SecProbe.io

June 7 , 2012

Via E -mail
Michael Norona
Executive Vice President and Chief Financial Officer
Advance Auto Parts, Inc.
5008 Airport Road
Roanoke, VA 24019

Re: Advance Auto Parts, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 28, 2012
Response Dated May 24, 2012
File No. 001 -16797

Dear Mr. Norona :

We have reviewed your response and have the following additional comments.  In some
of our comments, we may ask you to provide us with information so we may better understand
your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Item 8.  Financial S tatements and Supplementary Data

Notes to the Consolidated Financial Statements, page F -9

17. Contingencies, page F -31

1. We note your response to prior comment 2. Please clarify for us whether an estimate of
the additional potential liability is not reaso nably estimable or estimable but immaterial.
In the first paragraph you assert a range cannot be reasonably estimated for claims that
may be filed in the future.  In the second paragraph you state you will revise your
disclosure in future filings to indic ate you are unable to estimate your potential additional
liability with respect to lawsuits.  In the third paragraph you discuss the procedures you
have developed and undertake on a quarterly basis and indicate your calculated estimate
of the potential lia bility for the “asbestos portfolio” has been immaterial.  If your
conclusion is that you are not able to estimate a range of reasonably possible losses in

Michael Norona
Advance Auto Parts, Inc.
June 7 , 2012
Page 2

 addition to the amount accrued please clearly state  that fact and revise your disclosure in
future f ilings accordingly.

2. We note your assertion that claim filing rates have yet to form a predictable pattern and
that as result you are unable to reasonably estimate your asbestos liability with respect to
claims that may be filed in the future.  Please explain in more detail how the historical
experience gained over the past nine years has not provided sufficient and reasonable
information to estimate a range of loss and what review procedures you undertake with
respect to unasserted claims.  In this reg ard, your quarterly legal review refers to the
“asbestos portfolio” which appears to mean pending matters.  If our understanding is
incorrect, please advise us of the scope of matters included in the “portfolio.”   See FASB
ASC 450 -20-55.

You may contact  Scott Stringer, Staff Accountant , at (202) 551 -3272  or Donna Di Silvio,
Staff Accountant , at (202) 551 -3202  if you have questions regarding our comments .  You may
contact me at (202) 551 -3720  with any other questions.

Sincerely,

 /s/ Andrew D. Mew

Andrew D. Mew
Accounting Branch Chief