installation pollution prevention program guide · 1.4 purpose and organization of guide 1-3 2....

INSTALLATION

POLLUTION PREVENTIONPROGRAM GUIDE

July 1994

Headquarters Air Force Center for Environmental ExcellencePollution Prevention DirectorateHQ AFCEE/EP8106 Chennault RoadBrooks AFB TX 78235-5318

A Reference for PreparingU.S. Air Force

Pollution PreventionManagement Action Plans

U.S. Air Force--Pollution Prevention Program Manual

U.S. AIR FORCE

INSTALLATION POLLUTION PREVENTION

PROGRAM GUIDE

July 1994

Prepared by: HQ AFCEE/EP 8106 Chennault Rd Brooks AFB TX 78235-5318

INSTALLATION POLLUTION PREVENTION PROGRAM GUIDE

TABLE OF CONTENTS

1

Pollution Prevention Program Manual

Page 1. POLLUTION PREVENTION PROGRAM 1.1 Overview of Policy 1-1 1.2 Program Area Goals 1-1 1.3 Regulatory Intent 1-2 1.4 Purpose and Organization of Guide 1-3 2. POLLUTION PREVENTION AS A PROCESS 2.1 Overview 2-1 2.1.2 Pollution Prevention Conceptual Model 2-1 2.1.2 Pollution Prevention Hierarchy 2-2 2.2 Pollution Prevention Process 2-2 2.2.1 Policy 2-3 2.2.2 Baselines 2-3 2.2.3 Requirement 2-3 2.2.4 Options 2-4 2.2.5 Solutions 2-4 2.2.6 Program 2-4 2.2.7 Execution 2-5 2.2.8 Metrics and Reporting 2-5 2.3 Baselines 2-5 2.3.1 Program Area Goals 2-5 2.3.2 Baseline Units 2-5 2.3.3 Methodology for ODCs, EPA 17, HW and MSW 2-6 2.3.4 Methodology for Affirmative Procurement and Energy 2-10 2.4 Opportunity Assessments 2-11 2.4.1 General 2-11 2.4.2 Methodology 2-12 2.5 Pollution Prevention Management Plans 2-14 2.5.1 Definition 2-14 2.5.2 Methodology 2-14 2.5.3 Process 2-14 2.5.4 Program 2-17 2.5.5 Execution 2-19 2.5.6 Revision 2-19 3. PROGRAM MANAGEMENT 3.1 Overview 3-1 3.2 ODCs 3-1 .2.1 Goals 3-1


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3.2.2 Overview 3-1 3.2.3 Directives 3-2 3.2.4 Halons 3-2 3.2.5 Refrigerants 3-4 3.2.6 Solvents 3-5 3.2.7 Procurement Contracts 3-5 3.2.8 Waivers 3-5 3.2.9 Tracking and Reporting 3-5 3.2.10 Alternative Chemicals 3-5 3.2.11 Additional Resources 3-6 3.3 EPA 17 Target Chemicals 3-7 3.3.1 Goal 3-7 3.3.2 Background 3-7 3.3.3 EPA 17 Target Chemicals and Typical Uses 3-7 3.3.5 Typical Opportunities 3-7 3.3.6 Tracking and Reporting 3-9 3.4 Hazardous Waste/Industrial Waste 3-9 3.4.1 Goal 3-9 3.4.2 Tracking and Reporting 3-10 3.4.3 Processes Generating Hazardous Waste 3-11 3.4.4 Typical Hazardous Waste Reduction Opportunities 3-11 3.4.5 Additional Resources 3-12 3.4.6 On-Site Recycling/Reuse of Hazardous Waste 3-13 3.5 Municipal Solid Waste 3-17 3.5.1 Reducing Solid Waste Disposal 3-17 3.5.2 Typical Processes 3-17 3.5.3 Basic Strategy for Reducing Solid Waste Disposal 3-19 3.5.4 Programs 3-20 3.5.5 Tracking and Reporting 3-21 3.6 Affirmative Procurement 3-21 3.6.1 Goals 3-21 3.6.2 Tracking and Reporting 3-22 3.6.3 Typical Processes/Opportunities 3-23 3.6.4 Unique Aspects 3-24 3.6.5 Exceptions 3-24 3.6.7 Product Sources 3-24 3.6.8 References 3-25 Page 3.7 Energy Conservation 3-25 3.7.1 Goals 3-25 3.7.2 Background 3-25


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3.7.3 Energy Program 3-26 3.7.4 Typical Opportunities 3-27 3.7.5 Unique Aspects 3-28 4. EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT 4.1 Background 4-1 4.2 Reporting 4-1 4.3 Goals 4-2 4.4 Tracking 4-2 4.5 Hazardous Material Pharmacy 4-2 5. TEAM BUILDING AND IMPLEMENTATION 5.1 Introduction 5-1 5.2 The Pollution Prevention Team 5-1 5.2.1 Pollution Prevention Subcommittee (Working Group) 5-1 5.2.2 Pollution Prevention Teams 5-1 5.3 Training 5-3 5.3.1 AFIT Env 220, Pollution Prevention Course 5-4 5.3.2 USAF SAM Pollution Prevention Technologies Course 5-4 5.3.3 AFCEE Opportunity Assessment Training 5-4 4.3.4 Other Training Opportunities 5-4 5.4 Recognition of Personnel 5-5 6. PROGRAMMING AND BUDGETING 6.1 Overview 6-1 6.1.1 Pollution Prevention Budget Program 6-1 6.1.2 Appropriations 6-1 6.1.3 Program Element Code 6-1 6.2 Pollution Prevention Program Budget and Priorities 6-1 6.2.1 Recurring Requirements 6-2 6.2.2 Non-recurring Requirements 6-2 6.3 Pollution Prevention Program Eligibility/Exclusions 6-3 6.3.1 Non-Environmental Projects 6-3 6.3.2 Maintenance Projects 6-3 6.3.3 Air Conditioning Projects 6-3 6.3.4 Halon Projects 6-3 Page 6.3.5 Fire Extinguisher Projects 6-3 6.3.6 Depot-Level Equipment 6-3 6.3.7 Acquisition Projects 6-3 6.3.8 Energy Conservation MILCON Projects 6-3 6.3.9 Environmental Certifications and Licenses 6-3


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6.4 Line Item Approval 6-3 6.5 WIMS-ES 6-4 6.5.1 WIMS-ES A106 Module 6-4 6.5.2 Pollution Prevention Module 6-4 7. TECHNOLOGY NEEDS 7.1 Overview 7-1 7.2 Technology Process 7-1 7.2.1 Technology Categories 7-1 7.2.2 Final Step 7-2 7.3 Base Level Responsibilities 7-2 7.4 Points of Contact 7-2 7.4.1 Primary Points of Contact 7-2 7.4.2 Other Sources 7-2 7.4.3 Additional Sources 7-2 8. SUPPORTING ORGANIZATIONS 8-1 APPENDICES APPENDIX A - GLOSSARY

APPENDIX B - OPPORTUNITY ASSESSMENT WORKSHEET EXAMPLE

APPENDIX C - AIR FORCE POLLUTION PREVENTION MANAGEMENT ACTION

PLAN PROTOTYPE

1-1 Pollution Prevention Program Manual

1. POLLUTION PREVENTION PROGRAM

1.1 OVERVIEW OF POLICY The Air Force (AF) is committed to environmental leadership and preventing pollution by reducing use of hazardous materials and releases of pollutants into the environment to as near zero as feasible. The AF pollution prevention policy is solidly in step with the national policy of the United States as stated in the Pollution Prevention Act of 1990. The act calls for pollution prevention at the source whenever feasible; this is exactly the concept that drives the AF's program. The AF's pollution prevention program involves efforts to reduce the use of wastes through a hierarchy of actions. The actions range from the most preferred choice of source reduction, to recycling, treatment, and finally disposal as a last resort. This hierarchy of actions must be fully integrated into day to day AF operations to build a strong pollution prevention program. In keeping with the requirement for full integration, the Air Force pollution prevention program applies to all AF installations within the United States, its territories, and foreign countries. Additionally, it applies to the Air Force Reserves, the Air National Guard, and Government Owned Contractor Operated (GOCO) facilities. Reduction efforts apply equally to all aspects of the AF mission: from concept through production, deployment, and ultimate disposal of new weapon systems; to finding less hazardous materials and processes and integrating them into technical orders, military specifications, and military standards of existing (deployed) systems; to reducing hazardous materials use and waste generation at installations (civil engineering, vehicle and aircraft maintenance, family housing, etc.). 1.2 PROGRAM AREA GOALS Specific goals have been established for selected pollution prevention program components: Ozone Depleting Chemicals (ODCs), Environmental Protection Agency 17 Industrial Toxics (EPA 17), Hazardous Waste, Municipal Solid Waste, Affirmative Procurement, and Energy. These program components will be continuously monitored and measured to ensure goals are achieved. All measurements will be taken against a CY 1992 baseline for the first four program


components; the fifth program component (affirmative procurement) is evaluated each year, against itself; and the sixth component (energy conservation) is measured against a 1985 baseline.

TABLE 1-1

AIR FORCE POLLUTION PREVENTION GOALS PROGRAM COMPONENT: GOAL: Ozone Depleting Chemicals (ODCs): 100% Reduction of purchases by 1 Apr 93 Environmental Protection Agency 17 Industrial Toxics (EPA 17): 50% Reduction of purchases by 31 Dec 96 Hazardous Waste Minimization: 25% reduction by 31 Dec 96 50% reduction by 31 Dec 99 Municipal Solid Waste: 10% reduction by 31 Dec 93 30% reduction by 31 Dec 96 50% reduction by 31 Dec 97 Affirmative Procurement: 100% of all products purchased each year in each of EPA's "Guideline Item" categories shall contain recycled materials meeting EPA's Guideline Criteria Energy Conservation: 10% reduction by 1995 20% reduction by 2000 25% reduction by 2005

1.3 REGULATORY INTENT


The AF developed its Pollution Prevention Policy (PPP) to implement the federal regulatory mandate of the Pollution Prevention Act of 1990. The pollution prevention concept is designed to prevent pollution by reducing or eliminating environmentally harmful discharges to the air, land, surface water and groundwater at the source. Under the PPP, each installation, including those outside the U.S., will develop and execute a PP Management Action Plan (PP MAP) that addresses source reduction, recycling, treatment opportunities and disposal for major pollutant sources. Pollution prevention provides every installation with the opportunity to become good stewards of the environment. By considering how all operations-not just those producing hazardous wastes-contribute to the pollution of air, land, and water resources, the Air Force can better identify and control pollution sources. 1.4 PURPOSE AND ORGANIZATION OF GUIDE The purpose of this guide is to give AF personnel a comprehensive document describing how to implement AF Pollution Prevention Policy and establish effective programs at their installations . It is also meant to serve as an overview and reference document to assist managers in developing their PP MAP. Since pollution prevention is an evolving program, the guide will require a recurring update. Personnel are encouraged to expand this document as required and to send suggested changes to HQ AFCEE/EP. Chapter 1 provides the policy background, mandate, and context for the PPP. Chapter 2 describes the three phases required to develop a PP MAP. Chapter 3 details PP program components including ozone depleting chemicals, EPA 17 target chemicals, hazardous materials/waste, municipal solid waste, affirmative procurement and energy conservation. Chapter 4 discusses the Emergency Planning and Community Right-to-Know Act (EPCRA). Chapters 5 through 8 focus on other aspects of an effective program, to include team building, programming and budgeting, technology needs, and sources of information.


2. POLLUTION PREVENTION AS A PROCESS

2.1 Overview Installation Pollution Prevention Management Action Plans (PP MAPs) will address the process required to run a pollution prevention program at the installation; the program required to fund pollution prevention projects; and the actions required to execute the program. MAPs will be based on recurring opportunity assessments designed to continually evaluate an installation's success in achieving pollution prevention at the highest level in the hierarchy of actions. This chapter explains how to establish an installation pollution prevention program. It does not address organizational structure or management of specific program areas, which are covered in other chapters. It describes the process (baselines, opportunity assessments, and management plans) needed to develop a program to meet installation pollution prevention goals. 2.1.1 Pollution Prevention Conceptual Model. AF activities may be modeled as processes (e.g. base industrial activities, administrative activities, support activities and family housing); each relying on a steady stream of material and energy. Waste is generated as a by-product of these processes. The specific minimization efforts of pollution prevention target subsets of these input (material) and output (waste) streams. The relationships between these areas are shown in Figure 2-1. AF processes are fueled by energy and materials. Some of the materials purchased are hazardous to human health or to the environment. Among these hazardous materials are ODCs such as Halons and refrigerants. Hazardous wastes are by-products of AF processes that can pose a substantial or potential hazard to human health or the environment when improperly managed. They possess at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity), or are listed in 40 CFR 261.3 or applicable state or local waste management regulations. Municipal solid waste (trash) is non-hazardous waste generated by domestic and industrial processes. Hazardous material use often produces hazardous emissions into the air or water, increasing environmental compliance requirements for these media. Hazardous material can become hazardous waste through non-use (i.e., through expiration of shelf-life).


FIGURE 2-1POLLUTION PREVENTION CONCEPTUAL MODEL

Input Air ForceProcesses

Output

By-Products

Recyclingwithin AF

AffirmativeProcurement

Recycling Outside AF

Energy and Materials(incl HAZMATs and ODCs)

Product or Service

Energy and Materials(incl municipal and hazardous wastes)

2.1.2 Pollution Prevention Hierarchy. Pollution prevention first seeks to change processes to eliminate purchase and generation of undesirable "targeted" materials. This is known as "source reduction." Where source reduction is not feasible or cannot eliminate waste, materials may be reused or recycled to reduce waste and purchase requirements. Goals to purchase products with recycled content through affirmative procurement help "close the recycling loop" by creating demand for recycled products. Treatment of wastes and emissions control to reduce environmental impacts prior to disposal should be used only when source reduction is not feasible. Pollution prevention must be integrated into AF activities across all functions to ensure environmentally sound practices are in place. This Guide discusses methods for reviewing existing base operations to identify pollution prevention opportunities. However, installations must not forget to pay equal attention to new operations and activities. New facility construction, new industrial processes, and even projects to repair buildings and equipment, all offer opportunities to plan pollution prevention into the project. Remember to consider pollution prevention as a part of the environmental review process for all new projects and activities coming to the installation. 2.2 Pollution Prevention Process.


Figure 2-2 represents the process of developing and executing a pollution prevention program. Paragraphs 2.3 through 2.5 explain baseline surveys, opportunity assessments and management action plans in greater detail. The following subparagraphs describe each portion of the process. 2.2.1 Policy. Policy is a statement of values embodied in a goal that the AF will commit resources to achieve. Pollution prevention policy is contained in Air Force Policy Directive (AFPD) 32-70, Environmental Quality, and Air Force Instruction (AFI) 32-7080, Pollution Prevention Programs.

FIGURE 2-2THE POLLUTION PREVENTION PROCESS

POLICY BASELINES

REQUIREMENT

OPTIONS

SOLUTIONS

PROGRAM

METRICSAND

REPORTING

EXECUTION

2.2.2 Baselines. A baseline is a measurement of the amount of targeted substance purchased or generated during a specified time period. The baseline is the beginning status relative to a goal. It will be the basis for calculating future progress toward the goal. Baseline information includes not only the quantity of material purchased or generated during the time period, but also the name of the substance, its unit cost of purchase or


disposal, and the using or generating process. See Section 2.3 for more information on baseline development. 2.2.3 Requirement. The requirement for minimization for each program component equals the difference between the goal and the baseline. For a non-baseline area (Affirmative Procurement), the requirement will equal the difference between the goal and the current measurement. The requirement identifies what the program needs to do. For example, the first Energy goal is to reduce energy use 10% by the end of CY 1994 from a 1985 baseline. If the 1985 consumption was 0.149 MBTU, a 10% reduction amounts to 0.0149 MBTU; this is the requirement. If energy consumption efforts after 1985 have already yielded a reduction of 0.004 MBTU, this can be subtracted, and the remaining requirement is 0.0109 MBTU, or the amount of reduction still needed to attain the goal. This process is repeated to obtain the requirements for the second and third phase energy reduction goals (20% by 2000 and 25% by 2005 respectively). 2.2.4 Options. Options include all possible ways to achieve the goals. They may involve procedural changes, material substitutions, equipment purchases, facility modifications or construction, technology needs, or any combination of these. Identification of options is often called an "opportunity assessment." Paragraph 2.4 covers opportunity assessments in detail, including discussion of option development. The information generated by an opportunity assessment should include: (1) a description of the option; (2) which processes are affected; (3) the option's cost by appropriation and fiscal year; (4) its value in terms of which substances and program components are affected; (5) how much each substance is reduced for each affected process; (6) the unit cost of purchase or disposal for each substance; (7) and the return on investment (ROI) in years, calculated from cost and value (see example ROI calculation in section 2.5.4.3). 2.2.5 Solutions. Choose solutions from the range of options. For each program component, choose solutions where the sum of the contributions of each solution toward the goal will equal the requirement. Some options may require MAJCOM approval or assistance, while others may require Air Force Materiel Command (AFMC) assistance for technology solutions. MAJCOMs are responsible for identifying technology needs (see Chapter 7 of this publication and AFI 32-7003, Environmental Research and Development).


2.2.6 Program. Programs will consist of the chosen solutions satisfying the goals of each program component. Many solutions will require funding not available locally or from the MAJCOM. Enter the cost of these solutions for each installation into the budget and Program Objective Memorandum (POM) submittals as appropriate. See Chapter 6 of this publication and AFI 32-7001, Environmental Budgeting, for programming and budgeting information. 2.2.7 Execution. Execute projects as soon as they are funded. Early execution of pollution prevention projects will result in early return on investment. 2.2.8 Metrics and Reporting. The actual benefit of implemented ideas should be measured and compared with the projected benefits. The program should then be adjusted accordingly, adding or deleting ideas to the program if benefits are disappointing. This will "close the feedback loop" to ensure the pollution prevention program will ultimately meet its goals. Progress toward goals will be measured by metrics provided in AFPD 32-70, Environmental Quality. The Work Information Management System-Environmental Subsystem (WIMS-ES) will be used for reporting metrics and baselines. Although WIMS-ES is a Civil Engineering system, reporting data will come from many functional organizations. Details on tracking and reporting are included in Chapter 4 for each of the program components, and AFI 32-7002, Environmental Information Management System, contains reporting procedures and formats. 2.3 Baselines. 2.3.1 Program Area Goals. AF goals for each of the pollution prevention program areas are identified in Chapter One, Section 1.2. 2.3.2 Baseline Units. The baseline on which these program component goals are based is calendar year 1992, except for energy conservation and affirmative procurement. The energy conservation baseline year is 1985. Units of the baseline quantities are as follows: - ODC purchases are in pounds of each Class I chemical. - EPA 17 Industrial Toxics purchases are in pounds of each chemical. - Hazardous Waste disposal is in pounds.


