4. Ft-Buch Pollution Prev & Sust Plan-2015.pdf

USAG FORT BUCHANAN

POLLUTION PREVENTION AND

SUSTAINABILITY PLAN

Prepared by:

The U.S. Army Public Health Command

Waste Management Program Report No. S.0026525.15

Aberdeen Proving Ground, MD 21010-5403

January 2015

Fort Buchanan P2 Plan

The use of trademarked names does not imply endorsement by Fort Buchanan or the U.S. Army but is intended only to assist in the identification of a specific product.

i

Summary Table of Proposed Initiatives

ENVIRONMENTAL

MEDIA POTENTIAL P2 INITIATIVE SECTION STATUS

ESTIMATED

IMPLEMENTATION

DATE

Hazardous Waste

Reinstate oversight of hazardous waste generated by all organizations.

5.6.1

Implement a Hazardous Material Management Program.

5.6.2

Solid Waste

Evaluate locations and placements of recycling dumpsters.

6.6.1

Collect and recycle steel cans. 6.6.2

Investigate and implement in-vessel composting of food and yard waste.

6.6.3

Energy Conservation

Track and analyze maintenance of all utility equipment.

7.6.1

Minimize building miscellaneous and plug loads.

7.6.2

Promote building occupant conservation behavior.

7.6.3

Treat wastewater for nonpotable reuse. 7.6.4 ii

ENVIRONMENTAL

MEDIA POTENTIAL P2 INITIATIVE SECTION STATUS

ESTIMATED

IMPLEMENTATION

DATE

Green Procurement

Inventory hazardous materials and identify green alternatives.

8.4.1

Incorporate green procurement operational controls.

8.4.2

Promote green procurement. 8.4.3 iii

TABLE OF CONTENTS

SUMMARY TABLE OF PROPOSED POLLUTION PREVENTION INITIATIVES ........... i

CHAPTER 1 INTRODUCTION

1.1 PURPOSE

1.2 SUSTAINABILITY

1.3 POLLUTION PREVENTION

1.4 NET ZERO

1.5 ENVIRONMENTAL MANAGEMENT

CHAPTER 2 POLLUTION PREVENTION REGULATORY BACKGROUND

2.1 FEDERAL LEGISLATION

2.2 COMMONWEALTH OF PUERTO RICO REGULATIONS

2.3 PRESIDENTIAL EXECUTIVE ORDERS

2.4 DOD DIRECTIVES, INSTRUCTIONS, PLAN, AND POLICY

2.5 OTHER GUIDANCE

CHAPTER 3 STATUS OF PREVIOUSLY RECOMMENDED INITIATIVES

CHAPTER 4 MEDIA DATA TABLES

CHAPTER 5 HAZARDOUS AND INDUSTRIAL WASTE REDUCTION

5.1 REDUCTION GOALS AND OBJECTIVES

5.2 SEMS OBJECTIVES AND TARGETS

5.3 BASELINE AND PROGRESS

5.4 DIVERSION OF INDUSTRIAL WASTE

5.5 CURRENT P2 INITIATIVE

5.6 POTENTIAL P2 INITIATIVES

CHAPTER 6 SOLID WASTE REDUCTION

6.1 SOLID WASTE REDUCTION GOALS

6.2 SEMS OBJECTIVES AND TARGETS

6.3 BASELINE AND PROGRESS

6.4 SOLID WASTE COLLECTION, RECYCLING, AND DISPOSAL

6.5 CURRENT P2 INITIATIVES

6.6 POTENTIAL P2 INITIATIVES

iv

CHAPTER 7 ENERGY CONSERVATION

7.1 ENERGY CONSERVATION GOALS AND REQUIREMENTS

7.2 SEMS OBJECTIVES AND TARGETS

7.3 BASELINE AND PROGRESS

7.4 DESCRIPTION OF ENERGY SOURCES

7.5 CURRENT P2 INITIATIVES

7.6 POTENTIAL P2 INITIATIVES

CHAPTER 8 GREEN PROCUREMENT

8.1 GREEN PROCUREMENT GOALS AND REQUIREMENTS

8.2 SEMS OBJECTIVES AND TARGETS

8.3 CURRENT P2 INITIATIVES

8.4 POTENTIAL P2 INITIATIVES

APPENDICES

APPENDIX A - REFERENCES

APPENDIX B - DOD 2014 SUSTAINABILITY OBJECTIVES AND GOALS

APPENDIX C - SUMMARY P2 AND SUSTAINABILITY GOALS

GLOSSARY

TABLES

1-1. Fort Buchanan Tenant Activities 3-1. Status of 2009 P2 Study Proposed Initiatives 4-1. Air Emissions Summary 4-2. Water Consumption Summary 4-3. 2013 TRI Chemical Releases by Source Category 4-4. Class I and II ODS Summary 4-5. Garrison Light Duty Fleet Vehicles by Fuel Type 4-6. Garrison Vehicle Petroleum Fuel Consumption 4-7. Pesticide Use Summary 5-1. SEMS Objective and Target to Reduce HW 5-2. Current P2 Initiative and SEMS Target to Reduce HW 5-3. Proposed P2 Initiatives and Target to Reduce HW 5-4. Garrison HW Generation 5-5. Fort Buchanan Recycled Industrial Waste 5-6. Tenant Organization EPA ID Numbers 6-1. SEMS Objective and Targets to Reduce SW 6-2. Current P2 Initiatives and SEMS Targets to Reduce SW 6-3. Proposed P2 Initiatives and SEMS Targets to Reduce SW 6-4. Fort Buchanan SW Diversion Summary v

