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L3 <br />Mr. Willy Ng <br />Senior Registered Environmental <br />Environmental Health Department <br />San Joaquin County <br />600 East Main Street <br />Stockton, CA 95202 <br />Lawrence Livermore National Laboratory <br />July 25, 2007 <br />Health Specialist <br />Subject: Response to the Hazardous Waste Violation Issued by San Joaquin <br />County Environmental Health Department to Lawrence Livermore <br />National Laboratory, Site 300 EPA ID. No. CA2890090002 <br />Dear Mr. Ng: <br />This letter is submitted in response to violation issued by the San Joaquin County <br />Environmental Health Department during the hazardous waste generator inspection of <br />LLNL Site 300 on June 25, 2007. <br />The June 25, 2007 inspection report is included with this letter as Attachment 1. <br />LLNL's response appears after the violation, which was re -typed from the inspection <br />report. <br />Violation: <br />Metal grindings containing fines are being disposed of as industrial waste at the <br />Machine Shop [Building 875]. No waste was found at this location at the time of the <br />inspection, but according to Dave Arnold, this was the routine procedure. Immediately <br />stop this procedure and make a hazardous waste determination prior to the next <br />disposal. Submit a copy of the lab results to this office when available, if sampled. <br />Alternatively, handle as hazardous waste. <br />Response: <br />LLNL Site 300 will manage metal grinding waste as "hazardous waste" if the waste <br />meets the regulatory definition of "hazardous waste" pursuant to Chapter 11, <br />Identification and Listing of Hazardous Waste, Division 4.5, Environmental Health <br />Standards for the Management of Hazardous waste, Title 22, California Code of <br />Regulations (22 CCR Division 4.5, Chapter 11), and in accordance with 22 CCR <br />Division 4.5, Chapter 12, Standards Applicable to Generators of Hazardous Waste. <br />An Equal Opportunity Employer • University of California • P.O. Box 808, L-626, Livermore, California 94551 <br />(925) 422-4750 - Fax (925) 423-9365 <br />SG/ST:jh - PRA07-075 <br />