- Municipal Solid Waste disposal is in tons. - Affirmative Procurement is in dollars for each Guideline Item (total value of purchases in each category, and total value of purchases in each category which met the recycled content goals). - Energy Conservation is measured in BTUs per square foot. 2.3.3 Methodology for ODC, EPA 17, Hazardous Waste and MSW Baselines. There are two possible approaches for obtaining the baseline data needed to develop pollution prevention opportunities: a "top-down" analysis or a "bottom-up" analysis. The "top-down" approach starts with the installation's available procurement records and waste generation records, uses these data to develop installation baselines, and performs detailed process analysis on only a selected number of activities. The "bottom-up" approach begins with identifying every activity on the installation which uses targeted chemicals or produces wastes, then performs detailed analysis and calculation of target chemical usage or waste generation for every activity, and sums these individual process results to obtain the installation baselines. Cost data will also need to be gathered for each process which is studied for opportunities. Cost becomes important when the base is selecting pollution prevention actions from a list of opportunities, or when project justification must include economic cost/benefit data. Methodology for a "top-down" baseline involves searching installation supply, contracting, bioenvironmental and environmental records for ODCs and EPA 17 chemicals, and hazardous and MSW generation data; totaling these data for each program component and reporting these data as the installation baselines; and then identifying a limited number of organizations and processes which use the largest amounts of the targeted substances, or generate the largest or most toxic waste streams, for further study and development of pollution prevention opportunities. The advantage of this approach is that it minimizes the labor required to develop baselines; the disadvantage is that it does not provide a full picture of all processes which may yield worthwhile pollution prevention opportunities. Methodology for a "bottom-up" baseline requires identifying all activities on base that use targeted substances or generate wastes; fully documenting each process, the materials it


uses and wastes it generates; and then summing all activities' material usage and waste generation quantities to obtain the total baselines for each program component. The advantage of this approach is that it provides a comprehensive picture of all processes and provides a complete and detailed foundation for development of pollution prevention opportunities. The disadvantage is that it requires extensive effort and knowledge of all installation processes. Practical experience gained during baseline surveys to date shows that baseline data obtained by the two approaches will seldom agree. For the top-down approach, it is difficult to gather complete data using records which were never designed with environmental data collection needs in mind. For the bottom-up approach, detailed records of material use and waste generation at the process level are seldom available, and estimating will always introduce errors. Each MAJCOM and installation should consider the nature of their activities, and adopt the approach which provides the most useful information while making the best use of limited data and personnel resources. Keep in mind that meeting the AF reduction goals will require consideration of a sufficient number of processes to identify enough material and waste reduction opportunities to meet the goals of each program component - and the identification of these opportunities still requires detailed analysis of the inputs, outputs and costs for each process. In the end, a compromise between the two approaches may provide the best solution. Consider quantifying the installation's baseline data for each program component using the top-down approach; select the activities believed to use the most targeted chemicals and generate the most wastes; and perform process analysis on the selected activities, according to the process analysis methodology which follows. If the selected activities don't yield enough reduction to meet the goals, do another iteration of activity selection and analysis. 2.3.3.1 Data Sources: Use the following fundamental sources of information when determining baseline data: (1) purchase data from supply sources and contracting; (2) shop interviews (spend time to draw out information, otherwise the interviewee will not realize what information he actually knows or remembers that will help you); (3) inventory data from the Hazardous Materials Pharmacy or HazMart; (4)


Bioenvironmental Engineering annual shop surveys and inventories (AF Form 2761); (5) any prior installation reports; (6) waste disposal data from hazardous waste manifests and reports as well as disposal contracting information. Use professional judgment to reconcile the data, when the numbers will not match, and establish the baseline data within each activity and finally for the base. In preparing the baseline survey it is important that all facilities be considered for evaluation to fully exploit all pollution prevention opportunities. This includes facilities such as: base exchange, commissary, snack bars, service stations, hospitals, hobby shops. 2.3.3.2 Uniquely identify each activity on base having a process that uses hazardous materials (Class I ODCs or EPA 17), or which generates solid or hazardous waste as a by-product. An activity is defined as a single sequence of operations, having an input and an output, performed by one organizational element or sub-element for a single purpose. Parallel operations, prior or subsequent actions performed by other organizational elements, and similar actions for different purposes should all be different activities. 2.3.3.3 Assign a unique identification (ID) number to each activity, perhaps including office symbols for ease of recognition, e.g. "LGTM 23." 2.3.3.4 For each process, document: - ID number - the unique ID number assigned to each process - Title - the name of the process - Program Component(s) - specify the particular chemical(s) or hazardous waste type(s), and the program component goal(s) affected by these chemicals - Organization (if not in ID number) - Purpose - specify any directive technical orders or regulations and a general statement of why process exists. - Description - describe the process - Input units and origin - input/output units are what the process manipulates; the reason for its existence. Origin (destination) is generally other organizational elements. This information describes the relationships between processes often needed for generating options and checking production rates. - Output units and destination - (see definition for input units and origin)


- Production rate - how many output units are processed per year. - Amount of material or waste used or generated per unit output - -a number relating the amount of undesirable material to the production rate. This information improves the accuracy of shop estimates and is useful for generating ideas. - Total amount used or generated by the process in the baseline year. 2.3.3.5 Example of baseline information: Process ID: LGMA 14 Title: Wheel Stripping Program Component(s): EPA 17 (Methylene Chloride), Hazardous Waste Organization: LGMA Tire Shop Purpose: Remove paint from aircraft wheels prior to non-destructive inspection (NDI) as required by Tech Order XX-XX. Description: Receive wheel, remove tire, soak in 30-gallon solvent vat of Methylene chloride for 2 hours, remove paint with air knife, send to NDI. Input units and Origin: Painted wheels, removed directly from aircraft Output units and Destination: Unpainted wheels; Production Rate: 160 wheels/year Material Quantity/Wheel: 11 lbs of Methylene chloride/wheel; 15 lbs of hazardous waste/wheel Process Baseline Quantity: 1760 lbs of Methylene chloride; 2400 lbs of hazardous waste

2.3.3.6 Sample calculation: Use the example stripping process described in Section 2.3.3.5 above. Background data: Solvent requires changeout after 15 wheels Solvent becomes hazardous waste Four pounds of paint are removed per wheel:


(Quantity of hazardous material used)(Conversion factor-gal to lbs)/(# of wheels per vat) = lbs hazardous material used/wheel (30 gal solvent/vat)(5.5 lbs/gal)/(15 wheels/vat) = (11 lbs of methylene chloride/wheel); (lbs hazardous material/wheel) + (lbs hazardous waste removed from wheel)= Total amount of hazardous waste generated/wheel (11 lbs solvent/wheel)+(4 lbs paint/wheel) = (15 lbs of hazardous waste/wheel) 2.3.3.7 Identify all costs associated with each hazardous material purchased or waste generated. These should include not only purchase and disposal costs, but also costs of special process equipment, permit applications, personal protective equipment, training, etc. directly attributable to the material. Establish a total cost per unit weight for each chemical and each type of waste. 2.3.3.8 For a data integrity check, ensure: - Baseline totals equal amounts reflected in purchasing and disposal contract records - Process usage and generation totals equal baseline totals - Material quantities issued for each organization minus unused quantities equals production rates times usage per unit output - Waste quantities generated by each organization equal production rates times generation per unit output - Sequential processes have the same production rates 2.3.4 Affirmative Procurement and Energy Baseline Methodology. 2.3.4.1 Affirmative Procurement. EPA's goals for Affirmative Procurement are expressed in Executive Order 12873, Federal Acquisition, Recycling, and Waste


Prevention, dated 22 Oct 93. According to the EO, 100% of the products purchased by Executive agencies in each of several product categories ("EPA Guideline Items") shall meet or exceed certain standards for recycled content. Goals for affirmative procurement are measured differently from the program components previously discussed. We do not develop a baseline and reduce our totals to some percentage of that baseline. Instead, we look at annual procurements made for each of the Guideline Items and determine what percentage of the purchases in each category met the guideline criteria for recycled content. The EPA Guideline Items, tracking and reporting methodology are discussed in Section 4.6. 2.3.4.2 Energy Consumption. Facility energy consumption includes the energy to operate the facility (heating, air conditioning, lights, hot water, etc.) and the energy consumed within the facility (computers, appliances, equipment, etc.) Consumption is measured on a BTU per square foot basis. The baseline is the amount of energy consumed in 1985. Executive Order 12902 and the Energy Policy Act of 1992 drive the Air Force's Energy Program, which is discussed in Section 4.7. 2.4 Opportunity Assessments. 2.4.1 General. The method of identifying process improvements or options is referred to as an "opportunity assessment." This effort assesses all pollutant sources and examines material usage and waste generation by type and volume of content, and determines the most practical and economical options for reduction. This generally involves examining each process involving a targeted substance to determine ways to avoid use or generation of that substance. Detailed baseline information characterizing material use and waste streams for each process may be gathered concurrently with the assessment process. Opportunity assessments may be done by trained base level personnel, contractor, or MAJCOM team. Many MAJCOMs decide to build their initial programs with contractor support, but train their personnel to take over the process in the future. Base personnel can potentially generate the best options because of their familiarity with the processes. The result of the opportunity assessment should be a list of options and associated information described below.


2.4.2 Methodology. 2.4.2.1 Review baseline data and look for activities using targeted compounds and look for opportunities to reduce generation. For each idea, identify: - To which process(es) it applies, and for each process: -- Which chemical(s) and/or waste(s) are affected, and for each chemical and waste affected: --- The proposed reduction quantity, in pounds per year (the "benefit"), calculated by multiplying the production rate times the amount of material used/generated per unit output times the percentage of reduction proposed by the idea. In the example in Section 2.4.3.6, if a plastic media blaster is proposed to eliminate the solvent bath: (Mat'l Qty Saved) = (Process Output)(Mat'l per Unit Output)(100%) (1760 lbs/yr) = (160 wheels/yr)(11 lbs/wheel)(100% reduction) 73.3% = (1760 lbs methylene chloride/yr)(100%) -- The percentage of the (2400 lbs hazardous waste) hazardous waste which is methylene chloride (Waste Qty Saved) = (Process Output)(Waste per Unit Output)(73.3%) (1760 lbs/yr) = (160 wheels/yr)(15 lbs/wheel)(73.3% reduction)


The calculation must also account for any additional waste generated as a result of the process change . If the plastic beads in the example break down after 800 hours of use, if it takes 6 minutes to strip a wheel with the bead blaster, and the blaster contains 20 pounds of beads, then the additional waste generated is: (Add'l Waste) = (Process Output)(Waste per Unit Output) (0.4 lbs/yr) = (160 wheels/yr)(20 lbs)(.1 hrs/wheel)/(800 hrs) Therefore, the net waste quantity saved is (1760 - 0.4) = 1759.6 pounds. After the calculation is complete, check to ensure the benefit does not exceed the amount the process uses. Then, to complete the data gathering for the opportunity: - Determine the total benefit to each program component. - Estimate the one-time cost of implementing the idea, including equipment purchases, facility modifications, training, and other non-recurring costs. - Estimate recurring costs of implementing the idea, such as additional labor, electricity, contract costs, or other recurring costs incurred by implementing the idea. 2.4.2.2 Calculate the "requirement," or the difference between the baseline and the goal, for each program component. Components having multiple goals will also have multiple requirements. 2.4.2.3 The sum of the project benefits for each program component must be greater than or equal to the requirement. If not, the goal cannot be met even if all the proposed ideas are implemented. Only if the benefits exceed the requirements will the opportunity assessment have identified an adequate number of ideas. Base environmental managers are encouraged to identify as many ideas as possible.


2.4.2.4 Summary of essential features of opportunity assessments: - Each idea presented in an opportunity assessment must have a cost and a benefit (if no cost is associated with an idea, that should be noted). - Ideas must identify the PP program components to which they contribute. - The minimum requirement for each program component (except affirmative procurement) equals the difference between the goal and the baseline. - The number of ideas identified for a program component is sufficient when the cumulative benefits for the ideas exceed the requirement to be met for that program component. Examples of worksheets to aid in conducting opportunity assessment are included in Appendix B. 2.5 Pollution Prevention Management Action Plans. 2.5.1 Definition. The Pollution Prevention Management Action Plan (PP MAP) is a single reference used to manage the actions needed to develop and execute an installation's pollution prevention program. A well prepared plan will document an installation's previous, current and future pollution prevention actions. Appendix C is a sample pollution prevention management action plan. 2.5.2 Methodology. The PP MAP has three sections: process, program, and execution. Each section lists required management actions, who is responsible for doing them, and when they will be completed. The "process" section lists actions needed to establish and maintain a framework for processing ideas to accomplish goals. The "program" section lists the ideas, or "options," generated by the process that are chosen as the solution set for achieving the goals. The "execution" section lists actions needed to implement specific options. Paragraphs 2.5.3 through 2.5.5 describe the methodology involved in building each of these three sections. 2.5.3 Process. Figure 2-2, page 2-3, describes the process of establishing and executing a pollution prevention program. The "Process" section is divided into subsections, one for


each "box" in Figure 2-2. Each subsection lists all the management actions needed to cause that box to function ("initial" actions) and to continue functioning ("recurring" actions). Sample actions for each are listed below. However, these actions in an actual plan would likely be much more detailed and comprehensive. (Actual OPRs may vary depending on MAJCOM or base directives). 2.5.3.1 Policy: - Initial: Publish a wing supplement to Air Force or MAJCOM policy, if required. (OPR: Wing Environmental Manager) - Recurring: Maintain local policy supplements. (OPR: Wing Environmental Manager. Frequency: Annual) 2.5.3.2 Baselines: - Initial: Establish 1992 baselines for EPA-117 and ODC purchases. (OPR: SGPB) - Recurring: None 2.5.3.3 Requirement (The difference between goals and baselines): - Initial: Determine requirements for the pollution prevention program. (OPR: Wing Environmental Manager) - Recurring: None 2.5.3.4 Options: - Initial: Train base personnel in how to accomplish opportunity assessments. (OPR: Wing Environmental Manager) - Recurring: Accomplish periodic opportunity assessments. (OPR: Wing Environmental Manager. Frequency: Annual)


2.5.3.5 Solutions: - Initial: Select options to be implemented, schedule them, and document them in the Management Action Plan. (OPR: Wing Environmental Manager) - Recurring: Evaluate the results of implemented options, determine the deviation from projected results, and add new options or subtract old ones as needed. (OPR: Wing Environmental Manager. Frequency: Annual) 2.5.3.6 Program: - Initial: Submit the initial pollution prevention program through MAJCOM to higher headquarters in the FY 96-01 POM submittal. (OPR: Accounting and Finance) - Recurring: Submit unfunded pollution prevention projects through MAJCOM to higher headquarters for funding. (OPR: Accounting and Finance. Frequency: As required by budget cycle.) 2.5.3.7 Execution: - Initial: Establish single-point control of hazardous material purchases. (OPR: LGS. OCR: LGC.) - Recurring: Maintain public awareness of the role of the base populace in the success of pollution prevention initiatives. (OPR: Wing Public Affairs. Frequency: Monthly) 2.5.3.8 Metrics and Reporting: - Initial: Establish procedures to capture and record hazardous material purchase data for AFPD metrics and other legally mandated reports (e.g., the Emergency Planning and Community Right-to-Know Act). (OPR: LGS. OCR: LGC.)


- Recurring: Enter reportable data into the Pollution Prevention Module of WIMS-ES for AFPD metrics. (OPR: CEV. Frequency: Semi-Annual) 2.5.4 Program. The set of options selected to achieve the program's goals are listed in this section. Responsibilities and deadlines are listed in this section, too. For options requiring funding, or "projects," the deadline becomes the fiscal year in which the project is to be programmed. This section will contain a list of projects for each program component. The following steps will generate the "program" section: 2.5.4.1 Generate a list of all pollution prevention ideas ("options") not yet implemented. Include locally generated ideas as well as those from opportunity assessments. Many ideas may not cost anything and many may be implemented immediately. Be sure to include these options, since they represent departures from the baselines toward the goals. Also include projects currently programmed and funded, but not yet accomplished, as these will contribute to the goals, too. - Include the title of each option, a unique ID number for the option, its cost, and its benefit. 2.5.4.2 List the options by program component, subdividing ODCs and EPA 17 by chemical. Options which affect more than one goal should be listed in all areas that apply. Further sort the ODC and EPA-17 lists into lists for each of the different ODCs and each of the 17 toxic chemicals. Compare total benefits for each substance with baseline amounts to ensure there is no "double-dipping" of reduction credit. Since each requirement is a total requirement for all EPA-17 and all ODCs, use the single ODC and EPA-17 lists for the following calculations, but document the chosen solutions in the management plan with the sorted lists. This will make it easier to identify future opportunities. 2.5.4.3 Calculate ROI (see section 2.2.4 for more information) for each option. ROI involves the following two steps:


ROI EXAMPLE

1) Annual Savings ($/yr) = Annual Mat'l Qty Saved (lbs/yr) x Cost of Purchase ($/lb) 2) Payback (yr) = (Project Cost) [(Annual Savings)-(Annual Cost)] 2.5.4.4 Rank options within each list by ROI, with fastest payback options at the top of each list. 2.5.4.5 Starting at the top of each list and working down, add the benefits of the options until the cumulative total exceeds the requirement. These ideas are the solution sets of chosen options for each minimization area. Assign deadlines and responsibilities to each selected option. The options must be implemented prior to the deadlines for the goals they are intended to satisfy. For example, if a goal is to be met by the end of 1995, all options to meet that goal should be implemented by then. Try to implement the fastest payback options first. For program components with phased requirements (generated by sequential goals in various fiscal years), plan to meet the requirements with groups of actions which will provide sufficient reductions to meet each phase. Once the initial requirement is met, determine the next solution set by continuing down the list until the benefits exceed the next phase's requirement, and so on. Projects selected to satisfy a second phase requirement should generally be programmed after the deadline imposed by the first requirement. For example, projects supporting between 25% and 50% hazardous waste reduction by the end of 1999 should be programmed after the end of 1997, when hazardous waste is to be reduced by 25%. 2.5.4.6 Total the initial costs of the projects in each category by each fiscal year. 2.5.4.7 Enter the lists, now subdivided by fiscal year of programming or implementation, into the management action plan. (Use the ODC and EPA-17 lists previously sorted by substance.) (See Appendix C, Tables 3 through 8).


2.5.4.8 Prepare a summary sheet for this section documenting the goals, baselines, requirements, benefits by fiscal year, and costs by fiscal year. (See Appendix C, Table 1). 2.5.5 Execution. Actions needed to implement specific options are listed in this section. These are unique to each option and to each installation. The level of detail is up to each environmental manager. Subdivisions in this section will generally be each program component, then each chosen option. For example, in the municipal solid waste area, there may be a project to purchase two cardboard baling machines. Examples of actions associated with executing this project might be identifying where the machines will be located, who will operate them, how operators will receive training, how procedures will be modified to use the machines (e.g., asking customers to segregate cardboard waste, how cardboard bales will be transported, etc.), and other details determined by the installation to be important enough to formally manage. 2.5.6 Revision. The Management Action Plan must be updated from time to time to ensure its role as a living document reflecting changes in pollution prevention technology or regulatory requirements. If small corrective actions are not taken when they are needed, large ones will be needed later. The following steps are necessary to incorporate the proper feedback into the plan. 2.5.6.1 Measure the actual benefit of completed projects. Do this by looking at the measurement data, e.g., amount of hazardous waste sent to disposal, for the period of time after the project is fully implemented. 2.5.6.2 Determine the difference, in amount of reduction, between the estimated benefit and actual benefit. 2.5.6.3 If the benefits were over-estimated, select the next most cost effective idea from the opportunity assessment to include in the program. If benefits are consistently under-estimated, consider deleting the least cost-effective project from the program if it appears the project will not be needed to meet the goal. How well the program will allow the installation to meet its goals depends on how faithfully the program is adjusted to match the remaining requirement.


