# JOINT BASE ELMENDORF-RICHARDSON (FF)
> **Administrative - Formal** · FY2020 · — · Final Order With Penalty
## Case
- **Activity ID:** `3602261293`
- **Case Number:** 10-2020-0164
- **Type:** Administrative - Formal
- **Lead:** EPA
- **Outcome:** Final Order With Penalty
- **Penalty assessed:** —
- **Cost recovery:** —
- **Compliance action $:** —
- **Multimedia (multi-env):** —
## Defendants
- JOINT BASE ELMENDORF-RICHARDSON (complaint) (settlement)
## Summary

On September, 16, 2020, EPA Region 10 filed a consent agreement and final order (CAFO) resolving
violations of the Resource Conservation and Recovery Act (RCRA) at Joint Base Elmendorf-
Richardson (JBER). On October 9, 2019, JBER disclosed to EPA Region 10 that it had speculatively
accumulated a large quantity of expended small-arms cartridge casings (ESACCs) that exhibit the
toxicity characteristic for lead. Prior to 2017, JBER recycled its ESACCs since they are made of a
valuable commodity, brass, but in 2017, this recycling activity ceased. Since 75% of the ESACCs were
not recycled in calendar year 2018, the ESACCS became a solid waste, and those that exhibited the
toxicity characteristic for lead became hazardous waste. To date JBER has accumulated about 200,000
lbs of brass ESACCs. Under the terms of the CAFO, EPA is allowing JBER to recycle the brass
ESACCs versus disposing of it in a permitted RCRA treatment, storage, and disposal facility. The
CAFO sets forth schedules and requirements for the storage and recycling of the ESACCs in a manner
that protects human health and the environment. The CAFO also requires JBER to report to EPA on its
recycling progress, and to decontaminate the building at which the hazardous ESACCs are stored when
the recycling is completed. In addition, the settlement resolves universal waste management violations
identified during an October 7-9, 2019, EPA inspection of JBER. JBER will spend $486,500 to come
into compliance, but

---
*Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*