Why is Pollution Prevention (P2) important in the military sector?

The military sector generates various pollutants and waste. Adopting any of the following measures may significantly reduce or even eradicate the generation of pollutants and waste as well as their impacts on the environment.

Reducing Toxic Substance Use

To reduce the use of toxic substances and amount of generated hazardous waste, try these tips:

• Replace mercury-containing devices with mercury-free alternatives. For instance, use digital thermometers instead of mercury-containing thermometers and LED lamps in place of mercury-containing bulbs. To properly dispose of mercury-containing thermometers or lamps, consult the hazardous waste rules or universal waste rules. See Title 40 of the Code of Federal Regulations (CFR), Part 273.
• Check if hazardous/toxic chemicals are necessary. Conduct a process analysis to determine if chemical formulations can be conducted that reduce the material use or if the material is characterized properly per 40 CFR, Part 261, and disposed accordingly.
• Coordinate with vendors for samples or demonstrations of biodegradable or environmentally friendly solvents. Use the Environmental Protection Agency’s Safer Choice product listing to identify safer chemicals for performing the task.
• Replace old heating, ventilation and air conditioning (HVAC) systems and implement use of biodegradable solvent or aqueous parts washers. This will help reduce nitrogen oxides, carbon monoxide, sulfur dioxide and volatile compounds from boilers, swamp coolers, old HVAC systems, and organic solvents parts washers.
• Develop and consult chemical use lists. Lists, such as “Authorized Hazardous Materials Use List,” “Restricted Hazardous Materials Use List” and “Army/Military/Airforce and EPA Approved Alternatives List," will help you order, use and substitute toxic chemicals.
• Update an accurate baseline emissions inventory. Keeping track of emissions will aid in reducing the use of methylene solvents/mineral spirits and reduce volatile organic compounds (VOCs) emissions.
• Track toxic substance waste by tracking expiration dates. Discarded, off-specification commercial chemical products (i.e., unused and expired material) may add to hazardous waste volumes. Create a good tracking system for both toxic and nontoxic chemicals to ensure older materials are used first and to track a surplus.

Reducing Hazardous Waste Generation Related to Painting Activities

Many paints in the military sector contain toxic chemicals that may need to be managed as a hazardous waste when disposed. The primary purpose of painting is to protect metal and other materials in aircrafts, vehicles and other equipment from rust and corrosion. Products, such as paints, primers, coatings and sealants, can contain toxic chemicals including lead, chromium VI, cadmium, copper, tin, nickel, zinc and beryllium. To avoid waste caused by such chemicals:

• Consider less toxic paint and coating substitutes. Find chrome-free primers and paint and coating alternatives with low VOCs and fewer metal ingredients.
• Determine if paint sprayer is more desirable than powder coating. Powder coating does not require the use of solvents but does require other mechanical equipment such as ovens.
• Purchase paint in smaller quantities to reduce a surplus in inventory. Maintain up-to-date inventory of paint and paint-related materials.
• Train employees on the proper use, waste identification, handling, and disposal of paint and paint-related waste. Mix enough paint as needed for specified projects and develop a standard work for employees.
• Use plastic sheet liners. Place liners on the paint stripping hangar floor to reduce the need for wash water and prevent the generation of wastewater. The dried scraps/stripping solution collected on the liners will need to be characterized and properly disposed of to remain in compliance with hazardous waste regulations. 
• Reuse spent solvents. Determine if spent solvents can be reused in the same or other processes or if they need to be recycled (i.e., reclaimed by distillation). If the spent solvent is reclaimed, it may meet the definition of a solid waste and considered a hazardous waste (see 40 CFR 261.2).
• Use high purity solvent in distillation units. To dispose of waste, heat a solvent to vaporize it and allow vapor to condense. The condensed vapor is reverted back to liquid form in the condenser and collected. Collect and properly dispose of the waste at the bottom of the still after performing a waste determination.

Reducing Hazardous Waste Generation Related to Munitions in Outdoor and Indoor Firing Ranges

To help reduce waste from combat arms training ranges: 

• Substitute lead ammunition with lead-free ammunition and recycle lead generated from the firing range activities, if feasible.
• Use a proper bullet containment system and ventilation to reduce airborne lead particulates.
• Consider laundering and reusing used shop rags, seeking third-party laundering vendors to extend life of rags.
• Create an inventory to track shipments and savings.
• Recycle industrial metal waste as excluded scrap metal (see 40 CFR 261.4(a)(13)).

Other Ways to Reduce Waste

• Increase recycling infrastructure throughout the facility.
• Conduct a waste audit to determine common contaminants and identify areas that generate more waste.
• Address contaminants with staff and soldiers through education (trainings, signs, newsletters, etc.).
• Strategically place solid waste receptacles (trash and recycling) where they are needed and co-locate recycling bins, incorporating signage to identify materials that belong in each.
• Train employees and soldiers on proper identification and segregation of hazardous waste from non-hazardous waste and proper disposal methods.
• Divert construction/demolition materials from landfills by finding alternative uses.
• Reduce/eliminate paper towel use and install energy efficient hand dryers.
• Properly collect and store jet fuel for reuse, disposing of spent jet fuel in compliance with hazardous waste regulations. Off-specification fuel is considered a commercial chemical product and not a solid waste if it is burned for energy recovery and if that is its intended purpose (see EPA 7/11/1994 Letter from D. Bussard to D. Gable).
• Ensure to follow the used oil regulations to correctly store, label and date used oil containers (see used oil regulations 40 CFR, Part 279). Segregation will allow for convenient oil recycling and better chance of reuse. Avoid contaminating used oil with hazardous waste.

Pollution Prevention Resource Summary for the Military Sector | PDF Coming Soon for Download >

This resource summary was created by the ADEQ’s Pollution Prevention (P2) Program with assistance from a P2 Grant provided by the U.S. Environmental Protection Agency.