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| Resource Library > Installation Planning > USAF Commander Guide to Environmental Quality |
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| Installation Planning/USAF Commander Guide to Environmental Quality |
Achieving and maintaining environmental quality is essential to the Air Force mission. The Chief of Staff has established the following environmental leadership goals:
- Reduce all cleanup sites in the high and medium risk categories to low risk;
- Ensure our operations comply with Federal, state, and local standards;
- Prevent future pollution by reducing the generation of hazardous waste to as near zero as feasible;
- Use the Environmental Impact Analysis Process (EIAP) to support decision making; and
- Protect and enhance our natural resources through sound stewardship and management.
Solutions:
- Adhere to the goals of the four pillars of the Air Force Environmental
- Quality Program, outlined in Air Force Policy Directive (AFPD) 32-70
Cleanup
- Reduce health and envimnmenta1 risks created or caused by past operations;
- Identify, characterize, and cleanup contamination; and
- Promote open, unbiased, and comprehensive processes by involving public and regulatory agencies
Compliance
- Comply with Federal, state, and local environmental laws and standards; and
- Support compliance inspections, and aggressively correct areas not in compliance.
Conservation
- Conserve natural and cultural resources through effective environmental planning;
- Protect our environmental resources, managing them in the public interest; and
- Assess environmental opportunities and constraints for proposed actions.
Pollution Prevention
- Eliminate pollution 5rom all activities whenever possible;
- Reduce waste generation and procurement of environmentally damaging materials to as near zero as feasible; and
- Recycle or reuse spent hazardous materials whenever possible when their use is unavoidable.
Measuring Success
- Cleanup: Reduction in the number of sites assessed as high or medium relative risk;
- Compliance: No Notices of Violations (NOVs) from regulatory agencies;
- Conservation: Complete comprehensive plans of the installation;
- Pollution Prevention: Reduced quantities of hazardous and solid waste discharged compared to CY92 baseline.
| The Air Force Environmental Organization |
Role of the Commander
- Identify environmental management responsibilities and individual performance standards;
- Provide adequate training;
- Lead an effective Environmental Protection Committee;
- Employ the Environmental impact Analysis Process (EIAP) and Comprehensive Planning;
- Utilize the Environmental Compliance Assessment and Management Program (ECAMP);
- Prioritize project requirements through the 0MB A-106 process;
- Identify requirements and obtain resources through the Planning, Programming, and Budgeting System (PPBS); and
- Partner with environmental planning and regulatory agencies and local communities.
Management Tools
The Environmental Protection Committee (EPC) is the commander's primary tool for environmental management and is governed by Air Force Instruction (AFI) 32-7005.
The Environmental Flight, composed of environmental staff personnel in the Civil Engineer Squadron, administers protection programs, prepares reports and permits, inspects activities for compliance, and provides training.
Training opportunities include Air Force institutional training, available through the Air Force Institute of Technology (AFIT) and Air University (AU); outside sources, such as other Federal and state agencies; and private companies.
The Air Force Environmental Restoration Program (AFI 32-7020) focuses on identifying and cleaning up hazardous waste sites that were contaminated prior to 1984. Legal agreements, or corrective action owners, by federal and state regulators drive specific cleanup requirements and schedules. These legal documents outline specific requirements to study, design and contract remedial actions, and can take anywhere from 4 - 20 years before the regulators will acknowledge we have adequately cleaned up the site.
Significant funding reductions started in FY95, with a promise of continued reductions in the future. In addition to project dollars, these reductions also affect the funding for management and manpower activities. However, we are still required to cleanup contamination in compliance with state and federal laws, and more importantly, safeguard the health and safety of our own people and the surrounding civilian communities.
Recent Congressional language, and decentralization of the DoD account to the Air Force, will result in cleanup funds being allocated to the Air Force in regular operations and maintenance accounts. Presently, the Environmental Restoration Account remains the sole source of funding for cleanup project execution. Funding from other operations and maintenance accounts appropriated for mission readiness activities cannot be used to pay for cleanup activities. This includes any fines and penalties that may be assessed by environmental regulators for noncompliance with legal agreements or schedules. In addition, credibility within the program is very critical, emphasizing the accuracy of our project cost estimates and completion schedules.
We need to do the smart things first by ensuring we direct our funding to cleaning up the sites that pose the greatest threat to human health and the environment. The "relative risk" evaluation plays an important role as we plan and sequence our study and cleanup requirements for every site. All sites are evaluated and classified as either high, medium, or low risk. The Air Force program goal is to clean up, or have a remedy in place, for all "high" risk sites by FY 2002. "Medium" risk sites should be complete, or have a remedy in place by FY 2008.
Installation environmental managers should be using the most cost effective contracting processes and engineering technologies for study and cleanup projects. Emphasis is on removing toxic contaminants, allowing the land to be used for its intended industrial purposes, not completely cleaning up every site to pristine levels. Concentrate on forcing the process to the stage we are "turning dirt," while minimizing our efforts in expensive and time consuming studies. We need to track and persistently reduce our overhead and management costs, as well.
