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i <br /> o 6TATE OF C,QGIFORNIA—CALIFORNIA ENVIRONMiN' QTECTION AGENCY <br /> I <br /> DEPARTMENT OF TOXIC SUBSTANCCS CONTROL `�'�` PET�wl <br /> f;rtsoH` Co�r,�P, <br /> 400 P STM; ,4TH FL00A ' <br /> 4013OX Soo <br /> +AMENTO.CA 96fi12.08a8 <br /> (916) 322--0504 <br /> April 11, 1995 <br /> Mr. David E. Vieweg <br /> Vice President and Senior General counsel <br /> Northern Automotive corporation <br /> P-0- ,Sox 6030 <br /> Phoenix, Arizona $5005 <br /> Dear Mro vi.eweg: <br /> Thank you for your recent letter in which <br /> you I as 'to whether the used oil collection programs cpelu ,t ingsata24o1 inch <br /> Kragen Auto Parts stores in California causes thost: !altare� to be <br /> classified as hazardous waste generators, and, if fir, whether any <br /> $xemptione apply. You state that you are concernedt : about the <br /> practicality of continuing these operations given t;:�, r:it the annual <br /> cost of providing this service exceeds $400,000, ani, tohat various <br /> local governments are now attempting to classify Nci% t:aern Automotive <br /> corporation (NAC) as a generator of hazardous waste:,, <br /> The Department of Toxic Substances Control. (17T,. , � has looked <br /> very carefully at the issue of whether NAC is a gena:d l:"itor of <br /> hazardous waste as a result of operating its used o1. 1. collection <br /> -progra)ns at Kragen Auto Parts stores. With respect .0 the used oil <br /> received from Consumers at these locations, the DTS(:: concludes that <br /> Kragen Auto Parts stores (and similar operations) air ,: not <br /> "generators" under current state law, but rather, ac. ;: offsite <br /> hazardous waste storage facilities that are exemptf.` ,'f.)m hazardous <br /> waste facility permit requirements when the conditil.rlls;.; specified in <br /> Health and Safety Code (HSC) section 25250. 11 are mar Although NAI_ <br /> and similar operations are not presently generators ffj" used oil <br /> collected from consumers, for reasons discussed in �.,� IEi. next <br /> paragraph, they will soon be required to meet used cJ. clenerator <br /> standards. In spite of this change, NAC will not be :t:egenerd to par <br /> generator fees on the used oil collected from conith <br /> surI2� xs since to pay <br /> and Safety code section 25250.24, (b) states that used ail removed <br /> from motor vehicles and subsequently recycled is not: Included in thE, <br /> calculation of generator fees. <br /> Comprehensive federal regulations (40 CFR part ;2;r9 Subpart D) <br /> on used oil Collection centers were finalized on ser-ti:;mber 10, 1992. <br /> These regulations require "do-it-yourselfer" and othijc' used oil <br /> collection centers to meet specified used oil general: c►:r standards. <br /> The ?ederal used oil generator standards are detailec;j and in some <br /> areas more stringent than existing state requirementl4 for used oil <br /> collection programs. As an authorized State, Califon: °fia has until <br /> P"nw-Nr"I.W A"', <br />