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SJCEHD March 25,2011 Page 2 3. The 55-gal. drum of waste absorbent stored onsite more than 90 days at AutoZone stores #3315, #5684 and #5686 were picked up by Safety-Kleen for proper transportation and disposal. Manifest copies are attached. 4. The used oil filter drum at stores#3315 and#5686 were picked up by Sacramento Waste Oil Filters for proper transportation and disposal. Receipts are attached. 5. AutoZone conducted further review to follow up on your question regarding Contingency Plans. Autozone's response in our letter dated February 25, 2011 was inaccurate. AutoZone did prepare a revised HMMP for each San Joaquin County store including a contingency plan. However, the San Joaquin County Office of Emergency Services (OES) electronic submittal procedure allowed only a very basic HMMP format to be uploaded. AutoZone was unable to upload the contingency plan portion of the HMMP to the San Joaquin County OES system. Attached, please find hard copies of the complete HMMP for each AutoZone store in San Joaquin County. 6. SJCEHD reiterated that AutoZone must obtain and retain a written log to document every universal waste bulb removed from each store per CCR 66273.39 (c)which states that"a universal waste handler shall keep a record of each shipment of universal waste sent from the universal waste handler's facility to another facility. The record may take the form of a log, invoice, manifest, bill of lading or other shipping document." Please find attached to this correspondence a written log of the information required by the foregoing regulation for the subject stores. I further explain the derivation of this log and why it satisfies the requirements of the regulations. Sylvania Lighting Services(SLS)which is under contract to relamp each AZ store every three years and to conduct semi-annual inspections of each store and to remove and replace individual fluorescent bulbs (indoors) and metal halide bulbs (outdoors) as needed. AutoZone store and maintenance personnel never remove,handle, store or dispose spent bulbs. When we first contracted with SLS to perform this service in 2006, SLS reported that their standard operating procedure does not include providing customers with a written receipt to document each lamp removed. Lamps removed from the customer site are electronically logged into the SLS handheld data logger and that data later uploaded into the SLS database. All related boxes and lamps are labeled as universal waste with an accumulation date noted. Once removed from the site, the spent material is transported to the local SLS facility and staged for recycling. At the SLS service center,the spent lamp boxes are inspected and comingled with other spent lamp material. The spent material is organized and staged for pick up by Waste Management Lamp Tracker,the designated transporter and recycler of UW for SLS. Universal waste lamps picked up by Waste Management are listed on a bill of lading. Upon recycling, the Waste Management facility issues a certificate of recycling (in SLS name) listing the lamps and the associated bill of lading number. In a letter of interpretation (RCRA Monthly Call Center Report, June 2004), U.S. EPA interpreted that both the facility and the contractor would be subject to the universal waste handler standards in Part 273 because they would both be considered universal waste handlers. In this case, the facility used the lamps and made the determination to discard them and is thus a generator. The contractor that actually removes the universal waste lamps from service is considered a handler and generator of the waste making the facility and the contractor cogenerators (64 FR 36466, 36474; July 6, 1999). As cogenerators, both the facility and the contractor are jointly and severally liable as universal waste