6-5. Fort Buchanan C&D Waste Diversion Summary 6-6. Tons of Materials Recycled from FY 2009 Through FY 2014 6-7. Comparison of Three In-Vessel Composting Systems 7-1. SEMS Energy Conservation Objectives and Targets 7-2. Current Energy Conservation P2 Initiatives and SEMS Targets 7-3. Proposed Energy Conservation P2 Initiatives and SEMS Targets 7-4. Fort Buchanan Facility Energy Intensity 7-5. Fort Buchanan Electricity from Renewable Energy Sources 8-1. SEMS Objective and Targets for GP 8-2. Current GP P2 Initiatives and SEMS Targets 8-3. Proposed GP Initiatives and SEMS Targets

FIGURES

1-1. Net Zero Waste Hierachy 1-2. Net Zero Hierarchy vi

CHAPTER 1

INTRODUCTION

1.1 PURPOSE AND SCOPE

1.1.1 Purpose

This Pollution Prevention (P2) and Sustainability Plan reestablishes the U.S. Army Garrison (USAG) Fort Buchanan’s commitment to environmental leadership by outlining the concepts and practices necessary to reduce the use of hazardous materials (HMs) and the release of pollutants to as near zero as is feasible. All of Fort Buchanan's personnel will use this plan to develop ways to minimize the environmental impacts of their activities and achieve the Federal, Department of Defense (DOD), and U.S. Army’s P2 and sustainability goals. This plan will also be used as a tool to document, track, and manage installation efforts in pursuit of achieving the DOD and Army’s strategy of Net Zero and environmental sustainability.

This plan updates the solid waste (SW), hazardous waste (HW), green procurement (GP), and energy conservation chapters of the Fort Buchanan 2009 Pollution Prevention Plan (reference 1-1). The P2 initiatives recommended in the 2009 plan were evaluated and implementation information is provided in Chapter 3. Chapter 4 provides data tables for the environmental chapters not evaluated in this update (air emissions, drinking and wastewater, ozone depleting substances (ODSs), vehicle fuel conservation and alternate fuel vehicles, and toxic release inventory chemicals).

1.1.2 Summary Table, References, and Abbreviations

A summary table of all proposed P2 initiatives is presented at the front of this plan.

Publications and prescribed references are listed in Appendix A. Abbreviations and special terms used in this plan are defined in the Glossary.

The 2014 DOD sustainability goals are provided in Appendix B. A summary of published or codified P2 goals applicable to Fort Buchanan is provided in Appendix C.

The goals are listed as they apply to each environmental media area along with the regulatory citation, the implementation date, and the target date of when a particular goal is to be achieved.

1.1.3 Organization

The Director of Public Works (DPW) is the advisor to the Commander and responsible for maintaining and repairing all of the infrastructure and facilities at Fort Buchanan.

The DPW is charged with ensuring the stability of installation facilities and environmental practices; directorate responsibilities include Engineering Design, Master Planning, Maintenance & Repair, Environmental Division, and Utilities operations.

The Environmental Division is responsible for developing and implementing the installation’s environmental programs through compliance with all environmental laws and regulations, preventing pollution, and protecting, conserving, and sustaining natural resources for Soldiers, civilians, families, and the local community. The Environmental Division is comprised of three sections: Environmental Compliance, Environmental Conservation, and Energy Management. The Environmental Division manages the environmental program for the garrison and maintains oversight of the environmental programs of the tenant organizations. See Table 1-1 for a list of Fort Buchanan's tenant activities.

Table 1-1. Fort Buchanan Tenant Activities1

1st Mission Support Command Det 1, 2/231st Reg, 98th Div

1/350th Logistics Support Battalion 2/348th Reg, 158th IN Bde

402nd Civil Affairs Battalion (TAC) 5th Bde (MF), 80th TC, 94th Div

A/B Co (Drill Sgt), 108th Tng Cmd 1/389th Reg, 1st Bde, 98th Div

Army and Air Force Exchange Service (AAFES) AAFES Concessionaires

Banco Popular de Puerto Rico Defense Commissary Agency

Domestic Dependent Elementary and Secondary Schools

Defense Military Pay Office

Defense Contracting Audit Agency TRICARE

Puerto Rico National Guard (PRNG) Counterdrug Program

832d Transportation Battalion

Army Reserve Officers’ Training Corps U.S. Marine Corps 3rd Longshoreman Det, 4th LS

Navy Operational Support Center Combat Battalion Warrior Transition Unit

Rodriguez Army Health Clinic Veterinary Detachment, South Atlantic District Veterinary Command

Civilian Personnel Advisory Center Mission and Installation Contracting Office

U.S. Army Criminal Investigation Division PRNG U.S. Property & Fiscal Office

Military Entrance Processing Station Defense Logistics Agency

Network Enterprise Center (NEC) Logistics Readiness Center (LRC)

Pentagon Federal Credit Union U.S. Customs & Border Protection

Note:

Information derived from http://www.buchanan.army.mil/.

1.2 SUSTAINABILITY

Executive Orders (EO) 13423 and 13514 define sustainability as the means to create and maintain conditions, under which humans and nature can exist in productive harmony, that permit fulfilling social, economic, and other requirements of present and future generations of Americans. (See Chapter 2 for more details.)

1.2.1 DOD Sustainability

The DOD vision of sustainability is to maintain the ability to operate into the future without decline—either in the mission or in the natural and man-made systems that support it. It embraces sustainability as a critical enabler in the performance of the mission, recognizing that it must plan for and act in a sustainable manner now in order to build an enduring future. Sustainability is not an individual departmental program;

rather, it applies to all DOD mission and program areas. For this reason, many DOD efforts to drive improved sustainability reach across topical and organizational boundaries, in keeping with the interdisciplinary and synergistic nature of sustainability (reference 1-2).

