11_2_2022_-_PAFB-_141_-_920_Hydraulics_P2OA_docx_0002.pdf

45 Space Wing P2 Opportunity 141: Hydraulics Shop, 750 –

1.1 Description

This Pollution Prevention Opportunity Assessment (P2 OA) addresses potential pollution prevention (P2) alternatives for the Hydraulics Shop located in Building 750, 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 Auto Hobby personnel are responsible for preventative and corrective maintenance on government and civilian owned vehicles. Maintenance activities include fluid changes, brake jobs, resurfacing drums and rotors, air condition system recharges, mopping shop floor, and battery replacement.

1.3 Waste Streams

The following waste streams are generated by processes performed by Auto Hobby personnel: used oil, antifreeze, petroleum contaminated solids, used rags, batteries, brake dust, scrap metal, mop water, and fluorescent lights for internal lighting.

1.4 Potential P2 Alternatives

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

1.4.1 Develop a Transfer Oil and Clean Containment Procedure

Facility personnel generate used oil as a result of shop processes. The used oil is captured in a steel 30 gallon container and pumped from the container to the aboveground storage tank (AST) via a pneumatic pump. Due to past releases, personnel turnover, inefficient overfill protection devices, and inadequate understanding of how the system functions, it is recommended a thorough 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 standard operating procedure and post a copy in the shop adjacent to the pump as well at the AST

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

- Reduce spills

- Reduce potential regulatory fines

NA

Potential Cost Item Alternative 1 *Labor $50.00 **Materials $25.00 Total Potential Costs $75.00

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

*Labor Rate (Auto Service Manager Salary per http://www.payscale.com/research/US/Job=Service_Manager_Automotive/Salary

- $25.00/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