J-0200000-12_SPCC.pdf

Pollution Prevention Plan

Prepared for

Naval Support Activity Orlando

November 2015

Prepared by

Building 903 Yorktown Avenue

Jacksonville, Florida 32212

AND

3E Consultants, Inc.

402 Carl Street, Suite 102

Wilmington, NC 28403

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Naval Support Activity Orlando, FL

I

Document History Log

This Pollution Prevention Plan will be revised as necessary to reflect changes in operations at the Naval Support Activity Orlando and to remain current with all applicable federal, state, and local regulations. This sheet is updated with each revision of this document.

Revision Number

Section and Pages Affected Reason for Revising

Person Revising

Revision Date

II

November 2015 Table of Contents

III

Table of Contents

NSA Orlando Pollution Prevention Policy Statement .................. ES-1

Executive Summary ....................................................................... ES-3

1.0 Background and NSA Orlando Mission .................................. 1-1

2.0 Purpose and Scope .................................................................. 2-1

2.1 Purpose ........................................................................................................ 2-1

2.2 Scope ........................................................................................................... 2-1

2.3 P2 Plan Structure ......................................................................................... 2-2

3.0 Regulations and Requirements ............................................... 3-1

3.1 P2 Regulations and Drivers .......................................................................... 3-1

4.0 Responsibilities ........................................................................ 4-1

5.0 Pollution Prevention Baseline Information and Current

Activities ............................................................................................ 5-1

5.1 P2 MoMs ...................................................................................................... 5-1

5.2 Toxic Chemicals and Hazardous Materials at NSA Orlando ........................ 5-3

5.3 Hazardous and Universal Waste .................................................................. 5-5

5.4 Solid Waste .................................................................................................. 5-6

5.5 Fleet Vehicles Composition .......................................................................... 5-9

5.6 Greenhouse Gas Emissions ....................................................................... 5-10

5.7 Water Consumption and Wastewater Generation ...................................... 5-12

5.8 Energy Conservation .................................................................................. 5-14

6.0 P2 Opportunities to Meet EO Goals ........................................ 6-1

6.1 P2O 1 – Re-evaluate landscape and irrigation plans and make corrective actions. ................................................................................................................... 6-2

6.2 P2O 2 – Implement a qualified recycling program (QRP) at NSA Orlando in order to receive revenue for recyclable commodities. ........................................... 6-11

6.3 P2O 3 – Implement solar-powered street lights. ........................................ 6-15

6.4 P2O 4 – Improve solid waste record keeping ............................................. 6-18

6.5 P2O 5 – Implement a P2 training and outreach program. .......................... 6-19

IV

7.0 P2 Promotion ............................................................................ 7-1

7.1 P2 Accomplishments .................................................................................... 7-1

8.0 Implementation ......................................................................... 8-1

9.0 Training and Education ........................................................... 9-1

10.0 References .............................................................................. 10-1

V

Tables

TABLE ES-1 Summary of P2Os for NSA Orlando .............................................. ES-iii

TABLE 3-1 P2 Related Federal Regulations .......................................................... 3-1

TABLE 3-2 P2 Related EOs ................................................................................... 3-4

TABLE 3-3 P2 Related DoD and DON Regulations ............................................... 3-6

TABLE 4-1 P2 Roles and Responsibilities ............................................................. 4-1

TABLE 5-1 P2 MoMs Reporting Requirements ..................................................... 5-1

TABLE 5-2 NSA Orlando Tier 2 Reporting, CY2010 through CY2014 .................... 5-3

TABLE 5-3A NSA Orlando HW Generation, CY2011 through CY2014 ................. 5-5

TABLE 5-3B NSA Orlando UW Generation, CY2011 through CY2014 ................. 5-6

TABLE 5-4A NSA Orlando SW Generation and Diversion Rate, CY2014

(Baseline) ................................................................................................................ 5-7

TABLE 5-4B NSA Orlando, Recycled Materials, CY2011 through CY2014 ........... 5-9

TABLE 5-5 NSA Orlando Vehicle Summary, CY2014 (Baseline) ........................ 5-10

TABLE 5-6 NSA Orlando Fuel Usage, CY2014 (Baseline) .................................. 5-12

TABLE 5-7 NSA Orlando Water Consumption and Cost, CY2007 through CY2014

…………………………………………………………………………………………….5-13

TABLE 5-8 NSA Orlando Energy Consumption and Cost, FY2003 through

FY2014 ................................................................................................................. 5-15

TABLE 6-1 Summary of the P2 Opportunities for NSA Orlando ............................. 6-1

TABLE 6-2 P2O 1 – Re-evaluate landscape and irrigation plans and make corrective actions ................................................................................................... 6-1

TABLE 6-3 P2O 2 - Implement a qualified recycling program (QRP) at NSA Orlando in order to receive revenue for recyclable commodities ........................................ 6-12

TABLE 6-4 P2O 3 - Implement solar-powered street lights ................................... 6-1

TABLE 6-5 P2O 4 - Improve solid waste record keeping ....................................... 6-1

TABLE 6-6 P2O 5 - Implement a P2 training and outreach program ..................... 6-1

TABLE 7-1 NSA Orlando P2 Accomplishments ...................................................... 7-1

