Natick ISWMP January 2025.pdf

INTEGRATED SOLID WASTE MANAGEMENT PLAN

USAG NATICK SOLDIER SYSTEMS CENTER

NATICK, MASSACHUSETTS

January 2025

Distribution authorized to U.S. Government Agencies only.

Requests for this document must be referred to Commander, USAG Natick, AMIM-SSG-

ZA, Natick, MA 01760-5002

USAG NATICK Integrated Solid Waste Management Plan

TABLE OF CONTENTS

1.0 PURPOSE AND OBJECTIVES

2.0 BACKGROUND

2.1 Location

2.2 Scope and Applicability

2.3 Mission

2.4 Army Net Zero Waste Strategy

3.0 REGULATORY REQUIREMENTS AND POLICIES

4.0 RESPONSIBILITIES

4.1 Garrison Commander

4.2 All Directors and Tenant Activity Leadership

4.3 Director of Public Works

4.4 Natick Contracting Division

4.5 Chief, Environmental Health Office

4.6 Solid Waste Manager

4.7 Contracting Officers Representatives for the Solid Waste Contract

4.8 Logistics Readiness Center

4.9 Public Affairs Office

4.10 Environmental Quality Control Committee

4.11 All Organizations, Units, and Tenant Activities…

5.0 SOURCE REDUCTION

5.1 Green Procurement

5.2 Pollution Prevention

5.3 Reuse and Repurposing

5.4 Best Management Practices

6.0 INSTALLATION RECYCLING PROGRAMS ……………………………………

6.1 Single Stream Recycling Program

6.2 Procedures for Specific Recycled Materials

6.3 Diversion Rate

7.0 SOLID WASTE GENERATION AND COMPOSITION ................................ ……...14

7.1 Solid Waste Generation

7.2 Solid Waste Composition

8.0 SOLID WASTE MANAGEMENT PRACTICES ........................................... ……...15

8.1 Solid Waste Collection and Disposal

8.2 Management Practices for Specific Waste Types

9.0 PROGRAM PROMOTION, OUTREACH, AND TRAINING

9.1 Program Promotion

9.2 Outreach

9.3 Training

10.0 RECORDKEEPING, TRACKING, AND REPORTING

10.1 Solid Waste Management Records

10.2 Tracking and Reporting

11.0 SOLID WASTE MANAGEMENT ACTION ITEMS

12.0 TECHNICAL POINT OF CONTACT

APPENDICES

A – References .............................................................................................................A-1 B – Relevant Solid Waste Regulations and Policies .....................................................B-1 C – NSSC Memo No. 07-24 – Solid Recycling and Waste Reduction …………..................C-1 D – Summary of Solid Waste Disposal and Diversion ...…........................................... D-1 E – Solid Waste Dumpster Inventory ............................................................................E-1 F – Solid Waste and Recycling Training Opportunities .................................................. F-1

TABLES

Table 1. Scrap Metal and Single Stream Recycling Tonnage, FY11-24 Table 2. Solid Waste Diversion Rates Reported for USAG NATICK Table 3. USAG NATICK Management Practices for Massachusetts Banned Wastes .. 23

FIGURE

Figure 1. Waste Composition, USAG NATICK Solid Waste Characterization Study ii

INTEGRATED SOLID WASTE MANAGEMENT PLAN

U.S. ARMY SOLDIER SYSTEMS CENTER

1.0 PURPOSE AND OBJECTIVES

The purpose of this Integrated Solid Waste Management Plan (ISWMP) is to document U.S. Army Garrison Natick (USAG Natick) current solid waste management requirements and practices, identify goals for solid waste minimization and diversion, and specify the approach for achieving those goals. The plan identifies various elements and quantities of the waste stream; identifies the current practices for reuse, recycling, and disposal of solid waste. This ISWMP applies to all current and future USAG Natick directorates, mission partners, and activities.

The objectives of the solid waste management program at USAG Natick are stated below.

• Minimize the generation of solid waste through source reduction

• Reuse, repurpose, or recycle elements of the solid waste stream to the maximum extent practicable

• Divert construction and demolition (C&D) waste to the maximum extent practicable, with the goal of diverting 60% C&D annually in accordance with the Department of Defense (DOD) Strategic Sustainability Performance Plan (SSPP) (Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics (OUSDATL), 2016a)

• Divert at least 50% of nonhazardous solid waste (excluding C&D waste) annually (OUSDATL, 2016a)

• Strive to meet the goal of Net Zero Waste in accordance with Army Directive

2014-02 (SECARMY, 2014).

• Comply with all applicable Federal, Commonwealth of Massachusetts, local and Army solid waste management regulations including applicable Executive Orders (EOs)

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

2.0 BACKGROUND

2.1 Location.

USAG NATICK is located on 74 acres in the town of Natick, approximately 17 miles west- southwest of Boston, Massachusetts. The main campus is located on a point of land protruding into Lake Cochituate in the Town of Natick. The main campus is a 78-acre, military property containing nearly 80 buildings including laboratories;

administrative offices; an infirmary; a textile research center; environmental test chambers; drop test facilities; and laser, thermal, and ballistic test facilities. A cafeteria, enlisted housing and mess, barbershop, credit union, and recreational facilities are also located on site. The housing areas in Needham, Wayland, and Hudson have been divested, only the Heritage Lane and General Greene Drive housing areas in the Town of Natick remain and were privatized 01OCT23. In total, USAG NATICK supports a civilian and military population of approximately 1,600 personnel.

