Appendix_K_-_Non_haz_SW_Data_Reporting_Guidance.pdf

Air Force Non-Hazardous Solid Waste Diversion Reporting Guidance

1. Non-Hazardous Solid Waste Diversion Policy Statement: All Air Force installations must implement integrated solid waste management (ISWM) to maximize solid waste diversion and maintain recycling programs in the most cost-effective manner possible.1 The generally accepted methods of diversion include reuse, composting, mulching, recycling, and donation.

Installation ISWM will include a recycling program that will strive to divert as much non-hazardous solid waste as economically and technically practical, and at a minimum, in accordance with 40 CFR Part 246.200-1, Part 201-1, and Part 202-1 and any state, local, or FGS requirements or OEBGD in the absence of approved FGS. All relevant contracts (base, AFCEE, AFCESA, USACE, and other MILCON) must include appropriate FAR clauses and scope language requiring meeting the diversion goals and timely metrics reporting to CEVs.

Air Force Non-Hazardous Solid Waste Diversion Goal: The Air Force non-hazardous solid waste diversion goal percentage without including construction and demolition (C&D) debris is 40% by 2010.2,3

2. Construction and Demolition (C&D) Debris Policy Statement: The Air Force will make every effort to identify local recycling and salvage operations that could process site related waste. Project design must include plans to recycle or salvage at least 50% of C&D debris, land clearing waste, excluding soil, where economically and technically practical.4 The generally accepted methods of diversion include reuse, donation, recycling, composting, and mulching. All relevant contracts (base, AFCEE, AFCESA, USACE, and other MILCON) must include appropriate FAR clauses and scope language requiring contractors to meet the diversion goals and provide timely metrics reporting to CEVs.

C&D Debris Diversion Goal: The Air Force C&D debris diversion goal percentage is 50% by 20105.

3. Applicability: All Air Force installations within the continental United States and its territories, and all overseas installations that generate solid waste must report non-hazardous solid waste data except when the exemption criteria described herein is met. Installation tenants’ solid waste generation must be included in the total waste generation figures

4. Exemptions: Installations generating less than an average of one ton of solid waste per day may be exempt from these reporting requirements. Installations that fall into this category are usually small facilities and reserve centers. For an installation to legitimately claim this exemption, the installation must produce less than one ton of total combined non-hazardous solid waste generation amounts per day (calculated annually). The one ton per day includes

1 Air Force Instruction 32-7042, Waste Management, TBD 2 DoD Installation Strategic Plan, Dec 2007 3 This new solid waste diversion rate was developed in accordance with EO 13423, Instructions for implementing Executive Order 13423, Sec IX. A.

4 In accordance with the Federal Leadership in High Performance and Sustainable Buildings Memorandum of Understanding, signed by all federal agencies. Mr. Philip Grone, Deputy Under Secretary of Defense for Installations and Environment was the signatory for the DoD, signed 26 Jan 06.

5 DoD Installation Strategic Plan, Dec 2007

Attachment 1 of 10 refuse, recyclable materials, green waste, incinerated waste, and total C&D debris generated, and other select waste (i.e. antifreeze, oils, and lead-acid batteries). Installations seeking this exemption must request approval from their respective MAJCOM with sufficient data to demonstrate the exemption is applicable. If the installation’s population is 300 or more, they will probably generate about a ton of solid waste per day or more. Additionally, documentation shall be maintained to demonstrate that the installation is eligible for the exemption and is making efforts to meet the agency solid waste diversion goal. Any installation claiming an exemption from reporting shall be audited during each subsequent external ESOHCAMP years to revalidate eligibility.

All privatized (family housing) FH shall be exempt from all non-hazardous solid waste reporting requirements and diversion goals. Non-privatized FH are required to report and achieve non-hazardous solid waste diversion goals specified herein.

