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#3335 NOV response <br /> July 12,2022 <br /> Page 2 <br /> regenerated, as if it were "spent" or used refrigerant removed from an air conditioning system. <br /> Rather, it is being returned to the manufacturer to be recovered as unused product. These canisters <br /> are no different than cylinders of industrial gasses being returned to be refilled. The residual gas in <br /> those industrial gas cylinders is still useful product, not "waste." (See, e.g., USEPA Letter to the <br /> Compressed Gas Association, dated November 3, 1980). Again, R134a in canisters received from DIY <br /> customers is not "waste." <br /> However, even if the R134a were to become a waste, it would still not be a "hazardous waste" <br /> because R134a does not exhibit any of the characteristics that would cause it to be a hazardous waste. <br /> Per the attached is an SDS, R134a is not "ignitable" (it has no flash point), is not reactive (it will not <br /> spontaneously explode or react to generate heat at normal temperatures and pressures), and is not <br /> corrosive (since the "corrosive" characteristic is defined by pH, which only applies to aqueous <br /> materials). As a gas, it has no oral or dermal toxicity, nor does the standard for acute aquatic toxicity <br /> apply to gasses (there is no approved protocol for evaluating acute aquatic toxicity for gasses). The <br /> inhalation toxicity of R134a is >500,000 ppm,far above the standard for inhalation toxicity of<10,000 <br /> ppm for"hazardous waste." In short, residual R134a is not a "hazardous waste" because it does not <br /> exhibit the "hazardous" characteristics of a "hazardous waste." <br /> Because residual R134a in consumer canisters is not a "waste," and it is not a "hazardous waste," it <br /> does not need to be labeled and managed as either a "hazardous waste" or as an "Excluded <br /> Recyclable Material." Therefore,there was no violation and the Notice of Violation issued to <br /> AutoZone Store#3335 should be withdrawn. <br /> Please let me know if you have any questions, and thank you for your courtesies. <br /> Regards, <br /> Andrew Beaven <br /> Environmental Manager <br /> 901.495.6949 <br /> andrew.beaven@autozone.com <br /> SDS attachment <br />