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Disputed Violations hell LLNL Sitl-� 300 Hazardous Waste Generator
<br />September -October 20153 Inspection
<br />Violation stands
<br />Violation rescinded
<br />LLNL response to EHL; decision
<br />I - I E - C,"i'E - I V ED
<br />R� 0 7 2 0 1 G
<br />2/25/2016
<br />ESI; -EFA -WP- 16- 13611
<br />CCR
<br />66262,11 -Failed to determine. if a waste is a hazardous waste
<br />Violation
<br />Violation Description
<br />Dispute Explanation
<br />EHD Response
<br />ENVIRONMENTAL
<br /># 106
<br />At building 810 Bay .1, solid waste, Including
<br />The solid waste was not stored in a hazardous
<br />E H D D e c i s i o n
<br />At the time of inspection, the operator of burding 81.0 Bay The violation
<br />H-Atrit
<br />LLNL Respon
<br />--f."Jecision,
<br />wipes and i was observed in a SS-
<br />gallon drum that was identified by the
<br />waste container. Refer to Attachr'nent 7, page
<br />16,
<br />stands because the container was
<br />I told the inspector that the container was an empty identified as a hazardous waste container during the
<br />I.LNI., accepts SKE11C's violation
<br />building operator as a "Frofril 4 hazardous
<br />hazardous waste container. The contents were not irlsPection but was storing an Unidentified waste,
<br />waste container,"
<br />consistent with the type of container and may point to a
<br />training issue for the operator of that location and
<br />_06-
<br />whomever deposited the waste into the container,
<br />31
<br />A't"--Co—r,p-Y--a"r--d--8-4-3,-,-t-w-(-)-"5-5- _ga _1fo`nJ_rurr_) "a-ai A
<br />The iron filings were purchased for use in air
<br />Iron is not a hazardous waste uilless it was cciltar-ninated At this time, the violation
<br />one open 5 gallon container of iron filings
<br />evaluation of in Situ iron filings for Vo('
<br />stands. Please provide
<br />with a hazardous waste such as VOCs,
<br />LLNL disputes EHD's decision based on the following information.
<br />were observed.
<br />rernediation and are still considered product,
<br />additional information regarding the use of the it -on
<br />Refer to Attachment 7, page 5.
<br />filings Were these particular iron filings used in the
<br />LLNL's Environmental Restoration Department load conducted a treatability study
<br />VOC remediation project? If so, a hazardous waste
<br />to evaluate the effectiveness of iron filings in the ex situ treatinent of voCs in
<br />determination must be made,
<br />extracted gfOUVId water. Iron filings were purchased for use in the treatability
<br />Study, and some of the filings were placed in the ex situ treatment unit, At the end
<br />of the treatability study, not all of the Iron filings that had beer) purchased for rise
<br />in the study were actually deployed into the treatability stridy treatment unit, The
<br />drums of unused iron filings (pnoduct) were stored at Corp Yard 843 in the event
<br />another applicaijojrqusce for the iron filings was determined in the future. Becal,)S(2
<br />the iron filings ill dr unrs at the 843 Corks Yard referenced in the inspection report
<br />are Unused product that were never exposed tea VOC-contaminated ground water,
<br />[T,NL contenrjs that the iron filings are not waste, hazardous or otherwise,
<br />H 106
<br />At South of building 875, one 55 gallon
<br />dream of unknown solid nearby a heavy
<br />the, contents inside the churn were identified
<br />lead
<br />the LLNL response Identified the contents of the.. drurn as a The violation stands because a hazardous waste
<br />I_LNL
<br />equipment outside,
<br />as pipe joint seal T.,,ioduct. It is usable
<br />product,
<br />I Csult of the violation, determination bad to be. made due to the unknown
<br />accepts EHID's violation decision,
<br />status of the drum at the time of inspection.
<br />4202
<br />At building 806, oil leaking ficirn a
<br />HSC 25189.5(a)
<br />Disposed or caused disposal of a�1�zardQ)LdS Wash at �t1 unauthorized p oint
<br />machine
<br />was seen dripping Into the drain. The
<br />The oil did not drip into the rion-hazardous
<br />waste water" Trench (draln). The oil was
<br />During the inspection, the dripping oil was ofil y U p At this tirne, the violation stands, Please provide
<br />it -file
<br />LLNL accepts SMEHICt's violation decision.
<br />waste from the drain was confirmed as
<br />frit-nediately cleaned up and placed in a
<br />when \s(as pointed Out by the inspector. operator of additional information regarding how this leaking oil
<br />the area explained to the inspector that any vaste in that
<br />being hauled off as non hazafdou5
<br />Satellite AccunlUlation Area hazai 'do' -is waste
<br />was prevented from critering the non-hazaidou s
<br />trench would end up in the outside waste \witer collection waste water tote/tank as it is
<br />However, H_NL. �,,sselts the oil never entered the waste eYater trench, The oil was
<br />accumulation container. The container will be
<br />unlikely the first time
<br />tote/tank and is hauled off as non -hazardous waste. the machine leaked was during this hazaidous waste
<br />wiped up immeJiatety and the oily rag placed in the hazardous waste coijection
<br />transported to the B883 Waste Accumulation
<br />container ill the room, To avoid fUtWe concerns, absorbents nts materials have been
<br />E,
<br />Area, then transfer red to the of) site TSDF,
<br />inspection, At a Minirnurn this may be failed to
<br />placed around Cie machine, It will be changed Out when the absorbent is no longer
<br />before shipping to the off-site TSDF as
<br />minit-nize the release of a hazai dous waste violation
<br />effective and w�!: be maria�ed as hazardous waste,
<br />a
<br />hazardous Waste,
<br />#202
<br />Outside of building 874, two rectangular
<br />Particle size analysis indicate the metal fines
<br />Two LLNL staff stated that all metal is recyclsd
<br />scrap metal bins had rnetal fines. Both
<br />Dawn Kramer Kenneth
<br />are not less than 100 microns; therefore, the
<br />and all This violation is rescided. There
<br />metal fines are handled as hazardous waste, fines (meltals 100 micrnons less) were no metal
<br />and Newman stated
<br />metal is not considered hazardous waste due
<br />or
<br />the waste from the bins goes to metal
<br />to particle size. The metal will be managed as
<br />recycling, Mr. Newman confii rned that all
<br />scrap metal, Refer to Attachment 8, Particle
<br />metal fines are being managed as
<br />Size Analysis.
<br />hazardous waste,
<br /># 301
<br />- - ----------
<br />At building 8278, metal fines
<br />CCR 66265.31-
<br />Particle
<br />-------
<br />Facility not maintained to minimize the release of a hazardous waste
<br />generated
<br />from sheet metals were observed
<br />size analysis indicate the metal fines
<br />Metals will be recycled and were not 100 micron s or less, This violation is rescindedThewere no etal
<br />re m
<br />on and
<br />are not less than 100 microns; therefore, the
<br />,
<br />around the table vise, belt sander, and
<br />metal is not considered hazardous waste due
<br />fines (metals 100 microns or less) It should be
<br />work table in the frrechanic shop,
<br />to particle size. The metal will be managed as
<br />noted that the metal recycling exclusion only applies
<br />scrap rnetal, Refer to Attachment 8 Particle
<br />when the metal is recycled. It should be cleaned up
<br />Size Analysis,
<br />at the end of each shift.
<br />2/25/2016
<br />ESI; -EFA -WP- 16- 13611
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