Full disclosure and stakeholder involvement within our local communities are key elements of a successful program, to include state and federal regulating agencies. Active involvement by senior Air Force leadership at the installation level will ensure your programs run smoother. By building a networked team, you will be able to proactively incorporate program initiatives, as well as prevent potential barriers to success, before they occur. Community members around our installations have a right to be involved in cleanup decisions affecting themselves and their families. Use your public affairs office to maximize opportunities to discuss environmental cleanup issues with the public and market your success stories.
Review and assess cleanup requirements in legal agreements and orders with your regulators.
- Requirements will not exceed the available funding program for your installation...before you sign the agreement.
- Continuous renegotiations may occur - incorporate language that allows you to sequence work according to relative risk, and allow for flexibility to "roll" requirements to the following fiscal year, if sufficient funding is not available.
- Cleanup of medium and low risk sites should be delayed, as much as possible, until there are no more high risk sites.
Accelerate risk reduction by reducing cleanup requirements and streamlining the process.
- Recommend "interim" cleanup actions wherever possible to contain or reduce the spread of contamination. Additional information can be collected while monitoring the cleanup results.
- Reduce studies to the minimum required to adequately understand the site.
- Use simple, generic remedies that require less study effort before starting cleanup.
- New technology is a powerful force multiplier in reducing costs in all areas.
- Management and overhead costs must be kept below 10 percent of project costs-this includes manpower costs associated with your civilian personnel salaries.
- Contracting agents should be selected with management costs in mind.
Strict fiscal discipline and tracking will be required to ensure funds are used properly.
- Environmental Restoration Account funds should be expended as authorized and appropriated.
- Other operations and maintenance funds must not be used to pay for cleanup of these sites or to cover fines or penalties resulting from these sites.
- Whether it's your own base contracting of5ce, the Air Force Center for Environmental Excdlence (AFCEE), or the Army Corps of Engineers, demand responsive, quality services from your service centers.
- Obligate funds as early as possible in the fiscal year and be competitive for year-end funding.
Partnering has proven itself across the Air Force to enhance our relations with regulators.
- Make the regulators part of the cleanup team, working towards a common goal. With an active partnership, reduced study requirements and reasonable cleanup levels are easier to establish.
- Making the local public part of the team through a Restoration Advisory Board (RAB) increases public confidence and complies with federal law on public involvement.
- An informed public will make better decisions and be as suspicious.
- The local public stakeholders often support a reasonable Air Force approach in negotiations with regulators
Management action plans should be the environmental flight's constant reminder - ensure they are comprehensive and up to date.
- Identify all installation restoration requirements in the management action plan and the Civil Engineer Squadron computer data base. Ensure the information is current and accurate.
- Ensure actual program execution meets your planned milestones submitted at the start of the year.
- Ensure funds spent on cleanup activities meet or exceed 60 percent of the total program.
- Maintain management and overhead expenses less than 10 percent of the total program.
- Know what percentages of your sites have a remedial action in place.
- Know the distribution of high, medium and low relative risk among your sites and ensure your execution plan places funding against the high risk sites.
- Complete annual assessments for sufficient and sustained community interest to operate a RAB.
Overview
Compliance is conducting today's operations in accordance with today's environmental standards. It is assessed by:
- The Environmental Compliance Assessment and Management Program DECAMP); or
- By a formal inspection conducted by a Federal, state, or local regulatory agency.
The Federal Facility Compliance Act of 1992:
- Ensures Federal facilities are treated the same as private parties with regard to compliance with the requirements of lee Resource Conservation and Recovery Act (RCRA);
- Allows fines and penalties to be assessed on RCRA violations, with exceptions; and
- Requires annual compliance inspections conducted by the EPA at every Federal treatment, storage, and disposal facility.
The Air Force Compliance pillar encompasses Air Quality, Hazardous Waste, Storage Tanks, Polychlorinated Biphenyls (PCBs), Drinking Water, Storm Water, Wastewater, Hazardous Materials, Asbestos, and Lead-based Paint.
Focus Area
Air Force installations have sources of regulated air pollutants. These sources require operating permits, or permits for new construction and major modifications (see AFI 32-7040). Operational permits include vehicle and industrial operations, electrical power generation, and fuel dispensing. The Clean Air Act and National Ambient Air Quality Standards form the basis of compliance. Installations are expected to encounter greater dif5culty with compliance in Air Quality as permitting rules of the Dean Air Act are implemented.
Solutions:
- Establish program to document compliance with Conformity Rule;
- Ensure installation emission growth is specified in State Implementation Plan's Emission Budget;
- Complete Installation Emission Baseline Inventory;
- Complete and submit operating permit application;
- Establish operating permit recordkeeping, reporting, and monitoring program;
- Establish program for new construction and major modification permitting;
- Establish emission control technologies requirements program; and
- Establish program for accidental release reporting under risk management plans.
