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Ms. Michelle Henry, San Joa,,-.n County April 26, 2010 Response to the Two Hazardous Waste Violations From the 2010 CUPA Page 2 Inspection Issued by San Joaquin County Environmental Health Department to LLNL, Site 300 10111 APR 2 S 2010 Violation #2: 1941TISERVICES MENT HEALTH Universal Waste, 985, CCR 66273.39. Failed to keep records of each shipment of uni waste according to this section. At the time of inspection, shipping records for alkaline batteries sent to the consolidation site in Livermore could not be provided. Shipping records must be maintained for each shipment of universal waste. Begin this practice immediately. Response: Universal Waste battery shipments from LLNL Site 300 to LLNL Site 200 in Livermore were immediately discontinued on April 1, 2010. LLNL Site 300 has established a process, effective April 20, 2010, to inventory Universal Waste batteries that are transported to LLNL Site 200 for consolidation in compliance with 22 CCR 66273.39, Tracking Universal Waste Shipments. The inventory (Attachment 2) records the following information: Accumulation Start Date, Shipment Date, Weight (lbs) and Bill of Lading number. Compliance Requirement: Complete and submit a copy of the RETURN TO COMPLIANCE CERTIFICATION, found on the back of page I of this inspection report, w/ a statement addressing how each of the above listed violations have been corrected to this office w/in 30 days (5-1-10). Response: The completed RETURN TO COMPLIANCE CERTIFICATION is included with this submittal as Attachment 3. Please contact Sav Mancieri, Division Leader, Permits and Regulatory Affairs, at (925) 422-6920 if you have any questions. Sincerely, Bruce Schultz Acting Department Head Environmental Protection Department Attachments: 1. San Joaquin County Hazardous Waste Program Inspection Report 2. Universal Waste Battery Shipment Log 3. Return to Compliance Certification PRAD10-096/EPD:AI10-103 - BS/ST:jh