Document R20yVLM3pj4QKwzya76xyZ1qE
Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied:
REGION 10 Enforcement Division
INSPECTION REPORT
02/08/2021 - 02/08/2021 Announced: No
Entry: 10:30 AM (AKT)
Exit: 02:00 PM (AKT)
RCRA
Title 40 - ENVIRONMENTAL PROTECTION AGENCY
Company Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address)
TARGET CORPORATION
TARGET STORE T2339
1801 E PARKS HWY
WASILLA, AK 99654
Retail store
157000 sq. ft.
October 2008
61.577971, -149.402854
Paul Hamilton, Sr. Environmental Program Owner (612) 304-6171 Corporate Compliance and Ethics/Legal Affairs Mailstop: CC-3625, 33 South 6th Street Minneapolis, MN 55402 paul.hamilton@target.com corporate.compliance@target.com
CC: Ben Munson, T2339 Store Director benjamin.munson@target.com Derek Siegrist, Executive Team Leader - Human Resources derek.siegrist@target.com
Nicole Ratigan, Senior Environmental Specialist, Corporate Environmental 1 CVS Drive, Mail Code 2340 Woonsocket, RI 02895 (401) 770-6259 nicole.ratigan@cvshealth.com
(city, state, zip code) County:
Minneapolis, MN 55402
Facility/Site Identifier: Media Number: NAICS:
AKD983068990 Unpermitted Facility 452210 - Department Stores
Lead Inspector: Jon Jones
REGION 10
Jones.Jon@epa.gov
(907) 271-6329
1 of 18
TARGET STORE T2339 Inspection Date(s):
02/08/2021 - 02/08/2021
Supervisor Review: Jen Sullivan
REGION 10
Sullivan.Jennifer.A@epa.gov (206) 553-6978
SECTION I - INTRODUCTION Purpose of the Inspection/Objective
Type of inspection: CEI - Compliance Evaluation Inspection
This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279) The inspection was conducted as part of a Core Program requirement for FY 2021.
Attendees
Title
Name
Lead Inspector Jon Jones
Store Director Ben Munson
Executive Team Lead Human Resources
Derek Siegrist
Phone 9072716329 (907) 631-7200 (907) 631-7200
Email
Present in Opening Conf.
Jones.Jon@epa.g Yes ov
benjamin.munso Yes n@target.com
derek.siegrist@ta Yes rget.com
Present in Closing Conf. Yes
Yes
Yes
Opening Conference
EPA Lead Inspector Jon Jones arrived at the Target Store T2339 at 10:30 AM (AKT) on 02/08/2021 for an inspection. I presented my credentials to Ben Munson and informed him that this was an EPA RCRA inspection. The table above presents all the inspection participants.
During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's universal waste. Additionally, the facility representatives told me they were not managing used oil and I did not observe any while at the facility. Specifically, I inspected the following areas of the facility:
Store front Shipping and receiving area (CAA) Property Management Lead Office On-site CVS Pharmacy #17404
CVS Pharmacy #17404 operates inside the Target Store T2339. There is no separate entry or exit for the pharmacy. Customers using the pharmacy must enter and exit through the Target Store. During the inspection, Mr. Derek Siegrist, Executive Team Leader - Human Resources, gave me the following contact information for questions related to the CVS Pharmacy #17404:
Shannon Slavens, CVS Environmental Manager (401) 770-2836
2 of 18
TARGET STORE T2339 Inspection Date(s):
02/08/2021 - 02/08/2021
During the inspection, I spoke with the following CVS Pharmacy #17404 Staff:
Eryn Von Edwins, Pharmacy Technician
Uriah Clarkson, Pharmacist
They told me the following items, generated at CVS Pharmacy #17404 , are sent for Reverse Distribution are sent via common carrier (UPS), to Inmar Rx Solutions, 3845 Grand Lakes Way, Suite 125 Grand Prairie, TX 75050:
Creditable Hazardous Waste (HW) Pharmaceuticals (PHARMS) Non-Creditable Non-Hazardous Waste PHARMS
I asked Ms. Von Edwins if Inmar Rx Solutions ever provided any information as to what items did or did not receive any credit. Ms. Von Edwins told me that the only information they receive is how much credit they receive. She told me they are not made aware of items that don't receive credit.