Measuring Success:
- All construction projects have proper permits to allow on-time construction;
- All construction activities ensure compliance with State Implementation Plan objectives;
- Conformity is documented and demonstrated for all proposed Federal actions;
- Accurate self-reporting and correction of permit violations;
- No accidental releases; and
- No National Emission Standards for H us Air Pollutants (NESHAP) violations.
Focus Area:
Hazardous wastes are materials that no longer serve a useful purpose and either:
- Appear in the EPA's "Listed Wastes" in the Code of Federal Regulations (CFR); or
- Demonstrate the hazardous characteristics of ignitability, corrosivity, reactivity, or toxicity.
The Resource Conservation and Recovery Act (RCRA) and supporting CFRs regulate the management of hazardous waste from its generation through disposal, or from "Cradle-to-Grave." The Federal Facility Compliance Act waives the Federal Government's immunity from prosecution for violations of RCRA, and gives regulators the ability to impose fines for RCRA violations, except for Underground Storage Tanks. Hazardous waste violations constitute the single largest number of enforcement actions the Air Force receives. Most violations occur for failure to follow administrative requirements in plans, inspections, recordkeeping, and for improper labeling of drums. Refer to AFI 32-7042 for more information.
The Air Force hazardous waste reduction goals are to reduce hazardous waste disposal by 25% by the end of 1996 and by 50% by the end of 1999, from a 1992 baseline.
Solutions:/Administrative
- Have a good up-to-date Hazardous Waste Management Plan.
- Assign responsibility for inspecting accumulation and storage areas and hold an individual accountable.
- Ensure all hazardous waste handlers are properly trained.
- Keep records of inspections, training, and disposal.
- Submit reports to regulators as required.
Facility Management
- Know and comply with facility standards.
- Have the minimum number of accumulation sites required to do the job.
- Aggressively manage storage containers.
- Ensure proper labeling of hazardous waste containers.
Spills/Releases
- Include secondary containment with hazardous waste and POL storage tanks.
- Prevent releases by having a good container management program.
Measuring Success:
- No Notices of Violations (NOVs) born regulatory agencies; and
- Reduce quantities of hazardous waste disposed and meet waste
- reduction goals.
Focus Area
- The principal goal of Underground Storage Tanks (USTs) regulations is to protect groundwater and soil from contamination (AFI 32-7044).
- All existing regulated USTs must be upgraded by Dec 98. All upgraded existing USTs and new USTs will provide:
- Leak detection,
- Corrosion protection, and
- Spill/Overfill prevention
- Initial leak detection should have been completed by Dec 93 on all existing UST systems.
- Existing USTs are those installed prior to Dec 88; new USTs are those installed after Dec 88.
- UST enforcement actions are not subject to fines and penalties from regulators.
Solutions:
- Inventory all USTs;
- Eliminate USTs where possible - use above ground tanks where feasible or locate tanks in underground vaults;
- Existing USTs in good condition can be upgraded in-place;
- Use double-wall or secondary containment for allrequired USTs;
- Report and assess leaks; and
- Maintain records.
Measuring Success
- No Notices of Violation (NOVs);
- Reduce the number of USTs from the 1988 baseline; and
- Stay on target to meet the 1998 UST upgrade goal.
| Polychlorinated Biphenyls |
Focus Area
Polychlorinated Biphenyls (PCBs) are found in electrical equipment such as transformers, capacitors and circuit breakers. PCB production ended in 1977. PCBs exhibit potential for adverse reproductive effects and cancer. Because of these hazards and the costs of cleanup after fires and spills involving PCBs, the Air Force established a goal of becoming PCB-Free.
EPA regulations specify conditions for the use, storage, cleanup, disposal, tracking, and record keeping for PCBs and equipment containing PCBs. Violations of these conditions are the cause of most enforcement actions for PCBs.
Solutions:
- Ensure program and budget are in-place to support PCB elimination;
- Ensure PCB equipment is properly labeled, inspected, and maintained; and
- Meticulously document all inspections and transactions involving PCBs from their origin through disposal.
Measuring Success:
- PCBs and PCB equipment are systematically eliminated from the installation as equipment becomes unserviceable.
Focus Area.
Our drinking water systems are federally regulated by the Safe Drinking Water Act (SDWA). AFI 48-119 requires compliance with the standards and monitoring requirements of the SDWA. Almost all states have authorization to administer drinking water compliance programs, and a State's compliance requirements for your base may be more stringent than 1 requirements.
Solutions:
- Ensure base water system meets safe drinking water standards for quality, testing, monitoring and sporting including public notification requirement when noncompliance occurs;
- Ensure adequate actions are taken to protect drinking water sources and have plans for an alt source of water supply to meet base needs; and
- Review adequacy of the water supply system and take action to repair, and/or upgrade the drinking water system to meet future needs.
Measuring Success:
- No violations of the Safe Drinking Water Act
| Wastewater and Storm Water |
Focus Area.
The Clean Water Act (CWA) requires permits to discharge pollutants to the waters of the U.S. Discharges of domestic and industrial wastewater, as well as storm water run-off, are regulated under the National Pollutant Discharge Elimination System (NPDES) permit program of the CWA.
