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Introduction The Air Force is continually looking for new and innovative ways to prevent and reduce pollution to the environment. Pollution prevention (P2) can be defined as a process designed to curtail the use of hazardous materials and the release of pollutants into the environment to "as near zero" as is technically and economically feasible. Many federal, Department of Defense (DoD), and Air Force guidance documents require the implementation of P2 practices as a means of preventing future pollution that would eventually require remediation, and to reduce the burden of complying with various environmental regulatory requirements. One of the principal P2 practices employed is the Pollution Prevention Opportunity Assessment, also known as PPOA or P2OA. The P2OA is a systematic procedure that is used to identify opportunities for reducing or eliminating the generation of waste, thereby lessening potential adverse impacts to the environment. The final outcome of a P2OA should be the identification of all pollutant sources, examination of the total waste generation by type and volume, and finally, a determination of the most economical and practical options. Several policy memorandums issued by the Office of the Air Force Civil Engineer, and the planned update of Air Force Instruction (AFI) 32-7080, "Pollution Prevention Program," have cast P2 as the primary method by which the Air Force will achieve compliance with environmental program requirements. Conducting P2OAs is seen as an important and integral component of this "compliance through pollution prevention" mandate. The purpose of this fact sheet is to provide Air Force personnel with a basic understanding of the P2OA process. Included is a summary of the policy drivers for conducting P2OAs, general guidance on how to set-up and conduct an assessment, and sources of additional information and assistance. Important Terms Alternatives: Ways of reducing adverse effects of hazardous materials (HAZMAT). Alternatives (also called opportunities), as applied to HAZMAT decision-making, include, but are not limited to:
Compliance Site: Any regulated facility, regulated process, or a discharge to a regulated facility or process. Compliance sites include any location under Air Force control where the activity is subject to any current or future known requirements levied by federal, State, and local statutes and regulations; Executive Orders; Department of Defense (DoD) and Air Force policies; the Overseas Environmental Baseline Guidance Document (OEBGD), Final Governing Standards (FGS), and international agreements. Cost Factor: The expense and the cost avoidance associated with a hazardous material that may be reduced to monetary terms, including future liability. Cost factors refer to direct and indirect costs attributable to HAZMATs that are encountered in any type of operation, such as acquisition, supply, engineering controls and disposal. Economic Analysis: An evaluation of the costs associated with the use of HAZMAT and potential alternatives. Although several computer-based tools are available for completing an economic analysis, there is no single analysis process that will cover all situations. Economic analyses should be guided by the basic principles of economics and informed judgement. Hazardous Materials Reduction Prioritization Process (HMRPP): The HMRPP provides a formalized way for installations to identify weapon system-driven HAZMAT reduction needs. This enables Major Command (MAJCOM) and installation priorities to drive weapon system HAZMAT reduction efforts. The weapon system HMRPP is not a separate requirements process. Rather, it integrates HAZMAT reduction requirements into the existing weapon system requirements, identification, prioritization, funding, and execution processes. Additional information on the HMRPP can be found in PRO-ACT's Air Force Weapon System HMRPP Fact Sheet. Life Cycle Costs: An evaluation of the costs associated with the use of HAZMAT and potential alternatives over the life of the investment or the hazardous material. The analysis is not a specific step-by-step procedure, but must be guided by basic principles and informed judgement. Life cycle cost also incorporates the amortized annual cost of a product, including capital costs, installation, operating, maintenance and disposal costs discounted over the lifetime of the product. Life Cycle of Hazardous Material: The period starting when the use or potential use of HAZMAT is first encountered, and extending as long as the actual material is in use, or its after effects (such as discarded residue in a landfill). In the case of weapons systems acquisition, the life cycle starts when the system is first envisioned. Effects of the use of HAZMAT on later operations and maintenance are also to be considered. Mission Critical System: A system whose operational effectiveness and operations suitability are essential to successful completion. If this system fails, the mission will not be completed. Such a system can be auxiliary or supporting as well as a primary system. Source reduction: Any practice that reduces the amount of a hazardous substance, pollutant, or contaminant entering the waste stream or otherwise released to the environment prior to recycling, treatment or disposal, and that reduces the hazards to public health and the environment. Source reduction may include, but is not limited to:
