New Hampshire Army National Guard (NHARNG)
Pollution Prevention (P2) Plan
Summer 2003
Shelley Dougherty
University of New Hampshire
P2 Intern
(207)384-4227
NHARNG
Environmental Office
57 Regional Dr.
Concord NH, 03301
Mrs. Eileen Chabot
NHARNG Environmental Office
Environmental Specialist
(603)225-1211
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Table of Contents
LIST OF ACRONYMS .................................................................................................................................................... 5
I.) EXECUTIVE SUMMARY ......................................................................................................................................... 7
II.) INTRODUCTION ...................................................................................................................................................... 7
A.) PURPOSE................................................................................................................................................................... 7
B.) NHARNG P2 BACKGROUND.................................................................................................................................... 7
C.) SCOPE OF P2 PLAN.................................................................................................................................................... 9
D.) OUTLINE OF P2 PLAN ............................................................................................................................................... 9
III.) GOALS AND OBJECTIVES .................................................................................................................................10
IV.) APPROACH .............................................................................................................................................................11
A.) DEVELOPMENT OF THE P2 PLAN ..............................................................................................................................11
i.) Site Visits ............................................................................................................................................................ 11
ii.) Data Collection and Analysis ............................................................................................................................ 12
iii.) Writing the P2 Plan .......................................................................................................................................... 12
B.) ANTIFREEZE RECYCLING PROGRAM ........................................................................................................................12
i.) Baseline Development and Current Recycling Procedures .................................................................................12
ii.) Investigation of On-Site Recycling Opportunities ..............................................................................................13
iii.) Investigation of Off-Site Recycling Opportunities .............................................................................................13
iv.) Antifreeze Recycling Presentation .....................................................................................................................14
v.) New Off-Site Recycling Opportunity ...................................................................................................................14
C.) PAPER RECYCLING PROGRAM
14
i.) Previous Paper Recycling Program and Baseline Development .........................................................................14
ii.) Investigation of Potential Recycling Opportunities ............................................................................................14
iii.) Development of Awareness Poster and Presentation ........................................................................................15
D.) AUTHORIZED USE LIST............................................................................................................................................15
V.) CHEMICAL USAGE ................................................................................................................................................16
VI.) RELEASES/WASTES GENERATED...................................................................................................................18
A.) HAZARDOUS WASTE STREAMS ...............................................................................................................................18
B.) ENERGY RECOVERY STREAMS.................................................................................................................................19
C.) SOLID WASTE STREAMS ..........................................................................................................................................20
i.) Recycled Solid Waste Streams .............................................................................................................................20
ii.) Non-Recycled Solid Waste Streams ....................................................................................................................20
D.) AIR EMISSIONS ........................................................................................................................................................23
VII.) PROJECT RESULTS ............................................................................................................................................26
A.) ANTIFREEZE RECYCLING PROGRAM RESULTS .........................................................................................................26
i.) Current Antifreeze Recycling through DRMO .....................................................................................................26
ii.) On-site Antifreeze Recycling ..............................................................................................................................26
iii.) Off-site Antifreeze Recycling .............................................................................................................................29
iv.) Advanced Liquid Recycling, Inc.........................................................................................................................30
v.) ARNE and NEES Partnership .............................................................................................................................31
vi.) Economic Analysis Summary .............................................................................................................................32
B.) PAPER RECYCLING PROGRAMS RESULTS .................................................................................................................33
VIII.) FUTURE RECOMMENDATIONS ....................................................................................................................35
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IX.) LIST OF CONTACTS.............................................................................................................................................37
X.) REFERENCES ..........................................................................................................................................................40
XI.) APPENDICES ..........................................................................................................................................................41
A.) NHARNG P2 EQUIPMENT ......................................................................................................................................43
B.) SITE VISIT CHECKLIST .............................................................................................................................................45
A.) PAPER RECYCLING AWARENESS POSTER ................................................................................................................47
Table of Figures
FIGURE 1: HAZARDOUS WASTE CONTAMINATION
FIGURE 2: TYPE AND QUANTITY OF BATTERIES DISPOSED
FIGURE 3: SOLID WASTE STREAMS
FIGURE 4: AIR EMISSIONS SOURCES
FIGURE 5: ON-SITE ANTIFREEZE RECYCLING PROCESS, MATERIAL FLOW DIAGRAM
FIGURE 7: ANTIFREEZE ANNUAL COST/SAVINGS COMPARISON
FIGURE 8: ANTIFREEZE AVERAGE COST/SAVINGS PER GALLON COMPARISON
FIGURE 9: POTENTIAL IMPACT OF PAPER RECYCLING
FIGURE 10: ANTIFREEZE RECYCLING MACHINE
FIGURE 11: AQUEOUS PARTS WASHER (INSIDE)
FIGURE 12: SECONDARY CONTAINMENT AREA
FIGURE 13: FILTER CRUSHER
FIGURE 14: AEROSOL CAN PUNCTURING MACHINE
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19
23
25
27
33
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34
43
43
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Summer 2003
List of Acronyms
AASF
Army Aviation Support Facility
ALR
Advance Liquid Recycling, Inc.
AOAP
Army Oil Analysis Program
ARNE
Antifreeze Recycling of New England
CSMS
Combined Support Maintenance Shop
DRMO
Defense Reutilization and Marketing Office
DRMS
Defense Reutilization and Marketing Service
EO
Executive Order
EPA
Environmental Protection Agency
EMS
Environmental Management System
IMPAC
International Merchant Purchase Authorization Card
IRN
Institution Recycling Network
NEES
New England Environmental Service
NHDES
New Hampshire Department of Environmental Service
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
USP&FO
United States Property & Fiscal Office
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I.) EXECUTIVE SUMMARY
The New Hampshire Army National Guard (NHARNG) needs to develop an updated Pollution
Prevention (P2) Plan in accordance with Executive Order (EO) 13148, “Greening the Government
through Leadership in Environmental Management” and ISO 14001.
The purpose of this internship was to develop a new P2 Plan for the NHARNG by analyzing the
mission and the processes that take place at NHARNG facilities included in the scope of the P2 plan
and brainstorming potential P2 initiatives that could help further NHARNG’s future P2 endeavors.
On August 1st, 2003 a rough draft of the new P2 Plan was given to Mrs. Eileen Chabot for review.
After revisions are made, the final P2 Plan will be signed and turned in on or before October 15th,
2003.
The NHARNG has made arrangements to extend this internship through the 2003 – 2004 academic
year in order that implementation of potential P2 initiatives recommended in the P2 plan may begin.
II.) INTRODUCTION
A.) Purpose
The purpose of a P2 plan is to outline a facility’s commitment to P2 by documenting, tracking, and
managing practices and initiatives necessary to reduce the release of pollutants and decrease the use
of hazardous materials.
As a federal facility, the NHARNG is required by EO 13148, “Greening the Government through
Leadership in Environmental Management” to develop a P2 plan that addresses their P2 endeavors
aimed toward achieving the goals prescribed by this EO as well as EO 13101, “Greening the
Government through Waste Prevention, Recycling, and Federal Acquisition,” EO 13123, “Greening
the Government through Efficient Energy Management,” and EO 13149, “Greening the
Government through Federal Fleet and Transportation Efficiency.” The following sections
describe NHARNG’s previous P2 plans as well as the scope and outline of the updated P2 plan.
B.) NHARNG P2 Background
NHARNG’s previous P2 plan was written in 1996 by Environmental Protection Specialist SFC
Richard A. Laflamme. This plan was developed in order to comply with EO 12856, “Federal
Compliance with Right-To-Know Laws and Pollution Prevention Requirements; August 1993.”
The P2 initiatives recommended for implementation by this plan resulted from an Opportunity
Assessment (OA) conducted in June of 1993 by two Pollution Prevention Assessment Teams from
the New Hampshire Department of Environmental Services (NHDES). All the P2 initiatives
documented in this P2 plan were implemented, and are currently still being implemented with the
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exception of on-site antifreeze recycling at the Combined Support Maintenance Shop (CSMS) in
Concord.
The P2 initiatives that are currently being implemented as a result of previous P2 plans and OAs
include the following:

