. The DOD issues directives and instructions in response to the EOs. These DOD policy statements are interpreted and promulgated in Army Regulations (ARs), pamphlets, and other policy documents. In addition, Major Army Commands (MACOMs), Major Subordinate Commands, and individual installations may adopt supplemental policies. This section provides summaries of the major laws, EOs, and DOD policy statements pertaining to pollution prevention. Due to the wide-reaching nature of P2 issues and frequent changes to laws and regulations, the list is not intended to be allinclusive. 2.1 ARMY REGULATIONS 2.1.1 AR 200-1 Environmental Quality: Environmental Protection and Enhancement 1997 (Revision) AR 200-1 prescribes responsibilities, policies, and procedures for preserving, protecting, and restring the quality of the environment. It prescribes the Army’s policies for hazardous waste minimization and requires Army installations to reduce the quantity or volume and the toxicity of hazardous wastes whenever economically practical or environmentally necessary. 2.1.2 ARMY PAMPHLET PAM 200-1 Environmental Protection and Enhancement, January 2002 Army Pamphlet Pam 200-1 provides detailed guidance to support implementation of AR 200-1 to include: water resources management, oil and hazardous substances spills, hazardous materials management, hazardous and solid waste management, air pollution, environmental noise management, asbestos management, radon reduction, P2, environmental restoration, environmental quality technology, automated environmental management systems, the Army environmental program in foreign countries, and other miscellaneous topics. 2.2 FEDERAL LEGISLATION 2.2.1 RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) OF 1976. An early legal impetus for P2 practices. “...It shall be a condition of any permit issued under this section for the treatment, storage, or disposal of hazardous waste on the premises where such waste was generated that the permit holder certify, no less often than annually, that the generator of the hazardous waste has a program in place to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be economically practicable.” Michael O'Connor Page 18 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND 2.2.2 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT (CERCLA) OF 1980. This act required that generators of hazardous wastes must evaluate and document their procedures for controlling the environmental impacts of their operations. 2.2.3 HAZARDOUS AND SOLID WASTE AMENDMENTS (HSWA) OF 1984 This act required all RCRA-regulated generators of hazardous waste to develop waste minimization programs. 2.2.4 POLLUTION PREVENTION ACT (PPA) OF 1990 The Federal PPA became a law on 5 November 1990. The PPA is summarized below. Prevent or reduce pollution at the source level whenever feasible, Promote recycling if waste generation cannot be prevented, Permit treatment if waste cannot be prevented or recycling cannot be implemented, and Discourage disposal or other releases into the environment. The applicability of the PPA is not limited to hazardous waste or chemicals subject to the Toxics Release Inventory (TRI) reporting required by Section 131 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). The PPA encompasses all hazardous substances, pollutants, or contaminants. 2.3 STATE POLLUTION PREVENTION LEGISLATION The New Hampshire Department of Environmental Services (NHDES) promulgates and enforces regulations for Air Quality, Water, and Hazardous Materials specific to the state of New Hampshire. 2.3.1 AIR QUALITY Env-A 1400 Regulated Toxic Air Pollutants Env-A 1400 regulates the emissions of toxic air pollutants into the outdoor air. Any non-exempt source that emits any of the listed Regulated Toxic Air Pollutants (RTAPs) is required to demonstrate compliance with the established Ambient Air Limits (AALs) for each RTAP. Those sources that are not in compliance are required to obtain a permit restricting their RTAP emissions. Sources that are in compliance must keep records on-site that verify their compliance status. Env-A 1600 Fuel Specifications Env-A 1600 prevents, abates, and controls pollutants emitted into ambient air by controlling the uses of fuels containing specific pollutant elements and compounds. SULFUR CONTENT LIMITATIONS FOR LIQUID FUELS: Michael O'Connor Page 19 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan The sulfur content of No. 2 oil and JP-4 aviation fuel shall not exceed 0.40 percent sulfur by weight. The sulfur content of gasoline shall not exceed 0.10 percent sulfur by weight. The sulfur content of used oil shall not exceed 2.00 percent sulfur by weight. 2.3.2 WATER Env-Ws 412 Reporting and Remediation of Oil Discharges Env-Ws 412 establishes procedures and requirements for notification, reporting, response actions, and investigations for sites where discharges of oil have occurred. Env-Ws 315-319 Drinking Water Quality Standards Env-Ws 315-319 establishes rules regulating the quality of drinking water based upon specific criteria regarding microbial contaminants, inorganic chemical contaminants, regulated organic contaminants, and unregulated organic contaminants. 2.3.3 HAZARDOUS MATERIALS Env-Wm 100-300, 2100-3700 Solid Waste Rules The purpose of the solid waste rules is to “minimize risks to the environment, public health, and safety by assuring proper management of solid waste.” Env-Wm 101 – 102, Solid Waste Rule Exceptions and Definitions Env-Wm 201 – 205, Solid Waste Procedural Rules Env-Wm 301 – 316, Solid Waste Permits Env-Wm 2600, Management of Certain Wastes Env-Wm 2600 establishes rules to regulate the management of certain wastes such as asbestos, ash, contaminated soils and media, infectious waste, and tires. Env-Wm 2700, Universal Facility Requirements Env-Wm 2700 establishes rules to “ensure that facilities are located, designed, constructed, operated, and closed in a manner that does not endanger public health or adversely affect the environment and which minimizes the potential for accidents that could lead to personal injury or property damage.” Env-Wm 400 - 1100 Hazardous Waste Rules The purpose of hazardous waste rules is to “identify the requirements for generating, transporting, storing, recycling, and disposing of hazardous waste.” Env-Wm 401 – 406, Identification and Listing of Hazardous Wastes Env-Wm 501 – 513, Requirements for Hazardous Waste Generators Michael O'Connor Page 20 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND Env-Wm 601 – 610, Requirements for Hazardous Waste Transporters Env-Wm 801 – 809, Requirements for Recycling of Hazardous Wastes Env-Wm 801 identifies materials to be recycled that are considered wastes and therefore subject to regulation under Env-Wm 804 – 810, and identifies materials to be recycled that are not wastes and therefore not subject to regulation under the hazardous waste rules. It also sets forth requirements for the management of these identified materials. Env-Wm 1101 – 1114, Requirements for Universal Waste Management Env-Wm 1101-1114 establishes the “requirements for certain types of widely generated hazardous wastes called universal wastes. These wastes include certain types of batteries, certain types of pesticides, automotive antifreeze, cathode ray tubes, and mercury-containing lamps and devices. The risk posed by these wastes during accumulation and transport is relatively low compared to other hazardous wastes.” Env-Wm 1401 Underground Storage Facilities Env-Wm 1401 “sets forth requirements for underground storage facilities under RSA 146-C to prevent and minimize contamination of the land and waters of the state due to the storage and handling of motor fuels, heating oils, lubricating oils, other petroleum and petroleum contaminated liquids, and hazardous substances, by establishing criteria for registration and permitting, and standards for design, installation, operation, maintenance, and monitoring of such facilities.” Env-Wm 1402 Control of Aboveground Petroleum Storage Facilities Env-Wm 1402 establishes rules to “minimize contamination of waters and land of the state due to the improper storage and handling of motor fuels, heating oils, lubricating oils, insulating oils, other petroleum products, and petroleum contaminated liquids by establishing requirements for the registration, design, installation, operation, maintenance, and monitoring of above-ground petroleum storage facilities. Env-Wm 1403 Groundwater Management and Groundwater Release Detection Permits Env-Wm 1403 establishes procedures and requirements for the investigation, remediation and management of contamination for sites where discharges of regulated contaminants have occurred "and procedures for monitoring the groundwater for early detection of any impact associated with the activities listed in RSA 485-C.” 2.4 PRESIDENTIAL EXECUTIVE ORDERS 2.4.1 EO 13101 “Greening the Government through Waste Prevention, Recycling, and Federal Acquisition,” September 1998 Michael O'Connor Page 21 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan EO 13101 requires federal agencies to implement acquisition programs aimed at procuring products that are environmentally preferable, energy efficient, and/or contain post-consumer recovered materials. This order supersedes EO 12873. The focus of this EO is threefold: Incorporate waste prevention and recycling into daily operations and work to increase and expand markets for recovered materials through greater preference and demand for such products, Acquire and use environmentally preferable products and services and implement cost effective procurement preference programs favoring the purchase and use of these products and services, and New positions in each government agency were created to enforce the implementation of the above two requirements. 2.4.2 EO 13123 “Greening the Government through Efficient Energy Management” June 1999. This EO gives the government the responsibility to improve its energy management as the nation’s leading energy consumer to provide leadership as an environmental steward. This EO combined several P2 elements of previously existing EOs to establish goals that involve implementing environmental management programs reaching measurable P2 milestones. The focus of this EO is stated as seven points, as follows: Greenhouse Gases Reduction – This goal requires the reduction of greenhouse gas emissions attributed to facility energy use by 30 percent by 2010 compared to such emission levels in 1990. Energy Efficiency Improvement – This set of goals refers to the reduction of energy consumption at a gross square foot level. For each facility, a reduction by 30 percent (relative to 1985) is needed by 2005 and a further 5 percent reduction to 35 percent is required by 2010. Industrial and Laboratory Facilities - Specific to these activities, a 20 percent energy reduction, (relative to 1990) is required by 2005 and a further 5 percent reduction to 25 percent is needed by 2010. Renewable Energy - Implementing renewable energy projects and purchasing power from renewable sources will expand renewable energy usage to satisfy this goal. The installation of solar energy collectors on roofs is another initiative of this goal. Petroleum – Petroleum use reduction is the focus of this goal. Switching to the use of natural gas or renewable energy sources is a priority. Eliminating unnecessary fuel use and other methods of decreasing petroleum-based fuel are encouraged. When alternatives are not possible, this goal requests that agencies and facilities strive to improve the efficiency of their facilities. Source Energy – This goal stipulates that total energy use associated with greenhouse gases and other emissions will be reduced as measured at the source. Water Conservation – Reducing water consumption and associated energy use are the target for this goal. Incorporating this goal into contracts and finance mechanisms is encouraged. Michael O'Connor Page 22 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND 2.4.3 EO 13148 “Greening the Government through Leadership in Environmental Management” April 2000. This EO restates that the government has the responsibility to improve its energy management as the nation’s leading energy consumer to provide leadership as an environmental steward. EO 13148 establishes goals that involve establishing environmental management programs as well as goals that involve reaching measurable P2 milestones. Six goals stated in EO 13148 include the following: Environmental Management – Through environmental management systems strategies will be established to support environmental leadership programs, policies, and procedures. Senior level managers will explicitly and actively endorse these strategies. Environmental Compliance – Establishing and implementing an environmental compliance audit program will enforce compliance with environmental regulations. Policies that emphasize P2 as a means to achieve and maintain environmental compliance will be central to achieving this goal. Right-to-Know and Pollution Prevention – Strive to reduce or eliminate harm to human health and the environment from releases of pollutants from facility operations. Inform the public and personnel about possible sources of pollution from the facility. Whenever feasible and costeffective, pollution should be prevented or reduced. Funding for regulatory compliance programs shall emphasize P2 as a means to achieve compliance. Release Reduction: Toxic Chemicals and Hazardous Substances and Other Pollutants - Reduce use of toxic chemicals, hazardous substances, and pollutants by 50 percent by 31 December 2006. Reduction of Ozone-Depleting Substances – Plan to phase out the procurement of ozonedepleting substances by 31 December 2010. Environmentally and Economically Beneficial Landscaping – Strive to promote the implementation of cost-effective, environmentally sound, landscaping practices and programs to reduce adverse impacts to the natural environment. 2.4.4 EO 13149 “Greening the Government through Federal Fleet and Transportation Efficiency” April 2000. This EO establishes goals to improve the average fuel economy to increase the use of alternative fuels for fleet vehicles. Note that this order exempts tactical military vehicles, law enforcement vehicles, and emergency vehicles from its requirements. This EO supersedes EO 13031 of December 1996. This order established the following specific goals: Reduce vehicle petroleum consumption 20% by the end of Fiscal Year (FY) 2005 from an FY 1999 baseline. Increase the average Environmental Protection Agency (EPA) fuel economy rating of cars and light trucks by at least 1 mile per gallon (mpg) by the end of FY 2002 and by 3 mpg by the end of 2005 from an FY 1999 baseline. Michael O'Connor Page 23 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Ensure that alternative fuels account for at least 50% of the fuels used in dual-fuel, alternative fuel vehicles. Ensure that at least 75% of car and light truck procurements are alternatively-fueled vehicles. 2.4.5 EO 13221 “Energy-Efficient Standby Power Devices,” July 2001. This EO establishes efficiency regulations for standby power devices. When an agency purchases products that use external standby power devices or contain an internal standby power function they must purchase products that use no more than one watt in their standby power consuming mode if available. Otherwise, agencies must purchase products with the lowest standby power wattage while in their standby power consuming mode. These requirements must be met when cost effective and the utility and performance of the product are not sacrificed as a result. 2.5 DOD DIRECTIVES AND INSTRUCTIONS 2.5.1 DOD INSTRUCTION 4715.4, “POLLUTION PREVENTION,” JUNE 1996. This document provides explicit guidance on P2 activities. It reiterates the P2 Hierarchy principle, and establishes the DOD P2 measures-of-merit for TRI releases reduction, hazardous waste reduction, non-hazardous solid waste diversion, and alternatively-fueled vehicles. The following measures-of-merit were established by DOD Instruction 4715.4: TRI Releases Reduction The goal is to reduce the amount of toxic releases and off-site transfers of toxic chemicals (measured in pounds) by 50% by 1999 from the 1994 TRI baseline. Hazardous Waste Reduction The goal is to reduce the amount of hazardous waste shipped off-site for disposal, treatment, or recycling (measured in pounds) by 50% by 1999 from a 1992 baseline. Non-hazardous Solid Waste Diversion The goal is to recycle 50% of the amount of non-hazardous solid waste (measured in pounds) by 1999 from a 1992 baseline. Alternatively-fueled Vehicles (AFVs) The following goals were established: 75% of acquisitions of new non-tactical vehicles must be AFVs after FY 1999 20% reduction of petroleum fuel consumption by FY 2005 from a 1999 baseline For the majority of operation, AFVs will rely of alternative fuel by FY 2005 Michael O'Connor Page 24 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND Increase the fleet fuel economy by 3 miles per gallon by FY 2005 from a 1999 baseline Note that the TRI, hazardous waste reduction, and non-hazardous solid waste diversion goals listed above became obsolete on 31 December 1999. As a result, the DOD developed a new solid waste measure of merit in May 1998, which was further revised in April 2002. The DOD is currently developing new TRI and hazardous waste reduction measures of merit that will be incorporated into this plan as soon as they become available. 2.5.2 DEPARTMENT OF ARMY (DOA) MEMORANDUM, OZONE-DEPLETING CHEMICALS (ODCS) ELIMINATION AT ARMY INSTALLATIONS, FEBRUARY 1996 With the Memorandum entitled, “ODC Elimination at Army Installations,” the Assistant Secretary of the Army for Installations, Logistics, and Environment established an Army-wide goal to completely eliminate Class I ODCs from all Army installations by 31 December 2003. 2.5.3 DOD MEMORANDUM, “NEW DOD P2 MEASURE OF MERIT (MOM),” MAY 1998 This memorandum establishes a new solid waste MOM to replace those in DOD Instruction 4715.4 (above). The new measure of merit is to “ensure that the diversion rate for non-hazardous solid waste is greater than 40% while ensuring integrated non-hazardous solid waste management programs provide an economic benefit when compared with disposal using land-filling and incineration alone.” This goal is to be attained by the end of FY 2005. 2.5.4 MEMORANDUM, ASSISTANT SECRETARY FOR INSTALLATIONS, LOGISTICS, AND ENVIRONMENT, “ODC ELIMINATION AT ARMY INSTALLATIONS,” 13 FEBRUARY 1996. With this memorandum, the Assistant Secretary of the Army for Installations, Logistics, and Environment established an Army-wide goal to completely eliminate Class I ODCs from all Army installations by 31 December 2003. 2.5.5 DOA MEMORANDUM, REVISED CLEAN WATER ACT MOM, MAY 1998 The Deputy Undersecretary of Defense signed this Army memorandum to memorialize two water goals for the Army. This memorandum requires that all DOD Clean Water Act (CWA) permitted water pollution control systems and activities shall be in compliance with their permit requirements, CWA P2 nonrecurring investments shall be increased to 15 percent of the total CWA nonrecurring investments (combined P2 and compliance) by the end of fiscal year 2004. 