The 2010 DOD Strategic Sustainability Performance Plan was developed to comply with the requirements of EO 13514 and beyond. It establishes mission-oriented objectives, goals and sustainability performance expectations through fiscal year (FY) 2020, providing the path by which DOD will improve mission, lower life-cycle costs, and advance technologies and practices that further the sustainability goals of the Nation.

The plan is updated each year to show how the DOD has progressed in the meeting the goals. The DOD 2014 mission-oriented objectives and associated goals are provided Appendix B.

1.2.2 Army Sustainability

The Army Strategy for the Environment: Sustain the Mission – Secure the Future states that “a sustainable Army simultaneously meets current as well as future mission requirements worldwide, safeguards human health, improves quality of life, and enhances the natural environment.” This strategy transitions the Army’s historically compliance-based environmental program to a mission-oriented approach based on the principles of sustainability, and it builds on the success of the Army’s strategic “beyond compliance” activities in areas such as P2 and ecosystem management.

Sustainability planning seeks approaches that simultaneously satisfy mission, environmental, and community needs through innovative systems thinking while also trying to reduce long-term costs, including waste treatment and disposal costs, facility operating and maintenance costs, and energy costs. The Army's sustainability vision provides the transformational approach for operating successfully under challenging conditions. It was developed to provide the Army with a systems approach to the triple bottom line of mission, environment, and community. The Army adapts the triple bottom line to its national security mission in its "mission, community, and environment" paradigm. It promulgates six goals to successfully meet the Army's triple bottom line (reference 1-3). The goals of the Army's sustainability strategy are:

Foster a sustainability ethic: Foster an ethic within the Army that takes us beyond environmental compliance to sustainability.

Strengthen Army operations: Strengthen Army operational capability by reducing our environmental footprint through more sustainable practices.

Meet test, training, and mission requirements: Meet current and future training, testing, and other mission requirements by sustaining land, air, and water resources.

Minimize impacts and total ownership costs: Minimize impacts and total ownership costs of Army systems, material, facilities, and operations by integrating the principles and practices of sustainability.

Enhance well-being: Enhance the well-being of our Soldiers, civilians, families, neighbors, and communities through leadership in sustainability.

Drive innovation: Use innovative technology and the principles of sustainability to meet user needs and anticipate future Army challenges.

1.2.3 Fort Buchanan Sustainability

Fort Buchanan supports the Army Sustainability Campaign Plan and Army Strategy for the Environment: Sustain the Mission – Secure the Future (reference 1-4). Our vision is powered by the recognition of our obligation to ensure that our Soldiers today-and the Soldiers of the future-have the land, water, and air resources they need to train; a healthy environment in which to live; and the support of local communities and the American people.

Sustainable Fort Buchanan works to improve energy security and decrease reliance on petroleum; reduce unnecessary impacts to lands and restore natural habitat; reduce environmental compliance risks; eliminate waste; enhance human health, safety, and well-being; and conserve water for human and ecosystem needs. Our sustainability goals are to meet or exceed the DOD sustainability goals (Appendix B).

1.3 POLLUTION PREVENTION

Pollution prevention is an integral step in achieving Army sustainability goals such as Net Zero. Specifically, P2 encompasses those activities which reduce the quantity of hazardous, toxic, or industrial pollutants at the source by changing the waste generating process. In addition, P2 is not limited to hazardous pollutants released to air, water, and land, but also includes activities to reduce the amounts of nonhazardous commercial and household wastes and the consumption of energy or natural resources.

The Pollution Prevention Act of 1990 defines P2 ("source reduction") as any practice which—

"... 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, or disposal; and reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants" (reference 1-5).

Pollution prevention is any mechanism that successfully and cost-effectively avoids, prevents, or reduces the sources of pollutant discharges or emissions other than the traditional method of treating pollution at the discharge end of a pipe or stack. In this way, P2 is the initial step of the path that leads to sustainable operations.

1.3.1 Pollution Prevention and Net Zero Waste

Pollution prevention has evolved into the more comprehensive concept of Net Zero.

The components of Net Zero include reducing the amount of waste generated, repurposing, maximizing recycling of the waste stream to reclaim recyclable and compostable materials, recovery to generate energy as a by-product of waste reduction, and finally disposal as a last resort. This is illustrated in Figure 1-2(Net Zero Waste Hierarchy). The key to Net Zero, however, is to integrate decisions regarding waste management with the goals for reducing energy and water. This is accomplished by incorporating Net Zero goals into facility long-term planning (including the master plan and sustainability plans), while evaluating the associated benefits and costs.

Examples of P2, and how they fall under the hierarchy, include:

Source Reduction. Substitution of a material with one having a lesser environmental impact, or changing a process so that it uses less of the material or generates less pollution.

Recycling. Reuse or regeneration of materials and wastes into useable products or by-products.

Energy Recovery. This includes waste-to-energy processes.

Treatment. Change in the form or composition of a waste stream, to minimize the quantity or toxicity of waste discharged into the environment.

Disposal. Disposal is the least preferred method of any waste reduction program.

Figure 1-1. Net Zero Waste Hierarchy

1.3.2 Benefits of Pollution Prevention

As the concern for the environment has risen, increased environmental regulation and public awareness have raised the standards, costs, and potential liabilities of waste management practices. Waste and resource management programs that adopt P2 principles can realize benefits in many different ways:

Major contributing factor to reaching the Army’s Net Zero goals.

Reduced costs associated with the procurement and storage of HM and subsequent disposal of HW.

Reduced costs associated with the management, treatment, and disposal of solid and HW.

Decreased use of energy and natural resources.

