Appendix_L_-_QRP_Guide_Sep_08.pdf

Qualified Recycling

Program

(QRP)

Guide

SEPTEMBER 2008

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Table of Contents

Section 1. Introduction Who Should Use This Guide How to Use This Guide

Section 2. Qualified Recycling Program

Section 3. QRP Planning

Commodity Market Feasibility Study Identify Potential Recyclable Materials Estimate Generation Rates Evaluate Quality and Packaging of Materials Conduct an Economic Analysis for Each Material

Outsourcing Alternatives Cost-Benefit Study Source Separation Commingled Collection with Curbside Sorting Commingled Collection with Material Recovery Facilities (MRF) Sorting Downstream Separation

Decision Matrix

Section 4. Roles and Responsibilities

Installation Commander Role QRP Subcommittee to the ESOHC Role Comptroller (FM) Role Civil Engineering Squadron (CES) Role Asset Management (CEA) Housing Program Management (CEAC) Unaccompanied Housing (UH) (CEAC) Operations (CEO) Resources (CER) QRP Manager Role Recycling Center Manager Role Building/Facility Managers Role Unit Environmental Coordinator Role Tenants Role Contractors Role DRMO Role

Section 5. Recycling Practices

Contract Language Shop-Level Procedures Base-Wide Procedures DRMO Turn-in and Accountability Procedures

Section 6. Financial Management

Sales Management DRMO Sales Direct Sales Sales through Contractors or Partners

Sales Proceeds Handling QRP F3875 Budget Clearing Account (Suspense) Forms of Payment Recovery of QRP Costs Proceeds Allocation

Financial Performance Calculation

Section 7. Records Management and Reporting Recordkeeping Operation/Overhead Cost Records Direct Sales Documentation Reporting

Diversion Rate Calculation Incineration Rate Calculation Economic Benefit of Integrated Solid Waste Management Calculation

Section 8. Audits and Staff Assistance Visits

Section 9. Education, Awareness and Outreach Program

Training Outreach

Celebrations and Environmental Days Outreach in Mass Media Other Outreach Ideas

Appendix A – Definitions Appendix B – Abbreviations Appendix C – References Appendix D – Standard Volume-To-Weight Conversion Factors Appendix E – Letter to DRMO Requesting QRP Account Appendix F – Example QRP Manager Appointment Letter Appendix G– Example QRP Fiscal Year Budget

Figures

Figure 1 Quick Checklist for QRPs………………………………………………………….…..6 Figure 2 Recycling Requirements for Air Force Installations ……………………………….10 Figure 3 Example of a Decision Matrix for Recycling Options ………………………… Figure 4 Handling of Proceeds and Data for QRP Participants …………………………….22 Figure 5 Daily Inspection Checklist for Shop ……………………………………………….. 25 Figure 6 Inspection Checklist for Recycling Center ………………………………………… 26 Figure 7 Who Pays for What? ………………………………………………………………… 30 Figure 8 Recommended Training for QRP Personnel ……………………………………….38 Figure 9 Suggested Training for Installation Personnel ……………………………………. 38 Figure 10 “Win the War Against Waste” Logo ………………………………………………….41

Section 1 Introduction

USAF QRP Guide September 2008 5

Section 1. Introduction

This document is the U.S. Air Force Qualified Recycling Program (QRP) Guide which provides guidance for operating installation recycling programs. This guide is intended for use by all USAF components (active, guard and reserves), worldwide. A QRP is an installation recycling program that is qualified to retain direct sales proceeds of certain recyclable materials.

Installations must operate QRPs in accordance with specific requirements to retain proceeds for installation use.

Questions, clarifications or edits concerning this Guide may be directed to mailto:nancy.carper@us.af.mil.

Who Should Use This Guide

This guide is intended for Air Force installation solid waste and recycling program managers, QRP Managers, and QRP Subcommittee members. The guide may also be used as a reference for other interested parties, such as MAJCOM solid waste program managers, environmental auditors, or recycling contractors. The guide may be of use to commanders and Environmental, Safety and Occupational Health Council (ESOHC) members as an introduction to QRP operating requirements.

How to Use This Guide

The guide’s purpose is to assist installation QRP Managers with requirements for operating a QRP. The guide is formatted to serve as a reference document and is not necessarily intended to be read through from beginning to end. The document makes use of hyperlinks throughout the text to direct the reader to definitions and additional information including references to other documents, regulations and legal citations. The guide’s first section provides a checklist of major QRP topics. This guide is not a legal document and should not be used as the basis for making legal interpretations on compliance with QRP requirements. Please refer to the specific federal law or Air Force policy documents to learn about those requirements.

mailto:nancy.carper@us.af.mil

Section 2 Qualified Recycling Program

USAF QRP Guide September 2008 6

Section 2. Qualified Recycling Program

A QRP is an installation recycling program that is qualified to retain the direct sales proceeds of certain recyclable materials or also known as recyclable commodities. The QRP is “qualified” if it meets the DoD and Air Force requirements for maintaining accountability for materials sold or diverted through the program. An installation may retain proceeds from recyclable commodity sales for use in certain projects if it operates a QRP.

If an installation does not meet the QRP accountability requirements, recyclable material sale proceeds will be returned to the U.S.

Treasury.