2.5.6 “PROPOSED REVISIONS TO DOD SOLID WASTE MOM,” APRIL 2002 The following revisions of the Solid Waste MOM were proposed: Michael O'Connor Page 25 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Focus on diversion rate rather than quantity. Incorporate the previously established goal of 40% diversion rate for non-hazardous municipal solid waste by the end of FY 2005 and continuously increase the diversion rate thereafter. Separate construction and demolition (C&D) waste from the rest of the non-hazardous solid waste. Continuously reduce the diversion rate for C&D waste. Focus on cost management in terms of economic benefit to better define the goal and to establish a quantifiable cost metric. Continuously increase the economic benefit of solid waste diversion by investing in pollution prevention initiatives and better managing costs associated with disposal, diversion, and program administration. 2.5.7 DOA MEMORANDUM, CALL FOR CALENDAR YEAR (CY) 2001 TRI FORM DATA, JULY 2002 EO 13148 requires that all federal facilities submit already defined TRI data to the U.S. EPA. This memorandum requires that facilities submit their CY 2001 TRI data to the EPA for use as the baseline to measure reductions as specified in EO 13148. This EO requires a 10 percent per year reduction or 40 percent overall reduction in TRI release by the end of CY 2006. 2.5.8 AFFIRMATIVE PROCUREMENT PROGRAM (APP) METRICS The following goals have been established by the APP: To increase the percentage of contracts and contract value that include FAR clauses for use of recycled materials. To increase the percentage of contracts with APP clauses that are fully compliant with APP requirements in block B12F. To increase the percentage of personnel trained as purchase card holders, specification writers, and contract personnel. Michael O'Connor Page 26 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 2: POLLUTION PREVENTION REGULATORY BACKGROUND Michael O'Connor Page 27 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 3: NHARNG POLLUTION PREVENTION PROGRAM 3.1 POLICY “The NHARNG’s command extends across every aspect of the Army mission. Virtually all actions and operations impact the environment. [NHARNG] must conserve, protect, and restore natural resources while accomplishing the military missions so necessary in today’s world. [NHARNG] must integrate environmental values into the Army mission in order to sustain readiness, improve the soldier’s quality of life and strengthen community relationships. The NHARNG is committed to: Ensuring that operations meet Federal, State, Local and applicable Host-nation environmental requirements Promoting environmental awareness among all personnel throughout the organization Focusing on sustainable use of the land and renewable resources through ecological management, conservation and restoration Considering environmental effects of activities from planning and execution through completion of operations Encouraging the use of source reduction, recycling, and resource conservation”2 3.2 POLLUTION PREVENTION MANAGEMENT STRUCTURE The NHARNG is currently developing an Environmental Management System (EMS), which will include a P2 Management Structure. This structure will likely be similar to the following example: The Adjutant General Chief of Staff (CoS) Environmental Quality Control Committee (EQCC) EMS Management Representative Environmental Program Manager Pollution Prevention Coordinator USP&FO Director of Army Aviation/State Safety Manager (SSM) CSMS and OMSs Supervisors 2 Environmental Policy, 2 April 2003. John J. Weeden BG, NHARNG Assistant Adjutant General. Michael O'Connor Page 28 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 3: NHARNG POLLUTION PREVENTION PROGRAM Materials Handler Public Affairs Office Defense Reutilization and Marketing Office (DRMO) 3.3 BASELINE DEVELOPMENT The NHARNG’s baselines were developed in accordance with the pollution prevention guidelines and regulations established by EOs and DOD Measure of Merits. These baselines are based on the following metrics and are quantitatively defined in Chapters 5 – 14 of this plan. Hazardous Waste: Total disposed (pounds) Solid Waste: Total disposed (pounds) and percent of total generated diverted to recycle (percent) Air Emissions: Amount emitted (tons) Water: Amount consumed (gallons) Wastewater: Amount generated (gallons) TRI Form R Chemical Releases: Releases and off-site transfers (pounds) EPA Priority Chemicals: Purchases of individual target chemicals (pounds) Vehicle Fuel Use: Amount of petroleum consumed (gallons) Energy: Electricity used (kWh) per total square feet AFVs: Number of AFVs leased/procured 3.4 POLLUTION PREVENTION GOALS Ideally, the ultimate long-term goal of NHARNG is to achieve a discharge of zero pollutants to the environment through the elimination of the use of hazardous materials and generation of waste. Although this goal is not technically or economically feasible, short term P2 goals have been developed based on environmental laws, EOs, and DOD policies in order to work towards this definitive goal of zero discharge. In cases where mandated regulations have already been met, NHARNG developed personal goals in order to continually improve P2 endeavors. Chapters 5 – 14 of this plan describe the specific P2 goals developed with respect to each environmental media area. These media specific goals are also given in detail in the P2 Goal Summary Table. Upon development of the EMS, the NHARNG will refine these goals on an “as needed” basis with the objective of continuous improvement. 3.5 OPPORTUNITY ASSESSEMENTS With the development of new reduction requirements it is essential for pollution prevention and reduction options to be identified in order to meet the established requirements. These options are identified through pollution prevention opportunity assessments (PPOAs). PPOAs are conducted by a team of qualified people who work together to identify process improvements that will reduce Michael O'Connor Page 29 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan pollution at its source. PPOAs involve the examination of input and output streams of target suspect processes, which include the type and weight of materials used and wastes generated. All resulting process improvement options are then evaluated to determine the technical, environmental, and economic feasibility of the suggested improvement. A PPOA guide that outlines the process of conducting an internal PPOA is provided in Appendix IV. Prior to the PPOA conducted specifically for the purposes of this plan, the most recent PPOA was conducted on February 27, 2003 by the NHDES. The following P2 recommendations were made: “Implement a chemical exchange or chemical sharing program with other NH bases. By sharing useable chemicals with other bases, this may reduce over purchasing issues and decreasing the amount of chemicals that may need disposal after the expiration date Purchase only what is ‘needed’ and determine if other alternatives are available that are less ‘toxic’ or have a longer shelf life Consider implementing a solid waste program to collect paper, metals including aluminum, glass, plastic and cardboard Consider energy use and conservation opportunities in the new environmental management system.”3 The results of the PPOA conducted for this plan are discussed in their respective chapters according to the media type addressed. All P2 projects resulting from the PPOA are discussed in detail in the Potential P2 Initiative(s) sections of Chapters 5 – 14 of this plan. A project status summary of all P2 projects (current and potential) is given in the P2 Initiatives Summary Table. 3.6 IMPLEMENTATION AND EVALUATION Following the documentation of recommended Potential P2 Initiatives is the process of implementation. Initiatives are implemented based on careful evaluation of technical, environmental, and economic feasibility. If a potential initiative should prove to be practical and cost effective it is implemented and re-categorized as a Current Initiative. Current initiatives are the P2 projects currently being implemented by NHARNG as a result of past PPOAs. The Current P2 Initiative(s) sections of Chapters 5 – 14 describe all currently implemented P2 endeavors as well as the resulting environmental benefits. These sections allow the success of current P2 projects to be tracked and evaluated. Documentation of current and past projects also allows for problems and corresponding improvements to be made to less successful P2 projects in order to achieve the intended goal. 3.7 P2 PROGRAM FUNDING Funding for P2 projects is secured through the Master Cooperative Federal-State Agreement. To secure funding for a P2 project, contact either the P2 Coordinator or the Environmental Program 3 Data Source: E-mail correspondence with Sara J. Johnshon, P2 Program Manager, NH DES Michael O'Connor Page 30 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 3: NHARNG POLLUTION PREVENTION PROGRAM Manager at the NHARNG Environmental Office (NHARNG-FM-EV), who will pursue the appropriate funding source. Michael O'Connor Page 31 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 4: COMPLIANCE THROUGH POLLUTION PREVENTION 4.1 DESCRIPTION OF COMPLIANCE THROUGH P2 Pollution Prevention can be a strong tool that an installation can use to reduce its compliance burden. Since the concept of pollution prevention was first introduced, it has been accepted that P2 can improve an installation’s compliance status. However, this benefit was taken as a matter of course but was not widely explored. This section represents NHARNG’s efforts to categorize and document its compliance benefit. 4.2 COMPLIANCE SITES A compliance site is a facility or process that falls under environmental regulation. A single area may have multiple compliance sites associated with it. 4.2.1 HAZARDOUS WASTE STORAGE AND/OR TREATMENT AREAS The NHARNG does not operate any hazardous waste treatment areas or any RCRA Part B storage facilities. However, hazardous waste holding areas exist at all of the OMSs, as well as at the SMR. Specifically, the SMR is the only Full Quantity Generator and therefore, the only area to operate any Satellite Storage Areas. Table 4.1: Hazardous Waste Holding Areas Location # of Holding Areas Littleton Somersworth Manchester Hillsboro SMR 1 2 1 1 N/A Total 5 4.2.2 AIR EMISSIONS SOURCES The NHARNG currently has one permitted air emissions source consisting of an emergency diesel generator located in Building A on the SMR. The generator is covered under New Hampshire’s General State Permit for Emergency Generators which requires that NHARNG limit use to less than 500 hours of operation during any consecutive 12 month period and keep records to ensure compliance. The permit application for a new emergency generator, installed at the new AASF (currently under construction), has been submitted. (See Appendix III for permit information) 4.2.3 SOLID WASTE FACILITIES There are no solid waste facilities owned or operated by the NHARNG. Solid waste disposal is handled by the State of New Hampshire. Dumpsters are contracted with 100% state money. Details on solid waste can be found in Chapter 6 – Solid Waste. 4.2.4 STORAGE TANKS Michael O'Connor Page 32 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 4: COMPLIANCE THROUGH POLLUTION PREVENTION Table 4.2: Storage Tanks Town/City Tank # Location Type ID # Installation Date Tank Material Containmen t Piping Material 970732A 27-Jun-97 Steel Double Wall 22 State Maint. UST 0-111093 14-Jun-89 Steel Double Wall Concord N/A State Maint. Steel Double Wall Concord 23 Warehouse UST 0-111093 21-Jun-89 Steel Double Wall Hillsboro 8 OMS UST 0-113320 26-Jun-89 Steel Double Wall Manchester Center Strafford Center Strafford Center Strafford 5 UST 0-113325 1-Aug-89 Steel Double Wall UST 0-113315 10-Jan-90 Steel Double Wall 4 Armory Thomas Building Admin. Building UST 0-113315 10-Jan-90 Steel Double Wall Stainless Steel / Composite Copper/PVC Sleeve Copper/PVC Sleeve Copper/ PVC Sleeve Copper/ PVC Sleeve Copper/ PVC Sleeve Copper/ PVC Sleeve Copper/ PVC Sleeve N/A Lower Foss AST Steel N/A Steel Concord 1 Concord 5 AASF AST AST N/A N/A 1-Jul-99 Size (gal) Contents Ownership 10,000 JP-8 100% Federal 5,000 #2 Oil 100% State 275 Diesel 6,000 #2 Oil 3,000 #2 Oil 10,000 #2 Oil 5,000 #2 Oil 3,000 #2 Oil 500 #2 Oil 100% State 100% Federal 100% Federal 12.3% Federal 100% Federal 100% Federal 100% Federal The NHARNG holds permits for the operation of five underground storage tanks. The underground storage tanks are located at the USP&FO Warehouse in Concord, Hillsboro OMS #5, Manchester Armory, the Thomas Building at the NHNGTS in Center Strafford, and the Administration Building at the NHNGTS. These tanks are double-walled steel construction, with copper/PVC sleeve piping. They are used to store #2 Oil. For further information on each tank, see the corresponding permits which appear in Appendix III. Table 4.3: Oil-Water Separators 4.2.5 WASTE WATER SITES The NHARNG operates oil-water separators at many locations. They are cleaned periodically (on an as-needed basis) and they allow many shops to connect their drainage system to the city/town wastewater treatment plant. See Appendix III for permits. 4.2.6 STORMWATER Location Permitted Daily # Separators Flow Rate (gal) Littleton Somersworth Manchester Hillsboro CSMS/Building F CSMS Annex AASF 1 1 1 1 1 1 1 200 Not Specified 500 Not Specified 1050 700 1460 Stormwater permits are located in Appendix III. 4.2.7 DRINKING WATER SITES The NHARNG operates 3 wells on the NHNGTS property. The most recent NHDES Sanitary Survey was completed on August 8th, 2003 (8/8/03). 4.2.8 PESTICIDE APPLICATION SITES Pesticide application sites vary by year and by location. The main pesticides employed are in the form of ant traps and household wasp spray, and this is applied so infrequently that no meaningful quantitative estimates can be made. Each installation could potentially have these forms of pesticide in very small quantities. They are used on an ‘as needed’ basis and do not require Michael O'Connor Page 33 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan permitting. The National Guard Bureau (NGB) requires that each state report the amount used per year, rounded to the nearest pound. The NHARNG uses less than ½ of a pound, and is therefore reported as zero. 4.3 COMPLIANCE THRESHOLDS Compliance thresholds are quantitative limits that govern the applicability of environmental compliance requirements and the appropriate level of regulation. 4.3.1 HAZARDOUS WASTE GENERATION Table 4.4: Compliance Thresholds – Hazardous Waste Generation NH DES US EPA <220 lbs/month Small Quantity Generator Conditionally Exempt Small Quantity Generator 220< x < 2200 lbs/month Full Quantity Generator >2200 lbs/month Full Quantity Generator Small Quantity Generator Large Quantity Generator Threshold Status The OMSs are considered to be Small Quantity Generators by NH and Conditionally Exempt Small Quantity Generators by the federal government. The SMR is considered to be a Full Quantity Generator by the state of NH and a Small Quantity Generator by the federal government. Initiatives to Reduce Generation It is nearly impossible to completely eliminate the generation of hazardous waste at the OMSs due to the nature of their work. As such, generation can be minimized, but not reduced to zero. The OMSs currently have the lowest generator status for both the state of NH and the federal government. Initiatives to reduce generation at SMR and OMS facilities can be found in Chapter 5 as Current Initiatives (5.6). 4.3.2 TRI FORM R REPORTING TRI Form R Reporting is required when more than the threshold quantity of any single listed chemical is used in a given year. See NHARNG Environmental Office’s EPCRA Binder for exceptions and other TRI Form R Reporting Guidelines. The NHARNG does not utilize any TRI chemicals in quantities high enough to require Form R reporting. To reduce releases of TRI chemicals, spill kits should be periodically inspected to ensure that they are both complete and available. 4.3.3 EPA PRIORITY CHEMICAL USE The NHARNG does not use any EPA Priority Chemicals. See Appendix I for EPA Priority Chemical List. Michael O'Connor Page 34 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 4: COMPLIANCE THROUGH POLLUTION PREVENTION 4.3.4 PESTICIDE USAGE Compliance Threshold NHARNG must report their pesticide usage annually to the NGB. This is reported in pounds (lbs), rounded to the nearest whole pound. Less than ½ of one pound is used per year, so the reported use is 0 lbs. Current Initiatives The NHARNG is currently working with a contractor, J.M. Waller, to develop an Integrated Pest Management Plan. This plan is scheduled to be complete by 2004. Another initiative currently in place is being tested at the NHNGTS: “The Environmental Office staff installed six birdhouses in and around the track and student dormitories. The birdhouses are designed to attract Tree Swallows and Bluebirds. The attracted birds feed on mosquitoes and other biting insects. By using birds for insect pest management, it reduces the need to use pesticides, which are costly and can be harmful to humans and animals.”4 4 Source: NHARNG-FM-EV Website – Pest Management Program Michael O'Connor Page 35 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 5: WASTE GENERATING PROCESSES 5.1 DESCRIPTIONS Training and Unit Exercises: Include activities that would occur during routine training exercises (excluding nuclear, biological, and chemical (NBC) activities and weapons cleaning). Includes battery replacement in small, battery-operated equipment such as radios and flashlights. Meals Ready to Eat (MREs) are commonly eaten during field training exercises. NBC Activities: Includes routine NBC training exercises, decontaminating equipment and gear, and replacing gas mask filters. Weapons Cleaning and Repair: Includes cleaning, lubricating, and preserving weaponry. Weapons may be cleaned at unit locations during routine training exercises and may be repaired at a Small Arms Repair Shop. Weapons cleaning may generate rags and swabs contaminated with cleaning solvent and metal particulates. Fueling Operations: Include refueling of equipment, surface vehicles and aircraft using fuels stored on-site or contracted from vendors. May include any operation associated with vehicle fueling, on-site fuel supplies, and storing fuel or vehicles containing fuel. Fueling operations may result in the spill of fuels from vehicles. Vehicle and Aircraft Washing: Includes surface vehicle and airframe washing using either hot or cold water, with or without detergent. May be performed at facilities equipped with oil/water separators or at commercial car washes. Also includes engine cleaning. Oil Changes: Includes all routine oil replacement conducted on surface vehicles and equipment (excluding brake fluids, hydraulic fluids, and transmission fluids). Brake Maintenance: Includes routine brake maintenance and repair, such as replacing hydraulic fluid, brake shoes and brake pads. Brake shoes and pads may contain asbestos. Tire Maintenance: Includes replacing worn surface vehicle or aircraft tires. Battery Maintenance: Includes any activity involving servicing or replacing surface vehicle or aircraft batteries. Also includes replacing batteries in small equipment. It may result in waste batteries, recyclable batteries, or batteries turned in on a 1-for-1 exchange. Radiator Flushing: Includes replacing spent antifreeze and treating corrosion in surface vehicle radiators. Parts Washing: Includes cleaning and degreasing mechanical components during routine maintenance or repair. Can be done using various techniques such as steam, solvents, acids, bases, detergents, or hot water. Mechanical Work: Includes any mechanical component repair (other than brakes, tires, batteries, radiators or parts washing), such as engine overhauling or aircraft turbine repair, drive train work, or transmission overhauls. May be performed on surface vehicles and equipment or aircraft. Michael O'Connor Page 36 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 5: WASTE GENERATING PROCESSES Large-Scale Painting: Includes high-volume painting on surface vehicles and equipment and aircraft. Usually done in a paint booth equipped with a wet- or dry- filter system. Paint is applied via spray paint guns or aerosol cans. Spot Painting: Includes touch-up painting, corrosion control, and stenciling on surface vehicles, aircraft, and miscellaneous equipment. Minimal quantities of paint are used and may be applied by brushes or aerosol cans. Metal Fabrication: Includes manufacturing and/or modifying sheet metal for vehicles and aircraft frames and cutting, machining, and welding metal parts. Electronics Maintenance: Includes testing, cleaning, repairing, or replacing electronic components, such as circuit boards. Components are often cleaned with solvents or environmentally friendly chemicals such as denatured alcohol. Shop and Spill Cleanup: Includes routine shop cleanup measures or emergency and nonemergency spill cleanup measures. Facility Building Maintenance: Includes repair and routine maintenance of building interiors and exteriors, janitorial work, cleaning and waxing floors, carpentry work, plumbing, electrical repairs, fluorescent light bulb and ballast replacement, and facility painting. May also include performing structural repairs as needed. Building Equipment Maintenance: Includes maintaining and repairing plant equipment such as boilers. Pest Management: Includes pest control measures for facilities and buildings. Grounds Maintenance: Includes maintaining facility grounds through activities such as landscaping, mowing, and mulching. Procurement Operations: Includes shipping, receiving and warehousing purchased materials. 