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Rev date: 1/14/15 Attachment 6. LLNL Violation Tracking Spreadsheet - Hazardous Waste Generator RECEIVED ^E I` V'� D September - October 2015 /C LLNL Site 300 .IAN 14 ZO16 Violation Regulation/Code Violation Description Inspection Report Action Status Report Item q Violation Class Item ENVIRONMENTAL CCR 66273.35 STORED UW ONSITE GREATER THAN ONE YEAR OR WAS UNABLE TO DEMONSTRATE THE TIME UW HAS 713 Class 11 BEEN STORED CCR 66273.35 Stored UW onsite greater than one year or was unable to demonstrate the time UW has been stored. The following observations were made during the inspection: Immediately dispose of Universal waste may be accumulated for no longer than one year from the date the universal waste was this waste and submit a a generated. The universal waste handler shall be able to demonstrate the length of time that the universal copy of the disposal Disposal receipts are provided in Attachment 11. waste has been accumulated. Since it could not be demonstrated how long this waste was stored on site, receipt to the EHD. immediately dispose of this waste and submit a copy of the disposal receipt to the EHD. At 865 Corp Yard, two fluorescent tubes were stored open and unlabeled. Violation acknowledged and corrected. Fluorescent tubes disposed as Universal Waste (see Bill of Lading 12/10/2015). b See above. Corrected the day of inspection. Transported to the 883 WAA for management as Universal Waste. See Attachment 11. At Corp Yard north of 865, there were electronics waste and a CRT stored on the ground and a pallet Violation acknowledged and corrected. including a microwave, a computer monitor, a keyboard, and lamps without a label. CRT, computer monitor, and keyboard were disposed as Universal Waste c See above. see Bill of Lading dated 1/7/2016). Lamps were disposed as Universal Waste (see Bill of Lading 12/10/2015). See Attachment 11. At building 874, electronics waste was stored on a pallet outside without a label. LLNL requests SJCEHD to rescind the violation. d See above. Refer to LLNL response dated 12/4/15. 715 CCR 66273.39FAILED TO KEEP COMPLETE RECORDS OF EACH SHIPMENT OF UNIVERSAL WASTE FOR THREE YEARS Class II1 Copies of universal waste disposal records for 2012, 2013, 2014 and 2015 were not found on site. Universal Immediately locate a copy LLNL requests SJCEHD to rescind the violation. waste shipments are going to the Livermore facility for disposal according to Kenneth Newman. Universal of all universal waste waste disposal records shall be retained for three years and have them readily available for review. disposal receipts for the Refer to LLNL response dated 12/4/15. a Immediately locate a copy of all universal waste disposal receipts for the last three years, maintain them on last three years, maintain site, and submit copies to the EHD. them on site, and submit copies to the EHD. RCRA Large Quantity Hazardous Waste Generator Inspection Report