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123 South Front Street, Memphis TN 38103-3607 <br /> July 12,2022 <br /> San Joaquin County, Environmental Health Dept. <br /> 1868 E. Hazelton Avenue <br /> Stockton, California 95205 <br /> Attention: Garrett Backus, Lead Senior REHS <br /> RE: Return to Compliance <br /> AutoZone#3335 <br /> 147 S Main St,Manteca, CA 95336 <br /> CERS ID# 10140033 <br /> Inspector Backus: <br /> AutoZone does not believe that store's handing of R134a canisters violates any hazardous waste laws or <br /> regulations and respectfully requests that the violation as described in the Small Quantity Hazardous <br /> Waste Generator Inspection Report dated June 28,2022 be withdrawn. <br /> 609 HSC 25143.2, 25143.9 Failed to properly manage a recyclable material <br /> OBSERVATION.• The facility returns non-empty refrigerant containers to an AutoZone Distribution <br /> Center(DC) 1800 Wineville Ave, Ontario, California. Information demonstrating that the refrigerant is <br /> recycled was not available for review. The non-empty refrigerant containers are not labeled as Excluded <br /> Recyclable Material. <br /> CORRECTIVE ACTION.•Provide documentation that the chlorofluorocarbon or <br /> hydrochlorofluorocarbon excluded recyclable materials are being reclaimed and recycled. Label the <br /> chlorofluorocarbon or hydrochlorofluorocarbon excluded recyclable materials: "Excluded Recyclable <br /> Material", composition of the material, "AutoZone'; address of the store, accumulation start date, <br /> physical state, and hazardous property. Provide a corrective action statement and supporting <br /> documentation to the San Joaquin County Environmental Health Department(EHD)within 30 days. <br /> This is a Class II violation. <br /> There are several reasons that AutoZone store handing of R134a canisters does not violate any <br /> hazardous waste laws or regulations. <br /> First, R134a canisters are not "waste" because they haven't been discarded. By state law, at the time <br /> they were purchased from AutoZone, the consumer paid a deposit on the canisters. When they are <br /> returned to AutoZone, AutoZone returns the deposit to the customer. Similarly, at the time AutoZone <br /> purchased the canister from the manufacturer, AutoZone paid a deposit on the canisters. AutoZone is <br /> required by law to return those canisters to the manufacturer and, when they are returned, the <br /> manufacturer returns the deposit to AutoZone. The canisters have not been discarded by the <br /> consumer because they have value. Similarly, they have not been discarded by AutoZone because <br /> they have value. They are not "waste." <br /> Second, the residual R134a in the canisters is perfectly good refrigerant. It is not being "recycled" <br /> after it has been used and discarded, and it is not being sent to the manufacturer to be reclaimed or <br />