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Rev date:1/13/2016 Attachment 4.LLNL Violation Tracking Spreadsheet-Hazardous Materials Program(HMP) RECEIVED September-October 2015 LLNL Site 300 .IAN 14 2016 ENVIRONMENTAL Remarks Response Status Violation Report Regulation/Code IiEALTH DEPARTMENT Item N Violation Class Discovered three cylinders of Freon 13. The containers were in the ChemTrack disposed table. Violation acknowledged and corrected. Resurrected the containers in the ChemTrack inventory and add Freon 13 k to the HMP inventory. Corrective action date 11/10/15. See CERS Submittal 11-10-2015(Attachment 7) Discovered four non-bar coded cylinders at B834A. It was impossible to determine the Violation acknowledged and corrected. contents of these cylinders at the time of the inspection. Two of the non-bar coded containers contain Freon 13. Bar coded the two containers and add them to the ChemTrack inventory. Freon 13 was added to the HMP inventory on 11/10/15 with a maximum daily amount of 2,100 cubic feet. The maximum daily amount at Site 300 after the addition of the two cylinders will be 1,750 cubic feet. Not necessary to update HMP inventory. The other two non-bar coded containers are R-5088. One is empty,and the other contains a maximum of 70 pounds of R-5088(assuming it is 100%full). The non-empty cylinder of R-5088 was bar coded and entered into the ChemTrack inventory. R-5088 is the same as SUVA 95. The specific volume is approximately 4.1 cubic feet per pound,so based on a charge of 70 pounds and the 70 pounds of SUVA 95 already in the ChemTrack database,there are approximately 574 cubic feet of SUVA 95 at Site 300. We previously reported a maximum daily quantity of 450 cubic feet of SUVA 95 in the HMP. Since we don't exceed the maximum daily quantity by 100 percent,we don't need to file an amendment to the HMP. Not necessary to update HMP inventory. Discovered a 55-gallon plastic container of Purasolv EL. The container was in the ChemTrack Violation acknowledged and corrected. disposed table. The material had been moved to a cold and dark facility,and proper transfer procedures were not followed. Purasolv EL is already in Site 300 HMP inventory with a maximum daily m quantity of 100 gallons.After resurrecting the 55 gallon container in the ChemTrack inventory,there are a total of 55.3 gallons of Purasolv EL at Site 300. Not necessary to update HMP inventory. There was disagreement concerning hazardous waste streams. We have been using categories Violation acknowledged and corrected. to report hazardous waste(e.g.,Waste,aqueous solution with metals or Waste,organicsolids with halogens). The inspectors want each waste stream broken out. For example,if you have Hazardous waste listed by material and not by hazard class as noted in the n three 55 gallon drums and one drum contained methanol,the second ethanol,and the third a Hazardous Materials Program Inspection Report. Corrective action date mixture of the two,then you would have three separate waste streams. You couldn't 1/11/16. aggregate and call the waste stream flammable alcohols. See CERS Submittal 01-11-2016(Attachment 7). Hazardous Materials Program Inspection Report 3