Document dnk1Zyvzbo9gpEn08v101qj29

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 02/22/2021 - 02/22/2021 Announced: No Entry: 09:30 AM (AKT) Exit: 10:31 AM (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 T2372 150 W 100TH AVE ANCHORAGE, AK 99515 Retail store 114,121 square feet 12 years 61.129371, -149.882419 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: Ian Momany, T2372 Store Director ian.momany@target.com (city, state, zip code) County: Nicole Ratigan, Senior Environmental Specialist, Corporate Environmental 1 CVS Drive, Mail Code 2340 Woonsocket, RI 02895 (401) 770-6259 nicole.ratigan@cvshealth.com Minneapolis, MN 55402 Facility/Site Identifier: Media Number: NAICS: AKR000203471 Unpermitted Facility 452210 - Department Stores Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.04.21 13:30:50 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: 1 of 15 TARGET STORE T2372 Inspection Date(s): 02/22/2021 - 02/22/2021 Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2021.04.21 14:38:28 -07'00' Sullivan.Jennifer.A@epa.gov SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection (206) 553-6978 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 Ian Momany Phone 9072716329 (503) 806-1235 Email jones.jon@epa.gov Present in Opening Conf. Yes ian.momany@target.com Yes Present in Closing Conf. Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the Target Store T2372 at 09:30 AM (AKT) on 02/22/2021 for an inspection. I presented my credentials to Mr. Ian Momany, Store Director, 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 #17436 CVS Pharmacy #17436 operates inside the Target Store T2372. There is no separate entry or exit for the pharmacy. Customers using the pharmacy must enter and exit through the Target Store. Following the inspection, I sent Mr. Paul Hamilton (Target Corporation) a request for documents email, via "GoAnywhere", on 2/22/21. I also sent Ms. Nicole Ratigan (CVS) a request for documents. Mr. Hamilton's response was received on 2/26/21 and Ms. Ratigan's response was received on 3/4/21. The areas of concern identified during the document review were not shared with Mr. Momany during the closing conference since the document review was conducted after the onsite portion of inspection. 2 of 15 TARGET STORE T2372 Inspection Date(s): 02/22/2021 - 02/22/2021 Facility/Site Description Target Store T2372 is a department store located in Anchorage, AK. CVS Pharmacy #17436 operates as a separate entity inside the T2372 store. According to facility representatives, Target got out of the pharmacy business approximately five years ago when they sold their pharmacy business to CVS Health. Since Target does not operate the pharmacy, Target representatives said they did not have any information about how CVS Pharmacy #17436 manages hazardous waste pharmaceuticals. Facility Info Number of employees 160 Weather Conditions Sunny and cold Operating Hours 8 to 10 Monday through Sunday Safety Training No Provided to Inspector(s)? What type of generator facility notified? Small Quantity Generator (SQG) What type of generator facility verified as? SQG verified by Mr. Momany Process Description Based on information I obtained during a previous Target Store T2339 inspection I conducted on February 8, 2021, 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. 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, according to the labeling, included: Non-RCRA Hazardous Waste WA 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 3 of 15 TARGET STORE T2372 Inspection Date(s): 02/22/2021 - 02/22/2021 Building(s) Building/Area Target Store CVS Pharmacy #17436 Property Management Lead Office (PMLO) Shelf outside PMLO Shipping and Receiving Central Accumulation Area (CAA) Process Description Store front On-site pharmacy Store maintenance Used to store lamps. SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Area of Concern Yes Yes Yes Yes No No Building: Target Store/CVS Pharmacy #17436 Contains CBI: No Observation #: JJ1-OB-004 Date/Time: 02/22/2021 I inspected the CVS Pharmacy #17436 while at Target Store T2372. While there I met with the pharmacist, Jennifer Veloudas. I asked Ms. Veloudas if she could show me where the pharmacy was accumulating their hazardous waste pharmaceuticals (HWPharms). She led me to where the waste was being accumulated in a hazardous waste tote. At the time of the inspection, the container of HWPharms was incorrectly labeled as "Pharmacy Hazardous Waste." The container