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rCVSHeaIt h Nicole Wilkinson <br /> Director Corporate Environmental <br /> One CVS Drive — MC2340 <br /> Woonsocket, RI 02895 <br /> p 401 -7704132 <br /> c 401 -256-7615 <br /> f 401 -652- 1901 <br /> nicole .wilkinson@cvshealth . com <br /> October 12 , 2018 <br /> VIA UPS RECEIVED <br /> Ms . Elianna Florido OCT 15 2018 <br /> San Joaquin County <br /> 1868 East Hazelton Avenue ENVIRONMENTAL HEALTH <br /> Stockton, CA 95205 - 6232 DEPARTNIENT <br /> (209) 468 - 0343 <br /> Re : CVS Pharmacy , Inc . , Store 9261 , Small Quantity Waste Generator Report <br /> Received on September 13 , 2018 . <br /> Dear Ms . Florido : <br /> CVS Pharmacy, Inc . (CVS ) is in receipt of your RCRA Small Quantity Hazardous Waste <br /> Generator Inspection Report (Report) received on September 13 , 2018 . This letter addresses your <br /> concerns noted in the above-referenced Report . <br /> Hazardous Waste Training <br /> Your item # 106 relates to completion of training on hazardous waste management . We <br /> understand that during your inspection you observed inconsistencies related to damages <br /> processing and onsite management of hazardous waste items . Below, we address each area of <br /> concern . <br /> Front Store Unsalable Items Processing <br /> As background , CVS ' s California hazardous waste management program requires front <br /> store retail colleagues to process unsaleable items (often referred to "damages" at the store level) <br /> daily . To determine whether an item is a waste , each item must be scanned using the RF Unit . <br /> Based on the condition of the item and RF Unit coding, which is programmed to identify items <br /> that are hazardous when they become wastes , disposition direction is provided to the store <br /> colleague . Based upon the disposition direction, items could be sent to a reverse logistics partner <br /> for donation/liquidation, placed into the dumpster (if determined to be non-hazardous/non- <br /> regulated waste) , or placed into the appropriate hazardous waste tote (this process is described in <br /> further detail below) . Unsaleable items awaiting processing have not been determined to be a <br /> waste and may be eligible for resale, liquidation or donation . Because unprocessed items could <br /> be returned to the sale floor, liquidated, or donated , they are not waste and thus also not a <br /> hazardous waste (and therefore not stored in labeled hazardous waste containers) . <br /> CVS pharmacy / caremark / minute clinic / specialty <br />