11_2_2022_-_P2OA_Template_0002.pdf

45 Space Wing P2 Opportunity Number: Facility, Number –

1.1 Description

This Pollution Prevention Opportunity Assessment (P2 OA) addresses potential pollution prevention (P2) alternatives for Burger King located in Building

1369, PAFB.

Pollution Prevention Objective: To analyze the impacts of mission activities and identify opportunities to eliminate waste. Evaluate the products used, processes performed and wastes generated by the shops to identify ways to reduce Air Force, contractor and tenant environmental liability.

1.2 Shop Processes

The Burger King personnel are responsible for preparing and providing fast food services which includes a breakfast, lunch and dinner menu. Processes and/or activities performed include food preparation, cooking (frying and grilling), cleaning, mopping, and communication utilizing headsets.

1.3 Waste Streams

The following waste streams are generated by processes performed by Burger King personnel: used cooking oil from fryers, batteries from communication headsets, and fluorescent lights for internal lighting.

1.4 Potential P2 Alternatives

The following potential P2 alternatives were identified and analyzed during the P2 OA as opposed to the no action or status quo alternatives.

1.4.1 Used Cooking Oil Drum Capacity

Used cooking oil is generated from food preparation activities. The used oil is transferred from the fryers into a container, which operates as a dolly. From the container the oil is transferred to the drum storage area which houses a covered storage unit that stores up to 220 gallons in four 55 gallon drums. The drums are pumped out approximately every six weeks by the AAFES recycling contractor, Darpro. The approximate volume of used cooking oil removed from the drums during the last three visits noted on 27 Jan, 11 March, and 21 April 15;

equaled 56, 51, and 44 gallons respectively.

Due to the size of the drums (55 gallon capacity), the facility is regulated by 40 CFR 112 and has to be included in the PAFB SPCC Plan. The facility is required to perform monthly inspections by SPCC trained personnel, keep copies of all inspections, receive annual SPCC training, and maintain proper spill kits appropriate for the type and quantity of material stored.

In an effort to reduce SPCC program liability, it is recommended the drum size be reduced from 55 gallon to 30 gallon drums. Replacing the existing four 55 gallon drums (220 gallon capacity) with four 30 gallon drums (120 gallon capacity) will allow the facility to be removed from the SPCC Plan, thus reducing or eliminating the required monthly inspections, annual documented training, and potential regulatory fines and penalties.

Alternative Advantages Disadvantages Replace the four 55 gallon drums with four 30 gallon drums

- Eliminate regulation of the facility by the SPCC Plan

- Reduce the regulatory inspections and training requirements

- Reduce the total volume stored on site

- Assist with more efficient transfer of oil due to smaller drums

- Reduce potential regulatory fines

- Waste stream will need to be managed IAW Used Oil regulations 40 CFR 279 and FAC 62-710

Potential Cost Item Alternative 1 *30 Gallon Drums $237.23 Total Potential Costs $237.23

Potential Savings Alternative 1 **Monthly Inspections $60.00 **Annual Training (2 employees) $20.00 ***Potential Fines $12,000 - $25,000 Total Potential Savings $12,000 - $25,080

*Global Industrial - $55.95 each x 4 + 6% sales tax **Labor Rate (Fast Food Manager Salary per http://www.payscale.com/research/US/Job=Fast_Food_Manager/Hourly_Rate) = $10.00/hour **Inspections - 1/month or 12/year x 30 mins/per inspection = 6 hours/year **Annual Training - 2 employees x Labor Rate of $10.00 ***Potential Fine Costs are from Penalty Matrix from CIVIL PENALTY POLICY FOR SECTION 311(b)(3) AND SECTION 311(j) OF THE CLEAN WATER ACT, Office of Enforcement and Compliance Assurance August

1.4.2 Develop a Transfer Oil and Clean Containment Procedure

Facility personnel transfer the used cooking oil from the container to the drums. Since there are different personnel engaged with the activity and not all personnel fully understand the procedures, it is recommended a procedure be developed to assist with the transfer, clean up, and disposal of any spilled material (if needed) to ensure all personnel understand how to better manage the waste stream in an effort to reduce liability.

Alternative

Advantages Disadvantages

Develop a hard copy administrative procedure and post a copy in the kitchen as well in the covered drum storage area

- Allow personnel to understand the means/methods of when and how to transfer the used cooking oil to the drum

- Reduce spills

- Reduce potential regulatory fines

NA

Potential Cost Item Alternative 1 *Labor $20.00 **Materials $25.00 Total Potential Costs $45.00

Potential Savings Alternative 1 ***Potential Fines $12,000 - $25,000 Total Potential Savings $12,000 - $25,045

*Labor Rate (Fast Food Manager Salary per http://www.payscale.com/research/US/Job=Fast_Food_Manager/Hourly_Rate) - $10.00/hour x 2 hours **Materials include hard copy(s) and laminate sheets ***Potential Fines Costs are from Penalty Matrix from CIVIL PENALTY POLICY FOR SECTION 311(b)(3) AND SECTION 311(j) OF THE CLEAN WATER ACT, Office of Enforcement and Compliance Assurance August 1998