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Disputed Violations from LLNL Site 300 Hazardous Waste Generator <br />September -October 2015 inspecti on <br />CCR 66265.31- Facility not maintained to minimize the release of a hazardous <br />g3LI1 <br />Outside ofbuilding874,twa <br />Particle s ize anaiy,, is indicate the <br />Two LLNLs taffstated that all metal is rec�cled <br />rectangulars crap metal bins had <br />metalfines are not less than 100 <br />and all metal fines are handled as hazardous <br />metalfines. Both Dawn Kramer <br />microns; therefore, the metal is not <br />tiraste_ <br />and Kenneth hlewrmanstated the <br />considered hazardous waste due to <br />waste from the bins goes to metal <br />particle size_ The metal will be <br />recycling. Ih.1r. Newman confirmed <br />managed as scrap metal. Referto <br />that all metal fines are being <br />Attachment8,Particle Size.Analysis. <br />managed as hazardous waste. <br />t1301 <br />At building3278, metal fines <br />Particle size analysis indicate the <br />IMetals will be recycled and were not 100 <br />generated from s heel metals were <br />metal fines are not less than 100 <br />microns or less. <br />obs er.-edanarid around the table <br />microns; therefore, the metal is not <br />vise, belt s ander, and wart -table in <br />cons lderedhazardous waste due to <br />the mechanics hop. <br />particle size. The metal will be <br />managed as scrap metal. Referto <br />.Attachment8,Particle3izeAnahisis. <br />*301 <br />At building343, metalfines were <br />Particlesize analysis indicatethe <br />Metals will be rec/cled andwere not 100 <br />observed in the outdoorworking <br />metalfines are not less than 100 <br />microns orless. <br />area around a machine labeled <br />microns; therefore, the metal is not <br />"Metal Only." Accordir oto Larry <br />cons idered hazardous waste due to <br />Griffin, the metalfines are <br />particle size. The metal will be <br />generated from steel. <br />managed as scrap metal. Referto <br />Attachment 8, Particle Size Analys is. <br />From: Mancieri, Sav [mailto:mancieril@Ilnl.gov] <br />Sent: Thursday, February 11, 2016 7:14 AM <br />To: Kasey Foley [EH] <br />Cc: Kato, Thom <br />Subject: RE: Amended Response to LLNL Request for Rescinding Violations <br />Kasey, thank you for getting back to us so quickly. We will get the additional information to you on the remaining 5 <br />unresolved violations. <br />Also, violation for #202/6806 <br />This violation was initially listed in the inspection report under #202 (25189.5(a)) - Disposed or caused disposal at an <br />authorized point. <br />5 <br />