3. PROGRAM COMPONENTS

3.1 OVERVIEW Pollution prevention addresses the reduction and recycling of ozone depleting chemicals, EPA 17 target chemicals, hazardous waste/industrial waste, municipal solid waste, affirmative procurement and energy conservation. The purpose of this chapter is to discuss in detail each of these program elements. MAJCOMs are to establish a pollution prevention program that crosses functional areas to meet these AF goals and objectives. The following discussion addresses, as appropriate, the unique aspects of each of these program areas, typical uses, and typical opportunities for reduction in use or recycling. 3.2 OZONE DEPLETING CHEMICALS (ODCs) 3.2.1 Goals. Air Force Pollution Prevention Goals concerning ODCs: - Cease purchases of Halon (Class I ODCs) by 1 Jun 93 - Cease purchasing air conditioners, Aerospace Ground Equipment (AGE) and other refrigeration and support equipment containing Class I chlorofluorocarbons (CFCs) after 1 Jan 93 - Cease purchasing commercial vehicles with ODC air conditioning equipment after 1 Jun 93 - Cease purchasing newly produced Class I CFC refrigerants by 1 Jun 93 - Cease awarding contracts requiring use of ODCs by 1 Jun 93 - Cease purchasing solvents containing Class I CFCs after 1 Apr 94 3.2.2 Overview. ODCs are substances that deplete the earth's stratospheric ozone layer, and contribute significantly to greenhouse warming. Some examples include CFCs and hydrochlorofluorocarbons (HCFCs) which are used in ground air conditioning and refrigerant systems, automobile air conditioning systems, cleaning solvents and aerosol sprays. Another class of ODCs is Halon. Halons are primarily used in fire suppression systems and for vector control in some missile systems. Other controlled substances include carbon tetrachloride and Methyl Chloroform, which are used primarily as


cleaning solvents and methyl bromide, which is used as a pesticide and fumigant. Table 3-1 identifies the Class I ODCs. 3.2.3 Directives. The Department of Defense (DoD) has established regulations and policies included in directive 6050.9 which outline steps required to comply with the Montreal Protocol (Sep 87), the Copenhagen-amended Montreal Protocol (1992), the Clean Air Act (CAA) of 1990, and the National Defense Authorization Act for FY 1993. These laws/acts restrict the production, purchase and use of Class I ODCs listed in Table 3-1. See section 3.2.11 for suggested reading materials for these specific acts and regulations. 3.2.4 Halons. The purchase of newly produced Halons or obtaining Halon through the defense reserve (Defense Logistics Agency [DLA] Bank), without an approved waiver, is prohibited (See section 3.2.8 on waivers). MAJCOMs may request waivers for mission critical Halon applications. "Mission critical" is defined as those Halons used on board aircraft to meet flight safety, flight survivability, or flight certification requirements.

TABLE 3-1

OZONE LAYER DEPLETING CHEMICALS Halocarbon Number Chemical Name Primary Uses

CLASS I ODCs CFC-11 Trichlorofluoromethane 1, 2, 3, 4, 5 CFC-12 Dichlorodifluoromethane 1, 2, 4 CFC-113 Trichlorotrifluoroethane 2, 3, 4 CFC-114 Dichlorotetrafluoroethane 1, 2, 3, 4, 6 CFC-115 Chloropentafluoroethane 6 Halon 1211 Bromochlorodifluoromethane 3, 7 Halon 1301 Bromotrifluoromethane 1, 3, 5 Halon 2402 Dibromotetrafluoroethane 1, 3 CFC-13 Chlorotrifluoromethane 6, 7 CFC-111 Pentachlorofluoroethane 0 CFC-112 Tetrachlorodifluoroethane 4 CFC-211 Heptachlorofluoropropane 0 CFC-212 Hexachlorodifluoropropane 0


TABLE 3-1 (Cont.) OZONE LAYER DEPLETING CHEMICALS

Halocarbon Number Chemical Name Primary Uses CFC-213 Pentachlorotrifluoropropane 0 CFC-214 Tetrachlorotetrafluoropropane 0 CFC-215 Trichloropentafluoropropane 0 CFC-216 Dichlorohexafluoropropane 0 CFC-217 Chloroheptafluoropropane 0 Carbon Tetrachloride Tetrachloroethane 1, 4, 5, 8 Methyl Chloroform Trichloroethane (all isomers) 4, 5, 8 Methyl Bromide

4, 5, 8

CLASS II ODCs HCFC-21 Dichlorofluoromethane 1, 4 HCFC-22 Chlorodifluoromethane 1, 4, 5 HCFC-121 Tetrachlorofluoroethane 0 HCFC-122 Trichlorodifluoroethane 0 HCFC-123 Dichlorotrifluoroethane 1, 3 HCFC-124 Chlorotetrafluoroethane 1, 3 HCFC-131 Trichlorofluoroethane 0 HCFC-132 Dichlorodifluoroethane 0 HCFC-133 Chlorotrifluoroethane 0 HCFC-141 Dichlorofluoroethane 2 HCFC-142 Chlorodifluoroethane 1, 4, 5 The eight use categories are as follows: 1 Refrigeration: Air Conditioning 2 Blowing Agent for Plastics 3 Fire Extinguishing Agent 4 Solvent: Dry Cleaning Agent; Degreaser 5 Intermediate for Synthesis of Other Compounds 6 Dielectric Gas 7 Aerospace Chemical 8 Fumigant: Pesticide


0 An "0" in the use column indicates the compound has no practical use. These compounds occur as by-products or impurities in other ODCs and are not manufactured deliberately for any application. 3.2.5 Refrigerants. The purchase of facility air conditioning systems, aerospace ground equipment (AGE), other refrigeration and support equipment, and commercial vehicles that use Class I ODCs, without an approved waiver, is prohibited as of 1 Jan 93. Existing equipment presently being used will be phased out through normal attrition or conversion at scheduled overhaul. The determination of conversion or replacement is one of economics and should be based on life cycle costs. There is no requirement for change out or conversion for the sake of becoming "CFC" free. All weapons systems (pre Milestone III) shall be designed to use non-Class I ODC refrigerants. The purchase of newly produced ODC refrigerants without an approved waiver is prohibited as of 1 Jun 93. Refer to the 7 Jan 83 Action Memorandum, Air Force Ban on Purchases of ODCs, for further information. 3.2.5.1 Refrigerant Projects: The pollution prevention program will support the following projects with funding: - ODC recycling/reclaiming equipment - Chiller modifications for leak detection - Efficient purge hardware 3.2.5.2 Refrigerant Management Planning: The base Refrigerant Manager, located in the Base Civil Engineering organization, manages air conditioning/refrigerant equipment and regulated refrigerants through the use of a Refrigerant Management Plan (RMP). AFCESA/EN's Refrigerant Management Handbook focuses on conservation measures and the development of the RMP. Conservation measures include improved servicing techniques, training and certifying technicians, and recording equipment maintenance and refrigerant usage. The RMP provides a plan to ensure adequate refrigerant supplies will be available to meet mission needs until the last of the units using CFC refrigerants have achieved their full economic life. The RMP provides a refrigerant inventory timeline that shows refrigerant consumption rates, equipment retirements, and other activities which affect the inventory of refrigerant. An implementation schedule is part of the RMP. A simple comparison of a plan's projected refrigerant inventory quantity versus what is


actually on-hand will determine whether the base is in danger of a negative mission impact. 3.2.6 Solvents. Effective 1 Apr 94, the purchase of ODC solvents and equipment/systems/products requiring ODC solvents for maintenance or operation is prohibited. Any new or modified system may not include the use of ODCs unless approved by SAF/AQ. No solvent uses are considered mission critical. 3.2.7 Procurement Contracts. Contracts awarded on or after 1 Jun 93 must not include specifications or standards that require the use or that only can be met by the use of Class I ODCs, unless an exception is approved. SAF/AQ, HQ USAF/LG and HQ USAF/CE are the approval authorities for their respective areas. 3.2.8 Waivers. In the National Defense Authorization Act for FY 1993 (P. L. 102-484) waivers are permitted for the purpose of extending time to develop and implement ODC alternatives. Waivers are not required for ODCs currently in stock or use. Waiver approvals are required: - prior to award of any contract that requires the use of a Class I ODC; - prior to purchase of any Class I ODCs; - prior to obtaining Class I ODCs from the Defense Reserve DLA ODC bank for mission critical applications. 3.2.9 Tracking and Reporting. ODCs are tracked in quantities of lbs used/quarter or lbs purchased/quarter. The WIMS-ES Pollution Prevention module reports ODCs in lbs/quarter. Installations report ODC quantities to their MAJCOMs as determined by the MAJCOMs. 3.2.10 Alternative Chemicals. Substitute chemicals to replace ODCs must be chosen with care. Alternatives which are hazardous or are Class II ODCs may be used only as a last resort after all other environmentally preferable alternatives have been evaluated and rejected for technical or economic reasons. EPA has the authority to identify and restrict the use of substitutes for Class I and II ODCs where other alternatives exist that reduce overall risk to human health and the environment. The program that would provide these determinations is the Significant New Alternatives Policy (SNAP) Program.


Proposed rules for the SNAP Program were issued in the May 12, 1993 Federal Register. Under SNAP, EPA can approve or disapprove the use of chemicals, product substitutes, or alternative manufacturing processes, whether existing or new. The proposed rule includes detailed listings of acceptable substitutes, unacceptable substitutes, and pending decisions for the following "use sectors": refrigerants, foams, solvent cleaning, halons, sterilants, aerosols, tobacco expansion, and adhesives/coatings/inks. The listings are 28 pages long, which prevents their inclusion here. At this time, these are the only "use sectors" covered by SNAP. Small-use ODC applications, other than the eight previously listed, are excluded. Once the final SNAP rule is issued, EPA will publish quarterly updates to the SNAP lists in the Federal Register. 3.2.11 Additional Resources. Additional information and details concerning ODCs, Halons, refrigerants, solvents, etc. may be obtained by consulting the following documents: - AFI 32-7080; - Action Memorandum, Air Force Ban on Purchases of ODCs, 7 Jan 93; - Air Force ODC Interim Waiver Application, Approval Procedures, and Reporting Requirements, 14 Jul 93; - EO 12843, Procurement Requirements and Policies for Federal Agencies for Ozone Depleting Substances, 21 Apr 93, Office of the Press Secretary; - Guidance for Eliminating the Use of Class I ODCs in Military Procurement Contracts, 20 May 93, Department of Defense; - Interim Air Force Contracting Policy for Elimination of Class I ODCs, SAF/AQC, 26 May 93; - Procedures for Returning ODCs to the Defense Reserve, DLA, 18 Aug 93 (updated version is expected out in Aug 94) ; - Class I and II ODCs, Federal Register (57 Fed Reg. 33753), 30 Jul 92; - Refrigerant Management Handbook, AFCESA Systems Engineering; - Draft Significant New Alternatives Policy (SNAP), EPA, May 12, 1993 Federal Register 3.3 EPA 17 TARGET CHEMICALS


3.3.1 Goal. By the end of 1996, the AF goal is to reduce purchase of EPA 17 Industrial Toxics by 50% (EPA 33/50 Program) from a 1992 baseline. The policy will be assessed by measuring the weight in pounds of substance purchased compared to CY92 baseline. 3.3.2 Background. EPA has selected seventeen target chemicals for reduction or elimination of their use based on the volume of use, toxicity, persistence, and mobility. These chemicals were drawn from the Toxic Release Inventory (TRI) List in the Superfund Amendments and Reauthorization Act (SARA) Title III and given the highest priority for reduction or elimination based on the hazards they can present to workers, the public, and the environment. The EPA 33/50 Program is a voluntary pollution prevention initiative to reduce national pollution releases and off-site transfers of 17 toxic chemicals by 33 percent by the end of 1992 and by 50 percent by the end of 1995. The AF is committed to participation in this program, and monitors the reduction of these constituents at AF installations through the EPA 17 industrial toxics reduction program. 3.3.3 EPA 17 Target Chemicals and Typical Uses. Table 4-2 identifies the EPA 17 chemicals and typical processes and/or uses for these chemicals at AF installations. 3.3.5 Typical Opportunities. Potential reduction/recycle methods are described briefly below. This discussion provides some of the more common methods available to reduce the use of EPA 17 chemicals or recycle those that are being used. Remember that prior to making any substitution for chemicals used in a process, concurrence of the owner of any applicable Technical Orders (TOs) must be obtained. 3.3.5.1 Physical Removal of Paint: The substitution of chemical stripper with media blasting or other physical methods of paint removal such as sanding with vacuum capabilities. This opportunity for pollution prevention can be applied to the following EPA 17 chemicals: benzene; toluene; xylene; dichloromethane; methyl ethyl ketone (MEK); and methyl isobutyl ketone (MIBK). 3.3.5.2 Recycling: Although the Air Force's EPA 17 reduction goals exempt jet fuels, recycling of other petroleum products and plastics helps reduce the purchase of materials containing benzene and toluene. For benzene the recycling of tires is also applicable, in two ways. Using retread tires saves production of new tires from benzene-containing


petroleum products, and burning old tires for energy saves the use of fuel oils which contain benzene. 3.3.5.3 Parts Washers: The use of parts washers using an aqueous base soap and water rather than solvents as replacement for degreasers. This opportunity can be applied to: toluene; xylene; carbon tetrachloride; chloroform; dichloromethane; trichlorethane (TCA); trichloroethylene (TCE); tetrachloroethylene (PCE); MEK; and MIBK. Hot water and citric-based compounds can also be used as a substitute for MEK and MIBK degreasers. 3.3.5.4 Product Substitution: There are many opportunities to substitute other materials as a form of source reduction for all EPA 17 chemicals. Opportunities include avoiding the use of canisters which contain fluorocarbons to reduce the use of chloroform, and substitute solvents to replace TCA, TCE, PCE, MEK, and MIBK. 3.3.5.5 Opportunities for the Inorganics: Reduction opportunities for the inorganic chemicals include reducing the amount of water used in electroplating, to concentrate the cadmium, chromium and nickel, then remove them through precipitation, evaporation, etc. from the waste water. The cadmium, chromium and nickel can then be reused or recycled. Reduction in the use of cyanide can be achieved though avoiding its use in electroplating compounds. Reduction in mercury use can be achieved through substitution of other chemicals. Lead usage can also be reduced through the avoidance of lead containing paint and solder.

TABLE 3-2 THE EPA 17 TARGET CHEMICAL LIST AND TYPICAL USES

ORGANICS TYPICAL USES Benzene Fuels, solvents, inks, paint thinner,

component in plastics and tires Toluene Solvent in paints and coatings, fuels,

cleaning agents, plastics Xylene (includes ortho-, meta-, and para-) Solvent in paints and coatings, cleaning

agents, fuels Carbon Tetrachloride Bearing cleaning and PMEL


Chloroform Cleaning agents in Bearing shop, present in fluorocarbons


TABLE 3-2 (Cont.) THE EPA 17 TARGET CHEMICAL LIST AND TYPICAL USES

Dichloromethane (methylene chloride) Wipe down cleaner, paint stripper, foam blowing

1,1,1 Trichloroethane (1,1,1-TCA) Parts cleaning, degreasing Trichloroethylene (TCE) Degreasing, paints Perchloroethylene (PCE) Degreasing, dry cleaning Methyl Ethyl Ketone (MEK) Paints, cleaning agents adhesives, inks,

gun cleaning, thinners Methyl Isobutyl Ketone (MIBK) Paints, cleaning agents INORGANICS TYPICAL USES Cadmium and Compounds Plating operations, batteries, pigments,

chemical cleaning Chromium and Compounds Plating and paint preparation Cyanide and Compounds Plating solutions Lead and Compounds Batteries, paint, sealing compounds, lead

solders Mercury and Compounds Laboratories, mercury vapor lamps,

thermostats Nickel and Compounds Plating operations, batteries, welding 3.3.6 Tracking and Reporting. The EPA 17 chemicals are tracked in quantities of lbs purchased/quarter and lbs purchased/year in the WIMS-ES Pollution Prevention module. Refer to the AFI 32-7002, Environmental Information Management System, for specific record keeping requirements. Record reporting suspense dates will be independently established by the MAJCOMs and HQ USAF/CEV. 3.4 Hazardous Waste/Industrial Waste 3.4.1 Goal. The objective is to reduce hazardous waste disposal 25% by the end of 1996 and 50% by the end of 1999 from the CY 92 baseline.


3.4.2 Tracking and Reporting. 3.4.2.1 AFI 32-7042, Solid and Hazardous Waste Compliance, requires automated reporting of hazardous waste from accumulation to disposal through the WIMS-ES Hazardous Waste Module. Hazardous waste is tracked in the following quantities: - lbs recycled/quarter - lbs treated/quarter - lbs disposed/quarter - cost/lb recycled/quarter - cost/lb treated/quarter - cost/lb disposed/quarter Refer to the AFI 32-7002, Environmental Information Management System, for specific record keeping requirements. Record reporting suspense dates will be independently established by the MAJCOMs and HQ USAF/CEV. 3.4.2.2 Hazardous waste disposal quantities are reported in pounds and includes all hazardous waste disposal through the installation (via contract, Defense Reutilization and Marketing Office (DRMO), etc.). Hazardous waste accepted from offsite facilities should not be included in the installation's figures. If an installation's state regulates used oil as a hazardous waste, disposal figures should be considered a reportable quantity. Wastes removed or treated under the Defense Environmental Restoration Account (DERA) program do not count toward total hazardous waste quantities included in baselines. 3.4.2.3 Disposal information can be obtained from the documents listed below and should be reported through the WIMS-ES Hazardous Waste Management Program module. Currently there is no standardized automated tracking program for compiling the HW disposal quantities. - Hazardous Waste Disposal Manifests - include all disposal contracts, e.g., Safety Kleen, DRMO, installation contracts. (Note: if certificate of destruction or treatment codes on HW manifest indicate recycling or fuels reblending, the item should not be reported as disposed.)


- Annual federal and state hazardous waste disposal summaries generated at the installation. 3.4.3 Processes Generating Hazardous Waste. Hazardous waste is generated through many processes typical to most Air Force installations. However, identification of new hazardous waste streams is ongoing and requires constant attention. The WIMS-ES Waste Stream Program is a tool developed to record individual waste stream data and allows for electronic transfer of the information to MAJCOM and Air Staff. This provides a crossfeed mechanism as the waste stream may not have been identified at other installations. Processes with associated hazardous waste streams typical to all installations are listed in Table 3-3. Installations should also cross check these processes with their opportunity assessments to ensure all waste streams have been identified. 3.4.4 Typical Hazardous Waste Reduction Opportunities. Opportunities exist in almost all processes to reduce and/or eliminate hazardous waste generation. Each installation should conduct opportunity assessments to define current waste management practices, characterize existing waste streams and assess actions needed to reduce and/or eliminate waste. Assessments should be done at all facilities on base as appropriate toward reaching the pollution prevention goals. See Chapter 2, Pollution Prevention as a Process, for additional information on opportunity assessments. 3.4.4.1 Waste Segregation: Waste Segregation is a simple opportunity that should be practiced at all installations. Physical segregation of hazardous and non-hazardous waste streams increases waste minimization effort capabilities, such as recycling, and it also decreases the costs associated with waste disposal. It is easily achieved by recurring hazardous waste management and awareness training and the use of good waste handling techniques. Waste streams must be properly classified in order for them to be properly segregated. Refer to your installation hazardous waste management plan and hazardous waste program manager for more information. 3.4.4.2 Waste Minimization: Minimization opportunities focus on source reduction or recycling activities that reduce either (or both) the volume or the toxicity of hazardous waste generated. Waste treatment is another option that may be considered, however, it is the least favored alternative. Treatment is typically performed downstream of the source


on a waste stream generated by various facilities. Additionally, it normally requires regulatory notification and/or permitting. A list of some hazardous waste minimization opportunities is presented in Table 3-3. Recycling refers to the use or reuse of a waste as an effective substitute for a commercial product, or as an ingredient or feed stock in an industrial process. Federal and local regulatory requirements dictate how reuse of waste materials must be used in order to qualify as recycling. (See section 3.4.6). Source reduction refers to the reduction or elimination of waste generation at the source, usually within a process. The Hazardous Material Pharmacy concept, discussed in more detail in Section 4.5, provides a mechanism for hazardous material source reduction through purchasing controls and inventory management of hazardous materials. This in turn results in less hazardous material becoming hazardous waste. 3.4.5 Additional Resources. 3.4.5.1 Source Reduction Resources: Each AF base is faced with the need to develop a list of specific HW minimization techniques to achieve the HW disposal reduction goal. The first source is in-house input from personnel including operations and maintenance workers, supervisors, engineers, and others with first hand knowledge of the base operations. Other references that document source reduction methods are listed below. - AF Waste Minimization Program Reports - Other installations with existing waste minimization programs - U. S. Environmental Protection Agency (U.S. EPA) Publications, databases (Pollution Prevention Information Clearinghouse), technical references - Air Force Center for Environmental Excellence - -- PRO-ACT Environmental Information Clearinghouse (DSN 240-4214) -- "Commander's Guide to the Implementation of the Hazardous Materials Pharmacy", 1994 version (available from PRO-ACT) - Opportunity Assessments - State and local environmental agency publications - Published literature, journals, technical papers - Equipment vendors and suppliers - Consultants - MAJCOM Cross feeds - Technology Transfer