2.2 Scope and Applicability.

Solid waste, as defined in the Resource Conservation and Recovery Act (RCRA), is any garbage, refuse, sludge, or other discarded material resulting from industrial, commercial, institutional, and residential activity. Discarded materials include those disposed, abandoned, recycled, or inherently waste-like. Hazardous wastes are solid wastes that meet specific RCRA criteria involving hazardous characteristics or the presence of listed constituents and are not addressed in this ISWMP. This plan applies to the entire NSSC including tenant organizations, which include the following organizations:

• U.S. Army Research Institute of Environmental Medicine (USARIEM)

• U.S. Army Integrated Logistics Support Center(ILSC)

• U.S. Navy Clothing and Textile Research Facility (NCTRF)

• U.S. Army Soldier Research, Development, and Engineering Center (DEVCOM)

• U.S. Army Project Manager Soldier Equipment (PMSE)

• U.S. Army Project Manager Force Sustainment Systems (PMFSS)

• U.S. Coast Guard Clothing Design and Technical Office

• U.S. Army Contracting Command – Natick Contracting Division (NCD)

• U.S. Army Sustainment Command – Logistics Readiness Center (LRC)

2.3 Mission.

USAG Natick is home to the Natick Soldier Systems Center (NSSC) that integrates and delivers comprehensive installation support services, providing a resilient and sustainable Performance Institute for Mission Partners and the Total Army Family, to ensure the success of the Joint Force. NSSC is responsible for the technology, research, development, engineering, fielding, and sustainment of the military’s food, clothing, shelters, airdrop systems, and Soldier support items.

NSSC also has the lead for Soldier integration for the U.S. Army.

2.4 Army Net Zero Waste Strategy.

This ISWMP reflects the U.S. Environmental Protection Agency (EPA) pollution prevention (P2) hierarchy, which emphasizes source reduction and recycling to reduce the solid waste stream. The Army Net Zero Waste strategy expands on the P2 hierarchy, and identifies five elements of waste management in order of preference:

source reduction, repurposing, recycling/composting, energy recovery, and disposal.

This is similar to the P2 hierarchy in that emphasis is placed on reducing waste at the source, followed by ways to transform wastes into new products or recover energy. An Army Directive issued in January 2014 sets policy and assigns responsibilities to strive toward Net Zero at all Army installations (SECARMY, 2014).

3.0 REGULATORY REQUIREMENTS AND POLICIES

The USAG NATICK solid waste management practices have been developed based on legislation enacted by the Commonwealth of Massachusetts, U.S. Congress, EOs signed by the President, and directives and instructions issued by the DOD and the Army. A summary of relevant laws, EOs, and other policies is provided in Appendix B.

4.0 RESPONSIBILITIES

The responsibilities of key participants in USAG NATICK’s solid waste management program are as follows.

4.1 Garrison Commander.

• Provide command emphasis on solid waste reduction, materials reuse, recycling, and green procurement (GP).

• Approve and promulgate the USAG NATICK ISWMP.

• Maintain a functional organizational structure to plan, execute, and monitor the solid waste management program.

• Promote participation in the installation’s recycling program

(Appendix C NSSC Policy Memo No. 07-24 Natick Recycling and Waste Reduction).

• Participate on the Environmental Quality Control Committee (EQCC), the forum that addresses environmental issues including solid waste management and recycling.

4.2 All Directors and Tenant Activity Leadership.

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

• Monitor activities regarding compliance with solid waste management requirements.

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

• Participate in the EQCC.

4.3 Director of Public Works.

In addition to the responsibilities listed in paragraph 4.2, the Director of Public Works is responsible for the following:

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

• Ensure that all new contracts awarded, particularly C&D contracts, include contract language stipulating the diversion of recyclable materials when feasible and cost-effective to the Government

• Additionally, ensure that C&D contracts specify that contractors submit

C&D waste management plans and waste diversion data.

• Ensure that new construction and major renovations conform to applicable building energy efficiency requirements and sustainable design principles as specified in EO 13834 (section 6, section 7, and section 11) as directed under EO 13990.

4.4 Natick Contracting Division.

In addition to the responsibilities listed in paragraph 4.2, the Contracting Division is responsible for ensuring that contracts meet Federal GP requirements and source reduction strategies as follows:

• Ensure that contracts have appropriate clauses for source reduction and recycling, GP, and C&D waste.

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

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

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

• For construction, demolition, and renovation contracts, include provisions for quantifying and reporting the materials diverted from the waste stream and ensure measures for the salvaging, reuse, and recovery of materials are incorporated by requiring contractors to provide and follow a C&D waste management plan (see section 8.2.3 for additional details).

4.5 Chief, Environmental Office.

• Identify a person(s) responsible for managing the solid waste program and the recycling program. The Solid Waste Manager may also be designated to assume any or all of the responsibilities listed below.

