1) Respondent failed to operate facility so as to minimize the possibility of fire, explosion or unplanned release of a hazardous waste constituent, mercury, to the air that might result from its management of spent flourescent light bulbs, thereby threatening human health or the environment. This is a violation of 40 CFR 264.31; NJAC 7:26G-9.1(a); and Section II(3) of Haz.Waste Facility Permit. 2) Modify equipment/improve operation of bulb eater crushing unit so as to minimimize threat of releases of mercury vapors during the crushing of spent bulbs in an approved crushing unit. The Respondent has a Hazardous Waste Facility Permit and violated both the permit requirement and the State of New Jersey regulation (The New Jersey regulation is cited because the State of New Jersey was authorized to conduct a hazardous waste program).
Fort Dix will develop an SOP for the operation of the Bulb Crusher and implement a sampling and analysis plan to ensure that the procedures in the SOP prevent exposures of workers above the NIOSH REL. A final report will then be submitted to EPA upon completion of the sampling and analysis evaluation.