5. How is the data used and why is it collected?: AFCEE manages the database used for collecting Air Force solid waste data among other media data called the Air Force Environmental Data Collection System. Once the installations have input their data, the MAJCOMs are then responsible for QA/QC prior to final submission to Air Staff. Once the data is ready for final submission, AFCEE consolidates it, provides trend analysis, and submits it to Air Staff. Air Staff then creates the following required data points: % of non-hazardous solid waste generated/diverted from the landfill (reused, donated, recycled, composted, and mulched), incinerated, recyclable commodity sales, % of C&D debris generated/diverted, and per capita waste generation (to name a few). These data points are submitted to the Assistant Deputy Under Secretary of Defense for environmental, safety, and occupational health ADUSD(ESOH) Environmental Management and consolidated with the rest of the Services for final submission to the Office of the Federal Environmental Executive and to the US.

Congress. The success stories are used by Air Staff and ADUSD(ESOH) to publicize the good work the installations are accomplishing in their waste diversion efforts, and are many times published in the ADUSD(ESOH)Annual Report to Congress. Data collected in the AFEDCS receives a high level of visibility as it is presented in the semi-annual Environmental Management Review briefing to ADUSD(ESOH).

6. Definitions:

Actual Cost (AC) is the actual cost to operate an integrated solid waste management program including the cost of recycling.

AC = collection costs + transportation costs + disposal costs + diversion costs – diversion proceeds

Installations submit data into the AFEDCS For MAJCOM approval

MAJCOMs QA/QC data prior to submission to

AFCEE

AFCEE consolidate data and submits it to Air Staff

Air Staff conducts HQ - level data review

Air Staff incorporates data in EMR brief submits to OSD for the Annual Report to

Congress

Installations submit data into the AFEDCS For MAJCOM approval

MAJCOMs QA/QC data prior to submission to

AFCEE

AFCEE consolidates data and submits it to Air Staff

Air Staff conducts HQ - level data review

Air Staff incorporates data in EMR brief submits to OSD for the Annual Report to

Congress

Attachment 2 of 10

Alternative Daily Cover is cover material, other than earthen material, placed on the surface of the active face of a municipal solid waste landfill at the end of each operating day to control vectors, fires, odors, blowing litter, and scavenging.

Biosolids is solid or semisolid organic material obtained from treated wastewater, often used as a fertilizer or soil amendment.

Collection and Transportation Costs are the costs to collect and transport wastes and materials that are destined for either disposal or diversion. The collection and transportation costs include labor, maintenance, and other operational expenses associated with collection and transportation of all non-hazardous waste/material

Composting is the controlled process for managing the degradation of organic material that is biologically decomposed (broken down) into a useful soil amendment. Compost can also be used as mulch. Grasscycling (i.e., mulching mowers) does not qualify as a diversion credit for non-hazardous solid waste diversion.

Construction and Demolition (C&D) debris is defined as material produced during the construction, renovation, demolition or deconstruction of roads, runways, residential and commercial buildings, and their infrastructure. C&D debris typically includes concrete, copper piping, steel, copper wire, wood, metals, gypsum wallboard, ceramic tile, porcelain bathroom fixtures, asphalt, and roofing material. C&D debris does not include the dirt/soil removed from construction sites, although every effort for reuse is encouraged.

Cost Effective is something that is economical, based on the tangible benefits produced by the money spent and producing good results. Cost effectiveness is a function of both costs saved and costs avoided.

Defense Reutilization and Marketing Service (DRMS) is part of the Defense Logistics Agency (DLA), and was established to consolidate the different military services’ disposal operations.

Disposal Costs are the costs to dispose of waste/material and include tipping fees, service contract fees and other administrative fees. For the purposes of metric calculation, they do not include collection and transportation fees. When collection and transportation fees cannot be separated from disposal costs as defined above they are used collectively.

(Waste) Disposal Facility includes a contained landfill; construction/demolition debris landfill;

residual landfill; solid waste incinerator; waste-to-energy facility; or a hazardous waste incinerator, landfill, or other site or facility for the land disposal of hazardous waste.