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

• Ensure sufficient funding levels to comply with regulatory requirements and support waste reduction initiatives.

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

• Ensure that the ISWMP is updated annually or as necessary to reflect current solid waste handling and disposal practices.

• Promote and implement GP strategies.

• Report to the EQCC on a quarterly basis on issues related to solid waste management and recycling.

4.6 Solid Waste Manager.

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

• Coordinate with Solid Waste Contracting Officer’s Representative (COR) on all aspects of the integrated solid waste management program including source reduction, recycling, reuse, and disposal methods.

• Periodically review all applicable Federal, Commonwealth, and Army requirements for managing solid wastes and advise all waste-generating activities of the requirements including requirements for reporting and recordkeeping. Monitor installation compliance with Federal, Commonwealth, and Army solid waste management requirements.

• Determine the most cost-effective and efficient means of source reduction, recycling, and waste collection, storage, treatment, and/or disposal. Seek out and propose more efficient, cost-effective methods of integrated solid waste management when applicable.

• Request, justify, and procure equipment necessary to perform solid waste and recycling operations.

• Review contracts related to solid waste management and recycling for environmental compliance.

• Maintain liaison and coordinate as necessary with Federal and

Commonwealth solid waste regulators.

• Collaborate with Town of Natick Sustainability Coordinator (or officials) toward future co-operative agreements for solid waste collection services.

• Create and maintain a recordkeeping system to track materials diverted and disposed. Track solid waste and recyclables quantities and submit appropriate data into Solid Waste Annual Reporting System Web-based (SWARWeb) database (or the successor module in the new enterprise business system, the Headquarters Army Environmental System).

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

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

4.7 Contracting Officer Representative for the Solid Waste Contract.

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

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

• Coordinate with the Solid Waste Manager to develop strategies for improvements in integrated solid waste management and, if necessary, modify contracts to implement those strategies.

• Closely monitor weight slips generated by the solid waste services contractor; verify that weight information corresponds with monthly Wide Area Work Flow invoice payments.

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

• Ensure contract provisions are fully executed, and take appropriate actions when found to be deficient.

• Require contractors disposing of C&D waste to report the quantities of C&D waste diverted from the landfill disposal (referred to as Leadership in Energy and Environmental Design (LEED) reports).

4.8 Logistics Readiness Center.

In addition to the responsibilities listed in paragraph 4.2, the Logistics Readiness Center is responsible for the following:

• Actively support the DPW Environmental Office in measuring progress to meet Federal and DOD waste reduction goals and GP requirements.

• Complete and submit DD FORM 1348-1A’s to the Solid Waste

Manager for materials turned into the DLA Disposition Service activity serving the installation.

4.9 Public Affairs Office.

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

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

4.10 Environmental Quality Control Committee.

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

• Provide a forum for planning, identifying needs and objectives, and coordination among various installation entities.

4.11 All Organizations, Units, and Tenant Activities.

• Participate in and support the recycling program by identifying, collecting, separating and placing recyclables into the proper bins, breaking down cardboard boxes, and removing contaminants from all potentially recyclable materials.

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

5.0 SOURCE REDUCTION

Source reduction (i.e., creating less waste) is the preferred management method for reducing the volume of solid waste that is disposed by landfilling or incineration. The EPA calls for source reduction as the primary tool in the waste management hierarchy, and it is integral to the Net Zero Waste strategy. Key components of source reduction include procurement of sustainable products and services, reuse of materials and waste exchanges, repurposing items into secondary uses, and management processes that create less waste.

5.1 Green Procurement.

GP (also known as sustainable procurement) is the purchase of environmentally beneficial products and services in accordance with one or more of the established Federal procurement preference programs. The benefits associated with GP practices include conserving resources, saving energy, saving landfill space, reducing pollution, and creating markets for recycled, biobased, and other environmentally beneficial materials. Federal Agencies are required to establish a GP Program to meet the requirements of the EPA “Buy Recycled” Program and the United States Department of Agriculture “BioPreferred” Program. DOD’s GP policy reaffirms a goal of 100 percent compliance with Federal laws and EOs requiring the procurement of green products and services (OUSDATL, 2008). The Federal GP Program includes the following categories of green products: recovered materials, biobased, environmental preferable, energy efficient (Energy Star or Federal Energy Management Program (FEMP) designated), water efficient (WaterSense labeled), alternative fuels and fuel efficient vehicles, non-ozone depleting substances, electronic products registered with the Electronic Product Environmental Assessment Tool, and sustainable buildings.

5.2 Pollution Prevention.

The Pollution Prevention Act (PL 101-508, 1990) established P2 as a national objective in reducing waste at the source. This is to be achieved by lessening the toxicity and/or the quantity of waste generated through such tools as material substitution, use of raw materials, procurement policies, or process changes. The USAG NATICK Environmental Office manages the USAG NATICK P2 Program and strives to reduce or eliminate the impact that any USAG NATICK operation may have on the environment through reduction or elimination of wastes, more efficient use of raw materials and energy, and reduced emissions of toxic materials to the environment.

