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Rev date: 12.3.15 Attachment 6. LLNL Violation Tracking Spreadsheet- Hazardous Waste Generator RECEIVED September-October 2015 LLNL Site 300 DEC 04 2015 Violation Regulation/Code Violation Description Inspection Report Action Status ENVIRONMENTAL Report Item q Violation Class Item HEALTH DEPARTMENT Immediately contact a licensed hazardous waste 602 CCR 66262.34(e)(1)(B) STORED SATELLITE ACCUMULATED WASTE ON SITE LONGER THAN ONE YEAR OR 90 DAYS AFTER FILL hauler to dispose of this Class I DATE waste under manifest and submit a copy of the manifest to the EHD. CCR 66262.34(e)(1 )(B) Stored satellite accumulated waste on site longer than one year or 90 days after fill above. ill date. At 875 upper Corp Yard, several containers of Nexguard 22352, Nalco 2895 Plus, Chemtreat CL49,Transport Violation acknowledged and corrected. Plus 2858 and Nalco 2833 in a shed and four containers of chlorine tablets in a outhouse were observed. According to David Rockstead,these chemicals are no longer in use ever since he "came here almost four Hazardous waste facility personnel removed all containers in storage unit a years ago." See above. that are no longer needed including the chlorine tablets, and managed as a hazardous waste. Hazardous waste manifest will be provided after waste shipped to off-site TSDF. Refer to Attachment 7, page 25. According to Robert Bates, high explosive machining fines collected in filter bags throughout the high LLNL requests SJCEHD to rescind the violation. explosive processing areas could potentially be held for clients'future use, which "could be as long as 10 years" . Satellite accumulated waste shall not be stored on site for more than 90 days after the container See above. The explosives were considered material;therefore,the requirement to b was filled, or a total of one year,whichever comes first. Immediately contact a licensed hazardous waste comply with 22 CCR 66262.34 (e)(1)(B) does not apply. hauler to dispose of this waste under manifest and submit a copy of the manifest to the EHD. 605 CCR 66262.34(f) FAILED TO COMPLETELY LABEL CONTAINERS OR TANKS OF HAZARDOUS WASTE Class II CCR 66262.34(f) Failed to completely label containers or tanks of hazardous waste. The following observations were made during the inspection (a-f) All hazardous waste containers shall be marked with the following information: -the words "Hazardous Waste' -name and address of generator Immediately contact a -hazardous properties licensed hazardous waste hauler to dispose of this -physical state Manifests to be provided for 602a, 605c,605e, 605f -composition (contents) waste under manifest and -accumulation start date submit a copy of the manifest to the EHD. Immediately label these containers and ensure that all containers are marked with all the required information. Since these containers have been on site longer than 90 days, immediately contact a licensed hazardous waste hauler to dispose of this waste under manifest and submit a copy of the manifest to the EHD. At building 807, a filter bag of high explosive waste removed from the process was not labeled.According to LLNL requests SJCEHD to rescind the violation. Robert Bates,the filter bag of high explosive machining fine is pulled to separate out the different high a See above. explosive wastes and is temporarily stored to dry on the drain. The explosives were not considered hazardous waste;therefore, the requirement to comply with 66262.34(f) did not apply. RCRA Large Quantity Hazardous Waste Generator Inspection Report 9