Project Title: New Hampshire Army National Guard Pollution Prevention Plan Intern: Michael O’Connor (603) 295-8744 Facility: New Hampshire Army National Guard Environmental Office 57 Regional Drive Concord, NH 03301 Contact: Eileen Chabot (603) 225-1211 UNH & NHPPP P2 Internship – NH Army National Guard Table of Contents Executive Summary ........................................................................................................................ 4 CHAPTER 1 Introduction and Background ............................................................................. 5 1.1 Scope of P2 Plan ............................................................................................................. 5 1.2 Current Initiatives ........................................................................................................... 5 1.2.1 Aerosol Cans ........................................................................................................... 5 1.2.2 Aqueous Parts Washers........................................................................................... 5 1.2.3 Oil Filters ................................................................................................................ 5 1.2.4 Oil-Water Separators .............................................................................................. 5 1.2.5 Secondary Containment Areas ................................................................................ 6 1.2.6 Used Oil Burner ...................................................................................................... 6 1.2.7 Scrap Metal ............................................................................................................. 6 1.2.8 Tires ........................................................................................................................ 6 1.2.9 Used Antifreeze ...................................................................................................... 6 1.2.10 Used Shop Rags ...................................................................................................... 6 1.2.11 Lead Acid Batteries................................................................................................. 7 CHAPTER 2 Goals and Objectives .......................................................................................... 9 CHAPTER 3 Approach/Methodology .................................................................................... 11 3.1 Pollution Prevention Plan ............................................................................................. 12 3.2 Recycling Programs ...................................................................................................... 12 3.2.1 Antifreeze Recycling ............................................................................................ 12 3.2.2 Paper Recycling .................................................................................................... 13 3.3 Product Replacement Opportunities ............................................................................. 14 3.4 Presentations ................................................................................................................. 14 CHAPTER 4 Chemical Usage and Equipment Requirements ................................................ 15 CHAPTER 5 Wastes Generated.............................................................................................. 16 5.1 Air Emissions ................................................................................................................ 16 5.2 Regulated Waste ........................................................................................................... 18 5.3 Non-Regulated Waste ................................................................................................... 20 5.3.1 Baseline ................................................................................................................. 20 5.3.2 Recycled Waste Streams ....................................................................................... 21 5.3.3 Non-Recycled Waste Streams............................................................................... 22 5.4 Energy Recovery Streams ............................................................................................. 22 CHAPTER 6 Project Results .................................................................................................. 23 6.1 Pollution Prevention Plan ............................................................................................. 23 6.2 Antifreeze Recycling Program ...................................................................................... 23 6.2.1 Current Method ..................................................................................................... 23 6.2.2 On-Site Recycling ................................................................................................. 24 6.2.3 Off-Site Recycling ................................................................................................ 27 6.2.4 Summary ............................................................................................................... 30 6.3 Paper Recycling Program ............................................................................................. 32 CHAPTER 7 Recommendations for Future Efforts................................................................ 34 APPENDIX A References ..................................................................................................... 35 Page 2 2/6/2016 APPENDIX B Selected Pictures ........................................................................................... 38 (i) Army Aviation Support Facility (AASF) ..................................................................... 38 (ii) Combined Support Maintenance Shop (CSMS) and CSMS Annex ............................. 38 (iii) Littleton Organizational Maintenance Shop (OMS) #2 ................................................ 38 (iv) Somersworth Organizational Maintenance Shop (OMS) #3 ........................................ 38 (v) Manchester Organizational Maintenance Shop (OMS) #4 ........................................... 38 (vi) Hillsboro Organizational Maintenance Shop (OMS) #5 .............................................. 38 (vii) New Hampshire National Guard Training Site (NHNGTS) ......................................... 38 APPENDIX C NHARNG Hazardous Materials Inventory................................................... 39 APPENDIX D Paper Recycling Awareness Poster ............................................................... 41 APPENDIX E Site Visit Checklist ....................................................................................... 43 APPENDIX F Antifreeze Recycling Presentation Handout ..................................................... 