COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

TARGET. March 25,2009 Michelle Henry,Registered Environmental Health Specialist County of San Joaquin Department of Environmental Health 600 E. Main St. Stockton,CA 95202 Re: Facility Certification of Return to Compliance Target Store T0313: 4707 Pacific Ave,Stockton Dear Ms Henry: This letter is to respond to the inspection conducted at Target Corporation's(Target)above mentioned store(313)January 16,2009. We have a number of concerns we would like to express. First, as you know,we requested a short,reasonable extension of time to provide these responses. The additional time was requested to allow us to complete our investigation and to accurately determine the facts and applicable regulations referenced in your letter. We were surprised and disappointed that our request was denied,and do not understand the basis for your denial. Second,we contacted you in an attempt to discuss some questions we have regarding some of the alleged violations,and you refused to set up a telephone conference. You said that the only way to discuss these issues was in person. As you know, I am located in Minnesota,so it is very difficult for me to travel to California for this in person meeting. As an alternative,we propose setting up an in person meeting with our counsel, Peter Hsiao,who we believe you have met during the last tour provided to your group. Please let me know if this is acceptable and we will schedule the meeting. Third,we are concerned that some of the assertions of violations in your Notice of Violation are based upon interpretations that are not consistent with how those regulations are interpreted by the state Department of Toxic Substances Control or other County environmental agencies. Given our limited time to prepare this response,we may need to have additional dialogue with your office regarding these points. Fourth,we are aware that the San Joaquin District Attorney's Office has been involved in this matter prior to the subject inspection,and that Target has provided notice that it is represented by outside counsel in this matter who has asserted the standard attorney-client privilege for that investigation, including witness interviews. This response is intended to meet your requests to the best of our ability. We expressly assert and reserve without waiver all of Target's rights and defenses in this matter. Target takes compliance with all laws, including the regulations cited in your report,very seriously. We are currently in discussions with respective government agencies to attempt to reach a consensus understanding as to the interpretations of the subject regulations and clarity as to the applicable requirements for our operations. We believe Target stores operate safely, including the store cited in your report. Subject to the above,the following is Target's response to the waste generator inspection report, segregated by the alleged violations identified in your report. Corporate Risk and Responsibility, 1000 Nicollet Mall, TPN-1132, Minneapolis, MN 55403