Enhanced relations with the public, neighboring communities, and regulators.

Reduced costs of complying with environmental and HM regulations, and diminished risk of noncompliance.

Reduced future compliance liability.

Improved long-term environmental quality and prevention of environmental degradation.

1.3.3 Fort Buchanan Pollution Prevention Policy and Program

Fort Buchanan is committed to reducing the amount and toxicity of pollution it generates. As part of its commitment, the installation gives priority to efforts based on source reduction methods. The Fort Buchanan policy statement and P2 program are described in the Fort Buchanan Pollution Prevention and Fort Buchanan Pollution Prevention Program policy memoranda (references 1-6 and 1-7).

1.4 NET ZERO

Net Zero is a strategy that strives to bring the overall consumption of resources on installations down to an effective rate of zero. Net Zero is comprised of five interrelated steps: reduction, repurpose, recycling and composting, energy recovery, and disposal.

Each step is a link towards achieving Net Zero. Reduction includes maximizing energy efficiency in existing facilities, implementing water conservation practices, and eliminating generation of unnecessary waste. Repurpose involves diverting energy, water or waste to a secondary purpose with limited processes. Recycling or composting involves maximizing diversion of materials from the SW stream, development of closed-loop systems to reclaim water, or cogeneration where two forms of energy (heat and electricity) are created from one source. Energy recovery can occur from converting unusable waste to energy, renewable energy or geothermal water sources. Disposal is the final step after all other mitigation strategies have been fully exercised (reference 1-8).

Figure 1-2. Net Zero Hierarchy

1.4.1 Army Net Zero

The Army’s Net Zero initiative is built upon the Army’s long-standing energy efficiency and sustainability practices. The Assistant Secretary of the Army for Installations, Energy and Environment developed the Army's Net Zero Installation Strategy. The goal is for installations to be net zero, based on net zero energy, net zero water and net zero waste, all striving towards sustainable installations. The Army’s Net Zero vision is a holistic approach to addressing energy, water, and waste at installations:

A net zero installation is one which applies an integrated approach to management of energy, water, and waste to capture and commercialize the resource value and/or enhance the ecological productivity of land, water, and air.

A net zero energy installation produces as much energy onsite as it uses over the course of a year.

A net zero water installation limits the consumption of freshwater resources and returns water back to the same watershed so not to deplete the groundwater and surface water resources of that region in quantity or quality.

A net zero waste installation reduces, reuses, and recovers waste streams, converting them to resource values with zero landfill.

1.4.2 Fort Buchanan Net Zero

Fort Buchanan was selected as an Army Net Zero water pilot installation. It serves as a test bed to identify lessons learned and best practices to be institutionalized across the Army. All installation building projects must incorporate water consumption reduction technologies and practices that represent an operational cost saving to the Army.

Some of the technologies and practices that must be implemented include rain water harvesting, onsite stormwater retention and infiltration, implementation of the Environmental Protection Agency’s (EPA’s) WaterSense program for low flow fixtures, and recycling of condensate water from high velocity heating, ventilation, and air conditioning (HVAC) and other refrigeration systems. More information is found in the Fort Buchanan Sustainable Design Guide for New Construction & Major Renovations (reference 1-9).

1.5. ENVIRONMENTAL MANAGEMENT

Environmental management systems (EMSs) are identified in both EO 13514 and EO 13423 as the management framework which agencies and facilities should use to identify and achieve their sustainability goals and targets. An EMS is a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency. It is a framework that helps achieve environmental goals through consistent control of operations. The theory is that this increased control will improve the environmental performance of an organization. The Fort Buchanan EMS program is referred to as the Sustainability and Environmental Management System (SEMS).

1.5.1 Army Environmental Management

The Army EMS policy requires all designated appropriate facilities to implement and maintain mission-focused, ISO 14001: 2004-conformant EMSs that includes environmental aspects of all activities, products, and services of all installation missions, sub-installations, facilities (including government owned and contractor owned), tenants, and contractors.

1.5.2 Fort Buchanan Environmental Management Policy

Environmental protection and safety are essential elements in the mission of the U.S.

Army and Fort Buchanan. Successfully blending the military mission with a commitment to safety and environmental stewardship is Army policy. In keeping with this policy, Fort Buchanan strives to proactively address environmental and safety issues by communicating its policy with neighboring communities and various interested parties.

Fort Buchanan’s SEMS policy is stated in Policy Memorandum 23, Fort Buchanan Environmental Management, 7 February 2013 (reference 1-10).

CHAPTER 2

POLLUTION PREVENTION REGULATORY BACKGROUND

The DOD’s P2 policies originate in legislation enacted by the U.S. Congress. Executive Orders direct Federal agencies, including the DOD, to conform to Federal legislation and may impose additional requirements that are not founded in legislation. The DOD issues directives and instructions in response to the EOs. These DOD policy statements are interpreted and promulgated in regulations, pamphlets, and other policy documents. This chapter provides summaries of the major laws, EOs, and DOD policy statements pertaining to P2. Due to the wide-reaching nature of P2 issues and frequent changes to laws and regulations, the list is not intended to be all-inclusive.

2.1 FEDERAL LEGISLATION

2.1.1 Clean Water Act of 1972

The Clean Water Act (reference 2-1) requires certain discharges of storm water to be permitted under either an individual or general permit. Discharges of storm water from industrial activities, construction, and municipal separate storm sewer systems (MS4s) are among those that require permit coverage.

2.1.2 Resource Conservation and Recovery Act

The Resource Conservation and Recovery Act (RCRA) was enacted in 1976 as an amendment to the Solid Waste Disposal Act. RCRA was early legal impetus for P2 practices, requiring "... it shall be a condition of any permit issued under this section for the treatment, storage, or disposal of HW on the premises where such waste was generated that the permitee certify, no less often than annually, that the generator of the HW has a program in place to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be economically practicable" (reference 2- 2).

