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Disputed Violations from LLNL Site 300 Hazardous Waste Geri era tor <br />September -October 2015 Inspection <br />CCR 66262.11 -Failed to determine if a waste is a hazardous waste <br />Violation <br />Violation Description <br />LLNL Dispute Explanation <br />EHD Response <br />#106 <br />Atbuilding810Bay 1,solidwaste, <br />The solidwaste-wasnot stared ina <br />At the Iimeofinspection, the ape rat arof <br />including vipc5 and Q -tips, was <br />hazardous waste container. Referto <br />building810Bay IIold the ins pert arthatthe <br />observed in a 5S gallon drum that <br />Attachment 7, page 15. <br />containerwas an empty hazardous waste <br />was identified bythe building <br />container. The contents were not consistent <br />operator as a "Form 4 hazardous <br />with the Hype ofcontainer and may point to a <br />waste container". <br />training issuefortheoperatoraft hat location <br />and whomever depositedthe waste into the <br />container. <br />#106 <br />AtC:orpYard843,two 55gaIIan <br />Theiranfilings werepurchasedforuse <br />Iron is not ahazardauswas teunlessitwas <br />drums and one open 5gallon <br />in an evaluation ofin situ iranfilings <br />co nt ami nat ed wit h a hazardous was tesuch as <br />container ofironfilings were <br />forVOCrem ediationand are still <br />VOCs. <br />observed. <br />cans idered product . Referto <br />Attachment 7, page 5. <br />#106 <br />Atsouthofbuilding675,one 55 <br />Thecontenisinside the drumwere <br />The LLNLresponse identifredthecontentsof <br />gallon drum ofunknownsolid <br />identified as lead pipe joint seal <br />the drumasaresult oftheviolation. <br />nearby a hea,.y equipment <br />product. 11 is usable product. <br />outside. <br />#202 <br />HSC 25189.5(a) Disposed or caused disposal of a hazardous waste at an unauthor <br />At building806, oil leakingfrom a <br />machine was seen drippinginto <br />the drain. The waste from the <br />drain was confirmed as being <br />hauled offas non -hazardous. <br />The oil did not drip into the non- <br />hazardous was tewatertrench (drain). <br />The oil was immediately cleaned up <br />and placed in aSatellite Accumulation <br />Area hazardous waste accumulation <br />container. The containerwill be <br />transported to the 63-83 Waste <br />Accumulation Area, then transferred <br />to the on- iteTSDF,before shippingto <br />the offwsiteTSDFas hazardous waste. <br />Duringthe inspection,the dripping oil was <br />onlycleaned upwhen it was pointed out by <br />the inspector. The operator ofthe area <br />explained to the ins pectorthat any%vaste in <br />thattrenchwould end up in the outside waste <br />water collection tote/tank and is hauled off as <br />non-hazardnus waste. <br />