was not labeled "Hazardous Waste Pharmaceuticals." Building: Target Store/Property Management Lead Contains CBI: No Office/Shelf outside PMLO Observation #: JJ1-OB-002 Date/Time: 02/22/2021 At the time of the inspection, I saw a box that contained four-foot fluorescent lamps that had been placed on a shelf, just outside of the Property Management Lead office. The lamps were inside of a box that was labeled with the vendor name, Clean Earth. According to Mr. Momany, and based on information obtained from two prior Target Store inspections, the Clean Earth boxes are used to accumulate waste fluorescent lamps. I asked if the lamps were waste lamps and Mr. Momany said that they were waste lamps. Target stores manage waste fluorescent lamps as universal waste. At the time of the inspection, the box of waste fluorescent lamps was not closed. Building: Target Store/Property Management Lead Contains CBI: No Office/Shelf outside PMLO 4 of 15 TARGET STORE T2372 Inspection Date(s): Observation #: JJ1-OB-003 Date/Time: 02/22/2021 02/22/2021 - 02/22/2021 At the time of the inspection, the same box, containing four-foot waste fluorescent lamps, was not labeled with the words, "Universal Waste - Lamps", "Waste Lamps", or "Used lamps." Target personnel labeled the box with the words "Universal Waste - Lamps" during the inspection. Building: Target Store/Shipping and Receiving/Central Accumulation Area (CAA) Contains CBI: No Observation #: JJ1-OB-001 Date/Time: 02/22/2021 I inspected the facility's central accumulation area (CAA), located in the Shipping and Receiving Area in the back room of the store. At the time of the inspection, I saw that there were multiple plastic totes containing various wastes that included hazardous, universal, non-RCRA state only waste (WA), and hazardous waste pharmaceuticals (HWPharms) which were also labeled as "OTC" (Over-the-counter), meaning they were nonprescription. 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 HWPharms (OTC) have been in accumulation for less than a year. Records Review Record: Inspections Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/07/2021 10:17 AM (AKT) At the time of the inspection, I asked Mr. Momany for a copy of the Target Store T2372 weekly hazardous waste inspections for the period covering February 22, 2018 through February 22, 2021. This information was reviewed after the closing conference. While reviewing the weekly inspection logs for the Target Store I saw that there were no weekly inspections conducted for 44 weeks during the three-year period. Document(s) 1. T2372 weekly HW inspections.pdf Record: Ensure applicable employees are trained - SQG Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/07/2021 10:31 AM (AKT) During the inspection, I asked Mr. Momany for a copy of training records for Target Store T2372 personnel that manage hazardous waste, universal waste and non-creditable hazardous waste pharmaceuticals, regulated by Part 266, Subpart P. Mr. Momany had Target Store personnel provide a copy of the training records on the day of the inspection. Following the inspection, I reviewed the training records and observed that there were several Target Store personnel that had been conducting weekly hazardous waste inspections that were not listed in the training records provided to me. On February 22, 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 training records for the following Target Store personnel that had conducted weekly hazardous waste inspections: 5 of 15 TARGET STORE T2372 Inspection Date(s): Trevor Bonk 02/22/2021 - 02/22/2021 Misty Monroe Cayton Cox Devon Haskell William Brown Erik Mata In my "Request for Documents" email to Mr. Hamilton, I requested that he provide the documentation to me on or before March 8, 2021. This information was received on 2/26/21. After reviewing the training records that Mr. Hamilton sent to me, I saw that the following Target Store T2372 personnel were conducting weekly hazardous waste inspections at the CAA without ever receiving Environmentally Sensitive Item Management (ESIM) Hazardous Waste Management (HW Mgmt.) training: Trevor Bonk Misty Monroe Cayton Cox Devon Haskell William Brown Erik Mata Document(s) 1. T2372 employee training.pdf 2. T2372 TGT_RPT_ESIM_Recap_Report.xlsx Record: Ensure applicable employees are trained - SQG Ref #: JJ1-RR-003 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/07/2021 11:07 AM (AKT) At the time of the inspection, CVS Pharmacy #17436 was operating inside Target