Discharge permits are issued by EPA and the States having an EPA approved NPDES program. The permit establishes pollutant discharge levels and monitoring and reporting requirements. Often permits are jointly issued and the States may have mere stringent compliance standards. Local entities may also require pretreatment of industrial discharges to off-base Publicly Owned Treatment Works (POTW). AFI 32-7041, Water Quality Compliance, is the governing document. It also provides additional policies, such as fire training, release of aqueous film forming foam ( ), and the need to have Spill Prevention, Control, and Countermeasures (SPCC) plans.
Key wastewater compliance requirements include the use of NPDES permits, pretreatment of industrial discharges to on- or off- base treatment plants, sludge management permits, non-point source pollution control (storm water runoff), and protection of streams, rivers, and lakes. Since the majority of enforcement actions are for failure to meet discharge standards and for administrative deficiencies, special emphasis must be placed on monitoring discharges, record keeping and reporting, and training and certification of treatment plant operators.
Solutions:
- Obtain permits for polluted wastewater discharge points, including storm water run-off, before discharging;
- Ensure on-base wastewater treatment plant discharge does not exceed the permitted pollutant discharge limits and ensure a designated official files timely and accurate discharge monitoring reports with the regulators;
- Implement an industrial wastewater pretreatment (including pollution prevention) action plan to eliminate toxic discharges to treatment plants;
- Ensure the base has an effective wastewater system and includes operation and maintenance plans of the oil/water separators;
- Ensure the base has an adequate Spill Prevention, Control, and Countermeasures (SPCC) plan and a quality control program to meet EPA requirements for testing, monitoring and reporting;
- Ensure the wastewater treatment plant has the required number of certified operators;
- Renew NPDES permits 180 days prior to expiration of the existing t; and
- Program and budget for upgrades to your wastewater system if it cannot meet the permitted discharge standards.
Measuring Success:
- No wastewater and storm water discharges without a NPDES permit;
- No violations of NPDES permit requirements including wastewater discharge standards; and
- No construction activities over 5 acres in area undertaken without a storm water permit.
| HAZMAT Emergency Planning and Response |
Focus Area
Hazardous materials include all ignitable, corrosive, reactive, or toxic products and more. Since releases of hazardous materials present a severe health and safety risk, many federal regulations require you to take action to prevent, prepare for, respond to and recover from hazardous material releases. AFI 324002 provides policy for compliance with these requirements. The most common cause of enforcement actions regarding HAZMAT planning and response is failure to comply with the installation HAZMAT Plan.
Solutions
- Form a HAZMAT Planning Team to address and resolve HAZMAT issues;
- Prepare and maintain a HAZMAT Plan meeting the requirements in AFI 32-4002;
- Ensure all base organizations are aware of and comply with the HAZMAT Plan; and
- Emphasize training, equipment, and coordination with state and local emergency response agencies.
Measuring Success
- Reduction in number and size of releases;
- "Problem-free" responses to releases that do occur, and
- Rapid, proper, and complete cleanup and closure of incidents.
Focus Area.
Asbestos is used in construction and insulation, and, when damaged, may release fibers that pose a health hazard. Manage asbestos "in place" when possible and systematically eliminate it from facilities as we complete renovations. Environmental Compliance funds can only be used where asbestos poses a known health hazard. Asbestos removal in conjunction with facility projects is funded using the same funds as the larger project it is part of. Refer to AFI 32-1052 for more information.
Solutions:
- Prepare and implement Asbestos Management and Operations Plans;
- Know where asbestos is present in your facilities - complete and maintain an inventory; and
- Prevent damage to asbestos and gradually eliminate it through routine facility projects;
- Ensure personnel are trained in procedures to prevent damage to asbestos and to properly deal with asbestos in both planned and unplanned circumstances; and
- Make sure your staff has considered asbestos before a facility project is started.
Measuring Success:
- No known health hazards from asbestos;
- Asbestos presenting a human health hazard is immediately controlled/eliminated: and
- Asbestos hazard abatement is completed as part of facility projects/renovations.
Focus Area
Lead-based paint (LBP) was commonly used in and on buildings and other structures until 1978. LBP in good condition does not generally pose a health hazard. When LBP is in a deteriorated (cracking, peeling, chipping) condition, or damaged by renovation or maintenance activities, it can release lead-containing particles that pose a threat of lead contamination to the environment and a health hazard to workers and building occupants. Children are at greatest risk for adverse effects from exposure to lead from LBP; accordingly, Air Force policy considers facilities frequented by children to be "high priority" facilities. Manage LBP "in place" when possible and systematically eliminate it from facilities as we complete renovations.
Solutions:
- Prepare and implement a Management/Education Plan
- Know where LBP is present in your facilities - maintain an inventory
- Ensure personnel are trained in procedures to prevent damage to LBP and to properly deal with LBP in both planned and unplanned circumstances
- Conduct LBP hazard awareness training
- Make sure your staff has considered LBP before a project is started.