Organizational Maintenance Shops (OMSs) participate in the Army Oil Analysis Program
(AOAP) to ensure that oil is changed only when necessary

“Used Oil for Recycle” is burned in Manchester for the Energy Recovery Program

Aqueous parts washers are used in place of petroleum based solvent parts washers

Maintenance shop rags are laundered by a contracted rag laundering service and reused

Oil filters are hot drained, crushed and the resulting scrap metal is recycled

Secondary containment areas are used for storage of tactical fueling truck tanks to capture
any fuel spillage/leakage

An aerosol can puncturing system is used to puncture and drain aerosol cans; the resulting
scrap metal from the empty cans is recycled

Oil-water separators are used to separate any oil from wastewater before wastewater is
discharged to the sewer system

Scrap metal is collected and recycled; all the money acquired is placed in a fund site
dedicated to the health and welfare of the troops as well as P2 equipment

Used tires are sent through the Defense Reutilization Marketing Service (DRMS) to New
York to be ground up and reused in rubberized asphalt

Spend lead-acid batteries are recycled through a one-for-one exchange program with Exide,
and

Antifreeze is recycled through the Defense Reutilization Marketing Office (DRMO).
Pictures of NHARNG’s P2 equipment utilized to implement many of the P2 initiatives described
above can be found in the Appendices.
The majority of the P2 initiatives implemented by NHARNG in the past have remained successful
over the years. As can be expected, however, some were terminated due to either a decrease in
effectiveness or lack of interest and participation. These problems plagued both NHARNG’s onsite antifreeze recycling program as well as the paper recycling program.
In the mid 90s, an antifreeze recycling machine was purchased and an on-site antifreeze recycling
program was established at the CSMS in Concord. CSMS mechanics were trained to operate the
machine and the recycling program ran smoothly for several years. Approximately two years ago,
however, accumulation of excess recycled antifreeze became a problem and use of the machine
stopped. Upon termination of the on-site antifreeze recycling program, NHARNG began recycling
antifreeze through the DRMS, a very costly alternative.
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A paper recycling program was also established at the State Military Reservation (SMR) a couple
years ago with Tobey School, a nonprofit organization, in partnership with Revamp Inc. Recycling
totes were placed in various locations on the SMR and Tobey School/Revamp would empty and
replace all the totes and recycle the paper free of charge. Due to lack of awareness and participation
on behalf of SMR staff, the paper recycling program was terminated by Tobey School/Revamp
shortly after it began.
The new P2 plan will not only help maintain the successfulness and effectiveness of the currently
implemented P2 initiatives, but will also address the problems of the unsuccessful ones as well in an
attempt to overcome the obstacles encountered in the past.
C.) Scope of P2 Plan
National Guard facilities function jointly as state and federal establishments. Do to the fact that
only federal funds were allocated to the development of this P2 plan, the scope extends across only
federally owned and operated NHARNG facilities.
The SMR, located in Concord NH, serves as the NHARNG headquarters. The facilities included in
the P2 plan that reside on the SMR include the CSMS, the CSMS Annex, the Army Aviation
Support Facility (AASF), the United States Property & Fiscal Office (USP&FO) Warehouse, and
the State Maintenance Shop. In general these facilities perform a variety of activities which
contribute to the overall maintenance and repair of tactical vehicles, field artillery equipment,
construction equipment, and Blackhawk helicopters as well as the dispensing of JP-8 fuel.
In addition to the SMR facilities, the P2 plan also addresses NHARNG’s 4 OMSs located in
Littleton, Somersworth, Manchester, and Hillsboro. The OMSs perform routine maintenance on
tactical vehicles and field artillery equipment. Typical processes involved in the routine
maintenance include fluid, battery, and filter changes, parts cleaning and replacement, brake
servicing, and vehicle washing.
Aside from the maintenance facilities, the P2 plan also includes the New Hampshire National Guard
Training Site (NHNGTS), located in Center Strafford. The NHNGTS is the primary training
facility for NHARNG and an auxiliary training facility for the NH Air National Guard, and serves
as a basis for the majority of training operations.
D.) Outline of P2 Plan
The P2 Plan is comprised for 14 chapters. The first 5 chapters are dedicated to introductory and
background information relating respectively to pollution prevention, P2 regulations, NHARNG P2
program, compliance sites and thresholds, and NHARNG’s waste generating processes.
Chapters 6 – 14 of the P2 plan focus specifically on the establishment of potential P2 initiatives that
will help NHARNG achieve all the P2 goals instituted by EOs. These chapters respectively address
the following areas:

Hazardous/Universal Waste

Solid Waste
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
Air Emissions

Water and Wastewater

EPA Priority Chemical Reduction and TRI Form R Reporting

Ozone Depleting Substance

Vehicle Fuel Conservation

Energy Conservation

Affirmative Procurement
Each chapter is comprised of four major sections which include goals, baseline and progress,
current P2 initiatives, and potential P2 initiatives. The goals section states the source, baseline year,
and target year of the goal in addition to the goal itself. The baseline and progress section is
comprised of information regarding data collection and techniques/sources utilized to approximate
quantities. It also includes a table for tracking progress beginning with the baseline year. The
current P2 initiatives section describes all P2 initiatives that are currently being implemented as a
result of previous P2 plans and past opportunity assessments. Finally, the potential P2 initiatives
section details all P2 initiatives that were developed as a result of this internship and recommended
for future implementation.
III.) GOALS AND OBJECTIVES
The primary goal and overall purpose of this P2 internship was to develop a new, updated, P2 plan
for the NHARNG that specifically addressed the goals and requirements of EO 13148. Embedded
in the development of the P2 plan were specific P2 objectives that NHARNG wished to have
addressed. These objectives became the primary focus of the “Potential P2 Initiatives” portions of
the P2 plan and included the following projects:

research and evaluation of re-establishing a paper recycling program

research and evaluation of an antifreeze recycling program, as an alternative to the DRMS,
and