5.2 MATERIAL INPUTS AND WASTE STREAMS The following table shows the material inputs and outputs for the operations and processes typical of NHARNG. Michael O'Connor Page 37 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Table 5.1: Process Inputs and Outputs Process Inputs Outputs Training and Unit Exercises New batteries MRE heaters Spent batteries MRE heaters NBC Activities Gasmask canisters Gas mask filters Decon kits DS2 Decon Liquid Gas mask canisters Gas mask filters Decon kits DS2 Decon Liquid Weapons Cleaning/ Repair Cleaning patches Grease/ lubricants Rags CLP Chlorinated CLP Non-Chlorinated Cleaning patches Grease/ lubricants Waste rags CLP Chlorinated CLP Non-Chlorinated Procurement Operations New materials Excess materials Expired materials Fueling Operations Clean fuel Absorbents Off spec fuel Contaminated absorbents Recovered fuel Contaminated soil Contaminated fuel Vehicle Washing Gas path Water Cleaning compound Rags Spent gas path Oily sludge Engine wash Cleaning compound Waste rags Waste water Oil Changes New oil Oil filters Rags Recycled oil Used oil Oil filters Waste rags Brake Maintenance Grease/lubricants Asbestos brake pads Non-asbestos brake pads Brake fluid Solvent-based brake cleaner Aerosol brake cleaner Rags Brake Shoes Asbestos Grease/ Lubricants Brake fluid Waste rags Parts Washing Solvent Water Rags Brushes Sludge Waste water Waste solvent Waste rags Michael O'Connor Page 38 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 5: WASTE GENERATING PROCESSES Battery Maintenance Sulfuric acid Tin alloy solder Baking soda New sealed batteries Aerosol solvent and containers Water from these processes Rags Spent batteries Waste rags Radiator Flushing Water Rags New antifreeze Recycled antifreeze Spent antifreeze Waste rags Waste water Grease/ lubricants Hydraulic fluid Transmission fluid Carburetor cleaner Power steering fluid Liquid solvent Engine oils Fuel filters Junk parts Solvents Hydraulic fluid Transmission fluid Grease/ lubricants Waste rags Used oil Fuel filters Rags Waste rags Large-Scale Painting Paint thinners Solvents Primer/ paint Paint booth filters Aerosol paints Rags Paint thinners Solvents Primer/ paint waste Paint booth filters Empty aerosol cans Waste rags Spot Painting Paint thinners Primer/paint Aerosol paints Rags Waste rags Primer/paint waste Empty aerosol cans Metal Fabrication Sheet metal Cutting oil Grease/ lubricants Solvents Rags Scrap metal Cutting oil Grease/ lubricants Solvents Empty aerosol cans Waste rags Metal shavings Electronics Maintenance Solvents Adhesives Vacuum-filled tubes Circuit boards Batteries Swabs Solder Rags Solvents Adhesives Vacuum-filled tubes Circuit boards Batteries Swabs Solder Waste rags Mechanical Work Michael O'Connor Page 39 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Process Shop andand Training Spill Cleanup Unit Exercises NBC Activities Facility/ Building Weapons Maintenance Cleaning/ Repair Procurement Operations Fueling Operations Building Equipment Maintenance Absorbent Inputs Alkali floor cleaner New batteries Absorbent "kitty litter" MRE heaters Rags Water Gasmask canisters Gas mask filters Decon kits Air filters DS2 Decon Liquid Adhesives Fluorescent lights/ballasts Cleaning patches Sand paper Grease/ lubricants Solvents Rags Paint CLP Chlorinated Cleaning supplies CLP Non-Chlorinated Rags New materials Adhesives Paint Clean fuel Refrigerants Lubricants/ grease New parts Rags Solvents Outputs Contaminated absorbent Alkali floor cleaner Spent batteries Waste water MRE heaters Waste rags Gas mask canisters Gas filters mask filters Air Decon kits Adhesives DS2 Decon Liquid Fluorescent lights/ Ballasts Cleaning patches Sand paper Grease/ lubricants Solvents Waste rags Paint waste CLP Chlorinated Cleaning supplies CLP Non-Chlorinated Waste rags Saw dust Excess materials Expired materials Adhesives Solvents Paint waste Off spec fuel Refrigerants Waste rags Lubricants/grease Empty aerosol cans Junk parts PCBs Pest Management Pesticides Baits/Traps Pesticides Waste rags Empty aerosol cans Grounds Maintenance Gas/Oil Herbicides Yard waste Herbicides Michael O'Connor Page 40 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 5: WASTE GENERATING PROCESSES Absorbents Contaminated absorbents Recovered fuel Contaminated soil Contaminated fuel Vehicle Washing Gas path Water Cleaning compound Rags Spent gas path Oily sludge Engine wash Cleaning compound Waste rags Waste water Oil Changes New oil Oil filters Rags Recycled oil Used oil Oil filters Waste rags Brake Maintenance Grease/lubricants Asbestos brake pads Non-asbestos brake pads Brake fluid Solvent-based brake cleaner Aerosol brake cleaner Rags Brake Shoes Asbestos Grease/ Lubricants Brake fluid Waste rags Parts Washing Solvent Water Rags Brushes Sludge Waste water Waste solvent Waste rags Michael O'Connor Page 41 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Battery Maintenance Sulfuric acid Tin alloy solder Baking soda New sealed batteries Aerosol solvent and containers Water from these processes Rags Spent batteries Waste rags Radiator Flushing Water Rags New antifreeze Recycled antifreeze Spent antifreeze Waste rags Waste water Grease/ lubricants Hydraulic fluid Transmission fluid Carburetor cleaner Power steering fluid Liquid solvent Engine oils Fuel filters Junk parts Solvents Hydraulic fluid Transmission fluid Grease/ lubricants Waste rags Used oil Fuel filters Rags Waste rags Large-Scale Painting Paint thinners Solvents Primer/ paint Paint booth filters Aerosol paints Rags Paint thinners Solvents Primer/ paint waste Paint booth filters Empty aerosol cans Waste rags Spot Painting Paint thinners Primer/paint Aerosol paints Rags Waste rags Primer/paint waste Empty aerosol cans Metal Fabrication Sheet metal Cutting oil Grease/ lubricants Solvents Rags Scrap metal Cutting oil Grease/ lubricants Solvents Empty aerosol cans Waste rags Metal shavings Electronics Maintenance Solvents Adhesives Vacuum-filled tubes Circuit boards Batteries Swabs Solder Rags Solvents Adhesives Vacuum-filled tubes Circuit boards Batteries Swabs Solder Waste rags Mechanical Work Michael O'Connor Page 42 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 5: WASTE GENERATING PROCESSES Shop and Spill Cleanup Absorbent Alkali floor cleaner Absorbent "kitty litter" Rags Water Contaminated absorbent Alkali floor cleaner Waste water Waste rags Facility/ Building Maintenance Air filters Adhesives Fluorescent lights/ballasts Sand paper Solvents Paint Cleaning supplies Rags Air filters Adhesives Fluorescent lights/ Ballasts Sand paper Solvents Paint waste Cleaning supplies Waste rags Saw dust Building Equipment Maintenance Adhesives Paint Refrigerants Lubricants/ grease New parts Rags Solvents Adhesives Solvents Paint waste Refrigerants Waste rags Lubricants/grease Empty aerosol cans Junk parts PCBs Pest Management Pesticides Baits/Traps Pesticides Waste rags Empty aerosol cans Grounds Maintenance Gas/Oil Herbicides Yard waste Herbicides Michael O'Connor Page 43 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 44 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE 6.1 GOALS The NHARNG’s goal is to show continuous annual reduction in both generation and disposal of hazardous waste. Regulated waste is hazardous, while non-regulated waste can be either nonhazardous or universal waste. Examples of regulated hazardous wastes generated by the NHARNG are contaminated used oil, contaminated spent antifreeze, and aerosol can residue. Additionally, certain industrial universal waste streams, including batteries, antifreeze, computers, and computer monitors are also targeted for reduction. 6.2 BASELINE AND PROGRESS Table 6.1: Total lbs/yr of Hazardous Waste Disposed in the corresponding years. Target: Continuous Annual Reduction Baseline 2000 2001 2002 2003 2004 14,847 4,746 5,731 Current 2005 2006 2007 6.3 MAJOR HAZARDOUS WASTE STREAMS Wastes common to the State Military Reservation (SMR) and all Organizational Maintenance Shops (OMS) include contaminated used oil, contaminated used antifreeze, oil-water separator sludge, parts-washer sludge, and batteries (Mercury – Hg, Lithium – Li, Nickel-Cadmium – NiCd, etc.). The AASF has an additional waste stream consisting of aircraft washwater. Michael O'Connor Page 45 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan These pie graphs show the compositions of the regulated waste streams for the past three years. A waste is regulated because either a contaminant contained in the waste or the waste itself is hazardous. Heavy metals are some of the most common contaminants. The waste streams have been categorized as containing lead, containing another regulated metal, or containing other (non-metal) contaminants such as solvents. No Regulated Metal Contamination 6223 lbs, 42% No Regulated Metal Contamination21 30 lbs, 44% Lead Contamination 6970 lbs, 47% Other Regulated Metal Contamination (Ba, Cd, Ag) 928 lbs, 20% Other Metal Contamination (Cr, Cd, Ag) 1654 lbs, 11% Figure 6.2: Composition of Regulated Waste Stream in 2000 Michael O'Connor Lead Contamination68 8 lbs, 36% Figure 6.3: Composition of Regulated Waste Stream in 2001 Page 46 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE Other Regulated Metal Contamination, 0, 0% Lead Contamination, 325, 6% No Regulated Metal Contamination, 5359, 94% Figure 6.4: Composition of Regulated Waste Stream in 2002 Michael O'Connor Page 47 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 6.4 MAJOR UNIVERSAL WASTE STREAMS Major universal waste streams include lead-acid batteries, fluorescent light bulbs, computers and computer monitors, and uncontaminated antifreeze. 6.5 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. 6.6 CURRENT P2 INITIATIVES 6.6.1 ANTIFREEZE An on-site antifreeze recycling program was implemented and ran for 6 yrs. It has not run for the past two years due to management changes and lack of policy enforcement. Antifreeze is now recycled through the DRMO, which charges more for recycling than disposal. 6.6.2 AEROSOL CANS Aerosol cans, an item that would be considered hazardous, are punctured using an aerosol can puncturing system. The cans are then recycled as scrap metal, and the collected residue is disposed of as hazardous waste. This greatly decreases the volume of hazardous waste. 6.6.3 AQUEOUS PARTS WASHERS The NHARNG owns and operates aqueous parts washers at all OMS locations, as well as at the CSMS and the AASF. These replaced solvent-based cleaners, reducing air emissions from VOCs and increasing worker safety. Figure 6.5: Aerosol Can Puncturing System 6.6.4 OIL FILTERS Used Oil Filters are replaced when necessary in accordance with the Army Oil Analysis Program (AOAP) results and are hot-drained for 24 hrs after removal. They are then considered non-hazardous waste and are crushed with an oil filter crusher for recycle as scrap metal. 6.6.5 OIL-WATER SEPARATORS Figure 6.6: Oil Filter Crusher at the CSMS Michael O'Connor All shops are equipped with an oil-water separator designed to clean oils out of the water before discharge to municipal wastewater treatment plant. Page 48 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE 6.6.6 SECONDARY CONTAINMENT AREAS Some installations are equipped with secondary containment facilities, as seen in Figure 5-3. These provide better protection from spills, while at the same time extending the life of the equipment. They are ventilated and sloped to provide drainage, which leads to contained tanks located below. 6.6.7 USED OIL BURNERS One used oil burner was purchased by the NHARNG and was installed in the Manchester OMS. It is used during the coldweather months to provide heat, reducing the need to buy as much heating oil. Oil is tested and currently, only onspecification oil is burned. Figure 6.7: Secondary Containment Facility at OMS #5 6.7 POTENTIAL P2 INITIATIVES 6.7.1 ANTIFREEZE Description A different method of recycling antifreeze either on-site or off-site could be utilized to reduce the volume of antifreeze being disposed of as un-recyclable. Through the current organization, approximately 42% of spent antifreeze each year must be disposed of as hazardous waste. With a different system, the amount of un-recyclable antifreeze would greatly decrease. Depending on the method chosen, un-recyclable antifreeze could be entirely eliminated as an output. This recycling program would be applied to the OMSs throughout the state, and to the Concord facilities located on the SMR Current Recycling Procedures through the 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 contaminated5 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. 5 Approximations are based on FY 2002 waste manifests. Michael O'Connor Page 49 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 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. On-Site Antifreeze Recycling TECHNICAL EVALUATION The current process of dealing with antifreeze is to buy new product, and either recycle or dispose of spent antifreeze through the DRMO. The new process would consist of the purchase of a greatly reduced amount of new product. The spent antifreeze, unless contaminated with fuel (gasoline, diesel fuel, kerosene, etc.), would be recycled using the BG Cool’r Clean’r Coolant Purification System, which is currently located at the CSMS. The coolant is allowed to settle and oil is removed with an oil absorbing pad. This 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 material flow diagram shown below illustrates this process. This process creates a surplus of recycled antifreeze. Disposal is a possible issue with this method of recycle. The 15 and 1 micron filters can be dealt with in the same manner as regular oil filters. The charcoal filter must be disposed of. The tanks of resin are regenerated by an approved facility. Currently, the closest facility approved by the manufacturer is in Maryland. For additional information about the process or technical specifications on the machine, please see Appendix D or the BG Cool’r Clean’r Coolant Purification System Manual. Michael O'Connor Page 50 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE Recycled Antifreeze Approx. 90% Resin: Cation and Anion Inhibitor Oil Absorbent Buffer Filters Pads Concentrated Antifreeze Spent Spent Antifreeze Antifreeze Treated Antifreeze Testing Cycle Used Oil Absorbent Pads Used Filters Resin for Regeneration Unrecoverable Antifreeze Approx. 10% Figure 6.8: On-site Antifreeze Recycling Process, Material Flow Diagram ENVIRONMENTAL EVALUATION The environmental benefits associated with this initiative involve the decrease in waste of antifreeze. Currently, 42% of spent antifreeze is disposed of as hazardous waste because the organization used, the Defense Reutilization and Marketing Office, cannot recycle it. Both on-site and off-site recycling options provide a better recycling avenue because a greater amount could be recycled. This creates a reduction in raw material required and reduces pollution from the disposal of antifreeze. Estimates indicate that with on-site recycling as little as 10% would require disposal as hazardous waste. ECONOMIC EVALUATION A cost-benefit analysis of on-site antifreeze recycling determined an annual savings of over $5,600, with a payback period of 3 months. This is an average savings of $10.23 per gallon (for purchase and disposal).The following table gives information regarding the implementation and recurring costs associated with on-site antifreeze recycling. . Michael O'Connor Page 51 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Table 6.9: On-Site Antifreeze Recycling Cost Analysis CURRENT ANNUAL COSTS: Disposal: recycled anti-freeze (42%) contaminated anti-freeze (58%) gal/year cost/amount Subtotal: Purchasing: 231 319 550 $12.14 $10.08 $2,804.34 $3,215.52 $6,019.86 550 $4.37 $2,403.50 $8,423.36 TOTAL: IMPLEMENTATION COSTS: refractometer training (8 hours for shop worker) training from company TOTAL: POTENTIAL ANNUAL COSTS: Additives: P-Corrosion Inhibitor (74 oz) KOH pH Adjustor (2 oz) Virgin Anti-freeze (200 gallons @ $4.37/gallon) Resin Regeneration (once per year) cost/year $186.75 $200.00 $1,000.00 $1,386.75 amount/year cost/amount cost/year 10 10 200 gal 1 $63.38 $9.12 $4.37 $400 + freight $633.80 $91.20 $874.00 $450.00 $2,049.00 $11.55 $10.00 $28.05 Subtotal: 2 2 2 6 $23.10 $20.00 $56.10 $99.20 $25/hr $25/hr $25/hr Subtotal: 2 hr 1 hr 4 hr 7 hr $50.00 $25.00 $100.00 $175.00 $25/hr $25/hr $25/hr $25/hr Subtotal: 6 hr 3.5 hr 4 hr 4.5 hr 18 hr $150.00 $87.50 $100.00 $112.50 $450.00 Subtotal: Filters (changed twice per year): 1 Micron Filters 20 Micron Filters Charcoal Filter Cartridges Labor: Filter changes (2 per year) Resin Regeneration Operation (based on 180gal/hr machine rate) Transportation: Littleton (4hrs round trip + 2 hrs @ CSMS) Manchester (1.5hrs round trip + 2 hrs @ CSMS) Hillsboro (2hrs round trip + 2 hrs @ CSMS) Somersworth (2.5hrs round trip + 2 hrs @ CSMS) Waste Disposal: Used Filters (charcoal only) Oil Absorbant Pads (negligible contribution to waste) 2 $25.00 $0.00 $25.00 $2,798.20 Subtotal: TOTAL: RECURRING ANNUAL SAVINGS Current Annual Costs Potential Annual Costs ANTICIPATED SAVINGS: per gallon $15.91 $5.09 $10.82 per year $8,423.36 $2,798.20 $5,625.16 IMPLEMENTATION STATUS Michael O'Connor Page 52 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE Implementation Pending/Pursuing Funding. This initiative will be implemented if off-site recycling does not get approval. Funding will then be sought to cover minimal implementation costs. Off-Site Antifreeze Recycling Multiple off-site companies were researched and found to be inadequate for the needs of the NHARNG. There were only two favorable off-site recycling companies researched; Advanced Liquid Recycling, Inc. and a partnership between Antifreeze Recycling of New England (ARNE) and New England Environmental Services (NEES). Advanced Liquid Recycling, Inc. NHARNG TECHNICAL EVALUATION Concord Littleton Somersworth Hillsboro Manchester Advanced Liquid Recycling Inc Newington, NH Advanced 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, Consolidated United Industrial United Industrial Services provides the transportation, Recycling Co. Inc. Services Inc and Consolidated Recycling is the end destination of Troy, IN Meriden, CT the antifreeze and the site where the actual recycling occurs. The diagram to the right illustrates the “cradle-to-grave” trail. Figure 6.10: Off-Site Recycling "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 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 Michael O'Connor Page 53 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 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 System6 ENVIRONMENTAL EVALUATION The environmental benefit for this process is greater than on-site recycling. With this process, 100% of spent antifreeze could be recycled. This reduces the need for the manufacture of new antifreeze because more recycled antifreeze enters the market for purchase. There is a much smaller exposure to chemicals than with the on-site recycling which makes a safer workplace and reduces the chances of a chemical spill. 