DSHW-2018-003748 - 0901a06880801d5f

Vensk 3E Vensk 3E Corporate Headquarters P +1 760 602.8700
3207 Grey Hawk Court W Vensk3E.com
Carlsbad, CA 92010 USA Ltik C\ 3
April 19, 2018
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
To Whom It May Concem: 1)SW/4-2W-0037,443
Re: CVS Pharmacy # 10234: 4240 Harrison Blvd., Ogden, UT 84403
This letter serves as notification regarding a CVS Pharmacy in your jurisdiction located at the address above that
uses/stores hazardous materials, and generated hazardous waste. Furthermore, CVS Pharmacy would like to take
this opportunity to request support from your agency in the unlikely event of a fire, explosion, or uncontrolled
release of a hazardous waste pursuant to 40 CFR 262.256, 40 CFR 262.262, and Utah Administrative Code R315-
265-1 .
CVS Pharmacy uses & stores hazardous materials and generates hazardous waste. The hazardous materials at this
facility are stored throughout the retail sales floor area, in the receiving/stockroom area, and in the pharmacy. The
nature of the hazardous materials on site includes: flammable and combustible liquids; compressed, flammable
gases; aerosol products; corrosive liquids; unstable and water-reactive liquids; solid oxidizers; irritants; and
chemicals classified as causing "Other Health Hazards." Hazardous waste is generated primarily resulting from
severely damaged, pre-packaged consumer products, or unsaleable pharmaceuticals, or from small, incidental spills
or releases of chemicals. Facility personnel at CVS Pharmacy work throughout the entire facility.
Due to the possibility that this store has or will be registered as a Large Quantity Generator of RCRA hazardous
waste primarily resulting from low volumes of acutely hazardous pharmaceutical or nicotine-containing wastes, the
CVS Pharmacy Retail Store Hazardous Waste Contingency Plan is enclosed for your review, pursuant to 40 CFR
262.262. For more specific information on what materials this facility uses and stores, or emergency preparedness
measures in effect, please contact Verisk 3E Regulatory Compliance Support Services at [phone] ext. 8400.
Additionally, Verisk 3E provides CVS Pharmacy stores with the following support services:
• SDS on Demand®
• 24-Hour Spill Response Guidance (Stores can dial 888-464-2960 - 24-7-365)
• Poison Control Assistance
• DOT Hazardous Materials Shipping Guidance
• Regulatory Compliance Reporting Services
Please take a moment to review this information. If you have any questions, or concems, please do not hesitate to
contact Verisk 3E Regulatory Compliance Support Services at [phone] ext. 8400.
Thank you, in advance, for your cooperation and support.
Verisk 3E, Regulatog Compliance Support Services
1
S TBITAY
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3
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# 0234
HWS I
11
UTAH ANNOTATED SITE MAP
A
BUSINESS NAME:
CVS PHARMACY #10234
SITE ADDRESS: 4240 HARRISON BLVD
OGDEN, UT 84403 MAP #1 OF 1
SCALE. NOT TO SCALE
DATE 05/12/2018
LEGEND
1=4 EVACUATION ROUTE
SAFE REFUGE AREA
Eat STORM DRAIN
Fò FIRE HYDRANT
1=1 HAZARDOUS WASTE STORAGE
CVS PHARMACY #10234
ENTRANCE LOCATED
ON CORNER OF
HARRISON BLVD AND
COUNTRY HILLS DR
6
MNE
7 PREPARED BY:
1 I Verisk SE
iPCVSHealth
RETAIL STORE
HAZARDOUS WASTE
CONTINGENCY PLAN
Revision Date: iVlay 2016
Table of Conten s
1.0 OVERVIEW 4
2.0 GENERAL STORE INFORMATION 6
3.0 HAZARDOUS WASTE GENERATION 7
4.0 EMERGENCY COORDINATOR DUTIES 9
5.0 EMERGENCY RESPONSE PROCEDURES 11
6.0 EMERGENCY EQUIPMENT 13
7.0 EVACUATION PLAN 15
8.0 REPORTING 16
9.0 PLAN AMENDMENTS 18
10.0 REVISION LOG 19
MAY 2016
REVISION DATE
Page 2 of 20
APPENDICES
Appendix A — Contingency Plan Implementation Record
MAY 2016
REVISION DATE
Page 3 of 20
1.0 OVERVIEW
A CVS/pharmacy Retail Pharmacy Store (Store) typically generates a relatively small amount of
hazardous waste during normal store operations. This Contingency Plan has been developed
for Stores in keeping with applicable federal and state hazardous waste regulations. This
Contingency Plan provides emergency response procedures to minimize health and
environmental hazards resulting from fire, explosion, or other releases to air, soil, or surface
water related to the storage of hazardous waste consumer products which may occur at a CVS
Store. This Contingency Plan establishes a system of procedures to be used at the Store in
response to an incident involving hazardous waste consumer products.