Effective 1 February 2008, installations should strive to achieve the DoD non-hazardous solid waste diversion goal of 40% by 2010, based on current year generation, by maintaining waste prevention and recycling programs in the most cost-effective manner possible.

Figure 1 Checklist provides an overview of major QRP topics. This checklist will help QRP Managers set up and check management controls for their installation’s QRP. Many items in the checklist are required by DoD guidance or Federal regulations. For more information on checklist items, see the corresponding section in this guide, or click on the question to go directly to a detailed item discussion.

Figure 1. Quick Checklist for QRPs

QRP Planning (Section 3) Yes No

Does the installation have a single QRP that covers all Air Force and tenant organizations on the installation?

Has the installation conducted a waste characterization study to identify recycling types and amounts?

Has the QRP performed a periodic economic and market analysis to determine whether mandatory and recommended items can be recycled more cost effectively?

Has a cost-benefit study of outsourcing alternatives been completed and is on file?

Has a decision matrix on how to operate the QRP been completed, briefed to the QRP Subcommittee and approved?

Does the installation collect all materials required by the Air Force?

Does the QRP collect and recycle materials prohibited by Air Force and DoD regulations?

For more information on requirements for QRPs, see DoD Instruction 4715.4 and USAF Policy Letter Air Force Solid

Waste Diversion and Qualified Recycling Program Policy, L. Dean Fox, MG, USAF, The Civil Engineer, DCS/Logistic, Installation & Mission Support, 11 April 2006 For the legal citation on retention of recycling proceeds, see 10 U.S.C. 2577 and 32 CFR 172.

OUSD (I&E) Memorandum, DoD Integrated (Non-Hazardous Solid Waste Management Policy, 1 Feb 08

USAF QRP Guide September 2008 7

Roles and Responsibilities (Section 4) Yes No

Does the installation’s Environmental, Safety and Occupational Health Council (ESOHC) have a solid waste, recycling, or QRP Subcommittee?

Has the installation commander designated, in writing, a QRP Manager?

Does the QRP Manager chair the ESOHC QRP Subcommittee?

Does the QRP Manager report sales proceeds amounts to the ESOHC QRP Subcommittee?

Does the QRP include appropriated funds activities?

Does the QRP include non-appropriated funds activities?

Does the QRP include the base exchange and its activities (AAFES)?

Does the QRP include the Commissary (DeCA)?

Does the QRP include Military Family Housing (non-privatized)?

Does the QRP include Unaccompanied Airman Housing?

Does contractors’ Statement of Work require QRP participation?

Recycling Practices (Section 5) Yes No

Are shop-level diversion procedures in place?

Are QRP procedures included in the installation Integrated Solid Waste Management Plan (ISWMP)?

Are DRMO turn-in and accountability procedures in place?

Does the installation conduct regular solid waste opportunity assessments?

Financial Management (Section 6) Yes No

Does the installation conduct recyclable material direct sales?

Does the QRP Manager conduct direct sales that exceed $15,000 per sale?

Does the QRP Manger conduct commodity sales and also collects the sale proceeds?

Does the QRP receive cash payments for direct sales?

USAF QRP Guide September 2008 8

Does the QRP deposit all proceeds into a F3875 Budget Clearing Account (Suspense) with Defense Finance and Accounting Service (DFAS)?

Are QRP sales proceeds utilized to cover QRP costs?

Are QRP sales proceeds allocated by the QRP Subcommittee?

Does the QRP have a fiscal year operating budget?

Records Management and Reporting (Section 7) Yes No

Does the QRP have a current written business plan?

Does the QRP Manager maintain direct sales records?

Does the QRP Manager maintain records of DRMO sales?

Does the QRP Manager maintain QRP expense records? (Operating, overhead, equipment, start-up, etc.)

Does the QRP Manager maintain cost avoidance records?

Does the QRP Manager report diversion metrics to the installation’s

MAJCOM?

Does the QRP Manager report sales proceeds amounts to the ESOHC QRP Subcommittee?

Audits and Staff Assistance Visits (Section 8) Yes No

Does the installation conduct an annual QRP self-audit?

Does the installation conduct an external QRP audit every three years?

Does the installation have an AFCEE or MAJCOM Staff Assistance Visit (SAV) conducted as needed?

Education, Awareness and Outreach (Section 9) Yes No

Has the QRP Manager received required training?

Do installation personnel receive training on recycling procedures?

Does the installation have an established QRP education and awareness plan?

USAF QRP Guide September 2008 9

Does the installation have a recycling awards/recognition program?

Section 3 QRP Planning

USAF QRP Guide September 2008 10

Section 3. QRP Planning

Each Air Force installation can operate a single, cost-effective QRP and conduct recyclable material direct sales. It is essential to determine what recyclable materials (aka commodities) will be recycled by the installation QRP and the mechanics of commodity collection.

Waste Stream Analysis First step is to determine what commodities are generated throughout the installation. This will require a waste stream analysis or commonly refer to as a waste characterization. Waste characterization information assists in planning how to reduce waste, set up your installation QRP, and conserve money and resources. Waste characterization data is collected by taking samples of waste and sorting it into material types like newspaper and aluminum cans, and weighing each type. Typically, samples are taken from trucks delivering waste to landfills and transfer stations. Samples can also be taken from refuse receptacles (aka dumpsters). Results of sampling also increase the body of knowledge about variations due to climatic and seasonal changes and population.