5.3 Reuse and Repurposing.

The practices of reuse and repurposing are being instituted or assessed on USAG NATICK as potential diversion methods for waste streams. Reuse is using an item for its original intended purpose, such as collecting items for clothing drives, or collecting packing materials to be used in future shipments. Repurposing entails using a product in a different way or for a different application, while retaining its basic structure/appearance. Examples of repurposing are using industrial 55-gallon drums for the collection of waste.

5.4 Best Management Practices.

USAG NATICK personnel will follow general office management practices that will minimize the generation of solid waste. Examples include practices that will save paper, such as setting the default on printers to print double-sided, using e-mail in place of written memos when possible, using electronic routing systems, providing electronic signature authority capabilities, and saving e-mail messages to files instead of printing them.

Other procedures involve reuse and repurposing, such as sending internal mail in reusable envelopes, extending the life of file folders by using stick-on labels to cover old labels, and reusing plastic and paperboard binders.

6.0 INSTALLATION RECYCLING PROGRAMS

The USAG NATICK operates a single stream collection executed through a solid waste services contract.

6.1 Single Stream Recycling Program.

The DPW Environmental Office has operated USAG NATICK’s single stream recycling program since 2011. The single stream program includes paper, cardboard, plastic bottles (plastic resin codes 1-7), glass bottles, and metal cans.

The single stream recycling tonnage from FY11-24 is shown in Table 1.

Table 1. Scrap Metal and Single Stream Recycling Tonnage, FY11-21

Fiscal Year Scrap Metal (tons)

Single Stream (tons)

2011 62 90

2012 55 108 2013 69 103 2014 69 91 2015 96 93 2016 136 90 2017 74 71 2018 64 57 2019 93 72 2020 62 46 2021 59 38 2022 60 38 2023 76 40 2024 68 38

The single stream program pays a solid waste services contractor to collect recyclables and transport to a Materials Recovery Facility (MRF) facility where they are separated and later sold. USAG NATICK’s contract allows the contractor to retain the sales proceeds in accordance with its agreement with the MRF. This arrangement is appropriate for a smaller installation that does not generate the quantities of recyclable materials to warrant a full-scale recycling program and does not have the personnel to operate such a program.

6.2.1 Single Stream Segregation and Storage Procedures

The recyclable materials in the single stream program are generated by many employees in various USAG NATICK activities, including office workers. Employees have desk- side containers for recyclables and are responsible for segregating wastes from recyclables and transporting the recyclables to containers at centralized collection points located within each building. The following items can be placed in the desk-side recycling containers:

• Plastics (with plastic resin codes 1-7)

• Glass (food and beverage containers only)

• Cans and other metal (aluminum, tin, steel, bi-metal, and jar lids)

• Paper (newspaper, magazines, cardboard, and paper products)

• Shredded paper (bagged)

The custodial contractor is responsible for collecting recyclables from centralized collection points in USAG NATICK buildings and taking the material to the single stream compactor. The operation of the compactor and 30 yd3 roll-offs at Bldg 20 are part of the solid waste services contract. The contractor picks up recyclables monthly or on an as-needed basis. The recyclables are transported to the Cassela Recycling of New England Zero-Sort Facility located in Charlestown, Massachusetts.

All activities and tenants at USAG NATICK are required to participate in the installation recycling program, including the family housing communities. Family housing units are provided a collection bin for recyclables and will be picked up curbside by the solid waste contractor on a bi-weekly basis.

6.2.2 Single Stream Collection and Reporting Procedures.

USAG NATICK installed a certified truck scale in FY13 and began requiring contractors to obtain weights for all recyclable materials collected. Upon entering the installation, the vehicle operator is required to pull the truck up to the unattended remote scale terminal kiosk located on the scale on the west side of Bldg 20. The operator identifies the vehicle using a supplied radio frequency identification tag and obtains a vehicle tare weight. Prior to exiting the installation, vehicle operators repeat this process to obtain a vehicle weight ticket. A copy of the weight ticket receipt must be provided to the guard at the DeFranzo Service Gate upon exiting the facility. The weight tickets are retained by the Solid Waste Manager and provided to the solid waste contract COR. All weight data are included in the installation diversion rate calculations in SWARWeb.

6.2 Procedures for Specific Recycled Materials.

As stated in section 6.1, USAG NATICK has a single stream recycling program that accepts paper products, aluminum and other metal containers, glass containers, and plastic containers. Other materials that are recycled at USAG NATICK are lead-acid batteries, metals, green waste, textiles, fluorescent light fixtures, batteries, and C&D waste. Collection procedures for each recyclable material type are described below.

6.3.1 Aluminum, Glass, and Plastic.

Aluminum, glass, and plastic are all part of the single stream recycling program. USAG NATICK personnel have a desk-side container for the collection of the materials and are responsible for transporting the materials to centralized recycling containers located in their building. Custodial contract personnel collect the commingled materials and bring them to the 40-yd3 compactor located at Bldg 20. Some of these containers are subject to the Massachusetts Beverage Container Law ("Bottle Bill”), which places a 5- cent deposit on all carbonated soft drink, beer, malt beverage and sparkling water containers (including glass, plastic metal, aluminum, and bi-metal) sold in Massachusetts. Many employees take their used beverage containers to a redemption center, and therefore these items are not found in great abundance in the recycling or waste stream.