investigation and development of an authorized use list
Aside from the actual development and writing of the P2 plan, the internship focused on initializing
the implementation of the projects listed above.
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IV.) APPROACH
A.) Development of the P2 Plan
i.) Site Visits
Ultimately the first course of action taken upon beginning the internship was the scheduling of site
visits to all the facilities that were to be included in the scope of the P2 plan. Having been given a
list of the facilities and their corresponding contact person, several phone calls were made as well as
E-mails sent, and within the first week the majority of the site visits had been scheduled and
confirmed.
It was decided that for timing purposes all site visits would be scheduled and completed by the end
of June. The remainder of internship would be allocated to data analysis and the writing/revising of
the P2 plan.
Table 1: Site Visit Itinerary
Facility
Point of Contact
Date/Time of Site Visit
Manchester OMS #4
CW2 Michael Tkacz
Tuesday June 10, 8:30am
State Maintenance Shop
Mr. Joe Sampson
Thursday June 12, 8:30am
USP&FO Warehouse
1SG Kevin Reynolds
Monday June 16, 9:00am
Littleton OMS #2
SSG Randy Dockham
Wednesday June 18, 10:00am
AASF
SGT Roger Prive
Thursday June 19, 8:30am
Hillsboro OMS #5
SFC Dennis MacKenzie
Friday June 20, 9:00am
CSMS and CSMS
Annex (OMS #1)
CW4 Tom LaPierre
Tuesday June 24, 8:30am
NHNGTS
CW2 George Spaulding
Wednesday June 25, 9:00am
Somersworth OMS #3
MSG Mike Dignard
Monday June 30, 8:30am
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In order to ensure that site visits would run as smoothly and as efficiently as possible, a site visit
checklist was developed and E-mailed to the contact person of each facility. The checklist included
all documentation we wanted to acquire as well as the equipment/processes we wanted to view and
evaluate. In addition to E-mailing this checklist to the facilities, a copy of the checklist was brought
to each visit to serve as a reminder of what needed to be accomplished. A copy of the site visit
checklist can be found in the Appendices.
ii.) Data Collection and Analysis
Data was collected primarily through site visits and phone calls/E-mails. All people who were
contacted over the course of this internship have been referenced in a list of contacts. In addition,
other previously drafted plans were utilized as well. Examples of such plans include Air Emissions
Inventories, Integrated Contingency Plans, Energy Audits, etc.
Attempts were made to collect data dating back to the baseline years developed for the goals
established by the EOs. For the most part these efforts were made in vain. Typically the oldest data
that could be acquired was for FY 2000, which consequently restricted data analysis to a mere 3
years at most.
Data analysis consisted of the creation of Excel spreadsheets and charts corresponding to the
specific chapters addressed in the outline of the P2 plan (i.e. hazardous/universal waste, solid waste,
air emission, etc.). These spreadsheets and charts were utilized to analyze trends and develop
appropriate goals for NHARNG based on their personal progress in regards to federal requirements.
iii.) Writing the P2 Plan
The P2 plan was written jointly by Michael O’Connor and me. Essentially the plan was written
chapter by chapter as separate documents and merged into one final document upon completion of
all 14 chapters. Responsibility for researching and writing specific chapters were divided equally
between us. In particular, I focused on the following chapters: P2 Regulatory Background, Solid
Waste, Air Emissions, Ozone Depleting Substances, and Vehicle Fuel Conservation.
B.) Antifreeze Recycling Program
i.) Baseline Development and Current Recycling Procedures
Waste manifests from FY 2002 were analyzed to determine a baseline quantity for the approximate
amount of antifreeze used by NHARNG and to investigate the costs associated with the current
antifreeze recycling procedures through the DRMO. Results of the analysis are given in the
following table which details the location, condition (recycled vs. contaminated), quantity (lbs), and
processing cost ($1.30/lb recycled, $1.08/lb contaminated) of the manifested waste antifreeze.
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Table 2: FY 2002 Waste Antifreeze Data
Location
Condition Quantity (lbs) Cost
Somersworth
recycled
432
$561.60
Concord
contaminated
895
$966.60
Manchester contaminated
1646
$1,777.68
Littleton
recycled
1010
$2,139.80
Concord
recycled
477
$1,313.00
Concord
contaminated
143
$154.44
Subtotals:
Recycled
1919
$4,014.40
Contaminated
2684
$2,898.72
TOTAL
4603
$6,913.12
Based on the data given in the table above and the approximation that 1 gallon of antifreeze weighs
9lbs, a baseline of 550 gallons of antifreeze used/disposed of per year was developed. This baseline
was used to analyze and compare the annual costs associated with alternative antifreeze recycling
programs. This baseline was purposefully over-estimated such that cost analyses would project
maximum annual costs or, in other words, the “worst-case-scenario.”
ii.) Investigation of On-Site Recycling Opportunities
Investigation of on-site recycling opportunities began with a trip to the CSMS to view antifreeze
recycling machine, the BG Cool’r Clean’r, currently owned by NHARNG. We questioned several
mechanics in the CSMS about the potential of using the machine again. In general, we received a
negative response. The only positive response received was from an interview with MSG Jim
Muhnisky, the man who previously operated the machine before being transferred to a new job
outside the CSMS.
Following the CSMS visit and interview, the BG Cool’r Clean’r company was contacted to receive
information regarding specific procedures for operating the machine and any new product
information and pricing.
iii.) Investigation of Off-Site Recycling Opportunities
Investigation of off-site recycling opportunities was already being conducted prior to this internship.
Mrs. Muriel Lajoie, the NHARNG’s Hazardous Waste Manager began researching and contacting
off-site recycling companies. These responsibilities were transferred to us upon the beginning of
our internship.
The primary opportunity that Muriel was investigating was Advanced Liquid Recycling Inc. She
had only made the initial phone contact with the company. We took the next step and set up a
meeting with a representative of the company to inquire about the details and costs associated with
their services.
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iv.) Antifreeze Recycling Presentation
An antifreeze power point presentation including technical and economic evaluations of both onsite and off-site recycling opportunities was developed and presented on July 8th, 2003. The
presentation was given to environmental office staff, CSMS staff, and other SMR personnel with
the intent of emphasizing the need for an alternative antifreeze recycling program. Overall,
feedback indicated that there was indeed interest in perusing an alterative. However, no final
decisions regarding the recycling program chosen for implementation were made, or have been
made since.
v.) New Off-Site Recycling Opportunity
An off-site recycling opportunity with Antifreeze of New England, which was initially deemed
unfeasible due to inadequate payment options, was recently brought back the circle of potential
recycling opportunities. Through E-mail correspondence with USP&FO staff member Spencer
Wilber, it was determined that a payment method could be arranged to suite NHARNG’s needs.
C.) Paper Recycling Program
i.) Previous Paper Recycling Program and Baseline Development
In order to facilitate the implementation of a new successful paper recycling program, it was
essential to understand the problems associated with the original program and to emphasize the
need for such a program through the development of a baseline and goals.
The previous paper recycling program was established by SFC Richard Laflamme through a nonprofit organization called Tobey School. SFC Laflamme purchased recycling bins and Tobey
School provided large recycling totes for the buildings on the SMR. Tobey School would empty the
totes both on a set schedule or an as needed basis. The program functioned as expected for a short
period of time and then gradually began to deteriorate due to lack of participation. Tobey School
eventually terminated their relationship with NHARNG when totes were not adequately filled on a
bi-weekly basis. The primary problem associated with the original paper recycling program was a
combination of inadequate enforcement and awareness which resulted in a lack of participation.
A baseline for the amount of waste paper generated by NHARNG annually was developed
according to testimonials regarding the results of the original program. During the initial success of
the original recycling program approximately 11 totes were filled and emptied bi-weekly.
Assuming that the totes weighed an average of 200lbs each, NHARNG could potentially generate
an estimated 52,800lbs of waste paper annually.
ii.) Investigation of Potential Recycling Opportunities
Extensive online research was conducted in search of paper recycling opportunities that could meet
the needs of NHARNG. Unfortunately, since NHARNG is a relatively small establishment, its
waste paper generation isn’t significant enough to utilize many of the opportunities that were
researched online. For this reason the majority of the opportunities were not pursued beyond the
initial internet research stage.
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INSTITUTION RECYCLING NETWORK
The only opportunity which was extensively researched was with Institution Recycling Network
(IRN). A meeting was scheduled with Mr. Mark Lennon, a representative from IRN on July 9th,
2003. In addition to Mr. Lennon, Mike and I, this meeting was attended by SFC Richard Laflamme
and a representative from the USP&FO. It was determined from this meeting that IRN could not
provide a cost effective recycling program and it was suggested that NHARNG re-establish
relations with Tobey School, which is now in partnership with Revamp Inc.
TOBEY SCHOOL/REVAMP INC.
Ms. Wanda Kula, a representative from Revamp Inc. was contacted via SFC Richard Laflamme. A
short visit to the Tobey School/Revamp facility was conducted and the feasibility of re-establishing
the paper recycling program was discussed. To summarize, Tobey School/Revamp was willing to
service the SMR provided that participation on behalf of NHARNG was guaranteed.
iii.) Development of Awareness Poster and Presentation
In order to increase the participation of NHARNG Mike created an awareness presentation and
poster. Prospectively, an awareness presentation will be given prior to the re-implementation of the
recycling program. The posters will be utilized during the initial implementation to ensure that
paper is sorted appropriately. A copy of the awareness poster is given in the Appendices.
D.) Authorized Use List
Development and implementation of the Authorized Use List has not yet begun. Potentially this
project will be one of the major focuses of this internship, should it be extended through the fall.
The following steps outline the proposed approach that may be taken to develop and implement the
Authorized Use List:

