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RECEIVED 2/28/2019 <br /> E) <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 T2347— Lathrop <br /> EPA ID#: CAR000218677 <br /> Dear Ms. Florido, <br /> In order to demonstrate compliance with findings associated with the inspection of Target Store T2347 on <br /> January 29, 2019, Target Corporation provides the following responses to the alleged violations. <br /> #1 Failed to train employees on waste handling and emergency procedures. [CCR 66262.23(a)(4)1 <br /> Response: Target's Corporate Compliance team has worked with Store T2347 to review best practices <br /> for properly sorting hazardous waste. Based on the observations noted during the inspection, a member <br /> of Target's Field Compliance Team will be visiting the store to review the ESIM process with the store <br /> team. A copy of the training records for T2347 is attached, along with a photo of the hazardous waste <br /> storage area showing all containers are properly closed and labeled [Attachments A and B]. <br /> #2 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 /> T2347 I Manifest (generation date) I Date Mailed to DTSC <br /> - 011966424FLE (12/27/18)— 1/02/19 <br /> - 011882997FLE (11/7/18)— 11/14/18 <br /> - 011890004FLE (9/19/18)— 9/28/18 <br /> - 011890003FLE (9/19/18)— 10/18/18 <br /> - 011862692FLE (8/1/18)— 8/09/18 <br /> - 011862694FLE (8/1/18)— 8/27/18 <br /> - 011841018FLE (6/12/18)— 6/26/18 <br /> - 011221878FLE (12/26/17)— 1/16/18 <br /> - 010512880FLE (3/17/17)— 4/21/17 <br /> - 009725345FLE (5/10/16)— 6/22/16 <br /> - 009597815FLE (3/2/16)— 4/08/16 <br /> Corporate Compliance&Ethics,33 South 6th Street,CC-3625, Minneapolis, MN 55402 <br />