Attach-3-Tech5-W912C324R0002-BuchananSolidWasteManagPlan.pdf

INTEGRATED SOLID WASTE

MANAGEMENT PLAN

FORT BUCHANAN

PUERTO RICO

APRIL 2009

Prepared by the U.S. Army Center for Health Promotion and

Preventive Medicine

Fort Buchanan Integrated Solid Waste Management and Recycling Plan i

TABLE OF CONTENTS

1.0 PURPOSE

2.0 OBJECTIVES

3.0 BACKGROUND

3.1 Location

3.2 Mission

3.3 Organization

3.4 Environmental Management System (EMS)

4.0 APPLICABLE REGULATONS

4.1 Federal Regulations

4.1.1 Resource Conservation and Recovery Act (RCRA)

4.1.2 Pollution Prevention Act of 1990

4.1.3 Federal Facilities Compliance Act

4.2 Executive Orders

4.2.1 Executive Order 13423 (Strengthening Federal Environmental, Energy, and

Transportation Management)

4.2.2 Executive Order 12856 (Federal Compliance with Right-to-Know Laws and

Pollution Prevention Requirements)

4.2.3 Executive Order 12780 (Federal Agency Recycling and Council on Federal

Recycling and Procurement Policy)

4.3 Commonwealth of Puerto Rico Regulations

4.4 Department of Defense Regulations

4.4.1 Department of Defense Memorandum, DOD Integrated (Non-Hazardous) Solid Waste Management Policy

4.4.2 Department of Defense Memorandum, Revised Pollution Prevention and Compliance Metrics

4.4.3 Qualified Recycling Program (QRP) Guidance

4.4.4 Department of Defense Instruction 4715.4 (Pollution Prevention)

4.5 Army Requirements and Policies

4.5.1 Army Regulation 420-1 (Army Facilities Management)

4.5.2 Sustainable Management of Waste in Military Construction, Renovation, and

Demolition Activities

4.5.3 Guidelines for Managing Construction and Demolition Waste

5.0 RESPONSIBILITIES

5.1 Garrison Commander

5.2 All Directors

5.3 Director of Public Works (DPW)

5.4 Directorate of Logistics (DOL)

5.5 Directorate of Contracting (DOC)

5.6 Chief, Environmental Division

ii

5.7 Compliance Manager

5.8 Contracting Officers Representative (COR)

5.9 Defense Reutilization and Marketing Office (DRMO)

5.10 Public Affairs Office

5.11 Energy and Environmental Officers (EEOs)

5.12 Environmental Quality Control Committee

5.13 All Organizations, Units, and Tenant Activities

6.0 SOURCE REDUCTION

6.1 Green Procurement

6.1.1 Background

6.1.2 Green Procurement Program Status

6.2 Pollution Prevention

6.3 Reuse

6.3.1 Packaging Materials

6.3.2 Waste Exchange

6.4 Best Management Practices

7.0 INSTALLATION RECYCLING PROGRAM

7.1 Program Status

7.2 Program Structure

7.3 Materials Recycled

7.4 Segregation, Storage, and Collection Procedures

7.4.1 Aluminum, Cardboard, Mixed Paper, and Plastics

7.4.2 Cooking Oil

7.4.3 Fluorescent Lights

7.4.4 Metals

7.4.5 Pallets

7.4.6 Toner Cartridges

7.4.7 Used Motor Oil

7.4.8 Materials Recycled Through the Defense Reutilization and Marketing

Office

7.4.9 Potential Recyclables

7.5 Diversion Rates

8.0 SOLID WASTE MANAGEMENT AND HANDLING PRACTICES

8.1 Solid Waste Generation

8.2 Solid Waste Collection and Disposal

8.2.1 Nonresidential Waste

8.2.2 Residential Waste

8.3 Yard Waste

8.4 Bulky Wastes

8.5 Universal Waste

8.6 Construction and Demolition Waste

8.6.1 Construction and Demolition Activities at Fort Buchanan iii

8.6.2 Construction and Demolition Waste Management Program Requirements. .. 21

8.6.3 Documentation

9.0 PROGRAM PROMOTION AND TRAINING

9.1 Recycling Program Promotion

9.2 Education and Outreach

9.2.1 Media Information

9.2.2 Community Outreach Programs

9.3 Training

9.3.1 Pollution Prevention Training

9.3.2 Solid Waste and Recycling Training

9.3.3 Construction and Demolition Waste Management Training

10.0 RECORDKEEPING AND REPORTING

11.0 SOLID WASTE MANAGEMENT ACTION ITEMS

12.0 TECHNICAL POINT OF CONTACT

APPENDICES

A – References............................................................................................................................ A-1 B – List of Recycling Facilities in Puerto Rico ...........................................................................B-1 C – Fort Buchanan Map...............................................................................................................C-1 D – Fort Buchanan Solid Waste Collection Schedule ................................................................ D-1 E – Sample Promotional Materials ..............................................................................................E-1

TABLES

Table 1. Materials Recycled in FY 07 Table 2. Diversion Rates for Fort Buchanan’s Waste Stream

INTEGRATED SOLID WASTE MANAGEMENT AND

RECYCLING PLAN NO. 38-EH-094D-08

FORT BUCHANAN

FORT BUCHANAN, PUERTO RICO

1.0 PURPOSE.

The management and disposal of solid waste in Puerto Rico is more challenging than it is on the mainland because there is limited disposal space available on the island; recycling rates are lower than they are on the mainland; and, according to the U.S. Environmental Protection Agency’s (EPA) statistics, Puerto Rico residents generate more waste than people living on the mainland.