Diversion is defined as any process by which waste is diverted from entering a disposal facility. Composting, mulching, recycling, reuse, and donation are generally accepted waste diversion methods.

Donation is the distribution of donable surplus property under the control of an executive agency to a federally authorized and eligible donee.

Attachment 3 of 10

Economic Benefit of Integrated Solid Waste Management Programs is the cost avoided by diverting solid waste rather than disposing of it. It is calculated by subtracting the actual cost to operate an ISWM program, including the cost of recycling from the potential cost if all waste (including C&D debris) were to be landfilled or incinerated rather than diverted. A positive economic benefit means that the cost to dispose of the diverted material is greater than the cost to divert the material.

Economic Benefit = PC – AC

Grasscycling is a source reduction activity in which grass clippings are left on the lawn after mowing to break down and add nutrients. Grasscycling does not qualify as a diversion credit for non-hazardous solid waste diversion unless is it routinely collected, bagged and disposed.

Incineration is a controlled burning process (also called combustion) to reduce the volume of waste that must be disposed in landfills, and can reduce the toxicity of waste, ideally converting organics to carbon dioxide and water.

Integrated Solid Waste Management (ISWM) is a comprehensive approach to managing non-hazardous solid waste that encompasses waste prevention, recycling, composting, and disposal programs. Through ISWM, DoD Components seek to determine the most cost effective, energy-efficient, least-polluting ways to deal with the various segments of, and the items typically found in, an installation or facility solid waste stream.

Land clearing waste is landscaping and land clearing material which includes yard waste, rock, brush, woody waste and clean or contaminated soil, dirt or sod.

A landfill is a discrete area of land or an excavation, on or off an installation, that receives household waste and that is not a land application unit, surface impoundment, injection well, or waste pile. A solid waste landfill also may receive other types of waste, such as commercial waste or industrial waste.

Class I (secure landfills) = Hazardous Waste Landfill Class II (monofills) = Designated Waste Landfill Class III (sanitary landfills) = Municipal Solid Waste Landfill

Municipal Solid Waste (MSW) is any garbage or refuse, sludge from a wastewater treatment plant, water supply treatment plant, or an air pollution control facility and other discarded material, including solid, liquid, semi-solid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities.

Solid waste does not include solid or dissolved materials in domestic sewage, solid or dissolved materials in irrigation return flows, industrial discharges that are point sources subject to permit under 33 U.S.C. 1342, or source, special nuclear, or by-product material as defined by the Atomic Energy Act of 1954, as amended (68 Stat. 923).

Attachment 4 of 10

Mulch can be made from chipped wood waste onsite from sources such as furniture and other durable goods, wood packaging (e.g., crates and pallets), and other miscellaneous products.

Once chipped, these products can also be used as a composting bulk agent.

Non-hazardous solid waste is defined by the Department of Defense as refuse, garbage, scrap, sludge, and discarded waste that is routinely landfilled. The waste is generally non-hazardous but may contain household waste, both hazardous and non-hazardous construction and demolition waste.

Potential Cost (PC) is the potential cost if all waste (including C&D debris) were to be landfilled or incinerated rather than diverted (i.e. reused, mulched, composted, recycled, or donated).

PDC = Collection Costs +Transportation Costs + Disposal Cost + Diverted Materials Disposal Cost

Qualified Recycling Program (QRP) is a recycling program that manages proceeds pursuant to 10 U.S.C. 2577 and requires concerted efforts to divert or recover scrap or waste from waste streams and identify, segregate, and maintain the integrity of the recyclable materials to maintain or enhance the marketability of the materials.

Recycling is the process by which materials otherwise destined for disposal are collected, processed, and remanufactured into new products.

Reuse is the subsequent uses of a product after the initial / first use without the need for reprocessing - by repairing them, donating them to charity and community groups, or selling them – to reduce waste. For example, a soft-drink bottle is re-used when it is returned to the bottling company for refilling. Special processing is not required.