6.3.2 Cardboard and Paper Products.

Activities that generate cardboard are responsible for flattening cardboard and placing it in or adjacent to the centralized recycling containers located in each building. Other paper products (white paper, newspaper, magazines, and paperboard) should be placed in the employee’s desk-side recycling container and ultimately transported to the building’s centralized collection container. The custodial contract personnel collect the commingled materials and take them to the 40-yd3 compactor located at Bldg 20.

Shredded paper may be collected in the single stream recycling program. Activities that use onsite mobile shredding must be reported to the Solid Waste Manager so it may be counted towards the installation’s diversion rate.

6.3.3 Vehicular Products.

USAG NATICK participates in a one-for-one exchange program for lead-acid batteries;

the used batteries are collected and recycled when new ones are purchased. In the past, antifreeze and used oil were collected and recycled; however, most maintenance activities are presently conducted offsite and limited quantities of antifreeze and used oil are generated. Currently these small quantities of antifreeze and used oil are disposed along with other hazardous materials.

6.3.4 Green Waste.

The USAG NATICK DPW Roads and Grounds personnel are responsible for grounds maintenance. Yard waste is centrally collected in a 30 yd3 roll-off behind Bldg 1. A contractor picks up the yard waste when requested and transports it to a composting facility. The quantity of green waste composted is captured in the SWARWeb data and counts toward USAG NATICK’s diversion rate.

6.3.5 Wood.

Wood is banned from landfill disposal in Massachusetts (see section 8.2.2 for information on banned wastes). Wood is generated primarily through small construction projects and repairs at USAG NATICK. It is placed in the 30 yd3 construction debris roll-off at Bldg. 111 and recycled or reused.

6.3.6 Fluorescent Lights.

Fluorescent light bulbs are managed as universal waste (a category of HW) and are turned in through the USAG NATICK Hazardous Waste Program for recycling.

Fluorescent light bulbs are crushed and recycled by a contractor.

6.3.7 Batteries.

Batteries are managed as universal waste, are collected in approved containers, and are turned in through the USAG NATICK Hazardous Waste Program for recycling.

6.3.8 Toner Cartridges.

USAG NATICK personnel are responsible for their own toner cartridge disposal.

Individuals are encouraged to work with team leaders to coordinate and reduce time, travel, and confusion. Old / used cartridges are to be placed back into original packaging and recycled per manufacturer directions which may include dropping them off at the store or using the mail in return labels.

Historically, toner cartridges were picked up by a third party vendor for recycling.

Unfortunately the previous vendor went out of business and another local vendor could not be found. No revenues are obtained from the recycling of the toner cartridges.

6.3.9 Textiles.

Per the Massachusetts Solid Waste Ban updated as of November 2022 100% of non contaminated textiles are to be recycled or re-used. In January of 2023 and December of 2024, USAG NATICK was granted a waste ban waiver (re-issued annually) from the Massachusetts Department of Environmental Protection to allow for the disposal of fabric materials (textiles) through destruction via incineration with an approved contractor. Textiles included are those which are under development, being evaluated, or used for prototypes. The materials include proprietary and/or sensitive materials in-use or in-development by the government/private industry/academia for the protection against the elements, chemical/biological/nuclear threats, ballistic/blast exposures, and/or improved camouflage against current or emerging technologies. Propriety or sensitive materials relating to contracts, camouflage, and ballistics are used in designs and evaluated across the center on a continual basis. All non-proprietary / sensitive textile material including but not limited to clothing, bedding, fabric scrap, etc. must be recycled through the collection site managed by DPW Environmental. The quantity of textiles recycled and destroyed via incineration is reported to the Solid Waste Manager and is captured in the installation’s diversion rate.

6.3 Diversion Rate.

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

(R/(R+L))*100

Where:

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

Recycling is the most prevalent form of diversion at USAG NATICK. The diversion rates reported in Table 2 include the USAG NATICK Recycling Program’s total annual diversion rates since 2011, recorded in SWARWeb. In the past, the solid waste services contractor provided estimates on wastes generated, based on the container capacities and pickup frequency. USAG NATICK installed a truck scale to enable exact weights of wastes and recyclables to be recorded. This enables much more accurate reporting of both wastes and recyclables generated at USAG NATICK.

Table 2. Solid Waste Diversion Rates Reported for USAG NATICK1

FY

Solid Waste Generated

(tons)

Solid Waste Diverted

(tons)

Solid Waste Disposed

(tons)

Diversion Rate

(% by wt)

2011 986 154 832 16%

2012 996 164 832 16%

20132 350 175 175 50%

2014 352 176 175 50.09%

2015 425 246 179 57.89%

2016 421 253 168 60.13%

2017 309 165 143 53.54%

2018 400 248 152 61.90%

2019 446 268 178 60.07%

2020 297 151 146 50.79%

2021 258 139 119 53.71%

2022 234 135 100 57.38%

2023 335 216 120 64.40%

2024 353 228 125.1 65.13% 1Nonhazardous solid waste; does not include C&D waste 2Starting FY13, wastes and recyclables weighed on USAG NATICK truck scale, increasing accuracy Data Source: SWARWeb Comprehensive Reports