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 6.11: ALR Off-site Cost Analysis Cost/Drum Drums/Year Cost/Year 50/50 Blend $198.00 10 $1,980.00 Concentrated $286.00 10 $2,860.00 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). IMPLEMENTATION STATUS Available Option. This initiative has been researched and is available to implement at any time. ARNE and NEES Partnership TECHNICAL EVALUATION 6 List taken from Consolidated Recycling’s website: http://www.chem-group.com/consolidated.html Michael O'Connor Page 54 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE 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 payments7 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 50/50 premixed antifreeze is produced to service all fleets (Standard Green, Long Life, Red, and Heavy Duty) ENVIRONMENTAL EVALUATION Antifreeze recycling through ARNE in partnership with NEES will provide similar environmental benefits as recycling with ALR. 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. 7 Wilber, Spencer. E-mail correspondence regarding Antifreeze Recycling, Friday, August 01, 2003 Michael O'Connor Page 55 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 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. Antifreeze Recycling Cost 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. $8,000.00 Costs/Savings per Year $7,000.00 $6,000.00 $7,213.36 $5,000.00 $4,000.00 $6,443.36 $8,423.36 $5,625.16 $3,000.00 $2,000.00 $- $2,798.20 $1,980.00 $1,000.00 $Cost/Year Savings/Year $1,210.00 Current On-site Off-site with ALR Off-site with ARNE $8,423.36 $2,798.20 $1,980.00 $1,210.00 $- $5,625.16 $6,443.36 $7,213.36 Recycling Method Figure 6.12: Antifreeze Annual Cost/Savings Comparison Michael O'Connor Page 56 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 6: HAZARDOUS AND UNIVERSAL WASTE $16.00 Cost/Savings per Gallon $14.00 $12.00 $10.00 $8.00 $15.32 $10.23 $11.72 $13.12 $6.00 $4.00 $- $5.09 $2.00 $3.60 $2.20 $- Cost/Gallon Savings/Gallon Current On-site Off-site with ALR $15.32 $5.09 $3.60 Off-site with ARNE $2.20 $- $10.23 $11.72 $13.12 Figure 6.13: Antifreeze Average Cost/Savings Comparison 6.7.2 PRODUCT REPLACEMENT Product replacement includes paints, thinners, degreasers, cleaning solvents, and others chemical products. The replacement of solvent based products with aqueous-based or ‘natural’ solvents will create a safer working environment and allow for a healthier environment. The method by which this will be accomplished is through Affirmative Procurement and an AUTHORIZED USE LIST. More information can be found in Chapter 14 – Affirmative Procurement. Michael O'Connor Page 57 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 58 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 7: SOLID WASTE 7.1 GOALS To divert 40% of the solid waste stream from disposal to recycling by CY 2006 in order to meet the DOD Solid Waste Measure of Merit. This can be accomplished by establishing recycling programs on the State Military Reservation for cardboard, office paper, scrap wood, and tires and by encouraging individual OMS’s to establish programs with local transfer stations and recycling centers in order to reduce their solid waste stream. 7.2 BASELINE AND PROGRESS Table 7.1: Solid Waste Streams (lbs/year) Baseline Target: 40% Solid Waste Streams FY 2003 FY 2004 FY 2005 FY 2006 Recycled Wastes scrap metal 30,000 tires 47,600 used antifreeze 1919 used shop rags N/A spent lead-acid batteries N/A subtotal: 79,519 Non-Recycled Wastes cardboard 9,600 scrap wood 6,000 paper 52,800 "regular" garbage 31,440 spent batteries 1,118 non-regulated waste 5,511 subtotal: 106,469 TOTAL: 185,988 % diverted to recycling: 43% Note: Cardboard, paper, and “regular” garbage quantities are estimates based on SMR generation alone. Individual OMS’s are responsible for the recycling and disposing of these waste streams through local transfer stations where feasible and practical. 7.3 MAJOR SOLID WASTE STREAMS The major solid waste streams generated by NHARNG processes are separated into two categories, recycled solid waste streams and non-recycled solid waste streams. Michael O'Connor Page 59 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 7.3.1 RECYCLED WASTE STREAMS Recycled solid waste streams “include all non-hazardous waste as defined by 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 the individual 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, and acquisition of pollution prevention equipment. Figure 7.2: Scrap Metal collected for recycle Tires 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 through the DRMO 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 Figure 7.3: Tires Collected For Shipment and Recycled through the DRMO According to waste manifests, approximately 1919 lbs of used antifreeze is generated and recycled through DRMO per year. Please refer to Chapter 6 – Hazardous and Universal Waste for additional information regarding antifreeze and alternative recycling opportunities. Michael O'Connor Page 60 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 7: SOLID WASTE Used Shop Rags A shop rags laundering service is used to eliminate a potential hazardous waste stream. Instead of one-time-use cloth rags and paper towels, a laundering service delivers clean rags to the shops and removes soiled rags. They are then cleaned by the company and returned to service. Spent Lead-Acid Batteries Figure 7.4: Used Shop Rags at the AASF 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. 7.3.2 NON-RECYCLED 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. Cardboard 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. Michael O'Connor Page 61 UNH & NHPPP P2 Internship Program Figure 7.5: Scrap Wood behind the USP&FO Warehouse Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 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 tote, 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 with a strong education and awareness program to help promote successful recycling efforts. “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 at NHARNG facilities where solid waste is maintained by dumpster contracts held by the State. These facilities 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 7.6: "Regular" Garbage Estimates and Dumpster Information location amount size (cy) pick-ups/month cy/month lbs/year* cost/pick-up cost/year OMS #3 1 2 1 2 624 $232.68 $2,792.16 OMS #4 1 8 4 32 9,984 $37.50 $1,950.00 SMR, Building M 1 8 8 64 19,968 $25.50 $2,652.00 SMR, Building C 1 8 4 32 9,984 $25.50 $1,326.00 SMR, Building H 1 8 4 32 9,984 $25.50 $1,326.00 SMR, Building L 1 6 4 24 7,488 $21.50 $1,118.00 SMR, Building K 1 6 4 24 7,488 $21.50 $1,118.00 SMR, Building A 1 6 4 24 7,488 $21.50 $1,118.00 NHNG-TS 1 2 2 4 1,248 $29.50 $708.00 NHNG-TS 1 4 2 8 2,496 $59.50 $1,428.00 NHNG-TS 2 6 2 24 7,488 $89.50 $2,148.00 TOTAL: 12 64 39 270 84,240** $17,684.16 *Estimates are based upon a quarter cubic yard garbage bin found in the AASF filled with "regular" garbage consisting of food wrappers, paper, plastic bottles, paper, and packaging wastes 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. Michael O'Connor Page 62 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 7: SOLID WASTE 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. Michael O'Connor Page 63 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan The following chart illustrates the amount and percentage of each source contributing to solid waste streams as well as the type, amount, and percentage of waste diverted to recycle. Although spent lead-acid batteries and used shop rags are being recycled, the amount and percentage contributing to the recycled waste streams is not available. paper 52,800 lbs 28% NON-RECYCLED WASTE STREAMS 106,469 lbs 57% scrap wood 6,000 lbs 3% "regular" garbage 31,440 lbs 17% cardboard 9,600 lbs 5% spent batteries 1,118 lbs 1% used antifreeze 1919 lbs 1% RECYCLED WASTE STREAMS 79,519 lbs spent lead-acid batteries N/A tires 47,600 lbs 26% non-regulated waste 5,511lbs 3% scrap metal 30,000 lbs 16% used shop rags N/A Figure 7.7: Solid Waste Streams Michael O'Connor Page 64 UNH & NHPPP P2 Internship Program Shelley Dougherty 7.4 CURRENT P2 INITIATIVES 7.4.1 SCRAP METAL RECYCLING DESCRIPTION Approximately 30,000 lbs of scrap metal are recycled per year. The scrap metal from all NHARNG facilities is transported to the USP&FO Warehouse where it is collected in a large container to be recycled. ENVIRONMENTAL BENEFIT Recycling scrap metal diverts a large quantity of waste from the solid waste stream, thereby reducing the amount of waste that is disposed of in landfills. ECONOMIC BENEFIT Currently the NHARNG is receiving money for the scrap metal that is recycled. All money acquired through this recycling program is added to a fund site dedicated to the health and welfare of the troops as well as pollution prevention equipment. 7.4.2 SHOP RAG LAUNDERING WITH ALLTEX DESCRIPTION NHARNG uses shop rags for various cleaning purposes for the routine maintenance of vehicles. The used shop rags are picked up and laundered by Alltex who provide us with a laundering service. ENVIRONMENTAL BENEFIT Laundering the used shop rags reduces NHARNG’s hazardous waste stream and eliminates the use of a large quantity of paper towels, which were previously used prior to initiating the laundering of the shop rags. 7.4.3 ONE FOR ONE BATTERY EXCHANGE WITH EXIDE DESCRIPTION NHARNG participates in a one for one battery exchange with Exide. Transporters from Exide pickup used lead-acid batteries from NHARNG facilities and exchange them with new lead-acid batteries. Information regarding the quantity of batteries exchanged with Exide is not available. ENVIRONMENTAL BENEFIT Exchanging used lead-acid batteries with Exide reduces NHARNG’s hazardous waste stream. ECONOMIC BENEFIT Charges associated with the disposal of lead-acid batteries as hazardous waste are alleviated. Michael O'Connor Page 65 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 7.5 POTENTIAL P2 INITIATIVES 7.5.1 PAPER RECYCLING WITH TOBEY SCHOOL/REVAMP INC. DESCRIPTION Tobey School/Revamp Inc. is a recycling facility in Concord that recycles paper. They require the paper to be separated into three categories white office paper and envelopes, mixed colored paper and envelopes, and newspaper and magazines. Implementation of this initiative will help the NHARNG achieve compliance with the Solid Waste Measure of Merit established by the DOD. TECHNICAL EVALUATION In order for this program to be successful absolute participation is required of all staff members working at the SMR. Participation includes the conscious separation of paper into the three appropriate categories. All buildings will have several small totes for each category of recycled paper. These small totes will be emptied into larger 95 gallon totes with wheels which will reside in a convenient location in each building. When full, the 95 gallon totes will then be placed in one central location to be picked up and replaced by Tobey School/Revamp. ENVIRONMENTAL EVALUATION All the paper picked up by Tobey School/Revamp will be sorted and recycled. This will divert a large portion of the NHARNG’s solid waste stream to recycling. As a result, less solid waste will be disposed of in either a landfill or incinerated. Based upon an estimated 52,800lbs of paper that could potentially be recycled per year, the percent of solid waste diverted to recycling will increase from 44% to 73%, which will place NHARNG far above the present goal required by the DOD. ECONOMIC EVALUATION Currently Tobey School/Revamp provides all the necessary amount of large 95 gallon totes and provides their recycling services free of charge. All the small totes required to reestablish this program were purchased when paper recycling initially began in the past. Implementation Costs: None. Recurring Costs: None. Recurring Cost Savings: Recurring cost savings are dependent upon the volume of paper that is diverted from the solid waste stream. The more paper recycled, the less contracted dumpsters needed for disposal. Payback Period: Immediate IMPLEMENTATION STATUS: IN PROGRESS The implementation of a recycling program with Tobey School/Revamp is currently in progress. An initial meeting with Tobey School/Revamp has taken place and an awareness presentation and informative posters have been created. As soon as awareness has increased and participation by Michael O'Connor Page 66 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 8: AIR EMISSIONS SMR staff has been guaranteed this program will be ready for implementation. All that is required for this to begin is a phone call to Tobey School/Revamp. Totes will then be delivered, and paper will be recycled. 7.5.2 SCRAP WOOD RECYCLING DESCRIPTION Scrap Wood would be transported to PetroFiber, located in Henniker, New Hampshire. PetroFiber works with pallet recyclers who recycle/reuse any wood material they can. All non-reusable wood is then handled by PetroFiber. The waste wood is ground into boiler fuel or woodchips and sent to wood burning power plants for energy recovery. PetroFiber does not pickup or make any deliveries, so NHARNG would be responsible for all transportation costs. ENVIRONMENTAL EVALUATION Utilizing PetroFiber’s services will divert scrap wood from the solid waste stream thereby reducing the amount of waste that will be disposed of in a landfill or incinerated. The “good” pallets will be recycled or reused, and the waste wood will be burned for energy recovery. ECONOMIC EVALUATION PetroFiber charges $35.00 per ton. Based upon an estimate of 6000lbs of scrap wood per year, implementing this initiative would cost $105.00 per year plus the cost of transporting the wood. Current disposal costs are not known. Thus information regarding recurring cost savings (if any) and payback period are not available. IMPLEMENTATION STATUS: REQUIRES FURTHER INVESTIGATION In order for PetroFiber’s scrap wood recycling/reuse services to be utilized by NHARNG further information regarding current disposal procedures and costs must be acquired in order to conduct a more complete economic evaluation. If this opportunity should be chosen for future investigation the following contact information has been provided: Mr. Harry Smith PetroFiber Corporation Henniker, NH 03242 (603)428-7044 harry@bioenergycorp.com 7.5.3 RECHARGEABLE BATTERIES The use of rechargeable batteries within the NHARNG has not been well documented. More research should be done to determine the benefits, difficulties, and feasibility of increased rechargeable battery use. The U.S. Army Rechargeable Battery Program has posted information at the following address. http://www.monmouth.army.mil/cecom/Irc/power/rechargebat.html Michael O'Connor Page 67 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 68 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 8: AIR EMISSIONS CHAPTER 8: AIR EMISSIONS 8.1 GOALS Reduce air emissions 10% by FY 2005 from a FY 2002 baseline. 8.2 BASELINE AND PROGRESS Table 8.1: Air Emissions Based On 2002 Air Emissions Inventory Baseline Target: 10% Pollutant (tpy) FY 2002 FY 2003 FY 2004 FY 2005 SOx 1.811 NOx 1.890 CO 0.505 PM 0.251 VOC's 1.743 HAP's 0.475 Totals: 6.675 % Reduction: Note: Figures depicting emissions quantities based on source and location are given in Appendix F, as well as a more detailed emission table. 8.3 MAJOR AIR EMISSIONS SOURCES 8.3.1 MANCHESTER NHARNG INSTALLATION EMISSIONS SOURCES The air emissions evaluation of the Manchester NHARNG Instillation included the following facilities: Manchester Readiness Center/ Armory; Flammable Materials Building; and OMS #4. Distillate Oil Boilers There are two dual-fired boilers, both of which burn either No. 2 (distillate) fuel oil or natural gas located in the armory. Natural Gas Boilers/Heaters As previously stated there are two dual-fired boilers which burn No. 2 (distillate) fuel oil as well as natural gas. In addition, there is a natural gas-fired hot water heater located in the armory. Michael O'Connor Page 69 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Used Oil Burner OMS #4 has a used oil burner that is used to provide heat to the building. This burner typically burns either used motor oil or used diesel fuel that is generated by the various OMS’s throughout the state. Stationary Internal Combustion Engines OMS #4 has a steam cleaner that is occasionally used to clean the floor of the building. Vehicle Exhaust emissions from diesel trucks OMS #4 is equipped with six 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). Miscellaneous use of paints and solvents Small painting operations occur throughout the Manchester NHARNG installation and typically include “spot” painting or touch-up operations, using aerosol spray cans, and/or brush painting. In addition, solvents such as methanol and alcohols and spray cans containing other solvents are used as well. Welding operations Electric arc welding is performed at OMS #4 on a periodic basis for repairing metal parts. Stainless steel welding rods are typically used. Emissions from storage tanks OMS #4 has a 300 gallon used oil storage tank that is used in conjunction with the used oil burner. 