Improving Military Solid Waste Management: Economic and Environmental Benefits

Published by the Government Accountability Office on 1977-06-02.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                         DOCUMENT RESUME
02464 - [A612599]3

Improving Military Solid Waste 1anagement: Economic and
Environmental Benefits. LCD-76-J35; B-166506. June 2, 1977. 32
pp. + 5 appendices (11 pp.).
Report to the Congress; by Elmer B. Staats, Comptroller General.
Issue Area: Facilities and Material Management: Operation and
    Maintenance of Facilities (708); Materials: Renewing
    Resources (1810);Environmental Protection Programs: Solid
    Waste Disposal and Resource Recovery (2206).
Contact: Logistics and Communications Div.
Budget Function: National Defense: Department of Defense -
    Military (except procureenut & contracts) (051).
Organization Concerned: Department of Defense; Environmental
    Protection Agency.
Congressional Relevance: House committee on Armed Services;
    Senate Committee on Armed Servi-es; Congress.
Authority: Resource Conservation and Recovery Act (90 Stat.
    2795). Resource Recovery Act of 1970. Solid Waste Disposal
    Act of 1965. National Environmental Policy Act of 1970.

         The Department of Defense (DOD) can save money and
protect the environment by improving it. solid waste management.
Findings/Conclusions: DOD and other Federal agencies are
responsible for the annual disposal of 32 million tons of solid
waste. Low priority has been given solid waste management, and
the absence of DOD deadlines for complying with the
Environmental Protection Agency's guidelines contribute to the
problem. There has been only minimal recovery of recyclable
materials to date. As of June 1975, military i.nstallations
recycled 4.2% of their waste material in FY 75, compared with
the natio.al average of 6%. There are both economic and
environmental benefits relates to energy recovery from solid
waste. However, military management has been slow in recovery
programs because most bases have sufficient landfill areas.
Recommendations: The Secretary of Defense should publish
guidance for determining whether and under what circumstances
bases should initiate energy recover: programs; issue
specifications to the services for preparing energy recovery
systems proposals; and designate a focal point for reviewing
such project proposals and establishing priorities for their
funding. (Author/DJM)


Improving Military Solid
Waste Management: Economic
And Environmental Benefits
Department of Defense

Local governments consider solid waste a ma-
jor urban problem, but, with diminishing
natural resources and increasing land and dis-
posal costs, alternative uses for solid waste
make it potentially valuable to the Nation.
Rescurce recovery legislation requires Federal
agencies to comply with all Federal, State,
and local laws. The Department of Defense
and other Federal agencies are responsible for
annual disposal of about 32 million tons of
the 135 million tons of community and busi-
ness waste. This report discusses how the
Department is meeting its responsibilities in
disposing of solid wastes.


                           WASHINGTON, D.C.   204


To the President of the Senate and the
Speaker of the House of Representatives
     This is our report on Department of Defense efforts to
comply with the Resource Recovery Act of 1970 and the En-
vironmenLal Protection Agency's impl-.cnt.ng guidelines.

     A previous report issued on October 26, 1972 (B-166506),
also dealt with ways in which Federal agencies could exer-
cise greater leadership in the nationwide effort to improve
solid waste management practices.

     We made the review pursuant to the Budget and Account-
ing Act, 1921 (31 U.S.C. 53), and the Accounting and Audit-
ing Act of 1950 (31 U.S.C. 67).

     We are sending copies of this report to the Director,
Office of Management and Budget; the Secretary of Defense;
and the Administrator, Environmental Protection Agency.

                               Comptroller General
                               of the United States
                                      ENVIRONMENTAL BENEFITS
                                      Department of Defense

             The Department of Defense can save money and
             better protect the environment by improving
             its solid waste management. In this report
             GAO recommends steps toward reduced pollution,
             higher land use, and greater energy recovery.
             The Department has programs in progress to
             accomplish the recommendations.

             Although the military services have 'reduced
             pollution by eliminating most open burning
             and dumps, more stringent controls over on-
             and off-base landfills are needed to keep
             track of landfill, uses and to prevent leach-
             ing into ground and surface water.
             The low priority given solid waste management
             and the absence of Department of Defense dead-
             lines for complying with Environmental Protec-
             tion Agency guidelines have contributed to the
             problems. The Department's October 1976 direc-
             tive established compliance deadlines.
             For better leadership in solid waste manage-
             ment, the Secretary of Defense should require
             the service Secretaries to establish periodic
             environmental team inspections of installa-
             tion disposal practices and prescribe enforce-
             ment procedures for correcting reported vio-

             The Department said that the services' pro-
             cedures provide for inspections above the
             installation level and appropriate followup
             to correct deficiencies.

             A Defense official told GAO that the services
             are drafting regulations implementing the
             October 1976 directive, including procedures
             to insure correction of identified deficien-
             cies.  (See p. 15.)

Tear Sh.j. Upon removal, the report    i                   LCD-76-345
cover date should oe noted hereon.
 Recycling of waste materials can
 benefits in lower disposal costs, produce
 t.on of natural resources, and reduced
 lution. As of June 1975, Defense         pol-
 showed that installations recycled records
                                     4.2 per-
 cent of their waste materials in
 1975 compared with the national   fiscal  year
 average of about 6 percent.
 The installations' recycling rate
 to improve during fiscal year 1977 will start
                                       as they
 begin compliance with Environmental
 tion Agency's materials recovery       Protec-
 container guidelines.              and  beverage
                          (See p. 17.)
 Competition with other installation
 for resources, inability to recover activities
 and fluctuating markets for recyclable costs,
 terials held bacK. recycling programs. ma-
GAO proposed that the Secretary
                                 of Defense
require the Secretaries or the Army
Force to conduct surveys, as the      and A r
doing, to decide on the conditionsNavy  is
recycling programs practical and     that make
each installation's potential for to  determine
materials from solid waste.
The Department said that its October
directive will apply the Environmental1976
tection Agency guidelines Defense-wide, Pro-
cluding the conduct of appropriate
The directives's policy is designed surveys.
                                     to pre-
vent competition with commercial
and requires participation in joint
gional civilian systems when possible re-
lieu of separate Defense systems.       in

The Department's current directive
ongoing test of beverage container and its
will improve the recycling of materials
its installations.                      at
                    (See p. 22.)
Tie economic benefits of energy
                                 recovery from
solid waste are the value of the
duced, improved materials recoveryenergy pro-
ical separation, and the savin-s    by mechan-
                                  in disposal

          costs. The environmental benefits are the
          potential for decreasing air and water pol-
          lution and the reduced land area needed for

          Service officials have been reluctant to begin
          recovery system projects partly because of
          technology problems but mainly because most
          bases have sufficient landfill areas avail-
          able.  (See p. 23.)
          The Army has programed two energy recovery
          facilities, the Air Force one; the Navy, on
          the other hand, has built one facility, is
          constructing another, and has designed three
          others.  (See pp. 26 and 27.)
          Installations that considered such systems
          generally planned only for their own needs
          without considering joint or regional sys-
          tems that may be more economical. Only the
          Navy issued some guidance for considering
          energy recovery, but the Navy could also
          improve coordination and review of the in-
          dividual installations' plans for recovery
          systems. (See pp. 6 and 29.)
          Defense can help insure that the   most bene-
          ficial systems are considered by   issuing
          guidance for feasibility studies   and coor-
          dinating the requirements of the   various

          The Secretary of Defense should:

          -- Publish guidance for determining whether
             and under what circumstances bases should
             initiate energy recovery projects.

          -- Issue specifications to the services for
             preparing energy recovery systems pro-

          --Designate a focal point for reviewing
            such project proposals and establishing
            priorities for their funding.
          Although the Department commented on the
          prudence of installing several types of

ehalr                          iii
energy recovery systems, it did not say
whether it intended to take these actions.
GAO believes that such action is necessary
for an orderly and economic selection of
energy recovery systems. (See p. 30.)