This Contingency Plan is not a stand-alone document. It is designed to operate in concert with
other emergency preparedness plans and procedures in effect at the Store, specifically
including the Store's Emergency Procedures Plan and Emergency Procedures Plan Summary.
The purpose of the Emergency Procedures Plan is to educate store managers and colleagues
and allow for coordinated actions during a workplace emergency. The Manager-on-Duty is
responsible for the implementation and enforcement of the Emergency Procedures Plan. All
store-specific information must be completed on the Emergency Procedures Plan Summary
for each store and the Summary must be posted in the break room, at out-dialing phones
including near the hazardous waste storage areas and in MinuteClinic locations. Store
colleagues are trained to the Emergency Procedures Plan and Contingency Plan.
CVS has developed this Contingency Plan for stores that have attained Large Quantity
Generator (LQG) status, Small Quantity Generator (SQG) status as required by some states, as
well as other stores at which CVS has elected to implement the Plan. It is intended to provide
additional emergency preparedness and response information that is correlative to the risk
posed by hazardous waste located on-site.
MAY 2016
REVISION DATE
Page 4 of 20
IMPORTANT NOTE: Classification as a large quantity generator (LQG) at the store level is
almost exclusively due to the generation or accumulation of small amounts of consumer
products or pharmaceuticals that are regulated as "acutely hazardous waste" when discarded.
Additional information on potential acutely hazardous wastes is provided in a later section.
MAY 2016
REVISION DATE
Page 5 of 20
2.0 G JERAL STORE INFORICA .10N
In keeping with a typical Store profile, this Store generates relatively small amounts of
hazardous waste through normal Store operations. Typical Stores have a secure pharmacy
area in which all pharmaceuticals must be stored, the front store floor area where all customer
activity occurs, and a backroom area in which the hazardous waste storage area is located as
well as additional storage for consumer products and other program support resources. A
manager's office and employee break area complete the store footprint.
Select Stores have a wet photo lab, usually near the customer entrance to the front store floor
area.
Store colleagues are normally present within most areas of the Store during normal working
hours. Store colleague work schedules vary between full and part time colleagues. Some
colleagues may have occasion to handle waste products during their work days. It is very
unlikely an occasion will arise where there will be only one colleague at the premises.
Telephones capable of summoning external emergency assistance are available for
colleague use.
N1AY 2016
REVISION DATE
Page 6 of 20
3.0 Hmic_k-ki DOUS WASTE GdNUZATION
Stores have a U. S. Environmental Protection Agency (EPA) hazardous waste generator
identification number (EPA ID Number). Re-notifications are prepared on behalf of the Store
(USEPA Form 8700-12) as needed to identify new hazardous waste streams generated, or to
identify changes in generator status or other noteworthy changes to Store information. Store
colleagues receive initial and annual refresher hazardous waste management awareness
training, in keeping with the CVS/pharmacy Hazardous Waste Management Program.
The Hazardous Waste Storage Area is located in the back room. Spill response equipment is
located nearby and is replenished as it is used. Additional hazardous waste storage containers
may be located in the pharmacy (hazardous pharmacy waste only) and/or in the wet photo lab,
where present (hazardous photo waste only).
Hazardous waste generated at the store generally consists of broken, spilled or damaged
retail products, over-the-counter medications, waste pharmaceuticals and, in some locations,
silver-bearing photo processing liquid waste, filters, or outdated photo processing chemicals.