VI

Figures

1 Site Location Map 2 Site Layout

November 2015 Acronyms and Abbreviations

VII

Acronyms and Abbreviations

AFV Alternative Fuel Vehicles AUL Authorized User List

BOSC Base Operation and Support Contractor

C&D Construction and Demolition CAA Clean Air Act CESQG Conditionally Exempt Small Quantity Generator CFR Code of Federal Regulations CNRSE Commander of the Navy Region Southeast CO Commanding Officer CPG Comprehensive Procurement Guideline CWA Clean Water Act CY Calendar Year

DLA Defense Logistics Agency DoD Department of Defense DOE Department of Energy DON Department of Navy

EEA External Environmental Assessment EHS Extremely Hazardous Substances EISA Energy Independence and Security Act EMS Environmental Management System EO Executive Order EPAct Energy Policy Act EPCRA Emergency Planning and Community Right-to-Know Act

FAC Florida Administrative Code FDEP Florida Department of Environmental Protection FEMP Federal Energy Management Program FWPCA Federal Water Pollution Control Act FY Fiscal Year

GSA General Services Administration

HM Hazardous Material HSWA Hazardous and Solid Waste Amendments HVAC Heating, Ventilation, and Air Conditioning HW Hazardous Waste

Kg Kilogram KSF Thousand Square Feet kW Kilowatt lbs Pounds LEPC Local Emergency Planning Committees

November 2015 Acronyms and Abbreviations

VIII

Acronyms and Abbreviations (Continued)

MMBTU Million British Thermal Units MoM Measures of Merit MSDS Material Safety Data Sheet MSW Municipal Solid Waste

N/A Not Applicable NA Not Available NAAQS Naval Ambient Air Quality Standards NAVFAC SE Naval Facilities Engineering Command Southeast NAWCTSD Naval Air Warfare Center Training Systems Division NFESC Naval Facilities Engineering Service Center NPDES National Pollutant Discharge Elimination System NSA Naval Support Activity

ODS Ozone Depleting Substance OPNAV Office of the Chief of Naval Operations OSHA Occupational Health & Safety Administration

P2 Pollution Prevention P2ADS Pollution Prevention Annual Data Summary P2O Pollution Prevention Opportunities POA&M Plans of Action and Milestones PPA Pollution Prevention Act PPIC P2 Information Clearinghouse PPIS P2 Incentives for States

QRP Qualified Recycling Program

RCRA Resource Conservation and Recovery Act RMAN Recovered Material Advisory Notices

SARA Superfund Amendments and Reauthorization Act SECNAV Secretary of the Navy SERC State Emergency Response Commissions SSPP Strategic Sustainability Performance Plan (DoD) SW Solid Waste

TRI Toxic Release Inventory

UCF University of Central Florida UG User’s Guide U.S. EPA United States Environmental Protection Agency UW Universal Waste

November 2015 Executive Summary

ES-1

Naval Support Activity Orlando’s Pollution Prevention Policy Statement

Naval Support Activity Orlando is an advocate of Pollution Prevention objectives and a clean, safe environment. As such, it has developed its own Pollution Prevention Management Plan and supports its full implementation. The Installation’s Pollution Prevention Program is dynamic; changing as new regulations, new work process improvements, new material substitutions, and better waste management procedures are developed.

November 2015 Executive Summary

ES-2

November 2015 Executive Summary

ES-3

Executive Summary

Title 40 of the Code of Federal Regulations (CFR) and the Pollution Prevention Act of 1990 direct each Department of Defense (DoD) installation to develop a Pollution Prevention (P2) Plan. The P2 Plan is a tool that summarizes the current state of P2 activities and the mandated P2 goals for the installation, and identifies areas of potential P2 opportunities (P2Os) for all commands, units, tenants, and contractor organizations on the installation. This P2 Plan for Naval Support Activity (NSA) Orlando was prepared in accordance with Title 40 of the CFR; state environmental regulations as established in the Florida Administrative Code (FAC); Naval Facilities Engineering Service Center (NFESC) User’s Guide (UG) 2046-ENV, DoD Instruction 4715.4, and Office of the Chief of Naval Operations (OPNAV) Instruction 5090.1D.

This P2 Plan illustrates the measures that NSA Orlando has taken to achieve its mandated P2 goals. In addition to the projects listed in Table ES-1, the P2 Plan also identifies and describes the implementation of P2 actions required by the Resource Conservation and Recovery Act (RCRA); DoD Strategic Sustainability Performance Plan (SSPP); Executive Order (EO) 13693, “Planning for Federal Sustainability in the Next Decade”; as well as DoD and Department of Navy (DON) requirements. OPNAV Instruction 5090.1D was revised in January 2014 and requires the P2 Plan and program to be incorporated under the environmental management system (EMS) in Chapter 17. Due to the small size of the installation, NSA Orlando does not have an EMS. Although this P2 Plan and program does not function as an aspect of an EMS, it is still implemented at NSA Orlando in accordance with the objectives, targets, and goals of OPNAV Instruction 5090.1D.

This P2 Plan focuses on P2 of hazardous materials (HM), hazardous waste (HW), universal waste (UW), non-hazardous solid waste (SW), recycling, and use of petroleum-based fuels at the installation. Other P2 topics included in EO 13693, such as energy and water conservation, and electronic equipment procurement are addressed in more detail in the “Shore Installation Energy and Water Management Annual Report” for the facility. Potential P2Os were also identified based on installation visits and interviews with key personnel. Table ES-1 summarizes the identified P2Os for NSA Orlando.