Solid Waste is any discarded material as defined in 40 CFR 261.2.

Soil amendment is any material added to soil to improve physical properties, such as water retention, permeability, water infiltration, drainage, aeration and structure to provide a better environment for roots.

Solid Waste Diversion is the act of preventing non-hazardous solid waste from entering an incinerator, waste disposal, or waste-to-energy facility.

Waste-to-energy Incineration is a controlled burning process used to obtain positive energy output and offset energy required from other energy sources such as fossil fuel, nuclear hydroelectric, wind, or other sources

7. What must be reported?: Each of the following applicable data elements must be completed for each reporting installation. Installations and MAJCOMs must validate their data and indicate to best knowledge that their non-hazardous solid waste data is accurate prior to final submission to the Air Force environmental data collection system.

Attachment 5 of 10

Data Element Data Definition Tons of non-hazardous solid waste composted this quarter

Amount of non-hazardous solid waste that is composted (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris.

Tons of non-hazardous solid waste mulched this quarter

Amount of non-hazardous solid waste that is mulched (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris.

Tons of non-hazardous solid waste recycled this quarter

Amount of non-hazardous solid waste that is recycled (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris

Tons of non-hazardous solid waste reused this quarter

Amount of non-hazardous solid waste that is reused (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris

Tons of non-hazardous solid waste donated this quarter

Amount of non-hazardous solid waste that is donated (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris

Tons of construction and demolition (C&D) debris diverted this quarter

Amount of construction/demolition (C&D) debris that is diverted (in tons, where 2,000 pounds = 1 ton). Include only C&D debris

Tons of biosolids composted or used as Alternative Daily Cover this quarter

Amount of biosolids generated by the wastewater treatment plant sent to a composting operation or sent to a landfill to use as Alternative Daily Cover

Tons of non-hazardous solid waste sent to disposal facilities this quarter

Amount of non-hazardous solid waste that is sent to landfill disposal facilities (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris. Do not include non-hazardous solid waste disposed by waste-to-energy incineration, or non waste-to-energy incineration.

Tons of C&D debris disposed of this quarter

Amount of non-hazardous solid construction/demolition debris that is sent to disposal facilities (in tons, where 2,000 pounds = 1 ton). Include only C&D debris. Do not include C&D disposed by waste-to-energy incineration, or non waste-to-energy incineration.

Tons of non-hazardous solid waste disposed by waste-to-energy incineration this quarter

Amount of non-hazardous solid waste that was disposed by waste-to-energy incineration (in tons, where 2,000 pounds = 1 ton). Do not include C&D debris, or non waste-to-energy incineration.

Tons of construction/demolition debris disposed by waste-to-energy incineration this quarter

Amount of construction/demolition debris that was disposed by waste-to-energy incineration (in tons, where 2,000 pounds = 1 ton). Include only C&D debris. Do not include C&D debris disposed of by or non waste-to-energy incineration.

Tons of biosolids disposed of this quarter.

Amount of biosolids from the wastewater treatment plant disposed of at a landfill.

Actual Cost = AC Actual integrated solid waste management cost in dollars is the actual cost to operate an integrated solid waste management program, including recycling (diversion). AC = collection and transportation costs + disposal costs (tipping fees, contract service fees, etc.) – diversion proceeds. If solid waste and recycling are both contracted operations, Attachment 6 of 10 this is the total cost of the two contracts minus the diversion proceeds. If the contractor retains the recycling proceeds to reduce or offset contract costs, then this is simply the cost of the two contracts. Strongly recommend that you request and obtain the recycling sales amounts from the contractor to ensure the contract is appropriately credited/offset.

Potential cost in dollars = PC is the potential cost if all waste (including C&D debris) were to be landfilled or incinerated rather than diverted (i.e.

reused, mulched, composted, recycled, or donated). PC = collection and transportation costs + disposal cost + the cost to dispose of diverted material.