2.1.3 Comprehensive Environmental Response, Compensation, and Liability Act of 1980

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 and the Superfund Amendments and Reauthorization Act (1986) regulate prevention, control, and compensation of environmental pollution. This act is commonly referred to as "Superfund" and regulates the cleanup of contaminated HW sites and releases of hazardous substances into the environment. The CERCLA list of hazardous substances is published in Title 40, Code of Federal Regulations (CFR), Part 302 and in 49 CFR Part 172.101, Appendix A. The Defense Environmental Restoration Program is the DOD program that implements CERCLA (reference 2-3).

2.1.4 Hazardous and Solid Waste Amendments of 1984

The Hazardous and Solid Waste Amendments, enacted in 1984, reauthorized and amended RCRA and imposed new and far-reaching requirements for HW management.

The amendments established programs to regulate small quantity generators of HW (between 100 and 1,000 kilograms of waste/month), restricted land disposal of HW, established minimum technology requirements for land disposal units, required corrective actions for releases of HW, regulated underground storage tanks containing petroleum products or hazardous substances, initiated listing of new materials as HW, and set deadlines for the EPA to issue or deny HW facility operating permits (reference 2-4).

2.1.5 Pollution Prevention Act of 1990

Facilities that are required to report releases for the Toxic Release Inventory (TRI) under the Emergency Planning and Community Right-to-Know Act of 1986 must provide documentation of their procedures for preventing the release of or for reusing these materials. However, the P2 Act goes beyond wastes designated as hazardous. Its intent is to force industries to reduce or prevent pollution at the source. In addition to source reduction, the P2 Act also emphasizes reuse and closed-loop recycling whenever possible. The emphasis is fundamentally different from offsite recycling, treatment, and disposal as primary ways to handle waste. The P2 Act first established, as comprehensive national policy, the P2 hierarchy (reference 2-5).

2.1.6 Energy Policy Act of 2005

The Energy Policy Act of 2005 (EPAct 2005) consists of several major provisions to include annual energy use reduction goals, renewable energy purchase goals, reauthorization of energy performance contracts, Federal procurement requirement of Energy Star® or Federal Energy Management Program (FEMP) designated products, and updated standards of Federal green buildings (reference 2-6).

2.1.7 Energy Independence and Security Act of 2007

The Energy Independence and Security Act of 2007 (EISA 2007) in some cases reaffirms goals set in the EPAct of 2005 and in other cases expands previous goals (reference 2-7).

2.1.8 The National Defense Authorization Act (NDAA) of 2007

The NDAA of 2007 codified the 25 percent renewable goal established by DOD memorandum in November 2005 (reference 2-8). The Army Energy Strategy for Installations adopted in July of 2005 established an objective to “Reduce the dependency on fossil fuels by increasing the use of clean, renewable energy …” The NDAA language is consistent with the DOD‘s and the Army‘s renewable energy plans and the renewable resource assessments and plans upon which they are based.

Accordingly, the renewable resource goal for the Army shall be: “To produce or procure energy from renewable resources equivalent to at least 25 percent of its electricity use by no later than 2025.”

2.2 COMMONWEALTH OF PUERTO RICO REGULATIONS

In Puerto Rico, HW is regulated by the Public Policy Environmental Act of 1970 (reference 2-9) and the Puerto Rico Environmental Quality Board Regulation for the Control of Dangerous Solid Wastes (reference 2-10). The Puerto Rico HW regulations are similar and essentially equivalent to the RCRA HW regulations. Until the EPA authorizes Puerto Rico to implement its HW program in lieu of the Federal scheme, both the local and Federal HW regulations are enforceable.

In addition to the Federal regulations, SW in Puerto Rico is regulated by the Puerto Rico Regulation for the Handling of Non-Dangerous Solid Waste (reference 2-11). Two Commonwealth agencies, the Puerto Rico Solid Waste Management Authority and the Puerto Rico Environmental Quality Board (PREQB) are responsible for managing the island's SW.

Puerto Rico does not have primacy for the Clean Water Act regulation. There are no separate laws for the Commonwealth of Puerto Rico concerning water conservation and wastewater. The PREQB enforces the applicable Federal laws concerning water and wastewater.

2.3 PRESIDENTIAL EXECUTIVE ORDERS

While many of the goals established in the following EOs apply to the agency (DOD) level of the Federal government, Fort Buchanan matches the requirements in order to assist the Department of Army (DA) and DOD in meeting their goals. Each of these goals, except where noted as being revoked or superseded, is addressed in this plan.

2.3.1 Executive Order 13423, Strengthening Federal Environmental, Energy and Transportation Management, January 2007

The EO sets goals in the areas of energy efficiency, acquisition, renewable energy, toxics reduction, recycling, sustainable buildings, electronics stewardship, fleets, and water conservation. This EO requires Federal agencies to lead by example in advancing the nation’s energy security and environmental performance (reference 2- 12). It also requires use of the EMS as the framework for managing and continually improving sustainable practices. The EO consolidates five prior EOs (13101, 13123, 13134, 13148, and 13149) and integrates the sustainable practices of those orders into a more cohesive approach for environmental and energy management.

Vehicles. Use plug-in hybrid (PIH) vehicles when commercially available at a cost reasonably comparable, on the basis of life-cycle cost, to non-PIH vehicles.

Petroleum Conservation. Reduce petroleum consumption in fleet vehicles by 2 percent annually through the end of FY 2015, relative to the agency baseline for FY 2005. (Updates expired goals of EO 13149.)

