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P.O. Box 806 <br /> Sacramento, Colifornio 95812-0806 <br /> (916)324-2428 <br /> ischne11@dtsc.co.qo v <br /> "Science says the first wordon everything, andthe fast lvordon nothing"--Victor Hugo <br /> From: Maclean, Leta [mailto:Leta,Maclean@aecom.com] <br /> Sent: Wednesday, May 28, 2014 8:01 PM <br /> To: Schnell, Jessie@DTSC <br /> Subject: Re: particle size analysis for resurfacing wastes <br /> The only contaminant is chromium and according to your guidance we can treat the grindings as scrap metal based on <br /> particle size, regardless of the chromium concentration. But is there a percentage of the grindings that have to meet the <br /> criteria of larger than 0.004 inches- let's say 90%of the sample-or do we need to sieve the grindings to separate out <br /> the finer particles and treat them as hazardous waste, and classify the rest as scrap metal? <br /> Sent from my iPhone <br /> On May 28, 2014,at 6:18 PM, "Schnell,Jessie@DTSC"<Jessie.Schnell@dtsc.ca.gov>wrote: <br /> Hi Leta, <br /> If metal grindings are contaminated with a hazardous waste to the extent that the contaminated <br /> grindings exhibit a characteristic of a hazardous waste,the grindings would not meet the regulatory <br /> definition of scrap metal, and thus the whole batch must be managed as a hazardous waste. My guess is <br /> it would be very hard to separate the finer particles from the grindings, and in any case,to do so,you <br /> would require authorization from DTSC for treating a hazardous waste. <br /> If you have further information, I'd be happy to look at it. <br /> Jessie <br /> From: Maclean, Leta [mailto:Leta.MacleanCdaecom.com] <br /> Sent: Wednesday, May 28, 2014 8:53 AM <br /> To: Regulatory Assistance Office@DTSC <br /> Cc: Schnell, Jessie@DTSC <br /> Subject: RE: particle size analysis for resurfacing wastes <br /> Yes,that is correct. Unfortunately I am unable to get a copy of their analytical results to see what was <br /> done for particle size analysis. <br /> From: Regulatory Assistance Office@DTSC [mailto:RAOCabdtsc.ca.gov] <br /> Sent: Wednesday, May 28, 2014 8:38 AM <br /> To: Maclean, Leta <br /> Cc: Schnell, Jessie@DTSC <br /> Subject: RE: particle size analysis for resurfacing wastes <br /> Leta, <br /> 2 <br />