44 List of Acronyms AASF Army Aviation Support Facility IRN Institution Recycling Network ALR Advance Liquid Recycling, Inc. NEES New England Environmental Service AOAP Army Oil Analysis Program NGB National Guard Bureau ARNE Antifreeze Recycling of New England NHDES New Hampshire Department of Environmental Service Combined Support Maintenance Shop NHNGTS New Hampshire National Guard Training Site NSN National Stock Number OA Opportunity Assessment OMS Organizational Maintenance Shop P2 Pollution Prevention SMR State Military Reservation CSMS DOD Department of Defense DRMO Defense Reutilization and Marketing Office DRMS Defense Reutilization and Marketing Service EO Executive Order EPA Environmental Protection Agency TRI Toxic Release Inventory EMS Environmental Management System USP&FO United States Property & Fiscal Office International Merchant Purchase Authorization Card VOC Volatile Organic Compound IMPAC Page 3 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard Executive Summary The goal of this internship was to create a new Pollution Prevention (P2) Plan for the New Hampshire Army National Guard (NHARNG). This plan was based upon the existing “Guidance for Developing Army Pollution Prevention Plans” (June 2001) document provided by the facility P2 Manager. In July, an updated template was released, and portions of that document were also incorporated into the P2 Plan. The plan consists of 14 Chapters, each relating to an aspect of P2. Examples of these chapters are Hazardous/Universal Waste, Water and Wastewater, Solid Waste, and Air Emissions. Site visits were performed at several NHARNG facilities around the state. Included were all Organizational Maintenance Shops (OMSs), as well as many facilities on the State Military Reservation (SMR), including the Combined Support Maintenance Shop (CSMS) the CSMS Annex (Concord’s OMS), the Army Aviation Support Facility (AASF), the New Hampshire National Guard Training Site (NHNGTS), and the US Property and Fiscal Office (USP&FO) Warehouse. In addition to the P2 Plan, antifreeze and paper recycling programs were researched. An antifreeze recycling presentation including cost-benefit analyses outlining the differences between the use of the Defense Reutilization and Marketing Service (DRMS), on-site, and offsite recycling programs was given during the course of this internship. A paper recycling presentation was prepared to be used in an educational campaign to aid in the initiation of a new paper recycling program. Page 4 2/6/2016 CHAPTER 1 Introduction and Background The New Hampshire Army National Guard is currently updating their Pollution Prevention Plan. The last P2 Plan was completed in 1996 and nearly every goal set forth has been achieved. The plan developed this summer identifies potential initiatives for the NHARNG. The NHARNG has many initiatives currently in place to help reduce pollution. Many of these initiatives were taken as a direct result of goals outlined in the previous P2 Plan. Table 1-1 summarizes the NHARNG’s current initiatives as well as projected future initiatives. 1.1 Scope of P2 Plan The P2 Plan is written for all NHARNG facilities and operations. Only federally funded facilities were visited, and the goals developed for each apply also to the state funded activities and facilities. 1.2 Current Initiatives This following sections detail the Current Initiatives being taken by the NHARNG to help reduce pollution. 1.2.1 Aerosol Cans Aerosol cans, items that would otherwise 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. 1.2.2 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 solventbased cleaners, reducing air emissions from VOCs and increasing worker safety. 1.2.3 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. 1.2.4 Oil-Water Separators All facilities are equipped with an oil-water separator designed to clean oils out of the water before discharge, preventing contamination of the discharge area environment. Page 5 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 1.2.5 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 the installation’s contained wastewater system. 1.2.6 Used Oil Burner One used oil burner was purchased by the NHARNG and was installed in the Manchester OMS. During the cold-weather months, it is used to provide heat, reducing the need to buy as much heating oil. Oil is tested and currently, only on-specification oil is burned. 1.2.7 Scrap Metal An estimated 30,000lbs of scrap metal is generated annually by NHARNG and transported to the USP&FO Warehouse to be recycled. Currently NHARNG is receiving money for the scrap metal that is recycled. All money that is acquired through the recycling program is added to a fund site dedicated to the health and welfare of the troops as well as pollution prevention equipment. 1.2.8 Tires Approximately 47,600 lbs 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. 1.2.9 Used Antifreeze According to waste manifests, approximately 1,919 lbs of used antifreeze are generated and recycled through DRMO per year. Please refer to the Hazardous and Universal Waste chapter of the P2 Plan for additional information regarding antifreeze and alternative recycling opportunities. 1.2.10 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. Page 6 2/6/2016 1.2.11 Lead Acid Batteries Spent lead-acid batteries are recycled through a one for one exchange program with Exide. Specific information regarding the quantity of batteries exchanged with Exide is not available. (Summary of P2 Initiatives on next page) Page 7 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard Figure 1-1: NHARNG P2 Initiatives Project Name Targeted Pollution Source Implementation Status and Date Aerosol Can Crushing Hazardous Waste Fully Implemented Aqueous Parts Washing Hazardous Waste Implementation Date Funding Source P2 Plan Section EPR 6.6.2 Fully Implemented 1995 6.6.3 Air Emissions Oil Filter Draining/Crushing 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 Fully Implemented 1994 7.4.2 Alltex Shop Rags Laundering Service Hazardous Waste Solid Waste Scrap metal Recycling 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 Requires Further Investigation 2004 7.5.2 Rechargeable Batteries Solid Waste Requires Further Investigation 2004 7.5.3 Tires Solid Waste Fully Implemented Page 8 2/6/2016 CHAPTER 2 Goals and Objectives The goal for this internship was to develop a detailed and thorough Pollution Prevention Plan for the New Hampshire Army National Guard. A secondary goal was to research some of the major initiatives developed in the Plan to determine the feasibility of each. The main two initiatives were antifreeze and paper recycling. An additional secondary goal was to gain experience working in both office and field settings. The following table outlines the initiatives relating to each area of Pollution Prevention considered in the P2 Plan. The source of each goal is noted, and many come from Presidential Executive Orders. A summary of these Executive Orders can be found in Chapter 2 of the P2 Plan. (Continued on next) Page 9 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard Media Hazardous Waste Solid Waste Goal Source of Goal Baseline Year Target Year 50% Reduction DOD Measure of Merit 1992 1999 DOD Measure of Merit 2003 2005 NHARNG Air Emissions Inventory 2002 2005 Diversion of 40% of waste stream to recycle Air Emissions 10% Reduction Water Use Continuous annual reduction Wastewater 2003 Not Yet Developed --- --- --- TRI Releases 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 