Waste Minimization: The reduction of the quantity or toxicity of a residual waste that is generated and subsequently processed, stored, or disposed. Its reduction minimizes present and future threats to human health and the environment. Drivers for Conducting P2OAs The need to conduct P2OAs is derived from AFI 32-7080; however, its roots are found in the Pollution Prevention Act and two Executive Orders that implement the provisions of the Act for federal agencies. Pollution Prevention Act (PPA) [42 US Code . 13101, et seq.]. Congress passed the PPA in 1990 in order to establish a national policy whereby pollution should be prevented or reduced at the source rather than controlled after its production. The law requires specific action on the part of the Environmental Protection Agency (EPA) for setting up requirements in environmental protection programs, and the establishment of source reduction programs. Executive Order (EO) 12856, Federal Compliance with Right-to-know-laws and Pollution Prevention Requirements, 6 August 1993. This EO requires the EPA administrator to promote source reduction in compliance with the PPA. It encourages companies to conduct their facility management and acquisition activities so that quantities of toxic chemicals entering any waste stream (including any release to the environment) are reduced as expeditiously as possible through source reduction. Further, the EO states that waste generated should be recycled to the maximum extent possible, and any remaining wastes are stored, treated or disposed of in a manner protective of public health and the environment. The federal government, the largest single consumer in the Nation, was targeted to lead the way in this endeavor. The EO proposes that the federal government should become a leader and set the example in the field of pollution prevention through the management of its facilities, its acquisition practices, and in supporting the development of innovative P2 programs and technologies. Executive Order 13101, Greening the Government through Waste Prevention, Recycling, and Federal Acquisition, 14 September 1998. This EO serves to incorporate the concepts of waste prevention and recycling into daily operations, and to promote federal government preference and demand for environmentally preferable products, especially those containing recovered and recycled materials. Further, this EO reinforces the philosophy found in the PPA that if pollution cannot be prevented, it must be recycled, if not prevented or recycled, it must be treated in an environmentally safe manner. Disposal is viewed as the last resort. "Pollution Prevention to Achieve Compliance," HQ USAF/ILEV Memorandum, 20 August 1997. This memorandum reemphasizes the Air Force's commitment to "compliance through pollution prevention" by stating that compliance requirements drive both traditional compliance (end of pipe treatment and disposal options) and pollution prevention. The memorandum also reaffirms that the environmental management hierarchy must be applied when developing solutions for every potential compliance requirement. Air Force Policy Directive (AFPD) 32-70, Environmental Quality, 20 July 1994. This directive implements the provisions of the PPA and Executive Order 12856. In establishing the Air Force's Environmental Quality Program, it directly incorporates the PPA's charter of preventing future pollution by reducing the use of hazardous materials at the source. Air Force Instruction 32-7080, Pollution Prevention, 12 May 1994. This AFI implements the pollution prevention portion of the Air Force Environmental Quality Program. Included within the AFI is a requirement for installations to conduct P2OAs on a recurring basis in order to assess all pollutant sources and determine opportunities for reducing or eliminating waste streams. P2OAs are to include all pollutant sources, examine total waste generation by type and volume, and determine the most economical and practical option for reduction. Results of the P2OAs are to be included in the installation's Pollution Prevention Management Action Plan (P2 MAP). Draft Air Force Instruction 32-7080, Compliance Assurance and Pollution Prevention, undated. This update to the current AFI 32-7080, which is scheduled for release in 2000, specifies the use of the HMRPP for identifying and advocating changes to processes controlled by Technical Orders (T.O.s), and the use of process-specific P2OAs for processes not under T.O. control. It will require P2OA evaluations for a minimum of 4 percent of installation compliance sites each year beginning with the highest burden sites. As with the current version of AFI 32-7080, the draft requires installations to maintain a P2 MAP and to update it on an annual basis. Air Force Instruction 32-7086, Hazardous Materials Management, 1 August 1997. Among its many provisions, this AFI establishes procedures and standards that govern the management of hazardous materials in the Air Force including the establishment of the Hazardous Materials Management Process (HMMP), and the creation of the HMRPP described above. The Waste Management Hierarchy The Pollution Prevention Act established a hierarchy for waste management that has been incorporated by the Air Force into its Environmental Quality Program. This hierarchy should be used in selecting potential pollution prevention opportunities and calls for:
Treatment and disposal of wastes are complex topics that are beyond the scope of this fact sheet. Readers are encouraged to discuss these "last resort" options with a representative from their installation Environmental Management Flight. Conducting a P2OA The pollution prevention opportunity assessment is an environmental analysis tool used to evaluate processes and operations. The goal of the assessment is to:
Step 1: Identify and Select the Process(es) The first step in performing a P2OA is to select the process(es) you wish to evaluate. P2OAs can be performed at the installation and unit (e.g., squadron, shop, etc.) levels and encompass a large number of processes, or they can be focused down to a specific process. The best place to begin is with the highest priority process(es) based on command, regulatory, and environmental priorities (Note: the compliance site rankings required under the proposed update to AFI 32-7080 will encompass these priorities and thus help in the process selection). If there are several such sites, it may be best to begin with a process that generates a waste that is significantly more hazardous than other processes, or one that generates a higher quantity of waste than another. An important consideration in identifying and selecting processes is to be sure and keep the scope of the assessment at a manageable level. Trying to evaluate too many processes all at the same time can strain resources and reduce the overall quality of the assessment. Step 2: Select the P2OA Team Once the process(es) have been selected, it is time to build the assessment team. The team should consist of a variety of individuals with different backgrounds and skills, and ideally should contain a balanced mixture of personnel from the shop(s) responsible for the process(es) [including workers, supply staff, and supervisors], Environmental Management (EM), Bioenvironmental Engineering Services (BES), and the Hazardous Material