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Pal W14F�q4PFAWjWqW 123 South4FrontSMemphis TN 38103-3607 March 25,2011 RECEIVED Ms. Michelle Henry MAR 2 9 2011 San Joaquin County Environmental Health Dept. 600 E. Main Street ENVIRONMENTAL HEALTH Stockton, CA 95202 3029 PERMIT/SERVICES RE: Hazardous aste Program Inspection Reports AutoZone ores located in San Joaquin County,CA Dear Ms.Henry: In a letter dated F bruary 25, 2011, AutoZone responded in writing to the San Joaquin County Environmental Healti Department (SJCHD) - Hazardous Waste Program Notices of Violations issued to multiple AutoZon stores. The purpose of this letter is to provide further clarification to your comments as discussed in a telephone conversation on Mon Jay March 7,2011. As a follow up to SJ HD comments regarding Personnel Training, I will be attending a With respect to the training 1. SJCEHD pointed ut that one of the five Return to Compliance Certification forms submitted with the February 25, 201 letter had not been properly signed. Attached, please find the signed document for AutoZone store# 315. 2. In response to your question regarding generator status, AutoZone would like to clarify again that each of our retail sto es 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 o er automotive fluids, but does not offer any automotive repair services which generate used motor il. 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 iscover a leaking retail package of new motor oil. Company policy and practice is to pour this contain r of oil into the used oil storage container and properly dispose of the empty retail package. This type f 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 certified Used Oil Collection Center, it is not required to keep an Industrial Oil Receipt Log pursuant o 14 Cal.Code Regs. §18651.2(f). No similar logging requirement exists for used oil received from the ompany'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 cit,-d as the rationale to regulate a Used Oil Collection Center as a Large Quantity Generator of hazardous waste.