7.0 SOLID WASTE GENERATION AND COMPOSITION

7.1 Solid Waste Generation.

USAG NATICK nonhazardous solid waste generation is similar to that of other light-industrial Army facilities, consisting mainly of administrative offices with some laboratory facilities and waste from family housing. Based on data collected since FY13 (when more accurate data were available using the certified truck scale), USAG NATICK generates an average of 145 tons of undiverted solid waste (excluding C&D waste) on an annual basis (see Table 2). The total average annual tonnage of solid waste diverted is 202 tons, based on data since FY13. A 2015 solid waste characterization study conducted by the Army Public Health Center (APHC) provided useful data on the waste composition at USAG NATICK (APHC, 2016). The results are discussed below.

7.2 Solid Waste Composition.

General nonhazardous waste at USAG NATICK is generated from onsite operations, such as administrative offices, laboratories, test facilities, and cafeterias. A solid waste characterization study was conducted at USAG NATICK in September 2015 by APHC (APHC, 2016). The study team collected 35 samples (over 2,000 pounds) from 18 dumpsters on the installation. Wastes in the samples were separated into 32 different categories. Figure 1 is a depiction of the overall composition of waste samples collected during the study. Note that samples were collected from waste containers only, and not from single stream collection points or other materials separated for recycling. The following are notable results for major waste categories in the characterization study.

7.2.1 Paper.

The high percentage of paper (34.2%) does not reflect recyclable paper in the waste stream; the majority of this paper was observed to be non-recyclable paper such as used paper towels. The study data and onsite observations indicated that USAG NATICK personnel are adequately segregating recyclables from the waste stream

7.2.2 Organics.

The second largest category identified was organics, including food waste (making up 26.7% of the waste stream). Most of the food waste was generated in the cafeteria in Bldg 1 and the Dining Facility (DFAC) in Bldg 15. (The study was conducted just before the initiation of a food waste diversion pilot study conducted in late 2015). The remaining food waste found in the dumpsters came from break rooms and offices, commingled with other trash. The Combat Feeding Directorate’s Food Lab in Bldg 36 also generates food waste, consisting of Meals, Ready-to-Eat (MREs) that have been opened for testing. The study team found one dumpster completely full of boxed MREs (over 150 pounds).

7.2.3 Plastic.

Plastics identified (25.1%) consisted largely of plastic film, which includes trash bags, wrap, and packing material. Plastics in the solid waste stream for the most part did not include recyclable items that could be sent through the single stream recycling program.

It is notable that some materials determined to be household waste were identified in the sampling study. USAG NATICK should periodically remind personnel that household waste should not be brought in to the facility for disposal.

Figure 1. Waste Composition, USAG NATICK Solid Waste Characterization Study (APHC, 2016)

8.0 SOLID WASTE MANAGEMENT PRACTICES

8.1 Solid Waste Collection and Disposal.

The custodial contractor is responsible for emptying individual waste containers at the point of generation, and transporting the waste to the waste dumpsters. The dumpster inventory is provided in Appendix E. The solid waste services contractor provides all labor, equipment (dumpsters, collection truck), and labor necessary to perform refuse and bulk recycling collection at the main USAG NATICK campus and the family housing areas. Dumpsters are required to be designed to shed 100% of all precipitation and prevent vector attraction. The solid waste contractor (DBI Waste Systems, Inc.)

collects the waste twice a week and transports it to the Wheelabrator ‘energy-from-waste’ facility located in Millbury, Massachusetts. The Wheelabrator Waste Combustor can process 1,500 tons of waste per day, producing 45 megawatts of renewable electricity to power its own operations and 47,000 homes in the local community.

According to USAG NATICK’s solid waste services contract, the tipping fee charged to USAG NATICK is approximately $150 per wet ton, resulting in USAG NATICK annual expenditures approaching $18,000 for solid waste tipping fees.

To obtain more accurate waste generation data, USAG NATICK installed a certified truck scale in FY13 and now requires the solid waste services contractor to measure and record the weight of all wastes picked up at the installation. Upon entering the installation, the vehicle operator pulls up to an unattended remote scale terminal kiosk located on the scale near Bldg 20. The operator identifies the vehicle using a radio frequency identification tag and obtains a vehicle tare weight. Prior to exiting the installation, vehicle operators repeat this process to obtain a vehicle weight ticket. A copy of the weight ticket receipt is then given to the guard at the DeFranzo Service Gate upon exiting the facility. The weight tickets are retained by the Solid Waste Manager and included in the installation diversion rate calculations in SWARWeb.

8.2 Management Practices for Specific Waste Types.

8.2.1 Residential Waste.

The family housing units located at Heritage Lane and General Greene Avenue are privatized and responsible for their own solid waste and recycling disposal and management.

8.2.2 Massachusetts Banned Wastes.

In 1990, the Massachusetts Department of Environmental Protection (MassDEP) first identified toxic and easy-to-recycle materials and banned them from landfill disposal or incineration. Since then, more materials have been added to the list, forcing businesses and communities to identify recycling or other diversion methods in lieu of disposal. The banned wastes are listed in Title 310 Code of Massachusetts Regulations (CMR) (CMR, 19.017) and shown in Table 3. The USAG NATICK’s current management practices for these banned wastes are also included in the table.