Additionally,
Clean Earth, Inc., 8100 Petersburg St., Anchorage, AK 99507
Picks up the Non-Creditable HW PHARMS from CVS Pharmacy #17404 and they are shipped to Burlington Environmental, LLC in Tacoma, WA. Picks up the HW PHARMS tracked by the Drug Enforcement Agency (DEA) and they are shipped to Nortru, LLC, 421 Lycaste St., Detroit, MI 48214. CVS Pharmacy #17404 manages their disposal through DEA Registrant #FA5754785.
*Clean Earth, Inc. purchased the Environmental Division of Stericycle Specialty Waste Solutions, Inc. in April 2020. Stericycle continues to manage biohazard/medical wastes.
On the day of the inspection (2/8/21), I received an email from Brenna Hermen, Pharm. D., CVS Health Pharmacy Supervisor, Region 83, District 2. In Ms. Hermen's email, she states..."My team at CVS/Pharmacy inside Target in Wasilla, AK notified me you had stopped in for a visit! If you have any questions please feel free to reach out to my corporate partner, Shannon Slavens." Before I was able to reach out to Ms. Slavens, she also sent me an email, dated 2/9/21 in which she states..."We are happy to help with any questions you might have. Nikki Ratigan, on my team and copied, can assist also. We are happy to jump on a call, or feel free to send us questions. Also - we will be the point of contact for all follow up that might be needed (we help facilitate close out of all inspections for CVS nationwide). We are happy to help! Shannon."
Site Description
Target Store T2339 is a department store located in Wasilla, AK. CVS Pharmacy #17404 operates as a separate entity inside the T2339 store. According to Mr. Munson, Target got out of the pharmacy business approximately five years ago. According to Mr. Munson, Target sold their pharmacy business to CVS. Mr. Munson explained that since Target does not operate the pharmacy, Target does not have any information about how CVS Pharmacy #17404 manages hazardous waste pharmaceuticals.
Facility Info
Number of employees 155
3 of 18
TARGET STORE T2339
Inspection Date(s):
Weather Conditions Operating Hours Safety Training Provided to Inspector(s)?
Sunny and cold 8:00 am to 10:00 pm, Monday through Sunday No
02/08/2021 - 02/08/2021
What type of generator facility notified?
What type of generator facility verified as?
Small Quantity Generator (SQG) SQG generator status was verified by Mr. Munson, T2339 Store Director
Process Description
According to Mr. Munson, most of the waste generated by Target includes various chemicals and cleaners that are either damaged when they arrive in store, damaged in store, or returned by the customer. Mr. Munson stated that these wastes include, but are not limited to the following:
Waste batteries that are managed as universal waste Waste fluorescent lamps that are managed as universal waste Cosmetics, such as nail polish Various cleaners Waste streams in the facility's central accumulation area (CAA) were accumulated in transparent plastic totes and included: Non-RCRA Hazardous Waste State Toxic Hazardous Waste Aerosol - Toxic Ignitable Hazardous Waste Pharmaceuticals Over the Counter (OTC) Hazardous Waste Oxidizer - Ignitable Hazardous Waste Corrosive - Basic Hazardous Waste Corrosive - Acidic
Building(s)
Building/Area Target Store Shipping and receiving area Central accumulation area (CAA)
Process Description
Location where the store personnel accumulate hazardous waste, universal waste (batteries and lamps), and HW PHARMS (OTC).
