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SJCEHD March 25,2011 Page 2 3. The 55-gal. dru of waste absorbent stored onsite more than 90 days at AutoZone stores #3315, #5684 and #5686 w re 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 transportat on and disposal. Receipts are attached. 5. AutoZone condu ted 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 Im h San Joaquin County store including a contingency plan. However, the San Joaquin County Off of Emergency Services (OES) electronic submittal procedure allowed only a very basic HMMP foat to be uploaded. AutoZone was unable to upload the contingency plan portion of the HMMP to thSan Joaquin County OES system. Attached, please find hard copies of the complete HMMP forch AutoZone store in San Joaquin County. 6. SJCEHD reiteratehat AutoZone must obtain and retain a written log to document every universal waste bulb removed 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. TI e record may take the form of a log, invoice, manifest, bill of lading or other shipping document." Please find attached t this correspondence a written log of the information required by the foregoing regulation for the sub ect stores. I further explain the derivation of this log and why it satisfies the requirements of the re ulations. Sylvania Lighting Se ices(SLS)which is under contract to relamp each AZ store every three years and to conduct semi-annua inspections of each store and to remove and replace individual fluorescent bulbs (indoors) and metal h lide bulbs (outdoors) as needed. AutoZone store and maintenance personnel never remove, handle, tore or dispose spent bulbs. When we first contrac ed with SLS to perform this service in 2006, SLS reported that their standard operating procedure d s not include providing customers with a written receipt to document each lamp removed. Lamps rem ved from the customer site are electronically logged into the SLS handheld data logger and that data la er uploaded into the SLS database. All related boxes and lamps are labeled as universal waste with a 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 an comingled with other spent lamp material. The spent material is organized and staged for pick up by aste Management Lamp Tracker,the designated transporter and recycler of UW for SLS. Universal wa to lamps picked up by Waste Management are listed on a bill of lading. Upon recycling, the Waste anagement facility issues a certificate of recycling (in SLS name) listing the lamps and the associate bill of lading number. In a letter of interpretat on (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 bo h be considered universal waste handlers. In this case, the facility used the lamps and made the det rmination to discard them and is thus a generator. The contractor that actually removes the universal aste lamps from service is considered a handler and generator of the waste making the facility a the contractor cogenerators (64 FR 36466, 36474; July 6, 1999). As cogenerators, both the acility and the contractor are jointly and severally liable as universal waste