The solution is a comprehensive and integrated solid waste management plan (ISWMP) that calls for a reduction in the amount of solid waste generated, an increase in the recycling rate, and the proper and efficient management of all landfills. The purpose of this ISWMP is to document current solid waste management practices, to set forth goals for improvement, and to specify the approach for achieving those goals at Fort Buchanan. This plan meets the Army requirement to develop an ISWMP (Army Regulation (AR) 420-1, paragraph 23-10b; reference 1). This ISWMP also reflects the EPA pollution prevention (P2) hierarchy that places an emphasis on source reduction and recycling to reduce the solid waste stream. The plan identifies various elements and quantities of the waste stream; identifies the current practices for reuse, recycling, and disposal of solid waste; documents the correct procedures for all aspects of solid waste management including collection, storage, segregation, transportation, treatment, recycling, and disposal; identifies the solid waste responsibilities of Fort Buchanan personnel; and lists action items for future consideration. This ISWMP applies to all current and future Fort Buchanan directorates, tenants, residents, and activities. Appendix A contains references used to prepare this plan.

2.0 OBJECTIVES.

The objectives of the solid waste management program at Fort Buchanan are described below.

• Reduce the rate of solid waste generation to meet or exceed the Department of Defense (DOD) goal of diverting a minimum of 40 percent of the installation’s nonhazardous solid waste excluding construction and demolition (C&D) waste from the offpost landfill.

• Comply with all applicable Commonwealth of Puerto Rico, Federal, DOD, and Army solid waste management regulations and all applicable Executive Orders (EOs) and Army guidance.

• Manage solid waste in a manner protective of human health and the environment.

• Reduce, reuse or recycle elements of the solid waste stream to the maximum extent possible.

3.0 BACKGROUND.

3.1 Location.

Fort Buchanan is located in two municipalities – Bayamon and Guaynabo. These municipalities are part of the San Juan greater metropolitan area. San Juan, the capital of the Commonwealth of Puerto Rico, is located along the northeast coast of the island. Fort Buchanan encompasses 746 acres and supports a military and civilian population of roughly 4,500. In addition, Fort Buchanan schools support approximately 2,000 students and another 40,000 individuals are eligible for post privileges.

3.2 Mission.

Fort Buchanan’s principal mission is the mobilization, readiness, and actual deployment of approximately 15,000 Reserve Component Soldiers in Puerto Rico and the U.S. Virgin Islands.

The installation also provides support to DOD operations in the Caribbean area. Fort Buchanan’s mission is to succeed by providing sustainable base support and excellent services as the Federal Support Center of the Caribbean by developing and retaining visionary leaders and an innovative, professional workforce; planning, designing, building, and sustaining infrastructure to support readiness and mission execution, and to enhance the well-being of the Federal community; being an agile, efficient, customer-driven, results-oriented organization to support current and future missions; and planning, coordinating, and executing mobilization/demobilization of Reserve Component Commands of Puerto Rico and the U.S.

Virgin Islands.

3.3 Organization.

Fort Buchanan supports the Reserve Component and Active Component Soldiers in Puerto Rico and the U.S. Virgin Islands as a power support platform to mobilize the nation’s only fully bilingual and bicultural forces. DOD tenant organizations include the 65th Regional Readiness Command, the 2/348th Theater Support Brigade, the Navy Reserve, the Army and Air Force Exchange Service (AAFES), the Commissary, the Antilles Consolidated School System, the Defense Military Pay Office, Educational and Developmental Intervention Services, a Criminal Investigation Division, the Rodriguez Army Health Clinic, a dental clinic, veterinary services, the Civilian Personnel Advisory Center, a Contracting Office, and the U.S. Property and Fiscal Office for the Puerto Rico National Guard. Non-DOD tenants include Carlson Wagonlit, the Fort Buchanan Federal Credit Union, the Banco Popular de Puerto Rico, the U.S. Postal Service, AAFES concessionaires, Central Texas College, and customer service offices for the Puerto Rico Treasury Department and the Puerto Rico Department of Transportation and Public Works.

3.4 Environmental Management System (EMS).

An EMS is a management structure designed to integrate environmental considerations into all operations and to systematically identify, evaluate, and control environmental impacts associated with those activities. Fort Buchanan will implement this ISWMP by integrating it into its established EMS. The EMS framework includes the following management elements: policy, planning, implementation and operation, checking and corrective action, and management review.

One of the objectives (published in 2006) of the Fort Buchanan EMS is to divert 35 percent of solid waste generated. Fort Buchanan will update this objective to at least 40 percent to achieve compliance with the DOD solid waste diversion goals (reference 2). Targets to achieve this objective include the following:

• Increase recycling material stream;

• Maintain the Fort Buchanan recycling program; and

• Increase awareness through educational programs.

4.0 APPLICABLE REGULATONS.

4.1 Federal Regulations.

4.1.1 Resource Conservation and Recovery Act (RCRA).

In an effort to improve solid waste disposal practices, Congress passed the Solid Waste Disposal Act in 1965. The Solid Waste Disposal Act was amended in 1976 by the RCRA (reference 3), which established standards and guidelines for the management of hazardous and nonhazardous solid wastes. RCRA was promulgated to encourage waste minimization through source reduction and use of nonhazardous substances, recycling, affirmative procurement, and conversion of waste to energy. RCRA also established the legislative language governing solid and hazardous waste storage, transportation, and disposal. RCRA Section 6002 requires the Federal Government to promote standards and practices for the procurement of products made from recycled materials. RCRA regulations are contained in Title 40, Code of Federal Regulations (CFR), Parts 239 to 282. RCRA Subtitle C (40 CFR 260-279) contains the hazardous waste regulations, and RCRA Subtitle D (40 CFR 239-259) contains the regulations for solid waste. Some significant sections of Subtitle D are summarized below.