DIGEST                                                    i


             OF RESOURCE RECOVERY                         1
               Costs                                      2

               Legislation                                3
               EPA guidelines                             4
               DOD policy and guidelines                  5

               Status of pollution controls               7
               Program responsibilities decentralized    13
               Surveys and audits                        14
               Conclusions                               15
               Recommendation, agency comments, and
                 our evaluation                          15

               Problems in recovery of recyclable
                 materials                               17
               Conclusions, agency comments, and
                 our evaluation                          22

             CAN HELP                                    23
               Benefits of energy recovery systems       23
               Problems in recovery of energy from
                 refuse                                  24
               Direction of effort by the services       25
               Conclusions                               30
               Recommendations, agency comments, and
                 our evaluation                          30

   6       SCOPE                                         32

   I        Letter dated January 25, 1977, from the
              Assistant Administrator for Planning
              and Management, Environmental Protec-
              tion Agency                                33
APPENDIX                                           Page

   II      Letter dated January 19, 1977. from
             the Assistant Secretary of Defense
              (Installations and Logistics)         34

  III      Glossary on solid waste                   40

   IV      EPA analysis of 1974 postconsumer net
             solid waste                             42

      V    Principal officials responsible for
             administering activities discussed
             in this report                          43


DOD        Department of Defense

EPA        Environmental Protection Agency

GAO        General AccountinC Office
                          CHAPTER 1


     Local governments consider solid waste a major urban
problem, but in today's environment of diminishing natural
resources and increasing land and disposal costs, solid
waste is potentially very valuable to the Nation.   Solid
waste consists of garbage, refuse, sludge, and other material
discarded from industrial, commercial, and community activi-
ties. This report discusses postcornsumer wavte from admin-
istrative offices and community activity in the Department
of Defense (DOD). Waste from administrati-e offices is
generated from goods bought with public (appropriated) funds
and, to some extent, private money; community activity waste
is from goods bought with a person's own money.
     In 1974, the year of latest auvailable data, homes and
businesses disposed of about 135 million tons of postcon-
sumer waste. DOD and other Federal agencies are responsible
for disposal of about 32 million tons of postconsumer waslt
     An Environmental Protection Agency (EPA) analysis of
such waste showed that over half is composed of recyclable
items, such as paper, glass, steel, and aluminum.  fJee
app. IV.)  Benefits from recovery of such items include
     -- conservation of nonreplenishable resources, such
        as steel and aluminum;
     -- less land required for waste disposal landfills;
     -- fewer environmental problems with waste disposal
        in landfills;
     -- lower disposal costs; and

     -- energy savings from recycling used materials in-
        stead of producing new ones.
     A major resource in solid waste is its value as fuel
to produce energy. DOD is recovering too little of this
energy at a time when fossil fuel costs are soaring and
the future availability of sufficient fuel is in doubt.
Also, Federal and private research has developed improved
techniques and facilities for recovering energy from solid

waste, thereby widening opportunities for economically
feasible recovery.


     The military construction funds appropriated for the
control of pollution caused by solid waste, within the
lump-sum authorizations for air and water pollution aLate-
ment, are as follows,

            Fiscal                                      Air
             year             Army         Navy        Force
                                     -   (millions)-
             1974            $ 2.6         $ -         $ -
             1975               .1          1.8          .4
             1976              5.3          2.9         1.5
             1977              6.7           .3          -
                             $14.7         $5.0        $1.9
     In addition the services plan to alter two oil-fired
boilers, enabling them to burn refuse as fuel, and to in-
stall two new boilers to be fired with refuse and coal.
projects were funded under the fiscal year 1976 and 1977 The
energy conservation investment programs at a cost of $8.7

     During fiscal years 1975 and 1976, the services spent
about $50 million and $57 million, respectively, for trash
collection and disposal in the continental United States.

                          CHAPTER 2


     The Solid Waste Disposal Act of 1965 was the first
major Federal legislation to deal with the solid waste
problem. The Resource Recovery Act of 1970 amended the
Solid Waste Disposal Act to redirect wabte management in
urban areas from disposal to resource recovery and recycling.

     The 1970 act and the President's reorganization plan of
197G gave the Environmental Protection Agency the responsi-
bility to take certain actions, such as to study resource
recovery activities, make grants for recovery systems and
improved disposal facilities, and develop guidelines for
collection. separation, recovery, and disposal systems.

     The National Environmental Policy Act, approved Janu-
ary 1, 1970, established a national policy for protecting
the environment and further recognized that the Nation
should make every effort to enhance the quality of renewable
resources and maximize recycling of depletable resources.

     The Resource Conservation and Recovery Act (90 Stat.
2795), approved on October 21, 1976, after our fieldwork
wan completed, further amended the Solid Waste Disposal
Act. The objectives of the 1976 act are to promote the pro-
tection of health and the environment and to conserve valu-
able material and energy resources by

    -- providing technical and financial assistance to
       State and local governments and interstate agencies
       for the development of solid waste management plans;
    -- prohibiting future open dumping on the land and
       requiring the conversion of existing open dumps
       to facilities that do not pose a danger to the en-
       vironment or to health;
    -- providing for the promulgation of guidelines for
       solid waste collection, transport, separation,
       recovery, and disposal practices and systems;
    -- promoting a national research and development pro-

     -- promoting the demonstration, construction, and ap-
        plication of solid waste management. resource re-
        covery, and resource conservation systems;
     -- establishing a cooperative effort among the Federal,
        State, and local governments and private enterprise
        to recover valuable materials and energy from solid
     -- requiring Federal agencies to comply with all Fed-
        eral, State, interstate. ala local requirements,
        both substantive and procedural (including any re-
        quirement for permits or reporting); and

     --requiring each procuring agency t. procure items
       composed of the highest percentaee of recovered
       materials practicable consistent with maintaining
       a satisfactory level of competition.

      In December 1973, to make certain that the Government
provides leadership in pollution control, the President
issued Executive Order 11752 on prevention, control, and
abatement of environmental pollution at Federal facilities.
This order requires Federal agencies to see that all facil-
ities under their jurisdiction are designed. constructed.
and operated so as to conform to EPA guidelines for solid
waste recovery, collection, storage, separation, and dis-

     EPA issued guidelines for
    -- incinerating and landfilling waste that cannot be
       recovered beneficially (August 1974);
    -- the establishment and use by Federal agencies of
       source separation systems to conserve resources,
       reduce waste disposal. and produce high-value in-
       dustrial raw materials (April 1976);
    -- resource recovery facilities. requiring agencies to
       determine within 1 year what actions will be taken
       to establish a resource recovery facility (September
       1976); and
    -- beverage containers, requiring Federal facilities
       that sell beverages in containers to sell them in
       returnable containers and to charge a refundable

       deposit of at least 5 cents on each refillable or
       nonrefillable container (SeptemLbr 1976).
     Besides these guidelines, EPA has periodically published
data on several technologies in various stages of development
for recovering energy from solid waste.

    In May 1973 DOD stated its overall policy to

     -- comply with environmental laws, Executive orders,
        and regulations and
     --demonstrate leadership in both abating environmental
       pollution and enhancing the environment, in ways
       that do not conflict with the security interests of
       the Nation.
     More specifically, DOD's policy for solid waste is to
(1) design, use, store, handle, and ultimately dispose of all
materials so as to mirnimize the possibility of polluting
the environment; (2) conserve resources; and (3) dispose of
waste materials to the extent practicable by reprocessing,
recycling, and reuse.
     DOD assigned responsibility to the services for identi-
fying environmental problems, taking necessary corrective
measures, and implementing its policy guidance.
     rOD Directive 6050.3 (November 19, 1974) set the follow-
ing requirements for the military services in reprocessing,
recycling, and disposing of solid waste.

     -- Quantities of solid and other waste shall be reduced
        at the source wherever possiblE.
     -- Solid and other waste materials shall be recovered
        and recycled.
     -- Joint or regional systems are encouraged when it
        will be advantageous to combine collection and/or
        processing facilities.

     -- Contracts for disposing of solid and other waste
        material shall include provisions for recycling
        whenever possible.

     DOD Directive 4165.60 (October 4, 1976) supersedes the
1974 directive, incorporates the above provisions, and adds
the following:

     -- Incorporates the EPA guidelines issued after the
        1974 DOD directive was published.
     -- Expands on various management responsibilities.

