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05/20/2010 THU 14: 01 FAX 612 696 5163 0003/010 Facility Certification of Return to Compliance Target Store T0738 2 Logistics are also available to assist team members in determining the appropriate ESIN4 bin for the product. Violation 427 66265.173(a)CCR All hazardous waste containers in the ESIM Storage Area are kept closed at all times unless a team member is actively adding or removing items. As explained above,the sorting cart is not a"container" for waste accumulation. Target incorporates by reference its explanation in the"near compactor"section. Because the sorting cart is not a"container"for waste accumulation under the regulations,the requirement that the cart be"kept closed"does not apply. Violation#50 66262.34(d)CCR Pharmacy ha7ardous waste is considered satellite accumulation due to the slow rate of generation because the accumulation amount remains under 55 gallons and is not held onsite for more than one year from the initial date of accumulation. 22 C.C.R_ 66262.34(e)(1)(B). This process is under the direct supervision of the pharmacy team. Violation#59 662§2.23(a)(4)CCR Generator manifest copies listed in the inspection report have been submitted to the DISC. Enclosed please find mailing receipt. Violation#60 66262.40(a)CCR Signed copies of manifests will be maintained onsite for three years. Violation#62 25123.3(h)(2) HSC Target works with Heritage Environmental Services to ensure that manifests are properly maintained and submitted to the DISC. Violation#84 66273.35 CCR Waste alkaline batteries were removed from the RBRC bin and placed in an ESIM bin Violation#85 66273.39 CCR Copies of shipment records for universal waste, RBRC box, are enclosed. Violation#999 118215 HSC Health and Safety Code section 118215 applies to"medical waste,"which differs from the definition provided for"waste pharmaceuticals"in the inspection report_ Genco Pharmaceutical Services("GPS") has developed a web-based tool that allows the pharmacist to input the National Drug Code("NDC")of the pharmaceutical that needs to be returned(e.g.,damaged, expired, returned, or contaminated product) to determine if it can be returned or if it meets the designation of a hazardous or medical waste. If the pharmaceutical meets the definition of a hazardous or medical waste,the pharmacist is prompted to place the pharmaceutical in a satellite waste container located in the pharmacy. The program does not allow the pharmacist to execute the return process to GPS if the pharmaceutical is a hazardous or medical waste. Target utilizes Heritage Environmental Services to transport and incinerate hazardous or medical wastes. I would like to follow-up with a telephone call or meeting with you and your supervisor to discuss these issues and make sure Target fully complies with all aspects of the laws and regulations referenced in this letter_ We take your inspection report and directives seriously and wish to work with the County to resolve this matter. Please contact me at(612)6964035 or by email at Steve.Musser@Target.com. Thank you. Corporate Risk and Responsibility, 1000 Nicollet Mall, TPN-1132, Minneapolis, MN 55403