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Hazardous Waste Program Insp n Report Home Depot Store#1006 waste stream is managed as a hazardous waste with waste codes D001, D005, D007, D008, D035, and 331. No changes to the existing accumulation of this waste stream are being made at this time, 52. Modified contingency plan is not accurate. RESPONSE: The store's emergency contact list has been updated to include the current District Operations Manager as well as the local phone numbers for the police department, fire department, and hospital. A copy of the list is enclosed for your review. 52. Failed to train all employees on waste handling and emergency procedures. RESPONSE: The Home Depot developed and implemented the HHM Program to ensure proper management of hazardous materials and hazardous wastes at its stores. All Store Associates receive initial hazardous waste-related training at the beginning of employment(Class#4265). Other designated Store Associates (i.e. salaried managers, hourly key carrying associates, all department supervisors, and the Return-to-Vendor Associate) receive additional training beyond the orientation class to provide further instruction for additional spill response, storage, and labeling considerations (Class#4266). In addition to the HHM Training Program, The Home Depot has developed and implemented an Annual Safety Training course (Class#4740). This course provides an annual review of HHM topics presented during the initial HHM Program classes. Copies of employee training records for the three classes presented above are enclosed for your review. The concerns outlined in the inspection report for this issue (final manifest retention, hazardous and universal waste containerization, hazardous and universal waste labeling, etc.), are incorporated into the HHM Program. These aspects of the HHM Program have been reviewed with affected store associates to ensure proper execution going forward. 60/62. Failed to keep signed copy for 3 years. Failed to file an exception report. RESPONSE: Copies of TSDF-signed manifests are retained in an online database, which is accessible to all store associates 24 hours per day. The Home Depot's HHM Program requires store associates to download the TSDF-signed manifests from the database and retain copies in the store's HHM Binder for 3 years. This aspect of the HHM Program has been reviewed with affected store associates to ensure copies of the last 3 years' worth of manifests are available at the store and to ensure proper retention going forward. Copies of the 22 manifests listed on the inspection report are enclosed for your review. 79. Failed to store universal waste lamps in a closed container and in a manner that prevents breakage and release to the environment. RESPONSE: The Home Depot's CFL collection program is designed for the recycling of CFLs(not fluorescent tubes)from our household customers only (not agencies, businesses, contractors, etc.). The specified CFL collection container is a properly labeled cardboard box contained within an orange fixture. While we try to inform customers of the intended CFL program, there are times when customers leave fluorescent tubes and u-shaped lamps at the store. If this is the case, the HHM Program requires store associates to immediately take these tubes and lamps to the Central Storage Area and place them in the universal waste boxes designated for store-generated tubes and lamps. These aspects of the HHM Program have been reviewed with affected store associates to ensure proper containerization going forward. 2