Commodity Market Feasibility Study

The QRP Manager (or a contracted consultant) should conduct a commodity market feasibility study to determine if it makes good business sense for the QRP to recycle specific materials.

With the waste characterization data, the QRP Manager can determine if sufficient quantities are economically feasible for recycling. Feasibility study objectives are:

Identify potential recyclable materials

Estimate generation rates

Evaluate material quality and packaging

Determine if adequate markets exist

Conduct an economic analysis for each material

Identify Potential Recyclable Materials

The first step in the commodity market feasibility study is to identify recyclable materials that are generated throughout the installation. This information may be available from a waste characterization, DRMO, an existing recycling program, or from solid waste disposal contractor(s). The QRP Manager should prepare a potential recyclable materials list generated throughout the installation. At a minimum, the installation must recycle materials listed in Figure 2.

Figure 2. Federal Recycling Requirements for Air Force Installations

Recyclable Material Source Threshold

High-grade paper Office facilities 100 or more workers

Newspaper Residences 500 or more families

Corrugated cardboard Commercial establishments

10 or more tons per month

The Air Force requires installations to recycle the following materials:

4 For more information, see 40 CFR 246.200-1, 201-1 and 202-1 5 AFI 32-7080, Section 3.4.1.2.1.

USAF QRP Guide September 2008 11

Paper

Plastic

Metals

Glass

Used oil

Lead acid batteries

Tires

High grade paper

Cardboard

Newspaper

There are certain types of materials that a QRP cannot sell which are referred to as QRP-ineligible materials.

Materials a QRP cannot sell include:

Scrap metal containing precious metals

Items that may be used again for their original purpose without processing

Used vehicles

Machine parts

Electrical components

Unopened containers of solvents or oils

Fuel

Hazardous materials

Hazardous waste (except antifreeze, used oil, and lead acid batteries)

Ships, planes, or weapons that must be demilitarized

Scrap generated from Working Capital Funds activities

Bones, fat, and meat trimmings from the commissary or base exchange

Installations that operate ranges may conduct direct sales of range residue gleaned from range activities, provided that certain conditions are met. Range residue includes expended brass, aluminum, and mixed metals cleared from firing ranges. The QRP Manager must ensure that the following conditions are met before the material is sold:

Certified as safe by a qualified person

Must not require further demilitarization

Unusable for its intended purpose

Unsuitable for reloading

Unrecognizable from its original configuration

Must not be a Munitions List Item, Strategic List Item, or Commercial Control List Item

The QRP Manager must establish and maintain management controls to ensure all range residue sold through direct sales meet these conditions. Any items requiring demilitarization must be:

demilitarized by the generating installation sold through DRMO sold to a DRMO contractor with Trade Security Control Clearance

The QRP Manager and recycling operations personnel must receive safety training in material potentially presenting an explosive hazard (MPPEH) recognition.9

Overseas installations must

For more information on excluded materials, see 32 CFR 172.2 (b)(3)

IAW DODI 4160.21M, precious metals encompasses silver, gold and the platinum family. The platinum family includes platinum, palladium, iridium, rhodium, osmium and ruthenium.

8 DODI 4715.4

Training on MPPEH is offered by the U.S. Army Engineering and Support Center, Huntsville.

USAF QRP Guide September 2008 12 recycle range residue through DRMO due to strict requirements under the Arms Export Control Act and the International Traffic in Arms Regulation (ITAR). Sales proceeds are returned to the OCONUS QRP in accordance with current DLA reimbursement policy.

Estimate Generation Rates

After preparing a potential recyclable materials list the installation can recycle through the QRP, the QRP Manager must determine if the installation generates a sufficient amount of materials to make recycling economically feasible. The QRP Manager should analyze the following factors to determine if recycling is feasible:

Quantity of each recyclable material generated

Storage availability

Shops pick-up frequency

Storage pick-up frequency

This information can be obtained from weight tickets, contractor billings, shop interviews, waste characterization studies, and opportunity assessments. If the QRP Manager cannot obtain all information required, he or she should prepare an estimate based on available data, list assumptions made to cover the data gaps, and make changes appropriately. The QRP Manager should add the estimated generation rate to the divertible materials list.

Evaluate Quality and Packaging of Materials

The QRP Manager should evaluate other factors that may affect the ability to divert material through the QRP. These factors include:

Material quality

Material packaging

The material quality is generally determined by how clean it is, or how well materials are segregated. Generally speaking, if the material quality is low, the QRP will receive less money for the material. Some brokers/buyers and recyclers will allow for a certain amount of contamination. Other recyclers may separate materials that are turned in as mixed materials, such as mixed aluminum and plastic bottles or mixed cardboard and paperboard. To enhance marketability, installation personnel should separate recyclable materials at the source. For example, when recycling mixed paper, it is important that employees do not throw food waste and other trash into recycling collection containers.

Packaging is also an important factor in recyclable material marketability. Brokers/buyers may not accept cardboard unless it is baled. Recycling contractors may require materials to be packaged according to certain specifications. The factors listed above form the basis for making a feasibility decision on material recycling. The QRP Manager should contact recycling contractors and recyclable material brokers/buyers to determine if they have specific recyclable material requirements for separation, quality, or packaging.