Generation Vehicle Fuel Energy Affirmative Procurement Page 10 2/6/2016 CHAPTER 3 Approach/Methodology The approach to this internship was a three part process consisting of site visits, analysis of results, and follow-up contact with facility personnel. This was the method used to develop P2 initiatives not already defined by the NHARNG. Due to the funding source of this project, only federally funded facilities were visited. The initiatives developed in the P2 Plan, however, can be extended through the NHARNG to include all facilities. The facilities visited include: Littleton OMS #2 Somersworth OMS #3 Manchester OMS #4 Hillsboro OMS #5 CSMS and Annex AASF USP&FO Warehouse NH National Guard Training Site The mission of the shops is to support the units they service. Their main function in this endeavor is to perform vehicle maintenance. The training site functions as a school for the soldiers with both classroom and hands-on training. A form was developed for site visits and was utilized on many occasions. Facility personnel were consulted in each case to answer questions regarding the frequency and procedure for many of the processes. After the initial site visit, results were analyzed to determine any possible pollution prevention initiatives. Finally, in some cases, facility personnel were contacted additional times to gather more information or for clarification. The Environmental Office staff was extremely helpful during the course of this internship. The following table details the site visits conducted: Page 11 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 3.1 Facility Date/Time of Site Visit Point of Contact Manchester OMS #4 Tuesday June 10, 8:30am CW2 Michael Tkacz State Maintenance Shop Thursday June 12, 8:30am Mr. Joe Sampson USP&FO Warehouse Monday June 16, 9:00am 1SG Kevin Reynolds Littleton OMS #2 Wednesday June 18, 10:00am SSG Randy Dockham AASF Thursday June 19, 8:30am SGT Roger Prive Hillsboro OMS #5 Friday June 20, 9:00am SFC Dennis MacKenzie CSMS and CSMS Annex (OMS #1) Tuesday June 24, 8:30am CW4 Tom LaPierre NHNGTS Wednesday June 25, 9:00am CW2 George Spaulding Somersworth OMS #3 Monday June 30, 8:30am MSG Mike Dignard Pollution Prevention Plan The Pollution Prevention Plan was developed by researching the facilities owned and operated by the NHARNG. This consisted of site visits to federally funded facilities and of interviews with facility personnel. Data collected from each facility was analyzed and incorporated into the final P2 Plan. The P2 Plan was co-written by Shelley Dougherty and me over the course of this internship. Existing NHARNG plans were utilized in some cases for specific areas of the P2 Plan. For example, the Air Emissions Inventory was utilized in the Air Emissions Chapter of the P2 Plan. The plan was composed by chapter, each of which was a separate document. These separate documents were then inserted into a master document and merged to create a working copy of the P2 Plan. It was then refined multiple times through proofreading and review. 3.2 Recycling Programs 3.2.1 Antifreeze Recycling BASELINE DEVELOPMENT Currently, the NHARNG recycles antifreeze through the DRMO. This is an inefficient ad costly method of dealing with spent antifreeze. Based on numbers from recent years, the NHARNG generates approximately ten 55 gallon drums of spent antifreeze per year. The purchase of new Page 12 2/6/2016 antifreeze through the military system combined with the cost of recycling makes this method wasteful. The alternative methods of antifreeze recycling that were researched include both onsite and off-site possibilities. ON-SITE OPPORTUNITIES On-site research involved contact with both the manufacturer of the antifreeze recycling machine owned by the NHARNG and with the soldier who most frequently operated the machine in the past. OFF-SITE OPPORTUNITIES Off-site research included a meeting with a representative of Advanced Liquid Recycling, Inc. as well as research into the end destination and recycling methods employed by the recycler. Compliance with all environmental regulations was also researched. One company that was initially researched and dismissed due to payment method difficulties was included in the search toward the end of this internship. Antifreeze Recycling of New England, which is a transporter for New England Environmental Services worked with the purchasing and contracting officer and resolved this difficulty. They were also included in the research. 3.2.2 Paper Recycling The first step in researching the paper recycling issue was to determine the baseline quantity generated. This was done through analyzing a representative quantity of trash in order to generate an estimate. Through this and an interview with the Recycling Coordinator, a reasonable estimate for paper waste was determined. THE INSTITUTION RECYCLING NETWORK “The Institution Recycling Network offers membership to institutions including colleges and universities, hospitals, nursing homes, private schools, and others.” The Institution functions as a broker for the individual members, arranging for the transportation and recycle of materials. The size of the organization allows members access to better prices in recycling markets, generating revenue in some cases. An annual membership fee of $750.00 is charged. A meeting with an IRN representative and tour of the State Military Reservation was arranged and carried out. Based on estimates of waste paper generation and the tour, the IRN representative informed us that it would probably not be cost effective for the NHARNG to join the IRN and suggested working directly with their local recycler as a more cost effective method. THE TOBEY SCHOOL/REVAMP, INC. The Tobey School and Revamp, Inc. work together to provide transportation and recycling of many different grades of paper. The option of paper recycling was offered to the NHARNG as a free resource. All material costs (such as bins or totes) and transportation costs would be assumed by Revamp, Inc. This is a beneficial relationship that had participation difficulties in the past that could easily be resolved. It remains the NHARNG’s most feasible option. Page 13 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 3.3 Product Replacement Opportunities Replacement opportunities exist for many of the products that the NHARNG utilizes. In some cases, the product targeted for replacement contaminates used oil or antifreeze drained from the vehicle, thereby causing an increase in hazardous waste generation. The goal of an Authorized Use List is to determine which products contaminate the waste fluids and target that product for replacement with a more environmentally friendly product. This pollution prevention opportunity employs the concept of source reduction to reduce hazardous waste generation, at the same time, resulting in a cost savings for the NHARNG. An Authorized Use List would contain a list of products approved by the Environmental Office for use in maintenance operations. In order to purchase an off-list item, a request would be made, and the Environmental Office would review the possible impacts of using that product. 