Pollution Prevention at Fort Riley
Dr. Anthony Randall, Dynamac Corporation
The Directorate of Environment and Safety at Fort Riley has established a proactive Pollution Prevention Program, whose primary goal is to develop and implement projects to reduce the amount of waste (both hazardous and nonhazardous) generated and disposed of by the installation.
The first step in achieving an effective P2 Program was to gain the support of Fort Riley's Command. This was accomplished by establishing a Pollution Prevention Policy, signed by the Chief of Staff, that identifies preventing pollution as one of Fort Riley's top environmental priorities, and commits all Fort Riley organizations to exhibit environmental leadership in their activities. The next step involved writing a Pollution Prevention Plan for Fort Riley, as required by EO 12856. The P2 Plan served to outline reduction goals and identified programs/projects that could be implemented to achieve those goals. Fort Riley is currently in the process of developing and implementing projects to ensure that the strategies developed in the P2 Plan are met.
The installation's pollution prevention, waste reduction, and solid waste goals are outlined in the Fort Riley Pollution Prevention Plan. The hazardous waste reduction goals were established in a cooperative effort between Programs and Divisions within DES.
Projects that reduce hazardous waste
DES has implemented several projects that have served to reduce the amount of hazardous waste generated at Fort Riley, including: The Vehicular Battery Consignment Program, low-mercury fluorescent lamps, antifreeze recycling, dry cleaning facility equipment modifications, the Household Hazardous Waste Program, solvent filtration, and other projects.
The Vehicular Battery Consignment Program (VBCP) . The VBCP was established to reduce the amount of waste electrolyte being generated through the use of lead-acid batteries by tactical vehicles. The past method for battery operations involved receiving the batteries "dry" (without electrolyte) and uncharged. They would then have to be filled and charged prior to being placed in service. Once the service life of the battery ended, the battery was drained of the electrolyte. The spent electrolyte was disposed as a hazardous waste and the lead case was sold to a recycler. This method resulted in large amounts of waste electrolyte being disposed of at a large cost to the installation ($28,000) with a small profit ($10,000) from the sale of the lead cases.
The VBCP utilizes a delivery of "wet" (filled with electrolyte) and charged batteries. Once the end of the serviceable life is reached, the contractor picks up the unserviceable batteries "wet" and delivers new charged batteries on a one-to-one exchange. This eliminates the disposal of waste electrolyte and allows both the lead case and spent electrolyte to be recycled by the manufacturer. This program has resulted in a direct savings of nearly $10,000 to the installation plus reduced labor costs associated with the battery operations (battery preparation/disposal, waste manifesting, record keeping, etc.). With the cooperation of Fort Riley's Directorate of Logistics (DOL), the VBCP was implemented in the Spring of 1996; this program has resulted in a decrease in the amount of spent electrolyte disposed of by Fort Riley by nearly 82%.
Alto Low-Mercury Fluorescent Lamps . Another initiative which will reduce hazardous waste is through the purchase of ALTO low-mercury fluorescent lamps, manufactured by Phillips Lighting Company. Conventional fluorescent lamps contain an average of 22.8 milligrams of residual mercury after use, but the ALTO lamps contain less than 10 milligrams. The amount of mercury contained in the ALTO lamps falls below the definition of a hazardous waste set by the EPA, and they can be thrown away after use. At DES' recommendation, Fort Riley's Directorate of Public Works (DPW) began ordering these lamps in early 1996, and will continue to order and install these across the installation.
Antifreeze Recycling Program (ARP). In order to meet the goal of a 50% reduction in TRI reportable releases, DES has developed a Fort Riley Antifreeze Recycling Program (ARP). This program will take advantage of the current centralized turn-in system for waste military antifreeze at the installation's Environmental Waste Management Center by having recycling operations take place at that facility. The recycled product will then be purchased by DOL for distribution through the installation's supply channels, with the funds going toward purchasing supplies and providing personnel to operate the ARP. Because of the recent change from MILSPEC antifreeze to commercial, heavy-duty antifreeze as mandated by the Army's Tank and Automotive Command, Fort Riley is producing a recycled antifreeze product which meets this new standard.
The Directorate of Environment and Safety is currently developing the Fort Riley Antifreeze Management Policy, which will be signed by the Commanding General, and the Fort Riley Antifreeze Management Plan, which will serve as the master plan for the installation activities that purchase, use, and create waste antifreeze. The Fort Riley Antifreeze Recycling Program will reduce our off-site transfers of ethylene glycol and the amount of new antifreeze that needs to be purchased. The cost savings associated with the these two factors will save Fort Riley approximately $16,000 per year.
