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Rev date: 1.20.17 <br />Color Code Legend: <br />Attachment 2. violation Tracking Spreadsheet <br />Green highlight <br />- Violation acknowledged <br />and corrected. <br />Yellow highlight <br />- Corrective action in progress. <br />violation <br />Regulation/Code <br />violation Description <br />Corrective Action Requirement <br />ENV777`°7 77777 7- <br />L.LNL Response/Status N1 E <br />Report 4 <br />Violation Class <br />102 <br />CCR 66262,11 <br />Failed to determine if a waste is a hazardous waste. <br />Class 11 <br />Immediately make a hazardous <br />CCR 66262,11 Failed to determine if a waste is a hazardous waste, The following observations were made <br />waste determination for the <br />during the inspection. <br />above listed items, and manage <br />Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately make a <br />them according to the Title 22 <br />hazardous waste determination for the above listed items, and manage them according to tile l'iLle 22 <br />hazardous waste regulations. <br />hazardous waste regulations. Submit a statement and supporting docurnentation explaining how this <br />Submit a statement and <br />waste was rnanaged. <br />supporting documentation <br />explaining [low this waste was <br />managed. <br />Violation acknowledged and corrected. <br />B-875 - compressor oil drain equipment with black oily sludge. Waste was determined to be hazardous <br />See above, <br />The waste was transported to 8883 WAA for management as hazardous <br />a <br />after noted during inspection. <br />waste. The LLNL Waste Disposal Requisition is attached to document <br />..... . ... . . . . . . . . ............. ......... . <br />- — - --- <br />acceptance of the waste into the 8883 WAA. See Attachment 3, #102 as <br />Violation acknowledged. <br />The oil was pumped into containers compatible with the waste and <br />managed Pursuant to 22 CCR, Division 4.5, Chapter 29, Standards for the <br />Management of Used Oil and LI&SC Chapter 6.5, Division 20, Article 13, <br />Management of Used Oil. The Waste Disposal Requisition is provided in <br />8-872- Eleven transformers were seen outside building 872. Analytical data indicated the oil did not <br />Attachment 3, #102 b as docurnentation of storage of the waste in <br />b <br />contain PCBs. The waste will be handled as California regulated hazardous for toxicity. Provide the EFID <br />See above. <br />B883WAA. The hazardous waste manifest will be submitted to END when <br />with a copy of the hazardous waste manifest for the transformers. <br />the waste is shipped to the offsite disposal facility. <br />The empty transformer carcasses will be managed as scrap metal pursuant <br />to 22 CCR 66261.7, Contaminated Containers. The carcasses will be <br />transported to the Livermore site and consolidated with other scrap metal <br />prior to transport to the offsite scrap metal facility. I lie Bill of Lading that <br />documents the shipment of the carcasses from LLNL Site 300 to LLNL <br />. . . ........... <br />Livermore will be provided once the scrap metal is shipped. <br />Violation acknowledged and corrected. <br />The filter was determined to be California hazardous waste for the <br />B 867 - A rusted abandoned piece of equipment seen on a wooden pallet near building 867 has a filter <br />characteristic of toxicity. The filter was transported to 8883 WAA for <br />c <br />still attached. It could not be determined what the filter was used for on the piece of equipment. it <br />See above. <br />management as hazardous waste. The LLNL Waste Disposal Requisition is <br />appeared to be dirty, oily and waste like, <br />attached to document acceptance of the waste into the 8883 WAA, <br />. . . . . .................. <br />.................... . .... .......... . <br />- - _-- - , .................. .... . ...... ____ ....... . ........ <br />. . .......... . . ..................... <br />See Attachment 3, #102 c. <br />.. . ....... . ....... . . .... . ... ........ . ... . .. . ...... . . . ....... . ... . ..... <br />