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I Lawrence Livermore National Laboratory <br />May 18, 2006 <br />Mr. Willy Ng <br />Senior Registered Environmental Health Specialist <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 Hazardous Waste Violations Issued by San Joaquin <br />County Environmental Health Department to Lawrence Livermore <br />National Laboratory (LLNL), Site 300 EPA ID. No. CA2890090002 <br />Dear Mr. Willy Ng: <br />This letter is submitted in response to two violations issued by the San Joaquin County <br />Environmental Health Department during the hazardous waste generator inspection of <br />Lawrence Livermore National Laboratory (LLNL) Site 300 on April 19, 2006. The initial <br />report, dated April 19, 2006 (without violations) was amended and faxed to LLNL on <br />April 24, 2006 with two violations. Both violations were issued for the same non- <br />compliance issue. <br />The April 24, 2006 inspection report is included with this letter as Attachment 1. LLNL's <br />responses follow the violations, which were re -typed from the inspection report. <br />Violation 1: <br />#10. Metal grindings from brake rotors and drums are being thrown in the trash. Immediately <br />stop this practice and prior to the next disposal, make a determination whether this waste is <br />hazardous or not and handle per Title 22 Hazardous Waste Regulations. <br />(#10 refers to the operations regulation on page 1 of 5 on the inspection report.) <br />Response: <br />The disposal of this waste as municipal solid waste was immediately stopped and <br />sampled on April 24, 2006. The attached Toxicity Characteristic Leaching Procedure <br />(TCLP), Soluble Threshold Limit Concentration (STLC), and Total Threshold Limit <br />Concentration (TTLC) sample results indicate the waste is non -hazardous per 22 CCR <br />Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, <br />Chapter 11, Identification and Listing of Hazardous Waste. <br />An Equal Opportunity Employer • University of California • P.O. Box 808, L-668, Livermore, California 94550 <br />(925)422-0757-Fax(925)423-9365 <br />PRA06-047 <br />