3.4.5.2 Hazardous Waste Program References: Other references providing guidance and execution of the overall hazardous waste program listed below. - AFI 32-7042, Solid and Hazardous Waste Compliance - Base Hazardous Waste Management Plan 3.4.6 On-Site Recycling/Reuse of Hazardous Waste The regulatory requirements of recycling hazardous waste onsite must be considered. Recycling decreases the volume of waste that may be considered hazardous and it may exempt the waste from consideration under RCRA. However, institution of onsite recycling activities involves many site-specific and waste-specific factors including the type, rate, and frequency of waste generation; the concentration of contaminants in the waste; and the value of the recycled material. There are also many off-site factors that may affect the implementation of an onsite recycling program. Off-site factors include: regulatory limitations; base location; markets for recycled materials; and waste acceptance criteria by recycling facility (where recycled products are segregated on base and shipped to off-base recycling facility). Several recycling practices may be implemented at a base to reduce the volumes of hazardous waste generated. These methods include: - Establishing an internal clearinghouse for excess inventory, expired or near

expired shelf life hazardous materials, and recoverable wastes (through Hazardous Material Pharmacy or other means) - Identifying recoverable used materials - Installing closed loop systems where hazardous wastes generated in a given

process are reused in that same process


TABLE 3-3 TYPICAL PROCESSES/OPPORTUNITIES

Hazardous Waste Typical Industrial Hazardous Minimization/Source Operation or Process Waste Generated Reduction Opportunities Metal working/ Coolants; quenching Filtration Work heat treating oils; salt baths Centrifuge for reuse Fuel supplements Painting Thinners; heavy metals; Process change polyurethanes; - airless sprays wastewater - powders - water base primers - HVLP spray guns Segregation Replace water curtain with dry filters in spray booth Solvent substitution Paint substitution Waste MEK Recycle solvents Enzyme wipes Alodine/Chromic Acid On-site treatment (Hexavalent chrome to trivalent chrome) Rags Dry cleaning system Paint Booth Filters Dissolvable filters Less frequent filter changes (do not compromise air emissions) Paint booth baffles


TABLE 3-3 (Cont.) TYPICAL PROCESSES/OPPORTUNITIES

Typical Industrial Hazardous Hazardous Waste Operation or Process Waste Generated Minimization Opportunities Aerosol Cans Empty and puncture cans, then recycle with scrap metal contract

Fluids change out/ Oils; lubricants; Fuel supplements transport vehicle coolants; petroleum; Waste segregation maintenance alcohols Good housekeeping Recycling & Recovery Fuel filters Contact manufacturer for reuse Oil filters Crush and drain, recycle oil, recycle filters with scrap metal contract Cleaning, degreasing, Solvents; detergents; Fuel supplements metal preparation ketones; freon; alkalis; Recovery heavy metals Substitution Jet Washers Filtration Chemical rejuvenation Electrical/electronic Heavy metals; poly- No-clean maintenance chlorinated biphenyls; Substitution solvents; freon Freeze guns



Typical Industrial Hazardous Hazardous Waste Operation or Process Waste Generated Minimization Opportunities Stripping Solvents; caustics Process change: - dry media blasting (plastic beads) - water jet - soda bicarbonate blasting Review stripping schedule ` Reduce # of planes stripped/year Reduce # times plane must be stripped

Metal plating/ Acids; bases; metal Process change: finishing rinses - aluminum coating by ion vapor depositing - discharge hard chrome plating - fume suppressants - proprietary solutions Industrial waste treatment - neutralization - ion exchange - electrolyte precipitation - non cyanide baths Battery shop operations Acids; bases; cyanides; Neutralization heavy metals Battery contractors will accept w/o draining fluids



Typical Industrial Hazardous Hazardous Waste Operation or Process Waste Generated Minimization Opportunities Battery repair and Heavy metals, acids Reclamation replacement Neutralization Laboratory operations Spent, used, expired Material control chemicals; silver Industrial or domestic waste- (photography) water treatment Bulk Petroleum, Oils, and Water contaminated w/ Install covers on tanks Lubricants (POL) Storage benzene On-site carbon absorption treatment

3.5 MUNICIPAL SOLID WASTE 3.5.1 Reducing Solid Waste Disposal. The goal for this program component calls for reducing solid waste disposal 50% by 1997 based on a 1992 baseline. Interim objectives call for a 10% reduction by 1993 and a 30% reduction by 1996. 3.5.2 Typical Processes. The AF's solid waste management system consists of all facilities, equipment and procedures used to collect, store, transport, and dispose a base's solid waste stream. It also includes the facilities, equipment and procedures used to process and market the recyclable, compostable or treatable components of the solid waste stream. The Air Forces solid waste management system extends off base to facilities, equipment and procedures available from commercial and municipal solid waste management providers, that are used by the Air Force. 3.5.2.1 Refuse Collection and Disposal: Refuse collection and disposal are performed almost exclusively by service contracts at AF installations. Separate contracts usually exist for the main base ( i.e. the industrial, commercial and administrative sector of the base) and military family housing (i.e., the residential sector of the base). These contracts should also allow for bulk pick up of solid waste generated from specific events or


processes The majority of solid waste generated by a base is collected and disposed via a service contract. 3.5.2.1.1 Yard waste may or may not be separated out from the main base and military family housing refuse collection and disposal contracts, depending on installation specific policy. Yard waste is generated from grounds maintenance, tree trimming contracts, and yard maintenance in military family housing. Some installations have begun to divert yard waste into composting operations on base. 3.5.2.1.2 Only a few bases maintain and operate their own sanitary landfill. Most bases dispose of their refuse at commercial or municipal facilities. 3.5.2.2 Recycling: Each installation will have a Qualified Recycling Program (QRP). The installation commander is responsible for the organization and operation of the QRP. Requirements are included in AFI 32-7080. Each QRP will have a designated program manager to be the single point of contact for all aspects of the program, including: solid waste reduction and reporting, composting, affirmative procurement reporting, environmental compliance, and education. The QRP will be an umbrella organization, consisting of up to four separate activities involved with recycling: an appropriated funded activity; a nonappropriated funds (Services) operation; Army Air Force Exchange Service (AAFES) section; and a Defense Commissary Agency (DeCA) portion. All of these groups are required to report their recycling data to the QRP manager. Services, AAFES and DeCA will be given the money earned from the sales of their materials to offset expenses. Recycling proceeds from the Defense Reutilization Marketing Service (DRMS) and appropriated funds activities will disburse proceeds in accordance with the policy in AFI 32-7080. DoD recycling policy and AF recycling guidance provide the boundary lines to establish a QRP. The installations decide on the methods to effectively and efficiently recycle. The installation commander must determine the most effective arrangement between appropriated and nonappropriated groups. The lines defining each group must be clearly marked and understood by all the principles. The 1992 solid waste baseline established that the AF recycled 11% of its solid waste stream. This is due primarily to Services spearheading efforts as a means to increase


revenues for their programs. However, the increased costs associated with capturing 30% to 50% of the waste stream will require innovative ideas and teamwork from the recycling groups. 3.5.3 Basic Strategy for Reducing Solid Waste Disposal. 3.5.3.1 Strategy: There are two primary ways to reduce solid waste disposal. One is to directly reduce disposal by reducing the amount of waste generated (e.g., source reduction) . The other is to indirectly reduce disposal by diverting the solid waste stream to a process such as recycling or composting. Source reduction is the preferred solid waste management alternative for reducing solid waste. The 1992 solid waste baseline established the reference point for monitoring the solid waste stream for reductions in waste generation. Meeting the 50% reduction objective will require a combination of source reduction, reuse, recycling, and composting. Each QRP manager must analyze the existing base waste stream and determine the most effective combination of methods. 3.5.3.2 Service Contracts: Draft guidance for preparing criteria and specifications for performance work statements was issued by HQ AFCESA/ENM to MAJCOM CE organizations on 9 Mar 94, with the final guidance scheduled for release in Aug 94. The pollution prevention manager will need to work closely with service contracts personnel to assure that the solid waste reduction strategy is fully represented in the terms and conditions of the service contract (See Chapter 5, Team Building). 3.5.3.3 Paper: Paper, by weight, makes up over 40% of the national solid waste stream. The preliminary detailed characterizations of the solid waste stream conducted at AF installations indicate that the AF's waste composition is consistent with, although somewhat higher than, the national average for paper. Thus, paper presents an ideal target of opportunity to achieve reductions in waste disposal at AF installations.

Paper alone may not be the optimal component of the solid waste stream to recycle either in terms of meeting the solid waste reduction objectives or operating a cost effective program. Each installation must analyze its waste stream and determine the best opportunities. There are many dependable references that can be consulted concerning


what components of the waste stream to recycle. For reference, the 1992 baseline revealed that the AF was recycling the following components at measurable levels: aluminum cans, steel cans, cardboard, newspapers, high grade paper, glass, plastics, wood, ferrous scrap, nonferrous scrap and tires. 3.5.3.4 Composting: Yard Waste, by weight, may make up to 20% of the solid waste stream at an AF installation. Yard waste composting offers the opportunity to achieve a significant reduction in solid waste disposal at a low level of technology and investment. However, processing other components of the waste stream, such as food waste or other organic materials through composting, may potentially require a significant investment in higher technology operations. These areas should still be evaluated for their potential reduction capabilities. Investing in a high level performance composting operation may be warranted for some bases based on potential benefits. 3.5.3.5 Other Waste Reduction Options: Some installations will be uniquely situated to take advantage of high technology recycling facilities, waste-energy facilities or municipal waste incinerators that are part of the local waste management system to recycle or reduce their solid waste stream. Specific protocols will be established by either the EPA or the Air Force to determine how waste reduction credits will be accounted for when using these type of operations. Also, the construction and operation of these types of facilities on base may be economically viable under select circumstances. 3.5.4 Programs. The reduction of solid waste disposal must be conducted in accordance with all applicable public law, Executive Order (EO), and Department of Defense (DoD) and regulatory guidance. DoD Recycling Policy, 28 Sep 93, and Air Force Recycling Guidance, 24 Mar 94 (incorporated in AFI 32-7080) provide policy guidance on setting up a QRP. Education and feedback are important elements of a recycling program. Increasing the participants awareness of their role in using the recycling collection system established at their base and providing them feedback on how they are doing will improve the chances of operating a successful program.


3.5.5 Tracking and Reporting. 3.5.5.1 Refer to AFI 32-7002, Environmental Information Management, Pollution Prevention Module System, for specific record keeping requirements for reporting progress in solid waste reduction. Solid waste is tracked in the following quantities: - lbs recycled/quarter and expenses and revenue - lbs composted/quarter and expenses and revenue - lbs incinerated/quarter and expenses - lbs landfilled/quarter and expenses - lbs sent for energy recovery Record reporting suspense dates will be independently established by the MAJCOMs for the installations and MAJCOMs report to HQ USAF/CEV 1 Aug of each year. 3.5.5.2. Tracking progress in meeting the solid waste disposal reduction objectives will require a cumulative accounting of the total amount of solid waste disposed and the total amount of the solid waste stream that is diverted into recycling, composting or other waste reducing processes. 3.4.5.3 Obtaining data required to report on solid waste reduction will require making contact with the different offices that keep operating records on solid waste management. The QRP manager is responsible for gathering and reporting data on installation recycling operations. Grounds maintenance maintains records related to yard waste generation. The pollution prevention manager will need to work with these and other offices to assure that the data is available in a form useful for input into WIMS-ES. 3.6 AFFIRMATIVE PROCUREMENT 3.6.1 Goals. Affirmative procurement is the purchase of supplies and services using recycled products and minimizing the amount of waste generated. One of the problems facing recycling is creating a market for products made from recycled materials. Today, these products rival virgin products in quality and cost, yet their market remains largely untapped. The stimulus of government procurement can help close the recycling loop by encouraging market demand for recovered materials.


The AF Pollution Prevention Action Plan included the affirmative procurement goal that by the end of 1993, at least 10% of all non paper products and 50% of all paper products procured should contain recycled material. However, this goal has been broadened by the recent introduction of EO 12873. Air Force policy as expressed in AFI 32-7080 requires MAJCOMs to establish procurement programs for all EPA guideline items. 3.6.2 Tracking and Reporting. The U.S. EPA designated specific items that shall contain recycled materials for federal procurement. Current U.S. EPA guideline items are: paper and paper products, lubricating oil, retread tires, building insulation products, and cement and concrete containing fly ash. In the April 20, 1994 Federal Register, EPA proposed to modify the paper and paper products category, and to add guideline items in the following categories: vehicular products, construction products, transportation products, park and recreation products, landscaping products, and non-paper office products. However, this proposed rule has not been finalized as of the date of publication of this guide. Each installation is required to collect data for U.S. EPA guideline items which are locally purchased or provided through construction contracts administered by the installation. The General Services Administration (GSA), Defense Logistics Agency (DLA), or similar contracting services will report products they obtain directly to the Federal Environmental Executive. Each installation is required to report the total value of the product purchased and the total value of the product purchased that met the guideline criteria. The installation is required to explain the reasons for any difference between these two numbers (e.g., is not available competitively, does not meet performance standards). Reports are required quarterly on the Affirmative Procurement screens of the Pollution Prevention module in WIMS-ES. Refer to the AFI 32-7002, Environmental Information Management System, for specific record keeping requirements. Record reporting suspense dates will be independently established by the MAJCOMs for the installations and MAJCOMs report to HQ USAF/CEV 15 Dec of each year. Local contracting offices will collect the data and provide to civil engineering for reporting in WIMS-ES. AF policy is included in AFI 32-7080. Instructions to implement these requirements will be issued sometime in 1994. These include an AF supplement to the Federal Acquisition


Regulations and detailed procedures for collecting and reporting data (WIMS-ES is the vehicle for reporting). 3.6.3 Typical Processes/Opportunities. Installations must establish an aggressive affirmative procurement program to meet Air Force goals. The following list of actions is intended to help installations establish an effective procurement program consistent with our goals. This list of examples should not be a limitation, instead, use it to generate ideas and actions unique to your installation. Each action is followed by the office(s) typically responsible for initiating any changes. 3.6.3.1 Review and revise specifications for the designated items not only to eliminate requirements for newly produced raw material, but to give preference to recycled material. (Contracting, Civil Engineering) 3.6.3.2 Require recycled content in all writing and copy paper. (Contracting, Supply, Defense Printing Service, Government Printing Office) 3.6.3.3 Establish preference procedures for chlorine free paper for paper products. (Contracting, Information Management, Defense Printing Service) 3.6.3.4 Require all paper deliverables be on recycled, chlorine-free paper and double-sided. (Contracting) 3.6.3.5 Require recycled letterhead paper. (Information Management, Defense Printing Service) 3.6.3.6 Require recycled newsprint in all base newspapers, news magazines, and base directories (Public Affairs) 3.6.3.7 Require all newly acquired/leased copy machines to be capable of using recycled paper and automatically producing two sided copies. (Contracting) 3.6.3.8 Require recycled toner cartridges for copy machines and laser printers (Information Management)


3.6.3.9 Require documents to be transferred electronically where possible. (Contracting, Information Management, all base organizations) 3.6.3.10 Specify building insulation with recycled content. (Civil Engineering and Contracting) 3.6.3.11 Specify concrete and cement with fly ash, including items such as concrete pipe and block (Civil Engineering and Contracting) 3.6.3.12 Specify re-refined oil for lubricating oil purposes. (Civil Engineering, Transportation) 3.6.3.13 Specify retread tires for all vehicles approved for retread use. (Transportation) 3.6.3.14 Exhaust existing supplies of non-recycled products before using new recycled products. (All) 3.6.4 Unique Aspects. The absence of regulators, inspectors, fines, and health and safety risks make affirmative procurement the most unique component of the pollution prevention program. Many issues such as coding recycled products for tracking, reviewing performance standards of recycled products, and revising procurement procedures require a coordinated effort among personnel outside the typical pollution prevention arena. In particular, close coordination with procurement personnel is essential to successful implementation of the affirmative procurement program. As a result, installations should consider establishing a team through the Pollution Prevention Working Group to address the issues unique to Affirmative Procurement. 3.6.5 Exceptions. Installations may choose not to purchase a guideline item containing recycled materials if: - Price is unreasonable - Items are not readily available (resulting in unusual and unreasonable delays) - All reasonable performance standards are not met. 3.6.6 Product Sources. When procuring products from General Services Administration (GSA), installations should identify products included in GSA's "Environmental Products


Guide" (an updated and expanded version of GSA's "Recycled Products Guide"). Numerous recycled products, in addition to letterhead and copy paper are available. For example: writing tablets, message forms, post-it notes, toilet tissue, paper towel products, computer paper, file folders, envelopes, napkins, and disposable cups. Contact the GSA Centralized Mailing List Service in Fort Worth, TX 76115, commercial (817) 334-5215 or DSN 739-7369, to obtain copies of the "Environmental Products Guide." 3.6.7 References. - Resource Conservation and Recovery Act, Section 6002 - 40 CFR Parts 247-253 - Comptroller General Decision No. B-238290 - Office of Federal Procurement Policy Ltr 92-4 - HQ USAF/CC and SAF Ltr, 25 Sep 92 - DASD (Production and Logistics) Memorandum, 3 Feb 93 - EO 12873, Federal Acquisition, Recycling, and Waste Prevention, 20 Oct 93 3.7 ENERGY CONSERVATION 3.7.1 Goals. The AF goal to reduce facility energy (natural gas, coal, electricity, fuel oil, etc.) is 10% by 1995, 20% by 2000, and 25% by 2005 on a BTU/sq ft basis, with 1985 consumption as the baseline. Data input by MAJCOMs and bases into the Defense Utility Energy Reporting System (DUERS), previously Defense Energy Information System (DEIS), is used to track progress toward the goals. These goals apply to the energy consumed within the facility (computers, appliances, equipment, etc.) not just the energy used to operate the facility (heating, air conditioning, lights, hot water, etc.) These goals mirror EO 12902, Energy Efficiency and Water Conservation at Federal Facilities, and the Energy Policy Act of 1992, which extends the energy conservation goals of the Federal Energy Management Improvement Act (FEMIA) of 1988. Reduced energy consumption equates directly to pollution avoidance. 3.7.2 Background. Energy conservation reduces pollution through the reduction of greenhouse gas emissions, protection of the stratospheric ozone, and prevention of acid precipitation. As electricity is generated by burning fossil fuel or operating nuclear reactors, it produces emissions of trace metals such as beryllium, cadmium, chromium,


copper, manganese, mercury, nickel, and silver. Reducing energy generation decreases boiler ash, and scrubber and spent nuclear waste. It also lessens the need to mine and transport virgin fuels, and dispose of powerplant wastes. The Energy Policy Act of 1992 requires federal agencies to implement all energy measures which have a ten year payback by 2005. 3.7.3 Energy Program. Each base should have a designated Facility Energy Program Manager. This person is typically located in the Maintenance Engineering Flight of the Base Civil Engineer organization. The Air Force has provided information to help this person develop and manage an Energy Conservation Program. A DoD Energy Management Handbook, Volume I, Air Force Version was provided to all MAJCOMs and bases. An Energy Management Training course has also been offered to all base and MAJCOM Energy Managers. AFIT is also offering an Energy Management course. The Energy program should have two main thrusts - Energy Awareness and Energy Project Investment. Water conservation has been added to the energy program, but is not yet well defined. Energy Awareness simply means not using energy when it is not needed (i.e. turn off lights/equipment when not needed; buy energy efficient equipment when buying new or replacement products; don't leave windows and doors propped open when heating or cooling is needed). This thrust should not cause discomfort or inconvenience to the occupant of the facility, just use common sense on how and when energy is used. Be good stewards of energy and use it like you were paying the bill. Energy Project Investment is divided into three areas: government funds, utility company funds and private sector funds. Two special DoD programs, Energy Conservation Investment Program (ECIP) and Federal Energy Management Program (FEMP), have been provided by Congress to fund energy projects. Also, utility companies are offering rebates for installing energy efficient equipment and have Demand Side Management (DSM) programs to fund energy efficient equipment installation on their customers' facilities. Within the private sector many companies have developed programs such as Shared Energy Savings (SES) and Energy Savings Performance Contracting (ESP), that pay for installation of energy efficient equipment on a customer's facilities up front and they get paid out of the savings realized by the customer. Congress has provided special legislation to encourage government participation in these private sector programs.


