At the de Lugo Building, Respondent, over a three year period, utilized and disposed of a moderately large number of fluorescent bulbs (approximately 1,300 bulbs) in the trash and evidence of bulb breakage was noted. Disposal in the regular trash may have potentially exposed people to metallic mercury vapor and may have led to the release of mercury into the environment. Respondent had failed to determine whether its spent fluorescent lamps were hazardous wastes over an extended period of time. Hazardous waste lamps constituted the predominant potentially hazardous wastestream for the facility.
This Case Action seeks to bring a halt to the aforementioned activities and seeks compliance with generator requirements at this and all R2 GSA facilities.