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0 • <br /> ROGERS JOSEPH O'DONNELL V~.rjo.com <br /> Michelle Henry <br /> July 3, 2012 <br /> Page 2 <br /> Acidic, (4) Corrosive Basic, (5) Universal Waste—Non-Aerosol, (6) P-rated/Toxic <br /> Pharmaceutical, or(7) Pharmaceutical Products —Toxic/Ignitable. Hazardous waste totes are <br /> kept closed at all times, unless an item is being added or removed from the tote. Walgreen's <br /> environmental contractor thereafter performs a final review of the classification and <br /> segregation of the hazardous waste within the totes for proper D.O.T. transportation. The <br /> hazardous waste is then transported in accordance with D.O.T. guidelines and is properly <br /> disposed of in a licensed facility. <br /> Walgreen has recently upgraded its Telzon system specifically to assist with <br /> categorization of hazardous waste, and it is currently being pilot tested with a full roll-out in <br /> the next month. The upgraded Telzon system properly categorizes nicotine containing items <br /> to be disposed of as P-rated waste. Waste aerosol cans are properly disposed of in the <br /> Flammable/Aerosol/Toxic waste tote. All other waste items have been properly categorized <br /> and placed in the appropriate bin based on the waste items' hazardous characteristic(s). Any <br /> concerns raised in the Report were addressed, and Walgreen store #10482 is in compliance. <br /> 3. Weekly Inspections (Violation #405) <br /> Walgreen disagrees that it has a weekly inspection requirement, since <br /> California regulations that require weekly inspections either do not apply or rely on federal <br /> CESQG regulations that exclude applicability to Walgreen. Notwithstanding the parties' <br /> positions, this disagreement is academic in light of Walgreen store 410482 conducting <br /> voluntary weekly inspections. A copy of a weekly inspection form is enclosed herein, and <br /> Walgreen store #10482 is in compliance. <br /> 4. Labeling(Violation #605, 701) <br /> Walgreen's hazardous waste program requires each hazardous waste tote to be <br /> labeled with: (1) the words "Hazardous Waste;" (2)the accumulation start date; (3) the <br /> composition, physical state, and hazardous properties; and (4)the generator's name and <br /> address. Hazardous waste totes have had appropriate labels affixed, with all the necessary <br /> information accurately included. Any concerns raised in the Report were addressed, and <br /> Walgreen store #10482 is in compliance. <br /> 5. Emergency Coordinator/Contingency Plan (Violation #703) <br /> A copy of the emergency response plan has been posted in an appropriate <br /> location near the telephone next to the hazardous waste area, and an emergency coordinator <br /> is on-site or on-call at all times. <br /> 318210.1 <br /> A Professional Law Corporation <br />