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i <br />Lawrence Livern.ire National Laboratory <br />Subject: Response to the Two Hazardous Waste Violations From the 2010 CUPA <br />Inspection Issued by San Joaquin County Environmental Health <br />Department to Lawrence Livermore National Laboratory, Site 300 EPA <br />ID. No. CA2890090002 <br />Dear Ms. Henry: <br />This letter is submitted in response to two violations issued by the San Joaquin County <br />Environmental Health Department to Lawrence Livermore National Laboratory (LLNL) Site 300 <br />during the Certified Unified Program Agency (CUPA) hazardous waste generator inspection on <br />March 31, 2010. <br />The March 31, 2010 San Joaquin County Hazardous Waste Program Inspection Report is <br />included with this letter as Attachment 1. LLNL's response appears after each violation, which <br />is re -typed from the inspection report. <br />Violation #1: <br />Preparedness, #15, CCR 662652.33. Failed to maintain all communication or alarm systems, <br />spill control, or decon equipment. (#15 refers to the violation number on the Hazardous Waste <br />Program Inspection Report.) <br />At the time of inspection, anti freeze [was] seen in the spill containment in B-875 Heavy <br />Equipment Maintenance. All facility spill control equipment shall be tested and maintained as <br />necessary to assure its proper operation in time of [an] emergency. Immediately remove this <br />liquid, handle per Title 22 HW and begin maintaining spill equipment in such a manner to <br />assure its proper operation in time of [an] emergency. <br />Response: <br />The anti -freeze was removed from the secondary containment pallet immediately following the <br />inspection on March 31, 2010. The anti -freeze and wipes used to clean the pallet were managed <br />as hazardous waste. <br />Recycle <br />PRAD10-096/EPD:Al10-103 — BS/ST:jh 7600-61230 <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 />April 26, 2010 <br />M s. Michelle Henry <br />U ll <br />Senior Registered Environmental Health Specialist <br />Environmental Health Department, Unit III - CUPA <br />San Joaquin County <br />600 East Main Street <br />APR 2 g 2010 <br />ENVIRONMENT <br />PERMIT/SENAGE3 <br />Stockton, CA 95202 <br />Subject: Response to the Two Hazardous Waste Violations From the 2010 CUPA <br />Inspection Issued by San Joaquin County Environmental Health <br />Department to Lawrence Livermore National Laboratory, Site 300 EPA <br />ID. No. CA2890090002 <br />Dear Ms. Henry: <br />This letter is submitted in response to two violations issued by the San Joaquin County <br />Environmental Health Department to Lawrence Livermore National Laboratory (LLNL) Site 300 <br />during the Certified Unified Program Agency (CUPA) hazardous waste generator inspection on <br />March 31, 2010. <br />The March 31, 2010 San Joaquin County Hazardous Waste Program Inspection Report is <br />included with this letter as Attachment 1. LLNL's response appears after each violation, which <br />is re -typed from the inspection report. <br />Violation #1: <br />Preparedness, #15, CCR 662652.33. Failed to maintain all communication or alarm systems, <br />spill control, or decon equipment. (#15 refers to the violation number on the Hazardous Waste <br />Program Inspection Report.) <br />At the time of inspection, anti freeze [was] seen in the spill containment in B-875 Heavy <br />Equipment Maintenance. All facility spill control equipment shall be tested and maintained as <br />necessary to assure its proper operation in time of [an] emergency. Immediately remove this <br />liquid, handle per Title 22 HW and begin maintaining spill equipment in such a manner to <br />assure its proper operation in time of [an] emergency. <br />Response: <br />The anti -freeze was removed from the secondary containment pallet immediately following the <br />inspection on March 31, 2010. The anti -freeze and wipes used to clean the pallet were managed <br />as hazardous waste. <br />Recycle <br />PRAD10-096/EPD:Al10-103 — BS/ST:jh 7600-61230 <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 />