Appendix_F_-_AF_SW_Diversion_and_QRP_Policy.pdf

I I I I I I I I I I I I I I I I I I I

DEPARTMENT OF THE AIR FORCE

HEADQUARTERS UNITED STATES AIR FORCE

WASHINGTON DC

APR 1.1 2006

MEMORANDUM FOR ALMAJCOM/A7/A7C

10 CES/CC

11 CES/CC

FROM: AF/A7C

1260 Air Force Pentagon Washington, DC 20330-1260

SUBJECT: Air Force Solid Waste Diversion and Qualified Recycling Program (QRP) Policy

As a result of a recent audit of the Air Force QRP, the Air Force Audit Agency identified the need for increased oversight on QRP management and operations, and consolidation and clarification of Air Force policy. Attached is the new Air Force Solid Waste Diversion and QRP policy, effective immediately. This policy clarifies and consolidates current solid waste diversion and QRP policy and procedures, and ensures appropriate management controls are in place for good program operation.

If you or members of your staff have any questions, please contact our POCs, Ms. Michelle Brown, AF/A7CVQ, at DSN 664-3475 or michelle.brown@pentagon.af.mil; or Ms. Nancy Carper, HQ AFCEE/TDN, at DSN 240-4964 or nancy.carper@brooks.af.mil.

~~USAF

The Civil Engineer DCSlLogistics, Installations & Mission Support

Attachment:

1. Air Force Solid Waste Diversion and QRP Policy

Air Force Solid Waste Diversion and Qualified Recycling Program (QRP) Policy

April 2006

DoD has directed each Service to establish and execute a QRP to reduce the volume of non-hazardous solid waste disposed, in accordance with 10 U.S.C. §2577, and to establish procedures governing the QRP as directed in DoD Instruction 4715.4, Pollution Prevention, 6 Jul 1998. It is the intent of the Air Force to recycle at its installations and, whenever possible, to conduct direct sales of recyclable commodities through a QRP as directed in Air Force Instruction (AFI) 32-7080, Pollution Prevention, 12 May 1994. Once an installation establishes a QRP, auditable financial accounting must be an inherent part of program operation with appropriate checks and balances in place to ensure transparency to leadership.

AFI 32-7080, Pollution Prevention contains current Air Force recycling policy; however all AF recycling policy, including this document, will be moved to and incorporated in AFI 32-7042, Waste Management. AFI 32-7042 is currently under review and, when published (2006), will address appropriate HQ and MAJCOM policy.

Applicability

This policy applies to Air Force operations, activities, and installations in the United States, Puerto Rico, and territories or possessions over which the United States has jurisdiction, including Government-owned, contractor-operated (GOCO) facilities, and facilities supported by appropriated and non-appropriated funds. For installations outside the United States, implement the elements of this policy to the maximum extent practicable consistent with DoD Instruction (DoDI) 4715.4, international agreements, status of forces agreements, and Final Governing Standards (FGS) issued for host nations (or the Overseas Environmental Baseline Guidance Document where no FGS have been issued).

Roles and Responsibilities

The Wing Commander maintains overall responsibility for establishing a QRP and ensuring that it is operated and maintained in accordance with 10 U.S.C. 2577, DoDI 4715.4, and AFI 32-7080. The Wing Commander (or if designated, Environmental, Safety, and Occupational Health Council (ESOHC) Chairperson) must designate the QRP manager by issuing a QRP designation/appointment letter. Once appointed, the QRP manager is responsible for the day-to-day operation of the QRP. This position is not mandated to be an environmental flight position. The MAJCOM or installation commander has the authority and the responsibility to determine where this position should reside. Guidance on Wing Commander (as they relate to the QRP) and QRP manager responsibilities will be included in the USAF QRP Guide.

Environmental management and civil engineering operations must collaborate and coordinate their efforts to ensure that policy, guidance and implementation are all consistent. Since solid waste disposal data originates with a Facilities Operations (FO)(formerly referred to as "Real Property Services" (RPS)) funded component, but is currently submitted through environmental, data collection and validation must

Air Force Solid Waste Diversion and QRP Policy

Page 2 of 11 April 2006 be a joint effort between all parties involved. Funding for the day-to-day management and operation of recycling operations (to include manpower authorizations, peculiar and support equipment, necessary facilities, contracts, and associated costs to plan, manage, and execute those functions) and compliance with and implementation of related permit requirements resides in the FO program element code, no matter what organization is responsible for management. However, environmental management is generally responsible for overall non-hazardous solid waste recycling program oversight, permits (applications, renewals, oversight, reporting), and the development of compliance guidance.