Determine If Adequate Markets Exist The QRP Manager should determine if there are available brokers/buyers for recyclable materials. This determination will aid the QRP Manager in deciding which recyclable materials to include in the QRP. Certain recyclable material dollar value may fluctuate significantly from listed values because of economic factors and local conditions. Some areas may not have a market for certain recyclable materials, or an installation may not generate enough of a particular recyclable material to make recycling cost-effective. Installations may have to pay for removal of some recyclable materials, but could save money through avoided disposal costs. The QRP Manager may obtain information from local recyclable material brokers/buyers and end users. Information useful in a market analysis includes:

USAF QRP Guide September 2008 13

Recent market prices

Past market trends

Estimates of future market prices

Names and locations of recycling brokers/buyers and/or end users

Quality requirements (e.g. moisture content of paper, cleanliness of bottles)

Packaging requirements (e.g. baling, cubing, bundles, etc.)

These websites may be useful in determining commodity market prices, trends and futures:

http://grn.com/prices.htm http://amm.com/pricing/default.asp http://www.recycle.net/price http://www.recycle.cc/ http://www.scrappricebulletin.com http://recyclingtoday.com http://wastenews.com http://packaging-online.com

Conduct an Economic Analysis for Each Material

After receiving the market analysis report and estimated sales revenue, the QRP Manager (or a contracted consultant) should conduct an economic analysis to determine if recycling the commodity would be cost-effective. If no market exists for the commodity, the QRP Manager does not need to conduct an economic analysis. A QRP can generate revenue from selling recyclable commodities, but recycling may not always be cost-effective because QRP operating costs may exceed revenues generated and avoided costs. Additionally, a review of recent trends and on-the-horizon laws that would impact the QRP should be completed. The economic analysis results should be presented by the QRP Manager to the QRP Subcommittee for approval before beginning any diversion efforts.

To conduct an economic analysis of a particular material, the QRP Manager must calculate the following values:

Additional QRP costs to recycle the material

Avoided costs from recycling

Revenue from recyclable material sales

Additional Costs Additional costs are increased time, effort, and equipment associated with separating recyclable materials from the waste stream and subsequently preparing it for sale.

Avoided Costs Estimate avoided costs by determining the weight or volume of each recyclable material diverted from the waste disposal stream by the QRP. Calculate tipping fees, prorated hauling costs, maintenance costs, landfill tipping fee and any other disposal charges that would have incurred in the absence of waste prevention/recycling. This may or may not be a significant factor, depending on material. An avoided cost example is a reduction in the installation’s solid waste disposal contract fees. Savings can be realized by less frequent solid waste pickups such as once-a-week instead of twice-a-week. The total avoided cost savings can be calculated on a monthly or annual basis, but all facts considered should be realistic and well defined.

10 For more information on methods for performing economic analyses, see AFI 65-501, Economic Analysis, and AFMAN 65-506, Economic Analysis.

http://grn.com/prices.htm http://amm.com/pricing/default.asp http://www.recycle.net/price http://www.recycle.cc/ http://www.scrappricebulletin.com/ http://recyclingtoday.com/ http://wastenews.com/ http://packaging-online.com/

USAF QRP Guide September 2008 14

Revenue For each recyclable material, estimate annual sales revenue. Timely and accurate price and other commodity information are critical. Numerous websites offer useful market information for recyclables.

Calculate economic benefit for materials. There is a positive economic benefit if additional costs are less than avoided costs and revenue. This is expressed in the following equation:

Additional Costs < Avoided Costs + Revenue

The QRP Manager should conduct the analysis by determining if additional costs of recycling are more or less than the sum of the avoided costs plus additional revenue. If additional costs are less than the avoided costs plus revenue, then it is economically feasible to recycle the material.

Outsourcing Alternatives Cost-Benefit Study

In addition to conducting an economic analysis of specific materials, the QRP Manager must consider QRP operation economic costs. Costs that should be considered include:

Startup costs

Equipment purchases

Construction of facilities (buildings, storage areas, etc.)

Operation and maintenance costs

Equipment maintenance

Energy Consumption

Labor costs

Advertising and Promotion

Contract costs

The QRP Manager should prepare cost estimates for use in evaluating alternatives for operating the QRP. The QRP Manager may obtain assistance from installation finance personnel to evaluate QRP operating costs. If the QRP is operated using government employees, equipment and facilities, costs will be from appropriate funding or recyclable material sales proceeds held in the F3875 Budget Clearing Account (Suspense). If the QRP is contractor operated, equipment may be the contractor property and included as contract cost. The QRP Manager may need to prepare several estimates, one for each possible alternative. These alternatives are discussed in the following sections.

QRP operating costs will vary depending on techniques used to collect and transfer recyclable materials. There are several possible techniques for operating a QRP. The differences between techniques focus on who handles recyclable materials and where materials are separated. To evaluate who should handle recyclable materials, the QRP Manager should conduct a commercial activities study.

The Air Force utilizes commercial activities studies to determine if an activity conducted at an installation would be less expensive to the government if performed by a private enterprise. There are many options involved in conducting a recycling operation commercial activity study. These include:

Outsourcing all recycling activities

Partial outsourcing

11 DoD policy [Memorandum on Qualified Recycling Program Guidance, John P. Woodley, Jr., Assistant Deputy Under Secretary of Defense (Environment), 24 April 2003] requires military services and defense agencies to conduct an economic analysis when considering establishing a QRP with direct sales authority. The purpose of the economic analysis is to determine the most cost effective alternative for operation of the QRP, which may include outsourcing of operations. The Federal Government conducts commercial activities studies to evaluate outsourcing of operations. For more information on commercial activities studies, see OMB Circular A-76 Performance of Commercial Activities, 29 May 2003 and DoD Directive 4100.15, Commercial Activities Program, 10 March 1989.

