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Violation #20 (CCR 66262.34(f)) — Failed to completely label containers or tanks of hazardous waste. See response to violation #18 above and corresponding documentation for the waste brake fluid drum and waste oily absorbent drum in the auto center. The hazardous waste label on the 65 -gallon overpack drum "A" in the retail store has been amended to accurately list the flammable constituents in the waste consumer products for which the drum is designated. A scan of the revised label along with a picture of the label in use on the drum is included in this response package. Violation #27 (CCR 66265.173(a)) — Failed to keep containers of HW closed except when adding or removing HW. See response to violation #18 above and corresponding documentation. Violation #30 (CCR 66261.7(f)) — An empty HW or Haz Mat container (larger than 5 gallons) was not marked with the date it was emptied and/or not managed within one year of being emptied. The empty hydraulic fluid drum on the right (as photographed in your inspection report) has been hauled off and a copy of the manifest is included in this response package. The empty drum on the left (as photographed in your inspection report) had been designated for scrap metal storage long ago and was positioned upside-down during your inspection, thus the open end was not visible. It was brought back upstairs and returned to the scrap metal storage area. The six (6) 65 -gallon overpack drums at the retail store have been labeled as "empty" along with the date on which they were emptied. A picture of these drums is included in this response package. Violation #35 (CCR 66265.195(x)) — Failed to conduct daily inspections of HW tank. Inspections of the facility's used oil AST are now taking place and being documented daily. Inspection documentation for the month of August 2011 is included in this response package. Violation #43 (CCR 66268.7(a)(8)) — Failed to retain notifications, certifications, waste analysis data, and other records required in this section on site for 3 years. Sears believes that the brake rotor shavings generated at its auto center facilities meets the definition of "scrap metal" and manages them as such. This belief is based on shavings analysis conducted in 2008 and a 2011 update evaluation (see letter dated August 24, 2011 included) as well as generator knowledge of brake rotor constituents (iron, steel). Violations #45 and 47 (CCR 66265.52 & CCR 66265.55) — Contingency plan incomplete & No emergency coordinator. Included in this response package are copies of this facility's Emergency Action Plan (EAP) and Hazardous Materials Management Plan (HMMP) that contain hazardous waste management provisions