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123 South Front Street, Memphis TN 38103-3607 <br /> February 25, 2011 RECEIVED <br /> Ms.Michelle Henry FEB 2 8 2011 <br /> San Joaquin County Environmental Health Dept. ENVIRONMENTAL HEALTH <br /> 600 E.Main Street PERMIT/SERVICES <br /> Stockton,CA 95202-3029 <br /> RE: Hazardous Waste Program Inspection Reports <br /> AutoZone Stores located in San Joaquin County, CA <br /> Dear Ms. Henry: <br /> The San Joaquin County Environmental Health Department conducted inspections at the following <br /> AutoZone stores: <br /> #5684 Stockton,CA(inspected 1/26/11) #2858 Stockton,CA(inspected 1/26/11) <br /> #3315 Tracy,CA(inspected 2/8/11) #5686 Stockton,CA(inspected 2/10/11) <br /> #5682 Lodi,CA(inspected 2/10/11) <br /> This letter shall serve to provide AutoZone's responses to the Hazardous Waste Inspection reports for <br /> the above-referenced AutoZone stores and as required pursuant to the Return to Compliance <br /> Certification. A Return to Compliance Certification Form for each store is attached. <br /> Item 7. Failed to determine if a waste is a hazardous waste. <br /> The Hazardous Waste Inspection Reports for stores#2858 and#3315 noted that a store employee was <br /> apparently not aware of the proper disposal practices for used soda ash. AutoZone has very specific <br /> policies, procedures and annual training that address the proper handling and disposal of spent soda <br /> ash. Additionally, a CA Environmental Audit is conducted at every store each period (13 times <br /> annually). Audit question #22 asks: "Is used soda ash placed in the absorbent collection drum?" We <br /> have since spoken to both Store Managers to ensure he and his employees understand and abide by <br /> AutoZone's policy applicable to the handling and disposal of used soda ash. <br /> Each store maintains a sufficient supply of new soda ash for neutralizing and absorbing occasional <br /> battery acid leaks and spills. Each store is equipped with a 55-gallon drum specifically for storage of <br /> spent absorbent materials. AutoZone's CA Environmental Safety Policy details the proper procedure <br /> for cleaning up battery acid spills and properly disposing the neutralized acid/soda ash residue in the <br /> used absorbent collection drum. Used absorbent waste is accumulated and transported under a <br /> manifest as hazardous waste by Safety-Kleen no less than every 180 days. <br /> Item 18. Stored Hazardous Materials on site longer than 90 days without a permit or authorization. <br /> AutoZone stores are categorized as Small Quantity Generators (SQGs) of hazardous waste. The <br /> applicable maximum accumulation time for SQGs is 180 days rather than 90 days. <br /> AutoZone stores accept used motor oil from the public and therefore meet the definition of "a Used <br /> Oil Collection Center"pursuant to Health & Safety Code § 25250.11(a)and/or Public Resources Code <br />