Alternate Fuel Use. Increase alternative fuel consumption (non-petroleum based) at least 10 percent annually, relative to the agency baseline for FY 2005.

Energy Efficiency. Reduce energy intensity by 3 percent annually or 30 percent by the end of FY 2015, relative to the baseline of the agency’s energy use in FY 2003. (The new 30 percent energy efficiency goal seeks to achieve in 10 years the same level of improvement that Federal agencies achieved in the last 20 years and is 50 percent more stringent than the goal in the EPAct of 2005.)

Energy intensity is the energy use per square foot of building area.

Greenhouse Gases. Reduce greenhouse gas (GHG) emissions through reduction of energy intensity by 3 percent annually or 30 percent by the end of FY 2015, relative to the baseline of the agency’s energy use in FY 2003. (30 percent will be realized through other EO goals that will exceed the prior 30 percent goal set in EO 13123.)

Renewable Power. At least 50 percent of current renewable energy purchases must come from new renewable sources (in service after 1 January 1999); and to the extent feasible, the agency will implement renewable energy generation projects on agency property for agency use. (The EPAct of 2005 sets a renewable energy goal but does not require that any percentage come from new sources. The prior EO 13123 set a goal of 2.5 percent for renewable power purchases.)

Building Performance. Ensure that new construction and major building renovations comply with sustainability strategies, including resource conservation, reduction, and use; siting; and indoor environmental quality, and 15 percent of the existing Federal capital asset building inventory of the agency as of the end of FY 2015, incorporate the referenced sustainable practices. (The order makes mandatory the elements of the High Performance Buildings Memorandum of Understanding signed by 19 agencies in January 2006.)

Water Conservation. Beginning in FY 2008, reduce water consumption intensity by 2 percent annually through the end of FY 2015, or 16 percent by the end of FY 2015, relative to the baseline of the agency’s water consumption in FY 2007.

(Prior orders did not include such a goal.) Water intensity is the water use per square foot of building area.

Procurement. Expand purchases of environmentally-sound goods and services, including biobased, environmentally preferable, energy-efficient, water-efficient, and recycled-content products; and require use of paper of at least 30 percent post-consumer fiber content. (The new EO and guidance require agencies to integrate four existing disparate purchasing requirements into an integrated Federal purchasing effort that applies to all types of acquisitions of goods and services. Federal purchasing of energy-efficient, recycled-content, biobased, and environmentally preferable products will increase as a result. The EO also continues the requirement that agencies purchase office paper containing 30 percent post-consumer fiber.)

Pollution Prevention. Reduce the quantity of toxic and hazardous chemicals and materials acquired, used, or disposed of by the agency; increase diversion of SW as appropriate; and maintains cost-effective waste prevention and recycling programs in its facilities.

Electronics Management. Annually, 95 percent of electronic products purchased must meet Electronic Product Environmental Assessment Tool (EPEAT) standards where applicable; enable Energy Star features on 100 percent of computers and monitors; and reuse, donate, sell, or recycle 100 percent of electronic equipment that has reached the end of its useful life using environmentally sound management practices. (The order makes mandatory the elements of the 2004 Federal Electronics Stewardship Memorandum of Understanding signed by 12 agencies and the Executive Office of the President.)

Environmental Management Systems. Implement EMS at all appropriate organizational levels to ensure use of EMS as the primary management approach for addressing environmental aspects of internal agency operations and activities. The Instructions for Implementing Executive Order 13423 state that the EMS objectives shall include the goals identified in Section 2 of the EO (reference 2-29).

2.3.2 Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, October 2009

The goal of this EO is "to establish an integrated strategy towards sustainability in the Federal Government and to make reduction of GHG emissions a priority for Federal agencies." EO 13514 introduces new GHG emissions management requirements, expands water reduction requirements for Federal agencies, and addresses waste diversion, local planning, sustainable buildings, environmental management, and electronics stewardship (reference 2-13).

This EO does not rescind or eliminate the requirements of EO 13423. Instead, it expands on the energy reduction and environmental performance requirements for Federal agencies identified in EO 13423. All the provisions of EO 13423 remain in effect.

Establish a percentage reduction target for agency-wide reductions of scope 1 and 2 GHG emissions in absolute terms by FY 2020, relative to a FY 2008 baseline.

Establish a percentage reduction target for reducing agency-wide scope 3 GHG emissions in absolute terms by FY 2020, relative to a FY 2008 baseline.

Reduce, if the agency operates a fleet of at least 20 motor vehicles, the agency fleet’s total consumption of petroleum products by a minimum of 2 percent annually through the end of FY 2020, relative to a baseline of FY 2005.

Reduce potable water consumption intensity by 2 percent annually through FY 2020, or 26 percent by the end of FY 2020, relative to a baseline of the agency’s water consumption in FY 2007.

Reduce agency industrial, landscaping, and agricultural water consumption by 2 percent annually or 20 percent by the end of FY 2020, relative to a baseline of the agency’s industrial, landscaping, and agricultural water consumption in FY 2010.

Consistent with State law, identify, promote, and implement water reuse strategies that reduce potable water consumption.

Implement and achieve the objectives identified in the stormwater management guidance provided by the EPA for implementation of section 438 of the Energy Independence and Security Act of 2007, which requires that any development or redevelopment project involving a Federal facility with a footprint that exceeds 5,000 square feet shall use site planning, design, construction, and maintenance strategies for the property to maintain or restore, to the maximum extent technically feasible, the predevelopment hydrology of the property with regard to the temperature, rate, volume, and duration of flow.

Divert at least 50 percent of nonhazardous SW, excluding construction and demolition (C&D) debris, by the end of FY 2015.

