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SAN J 0 A Q U 1 N Environmental Health Department <br /> U ; i y 1 Iii <br /> Small Quantity Hazardous Waste Generator Inspection Report <br /> Facility Name: Facility Address: Date: <br /> TRACY USD-MERRILL WEST HIGH SCHOOL 1 1775 W LOWELL AVE, TRACY January 31, 2020 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item# Remarks <br /> 704 CCR 66273.33(b) UW handler failed to properly manage universal waste lamps. <br /> OBSERVATION: The facility is managing universal waste(UW)lamps in a way that does not prevent a release of <br /> waste to the environment. The following UW lamps were observed in maintenance room: <br /> -1 box with 36 fluorescent tubes observed with no universal waste label and non-secure lid. Operator filled out <br /> universal waste label and attached to box. Box observed still open. <br /> -1 box with 4 fluorescent tubes observed with no universal waste label and non-secure lid. Operator filled out <br /> universal waste label and attached to box. Box observed still open. <br /> -1 box with 20 fluorescent tubes observed with no universal waste label and non-secure lid. <br /> -1 box with 30 fluorescent lamps observed with no universal waste label and non-secure lid. Operator corrected on <br /> site. <br /> -1 box with 40 fluorescent lamps observed with no universal waste label and non-secure lid. Operator corrected on <br /> site. <br /> -1 box with 30 fluorescent lamps observed with non-secure lid. <br /> REGULATION GUIDANCE: <br /> (b)Lamps(including M003 wastes that contain lamps).A universal waste handler shall manage lamps in a way that <br /> prevents releases of any universal waste or component of a universal waste to the environment, as follows: <br /> (1)A universal waste handler shall contain any lamp in a container or package that is structurally sound, adequate <br /> to prevent breakage, and compatible with the contents of the lamp. Such a container or package shall remain <br /> closed and shall lack evidence of leakage, spillage or damage that could cause leakage under reasonably <br /> foreseeable conditions. <br /> (2)A universal waste handler shall immediately clean up and place in a container any lamp that is broken and shall <br /> place in a container any lamp that shows evidence of leakage or damage that could cause the release of mercury or <br /> other hazardous constituents to the environment. Containers shall be closed, structurally sound, compatible with the <br /> contents of the lamps and shall lack evidence of leakage, spillage, or damage that could cause leakage or releases <br /> of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions. <br /> (3)A universal waste handler may remove a lamp from a product or structure, provided the universal waste handler <br /> removes the lamp in a manner designed to prevent breakage. <br /> CORRECTIVE ACTION: Immediately place all UW lamps into closed, structurally sound containers with labeling: <br /> "universal waste-lamps". Provide a corrective action statement and supporting documentation to the San Joaquin <br /> County Environmental Health Department(EHD)within 30 days. <br /> This is a repeat violation, Class II. <br /> FA0012045 PR0518789 SCO01 01/31/2020 <br /> EHD 22-01 Rev.9/20/2019 Page 5 of 8 Small Quantity Hazardous Waste Generator OIR <br /> 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com <br />