Waste items, including waste retail products, may be regulated as hazardous waste either
because they are specifically listed as hazardous in Federal or state regulations (e.g., certain
pharmaceutical waste) or because they exhibit one or more of the following hazardous waste
characteristics: corrosivity (acidic or basic), toxicity, flammability, or reactivity. The Store may
also generate electronic waste and universal waste lamps and batteries that must be managed
in accordance with specified regulatory requirements in order to avoid being regulated as
hazardous waste.
MAY 2016
REVISION DATE
Page 7 of 20
Specifically, the primary waste products known to have the potential to result in the generation or
accumulation of greater than 2.2 lbs of acute hazardous waste are (1) nicotine from waste
nicotine replacement therapy products and (2) warfarin-family pharmaceutical waste generated in
the pharmacy. Except in very rare cases, CVS Stores do not otherwise reach LQG status,
because they do not generate large amounts (greater than 2200 lbs.) of other hazardous waste.
MAY 2016 REVISION DATE
Page 8 of 20
4.0 EMERGENCY COORDINATO 9UTIES
This Contingency Plan will be implemented whenever there is a fire, explosion, or release of
hazardous waste or hazardous waste constituents to air, soil, or surface water that could
threaten human health or the environment. Due to the nature of the retail setting, the
Emergency Coordinator role has been divided between a local contact and 3E Company, a third
party service provider which ensures expertise is available 24/7. The local contact and 3E
Company must work together on any emergency requiring the implementation of this plan. All
store management colleagues are authorized to act as the local contact, and a member of store
management is always present during store operation.
3E Company (3207 Greyhawk Court, Carlsbad, CA) has been retained by CVS's Environmental
Department and authorized to act as the designated Emergency Coordinator at all CVS Store
locations. 3E Company has the expertise and authority to decide when the procedures outlined
in this Contingency Plan should be executed. If an emergency situation develops at the Store,
such as a fire, the first Store colleague(s) on the scene will immediately call 911 and then notify
the Store Manager and 3E Company. Contact information for 3E Company and the Store
Manager is provided on the Emergency Procedures Plan Summary Posters located next to out-
dialing telephones at the Store. Please note that due to confidentiality concerns, additional
personal information such as home addresses and phone numbers for the Store Managers or
other store management colleagues is not included in this document. CVS has taken every
effort to design this Contingency Plan such that personal information is not necessary for
successful implementation.
3E Company has been delegated the authority to commit company resources necessary to
implement this Contingency Plan. Where needed, 3E Company will assist CVS with making
NIAY 2016
REVISION DATE
Page 9 of 20
arrangements with CVS's approved emergency response contractor, and shall have authority to
perform the following:
• Engage CVS's approved emergency response contractor for response to a Store
emergency,
• Deputize/enlist other properly trained Store colleagues to assist him/her in the event of
an emergency, and
• Enlist Store colleagues or other emergency response personnel to direct or divert traffic
in the event of an emergency.
The rvlanager-on-Duty, is required to assist 3E Company with emergency response at the Store
level, where possible, and is responsible for contacting CVS's Corporate Environmental
Representative in the unlikely event that 3E Company is inaccessible to Store colleagues.
MAY 2016
REVISION DATE
Page 10 of 20
5.0 EMERGENCY RESPONSE PROCEDURES
The decision to implement this Contingency Plan is the responsibility of the Emergency
Coordinator, and depends upon whether an imminent or actual incident involving a fire,
explosion, or release of hazardous waste or constituents could threaten human health or the
environment. The Emergency Coordinator should use judgment based upon his/her experience
with the processes involved in making this decision and confer with CVS's Corporate
Environmental Representative, as appropriate. Not all incidents require the implementation of
this Contingency Plan. In fact, minor incidents will not generally require implementation of the
Contingency Plan.
The following universal notification and coordination actions will be followed when a fire,
explosion, or hazardous waste spill that requires the implementation of this Contingency Plan
Occurs.
1. The first Store colleague(s) on the scene of an emergency situation will immediately
notify the Manager-on-Duty or call 911, if there is concern of an immediate threat to
human health or the environment.
2. The Manager-on-Duty will determine whether he or she has the training and capability to
address the situation (e.g., a spill of a known chemical that can be contained).
