Appendix_L_-_Affirmative_Proc_Plan.pdf

Supersedes 01 July 2010 edition signed 16 February 2011

CDRL CEV-15H

AFFIRMATIVE PROCUREMENT PLAN

Thule Air Base, Greenland

FINAL FY-12

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Contract No. FA2523-05-C-9001

CDRL CEV-15H Affirmative Procurement Plan

Thule Air Base, Greenland 3/18

TABLE OF CONTENTS

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2.0 GENERAL

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3.0 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Accounting and Finance, 821 ABG/FM

3.3 Danish Liaison Officer, DLO

3.4 Environmental Engineering, GC/EE

3.5 Occupational Health and Safety, GC/OHS

3.6 Civil Engineering, GC/CE

3.6.1 Project Management, GC/CEPF

3.7 Base Supply, GC/LGS

4.0 AFFIRMATIVE PROCUREMENT PLAN

4.1 Comprehensive Procurement Guidelines (CPG)

5.0 HAZMAT PHARMACY PROGRAM (HPP)

6.0 PERSONNEL TRAINING

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: GLOSSARY OF TERMS

APPENDIX 3: ACRONYMS AND ABBREVIATIONS:

APPENDIX 4: DISTRIBUTION LIST

APPENDIX 5: 2011 REVIEW COMMENTS

Thule Air Base, Greenland 4/18

1.0 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title

: The title of this document is “Affirmative Procurement Plan”, CDRL CEV-15H. The acronym APP will be used throughout the document.

Classification

: The document is unclassified.

Responsibilities

: Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility (OPR) for establishing, implementing and maintaining the APP. The instructions given in the APP are applicable to all organizations and tenant units at Thule AB.

Organizations and tenant units are authorized to extract and reproduce those sections of the APP that are essential in the planning and preparation of supporting documents and reports.

Reviews/changes

: The APP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to 21 CES/CEAN by 1 Nov for review. Review comments, if any, will be provided within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Furthermore, the APP is subject to change if any of the applicable laws, regulations, or require-ments is altered.

Distribution APPENDIX

: The APP is distributed to the organizations listed in the distribution list, Thule Air Base, Greenland 5/18

2.0 GENERAL

2.1 Purpose

The APP establishes Thule AB's guidelines for the Affirmative Procurement Program. The APP includes the acquisition of recycled content products, and environmentally preferable purchasing as one program. The APP contains the necessary guidance for developing an effective installation affirmative procurement program, which are required of all Air Force installations in CONUS and overseas.

Thule Air Base is working towards improving pollution prevention strategies by encouraging all activities/units to work together and consider the following factors:

a. Use of recovered materials.

b. Reuse of product.

c. Recyclables.

d. Use of environmentally preferable products.

e. Energy efficiency.

f. Waste prevention (including toxicity reduction or elimination).

2.2 Scope

The purchase and use of products and services can have a profound impact on the environment.

Thule Air Base (Thule AB) recognizes the positive impact that it can make on the environment through the purchasing decisions that its employees make. It is the intent of Thule AB to integrate environmental considerations into the aspect of acquisition.

The APP applies to all organizations that are located on Thule AB. The following plans have to be consulted: PCB Replacement Plan, CDRL CEV-12, and Pollution Prevention Management Plan, CDRL CEV-15D. Furthermore, the homepage of Environmental Protection Agency (EPA) for purchasing designated items through US sources is used as a guideline (www.epa.gov/cpg).

2.3 Regulatory Overview

US State Laws: Not applicable

USAF: AFI 32-7080 “Compliance Assurance and Pollution Prevention”.

AFI 32-7086 “Hazardous Materials Management”.

Thule AB: EPC Decisions Statement of Work, Part 1, Chpt. 4, para 4.1 and Chpt.18, para.8.8

Host Country: Not applicable

Thule Air Base, Greenland 6/18

3.0 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

In order to ensure that materials and products purchased are handled in an environmentally correct manner, it is important that the purchase specialists are fully aware of their responsibilities in the affirmative procurement program. These responsibilities are outlined in the following:

3.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the management of affirmative procurement at Thule AB. The responsibility is implemented through the base Environmental Protection Committee (EPC), of which the Installation Commander is the chairman.

3.2 Accounting and Finance, 821 ABG/FM

The Accounting and Finance office assists in setting up accounts for fund management.

3.3 Danish Liaison Officer, DLO

The Danish Liaison Officer serves as the official representative of Denmark and the Greenland Home Rule concerning environmental issues at Thule AB.

3.4 Environmental Engineering, GC/EE

Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility (OPR) for establishing, implementing and maintaining the APP.

• Assist Base Supply at Thule AB in identifying, characterizing and evaluating products and materials.

• Implementing an awareness program to promote affirmative procurement.

