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Disputed Violations from LLNL Site 300 Hazardous Waste Generator September -October 2015 Inspection #605 At building 843, a 5 gallon white The metal will be managed as scrap metal. Metals will be recycled and were not 100 microns or This violation is rescinded. container of metal fines was not labeled. The photo indicates the metal is larger than less. 100 microns and therefore is not hazardous waste. Refer to Attachment 7, page 6. Refer to Attachment 8, Particle Size Analysis. #605 At building 874, a vacuum machining for The dust collection system is equipment and Dust collection systems (baghouse waste) are This violation stands (unless an air district collecting metal fines was not labeled. not a hazardous waste generator Satellite regulated as tanks under Title 22 unless the baghouse permit exists for this collection system). Accumulation Area accumulation container system operates under a permit by another agency or tank subject to 22 CCR 66262.34 such as an air district. requirements. Refer to Attachment 7, page 18. CCR 66273.33.5 -Failed to properly manage universal waste electronic devices, CRTs or CRT glass #706 At building 874, electronic waste were The electronics are usable equipment; The electronic waste is still in use by LLNL. It cannot This violation is rescinded. left outside next to the bunker in a box. therefore, 66273.33.5 does not apply. Refer be stored in such a way as to cause a release to the to Attachment 7, page 21. environment (uncovered, outside). Properly store this electronic equipment. CCR 66273.34 -Failed to label universal waste to identify type of universal waste #712 At building 874, electronic waste was The electronics are usable equipment; The electronic waste is still in use by LLNL. It cannot This violation is rescinded. stored on a pallet outside without a therefore, 66273.33.5 does not apply. Refer be stored in such a way as to cause a release to the label. to Attachment 7, page 21. environment (uncovered, outside). Properly store this electronic equipment.