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Violation#20 and 49, 66262.34 CCR and 66265.17 CCR These violations are in regards to labeling of hazardous waste and the management of incompatible hazardous wastes. Target's response to these violations concerning the items found in reverse logistics area during the March 10, 2008, routine hazardous waste inspection was that these items were not waste and designated for donation to charity. When asked about the bagged items found in the blue totes, which included several damaged aerosol cans and leaking containers, Mr. Vargas stated that these items were hazardous wastes to be disposed of. Provide an explanation as to how these items are to be labeled and segregated based on compatibility. Target also states in the April 10, 2008 response that the reverse logistics area is not a hazardous waste storage area. When asked about how a hazardous material spill is cleaned up, Mr. Vargas stated the procedures provided by Alert One inside the spill stations are followed, and the bagged waste generated from the spill is placed in the blue totes in the reverse logistics area. Please provide a detailed explanation as to how and where this type of waste is stored and disposed of. Violation#34, 66268.7(a) CCR A land disposal restriction notification form was not found with manifest #003302542JJK. A copy of the form was submitted with the April 10, 2008 response. This violation has been corrected. Violation#49, 66265.16 CCR Training records pertaining to the management of hazardous waste were not available for review during the March 10, 2008, routine hazardous waste inspection, and training did not appear to be sufficient. Mr. Vargas, a member of management, did not know the basic management procedures of hazardous waste in the event of a spill. Target was asked to provide copies of hazardous waste training records to the EHD for review on the March 10, 2008 routine hazardous waste inspection report and has not done so. Please submit and ensure employees are trained in the management of hazardous waste. Violation#76, 66273.14 CCR A microwave was found on a pallet in an area designated for the Central Return Center (CRC) without a label of"Universal Waste — Electronic Device(s)" or UW — Electronic Device(s)" on the unit itself, the pallet, or designated area. Target's response is that "a sign is posted in this area with the wording `UW — electronic devices."' A photo taken by the EHD on March 10, 2008, of the CRC area does not show this. Violation#77, 66273.15 CCR A box of used fluorescent tubes was found without an accumulation start date. Target responded by marking a start date on the box. This violation has been corrected. Violation#90, 66262.34(d)(2) CCR A modified contingency plan and emergency coordinator information was not found on site. Target has completed the provided form, submitted a copy to the EHD, and states