USAF QRP Guide September 2008 15

Hiring contractors to separate materials or operate recycling equipment

Integrating recycling activities into solid waste disposal contract (e.g. ID/IQ paving contracts for asphalt and concrete recovery and reuse; custodian contracts for recyclable collection and recovery; and refuse/recycling contracts for performance-based pay-as-you-throw type incentives

The QRP Manager should review possible options and prepare estimates of each cost option.

The QRP Manager may not know exact cost options, but should be able to put together enough information to determine the most cost-effective option.

The QRP Manager should consider all possible options for recyclable materials separation and handling before selecting a QRP operation method. Recyclable materials are part of the installation’s overall solid waste stream. Before a material can be recycled, it must be separated from solid waste slated for disposal (landfilled or incinerated). In some cases, recyclable materials are separated from solid waste by the generator before it is placed in a collection container. In other cases, recyclable materials are mixed with solid waste and separated “downstream” by contractors or installation personnel.

After recyclable materials are separated from the solid waste stream, they must be sorted into different recycle categories, such as paper, aluminum, and glass, etc. Some materials may need to be sorted even further, such as sorting glass into green, brown, and clear. Mixed recyclable materials are also referred to as “commingled.” Recycle material brokers/buyers may require commingled recyclable materials be sorted into relatively homogeneous commodities so materials may be processed more efficiently. Many brokers/buyers may accept a certain amount of contamination or commingling of recyclable material types.

The acts of separating and sorting recyclable materials can occur at many different points.

Separation can occur at the point of generation or later in the recycling process. Four of the main options for separation and handling of recyclable materials are described below:

Source separation

Commingled collection with curbside sorting

Commingled collection with material recovery facility (MRF) sorting

Downstream separation

Source Separation

Source separation means setting aside recyclable materials at their point of generation by the generator. Generation means the act or process of producing solid waste.

Source separation requires recyclables to be separated by type, within the workplace or by housing residents. For example, white paper would be collected separately from colored paper.

The “Pros” of source separation:

There is the potential for more markets based on clean, separated materials Possible higher market value for separated material than if it was all mixed together There may be the opportunity for creating more environmental awareness among personnel as a result of more education required for source separation efforts

The “Cons” of source separation The program may require more recycling bins (and a higher start-up cost) based on the number of separated recyclable materials This may potentially require more personnel time to recycle various separated materials The opportunities for contamination of separated materials may be higher

40 CFR 246.101(n) and (cc).

USAF QRP Guide September 2008 16

The recyclers may be more sensitive to contaminates due to improper sorting

Source separation is required for those materials listed in Figure 2.

Commingled collection is mixing a variety of recyclable materials together. For example, an office program might mix together all paper (computer, white, and colored). Once collected, commingled recyclables may be shipped to a processor as raw material for a new product or they may go to a processing facility (material recovery facility) for separation.

The “Pros” of commingled collection:

It may be easier than source separation and less time consuming for employees It can potentially divert more recyclables from the landfill Requires minimal public education and awareness

The “Cons” of commingled collection:

The market value of the recyclable material may be lower than that of source separated recyclables. For example, mixed office paper may be of lower value than white paper that is separated

The recyclables may become more easily contaminated due to the larger number of recyclable materials included in the mix

Installation priorities, market demand for recyclables and your recycling broker/buyer sorting requirements will determine the best type of collection method suitable for your installation.

Commingled Collection with Curbside Sorting

This type of recyclable material handling involves source separation of recyclable materials from non-hazardous solid waste and placement of all recycled materials into a single container.

Military family housing residents place all their recyclable materials into a single container and put the container at the curb for collection. The recycling contractor or collection personnel drive through military family housing areas in a collection truck and sort recyclable materials into individual containers onto the collection truck. This increases the recyclable materials value and reduces contamination.

Commingled Collection with Material Recovery Facilities (MRF) Sorting

This type of handling is also known as “single stream recycling,” because it involves recyclable materials collection into a single “stream.” Recyclable material commingled collection involves source separation of recyclable materials from non-hazardous solid waste and placement by the generator of all recycled materials into a single container. Container contents are collected by a recycling contractor or installation personnel and transported to a facility on-site or off-site for sorting. Sorting facilities are known as material recovery facilities (MRFs). At the MRF, recycled materials are sorted into different commodities types to increase their value. This type of collection is easier for generators, but may result in recyclable material quality degradation.

Operating a MRF on-base can substantially increase QRP costs, but using an off-base MRF may reduce recyclable material direct sales revenue. The next subsection on downstream separation discusses some of MRF operating costs. Check State or local regulations before establishing an on-base MRF as there may be compliance permitting requirements.

Downstream Separation

Downstream separation is distinguished from source separation in that recoverable materials enter the non-hazardous waste stream and are mixed with non-recoverable solid wastes.