     -- Outlines the procedures for using excess proceeds
        from the recycling program to fund environmental
        improvement and erergy conservation projects.
     -- Provides for the net proceeds from the sale of
        commercial, residential, and institutional waste
        (includes high value paper and computer printouts
        and cards) to go to a base's recycling activity
        to help recover operating costs.
     -- Requires a base to establish or use resource re-
        covery facilities to separate and recover materials
        or energy when tnat base generates 100 tons of waste
        or more each day.
     -- Requires bases located in large metropolitan areas
        to participate with other Federal facilities in a
        single regional resource recovery system including
        energy generation.
     -- Requires use of regional resource recovery systems
        whenever possible.
     The Navy issued guidelines in August 1975 which provide
a systematic approach for evaluating alternatives, includ-
ing energy recovery, for disposing of solid waste at mili-
tary installations. The other services do not have such

                         CHAPTER 3



      By mid-1976, pollution control of solid waste disposal
at military installations had gone as far as closing dumps,
discontinuing open burning, maintaining landfills, and re-
claimning some materials for resale or reuse. Over 90 per-
cent of the solid waste is placed in landfills either on or
off Federal property. Most of the installations in our
review were not insuring that disposal operations complied
with EPA guidelines.
     Because it is considered a routine activity, solid
waste pollution control often competes for resources with
other installation activities. The table on pages 8 and
9 summarizes data from selected bases on waste disposal,
recycling, and energy generation.

Open burning of solid waste
     Although the Department of Defense does not specifically
prohibit open burning, the Navy and Air Force have issued
and the Army plans to issue regulations prohibiting open
burning. These will be consistent with EPA's recommendation
against open burning and the regulations of most States.

     Of the 20 installations in our review for which data
was available, only 3 burned trash in the open. After our
visit, the Naval Air Station, Jacksonville, closed its burn
dump in November 1975. The Holston Army Ammunition Plant
had a State exemption for open burning because much of its
waste is contaminated with explosive chemicals. The Marine
Corps' Camp Lejeune, contrary to State law, burns scrap wood
in the open.

Closing dumps
     At the time of our fieldwork, eight installations had
open dumps for waste, such as old appliances and construction
materials (see photographs on p. 10) but all have been or are
being closed. The Resource Conservation and Recovery Act of
1976 prohibits open dumps and requires that they be converted
into facilities which do not endanger the environment.

                        Solid Waste Disposal and Resource Recovery
                                   at DOD Instllations

Standard metropolitan                                              Resource recovery
                                Daily    Disposal in landfill    Materiasi
  statistical area             tonnage     Percent Percent
  and installation(sl                                             recycled    Energy
                              (note a)     on-base off-base       (note b) generation
Charleston, North
    Charleston Shipyard          70         -           100        Yes     Under study
    Charleston Air Force         24         -           100
      Base                                                          No     Under study
    Wright-Patterson Air         44         93               7     Yes     Under study
      Force ease
 Indianapolis:                                                               fuel)
      Fort B. Harrison          18         100           -         Yes     Not planned
      Naval Avionics             3          -           100         No     Not planned
     Naval Air Station,         24              5        95        Yes     Not planned
        Cecil Field
     Naval Air Station,         47          14           86        Yes     Designing
        Jacksonville                                                         system
     Mayport Naval              39          78           22         No     Designing
Johnson City, Kings-                                                         system
   port, Bristol:
     Holston Ammunition        277           8           10         No     Not planned
        Plant (note c)
     Robins Air Force Base      55         100           -         Yes    Not planned
Newport News, Hampton:
     FQrt Eustis                25         100           -         Yes    Planned with
    Fort Monroe                                                             Newport News
                                 8          -           100         No    Planned with
    Fort Story                                                              Hampton
                                10            (note d)              No    Not planned
    Langley Air Force           23         100         -           Yes    Planned with
Norfolk, Virginia                                                           Hampton
  Beach, Portsmouth:
    Norfolk Shipyard           101           (note e)               No    Under con-
   Oceana Naval Air                                                         struction
                               65         100           -         Yes     Not planned
                                                                Resource recovery
Standard metropolitan          Daily    Disposal in landfill   Materials
  statistical area            tonnage     Percent Percent      recycled    Energy
  and installation(s)        (note a)     on-base off-base     (note b)  generation

Seattle, Everett:
    Puget Sound Shipyard        33           -        100        No       Designing
    Keyport Torpedo              4           89        11        No       Not planned
    Trident Support Site         5            (Installation under construction)
    Fort Lewis                 281           -        100        Yes      Not planned
    McChord Air Force Base      73          100        -         Yes      Not planne'
    Camp Lejeane Marine        320          100        -          No      Not planned
      Corps Base

a/Based on a 5-day week (260 days a year), excluding materials reclaimed
  for recycling or for sale by the Defense Property Disposal Office.

b/Includes only those materials normally disposed of in landfills, such
  as waste paper, cardboard, aluminum cans, and glass; items that instal-
  lations normally turn in to the Defense Property Disposal Office, such
  as scrap metal, computer cards and printouts, scrap tires, and rubber,
  are therefore excluded.  These programs ranged from volunteer efforts
  to installation-wide programs to reclaim high-grade paper, cardboard,
  glass, and aluminum.

c/Mostly explosive-contaminated waste (82 percent of total waste).

d/Incinerated b' Norfolk Naval Base, Public Works Center.

e/Percentages not developed.

                                      OPEN DUMP

Landfills do not comply with
EPA guldelines
     EPA's landfill guidelines require or recommend that land
disposal sites confoLm to applicable water and air quality
standards; responsible agency and disposal site operators
determine acceptable and unacceptable wastes; cover material
be applied to minimize fire hazards, infiltration of precipi-
tation, odors, and blowing litter; and site location be
adaptable to appropriate land-use plans. The EPA guidelines
are mandatory for Federal agencies under section 211 of the
Solid Waste Disposal Act. as amevded.
      Eleven of 13 installations operating on-base landfills
deviated from EPA guidelines in one or more of the following
     -- Landfills were located in high water table areas
        near rivers and streams without due care for prevent-
        ing leaching into ground and surface water resources.
        (See photograph on p. 12.)

     -- Waste materials ineligible for disposal in landfills
        were not identified or controlled.

     -- Landfill operators did not apply 6 inches of cover
        material daily.  (See photograph on p. 12.)

     -- Waste was not compacted in 2-foot layers to
        minimize moisture infiltration and settlement.

     -- Fences or other devices were not used to control
        blowing litter.

     -- Disposal sites were located near aircraft runways,
        attracting birds which are a hazard to low-flying

Practices of private refuse
contractors not checked

     Twelve installations used private contractors to dispose
of part or all of their solid waste off base because they did
not have suitable landfill sites on base or contractors were
less costly. For example:
     -- Charleston Naval Base, South Carolina, terminated on-
        base landfilling in July 1974 because solid waste
        disposal experts of EPA, the State, and the county



       considered all available landfill sites unsuitable
       due to a high water table and possible contamination
       of tidal waters.
     -- The Naval Air Station, Cecil Field, Florida,
        elected to contract for off-base disposal because
        it estimated the contract for fiscal year 1975
        would cost about $36,000 less than on-base disposal.

     Where off-base facilities are used, EPA requires
Federal agencies to insure that processing and disposal
facilities comply with its guidelines. Only four installa-
tions that use private refuse contractors had taken steps
to insure that off-base disposal facilities complied with
EPA's guidelines.
     Service headquarters delegated responsibility for solid
waste pollution programing and related funding requests to
installation commanders, DOD said (see app. II) that such
delegation is consistent with decentralized management gener-
ally followed by large Federal agencies. It in no way implies
an abrogation of program control but ins-- es appropriate inte-
gration of pollution control with planning and budgeting for
the services' functional programs pursuant to Executive Order

     Office of Management and Budget Circular A-106 requires
Federal agencies to submit semiannual reports showing what is
needed to bring their facilities into compliance with appli-
cable environmental standards. DOD said that Circular A-106,
issued to place management control at the headquarters level,
works well and that DOD, with EPA and the Office of Manage-
ment and Budget, is effectively managing the numerous needs
identified and listed in the A-106 reports.

     DOD officials believed that pollution control needs
would not be overlooked because of continuous scrutiny by
State, local, and EPA officials and by community and environ-
mental groups. Because of this reliance on others, DOD and
the services had no internal system to check on the accuracy
and completeness of the installations' A-106 reports.

     Contrary to DOD's belief, EPA, State, and local officials
devoted little attention to DOD installations. EPA officials
said that their agency lacks the staff to monitor DOD instal-
lations regularly, and State and local officials said that
they did not have authority to inspect Federal sites.  (The

 Resource Conservation and Recovery Act of 1976 now authorizes
 the States to inspect Federal facilities.) Of the 13 bases
 in our review operating landfills in 1975, 3 had been in-
 spected by EPA and only 1 had been inspected by its State.