This policy does not direct the management change at base level for the QRP. At some bases the environmental management flight oversees the QRP, and some the Operations Flight, this policy directs the improvements that need to be made in the QRP to meet the DoD, AFI, and audit requirements.

Likewise, installations may change management to improve the oversight of the QRP.

Financial Management (FM) and Contracting must provide support and assistance where necessary to the QRP. Due to the financial implications of QRP operations, it is important for the FM community to be involved and provide assistance in creating suspense accounts, tracking funds, and obtaining reimbursement from DRMO. As a result of the contracting requirements that must be in place to ensure all of the appropriate data is available for required congressional reporting, contracting must provide assistance with any necessary contract modifications or enforcement.

Solid Waste Diversion and Recycling

It is Air Force policy to make every effort to divert non-hazardous solid waste from landfills and incinerators through reuse, recycling, composting, mulching, or donating, while ensuring integrated non-hazardous solid waste management programs provide an economic benefit. At a minimum, in accordance with 40 CFR §246.200-1, 201-1, and 202-1, the following mandatory items must be recycled under the following circumstances:

Installations with greater than 100 office workers must separate high-grade paper at the source of generation, collect it separately and sell it for the purpose of recycling.

Installations with greater than 500 families in residence must separate used newspaper at the source of residential generation, collect it separately, and sell it for the purpose of recycling.

Installations that generate greater than 10 tons of waste corrugated cardboard containers per month must recycle them.

In accordance with 40 CFR §246.100 (f), any installation that has determined, for whatever reason, that they will not follow the requirements of 40 CFR §246.200-1, 201-1, and 202-1 must submit a report to the US Environmental Protection Agency (US EPA) Administrator detailing the analysis and rationale used in making that determination. The report must be sent through the MAJCOM/CEV/A7CV to HQ USAF/A7CV for submission to US EPA, after which the US EPA Administrator will then publish the report in the federal register. The following are considered by the US EPA to be valid reasons for not source separating under individual facts and circumstances: inability to sell the recovered materials due to lack of market; and costs so unreasonably high as to render source separation for materials recovery economically impracticable. The report must include a description of alternative actions considered with emphasis on those alternatives that involve source separation for materials recovery.

In accordance with AFI 32-7080, the Air Force requires its installations to strive to divert/recycle the following additional items from the waste stream as cost effectively as possible:

Metals Plastic

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Glass Used oil

Lead acid batteries Tires

Installations are encouraged to add to the list of items, other commodities that are economically feasible to divert/recycle.

Solid Waste Diversion Reporting

Solid waste diversion data is required to ensure effective program management and to comply with reporting requirements to the Office of the Secretary of Defense (OSD) and the Congress. Accurate data reporting is critical to maintain program credibility, obtain adequate funding, and document program successes to OSD and Congress.

In accordance with Executive Order 13101, Sec. 701, all contracts that provide for contractor operation of a government-owned or -leased facility and /or contracts that provide for contractor or other support services at Government-owned or operated facilities awarded by executive agencies awarded by the Air Force must include provision to require the contractor to comply with this document. Refuse and disposal contracts must include provisions to collect and report solid waste data appropriate for implementing Air Force solid waste diversion policy. Protocols and procedures to obtain data from third parties (e.g. landfill operators) should be developed to augment service contract data.

All solid waste disposal, diversion and recycling data must be reported through, and validated by, the MAJCOM, prior to submission to HQ USAF/A7CV. Installations will utilize standard volume-to-weight conversion factors to ensure accurate calculations (See enclosure 1).

Appropriate Use of Net Proceeds

In accordance with 32 CFR §172.5(f)(1), an installation involved in the direct sale of scrap materials must establish and manage a QRP budget clearing account (suspense) account (F3875) for the collection of QRP proceeds up to $2 million. (Any balance in excess of $2 million must be transferred to the Treasury.)

