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., Maya AUG 1 5 2007 ENVIRONMENT HEALTH RESPONSE TO DEFICIENCY # 20 PERMIT/SERVICES As a result of the SJC Environmental Health Department inspection completed June 28, 2007, we have the following response to deficiency#20, we have made the following changes to our hazardous waste handling process: 1. All 55-gallon drums used for liquid hazardous material generated by the Maintenance department will be kept in containment and tagged with a proper Hazardous Material label indicating what is in the barrel and the start date of the accumulation. This part of the program was put back into compliance on 6/29/07. 2. The secondary containment used to catch the remainder of the oil after compressor cores have been drilled out has been cleaned and will no longer be used in this manner. Compressor cores will be drained into a 55-gallon drum surrounded by a secondary containment. This was done on 6/29/07. 3. The used batteries were disposed of properly by sending them to NorCal Batteries on 6/29/07. In the future all batteries shall be put in a 55-gallon drum surrounded by a secondary containment and labeled with a Hazardous Material label indicating the barrel contents and the accumulation start date. Maintenance also met with Materials Management on 7/3/07 and discussed with them the need for applying the Hazardous Material labels to the chemicals dropped off by the Lab and Histology. They indicated that they would make sure the labels were applied and the contents and accumulation start date written on the labels. Maintenance will follow up to see that the Medical Center stays in compliance. The Lab uses labeled 2-gallon containers to transport waste from the Lab to the hazardous material storage site. At the site, the containers are placed in flammable cabinets and empty containers are taken back to the Lab. Materials Management personnel who have been trained to gear up for chemical transfer will pour the contents of the 2-gallon containers into labeled 55-gallon drums that are in flammable cabinets. The hazardous waste hauler will then take the 55- gallon drum when appropriate and replace it with an empty drum. A single binder has been established to receive documentation as to the accumulation and transportation of hazardous materials generated by the Maintenance department operations. This binder includes batteries, fluorescent tubes, waste oil, used oil and compressor cores. It will be kept in the Maintenance office.