Actual Cost Avoidance =ACA This is the cost avoided and/or saved by diverting materials from tradition disposal. This field is auto calculated as PC-

AC.

Direct sales = DS This includes diversion proceeds from the direct sale of QRP eligible items by the installation QRP in total dollars (DS). This excludes diversion proceeds from DRMS sales.

DRMS sales = DRMS This includes the total diversion proceeds received from the sale of any recyclable commodity by DRMS on behalf of the installation and deposited in the installation QRP suspense account.

Total Gross recyclable sales in dollars =

GS

The total gross recyclable sales include the total proceeds received from the direct sale of recyclable by the installation QRP and on behalf from DRMS of QRP-eligible commodities (ex. cardboard, aluminum cans, paper).

Gross sales GS = DS + DRMS

Remaining lifespan for landfill If your installation has a permitted landfill, provide the remaining lifespan, in the number of years, for the landfill that is being used by the refuse collection contractor for disposal. As the lifespan is reduced, refuse costs may increase sharply. The installation may need to be involved in local planning meetings to site a new landfill.

Outreach/Education Events An event is defined as a newspaper article, Earth Day, America Recycles Day, e-mail newsletter, fact sheet, etc.

Residential population Also referred to as non-privatized Military Family Housing (MFH). This data point will help to calculate the installation (to include the dormitory residents) per capita waste generation rates. Be sure to only include the non-privatized residential housing population for whom the installation or the installation’s refuse/recycling contract handles their waste. Reference installation public affairs office or any office which maintains official demographic data for the installation. If the Air Force funds the contract for privatized housing refuse collection/recycling services then the population served by that contract should be included in the residential population figures.

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Non-residential population Installation working population. This data point includes the number of people working on the installation whether they are military, civilian or contractor, full time or part-time, and host nation armed forces if their waste is included with US waste during the reporting period. Again, this data point will feed into the per capita generation of waste for the installation. If you have difficulty determining what this number should be, the installation public affairs office (PAO) should track and maintain official demographic data that could be used for this data point. Reference installation public affairs office or any office which maintains official demographic data for the installation.

8. Potential Data Sources:

Installation solid waste/recycling contracts Installation construction contracts Contract Quality Assurance Evaluator (QAE) Installation CE Facility Operations component

9. What must not be reported: Installations must not report asbestos or lead based paint disposal costs or weights in their solid waste management calculation. Universal waste or other special wastes which do not go to a traditional class III MSW landfill must not be included in the solid waste diversion calculation. Additionally, waste-to-energy incineration is not considered traditional diversion and must be reported as a standalone data element.

10. Who submits the data: Since solid waste data originates with a facilities operations (FO) funded component, but is currently submitted through environmental, data collection and validation must be a joint effort. (Note: CE environmental responsibilities for solid waste diversion became the responsibility of CE Asset Management effective 1 Oct 08). CE operations must provide the required non-hazardous solid waste management data to environmental in time for a timely submittal. All construction contracts must include non-hazardous solid waste reporting requirements to ensure disposal and diversion data is supplied by the contractor. Include the following in host tenant support agreements and memorandum of agreements: “The host Wing will report all data for DoD units receiving service on the installation including Army, Navy, Marines, Reserve and Guard Units, AAFES, DeCA, and DRMO. The US Army Corps of Engineers and Navy Regional Officer in Charge of Construction must report data from construction and demolition related activities to the host Civil Engineer. Other federal agencies such as Department of Justice, Department of State, and Department of Homeland Security will also provide requested data to the host Civil Engineer.”

Frequently Asked Questions

How should Universal and other special wastes be counted?

Disposal or diversion weights for universal and other special waste that may contain hazardous constituents (i.e. wastes that cannot be disposed of in a class III Municipal Solid Waste landfill or MSW incinerator should not be reported as part of non-hazardous solid waste disposal or diversion.

Attachment 8 of 10

Should installations report non-hazardous solid waste diversion data from privatized housing?