As stated in the Air Force Memorandum transmitting DoD QRP Guidance, 29 Jul 2003, and in accordance with 10 U.S.C. §2577, QRP proceeds must first be used to reimburse the cost of operations, maintenance, and overhead for processing recyclable materials at the installation, to include any equipment purchased for recycling purposes. Proceeds must also be used to build up a surplus capable of sustaining operations through poor market conditions. If a balance remains at the end of the fiscal year after those costs are covered, not more than 50% of that balance may be used for pollution prevention projects, such as energy conservation and occupational health activities. The remaining balance can then be transferred to the non-appropriated Morale, Welfare, and Recreation account or retained in the installation QRP suspense account at the end of the fiscal year.

QRP Business Plan

The installation QRP must create and maintain a business plan that addresses QRP management, facilities, equipment and services, record keeping and auditing, market analysis, economic analysis of alternatives, and the financial plan. Guidance on creating a QRP business plan will be included in the USAF QRP Guide.

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The installation QRP must maintain all appropriate supporting financial records in order to adequately assess QRP operations; annually monitor market trends; and track the net proceeds from the direct sale of recyclables. The QRP must also maintain any necessary documentation to support non-hazardous solid waste diversion reporting in accordance with the Air Force Memorandum transmitting DoD QRP Guidance, 29 Jul 2003.

Economic and Market Analysis

The installation QRP must perform periodic economic and market analysis/assessments and re-check with vendors to determine whether mandatory and recommend items can be recycled, and whether they can be recycled more cost effectively either locally or elsewhere. In accordance with 40 CFR §246.100 (f), installations must be able to adequately justify (via documentation, economic and market analysis, etc.) lack of recycling /diversion efforts for mandatory items, recommended items in accordance with AFI 32-7080, and any subsequently recommended commodities. Guidance on completing economic and market analysis/assessment, and documentation of the lack of recycling efforts will be included in the USAF QRP Guide.

Recouping Proceeds from DRMO

DoDI 4715.4, Pollution Prevention, requires procedures and controls be established to ensure that 100% of any proceeds (less the costs of sales and handling) are returned to an installation for recyclable materials consigned for disposal through Defense Reutilization and Marketing Service (DRMS) on behalf of the QRP. The installation QRP must consistently process and track any outstanding recouping actions for un-reimbursed Defense Reutilization and Marketing Office (DRMO) scrap sales, with the assistance of the appropriate CE/A7C Resource personnel. The QRP Manager must ensure that DRMO scrap sale proceeds and QRP revenue are reported no less than once per quarter to the wing commander or the appropriate designee and the MAJCOM.

QRP Eligible and Non-Eligible Items

In addition to the mandatory recycling items mentioned in this document, industrial scrap metal from Air Force working capital fund (AFWCF)1 activities, if determined that recycling the scrap is not economical, and industrial scrap from non-AFWCF activities may be recycled in an installation QRP. The table in Enclosure 2 contains a detailed list of QRP eligible and ineligible items whose sales proceeds can be deposited into the QRP suspense account.

A list of relevant solid waste disposal and recycling reference documents is provided in enclosure 3 for further policy and technical guidance reference.

Enclosures:

1. Standard Volume-to-Weight Conversion Factors

2. Table: QRP Eligible and Non-Eligible Items

3. Solid Waste Disposal and Diversion/Recycling References

1 Air Force Working Capital Fund (AFWCF) [formerly Defense Business Operations Fund (DBOF)] was established on 11 Dec 1996 through the restructure of the DBOF into individual component working capital funds. AFWCF activities sell goods and services to a wide range of customers, including DoD operating forces, Air Force activities, other US government activities and foreign military sales customers. The AFWCF activity groups include Depot Maintenance, Supply Management, and Information Services.

