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Mr. Juston Smithers - 4 - February 11, 2015 Both values in this range of calculated concentrations are below the TTLC for zinc of 5,000 mg/kg, indicating that the DPFs containing ash (and, by extension, the non-DPF catalysts) would not be hazardous waste based on zinc concentration for these typical weight proportions. This conclusion is based on the assumption that the solid portion of the DPF is not readily friable and any zinc that may be potentially be present as part of solid is hence not in a finely divided state. Platinum in DPFs Pursuant to 22 CCR 66261, Appendix X, a waste that consists of or contains a chemical listed in Appendix X(a) is presumed to be a hazardous waste unless it is determined that the waste is not a hazardous waste pursuant to procedures in 22 CCR 66262.11, which may include testing, generator knowledge, or a determination as to whether the waste is excluded from regulation pursuant to 22 CCR 66261.4 or HSC 25143.2. Platinum compounds are listed in Appendix X(a), and the basis is indicated to be toxicity. Platinum compounds are also denoted with an asterisk in Appendix X, which indicates that the waste is presumed to be an extremely hazardous waste unless it does not exhibit any of the criteria in 22 CCR 66261.1101 and 66261.1132. ENVIRON understands that the platinum catalyst in the DPFs is in the form of elemental platinum that is affixed to the DPF substrate. In general, elemental metals do not exhibit the same hazardous properties as metal compounds, particularly when present in hard solid form or bound in a hard solid matrix. ENVIRON reviewed a variety of online toxicology database sources3 and did not identify any acute toxicity data. Based on the available sources, ENVIRON confirmed that elemental platinum is not generally recognized as being toxic. Therefore, although certain platinum compounds are expected to exhibit toxicity based on the listing in 22 CCR 66261, Appendix X(a), the platinum in the DPFs is not in a form that is generally recognized to be toxic. This evaluation constitutes the use of process knowledge to determine that the DPF is not a hazardous waste despite the presence of platinum in the DPF. ,•- • )' •; Because the DPFs containing ash are not characterized as hazardous waste under California or RCRA regulations, they are not subject to hazardous waste regulation for collection, storage, transportation, disassembly, or recycling activities. Acute oral LD50 << 50 mg/kg, acute dermal LD50 <_ 43 mg/kg, acute inhalation LC50 <_ 100 parts per million b (ppm) as gas or vapor, contains any substances listed in 22 CCR §66261.24(a)(7) at a single or combined concentration equal to or exceeding 0.1 percent by weight, has been show through experience or testing that human exposure to the waste or material may likely result in death, disabling personal injury, or serious illness because of the carcinogenicity, high acute or chronic toxicity, bioaccumulative properties, or persistence in the environment of the waste or material, or is water reactive). 2 Total threshold limit concentration values of persistent and bioaccumulative toxic substances in extremely hazardous wastes. 3 Online sources reviewed include: Toxnet (http://toxnet.nim.nih.gov); CDC — NIOSH pocket guide to chemical hazards (http://www.cdc.gov/niosh/npg); The European chemical Substances Information System (http://esis.irc.ec.europa.eu/); The Agency for Toxic Substances & Disease Registry (http://www.atsdr.cdc.gov/toxprofiles; European Chemicals Agency (http://echa.europa.eu); PubMed (http://www.ncbi.nim.nih.gov/pubmed); and OSHA 29 CFR 1910 Subpart Z P text version=FALSE)