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123 South Front Street, Memphis TN 38103-3607 March 25,2011 R E E I V E D Ms.Michelle Henry M A r L 9 7 a 11 San Joaquin County Environmental Health Dept. 600 E. Main Street ENVIRONMENTAL HEALTH Stockton,CA 95202-3029 PERMIT/SERVICES RE: Hazardous Waste Program Inspection Reports AutoZone Stores located in San Joaquin County, CA Dear Ms.Henry: In a letter dated February 25, 2011, AutoZone responded in writing to the San Joaquin County Environmental Health Department (SJCHD) - Hazardous Waste Program Notices of Violations issued to multiple AutoZone stores. The purpose of this letter is to provide further clarification to your comments as discussed in a telephone conversation on Monday March 7,2011. As a follow up to SJCHD comments regarding Personnel Training, I will be attending a With respect to the training 1. SJCEHD pointed out that one of the five Return to Compliance Certification forms submitted with the February 25, 2011 letter had not been properly signed. Attached, please find the signed document for AutoZone store#3315. 2. In response to your question regarding generator status, AutoZone would like to clarify again that each of our retail stores meets the definition 'of a Used Oil Collection Center pursuant to Health and Safety Code §25250.11(a)and/or Public Resources Code §48622 and CCR 66279.1(e). AutoZone sells new motor oil and other automotive fluids, but does not offer any automotive repair services which generate used motor oil. Similarly, the company does no maintenance of company vehicles at its store locations. As a result,AutoZone does not generate used oil as part of its store operations. On occasion a store employee will discover a leaking retail package of new motor oil. Company policy and practice is to pour this container of oil into the used oil storage container and properly dispose of the empty retail package. This type of occurrence is so infrequent, the company merely notes the loss for stocking purposes but does not otherwise record the disposition of the oil. Because AutoZone does not accept used industrial oil, as a certified Used Oil Collection Center, it is not required to keep an Industrial Oil Receipt Log pursuant to 14 Cal.Code Regs. §18651.2(f). No similar logging requirement exists for used oil received from the company's DIY customers. We are happy to provide an affidavit from one of our company managers to confirm the foregoing points. Because AutoZone does not generate the used oil managed in its status as a Used Oil Collection Center, it is unreasonable to conclude that a negligible quantity of an occasional quart of damaged, new retail motor oil poured into the used oil storage container would be cited as the rationale to regulate a Used Oil Collection Center as a Large Quantity Generator of hazardous waste.