8.3.2 SMR EMISSION SOURCES The air emission evaluation of the NHARNG’s SMR in Concord included the following facilities: Building A – United States Property & Fiscal Office; Building B – Offices/State Storage; Building C – Adjutant General’s Department Offices and Boiler Room; Building D – Vehicle Storage; Building E – Vehicle Storage; Building F – State Maintenance Shop (SMS)/3643rd Svc Co/Directorate of Information Mgt (DOIM)/Safety & Occupational Health; Building G – CSMS Annex; Michael O'Connor Page 70 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 8: AIR EMISSIONS Building H – CSMS; Building K – AASF; Building L – USPFO Warehouse; Building M – Readiness Center/Concord Armory; Building P – General Purpose Storage; Building Q – Flammable Materials Building; Building T – General Purpose Storage; and Building V – Counter Drug Program Offices. Distillate Oil Boilers There are four dual-fired boilers and two oil-fired boilers. The four 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 As previously stated, there are four dual-fire boilers which burn either No. 2 (distillate) fuel oil or natural gas. In addition, there are two natural gas-fired boilers, eleven natural gas heaters and four natural gas hot water heaters. Stationary Internal Combustion Engines There are several stationary internal combustion engines (SICE) on-site which include the following: Emergency Generator; Steam Cleaner; Auxiliary Ground Powering Unit (AGPU); 5 Helicopter Heaters; and Power Washer. Vehicle Exhaust emissions from diesel trucks OSM #1 and the CSMS are equipped with vehicle exhaust hoses that are placed on the tailpipes of the trucks that 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). Miscellaneous use of paints and solvents The CSMS has a paint spray booth that is currently not being used do to ventilation deficiencies. In addition, small painting operations occur throughout the Concord NHARNG installation and typically include “spot” painting or touch-up operations, using aerosol spray cans, and/or brush Michael O'Connor Page 71 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan painting. In addition, solvents such as methanol and alcohols and spray cans containing other solvents are used as well. Welding operations Welding is performed on a periodic basis for repairing metal parts. 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 additions, oxygen-acetylene cutting and soldering are performed. Cold Cleaning operations CSMS has one cold cleaning tanks. This cold cleaning tanks uses a product named Zep Sun Solvent #0419, which must be diluted at a 5:1 ratio for use. Emissions from storage tanks There are several aboveground fuel oil storage tanks at various locations across the Concord NHARNG installation. Note: Upon the completion of the new AASF in the spring of FY 2004 additional air emissions sources will need to be evaluated, which will include an on-site emergency generator and 2 above ground JP-8 jet fuel storage tanks (one new and one which will be transferred from the existing AASF). Table 8.2: Types and Sources of Air Emissions Manchester and Concord Emission Source SOx Distillate Oil Boilers 1.590 Waste Oil Boiler 0.030 Natural Gas Boilers/Heaters 0.001 Vehicle Exhaust 0.000 Stationary Internal Combustion Engines0.190 Paints and Solvents 0.000 Welding Operations 0.000 Tank and Fueling Emissions 0.000 Cold Cleaners 0.000 TOTALS: 1.811 Michael O'Connor NOx 0.880 0.010 0.150 0.030 0.820 0.000 0.000 0.000 0.000 1.890 CO 0.220 0.001 0.110 0.040 0.134 0.000 0.000 0.000 0.000 0.505 PM 0.150 0.040 0.011 0.001 0.044 0.000 0.004 0.000 0.000 0.251 VOC's HAP's TOTALS: 0.014 0.003 2.857 0.001 0.001 0.083 0.008 0.003 0.283 0.005 0.000 0.076 0.075 0.001 1.263 1.610 0.462 2.072 0.000 0.000 0.004 0.030 0.006 0.036 0.000 0.000 0.000 1.743 0.475 6.675 Page 72 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 8: AIR EMISSIONS 2.000 1.800 Tons Per Year 1.600 1.400 1.200 1.000 0.800 0.600 0.400 0.200 0.000 SOx NOx CO PM VOC's HAP's EmissionsType Distillate Oil Boilers Natural Gas Boilers/Heaters Stationary Internal Combustion Engines Welding Operations Waste Oil Boiler Vechicle Exhaust Paints and Solvents Tank and Fueling Emission Figure 8.3: Air Emissions Sources 8.4 POTENTIAL P2 INITIATIVES 8.4.1 ALTERNATIVE “ENVIRONMENTALLY FRIENDLY” PAINTS AND SOLVENTS According to the Air Emissions Inventory conducted in April 2002, paints and solvents comprise 31% of the total air emissions generated by NHARNG. The majority of the emissions from paints and solvents are VOCs. The development and implementation of an Authorized Use List will ensure that only low VOC paints and solvents are purchased and used. For more detailed information regarding the Authorized Use List please refer to Chapter 14. Paints and Solvents 31% Other Emission Sources 69% Figure 8.4: Composition of Air Emissions Sources Michael O'Connor Page 73 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 74 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 9: WATER AND WASTEWATER 9.1 GOALS The NHARNG’s goal is to show continuous annual reduction in water consumption and wastewater generation. 9.2 BASELINE AND PROGRESS Table 9.1: Water Consumption (drinking water and wastewater) Baseline FY 2003 Amount (gal/year) 750,000 2004 Target 2005 2006 Table 9.2: Oil-Water Separator Flow Rates Location Littleton Somersworth Manchester Hillsboro CSMS CSMS Annex AASF # Separators Permit No. Max. Daily Flow Rate (gal) 1 1 1 1 1 1 1 IDP 96-010 C14801 3022 DH715931 H39 H38 H37 200 No Limits 500 No Limits 1050 700 1460 9.3 CURRENT P2 INITIATIVES Current P2 initiatives consist of wastewater pretreatment. This is accomplished by the use of oilwater separators at all OMSs and facilities on the SMR. 9.4 POTENTIAL P2 INITIATIVES Vehicle washing is done on an “as needed” basis, and water use is limited to necessary functions. As such, there are no P2 initiatives recommended at this time. Michael O'Connor Page 75 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 76 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 10: EPA PRIORITY CHEMICAL REDUCTION AND TRI FORM R REPORTING 10.1 EPA PRIORITY CHEMICALS 10.1.1 GOAL NHARNG’s goal, as required by EO 13148, is to reduce the use of EPA priority chemicals by 50% by December 31, 2006 from a baseline of 2002. 10.1.2 BASELINE AND PROGRESS Analysis of NHARNG’s hazardous material inventory has led to the conclusion that NHARNG does not purchase or use any materials containing EPA priority chemicals. Therefore, the above stated goal has been met, and NHARNG shall remain in compliance as long as materials containing EPA priority chemicals are restricted from use. A list of hazardous materials stocked and in use at NHARNG facilities and a table containing the EPA’s 30 Waste Minimization Priority Chemicals can be found in Appendix II. 10.2 TRI FORM R REPORTING 10.2.1 GOAL The goal for TRI chemical release, as required by EO 13148, is to show a 10% reduction per year, or 50% reduction overall by 2006 from a 2000 baseline. 10.2.2 BASELINE AND PROGRESS The NHARNG does not have enough of any TRI chemical to require Form R Reporting. The requirements for Form R Reporting can be found in the “Community Right To Know Compliance Manual.” No quantitative records on TRI chemical use are available. Records should be kept to track use and release of TRI chemicals so that progress toward this goal can be tracked. Michael O'Connor Page 77 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 78 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 11: OZONE DEPLETING SUBSTANCES 11.1 GOAL The current goal established by Army policy for ozone-depleting substances (ODSs) is to eliminate Class I ODSs from all facilities on Army installations by the end of FY038. 11.2 BASELINE AND PROGRESS According to the NHARNG Ozone-Depleting Chemical Elimination Certification, granted in December 2000, “Class I Ozone-Depleting Chemicals (ODCs) are not in use9.” Therefore, the goal of eliminating all Class I ODSs has been met. According to the requirements of the Title VI of the Clean Air Act Amendments (CAAA), the NHARNG installations are exempt from ODS recordkeeping requirements do to the fact that none of the facilities own or operate appliances that contain 50 or more pounds of refrigerant. 11.3 DESCRIPTION OF ODS-CONTAINING EQUIPMENT The following is a list of general types of ODSs used in Army facilities. Please note that not all types are used by NHARNG. This list should be used to identify ODS-containing equipment in the future if such equipment should be procured by NHARNG. Halons Fixed, total flooding room fire suppression (halon 1301) Portable (two-wheeled) flightline fire protection (halon 1211) Hand-held building fire extinguishers (halon 1211) CFCs Large building chillers (R-11, R-12) Large fixed air conditioning systems (R-12, R-500, R502) Climate test facilities (R-13, R-113, R-114) Environmentally controlled warehouses (R-11, R-12, R-113) Walk-in refrigerators and freezers (R-12, R-502) Smaller, older appliances like ice-making machines (R-12) Older household appliances (R-12) 8 Guide to Preparing Ozone-Depleting Chemical Elimination Plans for Installations prepared by Mr. David A. Koehler, Senior Pollution Prevention Engineer and Army ODC Elimination Project Manager Alexandria, Virginia. January 1999. 9 New Hampshire Army National Guard Ozone-Depleting Chemical Elimination Certification prepared by Roy F. Weston, inc. December 2000. Michael O'Connor Page 79 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Air conditioners in non-tactical vehicles (R-12) HCFCs Smaller fixed air conditioning systems (R-22) Window air conditioners (R-22) Solvents: Maintenance and repair activities (carbon tetrachloride, TCA) General metal cleaning (carbon tetrachloride, TCA) Following is a comprehensive list of all NHARNG federally owned and operated ODS-containing equipment according to location. This list should be updated as units are installed or replaced. The data used to compile these lists was taken from the Energy Audit performed by AMEC in July 2003.10 Table 11.1: Air Conditioning Units Type and Number Capacity of Unit Amount of Location of Units (Btu/hr) Refrigerant State Maintenance Building 3 Fedders window units 7,500 0.6 lbs R22 each State Maintenance Building 1 GE window unit 12,000 1 lb R22 State Maintenance Building 1 window unit 24,000 2 lbs R22 State Maintenance Building 1 window unit 10,500 0.9 lbs R22 AASF* 2 York rooftop units Unknown Unknown AASF* 3 Carrier ceiling units Unknown Unknown AASF* 2 window units 5,000 0.6 lbs R22 each USP&FO Warehouse 1 Rheem window unit 36,000 3 lbs R22 USP&FO Warehouse 1 Amana window unit 24,000 2 lbs R22 USP&FO Warehouse 1 Friedrich window unit 24,000 2 lbs R22 CSMS* 1 Carrier ceiling unit 95,000 8.4 lbs R22 CSMS Annex (OMS #1) 1 York rooftop unit 48,000 4 lbs R22 Littleton OMS #2 1 York rooftop unit 60,000 5 lbs R22 Manchester OMS #4 1 Frigidare window unit 8,000 0.6 lb R22 NHNGTS Dining Hall 1 Trane rooftop unit 180,000 15 lbs R22 NHNGTS Cooper House 1 Hampton Bay rooftop unit 10,000 0.8 lbs R22 NHNGTS Elec. Skills Trainer Bldg1 Lennox rooftop unit 60,000 5 lbs R22 * Indicates data taken from 2002 Air Emission Inventory11. 10 Energy Audit of Army National Guard Facilities: State of New Hampshire, performed by AMEC Lakewood, Colorado July 2003. 11 Air Emissions Inventory and Air Toxics Compliance Determination: Concord and Manchester, New Hampshire submitted by AMEC Earth & Environmental Westford, Massachusetts April 2002. Michael O'Connor Page 80 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 11: OZONE DEPLETING SUBSTANCES Table 11.2: Refrigerators and Freezers Location Type and Number of Unit NHNGTS Dining Hall 3 Jordan kitchen refrigerators NHNGTS Dining Hall 1 McCall kitchen refrigerator NHNGTS Dining Hall 2 Manitowoc kitchen freezer NHNGTS Dining Hall 1 Manitowoc kitchen icemaker NHNGTS Thomas Hall 19 Marvel dorm room refrigerators Volts (V) 115 120 N/A N/A 115 11.4 CURRENT P2 INITIATIVES Air conditioners are used only when necessary to minimize their impact. When in use, surroundings are kept as contained as possible to minimize the amount of energy used in maintaining the specified temperature. 11.5 POTENTIAL P2 INITIATIVES 11.5.1 RESEARCH DESCRIPTION When replacement of an ODS containing device or material is necessary, research should be undertaken to determine the most efficient and environmentally friendly option. ECONOMIC ANALYSIS By selecting the most efficient product or material further costs of replacement or repair can be avoided, making the most efficient product or material the most cost-effective option. ENVIRONMENTAL ANALYSIS Choosing the most efficient product or material will help reduce pollution both directly and indirectly. The most efficient product should be investigated to determine that it also produces the least pollution. Indirectly, pollution will be prevented because less energy will be used for an equivalent output. Less energy demand means that less energy will have to be produced at power plants, which emit pollution from burning coal, natural gas, or other fuel. Michael O'Connor Page 81 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 82 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS CHAPTER 12: VEHICLE FUEL CONSERVATION 12.1 GOALS According to the DOD’s Alternative Fueled Vehicles Measure of Merit, the following goals must be met: Increase the average fuel economy of cars and light trucks by 3 mpg by the end of FY 2005 from a FY 1999 baseline. Reduce vehicle petroleum consumption 20% by the end of FY 2005 from a FY 1999 baseline Ensure that alternative fuels account for at least 50% of the fuels used in dual-fuel alternative fuel vehicles Ensure that at least 75% of car and light truck procurements are alternatively-fueled vehicles (AFV). 12.2 BASELINES AND PROGRESS Currently the NHARNG leases 21 non-tactical vehicles and purchases all fuel for those vehicles from GSA. NHARNG is not authorized to purchase AFVs and must wait for GSA to make these vehicles available. Therefore, “under current Army policy the GSA is responsible for meeting the [AVF] goals stated above as prescribed in the DOD MoM for the Army and its components.”12 The following tables have been provided to track the NHARNG’s future progress toward achieving the above stated goals and to evaluate detailed fuel use data from the prescribed baseline year of FY 2003 in order to determine where improvement is possible and necessary. Table 12.1: Average Fuel Economy Baseline Target: 3mpg FY 2003 FY 2004 FY 2005 mpg 22 Reduction - 12 Email correspondence with Mr. Robert Luther, NGB-ARE P2 Program Manager July 16, 2003 Michael O'Connor Page 83 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Table 12.2: Detailed Fuel Use FY 200313 Year 2002 2002 1999 2000 2002 2002 2002 2003 2003 2003 2000 2002 2002 2001 Model License # MALIBU G10-21969 STRATUS SE G10-21996 CARAVAN FFV G41-42855 CARAVAN FFV G41-49374 CARAVAN SE G41-65357 CARAVAN SE G41-65362 CARAVAN SE G41-65392 CARAVAN SE G41-70451 CARAVAN SE G41-70452 CARAVAN G41-70465 RAM3500* G43-09197 G3500 EXPRES* G43-20767 BLAZER LS G61-12196 SUBURBAN LS G62-06318 Subtotal: w/o heavy trucks* Fuel UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD UNLD Miles Milage Gallons Cost 9,750 28 351.75 $536.02 12,789 29 447.45 $680.54 12,549 24 518.33 $807.04 12,886 21 603.38 $922.05 16,392 23 722.88 $1,109.72 9,234 21 444.60 $672.29 22,374 23 983.36 $1,550.78 3,299 20 162.64 $245.54 5,601 20 274.14 $429.25 3,701 20 180.79 $289.87 12,453 14 895.61 $1,419.32 14,379 14 1,011.59 $1,569.34 5,661 18 320.66 $492.74 5,117 13 386.45 $583.63 146,185 20 7,304 $11,308.14 119,353 22 5,396 8,319 2000 1999 2003 1992 1994 1996 1992 C6500* TC2000 FC* FC 44 PASS* TC2000* TC2000* TC2000* TC2000* DISL DISL DISL DISL DISL DISL DISL DISL 4,474 5,085 7,461 4,936 7,949 7,623 4,858 42,386 188,571 G82-06373 G32-00907 G32-01632 G32-32350 G32-34955 G32-35600 G32-36151 Subtotal: TOTALS: 8 11 9 10 10 11 7 9 16 560.38 480.75 848.35 471.80 794.22 690.85 688.39 4,535 11,838 $916.71 $832.57 $1,464.54 $768.92 $1,364.66 $1,167.36 $1,201.48 $7,716.23 $19,024.38 * Indicates heavy trucks that are exempt from the average fuel economy goal. 12.3 CURRENT P2 INITIATIVES Currently NHARNG attempts to coordinate site visits in order to reduce the use of vehicles. However, this initiative requires more effort and attention in order to attain its maximum effectiveness. For this reason coordinated site visits are also suggested as a potential P2 initiative. In addition, NHARNG removed 6 sets of in-ground fuel tanks and now purchases all movility fuel for tactical vehicles from the Department of Transportation. 13 GSA Fleet Inventory, prepared by Duane Vallee July 16, 2003 Michael O'Connor Page 84 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 12: VEHICLE FUEL CONSERVATION 12.4 POTENTIAL P2 INITIATIVES 12.4.1 COORDINATED SITE VISITS DESCRIPTION Coordinating site visits such that a whole group of people will be available to attend at one time will allow for multiple tasks to be accomplished in a single trip. This will alleviate both the need for additional transportation and fuel usage as well as the aggravation felt on part of the site staff who must allocate valuable time to facilitate site visits. ENVIRONMENTAL EVALUATION Coordinating site visits will eliminate unnecessary travel and will therefore reduce the quantity of fuel used. ECONOMIC EVALUATION Reducing the quantity of fuel used will reduce the overall amount of money spent purchasing fuel. 12.4.2 ANTI-IDLING DESCRIPTION Establishing an anti-idling policy would prohibit drivers from leaving vehicles idling when not in use i.e. leaving vehicles running for air conditioning/heating purposes when unnecessary ENVIRONMENTAL EVALUATION When vehicles are left idling not only is unnecessary fuel consumed but toxins are also emitted into the atmosphere. Establishing an anti-idling policy would decrease the amount of fuel consumed per year as well as decrease the amount of pollutants emitted through mobile sources. ECONOMIC EVALUATION Requiring all vehicles to be turned off when not in use would conserve fuel, which in tern would require less fuel to be purchased per year. Michael O'Connor Page 85 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 86 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS CHAPTER 13: ENERGY CONSERVATION 13.1 GOAL NHARNG’s goal is reduce energy consumption by 30% per square foot by 2005 and 35% by 2010 from a 1985 baseline in order to meet the requirements of EO 13123. 