Analysis of hazardous waste laboratory test results to determine what chemicals are
contaminating NHARNG’s waste streams

Analysis of NHARNG’s hazardous material inventory to determine what products contain
the chemicals identified to be contaminants of NHARNG’s waste streams

Research of environmentally friendly alternatives to the targeted products

Identification of what products are required to be used by mechanics due to military
specifications and/or operating manuals and are not subject for replacement

Meet with shop chiefs/mechanics to develop a list of products that may be purchased/used
that will satisfy both shop chiefs/mechanics as well as the Environmental Office Staff.
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V.) CHEMICAL USAGE
NHARNG’s Hazardous Material Inventory is reflective of the products typically used on a routine
basis by NHARNG maintenance shops. Analysis of these products would reveal their specific
ingredient composion, which would be representative of the chemicals used by NHARNG.
Although this analysis has not yet been conducted, it will potentially be one of the initial steps of
the development and implementation of the Authorized Use List. A copy of NHARNG’s
Hazardous Material Inventory is given below.
The following inventory includes all products kept in flammable storage cabinets in NHARNG
facilities addressed in the scope of the P2 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. The products are listed in ascending order according to National Stock Number (NSN).
Table 3: NHARNG Hazardous Material Inventory
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
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
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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
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
Page 16
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
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
Summer 2003
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
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
Enamel Olive Drab
8120-00-268-3360
Enamel Alkyd Gloss Lo Voc Blue
8520-00-228-0598
Enamel, Brown
9150-00-145-0268
Enamel Alkyd Gloss Lo Voc Black
9150-00-181-7724
Enamel, Red Gloss
9150-00-190-0918
Enamel, Lacquer, Flat Black
9150-00-231-6689
Enamel Flat White
9150-00-231-9071
Enamel Alkyd Lo Voc Brown
9150-00-234-5197
Enamel Alkyd Lo Voc Brown
9150-00-257-5370
Enamel Alkyd Lo Voc Green
9150-00-273-2389
Enamel Olive Drab
9150-00-458-0075
Lacquer Spray Green
9150-00-657-4959
Enamel, Black
9150-00-698-2382
Primer Coating, Light Gray
9150-00-753-4667
Enamel Spray Orange
9150-00-823-7860
Enamel Spray Red Gloss
9150-00-935-5851
Enamel, Yellow
9150-00-935-9807
Enamel, Olive Drab
9150-00-935-9809
Enamel Spray
9150-00-944-8953
Enamel, Yellow
9150-00-999-7548
Lacquer Spray Paint
9150-01-007-4384
Enamel Alkyd Lo Voc Green
9150-01-015-1542
Enamel Alkyd, Yellow
9150-01-035-5393
Enamel Spray
9150-01-053-6688
Sealing Compound
9150-01-054-6453
Sealing Compound
9150-01-079-6124
Sealing Compound
9150-01-102-9455
Antiseize Compound
9150-01-126-4459
Coating Compound,Plastisol
9150-01-177-3988
Sealing Compound
9150-01-178-4725
Sealing Compound
9150-01-197-7692
Sealing Compound
9150-01-197-7693
Coating Compound,Bituminous,Solvent9150-01-198-3829
Sealing Compound
9150-01-260-2534
Corrosion Preventive Compound
9150-01-310-5762
Sealing Compound
9150-01-351-9019
Preservative Coating,Canvas
9150-01-353-4799
Antiseize Compound
9150-01-421-1427
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
Shelly Dougherty
Page 17
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
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
Summer 2003
VI.) RELEASES/WASTES GENERATED
A.) Hazardous Waste Streams
Waste streams are hazardous when contaminated with heavy metals or regulated chemicals. The
following chart shows the quantity and percentage of NHARNG’s hazardous waste streams
contaminated by lead, other heavy metals, and other regulated chemicals found in solvents.
Metal
Contamination
7,923 lbs
31%
Other
Contamination
16,594 lbs
66%
Lead Contamination
816 lbs
3%
Lead Contamination
Other Metal Contamination
Other Contamination
Figure 1: Hazardous Waste Contamination
The following list details the primary hazardous waste streams generated by the NHARNG:
CONTAMINATED USED OIL
Used oil that tests hot for dissolved metals and/or certain chemicals found in solvents is considered
contaminated and cannot be burned for energy recovery. Rather, it must be disposed of as a
hazardous waste.
CONTAMINATED USED ANTIFREEZE
Antifreeze that tests hot for dissolved metals, other automotive fluids/oils, and/or certain chemicals
found in solvents is considered contaminated and cannot be recycled through the DRMO. Rather it
must be disposed of as a hazardous waste.
Shelly Dougherty
Page 18
Summer 2003
OIL-WATER SEPARATOR SLUDGE
Oil-water separator sludge is the sludge that is separated from wastewater before the wastewater is
released into the water system. This sludge is composed of oils that are not miscible in water.
PARTS-WASHER SLUDGE
Parts-washer sludge is the sludge from inside the aqueous parts washer which could be
contaminated with dissolved metals, automotive fluids, and/or chemicals from solvents.
BATTERIES
900
272 lbs
800
185 lbs
240 lbs
700
Weight (lbs)
600
303 lbs
500
400
15 lbs
346 lbs
460 lbs
274 lbs
300
354 lbs
200
176 lbs
100
0
9
5 lbs
lbs
0 lbs
61 lbs
62 lbs
0
348 lbs
243 lbs
mercury
potassium
hydroxide
lithium
lead-acid
0
0
272
185
240
9
61
303
460
346
5
62
354
243
348
magnesium
nicad
2002
15
2001
274
2000
176
Battery Type
Figure 2: Type and Quantity of Batteries Disposed
B.) Energy Recovery Streams
Some materials are exempt from being a regulated waste but are not considered a recycled material
because they are burned for energy recovery. The NHARNG employs a used oil burner in the
Manchester OMS. Approximately 700-1,400 gallons per year are diverted from the waste stream
for energy recovery.
Shelly Dougherty
Page 19
Summer 2003
C.) Solid Waste Streams
i.) Recycled Solid Waste Streams
Recycled solid waste streams “include all non-hazardous waste as defined by the Environmental
Protection Agency (EPA) in the Solid Waste Disposal Act or by NH’s regulations that were
recycled or composted, on-site or off-site, or otherwise diverted from incineration, energy recovery,
or a landfill. NHARNG currently recycles scrap metal, used antifreeze, used shop rags, and spent
lead-acid batteries. Following are descriptions of each of the recycled solid waste streams.
SCRAP METAL
An estimated 30,000lbs of scrap metal is generated annually by NHARNG and transported to the
USP&FO Warehouse to be recycled. Currently NHARNG is receiving money for the scrap metal
that is recycled. All money that is acquired through the recycling program is added to a fund site
dedicated to the health and welfare of the troops as well as pollution prevention equipment.
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 by the DRMS to New York for recycle to be used for
rubberized highway asphalt. Although the tires are currently being recycled, ideally a more local
program would be beneficial to both NHARNG and the state of New Hampshire.
USED ANTIFREEZE
According to waste manifests, approximately 1919 lbs of used antifreeze is generated and recycled
through DRMO per year. Please refer to the Hazardous and Universal Waste chapter for additional