4.1.1.1 Part 243 (Guidelines for the Storage and Collection of Residential, Commercial, and Institutional Solid Waste). Part 243 establishes requirements and recommended practices for the storage, collection, and management of solid waste and for the operation of vehicles used in collection, transport, and handling of waste.

4.1.1.2 Part 246 (Source Separation for Materials Recovery Guidance). Part 246 contains recycling requirements for the recovery of paper, corrugated containers, and other consumer goods.

4.1.1.3 Part 247 (Guidelines for the Procurement of Products that Contain Recycled Material). Part 247 contains requirements regarding “buy recycled” practices that will stimulate the recovered materials market.

4.1.1.4 Part 257 (Criteria for Classification of Solid Waste Disposal Facilities and Practices). Part 257 contains guidance for determining if disposal facilities meet minimum standards to protect human health and the environment.

4.1.2 Pollution Prevention Act of 1990.

The Pollution Prevention Act (reference 4) established a national policy to prevent or reduce waste generation through reduction, reuse, recycling, and treatment. The act established the P2 hierarchy which is the cornerstone of integrated solid waste management.

4.1.3 Federal Facilities Compliance Act.

The Federal Facilities Compliance Act (reference 5) requires all Federal facilities to comply with substantive and procedural requirements of Federal, Commonwealth of Puerto Rico, and local solid and hazardous waste regulations. The act waived the immunity previously granted to Federal facilities.

4.2 Executive Orders.

4.2.1 Executive Order 13423 (Strengthening Federal Environmental, Energy, and Transportation Management).

EO 13423 (reference 6), signed in January 2007, requires Federal Agencies to increase solid waste diversion, to strive to meet the national 35 percent recycling goal established by the EPA (reference 7), and to maintain cost-effective waste prevention and recycling programs. EO 13423 also strengthens green procurement (GP) by requiring Federal Agencies to expand purchases of environmentally sound goods and services, including biobased products. This EO also requires Federal Agencies to follow certain guidelines when purchasing electronics and to reuse, donate, sell, or recycle 100 percent of electronic products using environmentally sound management practices. In addition, this EO requires Federal Agencies to construct or renovate buildings in compliance with the Guiding Principles for Federal Leadership in High Performance and Sustainable Buildings.

4.2.2 Executive Order 12856 (Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements).

EO 12856 (reference 8), signed in August 1993, requires Federal facilities to comply with requirements of Federal, Commonwealth, and local solid and hazardous waste regulations. It waived the immunity previously held by Federal facilities.

4.2.3 Executive Order 12780 (Federal Agency Recycling and Council on Federal Recycling and Procurement Policy).

EO 12780 (reference 9), signed in October 1991, encourages Federal Agencies to exercise waste reduction, recycling, and affirmative procurement techniques.

4.3 Commonwealth of Puerto Rico Regulations.

The Puerto Rico Solid Waste Management Authority implements the Solid Waste Reduction and Recycling Act of Puerto Rico (reference 10). This Act requires Commonwealth agencies and public corporations to establish procedures for the separation, collection, transport, and storage of recyclable materials generated at their installations. The Act requires that the following recyclables be separated at the source: paper, cardboard, metals, glass, plastic, and other materials that may be recovered and/or sold for recycling for less cost than disposal. The Act also mandates Commonwealth agencies and public corporations to give preference to green products.

4.4 Department of Defense Regulations.

4.4.1 Department of Defense Memorandum, DOD Integrated (Non-Hazardous) Solid Waste Management Policy.

This memorandum (reference 2) implements the solid waste and recycling requirements of EO 13423 by requiring all facilities to maintain waste prevention and recycling programs in the most cost-effective manner possible and setting solid waste diversion goals. The diversion goal for nonhazardous solid waste without C&D waste is 40 percent and the goal for C&D waste is 50 percent. The memorandum states that these goals should be achieved by 2010. The memorandum also includes some guidelines for implementing integrated solid waste management. These guidelines recommend an initial solid waste characterization study to define the basis for diversion goals and an annual review of the status of solid waste generation from all sources. The guidelines also state that complying with GP practices will have a positive effect on source reduction.

4.4.2 Department of Defense Memorandum, Revised Pollution Prevention and Compliance Metrics.

This memorandum (reference 11) supersedes the 1998 DOD Measure of Merit and it requires DOD facilities to establish a cost-effective solid waste management program that reduces solid waste generation, increases diversion rates, and optimizes cost avoidance.

4.4.3 Qualified Recycling Program (QRP) Guidance.

This memorandum (reference 12) issued by the Assistant Deputy Under Secretary of Defense (Environment) supplements DOD Instruction 4715.4, paragraph 6.2.3.3 with guidance on QRPs.

4.4.4 Department of Defense Instruction 4715.4 (Pollution Prevention).

DOD Instruction 4715.4 (reference 13) establishes the DOD requirement for installation QRPs, calls for GP, and authorizes direct sales of recyclables.

4.5 Army Requirements and Policies.

4.5.1 Army Regulation 420-1 (Army Facilities Management).

AR 420-1 (reference 1) requires implementation of integrated solid waste management, development of the ISWMP, implementation of source reduction programs for the solid waste stream, implementation of a QRP when cost effective, a 50 percent diversion of C&D waste from disposal, and a yard waste management program.

