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PRA04-074 <br />September 23, 2004 <br />Mr. Steven C. Shih <br />Subject: Response to the August 2004 Hazardous Waste Violations Issued <br />by San Joaquin County, Site 300 (EPA ID. No. CA2890090009) <br />Lawrence Livermore National Laboratory (LLNL) <br />Response: Stephen Smith completed the web -based hazardous waste generator <br />refresher training class immediately after the training deficiency was identified. A copy <br />of the course completion record is included as Attachment 2. <br />The following issue was identified as an issue, which was corrected by San Joaquin <br />County: LLNL Site 300 was identified as a small quantity hazardous waste generator <br />based on the County's records; however, the state hazardous waste manifest database <br />indicates Site 300 is a medium quantity generator and therefore subject to higher fees. <br />Resolution: San Joaquin County changed the facility status from small to medium in <br />their database. San Joaquin County issued an invoice to LLNL for $1,816.00, which <br />was paid by check on August 20, 2004 included as Attachment 3. <br />During the inspection, photos of the Building 872 Paint Shop solvent recycler and paint <br />gun cleaner were requested and are provided in Attachment 4. <br />The total amount of solvent recycled at Building 872 has never exceeded 78 kg/ month <br />based on a review of recycling records over the past three years. Therefore, the <br />"Recyclable Materials Report For Excluded Or Exempted Materials Only" is not <br />required to be submitted at this time. Mineral spirits and lacquer thinner are typical <br />solvents recycled in the unit. <br />The completed "CERTIFICATION OF RETURN TO COMPLIANCE" is included as <br />Attachment 5. <br />Please contact Sav Mancieri, Permits and Regulatory Affairs Group Leader at (925) <br />422-6920 if you have any questions. <br />Sincerely, <br />Ellen Raber <br />Department Head <br />Environmental Protection Department <br />Attachments: <br />1. Inspection report dated August 2, 2004 <br />2. Proof of course completion for Stephen Smith <br />3. Proof of payment <br />4. Building 872 solvent recycler and paint gun washer photos (2) <br />5. Certification of Return to Compliance <br />ER/ST:jn <br />cc: June Schwabe NNSA/LSO <br />Wen Kao NNSA / LSO <br />