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Areas of Concern No No No
TARGET STORE T2339 Inspection Date(s):
SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations
02/08/2021 - 02/08/2021
Building: Target Store/Shipping and receiving area/Central accumulation area (CAA)
Contains CBI: No
Observation #: JJ1-OB-001
Date/Time: 02/19/2021
I inspected the facility's CAA, located in the shipping and receiving area of the back room of the store. At the time of the inspection, I saw multiple plastic totes containing various wastes that included hazardous, universal, non-RCRA state only waste (WA), and HW PHARMS which were also labeled as "OTC" (Over-the-counter), meaning they were non-prescription. These totes were all closed, labeled, and marked with a hazard indicator. The containers were all dated and according to the dates, none of the hazardous wastes had been in accumulation for greater than 270 days and the universal waste and HW PHARMS (OTC) have been in accumulation for less than a year.
Records Review
Record: Inspections Ref #: JJ1-RR-002
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 02/18/2021 01:38 PM (AKT)
At the time of the inspection, I asked Mr. Munson to email Target Store T2339 weekly hazardous waste inspections for the period covering February 8, 2017 through February 8, 2021. While reviewing weekly inspection logs, I saw that there were no weekly inspections conducted for 76 weeks.
Document(s) 1. ESIM Weekly Log.xlsx
Record: Exception Reports
Ref #: JJ1-RR-004
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 02/18/2021 02:27 PM (AKT)
Following the inspection, I reviewed the hazardous waste manifests and associated paperwork that Mr. Hamilton emailed to me on February 9, 2021. Prior to February 6, 2020, Target Store T2339 had notified (870012) and was operating as a Large Quantity Generator (LQG) of hazardous waste since February 2014. During my review of the manifests, I saw 13 manifests with a span between the shipping dates for the hazardous waste and the dates the waste was received by the designated facility that was greater than 45 days. There were no exception reports for the 13 manifests included in Mr. Hamilton's February 9, 2021 email. On February 12, 2021 I sent a "Request for Documents" email to Mr. Hamilton, via the "GoAnywhere" platform. In that email I requested that he send Copies of exception reports for the following hazardous waste manifests:
#008411633 FLE dated 05/30/18
#008411635 FLE dated 05/30/18
#008411693 FLE dated 09/25/18
5 of 18
TARGET STORE T2339 Inspection Date(s):
#009994507 FLE dated 11/15/18
02/08/2021 - 02/08/2021
#009994472 FLE dated 05/02/19
#009994607 FLE dated 10/14/19
#009994682 FLE dated 10/14/19
#012698108 FLE dated 03/04/19
#012598125 FLE dated 01/11/19
#012598444 FLE dated 06/29/19
#012698109 FLE dated 03/04/19
#012698305 FLE dated 12/12/19
#012698308 FLE dated 12/12/19
In my "Request for Documents" email to Mr. Hamilton, I requested that he provide the documentation to me on or before March 1, 2021. This information was received on 2/24 and 2/25/21. I reviewed the documentation sent by Mr. Hamilton and saw that there were exception reports for the 13 manifests, but four of the exception reports were not sent to the EPA Region 10 Administrator. Four exception reports were sent to the Alaska Department of Environmental Conservation (ADEC) Commissioners Office. All the exception reports were submitted by Clean Harbors Environmental Services, Inc. on behalf of their client, Target Corporation.
No exception reports were sent to the EPA Region 10 Administrator for the following hazardous waste manifests:
#008411633 FLE
#008411635 FLE
#008411693 FLE
#012598444 FLE
Document(s)
1. #008411633FLE Exception Rpt.pdf 2. #008411635FLE Exception Rpt.pdf 3. #008411693FLE Exception Rpt.pdf 4. #012598444FLE Exception Rpt.pdf 5. #008411633FLE 5.30.18.pdf 6. #008411635FLE 5.30.18.pdf 7. #008411693FLE 9.25.18.pdf 8. #012598444FLE 6.29.19.pdf
Record: Exception Reports
Ref #: JJ1-RR-005
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 02/18/2021 02:53 PM (AKT)
Following the inspection, I reviewed the uniform hazardous waste manifests and associated paperwork that Mr. Hamilton emailed to me on February 9, 2021. On February 6, 2020 Target Store T2339 submitted a subsequent notification (8700-12) to EPA changing their generator status from LQG to Small Quantity Generator (SQG).