Recyclable materials are removed from the solid waste stream at a location “downstream” from the point of generation. This location may be a solid waste transfer station, MRF, or it may be a facility operated by a recycling broker/buyer. Separation of recyclable materials from solid waste

USAF QRP Guide September 2008 17 at “downstream” sites generally requires personal protective equipment (PPE), a large investment in equipment, and a large, steady supply of recyclable materials to receive full economic benefit from equipment investment. This method will generally require use of specialized equipment not normally found in the military supply system. This mechanical equipment is utilized to separate recyclable materials from other post-consumer wastes. The simplest form is a conveyor belt operated by laborers who do the actual separation. Likewise, markets for the recovered materials must exist. Check State and local regulations as it may require a permit to operate a transfer station.

Decision Matrix

The QRP Manager will not make exclusive or final decisions on how to operate the QRP. The QRP Manager should prepare a summary of possible QRP options and present them to the QRP Subcommittee for review, revision or approval. The QRP Manager should prepare a decision matrix that provides a picture of the advantages and disadvantages of each option. Examples of advantages include:

Economic benefit

Increased diversion

Increased recycling

Decreased solid waste generation

Reduced administrative burden

Available manpower

Figure 3. Example of a Decision Matrix for Recycling Options13

Option

Economic

Benefit

Administrative

Burden

Diversion

Recycling

Solid Waste Generation

Complete outsourcing

No Increased Some improvement

Some improvement No effect

Partial outsourcing

Some Increased Some improvement

Some improvement No effect

Integrating recycling into solid waste contract

Yes Some increase Very little improvement

Very little improvement

No effect

Operate QRP in-house

No No increase Improvement Improvement Minor effect

Figure 3 provides an example decision matrix the QRP Manager can use to brief the QRP Subcommittee. The QRP Manager may choose to add or remove items from the example or use another format altogether. The important point is the QRP Manager should document options and provide an explanation of each option’s strengths and weaknesses. This information will be useful to the QRP Manager during the annual reviews to determine if the installation should make changes to the QRP.

13 The data provided in Figure 3 is not based on an actual QRP; it is shown only as an example.

Section 4 Roles and Responsibilities

USAF QRP Guide September 2008 18

Section 4. Roles and Responsibilities

QRP operation involves many people at an Air Force installation. This section describes primary participants in a successful QRP and their responsibilities. Key participants in the QRP include:

Installation Commander

QRP Subcommittee

Comptroller (FM)

Civil Engineering

QRP Manager

Recycling Center Manager

Building/Facility Managers

Unit Environmental Coordinators

Tenants

Contractors

DRMO

Installation Commander Role

The installation commander is ultimately responsible for the installation QRP and compliance with Federal, state and local laws and regulations by enacting management controls to ensure compliance. Delegation of QRP review and oversight may be given to the Vice Commander or the Environment, Safety, and Occupational Health Council (ESOHC).

Establish and operate an efficient and cost-effective QRP that meets legal and policy requirements

Review and sign the QRP Manager designation/appointment letter

Review recycling proceeds allocation as recommended by QRP Subcommittee

Maintenance of QRP transactions and cost records

Enact management controls to ensure recyclable materials direct sales are conducted in accordance with the law

Promote recycling and encourage participation through policy, memos, and presentations

Direct internal and external QRP audits from USAF Audit Agency

Request Staff Assistance Visits from MAJCOM and AFCEE

Investigate complaints and, if appropriate, alert investigative organization to pursue allegations of fraud or corruption

QRP Subcommittee to the ESOHC Role The QRP Subcommittee is chaired by the QRP Manager. Commanders appoint primary and alternate representatives from their respective organization. Air Force installations are required to have an Environment, Safety, and Occupational Health Council (ESOHC).

The QRP

Subcommittee may be a stand-alone committee, or the responsibilities for overseeing the QRP may be delegated to an existing committee, such as a Pollution Prevention or Solid Waste Subcommittee. Suggested QRP Subcommittee members include the following individuals and representatives from installation organizations:

14 Memorandum on Qualified Recycling Program Guidance, John P. Woodley, Jr., Assistant Deputy Under Secretary of Defense (Environment), 24 April 2003 and USAF Policy Letter Air Force Solid Waste Diversion and Qualified Recycling Program Policy, L. Dean Fox, MG, USAF, The Civil Engineer, DCS/Logistic, Installation & Mission Support, 11 April

Memorandum on Qualified Recycling Program Guidance, John P. Woodley, Jr., Assistant Deputy Under Secretary of Defense (Environment), 24 April 2003

AFI 90-801 requires Air Force installations to have an ESOHC.

17 This is only a suggested list. Not all installations have these organizations or the organizations may have different names.

USAF QRP Guide September 2008 19

QRP Manager

Installation Vice Commander

AAFES

Aircraft Maintenance

Bioenvironmental Engineering

Civil Engineering

Commissary

Contracting

DRMO

Environmental Management

Military Family Housing

Unaccompanied Airman Housing

Logistics

Major Tenants

Public Affairs

Safety

Services

Staff Judge Advocate

The QRP Subcommittee has the following responsibilities:

Provides strategic focus, organizational design, oversight of performance measurements and development toward continuous organizational improvement

Enact program decisions can include changes in diversion practices, facility improvements, equipment purchases, and disbursement of recyclable material sale proceeds

