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San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www.sjgov.org/ehd RCRA Large Quantity Hazardous Waste Generator Inspection Repo Facility Name: Facility Address: Date: Lawrence Livermore National Lab - Site 300 15999 W CORRAL HOLLOW RD, Tracy October 31, 2016 Other Violations 3140 See below Unlisted Release/Leaks/Spills violation o V ❑ R ❑ COS 3150 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation ❑ V ❑ R ❑ COS SUMMARY OF VIOLATIONS (CLASS I, CLASS ll, or MINOR - Notice to Comply) Item # Remarks 102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. On November 1, 2016 behind building 875 a piece of equipment was seen with a black oily sludge at the bottom of the trough. The trough was covered by a grate and had what appeared to be a drainage hole. It could not be determined what the piece of equipment was used for, possibly a parts washer or a BBQ. As of November 2, the piece of equipment was deemed to be a "compressor oil drain equipment" and the waste had been cleaned and out placed in a labeled hazardous waste container. The waste was determined to be a hazardous waste. Photo 10, 14-18 Eleven transformers were seen outside of building 872. At time of inspection it could not be determined if the transformers held PCB oil. On December 16th, 2016 waste analysis was received showing the transformers did not contain PCB oil. According to the letter provided by Brian Perkins, the transformers will be handled as "California regulated hazardous waste for toxicity". The waste was determined to be hazardous, provide the EHD with a copy of the hazardous waste manifest for the transformers. A rusted abandoned piece of equipment seen on a wooden pallet near building 867 had a filter still attached. It could not be determined what the filter was used for on the piece of equipment. It appeared to be dirty, oily and waste like. Photo 4 Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately make a hazardous waste determination for the filter and manage it according the Title 22 hazardous waste regulations. Submit a statement and supporting documentation showing how the above waste streams were managed. This is a repeat violation, Class II. 103 CCR 66262.40(c) Failed to retain hazardous waste determination including waste analysis on site for 3 years. Waste analysis was not available for the non -hazardous granular activated carbon (GAC), and the eleven transformers containing unknown PCB oil outside of building 872. Photo 8 Complete waste analysis for the sludge from the oil water separator outside of building 879 was not available at the time of inspection. Waste analyses were received by the EHD on December 16, 2016. The waste analyses that were provided for the three waste streams were not complete analyses (reports). A generator shall make a hazardous waste determination and keep a record of any test results, waste analyses, or other determinations made in accordance with hazardous waste regulations for at least three years from the date that the waste was last disposed of. Immediately provide the EHD with a complete waste analyses for the three waste streams described above. This is a Class II violation. FA0003934 PR0514115 SCO01 10/31/2016 EHD 22-03 Rev. 09/22/16 Page 4 of 9 RCRA Large Quantity Hazardous Waste Generator OIR