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Lawrence Livermore National Laboratory <br />LLLI <br />Environmenta6 �tfQn,DgTrtment <br />Septe&Ur24 P9N <br />Mr. Steven C. Shih E PERONMENT HLALTH <br />Senior Registered Environmental Health Specialist MITiSERVICES <br />Environmental Health Department <br />San Joaquin County <br />304 East Weber Avenue, Third Floor <br />Stockton, CA 95292-2708 <br />SUBJECT: Response to the August 2004 Hazardous Waste Violations Issued by <br />San Joaquin County, Site 300 (EPA ID. No. CA2890090009) <br />Lawrence Livermore National Laboratory (LLNL) <br />Dear Mr. Shih <br />This letter is submitted as a response to violations issued by the San Joaquin County <br />Environmental Health Department during the hazardous waste generator area <br />inspection of Lawrence Livermore National Laboratory (LLNL) Site 300 that was <br />conducted on August 3, 2004. The inspection report is included with this letter as <br />Attachment 1. <br />LLNL responses follow the violations, which are paraphrased from the inspection <br />report. <br />Violation 1: #21. One bucket of crushed filters without a lid is located at Building 875 <br />[heavy equipment maintenance]. Immediately provide a lid to this hazardous waste <br />container. (#21 refers to the storage regulation on page 2 of 5 on the inspection report.) <br />Response: The container ("bucket") will only be used to transfer crushed filters from <br />the filter crushing unit to the satellite accumulation area container, which has a tight <br />fitting lid. Crushed filters will not be stored in the bucket; therefore, the bucket is not <br />required to have a lid pursuant to 22 CCR 66265.173. <br />Violation 2: #23. Building 879 [automotive fleet maintenance] is not handling fuel <br />filters as hazardous waste. Fuel filters are hazardous waste. Immediately handle fuel <br />filter as hazardous and dispose through the manifest system. <br />(#23 refers to the manifest regulation of page 2 of 5 of the inspection report.) <br />Response: All gas and diesel vehicle fuel filters, including gas and diesel dispenser fuel <br />filters are now managed as hazardous waste in accordance with generator area <br />regulations as well as hazardous waste transportation requirements, which includes <br />cradle -to -grave tracking with the Uniform Hazardous Waste Manifest. <br />Violation 3: #88. Building 872 Paint Shop. Employee Stephen Smith was not current <br />with respect to hazardous waste generator training. <br />(#88 refers to "other" violations. However, the applicable regulation is 22 CCR <br />66265.16 which is referenced at 22 CCR 66262.34 (a)(1)(c)(4)). <br />An Equal Opportunity Employer • University of California • P.O. Box 808, L-626, Livermore, California 94551 <br />(925) 422-3985 — Fax (925) 423-9365 <br />PRA04-074 <br />