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San Joaquin County Envi Intal Health Dept. February 25,2011 Page 2 §48622 (See also California Code of Regulations(CCR)Title 22, Section 66279.1(e). Please note that standard operating procedures limit AutoZone stores from accepting any more than 5 gallons of used motor oil per Do-It-Yourself customer per visit which effectively eliminates bulk quantities of used oil from industrial/commercial generators. As a Used Oil Collection Center, AutoZone agrees that our store is required to comply with the generator standards for the management of used oil commencing with 22 CCR §66279.1. However, consistent with the attached DTSC 1995 letter ruling to Northern Automotive Corporation (Kragen Auto Parts) regarding its used oil collection operations, AutoZone understands that a company which operates a used oil collection center is not considered the "generator" of used oil collected from third parties. To confirm this point, AutoZone consulted with DTSC's Regulatory Assistance Officers to ascertain whether the Kragen letter ruling is still followed and to determine whether the volume of used lubricating oil collected from third parties is to be "counted"by the company operating the used oil collection center in determining accumulation time limits under Health & Safety Code § 25123.3 and 22 CCR § 66262.34. In a recent conversation with a DTSC Regulatory Assistance Officer, AutoZone was informed that DTSC does not currently consider a used oil collection center to be the generator of used oil collected from third parties. The Regulatory Assistance Officer stated that, pursuant to 22 CCR § 66260.10, a collection center is not a generator because it is not a "person . . . whose act or process produces hazardous waste . . . . or whose first act causes hazardous waste to become subject to regulation." (Ibid.) The Regulatory Assistance Officer further stated that because the used oil collection center is not the generator of used oil collected from third parties, the company should not consider the volume of collected used oil in determining whether the company is considered a"Small Quantity Generator" or a "Large Quantity Generator" under 22 CCR § 66262.34. Rather, DTSC stated that the company should only consider the waste it generates in determining the appropriate accumulation times for its waste. The Regulatory Assistance Officer conceded that the Health & Safety Code and the California Code of Regulations are silent on these points and further noted that DTSC otherwise expects used oil collection centers to comply with other applicable generator requirements. However, in part based on DTSC's policy of encouraging the proper collection and recycling of used oil, the agency position is intended to avoid penalizing used oil collection centers with the imposition of Large Quantity Generator status. Item 20. Improperly labeled hazardous waste containers. This violation was noted at each store inspected. In most cases, the hazardous waste label on the 55- gal. spent absorbent waste drum and/or the DIY used oil tank was missing the hazardous property ("Toxic") label or was missing the accumulation start date. All hazardous waste labeling issues have been corrected. In addition, I have personally reviewed the noted waste labeling issues with the respective District Manager, who is tasked with ensuring his stores are abiding with company policies and procedures, and several of the Store Managers and instructed them accordingly. AutoZone has also discussed the labeling issues with our waste vendors. Asbury Environmental (a subcontractor for Safety-Kleen) services the used oil tanks in all California stores. Asbury reported that their policy requires their service technician to always write in the accumulation start date and the used oil manifest number on the hazardous waste decal. Asbury will review its policy with their field personnel. Safety-Kleen was notified that their standard preprinted hazardous waste label used on every oil absorbent drum does not provide a check box or a blank line to identify the applicable hazardous waste characteristic. It is anticipated that Safety-Kleen will develop and implement revised labeling.