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5. #21 - Corrected - All hazardous waste containers have been fitted with adequate storage lids 6. #33 - Corrected —All containers have been properly labeled and dated 7. #45 - Corrected — Copy of Contingency Plan attached 8. #49 - Attached is a copy of the NorCal Distribution, Spill Control Procedures training document along with copies of the Universal Waste Policy and Liquid Product Disposal Procedures Summary 9. # 64 — Benito — please get with Curt and let me know on this one# 69 - Daily inspections have begun and documented as of 5/27/09 6/10/09 Inspection: #10 — The inspection report ("Addendum to Hazardous Waste Inspection Report issued May 26, 2009") cited a number of grocery items that were observed in a truck at the Distribution Center, and the inspector assumed that these were waste. These items were in transit from stores to the Distribution Center, where they were to be cross-docked to a truck destined for the Product Recovery Center (PRC). The PRC is a facility operated by a third party that is responsible for disposition of returned products. I Returned products are those that the store no longer intends to sell from its retail shelves to the public. There can be several reasons for taking a particular product off sale from the store, including, but not limited to, label changes, product formulation changes, change in promotions, replacement by different brand, over-stock, and expiration of best-used-by dates. In general, these products are still usable and should not be considered waste. The process of transferring the products from the stores to the PRC is not an act of "discarding" the items, rather it is determining the best disposition for the items. Disposition typically includes liquidation (i.e. selling at reduced price), donation, recycling, and disposal. Of these choices, only recycling and disposal would be considered "discarding". The disposition determination for a particular item occurs at the PRC, not at the store or Distribution Center. When a store removes an item for retail sale, it does not have knowledge of the ultimate disposition, and it is not discarding the item — it is merely transferring it to the PRC. Also note that the store receives monetary credit for every returned item, which shows that these items still have value. The U.S. EPA has issued opinion letters in many instances that discuss the handling of product returns. In one letter (5/16/91), the EPA states, "As I understand your letter, pharmaceutical products may be returned for many reasons, including, among others: 1) an oversupply at the dispenser, 2) expiration of the recommended shelf life, 3) a recall has been initiated by the manufacturer, 4) the product was received as a result of a shipping error, and 5) the product has been damaged. You state that, in general the dispensers of the pharmaceutical products do not know whether the returned products will be reused, reclaimed, sold overseas, or i