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's safeloleeno� September 17, 2021 Mr.John Bounds Environmental Compliance Manager O'Reilly Auto Parts- Risk Management Department 233 S. Patterson Springfield, MO 65802 Phone(417)520-4589 jbounds2@oreillyauto.com RE: Recent Violations at O'Reilly Auto Parts Stores(e.g.,Store 2736-Tracy) in CA for not having the CA Waste Code on the Receipt Associated with the CA Consolidated Manifest Dear Mr. Bounds, I have been working with our sales and service representatives,as well as our MIS group, regarding the recent discovery of the missing California waste code on receipt(s)associated with consolidated manifests as required by HSC 25160.2(b)(4). This appears to be a limited scope issue involving the programing of our older hand-held computer devices. Please see the photo of one such receipt on the attached page. The issues found on the SK hand-held receipts were the result of a software issue that impacted our drivers' hand-held devices and the receipts printed from those devices beginning on September 19th, 2019. Safety-Kleen has discontinued use of the affected hand-held (HH)devices and have upgraded our drivers in California to an iPhone-based (iOS)app starting June 2nd 2020. The software issue on the HH devices did not impact the consolidated hazardous waste manifests or our waste tracking/reporting systems. The manifests that correspond to the impacted HH receipts all correctly listed the CA state waste code. Our waste tracking and reporting systems were also unaffected and populated the correct CA state waste codes in our systems which are the source for data used on regulatory reports. Training for using the current iPhone application was provided to all California drivers on June 2nd and 3rd of 2020. This appears to be a somewhat randomized and short-term issue. For customer number OR14422-O'Reilly#2736 in Tracy,CA, service order 81022732 was entered in the driver's HH on September 18th, 2019 with the prior version of OM (8.0.0.2). The receipt for this order does in fact have the 221 state waste code. The following service for this same location was entered on September 27th and the receipt for this service(order 81233203) unfortunately does not have the 221 state waste code. We believe this issue has been corrected and we can certainly manually modify(hand-write in)your receipts to reflect the addition of the CA waste code 221 where it may be missing or,alternatively,your stores can write this information in manually where needed. Please contact me or your key contacts within the Safety-Kleen sales support team if you have additional questions or need additional assistance. Sincerely, Billy Ross, P.E. Senior Vice President—Environmental Compliance Safety-Kleen Systems, Inc. bill.ross@safety-kleen.com 530-304-6915