Review and approve projects funded from recyclable sales proceeds

Establish QRP goals and objectives

Prepare QRP fiscal year budget and secure ESOHC approval

Obtain ESOHC approval for expenditures outside the QRP Fiscal Year Budget

Review QRP Business Plan annually and secure ESOHC approval

Brief Installation Commander and ESOHC on QRP status

Review QRP audit reports

Comptroller (FM) Role Provide financial assistance to the QRP Manager and CE Resources Flight

Receive QRP direct sales payments from QRP Manager or CE Resources Flight

Transfer QRP direct sales payments to F3875 Budget Clearing Account (Suspense) utilizing DD Form 1131, Cash Collection Voucher

Provide copies of all completed DD Form 1131 to the QRP Manager within five working days

Upon request from QRP Manager, provide F3857 Budget Clearing Account (Suspense) summary

Transfer QRP proceeds to designated appropriation or Government Purchasing Card (GPC)

Retain copy of approved QRP Fiscal Year Budget

Civil Engineering Squadron (CES) Role There are numerous CE flights involved with the QRP. These flights and responsibilities include:

Asset Management (CEA) Advises/assist CEO

Technical and regulatory oversight

Metric analysis

USAF QRP Guide September 2008 20

Metric reporting in accordance with data call requirements

Public education and awareness

Member, QRP Subcommittee to the ESOHC

Housing Program Management (CEAC) Provides education and awareness information to non-privatized MFH occupants

Ensure MFH occupants leave recycling containers in their unit upon PCS

Ensure funds are available for recycling collection

Unaccompanied Housing (UH) (CEAC) Provides education and awareness information to all dormitory residents

Monitor recycling containers and request off-cycle service as required

Operations (CEO) Manage/oversight of contract and in-house solid waste and recycling operations

Conduct commodity market price research

Aid shop-level personnel with diversion procedures

Compile metrics in accordance with DOD Non-Hazardous Solid Waste Measure of Merit Data Calls

Provide monthly solid waste diversion metrics to CEA

Resources (CER) Assist QRP Manager with QRP sales proceeds management

Transfer payment checks to FM

QRP Manager Role

The installation commander designates the QRP Manager, who can be any appropriated funded or non-appropriated funded civilian federal employee, military personnel or contractor who understands integrated solid waste management. This position is not mandated to be an environmental position. A QRP Manager must be a leader with accountability and authority for the QRP. The QRP Manager will oversee the entire QRP operation; be responsible for the budget, account for all costs incurred and revenues received, and manage equipment and employees.

Ideally, this program manager is an advocate who will follow the QRP’s development from start-up to successful operation. The QRP Manager’s responsibilities include:

Create and maintain the QRP Business Plan

Chairperson, ESOHC QRP Subcommittee

Provide QRP Subcommittee updates to the ESOHC

Screen recyclable materials to ensure excluded materials are not sold through the QRP

Conduct Commodity Market Feasibility Study

Conduct an economic analysis for each recyclable commodity generated

Conduct Outsourcing Alternatives Cost-Benefit Study

Prepare a recycling options decision matrix

Prepare QRP Fiscal Year Budget prior to the beginning of each fiscal year and submit to the QRP Subcommittee and ESOHC for approval

Submit approved QRP Fiscal Year Budget to Resources flight and Comptroller

Monitor and reconcile DRMO turn-ins ensuring recycling revenue is maximized

Establish a F3875 Budget Clearing Account (Suspense) with assistance from Resource flight and Comptroller

USAF QRP Guide September 2008 21

Designate a trained individual as the QRP Sales Agent to conduct local sales and award contracts for sales less than $15,000

Monitor/track recyclable sales proceeds due from buyers/vendors to ensure timely reimbursement to the Government

Receive direct sale payment checks

Record direct sales amount along with buyer/vendor name and other pertinent information

Transfer direct sales payments in a timely manner to Resource Flight or Comptroller. Retain copies of payment checks and pertinent documentation. This may require DD Form 1131, Cash Collection Voucher.

Quarterly reconcile the F3875 Budget Clearing Account (Suspense) with DD Form 1131 and payment check log. Obtain F3875 Summary from Resources flight or Comptroller.

Ensure designated contracting sales officer signs all documents requiring signature for the Federal Government

Ensure recycling proceeds are utilized properly

Track actual diversion costs versus potential disposal costs for all commodities diverted

Maintain well organized, detailed written/electronic records from direct sales, training, audits, meeting minutes, end use certification

Maintain necessary licenses and training to operate Recycling Center equipment/vehicles

Aid shop-level personnel with diversion procedures

Request AF Audit Agency audits and MAJCOM and AFCEE staff assistance visits

Investigate complaints and report to the commander or designated representative

Publicize the diversion program by conducting education and awareness outreach for base personnel, military family housing residents (non-privatized), and unaccompanied airman dormitory residents

Track and maintain records of diverted materials’ weights from all installation generators

Track actual diversion costs v. potential disposal costs for all materials diverted

Report DoD Non-Hazardous Solid Waste Measure of Merit data to designated installation Integrated Solid Waste Management Program (ISWMP) Manager for submission to the

MAJCOM

Conduct metric analysis

Recycling Center Manager Role The Recycling Center Manager reports directly to the QRP manager. Responsibilities include:

Supervise all on-base recycling center activities

Act as the commodity sales agent by conducting commodity sales < $15,000

Advise/assist QRP Manager

Maintain necessary licenses and training to operate Recycling Center equipment/vehicles

Establish collection schedules

Maintain recyclable direct sales records

Coordinate with Building/Facility Managers to identify unit recycling requirements and appropriate collection containers

Provide a 24-hour drop-off site for recyclables

Operate recycling center equipment, such as forklifts, vehicles, and processing machinery

Sort and prepare recyclables for processing, storage and/or transport

Perform operator maintenance and inspections on all forklifts, vehicles and processing machinery

Assist and guide base personnel with recyclables

18 The DD Form 1131can be found at http://www.dtic.mil/whs/directives/infomgt/forms/eforms/dd1131.pdf

The regulation governing the disposition of funds from the sale of recyclable materials may be found at 10 U.S.C. 2577.

