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Disputed Violations from LI,Nl- Site 300 Hazardous Waste Generator
<br />Septembe.r-C4ctolser 2015 Inspection
<br />CCR 66262,34(f) -Failed to completely label containers or tanks of hazardous wash � r
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<br />#/605 At building 1307, a filter bag of high l he. explosives were considered material; (luring the inspection, the inspector was told this filter hag This violation is rescinded. It for.ancl to be a waste
<br />___.
<br />,y_r
<br />explosive waste rednoved from the process therefore>, the requirement to comply with 22 of high explosives could potentially be held for clients" after further research a new violation will be issued.
<br />;h-�,.
<br />was not: labeled. According to Robert CCR E. 626?.34(e)(1)(B) does not apply, future use:., which "could be as long as 10 years". This is a ( 7 3�(�
<br />Bates, the filter bag of high explosive used r-naterial that could be considered to be accr� mulated
<br />16
<br />rnachini€ig fine is pulled to separate out the speculatively, If that is the case, at least 751of this waste
<br />different highexplosive wastes and is must tare used within one year of being gcnerated,ENVIRONMENTAL_
<br />temporarily stored to dry on the drain.
<br />III:AI..($(� F�..r rNj.jr
<br />#605 At building 843, a 5 gallon white container The metal will be managed as scrap metal. Metals will be recycled and were not 100 n-0cfons or less. This violation is d
<br />rescin �
<br />s .r id,
<br />of metal fines was not labeler. The photo indicates the rnetal is larger than
<br />100 microns and therefore is not hazardous
<br />waste, Refer to Attachment 7, page 6. Refer
<br />to Attachment gr Particle .Size Analysis.
<br />##605 At building RId, a vacuum machining for the dust collection system is equipment and Lust collection systems (baghouse waste) are regulated as This
<br />vi_.a ase e following
<br />g h s violation stands (unless an air district pe.rrnit L.1_NL disputes Fat L7"s decision based on the fcallowin=information.
<br />collecting metal fines was not labeled, not a hazardous waste generator Satellite tanks under Title '22 unless the baghouse system operates exists for this collection system), f
<br />Accumulation Area aro UMUlation container or under a permit by another agency Such as an air district.
<br />The dust collecti n system is an air abatement device, The emissic>ri unit is the��
<br />tank subject to 22 CCR ia6262.34
<br />metal cr.rtting machine generating the chips and metal dust (fines), Sat) Joaquin
<br />requirements. Refer to Attachment 7, page
<br />13. Valley Air Pollution Control district (SJVAPCE7) Rule 2201 (New or Modified
<br />Stationary Sours-! Review) defines "Er'nission Source" as an identifiable ope=ration or
<br />piece of equipment such as a source operation which emit, may emit, or reSulta in
<br />the emission of eny affected pollutant directly or as fugitive emission. The machine
<br />operator. stated that he is operating the cutting machine three (3) hours per month
<br />acid ge.ne.rating the metal chips and fines of less than one (1) pound per ruonth.
<br />SJVAPCD Rule 2020 defines this equipment as <a low en)FITing emit (Section 3,1.0)
<br />generating uncontrolled ernissiorr less than or equal to 2 pounds per day or less
<br />than or equal to 75 pounds per year. Rule 202.0, SeCtiean 6.C1 (District Exempt Source
<br />Categories) Subsection 6,113 (Low Emitting Units)-Spec;ificcally exempts low emitting
<br />units from requiting an Authority to Constrr.ac.t/ Permit to Operate.
<br />CCR 66273,33.5 Failed to property manage uniVE t sal waste electronic devices, CRTs or CRT glass
<br />ment, The electronic waste is still In
<br />_ ._
<br />#706 At building 374, electronic waste were left The electronics are usable equipuse by LI NL, It cannot be This violation is
<br />outside next to the bunker In a box. thereforer, 66213-33.5 does not apply. Refer stored it) such a way as to cause a release to the
<br />to Attachment 7, page 21 t.r°evironrraerat (urrcovc�.red, orrtsitle). Properly stare this
<br />CCR 66271,14 -Failed to label Universal waste to identify type of universal este
<br />4
<br />711 .a._ At building 87,4, electronic waste was __. _.. The electronics are usable equipment; The , e _i___._
<br />_ e) .ctron,c waste is still in use by LLNL. It cannot be This violation is rescinded.
<br />stored on a pallet outside without a label. therefore, 66273,33.5 does not apply. Refer stored it-) Such a way as to cause a release to the
<br />to Attachment 7, page 21. environment (uncovered, outside), Properly store this
<br />CCR �66273,35-Stored UW onsite greater than one year or was unable to demonstrate the time UW has been stared
<br />#71..3 At building 874, electronics waste was The electronics care usable equipment; — The electronic waste is still in use by LLNL, Itr n ,
<br />ca a ct be This violation is rescinded. --
<br />stored on a pallet outside without ea label. therefore, 66273, 3:3.5 does not apply, Refer .stored in such a way as to cause: a release to the
<br />to Attachment 7, page 21. environment (uncovered, Outside), Properly �tore this 471.5 Copies of universal waste disposal reccxds All universal waste records for the This vi — is rescinded,
<br />_ past. three is not a violation as the universal waste records were This violation is rescinded.
<br />for 2012, 2013, 2014, and 2O15 were not years were kept and provided of) Septernber provided during the inspection.
<br />found on site. Universal waste shipments 30 and again on October 10, 2015, Universal
<br />are going to the Livermore: facility for waste records for the last three years attached
<br />disposal according to Kenneth Newman. (Attachrnent 1.1).
<br />Universal waste disposal records shall be
<br />retained for three years and have them
<br />readily available for review, immediately
<br />locate a copy of all universal waste disposal
<br />receipts for the last three years, maintain
<br />therm on site, and submit copies to the
<br />EIAD1
<br />2/25/2016
<br />3
<br />ES11 EFA -WP -1.6-1;361.1
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