• Providing affirmative procurement consultation support to all personnel and organizations involved in the purchasing process.

• Providing recommendations to management personnel across all organizations involved in the purchasing process on the preparation, implementation, and monitoring of the

APP.

3.5 Occupational Health and Safety, GC/OHS

The responsibility of the OSH includes:

• Validation and approval of chemical products used at Thule Air Base, to ensure less hazardous materials are purchased.

3.6 Civil Engineering, GC/CE

The Civil Engineering office is responsible for the establishment of procedures to ensure that all projects are reviewed by GC/EE.

3.6.1 Project Management, GC/CEPF

In the design phase, Project Management shall:

• Identify and document whether green products and services are available and can satisfy local requirements for price, availability, and performance.

Thule Air Base, Greenland 7/18

• Ensure that affirmative procurement requirements are identified, prior to submission to supply, so that approved purchase requests properly address all relevant affirmative procurement requirements.

3.7 Base Supply, GC/LGS

The requirement of implementing affirmative procurement is applicable where appropriated funds are used and purchase is worth $10,000 of a designated item or purchase $10,000 or more of the item in the previous year. Base Supply is responsible for:

• Providing oversight of contract execution to ensure affirmative procurement requirements are addressed in accordance with the terms of the contract. Along with this: Reviewing procurement requests to ascertain and validate whether green products or services are involved in the procurement action.

• Providing guidance to procurement request originators and facilitating acquisition planning with respect to green products and services.

• Gathering, sorting, and reporting of procurement data for the purpose of management evaluation of affirmative procurement performance, when such data is maintained in databases operated by procurement organizations.

• Complying with procedures for monitoring and annually reviewing the effectiveness of the

APP.

Thule Air Base, Greenland 8/18

4.0 AFFIRMATIVE PROCUREMENT PLAN

A preference program: each acquiring activity and procurement activity will make it a practice, when purchasing any of the items listed in Appendix 1, to show a preference for items with recovered material content. There are three options to consider when purchasing these items:

a. Minimum-content standards. Identify the minimum content of recovered materials that an item should contain; these standards are located in Comprehensive Procurement Guidelines (CPG) and the Recovered Materials Advisory Notices (RMAN).

b. Case-by-case procurement. Open competition between products made of virgin materials and products made of recovered materials; procuring agencies or individuals must exercise a preference for the latter.

c. Other. Any approach which is substantially equivalent to the above approaches.

Exception:

1. The price of items with recovered material is unreasonable.

2. The requirement for items produced with recovered materials results in inadequate competition.

3. Obtaining items with recovered material results in unusual and unreasonable delays.

4. Items produced with recovered materials do not meet all reasonable performance specifications.

Purchase of Environmental Protection Agency (EPA) designated items (www.epa.gov/cpg) through US sources complies with the Thule AB Affirmative Procurement Plan. Exceptions are justified and documented. The requirement does not apply to non-appropriated fund purchases that, if any, will be separately identified.

As a minimum, Air Force major commands are required to establish procurement programs for all EPA guideline items, and in accordance with RCRA, subtitle F (Section 6002), and EO#12873. Each activity will review and revise specifications for the designated items to allow procurement of products containing recovered materials. While each procurement agency may design its own program, so long as it meets the requirements of RCRA, all affirmative procurement programs must have the following four elements:

1. A preference program

2. A promotion plan

3. Procedures for obtaining and verifying estimates, and certifications of the content of recovered materials

4. Annual review and monitoring

Annual review and monitoring: GC Environmental Engineering evaluates selected purchasing orders from Base Supply and other shops.

4.1 Comprehensive Procurement Guidelines (CPG)

Federal Register “Final Rules” Comprehensive Procurement Guidelines

The CPG is the document the EPA uses to formally designate the items covered by the APP. As a result the designated items are known as “guideline items”. The process begins as the EPA reviews a broad list of potential products made from recovered materials. They consider the availability of the item, the potential impact on the solid waste stream, the economic and technical feasibility of producing the item, and other uses of the recovered materials used to http://www.epa.gov/cpg/index.htm� http://www.epa.gov/cpg/index.htm� http://www.epa.gov/cpg� http://www.epa.gov/cpg�

Thule Air Base, Greenland 9/18 produce the item. The EPA also considers comments from end users, manufacturers, distributors, the general public, and other interested parties through a formal rulemaking process to designate items. The list of guideline items is complete when EPA publishes it as a Final Rule in the Federal Register.

Thule Air Base, Greenland 10/18

5.0 HAZMAT PHARMACY PROGRAM (HPP)

The HPP provides for process-based authorizing, procuring, issuing, tracking, and disposing of Hazardous Materials (HAZMAT). It is a repository for data required to meet reporting require-ments, assess processes for pollution prevention opportunities, and measure success in mini-mizing HAZMAT use.

