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Rev date: 12.3.15 Attachment 6. LLNL Violation Tracking Spreadsheet-Hazardous Waste Generator RECEIVED <br /> September-October 2015 <br /> LLNL Site 300 DEC 0 4 2015 <br /> Violation Regulation/Code Violation Description Inspection Report Action Status ENVIRONMENTAL <br /> Report Item q Violation Class Item HEALTH DEPARTMEN <br /> CCR 66265.31 <br /> 301 Class II FACILITY NOT MAINTAINED TO MINIMIZE THE RELEASE OF A HAZARDOUS WASTE <br /> CCR 66265.31 Facility not maintained to minimize the release of a hazardous waste.The following <br /> Immediately correct all <br /> observations were made during the inspection. <br /> items listed above and <br /> According to Mr. Newman,all metal fines are handled as hazardous waste. Facilities shall be maintained manage according to Title <br /> and operated to minimize the possibility of a fire, explosion,or release of hazardous waste to air,soil,or <br /> 22 hazardous waste <br /> surface water which could threaten human health or the environment. Immediately correct all items <br /> regulations. Submit a <br /> listed above and manage according to Title 22 hazardous waste regulations. Submit a statement and statement and supporting <br /> supporting documentation explaining how this waste was managed. <br /> documentation <br /> explaining how this waste <br /> was managed. <br /> At building 827B, metal fines generated from sheet metals were observed on and around the table vise, belt LLNL requests SJCEHD to rescind the violation. <br /> sander, and work table in the mechanic shop. <br /> Particle size analysis indicates the metal fines are not less than 100 microns; <br /> a See above. therefore,the metal is not considered hazardous waste due to particle size. <br /> The metal will be managed as scrap metal. <br /> Refer to Attachment 8, Particle Size Analysis. <br /> At building 843, metal fines were observed in the outdoor working area around a machine labeled "Metal LLNL requests SJCEHD to rescind the violation. <br /> Only."According to Larry Griffin,the metal fines are generated from steel. <br /> Particle size analysis indicates the metal fines are not less than 100 microns; <br /> b See above. therefore,the metal is not considered hazardous waste due to particle size. <br /> The metal will be managed as scrap metal. <br /> Refer to Attachment 8, Particle Size Analysis. <br /> Refer to Attachment 7, page 6 <br /> A damaged pallet of well pumps was leaking oily liquid onto the ground outside of building 843. Violation acknowledged and corrected. <br /> I <br /> Oil and water in the pallet and on the asphalt were cleaned up using Dry- <br /> c See above. sorb.The clean up waste was managed as hazardous waste. <br /> Refer to Attachment 7, page 7. The pumps were moved to an intact pallet. <br /> At building 874, metal fines were observed on the floor and belt sander. Violation acknowledged and corrected. <br /> d See above. All metal fines generated from this operation have been, and will continue to <br /> be managed as hazardous waste. <br /> Attachment 8- Particle Size Analysis. <br /> RCRA Large Quantity Hazardous Waste Generator Inspection Report 5 <br />