3.7.4 Typical Opportunities. Conserving energy can be as easy as turning off a light or turning down the heat. Examples of conservation measures (from simple to more technical in nature) include: Low Cost/No Cost Measures - Turning off unneeded lights, computers, copiers, etc. - Reducing inside temperature - Insulating walls, ceilings, floors - Installing storm doors and windows - Installing weather stripping and caulking - Keeping furnace serviced - Plant shrubs around windy side of building to block wind and decrease heat loss from both conduction and convection Some Investment Required - Automatic energy control systems and associated equipment - Furnace modifications including replacement burners, furnaces and/or boilers - Cogeneration systems - Solar energy systems Load Reduction - - Reducing lighting level or use of energy efficient bulbs or fixtures, as encouraged by DOE's Federal Lighting Initiative or EPA's Green Lights Program, helps reduce electric and cooling loads. - Use of efficient computers (such as those that meet EPA's Energy Star Computer requirements) helps reduce cost of energy for personal computers and peripherals. Air Handling Opportunities - to reduce air handling energy and reduce cost of Variable Speed Drive (VSD) technology - Variable speed drive fan motor controls - Smaller, high-efficiency motors and fans - High-efficiency diffusers Chiller Plant Opportunities - to eliminate CFCs, reduce chilling energy, reduce reheat, reduce dehumidification costs, avoid disruption of service and reduce technology costs - Replace older inefficient chillers or retrofit with CFC substitute refrigerants


- VSD on compressor where appropriate - Downsize pump - VSD on pumps and cooling tower fans - Heat pipes and desiccant dehumidification - Thermal storage systems Heating - reduce electric resistance use and lower electric and thermal load. - - Heat recovery - Heat pumps - Gas - Solar space heating systems Hot Water - Improve thermal efficiency and reduce electric resistance use. - Heat recovery - Heat pumps - Cogeneration - Solar thermal water heaters Other - - Passive solar systems (wind energy devices, earth-sheltered buildings, etc.) 3.7.5 Unique Aspects. Lighting accounts for over 20 % of the total U.S. electricity consumption. Available technology can reduce the electricity used for lighting by 50-70 %. These efficient technologies also provide excellent investment opportunities. A typical lighting upgrade yields an internal rate of return of 20 to 30 %, a payback of about 3 to 4 years. The U.S. EPA's Green Lights Program and DOE's Federal Relighting Program encourage investment in energy-efficient lighting. Office equipment and creature comfort are the fastest-growing electricity load. Computer systems account for 5% of total commercial electricity consumption. The Energy Policy Act and EO 12759 require the purchase of efficient computers such as EPA's Energy Star Computers.


4. EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT (EPCRA)

4.1 Background On 3 August 1993, President Clinton signed EO 12856 requiring all federal agencies to comply with the Emergency Planning and Community Right-To-Know Act (EPCRA) and to commit federal agency planning, management, and acquisition resources to fulfill the intentions of the Pollution Prevention Act. In December 1984 a release of methyl isocyanate from the Union Carbide plant in Bhopal, India became the major stimulus behind the enactment of EPCRA. Among its provisions, this act requires industry to notify state and local emergency planning entities of the presence and quantities of hazardous materials at their facilities and to notify federal, state, and local authorities of inventories and releases of those substances. The EPCRA is a stand alone amendment to the Superfund Amendments and Reauthorization Act (SARA). Section 313 of EPCRA is of significant importance to Air Force installations. This section requires federal facilities to begin submitting yearly U.S. EPA Toxic Release Inventory (TRI) Reports beginning in July 1995. The first report will cover calendar year 1994. The Executive Order is not applicable to federal agency facilities outside the customs territory of the United States. The EO does not apply to GOCOs not within Standard Industrial Classification (SIC) codes 20-39, as these are not currently covered by TRI and the EO cannot create new legal obligations for private parties, although overall agency reports shall take into account such activities. Future contract revisions will require GOCOs to provide their agencies with the information necessary for TRI reporting. 4.2 Reporting The TRI report or Form R was initially intended to inform the public and government officials of routine releases to the environment of toxic chemicals. With passage of the Pollution Prevention Act of 1990, the Form R was expanded to include pollution prevention and waste minimization progress as well. Completion of a Form R will


require detailed transaction records, utilization and release data. The chemicals eligible for inclusion will be those listed on the TRI List (40 CFR 372.65) current as of 1 Dec 93. The chemical monitoring required under EO 12856 tracks substance use (as calculated above threshold quantities) throughout all departments at a facility (including what is vented, evaporated, and spilled). This provides a "blueprint" of the aggregate chemical handling at the site. All federal facilities meeting the EPCRA definition of "facility" and exceeding toxic chemical thresholds for: manufacture or import - 25,000 lbs/yr; process - 25,000 lbs/yr; otherwise use - 10,000 lbs/yr; must report under Section 313 of EPCRA, as amended by the Pollution Prevention Act. Reporting applies even if facilities do not fall within SIC codes 20-39. 4.3 Goals The EO mandates agencies set voluntary goals to achieve a 50% reduction in total releases and off-site transfers of TRI toxic chemicals by 1999. In addition, the EO directs each agency establish voluntary goals for the reduction in use of toxic chemicals at facilities and in products purchased or manufactured by federal agencies. Each facility is expected to identify its own reduction goals and prepare a written plan outlining how it will contribute to the 50% DoD-wide reduction goal. The PP MAP meets this requirement. 4.4 Tracking The signing of the EO provides an excellent platform to move from the tracking of toxic chemicals or hazardous materials to centrally controlling the inventory through a "pharmacy" or hazardous material control system. A central system provides opportunities to pursue the correctness of quantities, adequacy or availability of more environmentally friendly substitutes, and smallest possible units of issue, among other things. 4.5 Hazardous Material Pharmacy Commanders may wish to establish a hazardous material pharmacy. The pharmacy offers single-point and accountability over the requisitioning, receipt, repackaging, and issue of hazardous material and is analogous to the control over prescription drugs. Control of hazardous material can eliminate unnecessary purchases, diminish handling hazards, and


reduce hazardous waste disposal costs for unused, expired material. A pharmacy is composed of three activities: - Authorizing the request: Each request for hazardous material should be given a health and environmental impact review. Each request should also be reviewed by logistics for quantity, unit of issue, alternative sources of supply (currently available on installation, smaller quantity vendor) and current supply position. - Distributing or dispensing the material: Each receipt of material should be provided to the pharmacy user organization in a reasonable quantity and within a reasonable time. ("Reasonable" shall be defined in a memorandum or agreement/understanding between the pharmacy and the using organization). This activity may require a new facility. - Tracking and reporting: All material requested, received, issued, used, returned, and stocked on the installation needs to be recorded. To comply with EO 12856, toxic chemical data must be gathered, processed and reported on the Form R (when required). The "Commander's Guide to the Implementation of the Hazardous Materials Pharmacy", 1994 version (referenced in Section 3.4.5.1 and available from PRO-ACT) is a useful reference for installations establishing a pharmacy.


5. TEAM BUILDING AND IMPLEMENTATION

5.1 INTRODUCTION Assembling and organizing installation resources is a critical aspect of building a successful program. The following sections provide guidance for developing and maintaining your pollution prevention team and includes information on key organizational responsibilities, training, and recognition programs. 5.2 THE POLLUTION PREVENTION TEAM Effective implementation of a PPP at AF installations will require a coordinated and focused effort on the part of all AF personnel involved in the generation or handling of solid wastes and hazardous materials/wastes. While pollution prevention is everyone's responsibility, key players and organizations must plan, organize, initiate, and evaluate pollution prevention actions at each base. Well run programs are led by an active Environmental Protection Committee (EPC) with a strong Pollution Prevention Subcommittee. 5.2.1 Pollution Prevention Subcommittee (Working Group). The Pollution Prevention Subcommittee of the EPC typically proposes policy and recommends action to the EPC. The Working Group may undertake some of the actions normally executed by the Assessment Team, outlined below, but in most cases will direct and review the Assessment Team's activity. Subcommittee membership should include those groups or departments that have significant operational or administrative interest in development of the program. Typical organizations represented on the subcommittee include civil engineering, maintenance, supply, bioenvironmental engineering, operational contracting, public affairs, and legal. Table 5-1 summarizes the responsibilities of the Pollution Prevention Subcommittee. 5.2.2 Pollution Prevention Teams. Pollution Prevention Teams are typical components of the Pollution Prevention Subcommittee which focus on achieving specific goals, such as the hazardous waste reduction or affirmative procurement goals. Teams should be made up of five to seven shop chiefs and mid-level managers normally representing the CE/SG/LG communities. Team responsibilities are outlined in Table 5-2. They report to the Pollution Prevention


subcommittee on progress, initiatives, problems encountered, and other requirements. This step is crucial to the PPP's success as the overall working group cannot efficiently discuss, track and implement initiatives to meet all the goals of the program. Subcommittee personnel should stress the need for base personnel to be constantly looking for opportunities to reduce waste in their areas of expertise.

TABLE 5-1 RESPONSIBILITIES OF THE POLLUTION PREVENTION SUBCOMMITTEE

− Recommend overall installation program goals (supplement to AF goals) − Recommend/implement HM identification and tracking system − Recommend/implement a waste tracking system − Prioritize the waste streams, processes, or facility areas for assessment − Select pollution prevention and opportunity assessment teams − Provide training for assessment teams − Establish criteria for selecting options for implementation − Conduct (or supervise) assessments − Conduct (or monitor) technical/economic feasibility analyses of favorable options − Select options for implementation − Consolidate "Program" data for MAP (Project Narrative, Cost, ROI, Benefit, OPR) − Consolidate "Execution" data for MAP (Identify implementation steps, ECDs, OPRs) − Advocate funding − Monitor (and/or direct) implementation progress − Monitor performance of new option(s), once operational


− Monitor overall progress toward achieving the installation's Pollution Prevention goals and objectives


TABLE 5-2 RESPONSIBILITIES OF THE POLLUTION PREVENTION TEAMS

− Recommend implementation of policy − Ensure accurate baseline calculations − Identify pollution prevention goal requirements − Classify options generated by assessments − Generate recommended solutions − Select options for implementation − Establish "Program" data for MAP (Project Narrative, Cost, ROI, Benefit, OPR) for

each requirement − Establish "Execution" data for MAP (Identify implementation steps, ECDs, OPRs)

for each requirement − Identify funding mechanisms − Document (and/or direct) implementation progress − Document performance of new option(s), once operational − Document overall progress toward achieving the program area's Pollution Prevention

goals and objectives 5.3 TRAINING As with most environmental programs, training must be conducted routinely. Every individual at an installation requires some level of environmental awareness/pollution prevention training on a frequency needed to maintain proficiency. Information on training and funding of training can be obtained by contacting the education office personnel. The following are recommended courses/materials for base personnel.


5.3.1 AF Institute of Technology (AFIT) ENV 220, Pollution Prevention Course. This five day in-residence course provides an introduction to pollution prevention for key personnel involved in program management. The course focuses on management and roles and responsibilities. Attendees are typically program managers from the CE/SG/LG communities. AFIT funds attendance at courses through course allocations to MAJCOMs. 5.3.2 USAF School of Aerospace Medicine Pollution Prevention Technologies Course. This five day in-residence course provides an introduction to pollution prevention for key personnel involved in program management. It places more emphasis on computer aided instruction and software resources than the AFIT course. Attendees are typically program managers and team members from the CE/SG/LG communities. Attendees fund course attendance through base training programs. 5.3.3 AFCEE Opportunity Assessment Training Workshops. The Air Force Center for Environmental Excellence conducts three and four day opportunity assessment training courses at Air Force installations throughout the world. These workshops are designed for installation shop personnel and are typically attended by mid-level and senior NCO's, LG/SG/CE program managers, and installation leadership, such as EPC members. The course includes actual shop assessments done by the trainees. Workshops are typically funded through MAJCOMs and the Environmental Protection Agency with installations paying individual TDY costs. Individual installations have also funded the full course in order to provide training to base personnel. 5.3.4. Other Training Opportunities. Additional environmental training is available through a variety of sources. AFIT offers courses in Environmental Compliance Assessment and Management (ECAMP), Installation Restoration Program (IRP), AF/EPA Team Approach to Environmental Cleanup, Introduction to Environmental Management, Environmental Management Applications, Environmental Contracting, and Hazardous Waste Management. Information on courses offered by AFIT can be obtained by calling the Environmental Education Center at DSN 785-0381/2. The EPA and Army Corps of Engineers offer a broad range of courses which AF employees may attend. MAJCOMs provide many training courses via contractors. The DENIX environmental electronic bulletin board system contains a listing of training resources, in addition to information on Pollution Prevention and all other aspects of environmental management; see Chapter 8 for the point of contact to request a DENIX account. Training videos are available from city, state and Federal agencies on many topics. AFCEE/EP


is preparing a pollution prevention awareness video (expected to be available in early 1995) designed to inform all base personnel on environmental issues, and describe ways they can contribute to the Pollution Prevention program. 5.4 RECOGNITION OF PERSONNEL Good daily operating practices include paying attention to the human resources that are involved in program management and program execution. This includes recognizing individual and command achievements by implementing a recognition or reward program. On a monthly and an annual basis, awards may be given for ideas or suggestions that result in the reduction of quantity or toxicity of hazardous waste. Publicizing these awards by including them in the base paper will increase awareness. Contact your installation awards point of contact to establish program criteria.


6. PROGRAMMING AND BUDGETING 6.1 OVERVIEW Through proactive programming and budgeting, utilizing the WIMS-ES, the AF will fiscally position itself to meet pollution prevention goals, policies, and regulations for years to come. This chapter describes the pollution prevention budgeting process. 6.1.1 Pollution Prevention Budget Program. Pollution prevention requirements must be programmed and budgeted in accordance with the associated rules for each appropriation, such as military construction (3300). (See your resource advisor for more information in this area.) Since pollution prevention requirements span all functional areas in the AF, it is the responsibility of each functional area OPR to program and budget pollution prevention requirements identified by opportunity assessments and supported by corporate management boards at each facility, e.g., EPC, CE facility boards, etc. Civil engineering is the lead organization for consolidating, tracking, and managing the Pollution Prevention Program and budget. 6.1.2 Appropriations. Pollution prevention funds are available to meet requirements which span the AF budget with funding in such appropriations as: Military Construction (3300), Operations and Maintenance (3400), Research, Development, Test & Evaluation (RDT&E) (3600), Aircraft Procurement (3010), Missile Procurement (3020), and Other Procurement (3080). The AF Reserves and Air National Guard use their appropriations with the Air Force program element for pollution prevention. 6.1.3 Program Element Code (PEC). All pollution prevention requirements are in program element 78054. Refer to AFI 32-7080, Pollution Prevention Program, and AFI 32-7001, Environmental Budgeting, for further information. 6.2 POLLUTION PREVENTION PROGRAM BUDGET AND PRIORITIES Pollution prevention requirements are divided into recurring (Operations and Services) and non-recurring categories (Levels PI, PII, and PIII). Pollution Prevention Management Action Plans


must identify all waste streams, determine options for meeting AF goals, and summarize program funding requirements (see Appendix C for a sample MAP). The WIMS-ES Pollution Prevention Module includes required PP documentation for project implementation into the A-106 budgeting process. The Air Force does not fund any projects not listed in WIMS-ES (see Section 6.5 for further discussion). 6.2.1 Recurring Requirements - Pollution Prevention Operations and Services (O&S). Annual recurring "must do" services and projects associated with "keeping the gates open" such as manpower (O & S moneys for personnel can only be programmed to fund approved manning document positions), periodic updates of management plans, baseline survey updates, recurring operating costs associated with composting and recycling programs, education, training, travel and supplies, costs for pollution prevention tracking systems and hazardous material pharmacies, opportunity assessments, and identification of hazardous materials in technical documents. 6.2.2 Non-recurring Requirements: Non-recurring requirements are categorized into three funding levels as follows: 6.2.2.1 Level PI - ODC & Legal Requirements: This category includes non-recurring projects and services required to avoid ODC mission stoppages and fix pollution prevention requirements needed to support a Federal or DoD signed order/agreement, or correct legal deficiencies cited by a regulatory authority, or meet an existing regulatory requirement. 6.2.2.2 Level PII - Meet Future AF Goals/Policies & Legal Requirements: Includes projects required to meet future AF goals, policies and legal requirements. These projects represent situations in which existing operations, programs, and facilities meet current standards, but require action to meet future legal requirements and AF Pollution Prevention Action Plan goals, objectives and sub-objectives. 6.2.2.3 Level III - Beyond AF Goals & Legal Requirements: Level PIII projects and services are those which augment the base's pollution prevention activities, but go beyond DoD and AF goals and legal requirements.


6.3 POLLUTION PREVENTION PROGRAM ELIGIBILITY/EXCLUSIONS The following requirements are not eligible for pollution prevention funds. These include, but are not limited to: 6.3.1 Non-Environmental Projects. Projects which include environmental requirements in the scope but are primarily justified for non-environmental reasons. 6.3.2 Maintenance Projects. Requirements to remedy poor infrastructure maintenance. 6.3.3 Air Conditioning Projects. Projects to replace or retrofit air conditioning using CFCs with HCFCs, unless specific criteria in AFI 32-7001 are met. 6.3.4 Halon Projects. Projects to replace halon fire protection systems with non-halon systems. 6.3.5 Fire Extinguisher Projects. Projects to replace hand held halon fire extinguishers. 6.3.6 Depot-Level Equipment. The Defense Business Maintenance Area (DBMA) in the Defense Business Operations Fund has been established to pay for the replacement of depot-level equipment costing more than $25,000. Equipment meeting this definition should be budgeted through the DBMA capital asset budget. 6.3.7 Acquisition Projects. The PP program does not fund acquisition projects associated with any one acquisition program. 6.3.8 Energy Conservation MILCON Projects. Funded through a separate program. 6.3.9 Environmental Certifications and Licenses. The PP program does not fund certifications and licenses unless part of a mandatory training course. 6.4 LINE ITEM APPROVAL


Since pollution prevention is a new program, it is being held to line item approval through the Air Staff resource allocation process. 6.5 WIMS-ES Required pollution prevention documentation must be included in the WIMS-ES. WIMS-ES is a subsystem of Civil Engineering's WIMS computer system and is a computerized management information system for programming and budgeting environmental projects (see AFI 32-7002). WIMS-ES contains 13 modules, which are menus within the main program. Each module is specific to certain programs and waste types, such as the hazardous waste module, the air management module, the water and wastewater module, and the pollution prevention module. One positive aspect of this system is that it allows the base user to send data directly to the MAJCOM via the network, providing for near real-time transfer of data. WIMS-ES provides for daily transfer of data between bases, MAJCOMs, and the Air Staff, and is intended to be updated on an as-needed basis. The Federal Facility Pollution Abatement (A-106) is the "hub" of the WIMS-ES system. All other modules have at least one screen of data that feeds into A-106 for funding requirements. Every environmental funding requirement, whether part of the compliance, cleanup, conservation, or pollution prevention program, must have a record in the A-106 module. No new pollution prevention requirements can be submitted to HQ USAF/CEVV for advocacy in the budget cycle without a corresponding A-106 listing. Before an environmental project can be funded, it must be submitted and validated through the A-106 process. 6.5.1 WIMS-ES A-106 Module. The A-106 module is a database of all AF environmental requirements (past, present, and future) regardless of fund source (i.e., pollution prevention, environmental compliance, DERA, MILCON, DBMA). In addition to the A-106 module, the pollution prevention program uses the Pollution Prevention Module. The pollution prevention module will include additional data fields needed to manage projects and be accessible from the main menu. When the A-106 module is accessed from the pollution prevention module, data is transferred to the new A-106 record. A new pollution prevention requirement cannot be submitted in the pollution prevention module without a corresponding A-106 record. 6.5.1.1 Record Updates: A-106 records will reflect the current status of each project or requirement. When the Air Staff sends the annual A-106 report to the U.S. EPA, a copy of the


record sent to the EPA is placed in the "EPA File" (formerly called the History File). After that time, if the project status changes, the record must be modified and revalidated so the updated status can be reported to the EPA the following year. With the exception of "Continuous" projects, every project must eventually be modified to show a progress code of "Complete" or "Discontinued." Once that status has been sent to the EPA, the record is no longer modifiable. 6.5.2 Pollution Prevention Module. The Programming and Funding "sub-module" of the Pollution Prevention Module must be used to program requirements related to the pollution prevention program. Justification information and specific project details are required in this portion of the module. This module uses five programs: programming and funding, municipal solid waste, affirmative procurement, hazardous material purchases, and technical orders, military specifications and military standards (TOMM). A certain amount of data is required to be input into the pollution prevention module by each base in order to satisfy reporting requirements of the A-106 module. Requirements are discussed in more detail in the AFI and specific questions may be addressed to the systems administrator or the MAJCOM WIMS-ES systems administrator. 6.5.2.1 Adding New Records: A Programming record must be added for every A-106 record identified as a pollution prevention requirement. The A-106 record must be added first. A-106 records are intended to replace the "single page justification sheet" (MAJCOM decision) which have been submitted in the past for pollution prevention projects. 6.5.2.2 Record Updates: Programming and funding records must be modified to reflect the current status of each requirement.