TABLE ES-1 Summary of P2Os for NSA Orlando

P2O

1st Year Capital Cost

Annual Savings Benefits

1 – Re-evaluate landscape and irrigation plans and make corrective actions

$77,724 $0 The result of the project may lead to small reductions in overall maintenance labor resulting from reduced leaks and healthier plants. The project may provide 5% to

70% reduction in irrigation water used, which may be needed to meet EO

13693(3)(f)(3) reduction requirements.

November 2015 Executive Summary

ES-4

P2O

1st Year Capital Cost

Annual Savings Benefits

2 – Implement a qualified recycling program (QRP)

$0 $3,292 Implementation of QRP at NSA Orlando may provide immediate benefits. It requires minimal manpower to initiate and immediately allows revenues from recyclables to be attributed back to environmental programs at NSA Orlando.

3 – Implement solar-powered street lights

$279,199 $18,000 Reduction in annual consumption of electricity; could also have the ancillary effect of saving money on electrical repairs and improving continuity of operations and minimizing downtime resulting from the periodic lightning strikes

4 – Improve solid waste record keeping

$1,600 $0 The minimal expense to purchase scales will allow NSA Orlando to better track solid waste diversion and disposal records and may assist the facility to come into compliance with SW diversion goals.

5 – Implement a P2 training and outreach program

$300 $29 Assumed the training and outreach would increase recycling rates at NSA Orlando by

10%. This would lead to an increase in revenue from recycled commodities by

10% as identified in P2O 2.

This P2 Plan is maintained in the office of the Environmental Coordinator/P2 Program Manager/Hazardous Materials Manager and conveyed to NSA Orlando personnel through P2 training. Installation commands, units, tenants, and contractor organizations will comply with this P2 Plan, which has been developed to provide all appropriate personnel with procedures and responsibilities for proper management of HW, HM, and SW. The P2 Plan is maintained to reflect current personnel responsibilities and current regulatory requirements and goals. This P2 Plan is revised as necessary to reflect changes in operations at NSA Orlando and to remain current with all applicable federal, state, and local regulations.

This P2 Plan serves as a tool for the NSA Orlando Environmental Coordinator/P2 Program Manager/Hazardous Materials Manager to use when establishing and maintaining P2 policy and programs at the installation. In addition, the success of this P2 Plan, and the continued compliance with all regulations and requirements, depends on all staff and personnel at NSA Orlando adhering to the guidance and recommendations provided herein.

November 2015 Background and NSA Orlando Mission

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1.0 Background and NSA Orlando Mission

Naval Support Activity (NSA) Orlando opened in 1988 as the home of the Naval Air Warfare Center Training Systems Division (NAWCTSD) Orlando. NAWCTSD Orlando is the Navy’s principal center for modeling, simulation, and training systems technologies. The Center provides training systems development for a wide spectrum of military programs, including aircraft, surface ships, submarines, and other specialized requirements. A site location map is included as Figure 1 and a site layout is included as Figure 2.

NSA Orlando provides support to all Department of Defense (DoD) activities in Central Florida, most of which support military training and simulation missions. It has added the United States (U.S.) Army’s Program Executive Office for Simulation, Training, and Instrumentation, the Army’s equivalent to NAWCTSD Orlando, as a major tenant unit.

Major organizations supported and adjacent to NSA Orlando include the U.S. Marine Corps’ Program Manager for Training Systems; the U.S. Army Research, Development and Engineering Command’s SFC Paul Ray Smith Simulation & Training Technology Center; the Orlando office of the U.S. Air Force Agency for Modeling and Simulation; the U.S. Navy Human Performance Center Orlando; the U.S. Joint Forces Command’s Joint Development Integration Facility and Joint Training Integration and Evaluation Center; and the Joint Advanced Distributed Learning Co-Laboratory.

NSA Orlando’s mission is to provide consistent, effective and efficient shore installation support services to tenant DoD agencies, enabling their mission accomplishment in a joint services environment. (NSA Orlando, 2015)

November 2015 Background and NSA Orlando Mission

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November 2015 Purpose and Scope

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2.0 Purpose and Scope

2.1 Purpose

The Pollution Prevention Act (PPA) of 1990 (42 U.S.C. 13101 et seq.) establishes the national policy that "pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner."

The Navy’s Environmental Quality Initiative is a comprehensive initiative focused on maximizing the use of pollution prevention (P2) to achieve and maintain compliance with environmental regulations. NSA Orlando is committed to environmental leadership and preventing pollution by reducing usage of hazardous materials and releases of pollutants into the environment to as near zero as feasible. The P2 concept is designed to prevent pollution by reducing or eliminating harmful discharges to the air, land, and water at the source. By maximizing the use of P2 methods to achieve environmental excellence, NSA Orlando will maintain operational readiness and regulatory compliance at the lowest life-cycle cost.

The purpose of this P2 Plan includes the following:

Present applicable federal and state P2 regulatory requirements;

Identify the procedures that are used to comply with the requirements of all applicable Executive Orders (EOs); DoD Measures of Merit (MoM); DON instructions; and federal, state, and local laws and regulations pertaining to hazardous and non-hazardous waste;

Establish baseline years for various MoMs based on available historical records and documents; and

Identify future pollution prevention opportunities that will drive NSA Orlando toward achieving the goals set forth by applicable EOs, directives, and regulations.

The overarching purpose of this initial P2 Plan is to establish baseline years to develop and implement effective P2 technologies and practices at NSA Orlando.