      Executive Orde' 11752 directs EPA to determine how well
 Federal agencies ,LitplementEPA guidelines. EPA planned to
 inventory and survey all solid waste land disposal facilities
 but did not have the staff or funds to do so. In March 1976
 EPA requested all Federal agencies to inventory and :urvey
 their land disposal sites and to determine if they were in
 compliance with EPA's guidelines. DOD said that it worked
 closely with EPA in completing the survey and was referring
 the results to the services for the installations to follow
 up with EPA regional offices.

 Environmental surveys

      The Army and Navy make environmental surveys of solid
 waste practices at their bases. The Air Force does not make
 environmental surveys but depends on the civil engineer at
 each base to arrange for waste disposal.
      The Army Environmental Hygiene Agency makes surveys at
 the request of a base commander, usually for specific prob-
 lems including evaluations of landfil£ sites, testing for
 leaching, and evaluations of disposal ~thods to select the
 most efficient one. Army officials told us that, because
 surveys are usually made at the request of base commanders,
 it is to a base's advantage to carry out survey team recom-
 mendations; however, there is no established procedure to
 make certain tliat recommended actions are taken. The
 reports _.e also sent to the Environmental Office in the
 Office, Chief of Engineers. The Environmental Office depends
 upon EPA and the States to report on base compliance with
 environmental standards.
      Regional environmental teams of the Navy's Engineering
 Field Divisions conduct regular surveys to identify pollu-
 tion problems and recommend corrective action. The Chief
 of Naval Operations requires all activities to report to the
,major commands and to his office the actions taken on the
 survey recommendations.

 Internal audits

     The Army Audit Agency reported in May 1973 that the in-
stallations, in reports to higher command le ils and regula-
tory bodies, had not identified all sources of pollution.

It recommended that the ,ejor commands start high priority
programs to identify ana Coive all pollution problems and
report them to headquarters.  The Deputy Chief of Staff for
Logistics agreed with the audit recommendations.

     In December 1975 the Air Force Audit Agency recommended
that Air Force headquarters (1) formalize funding procedures
to assure prompt completion of pollution projects requiring
operation and maintenance funds and (2) request firm guidance
from DOD for resource recovery and recycling programs.  Air
Force officials agreed with the Audit Agency's recommenda-

     The Navy Audit Service has not made any audits of the
Navy's control of environmental pollution.


     The services have reduced pollution by eliminating most
open burnir  and dumps.  But, in our opinion, the services
have not demonstrated the leadership in pollution abatement
contemplated by the May 1973 DOD policy statement.  (See p.
5.)  They have located landfills in high water table areas
without applying stringent controls to prevent leaching and
have not followed landfill management practices, such as com-
pacting waste and covering it with earth.  Also, the services
have not exercised control over the practices of private
refuse contractors working for them.

     We believe the low priority given solid waste manage-
ment and the absence of Department c. Defense deadlines for
complying with EPA standards contributed to the problem.
(DOD's October 1976 directive now requires a final deter-
mination on compliance actions within 1 year from the
effective dates of the EPA guidelines.)

       Because the Army did not insure compliance with envi-
ronmental team recommendations and the Air Force did not
rm,ake solid waste environmental surveys, we believe that
neither service made sure that all solid waste pollution
problems were identified and corrective action taken.


     FOL better leadership in solid waste management, we
recommend that the Secretary of Defense require the service
Secretaries to establish the following controls on land
disposal of solid waste:

     -- Periodic inspections and reports by service enviroit-
        mental teams not responsible to the installation

     -- Procedures for assuring that reported violations are

     DOD replied (see app. II) that:

     -- The military service audit and inspection procedures
        include provisions for inspections and reports by
        personnel above the installation level.
     -- The services initiate appropriate followup procedures
        as required to correct outstanding deficiencies in
        accordance with program priorities.
     A DOD official told us that the services are drafting
regulations implementing the new DOD directive, including
followup procedures to insure that identified deficiencies
are corrected.

     Since new directives in themselves do not insure com-
pliance, we believe periodic inspections and reports coupled
with enforcement procedures, as we recommend, will help tht
services overcome the land disposal problems we identified.

                          CHAPTER 4

      Recycling programs at DOD installations generally have
been voluntary activities not requiring large capital expend.-
tures. As of December 31, 1975, 105 of 313 major installa-
tior.s had such recycling programs.
     At of June 1975, DOD records showed that installations
had recycled 4.2 percent of the postconsumer solid waste
generated in fiscal year 1975, compared with the national
recycling average of about 6 percent. We believe that the
recycling rate at installations will improve during fiscal
year 1977 as they begin complying with EPA's materials re-
covery and beverage container guidelines.  (See p. 4.)

     Lack of resources, unrecovered costs, and fluctuating
demand for recyclable materials were the primary reasons
installation officials gave for not establishing required
comprehensive resource recovery and recycling programs. How-
ever, under DOD's November 1974 directive on resource recovery
and recycling, service Secretaries could grant an exemption
only when an installation could demonstrate that a recycling
program was not possible. Exemptions could not be granted
solely on the basis that proceeds from sales did not cover
operating expenses.
     DOD's October 4, 1976, directive on solid waste manage-
ment (see p. 6) allows exceptions after appropriate analysis
has determined that there is no market for recovered products
or that recovery is too costly to be economically practical.

Lack of resources and financial

     Under the November 1974 regulation, installations were
entitled only to that portion of the net sales proceeds needed
to reimburse them for certain recycling expenses.  Reclaimed
waste from materials purchased with appropriated and nonappro-
priated funds had to be turned in to the Disposal Service for
sale, and the installation was not entitled to any proceeds.

     Installation and headquarters officials told us that they
had not established comprehensive recycling programs because
they lacked the resources--funds, staff, and equipment. They
also told us that they do not expect sufficient revenue to cover

operating costs because waste from materials bought with -p-
propriated funds cannot be included in a recycling program.
     The Deputy Under Secretary of the Army, in a December 4,
1974, letter to the Assistant Secretary of Defense, expressed
the concern existing at the base and command levels over the
absence of financial incentives to recycling solid waste. He
said that, as a result, recycling programs would likely be
largely voluntary programs w 4 th most of the recovery done by
youth organizations and civic groups. He concluded that DOD
regulations should be changed to enable installations to
receive the proceeds from all recyclable materials which they
     Air Force officials endorsed the Army's position and
added that successful recycling programs cannot be expected
unless the installations can recover their expenses from sales
of postconsumer waste.
     Section 612 of the fiscal year 1975 Military Construc-
tion Authorization Act (Public Law 93-552, 88 Stat, 1765-66,
Dec. 27, 1974) established the following rules for the sale
of recyclable material: The proceeds must be credited first
to the cost of collecting, handling, and selling the mate-
rial, including purchase of required equipment; second to
environmental improvement and energy conservation projects,
up to $50,000 a year, at each installation with a recycling
program; and third any remaining proceeds to the Treasury.
     To cover some costs of recycling materials, the October
1976 directive provides that the net proceeds from the sale of
materials recovered from solid waste generated by commercial,
residential. and institutional (hospitals, schools, etc.)
activities go to the installation's recycling activity. The
new directive also outlines the procedures for using any
excess proceeds generated by recycling programs. This in-
cludes the requirements of section 612 of the 1975 Military
Construction Authorization Act.

     One of the most active recycling programs we observed was
at Fort Lewis, Washington, which, during the period September
1973 through August 1975, sold reclaimed materials for about
$89,000. Of these proceeds, $73,000 was returned to the
Treasury and most of the remaining $16,000 was paid to non-
appropriated fund activities for their recyclable bottles.
     The Army Audit Agency completed an audit of the Fort
Lewis recycling program in November 1974 and reported -nat

its operating cost (labor excluding prisoners, equipment
usage, and other costs) was about $160,000 during fiscal
year 1974. The Audit Agency recommended that the instal-
lation make a cost analysis to determine if the recycling
program should be continued by Government personnel or be
contracted out.

     Fort Lewis recovers only 5 percent of recyclable
materials because it collects only materials voluntarily
deposited in containers at the base. The Fort Lewis program
was mainly due to the interest of the commanding officer
in ecology and the use of military personnel and prisoners
to staff the program. (See photographs on p. 20.)