Quarter Master Laundry (QML) modifications to the Dry Cleaning Operations . The QML replaced the existing vented dry cleaning machines with ventless dry cleaning machines, which will substantially reduce the amount of tetrachloroethylene (PERC) used during the dry cleaning process. It is estimated that the use of PERC will be reduced from 1200 gal/year to 120 gal/year, and result in a savings of $14,000 per/year. A distillation unit, which recycles the PERC and a ventless exhaust system that virtually eliminates air emissions, was also included and installed with the machines. A water-chiller has also been installed to eliminate the use of large amounts of water for cooling purposes. The old dry cleaning machines were cooled by constantly running tap water over the coils. The new water chiller cools the water after it is passed over the coils and then recirculates to create a closed loop system for cooling, while fresh water is added as needed due to evaporation. Conservative estimates place the water usage of the old machines at around 3,000,000 gallons per year, which cost the facility nearly $11,000 per year in water and sewage expenses.
Household Hazardous Waste Program. The installation's Household Hazardous Waste Program, managed by the DES Recycle Division, has also served to reduce the amount of hazardous waste produced by Fort Riley. This program allows residents to turn in hazardous products that are common in the household (including pesticides, paints and thinners, fertilizers, waxes, automotive fluids, and drain openers). In addition, persons who have a specific need can visit the facility and pick up those products. Without this program of turn-in and re-issue, these materials would either have to be disposed of as hazardous waste (at a considerable expense to the installation) or would be thrown away in the garbage.
Safety-Kleen (SK) Solvent Basin with cyclonic filter . Fort Riley utilizes SK for maintenance of the over 200 solvent basins in service on the installation. Beginning in October 1994, DES established a contract with Safety-Kleen to provide solvent basins with on-board filtration systems. These systems, which are called "cyclonic filters", take used solvent and spin it at very high rates. This causes particles to be carried to the filter in the device where they are retained, and the clean solvent is then recirculated for use. The cyclonic filter extends the serviceable life of the solvent resulting in a lower change-out rate and thus a reduction in the amount of used solvent disposed. Fort Riley's annual solvent generation has been reduced by nearly 60% (from 169,525 pounds to 70,051 pounds) between 1994 and 1996.
Other waste minimization projects.
DES has began to use "Sea Sweep", a hydrophobic organic absorbent material made from pine sawmill sawdust, in spill response activities. When compared to inorganic (clay-based) absorbents, Sea Sweep can absorb up to 5 times more product, resulting in a smaller amount to use and dispose of. In addition, since Sea Sweep is organic, it can be bioremediated at the installation's Bioremediation Facility. Since it is hydrophobic, Sea Sweep can also be used to respond to spills on both land and water in all weather conditions. The use of this product will enable personnel at Fort Riley to better respond to accidental spills and releases of POL products.
Fort Riley also conducts Spring and Fall Installation Cleanups, where all organizations (military and civilian) and residents perform a "spring cleaning" of the entire installation. Included in this is an amnesty turn-in of hazardous wastes, solid wastes, and household hazardous wastes, which helps to ensure that wastes are identified and disposed of properly. This spring, over 70% of the materials collected during the Spring Cleanup were recyclable.
Process changes/source reduction projects resulting in pollution prevention
Industrial Process Survey. Currently, the Directorate is developing the Industrial Process Survey (IPS), which will be a comprehensive look at all major industrial processes that take place at representative units. The survey will also identify the materials each process uses and the wastes generated. The information gained from the IPS will serve as a series of detailed Pollution Prevention Opportunity Assessments, and allow the installation to develop more process-specific initiatives to reduce the amounts of hazardous material used and hazardous waste generated in daily organization operations. It will also assist Fort Riley in the implementation of the Hazardous Substance Management System (HSMS) and in the development of our Hazardous Materials Control Center (HMCC).
Fort Riley Restricted List. The Restricted List is a mechanism designed to control the procurement of items that may have an adverse impact on human health and/or the environment, including products that contain hazardous materials or Ozone Depleting Substances (ODSs), or that otherwise pollute the environment through use or disposal. Requests to purchase these products are "flagged" on the DOL logistics system, and the P2 Program is notified of the request. The product is then researched and approval, disapproval, or an approved substitute is recommended. This important hazardous material management program has assisted Fort Riley in meeting hazardous waste reduction goals and has resulted in lower waste disposal costs for Fort Riley through the use of less hazardous products, proper Units of Issue, and not allowing units to obtain unnecessary products.