13.2 BASELINE AND PROGRESS Table 13.1: Energy Consumption Summary – Electricity Used Per Square Foot Baseline FY 2003 kWh/sqft/yr 82.9 % Reduction - Target: 30% Target 35% FY 2004 FY 2005 FY 2010 Table 13.2: Energy Consumption – Electricity Used Per Location FY 2003 Location NHNG Training Site Administration Bldg Foss Dorms Bldgs 2,3,4 McLean Dormitory Lower Foss Dormitory Hall Dining Center Thomas Hall Dormitory Cooper House Admin Electronic Skills Trainer Area (sqft) Elec. (kWH/yr) Elec. (kWh/sqft/yr) subtotal: State Military Reservation State Maintenance Bldg CSMS Annex (OMS #1) CSMS AASF USP&FO Warehouse subtotal: Organizational Maintence Shops Littleton OMS #2 Somersworth OMS #3 Manchester OMS #4 Hillsboro OMS #5 subtotal: TOTAL: Michael O'Connor 15,082 4,642 4,562 4,317 5,458 13,329 3,749 2,625 53,764 115,037 28,768 N/A N/A 102,880 46,651 11,497 N/A 304,833 17,879 2,839 25,728 28,449 15,925 90,820 100,364 19,737 157,876 221,705 88,211 587,893 3,663 3,388 9,503 5,669 22,223 166,807 N/A N/A 43,409 40,204 83,613 976,339 7.6 6.2 N/A N/A 18.8 3.5 3.1 N/A 39.2 5.6 7.0 6.1 7.8 5.5 32.0 N/A N/A Page 87 UNH & NHPPP P2 Internship Program 4.6 7.1 11.7 82.9 Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 13.3 ENERGY ASSESSMENT SUMMARY AMEC performed an Energy Assessment of the NHARNG facilities in July 2003. The purpose of the Energy Assessment was to inventory and evaluate the condition of energy consuming equipment. The following is a summary of the results and recommendations obtained from the Energy Assessment. Controls Automated controls are few and far between. Programmable thermostats and controls, when encountered, were not programmed correctly. Good control systems would be the largest single source of savings for NHARNG. Lighting The majority of the facilities had the lights turned off in unoccupied areas of the buildings. Whether this practice maintained during dark winter months is unknown. The lighting at almost all of the facilities is T12 florescent and incandescent. Even in newly renovated facilities T12 fluorescent fixtures were installed instead of the more energy efficient T8 fixtures. Another energy saving candidate is replacement of incandescent exit signs to LED as almost all of the facilities assessed had incandescent exit signs. Possible lighting retrofits will have to be analyzed as to the hours of use, especially at the Training Site which is either partially occupied or only occupied parttime. HVAC A large number of buildings have major portions or all piping that requires insulation on the heating water and domestic hot water piping. The energy loss due to conduction losses from the bare piping can be recouped very quickly by insulating the pipes. Nearly all the building heating circulation pumps encountered are in need of replacement. Ancillary Systems Several of the facilities assessed were using the boiler to heat domestic water even during summer months. Firing a large boiler to heat a small amount of domestic water is very inefficient. During the heating season the practice makes sense, but a small gas or oil-fired water heater for summer use is a more energy efficient means of heating domestic water. Replacing electric water heaters with natural gas, fuel oil, or propane should be undertaken statewide. 13.4 POTENTIAL P2 INITIATIVES Potential energy conservation initiatives as suggested in the Energy Assessment are listed for each facility in the following table. Michael O'Connor Page 88 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 13: ENERGY CONSERVATION Table 13.3: Energy Conservation Initiatives Location State Maintenance Building CSMS CSMS Annex (OMS #1) AASF Suggested Energy Conservation Initiatives Add storm windows to single-pane windows Upgrade incandescent exit signs Replace T12 fluorescent and incandescent lighting with T8 HW reset control for boiler Seal around all overhead door openings and exterior personnel doors Insulate heating water return pipe header No recommendations made Replace T12 fluorescent and incandescent lighting with T8 Replace work bay furnace with infrared heaters Upgrade air compressor, add outside air intake NOT INCLUDED IN SCOPE OF ENERGY ASSESSMENT De-lamp office areas Replace T12 fluorescent lighting in warehouse offices with T8 HW reset control for boiler Remove domestic water heating from new boiler Shut-off exterior light over entry operating during daylight hours Replace T12 fluorescent and incandescent lighting with T8 NHNGTS Replace boiler – in poor material condition Administrative Building Insulate HW and DHW piping Repair propane leak Heating control system upgrade, 2 thermostats per floor USP&FO Warehouse Michael O'Connor Page 89 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Location NHNGTS Lower Foss Dorm NHNGTS McLean Dorm NHNGTS Upper Foss Dorm NHNGTS Dining Hall NHNGTS Cooper House Michael O'Connor Suggested Energy Conservation Initiatives Replace T12 fluorescent and incandescent lighting with T8 Replace boiler – in poor material condition Insulate DHW storage tank Insulate HW and DHW piping Replace electric heat Control system Replace T12 fluorescent and incandescent lighting with T8 Insulate DHW piping Replace electric heat Control system Replace T12 fluorescent and incandescent lighting with T8 Insulate DHW piping Program rooftop air conditioning unit controls for unoccupied and occupied temperature set points Turn off empty refrigerators between use Remove electric heater from internal electric room De-lamp vending machines Replace T12 fluorescent and incandescent lighting with T8 HW reset control for boiler Insulate HW and DHW piping in mechanical room Install small propane-fired or electric water heater for summer hot water usage Upgrade incandescent exit signs Page 90 UNH & NHPPP P2 Internship Program Shelley Dougherty CHAPTER 13: ENERGY CONSERVATION Location Suggested Energy Conservation Initiatives Replace T12 fluorescent and incandescent lighting with T8 Insulate forced air system ductwork Upgrade incandescent exit signs Replace T12 fluorescent and incandescent lighting with T8 HW reset control for boiler Insulate heating water and domestic water piping in mechanical room Shut off dorm room refrigerators when not in use Upgrade incandescent exit signs Replace T12 fluorescent and incandescent lighting with T8 Window upgrades for single-pane windows Install radiant heating system Control system Infiltration around windows and doors NOT INCLUDED IN SCOPE OF ENERGY ASSESSMENT Replace T12 fluorescent and incandescent lighting with T8 Air compressor improvements, use of outside air, efficient motors, moisture drain, and sequencing to use better compressor as primary Window upgrades for single-pane windows Control systems Replace T12 fluorescent and incandescent lighting NHNGTS Electronic Skills Trainer NHNGTS Thomas Hall Dorm Littleton OMS #2 Somersworth OMS #3 Manchester OMS #4 Hillsboro OMS #5 Michael O'Connor Page 91 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 92 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS CHAPTER 14: AFFIRMATIVE PROCUREMENT 14.1 BACKGROUND The Affirmative Procurement Program is a product of the 1976 Resource Conservation Recovery Act. It is directed by Executive Order 13101, “Greening the Government through Waste Prevention, Recycling, and Federal Acquisition.” It “directs federal agencies to purchase recycled and environmentally preferable products and services.”14 It can also be found in the Federal Acquisition Regulations. 14.2 CURRENT STATUS The NHARNG purchases many of their products from the General Services Administration (GSA). The GSA maintains an Affirmative Procurement Program which targets products identified by the EPA that contain recycled material. Also included in this are “products or services that are environmentally preferable,” and “products listed by the USDA which contain bio-based materials.”15 For specific text on the GSA Affirmative Procurement Program, see Appendix N. The NHARNG has not established a separate Affirmative Procurement Program, and relies on GSA specifications regarding environmentally preferable products. 14.3 POTENTIAL EXPANSION The goal of a NHARNG Affirmative Procurement Program would be to encourage and facilitate the purchase and use of recycled and environmentally sound products while minimizing the purchase and use of non-recycled and environmentally unsafe products. The goal is to help this program expand in order to accomplish a widespread pollution prevention effort. The NHARNG should develop an Affirmative Procurement Program to more clearly define the goal and the progress of AP. 14.3.1 AUTHORIZED USE LIST (AUL) An authorized use list would be the major component of the NHARNG AP Program. TECHNICAL EVALUATION Any products suggested as replacements must be tested and researched thoroughly to determine if they meet military specifications. Additionally, any replacements must show comparable durability and performance. ENVIRONMENTAL EVALUATION 14 Source: Army Environmental Center, P2 Program, AP – http://aec.army.mil/usaec/p2/app00.html 15 Quote source: GSA Affirmative Procurement Program (3/18/03) http://www.gsa.gov/Portal/offerings_content.jsp?channelID=-13905&programID=10905 Michael O'Connor Page 93 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Any substitute products must be able to show a distinct environmental benefit. All areas must be considered to ensure that use of the replacement will not create a new environmental issue, or make significant negative changes to an existing issue. Example: Product A creates contaminated waste oil. The replacement, Product B, does not create contaminated oil, but does create 4 tons of solid waste. Now instead of one contaminated oil drum, a truckload of solid waste must be brought to a landfill. ECONOMIC EVALUATION It must be shown that a replacement product can accomplish the same task as an environmentally unfriendly product, and that the new product is still a cost-effective solution. If Product A costs $14 a can, then the new product must show that it can be obtained at nearly the same price per mass or volume. If it cannot, then the necessity of use (i.e. regulatory requirement, etc.) must be determined. IMPLEMENTATION A list of preferred products should be created and maintained by the Environmental Office in order to foster greater compliance with the AP Program. This list could include the common product (environmentally unfriendly) and the preferred alternative (AP environmentally preferred). This list should be distributed to the appropriate leadership within each facility and posted in a highly visible location. Additionally, a widespread education campaign should be launched focusing on the goals of AP and the need for participation in this program. Michael O'Connor Page 94 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX I: EPA WASTE MINIMIZATION PRIORITY CHEMICALS APPENDIX I: EPA WASTE MINIMIZATION PRIORITY CHEMICALS16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Organic Chemicals and Chemical Compounds 1,2,4-Trichlorobenzene 1,2,4,5-Tetrachlorobenzene 2,4,5-Trichlorophenol 4-Bromophenyl phenyl ether Acenaphthene Acenaphthylene Anthracene Benzo(g,h,i)perylene Dibenzofuran Bioxins/Furans (considered one chemical on this list) Endosulfan, alpha Endosulfan, beta Fluorene Heptachlor Heptachlor epoxide Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclohexane, gamma Hexachloroethane Methoxychlor Naphthalene PAH Group (as defined in TRI) Pendimethalin Pentachlorobenzene Pentachloronitrobenzene Pentachlorophenol Phenanthrene Pyrene Trifluralin Metals and Metal Compounds Cadmium Lead Mercury CASR No. 120-82-1 95-94-3 95-95-4 101-55-3 83-32-9 208-96-8 120-12-7 191-24-2 132-64-9 959-98-8 33213-65-9 86-73-7 76-44-8 1024-57-3 118-74-1 87-68-3 58-89-9 67-72-1 72-43-5 91-20-3 40487-42-1 608-93-5 82-68-8 87-86-5 85-01-8 129-00-0 1582-09-8 CASR No. 7440-43-9 7439-92-1 7439-97-6 16 U.S. Environmental Protection Agency, Waste Minimization: Priority Chemicals http://www.epa.gov/epaoswer/hazwaste/minimize/chemilist.htm Michael O'Connor Page 95 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan EPA has identified 26 organic chemicals and three metals to serve as the highest priorities for waste minimization. The organic chemicals included in the list were selected following an agency-wide expert review of scientific information available for these chemicals. Based on its review, EPA concluded these 26 organic chemicals are persistent, bioaccumulative, and toxic (PBT). They are currently being generated in industrial waste and are found in soil, sediment, ground water, surface water, air, and/or animals and plants as a result of past and present releases. Even when released in very small amounts, they accumulate and can cause environmental problems. Many of these organic chemicals are difficult to clean up after they get into the environment resulting in costly clean up efforts. The three metals included in the list are known to occur frequently in Resource Conservation and Recovery Act (RCRA) regulated industrial wastes, and often “trigger” RCRA Toxicity Characteristic criteria. Michael O'Connor Page 96 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX II: NHARNG HAZARDOUS MATERIALS INVENTORY APPENDIX II: NHARNG HAZARDOUS MATERIALS INVENTORY The following inventory includes all products found in flammable storage cabinets in NHARNG facilities addressed in the scope of this plan. This inventory only details the type of product stored in the flammable cabinets and is not representative of the quantity or frequency of product use. 2640-00-138-8324 Solution,Buffing 6810-00-201-0906 Alcohol,Denatured 2640-00-256-5526 Lubricant,Tire And Rim 6810-00-249-9354 Sulfuric Acid,Electrolyte 2640-00-256-5527 Lubricant,Tire And Rim 6810-00-264-6715 Molybdenum Disulfide,Technical 2640-00-264-6642 Lubricant,Inner Tube 6810-00-275-6010 Methanol,Technical 2640-00-922-6917 Bonding Compound,Tire Repair 6810-00-543-7415 Alcohol,Denatured 2910-01-128-9537 Engine Starting Fluid (Diesel Start) 6810-00-597-3608 Methanol,Technical 3439-00-184-8960 Solder,Lead Alloy 6810-00-843-1640 Sulfuric Acid,Electrolyte 3439-00-255-4566 Flux,Soldering 6830-00-169-0800 Oxygen,Technical 3439-00-255-4572 Flux,Brazing 6830-00-584-3041 Propane 3439-00-262-2648 Electrode,Welding 6840-00-570-5299 Sanitizer-Detergent,General Purpose 3439-00-262-2652 Electrode,Welding 6850-00-001-4193 Water Indicating Paste 3439-00-262-2653 Electrode,Welding 6850-00-177-5094 Silicone Grease 3439-00-262-2743 Electrode,Welding 6850-00-181-7929 Fleet Charge Antifreeze & Coolant 3439-00-288-0868 Flux,Soldering 6850-00-274-5421 Cleaning Compound,Solvent 3439-00-640-3713 Flux,Brazing 6850-00-281-1985 Dry Cleaning Solvent 5970-00-962-3335 Insulating Varnish,Electrical 6850-00-485-4697 Cleaning Compound,Optical Lens 6140-01-210-1964 Lead Acid Battery 6850-00-598-7311 Leak Preventive Compound,Radiator 6140-01-431-1172 Battery,Storage 6850-00-664-1257 Silicone Compound 6140-01-446-9506 Lead Acid Battery 6850-00-823-7861 Fuel,Engine Primer 6505-00-104-9000 Denatured Ethyl Alcohol 6850-00-880-7616 Silicone Grease 6505-00-174-2293 Nitrogen Compressed 6850-00-926-2275 Cleaning Compound,Windshield 6630-01-011-5039 Test Kit,Antifreeze 6850-01-063-4760 Cleaning Compound,Solvent Michael O'Connor Page 97 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 6850-01-082-6783 Fuel,Engine Primer 8010-00-297-0567 Enamel, Lo Voc White 6850-01-085-1423 Carbon Removing Compound 8010-00-297-0585 Enamel Alkyde, Lo Voc Yellow 6850-01-246-6544 Stabilizer Additive,Diesel Fuel 8010-00-297-2105 Enamel Olive Drab 6850-01-377-5074 Inhibitor,Icing,Fuel System 8010-00-298-2302 Enamel Alkyd Gloss Lo Voc Blue 6850-01-441-3218 Antifreeze 8010-00-348-7715 Enamel, Brown 7510-00-183-7698 Ink,Marking Stencil 801000-527-2053 Enamel Alkyd Gloss Lo Voc Black 7930-00-269-1272 Absorbent Material,Oil And Water 8010-00-527-3199 Enamel, Red Gloss 7930-00-282-9699 Detergent,General Purpose 8010-00-582-5382 Enamel, Lacquer, Flat Black 7930-00-282-9700 Detergent,General Purpose 8010-00-584-3150 Enamel Flat White 7930-00-935-3794 Polish,Plastic 8010-00-597-7862 Enamel Alkyd Lo Voc Brown 7930-01-328-5959 Cleaning Compound,Solvent-Detergent 8010-00-598-5460 Enamel Alkyd Lo Voc Brown 7930-01-331-1507 Cleaning Compound,Solvent-Detergent 8010-00-598-5464 Enamel Alkyd Lo Voc Green 7930-01-342-5316 Cleaning Compound,Solvent-Detergent 8010-00-598-5936 Enamel Olive Drab 7930-01-383-7926 Cleaning Compound,Solvent-Detergent 8010-00-616-7503 Lacquer Spray Green 7930-01-393-6664 Defoamer 8010-00-616-9143 Enamel, Black 7930-01-423-1292 Cleaning Compound,Solvent-Detergent 8010-00-616-9181 Primer Coating, Light Gray 8010-00-079-3760 Enamel 8010-00-721-9479 Enamel Spray Orange 8010-00-141-2950 Enamel Yellow 8010-00-721-9743 Enamel Spray Red Gloss 8010-00-160-5787 Thinner,Paint Products 8010-00-721-9744 Enamel, Yellow 8010-00-181-8079 Thinner,Aliphatic Polyurethane Coating 8010-00-846-5117 Enamel, Olive Drab 8010-00-181-8080 Thinner,Paint Products 8010-00-848-9272 Enamel Spray 8010-00-251-6503 Lacquer 8010-00-852-9033 Enamel, Yellow 8010-00-257-5377 Lacquer 8010-00-935-7079 Lacquer Spray Paint 8010-00-286-7758 Enamel Yellow 8010-01-115-7984 Enamel Alkyd Lo Voc Green 8010-00-286-7838 Enamel Interior Semi-Gloss 8010-01-122-1969 Enamel Alkyd, Yellow 8010-00-290-6983 Enamel White 8010-01-331-6108 Enamel Spray 8010-00-290-6984 Enamel Black Spray 8030-00-051-4011 Sealing Compound 8010-00-297-0547 Enamel Black 8030-00-081-2328 Sealing Compound Michael O'Connor Page 98 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX II: NHARNG HAZARDOUS MATERIALS INVENTORY 8030-00-081-2335 Sealing Compound 8040-01-010-8758 Silicone Sealant 8030-00-087-8630 Antiseize Compound 8040-01-126-1422 Adhesive 8030-00-145-0151 Coating Compound,Plastisol 8120-00-268-3360 Cylinder,Compressed 8030-00-148-9833 Sealing Compound 8520-00-228-0598 Soap,Toilet 8030-00-252-3391 Sealing Compound 9150-00-145-0268 Grease,Aircraft 8030-00-275-8111 Sealing Compound 9150-00-181-7724 Grease,Aircraft 8030-00-290-5141 Coating Compound,Bituminous,Solvent 9150-00-190-0918 Grease,Graphite 8030-00-537-7925 Sealing Compound 9150-00-231-6689 Lubricating Oil,General Purpose 8030-00-546-8637 Corrosion Preventive Compound 9150-00-231-9071 Brake Fluid,Automotive 8030-00-656-1426 Sealing Compound 9150-00-234-5197 Lubricating Oil,Exposed Gear 8030-00-664-4944 Preservative Coating,Canvas 9150-00-257-5370 Grease,Graphite 8030-00-764-6658 Antiseize Compound 9150-00-273-2389 Lubricating Oil,General Purpose 8030-00-835-0884 Antiseize Compound 9150-00-458-0075 Lubricating Oil,General Purpose 8030-00-850-7076 Coating Compound 9150-00-657-4959 Hydraulic Fluid, AT 8030-00-926-2135 Filler,Dent,Metal Surface 9150-00-698-2382 Hydraulic Fluid, AT 8030-01-025-1692 Sealing Compound 9150-00-753-4667 Lubricating Oil,Air Compressor 8030-01-054-0740 Sealing Compound 9150-00-823-7860 Lubricating Compound,Dimethylsilicone 8030-01-087-3589 Sealing Compound 9150-00-935-5851 Grease,Aircraft 8030-01-103-2868 Sealing Compound 9150-00-935-9807 Hydraulic Fluid,Petroleum Base 8030-01-155-3238 Sealing Compound 9150-00-935-9809 Hydraulic Fluid,Petroleum Base 8040-00-117-8510 Adhesive 9150-00-944-8953 Grease,Aircraft 8040-00-181-7761 Adhesive 9150-00-999-7548 Lubricant,Interlocking Slide Fastener 8040-00-266-0850 Adhesive 9150-01-007-4384 Grease,Aircraft And Instrument 8040-00-728-3088 Silicone Sealant 9150-01-015-1542 Grease,Molybdenum Disulfide 8040-00-833-9563 Adhesive 9150-01-035-5393 Lubricating Oil,Gear 8040-00-844-9707 Adhesive 9150-01-053-6688 Cleaner,Lubricant And Preservative 8040-00-851-0211 Silicone Sealant 9150-01-054-6453 Cleaner,Lubricant And Preservative 8040-00-938-6860 Rubber Adhesive 9150-01-079-6124 Cleaner,Lubricant And Preservative Michael O'Connor Page 99 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan 9150-01-102-9455 Brake Fluid,Automotive 9150-01-260-2534 Lubricant,Solid Film 9150-01-126-4459 Lubricating Oil 9150-01-310-5762 Oil,Synthetic 9150-01-177-3988 