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Disputed Violations from LLNL Site 300 Hazardous Waste Generator September -October 2015 Inspection CCR 66262.11 -Failed to determine if a waste is a hazardous waste Violation Violation Description LLNL Dispute Explanation EHD Response EHD Decision # 106 At building 810 Bay 1, solid waste, The solid waste was not stored in a At the time of inspection, the operator of building 810 The violation stands because the container including wipes and Q -tips, was hazardous waste container. Refer to Bay 1 told the inspector that the container was an was identified as a hazardous waste container observed in a 55 -gallon drum that was Attachment 7, page 16. empty hazardous waste container. The contents during the inspection but was storing an identified by the building operator as a were not consistent with the type of container and unidentified waste. "Form 4 hazardous waste container". may point to a training issue for the operator of that location and whomever deposited the waste into the container. # 106 At Corp Yard 843, two 55 gallon drums The iron filings were purchased for use in an Iron is not a hazardous waste unless it was At this time, the violation stands. Please and one open 5 gallon container of iron evaluation of in situ iron filings for VOC contaminated with a hazardous waste such as VOCs. provide additional information regarding the filings were observed. remediation and are still considered product. use of the iron filings. Were these particular Refer to Attachment 7, page 5. iron filings used in the VOC remediation project? If so, a hazardous waste determination must be made. # 106 At south of building 875, one 55 gallon The contents inside the drum were identified The LLNL response identified the contents of the The violation stands because a hazardous drum of unknown solid nearby a heavy as lead pipe joint seal product. It is usable drum as a result of the violation. waste determination had to be made due to equipment outside. product. the unknown status of the drum at the time of inspection. HSC 25189.5(a) Disposed or caused disposal of a hazardous waste at an unauthorized point #202 At building 806, oil leaking from a The oil did not drip into the non -hazardous During the inspection, the dripping oil was only At this time, the violation stands. Please machine was seen dripping into the waste water trench (drain). The oil was cleaned up when it was pointed out by the inspector. provide additional information regarding how drain. The waste from the drain was immediately cleaned up and placed in a The operator of the area explained to the inspector this leaking oil was prevented from entering confirmed as being hauled off as non- Satellite Accumulation Area hazardous waste that any waste in that trench would end up in the the non -hazardous waste water tote/tank as hazardous. accumulation container. The container will outside waste water collection tote/tank and is it is unlikely the first time the machine leaked be transported to the B883 Waste hauled off as non -hazardous waste. was during this hazardous waste inspection. Accumulation Area, then transferred to the At a minimum this may be failed to minimize on-site TSDF, before shipping to the off-site the release of a hazardous waste violation. TSDF as hazardous waste.