7. TECHNOLOGY NEEDS

7.1 OVERVIEW Air Force Material Command has developed a technology master process (TMP) which integrates technology planning, development, transition, and application/insertion into a single, start-to-end process. The goal of the TMP is to formulate an integrated set of technology development projects in the laboratories and technology application/insertion projects which are balanced among, yet responsive to, the full set of technology customers. 7.2 TECHNOLOGY PROCESS Technology development needs are normally provided to AFMC by one of the following: - Weapon system single managers; - AFMC Air Logistic Center Technology Councils; and by - User response to an AFMC technology call letter. (August to October each year). 7.2.1 Technology Categories. Once the technology needs are identified and prioritized, they are divided into two categories: new or existing technology. 7.2.1.1 Those technology needs that can only be solved by the development of new technology are sent to the laboratories and compete for available resources; 7.2.1.2 Those technology needs which can be solved by application/insertion of existing technologies are sent to the AFMC Technology Transition office (ASC/SMT) and compete for available resources. The technology transition office is responsible for maintaining cognizance of the full set of technology application/insertion needs and resources and serves as the AFMC orchestrator for technology application insertion. As part of its mission the technology transition office will maintain a list of validated technologies in an integrated technology base, thereby serving as a "technology information clearinghouse."


7.2.2 Final Step. The final step in the process is engineering validation of technologies which the user will use in upgrading or developing new weapon systems/products/materials and supporting infrastructure. The purpose of engineering validation is to reduce the risk of inappropriate application by ensuring the technology meets established criteria for performance, sustainability and affordability. 7.3 BASE LEVEL RESPONSIBILITIES The base level environmental manager should identify all technology needs to their MAJCOM who will respond to the AFMC call letter. A telephone call to the Technology Transition office will confirm if your need has been previously identified, if it is included in an existing R&D/transition program or whether an existing technology exists. PRO-ACT is an additional resource to use in researching if technologies are available to solve your needs.. 7.4 POINTS OF CONTACT 7.4.1 Primary Points of Contact. ASC/SMT, Technology Transition Office. DSN 785-5940 (Technology Information Clearinghouse). 7.4.2 Other Sources. HSC/XRE, Environmental Technical Support Center. DSN 240-2861 (AF Environmental Strategic Plan/Tri-Service Environmental Strategic Plan) 7.4.3 Additional Sources. HQ AFCEE/EP, Pollution Prevention Division, DSN 240-3371 or PRO-ACT, DSN 240-4214/1-800-233-4356


8. SUPPORTING ORGANIZATIONS There are numerous sources of information that can be helpful to base-level personnel in conducting pollution prevention activities at their installations. Table 8-1 lists supporting organizations which can be utilized as a source for answers to a wide range of environmental questions.

TABLE 8-1 SUPPORTING ORGANIZATIONS

ORGANIZATION TELEPHONE NUMBER PRO-ACT (AF Environmental Information Clearinghouse)

DSN 240-4214 or (800) 233-4356

DENIX Access Requests (DoD Environmental Bulletin Board)

(800)642-3332

AF POL Technical Assistance Team DSN 945-4617 DOT Military Traffic Management (Hazardous Material Transportation)

(703)756-1951

EPA Publications (202)260-7751 Fuels Laboratory DSN 576-5051/5457 GSA Catalog Department (206)931-7353 GSA Paint Commodities (206)931-7110 EPCRA/SARA Hotline (800)535-0202 TSCA Hotline (202)554-1404 RCRA/Superfund Hotline (800)424-9346 Asbestos Hotline (800)368-5888 Pesticides Hotline (800)858-7378 NPDES/Stormwater Hotline (703)821-4823 Stratospheric Ozone Protection Hotline (800)293-1996 AFCESA Library DSN 523-6285 Facility Energy Program (Technical Advisors) Management and Equipment Evaluation Program (MEEP), Vehicle Maint & CE

DSN 523-6361 DSN 872-4217


TABLE 8-1 (Cont.) SUPPORTING ORGANIZATIONS

ORGANIZATION

TELEPHONE NUMBER

EPA Regulatory Hotlines: Air (919)541-5615 Water (202)260-5400 Radon (202)233-9400 DOT Hazardous Material (202)366-4488 OSHA (202)219-7031 NRC Spill Report (800)424-8802 Testing Methods SW-846 (703)821-4789 Tech Connect DSN 785-5940 EPA Pollution Prevention Information Clearinghouse (PPIC)

(703)821-4800

EPA Solvent Alternative Guide (SAGE) (919)541-0800 Navy CFC/Halon Information Clearinghouse (CHIC)

(703)769-1883

Emission Measurement Technical Center (919)541-1060 Acid Rain Hotline (617)674-7377 HQ Cataloguing and Standardization Center Customer Service (GSA Catalogues, etc)

DSN 932-HELP (4357)

HQ USAF/CEVV (PP Policy) DSN 227-2928/2797 HQ AFCEE/EP (PP Implementation Resources; Contract Support, Workshops, Pharmacy, DENIX data management)

DSN 240-3371


TABLE 8-1 (Cont.) SUPPORTING ORGANIZATIONS

MAJCOM Pollution Prevention Offices: HQ ACC/CEVCV HQ AETC/CEVP HQ AFMC/CEVV HQ AFRES/CEVV HQ AFSPC/CEV HQ AMC/CEVP ANGRC/CEVP HQ PACAF/CEVP HQ USAFA/CEVV HQ USAFE/RSIV

DSN 574-3252 DSN 487-3422 DSN 787-7414 DSN 497-1073 DSN 692-2551 DSN 576-8332 DSN 858-8154 DSN 448-0474 DSN 259-2289 DSN 480-6482


Appendix A

Glossary


APPENDIX A

GLOSSARY OF TERMS

Affirmative Procurement - Required by RCRA Section 6002 and EO 12783. Federal agencies must establish programs to encourage the purchase of products containing recycled materials. Affirmative procurement programs must establish preference for products containing recycled material, must include a promotion plan to place emphasis on buying recycled, and must have procedures for obtaining and verifying estimates and certifications of recycled content. Alternatives - Ways of reducing adverse effects of hazardous materials. Alternatives, as applied to hazardous material decision-making, include, but are not limited to, such possibilities as substituting less hazardous or nonhazardous material; redesigning a component such that hazardous material is not needed in its manufacture, use, or maintenance; modifying processes or procedures; restricting users; consumptive use; on-demand supply; direct ordering; extending shelf life; regenerating spent material; downgrading and reuse of spent material; use of waste as raw material in other manufacturing and combinations of those factors. Baseline - Quantified starting points from which progress is measured. Baselines are quantities of material purchased or generated over a specified period of time. Closed-loop Recycling - Utilization of byproducts from a production process in the original process, without significant alteration or reprocessing. There are three key requirements: The byproduct must be returned to the process without first being reclaimed (i.e. distilled, dewatered, or treated); the production process to which the byproduct is returned must be a primary production process (a process that uses raw materials as the majority of its feedstock); and the byproduct must be returned as feedstock to an operation within the original process from which it was generated. Compost - A mixture of garbage and degradable trash with soil in which certain bacteria in the soil break down the garbage and trash into organic fertilizer.


Composting - A waste management option involving the controlled biological decomposition of organic material in the presence of air to form a humus-like material. Controlled methods of composting include mechanical mixing and aerating, ventilating the materials by dropping them through a vertical series of aerated chambers, or placing the compost in piles out in the open air and mixing it or turning it periodically. EPA 17 Targeted Chemicals - Seventeen chemicals selected for reduction or elimination based on their volume of use, toxicity, persistence, and mobility. Also known as EPA Industrial Toxics Project (ITP) chemicals. EPCRA - Emergency Planning and Community Right-to-Know Act Fluorocarbons (FCs) - Any of a number of organic compounds analogous to hydrocarbons in which one or more hydrogen atoms are replaced by fluorine. Once used in the US as a propellant in aerosols, they are now primarily used in coolants and some industrial processes. FCs containing chlorine are called chlorofluorocarbons (CFCs). They are believed to be modifying the ozone layer in the stratosphere, thereby allowing more harmful radiation to reach the Earth's surface. Functional Areas - The operations or areas of responsibility that affect or are affected by the use of hazardous material. These areas include, but are not limited to , budget and fiscal planning, legal support, research and development, weapons systems acquisition and maintenance, material and performance specifications and standards, design handbooks, and technical manuals; maintenance and repair procedures, industrial processes, procurement policy, contracting provisions, new material identification, public works operations, construction, management of munitions, chemical agents, propellants, medical and other personnel support, safety and occupational health, transportation, and logistics analysis; supply; warehousing; distribution; recycling; disposal; spill prevention, control, and cleanup; contaminated site remediation; staffing, education, and training; information exchange; public affairs; general administration; and oversight. Halon - Bromine-containing compounds with long atmospheric lifetimes whose breakdown in the stratosphere cause depletion of ozone. Halons are used in fire-fighting. Hazardous Material Pharmacy - Single point of control for hazardous material.


Hazardous Material - Any material that poses a threat to human health and/or the environment typically due to their toxic, corrosive, ignitable, explosive, or chemically reactive nature. Hazardous Substance - 1. Any material that poses a threat to human health and/or the environment. Typical hazardous substances are toxic, corrosive, ignitable, explosive, or chemically reactive. 2. Any substance named by U.S. EPA to be reported if a designated quantity of the substance is spilled in the waters of the US or if otherwise emitted into the environment. Hazardous Waste - By-products of society that can pose a substantial or potential hazard to human health or the environment when improperly managed. Possesses at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity), or are listed in 40 CFR 261.3 or applicable state or local waste management regulations. Industrial Solid Waste - Includes wastewater treatment sludges, solids from air pollution control devices, trim or scrap materials that are not recycled, fuel combustion residues (such as the ash generated by burning wood or coal), and mineral extraction residues. Life Cycle Economic Analysis - An evaluation of the cost associated with the use of hazardous material and potential alternatives over the life of the investment or hazardous material. The analysis is not a specific, step-by-step procedure that can be applied by rote to all cases. Analysis shall be guided by basic principles of economics and informed judgment. Management Action Plan - Within the AF, a single reference to manage the actions needed to develop and execute an installation's pollution prevention program. Metrics - Measurement used to measure progress. Municipal Solid Waste (MSW) - Wastes generated by administrative and domestic activities. Includes wastes such as durable goods, nondurable goods, containers and packaging, food wastes, yard wastes, and miscellaneous inorganic wastes from residential, commercial, institutional, and industrial sources. MSW does not include wastes from other sources, such as municipal sludges, combustion ash, and industrial


nonhazardous process wastes that might also be disposed of in municipal waste landfills or incinerators. Open-loop Recycling - A recycling system in which a product made from one type of material is recycled into a different type of product. The product receiving recycled material itself may or may not be recycled. Opportunity Assessment - Systematic procedures to identify and assess ways to prevent pollution by reducing or eliminating wastes. Ozone (O3) - Found in two layers of the atmosphere, the stratosphere and the troposphere. In the stratosphere (the atmospheric layer beginning 7 to 10 miles above the earth's surface), ozone is a form of oxygen found naturally which provides a protective layer shielding the earth from ultraviolet radiation's harmful effects on humans and the environment. In the troposphere (the layer extending up 7 to 10 miles from the earth's surface), ozone is a chemical oxidant and major component of photochemical smog. Ozone can seriously affect the human respiratory system and is one of the most prevalent and widespread of all the criteria pollutants for which the Clean Air Act required EPA to set standards. Ozone in the troposphere is produced through complex chemical reactions of nitrogen oxides, which are among the primary pollutants emitted by combustion sources; hydrocarbons, released into the atmosphere through the combustion, handling and processing of petroleum products; and sunlight. Ozone Depletion - Destruction of the stratospheric ozone layer which shields the earth from ultraviolet radiation harmful to biological life. This destruction of ozone is caused by the breakdown of certain chlorine-, fluorine-, and/or bromine-containing compounds (chlorofluorocarbons or halons) which break down when they reach the stratosphere and catalytically destroy ozone molecules. Ozone Depleting Chemicals (ODCs) and Ozone Depleting Substances (ODS) - These terms are used interchangeably. CFCs, halons, and other substances that deplete the stratospheric ozone layer as classified by the Clean Air Act of 1990. Pollution/Pollutants - Refer to all nonproduct outputs, irrespective of any recycling or treatment that may prevent or mitigate releases to the environment.


Pollution Prevention Hierarchy - The Pollution Prevention Act of 1990 established a hierarchy as national policy. The hierarchy follows this order: (1) prevent or reduce pollution at the source wherever feasible; (2) recycle, in an environmentally acceptable manner, pollution that cannot feasibly be prevented; (3) treat pollution that cannot feasibly be prevented or recycled; and (4) dispose of, or otherwise release into the environment, pollution only as a last resort. PRO-ACT - An environmental information clearinghouse and hotline provided by the AFCEE for AF customers. It is designed to be the first point of contact for environmental support services within AFCEE. Program Element Code (PEC) - Funding designation required for budgeting and programming AF projects. For Pollution Prevention the PEC is 78054. RCRA - Resource Conservation and Recovery Act Recycle/Reuse - The process of minimizing the generation of waste by recovering usable products that might otherwise become waste. Examples are the recycling of aluminum cans, waste paper, and bottles. Recycled Content - The amount of recovered material, either pre- or postconsumer, in a finished product that was derived from materials diverted from the waste management system. Usually expressed as a percent by weight. Refuse Reclamation - Conversion of solid waste into useful products, e.g., composting organic waste to make soil conditioners or separating aluminum and other metals for melting and recycling. Return on Investment (ROI) - An attempt to quantify whether the benefits to a particular project exceed costs. SARA - Superfund Amendments and Reauthorization Act. Source Reduction - As defined in the Federal Pollution Prevention Act, source reduction is "any practice which 1) reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment


(including fugitive emissions) prior to recycling, treatment, and disposal; and 2) reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants. The term includes equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control." Source reduction does not entail any form of waste management (e.g. recycling and treatment). The Act excludes from the definition of source reduction "any practice which alters the physical, chemical, or biological characteristics or volume of a hazardous substance, pollutant, or contaminant through a process or activity which itself is not integral to and necessary for the production of a product or the providing of a service." Toxic Chemical - Those chemicals listed in Section 313 of EPCRA as of 1 Dec 1993. Toxic Chemical Use Substitution - This term describes replacing toxic chemicals with less harmful chemicals, although relative toxicities may not be fully known. Examples would include substituting a toxic solvent in an industrial process with a chemical having lower toxicity, or reformulating a product so as to decrease the use of toxic raw materials or the generation of toxic byproducts This also includes attempts to reduce or eliminate the use of chemicals associated with health or environmental risks. Examples include the phaseout of lead in gasoline, the phaseout of the use of asbestos, and efforts to eliminate emissions of chlorofluorocarbons and halons. Some of these attempts may involve substitution of less hazardous chemicals for comparable uses, while others involve the elimination of a particular process or product from the market without direct substitution. Toxic Use Reduction - This term refers to the activities grouped under "source reduction," where the intent is to reduce, avoid, or eliminate the use of toxics in processes and/or products so as to reduce overall risks to the health or workers, consumers, and the environment without shifting risks between workers, consumers, or parts of the environment. Treatment - Involves end-of-pipe destruction or detoxification of wastes from various separation/concentration processes into harmless or less toxic substances.


Waste Minimization - Source reduction and the following types of recycling: (1) beneficial use/reuse, and (2) reclamation. Waste minimization does not include recycling activities whose uses constitute disposal and burning for energy recovery. WIMS-ES - Work Information Management System-Environmental Subsystem. A subsystem of Civil Engineering's WIMS computer management information system for programming and budgeting environmental projects. Provides for daily transfer of data between bases, MAJCOMs, and Air Staff.


Appendix B

Opportunity Assessment Worksheet Examples


WORKSHEET 1

SITE DESCRIPTION • List the operations at this shop/building: • What are the major products?: • Provide a rough estimate of production volume per month (e.g., the number of circuit

boards produced): • What are the major waste streams? What media do they affect? How much waste is

generated in each? • Has the shop/building already implemented any waste reduction or recycling

techniques? If yes, describe the technique results to date. • How many people work in this shop/building? How many hours is it operational? • The following sources contain information that may help you determine the type and

amount of waste generated at your shop: • Work Flow Diagram • Hazardous Waste Manifests • Emission Inventories • Annual/Biennial Reports • Permit/Permit Applications • Material Safety Data Sheets • Chemical Materials Inventory • Permitting Details/Conditions • Environmental Audit Reports


WORKSHEET 2 WASTE STREAM ASSESSMENT FORM

Questions Waste #1 Waste #2 Waste #3 Waste #4 Waste Stream #/ Process Unit

Brief Description of how waste is

generated

Waste Stream Name (A) air emission (WW) waste water (SW) solid waste (HW) haz waste

Occurrence (R) regularly (NR) non-recurrent

Monthly generation rate

Treatment/Disposal method (R) recycled (L) landfill (S) sewage

treatment plant (I) incinerator (O) other

Disposal Cost


WORKSHEET 3 MANAGEMENT PRACTICES

Questions Y N GENERAL Does the shop have written procedures for shop inspection/ maintenance? Does the shop show signs of poor housekeeping (cluttered walkways, uncovered

drums, etc.)?

Does the aisle space appear adequate for equipment, bulky items? Is the drum storage area covered (e.g., all containers are protected from the

weather)?

Are all drums raised off the ground (e.g., on pallets)? Does the shop have equipment to prevent releases caused by over-filling of storage

tanks (e.g., high level shutdown/alarms, secondary containment)?

Are there noticeable spills, leaking containers, or leaking valves, pumps, hose fittings?

Are containers labeled as to their contents and hazards? Is there smoke, dust or fumes indicating material losses? Does the shop have a training program for raw materials handling, spill prevention

proper storage techniques and waste handling procedures?

If this is a training facility, are students trained to be environmentally aware? INVENTORY CONTROL Does the shop have a single point of contact for ordering and distributing new

supplies?