3. If the emergency involves a large spill that cannot be readily contained, may result in
exposure to Store colleagues or the general public, or may result in a release to the
environment (e.g., outside the building or down the drain), the Manager-on-Duty must
contact 3E Company via the 24-Hour CVS Health Safety Hotline at 888-464-2960. 3E
Company will then be responsible for contacting a CVS Health approved Emergency
Response Contractor, and all appropriate state or local authorities with designated
response roles as warranted by the nature and scope of the emergency. 3E Company
will also be responsible for notifying the National Response Center if needed.
MAY 2016 REVISION DATE Page 11 of 20
4. Contact information for the state environmental agency, local fire and police
departments, as well as other local emergency services, will be on file with 3E Company
and the Emergency Response Contractor and immediately accessible in an emergency.
5. To the extent possible, the Emergency Response Contractor will identify the character,
source, approximate amount, and aerial extent of the release (if applicable). The
Emergency Response Contractor will make additional notifications as required by
applicable regulations.
6. These include notifications to the National Response Center (phone number on file with
the Emergency Response Contractor and immediately accessible in an emergency), the
State Emergency Response Commission (phone number on file with the Emergency
Response Contractor and immediately accessible in an emergency), and the Local
Emergency Planning Committee (phone number on file with the Emergency Response
Contractor and immediately accessible in an emergency).
7. The Emergency Response Contractor will take all reasonable measures necessary to
minimize the potential for the impacts to human health and the environment.
8. Until emergency responders arrive, to the Manager-on-Duty should monitor building
conditions and be prepared to provide information to emergency response personnel.
Where required, local fire, police, hospitals, and the state emergency agency have been
provided a copy of this Contingency Plan along with aid notification letters. Copies of the
correspondence with these agencies and emergency response providers are available through
the CVS Corporate Environmental Representative.
MAY 2016
REVISION DATE
Page 12 of 20
6.0 EMERGENCY EQU1VIEJT
Emergency response equipment is maintained and inspected, as appropriate, and spill kit
supplies are replenished as they are used. Due to the space-constrained retail setting, no
equipment with extra capabilities above and beyond standard are required.
In addition to the information located on the store's Emergency Procedures Plan Summary
posted by telephones related to emergency response equipment, a list of emergency response
equipment available on-site is below. This information also includes equipment capabilities and
general equipment locations:
Emergency
Equipment
Physical Description Capabilities Location(s)
Fire alarm (where
applicable)
Varies by type Provides an audible
alarm capable of
being heard
throughout the
building
Varies by location
Fire extinguishers A, B, and C fire
extinguishers, 10 lbs
Extinguishing A, B,
and C fires
NOTE: Colleagues
Throughout store
should not attempt to
fight fires or use fire
extinguishers to put
out fires unless they
have been trained to
do so and the training
has been documented
and is available for
review at the Store.
Automatic sprinkler
system (where
applicable)
Ceiling mounted
sprinkler system
Spraying water from
the ceiling
Throughout store
MAY 2016
REVISION DATE
Page 13 of 20
Emergency
Equipment
Physical Description Capabilities Location(s)
Spill Cleanup
Materials
Collection of spill
response equipment
For use in cleaning up
spills
Hazardous waste
storage areas
(backroom)
Hazardous Waste
storage areas
(backroom)
- Nitrile gloves Disposable gloves
made of nitrile
Provides protection to
hands during spill
clean-up
- Vinyl apron Standard adult size
apron made of vinyl
Provides protection to
front of body during
spill clean-up
- Safety goggles Standard adult size
acrylic goggles
Provides protection to
eyes during spill
clean-up
- Absorbent
materials
Spill Magic (3 lb
container) or clay cat
litter
Used to absorb free
liquids
- Broom Standard broom with
handle
Used to sweep up
debris or other spilled
material
- Dustpan Non-sparking, plastic
dustpan (i.e., plastic)
Used to collect and
transport debris or
other spilled material
to disposal receptacle
- Paper towels Two rolls of standard
paper towels
Used to absorb free
liquids and/or wipe
surfaces
Eyewash station (in
stores operating a wet
photo lab)
Eyewash apparatus is
connected to sink.