2.2 Scope

This P2 Plan identifies objectives, goals, targets, and overall strategy for the NSA Orlando P2 Program. It provides a framework for managing the various elements of the P2 program including coordination of activities among multiple groups, centralized tracking and measurement of program performance, and providing the link to other compliance programs.

The P2 Plan is a vital tool utilized to:

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Maintain NSA Orlando’s compliance position with respect to federal, state, and local environmental laws;

Track EO 13693, EO 13514, DoD MoM, Navy, federal, state, and local P2 policy goals and attainment;

Track and characterize installation multi-media waste streams to include hazardous material (HM), hazardous waste (HW), universal waste (UW), non-hazardous solid waste (SW), recycling and SW diversion rates, and the use of non-petroleum-based fuels. NSA Orlando has addressed the current state of its water and energy consumption separately in their “Shore Installation Energy and Water Management Annual Report” and therefore, is not included in this report;

Actively participate in, and contribute to, the identification, implementation, and evaluation of P2 opportunities (P2Os) to reduce and conserve raw material use and waste generation;

Promote P2 as an integral part of the mission;

Implement P2 practices (e.g., contract language, equipment, material, tools, and models) in all installation contracting programs; and

Implement training to NSA Orlando personnel in environmental and pollution prevention awareness.

2.3 P2 Plan Structure

The goals, initiatives, and recommendations detailed in this plan are not strictly for the implementation of the NSA Orlando Environmental Program Manager but are a responsibility of the installation as a whole. Their implementation must involve all operating organizations at NSA Orlando to maximize available resources and achieve success in meeting the stated P2 goals. The NSA Orlando P2 Plan has been organized in ten (10) sections as follows:

Section 1.0 Background and NSA Orlando Mission provides the background and mission of NSA Orlando.

Section 2.0 Purpose and Scope provides the purpose and scope for the NSA Orlando P2 Plan and the report structure.

Section 3.0 Regulations and Requirements identifies and describes the Federal and State regulations, Presidential EOs, DoD Directives, and Navy Instructions and Policy associated with pollution prevention compliance.

Section 4.0 Responsibilities identities the NSA Orlando personnel responsible for P2 initiatives and implementation.

Section 5.0 Pollution Prevention Baseline Information and Current Activities identifies baseline and annual usage/waste generation for HM, HW, SW, UW, alternative fuel vehicles (AFVs) and vehicle fuel consumption, greenhouse gas emissions, water consumption, wastewater generation, and energy conservation, providing a summary of current progress toward P2 goals.

2-3

Section 6.0 P2 Opportunities to Meet EO Goals identifies P2Os for meeting mandated goals including a cost benefit analysis for each opportunity.

Section 7.0 P2 Promotion discusses P2 accomplishments achieved at NSA Orlando.

Section 8.0 Implementation discusses NSA Orlando’s Environmental Policy for continual implementation of P2 initiatives to achieve environmental excellence.

Section 9.0 Training and Education discusses the general awareness and P2 related training programs implemented at NSA Orlando.

Section 10.0 References presents the documents referenced throughout this report.

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November 2015 Regulations and Requirements

3-1

3.0 Regulations and Requirements

3.1 P2 Regulations and Drivers

Table 3-1 provides a summary of applicable federal regulations related to P2.

TABLE 3-1 P2 Related Federal Regulations Citation Regulation

Name Description and Installation Requirements NSA Orlando

Compliance Status

40 Code of Federal Regulations

(CFR) 260-

Resource Conservation and Recovery Act (RCRA)

In 1976, the U.S. Congress passed RCRA. The primary goals of RCRA are to:

Protect human health and the environment from the potential hazards of waste disposal.

Conserve energy and natural resources.

Reduce the amount of waste generated.

Ensure that wastes are managed in an environmentally sound manner.

RCRA and its amendments, the Hazardous and Solid Waste Amendments (HSWA), provide standards for managing HW in order to minimize risk to human health and the environment.

Requirements: Installation is required to develop programs to reduce volume, quantity, and toxicity of their waste. It also requires the installation to establish affirmative procurement programs.

Compliant. NSA Orlando manages waste in accordance with their conditionally exempt small quantity generator (CESQG) status and the applicable

RCRA

requirements.

40 CFR

350-372

Emergency Planning and Community Right-to-Know Act (EPCRA)

EPCRA, also known as Superfund Amendments and Reauthorization Act (SARA) Title III, was implemented in 1986 to help communities understand the chemical hazards in their areas.

Requirements: Installation must notify local emergency planning committees (LEPCs), state emergency response commissions (SERCs), and the local fire department of extremely hazardous substances (EHSs) onsite. Any releases of an EHS must also be reported to the LEPC and SERC;

Installation must notify the public regarding the quantities of toxic substances used, processed, released, and disposed of via annual Toxic Release Inventory (TRI) Form R reporting. Form R reports must be submitted to the U.S. Environmental Protection Agency (U.S. EPA) and the state environmental agency; the reports are then made available to the public.

Compliant. Annual summaries (Tier 2) of Emergency and Hazardous Chemical Inventories and updated EPCRA Section 311 List provided to the LEPC, SERC, and local fire department. TRI thresholds evaluated annually;

however, no thresholds exceeded requiring reporting on a Form R.

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Citation Regulation Name

Description and Installation Requirements NSA Orlando Compliance Status

40 CFR

100-149

Clean Water Act

(CWA)

This act amended the Federal Water Pollution Control Act (FWPCA) and requires federal agency consistency with state nonpoint source pollution abatement plans. The act was amended in 1987 to strengthen enforcement mechanisms and to regulate stormwater runoff. The CWA requires states to establish best management practices for reducing nonpoint source pollution.

