United States
                           Environmental Protection
                   Solid Waste
                   and Emergency Response
         EPA 530-F-97-024
         August 1997
    Changed RCRA
Generator Status from
Large Quantity to Small

    Significant reductions
in costs

    Developed Teamwork
& Trust Throughout the Base

 "Don't reinvent the wheel.
Recognize that others have
done this successfully. Realize
that you're not alone out there,
and apply others' ideas to your
Waste Minimization:  Relief
from RCRA  Large Quantity
Generator Status
105th  Airlift Wing,  New
York Air  National  Guard
 What is the 105th Airlift

    The 105th Airlift Wing is an Air
 National Guard Base in Newburgh,
 New York. Work at the base
 revolves around the enormous C-5
 Galaxy, a plane used to transport
 military personnel and their equip-
 ment. The Wing uses solvent sinks
 for cleaning and degreasing the C-
 5s.  Many different solvents are
 used at the base, such as PD 680, oil
 degreasers and defoamers, methyl
 ethyl ketone, and light paint thin-
 ners. The Wing also uses several
 types of detergents that may contain
 light oils, paraffin waxes, or linseed

 What Did They Accomplish?

    The 105th Airlift Wing, formerly
 regulated under RCRA as a Large
 Quantity Generator (LQG), has
 recently achieved the less regulated
 status of Small Quantity Generator


    The group achieved its SQG sta-
 tus through the acquisition of aque-
 ous-based parts washers and
 through elimination of some solvent
 sinks and downsizing of others.
The new parts washing solvents are
not hazardous under current regula-
tions and output from the washers
is 96 to 99% pure steam, alleviating
the need for further emission con-
trols. Total waste generation is very
small, to the point where it is diffi-
cult to quantify, but can be estimat-
ed at approximately one pound per
year of solid waste and three gallons
per year of liquid waste. This
amount is in contrast to much larger
volumes, which Master Sergeant Jan
Brown, Chief of Bio-Environmental
Engineering Services, could not
quantify but classified as "...enor-
mous... highly significant."

   Another major benefit of the
program was the development of
teamwork and trust between the
environmental managers and per-
sonnel from throughout the base.
Because of the success of these pro-
grams, environmental managers
have gained credibility, allowing
them to continue environmental
efforts in other areas.
Regulatory Relief

   Having achieved SQG status, the
105th Airlift Wing enjoys fewer and
less stringent reporting and record-
keeping requirements.  In addition,
the 105th Airlift Wing has reduced
the use of Emergency Planning and
Community Right-to-Know Act

 Waste Minimization: Relief from RCRA LOG Status
 105th Airlift Wing
(EPCRA) Section 313 chemicals to
the extent that it no longer must
submit Form Rs. The reduction in
labor hours formerly used to pre-
pare Form Rs saves money for the

The Implementation Process

   The idea to replace and down-
size solvent sinks originated from
several sources, including EPA, the
Occupational Safety and Health
Administration (OSHA), Surgeon
General bulletins, the Air Force
Center for Environmental Excellence
(AFCEE), and EPA-Air Force "Cross
Talk" newsletters and conferences.
In addition, many ideas originated
in house, thanks to  a quality initia-
tive that motivated  personnel. The
Hazardous Materials Pollution
Prevention (HMP2) Team reduced or
eliminated solvents in all areas
where they were used. Seven to 15
sinks were eliminated from various
functional areas within the base, the
smallest being approximately 25 gal-
lons and the largest about 300 gal-

   As part of the process, the Wing
purchased new equipment to test
oil, Halon, refrigerants, and
antifreeze, a reclamation system
used to capture airplane de-icing
materials, and jet washers to replace
the solvent sinks. An engineering
company supplied the jet washers,
which were, in essence, "glorified
dishwashers." The manufacturer
installed the washers and trained
personnel on  their use.
Economics: Costs and

   Waste minimization efforts have
resulted in significant reductions in
costs that are tracked monthly and
reported quarterly to Command.
Savings have generated positive
feedback from commanding officers.
Much of the money saved through
waste minimization efforts is
returned to the base for uses that
include recreation equipment.


   At the program's inception, per-
sonnel expressed general skepticism
and resistance. However, environ-
mental managers welcomed the
input of workers and empowered
them in project development. As a
result, acceptance increased rapidly.
Now, Master Sergeant Brown
explains, staff members regularly
approach him with new waste mini-
mization ideas.  The 105th Airlift
Wing also implemented an electron-
ic bulletin board that staff can use to
point out base activities that are can-
didates for waste minimization.

Words to the Wise

   Master Sergeant Brown recom-
mends getting all levels of staff,
especially those doing the actual
work, involved.  "...That's been our
success story ... solicit people's
ideas, and let them learn by doing ...
give them a real stake in the process,
as opposed to making a 'token
effort' to obtain their involvement.
Allowing workers to become  key
players can be integral to the pro-
gram's success."  Master Sergeant
Brown also cautioned others:  "don't
reinvent the wheel." He stressed
that those beginning programs
should recognize that others have
done this successfully. Realize that
"you're not alone out there," and
apply others' ideas to your needs.
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                           Reducing IOHCS m Our Ratal's Waste