4.5.2 Sustainable Management of Waste in Military Construction, Renovation, and Demolition Activities.

The memorandum (reference 14) issued by the Assistant Chief of Staff for Installation Management (ACSIM) in 2006 requires all military construction, renovation, and demolition projects to divert a minimum of 50 percent of C&D waste by weight from landfill disposal and requires contract specifications to include submission of a contractor’s C&D Waste Management Plan. In addition, this memorandum states that installations will achieve the silver level using the Leadership in Energy and Environmental Design (LEED) rating system.

4.5.3 Guidelines for Managing Construction and Demolition Waste.

The memorandum (reference 15) issued by the ACSIM in 2001 establishes guidelines for the development and implementation of programs to effectively manage wastes generated during C&D activities and requires the development of C&D waste management plans for all military C&D projects.

5.0 RESPONSIBILITIES.

5.1 Garrison Commander.

• Provide command emphasis on solid waste reduction, materials reuse, recycling, and GP.

• Approve the standing operating procedure for the recycling program.

• Promote participation in the installation’s recycling program.

• Chair the Environmental Quality Control Committee (EQCC). Ensure discussions on implementation of the ISWMP are included on the EQCC agenda.

5.2 All Directors.

• Advise directorate activities of Federal, Commonwealth of Puerto Rico, and DOD requirements for managing and reducing solid wastes and recycling.

• Monitor directorate activities regarding compliance with solid waste management requirements.

• Support and emphasize the practices of waste reduction, reuse of materials, recycling, and GP.

• Participate in the EQCC.

5.3 Director of Public Works (DPW).

In addition to the responsibilities listed in paragraph 5.2, the DPW is responsible for the following:

• Program, budget, and defend resource requirements to manage the solid waste program. This includes funds for personnel, equipment, studies, operation, maintenance, treatment, storage, disposal, waste minimization measures, promotion, and training.

• Ensure that all new contracts awarded, particularly C&D contracts, include recycling clauses stipulating the diversion of recyclable materials when feasible and cost-effective to the Government. Additionally, ensure that C&D contracts specify that contractors submit C&D waste management plans.

• Include the requirement to follow Guiding Principles for Federal Leadership in

High Performance and Sustainable Buildings as specified in EO 13423, and specify that new construction achieve a LEED rating of silver or higher.

• Ensure that GP provisions are implemented in applicable purchases and in construction and service contracts.

5.4 Directorate of Logistics (DOL).

In addition to the responsibilities listed in paragraph 5.2, the DOL is responsible for the following:

• Advise procurement activities on the availability of environmentally preferable products and GP requirements.

• Seek ways to reuse and reduce packaging and packing materials.

• Actively support the DPW Environmental Division in measuring progress to meet

Federal and DOD waste reduction goals and GP requirements.

• Communicate regularly with the Defense Logistics Agency activity serving the installation to maintain current information on markets for excess or unserviceable materials and recyclable materials.

5.5 Directorate of Contracting (DOC).

In addition to the responsibilities listed in paragraph 5.2, the DOC is responsible for ensuring that contracts meet Federal GP requirements and source reduction strategies as follows:

• Ensure that contracts require the use of environmentally preferable products where applicable, with emphasis on mandates for recovered materials, biobased products, and energy efficiency.

• Stipulate in contracts that paper products contain 30 percent recycled content at a minimum and that contractor documents be printed double-sided.

• Modify solid waste and recycling contracts as necessary to support installation solid waste management planning efforts.

5.6 Chief, Environmental Division.

• Serve as the Commander’s expert representative for the management of solid wastes. Advise the Commander on the most cost-effective and efficient means of storing, treating, and disposing waste, and modifying equipment or procedures if needed. Recommend changes in policies or procedures to improve program management to the Commander when necessary.

• Periodically review all applicable Federal, Commonwealth, and Army requirements for managing solid wastes.

• Create an active educational and promotional program for waste reduction and recycling practices. Work with the Public Affairs Office (PAO) to ensure the recycling program and procedures are publicized.

• Serve as the installation point of contact for questions, complaints, or other information regarding solid waste management and recycling.

• Ensure that the Environmental Division staff conducts compliance audits, to include solid waste and recycling, of all units, organizations, and tenant activities.

• Ensure that the ISWMP is updated every 5 years at a minimum or as necessary to reflect current solid waste handling and disposal practices.

• Ensure that the Environmental Division promotes and implements GP strategies.

• Participate in the EQCC or other installation forum that addresses solid waste management and recycling.

5.7 Compliance Manager.

• Serve as the Environmental Division Chief’s expert on integrated solid waste management issues including waste reduction, recycling, and composting.

• Monitor installation compliance with Federal, Commonwealth, and Army solid waste management requirements.

• Oversee the daily operation of the recycling program.

• Ensure that progress is made towards meeting solid waste reduction and recycling goals.

• Maintain liaison and coordinate as necessary with Federal and Commonwealth solid waste regulators.

• Continue to maintain a recordkeeping system to track materials diverted and disposed. Track solid waste and recyclables quantities and submit appropriate data for the Solid Waste Annual Report (SWAR) using SWARWeb.

• Add additional recyclable materials to the recycling program as markets are located and materials can be recycled in a cost-effective manner.

• Seek out and propose more efficient, cost-effective methods of integrated solid waste management when applicable.

