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Mr. Willy Ng, Environmental Health Department May 18, 2006 <br />Response to the Hazardous Waste Violations Issued by San Joaquin Page 2 <br />County Environmental Health Department to Lawrence Livermore <br />National Laboratory (LLNL), Site 300 EPA ID. No. CA2890090002 <br />Violation 2: <br />#39. Metal grindings from brake rotors and drums are not handled as hazardous waste. <br />According to Beverlee Morales, Fleet Maintenance Supervisor, this waste stream was analyzed in <br />the past and that it was shown to be non -hazardous. Records of all waste analyses are required to <br />be kept on site for at least three years from the date that the waste was last sent to treatment or <br />disposal. Submit a copy of the analysis of this waste stream to this office by 05118/06 and ensure <br />that a copy is left onsite. <br />(#39 refers to the manifest regulation of page 1 of 5 of the inspection report.) <br />Response: <br />In reviewing our records we were not able to locate documentation of the prior waste <br />characterization analyses that the manager thought had been done. Waste <br />characterization records, therefore, were not available pursuant to 22 CCR 66262.40, <br />"Recordkeeping," subpart (c), "A generator shall keep records of any test results, waste <br />analyses, or other determinations made in accordance with section 66262.11 for at least <br />three years from the date that the waste was last sent to an on-site or -offsite treatment, <br />storage, or disposal." <br />The attached analyses will be retained at the Site 300 Fleet Management Office for at least <br />three years pursuant to 22 CCR 66262.40 (c). <br />If you have any questions regarding this submittal please contact Sav Mancieri, Group <br />Leader of the Permits and Regulatory Affairs Group at (925) 422-6920. <br />Sincerely, <br />Jam <br />Albert L. Lamarre <br />Acting Department Head <br />Environmental Protection Department <br />Attachments: <br />1. Inspection Report fax date 4/24/06 <br />2. STLC, TTLC, TCLP Analytical Reports <br />3. Certification of Return to Compliance <br />ALL / ST:jh <br />cc: <br />Eissa, E. DTSC Berkeley Office <br />Kao, W NNSA / LSO <br />Schwabe, J. NNSA/LSO <br />