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V CVSHealth Ms. Florido November 2, 2018 Page 2 CVS's retail hazardous waste management program was designed to comply with applicable hazardous waste regulations in a manner that takes into consideration the unique challenges associated with a retail setting. Store-specific components of the store's Hazardous Waste Contingency Plan are found in the store's Emergency Procedures Plan(EPP) Summary, posted near out-dialing telephones, and in the Hazardous Materials Business Plan(HMBP) submitted via the California Environmental Reporting System (CERS), and included in the Environmental Health and Safety Reports Portal (the "EH&S Portal") at the store level. The HMBP includes the current telephone number for the State Office of Emergency Services. Utilization of the EPP summary, a component of the CVS Contingency Plan, for store- specific information was implemented in order to effectively and consistently manage the challenge of having a large quantity of stores (CVS has approximately 9,700 stores nationwide) and high employment turnover. CVS's EPP Summary (example attached), identifies a specific local contact for a given CVS store, including that person's telephone number. By posting this component of the CVS Contingency Plan by out-dialing telephones, employees can more quickly access emergency contact information than they would if the emergency contact information was solely detailed in the contingency plan document or the HMBP. In addition to the details above, we note that it is extremely important that employees follow a consistent, streamlined program in the event of a potential emergency. By requiring the store to call two contacts (the local store contact's cell phone and the 3E hotline),the program has proven successful in ensuring responses to potential emergencies are handled efficiently and consistently among CVS stores. For this reason, we do not distinguish between primary and secondary contacts; doing so would likely complicate the currently successful program and increase the possibility that an appropriate responder is not contacted during an emergency. A description of actions facility personnel will take in response to fires, explosions, or any sudden or non-sudden release of hazardous waste to air, soil, or surface water at the facility is included on page 11 of the contingency plan document,which is maintained onsite in the EH&S Binder and electronically at the store level in the EH&S Portal. The contingency plan document was also submitted via CERS, as part of the HMBP. A description of the arrangements made with local emergency responders is also included in the contingency plan document at page 12. Specifically, page 12 notes, "Where required, local fire, police, hospitals, and the state emergency agency have been provided a copy of the Contingency Plan along with aid notification letters." These letters familiarize emergency responders with the types of waste generated at the store and general layouts of the facility. Aid notification letters were provided to local emergency providers on Store 3908's behalf on September 19, 2012, which included a copy of the store's contingency plan document. A copy of these letters also available electronically at store level in the EH&S Portal. A copy of the Aid Notification letters are attached here for your reference. The emergency equipment is addressed in the contingency plan document, on pages 13 and 14. A list of the emergency response equipment onsite, along with the equipment capabilities locations is also included. Emergency equipment information is also available on the store's EPP CVS pharmacy / caremark /minute clinic/specialty