5.8 Contracting Officers Representative (COR).

• Identify the solid waste activities that are carried out by contract, review the responsibilities, and monitor the performance of the contractor.

• Ensure regular and systematic collection of solid wastes from designated pickup stations and disposal of solid wastes to provide efficient and cost-effective service in accordance with the requirements of Army regulations.

• Periodically review the number and location of dumpsters and ensure pickup schedule is adequate.

5.9 Defense Reutilization and Marketing Office (DRMO).

• Maintain records concerning quantities of scrap metal, tires, and any other materials turned in for reuse/recycling and the proceeds for resale/recycling activities.

• Perform market research concerning resale value and recycling opportunities from wastes generated at the installation.

• Advise generating activities on the required turn-in procedures to facilitate sales and recycling.

• Report the quantities of materials recycled to the DPW Environmental Division.

5.10 Public Affairs Office.

• Publish promotional material on solid waste management issues as provided by the DPW Environmental Division.

• Use a variety of media to maximize the audience reached.

5.11 Energy and Environmental Officers (EEOs).

• Ensure that recycling collection points with clearly marked recycling containers are established inside buildings and ensure that recycling containers are emptied into recyclables dumpsters as needed.

• Participate in compliance inspections and correct findings identified during inspections.

• Serve as a liaison between Environmental Division and facility personnel.

5.12 Environmental Quality Control Committee.

• Meet quarterly and discuss issues on the meeting agenda including solid waste management and the implementation of this ISWMP.

5.13 All Organizations, Units, and Tenant Activities.

• Participate in and support the recycling program by identifying, collecting, separating, and removing contaminants from all potential recyclable materials.

• Reduce the amounts of solid waste generated through procurement of products with recycled materials content and/or less or reusable packaging, buying only the amounts needed, seeking and implementing new recycling and reuse procedures, and altering operations to reduce wastes.

6.0 SOURCE REDUCTION.

Source reduction, or creating less waste, is the preferred method of solid waste management.

The EPA calls for source reduction as the primary tool in the waste management hierarchy. Key components of source reduction include GP, reuse of materials and waste exchanges, and management processes that create less waste.

6.1 Green Procurement.

6.1.1 Background.

GP is the purchase of environmentally beneficial products and services in accordance with one or more of the established Federal procurement preference programs. Federal Agencies are required to establish a GP Program to meet the requirements of the EPA “Buy Recycled” Program and the United States Department of Agriculture (USDA) “BioPreferred” Program. In 2004, DOD issued a GP policy (reference 16) that reaffirmed a goal of 100 percent compliance with Federal laws and EOs requiring the procurement of green products and services. The policy was accompanied by a strategy document that outlines steps for meeting those requirements and contains metrics for measuring progress. The Army also published a GP policy in August 2006 formalizing the Army commitment to GP compliance (reference 17). The Army Green Procurement Guide provides detailed instruction on implementing a GP Program at an Army installation and will be used by Fort Buchanan to implement the installation’s GP Program. The GP Program will include the following categories: recovered materials, environmental preferable, energy and water efficient, biobased, alternative fuels and fuel efficiency, non-ozone depleting substances, priority chemicals, Electronic Product Environmental Assessment Tool– registered electronic products, and sustainable buildings. Further guidance can be found in the Federal Acquisition Regulations (FAR) Part 23 (reference 18), EO 13423, and the 2002 Farm Security and Rural Investment Act (FSRIA) (reference 19). 40 CFR 247 contains the Comprehensive Procurement Guidelines designated by the EPA for which Federal purchasers must buy products containing recovered material. Title IX of the FSRIA requires Federal Agencies to show preference for biobased products as part of their GP programs. To obtain the current lists of EPA- and USDA-designated products, go to http://www.epa.gov/cpg/products.htm and www.biobased.oce.usda.gov/fb4p/, respectively. GP has many environmental benefits, including creating markets for recycled and biobased materials, conserving resources, saving energy, saving landfill space, and reducing pollution.

6.1.2 Green Procurement Program Status.

Fort Buchanan does not have a strong GP Program and does not have a GP Plan. The Environmental Division provided some GP purchasing information to the DOC and the DOL, but there is no evidence that either organization has implemented any GP initiatives. If any GP purchases are made, they are not tracked in any manner. Fort Buchanan has not provided GP training to major purchasers, such as the DOL, DOC, and credit card holders.

6.2 Pollution Prevention.

The Pollution Prevention Act of 1990 (reference 4) established P2 as a national objective in reducing waste at the source. This is to be achieved by lessening the toxicity and/or the quantity of waste generated through such tools as material substitution, use of raw materials, procurement policies, or process changes. The Environmental Division manages the Fort Buchanan P2 Program and strives to reduce or eliminate the impact that any Army operation may have on the environment through reduction or elimination of wastes, more efficient use of raw materials and energy, and reduced emissions of toxic materials to the environment. The Environmental Division works with other installation activities to make environmental considerations part of their daily operations. Fort Buchanan has a separate P2 plan that was published in 2001. Fort Buchanan has implemented several P2 initiatives that have helped to reduce the amount of solid waste disposed including implementing an installation-wide recycling program for cardboard, paper, aluminum, and plastics; recycling lead-acid batteries; recycling used motor oil; using remanufactured toner cartridges and sending used cartridges back to the manufacturer; and reusing wood pallets.

6.3 Reuse.

Material reuse will be instituted at the lowest functional level. Organizations and employees will strive to increase the reuse of materials. Reuse of materials may be either for the original intended purpose or for another related purpose. Fort Buchanan will consider implementing reuse strategies; two examples are detailed below.