3.4 Presentations Presentations were developed and given for both the antifreeze and paper recycling programs. Power Point slideshows were used to create clear and concise cost-benefit analyses for each program. Appropriate personnel were invited to attend, including OMS Staff, some SMR staff, and Environmental Office Staff. Additionally, a final presentation was given for all Environmental Office Staff to help summarize the results of the internship and the recommendations developed for future P2 efforts. This was very well received and generated insightful and helpful feedback. Page 14 2/6/2016 CHAPTER 4 Chemical Usage and Equipment Requirements The NHARNG uses a variety of chemicals in their regular maintenance of vehicles and aircraft. Some of these chemicals are necessary while others are optional. Technical Manuals (TMs) are the guidebooks or instructions that mechanics or maintenance personnel use for particular processes. If a chemical is specified in a TM, that chemical must be kept on hand and used in that process. This is controlled on a national level and cannot change until an updated TM replaces the current one. The NHARNG does not use any pure concentrated chemicals. All chemicals used are a component of a particular product, or are diluted. For example, antifreeze (ethylene glycol) is used in nearly all vehicles, but is present in a diluted form. A hazardous materials inventory has been compiled for the NHARNG, and can be found as Appendix II in the P2 Plan (see Appendix A of this document for more information). The NHARNG’s equipment requirements are also quite rigid. Facilities and/or units must have certain equipment to function or be prepared. Specific tactical vehicles are required and they must be driven on a certain schedule to ensure that they are properly maintained and ready if called to action. Please see Appendix C for the NHARNG Hazardous Materials Inventory. Page 15 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard Wastes Generated CHAPTER 5 The NHARNG generates both regulated and non-regulated wastes. These wastes are dealt with through recycling and disposal programs. The Defense Reutilization and Marketing Office (DRMO) handle the recycling and disposal for many of the NHARNG’s waste streams. The main categories of waste generated by the NHARNG are regulated (hazardous), non-regulated (non-hazardous), and universal waste. Additionally, some waste streams are diverted to energy recovery, and are not counted in any of the above categories. 5.1 Air Emissions Air Emissions data was gathered mainly from the Air Emissions Inventory developed for the NHARNG by AMEC in 2002. The following chart shows potential emissions, which are considerably higher than actual emissions. The most important piece of information gathered from this chart was the realization that paints and solvents account for the major portion of VOC 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 The sources of these emissions and specific values are characterized separately in the table below: Page 16 2/6/2016 Manchester and Concord Emission Source SOx NOx CO PM VOC's HAP's TOTALS: Distillate Oil Boilers 1.590 0.880 0.220 0.150 0.014 0.003 2.857 Waste Oil Boiler 0.030 0.010 0.001 0.040 0.001 0.001 0.083 Natural Gas Boilers/Heaters 0.001 0.150 0.110 0.011 0.008 0.003 0.283 Vehicle Exhaust 0.000 0.030 0.040 0.001 0.005 0.000 0.076 Stationary Internal Combustion Engines0.190 0.820 0.134 0.044 0.075 0.001 1.263 Paints and Solvents 0.000 0.000 0.000 0.000 1.610 0.462 2.072 Welding Operations 0.000 0.000 0.000 0.004 0.000 0.000 0.004 Tank and Fueling Emissions 0.000 0.000 0.000 0.000 0.030 0.006 0.036 Cold Cleaners 0.000 0.000 0.000 0.000 0.000 0.000 0.000 TOTALS: 1.811 1.890 0.505 0.251 1.743 0.475 6.675 DISTILLATE OIL BURNERS There are two dual-fired boilers, both of which burn either No. 2 (distillate) fuel oil or natural gas located in the armory at the Manchester facility. There are four dual-fired boilers and two oil-fired boilers on the SMR. 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. WASTE 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 OMSs throughout the state. NATURAL GAS BOILERS/HEATERS There is a natural gas-fired hot water heater located in the Manchester armory. There are two natural gas-fired boilers, eleven natural gas heaters, and four natural gas hot water heaters on the SMR. VEHICLE EXHAUST 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). OMS #1 and the CSMS are also equipped with vehicle exhaust hoses. STATIONARY INTERNAL COMBUSTION ENGINES OMS #4 has a steam cleaner that is occasionally used to clean the floor of the building. There are several stationary internal combustion engines (SICE) on-site at the SMR which include the following: Emergency Generator; Steam Cleaner; Power Washer Page 17 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 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. 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 painting. In addition, solvents such as methanol and alcohols and spray cans containing other solvents are used as well. WELDING Electric arc welding is performed at OMS #4 on a periodic basis for repairing metal parts. Stainless steel welding rods are typically used. At the SMR, 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 addition, oxygen-acetylene cutting and soldering activities are performed. TANK AND FUELING EMISSIONS OMS #4 has a 300 gallon used oil storage tank that is used in conjunction with the used oil burner. There are several aboveground fuel oil storage tanks at various locations across the SMR. 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). 5.2 Regulated Waste Baseline Hazardous Waste Target: (pounds disposed per calendar year) Continuous Annual Reduction 2000 2001 2002 2003 2004 14,847 4,746 5,731 Current Page 18 2005 2006 2007 2/6/2016 MAJOR REGULATED 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. Used oil can be contaminated with dissolved metals or solvents. It does not meet the specifications required for the used oil burner and is disposed of through the DRMO. Used antifreeze can also be contaminated with dissolved metals or solvents, as well as with oil or other petroleum derivatives. This cannot be recycled through the DRMO and is disposed of as waste. Oil-water separator and parts-washer sludges are both exposed to hydrocarbons and dissolved metals and accumulate sludge over time in their operation. These sludges must be removed of periodically and disposed of as hazardous waste. No Regulated Metal Contamination21 30 lbs, 44% Lead Contamination68 8 lbs, 36% Other Regulated Metal Contamination (Ba, Cd, Ag) 928 lbs, 20% Composition of the NHARNG’s regulated waste stream for 2002. Batteries can be in many shapes, sizes, colors, and of many different ages. Batteries with heavy metals (such as Cd, Pb, Hg) are also disposed of as hazardous waste. Page 19 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 5.3 Non-Regulated Waste 5.3.1 Baseline Target: 40% Baseline Solid Waste Streams FY 2003 FY 2004 FY 2005 FY 2006 Recycled Wastes 30,000 scrap metal 47,600 tires 1919 used antifreeze N/A used shop rags spent lead-acid batteries N/A subtotal: 79,519 Non-Recycled Wastes 9,600 cardboard 6,000 scrap wood 52,800 paper 31,440 "regular" garbage 1,118 spent batteries 5,511 non-regulated waste subtotal: 106,469 185,988 TOTAL: 43% % diverted to recycling: Page 20 These quantities were estimated through measurement of a representative amount of solid waste. 