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■ Lawrence Livermore National Laboratory L December 4, 2015 Mr. Peter Lombardi, Ms. Stacy Rivera and Ms. Cindy Vo R CE'VI=D San Joaquin County Environmental Health Department DEC U 1868 E. Hazelton Avenue 2015 Stockton, CA 95205 ENVIRONMENTAL HEALTH Subject: LLNL Site 300 Response to the Hazardous Materials Program, Aboveground RMIT/SERVICES Petroletmi Storage Act and RCRA Large Quantity Hazardous Waste Generator Inspection Reports issued by San Joaquin County, Environmental Health Department, Certified Unified Program Agency (CUPA) EPA ID # CA2890090002 Dear Mr. Lombardi, Ms. Rivera and Ms.Vo: This letter is being submitted in response to violations issued in the Hazardous Materials Program (HMP), Aboveground Petroleum Storage Act (APSA) and RCRA Large Quantity Hazardous Waste (HW) Generator inspection reports (Attachments 1, 2 and 3, respectively). All of the HMP, APSA and HW violations were transferred to three spreadsheets (Attachments 4, 5 and 6, respectively), in order to track the violation status, corrective action verification, and violation response. Please refer to Attachments 4, 5 and 6 for violation -specific information. Attachments 7-11 provide additional information. LLNL Site 300 proposes to submit the next violation status report (with updated Attachments 4, 5 and 6) in six weeks (i.e., no later than January 15, 2016) and monthly thereafter until all violations have been corrected. LLNL Site 300 will include the signed "Return to Compliance Certification" with the final submittal for each program (i.e., HMP, APSA, and HW). LLNL Site 300 anticipates the remaining HMP violation will be corrected during the first quarter of 2016. The seven APSA violations will be corrected no later than six months from the date the CUPA violation report was received by LLNL Site 300. The proposed due date is May 4, 2016. All of the hazardous waste violations, except the 17 disputed and one contingency plan violation have been corrected. Details of the 17 disputed violations are provided in the hazardous waste violation tracking spreadsheet (Attachment 6). The contingency plan will be corrected by the January 15, 2016 submittal. The inspection report states that an underground storage tank was found at Corp Yard by M80 and a second underground tank was found at Corp yard north of 865 and requests that a statement be submitted on the history of the usage of the tanks, where they came from and how long they have been removed. An extensive search for records related to the tank discovered at the M80 Corp Yard yielded no conclusive evidence as to the history of the tank, where it came from or how long it has been removed. The tank will be inspected and any contents sampled, Rocr ESH-EFA-WP-15-13432 FA/ST:jk 7WO412 0 An Equal Opportunity Employer • Lawrence Livermore National Security, LLC • Operated for the US Department of Energy P.O Box BOB Livermore, California 94551-0808 • Telephone (925) 422-1100 • http://www lint gov