8.2.3 Construction and Demolition Waste.

C&D waste consists of the debris generated during construction, renovation, and demolition projects and includes but is not limited to the following materials: lumber, reinforcing steel and other metals, piping and wiring, concrete, brick, plaster, wall board, roofing material, insulation, plumbing fixtures, doors, windows, and asphalt. Of these materials, asphalt pavement, brick, concrete, wood, metal, glass, and gypsum wallboard are subject to the Massachusetts waste ban. Contractors working at USAG NATICK generating these materials are required to divert them from landfill disposal.

8.2.3.1 Diversion Goal.

Divert construction and demolition (C&D) waste to the maximum extent practicable towards the goal of 60% diversion [Department of Defense (DOD) Strategic Sustainability Performance Plan] (Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics (OUSDATL), 2016a).

Table 3. USAG NATICK Management Practices for Massachusetts Banned Wastes Waste Type Storage Collection/Disposal

Batteries Batteries (nickel-cadmium, etc.) are managed as universal waste and are stored in approved containers at the point of generation.

Alkaline are collected as non-haz waste

Batteries (alkaline, nickel-cadmium, etc.)

are collected by the Hazardous Waste Program and are sent out to be recycled.

Lead-acid batteries are exchanged on a one-for-one basis and are recycled.

Leaves and other yard waste

USAG NATICK DPW Roads and Ground personnel store yard waste in a roll-off near in the Building 1 parking area..

Wellesley Trucking picks up the yard waste when requested and transports it to a composting facility.

Tires USAG NATICK does not generate tires. USAG NATICK does not generate tires.

White goods Personnel submit a turn-in request to

LRC and it is taken to the LRC warehouse.

Item is reused onsite if possible or is shipped to DLA Disposition Services.

Aluminum containers

Employees are instructed to place these wastes into recycling bins. Custodial staff collects the bins and transports the recyclables to the compactor located at Bldg. 20.

The solid waste contractor collects the recyclables and transports them to the recycling facility in Charlestown, Massachusetts.

Metal/glass containers

Employees are instructed to place these wastes into recycling bins. Custodial staff collects the bins and transports the recyclables to the compactor located at Bldg. 20.

The solid waste contractor collects the recyclables and transports them to the recycling facility in Charlestown, Massachusetts.

Single polymer plastics

Employees are instructed to place these wastes into recycling bins. Custodial staff collects the bins and transports the recyclables to the compactor located at Bldg. 20.

The solid waste contractor collects the recyclables and transports them to the recycling facility in Charlestown, Massachusetts.

Recyclable paper Employees are instructed to place these wastes into recycling bins. Custodial staff collects the bins and transports the recyclables to the compactor located at Bldg. 20.

The solid waste contractor collects the recyclables and transports them to the recycling facility in Charlestown, Massachusetts.

Cathode ray tubes

Personnel submit a turn-in request to LRC and it is taken to the LRC warehouse.

If screen is intact, item is sent to the DLA Disposition Services; if screen is not intact, item is disposed of as hazardous waste.

Asphalt, brick, and concrete

See section 8.2.3. See section 8.2.3.

Metal Scrap metal are stored onsite in two 30 yd3 scrap metal roll-offs.

Scrap metal generators and LRC place all scrap metal in roll-off containers.

Contractor removes metal for recycling when containers are full.

Wood Wood is placed in the construction debris roll-off at Bldg. 111.

The wood is recycled or reused.

Clean gypsum wallboard

See section 8.2.3. See section 8.2.3.

Textiles Textiles are to be recycled unless covered by MassDEP waiver. Textiles are collected in the Garrison managed container

The solid waste contractor collects the recyclables and transports them to the recycling facility in Charlestown, Massachusetts.

The solid waste incinerator collects the textiles for destruction and transports them to a facility in Westborough, MA

8.2.3.2 Construction and Demolition Activities at USAG

NATICK.

C&D waste is primarily generated by construction contractors working at USAG NATICK. Contracts involving C&D require achievement of a 60% minimum diversion of C&D waste, by weight, from landfill disposal. It is the contractor’s responsibility to report the quantity of C&D waste diverted and disposed. Applicable USAG NATICK contracts require C&D contractors to submit a C&D Waste Management Plan and waste diversion data (referred to as LEED reports).

8.2.3.3 Contract Requirements for C&D Waste Management Plan.

AR 420-1 (DA, 2008) requires that all military construction, renovation, and demolition projects shall include performance requirements for a 60%1 minimum diversion of C&D waste, by weight, from landfill disposal. This policy applies to all construction, renovation, and demolition projects. Specifications will include submission of a contractor’s C&D Waste Management Plan at least 15 days prior to the start of site clearance activities. The purpose of the waste management plan is to minimize the generation of C&D waste and ensure the maximum quantity of potential C&D waste (including material generated during site clearing and existing structure demolition). The waste management plan should include the following elements:

• Responsible Persons. The plan shall designate personnel on the contractor’s staff responsible for C&D waste prevention and management.

