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a t&t <br /> AT&T Services,Inc <br /> RECENED <br /> Environment,Health&Safety <br /> 2600 Camino Ramon,Room 3E000 <br /> San Ramon,CA 94583 <br /> August 4, 2010 AUG 0 9 0110 <br /> ENVIR0N1k1ENV; HEALTH FAX: 209-468-3433 <br /> PERMIT/�ERVICES SENT VIA CERTIFIED MAIL <br /> #7009 2820 0002 3307 3468 <br /> Garret Backus <br /> Senior Registered En 'ronmental Health Specialist <br /> San Joaquin County E ivironmental Health Department <br /> 600 E. Main Street <br /> Stockton, CA 95202-3029 <br /> Re: Brake havings at AT&T <br /> 2300 E Eight Mile Road,AT&T ITS#107629 <br /> Dear Mr. Backus: <br /> Thank you for your J ly 9, 2010 email to Andrew Taylor in response to my March 26, 2010 <br /> letter regarding your azardous waste generation inspection on February 26, 2010 at 2300 E. <br /> Eight Mile Road, Stoc ton. <br /> Your letter requests documentation that our scrap metal is recycled. We regret the oversight in <br /> providing that documentation, as we did not realize that the fact AT&T scrap metal is recycled <br /> was at issue. Please fijid enclosed Bills of Lading from Fortune Metal at or about the time of the <br /> inspection that document the recycling of scrap metal from the facility. <br /> The remainder of this esponse addresses other issues raised in your July 9, 2010 email, namely <br /> the conclusion based o review of the information we provided that metal shavings fines exceed <br /> the STLC for chromiu and, as a result, an explanation of how metal waste smaller than 100 <br /> microns will be handle as hazardous waste. <br /> Our hazardous waste r gulatory experts have reviewed your email and advice that, whereas we <br /> provided the analytica result to which you refer, the regulatory analysis with respect to the <br /> results for the fines we e not fully explained. Therefore, the following supplemental information <br /> is provided with the e pectation that you will reconsider your conclusion that the fine metal <br /> shavings are hazardous waste and must be managed separately from other scrap metal. <br /> L The applicable STLC regulatory limit for the fines is 560 m�,/l <br /> Although the STLC values listed in Table II at 22 CCR § 66261.24(a)(2)(A) indicate that <br /> the STLC for cl iromium VI compounds and chromium and/or chromium III compounds <br /> is 5 mg/l, footn to d must be considered. With respect to chromium VI or hexavalent <br /> chromium, there is no reasonable basis for a ferrous metal alloy brake component to <br /> contain hexaval nt chromium, which would be inconsistent with the heat of the casting <br /> process. For ch omium metal, footnoted states: <br />