2/6/2016 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 5.3.2 Recycled Waste Streams Recycled waste streams include used antifreeze, spent lead-acid batteries, tires, used shop rags, and scrap metal. More information regarding these recycled waste streams can be found in the Current P2 Initiatives section of Chapter 1. Used antifreeze is recycled through the DRMO. More information on used antifreeze can be found in Chapter 6 of this report. Approximately 1,919 lbs are recycled each year. Spent lead-acid batteries are part of a 1-for-1 exchange program with Exide, and are not disposed of as waste. No annual weight estimates could be made. Tires are recycled through the DRMO and ground up for use as rubberized asphalt in New York. No in-state alternatives were found for this recycled waste stream. Used shop rags are taken by a shop rags laundering service, Alltex. Cleaned rags are issued in exchange for the soiled shop rags. No annual weight estimates could be made. Page 21 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 5.3.3 Non-Recycled Waste Streams Non-recycled waste streams include cardboard, scrap wood, paper, “regular” garbage, some spent batteries, and some miscellaneous non-regulated waste. Cardboard and scrap wood both have the potential to become a part of the recycled waste stream, but no suitable recycling outlet for these materials has been found. Cardboard and scrap wood annual totals 9,600 lbs and 6,000 lbs respectively. Approximately 52,800 lbs of waste paper are generated per year by the NHARNG. This estimate is based upon the representative amount of solid waste measured as well as the figures estimated for the previous paper recycling program which was not successful. “Regular” garbage is comprised of tissues, candy wrappers, plastic bottles, packaging scraps, etc. This waste is disposed of in dumpsters, which are emptied on a regular basis. The details of the dumpster locations and sizes can be found in the table below. 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 Spent batteries and non-regulated waste numbers can be found on the NHARNG’s waste manifests. This excludes batteries involved in the 1-for-1 exchange program with Exide. The non-regulated waste includes asbestos, non-regulated spill cleanup material, and other miscellaneous material. 5.4 Energy Recovery Streams The NHARNG does have one energy recovery stream consisting of the used oil diverted to the used oil burner and burned for energy. On-specification used oil is sent to the Manchester OMS facility where the used oil burner is located. Any surplus used oil that will not be burned is sent to the Portsmouth Naval Shipyard. Energy recovery is not officially considered recycling, and therefore, is listed separately. Page 22 2/6/2016 CHAPTER 6 Project Results Pollution Prevention Plan 6.1 A Pollution Prevention Plan was successfully created and can be used by the NHARNG to aid in tacking progress toward established goals. Additionally, information on researched recycling programs is contained in the P2 Initiatives section of the corresponding chapter. Portions of this plan will be posted on the NHARNG Environmental Office’s website, allowing personnel to access this information when necessary. Antifreeze Recycling Program 6.2 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 6.2.1 Current Method Recycling antifreeze through the DRMO costs NHARNG exorbitant amounts of money. The following rates are associated with the DRMO antifreeze recycling program: $4.37/gallon to purchase new antifreeze through the military system $12.14/gallon to recycle used antifreeze through the DRMO $10.08/gallon to dispose of contaminated antifreeze not acceptable for recycle Using 550 gallons (10 drums) as a basis for the amount of antifreeze used per year and the approximation that 58% of the used antifreeze will be contaminated1 and consequently not accepted by the DRMO for recycle the total annual cost and cost per gallon of purchasing and recycling/disposing of antifreeze were determined. Total Annual Cost: $8,423.36 Average antifreeze cost: $15.32/gallon Both on-site and off-site antifreeze recycling programs that were investigated proved to be highly cost effective in comparison to the current costs associated with DRMO recycling. The following sections discuss the results of the technical and economic evaluations of both the onsite and off-site antifreeze recycling programs. 1 Approximations are based on FY 2002 waste manifests. Page 23 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 6.2.2 On-Site 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 refer to the BG Cool’r Clean’r Coolant Purification System Manual. Page 24 2/6/2016 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% This Process Flow diagram describes the on-site recycling process. Page 25 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard CURRENT ANNUAL COSTS: Disposal: recycled anti-freeze (42%) contaminated anti-freeze (58%) gal/year Subtotal: Purchasing: cost/amount 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: Page 26 per gallon $15.91 $5.09 $10.82 per year $8,423.36 $2,798.20 $5,625.16 2/6/2016 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 onsite 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. IMPLEMENTATION STATUS 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. 6.2.3 Off-Site Recycling Multiple off-site companies were researched and found to be inadequate for the needs of the NHARNG. Only two favorable off-site recycling companies were found: 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 Advanced Liquid Recycling, Inc (ALR) of Newington, NH Newington, NH works in conjunction with two other companies, United Industrial Services of Meriden, CT, and Consolidated Recycling of Troy, IN. These three companies function as a unit, each responsible for a particular step of the overall process. ALR serves as a holding facility for the used antifreeze, United Industrial Services provides the transportation, Consolidated United Industrial 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. Although this recycling program utilizes three separate companies, NHARNG would only interact with ALR. Utilizing this program NHARNG would have two options: Page 27 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 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 procedures it is known that they recycle the antifreeze using a multi-stage system, and the steps employed in this system are: Oil/Antifreeze Chemical Separation Atmospheric Water Distillation\ Water/Ethylene Glycol Vacuum Distillation Ethylene Glycol Concentrate Distillation Ethylene Glycol Bottoms Evaporator Salts Recovery and Re-Use System2 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: 2 List taken from Consolidated Recycling’s website: http://www.chem-group.com/consolidated.html Page 28 2/6/2016 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 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 indepth