• Waste Characterization. The plan shall characterize the waste to be generated during the project including types and quantities. The characterization should address generation and disposition of all waste materials.

• Waste Disposal Location. The plan shall provide the name of the designated landfill and/or incinerator, tipping fee, and projected disposal costs for all waste to be disposed.

• Recycling Strategy. The plan shall provide a description of specific approaches to be used in recycling or reuse of various materials generated. For all disposed materials, including anticipated hazardous wastes, the plan must include names of haulers, disposal sites, and applicable permits and registrations.

USAG NATICK has developed environmental contract language to be inserted in applicable contracts executed at the installation. The contract language includes the 60% diversion goal for C&D waste streams, the development of C&D waste management plans, use of installation dumpsters, and the collection and transport of ferrous and non- ferrous metals to the scrap metal containers at Bldg 20. The DPW staff responsible for solid waste management and recycling shall review the C&D waste management plans for installation-managed projects and participate in the review and approval of waste management plans for projects performed on the installation by others.

The requirements in this section are applicable to any construction, maintenance and repair, or demolition project large enough to warrant its own dumpster(s). Small maintenance and repair projects that generate minimal amounts of waste may not be subject to these requirements, at the discretion of the DPW - Environmental Office.

8.2.3.4 Documentation.

For each construction project requiring a C&D waste management plan, the COR shall document and monitor implementation of the approved plan. The DPW is responsible for reviewing the C&D waste management plan. In addition, the COR will ensure C&D activities and materials are monitored and quantified by the contractor for incorporation of the data into the installation’s C&D diversion rate calculation within the SWARWeb database.

9.0 PROGRAM PROMOTION, OUTREACH, AND TRAINING

Public education is an integral part of a solid waste management program and particularly a recycling program. The recycling program requires aggressive promotion to ensure its continued success since it depends on the participation of every worker and visitor to the facility.

9.1 Program Promotion.

Command emphasis is vital to the sustained success of a recycling program and proper solid waste management, and can be in the form of an installation policy, celebration of America Recycles Day, or simply endorsement of the facility’s recycling practices.

USAG NATICK will install posters near all recycling stations, photocopiers, printers, and vending machines that communicate what recycling services are available and where recycling stations are located. USAG NATICK will also ensure that signs are posted on all dumpsters that prohibit disposal of Massachusetts banned wastes (which includes many common recyclables) and C&D wastes.

9.2 Outreach.

USAG NATICK will continue to support the annual spring and fall cleanup events and emphasize waste segregation and recycling. To the extent feasible, USAG NATICK will partner with local communities and schools to increase environmental awareness and will attend community-sponsored events such as neighborhood clean-ups.

9.3 Training.

Appropriate and relevant training is integral to the success and safety of solid waste management operations and recycling programs. Training programs may be in the form of formal training courses, on-line courses, hands-on applications, subscriptions to appropriate professional journals, or attendance at seminars and conferences. Relevant training opportunities that may be beneficial to USAG NATICK personnel are presented in Appendix F. In addition, the USAG NATICK Solid Waste Manager and Recycling Program Manager will participate in information sharing events hosted by the HQ Army Installation Management Command (IMCOM). These include quarterly Net Zero waste collaboration calls that allow installations within an IMCOM region to share success stories, challenges, and diversion data.

10.0 RECORDKEEPING, TRACKING, AND REPORTING

10.1 Solid Waste Management Records.

The Solid Waste Manager will ensure that the recordkeeping and reporting system captures all recycling activities that occur at USAG NATICK. This will enable the Solid Waste Manager to accurately provide required annual reports and quarterly data calls to the Army via SWARWeb. Solid waste records include:

• Weight tickets from collection of solid waste

• Weight tickets from collection of recyclables (single stream)

• Wide Area Work Flow invoice payments

• DD Form 1348-1A for the turn-in of scrap metal to DLA (if under DLA Contract)

• Weight tickets from scrap metal collection

• Copies of receipts or bills of lading

• Invoices from solid waste services contractor

• Landfill tipping fee receipts

• Contract deliverables for solid waste generation and diversion (LEED reports)

10.2 Tracking and Reporting.

10.2.1 SWARWeb.

The USAG NATICK will track the nonhazardous solid waste diversion rate and cost avoidance and report solid waste generation, disposal, and diversion data monthly in

SWARWeb, which is an Army system to track and report installation solid waste and recycling data. The USAG NATICK Solid Waste Manager will ensure the quantities of solid waste disposed and diverted from the waste stream are reported to the USAG NATICK Environmental Office for inclusion in SWARWeb. USAG NATICK will use actual weight data obtained from the certified truck scale to measure wastes and recyclables hauled off the installation.

10.2.2 Construction and Demolition Waste Disposal and Diversion.

Contractors shall provide C&D waste disposal and diversion rates, or other approved quantifiable data, to the COR as required by contract, and the COR will provide this data to the Solid Waste Manager. The C&D diversion report form (Appendix C) may be used to record C&D waste generation and diversion data. The Solid Waste Manager will ensure that C&D activities and quantities are captured and reported annually in the SWARWeb.

10.2.3 Future…