information regarding antifreeze and alternative recycling opportunities.
USED SHOP RAGS
A shop rags laundering service provided by Alltex is used to eliminate a potential hazardous waste
stream. Instead of one-time-use cloth rags and paper towels, the laundering service delivers clean
rags to the shops and removes soiled rags. They are then cleaned by the company and returned for
reuse. Information regarding the quantity of shop rags laundered per year is not available.
SPENT LEAD-ACID BATTERIES
Spent lead-acid batteries are recycled through a one for one exchange program with Exide. Specific
information regarding the quantity of batteries exchanged with Exide is not available.
ii.) Non-Recycled Solid Waste Streams
Non-recycled solid waste streams include all non-hazardous waste that is disposed of either by
incineration, energy recovery, or landfill. Currently NHARNG’s non-recycled solid waste streams
Shelly Dougherty
Page 20
Summer 2003
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.
OFFICE PAPER
Approximately 52,800lbs of office paper is generated annually by the SMR. This estimate is based
upon a previous paper recycling program in which 11 totes, located in the various buildings across
the SMR, were filled and emptied bi-weekly. Each tote was capable of holding 95 gallons, which
weighed approximately 200lbs when full. Previous paper recycling programs were not successful
do the lack of awareness and participation on behalf of the SMR staff. Potentially a new paper
recycling program will be established.
“REGULAR” GARBAGE
For the purpose of this plan “regular” garbage is defined as any form of solid waste not previously
mentioned that is disposed of in dumpsters. This may include but is not limited to packaging
scraps, food wrappers, plastic bottles, and aluminum cans. An estimated 31,440lbs of “regular”
garbage is generated and disposed of in dumpsters maintained through dumpster contracts funded
by the State side of NHARNG. The facilities involved in solid waste management through the
dumpster contracts include the SMR, NHNG-TS, OMS #3 and OMS #4. An estimated 9,600lbs of
“regular” garbage is generated at the SMR alone. These estimates are based upon the evaluation of
solid waste found in both trash cans and dumpsters at the SMR and information obtained from
dumpster contracts.
Shelly Dougherty
Page 21
Summer 2003
Table 4: Criteria for "Regular" Garbage Estimates from Dumpster Contracts
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 which weighed 6.5lbs.
**The 84,240lbs estimate includes paper, as paper is not currently being recycling and was thus
found in garbage bins and dumpsters across the SMR.
SPENT BATTERIES
As determined from waste manifests an average of 1,118 lbs of spent batteries are generated per
year. Spent batteries include all types of batteries with the exclusion of the lead-acid batteries that
are exchanged with Exide. Some such types include magnesium, potassium hydroxide, mercury,
and lithium batteries.
NON-REGULATED WASTE
As determined from waste manifests, an average of 5,511lbs of non-regulated solid waste is
generated per year. Non-regulated solid waste includes all non-hazardous wastes recorded on waste
manifests with the exclusion of spent batteries. This includes such wastes as spill cleanup residue,
asbestos, wash water, and aerosol can residue.
Shelly Dougherty
Page 22
Summer 2003
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 3: Solid Waste Streams
D.) Air Emissions
All air emissions information is based on an Air Emission Inventory conducted in April 2002. The
scope of this inventory included only Manchester and Concord NHARNG facilities. Following are
descriptions of the air emission sources discussed in the inventory.
DISTILLATE OIL BOILERS
There are two dual-fired boilers located in the Manchester and four dual-fired boilers and two oilfired boilers located in Concord. The dual-fired boilers burn either No. 2 (distillate) fuel oil or
natural gas while the oil-fired boilers burn only No. 2 (distillate) fuel oil.
NATURAL GAS BOILERS/HEATERS
In addition to the dual-fired boilers and oil-fire boilers, there is a natural gas-fired hot water heater
located in Manchester there are two natural gas-fired boilers, eleven natural gas heaters, and four
natural gas hot water heaters located in Concord.
Shelly Dougherty
Page 23
Summer 2003
STATIONARY INTERNAL COMBUSTION ENGINES
Manchester only has one steam cleaner which is used occasionally to clean the floors of the OMS.
Concord on the other hand has several stationary internal combustion engines which include an
emergency generator at the AASF, a steam cleaner, an auxiliary ground powering unit, 5 helicopter
heaters and a power washer.
WELDING OPERATIONS
Welding is performed on a periodic basis for repairing metal parts in both Manchester and Concord.
Electric arc welding, metal inert gas (MIG) welding, tungsten inert gas (TIG) welding and oxygenacetylene welding are performed using a variety of welding rods. In addition, oxygen-acetylene
cutting and soldering are performed in Concord
WASTE OIL BOILER
Manchester has a used oil burner that is used to provide heat to the OMS building. This burner
typically burns either used motor oil or used diesel fuel that is generated by the various OMSs
throughout the state.
VEHICLE EXHAUST
The Manchester OMS and Concord CSMS and Annex are equipped with vehicle exhaust hoses that
are placed on the tailpipes of the trucks to vent the exhaust fumes outside. In this case, these
vehicles are acting as stationary sources. This emission category does not include the emissions
from vehicles driving around the complex (mobile sources).
PAINTS AND SOLVENTS
Small painting operations occur throughout the Manchester and Concord NHARNG installations
and typically include “spot” painting or touch-up operations, using aerosol spray cans, and/or brush
painting. Solvents such as methanol and alcohols and spray cans containing other solvents are used
as well. In addition, the Concord CSMS has a paint spray booth that is currently not being used do
to ventilation deficiencies.
TANKS AND FUELING
Manchester has a 300 gallon used oil storage tank that is used in conjunction with the used oil
burner and Concord has several aboveground fuel oil storage tanks in various locations reservation.
Shelly Dougherty
Page 24
Summer 2003
Table 5: Types and Sources of Air Emissions (tpy)
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
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
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 4: Air Emissions Sources
Shelly Dougherty
Page 25
Summer 2003
VII.) PROJECT RESULTS
Essentially the primary and most important result of this internship was the development of the P2
plan. Although the final draft of the P2 plan has not yet been completed, a copy of the rough draft
can be found in the Appendices.
A.) Antifreeze Recycling Program Results
Although a particular antifreeze recycling program has not yet been chosen for implementation, it
has been agreed upon by environmental office staff and shop chiefs alike that an antifreeze
recycling program must be developed and implemented as an alternative to recycling through the
DRMO for economic reasons.
i.) Current Antifreeze Recycling through DRMO
Recycling antifreeze through the DRMO costs NHARNG exorbitant amounts of money. The
following rates are associated with the DRMO antifreeze recycling program:

