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i_ <br />Lawrence Livermore National Laboratory <br />N Xr <br />Environmental Protection Department <br />Ms. Patricia Barni, Section Chief <br />Statewide Compliance Division <br />Department of Toxic Substances Control <br />700 Heinz Avenue, Suite 200 <br />Berkeley, CA 94710-2737 <br />April 28, 2006 <br />Epo/ �DRE0 <br />IAm 1 2006 <br />ENVIER MIj��F1RVICES H <br />P <br />SUBJECT: LLNL Site 300 Response to the Violations Identified in the DTSC <br />March 20, 2006 Inspection Report, EPA ID. No. CA2890090002 <br />Lawrence Livermore National Laboratory (LLNL), Site 300 <br />1107=&MIWOri <br />This letter is submitted in response to the two Class II violations identified in the <br />attached Department of Toxic Substances Control (DTSC) Compliance <br />Evaluation Inspection (CEI) Report. Both violations were issued for the same <br />waste shipment and associated manifesting compliance issue. The inspection <br />report is dated March 20, 2006 and was received by Lawrence Livermore <br />National Laboratory (LLNL) Site 300 on April 5, 2006. The violation response <br />date was extended from seven days after the March 20, 2006 letter date, which <br />would have been March 27, to April 28, 2006 by Essam Eissa of your staff. <br />The two Class H violations identified in the inspection report stemmed from <br />Safety Kleen's rejection of the waste due to the Proper Shipping Name (PSN) <br />entered by LLNL personnel in field 11a and llb on manifest #23440668 <br />(attached). Safety Meen personnel requested a PSN which was not authorized <br />by regulation. The PSN was entered and initialed in field llc by one Safety <br />Kleen employee, but later rejected by another Safety Kleen employee. <br />LLNL attempted to resolve the issue with Safety Kleen for nine days without <br />success. On the tenth day, LLNL exercised control over the situation by shipping <br />the seven containers to Clean Harbors. The seven containers had been off-loaded <br />from the Safety Meen vehicle and were placed on secondary containment pallets <br />on Safety Kleen facility property, without signing the manifest. <br />LLNL used a new manifest (#23440682, attached) free of errors and strike <br />through marks to ship the waste to Clean Harbors. Although non-compliant <br />with HSC 25160.6 (a)(1) and 25189 (a), LLNL complied with the substantive <br />waste transport and disposal requirements by: <br />1. Expediting the shipment of waste from Safety Kleen to Clean Harbors <br />after discussions with Safety Kleen personnel failed to resolve the issue. <br />An Equal Opportunity Employer • University of California • P.O. Box 808, L-668, Livermore, California 94551 <br />(925) 422-0757 - Fax (925) 423-9365 <br />PRA06-038 <br />