Laserfiche WebLink
f t <br /> t <br /> AMY P.MCIRROW <br /> TROUTMAN SANDERS LLP <br /> ,404.885.3267 telephone <br /> TROUTMAN Attorneys at Law <br /> 404.962.6624 facsimile Bank of America Plaza <br /> amy.mcmorrow®troutmansanders.com SANDERS 600 PeachtreAtlatnta tGAE30308-22116 <br /> 404.885.3000 telephone <br /> troutmansanders.com <br /> lit.,\ <br /> 1Ufle 3, 2011 <br /> JUN 06 2011 <br /> S,+1ti,1Cr!C�r,l,�a COUNTY <br /> ENV!ir*0N,,�_NTAL <br /> HEALTH DEPARTMENT <br /> VIA FEDERAL EXPRESS <br /> Ms. Michelle Henry <br /> San Joaquin County <br /> 600 East Main Street <br /> Stockton, CA 95202-3029 <br /> (209)468-3420 <br /> Re: Hazardous Waste Program Inspection Report Issued to CVS/pharmacy <br /> Store No. 9830 (6632 Pacific Avenue) (Inspected April 1 and April 5,2011). <br /> Dear Ms. Henry: <br /> As you are aware, our firm represents CVS Pharmacy, Inc. (CVS) with respect to <br /> environmental compliance issues that arise at its stores in California. This letter responds to the <br /> Inspection Report and Notice to Comply conducted at CVS Store 9830 on April 1 and 5, 2011 <br /> and delivered to CVS on May 5, 2011. <br /> As a result of this store's relocation, it appears that hazardous waste collection containers <br /> may have been improperly transported to the store's new location at 6632 Pacific Avenue by <br /> CVS or its contractors, as described in violation number 6. CVS is working to modify its store <br /> relocation protocols to ensure all hazardous waste accumulated at relocating stores is handled <br /> properly by CVS and its contractors in the future. All retail and pharmaceutical waste present at <br /> the store was removed by StrongPak on April 27, 2011. Manifest number 004510985FLE is <br /> provided here for your reference. <br /> You also expressed concern, in violation number 7, regarding the timeliness with which <br /> damaged products are characterized and processed and the return of such products to the <br /> distribution center. In response to these concerns, CVS has re-visited its waste determination <br /> procedure and will soon be implementing a new procedure requiring processing of damaged or <br /> returned items that are leaking as soon as practicable once received at the store. This entails <br /> placing the leaking item in a self-sealing bag with absorbent immediately upon receipt in order to <br /> segregate the item from other, potentially incompatible items. The items would then be <br /> processed out of inventory and, if determined to be hazardous, into the correct hazardous waste <br /> container as soon as practicable based on staffing availability, but at least on a daily basis. <br /> Damaged or returned items that are not leaking would not be immediately bagged, but would be <br /> set aside and also undergo a waste determination and be processed out of inventory on at least a <br /> ATLANTA CHICAGO HONG KONG LONDON NEW YORK NEWARK NORFOLK ORANGE COUNTY PORTLAND <br /> RALEIGH RICHMOND SAN DIEGO SHANGHAI TYSONS CORNER VIRGINIA BEACH WASHINGTON, DC <br />