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RECEIVED 2/22/2019 <br /> E) <br /> TARGET <br /> February 22, 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 T1862—Stockton North <br /> EPA ID#: CAR000217968 <br /> Dear Ms. Florido, <br /> In order to demonstrate compliance with findings associated with the inspection of Target Store T1862 on <br /> January 22, 2018, 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 /> T1862 I Manifest (generation date) I Date Mailed to DTSC <br /> - 011860825FLE (11/19/18)— 11/28/18 <br /> - 011860824FLE (11/19/18)— 11/19/18 <br /> - 011883230FLE (10/17/18)— 10/22/18 <br /> - 011883228FLE (10/17/18)— 11/07/18 <br /> - 011841858FLE (8/9/18)—8/21/18 <br /> - 011841855FLE (8/9/18)—9/13/18 <br /> - 011841599FLE (7/6/18)—7/19/18 <br /> - 009543210FLE (5/19/16)—7/6/16 <br /> #2 Failed to complete training on hazardous waste management and emergency response procedures. <br /> (CCR66265.16(a-c) <br /> Response: Target's Corporate Compliance team has worked with Store T1862 to review best practices <br /> for properly sorting hazardous waste. Due to the variety of potentially hazardous retail chemicals that may <br /> be generated, all products that will be sold at Target are pre-evaluated for hazardous waste <br /> determinations in case the product becomes unusable and therefore a solid waste. Target uses a third <br /> party company called the WERCs to classify the hazardous waste characteristics and chemical <br /> compatibility of all products that will be sold at Target stores. The WERCs uses SDS sheets along with <br /> ingredient levels to classify each retail product based on EPA/State waste identification and chemical <br /> Corporate Compliance&Ethics,33 South 6'h Street,CC-3625, Minneapolis,MN 55402 <br />