$4.37/gallon to purchase new antifreeze through the military system

$12.14/gallon to recycle used antifreeze through the DRMO

$10.08/gallon to dispose of contaminated antifreeze not acceptable for recycle
Using 550 gallons (10 drums) as a basis for the amount of antifreeze used per year and the
approximation that 58% of the used antifreeze will be contaminated1 and consequently not accepted
by the DRMO for recycle the total annual cost and cost per gallon of purchasing and
recycling/disposing of antifreeze were determined.
Total Annual Cost: $8,423.36
Average antifreeze cost: $15.32/gallon
Both on-site and off-site antifreeze recycling programs that were investigated proved to be highly
cost effective in comparison to the current costs associated with DRMO recycling. The following
sections discuss the results of the technical and economic evaluations of both the on-site and off-site
antifreeze recycling programs.
ii.) On-site Antifreeze Recycling
TECHNICAL EVALUATION:
Antifreeze would be recycled using the BG Cool’r Clean’r Coolant Purification System, which
already owned by NHARNG. A picture of this machine can be found in the Appendices. The
recycling process begins with a settling step, in which the coolant settles for a period of time. This
1
Approximations are based on FY 2002 waste manifests.
Shelly Dougherty
Page 26
Summer 2003
allows most of the oil to settle to the surface of the coolant and be removed with oil absorbing pads.
This step is a modification to the manufacturer’s process that extends the life of the filters and resin.
The spent coolant is then filtered by a 15 micron, a 1 micron, and an activated charcoal filter. Two
tanks of resin are then utilized to further purify the coolant. One tank targets cations, while the
other targets anions. This removes dissolved metals or other charged material from the solution. A
two part corrosion inhibitor is then added, as well as a KOH (potassium hydroxide) buffer solution
to stabilize the pH. The freezing point is then tested using a refractometer, and new ethylene glycol
(antifreeze) is added to lower the freezing point to the desired temperature. The following is a
material flow diagram for the recycling process described above.
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 5: On-Site Antifreeze Recycling Process, Material Flow Diagram
As depicted in the material flow diagram above, the raw material inputs of this process include oil
absorbent pads, filters, cation and anion resin, KOH buffer, inhibitor, and concentrated antifreeze.
The wastes generated by this process include used oil absorbent pads, used filters, resin for
regeneration, and unrecoverable antifreeze. The 15 and 1 micron filters can be dealt with in the
same manner as regular oil filters, hot drained, crushed, and recycled for scrap metal. The used oil
absorbent pads, charcoal filter, and unrecoverable antifreeze, which accounts for approximately
10% of the spent antifreeze fed into the process according to machine specification, must be
disposed of as hazardous waste. The tanks of resin are regenerated by an approved facility.
Currently, the closest facility approved by the manufacturer is in Maryland.
Shelly Dougherty
Page 27
Summer 2003
The major problem associated with this process is the accumulation of surplus recycled antifreeze,
which was the cause of termination of the previous on-site antifreeze recycling program. The
surplus is cause by the addition of concentrated antifreeze to lower the freezing point of the
recycled antifreeze. The amount of surplus generated varies depending upon the quality of the
spent antifreeze being recycled.
Shelly Dougherty
Page 28
Summer 2003
ECONOMIC EVALUATION:
Table 6: On-Site Cost Analysis
IMPLEMENTATION COSTS:
refractometer
training (8 hours for shop worker)
training from company
TOTAL:
$186.75
$200.00
$1,000.00
$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
20 Micron Filters
Charcoal Filter Cartridges
$11.55
$10.00
$28.05
Subtotal:
2
2
2
6
$23.10
$20.00
$56.10
$99.20
Labor:
Filter changes (2 per year)
Resin Regeneration
Operation (based on 180gal/hr machine rate)
Subtotal:
2 hr
1 hr
4 hr
7 hr
$25/hr
$25/hr
$25/hr
$50.00
$25.00
$100.00
$175.00
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)
Subtotal:
6 hr
3.5 hr
4 hr
4.5 hr
18 hr
$25/hr
$25/hr
$25/hr
$25/hr
$150.00
$87.50
$100.00
$112.50
$450.00
Waste Disposal:
Used Filters (charcoal only)
Oil Absorbant Pads (negligible contribution to waste)
Subtotal:
TOTAL:
2
$25.00
$25.00
$2,798.20
-
RECURRING ANNUAL SAVINGS
per gallon
Current Annual Costs
$15.91
Potential Annual Costs
$5.09
ANTICIPATED SAVINGS:
$10.82
per year
$8,423.26
$2,798.20
$5,625.06
iii.) Off-site Antifreeze Recycling
Investigation of off-site antifreeze recycling opportunities focused primarily on one company,
Advanced Liquid Recycling, Inc. Initially, all other potential companies were not able to meet the
Shelly Dougherty
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Summer 2003
needs and/or requirements set for by NHARNG. However, new information regarding an antifreeze
recycling partnership between Antifreeze Recycling of New England (ARNE) and New England
Environmental Services (NEES) has proven to meet NHARNGs payment requirements, which had
previously been the issue. Technical and economic evaluations of these off-site antifreeze recycling
opportunities are discussed below.
iv.) Advanced Liquid Recycling, Inc.
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
Troy, IN
Meriden, CT
and Consolidated Recycling is the end destination of
the antifreeze and the site where the actual recycling
occurs. The diagram to the right illustrates the
Figure 6: Off-Site Recycling "Cradle-to-Grave" Trail
“cradle-to-grave” trail.
Although this recycling program utilizes three separate companies, NHARNG would only interact
with ALR. Utilizing this program NHARNG would have two options:
1) purchase a premixed 50/50 blend of antifreeze from ALR and have equal amount taken for
recycle at no additional cost
2) purchase concentrated antifreeze from ALR and have equal amount taken for recycle at no
additional cost
Antifreeze that is already a 50/50 blend of ethylene glycol and water is ready to use without any
mixing and would therefore be purchased more frequently than concentrate. Concentrated
antifreeze would only be purchased occasionally according to specific need (i.e. - if a few vehicles
need a more concentrated solution of antifreeze nearing the winter months).
In order for this recycling program to be utilized it would be necessary for NHARNG to have the
National Guard Bureau (NGB) approve a waiver to use an alternative to the DRMO. Approval of a
waiver requires audit information for all companies handling the NHARNG’s antifreeze. So far
audit information has been received, however we’re still awaiting an environmental package from
Consolidated Recycling Co. Inc which will contain specific information regarding their recycling
procedures as well as permits and other documentation required to ensure compliance. In terms of
their recycling procedures it is known that they recycle the antifreeze using a multi-stage system,
and the steps employed in this system are:

Oil/Antifreeze Chemical Separation

Atmospheric Water Distillation\
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Summer 2003

Water/Ethylene Glycol Vacuum Distillation

Ethylene Glycol Concentrate Distillation

Ethylene Glycol Bottoms Evaporator

Salts Recovery and Re-Use System2
ECONOMIC EVALUATION:
The cost of off-site recycling with ALR offers an even larger savings over the current method than
on-site recycling. Based on the approximation of 10 drums of antifreeze used per year, the
following cost analysis has been developed for ALR’s antifreeze recycling program:
Table 7: ALR Off-site Cost Analysis
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).
v.) ARNE and NEES Partnership
TECHNICAL EVALUATION
ARNE of Warner, NH works in conjunction with NEES of Smithfield, RI. ARNE functions as the
transporter of the antifreeze, while NEES performs the actual recycling process. Initially in-depth
research of this partnership was placed on hold due to the fact that ARNE does not accept credit
cards, which is the only payment method acceptable for NHARNG to use based on the anticipated
volume of antifreeze. However, recent information has yielded a compromise which will allow for
this partnership to be utilized. The process will work as follows:
2