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Enclosure 2 - QRP Eligible and Non Eligible Items

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Table: Items that may or may not be recycled and directly sold under a QRP

Items that May be Recycled and Directly Sold under a QRP

Items that May Not be Recycled and Directly Sold under a QRP2

Industrial scrap metal from non-Air Force working capital fund (AFWCF) activity

Scrap generated from AFWCF activity routinely used to offset overhead and customer costs

Industrial scrap metal from AFWCF activities (if determined uneconomical for AFWCF to divert/recycle)

Items that must be demilitarized at any time during its life cycle

Expended firing range brass and gleanings - not requiring demilitarization, which have been crushed, shredded, or otherwise destroyed prior to public sale

Items that can be reused for their original purpose without special processing such as:

- Used Vehicles

Beverage containers (metal, glass, & plastic) - Vehicle or machine parts

Office paper (High-grade, bond, computer, mixed, telephone books and federal register)

- Electrical components

Newspaper - Unopened containers of oil, paints, or solvents

Cardboard/Pressboard - Bottles (not scrap glass)

Glass Commissary store wastes (Bones, fats, and meat trimmings) and Exchange store wastes

Plastics Repairable items not processed through the disposal cycle

Scrap wood Fuels

Rags/Textile wastes Ships, planes, or weapons that must undergo demilitarization or mutilation prior to sale

Used Oil (except when hazardous waste) Munitions List items or Strategic List items 3

Batteries (unless prohibited by law) Hazardous wastes (including household hazardous waste)

Tires Precious Metal Scrap4,5

Used cooking oils and food wastes from dining facilities Radioactive Materials

Wire and Cable (Primary and secondary building wiring)

Ozone Depleting Substances

Non-hazardous Construction and Demolition Items (i.e.

scrap metal from appliances, copper piping, etc.)

Government Furnished Material

2 32 CFR §172.2 (b)(3) 3 DoDI 4160.21-M-1, Defense Demilitarization Manual 4 DoDI 4160.21-M, Defense Demilitarization Manual, Chapter 11 5 Defense 16.18. Defense Logistics Agency Memorandum, Disposition Instructions for Precious Metals (PM) Bearing Plant Clearance Material - Fiscal Year 2006, 30 Nov 2005

Enclosure 3 - Solid Waste Disposal and Diversion/Recycling References

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1. Title 32 CFR §172.2 (b) - Disposition of Proceeds from DoD Sales of Surplus Personal Property

2. Title 40 CFR §246 Subpart A - Source Separation for Materials Recovery Guidelines

3. Title 40 CFR §246 Subpart B - Recycling Requirements and Recommended Procedures

4. 10 U.S.C. §2577 - Disposal of Recyclable Materials

5. 10 U.S.C §2805 - Unspecified Minor Construction

6. 40 U.S.C. §484 - Disposal of Surplus Property

7. Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and

Federal Acquisition, 16 Sep 98

8. Executive Order 13148, Greening the Government Through Leadership in Environmental

Management, Apr 21, 2000

9. DoDI 4715.4, Pollution Prevention (6 Jul 98)

10. DoDI 7310.1, Disposition of Proceeds from DoD Sales of Surplus Personal Property (July 10, 1989)

11. DoD Unified Facilities Criteria 1-900-1, Selection of Methods for the Reduction, Reuse, and

Recycling of Demolition Waste, 1 Dec 2002

12. DoD Unified Facilities Criteria 3-240-14N, Design: Solid Waste Disposal, 16 Jan 2004

13. DoD Manual 4160.21M, Defense Materiel Disposition Manual, Chapter 3, B.2.d.6(a)

14. Office of the Under Secretary of Defense Memorandum, 12 Oct 2004, Revised Department of

Defense Pollution Prevention and Compliance Metrics

15. Office of the Under Secretary of Defense Memorandum, 15 May 1998, Recycling of Firing-Range

Scrap Consisting of Expended Brass and Mixed Metals Gleaned from Firing-Range Clearance through Qualified Recycling Programs

16. Program Budget Decision 412 of 23 November 1997

17. AFI 32-7042, Solid and Hazardous Waste Management (12 May 94)

18. AFI 32-7080, Pollution Prevention Program (12 May 94)

19. Air Force Memorandum, 29 Jul 03, Department of Defense (DoD) Qualified Recycling Program

(QRP) Guidance

20. Defense Logistics Agency Memorandum, 30 Nov 2005, Disposition Instructions for Precious

Metals (PM) Bearing Plant Clearance Material - Fiscal Year 2006

21. The Air Force Center for Environmental Excellence website, http://www.afcee.brooks.af.mil/

Enclosure 3 - Solid Waste Disposal and Diversion/Recycling References

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22. The Federal Facilities Environmental Stewardship and Compliance Assistance Center website, http://www.fedcenter.gov/.