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Disputed Violations from LLNL Site 300 Hazardous Waste Generator September -October 2015 Inspection #202 Outside of building 874, two rectangular Particle size analysis indicate the metal fines Two LLNL staff stated that all metal is recycled and all This violation is rescinded. There were no scrap metal bins had metal fines. Both are not less than 100 microns; therefore, the metal fines are handled as hazardous waste. metal fines (metals 100 microns or less). Dawn Kramer and Kenneth Newman metal is not considered hazardous waste due stated the waste from the bins goes to to particle size. The metal will be managed metal recycling. Mr. Newman as scrap metal. Refer to Attachment 8, confirmed that all metal fines are being Particle Size Analysis. managed as hazardous waste. CCR 66265.31- Facility not maintained to minimize the release of a hazardous waste # 301 At building 827B, metal fines generated Particle size analysis indicate the metal fines Metals will be recycled and were not 100 microns or This violation is rescinded. There were no from sheet metals were observed on are not less than 100 microns; therefore, the less. metal fines (metals 100 microns or less). it and around the table vise, belt sander, metal is not considered hazardous waste due should be noted that the metal recycling and work table in the mechanic shop. to particle size. The metal will be managed exclusion only applies when the metal is as scrap metal. Refer to Attachment 8, recycled. It should be cleaned up at the end of Particle Size Analysis. each shift. #301 At building 843, metal fines were Particle size analysis indicate the metal fines Metals will be recycled and were not 100 microns or observed in the outdoor working area are not less than 100 microns; therefore, the less. around a machine labeled "Metal Only." metal is not considered hazardous waste due According to Larry Griffin, the metal to particle size. The metal will be managed fines are generated from steel. as scrap metal. Refer to Attachment 8, Particle Size Analysis. This violation is rescinded. There were no metal fines (metals 100 microns or less). It should be noted that the metal recycling exclusion only applies when the metal is recycled. It should be cleaned up at the end each shift and never allowed to be stored outside on the ground where it is not contained or this will be considered failure' minimize the release of a hazardous waste , they are hazardous waste metals).