The answer is NO. If the installation does not collect or control the waste, then they should not report the numbers for privatized housing. All the Services are having problems with this issue; not just Air Force. Privatized housing MSW disposal contracts currently don't have any requirement to report metrics to the installations.

In accordance with privatized housing legal opinion, the installation maintains ownership of the physical land in the instances of Air Force privatized housing but not the buildings (facilities) residing on the land. The Air Force has transferred the ownership of the housing buildings (facilities) by lease to a private entity for the period of 50 years. This private entity is then a private tenant on the installation and as such is not subject to federal law or requirements pertaining to the federal government. Additionally, the contract the government enters into with these private entities is not a Federal Acquisition Regulation (FAR) contract, and there is no guarantee that there is an environmental provision included therein. The recycling requirements in RCRA pertain only to federal entities, and are tied to the actual facilities and not the land beneath them. Therefore private tenants on an installation are only subject to the municipality or other local laws and regulations for private facilities within the same jurisdiction.

What are installations required to report if they do not meet the reporting threshold limit?

According to the ADUSD(ESOH) metrics, installations generating less than and average of one ton of solid waste per day are exempt from these reporting requirements. Installations that fall into this category are usually small facilities and reserve centers. If the installation’s population is 300 or more, they probably generate about a ton of solid waste per day or more. However, installations seeking this exemption must maintain data and documentation to continually demonstrate that they are making efforts to meet the agency goal solid waste diversion percentage goals, and that the exemption remains applicable. Any exempt reporting installation will be reevaluated at the whim of the MAJCOM and audited during the external ESOHCAMP to revalidate eligibility.

What is the policy for donated items? How does DRMS figure in the equation?

Donations are covered under DoDI 4160.21-M, chapter 6. Donation is the distribution of donable surplus property under the control of an executive agency to a federally authorized and eligible donee. It is the responsibility of the DRMS to administer the DoD donable surplus personal property program as it applies to approved Service Educational Activities and schools (non-national organizations). This includes such actions as prescribing procedures, developing donation agreements, and processing requests to higher authority for deviation from formal agreements. A list of authorized donees is listed in DoDI 4160.21-M, chapter 6, A.5.a-g.

What are division of roles and responsibilities for solid waste and recycling between Facility Operations (FO) and environmental?

Reporting requirements need to be explicitly clear in roles and responsibilities as to environmental's role (data collection, and metrics reporting) and FO’s role (day to day execution of the recycling and diversion efforts to meet these metrics).

Attachment 9 of 10

What are some common examples of diversion?

Type of Diversion Commodity/Item

Reuse (DRMS charged with execution) furniture, supplies, equipment, and appliances transferred to DRMS, pallets from the commissary, BX, and Supply

Donation (DRMS charged with execution)

Food waste to local food banks, eligible items to the thrift shops and Airmen’s Attic, computers to schools, etc.

Recycling through QRP scrap metal, expended firing range brass and gleanings – not requiring demilitarization, containers (metal, glass & plastic), office paper, newspaper, magazines, cardboard/pressboard, glass, plastics, scrap wood/pallets, rags/textile wastes, used oil/antifreeze (except when hazardous waste), batteries, tires, used cooking oil and food wastes from dining facilities, wire/cable, non-hazardous construction and demolition debris (e.g., scrap metal, asphalt, concrete, wood, roofing material, gypsum wallboard, etc.

Recycling through DRMS Munitions (>50 cal or 12.7mm), military scrap metal requiring demilitarization (proceeds are not QRP eligible)

Composting Grass clippings, yard waste, food waste

Mulching Grass clippings, yard waste, other applicable woody wastes

What are some common items that do not count toward diversion?

Common items that do not count toward diversion include the following:

• Grass clippings left on the lawn (Grasscycling)

• Waste-to-energy incineration

• Soil/dirt (unless exact weights can be tracked as diverted from landfilling with associated cost avoidance, or there is customarily a cost to dispose of it and the cost avoidance can be calculated)

Attachment 10 of 10