Measuring Success:
- No known health h from LBP; and
- LBP hazards in high priority facilities are immediately controlled or eliminated.
Conservation is the practice of preserving and protecting a resource while effectively using it to meet operational requirements. Conservation policies and programs are established by the following:
- The National Environmental Policy Act (NEPA) is our basic national charter for protection of the environment;
- The Environmental Impact and Analysis Process implements NEPA and is followed to analyze proposed actions and identify environmental impacts;
- Natural and Cultural Resources Management Programs help you protect these resources while permitting effective accomplishment of the military mission;
- The Comprehensive Planning program assists in base development decisions; and
- The Air Installation Compatible Use Zone (AICUZ) program promotes compatible land use in areas around your installation.
| Environmental Impact Analysis Process |
Focus Area
Air Force Instruction 327061, Environmental Impact and Analysis Process (EIAP), establishes policies, procedures, and responsibilities for Air Force implementation of NEPA. The process requires that decisions made on proposed actions be based on an understanding of the potential environmental effects of the action, reasonable alternatives, and the noaction alternative. Proponents of proposed actions are responsible for initiating the EIAP early in the planning stages of a proposal. There are three major elements of the process:
- A Categorical Exclusion exempts a proposed action from further environmental analysis.
- An Environmental Assessment is a document that provides evidence and analysis to determine if the action will have impacts. If it will not have impacts, a Finding of No Significant Impact can be issued.
- An Environmental Impact Statement (EIS) must be prepared if significant impacts are possible. A Record of Decision, summarizing the decision process, is then published in the Federal Register.
Solutions: The toughest part of the EIS is getting an adequate description of the operator's proposed action, such as the number of flights, frequency, types of aircraft, etc.
- The EIAP is done before the action is made.
Measuring Success:
- EIAP actions identified and progress of phases is effectively monitored;
- EIAP actions having operational mission impacts have alternatives under consideration;
- Environmental Assessments and Environmental Impact Statements are adequately funded; and
- Public Affairs is actively involved in EIAP.
Focus Area
The Air Force Comprehensive Planning Program (AFI 32-7062) is your master plan for the development of your installation. The result of the process is called the General Plan, which includes component plans that address specific resources, functions and programs available to support the mission. Before you do anything to the installation, you ought to know where the installation resources, such as wetlands, are. The plan should be the basis for new beddowns, new facility siting, and any other activity that could affect your resources, functions, and programs. The Base Civil Engineer is the keeper of the plan, and you are the decision maker.
Measuring Success:
- Mission changes or force structure changes are reflected in comprehensive plans;
- Effective implementation of the Comprehensive Plan;
- Significant environmental resources are identified and protected; and
- Federal, state and local agencies' objectives are addressed through effective coordination.
Focus Area
The Air Installation Compatible Use Zone (AICUZ) program (AFI 327063) is a DoD planning program designed to promote compatible land use around military airfields and has a threefold purpose:
- To assess aircraft noise and minimize the effects of flying on areas adjacent to installations;
- To prevent incompatible development in high noise and accident potential areas; and
- To maintain operational capability through compatible land use planning and control.
Measuring Success:
- AICUZ study is current, reflecting aircraft operations, and number and type of aircraft;
- Minimum flight disturbances to identified noise sensitive areas around the base;
- Coordinated planning activities with local community planning agencies;
- Published procedures to investigate noise complaints; and
- Effective land use control implemented to prevent incompatible development.
| Natural and Cultural Resources Management |
Focus Area
Your installation may have natural (AFI 32-7064) and cultural (AFI 32-7065) resources including forests, rivers, endangered species, historic buildings, artifacts, historic documents, and archaeological sites. All resources should be managed to assure protection and enhancement while permitting the successful accomplishment of the military mission. The following federal acts impact the management of those resources:
- Endangered Species Act
- National Historic Preservation Act
- American Indian Religious Freedom Act
- Sikes Act
- Federal Records Act
- Archaeological Resources Protection Act
- Native American Graves Protection and Repatriation Act Clean
- Water Act
Solutions:
Air Force installations that have natural or cultural resources must develop a program for restoring, improving, developing, and conserving those resources.
- Prepare and implement the Integrated Natural Resources Management Plan which addresses land management, grazing and croplands, wetlands and flood plains, forestry, fish and wildlife, and outdoor recreation;
- Maintain liaison with other federal, state, and local agencies and develop cooperative agreements to implement coordinated, multipleuse natural resources programs (agencies include your state forestry office, state game and natural resources department, and the U.S. Fish and Wildlife Service);
- Prepare and implement a Cultural Resources Management Plan which addresses archaeological sites and historic buildings (including those of the Cold War period 1946 - 1989), as well as museum collections, artifacts, and historical documents; and
- Develop programmatic agreements and maintain liaison with regulatory agencies (e.g., State Historic Preservation offices and Advisory Council on Historic Preservation).
