Laserfiche WebLink
RECEIVED 3/8/2019 <br /> TARGET <br /> March 8, 2019 <br /> Elianna Florido, REHS <br /> San Joaquin County Environmental Health Department <br /> 1868 East Hazelton Ave <br /> Stockton, California 95205 <br /> RE: Target Store T1526—Manteca <br /> EPA ID#: CAR000217869 <br /> Dear Ms. Florido, <br /> In order to demonstrate compliance with findings associated with the inspection of Target Store T1526 on <br /> February 6, 2019, Target Corporation provides the following responses to the alleged violations. <br /> #1 Failed to send generator manifest copies to DTSC within 30 days. [CCR 66262.23(a)(4)1 <br /> Response: Target contracts our hazardous waste vendor Clean Harbors, to submit manifests to the <br /> DTSC, and Clean Harbors has confirmed that the listed manifests have been mailed to DTSC. Once <br /> service is completed at the local store Target's vendor sign as both the transporter and generator. A <br /> copy of the manifest is created and the original carbon generator copy is left onsite. The photo copies are <br /> collected at the waste vendor's respective branches and mailed into the DTSC. Target, along with DTSC, <br /> have identified an issue with uploading manifests to the Hazardous Waste Tracking System (HWTS)that <br /> began in early 2012. Per the department website, the DTSC takes every precaution to ensure the <br /> accuracy of data in the HWTS. However, because of the large number of manifests handled, inaccuracies <br /> in the submitted data, limitations of the manifest system and the technical limitations of the database, <br /> DTSC cannot guarantee that the data accurately reflect what was actually transported or produced. <br /> T1526 I Manifest (generation date) I Date Mailed to DTSC <br /> - 011882966FLE (10/31/18) — 11/07/18 <br /> - 011882965FLE (10/31/18) — 11/21/18 <br /> - 011860486FLE (9/19/18) — 9/28/18 <br /> - 011860483FLE (9/19/18) — 10/18/18 <br /> - 011889912FLE (8/8/18) — 8/17/18 <br /> - 011841886FLE (6/27/18) — 7/11/18 <br /> - 011548341 FLE (6/5/18) — 6/20/18 <br /> - 011790975FLE (4/4/18) — 4/25/18 <br /> - 009858324FLE (7/14/16) — 7/26/16 <br /> - 009542966FLE (4/21/16) — 6/04/16 <br /> #2 Failed to complete training on hazardous waste management and emergency response procedures. <br /> [CCR66265.16(a-c)1 <br /> Response: Target's Corporate Compliance team has worked with Store T1526 to review best practices <br /> for properly sorting hazardous waste. Non Retail products which have been classified as ESIM are <br /> brought to Reverse Logistics daily for processing. The store's product rotation process is separate from <br /> the hazardous management process, and the product rotation process for OTC is currently under review. <br /> The hazardous materials training summary along with Store T1526 training records are attached <br /> [Attachment A]. <br /> Corporate Compliance&Ethics,33 South 6th Street,CC-3625, Minneapolis,MN 55402 <br />