Pharmacy (HAZMART). If multiple processes are being evaluated across several units, or even within the same shop, it may be beneficial to build a core team of personnel from EM, BES, and the HAZMART, and then supplement this core team with personnel from the shop responsible for each process. It is also quite useful to have someone on the team who is not an expert on the process, but who has successfully implemented some P2 options in their own shop. An important consideration in selecting the team is time. Conducting a P2OA on even one process can take a significant amount of effort once the time needed to collect the background information, identify alternatives, etc. is factored in. Team members need to have the commitment of their supervisors to see the assessment through to its completion. An alternative approach to building a P2OA team is to hire a responsible environmental consulting firm to conduct the assessment. This can be a successful and cost effective alternative, particularly when there is a need to assess processes across multiple units. Please remember that each shop will be required to devote time to answering questions regarding individual processes, even if an outside firm is hired. Step 3: Examine the Process(es) To examine the process it is important to characterize all aspects of the process or operation including sequencing of the steps in the process, waste generation patterns, material and energy consumption, costs, manpower, and reliance on hazardous/toxic chemicals. This can be accomplished by conducting site visits, interviewing shop staff, reviewing shop records, and collecting specific information concerning the process. Include visits to the shop storage areas, waste storage areas, and equipment areas. During this process, it is important to identify impacts that the process(es) and related wastes have on the air, water, and land. There can be a tendency to evaluate processes by first identifying the waste streams and then tracing them back to where they are introduced into the process. However, in doing this it is easy to miss materials that are consumed within the process including water and electricity. A better method is to start at the beginning of the process and then trace it step by step until its conclusion. Prior to visiting the shop(s), it is important to gather the following information:
Step 4: Establish a Baseline All P2OAs require a baseline from which to conduct comparisons against potential alternatives. The first step in preparing the baseline is the creation of a process flow diagram. The diagram should describe the steps in the process, and identify all of the materials used and the wastes generated. The next step is to assign material and waste quantities to the diagram. These quantities must balance in the process; in other words, whatever goes into the process must come out either as part of a product or as a waste. It is also important to note in the diagram whether a Technical Order or Military Specification requires any of the materials used as this may limit potential alternatives. Step 5: Identify Opportunities This step in the assessment process can be the most difficult. Once everyone on the team has reviewed the process flow diagram, it is typical to have a "brainstorming session" in which the entire process is reviewed and ideas are solicited as to how the process could be changed. It is important at this stage not to discount any idea as being too outlandish; alternatives that are not truly feasible will eventually be removed from consideration. Once a list of potential opportunities has been prepared, research needs to be conducted to obtain information necessary to evaluate them and make final selections. There are a number of excellent resources available for finding information on potential opportunities. HQ AFCEE/EQ has prepared several P2OA Model Shop Reports pertinent to processes performed by Civil Engineering, aircraft maintenance organizations, pesticide management shops, and others. The Environmental Protection Agency (EPA) also has several helpful references that can be accessed from their World Wide Web (WWW) site at http://www.epa.gov/. The Defense Environmental Network and Information exchange (DENIX) is another helpful reference and is found at the WWW site http://www.denix.osd.mil/. PRO-ACT is also available to assist AF organizations with researching potential alternatives. Step 6: Rank opportunities The purpose in ranking opportunities is to see if they merit further consideration for implementation. The team needs to establish a standard set of criteria, based on the existing process, and against which it will evaluate the list of P2 opportunities. Selecting the criteria is an important task because they need to provide a consistent basis for justifying and funding future projects. Typical criteria include:
Post P2OA Activities The P2OA team's work is essentially finished upon completion of the decision matrix and the ranking of the potential opportunities. From this point, the focus shifts primarily to those individuals responsible for advocating environmental initiatives. These individuals will take the recommendations from the team and develop the P2 MAP for implementing selected opportunities. Once the P2MAP has been developed, environmental program managers will need to seek funding for their projects. Readers are encouraged to review PRO-ACT's "Funding Air Force Environmental Projects" Fact Sheet for additional information and resources on this subject.
 For More Information. HQ AFCEE/EQ, in partnership with HQ AETC/LG-EM and other MAJCOM representatives, has developed the Shop Level Pollution Prevention Course. The course meets the training requirements in AFI 32-7086 and includes information on conducting P2OAs. The course is available on the WWW at http://www.afcee.brooks.af.mil/eq. Contact Ms. Tamee Tennison, HQ AFCEE/EQP, DSN 240-4670, Tamee.Tennison@hqafcee.brooks.af.mil, for assistance with the course or for assistance with other environmentally related training needs. PRO-ACT can provide copies of HQ AFCEE/EQ's P2OA Model Shop Reports, as well as individual support to AF customers for researching potential opportunities. Contact PRO-ACT at DSN 240-4215, or submit research requests through the WWW at http://www.afcee.brooks.af.mil/pro_act/pro_acthome.asp. References
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