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TARGET STORE T2339
Inspection Date(s):
02/08/2021 - 02/08/2021
During my review of the manifests, I saw five manifests with a span between the shipping dates for the waste and the dates the waste was received by the designated facility that was greater than 60 days. There were no exception reports for the five manifests included in Mr. Hamilton's February 9, 2021 email. On February 12, 2021 I sent a "Request for Documents" email to Mr. Hamilton requesting that he send copies of exception reports for the following hazardous waste manifests:
#009994732 FLE dated 10/28/20
#012698337 FLE dated 08/11/20
#012698338 FLE dated 08/11/20
#012698427 FLE dated 05/29/20
#012698428 FLE dated 05/29/20
I reviewed the documentation sent by Mr. Hamilton and saw that there were exception reports for the five manifests, but they were not sent to the EPA Region 10 Administrator. The five exception reports were sent to the ADEC Commissioners Office. Again, these exception reports were submitted by Clean Harbors Environmental Services, Inc. on behalf of their client, Target Corporation.
No exception reports were sent to the EPA Region 10 Administrator for the following hazardous waste manifests:
#009994732 FLE
#012698337 FLE
#012698338 FLE
#012698427 FLE
#012698428 FLE
Document(s) 1. #009994732FLE Exception Rpt.pdf 2. #012698337FLE Exception Rpt.pdf 3. #012698338FLE Exception Rpt.pdf 4. #012698428FLE Exception Rpt.pdf 5. #012698427FLE Exception Rpt.pdf 6. #009994732FLE 10.28.20.pdf 7. #012698337FLE 8.11.20.pdf 8. #012698338FLE 8.11.20.pdf 9. #012698428FLE 5.29.20.pdf 10. #012698427FLE 5.29.20.pdf
Record: Ensure applicable employees are trained - SQG
Ref #: JJ1-RR-006
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 02/18/2021 03:06 PM (AKT)
At the time of the inspection, I asked Mr. Munson to email training records for Target Store T2339 personnel that managed hazardous waste, universal waste and non-creditable HW PHARMS, regulated by Part 266, Subpart P. Mr. Munson had Mr. Siegrist email the training records to me on February 8, 2021, the day of the inspection. While reviewing the training records, I saw that there were several Target Store personnel that had
7 of 18
TARGET STORE T2339
Inspection Date(s):
02/08/2021 - 02/08/2021
been conducting weekly hazardous waste inspections and were not listed in the training records provided to me. In my February 12, 2021 "Request for Documents" email to Mr. Hamilton, I requested copies of training records for the following Target Store T2339 personnel that had conducted weekly hazardous waste inspections:
Mariah Householder
Steven Ehrhart
Melissa Donnally
Caitlin Self
Ryan Landis
I reviewed the documentation sent by Mr. Hamilton and saw that the training information provided for the Target personnel listed above, indicated the following:
Mariah Householder received Environmentally Sensitive Item Management (ESIM) Hazardous Waste Management (HW Mgmt.) training on 5/22/20, yet she conducted a total of eight weekly hazardous waste inspections prior to receiving any training. The inspections she conducted prior to her 5/22/20 training took place on the following dates: 3/2/20, 3/11/20, 3/19/20, 3/27/20, 4/2/20, 4/16/20, 4/24/20, and 5/13/20. Steven Ehrhart received ESIM HW Mgmt. training on 12/4/19. Melissa Donnally , whose last name changed several times (Roux/Butler) received the ESIM HW Mgmt. training on 2/18/15, 1/13/16, 1/3/17, and 12/8/17. Caitlin Self received ESIM HW Mgmt. training on 6/11/18 and again on 8/8/19, yet she conducted a weekly hazardous waste inspection at Target Store T2339 on 7/6/17, prior to receiving any training. Ryan Landis received ESIM HW Mgmt. training on 9/19/18, yet he conducted a weekly hazardous waste inspection at Target Store T2339 on 5/4/17, prior to receiving any training.