Store T2372. Following the inspection, on February 22, 2021 I sent a request for documents email, via "GoAnywhere", to Ms. Nicole Ratigan, CVS. In that document request, I asked for copies of training records for CVS Pharmacy #17436 personnel working at the Target Store T2372. In that email, I asked Ms. Ratigan to provide the requested documents on or before March 8, 2021. Ms. Ratigan sent the requested documents on March 4, 2021. After reviewing the documentation received, I saw that CVS Pharmacy #17436 personnel received "Hazardous Waste Training for Pharmacy Colleagues" Course #500147. I reviewed the "Hazardous Waste Training for Pharmacy Colleagues" Course #500147 that was submitted with Ms. Ratigan's March 4, 2021 response and saw that it contained information that was contrary to the hazardous waste pharmaceuticals rule which was effective as of August 21, 2019. Training course #500147 which was current as of May 2020 contained a picture of a hazardous waste pharmaceutical container with a label that was 6 of 15 TARGET STORE T2372 Inspection Date(s): 02/22/2021 - 02/22/2021 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 March 4, 2021 response and saw that it contained the same labeling information under the heading, "Hazardous Waste Tote Setup". Neither of the training documents contained any training information related to filling out the hazardous waste manifest correctly (i.e. "PHARMS" in Block 13). According to the training documentation, CVS Pharmacy #17436 personnel had not received adequate training either prior to or following the hazardous waste pharmaceuticals rule, which became effective on August 21, 2019. Document(s) 1. 17436 Haz Waste Training Records.pdf 2. 2020 500147_Pharmacy Hazardous Waste Training.pdf 3. 500147_JobAid_Packet_2020.pdf Record: Manifests Ref #: JJ1-RR-004 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/07/2021 11:23 AM (AKT) While reviewing the hazardous waste manifests that Ms. Ratigan sent on March 4, 2021, I saw that the following manifest did not contain the word "PHARMS" in block 13: #013107717FLE Document(s) 1. #013107717 FLE.pdf Record: Manifests Ref #: JJ1-RR-005 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/07/2021 11:32 AM (AKT) At the time of the inspection, CVS Pharmacy #17436 was operating inside Target Store T2372. On February 22, 2021, following the inspection, I sent a request for documents email, via "GoAnywhere", to Ms. Nicole Ratigan, CVS. In that document request, I asked for copies of hazardous waste manifests and land disposal restriction notices (LDRs) for the period February 22, 2018 through February 22, 2021. Ms. Ratigan sent the requested documents on March 4, 2021. I reviewed all the documentation and saw that none of the manifests contained the EPA I.D. # AKR000203471 in block 1, that is assigned to the Target Store T2372 site. The following CVS Pharmacy #17436 hazardous waste manifests contained the acronym "CESQG" in block 1: #010173556 FLE #010752090 FLE #010752296 FLE 7 of 15 TARGET STORE T2372 Inspection Date(s): #012962308 FLE #012962448 FLE #010174348 FLE #012960921 FLE #013107716 FLE #013107717 FLE 02/22/2021 - 02/22/2021 Document(s) 1. #010173556 FLE.pdf 2. #010174348 FLE.pdf 3. #010752090 FLE.pdf 4. #010752296 FLE.pdf 5. #012960921 FLE.pdf 6. #012962308 FLE.pdf 7. #012962448 FLE.pdf 8. #013107716 FLE.pdf 9. #013107717 FLE.pdf Record: Exception Reports Ref #: JJ1-RR-006 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/08/2021 03:02 PM (AKT) I reviewed hazardous waste manifests following the inspection and saw that there were 18 manifests that required an exception report. During the time period in which Target T2372 was operating as a large quantity generator, the following hazardous waste manifests did not arrive at the designated TSDF within 45 days and Target was required to submit an exception report. No exception reports were included with Target's records for shipments made with the following manifests: #008411630 FLE #008411632 FLE #008411807 FLE #009994406 FLE #009994408 FLE #009994409 FLE #009994410 FLE #009994512 FLE #012598127 FLE #012598447 FLE 8 of 15 TARGET STORE T2372 Inspection Date(s): #012698114 FLE #012698124 FLE #012698182 FLE #012698183 FLE #012698184 FLE #012698320 FLE #012698321 FLE #012698322 FLE Document(s) 1. #008411630 FLE.pdf 2. #008411632 FLE.pdf 3. #008411807 FLE.pdf 4. #009994406 FLE.pdf 5. #009994408 FLE.pdf 6. #009994409 FLE.pdf 7. #009994410 FLE.pdf 8. #009994512 FLE.pdf 9. #012598127 FLE.pdf 