Lubricating Oil,Engine 9150-01-351-9019 Lubricating Oil,Engine 9150-01-178-4725 Lubricating Oil,Engine 9150-01-353-4799 Hydraulic Fluid,Automatic Transmission 9150-01-197-7692 Grease,Automotive And Artillery 9150-01-421-1427 Lubricating Oil,Engine 9150-01-197-7693 Grease,Automotive And Artillery 9150-01-198-3829 Gear Lubricant Additive,Limited Slip Michael O'Connor Page 100 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX II: NHARNG HAZARDOUS MATERIALS INVENTORY APPENDIX III: PERMITS A.) OIL-WATER SEPARATOR PERMITS B.) STORMWATER PERMITS C.) UNDERGROUND STORAGE TANK PERMITS D.) GENERATOR (SICE) PERMITS Michael O'Connor Page 101 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 102 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 103 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 104 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 105 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 106 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 107 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 108 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 109 Shelley Dougherty UNH & NHPPP P2 Internship Program New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 110 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 111 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 112 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 113 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX III: PERMITS Michael O'Connor Page 114 Shelley Dougherty UNH & NHPPP P2 Internship Program APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE Michael O'Connor Page 115 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 116 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE Michael O'Connor Page 117 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Michael O'Connor Page 118 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE A Pollution Prevention Opportunity Assessment (PPOA) can be conducted using a systematic method to identify and prioritize waste streams, examine the processes that generate waste, and discover alternatives to reduce this waste. Any process or activity that generates waste represents an opportunity for improvement. A Pollution Prevention Assessment Team (PPAT) is a useful tool to conduct the PPOA process. During a PPOA, the PPAT, either formally constituted or informally assembled, reviews all the processes and activities at NHARNG and the total waste generated to determine the most feasible alternatives for waste reduction. This appendix explains how to create a PPAT, conduct a PPOA, and select P2 alternatives. Three keys to success of P2 include the following: Commitment of site personnel to P2, Positive change in attitude towards P2, and Creative assessment with common sense application. A.) POLLUTION PREVENTION ASSESSMENT TEAM The PPAT evaluates a facility's waste generation processes or hazardous material use to identify P2 opportunities. The PPAT reviews processes at a NHARNG facility under the leadership of the environmental office. i.) PPAT Responsibilities and Members The PPAT is responsible to: Perform PPOAs, Present PPOA recommendations to the EQCC, Implement P2 alternatives and Best Management Practices (BMPs), and Monitor the performance of P2 projects. Team members have technical and practical knowledge of the process being assessed. The PPAT includes people who work directly with the process or materials of interest, as they are most familiar with the routines and practices and will ultimately carry out any P2 alternatives. In addition to site personnel, the PPAT should also include personnel with a variety of backgrounds. Background differences can offer different viewpoints and approaches to identify and solve the problems that may arise in the PPOA and alternative implementation. Specifically, the PPAT might include the following personnel: Shop-level personnel, Hazardous materials management staff , Michael O'Connor Page 119 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Procurement and supply personnel, Environmental specialists, Logistics personnel, The facility director, Senior management, or Public affairs personnel. B.) CONDUCTING THE PPOA After the PPAT is assembled, the team may begin their assessment. In summary, conducting a PPOA involves the following six steps: 1. Select the process or activity for evaluation, 2. Examine the process or activity, 3. Identify P2 opportunities, 4. Select P2 alternatives, 5. Implement the selected alternatives, and 6. Review and track the P2 projects. These six steps are detailed in the following subsections. During these steps all worksheets and data for future PPOAs or other related assessments are maintained. i.) Selecting a Process or Activity for Evaluation Within the six-step process of conducting a PPOA, selecting a process or activity consists of four steps that are described below: 1. Identify the processes used at the facility, 2. Conduct a baseline survey for the processes or activities, 3. Rank the processes or activities and 4. Select the process or activity for evaluation through a multi-step process 4a. Map the process or activity, 4b. Complete the Materials Balance Analysis, 4c. Identify P2 opportunities and 4d. Analyze with brainstorming and fishbone diagrams. STEP 1 Identify the processes and activities conducted at the facility. Michael O'Connor Page 120 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE The PPAT investigates all the processes at the facility and their respective waste streams, including air emissions and energy consumption. A list of the processes and activities conducted at the facility are presented in Chapter 5 Table 5-1. STEP 2. Conduct a baseline survey for the processes or activities. A baseline survey provides a historical view of the material inputs, outputs, and wastes by reviewing various data such as, but not limited to: Supply or procurement records, Hazardous chemical inventories, Hazardous waste manifests, Solid waste disposal records, Waste accumulation inventory logs, TRI data (if applicable), Air emissions inventories (if applicable), and Spill data. The baseline survey reveals the type and quantity of materials entering and waste exiting the facility. Baseline data help eliminate target specific processes and activities for the PPOA. This baseline survey is general and includes any material inputs of significant quantity coming into the facility that may become waste. Wastes should be categorized according to type (e.g., hazardous, radioactive, or nonregulated) to assist in prioritization, STEP 3. STEP 3. Prioritize the processes and activities. The baseline survey may reveal one or several P2 opportunities, the most obvious being the largest volumes of either material inputs or wastes. Often, the process or activity with the highest cost waste stream and greatest volume is top priority, but other ranking factors including safety hazards and extremely toxic inputs or outputs may take precedence. The following questions are asked to prioritize processes: How complex is the process? What are the current command priorities (antifreeze, used oil, etc.)? Are there any command or technical order requirements and/or constraints? What are the current regulatory priorities or current compliance issues? What about environmental priorities such as the EPA's ODCs or Waste Minimization Priority Chemicals? Are there any health and safety issues associated with this process or waste stream? What about the compatibility and availability of other chemicals and/or processes? Could altering this process affect the mission? Michael O'Connor Page 121 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Based on these questions, each process or activity should be ordered consecutively in a list with the highest priority being placed at the top of the list and the lowest at the bottom. STEP 4. Select the process or activity. To conduct the PPOA, a process or activity is selected for further evaluation. Selection of a process or activity should be based on the answers to the questions in STEP 3. After a list is established with each process or activity ranked according to priority for further PPOA, begin the PPOA with the first, or highest priority activity or process in the list. Examining the chosen process or activity After prioritizing the processes and activities (STEP 3), an additional examination of the chosen process or activity must be completed. Examination consists of the following four actions: 1. Map the process, 2. Complete the Materials Balance Worksheet, 3. Identify P2 opportunities, and 4. Analyze the process or activity through fishbone diagrams and brainstorming. STEP 4a. Map the process or activity. Process mapping examines a system by graphically illustrating its input, process and sub-processes, and output. Input includes materials, manpower, equipment, and other resources. Process represents the work that is accomplished, such as training, painting, or other maintenance activities. Output includes the final product, waste streams, and excessive consumption of resources like energy and water. A Process Flow Diagram will help examine the process or activity that has been chosen for examination. When completing this, the following information will be necessary for the chosen process or activity: Raw materials, Intermediate processes or steps, Order and relationship of steps, and Wastes. As part of the process/activity mapping, it is necessary to review the baseline data or other available data. The data will reveal information relating to materials used and waste generated. Shop personnel should be encouraged to elaborate on any data based on their intimate knowledge of the process. Other helpful data that can aid in mapping a process or activity include the following: Regulations and permits (federal, state, and local), Michael O'Connor Page 122 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE Facility/ shop inventories, Equipment lists, Process descriptions, Raw material/production information, Cost accounting reports, and Organizational charts. STEP 4b. Complete the materials balance analysis. To address the Army Pollution Prevention Program goals, baselines are required for municipal solid wastes, hazardous wastes, EPA Priority Chemicals, VOC air emissions, pesticides/herbicides, EPCRA TRI chemicals, energy, and water. A baseline is the amount of targeted substance purchased or generated for a particular length of time and point in time. Baseline information also includes the name of the substance, its unit cost of purchase and/or disposal, and the generation process. A Materials Balance Analysis provides an accurate baseline. A Materials Balance Analysis accounts for all of a material used in a process or activity. This calculation indicates whether all material used adds up to the amount of material input. The amount of material that is used in the process or activity, material that becomes by-product, and material that accumulates or gets used in the process (such as a solvent bath or a paint booth) is added. This total is compared with the amount of material input as summarized in the formula below: Inputs = Products + By-products + Used Material An example can be found at Unit Training Equipment Site (UTES) #5 of a Materials Balance Analysis. At this UTES, a solvent bath is used to clean oil and grease from parts. The solvent needs to be changed every six months, the start and end date for the Materials Balance Analysis. This oil and grease parts cleaning process uses 5 gallons of solvent in the solvent bath, parts with oil and grease on them, and rags for drying and rubbing difficult areas of the parts. After cleaning parts over a period of time, by-products are produced in the form of dirty rags, solvent lost to the air, and oil and grease in the solvent. All of the inputs of this process should equal the outputs. This Analysis will allow every portion of the materials put into a process or activity to be recognized for P2 opportunities. The objective in a Materials Balance Analysis is for both sides of the equation to be equal. If 10 gallons of material are input, the sum of the by-product, the material in or on the product, and the material accumulated in the unit should equal 10 gallons. Using the Materials Balance Worksheet, which is presented as Figure B-4, may be helpful in completing the Materials Balance Analysis, because it can help quantify material used and waste generated. A Materials Balance Analysis provides the truest form of a baseline, which is useful for processes or activities that use a large volume of materials or when the materials or waste are extremely toxic or hazardous. Establishing an accurate baseline is critical to evaluating a program and meeting program goals. Michael O'Connor Page 123 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan The information needed to establish an accurate baseline using a Materials Balance Analysis is available from many sources (as noted in section 3), but must be collected, correlated, evaluated, and consolidated. To establish an accurate baseline, material balance, materials input, and waste generated must be understood, as defined in the Definitions section (found at the end of this document). After a baseline is established, a review of P2 technologies, methodologies, and regulatory requirements applicable to the designated waste stream is conducted to determine a realistic, achievable level of reduction. The basic steps for determining realistic, achievable reduction of material inputs, after an accurate baseline has been established through a Materials Balance Analysis, are as follows: Define waste streams, Quantify waste streams, Calculate the known generation rate per unit of time (pounds per year), Document the baseline, and Develop initiatives to reduce from baseline quantity. STEP 4c. Identify P2 opportunities. By mapping the processes or activities conducted by the NHARNG, the PPAT will identify any areas that may present one or more P2 opportunities. For example, if the process map shows that a large amount of hazardous waste is being generated during a certain part of a process or activity, this represents an opportunity to reduce or eliminate hazardous waste. Several actions and questions to keep in mind are: Tour the shop area where this process occurs and talk to the people who perform this process to see if they have any P2 ideas. Observe the process or activity carefully, take detailed notes, and ask questions. Are there any inefficiencies? Are there any intermediate steps that could be omitted? STEP 4d. Analyze with brainstorming and fishbone diagrams. Brainstorming and fishbone diagrams are analysis tools that encourage teamwork and discussion. They are useful when examining a process or activity for P2 opportunities. These tools are also helpful when identifying and selecting P2 alternatives later in the PPOA. Brainstorming is a tool to help the PPAT identify many ideas quickly. Some brainstorming suggestions include the following: Stress quantity not quality; ideas can be evaluated for feasibility later, Build on ideas from other team members, Michael O'Connor Page 124 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE Adapt ideas from other contexts, Consider outrageous ideas, and Do not overlook the obvious. Fishbone diagrams help sort and associate interactions in an orderly and easy-to-read form. They provide the following advantages: Allow the team to work together and focus on the facts, Show sources of variation, and Encourage questioning, helping the entire team to better understand the process being assessed. There are several types of fishbone diagrams that can be easily adapted to any situation by changing the major categories. When working with a fishbone diagram, the PPAT should work with one category at a time asking general questions and continually defining and relating the causes to each other. Potential questions include: How much (what percentage) does each cause contribute to the problem? What causes are the most likely source of the problem? Review other data if any verification is necessary. i.) Identify P2 Alternatives After the PPAT has agreed on the drivers at the base of the opportunity, the PPAT members are ready to investigate possible P2 alternatives. Remember to reflect on the following general principles of P2 when conducting PPOAs: Dilution is not the solution to pollution. In the long run, it is always easier to reduce or eliminate waste at the beginning of the process than to treat or clean contaminated material. Mixing waste streams will make treatment more difficult and expensive. Do not switch pollution from one medium to another, such as air pollution to water or vice versa. ii.) Select P2 Alternatives At this point the PPAT has identified potential P2 alternatives for the selected process or activity. Table B-2 includes terms relating to P2 alternatives that may be useful in understanding this discussion. Evaluating, ranking, and selecting P2 alternatives are the next sequential steps for implementing P2 alternatives. These steps are broken down into a stepwise approach as follows: Evaluate P2 alternatives, Rank the P2 alternatives, and Michael O'Connor Page 125 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Select the P2 alternatives. STEP 1. Evaluate P2 alternatives. When evaluating selected P2 alternatives, the following questions should be considered: Effectiveness Will the alternative minimize or eliminate a hazardous material input or output (waste)? Will this alternative comply with current or future regulations? Will this alternative improve employee safety? Will this alternative reduce material input? Will this alternative reduce hazardous attributes? Feasibility Will management and employees support the selected alternative? Are there any well-documented cases of this alternative being successful at other facilities? Is this alternative compatible with other chemicals and/or processes? Are vendors already available if purchases are necessary? Is the risk of media (air, water, and land) transfer low? Are there any additional storage or material handling requirements? Are there any new or additional training requirements? Would any secondary waste streams require additional processes not now available? Cost What are the potential cost savings, both direct and indirect? (Direct: raw materials, waste disposal, utilities, labor. Indirect: avoided liability, improved compliance, improved worker safety, and improved community relations) Is there funding available (internal or external)? What is the payback potential? (Three years is generally a good payback period.) Are there possible environmental or safety liabilities? STEP 2. Rank the P2 alternatives. The PPAT eliminates the impractical alternatives and focuses on the feasible ones by thoroughly discussing and ranking the options using the Rank Order Matrix presented as Table B-3. The Rank Order Matrix is used as described in the steps below: 1. For each criteria that affects whether an option will be successful, a subjective numerical value from 0 to 6 is assigned (with 0 meaning the option will be least likely to succeed). 