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E) RECEIVED 2/28/2019 <br /> TARGET <br /> February 28, 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 T0738—Tracy <br /> EPA ID#: CAR000219147 <br /> Dear Ms. Florido, <br /> In order to demonstrate compliance with findings associated with the inspection of Target Store T0738 on <br /> January 29, 2018, Target Corporation provides the following responses to the alleged violations. <br /> #1 Contingency Plan is incomplete. [CCR66265.521 <br /> Response: Target stores in California submit two separate Contingency Plans to comply with both federal <br /> and state regulations. The HMBP contains a Contingency Plan with required state specific information. A <br /> copy of the HMBP for Store T0738 is attached [Attachment A]. <br /> #2 Failed to send generator manifest copies to DTSC within 30 davs. [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 /> T0738 I Manifest (generation date) I Date Mailed to DTSC <br /> - 011883868FLE (12/5/18)— 12/13/18 <br /> - 011883867FLE (12/5/18)— 12/28/18 <br /> - 011841282FLE (11/8/18)— 11/16/18 <br /> - 011841281FLE (11/8/18)— 12/01/18 <br /> - 011883273FLE (10/10/18)— 12/01/18 <br /> - 011883277FLE (10/10/18)— 10/15/18 <br /> - 011944683FLE (9/25/18)— 10/15/18 <br /> - 011860688FLE (9/12/18)— 9/21/18 <br /> - 011860686FLE (9/12/18)— 10/04/18 <br /> - 011868434FLE (8/15/18)— 8/24/18 <br /> - 011868432FLE (8/15/18)— 9/07/18 <br /> - 018862662FLE (7/16/18)— 7/25/18 <br /> - 011862665FLE (7/16/18)— 8/02/18 <br /> - 011841654FLE (6/21/18)— 7/03/18 <br /> Corporate Compliance&Ethics,33 South 6'h Street,CC-3625, Minneapolis,MN 55402 <br />