10. #012598447 FLE.pdf 11. #012698114 FLE.pdf 12. #012698124 FLE.pdf 13. #012698182 FLE.pdf 14. #012698183 FLE.pdf 15. #012698184 FLE.pdf 16. #012698320 FLE.pdf 17. #012698321 FLE.pdf 18. #012698322 FLE.pdf 02/22/2021 - 02/22/2021 Record: Exception Reports Ref #: JJ1-RR-007 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/08/2021 03:07 PM (AKT) I reviewed hazardous waste manifests following the inspection and saw that there were two manifests for shipments made during the time period when Target T2372 was operating as a SQG that required an exception report. The hazardous waste shipments documented in the following hazardous waste manifests did not arrive at the designated TSDF within 60 days requiring an exception report and the records provided by Target did not include an exception report: #012698435 FLE #012698436 FLE Document(s) 1. #012698435 FLE.pdf 9 of 15 TARGET STORE T2372 Inspection Date(s): 2. #012698436 FLE.pdf 02/22/2021 - 02/22/2021 SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: JJ1-RR-001 While reviewing the weekly inspection logs for the Target Store I saw that there were no weekly inspections conducted for 44 weeks during the threeyear period. Area: Citation: Sub-area: Section: JJ1-RR-002 After reviewing the training records that Mr. Hamilton sent to me, I saw that the following Target Store T2372 personnel were conducting weekly hazardous waste inspections at the CAA without ever receiving Environmentally Sensitive Item Management (ESIM) Hazardous Waste Management (HW Mgmt.) training: Citation: Section: Trevor Bonk Misty Monroe Cayton Cox Devon Haskell William Brown Erik Mata JJ1-RR-003 According to the training documentation, CVS Pharmacy Citation: 10 of 15 Section: TARGET STORE T2372 Inspection Date(s): #17436 personnel had not received adequate training either prior to, or following the hazardous waste pharmaceuticals rule, which became effective on August 21, 2019. JJ1-RR-004 While reviewing the hazardous waste manifests that Ms. Ratigan sent on March 4, 2021, I saw that the following manifest did not contain the word "PHARMS" in block 13: Citation: #013107717FLE JJ1-RR-005 I reviewed all the documentation and saw that none of the manifests contained the EPA I.D. # AKR000203471 in block 1, that was being used by Target Store T2372. The following CVS Pharmacy #17436 hazardous waste manifests contained the acronym "CESQG" in block 1: Citation: #010173556 FLE #010752090 FLE #010752296 FLE #012962308 FLE #012962448 FLE #010174348 FLE #012960921 FLE #013107716 FLE #013107717 FLE JJ1-RR-006 The hazardous waste shipments Citation: made when Target T2372 was an LQG and documented in the 11 of 15 02/22/2021 - 02/22/2021 Section: Section: Section: TARGET STORE T2372 Inspection Date(s): following hazardous waste manifests did not arrive at the designated TSDF within 45 days requiring an exception report and no report was included with the records provided by Target: #008411630 FLE #008411632 FLE #008411807 FLE #009994406 FLE #009994408 FLE #009994409 FLE #009994410 FLE #009994512 FLE #012598127 FLE #012598447 FLE #012698114 FLE #012698124 FLE #012698182 FLE #012698183 FLE #012698184 FLE #012698320 FLE #012698321 FLE #012698322 FLE JJ1-RR-007 The hazardous waste shipments made when Target T2372 was an SQG and documented in the following hazardous waste manifests did not arrive at the designated TSDF within 60 days requiring an exception report and no report was included with the records provided by Target: Citation: #012698435 FLE #012698436 FLE 12 of 15 02/22/2021 - 02/22/2021 Section: TARGET STORE T2372 Inspection Date(s): Building: Target Store JJ1-OB-004 Area: CVS Pharmacy #17436 At the time of the inspection, the container of HWPharms was incorrectly labeled as "Pharmacy Hazardous Waste." The container was not labeled "Hazardous Waste Pharmaceuticals." Citation: Building: Target Store JJ1-OB-002 At the time of the inspection, the box of waste fluorescent lamps was not closed. Area: Property Management Lead Office Citation: JJ1-OB-003 A box, containing four-foot waste fluorescent lamps, was not labeled with the words, "Universal Waste - Lamps", "Waste Lamps", or "Used lamps." Citation: 02/22/2021 - 02/22/2021 Sub-area: Section: Sub-area: Shelf outside PMLO Section: Section: SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection. Closing Conference During the closing conference with Mr. Momany, I explained that I had a point-of-contact (Paul Hamilton) for Target Corporation that I was working with, due to a previous inspection at another Target Store (T2339) and I asked him if he wanted to be copied with any correspondence from EPA. Mr. Momany said he would like to be copied. Following the inspection, I sent Mr. Paul Hamilton (Target Corporation) a request for documents email, via "GoAnywhere", on 2/22/21. I also sent Ms. Nicole Ratigan (CVS) a request for documents too. Mr. Hamilton's response was received on 2/26/21 and Ms. Ratigan's response was received on 3/4/21. 