     In August 1975 the Navy issued (1) uniform survey and
analysis guidelines for a solid waste activity, (2) infor-
mation on a variety of available solid waste management
systems, and (3) a description of how an activity can
evaluate waste disposal options. Naval Facilities Engi-
neering Command division offices are applying these guides
at shore installations to survey the potential for recover-
ing resources, including energy from solid waste. By
September 23, 1976, the Navy had completed 16 surveys, 28
were in process, and about 20 others were scheduled.

     Seven of the 10 Navy installations in our review had
recycling programs but these programs were limited to co-
operating with Boy Scout troops to recover aluminum cans
(2 installations), and to the recovery and sale of card-
board and/or other paper products (5 installations).

     Air Force
     Contrary to the November 1974 DOD directive on resource
recovery, Air Force headquarters issued a letter in December
1974 instructing installations to implement recycling pro-
grams only where they proved to be cost effective.

     Robins Air Logistics Center, at the insistence of the
Center's commanding general, began to recover cardboard,
glass, aluminum, and paper in May 1975. An economic
analysis of the program showed operating costs of about
$1,270 a year and income of about $640.

     An Air Force test program in 1976 to find out whether
sales proceeds could finance the cost of recycling post-
consumer waste showed that recycling programs were not cost
effective. DOD's new directive on solid waste management



now permits bases to include high value paper in their re-
cycling programs.
Fluctuating markets for
reclaimed mate7ials

      A cost effective and successful materials recovery pro-
gram is contingent on a steady market and reasonable prices
for reclaimed products.   In its 1973 annual resource re-
covery report, EPA stated that, with the possible exception
of aluminum, lack of industrial demand for secondary materials
is the primary constraint on significantly increasing the re-
cycling rates of metal, fiber, and rubber by source separa-
     EPA's analysis of postconsumer net solid waste shows
that paper consti' ;-es about 32 percent and all glass and
aluminum about 11 percent of the total weight.    (See app. IV.)
The unsteady market for recyclable  paper is,  therefore,  a
major problem for installations. During 1973    and  early 1974
the demand for wastepaper increased  sharply  due to  an inade-
auate supply of virgin pulp, which caused wastepaper prices
to rise to their highest level since the Korean War. During
the last half of 1974 demand decreased sharply, and prices
fell to about one-fourth the early 1974 price level. Ac-
cordingly, wastepaper recovery became uneconomical for many
potential suppliers, including military installations.
     Of the 21 bases we visited, 11 have had programs to
recycle wastepaper. Seven discontinued their programs be-
cause they could not find markets for the paper. Officials
at the other four stated that the price for paper has de-
clined about 50 percent. Officials at the 10 remaining
bases said that there was no market for wastepaper.
     At several installitions, recycling programs were dis-
couraged by unfavorable market conditions. For example,
officials at McChord Air Force Base said they attempted to
set up a resource recovery program in 1S74, but soon dropped
the program because the market for reclaimed materials
ceased to exist. Officials at Wright-Patterson Air Force
Base said they do not plan to expand their recycling program,
other than through volunteer efforts, because a market for
such items as plastic and lumber is nonexistent and the
market for glass makes its recovery uneconomical.
     EPA's new requirement that Federal facilities charge
a refundable deposit on beverage containers by September
1977 should help substantially to reduce the volume of
glass and aluminum discarded at military installations. The

refund of at least 5 cents for each container provides a
positive incentive for consumers to return the empty con-
tainers so that refillable bottles can be reused and nonre-
fillable containers can be recycled.  DOD is testing the
feasibility of the EPA requirement at installations in the
continental United States.  Ten bases have been chosen for
the yearlong test, which was scheduled to begin at Fort
Knox in March 1977 and at the others by June.  DOD hopes to
develop enough data by September 1977 to select the bases
where the beverage container deposit-refund program would
be feasible and to determine how it should be conducted.
The test will also provide the type of evidence needed under
EPA guidelines to omit the program where it is not practical.

     The October 1976 DOD directive on solid waste management
outlines program responsibilities.  The Assistant Secretary
of Defense (Instal'ations and Logistics) has primary respon-
sibility for policy development, programing, and planning of
the program.

     The service Secretaries and the directors of Defense
agencies are responsible for identifying those installations
which should establish resource recovery programs and for
budgeting and financial planning for approved programs. The
Defense Logistics Agency is responsible for furnishing mar-
ket analyses to DOD components before the establishment of
recycling programs and for negotiating contracts for market-
able materials and sale of solid waste to public or commer-
cial resource recovery operations.


     The competition for resources, inability to recover
costs, and the fluctuating markets for recyclable materials
have been drawbacks to programs for recycling postcolisumer

     We proposed that the Secretary of Defense require the
Secretaries of the Army and Air Force to conduct surveys,
as the Navy is doing, to decide on the conditions that make
recycling programs practical and to determine each installa-
tion's potential for recycling materials from solid waste.
DOD (see app. II) said that its October 1976 directive will
apply the EPA recycling guidelines DOD-wide, including the
conduct of appropriate surveys.

     We believe that DOD's current directive and its ongoing
test for carrying out the beverage container guidelines will
improve the recycling of materials at military installations.

                           CHAPTER 5

                      WASTE--DOD CAN HELP
     Although energy recovery from solid waste has certain
economic and environmental benefits compared with other dis-
posal methods, military service officials have been reluctant
to initiate such recovery. This is partly due to technology
problems but mainly because most bases have sufficient land-
fill areas.
     The economic benefits of energy recovery from solid
waste are the value of the energy produced,.improved mate-
rials recovery by mechanical separation, and the savings
in disposal costs. The environmental benefits are decreased
air and water pollution and less land area used for disposal.

     From 1972 to June 1976 crude oil prices increased from
$2.48 to $10.88 a barrel and prices for coal used in steam or
utility plants increased from about $8 to $18 a ton. Accord-
ing to EPA, about 70 to 80 percent of residential and commer-
cial solid waste is combustible. A ton of average composition
waste when burned will release energy comparable to the energy

     --one-third toll of coal,
     --65 gallons of No. 2 fuel oil, or

     -- 10,000 cubic feet of natural gas.
     According to EPA, many industrial plants could generate
at least half of the process steam they need by using solid
waste fuel.  Industrial activities at military bases, by
implementing such recovery systems, could reduce their con-
sumption of fossil fuels as well as the quantity of waste
that otherwise would go into a landfill. For example, a
small municipal energy recovery incinerator system evaluated
by EPA reduced the volume of waste by 95 percent and saved
about 67,000 cubic feet of natural gas (or about $61) a day.


     The technology problems that cause some of the reluctance
of military officials to initiate energy recovery systems are
that several such recovery options are still in development
and the existing systems are large-scale operations and there-
fore require a large investment.

Energy recovery options
     Technologies for recovering energy from refuse are
(1) burning unprocessed waste in steam-generating incinera-
tors, (2) pyrolysis, (3) processing refuse for use as fuel,
and (4) methane recovery. A 1976 EPA solid waste management
guide stated that none of these technologies are yet free of
risks and only two are commonly considered commercially
available. The commercially available technologies are (1)
waterwall incinerators fueled solely by unprocessed solid
waste and used for cooling, heating, and industrial proces-
sing; and (2) boiler modifications to enable the use of
shredded solid waste as a supplement to pulverized coal.
     DOD said (see app. II) that waterwall incinerators are
costly to build, operate, and maintain and that pulverized
coal boilers are rare in DOD. EPA said that other, possibly
better, technologies are being developed and are ex-
pected to become commercially available during the period
1977 to 1982.
      DOD said that one such new development is refuse-derived
fuel.   It appears to offer several major advantages over
waterwall incinerators. The initial cost required to burn
refuse-derived fuel and the operation and maintenance costs
should be much less than incineration with heat recovery.
     Early 1976 tests at Wright-Patterson Air Force Base,
Ohio, on existing coal-fired boilers with stokers of the
type commonly found in DOD demonstrated that refuse-derived
fuel can be burned in combination with coal. An added bene-
fit is that higher sulfur coal can be used because the
refuse-derived fuel has little sulfur, and the mix results
in acceptable stack emissions. At present, procurement
authority to purchase the fuel from commercial souzces is
limited, and DOD is proposing to seek statutory authority
from the Congress to enter into 10-year contracts for refuse-
derived fuel.  (Commercial suppliers stated that a 10-year

period is the minimum time for them to amortize plant invest-
ment.) With 10-year contracting authority, DOD would use
the fuel at many installations having coal-fired boilers that
would require little or no modification.
Scale of operation required