research of this partnership was placed on hold due to the fact that ARNE does not accept credit cards, which is the only payment method acceptable for NHARNG to use based on the anticipated volume of antifreeze. However, recent information has yielded a compromise which will allow for this partnership to be utilized. The process will work as follows: OMS International Merchant Purchase Authorization Card (IMPAC) cardholder will call ARNE to arrange for antifreeze pickup ARNE will swap recycled antifreeze for waste antifreeze drum for drum (minimum 1 drum at a time for Concord, Hillsboro, and Manchester and minimum 2 drums at a time for Littleton and Somersworth) IMPAC cardholder will provide ARNE with credit card information and it will be included on the NEES invoice NEES will process the payments3 Again, in order for this recycling program to be utilized it would be necessary for NHARNG to have the NGB approve a waiver to use this alternative to the DRMO. This does not pose any potential problems as NEES currently hold contracts with both RI and CT National Guards and has forwarded NHARNG copies of information regarding their business with them. A “cradle-to-grave” diagram illustrating NEES’s recycling process was provided in their company’s brochure and can be summarized by the following steps: 1) Antifreeze is collected and transported in Department of Transportation (DOT) approved drums and totes 3 Wilber, Spencer. E-mail correspondence regarding Antifreeze Recycling, Friday, August 01, 2003 Page 29 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 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. 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. IMPLEMENTATION STATUS Available Option. This initiative has been researched and is available to implement at any time. 6.2.4 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. Page 30 2/6/2016 $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 The chart above describes the total annual cost of antifreeze (blue) and the possible savings (green) by implementing each method of recycle. The chart below describes the total cost per gallon of antifreeze (blue) from “cradle to grave” associated with each method of recycle. The total savings per gallon are also shown (green). $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 $2.20 $- $10.23 $11.72 $13.12 Page 31 Off-site with ARNE 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 6.3 Paper Recycling Program 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. Building # of Totes Size (gal) USP&FO 1 75 Counter drug 1 75 Armory 1 95 Building C 1 75 Building T 4 95 Building 57 2 95 Building B 1 75 CSMS Annex 1 20 AASF 1 20 CSMS 1 75 Warehouse 2 95 Building F 1 95 Recurring Costs: None. Recurring Cost Savings: 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 Page 32 2/6/2016 Paper 52,800 lbs; 28% Other Solid Waste 133,188 lbs; 72% This chart details the amount of paper in the NHARNG’s solid waste stream. Paper is estimated to be approximately 28% of the total solid waste stream. 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 (located in Appendix D) have been created. As soon as awareness has increased and participation by 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. Page 33 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard CHAPTER 7 Recommendations for Future Efforts There are many tools at an organization’s disposal that, if used properly, will drastically reduce the difficulty of Pollution Prevention efforts. The single most important tool is recordkeeping. Proper recordkeeping will allow statistics to be gathered and analyzed to determine the effectiveness of P2 efforts, as well as the necessity and feasibility of future efforts. It will also allow for the tracking of progress toward a goal. The Army, and therefore, the NHARNG, is goal and progress oriented. Plans are developed, goals established, and progress toward that goal is tracked. This ensures that goals are met on schedule and progress is made. During the course of this internship, gathering records was a very difficult task. In many cases, incorrect points of contact were given, or those points of contact did not have the information being sought. Companies with which the NHARNG has contracts had to be contacted for information regarding details of the services they were providing. For this reason, the most important recommendation for future efforts by the NHARNG is to improve recordkeeping. This will allow for baselines to be established and the successful implementation of this Pollution Prevention Plan. Page 34 2/6/2016 APPENDIX A References Mr. Zachary Boyajin Environmental Program Manager NHARNG – Environmental Office 57 Regional Drive Concord, NH 03301 603-227-1439 zachary.boyajin@nh.ngb.army.mil Re: office staff, pesticide use Eileen Chabot State Environmental Specialist NHARNG – Environmental Office 57 Regional Drive Concord, NH 03301 Phone: 603-225-1211 eileen.chabot@nh.ngb.army.mil Re: Supervisor, office check-in, point of contact Judy Chen SMR – Accounting Concord, NH 03301 (603) 225-1366 judy.chen@nh.ngb.army.mil Re: Dumpster contract NHARNG – USPFO State Military Reservation DOIM 603-225-1385 matthew.dupuis@nh.ngb.army.mil Re: Computer logon, e-mail capabilities SFC Stephen Dyment CSMS SMR – Concord, NH (603) 228-1135 x1539 stephen.dyment@nh.ngb.army.mil Re: Antifreeze presentation Bill Green Territory Manager W. H. Shurtleff Company South Portland, ME bgreen@whshurtleff.com Ms. Karen Hallenborg NHARNG – Supply 603-225-1358 karen.hallenborg@nh.ngb.army.mil Re: State Maintenance Shop Site Contact CW2 David Clemons CMSM SMR – Concord, NH (603) 225-1392 david.clemons@nh.ngb.army.mil Re: Antifreeze presentation Ken Herman KFM Corporation Anderson, SC 29621 ken@kfmllc.com Re: On-Site Antifreeze Recycling MSG Mike Dignard NHARNG – OMS #3 Somersworth, NH 603-692-4693 michael.dignard@nh.ngb.army.mil Re: OMS #3 Site Contact MAJ Wayne Kreiensieck CSMS Foreman – CSMS, SMR Concord, NH 03301 (603) 228-1135 x1297 wayne.kreiensieck@nh.ngb.army.mil Re: CSMS Site Visit SSG Randy Dockham NHARNG – OMS #2 Littleton, NH 603-444-2387 randy.dockham@nh.ngb.army.mil Re: OMS #2 Site Contact Wanda Kula Revamp, Inc. Concord, NH (603) 228-5211 SPC Matthew Dupuis MSG Richard LaFlamme Environmental Protection Specialist NHARNG – Environmental Office Page 35 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 57 Regional Drive Concord, NH 03301 Phone: 603-225-1333 e-mail: richard.laflamme@nh.ngb.army.mil Re: office staff, TRI, EPA priority chemicals info Ms. Muriel Lajoie Hazardous Waste Manager NHARNG – Environmental Office 57 Regional Drive Concord, NH 03301 603-227-1434 muriel.lajoie@nh.ngb.army.mil Re: office staff CW4 Thomas LaPierre CSMS – SMR Concord, NH 03301 (603) 228-1135 x1312 Thomas.lapierre@nh.ngb.army.mil Re: CSMS Site Visit Mark Lennon The Institution Recycling Network Concord, NH 1-866-229-1962 mlennon@ir-network.com Linda McCormack SMR – Accounting Concord, NH 03301 linda.mccormack@nh.ngb.army.mil Re: Wastewater information SFC Dennis MacKenzie NHARNG – OMS #5 Hillsboro, NH 603-464-0226 dennis.mackenzie@nh.ngb.army.mil Re: OMS #5 Site Contact SGT Brian McKay AASF – SMR Concord, NH 03301 (603) 228-1135 