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vIU <br /> APR 1 5._ 8 • <br /> ENNONMENT HEALTH <br /> PEI?MTSERVICES TARGET <br /> April 10,2008 <br /> Mr. William Ng, Lead Senior Registered Environmental Health Specialist <br /> County of San Joaquin <br /> Department of Environmental Health <br /> 600 E. Main St. <br /> Stockton, CA 95202 <br /> Re: Facility Certification of Return to Compliance <br /> Target Store T0853: Facility ID 10912 <br /> Dear Mr. Ng: <br /> Thank you for the opportunity to respond to the inspection conducted at Target Corporation's(Target) <br /> above mentioned store(0853)March 10,2008. <br /> The following is Target's response to the waste generator inspection report: <br /> 25189.5 HSC&25201(a)HSC <br /> In the event of hazardous waste generation from spills,Target protocol is to follow the steps outlined in <br /> the Alert One chart. In clarifying comments made by Executive Team Lead-Logistics,Andy Vargas <br /> stated that as a response to theoretical questions asked during the inspection he indicated he may have at <br /> some point in the past sewered small amounts of bleach with water. This is not a standard operating <br /> procedure for Target. <br /> 66265.31 CCR <br /> The cardboard containers observed having small amounts of moisture,presumably from the dish soap that <br /> was stocked there,have been set aside in plastic bags for our waste vendor to pick up with the next <br /> service. <br /> 66265.34&66265.17 CCR <br /> We believe there is a need to clarify the status of products which are returned to Target and when they <br /> become"hazardous waste"under the above citations. We ask for your assistance in this regard. The <br /> products we believe are in many cases not hazardous,and in all cases are not waste because there is no <br /> intent to discard them at the time they are returned. At the same time,Target has great respect for the <br /> County and its goal to protect the environment. In this respect,we hope to reach a consensus with you <br /> regarding the proper interpretation of this section and its application to our operations. <br /> The Target reverse logistics area,where guest returned items are processed,is not a hazardous waste <br /> storage area. Target has a program for environmentally sensitive items that are returned and/or cannot be <br /> sold. Items which are designated as sensitive do not necessarily contain materials that would be <br /> designated as hazardous waste if they were discarded. Rather,we identify a wider category of materials <br /> as sensitive so that we can pay additional attention to their ultimate disposition. Under our program,these <br /> items are segregated. Primary containment is provided by the original product container. A second level <br /> of containment and identification is provided by bagging and sealing the bags. A third level of <br /> containment is provided by placing the bagged products in totes in the Reverse Logistics area for potential <br /> donation or other disposition. <br /> As we believe your inspection will confirm,the items in question are in small household quantities. We <br /> have no reported release of the contents of those products to the environment,or of any other injury from <br /> our program. More importantly, under Section 25124,these products are not considered waste as they <br /> Environmental Services, 33 South 6'h Street, CC-3735, Minneapolis, MN 55402 <br />