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
List taken from Consolidated Recycling’s website: http://www.chem-group.com/consolidated.html
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Summer 2003

NEES will process the payments3
Again, in order for this recycling program to be utilized it would be necessary for NHARNG to
have the NGB approve a waiver to use this alternative to the DRMO. This does not pose any
potential problems as NEES currently hold contracts with both RI and CT National Guards and has
forwarded NHARNG copies of information regarding their business with them.
A “cradle-to-grave” diagram illustrating NEES’s recycling process was provided in their company’s
brochure and can be summarized by the following steps:
1) Antifreeze is collected and transported in Department of Transportation (DOT) approved
drums and totes
2) Antifreeze is remanufactured to O.E.M specifications and blended with Penray inhibitor
3) 50/50 premixed antifreeze is produced to service all fleets (Standard Green, Long Life, Red,
and Heavy Duty)
ECONOMIC EVALUATION
Although off-site antifreeze recycling with ALR has already proven to be more cost effective than
both the current recycling program through the DRMO and an on-site recycling program, ARNE
has been found to provide the most cost effective recycling program.
ARNE will swap recycled antifreeze for waste antifreeze drum for drum for a total cost of $121.00
per drum. Based on the approximation of 10 drums of antifreeze used per year:
Total Annual Costs: $1,210
Average Antifreeze Cost: $2.20/gallon
In comparison with the current antifreeze recycling program through the DRMO, implementation of
ARNE’s off-site antifreeze recycling program offers a potential recurring cost savings of
approximately $7200.00 per year and an average cost savings of $13.12 per gallon.
vi.) Economic Analysis Summary
Based upon the economic analysis of both the potential on-site and off-site recycling programs, it is
clear that an alternative to the DRMO antifreeze recycling program must be implemented.
Implementing an alternative program could save the NHARNG as much as $7,200.00 per year and
$13.12 per gallon of antifreeze (considering both purchasing and recycling) depending upon which
alternative program is chosen for implementation. The following charts illustrate the annual costs
and savings of the on-site and off-site recycling programs in comparison with the current recycling
program through the DRMO.
3
Wilber, Spencer. E-mail correspondence regarding Antifreeze Recycling, Friday, August 01, 2003
Shelly Dougherty
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Summer 2003
$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 7: Antifreeze Annual Cost/Savings Comparison
$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 8: Antifreeze Average Cost/Savings per Gallon Comparison
B.) Paper Recycling Programs Results
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
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Summer 2003
informative posters 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 being is a phone call to Tobey School/Revamp. Totes will then be delivered, and paper
will be recycled.
TECHNICAL EVALUATION
An estimated 52,800 lbs of waste paper is generated annually and disposed of in the same manner
are “regular” garbage (i.e. in dumpsters and transported to landfills or incinerators). Based on this
estimate, recycling waste paper could potentially increase the percentage of solid waste diverted to
recycle from 43% to 71%, which would place NHARNG far above the present goal required by the
DoD. The potential impact of paper recycling is illustrated by the following chart.
Non-recycled
Streams
53,669 lbs
29%
Other Recycled
Streams
79,519 lbs
43%
Total Recycled
Streams
132,319 lbs
71%
Recycled
Paper
52,800 lbs
28%
Figure 9: Potential Impact of Paper Recycling
In order for this program to be successful absolute participation is required of all staff members
working at the SMR. Participation is as simple as separating used paper into three categories, white
office paper and envelopes, mixed colored paper and envelopes, and newspaper and magazines, and
consciously placing it in the appropriate recycling bins. Different colored bins will be used to
indicate the appropriate type of paper to be place in that particular colored bin. In addition to small
recycling bins, large recycling totes will utilized to collect the recycled paper from all the small
recycling bins when they become full and must be emptied.
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Summer 2003
The distribution of large recycling totes in the various buildings on the SMR is given in the
following table.
Table 8: Distribution of Recycling Bins
Building
Number
of Totes
Size
(gal)
Building
Number
of Totes
Size
(gal)
USP&FO
1
75
Building B
1
75
Counterdrug 1
75
CSMS
Annex
1
20
Building C
1
75
CSMS
1
75
Building T
4
95
AASF
1
20
Building 57
2
95
USP&FO
2
Warehouse
95
Building F
1
95
Armory
95
1
ECONOMIC EVALUATION
Currently Tobey School/Revamp provides all the necessary large totes as well as their recycling
services free of charge. All the small totes required to re-establish this program were purchased
when paper recycling was previously implemented.
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
VIII.) FUTURE RECOMMENDATIONS
The recommendations that I would make for NHARNG arise directly from the difficulties
encountered throughout the course of this internship. The most challenging aspect of writing the P2
Shelly Dougherty
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Summer 2003
plan for the NHARNG was collecting data, specifically quantities. Attempting to collect data was
frustrating and often unrewarding, like not finding a pot of gold at the end of a rainbow. NHARNG
records were very difficult and sometimes impossible to attain. Often direct contact to NHARNG
contractors was the only affective means to acquire the necessary data. For instance, when
researching the non-tactical fuel usage, NHARNG did not have any traceable internal records
regarding the amount of fuel used or even the cost. GSA had to be directly contacted to ascertain
this information. In situations where there were no records at all, very crude approximations were
necessary to quantify certain waste streams, such as the amount of “regular” garbage generated
annually.
In regards to these difficulties, my primary recommendation for NHARNG is to establish a set of
procedures to ensure that records of the waste streams addressed in the P2 plan are kept up to date.
This will enable NHARNG to recognize trends in their environmental practices and establish the
necessary P2 programs to achieve their goals.
I would imagine that the future development of an Environmental Management System (EMS) will
facilitate NHARNG’s endeavors. In conclusion, it is my hope that the P2 plan developed as a
result of this internship will become a “living” document that is continuously referenced, updated,
and allowed to grow as NHARNG improves their environmental practices through pollution
prevention.
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Summer 2003
IX.) LIST OF CONTACTS
Eileen Chabot