Measuring Success:
- Actions have been implemented to protect and enhance the base's natural resources;
- People are properly trained;
- Working relationships with federal, state, and local agencies are strong;
- Cultural resources are protected and preserved; and
- The Cultural Resources Management Plan is current and is being executed
Pollution Prevention (AFI 32 - 7080) is the use of materials, processes, or practices that reduce or eliminate the creation of pollutants or wastes at the source. The Air Force goal is to reduce pollution to as near zero as feasible.
The Pollution Prevention Act established a hierarchy of pollution prevention practices beginning with:
- Source reduction as the primary means;
- Recycling alternatives after reduction options have been examined;
- Treatment after recycling has been determined unfeasible; and
- Disposal as the last resort.
Air Force policy requires all bases to prepare a Pollution Prevention Management Plan to address:
- The process required to run a pollution prevention program;
- The projects requiring funding;
- The road map to achieve the Air Force goals; and
- The actions required to execute the program.
The emphasis of the plan should be on source reduction and recycling instead of end of pipe treatment, and should focus on the following program elements:
- Ozone Depleting Substances;
- Hazardous Material Management;
- Solid Waste Reduction; and
- Purchasing Environmentally Preferable Products;
| Ozone Depleting Substances |
Ozone Depleting Substances (ODSs) break down the earth's stratospheric ozone layer. Examples of ODSs include chlorofluorocarbons (CFCs) and hydrofluorocarbons used in air conditioning, refrigerant systems, cleaning solvents, and aerosol sprays. Halon, a fire suppressant, is also an ODS.
The Clean Air Act, together with the Copenhagen-amended Montreal Protocol, provides an accelerated schedule for phasing out the production of ODSs, and also limit the consumption of ODSs. The National Defense Authorization Act of 1993 put specific restrictions on contracts that use or depend on ODSs, and requires certain reporting and stockpiling procedures.
Solutions
- Prohibit the purchase of class I ODSs unless approved by waiver;
- Identify existing ODSs that could be reallocated;
- Identify and give priority to ODS uses based on mission impact;
- Convert mission critical systems to non-ODSs; and
- Develop Refrigerant Management and Halon 1301 plans to conversion of systems to non-ODS substitutes.
Measuring Success:
- Reduce dependence on ODSs to as near zero as possible.
| Hazardous Material Management |
Efficient hazardous material management is integral to your success in meeting Air Force pollution prevention goals. There are three main elements of hazardous material management:
- Hazardous material (HM) control through the hazardous material pharmacy;
- Compliance with Executive Order 12856 and Toxic Release Inventory (TRI) reporting; and
- Modifying technical orders and military specifications and standards (MILSPECs/MILSTDs) to use less hazardous materials.
The hazardous materials pharmacy can assist you in reducing hazardous waste and in the purchase and use of hazardous materials. Your pharmacy can accomplish the following:
- Act as the single point of control for HM;
- Only authorize HM purchases for the quantity required;
- Record purchase data for reporting and management;
- Collect unused HM for reissue to authorized users; and
- At your option, manage hazardous waste and disposal.
Executive Order 12856 established a requirement for facilities using HM to report releases over established threshold levels. Submitting a Toxic Release Inventory (TRI) report meets this requirement.
There are many weapon systems technical orders and MILSPECs/MILSTDs that require the use of hazardous substances to perform required functions. With hazardous waste disposal costs growing at an exponential rate, the Air Force is continually seeking nonhazardous alternatives. Baselevel personnel can help identify opportunities where new processes or materials would reduce or eliminate hazardous waste, resulting in cost savings and a cleaner environment.
Solutions
- Institute a hazardous materials pharmacy concept;
- Establish procedures for TRI reporting;
- Encourage base personnel to submit recommended process or material changes to MILSPECs/ MILSTDs that would reduce or eliminate use of hazardous materials;
- Conduct Opportunity Assessments to help minimize hazardous waste; and
- Ask for assistance from the Air Force Center for Engineering and the Environment (AFCEE).
Measuring Success:
- Reduce hazardous waste disposal by 25% by the end of 1996 and by 50% by the end of 1999, from a 1992 baseline.
Focus area
The Air Force generates over one million tons of solid waste per year. This waste includes nonhazardous trash, rubbish, garbage, liquids, sludge, medical, and pathological wastes. Much of this material can be recycled or composted. The Resource Recovery and Recycling Program, consisting of recycling and composting operations, is the commander's primary tool for reducing municipal solid waste. The qualified recycling program may consist of up to four parts:
- Appropriated funded activities;
- Nonappropriated funds (NAF) activities;
- Army/AF Exchange Service section; and
- Defense Commissary Agency.
Executive Order 12873, together with Resource Conservation and Recovery Act (RCRA), requires the recycling of certain materials if more than a specific amount is generated, and requires goals to be established for solid waste prevention and recycling.
The DoD established a recycling policy to accomplish the following:
- Contribute to pollution prevention and conservation by reducing, reusing, recovering, and recycling;
- Divert materials from the solid waste stream;
- Procure products made of postconsumer and other recycled materials;
- Procure new materials which can be recycled; and
- Require each base to establish, or be associated with, a qualified recycling program.
