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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 Status Report Item # Violation Class Item CCR 66265.17(b), 66265.177 406 Class II FAILED TO MANAGE INCOMPATIBLE WASTES IN CONTAINERS PROPERLY At 875 upper Corp Yard, Nexguard 22352, Nalco 2895 Plus, Chemtreat CL49, Transport Plus 2858 and Nalco LLNL requests SJCEHD to rescind the violation. 2833 were all stored together without any physical separation in a shed. Incompatible wastes shall not be placed in the same container, or in an unwashed container that previously held an incompatible waste or The Nexguard 22352, Nalco 2895 Plus, Chemtreat CL49,Transport Plus 2858 material. A container holding a hazardous waste that is incompatible with any waste or other materials and Nalco 2833 chemicals are compatible according to the MSDS sheets. a transferred or stored nearby in other containers, piles, open tanks, or surface impoundments shall be Corrected on site. Attachment 9: MSDS documents for Nexguard 22352, Nalco 2895 Plus, separated from the other materials or protected from them by means of a dike, berm, wall, or other device. Chemtreat CL49,Transport Plus 2858 and Nalco 2833. Immediately transfer or separate the Nexguard 22352, Nalco 2895 Plus, Chemtreat CL49,Transport Plus 2858 and Nalco 2833 containers.This was corrected on site. 407 CCR 66261.7(f) CONTAMINATED CONTAINER NOT MARKED WITH DATE EMPTIED OR MANAGED WITHIN ONE YEAR OF Class II BEING EMPTIED CCR 66261.7(f) Contaminated container not marked with date emptied or managed within one year of being emptied.The following observations were made during the inspection (a-c) Immediately mark and Containers larger than five gallons that previously held a hazardous material shall be marked with the manage all empty date they were emptied and managed within one year of being emptied. Immediately mark and manage containers per this all empty containers per this section. section. At building 801,twelve 55 gallon drums that previously held Diala oil were not marked with the date that Violation acknowledged and corrected. a they became emptied. See above. Corrective action observed by inspector. Refer to Attachment 7, page 15. At building 867, one 55 gallon white empty drum that previously held Diala oil was not marked with the Violation acknowledged and corrected. date that it became emptied and has been stored at facility for"a couple of years," according to Tom b McWilliams. See above. Drum sent to 883 WAA for management as hazardous waste. Corrective action observed by inspector. Refer to Attachment 7, page 14. At 875 lower Corp Yard, one 55 gallon red drum that previously held oil was not marked with the date that Violation acknowledged and corrected. c it became emptied. See above. Drum was marked as EMPTY and the empty date. Refer to Attachment 7, page 22. 409 CCR 66262.34(e)(2) SATELLITE ACCUMULATION EXCEEDED 55 GALLONS OF HW (OR ONE QUART OF ACUTELY HW) PER WASTE Class II STREAM Observed a 20 gallon, a 30 gallon and a 55 gallon container of Nexguard 22352 and two 30 gallon containers Immediately make the Violation acknowledged and corrected. of necessary arrangements Transport Plus 2858 in a shed at 875 upper Corp Yard, . Satellite accumulation is limited to 55 gallons of to meet these limits or Hazardous waste facility personnel removed all containers that are no longer a hazardous waste or one quart of acutely hazardous waste for each process or group of processes. needed. All waste items were managed as hazardous waste. RECEIVED move all waste to the Immediately make the necessary arrangements to meet these limits or move all waste to the hazardous hazardous waste storage Refer to Attachment 7, page 25. waste storage area. DEC 0 2015 area. ENVIRONMENTAL HEALTH DEPARTMENT RCRA Large Quantity Hazardous Waste Generator Inspection Report 8