When activated, the
eyewash station is
designed to cleanse
both eyes
simultaneously.
Used to provide
mechanism for
continuous flushing of
eye(s)
Wet photo lab (if
present)
Telephones Standard telephone
connected to a land
line
For use in two-way
communication
Various locations in
store — front store,
pharmacy, back room,
and photo lab (if
present)
MAY 2016
REVISION DATE
Page 14 of 20
7.0 EVACUATION PLAN
In the event of a major emergency, it may be necessary to evacuate the premises. Store
colleagues will follow the CVS Emergency Procedures Plan, available on-site.
Details on the outdoor designated rally point are outlined on the Emergency Procedures
Plan Summary poster.
Colleagues are instructed to remain calm, walk to the nearest exit and leave the building
immediately. Exit doors are indicated by signs in the Store and exit routes are clearly marked.
There are no Store processes that require continued operation during an emergency.
Colleagues should not attempt to fight fires or use fire extinguishers to put out fires unless they
have been trained to do so and the training has been documented and is available for review
at the Store.
All colleagues, customers, patients and vendors are expected to leave the Store immediately
when an evacuation alarm is sounded or an evacuation order is announced. Each colleague
needs to be aware of at least two exits in the Store in the event one is compromised. After
leaving the Store, colleagues should proceed to the designated outdoor rally point.
MAY 2016
REVISION DATE
Page 15 of 20
8.0 REPORTING
After identifying the character, source, approximate amount, and areal extent of the release (if
applicable), 3E Company, the Emergency Response Contractor or the CVS Corporate
Environmental Representative will make additional notifications as required by applicable
regulations. These include notifications to the National Response Center (800-424-8802), the
State Emergency Response Commission (phone number on file with 3E Company and
immediately accessible in an emergency), and the Local Emergency Planning Committee
(phone number on file with 3E Company and immediately accessible in an emergency).
Following an emergency, 3E Company, with the assistance of CVS's Corporate Environmental
Representative and Emergency Response Contractor(s), will perform the following duties:
• Provide for the collection, treatment, and disposal, if necessary, of hazardous waste or
hazardous waste constituents released during the incident, and ensure that no waste
that may be incompatible with the released material is treated, stored, or disposed of
until cleanup procedures are completed,
• Ensure that all emergency equipment for the area is restored to full operational status or
is replaced if necessary prior to resuming normal operations,
• Place an entry in the Contingency Plan Implementation Log (Appendix A) indicating the
date, time, and details of the incident,
• Investigate the cause of the incident and take appropriate action to prevent a recurrence,
• As required by applicable regulations, before resuming operations, notify the
appropriate state and local authorities or agencies, and
• As required by applicable regulations, prepare a written report for submission to the
state environmental agency and/or Regional Administrator, as applicable. This report
should be submitted within 15-days after the incident. The report should include the
following:
o Name, address, and telephone number of the owner or operator;
MAY 2016 REVISION DATE
Page 16 of 20
o Name, address, and telephone number of the Store;
o Date, time, type (e.g., fire, explosion, spill), and brief description of the incident;
o Name and quantity of material(s) involved;
o The extent of injuries, if any;
An assessment of actual or potential hazards to human health or the environment,
where this is applicable; and
Estimated quantity and disposition of recovered material that resulted from the
incident.
MAY 2016
REVISION DATE
Page 17 of 20
9.0 PLAN AMENDMENTS
A copy of this Contingency Plan will be accessible for review by all affected colleagues. This
Contingency Plan may be revised as necessary.
The Contingency Plan must be reviewed, and amended, if necessary, on an annual basis
and whenever:
• Applicable regulations are revised;
• The plan fails in an emergency;
• The Store changes-in its design, construction, operation, maintenance, or other
circumstances-in a way that materially increases the potential for fires, explosions, or
releases of hazardous waste or hazardous waste constituents, or changes the response
necessary in an emergency;
• The list of emergency coordinators changes; or
• The list of emergency equipment changes.
