Page 358 - Beyond Decommissioning

334 Beyond Decommissioning

alarm panels so they could be accessed and filled in by any trained facility person
responding to a tank alarm. They were not maintained in a locked area to ensure avail-
ability to a variety of personnel at all times. The logbooks also are inspected by the
Livermore-Pleasanton Fire Department inspectors and must be onsite and complete
when requested. Otherwise, this could result in a violation of 22 CCR 66265.195
and 23 CCR Div. 3 Chapter 16 (Underground Storage Tank Regulations).
Personnel performing the clean-up operations were not informed that these log-
books were in use and needed to remain in place. Facility personnel responsible
for the logbooks were not available to provide oversight during that day’s clean-up
operations. The logbooks also had no labels or markings indicating that they were
records or providing a point of contact for disposition.
Because these logs are environmental records, their retention is reflected in LLNL
Records Retention Schedule 10, Item 10-00-033 (LLNL is to retain them for 75years).
Accidental or intentional disposal of these records before the end of the retention
period could result in a violation of 22 CCR 66265.195 and 23 CCR Div. 3
Chapter 16 (Underground Storage Tank Regulations).
Lessons learned: Personnel who create records, as defined by federal, state, or local
regulations or contract requirements, must ensure that they are managed and appro-
priately protected as long as required for use and retention.

1. Consider labeling records in a manner that allows all personnel to
– easily identify them as records and
– find the custodian (e.g., identify by function or position instead of a named individual).
2. Place records in a safe designated area relevant to the work and equipment documented in the
records.

7.14.7 Communication of changes in regulatory requirements,
Oak Ridge Site, United States [US Department of Energy,
lessons learned data base #: Y-2002-OR-BJCPAD-0501
(available upon DOE authorization)]

Problem encountered: Prior to initiation of environmental sampling in support of a
CERCLA remedial action, a readiness assessment was conducted. During the assess-
ment, it was determined materials and samples generated by the activity would not be
managed as Resource Conservation and Recovery Act (RCRA) hazardous waste since
existing data indicated RCRA constituent(s) were not present above RCRA character-
istic (i.e., hazardous) levels.
While the environmental sampling field activities were ongoing, a detailed process
knowledge review on historic waste discharges at the site was conducted to support the
development of the decision documents for the CERCLA remediation process.
A white paper document was issued to the DOE and regulatory agencies which con-
cluded that RCRA listed wastes have, more likely than not, been discharged to the site
during past operations. This conclusion changed the status of waste generated at the
site to RCRA hazardous (U- and F-listed), which meant that all waste generated must
be managed as a RCRA hazardous waste. The Sample Management Organization and