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San Joaquin County Envir atal Health Dept. February 25,2011 Page 3 The Inspection Report for store #2858 noted a 5 gal. bucket of waste oil with no hazardous waste label. The SJCEHD ordered this material to be removed immediately by a licensed hazardous waste hauler for disposal under a manifest as a hazardous waste. The 5 gal. bucket was orphan oil that had been discovered in the rear parking lot that day. AutoZone is often subject to people leaving used oil and other fluids outside our stores. Store personnel properly followed AutoZone procedure for the handling of orphan oil. As the used oil collection tank was full at the time, the orphan oil was moved inside the store to eliminate the potential for a spill outside. As soon as Safety-Kleen serviced the used oil tank the next day, store personnel inspected the contents of the unmarked 5-gal. bucket, confirmed it to be uncontaminated used oil and poured the used oil into the used oil tank for recycling. Item#22. Damaged lead-acid batteries not properly managed and labeled SJCEHD observed one (1) leaking, lead-acid automotive battery core in a plastic shopping bag which appeared to be leaking acid onto a piece of cardboard at AutoZone store#2858 . The Store Manager reported that immediately following the inspection, store personnel processed the leaking battery in accordance with AutoZone's CA Environmental Safety policy. The leaking battery was sealed in a plastic tote with sufficient soda ash to absorb any potential leaks,the outside of the tote was labeled"LEAKING BATERY"and the tote was placed on the battery core pallet for transport to a battery recycling facility. Each and every core battery shipment is tracked and documented on a Bill of Lading which is kept in the store file for no less than three years. Item #23. One 55-gallon drum of drained used oil filters and fuel filters was seen without an accumulation start date. SJCEHD noted this violation at all stores. AutoZone communicated proper labeling protocols to each Store Manager and confirmed that all hazardous waste containers in all stores are properly labeled with an accumulation start date. Please note that AutoZone does not have a corporate policy for used oil filter collection and recycling. This service is only offered at those stores where a municipal agency sponsors, maintains, and funds the program. The San Joaquin County Department of Public Works, Solid Waste Division sponsors and funds the used oil filter collection and disposal program at all San Joaquin County AutoZone stores. AutoZone accepts primary responsibility for ensuring proper labeling including a written accumulation start date on all waste drums, but some level of responsibility also lies with the Solid Waste Division and its oil filter collection subcontractor. AutoZone contacted Dave Gorton(209-468- 3066) to report these violations attributed to the used oil filter program and the recycling contractor was instructed to ensure that their field personnel write the accumulation start date on the label or at least remind store personnel to do so at the time the first filter is placed in the drum. Item#45. Contingency Plan Incomplete. AutoZone is revising the Hazardous Material Management Plan for all 460 AutoZone stores in CA to include a revised and expanded Mitigation, Preparation and Response section with all of the elements documented in the Hazardous Waste Program Inspection report for Store#5684.