     Most energy recovery systems in use today required large
capital outlays because plants had to be built to process
large quantities of waste--200 or more tons a Jay--to be
economical. However, the size of such plants becomes less of
a controlling factor as energy recovery technology is im-
proved. For example, EPA recently completed a study of a
small town's 21-ton-a-day modular system that uses solid waste
to generate steam and was built for about $371,000. By sell-
ing the steam to a local manufacturer, the town expects to
recover its costs (capital and interest on bonds) in about
16 years. The study showed that there were no significant
problems with the system's operations and that, for the pur-
poses intended, it operated effectively on untreated munici-
pal solid waste. Technology is being further improved for
using small incinerators with capacities of 5 to 12 tons a
day to economically generate energy from solid waste. Many
military installations use large quantities of steam and
therefore would not have a problem using the steam they

     Although DOD has recommended that the services con-
sider energy recovery from solid waste as an alternative
to recycling, it has not given them guidance for determining
under what circumstances nrojects for recovering energy from
solid waste would be ben  icial.   Consequently, the services
have adopted different approaches.
     The following table shows the potential annual fuel
(oil) savings by burning solid waste in resource recovery
facilities planned or in use at the installations listed.

           Potential Annual Fuel Savings by Burning
         Solid Waste in Resource Recov;ry Facilities

           Installation                     of oil
                                          (000 omitted)
     Fort Eustis                             4,000
     Fort Monmouth                           1,900
     Picatinny Arsenal                         330
     Puget Sound Naval Shipyard
       (note a)                                210
     Mayport Naval Station                     345
     Norfolk Naval Station                   1,000
     Norfolk Naval Shipyard                  1,000
     Charleston Naval Shipyard                 368
     Andrews Air Force Base                  1,000
         Total                              10,153
a/There will also be a savings in natural gas, but data was
  not available.
At Jacksonville Naval Air Station the potential annual fuel
savings is 132 million cubic feet of natural gas.

     The Army budgeted funds for two projects to recover
energy from solid waste--$1.8 million for Fort Monmouth, New
Jersey, in fiscal year 1976 and $600,000 for Picatinny Ar-
senal, New Jersey, in fiscal year 1977. By converting its
oil-fired central boiler, Fort Monmouth expects to save
$562,000 a year, and by building an energy recovery inciner-
ator, Picatinny Arsenal expects to save $250,000 a year worth
of fuel oil. Thus, the cost of each project would be re-
covered in about 3 years.

     Fort Eustis and the city of Newport News, Virginia, are
considering a resouLce/energy generating system. A 1974
study showed that Fort Eustis would save about $1.7 million
in reduced oil-generated steam and landfilling costs and the
city would save about $1.7 million in disposal costs.

     Until recently, the Army did not study methods for re-
covering energ, from waste because other Federal agencies
and private companies were doing so. Further, the Army does
not believe it has a disposal problem at most of its bases
because landfill space is plentiful.

     The Air Force received $1.7 million in its fiscal year
1977 budget to convert the oil-fired central heating plant
at Andrews Air Force Base, Maryland, to a solid waste burn-
ing operation. The Air Force expects the conversion to
save about $300,000 a year in fuel and disposal costs. The
Air Force, like the Army, has made very few studies of
energy recovery from -oidwaste and generally t_.ieves that
it has sufficient landfill area for its immediate needs.
Also, the Air Force does not believe that sufficient testing
has been done to prove the concept of generating energy from
solid waste.

     Of the three services, the Navy has made the most progress
in studying and initiating recovery systems to generate energy
from solid waste. Most Navy bases are located in or near
densely populated areas where available landfill areas are
scarce. Even when land is available, high water tables often
make such areas unsatisfactory as sanitary landfills.

      Accordingly, the Navy has studied the feasibility of
using solid waste to generate energy at 13 installations and
has built a solid waste energy recovery plant at the Norfolk
Naval Station, Norfolk, Virginia (see p. 28), and is building
another at the Norfolk Naval Shipyard in Portsmouth, Virginia.
It contracted for the design of solid waste energy recovery
systems at three other installations we visited:   Mayport
Naval Station, Florida; Jacksonville Naval Air Station,
Florida; and Puget Sound Naval Shipyard, Washington. The
estimated annual savings for Mayport is $535,000, Jackson-
ville, $589,000, and Puget Sound, about $245,000. Jackson-
vi...e received $4.7 million in fiscal year 1977 to build the
recovery system.
     The plant at the Norfolk Naval Station was the first
steam generating, waterwall incinerator built in the United
States for burning solid waste. The Navy completed it in
May 1967 at a cost of $2.2 million. Later improvements in-
creased this figure to almost $4 million. The plant supple-
ments the oil-fired plant, generating about 10 percent of
the station's steam demand from about 150 tons of waste a
day from five nearby military installations and from some
city activities. Although the Navy initially had many prob-
lems with the plant, they were alleviated as plant opera-
tors became familiar with operating procedures.
     The Navy contracted for an economic analysis of the
plant. The analysis showed that the cost to dispose of
36,000 tons of refuse in fiscal year 1975 was about $1.1
million and that the steam generated was valued at about



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$900,000. Thus, net disposal cost was about $6 a ton com-
pared to the Navy's estimate of about $10 a ton for a sani-
tary landfilling. The Navy is pleased with the plant and its
     Only nine other operational facilities in the United
States use solid waste to generate energy. Another 25
municipal plants are planned or under construction, and
about 37 other communities are interested in building

Lack of coordination

     Eleven of the 22 installations in our review have in-
dependently studied the feasibility of recovering energy from
solid waste. Four base 3tudies considered only direct bene-
fits to the installation, overlooking the economic advantages
of joint or regional systems with other Federal agencies and
civilian communities; three considered DGD installations only;
two considered joining regional systems (or y one decided to
do so); and two, Wright-Patterson Air ForCL ease and Fort
Eustis, are still working with other postible participants
on a regional program.

     The number of studies made suggests a duplication of
effort due to lack of a uniform, coordinated approach to con-
sidering energy recovery. Examples of activities that evi-
dence a need for guidance in establishing economical refuse-
fired energy recovery systems follow.

     Oceana Naval Air Station, Virginia, studied the feasi-
bility of a refuse-fired steam generating plant rather than
repairing and modernizing existing powerplant boilers. The
study did not consider waste from other nearby installations
or municipalities and concluded that landfilling was more
economical. The combined solid waste of this and one other
nearby Navy installation is about 65 tons a day. Navy cri-
teria provide that an economical energy recovery system be-
comes "probably applicable" at 40 tons a day.

     Camp Lejeune Marine Corps Base, North Carolina, which
collects about 320 tons of solid waste a day, considered
adding a refuse-fired steam generating boiler as one way to
increase its central heating nlant capacity. The base did
not consider refuse of other nearby military installations
or communities, but concluded that the system was feasible
with its own waste. Without making a cost comparison, how-
ever, base officials chose to add another oil-fired boiler
to the heating plant for $972,000 because they thought the

estimated cost of $2.4 million for a refuse-fired boiler
was prohibitive and would not be funded.

     In South Carolina, the Charleston Naval Shipyard and
nearby Charleston Air Force Base were independently planning
to construct refuse-fired energy recovery systems. Each
plan provided for using the refuse of other DOD installations
in the area. We discussed this matter with Air Force, ship-
yard, and Naval Facilities Engineering Command officials who
agreed they need better coordination on pollution control
plans. In January 1977 the Air Force canceled its projects
at the Charleston Air Force Base.
     The Puget Sound Naval Shipyard in Bremerton, Washington,
is planning to build a refuse-fired energy recovery plant
costing about $2.1 million to dispose of its 33 tons of daily
solid waste. The shipyard received funds for this project
in fiscal year 1977. However, shipyard officials did not
consider a consolidated plant to burn waste from two other
naval installations--Keyport Naval Torpedo Station and the
Trident Submarine Support Site--within 12 miles of the ship-
yard. The shipyard public works officer told us that this
was not considered because it would be uneconomical to trans-
port waste from the other installations to the shipyard.
     With current technology, use of solid waste for energy
can be economical and deserves systematic consideration as
a method of waste disposal. The installations that con-
sidered recovevr of energy from refuse generally planned
only for their own needs and therefore did not evaluate a
joint or regional system that may have been more economical.
The Navy is the only service that has issued some guidance
for evaluating energy recovery, but the Navy could also im-
prove the coordination and review of its installation plans
for recovery systems.
     DOD can help assure that the most beneficial energy
recovery systems are considered by issuing criteria and
guidelines for making feasibility studies and coordinating
the requirements of the various installations.