Requirements: A National Pollutant Discharge Elimination System (NPDES) permit and Stormwater Pollution Prevention Plan is not required for this Installation.

Not Applicable (N/A)

42 U.S.C.

13101 to 13106

Pollution Prevention Act

The PPA of 1990 established a national policy on P2.

Major provisions of the PPA include:

Providing matching funds for state and local P2 programs through the P2 Incentives for States (PPIS) grant program to support business with P2 programs.

Establishing a P2 strategy outlining the U.S.

EPA’s intent to promote source reduction and collect data on source reduction and recycling.

Operating a source reduction clearinghouse.

U.S. EPA’s P2 Information Clearinghouse (PPIC) provides telephone reference and referrals and distributes P2 documents. Information can be obtained from the PPIC via the PPIC Web site (http://www.epa.gov/oppt/ppic/) or via phone at

(202) 566-0799.

Requirements: Facilities are required to file an annual toxic chemical release form that includes a toxic chemical source reduction and recycling report.

Compliant. NSA Orlando evaluates all regulated substances maintained onsite annually. If threshold is exceeded, NSA Orlando will submit annual TRI Form Rs to the U.S. EPA and

SERC.

40 CFR 50-

Clean Air Act

(CAA)

This act requires the setting of National Ambient Air Quality Standards (NAAQS) and the development of federal and state programs to achieve these standards through the control of air pollution sources.

The 1990 amendments stress pollution control and prevention, such as the use of clean fuels and AFVs.

Requirements: NSA Orlando is exempt from air permit requirements.

Compliant. Due to the limited activities at NSA Orlando, no air permit is required; however, NSA Orlando complies with the use of AFVs as discussed in Section 5.5 of this P2 Plan.

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Description and Installation Requirements NSA Orlando Compliance Status

40 CFR

Comprehensive Procurement Guideline for Products Containing Recovered Materials

The U.S. EPA designates recycled content items in the Comprehensive Procurement Guideline (CPG), hence they are known as U.S. EPA “Guideline Items.”

These guidelines are published in 40 CFR 247. The U.S. EPA also prepares Recovered Material Advisory Notices (RMANs). These companion documents to the CPG contain recommended minimum recovered material content standards for designated items, in addition to recommendations for specifications and purchase mechanisms. In the CPG, U.S. EPA recommends both postconsumer recovered material content and total recovered material content levels.

Standards for both of these content levels are recommended because U.S. EPA has found manufacturers using both types of materials to manufacture their products. These material types are defined as follows:

Recovered materials refers to waste materials and by-products that have been recovered or diverted from SW, but does not include those materials and by-products generated from, and commonly used within, an original manufacturing process.

Postconsumer materials refers to a material or finished product that has served its intended end use and has been diverted or recovered from the waste destined for disposal, thereby completing its life as a consumer item. Postconsumer material is part of the broader category of recovered materials.

The RMAN levels are expressed as percentages of postconsumer content and/or total recovered content.

However, the RMANs apply to specific compositions of the CPG items, and may vary for CPG items made of different materials.

To date, the CPG has established the mandatory procurement of 54 items in eight product categories.

The product categories include:

Construction Products

Landscaping Products

Non-paper Office Products

Paper Products

Park and Recreation Products

Transportation Products

Vehicular Products

Miscellaneous Products

Requirements: The CPG implements section 6002 of RCRA, which requires the U.S. EPA to designate items that are or can be produced with recovered materials and to recommend practices for the procurement of designated items by procuring agencies. Once the U.S. EPA designates an item, RCRA requires any procuring agency using appropriated federal funds to procure that item to purchase it with the highest percentage of recovered materials practicable.

Compliant. All contracts through the Naval Facilities Engineering Command Southeast

(NAVFAC SE)

require the use of bio-based, Energy Star, and Federal Energy Management Program (FEMP)-certified materials when feasible.

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Description and Installation Requirements NSA Orlando Compliance Status

Public Law 110-140

Energy Policy Act of 2007

Energy Independence and Security Act (EISA) establishes a framework for installation project management and benchmarking. Under this new requirement, agencies must identify all "covered facilities" that constitute at least 75% of the agency's facility energy use. A covered facility may be defined as "a group of facilities at a single location or multiple locations managed as an integrated operation."

Requirements: An energy manager must be designated for the installation. NSA Orlando’s implementation of these requirements is discussed in the NSA Orlando’s “Shore Installation Energy and Water Management Annual Report”.

Compliant.

Discussed separately in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

Table 3-2 outlines the presidential EOs issued that address P2. These EOs include goals and guidance for implementing P2 metrics at federal agencies. Several amendments have been issued for some of the EOs below; however, the amendments did not revise the mandated goals and content of the requirements as discussed below and are therefore not referenced in Table 3-2 for brevity.

TABLE 3-2 P2 Related EOs

EO

Number EO Title

EO Description and Requirements as included in Table 2-1

NSA ORLANDO

Compliance

Status

13693 Planning for Federal Sustainability in the Next Decade

Supersedes EO 13514 and 13423 and establishes new reduction goals and baseline years for greenhouse gas emissions, sustainability efforts, energy intensity, clean energy, water use efficiency and management, the purchase of environmentally preferable products, SW diversion, HM use, HW generation, and improved tracking and reporting measures.

