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