Solutions
- Develop a Solid Waste Management Program;
- Implement a Resource Recovery and Recycling Program that includes:
- a Qualified Recycling Program;
- an onbase composting facility or participation in a regional program; and
- Use Opportunity Assessments to achieve further reductions.
Measuring Success:
- Reduce solid waste disposal by 50% by the end of 1999, from a 1992 baseline.
Focus area
The Air Force applies over 200,000 pounds of pesticides each year. These pesticides pose both a human health and an environmental quality risk. The human health risk issues include worker protection, food use, drinking water contamination, and exposure to pesticide residues in the home and the work place. The environmental quality risk refers to the degradation of a variety of resource values, including ground and surface water, endangered species, fish, and wildlife, including birds and nontarget domestic plant and animal species.
The use of pesticides provides both a health and an aesthetic benefit. An effective integrated pest management program balances these risks and benefits. This program is a management approach using monitoring to determine if and when treatments are needed, and to use the safest means possible to prevent damage or annoyance.
Herbicides are the largest pesticide use group in the Air Force and the one area of pesticide use where the primary justification is aesthetics and not the protection of human health.
Solutions
- Institute an effective integrated pest management program.
Measuring Success:
- Reduce the amount of pesticides applied annually by 50% by the end of FY 2000, from an FY 1993 baseline.
| Environmentally Preferable Products |
Focus area
Environmentally Preferable Products (known also as the Affirmative Procurement Program) are items containing postconsumer or recycled materials. The Air Force is committed to procuring these products (paper, concrete/cement with flyash, rerefined lubricating oil, retread tires, and building insulation products), listed by the EPA as "Guideline Items."
RCRA, coupled with EO 12873, requires the development of an affirmative procurement program. All programs must include the following four elements:
- A preference program;
- A promotion plan;
- Procedures to obtain and verify estimates and certifications of the content of material; and
- An annual review and monitoring process.
Your contracting office may choose not to purchase a guideline item containing recovered materials if one or more of the following applies:
- The item's price is unreasonable;
- Applying minimum content standards creates inadequate competition;
- Obtaining designated items results in unusual and unreasonable delays; and
- Items do not meet all reasonable performance specifications.
Solutions
- Purchase Environmentally Preferable Products (specifically, EPA Guideline Items).
Measuring Success:
- Environmentally Preferable Products are regularly used in day-to-day operations.
| Environmental Compliance Assessment and Management Program |
The Environmental Compliance Assessment and Management Program (ECAMP) is a comprehensive self evaluation and program management system for achieving, maintaining, and monitoring compliance with environmental laws and regulations (AFI 327045). ECAMP is a management tool to help you manage your environmental programs more effectively by helping you identify and correct deficiencies before they result in violations or enforcement actions by regulatory agencies.
The primary objectives of the ECAMP are to accomplish the following:
- Improve Air Force environmental management worldwide to ensure we address past, present, and future environmental concerns; and
- Build budgets for environmental compliance requirements.
ECAMP utilizes both internal and external evaluations. Internal evaluations are the foundation of ECAMP and are normally conducted by installation personnel annually, except during years when external evaluations are conducted. Team members should have appropriate technical backgrounds and be properly trained to function effectively. MAJCOMs conduct external evaluations at least once every 3 years and the team may be composed of personnel from various organizations and bases.
Problems or deficiencies noted during the ECAMP can be corrected on the spot, and noted in the findings. Other deficiencies may require a corrective action plan that becomes part of the ECAMP report. Required construction projects or other finding needs are also identified and programmed for execution in the Office of Management and Budget (OMB) A106 budget process. The Work Information Management System Environmental Subsystem (WIMSES) tracks the status of all findings, for both the installation and the MAJCOM Environmental Protection Committee (EPC) until resolved or closed out.
Solutions
- Request MAJCOM have HQ AFCEE Regional Compliance Offices prepare Enforcement Vulnerability Analyses prior to external ECAMPs to detail EPA enforcement trends;
Measuring Success:
- A rigorous ECAMP program;
- Notices of Violation (NOVs) trend is going in the right direction;
- NOVs received do not duplicate ECAMP findings.
Specific accounts have been established for Restoration, Compliance, Prevention, and Conservation. Major sources of funding are:
- Environmental Restoration Account (ERA);
- Operation and Maintenance Funding (O&M); and
- Military Construction (MILCON).
AFI 327001, Environmental Budgeting, provides funding guidance and includes examples of projects, services, and exclusions. For example, Compliance, Conservation and Prevention programs have designated levels to validate funding, as follows:
- Recurring requirements: Operations and Services (O&S) annually occurring "must do" items such as hazardous waste disposal, permit fees, sampling and analysis, among others.
- Nonrecurring requirements: Three classification levels for the U.S., its territories and possessions:
- Level I, Noncompliance projects necessary to correct conditions currently not in compliance with Federal, state, or local environmental laws;
- Level II, Prevent Noncompliance projects required to meet compliance deadlines where work or funding requires lead times greater than a fiscal year; and
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- Level III, Beyond Compliance projects to enhance the environment beyond legal requirements.
