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CONFIDENTIAL BIC Head Quarters-4900 E Dublin Granville Rd Columbus, OH 43081 LOTS Region 6-19331 Soledad Canyon Road Canyon Country, CA 91351 August 16th, 2019 Ms. Elianna Florido, REHS San Joaquin County Environmental Health Department Registered Environmental Health Specialist RE: Haz. Waste Generator Inspection Report 7.15.2019 Dear Ms. Elianna Florido, Big Lots takes its regulatory responsibility seriously, and it is our policy and practice to maintain compliance with all applicable laws and regulations. As observed during the inspection, we have a thorough and robust hazardous waste program that is appropriate for the scope and scale of the waste produced by a retail operation carrying an assortment of household consumer products. While we do not agree that all the observations and recommendations from the inspection constitute violations, let alone multiple violations from the same observation, we have taken these observations seriously and acted to improve our compliance program. Moreover, on August 121h, 2019, an independent member of our Asset Protection team verified on-site that the store team had made all the corrections set forth below. With respect to the specific points made during your most recent inspection at Stockton 4105, Big Lots responds as follows: Observation:#103 CCR 66262.40(c)Failed to retain hazardous waste determination including waste analysis on site for 3 years. This citation contains an incomplete quote of section 66262.40(c), which states: "A generator shall keep records of any test results, waste analyses, or other determinations made in accordance with section 66262.11 for at least three years from the date that the waste was last sent to on-site or offsite treatment, storage, or disposal." Section 26262.11, in turn, provides that the generator may make a waste determination by "applying knowledge of the hazard characteristic of the waste in light of the materials or the processes used, and the characteristics set forth in article 3 of chapter 11 of this division." Contrary to the report, the basis for hazardous waste determinations—our knowledge of the hazard characteristics-was available at the time of the inspection. The tools used in all California Big Lots' stores to make hazardous waste determinations, namely the Underwriters Laboratories WERCSmart iPod application and Big Lots Hazardous Waste Program poster, were available at this store.