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Rev date: 12.3,15 Attachment 6. LLNL Violation Tracking Spreadsheet - Hazardous Waste Generator September - October 2015 LLNL Site 300 Violation Regulation/Code Violation Description Inspection Report Action Report Item #f Violation Class___-_ . . . . .......... . . . . . . ......... Item Status 712 CCR 6627334 Class 11 FAILED TO LABEL UNIVERSAL WASTE TO IDENTIFY TYPE OF UNIVERSAL WASTE . ...... . . . . ...... CCR 66273.34 Failed to label universal waste to identify type of universal waste. The following observations were made during the inspection (a-c} immediately label these Universal waste shall be marked with the words "Universal Waste" and the type of waste (batteries, wastes and ensure that all mercury containing equipment, lamps, electronic devices, CRT's, CRT glass), Immediately label these universal wastes are wastes and ensure that all universal wastes are labeled with the required information. labeled with the required information, At 865 Corp Yard, two fluorescent tubes were stored open and unlabeled. Violation acknowledged and corrected. a See above. Corrected the day of inspection. Transported to the 883 WAA for managernent as Universal Waste. . . ...... Refer to Attachment 7, page 3. At Corp Yard north of 865, there were electronics waste and a CRT stored on the ground and a pallet Violation acknowledged and corrected. b including a microwave, a computer monitor, a keyboard, and lamps without a label. See above. Electronics waste vvas removed and managed as hazardous waste. Refer to Attachment 7, page 4. At building 874, electronics waste was stored on a pallet outside without a label. LLNL requests SJCEHD to rescind the violation, c See above. The electronics are usable equipment; therefore, 66273.34 does not apply, Refer to Attachment 7, page 21, 713 CCR 66273,35 STORED UW ONSITE GREATER THAN ONE YEAR OR WAS UNABLE TO DEMONSTRATE THE TIME LJW HAS 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: Universal waste may be accumulated for no longer than one year from the date the universal waste was Immediately dispose of a generated. The universal waste handier shall be able to demonstrate the length of time that the universal this waste avid submit a MsposA receipts for 113b, 713c to be submitted after waste transpoited waste has been accumulated, Since it could not be demonstrated how long this waste was stored on site, copy of the disposal off-site, immediately dispose of this waste and submit a copy of the disposal receipt to the EHD, receipt to the EHD, At 865 Corp Yard, two fluorescent tubes were stored open and unlabeled. . . . . .... . ....... Violation acknowledged and corrected. b See above. Corrected the day of inspection. Transported to the 883 WAA for management as Universal Waste. Refer to Attachment 7, page 3. RECEIVED DEC 0 4 2015 ENVIRONMENTAL HEALTH DEPARTMENT RCRA Large Quantity Hazardous Waste Generator Inspection Report 12