13 of 15 TARGET STORE T2372 Inspection Date(s): Communication Log 02/22/2021 - 02/22/2021 Additional information received by REGION 10 after exiting the Facility on 02/22/2021 includes hazardous waste management documentation that was requested following the inspection. This documentation is included in the inspection document log. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Document Log Document Type Document Name Contains Contains Uploaded By CBI PII Other - T2372 Photo T2372 Photo log.pdf Log No No Jon Jones Records Review 17436 Haz Waste Training Records.pdf No No Jon Jones Records Review T2372 weekly HW inspections.pdf No No Jon Jones Records Review T2372 employee training.pdf No No Jon Jones Records Review T2372 No No Jon Jones TGT_RPT_ESIM_Recap_Report.xlsx Records Review 2020 500147_Pharmacy Hazardous No No Jon Jones Waste Training.pdf Records Review 500147_JobAid_Packet_2020.pdf No No Jon Jones Records Review #010173556 FLE.pdf No No Jon Jones Records Review #010174348 FLE.pdf No No Jon Jones Records Review #010752090 FLE.pdf No No Jon Jones Records Review #010752296 FLE.pdf No No Jon Jones Records Review #012960921 FLE.pdf No No Jon Jones Records Review #012962308 FLE.pdf No No Jon Jones Records Review #012962448 FLE.pdf No No Jon Jones Records Review #013107716 FLE.pdf No No Jon Jones Records Review #013107717 FLE.pdf No No Jon Jones Records Review #013107717 FLE.pdf No No Jon Jones Records Review #008411630 FLE.pdf No No Jon Jones 14 of 15 Date Received 04/06/2021 04/07/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 04/08/2021 TARGET STORE T2372 Inspection Date(s): 02/22/2021 - 02/22/2021 Records Review #008411632 FLE.pdf No No Jon Jones 04/08/2021 Records Review #008411807 FLE.pdf No No Jon Jones 04/08/2021 Records Review #009994406 FLE.pdf No No Jon Jones 04/08/2021 Records Review #009994408 FLE.pdf No No Jon Jones 04/08/2021 Records Review #009994409 FLE.pdf No No Jon Jones 04/08/2021 Records Review #009994410 FLE.pdf No No Jon Jones 04/08/2021 Records Review #009994512 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012598127 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012598447 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698114 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698124 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698182 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698183 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698184 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698320 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698321 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698322 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698435 FLE.pdf No No Jon Jones 04/08/2021 Records Review #012698436 FLE.pdf No No Jon Jones 04/08/2021 Inspection Reports Field_Notes_AKR000203471v1.0.pdf No No Jon Jones 04/09/2021 15 of 15 PHOTO LOG Target Store T2372 AKR000203471 2021 RCRA Inspection Report TARGET STORE T2372 EPA ID # AKR 00020 3471 PHOTO LOG Unless otherwise noted, all photographs were taken by Jon Jones on the date of the inspection, using a Sony Cyber-shot DSC-H400 digital camera and appear in the Photo Log that accompanies this report. None of the photographs have been manipulated in any way. 1. DSC09978 - Box of four-foot waste fluorescent lamps, seen in center of photo, is not closed. 2. DSC09979 - Another view of box of four-foot waste fluorescent lamps, seen in center of photo, is not closed. 3. DSC09980 - Box of four-foot waste fluorescent lamps is not labeled as either "Universal Waste - Lamps", "Waste Lamps", or "Used Lamps." 4. DSC09981 - Another view, showing box of four-foot waste fluorescent lamps is not labeled as either "Universal Waste - Lamps", "Waste Lamps", or "Used Lamps." 5. DSC09982 - Box of four-foot waste fluorescent lamps was labeled during the inspection. 6. DSC09983 - Hazardous waste tote in CVS pharmacy is labeled incorrectly, as "Pharmacy Hazardous Waste." 7. DSC09984 - Another view of the same mislabeled tote.