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Rev data: 12.3,15 <br />Attachment 6. LLNL Violation Tracking Spreadsheet - Hazardous Waste Generator <br />September - October 20:15 <br />LLNL Site 300 <br />Violation <br />Regulation/Code <br />Violation Description <br />Inspection Report Action <br />Inspection <br />Report Item It <br />Violation Class <br />item <br />301 <br />CCR 6626531 <br />FACILITY NOT MAINTAINED TO MINIMIZE THE RELEASE OF A HAZARDOUS WASTE <br />Class II <br />_..v ... _.............. ........ _........ .. ..____............... _.... _..... _._._ <br />__.. _.._.................. <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 />According to Mr. Newman, all metal fines are handled as hazardous waste, Facilities shall be maintained <br />iterns listed above and <br />RECE <br />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 staternent and <br />listed <br />statement and supporting <br />supporting documentation explaining how this waste was managed. <br />documentation <br />ENVIRON MENTAL <br />HEALTH DEPARTMENT <br />explaining how this waste <br />was managed, <br />At building 82713, metal fines generated from sheet metals were observed on and around the table vise, belt <br />___.._._..._...... <br />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 <br />See above. <br />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 wo rking area around a machine labeled "Metal <br />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 fess than 100 microns; <br />b <br />See above, <br />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. <br />Violation acknowledged and corrected. <br />Oil and water in the pallet and on the asphalt were cleaned up using Dry -- <br />c <br />See above, <br />sorb. The clean LIP 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. <br />Violation acknowledged and corrected. <br />d <br />See above. <br />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 />RC'RA Large Quantity Hazardous Waste Generator Inspection Report <br />