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#403 <br />#406 <br />Disputed Violations from LLNL Site 300 Hazardous Waste Generator <br />September -October 2015 Inspection <br />CCR 66265.173 -Failed to keep hazardous waste containers closed except when adding or removing hazardous waste <br />At building 807, a filter bag of high <br />explosive waste removed from the <br />process was stored open. According to <br />Robert Bates, the filter bag of high <br />explosive machining fines is pulled to <br />separate out the different high <br />explosives and is temporarily stored to <br />dry on the drain. <br />The explosives were not declared hazardous <br />waste; therefore, there was no hazardous <br />waste container to be closed. <br />During the inspection, the inspector was told this <br />filter bag of high explosives could potentially be held <br />for clients' future use, which "could be as long as 10 <br />years". This is a used material that could be <br />considered to be accumulated speculatively. If that is <br />the case, at least 75% of this waste must be used <br />within one year of being generated. <br />This violation is rescinded. If found to be a <br />waste after further research a new violation <br />will be issued. <br />CCR 66265.17(b)/66265.177 -Failed to manage incompatible waste in containers properly <br />At 875 upper Corp Yard, Nexguard <br />22352, Nalco 2895 Plus, Chemtreat <br />CL49, Transport Plus 2858, and Nalco <br />2833 were all stored together without <br />any physical separation in a shed. <br />Incompatible wastes shall not be placed <br />in the same container, or, or in an <br />unwashed container that previously held <br />an incompatible waste or material. A <br />container holding a hazardous waste <br />that is incompatible with any waste or <br />other materials transferred or stored <br />nearby in other containers, piles, open <br />tanks, or surface impoundments shall be <br />separated from the other materials or <br />protected from them by means of a <br />dike, berm, wall, or other device. <br />The Nexguard 22352, Nalco 2895 Plus, <br />Chemtreat CL49, Transport Plus 2858 and <br />Nalco 2833 chemicals are compatible <br />according to the MSDS sheets. Attachment <br />9: MSDS documents for Nexguard 2235, <br />Nalco 2895 Plus, ChemtreatCL49, Transport <br />Plus 2858 and Nalco 2833. <br />LLNL has shown the chemicals are not incompatible. (This violation is rescinded. <br />