State Environmental Specialist
NHARNG – Environmental Office
57 Regional Drive
Concord, NH 03301
Phone: 603-225-1211
e-mail: eileen.chabot@nh.ngb.army.mil
Re: Supervisor, office check-in, point of contact
MSG Richard LaFlamme
Environmental Protection Specialist
NHARNG – Environmental Office
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
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
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, hazardous waste info
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
SPC Stephanie Roberts
NHARNG-HQ
SMR Building F - DCISM
Concord, NH 03301
603-228-1135 x1500
stephanie.roberts@nh.ngb.army.mil
Re: ID cards
Shelly Dougherty
SPC Matthew Dupuis
NHARNG – USPFO
State Military Reservation
DOIM
603-225-1385
matthew.dupuis@nh.ngb.army.mil
Re: Computer logon, e-mail capabilities
SGT Roger Prive
NHARNG
603-225-1290
robert.prive@nh.ngb.army.mil
Re: AASF site contact
Ms. Karen Hallenborg
NHARNG – Supply
603-225-1358
karen.hallenborg@nh.ngb.army.mil
Re: State Maintenance Shop Site Contact
1SG Kevin Reynolds
NHARNG – USPFO Warehouse
603-225-1216
kevin.reynolds@nh.ngb.army.mil
Re: USPFO Warehouse Site Contact
SSG Randy Dockham
NHARNG – OMS #2
Littleton, NH
603-444-2387
randy.dockham@nh.ngb.army.mil
Re: OMS #2 Site Contact
MSG Mike Dignard
NHARNG – OMS #3
Somersworth, NH
603-692-4693
michael.dignard@nh.ngb.army.mil
Re: OMS #3 Site Contact
CW2 Michael Tkacz
NHARNG – OMS #4
Manchester, NH
603-627-6299
michael.tkacz@nh.ngb.army.mil
Re: OMS #4 Site Contact
SFC Dennis MacKenzie
NHARNG – OMS #5
Hillsboro, NH
603-464-0226
dennis.mackenzie@nh.ngb.army.mil
Re: OMS #5 Site Contact
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Summer 2003
CW2 George Spaulding
NHARNG – NHNGTS Mgr
Center Strafford, NH
603-225-1353
george.spaulding@nh.ngb.army.mil
Re: NHARNG Training Site Contact
SFC Spence Wilber
NHARNG – USPFO
Concord, NH
603-225-1359
spencer.wilber@nh.ngb.army.mil
Re: Affirmative Procurement
MSG Jim Muhnisky
Joint Operation
SMR – Concord, NH
(603) 227-1533
jimmy.muhnisky@nh.ngb.army.mil
Dave Nylund
Air National Guard – Environmental Manager
Portsmouth, NH
(603) 430-2366
david.nylund@nhpeas.ang.af.mil
Re: Antifreeze Recycling
Colleen Schwalbe
P2 Specialist – NHDES
Concord, NH 03301
(603) 271-0878
Re: Contaminated Antifreeze
Tom Phenix
Advanced Liquid Recycling, Inc.
Newington, NH
(603) 817-0591
Re: Off-Site Antifreeze Recycling
Ken Herman
KFM Corporation
Anderson, SC 29621
ken@kfmllc.com
Re: On-Site Antifreeze Recycling
Judy Chen
SMR – Accounting
Concord, NH 03301
(603) 225-1366
judy.chen@nh.ngb.army.mil
Re: Dumpster contract
Linda McCormack
SMR – Accounting
Concord, NH 03301
Shelly Dougherty
linda.mccormack@nh.ngb.army.mil
Re: Wastewater information
MAJ Wayne Kreiensieck
CSMS Foreman – CSMS, SMR
Concord, NH 03301
(603) 228-1135 x1297
wayne.kreiensieck@nh.ngb.army.mil
Re: CSMS Site Visit
CW4 Thomas LaPierre
CSMS – SMR
Concord, NH 03301
(603) 228-1135 x1312
Thomas.lapierre@nh.ngb.army.mil
Re: CSMS Site Visit
SGT Brian McKay
AASF – SMR
Concord, NH 03301
(603) 228-1135 x1290
brian.mckay@nh.ngb.army.mil
Re: AASF Site Visit
LTC Daniel Saucier
CSMS – SMR
Concord, NH 03301
(603) 228-1135 x1231
daniel.saucier@nh.ngb.army.mil
Re: Antifreeze Recycling Presentation
CW2 David Clemons
CMSM
SMR – Concord, NH
(603) 225-1392
david.clemons@nh.ngb.army.mil
SFC Wesley Rand
CSMS
SMR – Concord, NH
(603) 228-1135 x1299
weseley.rand@nh.ngb.army.mil
SFC Stephen Dyment
CSMS
SMR – Concord, NH
(603) 228-1135 x1539
stephen.dyment@nh.ngb.army.mil
Wanda Kula
Revamp, Inc.
Concord, NH
(603) 228-5211
CW5 Richard Plante
USPFO Purchasing & Contracting Office
Concord, NH
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Summer 2003
(603)228-1135
richard.plante@ngb.nh.army.mil
Mr. Duane Vallee
GSA
Hooksett, NH
(603)666-7956
Re: Non-tactical fuel usage
Tom Phoenix
Regional Representative
Advanced Liquid Recycling, Inc.
Meriden, CT
(800) 637-0917
tphoenix@unitedindustrialservices.com
Bill Green
Jim Welch
Territory Manager
W. H. Shurtleff Company
South Portland, ME
bgreen@whshurtleff.com
Mark Lennon
The Institution Recycling Network
Concord, NH
1-866-229-1962
mlennon@ir-network.com
Richard Smith
Maintenance Manager
NHNGTS
(603)228-1135, x4703
Center Strafford, NH
RE: Training Site Visit
Shelly Dougherty
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Summer 2003
X.) REFERENCES
1) Air Emissions Inventory and Air Toxics Compliance Determination: Concord and
Manchester, New Hampshire submitted by AMEC Earth & Environmental Westford,
Massachusetts April 2002.
2) Army Environmental Center, P2 Program, AP – http://aec.army.mil/usaec/p2/app00.html
3) Consolidated Recycling. http://www.chem-group.com/consolidated.html
4) Energy Audit of Army National Guard Facilities: State of New Hampshire, performed by
AMEC Lakewood, Colorado July 2003.
5) Environmental Policy, 2 April 2003. John J. Weeden BG, NHARNG Assistant Adjutant
General.
6) GSA Affirmative Procurement Program (3/18/03)
http://www.gsa.gov/Portal/offerings_content.jsp?channelID=-13905&programID=10905
7) GSA Fleet Inventory, prepared by Duane Vallee July 16, 2003
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) Johnson, Sarah. E-mail correspondence P2 Program Manager, NH DES
10) Luther, Robert. Email correspondence, NGB-ARE P2 Program Manager July 16, 2003
11) New Hampshire Army National Guard Ozone-Depleting Chemical Elimination Certification
prepared by Roy F. Weston, inc. December 2000.
12) NHARNG-FM-EV Website – Pest Management Program
13) NHARNG FY03 Strategic Plan
14) NHARNG Waste Manifests CY 2000-2003
15) Wilber, Spencer. E-mail correspondence regarding Antifreeze Recycling, Friday, August 01,
2003
16) U.S. Environmental Protection Agency, Waste Minimization: Priority Chemicals
http://www.epa.gov/epaoswer/hazwaste/minimize/chemilist.htm
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Summer 2003
XI.) APPENDICES
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Summer 2003
A.) NHARNG P2 Equipment
Figure 12: Secondary Containment Area
Figure 10: Antifreeze Recycling Machine
NHARNG owns one Antifreeze Recycling
Machine which resides at the CSMS.
Only Littleton OMS #2 and Hillsboro OMS
#5 are currently equipped with secondary
containment area for storage of their fueling
truck tanks.
Figure 13: Filter Crusher
Figure 11: Aqueous Parts Washer (inside)
All maintenance shops are equipped with
Aqueous Parts Washers.
Shelly Dougherty
All maintenance shops are equipped with
Filter Crushers, with the exception of
Hillsboro OMS #5.
Page 43
Summer 2003
Figure 14: Aerosol Can Puncturing Machine
All maintenance shops are equipped with
Aerosol Can Puncturing Machines.
Shelly Dougherty
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Summer 2003
Site: __________________
Date: _________________
Attending: _____________
_____________
_____________
B.) Site Visit Checklist
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:



When implemented
Description
Benefits
 Economic
 Environmental
Contacts:
Name:
Job Title:
Phone:
E-Mail:
Re:
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:
Shelly Dougherty
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Summer 2003
C.) Paper Recycling Awareness Poster
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