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Page 1 of 2 <br /> �.. y <br /> Thuy Tran [EH] <br /> From: Thuy Tran [EH] <br /> Sent: Monday, October 04, 2010 11:06 AM <br /> To: 'mantecatire@yahoo.ca' <br /> Subject: Attn: Patrick Garrett-HW inspection <br /> Hello Patrick <br /> Per our conversation this morning, you had requested a listing of labs to perform a HW analysis for the brake <br /> grindings. This link should provide a listing of accredited labs <br /> htto://www.cdph.ca.gov/certlic/lab_s/Documents/ELAPLablist.xls. If the brake grindings are contaminated with <br /> waste oil, regardless of the particle size, it is a hazardous waste [CCR 66260.10(b)(5)]. If you do not handle the <br /> metal grindings as hazardous waste, please provide lab analysis how it was determine brake grindings were not <br /> hazardous waste with your Return to Compliance documentations. <br /> If you prefer to handle it as hazardous waste, ensure there a Hazardous Waste label identifying the contents <br /> within the secured closed container for the storage of brake grindings. Retain the disposal receipt for the brake <br /> grindings onsite for a minimum of three years. <br /> This link provides a free class schedule for courses that are held at our <br /> office: http;//www.sjgov.or /e_g_ hd/docs/CUPA%20FIyer%2oJuly-December%2O2O10%20by% <br /> 20Class%20Date.pd_f. I highly recommend these courses for all your employees: Basic Auto Industry HW <br /> Management, CUPA (Hazardous Waste)and Universal Waste Management. The Basic Auto Industry course is <br /> no longer offered the rest of this year but another course will be held next year. The funds from these courses <br /> comes from fines from non-compliant businesses. These valuable educational courses are for free for any <br /> business in San Joaquin County so I highly suggest your employees take advantage of them. <br /> Thuy Tran <br /> From: Thuy Tran [EH] <br /> Sent: Monday, September 20, 2010 2:51 PM <br /> To: 'mantecatire@yahoo.ca' <br /> Subject: FW: Brake Grindings <br /> Hello Greg, <br /> I have information on brake grindings and how it will help you can determine if it is a hazardous waste. <br /> The solid waste in question can be a mixture of small metal particles and fine particulate matter(commonly <br /> referred to as brake grindings). The fine metal particulate matter is of special concern because the particle size <br /> has been found to be less than 100 microns in diameter in cases where sample have been taken and analyzed. <br /> Scrap metals are exempted from regulations when recycled. Scrap metals, defined in California Code of <br /> Regulations, Title 22, Section 66260.10, as: <br /> 1. manufacturered, solid metal objects and products; <br /> 2. metal workings, including cutting, trimmings, stampings, grindings, shavings, and sandings; <br /> 3. solid metal residues of metal productions; or <br /> 4. printed circuit boards that are recycled [except for printed circuit boards referenced in subsection (b)(7)of this <br /> section]. <br /> Scrap metals excludes the following (non-recyclable): ... <br /> 6. sludges, fine powder, semi-solids and liquids solutions that are hazardous waste <br /> Fine powder- means a metal in dry, solid form having a particle size smaller than 100 micrometers (0.004 inches) <br /> in diameter. Fine powder hazardous waste must be managed as either hazardous waste or an Excluded <br /> Recyclable Material (California Health &Safety Code(CHSC)section 25143.2(d)(5)and (6)) <br /> So as a generator, your options are: <br /> If the powder particulate size is less than 100 microns then: <br /> 10/4/2010 <br />