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• . 311 California Street <br /> San Francisco CA 94104 <br /> y 415.956.2828 <br /> ROGERS JOSEPH O'DONNELL 415.956.6457 fax <br /> w .rjo.conn <br /> July 3, 2012 <br /> Michelle Henry <br /> County of San Joaquin <br /> Environmental Health Department <br /> 600 East Main Street <br /> Stockton, CA 95202-3029 <br /> Re: Return to Compliance—Walgreen #10482 <br /> Dear Ms. Henry: <br /> This office represents Walgreen Co. ("Walgreen") and hereby responds to <br /> your November 17, 2011 Hazardous Waste Program Inspection Report (the "Report") with <br /> respect to hazardous waste management issues noted at Walgreen store #10482 in Stockton. <br /> As you may know, Walgreen is identified as a Conditionally Exempt Small Quantity <br /> Generator("CESQG") and addresses your concerns below in that context. As discussed <br /> below, the errors made as stated in the Report have been corrected. <br /> 1. Record Keeping (Violations #122, 125, 705, 812) <br /> Walgreen's hazardous waste manifests are maintained and available for three <br /> years in accordance with applicable state law. Specifically, Walgreen contracts with a third <br /> party environmental contractor, StrongPak-Stericycle, to both manage and transport <br /> hazardous waste, including universal waste, and to ensure proper completion and delivery of <br /> manifests to the Department of Toxic Substances Control ("DTSC"). In addition to prompt <br /> delivery of copies of the manifests to DTSC, these manifests are also maintained <br /> electronically by StrongPak-Stericycle and Walgreen, and the manifests can be accessed by <br /> Walgreen management. TSDF-signed copies of the hazardous waste manifests for the <br /> previous three years are enclosed herein. <br /> 2. Classification and Storage of Waste (Violations #204, 404) <br /> Walgreen utilizes a multi-step process to ensure that incompatible hazardous <br /> waste is stored properly and not errantly comingled. First, Walgreen secures each individual <br /> hazardous waste item in a self-sealed plastic container so that any individual item is <br /> segregated from all other hazardous waste immediately. The plastic container is then placed <br /> in the appropriate hazardous waste tote. Walgreen has revised its labels so that they are <br /> compliant as follows: (1) Flammable/Aerosol/Toxic, (2) Oxidizer/Reactive, (3) Corrosive <br /> 318210.1 <br /> A Professional Law Corporation <br />