MAY 2016
REVISION DATE
Page 18 of 20
10.0 REVISION LOG
• June 2013: Contingency Plan Implemented
• August 2014: Substantive Revisions to Contingency Plan include the following:
o Section 4.0 Emergency Coordinator Duties: Added note that due to
confidentiality concerns, personal information such as home addresses and
phone numbers for store management is not included in the Contingency
plan.
o Section 6.0 Emergency Equipment: Deleted prior list of emergency
equipment; added table detailing emergency equipment, physical description
of equipment, equipment capabilities, and equipment location.
• March 2015: Substantive Revisions to Contingency Plan include the following:
o Section 8.0: Added note that when required by applicable regulations, before
resuming operation, the appropriate state and local authorities or agencies must
be notified.
• May 2016: NH SOP added as attachment
MAY 2016
REVISION DATE
Page 19 of 29
APPENDIX A
Contingency Plan Implementation Log
Date Time Details Name
implemented
MAY 2016
REVISION DATE
Page 20 of 20
air.smor aroma., &Oa isk 3E Vensk 3E Corporate Headquarters
3207 Grey Hawk Court
Carlsbad, CA 92010 USA
P. [phone]
W Vensk3E com
April 19, 2018
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
To Whom It May Concern:
Re: CVS Pharmacy # 10424: 5557 West 4100 South, West Valley City, UT 84128
This letter serves as notification regarding a CVS Pharmacy in your jurisdiction located at the address above that
uses/stores hazardous materials, and generated hazardous waste. Furthermore, CVS Pharmacy would like to take
this opportunity to request support from your agency in the unlikely event of a fire, explosion, or uncontrolled
release of a hazardous waste pursuant to 40 CFR 262.256, 40 CFR 262.262, and Utah Administrative Code R315-
265 -1.
CVS Pharmacy uses & stores hazardous materials and generates hazardous waste. The hazardous materials at this
facility are stored throughout the retail sales floor area, in the receiving/stockroom area, and in the pharmacy. The
nature of the hazardous materials on site includes: flammable and combustible liquids; compressed, flammable
gases; aerosol products; corrosive liquids; unstable and water-reactive liquids; solid oxidizers; irritants; and
chemicals classified as causing "Other Health Hazards." Hazardous waste is generated primarily resulting from
severely damaged, pre-packaged consumer products, or unsaleable pharmaceuticals, or from small, incidental spills
or releases of chemicals. Facility personnel at CVS Pharmacy work throughout the entire facility.
Due to the possibility that this store has or will be registered as a Large Quantity Generator of RCRA hazardous
waste primarily resulting from low volumes of acutely hazardous pharmaceutical or nicotine-containing wastes, the
CVS Pharmacy Retail Store Hazardous Waste Contingency Plan is enclosed for your review, pursuant to 40 CFR
262.262. For more specific information on what materials this facility uses and stores, or emergency preparedness
measures in effect, please contact Verisk 3E Regulatory Compliance Support Services at [phone] ext. 8400.
Additionally, Verisk 3E provides CVS Pharmacy stores with the following support services:
• SDS on Demand®
• 24-Hour Spill Response Guidance (Stores can dial 888-464-2960 - 24-7-365)
• Poison Control Assistance
• DOT Hazardous Materials Shipping Guidance
• Regulatory Compliance Reporting Services
Please take a moment to review this information. If you have any questions, or concerns, please do not hesitate to
contact Verisk 3E Regulatory Compliance Support Services at [phone] ext. 8400.
Thank you, in advance, for your cooperation and support.
Verisk 3E, Regulatory Compliance Support Services
3
HWS
4
4.100 S
I I
1_
6'44
4 EVACUATION RoUTE
CVS
PHARMACY
#10424
ENTRANCE
LOCATED ON
CORNER OF
5600 W AND
4100 S
UTAH ANNOTATED SITE MAP
A
BUSINESS NAME:
CVS PHARMACY #10424
SITE ADDRESS: 5557 WEST 4100 SOUTH
WEST VALLEY crm UT 84128 MAP #1 OF 1
SCALE' NOT TO SCALE RESIDENTIA DATE 05/12/2018
LEGEND
1 SAFE REFUGE AREA
STORM DRAIN UNKNOWN 1-41, FIRE HYDRANT
HAZARDOUS WASTE STORAGE 2 HWS
5
7 PREPARED BY:
1 1
Vensk 3E