Does the shop have written procedures regarding inventory control? Is inventory used in first-in, first-out order? Do you dispose of products due to expired shelf-life? Are empty containers returned to the supplier, or re-used on-site? Does the shop buy products in bulk? Estimate the volume of chemicals maintained on-site: If figures are unavailable, provide qualitative assessment: Low, Medium, High (Low = one supply cabinet/ Medium = 1 to 3-55 gallon drums/ High = stock room with more than 50 products with > 5-55 gallon drums) Check the inventory quickly - are there any toxic substances? (E.G., benzene, methyl ethyl ketone, methylene chloride, tetrachloroethylene, toluene, trichloroethylene, xylene - these migh be present in degreasers, adhesives, epoxies)


WORKSHEET 4 OPPORTUNITY ASSESSMENT

Opportunity Title: Describe the Opportunity: Waste Stream(s) Affected: Input Material(s) Affected: Product(s) Affected: Indicate Type of Opportunity : (the opportunity may be a combination of source reduction, recycling, and treatment) Source Reduction _____Equipment Change _____Personnel/Procedure Change _____Material Change Recycling/Reuse _____Onsite _____Offsite Treatment/Disposal After source reduction and/or recycling have been implemented, residual wastes may still require treatment and disposal (e.g., still bottoms or spent filters from an on-site solvent recycler). Treatment required _____Biological _____Incineration _____pH adjustment _____Precipitation _____Solidification _____Other Disposal _____Landfill _____Surface Impoundment _____Deep Well _____Other


Feasibility Assessment Explain why the opportunity appears to be technically feasible: Estimate the one-time cost to implement the opportunity, taking into account equipment costs, labor, etc. Estimate the annual recurring costs to implement the opportunity, taking into account materials, manpower, utilities, etc. Estimate how much money implementation will save the facility annually. Would the opportunity be difficult to implement? Y N Staff training required Y N Staff/management resistance expected Y N Cost to implement is high Y N Labor is required to install and maintain new equipment Y N Other factors (please add) Y N

Appendix C

Air Force Pollution Prevention Management Action Plan Prototype

2

APPENDIX C TABLE OF CONTENTS

Section Page LIST OF TABLES ...................................................................................................................... C-3 LIST OF FIGURES..................................................................................................................... C-3 LIST OF ATTACHMENTS........................................................................................................ C-3 LIST OF ACRONYMS............................................................................................................... C-4 INTRODUCTION....................................................................................................................... C-6 1.0 PROCESS ............................................................................................................................ C-7 1.1 POLICY ........................................................................................................... C-8 1.2 BASELINES................................................................................................... C-10 1.3 REQUIREMENTS ......................................................................................... C-11 1.4 OPTIONS ....................................................................................................... C-11 1.5 SOLUTIONS .................................................................................................. C-12 1.6 PROGRAM .................................................................................................... C-13 1.7 EXECUTION.................................................................................................. C-14 1.8 METRICS AND REPORTING...................................................................... C-14 2.0 PROGRAM ........................................................................................................................ C-16 3.0 EXECUTION ..................................................................................................................... C-24 3.1 OZONE DEPLETING CHEMICALS ............................................................ C-25 3.2 U.S. EPA INDUSTRIAL TOXICS PROJECT CHEMICAL

PURCHASES ........................................................................................................ C-27 3.3 HAZARDOUS WASTE DISPOSAL............................................................. C-29 3.4 MUNICIPAL SOLID WASTE DISPOSAL................................................... C-31 3.5 AFFIRMATIVE PROCUREMENT............................................................... C-33 3.6 ENERGY CONSERVATION ........................................................................ C-34

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LIST OF TABLES Table Page 1. PROGRAM SUMMARY SHEET...................................................................................... C-17 2. PURCHASE OF OZONE DEPLETING CHEMICALS..................................................... C-18 3. ITP CHEMICAL PURCHASES ......................................................................................... C-19 4. HAZARDOUS WASTE DISPOSAL ................................................................................. C-20 5. MUNICIPAL SOLID WASTE DISPOSAL........................................................................ C-21 6. AFFIRMATIVE PROCUREMENT ................................................................................... C-22 7. ENERGY CONSERVATION............................................................................................. C-23 LIST OF FIGURES Figure Page 1. THE POLLUTION PREVENTION PROCESS .................................................................. C-7 LIST OF ATTACHMENTS Attachment Page 1. PROJECT NARRATIVES.................................................................................................. C-36

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LIST OF ACRONYMS AF Air Force AFB Air Force Base AFI Air Force Instruction AFPD Air Force Policy Directive AGE Aerospace Ground Equipment ALC Air Logistics Center AP Affirmative Procurement BEE Bioenvironmental Engineering Btu British Thermal Unit CE Civil Engineering CE/DF Civil Engineering, Fire Department CEV Civil Engineering, Directorate of Environmental Quality CEOE Civil Engineering, Office of Energy CFC Chlorofluorocarbon CHP Central Heat Plant COPARS Contractor Operated Parts and Repair Store CNS Base Contracting Office CRS Component Repair Squadron CY Calendar Year DLA Defense Logistics Agency DRMO Defense Reutilization and Marketing Organization E.O. Executive Order EPA Environmental Protection Agency EPC Environmental Protection Committee FEMIA Federal Energy Management Improvement Act FY Fiscal Year GSA General Services Administration HCFC Hydrochlorofluorocarbon HM Hazardous Materials HTHW High Temperature Hot Water HVAC Heating, Ventilation, and Air Conditioning HW Hazardous Wastes ITP Industrial Toxics Project ("EPA 17" Toxic Chemicals) Lbs. Pounds

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LG Logistics LGS Supply M Million MAJCOM Major Command MAP Management Action Plan MEK Methyl Ethyl Ketone MFH Military Family Housing MSW Municipal Solid Waste MWR Moral, Welfare, and Recreation OA Opportunity Assessment OCR Office of Collateral Responsibility ODC Ozone Depleting Chemical OPR Office of Primary Responsibility OS Operations and Services PCB Polychlorinated Biphenyl PCE Perchloroethylene RCRA Resource Conservation and Recovery Act, as amended ROI Return on Investment TCE Trichloroethylene U.S. United States WIMS-ES Work Information Management System, Environmental Subsystem

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INTRODUCTION

This prototype plan provides a standard framework for Air Force Pollution Prevention Management Action Plans (PP MAPs). The information contained in this plan is illustrated in two ways. First, guidance and explanatory text are provided to familiarize the installation with the purpose of each section of the document. This information will be shown in a bold, table format as illustrated here. The remaining portions of the plan are representative of the actual format and content of a PP MAP. This MAP is divided into three sections: PROCESS, PROGRAM, and EXECUTION. The PROCESS section describes the steps the Installation has taken to develop and implement a pollution prevention program, as well as those steps necessary to modify and measure program success. The PROGRAM section lists the costs, benefits, and return on investment (ROI) for proposed pollution prevention projects in each goal area. The EXECUTION section lists all the actions that must occur to implement each project. The information contained in this plan was developed using actual pollution prevention projects at Dover AFB. While not all of these projects are appropriate to every installation, the intent of the plan and the examples outlined herein will provide valuable guidelines for developing Air Force MAPs.

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1.0 PROCESS

The pollution prevention process is outlined in Figure 1. Each portion of the process, shown in Figure 1, should be discussed in the PROCESS section of the MAP. The PROCESS section documents the initial and recurring management actions needed to cause the pollution prevention process to function. In addition, it assigns Offices of Primary Responsibility (OPR), Offices of Collateral Responsibility (OCR) when necessary, and dates of estimated and actual completion for each management action. The actions outlined in this section provide installations with ideas to consider in developing a pollution prevention program. These actions are not dictated; however, they demonstrate one way in which an installation can implement management actions which allow the installation to prepare a pollution prevention program which meets the Air Force pollution prevention goals.

Figure 1. The Pollution Prevention Process

The Pollution Prevention Process

REQUIREMENT

OPTIONS

SOLUTIONS

PROGRAM EXECUTION

POLICY BASELINES

METRICS

and

REPORTING

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1.1 POLICY

This section describes the areas in which the installation outlines its internal policies and procedures for meeting the Air Force pollution prevention goals outlined in the Air Force Installation Pollution Prevention Program Guide. It includes assigning responsibilities and deadlines to each management action.

Completion Date

Action OPR Estimated Actual

Initial: Incorporate pollution prevention program into EPC.

Wing Commander

7 Jul 93

Recurring:

Initial: Establish a pollution prevention subcommittee under the EPC and establish teams under this subcommittee in the areas of MSW, HW, Energy conservation, and ITP chemicals. Assign the Air subcommittee the responsibility for managing ODC issues.

EPC 15 Sep 93

Recurring: Staff the teams with necessary personnel; evaluate effectiveness of each group; modify structure as required.

EPC Annually

Initial: Assign the pollution prevention teams the responsibility of developing procedures for meeting the reduction goal in their area.

Pollution Prevention Subcommittee

30 Sep 93

Recurring: Review effectiveness of pollution prevention teams in meeting responsibilities.

EPC, Pollution Prevention Subcommittee

Annually

Initial: Implement procedures to comply with Air Force pollution prevention goals.

EPC 15 Dec 93

Recurring: Modify to meet Air Force pollution prevention requirements as necessary.

EPC As needed

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Action

OPR

Completion Date

Estimated Actual

Initial: Develop strategies to reduce MSW disposal 10% by the end of CY 1993, 30% by the end of CY 1996, and 50% by the end of CY 1997, from a CY 1992 baseline.

MSW Team 15 Dec 93

Recurring:

Initial: Eliminate the purchase of newly produced Class I ODCs, as specified in the Air Force ODC elimination policy.

Air Subcommittee

15 Oct 93

Recurring:

Initial: Develop management actions to eliminate unnecessary use of the U.S. EPA's 17 ITP Chemicals, and reduce the use of these chemicals by 50% by the end of CY 1996 from a CY 1992 baseline.

HM Team 15 Oct 93

Recurring:

Initial: Develop management actions required to reduce HW disposal by 25% by the end of CY 1996, and by 50% by the end of CY 1999, from a CY 1992 baseline.

HW Team 15 Oct 93

Recurring:

Initial: Develop management actions required to ensure all purchases of EPA Guideline Items meet EPA criteria for recycled content.

MSW Team, LGS

15 Oct 94

Recurring:

Initial: Develop management actions required to reduce energy consumption by 10% Btu/Square Foot by 1995, 20% by 2000, and 25% by 2005, from a 1985 baseline.

Energy Team 15 Oct 93

Recurring:

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1.2 BASELINES

Baselines identify a level of waste generation or material purchase by which future reductions will be measured. It is recommended that baselines are conducted in-house. This helps to familiarize installation personnel with the waste streams and processes that should be targeted for pollution prevention.

Action

OPR

Completion Date

Estimated Actual

Initial: Establish baselines for each minimization area for CY 1992, excluding energy conservation (1985) and affirmative procurement.

Pollution Prevention Teams

15 Dec 93

Recurring: Modify baselines as required. Modifications will be based on variations in mission.

EPC As required

Initial: Perform a waste stream analysis to identify components of the MSW stream.

MSW Team 15 Feb 93

Recurring: Evaluate after implementation of pollution prevention projects.

MSW Team Annually

Initial: Develop an ongoing feasibility study for the substitution of ITP chemicals (EPA 17). Work closely with the ALCs to stay abreast of these changes.

HM Team Quarterly

Recurring: None

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1.3 REQUIREMENTS

Installation requirements will identify the quantity of material or waste which must be reduced to meet the Air Force pollution prevention reduction goals. Requirements are calculated by taking the baseline data for a goal area and subtracting the goals which must be met in a given fiscal year (FY). For example, HW has a baseline of 259,175 lbs. Policy requires that 25% of that amount is reduced by 1996 and 50% by 1999. Multiplying 25% by the baseline gives the installation a requirement of reducing at least 64,794 lbs by 1996. Similarly, multiplying 50% by the baseline identifies a requirement for reducing 129,588 lbs by 1999.

Action

OPR

Completion Date

Estimated Actual

Initial: Determine requirements for the pollution prevention program in each goal area.

Pollution Prevention Teams

15 Aug 93

Recurring: None 1.4 OPTIONS

When base requirements are outlined, options for meeting the requirements must be identified. These options are identified through opportunity assessments (OAs). OAs identify waste generating processes and evaluate alternatives for pollution prevention. Projects identified by OAs must have complete data to show the cost, benefit, and ROI of the project.

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Action

OPR

Completion Date

Estimated Actual

Initial: Develop pollution prevention options that will achieve base requirements through OAs.

Pollution Prevention Subcommittee and Teams

15 Dec 93

Recurring: Accomplish periodic OAs. Pollution Prevention Teams

Every 3 years

Initial: Establish an OA training program. EPC 15 Dec 93

Recurring: Identify individuals requiring training. Pollution Prevention Subcommittee

30 Dec 93

Initial: Develop in-house expertise to conduct OAs.


On-going

Recurring: 1.5 SOLUTIONS

Once pollution prevention projects, which allow the Air Force to meet its reduction requirements, have been identified and determined feasible, the projects will be compiled into solution sets. Projects will be prioritized based on ROI.

Action

OPR

Completion Date

Estimated Actual

Initial: Select implementable options and document them in the PROGRAM section of the MAP.


1 Dec 93

Recurring: Continue to accept, evaluate, and prioritize options to maintain a viable pool of solutions.


On-going

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1.6 PROGRAM

Once the best solutions have been identified and documented in the PROGRAM section of the MAP, the actual program must be selected from the solutions. A decision-making body and process must be established to ensure funds are allocated against the highest priority projects and that the program is carried well into the out years.

Action

OPR

Completion Date

Estimated Actual

Initial: Submit the initial pollution prevention program to higher headquarters in the FY 96-01 Budget through WIMS-ES and local Accounting and Finance channels.

CEV Accounting and Finance (OCR)

15 Dec 93

Recurring: Submit unfunded pollution prevention projects to higher headquarters for funding.

CEV Accounting and Finance (OCR)

As required

Initial: Establish procedures to classify projects in accordance with AFI 32-7001 (Civil Engineering, Environmental Budgeting).

CEV 15 Dec 93

Initial: Establish a decision-making body for reviewing solutions and determining the installation pollution prevention program.


15 Dec 93

Recurring: Reconvene body periodically to ensure program meets current priorities and is executable.


As required

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1.7 EXECUTION This section outlines management actions which must occur to execute a pollution prevention program. Timely execution is critical to program success and resource allocation.

Action

OPR

Completion Date

Estimated Actual

Initial: Establish execution goals and track percentage of projects executed throughout the fiscal year.


15 Dec 93

1.8 METRICS AND REPORTING Established metrics are founded upon baselines in each goal area. Metrics will be tracked by each pollution prevention team annually to determine if the Air Force pollution prevention goals are being met in each goal area. Metrics measure actual execution data reflecting program performance. Bases are directed to report some metrics to higher headquarters or U.S. EPA to summarize program effectiveness. Modifications to the program will be based on the difference between estimated and actual performance.

Action

OPR

Completion Date

Estimated Actual

Initial: Establish procedures to capture and record data for the AFPD metrics in each goal area and other legally mandated reports (e.g. the Emergency Planning and Community Right-to-Know Act).


1 Jan 94

Recurring: Enter reportable data into the pollution prevention module of the WIMS-ES for AFPD metrics.

CEV Semi-annual

Recurring: Measure actual benefit of completed projects.


Annually

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Recurring: Compare actual benefit and cost of each project completed in this reporting cycle with estimated benefit and cost.


Annually

Recurring: Update requirements with actual benefit data, and modify program accordingly.


Annually

Recurring: Record actual cost data for improving future cost estimates.


Annually

Recurring: Evaluate the results of implemented solutions, determine the deviation from projected results, and initiate the requirement to generate new options through the OA process.


On-going

Recurring: Provide pollution prevention status briefings to wing commander.


Monthly

Recurring: Initiate requirement for more options to be generated by OAs.


As required

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2.0 PROGRAM Section 2 of the MAP provides a program summary and a listing of pollution prevention projects for each goal area. The Program Summary Sheet, listed in Table 1, summarizes and describes the relationship between the policy goals, baselines, requirements, benefits, and costs for each of the goal areas. The policy goals are quantified according to percent reduction, and the projected deadlines are specific for each goal area. The baselines for ODCs and ITP chemicals are based on 1992 base purchases. Baselines for HW and MSW were based on quantities of waste generated during 1992. The project listings for the individual goal areas are listed in Tables 2 through 7. The projects are categorized according to goal area and are followed by information regarding FY, ROI, cost, benefit, OPR, and when necessary OCR. All projects submitted to the MAJCOM for validation must be entered in the WIMS-ES. In addition, every project should be supported by a project narrative as illustrated in the example in Attachment 1, Project Narratives.

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TABLE 1. PROGRAM SUMMARY SHEET ODC

Purchases ITP

Purchases

HW

MSW

AP Energy

Conservation

Policy Goals Date 4/1/94 12/31/96 12/31/96 12/31/99 12/31/93 12/31/96 12/31/97 Annually 12/31/04

Reduction/ procurement

100%* 50% 25% 50% 10% 30% 50% 100% of purchases meet EPA guideline

standards

25% MBtu

Baselines CY Amount (lbs)

92 92 92 92 85

28,338 31,227 259,175 15,140,000 0.149 MBtu***

Requirements Amount of Reduction (lbs)

28,338 15,614 64,794 129,588 1,514,000 4,542,000 7,570,000 0.037 MBtu

Benefits FY **Amount of

Reduction (lbs)

Thru 94

28,338

Thru 95

22,986

Thru 95

103,736

95-99

199,996

Thru 93

1,569,500

94-96

5,013,850

96-97

7,587,650

Thru 2005

0.0376 MBtu

Costs ** ($K) 1,620 18 75 389 0 75 169 35,200

* Air Force policy mandates a 100% reduction in the purchase of newly-produced ODCs. While the policy became effective on 1 January 1993, it specifies several different

effective dates which vary with the type of ODC used and its application. For the purposes of this summary, the goal date is the latest effective date specified in the policy, which is the prohibition of purchasing ODC solvents after 31 March 1994. Recycled ODCs, and ODCs for mission critical applications, may still be obtained under specified conditions.

** Benefits for HW and MSW are cumulative. Costs are additive. *** The baseline for energy conservation will be measured in MBtus. This is derived by multiplying the total square footage of an installation by the Btu Usage/sq ft.

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TABLE 2. PURCHASE OF OZONE DEPLETING CHEMICALS* Requirement: Eliminate the purchases of ODCs according to the AF ODC elimination policy.

(FY) Project Title

Cost

Benefit (lbs/yr)

OPR

(FY 93) Halon Fire Suppressant Recovery/Recycling

$17,500 12,750 (Halon 1211) CEV CE/DF (OCR)

(FY 93 -) ODC-Containing Product Substitution

$80,000 12,388** (CFC-11, -12, -13, -113)

CEV

(FY 93) Freon Refrigerant Recovery/Recycling

$22,500 1,550 (CFC-12) CEV

(FY 93 - 08) Retrofit Facility Refrigerant Chillers

$300,000 750 (CFC-11, -12) CEV

(FY 93 - 08) Replace Facility Refrigerant Chillers

$1,200,000 900 (CFC-11, -12) CEV

TOTAL $1,620,000 28,338

* Because the ODC goal area calls for mandatory eliminations in purchases, a project's ROI does

not play a role in scheduling projects for implementation. ** This project will substitute products which do not contain Class I ODCs for the remaining

applications on the base.

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TABLE 3. ITP CHEMICAL PURCHASES ("EPA 17") Requirement: Reduce purchases and use of ITP chemicals by 50% by the end of CY 1996 from a 1992 Baseline.

(FY) Project Title

ROI

Cost

Benefit (lbs/year)

OPR

(FY 93) Free Use Shelf (Paint)

0 $0 3,011 (Toluene) 76 (Xylene)

LG

(FY 93) Hazardous Material Pharmacy

NA *** 3,122 ITP Chemicals*

OS**

LG

(FY 94) MEK/Paint Thinner Recycler

0 $3,000 5,376 (MEK) 4,070 (Toluene)

153 (Xylene)

Corr. Control

50% Reduction Achieved $3,000 15,808

(FY 96) Hazardous Materials Awareness Course

1 $15,000 3,122 ITP Chemicals*

BEE, CE (OCR)

(FY 96) Bead Blaster

1 *** 1,000 (Toluene) 200 (Xylene)

30 (Methylene Chloride)

Corr. Control

(FY 96) Jet Parts Washer

2 *** 218 (PCE) 643 (TCE)

65 (Methylene Chloride)

1,900 (Toluene)

Proplsn

TOTAL $18,000 22,986 * Assumes a 10% reduction in the baseline amount for each project. ** Operations and services project. *** Costs for these projects are shown in the HW table.

