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IJBASELINEENVIRONMENTAL CONSULTING Memorandum 8 October 2020 Page 2 later pumped directly into the trench drain). From the trench, the water is pumped into Baker tanks (two 20,000 gallon Baker tanks are used) that is located outside the reactor building. It is estimated that approximately 11,000 gallons of water is collected per event (after three events in 2019 the tank is still not full. Water samples from the pipeline drain, trench, and sump pump pipeline have been collected and analyzed at an analytical laboratory. The mercury concentration of the water in the trench has averaged 3.0 ug/L for the seven events in 2018- 2019. To our knowledge, mercury released from broken UV lamp is the only contaminant in the water in the trench drain. Regulatory Review This section presents a review of the state and federal hazardous waste regulations that apply to the mercury-contaminated water and determines whether this mercury-contaminated water temporarily stored as the Tesla Treatment Facility should be considered a hazardous or non- hazardous waste under these regulations. Hazardous Waste Determination Hazardous waste determination is conducted pursuant to California Code of Regulations Title 22 (22 CCR) section 66262.11. Mercury-contaminated water is not on the list of excluded materials from regulation under 22 CCR section 66261.4 or section 25143.2 of the Health and Safety Code (HSC). Mercury and mercury compounds are listed in Appendix X of Chapter 11 of 22 CCR, which create a presumption that the mercury-contaminated water may be a hazardous waste. However, mercury-contaminated water from lamp break is not listed as a hazardous waste in articles 4 or 4.1 of chapter 11 of 22 CCR. In this case, the hazardous waste presumption can be removed using analytical testing or knowledge of how the mercury- contaminated water was generated and comparing that information with the hazardous waste characteristics set forth in article 3 of chapter 11 of 22 CCR, including toxicity, reactivity, ignitability, and corrosivity. The mercury-contaminated water does not have the characteristics of reactivity, ignitability, or corrosivity pursuant to the characteristics set forth in 22 CCR section 66261.21, 66261.22, and 66261.23. For the Tesla Treatment Facility's mercury-contaminated water, toxicity is the most relevant characteristic due to the chemical and physical properties of elemental mercury. The measured mercury concentration is about 3.0 ug/L in the trench, which is far below the federal and state hazardous waste thresholds listed in Table 1. Thus, the mercury-contaminated water is not a toxic hazardous waste. Therefore, the mercury-contaminated water can be classified as a non-hazardous waste because it does not exhibit any of the four characteristics of hazardous waste identified in article 3. 04 Memo-Baseline-10/8/20