JOINT BASE ELMENDORF-RICHARDSON, Alaska -- JBER is considered a large-quantity generator of hazardous waste by the US Environmental Protection Agency.
The base has a permit to store hazardous waste for one year, and is subject to EPA inspections.
“What can come from those inspections, if we don’t properly manage hazardous and universal waste, is called a ‘notice of violation’,” said Dr. Mark Prieksat, JBER’s installation management flight chief. “For instance, last year more than $300,000 was spent on penalties and special projects to settle past allegations at this installation.”
One way to overcome these violations is to be as proactive as possible. To do this, support is being provided to all units, shops and facility managers to disseminate proper procedures, Prieksat said.
An example of a potential violation is the improper storage, labeling, and disposal of fluorescent bulbs. Because the bulbs contain mercury they are considered universal waste and are regulated by Title 40 of the Code of Federal Regulation Part 273. Based on recent in-house inspections, many facilities on this installation are not compliant, said Scott Tarbox, JBER hazardous waste program manager.
Examples of common universal waste lamps include fluorescent, high-intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.
Bulbs become waste on the date a person determines it cannot be used or recycled.
Labeling stored waste lamps is specific; according to Code of Federal Regulation, each container or package in which lamps are contained must be labeled or marked clearly with any one of the following phrases: ‘‘Universal waste—lamp(s),’’ ‘‘waste lamp(s),’’ or ‘‘used lamp(s)’’
Universal waste lamps cannot be stored on JBER for longer than one year. After lamps are used or determined to be waste, they must be stored in containers to prevent breakage; original packaging is suitable. Containers must remain closed and must lack evidence of leakage, and any pre-cut handles in the packing must be taped closed or sealed and each container must be labeled with the earliest date a lamp was placed in it.
“In the event a lamp becomes broken, personnel are required by law to immediately contain all releases of universal waste and other residues from universal waste,” Tarbox said. “Using appropriate personal protective equipment, pick up all broken lamps and residues from them, place the waste in a container, and mark the container.”
Containers must be closed, structurally sound, compatible with the contents of the lamps and must prevent leakage or damage that could cause releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions, Tarbox said.
“Although we are educating personnel on proper procedures, they do have alternative choices for the types of bulbs they use,” Prieksat said. “If personnel use ‘green bulbs’ such as the GE Ecolux® or Sylvania Ecologic fluorescent lamps, they do not fall under these same regulations because they pass the EPA Toxicity Characteristic Leaching Procedure test. This TCLP test characterizes fluorescent lamp waste as either hazardous or non-hazardous for the purpose of disposal. However, these green bulbs should still be placed in containers and turned in at the hazardous waste center located at building 4314.”
Tenants and contractors are required by law to manage universal waste lamps and all other forms of hazardous wastes they generate while working on JBER. These provisions are generally contained in the applicable tenant agreement or contract.
For more information regarding proper storage and disposal of fluorescent lamps and other hazardous waste management, call the 673d Civil Engineer Squadron environmental office at 384-3322.