Divert at least 50 percent of C&D materials and debris by the end of FY 2015.

Reduce printing paper use and acquire uncoated printing and writing paper containing at least 30 percent postconsumer fiber.

Reduce and minimize the quantity of toxic and hazardous chemicals and materials acquired, used, or disposed of.

Decrease agency use of chemicals where such decrease will assist the agency in achieving GHG emission reduction targets.

Beginning in 2020 and thereafter, ensure that all new Federal buildings that enter the planning process are designed to achieve zero-net-energy by 2030.

Ensure that all new construction, major renovation, or repair and alteration of Federal buildings complies with the Guiding Principles for Federal Leadership in High Performance and Sustainable Buildings (Guiding Principles).

Ensure that at least 15 percent of the agency’s existing buildings (above 5,000 gross square feet) and building leases (above 5,000 gross square feet) meet the Guiding Principles by FY 2015 and that the agency makes annual progress toward 100 percent conformance with the Guiding Principles for its building inventory.

Pursue cost-effective, innovative strategies, such as highly reflective and vegetated roofs, to minimize consumption of energy, water, and materials.

Ensure that 95 percent of new contract actions including task and delivery orders, for products and services with the exception of acquisition of weapon systems, are energy-efficient (Energy Star or FEMP designated), water-efficient, biobased, environmentally preferable (e.g., EPEAT) certified), non-ozone depleting, contain recycled content, or are nontoxic or less toxic alternatives, where such products and services meet agency performance requirements.

Promote electronics stewardship by:

o Ensuring procurement preference for EPEAT-registered electronic products.

o Establishing and implementing policies to enable power management, duplex printing, and other energy-efficient or environmentally preferable features on all eligible agency electronic products.

o Employing environmentally sound practices with respect to the agency’s disposition of all agency excess or surplus electronic products.

o Ensuring the procurement of Energy Star and FEMP designated electronic equipment.

o Implementing best management practices for energy-efficient management of servers and Federal data centers.

2.4 DOD DIRECTIVES, INSTRUCTIONS, PLAN, AND POLICY

2.4.1 DOD Instruction 4715.6, Environmental Compliance, 24 April 1996

This document implements policy, assigns responsibility, and prescribes procedures as established for achieving compliance with applicable EOs, Federal, state, inter-state, regional, and local statutory and regulatory environmental requirements (reference 2- 14).

2.4.2 DOD Instruction 4715.4, Pollution Prevention, 18 June 1996

This document provides specific guidance on P2 activities (reference 2-15). This instruction establishes the DOD requirement for installation Qualified Recycling Programs (QRPs), calls for Affirmative Procurement (AP), and authorizes direct sales of recyclables. It reiterates the P2 hierarchy principle and establishes the DOD P2 Measures of Merit for TRI releases reduction, HW reduction, nonhazardous SW diversion, and alternate fuel vehicles.

2.4.3 DOD Directive 4140.25, DOD Management Policy for Energy Commodities and Related Services, 12 April 2004

The purpose of this directive is to update policy and responsibilities to manage energy commodities (i.e., petroleum, natural gas, coal, electricity, steam, propellants, chemicals, pure gases, and cryogenic fluids), their quality assurance and quality surveillance, storage, and associated facilities (reference 2-16). This directive also minimizes the number and complexity of fuels required, maximizes the use of commercial fuels, and continues the authorization to publish DOD 4140.25-M, "DOD Management of Bulk Petroleum Products, Natural Gas, and Coal," and other DOD publications on the subject of energy commodities.

2.4.4 DOD Executive Order 13423, Agency-Level Toxic and Hazardous Chemicals Reduction Plan, 1 February 2008

This plan depicts the DOD programs, initiatives, and actions necessary to reduce procurement, use, release, and disposal of toxic and hazardous chemicals under EO 13423. The plan clarifies the DOD’s current status and planned next steps with regard to chemical management, both needed to ensure successful implementation of the EO.

DOD programs and initiatives relevant to chemical management are sequenced in the plan according to the three phases of the weapon systems and facilities lifecycle:

acquisition, operations and sustainment, and disposal (reference 2-17).

2.4.5 DOD Green Procurement Program Strategy, November 2008

The DOD Green Procurement Program (GPP) requires green products and services to be purchased to the maximum extent practicable. The responsibility for implementing DOD’s GPP lies not within any single organization, but with every person involved in the procurement process. This includes, but is not limited to, the technical/requirements planner, contracting specialist, contracting officer, persons requisitioning products or services through any source of supply, and government purchase card (GPC) holders.

The strategy document defines the GPP objectives and also provides metrics to measure the success of the GPP (reference 2-18).

2.4.6 DOD Instruction 4715.17, Environmental Management Systems, 15 April 2009

This DOD instruction establishes policy, assigns responsibilities, and prescribes procedures for achieving conformance with EMSs pursuant to EO 13423 (reference 2- 19).

2.4.7 DOD Instruction 4170.11, Installation Energy Management, 11 December 2009

DOD Instruction 4170.11 provides procedures for DOD installation energy management and pertains to all phases of administration, planning, programming, budgeting, operations, maintenance, training, and material acquisition activities that impact the supply, reliability, and consumption of energy at DOD installations (reference 2-20).

2.4.8 DOD Strategic Sustainability Performance Plan FY 2010, 26 August 2010

In response to the requirements of EO 13514, this first Departmental Strategic Sustainability Performance Plan (SSPP) lays out the goals and performance expectations for the next decade, establishing the path by which DOD will serve as a model of sustainability for the nation while enhancing their ability to achieve their mission. DOD sustainability goals include: reduce the use of fossil fuels; improve water resources management; minimize and optimally manage SW; minimize chemicals of concern; and reduce scope 1, 2, and 3 GHG emissions (reference 2-21).