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TABLE 4. HAZARDOUS WASTE DISPOSAL Requirement: Reduce HW disposal by 25% by the end of CY 1996 and by 50% by the end of CY 1999 from a 1992 baseline.

(FY) Project Title ROI Cost Benefit (lbs/yr) OPR

(FY 93) HM Pharmacy NA $75,000 89,736*, OS** LG

(FY 93 - 94) Use Dry Cell Battery

0 $0 14,000 AGE, Power Prod.,

COPARS(OCR)

25% Reduction Achieved $75,000 103,736

(FY 96) Bead Blaster 0.73*** (.80)

$33,941 64,680 Corr. Control

(FY 96) Recycle Bead Blasting Media

0.73*** (.03)

$150 6,150 Corr. Control

(FY 97) Recycle Paint Thinner

1.02 **** 3,900 Corr. Control, CE Paint

Shop (OCR)

(FY 98) Small Jet Parts Washers

5 $30,000 8,000 Proplsn

(FY 98) Jet Parts Washer 17 $250,000 13,500 Proplsn

TOTAL $389,091 199,966

* This reduction for the HM Pharmacy reflects a reduction of unused materials that are disposed of

annually as hazardous waste. Although ranked as OS, disposal of this waste will be reduced through the implementation of the Pharmacy. This number accounts for 40% of total hazardous waste generated at the installation, excluding 34,836 lbs of PCB waste.

** Operations and Services. *** Although the bead blasting media recycling project has a greater return, it cannot occur until the

bead blaster is operational. Because the recycling project is dependent upon the bead blaster, a combined ROI has been derived so that the dependent project may be programmed after the independent one. This ROI is a combined calculation obtained by combining the costs and benefits of the two projects associated with the bead blaster. If a dependent project is scheduled after an independent project, there is no need to calculate combined ROI.

**** Costs for this project are shown in the ITP Chemical Purchase table.

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TABLE 5. MUNICIPAL SOLID WASTE DISPOSAL Requirement: Reduce MSW disposal by 10% by the end of CY 1993, 30% by the end of CY 1996, and 50% by the end of CY 1997 from a 1992 Baseline.

(FY) Project Title

ROI

Cost

Benefit (lbs/yr)

OPR

(FY 93) Recycle Oils from Filters 0 $0 18,000 LG

(FY 93) Used Tires 0 $0 37,500 MSW Team

(FY 93) Office Paper/Newspaper Recycling

0 $0 1,514,000 MSW Team

10% Reduction Achieved $0 1,569,500

(FY 94) Paper Recycling Awareness 0.53 $10,000 605,600* CEV

(FY 95) Recovery of Wood Pallets, Aircraft Packaging - Shredder

0.79 $65,000 2,838,750 MWR

30% Reduction Achieved $75,000 5,013,850

(FY 96) Cardboard Recycling 1.14 $25,000 757,000 MWR

(FY 96) Glass/ Aluminum Recovery ! Recycling Equipment ! Aluminum Can Receptacles

1.31** (1.79)

$59,000 1,135,500 MWR, CE (OCR)

(FY 96) Glass and Aluminum Recycling Awareness

1.31** (0.76)

$10,000 681,300 MSW Team, MWR (OCR)

50% Reduction Achieved $169,000 7,587,650

(FY 97-) Recycle PRC Sealant Tubes 8.39 $14,600 60,000 AGE

(FY 97-) Recycle Oil, Fuel, and Hydraulic Filters

9.32 $87,100 322,400 LG

(FY 97-) Composting Program and Wood Chipper

14.23 $150,000**** 363,360 MWR

TOTAL $420,700 8,333,410 * Assumes increase of benefits of paper recycling by 10%. ** This is a combined ROI calculated by combining the costs and benefits of the recovery equipment

and awareness projects. Although the awareness project has a quicker return, it is dependent upon the acquisition of recovery equipment. The benefit of the awareness project assumes a 10% increase in the recycling of glass and aluminum products.

*** PRC is a trade name, hence there is no breakdown of it in the acronym list. **** Includes the price of a dump truck that could be used for other recycling projects. TABLE 6. AFFIRMATIVE PROCUREMENT

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Requirement: Ensure that 100% of all EPA Guideline Items purchased each year contain recycled materials meeting EPA guideline standards.

(FY) Project Title

Cost

Benefit (% of Total

Procurement)

OPR

(FY 93) Procurement of Recycled Paper and Paper Products LG

TOTAL PAPER

(FY 93) Procurement of Retread Tires LG

(FY 93) Procurement of Building Thermal Insulation LG

(93) Purchase Cement Containing Fly Ash (American Concrete Institute)

LG

(93) Purchase Re-Refined Lubricating Oil (American Petroleum Institute)

LG

TOTAL NON-PAPER

NOTE: At the time of publication of this guide, actual costs and benefits of affirmative procurement

were not available.

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TABLE 7. ENERGY CONSERVATION Requirement: Reduce energy use by 10% by the end of CY 1994; 20% by the end of CY 1999; and 25% by the end of CY 2004 from a 1985 baseline.

(FY) Project Title

ROI

Cost

Benefit (MBtu.)

OPR

(FY 93) Reduce Base Heat 3°F 0 0 0.008 Energy Team, CEOE (OCR)

(FY 93) Reduce Military Family Housing (MFH) 3°F

0 0 0.003 Energy Team, CEOE (OCR)

(FY 93) Raise Base AC 3°F 0 0 0.0003 Energy Team, CEOE (OCR)

(FY 93) Raise MFH AC 3°F 0 0 0.0003 Energy Team, CEOE (OCR)

(FY 93 - 94) Central Heat Plant (CHP) Retrofit Fuel Oil to Natural Gas

4 $1,500,000 0.002 CEOE

(FY 94 - 95) Install Air Preheaters at CHP 4 $600,000 0.002 CEOE

10% Reduction Achieved $2,100,000 0.0156

(FY 94 - 95) High Temperature Hot Water (HTHW) Lines Replacements

46 $29,100,000* 0.015 CEOE


(FY 96) Convert Family Housing Boilers from Fuel Oil to Natural Gas

17 $4,000,000 0.007 CEOE


TOTAL $35,200,000 0.0376

* Infrastructure project will be funded by the Military Construction Program.

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3.0 EXECUTION

This section outlines the actions which are required to initiate and implement the projects identified in section 2. Subdivided according to the six goal areas, each section provides a brief discussion of relevant issues, and a description of the goal's relation to the installation. Every subdivision includes tables which outline the actions required to implement the sample projects. These actions will enable an installation to achieve the Air Force pollution prevention goals. In addition, the tables identify the OPR and the required completion dates for each action. The following section provides samples of pollution prevention projects in each goal area. In an actual plan, each pollution prevention project included in section 2 would be discussed.

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3.1 OZONE DEPLETING CHEMICALS The Clean Air Act identifies many substances which contribute to the depletion of the Earth's stratospheric ozone layer. Air Force policy outlines an elimination plan for the purchase of newly-produced ODCs. The purchase bans take effect on different dates for different ODC applications. At ___ AFB, LGS has suppressed the ordering of all ODC-containing products. In order to obtain ODCs for mission critical applications, shops must obtain a waiver before LGS will order substances from the Defense Logistics Agency (DLA) ODC bank. The process of obtaining a waiver may be initiated by CEV and BEE. The following projects are examples of the actions necessary to enable ___ AFB to achieve the Air Force pollution prevention goals while avoiding any negative mission impacts.

REPLACE CFC-12 CENTRIFUGAL WATER COOLED, WATER CHILLER IN BUILDING 266 WITH ABSORPTION CHILLER

Action OPR Completion Date

Estimated Actual

Establish contracts for the installation of high efficiency absorption chiller.

CEV, CNS (OCR)

31 Jun 95

Determine whether current infrastructure (i.e., water supply, electricity, facility layout, etc.) will be sufficient for new system.

Air Subcommittee

31 Dec 95

Schedule necessary infrastructure improvements with CE.

Air Subcommittee

31 Jan 96

Perform necessary infrastructure improvements/modifications.

CE 31 Jun 96

Install absorption system. CE 31 Dec 96

Collect recovered CFC-12 and ship to DLA ODC bank.

Air Subcommittee,

LGS (OCR)

31 Dec 96

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RECOVER AND RECYCLE HALON FROM FIRE SUPPRESSANT SYSTEMS


Estimated Actual

Deactivate automatic halon discharging mechanisms. CE/DF 1 Jan 93

Collect all facility fire extinguisher which utilize halon. CE/DF 31 Oct 93

Purchase halon tanks for storage and shipping of recovered halon.

CEV 31 Dec 93

Purchase a compressed air system for the CE/ Fire Department (DF) halon recovery system.

CEV 31 Dec 93

Recover halon from collected extinguisher and reuse, as necessary, for servicing of flightline extinguisher.

CE/DF 31 Jan 94

Ship excess halon to DLA ODC bank. CE/DF, CEV

(OCR)

On-going

Investigate the feasibility of using alternative substances as replacements for Halon 1211 (e.g. HCFC-221, HCFC-123, etc.).

CEV On-going

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3.2 U.S. EPA INDUSTRIAL TOXICS PROJECT ("EPA 17") CHEMICAL PURCHASES Controlling HM is essential to a successful pollution prevention plan. This includes reducing the quantity and types of HM, as well as implementing proper distribution, use, storage, and disposal. HM includes the chlorofluorocarbons, the U.S. EPA Industrial Toxics Project (ITP) chemicals, and the extremely hazardous substances identified under Title III of the Superfund Amendments and Reauthorization Act. These chemicals will be tracked and measured against a 1992 baseline. The following projects are essential to managing hazardous materials and accomplishing the Air Force goal of reducing the U.S. EPA ITP chemicals by 50% by the end of 1995 from the 1992 baseline.

PURCHASE JET PARTS WASHERS


Estimated Actual

Identify facilities where washers will provide the greatest reductions in ITP chemical usage.

HM Team, CEV

(OCR)

31 Dec 94

Identify required utility and infrastructure modifications. HM Team,

CE (OCR)

31 Jan 95

Establish work order with CE to perform modifications. CEV 31 Jan 95


CE 31 Jul 95

Procure cleaning agents for jet washers. HM Team

On-going

Install jet parts washers. CE 31 Jan 96

Oversee the training of personnel. CRS, HM

Team (OCR)

15 Feb 96

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PURCHASE METHYL ETHYL KETONE (MEK)/PAINT THINNER RECYCLERS


Estimated Actual

Identify facilities where recyclers will provide the greatest reduction in ITP chemical usage.

CEV 31 Dec 93

Identify required utility and infrastructure modifications. CE 31 Jan 94

Establish work order with CE to perform modifications. CEV 31 Jan 94


CE 31 Jul 94

Install MEK/Paint Thinner Recyclers. CE 31 Jan 95

Oversee the training of personnel. Corr. Control

15 Feb 95

ESTABLISH A FREE USE SHELF AT HAZARDOUS MATERIALS PHARMACY


Estimated Actual

Store unused portions of hazardous materials on shelf at hazardous materials pharmacy.

LGS 31 Oct 93

Establish data base of inventory and shop/personnel authority for acquisition.

LGS 31 Dec 93

Permit the cost-free acquisition of materials by personnel with appropriate approval.

LGS On-going

Retrieve unused portions of materials at close of business for storage on free use shelf.

LGS On-going

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3.3 HAZARDOUS WASTE DISPOSAL Hazardous wastes (HW) are most often regulated under RCRA, and the Toxic Substances Control Act for PCB waste. RCRA requires that a generator of RCRA HW certify that a waste minimization program is in place as part of the biennial report for HW generators. The U.S. EPA's interim final guidance, published in January 1993, provides guidance on what constitutes having a "program in place" in order to comply with the certification requirements. This plan should include the efforts undertaken during the year to reduce the volumes or toxicity of waste generated and the changes in the volume and toxicity actually achieved in comparison to previous years. Efforts listed in the hazardous waste section of this plan fulfill the requirements of RCRA and the Air Force MAP requirements. The section below lists those actions that are required to implement each of the projects outlined in the program section of this report.

PHASE OUT USE OF LEAD ACID BATTERY IN LG (COPARS, POWER PROD)


Estimated Actual

Collect cost/benefit data on performance and application of the Optima gel battery, as compared to lead acid batteries.

HW Team

30 Nov 93

Identify large volume users of lead acid batteries, and evaluate potential substitution of Optima gel battery.

HW Team

31 Dec 93

Purchase gel batteries for use, when feasible. LGS, AGE

(OCR)

On-going

Recycle lead acid batteries through DRMO. CEV On-going

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BEAD BLASTER


Estimated Actual

Order bead blaster. CE 15 Jul 93

Establish work order with CE for facility construction. LGS 15 Aug 93

Identify utility and infrastructure modifications necessary for the new facility.

CE 15 Aug 93


CE 31 Dec 93

Construct facility for bead blaster. CE 31 Dec 94

Install bead blaster at Corrosion Control shop. CE, Corr.

Control (OCR)

31 Jan 95

Increase procurement of bead blasting media to accommodate scale.

LGS 31 Jan 95

Train personnel in the operation of the system. Corr. Control

15 Feb 95

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3.4 MUNICIPAL SOLID WASTE DISPOSAL Municipal solid waste (MSW) is generated from three groups on base: residential areas, administrative offices, and industrial shops. MSW generated by these groups is currently placed into various dumpsters around the installation and taken off-base by contract. Although the weight and volume of waste that is shipped off-base are tracked, the components of the MSW have not been identified. For example, it is assumed that yard waste accounts for approximately 15% of the waste being shipped off-base, although there are no actual figures. Therefore, a MSW stream analysis must be conducted before other MSW reduction projects may be planned and the benefits of each project can be accurately calculated.

RECYCLE WASTE OIL FROM FILTERS


Estimated Actual

Purchase filter presses to retrieve waste oil. CE 1 Oct 93

Distribute presses to shops identified as large quantity generators of filter waste (AGE, etc.).

CE 1 Nov 93

Collect waste oil and recycle through DRMO. Shops On-going

Collect filters and recycle, if feasible. Shops On-going

GLASS AND ALUMINUM RECOVERY


Estimated Actual

Purchase glass and can receptacles. MSW Team

1 Oct 95

Purchase material handling equipment and balers for processing recyclable material.

MSW Team

31 Jan 96

Store recyclable material in warehouse for contractor pickup. MWR On-going

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BASE RECYCLING PROGRAM


Estimated Actual

Outline goals and strategies for a base recycling program, and submit information to Education and Training subcommittee for approval.

MSW Team

31 Dec 93

Assign responsibilities and schedules for the program. MSW Team

1 Mar 94

Initiate program to increase participation in recycling efforts. MSW Team

1 Apr 94

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3.5 AFFIRMATIVE PROCUREMENT RCRA, as amended, and Executive Order 12873 establish Federal requirements for solid waste management and the procurement of products containing recovered materials. The U.S. EPA has designated the following specific items ("guideline items") containing recovered materials for procurement: paper and paper products, lubricating oils, retreaded tires, building insulation products, and cement and concrete containing fly ash. (Six additional guideline item categories have been proposed by EPA, but are not yet final.) The Executive Order requires agencies to review their specifications for these designated items and to procure materials containing recovered materials whenever possible. Establishing an affirmative procurement plan is integral to achieving this goal and should include the following: a preference program which establishes open competition between recycled and non-recycled material-containing products; a promotion program which actively promotes the desire to buy recycled products; and an annual review and monitoring program which evaluates the success of the affirmative procurement program. The following actions are necessary to implement the installation's affirmative procurement program and meet the EPA goal that 100% of the guideline items purchased will contain recycled material.

PROCUREMENT OF RECYCLED MATERIALS


Estimated Actual

Identify products used for which a recycled alternative exists (i.e., recycled computer disks, paper and paper products, retread tires, etc.).

LG 1 Oct 93

Identify the costs associated with procuring recycled products from different vendors, as compared with new products.

LG 1 Nov 93

Investigate the feasibility of procuring recycled products from the General Services Administration (GSA).

LG 1 Dec 93

Identify the most cost effective vendor, negotiate contracts, and procure.

LG 1 Apr 94

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3.6 ENERGY CONSERVATION Executive Order (E.O.) 12902 and the Energy Policy Act of 1992 extended the energy conservation goals of the Federal Energy Management Improvement Act (FEMIA) of 1988. FEMIA had initially established the goal to reduce energy consumption by 10%, per square foot, in Federal buildings between 1985 and 1995. The new requirements extended the FEMIA Federal building reduction goal to the year 2005, and required a reduction of 25% per gross square foot, measured in Btus compared to the 1985 baseline. ___ AFB has a very proactive energy conservation program that is pursuing programs to accomplish these conservation goals. The following list is a compilation of existing and proposed energy conservation programs. If these programs are implemented, ___ AFB will meet and exceed the pollution prevention goal of reducing Btu consumption by 25% per square foot from the 1985 baseline levels.

REDUCE BASE HEAT BY 3 DEGREES


Estimated Actual

Promote base-wide energy conservation awareness. Energy Team

On-going

Present a mock energy bill to commanders and shop chiefs, demonstrating requirements.

CEOE 1 Dec 93

Make items available to base populace to help conserve heat energy.

Energy Team

1 Dec 93

Investigate the feasibility of implementing physical controls of heat usage.

CEOE 31 Dec 93

Provide incentives for heat reduction. Energy Team

On-going

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REPLACE HTHW PLANT LINES


Estimated Actual

Conduct an energy analysis of the HTHW plant lines to determine where energy is lost.

Energy Team

31 Jan 94

Prioritize replacement on a "worst-first" basis. Energy Team

1 Mar 94

Establish contracts for line replacement, taking advantage of funding sources which do not subtract from the Wing's budget.

CEOE, CNS

(OCR)

31 Aug 94

Oversee replacement of HTHW lines. Energy Team

1 Jan 95

RETROFIT FAMILY HOUSING BOILERS


Estimated Actual

Establish a natural gas service contract with a local utility. CEOE, CNS

(OCR)

1 Apr 96

Establish contracts for the installation of the boilers. CEOE, CNS

(OCR)

1 Oct 96

Convert from #2 fuel oil to a firm natural gas service. CEOE 31 Dec 96

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ATTACHMENT 1 PROJECT NARRATIVES

PROJECT NUMBER: XX-XXXXX

PROJECT TITLE: Purchase Jet Washing System

REQUIREMENT: Non-recurring, Level PII

INSTALLATION: ____ AFB

Current Process: Present cleaning method involves 1960-era dip vats which are outdated, ineffective, and labor intensive. Dip vats are hard to find parts for and not easily repaired. Only three of the six vats are now in operation. Open vat units allow large amounts of volatilization and account for unpleasant working conditions caused by vapor and odor residue.

New Process: Install self-contained unit to wash all TF39 engine components in building 719. This project will eliminate use of more than 2,000 gallons of descaler and 2,500 gallons of emulsion degreaser per year and will decrease HW disposal from 36 drums/year to 12 drums/year. Replacement of dip vats with self-enclosed washer units will enhance worker safety and reduce volatilization and vapor odor and residue. In addition, installation of the self-contained parts washer will eliminate the need for existing hand wash tables and ensuing worker hazards. The cleaning operations will also be run more efficiently with installation of the new system as only one individual is required to operate the system, as opposed to two previously, and 50% more parts will be washed in the same amount of time. POLLUTION PREVENTION GOAL: Will accomplish 5% of the base requirement to reduce HW disposal by 25% by 1996 and 5% of the base requirement to reduce ITP chemical purchases.

SAVINGS: HW Disposal Costs ($0.75/lb x 13,500 lb = $10,125) ITP Purchase Savings (4,500 gallons x $1/gal = $4,500) TOTAL: $14,625. COSTS: Equipment and Facility Modification $250,000/(14,625-0)= 17.09 Payback/ROI is approximately 17 years FUND APPROPRIATION: 3080 FEDERAL STOCK NO./CLASS: XXXX-XX-XXXXX-XXX INITIATIVE SOURCE: ____ Air Force Base Minimization Report APPLICATION TO OTHERS: Industry Wide

installation pollution prevention program guide · 1.4 purpose and organization of guide 1-3 2....

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