2. For each P2 alternative, criteria values are added. Michael O'Connor Page 126 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE 3. Rank the alternatives to help determine which program to choose. (The lower the sum, the less likely the option will succeed without conflict). Ranking scores are used to compare all opportunity assessments or to order specific opportunity assessments within functional areas. Ranking is also used to prioritize projects for funding. STEP 3. Select P2 alternatives. After ranking the alternatives, the PPAT will decide which alternative or alternatives to implement based on the PPOA. A.) IMPLEMENTING THE SELECTED P2 ALTERNATIVES Many alternatives require funding, approval, and/or training. These factors need to be considered to implement an identified P2 alternative and are broken into the following two steps: STEP 1. Obtain funding and approval. Many processes are subject to Lubrication Orders, Technical Manuals, or MIL SPECS. The point of contact at the state environmental office should be notified if not already aware of the proposed changes. Therefore, P2 alternatives may need to be approved before they can be implemented. Alternatives that need expensive equipment may require funding from internal or external sources. A comprehensive package must be submitted for the selected alternative. Facts about the selected alternative, the PPOA process of the alternative, and payback information must all be included in the funding request proposal. STEP 2. Implement the P2 alternative. Necessary additional training - Incorporate pollution prevention into routine shop training and provide periodic updates and refreshers. Document this training, including what was taught and who attended. Employee support - Employees must be included in the implementation process. Announce changes to standard operating procedures and encourage review and feedback from personnel. Be realistic in terms of tasks to be performed and the amount of time allotted for each task. Demonstrate clear expectations. Post any P2 literature, including the P2 Policy included in this P2 plan. Remember to promote pollution prevention and any awards associated with P2. A.) POSSIBLE BARRIERS PROHIBITING IMPLEMENTATION Barriers keep the identified and proposed P2 alternative from being implemented. Identifying barriers is integral to developing a strategy to overcome them. Barriers can be overcome by utilizing several methods, but most barriers can be alleviated through proper planning during the PPOA process. Institutional (mission priorities, MILSPECS), financial, technical, and regulatory barriers may be confined to one of these categories or may encompass several at once. Procedures to reduce barrier intrusion are presented in the following paragraphs. Michael O'Connor Page 127 UNH & NHPPP P2 Internship Program Shelley Dougherty New Hampshire Army National Guard Pollution Prevention Plan Institutional barriers may develop if there is no awareness of the need for P2. Institutional barriers can be overcome by raising the awareness of the troops, civilian employees, contractors, and tenant organizations. Methods to accomplish this may include the following: Installation Commander’s P2 directives, P2 news stories in the post newspaper, Outreach bulletins from environmental groups, Clear definition of communication channels between groups, and/or P2 training. Barriers can develop from lack of funding if the case is not presented well to the EQCC. Financial barriers can be overcome by demonstrating that a P2 alternative will result in a cost savings. Tools that may help overcome funding barriers include the following: Select P2 opportunities and alternatives with the greatest potential value, Use well defined economic analysis. DOD has guidelines on economic analysis in DOD Initiative 70413, “Economic Analysis and Program Evaluation for Resource Management,” and Investigate alternative funding sources, e.g., the Installation Commander may have discretionary funds, recycling returns, and Operation and Maintenance funds. Barriers from a technical standpoint can develop if expertise on the activity or process is not applied in the PPOA. Technical barriers can be overcome by attempting the following: Include the installation’s best technical expertise, which are the personnel performing the process or activity selected, during assessment, evaluation, planning, and implementation of P2 opportunities and assessments. Include other available expertise such as engineers, logistics personnel, and maintenance personnel. Consult with outside organizations such as the Command, other Commands, and/or the Corps of Engineers. Regulatory barriers can be overcome through a unique approach. Typical environmental regulations emphasize control, treatment, and end-of-pipe treatments. It may be difficult to break the thinking of doing only what is necessary to come into regulatory compliance. Try to be proactive and take a multimedia approach to eliminate the problem before it is regulated. Determine the regulatory effects on all media when implementing a P2 alternative. Michael O'Connor Page 128 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE MATERIALS BALANCE WORKSHEET (FIGURE B-4) Date: Process: Name of Evaluator(s): Facility/Building: Shop: Process Inputs (Description of Raw Materials) Quantity Process Outputs (Description of Wastes) Waste Air Emission Waste Water Hazardous Waste NonHaz Waste Other Quantity NOTE: Input of materials and output of products, by-products, and waste must equal each other. Michael O'Connor Page 129 UNH & NHPPP P2 Internship Program Shelley Dougherty Michael O'Connor Page 130 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE TABLE B-1: P2 EXAMPLES Term Example Pollution Prevention Opportunity A chlorinated solvent is used in a parts washer. This use represents a PPO, a chance to prevent a hazardous material from becoming a waste. Pollution Prevention Alternatives Replace the chlorinated solvent with a non-chlorinated solvent. Replace the solvent-based parts washer with a hot water aqueous parts washer Best Management Practice Keep the parts washer cover closed when not in use so that less solvent will evaporate. This BMP decreases air emissions and reduces the need to add more solvent. TABLE B-2: TERMS RELATING TO P2 ALTERNATIVES Term Definition Practices & Procedures Include BMPs and procedures such as personnel training, material handling and inventory practices, material loss prevention, and cost accounting. Material Substitution Changes to the input material that reduces or eliminates a hazardous material and ultimately reduces waste. New Process and/or Activity Change in a process or activity that reduces or eliminates waste. Waste Segregation/Hazard Reduction Separating waste streams to prevent a nonhazardous waste from being designated and handled as a hazardous waste. This can include neutralization, toxicity reduction, or volume reduction. Michael O'Connor Page 131 UNH & NHPPP P2 Internship Program Shelley Dougherty TABLE B-3: RANK MATRIX ORDER Rank Description Cost/Investment Payback in Years 5-6 Limited or no cost - current program will cover cost 3-4 Program must be funded by external resources (cost does not exceed $100,000) 1-2 Program must be funded by unidentified external resources (cost could exceed $100,000) 0 No Army funding category exists (cost could exceed $250,000) Ease of Implementation 5-6 Technology for program is fully developed and in place, or technology program requires no new equipment 3-4 Technology readily available 1-2 Technology in developmental stage, can be acquired within 3 years 0 Technology is yet unproven; not likely to be proven within 5 years Mission Impact 5-6 Positive impact on cost, time, and labor 3-4 Some positive impact but no discernible cost savings 1-2 No recognizable impact within 5 years 0 Clearly negative impact on cost, time, and labor Environmental Compliance (e g Regulations, Laws, Agreements; permit Requirements) 5-6 Program initiative complies with agreements and existing federal, state, and local laws 3-4 Some conflict may exist due to definition or scope of program 1-2 Conflict exists or program presupposes emerging federal, state, or local laws 0 There is a conflict with existing and/or emerging laws or statutes Environmental Benefits 5-6 Benefits will be shown in many areas 3-4 Some benefits may result 1-2 Program implementation has no effect on the environment 0 There may be negative effects on the environment Michael O'Connor Page 132 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE B.) DEFINITIONS Note: The following definitions are generalized and are typical of terms that appear in various ARNG documents. Alternative: Any action that may be taken in response to an opportunity; the solution to a problem. May involve a significant change in a process or the purchase of an expensive piece of equipment. Appliance: Any device that contains and uses a Class I or Class II substance as a refrigerant and that is used for household or commercial purposes, including any air conditioner, refrigerator, chiller, or freezer. Best Management Practice (BMP): A solution that is easily integrated into a daily routine. Cartridge Filter: A discrete filter unit containing both filter paper and activated carbon that traps and removes contaminants from petroleum solvent, together with the piping and ductwork used in installing this device. Characteristic Waste: The characteristics of ignitability, corrosivity, reactivity, and toxicity that identify hazardous waste. Chemical Warfare Agent: A substance that because of its chemical properties is used in military operations to kill, seriously injure, or incapacitate humans or animals or deny use of indigenous resources. Container: Any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Designated Facility: A hazardous waste treatment storage, or disposal facility (TSDF) that is identified on a manifest as the destination of a hazardous waste shipment. The facility must have an appropriate permit and interim status or be regulated under specific recycling requirements. Nonattainment Area: Any area designated as being out of compliance with the National Ambient Air Quality Standard (NAAQS) for ozone pursuant to rulemaking under section 107(d)(4)(A)(ii) of the Clean Air Act (CAA). Disposal: The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or onto any land or water so that such solid waste or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters, including groundwaters. EPA Hazardous Waste Number: The number assigned by EPA to each hazardous waste listed in 40 CFR 261, Subpart D, and to each characteristic identified in 40 Code of Federal Regulations 261, Subpart C. Facility: All contiguous land and structures, other appurtenances, and improvements to the land, used for treating, storing, or disposing of hazardous waste. A facility may consist of several Michael O'Connor Page 133 UNH & NHPPP P2 Internship Program Shelley Dougherty treatment, storage, or disposal operational units (i.e., one or more landfills, surface impoundments, or combination of them). Federally Enforceable: All limitations and conditions enforceable by the Administration, including those requirements developed pursuant to 40 CFR, requirements within any applicable state implementation plan, and any permit requirements established pursuant to 40 CFR. Generator: Any person or group whose act or process produces hazardous waste identified or listed in 40 CFR 261, or whose act first causes a hazardous waste to become subject to regulations. Good Management Practice (GMP): A practice that, although not mandated by law, is encouraged to promote safe operating procedures. Hazardous Waste: A solid waste, not specifically excluded from the restrictions of Federal Regulation (42 USC 6901), that meets the criteria listed in 40 CFR 261 or is specifically named as a hazardous waste in federal regulations. Household Waste: Includes material discarded by single and multiple residential dwellings, hotels, motels, and other similar permanent or temporary housing. Incinerator: Any furnace used to burn solid waste for the purpose of reducing the volume of the waste by removing combustible matter. Infectious Waste: Equipment, instruments, utensils, and fomites of a disposable nature from the rooms of patients who are suspected to have, or have been diagnosed as having, a communicable disease and who must, therefore, be isolated as required by public health agencies. 1. Laboratory waste such as pathological specimens and disposable fomites (any substance that may harbor or transmit pathological organism). 2. Surgical operating room pathological specimens and disposable fomites and similar disposable materials from outpatient areas and emergency rooms. Landfill: A disposal facility, or a part of a facility, in which waste is placed in or on land and that is not a land treatment facility, a surface impoundment, an underground injection well, a salt bed formation, an underground mine, or a cave. Hazardous Waste Management: The systematic control of the collection, source separation, storage, transportation, processing, treatment, recovery, and disposal of hazardous waste. Material Balance: The basic concept of a material balance is that input materials (e.g., hazardous materials, ODSs, water, energy, labor, etc.) entering the installation or process must leave it as a service, product, or by-product (e.g., hazardous or solid waste, air emissions, waste water discharges, or energy loss). In its simplest form the material balance is presented by the mass conservation principal: mass in = mass out + mass accumulated. Consequently, a material balance can aid in establishing a baseline. Michael O'Connor Page 134 UNH & NHPPP P2 Internship Program Shelley Dougherty APPENDIX IV: POLLUTION PREVENTION OPPORTUNITY ASSESSMENT GUIDE Material Inputs: Materials enter the installation from various sources. The majority of materials come into the YOUR STATE’S GUARD NAME through the USP&FO. Other sources include local purchase, Medical Logistics, Blanket Purchase Agreements, contracting, Non-Appropriated Fund activities, Defense Logistics Agency, General Services Administration, construction subcontractors, and purchases in local commercial establishments. Both ordering information and issue data are necessary to provide information on which types and quantities of materials are in use for baseline formulations. Material-tracking System: Each generator developing an in-house system to ensure that all hazardous materials and wastes are controlled from purchase to release or disposal in order to reduce loss and spillage. Medical Waste: When defined as applicable to municipal waste combustors, any solid waste generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in production or testing of biological agents. Medical waste does not include hazardous waste identified under RCRA-C or any household waste as defined in RCRA, subpart C. Off-specification Used Oil: Used oil burned for energy recovery and any fuel produced from used oil that exceeds the following allowable limits: Arsenic 5 ppm max. Cadmium 2 ppm max. Chromium 10 ppm max. Lead 100 ppm max. Flash Point 100F min. Total halogens 4,000 ppm max. Opportunity: Chance for progress or improvement. Particulate Emissions: Any airborne, finely divided solid or liquid material, except uncombined water, emitted to the ambient air. Pollution Prevention (P2): Source reduction and other practices that reduce or eliminate the creation of pollutants through increased efficiency in the use of raw materials, energy, water, or other resources, or protection of natural resources by conservation. Recycling, energy, treatment, and disposal are not included in the definition of pollution prevention. However, some practices commonly described as “in-process recycling” may qualify as pollution prevention. Examples might include solvent recycling, metal recovery from a spent plating bath, and recovery of VOCs. Qualifying Recycling Program: Organized operations that require concerted efforts to (a) divert or recover scrap or waste from waste streams and; (b) identify, segregate, and maintain the integrity of the recyclable materials to maintain or enhance the marketability of the material. Michael O'Connor Page 135 UNH & NHPPP P2 Internship Program Shelley Dougherty location amount size (cy) pick-ups/month cy/month lbs/year* cost/pick-up cost/year OMS #3 1 2 1 2 624 $232.68 $2,792.16 OMS #4 1 8 4 32 9,984 $37.50 $1,950.00 SMR, Building M 1 8 8 64 or19,968 $25.50 (such $2,652.00 Recyclable Material: Material that normally has been would be discarded as scraps and SMR, Building C 1 8 4 32 9,984 $25.50 $1,326.00 waste) and material that may be reused after undergoing some type of physical or chemical SMR, Building H 1 8materials may include 4 32 9,984 that $25.50 $1,326.00 processing. Recyclable discarded materials have undergone SMR, Building L 1 or mutilation 6 4 24 being7,488 $1,118.00 demilitarization at an installation before transferred$21.50 to the property disposal SMR, Building K for sale.1 Recyclable 6 materials do not 4 include24(1) precious-metal-bearing 7,488 $21.50 scrap $1,118.00 office and ; (2) those items for their original purpose without any special processing, SMR, Building A that may1be used again 6 4 24 or functions 7,488 $21.50 $1,118.00 vehicle or machine2parts, bottles scrap glass), electrical $708.00 components, and NHNG-TS such as used vehicles, 1 2 4 (not1,248 $29.50 of 4unused oil or solvent. NHNG-TS unopened containers 1 2 8 2,496 $59.50 $1,428.00 NHNG-TS 2 6 2 24 7,488 $89.50 $2,148.00 Recycling: The are transformed into new$17,684.16 or usable products. TOTAL: 12 process 64by which recovered 39 materials 270 84,240** Resource Recovery Facility: Any physical plant that processes residential, commercial, or institutional sold waste biologically, chemically, or physically and recovers useful products (such as shredded fuel, combustible oil or gas, steam, metal, or glass) for resale or reuse. Sludge: Any solid, semisolid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply treatment plant, or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant. Source Reduction: Any practice that reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or emitted to the environment (including fugitive emissions) before recycling, treatment, or disposal. The term includes equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution or raw materials, and improvements in housekeeping, maintenance, training, and inventory control. Source Separation: The setting aside of recyclable materials at their points of generation by the generator. Treatment: Any method, technique, or process (including neutralization) designed to change the physical, chemical, or biological character or composition of any hazardous waste. Used Oil: Any oil that has been refined from crude oil, or any synthetic oil that has been used and, as a result of such, is contaminated by physical or chemical impurities. Volatile Organic Compound (VOC): Any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides, carbonates, and ammonium carbonate, that participates in atmospheric photochemical reactions. Waste: Anything useless, unwanted, or hazardous, e.g., a by-product from a process, input inefficiencies (materials or energy), time inefficiencies (unnecessary steps), or process inefficiencies. Michael O'Connor Page 136 UNH & NHPPP P2 Internship Program Shelley Dougherty