6.3.1 Packaging Materials.

Fort Buchanan will reuse packing materials to the maximum extent possible. Buildings that routinely receive shipments of any type will designate a packaging reuse area which can be a large box, an area of a closet, or a corner of a utility room. Styrofoam peanuts, bubble wrap, and other packaging materials will be stored for future use. In addition, personnel should strive to purchase items that use less or contain recyclable packaging materials.

6.3.2 Waste Exchange.

Fort Buchanan will consider establishing a waste exchange by electronic bulletin board.

Activities or individuals generating potentially reusable items can advertise the excess materials so they may be reused by other activities or individuals. The Fort Buchanan DPW Supply Office uses a similar technique to minimize chemical waste. The Supply Office reissues chemicals that have been unused or opened but not reached their shelf life expiration date. These products are provided to customers free of charge.

6.4 Best Management Practices.

Fort Buchanan personnel will follow general management practices that will minimize the generation of solid waste. Examples include setting the default on printers to print double-sided, using the intranet or drive sharing to transmit nonsensitive information, using e-mail in place of written memos when possible, saving e-mail messages to files instead of printing them, conducting document reviews and providing comments electronically, sending internal mail in reusable envelopes, reusing file folders by using stick-on labels, using routing slips instead of making multiple copies, using “print view” features to reduce printing mistakes, making double-sided copies, reusing plastic and paperboard binders, and using washable coffee mugs and utensils instead of disposable supplies. Best management practices will be publicized to personnel.

7.0 INSTALLATION RECYCLING PROGRAM.

7.1 Program Status.

Fort Buchanan implemented its recycling program in 2000. Fort Buchanan does not operate a QRP as defined in AR 420-1 (reference 1). One of the main components of operating a QRP revolves around how fiscal accountability is maintained. The Fort Buchanan Recycling Program does not receive proceeds from the sale of recyclables nor does Fort Buchanan pay for the collection of recyclables.

The Fort Buchanan EMS has identified solid waste generation as a significant aspect and has developed an objective and targets to increase solid waste diversion. As a result, the Environmental Division is working to improve the recycling program at Fort Buchanan and is implementing some changes which are described below.

7.2 Program Structure.

The Fort Buchanan Recycling Program has been established since 2000 and the Environmental Division’s Compliance Manager oversees the day to day operations of the program. Fort Buchanan has a memorandum of agreement with ProNatura to provide dumpsters and collect the recyclables free of charge. ProNatura does not reimburse Fort Buchanan for any of the revenue generated through resale of the recyclables.

Currently, there are a small number of activities and tenants on Fort Buchanan that do not participate in the installation recycling program. However, all activities and tenants on the installation are required to participate in the recycling program. The Environmental Division is working with each activity on the installation to designate an EEO who will be responsible for ensuring that his/her activity is complying with all applicable environmental regulations. The Environmental Division is developing activity-specific compliance responsibilities and will provide each EEO with the specific responsibilities for his/her activity. All activities will have solid waste and recycling responsibilities. Each EEO will ensure that there is at least one established recycling area in a location convenient to all members of the activity. The EEO will work with the Environmental Division to develop the most efficient configuration or recycling containers based on the number of people located within the activity and should also ensure that recyclable materials are not being disposed of in trash containers. EEOs will also conduct training and convey general awareness information to ensure performance of best environmental management practices.

7.3 Materials Recycled.

Table 1 shows the quantities of materials recycled and reported at Fort Buchanan in fiscal year 2007 (FY 07) (reference 20). Collection procedures for each material type are described in paragraph 7.4.

Table 1. Materials (Non C&D) Recycled in FY 07.

Recyclable Material

Tons Recycled

Aluminum 0.09 Cardboard 501.65 Cooking oil 13.42 Fluorescent lamps 0.52 Lead-acid batteries 3.51 Metals 125.00 Mixed paper 343.66 Pallets 155.33 Plastics 0.44 Tires 9.24 Used motor oil 12.65 Total 1165.51

7.4 Segregation, Storage, and Collection Procedures.

EEOs will ensure that each building on Fort Buchanan has at least one centrally located recyclables accumulation area. The accumulation area, at a minimum, will have collection containers for mixed paper and commingled aluminum and plastic containers. Recycling accumulation areas will be well marked, recycling procedures will be posted in the recycling accumulation area, recycling collection containers will be labeled appropriately and kept clean, and the containers will be emptied regularly. Activity personnel are responsible for emptying recycling containers into the appropriate dumpsters; the Fort Buchanan custodial staff only empties waste containers into the exterior dumpsters. There are recycling dumpsters located near most of the buildings on Fort Buchanan. The Environmental Division will work with ProNatura to provide dumpsters for buildings that do not have convenient access to recycling dumpsters.

Residents in family housing are provided with a minimum of two bins to collect their recyclables; one bin for plastics and aluminum and one bin for paper products. Residents are responsible for emptying their recycling containers into the recycling dumpsters located in or near their neighborhoods.

7.4.1 Aluminum, Cardboard, Mixed Paper, and Plastics.

ProNatura collects aluminum, cardboard, mixed paper, and plastics for recycling. ProNatura provides dumpsters for the collection of these materials, provides biweekly pickup free of charge, and retains the revenues generated from the sale of the recyclables. Employees are responsible for transporting their recyclables to the centrally located recycling containers in their building. Personnel from each activity are responsible for transporting the recyclables in these central locations to the dumpsters designated for recycling. The individual who transports the comingled plastic and aluminum containers to the dumpster will ensure that these items are bagged to prevent soiling paper and cardboard destined to be recycled.