    We recommend that the Secretary of Defense:

     --Publish guidance for determining whether and under
       what circumstances military bases should initiate
       projects for recovering energy from solid waste.

     -- Issue specifications to the services for preparing
        energy recovery system proposals.
     -- Designate a focal point for reviewing such project
        proposals and establishing priorities for their
     DOD said (see app. II) that although recovery of energy
from solid waste is very attractive and simple in concept,
its execution is quite complex and cost intensive.  Because
the state of the art is still advancing rapidly, DOD con-
siders that the prudent course is to install a minimum num-
ber of several types of energy recovery systems and closely
observe results from these installations, as well as all
other new develcpments. DOD said that one such new develop-
ment is refuse-derived fuel for which both the initial cost
and the operation and maintenance costs should be much less
than waterwall incineration costs.

     Although DOD commented on the prudence of installing
several types of energy recovery systems, it did not say
whether it intended to carry out our recommendations. We
believe that publishing guidance, issuing specifications,
and designating a focal point for reviewing proposals and
establishing funding priorities are necessary for an orderly
and economic selection of energy recovery systems.

                            CHAPTER 6
     We examined regulations, operating procedures, and
available guidelines that each of the services uses to con-
trol residential and commercial types of solid waste. We
reviewed the solid waste management programs in operation
in early 1976 at selected installations to control pollu-
tion, recycle material, and produce energy from solid waste.
The programs and their effectiveness were discussed with
headquarters and installation officials. We excluded dis-
posal of agricultural, industrial, classified, and patho-
logical wastes.
     In addition to the installations listed on pages 8 and
9, the review covered the following organizations:
Department of Defense

     Office of the Secretary of Defense
     Army, Navy, and Air Force Headquarters
     Naval Facilities Engineering Command:
         Atlantic Division, Norfolk, Va.
         Southern Division, Charleston, S.C.
Environmental Protectior, AgencX

     Headquarters, Washington, D.C.
     Region II, Philadelphia, Pa.
     Region IV, Atlanta, Ga.
     Region V, Chicago, Ill.
     Region X, Seattle, Wash.

 APPENDIX I                                                           APPENDIX I

  t. ST',:p'

*,41boats't                        WASHINGTON. D.C.    20460

                                         AIA82 i !77

                                                                             OFFICE OF
                                                                     PLANNING AND MANAGEMENT

   Mr. Henry Eschwege
   Director, Community and Economic Development Division
   United States General Accounting Office
   Washington, D.C. 20548

   Dear Mr. Eschwege:

               Your draft report on solid waste management in the Department cf

   Defense has been reviewed and our comments were given to your Assistant

   Director, Mr. Oberson and his staff at a meeting in EPA on January 5th.

               We have no other comments or suggestions at this time.

                                                       Sincerely yours,

                                                        Alvin L. Aim
                                                  Assistant Administrator
                                                for Planning and Management

       GAO note:        EPA comments have been incorporated          into the
                        report where appropriate.

       APPENDIX II                                                              APPENDIX II

                              ASSISTANT SECRETARY OF DEFENSE
              x,/~~~,              WASHINGTON, D.C.   20301

                                                                          IN1 JAN 1977 1

        Mr. F. J. Shafer
        Director, Logistics and
          Communications Division
        U.S. General Accounting Office
        Washington, D. C. 20548

         Dear Mr. Shafer:

         This is in response to your letter of November 15, 1976 to
         Secretary Rumsfeld which forwarded copies of your draft report
         entitled ':Benefits to the Economy and Environment by Improving
         Solid Waste Management in the Department of Defense, " Code
         945260 (OSD Case #4483).

         The draft report has been reviewed by this office and the Military
         Departments.   Comments from these reviews are attached.

         We appreciate the opportunity to review and comment on this report.
         Its findings and recommendations will be helpful in our implementation
         of the applicable solid waste guidelines and compliance therewith.


                                            Asticta:'t   z::ro:ary of Defense
                                             (',U.iU.~;ciIu   and LcUistics)

APPENDIX II                                                  APPENDIX II

                    Department of Defense Position
              GAO Draft Report, dated November 15, 1976
                    (Code 945260 - OSD Case #4483)

       !'Benefits to 'the Economy and Environment by Improving
         Solid Waste Management in the Department of Defense"

I.    GAO Draft Report Summary

    Executive Order 11752 was issued to implement the major federal
environmental laws and insure that the federal government provides
leadership in a nation-wide effort to control pollution. It requires that
federal facilities be designed, constructed, managed, operated and
maintained to conform with Environmental Protectiqn Agency (EPA)
guidelines for solid waste recovery, collection, storage, separation
and disposal.

      The cGAO review concludes that the DoD can bring about greater
economy and environmental benefits by improving its solid waste manage-
ment. Findings indicated that (1) although much of the pollution has been
eliminated, proper precautions are not being taken at some landfills to
prevent leaching and to maintain daily ground cover as recommended;
(2) there is minimal recovery of recyclable materials, however, GAO
believes 'that recycling will start to improve in FY 7.7; and (3) there was
a reluctance to initiate recovery system projects partly due to technology
problems but mainly because of sufficient landfill areas at most bases.
It was recommended that the Secretary of Defense (1) require the
Service Secretaries to establish controls to insure adherence to require-
ments and recommended procedures in the land disposal guidelines;
(2) have Arm:y and Air Force conduct recycling surveys similar to the
Navy's; and (3) publish guidance, issue specifications, and designate
a focal point for reviewing and establishing funding priorities for
energy recovery projects.

II.   Defense Position Surmary

     The Department of Defense does not generally disagree with the
basic findings when compared with today's criteria for solid waste
management. It agrees that gre.ater overall environmental benefits
will be derived through the improved solid waste management practices
that are now being instituted when compared with the practices in
effect during the GAO review. It is fully intended that DoD facilities

 APPENDIX II                                                     APPENDIX II

  comply with the Solid Waste Act and related legislated requirements,
  However, the Draft Report does not account for several recent
  developments that impact significantly in this area:

      (1) Enactment of the "Resource Conservation and Recovery Act
 of 1976, " signed into law on October 21, 1976, "To provide technical
 financial assistance for the development of management plans and
 facilities for the reco.very of energy and other resources from
 materials and for the safe dispos;tl of discarded materials, and
 regulate the mnanagement of hazardous waste;

      (2) Issuance of the EPA guidelines for resource recovery
 facilities as late as September 21, 1976;

     (3) Deferred inmplementation within DoD of the DoD Directive
 6050. 3, "Resource Recovery and Recycling Program - Solid and
 Waste Material, " November 19, 1974, due to impending issuance
 EPA Guidelines;

      (4) DoD Directive 4165. 60, "Solid Waste Management - Collection,
 Disposal, Resource Recovery and Recycling Program, " dated
 October 4, 1976 that implements the criteria of a majority of the
 Solid Waste Management Guidelines; and

     (5) The DoD plan for testing    the EPA deposit-refund guidelines for
 beverage containers which were      promulgated on September 21, 1976,
wijl provide DolD with the data it   needs to determine the feasibility of
implementation of the guidelines     at military installations throughout

    The solid waste guidelines require DoD to report determinations
concerning compliance implementation actions. Where the determination
is not to implement a mandatory requirement of the guidelines,
rationale for this determination must be stated. Specific time
were not prescribed for reporting detailed deficiency corrections
                                                                  to EPA.

     The Military Services have programs currently in process under
which the GAO recommendations have already been accomplished,
are well underway, as result of the recent promulgation of the
EPA Guidelines on solid wastes and the subsequent DoD implementing
Directive. In addition, several research and engineering actions
have been underway for the past year or more in the Military

APPENDIX II                                                   APPENDIX II

to seek ways to recover resources from the solid waste. Many of the
conditions described by the draft report are in the process of being
corrected. It is recognized that many of these conditions in this
connection will require continuing emphasis, time, and follow-up, in
addition to significant programing actions. These actions are being
pursued on a continuing basis to insure full compliance.