The Shelf Life Extension Program allows units to obtain information on extensions for products whose shelf life has expired. DES and DOL Supply receive monthly shelf life extension updates from the Defense General Supply Center (DGSC), and use this information to assist units with product shelf life questions.
Both of these projects will help to reduce the amount of unused material that is turned in for disposal as a waste (resulting in lower costs to the installation). They have, along with better education and the development of better management practices, also been an important part of a 34% reduction in the use and disposal of chemicals on the EPA Toxic 17 list since 1994.
Hazardous Material Control Center. DES and DOL are jointly investigating the establishment of a Hazardous Material Control Center (HMCC) at Fort Riley. The HMCC would serve as the single point through which hazardous materials are authorized, ordered, distributed, and tracked. Hazardous materials would be authorized only to those units and organizations that have a demonstrated need and have the proper training and protective equipment to use them safely. Along with the HMCC, the HSMS would also be implemented and used to track products used at Fort Riley from the time they are delivered to the installation until the time they are either used or disposed of.
Solid Waste Minimization Projects
DES has developed and implemented numerous solid waste and waste minimization projects that have saved Fort Riley money through reduced disposal costs.
Bioremediation. The Fort Riley Bioremediation Facility opened in October 1995, and can be used to remediate POL-contaminated soil from UST removals, installation restoration projects, or from spill response activities.
Composting. The Fort Riley Compost Facility is an important program that helps reduce the amount of solid waste generated by the installation. Leaves, grass clippings, and wood chips from residential and non-residential areas of Fort Riley and manure from the buffalo corral and horse stables are taken to the facility, which can process up to 100 tons of this material (creating 33 to 50 tons of compost) per season. The materials are placed in windrows and, after the process is complete, becomes compost which is used as mulch and spread on wildflower plots and other damaged areas under reclamation around Fort Riley. The compost can also be picked up by military and civilian personnel at Fort Riley for use at their homes. The composting program will eventually save the installation over $50,000 dollars per year in reduced disposal costs and reduced purchase cost of new mulch and bring Fort Riley into compliance with an anticipated Kansas law. This was the first permitted compost facility in Kansas, and is the only such facility currently operational in the Army.
Recycling. The DES Recycle Division also has a drum crusher, cardboard bailer, used oil filter crusher, can crusher, glass crusher, aerosol can crusher, and paper bailer, all of which serve to reduce the amount of solid waste requiring disposal. The installation also depressurizes and crushes aerosol cans and propane containers and collects metal shavings from the lathes at the machine shop, all of which is recycled as scrap metal. These activities not only save the installation money through reduced disposal costs, but also provides funding for the Recycle Division to help cover personnel costs, utility and vehicle expenses, and develop new recycling programs. Between 1994 and 1996, the amount of materials recycled at Fort Riley increased by just over 70%.
TRI Reduction Goals
Fort Riley is in full compliance with the requirements of EPCRA, including the establishment of a baseline which will be used to measure the progress toward meeting the TRI reduction goals. In accordance with Executive Order 12856 and DoD and DA requirements, Fort Riley set a TRI toxic chemical release reduction goal of 50% by the end of 1999. The ways in which the TRI releases will be reduced to meet that goal were identified in the Fort Riley Pollution Prevention Plan.
Two chemicals were identified in our original TRI release baseline (which used CY94 data): tetrachloroethylene (PERC) and ethylene glycol. Although PERC was removed from our baseline and is no longer reportable due to the application of an exemption, new equipment was purchased and installed at the installation's dry cleaning facility. As discussed earlier, the use and subsequent release of PERC is expected to decrease by approximately 90% through the use of the new equipment.
Antifreeze is essential in the maintenance and operation of the tactical vehicles used at the installation, and a reduction in the use and availability of antifreeze could adversely impact mission readiness. However, an installation-wide military Antifreeze Recycling Program (ARP) is currently being implemented. This project, discussed in detail earlier, is expected to reduce the amount of ethylene glycol releases from Fort Riley by at least 90%. Recycling military antifreeze and reintroducing it into the installation's supply system will result in a cost savings of approximately $16,000 per year to Fort Riley through reduced new antifreeze purchase costs and lower waste disposal expenses.
The Directorate of Environment and Safety at Fort Riley has adopted a very aggressive approach toward identifying, developing, and implementing pollution prevention and waste minimization projects. With the support of the installation's Commanders, and in cooperation with other Directorates and organizations from across the installation, DES has been successful in initiating projects that will help Fort Riley meet and exceed the goals set in our Pollution Prevention Plan and become an environmental leader in the United States Army and the local community.