Record: Facility Layouts
Ref #: JJ1-RR-007
Reviewed By: Jon Jones
AOC: No
Reviewed Date: 02/19/2021 09:48 AM (AKT)
Document(s) 1. T2339 Facility Drawing.pdf
Record: Manifests Ref #: JJ1-RR-008
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 03/17/2021 10:19 AM (AKT)
At the time of the inspection, CVS Pharmacy #17404 was operating inside Target Store T2339. On February 11, 2021 I sent a request for documents email, via "GoAnywhere", to Ms. Nicole Ratigan, CVS Health. In that document request, I asked for copies of hazardous waste manifests and land disposal restriction notices (LDRs) for the period February 8, 2018 through February 8, 2021. In that email, I asked Ms. Ratigan to provide the requested documents on or before February 26, 2021. Ms. Ratigan sent the requested documents on February 26, 2021.
I reviewed the documentation and saw that none of the manifests contained the EPA I.D. # AKD983068990 in block 1, the number assigned to the Target Store T2339 site. The following CVS Pharmacy #17404 hazardous waste manifests contained the acronym "CESQG" (Conditionally exempt small quantity generator) in block 1:
8 of 18
TARGET STORE T2339 Inspection Date(s):
#010173578FLE
#010752086FLE
#010752291FLE
#012962304FLE
#012962438FLE
#010174334FLE
#012960926FLE
#011433799FLE
#011433800FLE
Document(s) 1. #010173578FLE 1.11.18.pdf 2. #010752086FLE 4.23.18.pdf 3. #010752291FLE 10.8.18.pdf 4. #012962304FLE 3.29.19.pdf 5. #012962438FLE 9.9.19.pdf 6. #010174334FLE 2.25.20.pdf 7. #012960926FLE 8.10.20.pdf 8. #011433799FLE 2.2.21.pdf 9. #011433800FLE 2.2.21.pdf
02/08/2021 - 02/08/2021
Record: Manifests Ref #: JJ1-RR-009
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 03/17/2021 11:19 AM (AKT)
While reviewing the hazardous waste manifests Ms. Ratigan sent on February 26, 2021, I saw that the following two manifests did not contain the acronym "PHARMS" in block 13:
#012962304FLE
#011433800FLE
Document(s)
1. #012962304FLE 3.29.19.pdf 2. #011433800FLE 2.2.21.pdf
Record: Ensure applicable employees are trained - SQG
Ref #: JJ1-RR-010
Reviewed By: Jon Jones
AOC: Yes
Reviewed Date: 03/17/2021 11:24 AM (AKT)
In my February 11, 2021 request for documents email, to Ms. Ratigan, I asked for copies of training records for CVS Pharmacy #17404 personnel working at the Target Store T2339, including a copy of the training CVS personnel received and training dates.
After reviewing the documentation Ms. Ratigan sent, I saw that the following active CVS Pharmacy #17404
9 of 18
TARGET STORE T2339
Inspection Date(s):
02/08/2021 - 02/08/2021
personnel received "Hazardous Waste Training for Pharmacy Colleagues" Course #500147 (May 2020) on the following dates:
Jenifer Breiner
4/14/2018
Cameron Carlson 10/13/2020
Lindsay Causey
11/17/2018
Uriah Clarkson
5/8/2018
Cameron Macon 5/8/2018
Desiree Molina
4/14/2018
Madison Ortega 9/29/2020
Nicole Spinner
5/8/2018
Benjamin Stancombe 5/12/2018
Eryn Von Edwins 5/2/2018
Kathleen Zinnerzwink 12/29/2020
The training records also contained the names of CVS Pharmacy #17404 personnel no longer employed with CVS that received Course #500147 training on the following dates:
Edward Danilyuk 5/12/2018 Separation Date: 7/21/2019
Barbara Gugelman 1/2/2019 Separation Date: 4/6/2020
Brianna Morris
4/26/2018 Separation Date: 9/7/2019
Courtney Ponte 8/6/2019 Separation Date: 8/30/2020
Jennifer Rochelle 4/18/2018 Separation Date: 10/31/2019
Margaret Spilman 7/20/2019 Separation Date: 7/21/2020
I reviewed the "Hazardous Waste Training for Pharmacy Colleagues" Course #500147 (May 2020) that was submitted with Ms. Ratigan's February 26, 2021 response and saw that it contained information that was contrary to the hazardous waste pharmaceuticals rule which was promulgated on February 22, 2019. Training course #500147 which was current as of May 2020 contained a picture of a hazardous waste pharmaceutical tote with a label that was marked with the words, "Pharmacy Hazardous Waste." The same page informed the pharmacy staff to "refer to job aides and training for each specific program to determine proper handling."