The program ensures HAZMAT users obtain the material required to perform their mission.

However, until the appropriate Environment, Safety and Occupational Health (ESOH) precau-tions are understood and in place, HAZMAT is not issued to users. This means personnel must have received proper training and/or are aware of the potential safety hazards of the product.

Furthermore, the program ensures that only the smallest quantities of HAZMAT necessary to accomplish the mission, consistent with the “Pharmacy” concept of operations, are purchased and used. This will be accomplished by eliminating HAZMAT usage not essential to mission ac-complishment, substituting reduced-risk HAZMAT whenever possible, and minimizing HAZMAT usage when the mission dictates their use. Decision making on minimization and substitution should take into account reducing overall ESOH.

During 2011 the EESOH-MIS (Enterprise Environmental, Safety and Occupational Health - Management Information System) software has been implemented at Thule AB and is used as a computerized tracking tool (database) designed to track hazardous materials from the time of purchase and arrival on base till the material has been consumed or disposed of (Cradle to Grave).

Thule Air Base, Greenland 11/18

6.0 PERSONNEL TRAINING

The Affirmative Procurement Training (APT) is recommended for personnel that purchase materials and products.

Environmental Engineering can provide training in Affirmative Procurement. Occupational Health and Safety can provide training in Chemical Hazard Communication.

AP training shall be incorporated into the general environmental awareness training. APT shall focus on procurement personnel. APT shall include, but not be limited to:

• Descriptions of products covered by CPG.

• How to identify if a product meets CPG standards.

• Where to find information on AP, CPG, and RMAN.

• How to order products meeting CPG standards.

Newly assigned personnel should be provided the training before starting the job; otherwise they must work under the direct supervision of a trained employee.

Training records for personnel involved in the affirmative procurement procedure must be kept on file by the organizations/departments, to which the employee in question is assigned, and retained for 3 years after termination. Records must identify the employee's position and responsibility in affirmative procurement, as well as the date when the training was received.

Thule Air Base, Greenland 12/18

APPENDICES

Thule Air Base, Greenland 13/18

APPENDIX 1: DEFINITIONS AND TERMS

Designated EPA Items

Section I Effective 2007, the CPG V covered the following items:

Paper and Paper Products Toner Cartridges Printer Ribbons Plastic Desktop Accessories Office Recycling Containers Plastic Trash Bags Waste Receptacles Plastic Envelopes Lubrication Oils Engine Coolant Insulation Products Tires Concrete/Cement Patio Blocks Structural Fiberboard Laminated Paperboard Plastic Pipe and Fittings Geotexiles Carpet Carpet Cushion/Padding Floor Tiles Flowable Fill Traffic Cones Parking Stops Traffic Barriers Delineators Channelizers Garden and Soaker Hoses Landscaping Timbers and Posts Running Tracks Plastic Fencing Pallets Hydraulic Mulch Awards and Plaques Sorbents Signage Industrial Drums Manual-grade Strapping Mats Presentation Folders Clipboards, File Folders Portfolios Binders Crossings/Surfaces Office furniture Compost made from recovered organic materials Fertilizer made from recovered materials

Thule Air Base, Greenland 14/18

APPENDIX 2: GLOSSARY OF TERMS

Affirmative Procurement Program RCRA Section 6002 requires each procuring agency to establish an affirmative procurement program for maximizing its purchases of EPA-designated items. The program should be developed in a manner that ensures items composed of recovered materials are purchased to the maximum extent practicable consistent with Federal procurement law.

CPG

Through the Comprehensive Procurement Guideline (CPG), EPA designates items that must contain recycled content when purchased by federal, state, and local agencies, or by government contractors using appropriated federal funds. Under E.O. 13101 EPA is required to update the CPG every 2 years.

Designated Products Products that are or can be made from recovered materials that have been designated in the CPG through EPA's formal rulemaking process. Also referred to as "designated items".

Materials in Solid Waste Materials found in the various components of the solid waste stream. Generally, solid waste has several components, such as municipal solid waste (MSW), construction and demolition debris (C&D), and no hazardous industrial waste. Under RCRA Section 6002, EPA considers materials recovered from any component of the solid waste stream when designating items containing recovered materials.

Post consumer Materials A material or finished product that has served its intended use and has been diverted or recovered from waste destined for disposal, having completed its life as a consumer item. Post consumer materials are part of the broader category of recovered materials.

Pre-consumer Materials Materials generated in manufacturing and converting processes, such as manufacturing scrap and trimmings/cuttings.

Procuring Agency Any Federal agency or any state agency, or agency of a political subdivision of a state that is using appropriated Federal funds for procurement.

RCRA Section 6002 Section 6002 of the Resource Conservation and Recovery Act (RCRA) of 1976, as amended, directs EPA to designate items that are or can be produced with recovered materials and to recommend practices for buying these items. Among other things, RCRA Section 6002 also provides criteria for EPA to consider when selecting items for designation, and requires procuring agencies to establish affirmative procurement programs for designated items.

