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Lawrence Liverr,. ,re National Laboratory <br />Ll <br />September 18, 2008 <br />Ms. Michelle Henry <br />Senior Registered Environmental Health Specialist <br />Environmental Health Department, Unit III <br />San Joaquin County <br />600 East Main Street <br />Stockton, CA 95202 <br />Subject: Response to the Hazardous Waste Violation Issued by San Joaquin County <br />Environmental Health Department to Lawrence Livermore National <br />Laboratory, Site 300 EPA ID No. CA2890090002 <br />Dear Ms. Henry: <br />This letter is submitted in response to a violation issued by the San Joaquin County <br />Environmental Health Department during the hazardous waste generator inspection of LLNL <br />Site 300 on August 18, 2008. <br />The August 18, 2008 hazardous waste generator inspection report is included with this letter as <br />Attachment 1. LLNL's response appears after the violation, which is re -typed from the <br />inspection report. <br />Violation: <br />#10. 66262.11. Failed to determine if a waste is a hazardous waste. (#10 refers to the violation <br />number on the Hazardous Waste Generator Inspection Report.) <br />At the time of the inspection, a [5] gallon container was seen approximately % full of "water and <br />oil from compressor" per Dave Arnold. This waste has been analyzed [by] LLNL for hazardous <br />waste constituents, Title 22 [Division 4.5, Chapter 11, Identification and Listing of Hazardous <br />Waste]. A toxicity analysis was run on the analytical profile from 1999, but not on this analysis <br />[in 2008]. In order to deem a waste as non -hazardous, a full set of analyticals based on Title 22 <br />Hazardous Waste Characteristics must be run. [LLNL shall] immediately make a hazardous <br />waste determination (based on Title 22 [Division 4.5, Chapter 11, Identification and Listing of <br />Hazardous Waste]) or begin handling as hazardous waste. <br />Complete and submit a copy of the RETURN TO COMPLIANCE CERTIFICATION, found on the <br />back of page I of this inspection report, w/ a statement addressing how the above noted violation <br />has or will be corrected to this office w/in 30 days (9-18-08). Supply all necessary or requested <br />documentation. <br />Requested copy of analytical data run on the above mentioned waste. <br />PRAD08:098:CSJ:ST:rtd R—leb <br />700001230 <br />An Equal Opportunity Employer • Lawrence Livermore National Security, LLC • Operated for the US Department of Energy <br />P.O. Box 808 Livermore, California 94551-0808 • Telephone (925) 422-1100 • http://www.11nl.gov <br />