I reviewed the "Hazardous Waste Job Aid Packet", also current as of May 2020, that was included with Ms. Ratigan's response and saw that it contained the same labeling information under the heading, "Hazardous Waste Tote Setup".
Neither of the two training documents contained any training information related to filling out the hazardous waste manifest correctly (i.e. "PHARMS" in Block 13).
Due to the inadequate content of the submitted training materials, the following CVS Pharmacy #17404
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TARGET STORE T2339
Inspection Date(s):
02/08/2021 - 02/08/2021
personnel had not received adequate training either prior to, or following the hazardous waste pharmaceuticals rule, promulgated on February 22, 2019:
Jenifer Breiner Cameron Carlson Lindsay Causey Uriah Clarkson Cameron Macon Desiree Molina Madison Ortega Nicole Spinner Benjamin Stancombe Eryn Von Edwins Kathleen Zinnerzwink Edward Danilyuk Barbara Gugelman Brianna Morris Courtney Ponte Jennifer Rochelle Margaret Spilman
Document(s) 1. 17404 AK Hazardous Waste Training Records.pdf 2. 500147_JobAid_Packet_2020.pdf 3. 2020 500147_Pharmacy Hazardous Waste Training.pdf
Record: Others Ref #: JJ1-RR-011
Reviewed By: Jon Jones
AOC: No
Reviewed Date: 03/17/2021 01:54 PM (AKT)
In my February 12, 2021 "Request for Documents" email to Mr. Hamilton, I requested that he send a copy of any contract or documentation outlining the arrangement between Target Corporation and CVS Health. This information was received on 2/24/21 and the following language was in Mr. Hamilton's email response:
"CVS CONTRACT LANGUAGE: c. Medical. Pharmaceutical, Environmental, Biohazard and Other Materials. CVS shall be responsible for the disposal of all medical, pharmaceutical, environmental, biohazard and other similar materials and similar records used or generated by CVS in any Leased Space in accordance with all applicable Laws. Target shall permit access to the Stores and Leased Space to CVS's vendors to conduct such disposal,
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TARGET STORE T2339
Inspection Date(s):
02/08/2021 - 02/08/2021
subject to the provisions of the Pharmacy Operating Agreement regarding access to such Stores. All obligations of CVS pursuant to this subsection 7.c shall be performed by CVS at CVS's sole cost and expense."
Document(s) 1. T2339 Response to Document Request.docx
Record: Others Ref #: JJ1-RR-012
Reviewed By: Jon Jones
AOC: No
Reviewed Date: 03/17/2021 02:09 PM (AKT)
In my February 11, 2021 "Request for Documents" email, to Ms. Ratigan, I asked for a copy of any contract or documentation of the arrangement between CVS Health and Target Corporation. Ms. Ratigan sent an "Execution Version" of a Master Lease Agreement between Target Corporation and CVS Pharmacy, Inc. with her February 26, 2021 response. I only conducted a cursory review of the Master Lease Agreement.
Document(s) 1. CVS Target Master Agreement.pdf
SECTION III - AREAS OF CONCERN
The presentation of areas of concern does not constitute a formal compliance determination or violation.
Building:
JJ1-RR-002
While reviewing the weekly inspection logs for the Target Store T2339, I saw that there were no weekly inspections conducted for 76 weeks during the three years prior to the February 8, 2021 RCRA CEI.