Air Force Policy is to fund all valid O&S and Level I requirements and fund all Level II requirements before their respective deadlines. Requirements are valid only when tied to an environmental law. Funding consideration for all Air Force environmental projects requires that they be in the WIMSES environmental budget system (A 106). The budget system is used to validate all environmental projects.
Solutions Once a problem that violates a legal standard is identified (e.g., exceeding the water discharge permit), perform necessary studies required for project justification in order to obtain funding, such as:
- Problem Identified: Wastewater flows exceed permitted levels during rainy season.
Steps: conduct and infiltration inflow study or sewer system evaluation survey.
Action: Program upgrades and repairs to sewer system.
- Problem Identified: Wastewater treatment plant sludge has to be disposed as hazardous waste because it contains heavy metals.
Steps: Conduct a wastewater characterization study.
Action: Construct or modify sludge treatment.
- Problem Identified: All underground storage tanks must be identified and upgraded by 31 Dec 1998.
Steps: Perform a UST inventory.
Action: Program tanks for removal, replacement and installation of leak detection systems.
- Problem Identified: In order to comply with the Clean Air Act permit you must reduce your overall emissions.
Steps: Complete Air Emissions Inventories surveying emission sources and quantity.
Action: Program projects to eliminate or reduce emissions in degreasing, plating, fueling, or paint stripping operations.
Established standards earn the authorization for your environmental organization. These standards are primarily driven by the size and complexity of your environmental programs. Some installation commanders have supplemented their environmental staff with other wing manpower to quickly bring deficient program elements to standard. However, your authorizations should be sufficient to maintain effective environmental programs. You may seek variances to manpower authorization through your manpower office based on installation-unique standards.
Recognition
An important part of team building is recognizing your outstanding performers. You are encouraged to develop a local awards program and to submit nominations for the Air Force environmental awards. Award categories are the General Thomas D. White Awards (in honor of the former Air Force Chief of Staff who was an avid naturalist and founder of the Air Force Environmental Awards program), additional Air Force Environmental Awards established after the Thomas D. White Awards and other non-Air Force environmental awards.
The General Thomas D. White Awards:
- Environmental Quality Award - winner nominated for the Secretary of Defense Environmental Quality Award;
- Natural/Cultural Resources Management Award - winner nominated for the Secretary of Defense Natural/Cultural Resources Management Award;
- Environmental Quality Award for Overseas Installation;
- Natural/Cultural Resources Management Award for Individual Excellence - winner nominated for the Secretary of Defense Individual Natural/Cultural Resources Management Award;
- Individual Award for Environmental Quality - winner nominated for the Secretary of Defense Individual Environmental Quality Award; and
- The Environmental Planning Award for Individual Excellence.
AFI 36-2817, Civil Engineer Awards Program, lists criteria for additional Air Force environmental awards and other non-Air Force awards . You should receive "call letters" from your MAJCOM for submitting award packages.
| The Environmental Program In Foreign Countries |
The Air Force complies with applicable international agreements and with the Air Force policy (AFI 32 - 7006) derived from the DoD Directive, Policy for Establishing and Implementing Environmental Standards at Overseas Installations.
Focus Area.
- Achieve and maintain environmental quality abroad to ensure long term access to air, land, and water needed to protect US interests;
- Maintain environmental quality while conducting day-to-day operations;
- Comply with DoD Final Governing Standards (FGS). Where FGS have not been completed or are not available, comply with Overseas Environmental Baseline Guidance Document (OEBGD);
- Cleanup sites contaminated by Air Force Activities to:
- Sustain current operations;
- Eliminate known imminent and substantial dangers to human
- health and safety; and
- Comply with applicable international agreements;
- Implement Pollution Prevention measures
Although foreign country standards are generally not enforceable on DoD installations, written findings are accepted, and corrective action is taken if the condition is out of compliance with the FGS (or OEBGD), or poses an imminent and substantial danger to human health and safety.
Funding for non-recurring requirements are different from those in the United States, its territories and possessions. In foreign countries, Level I projects and services accomplish the following:
- Correct conditions out of compliance with the DoD Final Governing Standards (or OEBGD);
- Restore contaminated sites posing imminent and substantial endangerment to human health and safety; and
- Restore contaminated sites as needed to sustain current operations.
Level II projects and services accomplish the following:
- Address conditions which in the future will be out of compliance with the requirements of international agreements; and
- Address conditions which in the future will be out of compliance with the requirements of the Final Governing Standards (or OEBGD), as applicable.
Solutions
- Use environmental O&M funding resources for compliance/cleanup/pollution prevention activities (other than MILCON and NATO eligible funding);
- Establish ECAMP;
- Work with DoD Executive Agent for environmental matters in designated countries; and
- Follow AFI 32-7006, Environmental Program in Foreign Countries.
Measuring Success:
- No notices of violation equivalents from local/host nation governments;
- Continued alliance with local and host nation governments; and
- Prompt resolution/programming.
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