Under EO 13514, all Federal agencies are required to develop, implement, and annually update a Sustainability Report that prioritizes actions to meet GHG emissions, energy, water, and waste reduction targets. The most recent DOD SSPP, available at the time of publication of this P2 Plan, is dated 31 October 2014 (reference 2-22). The plan reports DOD’s progress on meeting the goals of EO 13514. Federal agencies may implement additional or more stringent goals in their SSPPs.

2.4.9 DOD Sustainable Buildings Policy, 10 November 2013

In November 2013, the Office of the Under Secretary of Defense published a new sustainable buildings policy which supersedes the policy from October 2010. This revision establishes Unified Facilities Criteria (UFC) 1-200-02 as the sustainability standard for all DOD construction projects and requires DOD components to establish an auditable process to ensure compliance. The policy also states clearly that a building which complies with the UFC has met all applicable Federal standards for sustainability including the Guiding Principles for High Performance Sustainable Buildings (reference 2-23).

2.5 OTHER GUIDANCE

2.5.1 Memorandum, Department of the Army, Assistant Chief of Staff for Installation Management (ACSIM), subject: Change in Army Policy for the Elimination of Ozone Depleting Chemicals, 07 January 2003

With this memorandum, the ACSIM established the following changes (reference 2-24):

Chlorofluorocarbon (CFC) air conditioning and refrigeration (AC&R) equipment that needs periodic recharging may be used after calendar year (CY) 2003 as long as it is supported with CFC refrigerant that was recovered on-base.

Sealed CFC AC&R equipment (i.e., AC&R equipment that does not need recharging) may be used until retirement.

Halon 1301 fire suppression system may be used until discharged, but then must be retrofitted or retired.

2.5.2 Memorandum, Deputy Assistant Secretary of the Army for Installations and Housing, subject: Sustainable Design and Development Policy Update – SPiRiT to LEED Transition, 5 January 2006

This memorandum announced that the Army will transition from the Sustainable Project Rating Tool (SPiRiT) to the Leadership in Energy and Environmental Design (LEED) Green Building Rating System® effective with the FY 2008 Military Construction Program. It sets LEED Silver as the minimum sustainability rating for vertical New Construction projects. Prior year projects will continue to use SPiRiT and achieve Gold level (reference 2-25).

2.5.3 Memorandum, Assistant Secretary of the Army (Installations, Energy, and Environment), subject: Utilization of Efficient Lighting, 27 October 2010

This memorandum requires that all incandescent light bulbs acquired for use in facilities and structures owned, leased or controlled by the Army will meet the energy efficiency standards set forth in the EISA of 2007 Section 321(a)(3)(A) to the maximum extent feasible, with the goal of complete replacement of inefficient lighting within 5 years of the effective date of this memorandum (reference 2-26)1. When installed bulbs fail and the existing inventory is depleted, only efficient light bulbs may be purchased.

2.5.4 Memorandum, Secretary of the Army, subject: Army Directive 2014-02 (Net Zero Installations Policy), 28 January 2014

This memorandum sets policy and assigns responsibilities to strive toward Net Zero at all Army installations where fiscally responsible and in support of mission accomplishment (reference 2-27). It applies to all permanent Army, Army National Guard, and U.S. Army Reserve installations, sites and facilities operated and/or maintained by Federal funds.

2.5.5 Memorandum, Secretary of the Army, subject: Army Directive 2014-10 (Advanced Metering Utilities), 4 June 2014

This directive establishes policy and assigns responsibilities for installing advanced meters on utility systems (reference 2-28).

Note that proposed Federal legislation (as of Apr 2011) cited as the ‘Better Use of Light Bulbs Act‘ seeks to repeal all of Subtitle B of Title III of the EISA of 2007. This would include EISA 2007 Sections 321 and 323 as referenced in this Army policy memorandum and is used as the basis for the standards to be met.

CHAPTER 3

STATUS OF PREVIOUSLY RECOMMENDED INITIATIVES

This chapter provides a status update of the P2 initiatives recommended in the 2009 Fort Buchanan P2 Plan. Information for each environmental media and previously proposed initiative is provided in an easy to read table format.

Table 3-1. Status of 2009 P2 Study Proposed Initiatives

Media Initiative Implemented

Yes/No Comments

Hazardous Waste

Replace mercury thermometers in schools.

Unknown Unknown.

Continue to reduce hazardous material inventory.

Yes In 2013 the garrison reduced HW generation by 95% from a 2000 baseline.

Solid Waste

Increase scope and participation of recycling program.

Yes The Pronatura recycling contract was implemented in March 2009.

Chip vegetative waste onsite.

Partially

Instead of chipping vegetative waste onsite, the landscaping contractor is required to remove waste in accordance with the contract. Vegetative waste generated at the golf course is passively composted in a designated area.

Require C&D waste management plans.

Yes

Air Emissions

Substitute zero volatile organic compound content architectural paints.

Yes Contained in sustainable design guide.

Water & Wastewater

Energy savings performance contract.

Yes

Implemented under the ESPC measures, at least 30-40% reductions resulted from restroom fixture replacement, flow regulators, rain water harvesting plus new potable water well; however, condition of water distribution system piping and from new construction action has augmented system loses and water demand from new activity.

Meter water use at all buildings and charge for water use by volume.

Yes Completed, in addition t advanced meters will augment the amount of smart meters to properly quantify for all water consumption.

Meter fire hydrant flushing.

No This will be a future requirement for all new construction and a project for existing buildings.

Low-flow water fixtures.