Compliance with EO 13693 at NSA Orlando is addressed in Sections 5 of this P2 Plan. Energy related P2 goals are discussed briefly in applicable sections in this P2 Plan and EO 13423 and EO 13514, recently revoked by EO 13693, are discussed in more detail in the “Shore Installation Energy and Water Management Annual Report” for

FY2014.

13514 Federal Leadership in Environmental, Energy, and Economic Performance

Directs Federal facilities to increase energy efficiency;

measure, report, and reduce their greenhouse gas emissions from direct and indirect activities; conserve and protect water resources through efficiency, reuse, and storm water management; eliminate waste, recycle, and prevent pollution; leverage agency acquisitions to foster markets for sustainable technologies and environmentally preferable materials, products, and services; design, construct, Compliance with EO 13514 at NSA Orlando is addressed in NSA Orlando’s “Shore Installation Energy and Water Management Annual Report”.

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EO

Number EO Title

EO Description and Requirements as included in Table 2-1

NSA ORLANDO

Compliance

Status maintain, and operate high performance sustainable buildings in sustainable locations; strengthen the vitality and livability of the communities in which federal facilities are located; and inform federal employees about and involve them in the achievement of these goals.

EO 13693

revokes EO 13514 and is discussed above and in Section 5 of this P2 Plan.

13423 Strengthening Federal Environmental, Energy, and Transportation Management

The order sets goals in the areas of energy efficiency, acquisition, renewable energy, toxics reductions, recycling, renewable energy, sustainable buildings, electronics stewardship, fleets, and water conservation.

The EO requires more widespread use of Environmental Management Systems (EMS) as the framework in which to manage and continually improve these sustainable practices.

Compliance with EO 13423, revoked by EO 13693, at NSA Orlando is addressed in Sections 5.2 to 5.7 of this P2 Plan.

13221 Energy Efficient Standby Power Devices

Requires agencies to purchase products that use no more than 1 watt in standby power consuming mode.

The Department of Energy (DOE), DoD, and the General Services Administration (GSA) issues a list of acceptable products that meet this requirement. The following link published by the Federal Energy Management Program presents a guide on how to buy equipment with low standby power:

http://www1.eere.energy.gov/femp/technologies/stand by_power.aspx

Discussed separately in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

13212 Actions to Expedite Energy- Related Projects

Authorizes agencies to expedite projects that will increase the production, transmission, or conservation of energy. It also states that agencies shall expedite the review of permits or take other actions necessary to accelerate the completion of energy-related projects.

Discussed separately in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

12845 Purchasing Energy Efficient Computer Equipment

Establishes the U.S. EPA “Energy Star” energy efficiency requirements in the purchase of computer equipment. Mandates facilities to equip computers with energy efficient low-power standby feature. Mandates facilities to educate staff about environmental and economic benefits of energy efficiency.

Discussed separately in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

12844 Federal Use of AFVs

Requires procurement and use of AFVs, where possible. Requires facilities to purchase 50% more AFVs from 1993 to 1995 than specified in the Energy Policy Act of 1992. Requires that each installation report annually to the Secretary of Energy on actions and progress under this order.

Compliant. NSA Orlando has followed the rules and guidelines for EO 12844 for the purchase of AFVs and tracking and reporting requirements are discussed in Section 5.5 of this P2 Plan.

12898

(Amended by EO 12948)

Federal Actions to Address Environmental Justice

Requires facilities to document potential environmental impacts in environmental justice areas and target such impacts for reduction through P2.

Compliant, through Environmental Program and P2 Plan.

http://www1.eere.energy.gov/femp/technologies/standby_power.aspx http://www1.eere.energy.gov/femp/technologies/standby_power.aspx

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Table 3-3 outlines the DoD and DON Instruction that address P2. These instructions include goals and guidance for implementing P2 metrics at federal agencies.

TABLE 3-3 P2 Related DoD and DON Regulations

Instruction

Name

Description and Requirements NSA Orlando Compliance Status

DoD Instruction 4715.4

Pollution Prevention, June 1996

This instruction provides explicit guidance on P2 activities. It reiterates the P2 hierarchy principle and establishes DoD’s P2 MoMs for reductions in TRI releases, HW reduction, non-hazardous SW diversion, and AFVs. It also establishes a requirement for installation qualified recycling programs (QRP), calls for Affirmative (Green) Procurement, and authorizes direct sales of recyclables.

NSA Orlando is compliant with DoD Instruction 4715.4 in the establishment of affirmative procurement procedures and sale of recyclable materials. NSA Orlando does not have a QRP and is not compliant at this time, but has identified this as a P2O as discussed in Section 5.4 of this P2 Plan.

DoD Instruction 4715.6

Environmental Compliance

This instruction on environmental compliance implements policy, assigns responsibilities, and prescribes procedures for achieving compliance with applicable EOs and federal, state, interstate, regional, and local statutory and regulatory environmental requirements.

Compliant.

DoD Memorandum

Office of the Under Secretary of Defense, Revised P2 and Compliance Metrics, October 2004

On 12 October 2004, DoD issued revised P2 and Compliance Metrics in order to measure the effectiveness of DoD P2 and compliance programs in support of the DoD missions. This memorandum supersedes the 1998 DoD MoM. DoD facilities are required to achieve a diversion rate for nonhazardous SW greater than 40% by the end of fiscal year (FY) 2010; however, diversion rates for construction and demolition (C&D) waste are measured separately from other non-hazardous SW diversion rates under this memorandum. A separate diversion rate of 50% for C&D materials is mandated by the end of FY2020.

