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TARGET <br /> September 4, 2019 <br /> Elianna Florido, REHS RECEIVED BY SJCEHD (EF) ON 9/4/19 <br /> San Joaquin County <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205 <br /> RE: Target Store T0853— Lodi <br /> EPA ID#: CAR000048982 <br /> Dear Ms. Florido, <br /> In order to demonstrate compliance with findings associated with the inspection of Target Store T0853 on <br /> March 8, 2019, Target Corporation provides the following responses to the alleged violations. <br /> #1 Failed to retain hazardous waste determination including analysis on site for 3 years. [CCR <br /> 66262.40(c)1 <br /> Response: Target uses a third party company called the WERCs to classify the hazardous waste <br /> characteristics and chemical compatibility of all products that will be sold at Target stores. The WERCs <br /> uses SDS sheets along with ingredient levels to classify each retail product based on EPA/State waste <br /> identification and chemical compatibility. After the classification is completed, the WERCs assigns a <br /> Target"smart-sort" label designation to each product to ensure proper chemical compatibility during <br /> storage. Target retains the attached waste summary onsite for stores, and the WERCs Portal may be <br /> accessed through Target's workbench to identify the waste characteristics of specific items [Attachment <br /> A]. <br /> #2 Failed to send generator manifest copies to DTSC within 30 days. [CCR 66262.23(a)(4)1 <br /> Response: Target utilizes Clean Harbors as our waste contractor to properly prepare manifest shipments <br /> according to State and Federal regulations. Per this agreement, Clean Harbors submits a copy of each <br /> manifest to the DTSC. Because of inaccuracies in the submitted data, limitations of the hazardous waste <br /> manifest system, and the technical limitations of the database, DTSC cannot guarantee that the data <br /> accurately reflect what was actually transported or produced. Copies of the manifests identified during the <br /> inspection have been resubmitted to the DTSC. <br /> #3 Failed to keep signed copy of manifests from the designated facility for three years. [CCR <br /> 66262.40(a)1 <br /> Response: Target contracts with Clean Harbors to submit final copies of hazardous waste manifests to <br /> upload to Target's Regulatory Document Archive (RDA)within 35 days of accepting waste for shipment. <br /> Target has contacted Clean Harbors to obtain, and correctly upload the final manifest copy to the T0853 <br /> RDA[Attachment B]. <br /> Corporate Compliance&Ethics,33 South 6th Street,CC-3625, Minneapolis,MN 55402 <br />