x1290 brian.mckay@nh.ngb.army.mil Re: AASF Site Visit MSG Jim Muhnisky Joint Operation SMR – Concord, NH (603) 227-1533 jimmy.muhnisky@nh.ngb.army.mil Re: Antifreeze recycling Dave Nylund Air National Guard – Environmental Manager Portsmouth, NH (603) 430-2366 david.nylund@nhpeas.ang.af.mil Re: Antifreeze Recycling Tom Phoenix Regional Representative Advanced Liquid Recycling, Inc. Meriden, CT (800) 637-0917 tphoenix@unitedindustrialservices.com SGT Roger Prive NHARNG 603-225-1290 robert.prive@nh.ngb.army.mil Re: AASF site contact SFC Wesley Rand CSMS SMR – Concord, NH (603) 228-1135 x1299 weseley.rand@nh.ngb.army.mil Re: Antifreeze presentation 1SG Kevin Reynolds NHARNG – USPFO Warehouse 603-225-1216 kevin.reynolds@nh.ngb.army.mil Re: USPFO Warehouse Site Contact SPC Stephanie Roberts NHARNG-HQ State Military Reservation Building F – DCISM Concord, NH 03301 603-228-1135 x1500 stephanie.roberts@nh.ngb.army.mil Re: ID cards LTC Daniel Saucier CSMS – SMR Concord, NH 03301 (603) 228-1135 x1231 daniel.saucier@nh.ngb.army.mil Re: Antifreeze Recycling Presentation Page 36 2/6/2016 Colleen Schwalbe P2 Specialist – NHDES Concord, NH 03301 (603) 271-0878 Re: Contaminated Antifreeze CW2 George Spaulding NHARNG – NHNGTS Mgr Center Strafford, NH 603-225-1353 george.spaulding@nh.ngb.army.mil Re: NHARNG Training Site Contact CW2 Michael Tkacz NHARNG – OMS #4 Manchester, NH 603-627-6299 michael.tkacz@nh.ngb.army.mil Re: OMS #4 Site Contact Mr. Jason Weaver ETSS NHARNG – Environmental Office 57 Regional Drive Concord, NH 03301 603-227-1411 jason.weaver@nh.ngb.army.mil Re: office staff, computer information SFC Spence Wilber NHARNG – USPFO Concord, NH 603-225-1359 spencer.wilber@nh.ngb.army.mil Re: Affirmative Procurement Page 37 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard APPENDIX B Selected Pictures Pictures were taken at the following facilities during the 2003 UNH & NHPPP P2 Internship Program while working with the New Hampshire Army National Guard (NHARNG). All pictures taken during the course of this internship can be found on the accompanying CD. (i) Army Aviation Support Facility (AASF) (ii) Combined Support Maintenance Shop (CSMS) and CSMS Annex (iii) Littleton Organizational Maintenance Shop (OMS) #2 (iv) Somersworth Organizational Maintenance Shop (OMS) #3 (v) Manchester Organizational Maintenance Shop (OMS) #4 (vi) Hillsboro Organizational Maintenance Shop (OMS) #5 (vii) New Hampshire National Guard Training Site (NHNGTS) Page 38 2/6/2016 APPENDIX C 2640-00-138-8324 2640-00-256-5526 2640-00-256-5527 2640-00-264-6642 2640-00-922-6917 2910-01-128-9537 3439-00-184-8960 3439-00-255-4566 3439-00-255-4572 3439-00-262-2648 3439-00-262-2652 3439-00-262-2653 3439-00-262-2743 3439-00-288-0868 3439-00-640-3713 5970-00-962-3335 6140-01-210-1964 6140-01-431-1172 6140-01-446-9506 6505-00-104-9000 6505-00-174-2293 6630-01-011-5039 6810-00-201-0906 6810-00-249-9354 6810-00-264-6715 6810-00-275-6010 6810-00-543-7415 6810-00-597-3608 6810-00-843-1640 6830-00-169-0800 6830-00-584-3041 6840-00-570-5299 6850-00-001-4193 6850-00-177-5094 6850-00-181-7929 6850-00-274-5421 6850-00-281-1985 6850-00-485-4697 6850-00-598-7311 6850-00-664-1257 6850-00-823-7861 6850-00-880-7616 6850-00-926-2275 6850-01-063-4760 6850-01-082-6783 6850-01-085-1423 6850-01-246-6544 6850-01-377-5074 6850-01-441-3218 7510-00-183-7698 7930-00-269-1272 7930-00-282-9699 7930-00-282-9700 7930-00-935-3794 7930-01-328-5959 NHARNG Hazardous Materials Inventory Solution,Buffing Lubricant,Tire And Rim Lubricant,Tire And Rim Lubricant,Inner Tube Bonding Compound,Tire Repair Engine Starting Fluid (Diesel Start) Solder,Lead Alloy Flux,Soldering Flux,Brazing Electrode,Welding Electrode,Welding Electrode,Welding Electrode,Welding Flux,Soldering Flux,Brazing Insulating Varnish,Electrical Lead Acid Battery Battery,Storage Lead Acid Battery Denatured Ethyl Alcohol Nitrogen Compressed Test Kit,Antifreeze Alcohol,Denatured Sulfuric Acid,Electrolyte Molybdenum Disulfide,Technical Methanol,Technical Alcohol,Denatured Methanol,Technical Sulfuric Acid,Electrolyte Oxygen,Technical Propane Sanitizer-Detergent,General Purpose Water Indicating Paste Silicone Grease Fleet Charge Antifreeze & Coolant Cleaning Compound,Solvent Dry Cleaning Solvent Cleaning Compound,Optical Lens Leak Preventive Compound,Radiator Silicone Compound Fuel,Engine Primer Silicone Grease Cleaning Compound,Windshield Cleaning Compound,Solvent Fuel,Engine Primer Carbon Removing Compound Stabilizer Additive,Diesel Fuel Inhibitor,Icing,Fuel System Antifreeze Ink,Marking Stencil Absorbent Material,Oil And Water Detergent,General Purpose Detergent,General Purpose Polish,Plastic Cleaning Compound,Solvent-Detergent Page 39 7930-01-331-1507 7930-01-342-5316 7930-01-383-7926 7930-01-393-6664 7930-01-423-1292 8010-00-079-3760 8010-00-141-2950 8010-00-160-5787 8010-00-181-8079 8010-00-181-8080 8010-00-251-6503 8010-00-257-5377 8010-00-286-7758 8010-00-286-7838 8010-00-290-6983 8010-00-290-6984 8010-00-297-0547 8010-00-297-0567 8010-00-297-0585 8010-00-297-2105 8010-00-298-2302 8010-00-348-7715 8010-00-527-2053 8010-00-527-3199 8010-00-582-5382 8010-00-584-3150 8010-00-597-7862 8010-00-598-5460 8010-00-598-5464 8010-00-598-5936 8010-00-616-7503 8010-00-616-9143 8010-00-616-9181 8010-00-721-9479 8010-00-721-9743 8010-00-721-9744 8010-00-846-5117 8010-00-848-9272 8010-00-852-9033 8010-00-935-7079 8010-01-115-7984 8010-01-122-1969 8010-01-331-6108 8030-00-051-4011 8030-00-081-2328 8030-00-081-2335 8030-00-087-8630 8030-00-145-0151 8030-00-148-9833 8030-00-252-3391 8030-00-275-8111 8030-00-290-5141 8030-00-537-7925 8030-00-546-8637 8030-00-656-1426 Cleaning Compound,Solvent-Detergent Cleaning Compound,Solvent-Detergent Cleaning Compound,Solvent-Detergent Defoamer Cleaning Compound,Solvent-Detergent Enamel Enamel Yellow Thinner,Paint Products Thinner,Aliphatic Polyurethane Coating Thinner,Paint Products Lacquer Lacquer Enamel Yellow Enamel Interior Semi-Gloss Enamel White Enamel Black Spray Enamel Black Enamel, Lo Voc White Enamel Alkyde, Lo Voc Yellow Enamel Olive Drab Enamel Alkyd Gloss Lo Voc Blue Enamel, Brown Enamel Alkyd Gloss Lo Voc Black Enamel, Red Gloss Enamel, Lacquer, Flat Black Enamel Flat White Enamel Alkyd Lo Voc Brown Enamel Alkyd Lo Voc Brown Enamel Alkyd Lo Voc Green Enamel Olive Drab Lacquer Spray Green Enamel, Black Primer Coating, Light Gray Enamel Spray Orange Enamel Spray Red Gloss Enamel, Yellow Enamel, Olive Drab Enamel Spray Enamel, Yellow Lacquer Spray Paint Enamel Alkyd Lo Voc Green Enamel Alkyd, Yellow Enamel Spray Sealing Compound Sealing Compound Sealing Compound Antiseize Compound Coating Compound,Plastisol Sealing Compound Sealing Compound Sealing Compound Coating Compound,Bituminous,Solvent Sealing Compound Corrosion Preventive Compound Sealing Compound 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard 8030-00-664-4944 8030-00-764-6658 8030-00-835-0884 8030-00-850-7076 8030-00-926-2135 8030-01-025-1692 8030-01-054-0740 8030-01-087-3589 8030-01-103-2868 8030-01-155-3238 8040-00-117-8510 8040-00-181-7761 8040-00-266-0850 8040-00-728-3088 8040-00-833-9563 8040-00-844-9707 8040-00-851-0211 8040-00-938-6860 8040-01-010-8758 8040-01-126-1422 8120-00-268-3360 8520-00-228-0598 9150-00-145-0268 