The revised metric requires DoD facilities to establish a cost-effective SW management program that reduces SW generation, increases diversion rates, and optimizes cost avoidance. These metrics apply to all DoD installations worldwide.

Compliant. Tracking is discussed in Section 5.2 and Section 5.3 of this P2 Plan.

Office of the Chief of Naval Operations

(OPNAV)

Instruction 5090.1D

Environmental Readiness Program Manual

This instruction provides comprehensive and effective policy guidance, tools, and training to support operational readiness and sustainability, in compliance with environmental laws, regulations, and executive orders, across the Navy enterprise.

Chapter 23 establishes guidelines for hazardous materials management which includes but is not limited to the following items:

Follow requirements for appropriate HM labeling, disposal, training, reporting, and management such as EPCRA, U.S.

Occupational Health & Safety

Compliant with the exception of an EMS.

The environmental program at NSA Orlando adheres to the guidelines and requirements. The implementation of an EMS is discussed in Section 8.0 of this P2 Plan. NSA Orlando implements their HW management plan dated September 2012.

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Name

Description and Requirements NSA Orlando Compliance Status

Administration (OSHA), and PPA requirements.

Maintain readily-accessible OSHA Material Safety Data Sheet (MSDS) (electronic or hardcopy form) for al HM in the work place for reference.

Reduce the amount of HM used and HW generated and subsequent disposal costs.

Restrict HM procurement, storage, issue, and use via authorized use lists (AULs) based on validated need and trained qualified users. This serves to promote personnel safety, reduce potential environmental impacts, and minimize costs associated with the use of HM and disposal associated with HW.

Consider “green products” first in all procurements.

Develop and implement HM elimination or substitution processes that replace HM in existing systems, processes, and operations with the least hazardous technically acceptable materials.

Chapter 27 establishes guidelines for hazardous waste management which includes but is not limited to the following:

HW minimization shall be accomplished by applying the following hierarchy to HW management: (1) Eliminating or reducing the use of HM at the source by changing the process, equipment, requirement, or materials used; (2) Substituting a less hazardous material into the process; (3) Recycling or recovery and reuse of HM and HW; (4) Reducing or eliminating excess and expired shelf-life HM; (5) Treating HW to reduce the volume or reduce it to a less toxic or non-hazardous state; (6) destroying HW; and (7) disposal.

Clearly identify generator status and abide by all applicable regulatory requirements.

Generate, develop, and implement a HW management Plan.

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November 2015 Responsibilities

4-1

4.0 Responsibilities

Management involvement at all command levels is essential to the success of the P2 program to carry out the policy on a day-to-day basis. Implementation of the P2 program requires a team approach and is as important as technology-based solutions.

Successful integration of P2 is dependent on contributions from multiple organizations at the installation. Table 4-1 identifies the roles and responsibilities of these organizations.

TABLE 4-1 P2 Roles and Responsibilities Responsible Action

Installation Commanding Officer

(CO)

Direct programs to develop, implement, and administer management and engineering procedures and policies that will achieve and maintain full compliance with federal, state, and local environmental regulatory requirements for the installation related to P2.

NAVFAC SE Supports NSA Orlando’s environmental program.

Coordinates with Defense Logistics Agency (DLA) Disposition Services when NSA Orlando has materials available for recycling.

Conducts external environmental audits in accordance with OPNAV Instruction 5090.1D; highlights areas of improved environmental management or provides plan of action and milestones (POA&Ms), if applicable.

Supports NSA Orlando with the development of environmental plans such as the Ozone Depleting Substance (ODS) Plan and HW management Plan.

NSA Orlando Environmental Coordinator/P2 Program Manager/Hazardous Materials Manager

Ensures that adequate funding is planned, programmed, budgeted, and executed to meet NSA Orlando environmental requirements.

If environmental funding is reallocated for non-environmental initiatives, briefs the CO on the potential regulatory impacts, as applicable.

Supports Installation CO in endorsing and maintaining the Environmental Policy Statement and monitors environmental performance.

Conducts annual internal reviews and continual improvement efforts.

Recommends changes to environmental procedures, objectives, and targets, as applicable.

Oversees day-to-day operations of the environmental program at NSA Orlando.

Establishes and supports coordination and implementation of POA&Ms, for achieving objectives and targets.

Maintains environmental media program plans and procedures, as appropriate.

Maintains environmental compliance by ensuring that the media programs adhere to applicable federal, state, and local regulations.

Identifies environmental regulatory requirements and ensures conformance.

Ensures that appropriate training is provided to those personnel who perform tasks that may cause significant environmental impacts.

Follows procedures that identify prevention of, potential for, and response to accidents and emergency situations, including mitigation of environmental impacts.

Supports the monitoring and measurement of the operations and activities that can have a significant impact on the environment.

Other NSA Orlando Organizations/Tenants

Participates in environmental programs as required.

Notifies Environmental Branch staff or representative of environmental concerns and issues.

As directed, executes actions to achieve P2 objectives and targets for practices.

November 2015 Responsibilities

4-2

November 2015 Pollution Prevention Baseline Information and Current Activities

5-1

5.0 Pollution Prevention Baseline Information

and Current Activities

Tracking progress within the P2 Program implemented at NSA Orlando is necessary to assess installation progress in meeting the MoMs for HM, HW, SW, alternative fuel use, water consumption, and energy consumption. Focusing on MoMs allows the installation to verify whether goals are being met and to allocate resources (energy, money, and personnel) toward areas of need. Material reduction, reuse, and recycling and the reduction of environmental impacts resulting from waste and materials associated with the installation’s mission are discussed in the following sections.

