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SJCEHD <br /> March 25,2011 <br /> Page 3 <br /> handlers. EPA recommends that when two or more parties meet the definition of generator they should <br /> mutually agree to have one party perform the generator duties(45 FR 72024,72026; October 30, 1980). <br /> In this case, SLS is a cogenerator of the universal waste lamps and has assumed all generator duties. <br /> SLS follows all applicable state and federal requirements for properly managing universal waste. The <br /> contractor technicians for SLS record the spent lamps removed from AutoZone locations in their <br /> handheld data loggers and track the waste on a bill of lading when shipped from the SLS facility to <br /> Waste Management for recycling. As noted above,the handheld data logger does not provide a printout <br /> of logged items at the time of logging. Once recycled, a certificate of recycling is provided to SLS <br /> confirming that the lamps have been properly recycled. Data regarding this disposal process is then <br /> provided to AutoZone's corporate office. <br /> Realizing that SLS's procedures and practices would not make it possible for each store to have a <br /> written record of the lamps removed from each store, AutoZone wrote to the Department of Toxic <br /> Substances seeking confirmation that the contracted services, including the records regarding universal <br /> waste management, would conform to the requirements of the California code. On October 23, 2006, <br /> the Department responded that the program was acceptable as long as the information was available to <br /> the stores to provide to inspectors upon request. A copy of this letter is enclosed. As a result of this <br /> correspondence, AutoZone has undertaken to provide this information, upon request, in a format similar <br /> to that provided with this letter. While we concede that the information is not maintained in a hard copy <br /> format at each store, it is readily available to each store manager and/or inspector upon request to <br /> AutoZone's environmental department. <br /> Should you have any questions or comments, please feel free to call (901.495.6949) or email <br /> (andrew.beaven&autozone.com)me at your earliest convenience. <br /> Regards, <br /> QOW�- <br /> Andrew Beaven <br /> Environmental Manager <br /> Attachments <br />