7.4.2 Cooking Oil.

Several dining facilities on Fort Buchanan generate used cooking oil. Currently, the AAFES, Community Club, bowling alley, and school cafeterias recycled their used cooking oil and report the quantities recycled to the Environmental Division.

7.4.3 Fluorescent Lights.

The DPW is responsible for replacing fluorescent light bulbs throughout the installation.

Fluorescent light bulbs are managed as universal waste and are turned in through the Fort Buchanan Hazardous Waste Program. Fluorescent light bulbs are crushed and recycled by a contractor. The tonnage of fluorescent light bulbs recycled is reported to the DPW Environmental Division for inclusion in the installation diversion rate.

7.4.4 Metals.

The DPW has a 40-cubic yard rolloff dumpster for the collection of scrap metal. Activities that generate scrap metal on a regular basis collect the scrap metal onsite and transport to either the DPW rolloff or the DRMO, depending on the specific material. Quantities of scrap metal recycled are reported to the Environmental Division.

7.4.5 Pallets.

The Commissary and the Post Exchange (PX) reuse wood pallets. The tonnage of wood pallets diverted from disposal is reported to the DPW Environmental Division.

7.4.6 Toner Cartridges.

The Environmental Division collects used toner cartridges and sends them back to the manufacturer for recycling/reuse. Employees drop off their used toner cartridges to the DPW Environmental Division. The quantity of toner cartridges sent back to the manufacturer is not currently captured and included in the installation’s diversion rate.

7.4.7 Used Motor Oil.

Activities that generate used motor oil store the waste in a permitted onsite aboveground storage tank and notify a local vendor when their collection containers are approaching capacity. The local vendor picks up the oil free of charge and retains any revenues associated with resale of the used oil. The volume of recycled oil is reported to the Environmental Division.

7.4.8 Materials Recycled Through the Defense Reutilization and Marketing Office.

The Fort Buchanan DRMO is small and only serves as a scrap yard that accepts antifreeze, lead-acid batteries, tires and scrap metal, all of which can be recycled. Activities that generate these materials store the materials onsite and turn them in to the DRMO on an as-needed basis. The DRMO sends most of the recyclable materials to the mainland for recycling. With increased recycling opportunities on the island, the DRMO should consider recycling items in Puerto Rico, rather than pay for transport to the mainland. The DRMO currently provides the DPW Environmental Division with the quantities of lead-acid batteries, scrap metal, and tires turned in for recycling. The DRMO recycles antifreeze but does not currently report the quantity recycled to the Environmental Division.

7.4.9 Potential Recyclables.

The Fort Buchanan Environmental Division is resourceful when it comes to recycling and/or reusing materials. For example, Fort Buchanan had a surplus of salt that was formerly used as a water softening agent for the installation. Rather than dispose of the salt, Fort Buchanan donated it to the neighboring prison for use in its water softening process. Fort Buchanan environmental personnel have also coordinated with chemical companies to take back and recycle chemical products that are no longer needed. Fort Buchanan staff and residents should contact the Environmental Division if they have potential recyclable materials that they do not know how to dispose of properly.

7.5 Diversion Rates.

The diversion rate, expressed as a percentage, is the rate at which nonhazardous solid waste is diverted from entering a disposal facility. The diversion rate equals:

(R/(R+L))*100

Where:

R = amount (in tons) of nonhazardous waste diverted and L = amount (in tons) of solid waste disposed

Table 2 shows the diversion rates for non-C&D waste for FY 04, FY 05, FY 06, and FY 07 (references 20, 21, 22, and 23). The diversion rate was 30 percent in FY 07 and has been rising over the past 4 years. Fort Buchanan has not achieved the DOD 40 percent diversion goal, but will strive to meet the goal by the 2010 deadline (reference 2).

Table 2 also shows that only the C&D waste diverted from disposal is reported to the Environmental Division. In order to calculate the actual diversion rate, the quantities of C&D waste disposed must also be reported. Although all contracts require contractors to report the quantities of waste disposed and diverted, it is clear that contractors are not complying with the reporting requirements. Fort Buchanan will enforce these contract clauses so the actual C&D diversion rate can be calculated. The DOD and the Army have 50 percent diversion goals for C&D waste.

Table 2. Diversion Rates for Fort Buchanan’s Waste Stream.

Waste Type Disposal/Diversion Data FY 07 FY 06 FY 05 FY 04

Waste Disposed (tons) 2,402.02 2,892.27 2,527.00 1,764.00

Waste Diverted (tons) 1,040.49 762.28 671.40 732.20Non-C&D Waste

Diversion Rate1 30% 21% 21% 29%

Waste Disposed (tons)2 -- -- -- --

Waste Diverted (tons) 500.00 511.00 486.79 --C&D Waste

Diversion Rate3 -- -- -- -- 1Tonnage of materials diverted/ (Tonnage of materials diverted + Tonnage of materials disposed) x 100.

2 C&D waste disposal data is not reported to the Environmental Division.

3 Diversion rate cannot be calculated without material disposal data.

8.0 SOLID WASTE MANAGEMENT AND HANDLING PRACTICES.

Solid waste, as defined in RCRA, is any garbage, refuse, sludge, or other discarded material resulting from industrial, commercial, institutional, and residential activity. Discarded materials include those disposed, abandoned, recycled, or inherently waste-like. Hazardous wastes are solid wastes that meet specific RCRA criteria involving hazardous characteristics or the presence of listed constituents and are not addressed in this ISWMP. Solid waste at Fort Buchanan is categorized and managed based on the type of operation generating the waste. A discussion of the general waste categories is presented in the following paragraphs.