Area:
Citation:
Sub-area:
Section:
JJ1-RR-004
No exception reports were sent to the EPA Region 10 Administrator for the following hazardous waste manifests:
Citation:
#008411633 FLE
#008411635 FLE
#008411693 FLE
#012598444 FLE
Section:
12 of 18
TARGET STORE T2339 Inspection Date(s):
JJ1-RR-005
No exception reports were sent to the EPA R10 Administrator for the following hazardous waste manifests:
Citation:
#009994732 FLE
#012698337 FLE
#012698338 FLE
#012698427 FLE
#012698428 FLE
JJ1-RR-006
The training information, for the Citation: Target Store T2339 personnel listed below, indicated the following:
Mariah Householder received Environmentally Sensitive Item Management (ESIM) Hazardous Waste Management (HW Mgmt.) training on 5/22/20, yet she conducted a total of eight weekly hazardous waste inspections prior to receiving any training. The inspections she conducted prior to her 5/22/20 training took place on the following dates: 3/2/20, 3/11/20, 3/19/20, 3/27/20, 4/2/20, 4/16/20, 4/24/20, and 5/13/20. Caitlin Self received ESIM HW Mgmt. training on 6/11/18 and again on 8/8/19, yet she conducted a weekly hazardous waste
13 of 18
02/08/2021 - 02/08/2021 Section:
Section:
TARGET STORE T2339
Inspection Date(s):
inspection at Target Store T2339 on 7/6/17, prior to ever receiving any training. Ryan Landis received ESIM HW Mgmt. training on 9/19/18, yet he conducted a weekly hazardous waste inspection at Target Store T2339 on 5/4/17, prior to ever receiving any training.
JJ1-RR-008
The following CVS Pharmacy #17404 hazardous waste manifests contained the acronym "CESQG" in block 1:
#010173578FLE #010752086FLE #010752291FLE #012962304FLE #012962438FLE #010174334FLE #012960926FLE #011433799FLE #011433800FLE
Citation:
JJ1-RR-009 The following two manifests did Citation: not contain the word "PHARMS" in block 13:
#012962304FLE
#011433800FLE
JJ1-RR-010
14 of 18
02/08/2021 - 02/08/2021 Section: Section:
TARGET STORE T2339
Inspection Date(s):
Seventeen CVS Pharmacy #17404 personnel had not received adequate training either prior to or following the hazardous waste pharmaceuticals rule which was promulgated on February 22, 2019.
Citation:
SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection.
02/08/2021 - 02/08/2021 Section:
Closing Conference
I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern that I observed during my walk-through inspection and paperwork review while at the facility. I told Messer's. Munson and Siegrist that I had not identified any areas of concern during the walk-through portion of the inspection. At the time of the inspection, all the records for review were in electronic form and I performed a cursory review of the following records as viewed on Mr. Siegrist's desktop PC:
Weekly hazardous inspection logs Hazardous waste manifests Land disposal restriction notices and Training records
I told Messer's. Munson and Siegrist that I had observed a few areas of concern while conducting the cursory paperwork review on Mr. Siegrist's pc monitor and asked if they would email the documents to me so I could conduct a more thorough review. I explained to both gentlemen that due to COVID-19 it was important, for everyone involved, to have the least amount of contact time as possible during inspections. Both gentlemen agreed and Mr. Siegrist said he would email the documents to me. I told Mr. Munson that if I identified any areas of concern while reviewing the paperwork submitted by Mr. Siegrist, I would call him and let him know. I answered any questions they had and explained the follow-up process that would take place after the inspection. Messer's. Munson and Siegrist asked to be copied, by email, with the results of the inspection.
Following the inspection, I received copies of the manifests I had requested in an email dated 2/9/21 from Mr. Paul Hamilton. Mr. Hamilton became my point-of-contact (POC) for Target Corporation and Ms. Nicole Ratigan, was the POC for CVS Health. Following the inspection, I contacted Mr. Munson to let him know that I had identified an area of concern related to weekly hazardous waste inspections that had not been performed. I also sent emails to both Mr. Hamilton and Ms. Ratigan offering a closing conference to discuss areas of concern identified during the inspection. Neither Mr. Hamilton nor Ms. Ratigan were receptive to the offer, but each requested that any follow-up documentation be sent to them.