9150-00-181-7724 9150-00-190-0918 9150-00-231-6689 9150-00-231-9071 9150-00-234-5197 9150-00-257-5370 9150-00-273-2389 9150-00-458-0075 Preservative Coating,Canvas Antiseize Compound Antiseize Compound Coating Compound Filler,Dent,Metal Surface Sealing Compound Sealing Compound Sealing Compound Sealing Compound Sealing Compound Adhesive Adhesive Adhesive Silicone Sealant Adhesive Adhesive Silicone Sealant Rubber Adhesive Silicone Sealant Adhesive Cylinder,Compressed Soap,Toilet Grease,Aircraft Grease,Aircraft Grease,Graphite Lubricating Oil,General Purpose Brake Fluid,Automotive Lubricating Oil,Exposed Gear Grease,Graphite Lubricating Oil,General Purpose Lubricating Oil,General Purpose 9150-00-657-4959 9150-00-698-2382 9150-00-753-4667 9150-00-823-7860 9150-00-935-5851 9150-00-935-9807 9150-00-935-9809 9150-00-944-8953 9150-00-999-7548 9150-01-007-4384 9150-01-015-1542 9150-01-035-5393 9150-01-053-6688 9150-01-054-6453 9150-01-079-6124 9150-01-102-9455 9150-01-126-4459 9150-01-177-3988 9150-01-178-4725 9150-01-197-7692 9150-01-197-7693 9150-01-198-3829 9150-01-260-2534 9150-01-310-5762 9150-01-351-9019 9150-01-353-4799 9150-01-421-1427 Page 40 Hydraulic Fluid, AT Hydraulic Fluid, AT Lubricating Oil,Air Compressor Lubricating Compound,Dimethylsilicone Grease,Aircraft Hydraulic Fluid,Petroleum Base Hydraulic Fluid,Petroleum Base Grease,Aircraft Lubricant,Interlocking Slide Fastener Grease,Aircraft And Instrument Grease,Molybdenum Disulfide Lubricating Oil,Gear Cleaner,Lubricant And Preservative Cleaner,Lubricant And Preservative Cleaner,Lubricant And Preservative Brake Fluid,Automotive Lubricating Oil Lubricating Oil,Engine Lubricating Oil,Engine Grease,Automotive And Artillery Grease,Automotive And Artillery Gear Lubricant Additive,Limited Slip Lubricant,Solid Film Oil,Synthetic Lubricating Oil,Engine Hydraulic Fluid,Automatic Transmission Lubricating Oil,Engine 2/6/2016 APPENDIX D Paper Recycling Awareness Poster (located on next) Page 41 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard Page 42 2/6/2016 Pollution Prevention Plan – 2003 APPENDIX E Site Visit Checklist Site: __________________ Date: _________________ Attending: _____________ _____________ _____________ Documents Collected: Hazardous waste generated Hazardous material inventory Fuels usage Air conditioning units Boilers Solid waste generated/Recycling Air emissions inventory Used oil for recycle (Drum Logs, Bill of Lading) Water consumption Wastewater generation Raw materials purchased Description of current initiatives being implemented to reduce/eliminate hazardous waste, solid waste, air emissions, water consumption, and wastewater generation: Contacts: When implemented Description Benefits Economic Environmental Notes: Name: Job Title: Phone: E-Mail: Re: Name: Job Title: Phone: E-Mail: Re: Name: Job Title: Phone: E-Mail: Re: Name: Job Title: Phone: E-Mail: Re: Name: Job Title: Phone: E-Mail: Re: Page 43 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard APPENDIX F Antifreeze Recycling Presentation Handout (located on next) Page 44 2/6/2016 Pollution Prevention Plan – 2003 Anti-freeze Recycling at the CSMS: Cost Analysis IMPLEMENTATION COSTS: refractometer training (8 hours) $186.75 $200.00 training from company $1,000.00 TOTAL: $1,386.75 POTENTIAL ANNUAL COSTS: amount/year cost/amount cost/year Additives: P-Corrosion Inhibitor (74 oz) 10 $63.38 $633.80 KOH pH Adjustor (2 oz) 10 $9.12 $91.20 Virgin Anti-freeze (200 gallons @ $4.37/gallon) 200 gal $4.37 $874.00 Resin Regeneration (once per year) 1 $400 + freight $450.00 Subtotal: $2,049.00 Filters (changed twice per year): 1 Micron Filters 2 $11.55 $23.10 20 Micron Filters 2 $10.00 $20.00 Charcoal Filter Cartridges 2 $28.05 $56.10 Subtotal: 6 $99.20 Labor: Filter changes (2 per year) 2 hr $25/hr $50.00 Resin Regeneration 1 hr $25/hr $25.00 Operation (based on 180gal/hr machine rate) 4 hr $25/hr $100.00 Subtotal: 7 hr $175.00 Transportation: Littleton (4hrs round trip + 2 hrs @ CSMS) 6 hr $25/hr $150.00 Manchester (1.5hrs round trip + 2 hrs @ CSMS) 3.5 hr $25/hr $87.50 Hillsboro (2hrs round trip + 2 hrs @ CSMS) 4 hr $25/hr $100.00 Somersworth (2.5hrs round trip + 2 hrs @ CSMS) 4.5 hr $25/hr $112.50 Subtotal: 18 hr $450.00 Waste Disposal: Used Filters (charcoal only) 2 $25.00 Oil Absorbant Pads (negligible contribution to waste) $0.00 Subtotal: $25.00 TOTAL: $2,798.20 RECURRING ANNUAL SAVINGS Current Annual Costs Potential Annual Costs ANTICIPATED SAVINGS: Payback Period: Page 45 per gallon $15.32 $5.09 $10.23 per year $8,423.36 $2,798.20 $5,625.16 3 months 2/6/2016 UNH & NHPPP P2 Internship – NH Army National Guard Anti-freeze Recycling at the CSMS: Cost Analysis IMPLEMENTATION COSTS: refractometer training (8 hours) $186.75 $200.00 training from company $1,000.00 TOTAL: $1,386.75 POTENTIAL ANNUAL COSTS: amount/year cost/amount cost/year Additives: P-Corrosion Inhibitor (74 oz) 10 $63.38 $633.80 KOH pH Adjustor (2 oz) 10 $9.12 $91.20 Virgin Anti-freeze (200 gallons @ $4.37/gallon) 200 gal $4.37 $874.00 Resin Regeneration (once per year) 1 $400 + freight $450.00 Subtotal: $2,049.00 Filters (changed twice per year): 1 Micron Filters 2 $11.55 $23.10 20 Micron Filters 2 $10.00 $20.00 Charcoal Filter Cartridges 2 $28.05 $56.10 Subtotal: 6 $99.20 Labor: Filter changes (2 per year) 2 hr $25/hr $50.00 Resin Regeneration 1 hr $25/hr $25.00 Operation (based on 180gal/hr machine rate) 4 hr $25/hr $100.00 Subtotal: 7 hr $175.00 Transportation: Littleton (4hrs round trip + 2 hrs @ CSMS) 6 hr $25/hr $150.00 Manchester (1.5hrs round trip + 2 hrs @ CSMS) 3.5 hr $25/hr $87.50 Hillsboro (2hrs round trip + 2 hrs @ CSMS) 4 hr $25/hr $100.00 Somersworth (2.5hrs round trip + 2 hrs @ CSMS) 4.5 hr $25/hr $112.50 Subtotal: 18 hr $450.00 Waste Disposal: Used Filters (charcoal only) 2 $25.00 Oil Absorbant Pads (negligible contribution to waste) $0.00 Subtotal: $25.00 TOTAL: $2,798.20 RECURRING ANNUAL SAVINGS Current Annual Costs Potential Annual Costs ANTICIPATED SAVINGS: Page 46 Payback Period: per gallon $15.32 $5.09 $10.23 3 months per year $8,423.36 $2,798.20 $5,625.16 2/6/2016 Pollution Prevention Plan – 2003 Off-Site Recycling with Advanced Liquid Recycling Inc. 55 gal at a time New Antifreeze (from Off-Site) Recycling of Used Antifreeze Total New Antifreeze (from Military) Recycling of Used Antifreeze Total Cost/Drum $198.00 $0.00 $198.00 $241.00 $50.00 $291.00 Drums/Year 10 10 110 gal at a time New Antifreeze (from Off-Site) Recycling of Used Antifreeze Total New Antifreeze (from Military) Recycling of Used Antifreeze Total Cost/Drum $186.00 $186.00 $241.00 $84.00 $325.00 Drums/Year 10 5 10 10 10 5 Cost/Year $1,980.00 $0.00 $1,980.00 $2,410.00 $500.00 $2,910.00 Cost/Year $1,860.00 $1,860.00 $2,410.00 $420.00 $2,830.00 Anticipated Savings Purchasing New Antifreeze: Off-Site Military 55 gal at a time 110 gal at a time $6443.36/year $6563.36/year $11.72/gal $11.93/gal $5513.36/year $5593.36/year $10.02/gal $10.17/gal Cost/Benefit Analysis Summary $/year $/gallon $8,423.36 $15.32 Current Cost Off-Site Cost (Adv. Liq. Rec) $1,980.00 SAVINGS: $6,443.36 Off-Site Cost (military) On-site Cost $3.60 $11.72 $2,910.00 $5.29 SAVINGS: $5,513.36 $2,798.20 SAVINGS: $5,625.16 $10.03 $5.09 $10.23 Page 47 2/6/2016