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Mr. Garret Backus <br /> August 4, 201 <br /> Re: 107629 <br /> Pg. 4 <br /> [portions omitted] <br /> The gist of D SC's advice is: <br /> "I Take a measured amount of sample and pass it through a 100 micron <br /> sieve. Analyze the portion passing through the sieve. <br /> 4. The concentration of the regulated constituent in the sample from the <br /> bucket i.e., the waste)is equal to the concentration in fine powder of the <br /> regulated constituent multiplied by the fraction of fine powder in the <br /> waste. Therefore, one must divide the weight of the amount that passed <br /> through the sieve by the total amount of the sample. Multiply the <br /> resulting quotient by the concentration of the metal constituent. <br /> Compare this result to the regulatory threshold (RT) of the total <br /> threshold limit concentration (TTLC)for the constituent. If it exceeds <br /> the RT it is a hazardous waste. If it does not exceed the RT, there is not <br /> enough powder to cause the rest of the metal to be a hazardous waste." <br /> The letter g s on to provide example calculations based on proportioning the <br /> concentration of the hazardous waste constituent of concern in the less than 100 micron <br /> portion of thecrap metal sample back into the entire mass of the whole sample. <br /> In conclusion, althou we believe that there is sufficient knowledge available from the material <br /> itself and testing con ucted to show that the proper STLC of 560 mg/1 for the fines was not <br /> exceeded, the applicat on of any hazardous waste constituent testing of the finely divided portion <br /> must be proportioned back into the representative sample as specified by DTSC. <br /> Your reconsideration hat our facility can manage all of its brake shavings as recyclable scrap <br /> metal based on this additional information will be appreciated. <br /> Please let me know if,mu have any questions or need additional information. <br /> S' ly <br /> A. STEHR, AIA <br /> Environmental Manager <br /> AT&T EHS <br /> Encl: a/s <br /> JAS/kb <br />