5.1 P2 MoMs

EO 13693 was signed 25 March 2015 and superseded the mandated MoMs set forth in EO 13514, signed 8 October 2009, and EO 13423, signed 26 January 2007, for environmental, energy, and transportation management at all federal agencies. The OPNAV Instruction 5090.1D was revised in January 2014 and contains policy guidance for environmental readiness. Table 5-1 details these MoMs as well as the reporting requirements for tracking progress toward meeting the goals.

TABLE 5-1 P2 MoMs Reporting Requirements

Program Area Reduction Goal Baseline

Year Reduction

Year Reporting Requirements for

Tracking Progress

Greenhouse Gas Emission

The head of each agency will propose percentage reduction targets by FY2025 relative to a FY2008 baseline. Previously established as 3% annually or 30% by 2020 in EO 13514.

Not Available

2025 Reporting requirements and MoM tracking are discussed in Section 5.6 of this P2 Plan.

Clean Energy Sources (Renewable Electric Energy and Alternative Energy)

25% of energy consumed in FY2025 is clean energy; Implement renewable energy generation projects where feasible.

2016 2025 Reporting requirements and MoM tracking are discussed in Section 5.8 of this P2 Plan and in more detail in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

Potable Water Consumption

Reduce consumption by 2% annually or 36% by

FY2025.

2007 2025 Reporting requirements and MoM tracking are discussed in Section 5.7 of this P2 Plan and in more detail in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

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Program Area Reduction Goal Baseline

Year Reduction

Year Reporting Requirements for

Tracking Progress

Industrial, Landscaping, and Agricultural Water Consumption

Reduce industrial, landscaping and agricultural water consumption by 2% annually.

2010 2025 Reporting requirements and MoM tracking are discussed in Section 5.7 of this P2 Plan and in more detail in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

Toxic and Hazardous Chemicals and Materials

Demonstrate a reduction and minimization in the amount of toxic and hazardous chemicals and materials acquired, used, or disposed of.

Continually Continually Reporting requirements and MoM tracking are discussed in Section 5.2 of this P2 Plan.

Non-Hazardous Solid Waste

Divert at least 50% of non-hazardous SW from landfills.

Continually Continually Reporting requirements and MoM tracking are discussed in Section 5.4 of this P2 Plan.

C&D Waste Divert at least 50% of C&D material and debris from landfills.

Not Applicable

Not Applicable

NSA Orlando does not generate C&D waste.

Alternatively Fueled Vehicles

Reduce fleet-wide per-mile greenhouse gas emissions by 20% by 2025, increase use of zero emission vehicles or plug-in hybrid vehicles by 50%.

2014 2025 Reporting requirements and MoM tracking are discussed in Section 5.5 of this P2 Plan.

Sustainable Acquisition and Procurement

Purchase preferences for recycled content products, energy and water efficient products/services, Safer Choice labeled products, biobased products, and use of paper with at least 30% recycled content.

NA NA Reporting requirements and MoM tracking are discussed in more detail in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando. In short, although NSA Orlando has no Affirmative Procurement program, NSA Orlando does have guidelines to purchase energy efficient products and services.

Electronic Products

Ensure procurement preference for environmentally sustainable electronic products, employ environmental sound practices with respect to the disposition of excess or surplus electronic products.

Continually Continually The disposition of surplus electronics is discussed in Section 5.4 of this P2 Plan.

Procurement and reporting requirements are discussed in the “Shore Installation Energy and Water Management Annual Report” for NSA Orlando.

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5.2 Toxic Chemicals and Hazardous Materials at NSA Orlando

The mandates of EO 13693 and DoD directives require all facilities to track their toxic and hazardous materials in accordance with the requirements of EPCRA Sections 301 through 313, and to demonstrate a reduction and minimization in toxic chemical usage. NSA Orlando tracks their chemical usage through Tier II reports submitted to the appropriate state and local authorities annually. Table 5-2 provides the quantity for each Tier 2 reportable chemicals from calendar year (CY) 2010 to CY2014 with the baseline year established as CY2010 when Tier 2 reporting was first conducted.

TABLE 5-2 NSA Orlando Tier 2 Reporting, CY2010 through CY2014

Chemical Usage (pounds)

Chemical

CAS

Number

Reportable Threshold

Baseline

CY2010

CY2011 CY2012 CY2013 CY2014

Lead 7439-92-1 10,000 6,973 12,879 12,677 10,916 12,815

Sulfuric Acid 7664-93-9 500 2,128 1,813 1,775 2,236 2,780

Diesel Fuel 68334305 NA NA NA NA NA 13,896

Notes:

The chemical usage quantity in pounds is the maximum total inventory reported on the Tier 2 EPCRA reports.

NA = the data was not available.

Lead and sulfuric acid is utilized onsite for forklift and communication system lead acid battery power sources. In comparison to the baseline year and as an overall trend, lead and sulfuric acid usage has increased. These increases are most likely attributed to the inclusion of additional batteries in uninterruptable power supply modules both within the de Florez building and associated with Navy operations in the Partnership One building. Lead is the only 313 reportable chemical found in use at NSA Orlando;

however, it is excluded from reporting requirements as it falls under the Article Exemption [40 CFR §372.38(b)] provided by EPCRA Section 313 regulations.

Addition…