On 2/11/21, I sent an email to Ms. Ratigan requesting documents and on 2/12/21, I sent an email to Mr. Hamilton requesting additional documents associated with the 2/8/21 RCRA CEI. The requested documentation was received from Mr. Hamilton on 2/24 and 2/25/21. The requested documentation was received from Ms. Ratigan on 2/26/21.
15 of 18
TARGET STORE T2339 Inspection Date(s):
02/08/2021 - 02/08/2021
Communication Log The following information was received by EPA R10 on or after exiting the Facility on 02/08/2021.
Type Email
Email
Location
Target Store Corporate Office
CVS Pharmacy Corporate Office
Point of Contact Paul Hamilton
Nicole Ratigan
Description Request for documents
Contains PII No
Request for documents No
SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS
No sampling was conducted.
SECTION VI - LIST OF APPENDICES Photo Log - No photographs were taken during the inspection.
Document Log
Document Type
Records Review Records Review Inspection Reports Personnel Training Records Review Records Review Records Review Records Review Records Review Records Review
Document Name
Contains Contains Uploaded By
CBI
PII
T2339 Facility Drawing.pdf
No
No
Jon Jones
ESIM Weekly Log.xlsx No
No
Jon Jones
Field_Notes_AKD98306 No
No
Jon Jones
8990v1.0.pdf
ESIM Training.xlsx
No
No
Jon Jones
#009994732FLE
No
No
Jon Jones
Exception Rpt.pdf
#012698337FLE
No
No
Jon Jones
Exception Rpt.pdf
#012698338FLE
No
No
Jon Jones
Exception Rpt.pdf
#012698428FLE
No
No
Jon Jones
Exception Rpt.pdf
#012698427FLE
No
No
Jon Jones
Exception Rpt.pdf
#009994732FLE 10.28.20.pdf
No
No
Jon Jones
16 of 18
Date Received
02/19/2021 02/19/2021 02/19/2021 02/19/2021 03/15/2021 03/15/2021 03/15/2021 03/15/2021 03/17/2021 03/17/2021
TARGET STORE T2339 Inspection Date(s): Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review
#012698337FLE 8.11.20.pdf
#012698338FLE 8.11.20.pdf
#012698428FLE 5.29.20.pdf
#012698427FLE 5.29.20.pdf
#008411633FLE Exception Rpt.pdf
#008411635FLE Exception Rpt.pdf
#008411693FLE Exception Rpt.pdf
#012598444FLE Exception Rpt.pdf
#008411633FLE 5.30.18.pdf
#008411635FLE 5.30.18.pdf
#008411693FLE 9.25.18.pdf
#012598444FLE 6.29.19.pdf
#010173578FLE 1.11.18.pdf
#010752086FLE 4.23.18.pdf
#010752291FLE 10.8.18.pdf
#012962304FLE 3.29.19.pdf
#012962438FLE 9.9.19.pdf
#010174334FLE 2.25.20.pdf
#012960926FLE 8.10.20.pdf
#011433799FLE 2.2.21.pdf
#011433800FLE 2.2.21.pdf
#012962304FLE 3.29.19.pdf
#011433800FLE
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
17 of 18
Jon Jones
02/08/2021 - 02/08/2021 03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
Jon Jones
03/17/2021
TARGET STORE T2339
Inspection Date(s):
02/08/2021 - 02/08/2021
2.2.21.pdf
Records Review
17404 AK Hazardous No
No
Jon Jones
Waste Training
Records.pdf
03/17/2021
Records Review
500147_JobAid_Packet No
No
Jon Jones
_2020.pdf
03/17/2021
Records Review
2020 500147_Pharmacy No
No
Jon Jones
Hazardous Waste
Training.pdf
03/17/2021
Records Review
T2339 Response to No
No
Jon Jones
Document
Request.docx
03/17/2021
Records Review
CVS Target Master
No
No
Jon Jones
Agreement.pdf
03/17/2021
18 of 18