8.1 Solid Waste Generation.

Fort Buchanan generates approximately 3,500 tons of solid waste (excluding C&D waste) on an annual basis (Table 2). In FY 07, the diversion rate for solid waste, excluding C&D waste, was 30 percent. Fort Buchanan generates waste from administrative and commercial facilities, and from family housing. Monthly solid waste collection reports show that approximately 95 percent of the waste generated at Fort Buchanan is generated at administrative and commercial activities and only 5 percent is generated at family housing. Administrative and commercial activities at Fort Buchanan include administrative buildings, barracks, a health clinic, a dental clinic, schools, a daycare facility, vehicle maintenance shops, dining facilities, a bowling alley and snack bar, a retail exchange, and a gas station.

8.2 Solid Waste Collection and Disposal.

Fort Buchanan has a contract with LM Waste Services, Inc. to collect the installation’s solid waste and transport it to a landfill. LM Waste Services transports the waste to either the Guaynabo Municipal Landfill or the Humaco Municipal Landfill. The Guaynabo landfill is located about 5 miles south of Fort Buchanan and the Humaco landfill is located about 27 miles southeast of Fort Buchanan. Both landfills are permitted, have a lifetime of at least 20 years, and have a $30 per ton tipping fee. LM Waste Services provides Fort Buchanan with monthly reports regarding the quantity of nonresidential and residential waste collected and transported to the landfill.

8.2.1 Nonresidential Waste.

The janitorial staff is responsible for emptying waste containers and transporting the waste to the waste dumpsters located throughout Fort Buchanan. If a building is not serviced by janitorial staff, employees are responsible for disposing of solid waste in the designated dumpsters.

Dumpster locations are shown in Appendix B and the collection schedule is provided in Appendix C. The frequency of solid waste collection varies based on the type of facility. The solid waste collection contract also includes a provision for additional dumpsters for special events such as Armed Forces Day, the 4th of July and Christmas celebrations, and the AAFES sale.

LM Waste Services cleans the dumpsters on a regular basis to control pests and odors.

Dumpsters that need to be cleaned are removed from their locations and replaced with a clean dumpster. The dirty dumpster is taken to the washrack and washed with a biodegradable product that has been approved by the Environmental Division. Once the dumpster has been washed, it is brought to the contractor yard until it is used to replace the next dumpster that needs to be washed.

8.2.2 Residential Waste.

There are three family housing communities on Fort Buchanan: Coconut Grove, Las Colinas, and Coqui Gardens. In total there are 119 family housing units in these three communities.

Each family housing unit is provided with a 32-gallon waste container. Residents are responsible for taking their waste container to curb for collection. LM Waste Services collects the waste on Mondays. The contractor work crew collects the waste from each container and returns the container to the curb upside down. Family housing residents are responsible for cleaning their waste containers.

8.3 Yard Waste.

Fort Buchanan has a 40-cubic yard rolloff container for the collection of vegetative waste. LM Waste Services collects the waste and transports it to the landfill for disposal. There are several facilities in the nearby vicinity that accept vegetative waste for composting (Appendix B). Even though Fort Buchanan does not generate large quantities of vegetative waste, they will consider composting the waste rather than disposing of it. Quantities of vegetative waste composted should be reported to the Environmental Division DPW.

8.4 Bulky Wastes.

Residents and employees that have bulky waste items for disposal, such as furniture and mattresses, contact DPW to pick up the items. DPW personnel will dispose of the items in the appropriate 40-cubic yard dumpsters located in the DPW yard.

8.5 Universal Waste.

Fort Buchanan collects batteries (except lead-acid, which are collected by DRMO) and fluorescent light bulbs through its universal waste program. Universal waste is turned in through the Fort Buchanan Hazardous Waste Program. Batteries are disposed of properly and fluorescent light fixtures are crushed and recycled by a contractor. The tonnage of light fixtures recycled is reported to the DPW Environmental Division for inclusion in the installation diversion rate.

8.6 Construction and Demolition Waste.

C&D waste accounts for a large percentage of the waste stream at Army installations. According to Army-wide SWARWeb data, 60 percent of the Army’s nonhazardous solid waste stream consisted of C&D debris in 2004 (reference 14). Typical wastes from C&D activities includes lumber, reinforcing steel and other metals, piping and wiring, concrete, brick, plaster, wall board, roofing material, insulation, plumbing fixtures, doors, windows, and asphalt.

8.6.1 Construction and Demolition Activities at Fort Buchanan.

Since 2001, there has been a moratorium on new construction at Fort Buchanan so C&D wastes were primarily generated through maintenance and renovation activities. The moratorium was lifted in January 2008 and there are a number of demolition projects and several new construction projects planned to begin in 2009. It is expected that C&D waste generated at Fort Buchanan will increase substantially over the next few years. In accordance with Army regulations, Fort Buchanan inserts a specification into C&D contracts that requires contractors to provide weight tickets for the quantities of C&D waste disposed of and the quantities of waste diverted from the waste stream. C&D contracts also require contractors to remove and dispose of all C&D debris at approved offpost facilities.

8.6.2 Construction and Demolition Waste Management Program Requirements.

The DOD and the Army have established the requirement for a 50 percent minimum diversion rate by weight of C&D waste from landfill disposal (references 2, 14, and 15).