III.   Defense General Comments

       A.   Status of Pollution Controls

           The delegation of responsibilities for the solid waste program
is consistent with decentralized management practices generally
prevailing in large federal agencies. It in no way implies an abrogation
of program control in this area, but insures appropriate integration into
applicable planning and budgeting procedures for the-Services' functional
programs pursuant to the Executive Order.

            Contrary to the statement that there is no mechanism at the
headquarters level to insure identification of pollution control needs or
to monitor the progress of projects, the OMB Circular A- 106 process
was established to accomplish management control at this level. The
process works well and DoD, in conjunction with EPA and OMB, is
effectively managing the numerous needs that have been ide cified and
listed in the A-106 reports.

           Further, in accord with guideline requirements, DoD has
worked closely with EPA in completing the Solid Waste Management
Land Disposal Survey for its installations which is now being forwarded
to the Military Services for follow-up by the involved installations with
the EPA Regional Offices.

            Military Service audit and inspection procedures include
provision for inspections and reports by personnel abov! the installation
level; schedules for compliance with the various EPA Guidelines have
been established by the recently issued DoD Directive 4165.60 (copy
attached); and Services initiate appropriate follow-up procedures as
required to correct outstanding deficiencies in accordance with program
priorities. Continuing emphasis will be given to assure management
attention in this important area.

       B.   Recovery of Recyclable Materials

          The draft report, while reflecting that minimal recovery has
been achieved, recognizes the significant problem areas involved such as

APPENDIX   II                                               APPENDIX II

fluctuating market conditions, competition for resources, inability
to recover costs, etc. Historically, segregation of the waste stream
components and material recovery efforts have been limited to those
high value components which are possible to resell. Much resource
recovery effort has also been achieved in cooperation with recognized
voluntary organizations.    However, implementation of the governing
DoD Directive in this area will serve to apply the guidelines criter;a
uniformly DoD-wide, including the conduct by appropriate surveys.
The policy contained in the directive is designed to prevent competition
with the locally available commercial recycling industry, and specifies
that joint or regional civilian systems be utilized whenever possible in
lieu of establishing separate DoD systems. We feel that these procedures
satisfy the basic report recommendations regarding possible recycling

    C.   Energy Recovery from Solid Waste

            The recommendation for greater emphasis on energy recovery
from solid wasce is, in general, a good one. However, it must be noted
that the guideline on source separation stresses recycling of paper in
lieu of its use in energy recovery.

            While recovery of energy from solid waste is very attractive
and is simple in concept, 'its execution is quite complex and cost
intensive. .As noted on page 41 of the report, the EPA 1976 solid waste
management guide stated that none of these technologies (energy recovery
from refuse) are yet free of risks and only two are considered com-
mercially available.   The first of these two available methods is
waterwall incinerators which are costly and have high operation and
maintenance costs. The second of the two available methods is the use
of shredded solid waste as a supplement in pulverized coal boilers
which are rare in the DoD. Since the state of the art in energy recovery
from solid waste is still advancing rapidly, the DoD considers that the
prudent course of action is to install a minimum numbel of several types
of energy recovery systems and closely observe results from these
installations as well as all other new developments. One such new develop-
ment is Refuse Derived Fuel (RDF). At this time, it appears to offer
several major advantages over waterwall incinerators.      Both the initial
cost required to burn RDF as well as the operation and maintenance
costs should be much less than incineration with heat recovery. Early
1976 tests at Wright Patterson AFB in existing coal fired boilers, with
stokers of the type commonly found in DoD, indicated that RDF can
readily be burned in combination with coal. An added benefit is to be
found in that higher sulfur coal can be used and because RDF has

APPENDIX II                                                  APPENDIX II

essentially no sulfur, the mix results in acceptable stack emissions..
At present, procurement authority to purchase RDF from commercial
sources is limited and for this reason DoD is proposing to seek
statutory authority from Congress to enter into 10 year contracts for
RDF, Commercial suppliers have stated that 10 year contracts are
the minimum acceptable to enable them to amortize plant investment.
Given this contract authority, DoD would propose to use RDF at many
installations where existing coal fired boilers can burn RDF with little
or no modification.

 DoDD 4165. 60, 10/4/76

GAO notes:    1. Page references in this appendix may not ior-
                 respond to page numbers in the final report.
              2. The cited recent developments have been in-
                 corporated into the report.

 APPENDIX III                                      APPENDIX III

                         GLOSSARY ON SOLID WASTE
Burn dump             A site at which solid waste is burned
                      in the open.
Incineration         The controlled process in which com-
                     bustible solid, liquid, or gaseous
                     wastes are burned and changed into
                     noncombustible gases.
Leachate             The liquid that has percolated through
                     solid waste and contains extracted,
                     dissolved, or suspended materials from
Methane              The gas created by the natural decom-
                     position of organic waste.
Open dump            A land disposal site at which solid
                     wastes are disposed of in a manner
                     that does not protect the environment,
                     are susceptible to open burning, and
                     are exposed to the elements, pests,
                     and scavengers.
Postconsumer waste   Waste discarded by the final con-
                     sumer rather than by raw material pro-
                     ducers and manufacturers.  Includes
                     waste typically collected in household
                     refuse, as well as similar materials
                     from commerical or governmental office
                     buildings, wholesale and retai trade
                     establishments, and other general busi-
                     ness and service sectors of the economy.
Pyrolysis            The thermal decomposition of solid
                     waste into a gas or liquid that can be
                     used as a fuel.
Recycling            The process by which recovered materials
                     from solid waste are transformed into
                     new products.
Resource recovery    Any physical plant that processes resi-
  facility           dential, commercial, or institutional
                     solid waste biologically, chemically,
                     or physically and recovers useful pro-
                     ducts, such as shredded fuel, combus-
                     tible oil or gas, steam, metal, glass,
                     etc., for recycling.

APPENDIX III                                     APPENDIX III

Responsible agency     The organizational element that has the
                       legal duty to insure that owners, opera-
                       tors, or users of facilities comply with
                       EPA solid waste guidelines.
Sanitary landfilling   An engineered method of disposing of
                       solid waste on land in a manner that
                       minimizes environmental hazards and
Solid waste            Garbage, refuse, sludge; and other dis-
                       carded solid materials resulting from
                       industrial and commercial operations
                       and from community activities. It does
                       not include solids or dissolved material
                       in domestic sewage or other significant
                       water pollutants, such as silt, dis-
                       solved or suspended solids in industrial
                       wastewater effluents, or dissolved ma-
                       terials in irrigation return flows.
Waterwall inciner-     A furnace with walls consisting of
  ator                 vertically arranged metal tubes joined
                       side to side with metal braces. Radi-
                       ant energy from burning unprocessed
                       solid waste is absorbed by water passing
                       through the tubes. Additional boiler
                       packages, located in the flue, control
                       the conversion of this water to steam
                       of a specified temperature and pressure.

APPENDIX IV                                        APPENDIX IV


                        NET SOLID WASTE

                                 Millions          Percent
   Material                      of tons           of total
Paper                             43                 32
Glass                             13                 10
Metals (note a)                   13                 10
Plastics                           5                  4
Wood                               5                  4
Rubber and leather                 4                  2
Textiles                           2                  1
Food waste                        23                 17
Yard waste                        25                 19
Miscellaneous                      2                  1
    Total                        135                100
a/Includes about I million tons of aluminum.

APPENDIX V                                        APPENDIX V



                   DISCUSSED IN THIS REPORT

                                       Tenure of office
                                       Frcm          To
    Harold Brown                    Jan. 1977     Present
    Donald H. Rumsfeld              Nov. 1975     Jan. 1977
    James R. Schlesinger            July 1973     Nov. 1975
    Clifford L. Alexander           Feb.   1977   Present
    Martin R. Hoffmann              Aug,   1975   Feb. ?,977
    Norman R. Augustine (acting)    July   1975   Aug. L975
    Howard H. Callaway              May    1973   July 1975
    W. Graham Claytor, Jr.          Jan. 1977     Present
    J. William Middendorf II        Apr. 1974     Jan. 1977
    John W. Warner                  May 1972      Apr. 1974
    John C. Stetson                 Mar. 1977     Present
    Thomas C. Reed                  Dec. 1975     Mar. 1977
    John L. McLucas                 May 1973      Dec. 1975