The regulations that govern the use of particular accounts for managing the proceeds from sale of recyclables may be found at 32 CFR 172.

USAF QRP Guide September 2008 22

Investigate complaints and report to the commander or designated representative

Building/Facility Managers Role Building/Facility Managers are an extension of the QRP Manager, as they have direct contact with individuals in their building/facility. Their responsibilities include:

Implement the QRP within their building/facility by establishing recycling collections points throughout the building/facility

Perform training and briefing session for building/facility staff

Assist building/facility staff with proper reuse and diversion procedures

Monitor recycling containers

Perform periodic walk-through compliance inspections within the building/facility

Transportation of recyclables to a central collection area

Unit Environmental Coordinators Role Unit Environmental Coordinators, like the building/facility managers, are an extension of the QRP Manager. Their responsibilities include:

Serve as the recycling point of contact for their unit

Assist unit personnel with proper reuse and diversion procedures

Monitor recycling containers

Perform periodic walk-through compliance inspections within the building/facility

Attend QRP Subcommittee meetings

Figure 4. Handling of Proceeds and Data for QRP Participants

Participant Disposition of Proceeds20

Weight Data Goes to QRP?

Appropriated funds activities QRP Yes

Non-appropriated funds (NAF) activities May retain

Yes

AAFES May retain

Yes

DeCA (commissary) May retain

Yes

Other Tenants QRP Yes

Contractors

QRP Yes

Tenants Role

DoD and AF policy dictates that installation recycling programs serve all host and tenant organizations occupying space on the installation, including leased space.

Figure 4 lists proceeds handling and diversion data by various participants in the installation QRP. Non-appropriated funds activities, AAFES activities, and DeCA (commissaries) are permitted to sell their recyclables outside the QRP and retain proceeds. These organizations may choose to participate in the installation QRP. If these organizations choose to have the QRP manage

20 Participants that are listed as “retain” have the right to retain the proceeds from sale of recyclable materials. These participants may elect to contribute proceeds to the QRP.

Memorandum of agreement between participant and installation can specify that the QRP will manage participant’s recyclables with allocation of some proceeds to QRP to cover costs.

Getting contractors to contribute data or the proceeds from sale of recyclable materials may require modification of existing or new contracts

DoD Instruction 4715.4, Section 6.2.3.3.1 and AFI 32-7080, Section 3.4.1

USAF QRP Guide September 2008 23 recyclable materials handling and disposition, the QRP may recover recycling costs from proceeds derived from those participants. Establishing a memorandum of agreement (MOA), host-tenant and/or inter-service support agreements between the QRP and these organizations will clearly define partnership roles and responsibilities. Regardless, all installation organizations must provide data on diversion and solid waste generation to the QRP Manager. This requirement allows the QRP Manager to calculate performance on the Office of the Under Secretary of Defense Revised Pollution Prevention and Compliance Metrics (12 October 2004) for all installation activities. This requirement should be included in any MOA, host-tenant and inter-service support agreements.

Contractors Role

Air Force installations use contractors for a wide variety of services. Services provided by contractors include:

Aircraft maintenance

Janitorial services

Solid waste disposal and diversion services

Construction and demolition services

Facilities maintenance

Vehicle maintenance

Recreational facilities operation

Contractors tasks are established in written contracts and certain contracts may require special clauses or specific requirements outlined in the Statement of Work.

To require contractors to participate in a QRP, the installation contracting office must include specific clauses in those contracts. Contracting officers should modify existing contracts to require QRP participation and solid waste management data reporting. Contractor responsibilities in the QRP include:

Report quarterly solid waste and diversion data to the QRP Manager

Recycle materials as required by federal regulations

Provide appropriate solid waste diversion training to contractor employees

Consider reuse, source reduction and diversion in work plans

DRMO Role

QRP-ineligible recyclable materials should be managed by the Defense Reutilization and Marketing Office (DRMO) who manages excess property disposition from Defense agencies.

DRMO achieves this through reutilization, transfer, donation, and sale of excess property.

QRP-eligible material recycled by DRMO should be reimbursed into the F3875 Budget Clearing Account (Suspense). A reimbursement statement in Block #27 of Disposal Turn-in Document (DTID), DD Form 1348-1A Issue Release/Receipt Document should contain:

Applicable F3875 account number Applicable DODAAC QRP Point of Contact name, email and telephone number

Incomplete information on DD Form 1348-1A, DRMO will result in QRP-eligible materials sales deposited into the U.S. Treasury. Arrangements should be made with the servicing DRMO to

24 FAR 23.704 and 23.705 require that contracts for contractor operation of a Government-owned or leased facility and contracts for support services at such facilities, include provisions for…