Recovered Materials Waste materials and byproducts that have been recovered or diverted from solid waste, but do not include materials and byproducts generated from, and commonly reused within, an original manufacturing process.

http://www.epa.gov/cpg/#sec6002� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#executive2� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#sec6002� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#app�

Thule Air Base, Greenland 15/18

RMAN

Recovered Materials Advisory Notices (RMANs) provide purchasing guidance and recommend recovered and post consumer material content levels for designated items. RMAN recommen-dations are guidance and therefore are not codified in the Code of Federal Regulations.

Thule Air Base, Greenland 16/18

APPENDIX 3: ACRONYMS AND ABBREVIATIONS:

AF Air Force AFB Air Force Base AFI Air Force Instruction AP Affirmative Procurement APP Affirmative Procurement Plan BPL Biobased Products List CE Civil Engineering CONUS Continental United States CPG Comprehensive Procurement Guidelines DLA Defense Logistics Agency DoD Department of Defense EO Executive Order EPA Environmental Protection Agency EPC Environmental Protection Committee EPP Environmentally Preferable Purchasing GSA General Services Administration MAJCOM Major Command RCRA Resource Conservation Recovery Act RMAN Recovered Material Advisory Notice SOW Statement of Work

Thule Air Base, Greenland 17/18

APPENDIX 4: DISTRIBUTION LIST

The PDF document is distributed via email IAW CDRL Summary list.

Distributed in PDF format

21 Space Wing

21 CES/CEAN

William.ritchie@us.af.mil Todd.degarmo@us.af.mil

21 SW/PMD

21sw.pmd.thule@peterson.af.mil

821 Air Base Group 821 ABG/CC Commander

821SPTS.PM@thule.af.mil

821 Support Squadron 821 SPTS/CE Flight Commander

821SPTS.CE@thule.af.mil

Greenland Contractors, Thule Air Base All GC organizations (on GC LAN)

GC Intranet mailto:William.ritchie@peterson.af.mil� mailto:Todd.degarmo@peterson.af.mil� mailto:821SPTS.PM@thule.af.mil� mailto:821SPTS.CE@thule.af.mil�

APPENDIX 5: 2011 REVIEW COMMENTS

Ite m # Office

Symbol Org

Pa ge

Pa ra

Cr iti ca l, Su bs ta nt iv e or

Ad m in is tr at iv e

Comment Rationale Accept Modify Reject

Rationale

1 CEANQ 21 CES Docu ment throu ghout

S Add (Green Procurement Program) after "Affirmative Procurement" Comment not valid until DCR is approved.

(Todd)

Green Procurement has replaced Affirmative Procurement in the Air Force.

Should be added to avoid confusion.

R Awaiting DCR.

2 CEANN 21 CES 10 2nd to last

C Change EMIS to EESOH-MIS (throughout document). Delete last paragraph as EESOH- MIS was implemented earlier in 2011.

EESOH-MIS has been implemented at TAB.

A Paragraphs are updated.

3 CEANN 21 CES 17 App 4 A Change email address from @peterson.af.mil to @us.af.mil

Peterson email server was changed along with everyones email.

A Email address distribution list is updated IAW CDRL Distribution List.

4 CEANN 21 CES 10 last S Reword to state the EESOH-MIS is the current system instead of the future system.

EESOH-MIS has been implemented at TAB.

A Paragraphs are updated.

5 CEANN 21 CES 8 4 S Purchase of Environmental Protection Agency (EPA) designated items (www.epa.gov/cpg) through US sources complies with the Thule AB Affirmative Procurement Plan. Does the EU have and equivalent list of preferred products at the EPA? Can that be included for purchases made in Denmark and Europe?

Many of the purchases at Thule are made in Denmark and the EU countries. It would be good to purchase environmental friendly products from all purchases.

R Not a BMC requirement.

6 CEANN 21 CES 10 5 S Last 2 paragraphs are out of date. EESOH-MIS has been implemented at Thule.

A Paragraphs are updated.

7 CEANN 21 CES 11 6 S How often is the training conducted? Frequency of training and how often each employee should be train, should be clearly stated in the plan.

M Employees are trained appropiately.

8 CEANN 21 CES N/A Could you have an EU equivalent of Appendix 1?

Many of the purchases at Thule are made in Denmark and the EU countries. It would be good to purchase environmental friendly products from all purchases.

R Not a BMC requirement.

9 CEANN 21 CES Add 21 CES/CEAN comments and GC's response to the plan.

AF and GC agreed to add comments to all the plans.

A 21 CES/CEAN comments and GC's response are added to the plan.

3.7 Base Supply, GC/LGS