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CONFIDENTIAL <br /> BIC <br /> Head Quarters-4900 E Dublin Granville Rd <br /> Columbus, OH 43081 <br /> LOTS Region 6-19331 Soledad Canyon Road <br /> Canyon Country, CA 91351 <br /> Observation:#109 CCR 66262.23(a)(4)Failed to send generator manifest copies to DTSC <br /> within 30 days. <br /> In response to the above discrepancy, copies of manifests 002185121PSC (4/1/19), 002185123PSC <br /> (4/1/19), 002121941PSC (2/8/19), 002121938PSC (2/8/19), 002002324PSC (10/16/18) have been <br /> mailed to the DTSC. <br /> Observation:#110 CCR 66262.40(a)Failed to keep signed copy of manifests from the <br /> designated facility for three years. <br /> AND <br /> Observation:#111 CCR 66262.42(a)(c)(d)Failed to comply with uniform hazardous waste <br /> manifest exception requirements. <br /> Contrary to the inspection report, signed copies of all manifests were retained at Big Lots corporate <br /> headquarters and were readily available for production and inspection. As the regulations do not <br /> specify where the manifests must be kept, Big Lots Hazardous Waste Management Program (in <br /> consultation with outside counsel and the relevant California District Attorneys) utilizes centralized <br /> data management at its corporate headquarters for efficient and reliable storage of the manifests. As <br /> such, copies of manifests referenced as missing in the inspection report on 7.15.2019 were available at <br /> the time of the inspection. In response to the inspection report, copies of 3 years' worth of manifests <br /> were mailed to the DTSC Report Repository on 8.9.2019 and are attached with this letter (see attached <br /> copies of manifests referenced in inspection report). <br /> Observation:#605 CCR 66262.34(f) Failed to completely label containers or portable tanks of <br /> hazardous waste. <br /> In response to the above observation, store leadership immediately corrected the labeling on all <br /> hazardous waste totes and processed bags as directed by the inspector. Store leadership was <br /> retrained on all hazardous waste program labeling and container management requirements. <br /> We welcome the opportunity to discuss our responses in this letter at your convenience. If you have <br /> any questions or require additional information, please contact the undersigned directly. <br />