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v! Department of Toxic Substances Eontrol <br /> Jesse R. Huff,Director <br /> 400 P Street,4Lh Floor,P.O. Box 80b <br /> Sacramento,California 95812-0806 <br /> Pete Wilson Peter Rooney <br /> Governor Secretary for <br /> Environmental <br /> Protection <br /> October 15, 1998 <br /> Mr. David A. Thatte <br /> Environmental Engineer <br /> Kip Prahl Associat s <br /> 10805 Holder Stre t, Suite 165 <br /> Cypress, California90630 <br /> Dear Mr. Thaete: <br /> BRAKE ROTOR DRUM METAL SHAVINGS <br /> Thank you or your letter of August 26, 1998 regarding the classification of brake <br /> .shavings. Your let er requests a written response to follow up on our phone discussion <br /> confirming your understanding of how to conduct a waste determination of these brake shavings, <br /> Background <br /> In your lett r,you identified your clients as automotive repair dealerships who perform <br /> brake service on'c stomers' cars. Brake servicing includes turning brake rotors and/or drums on <br /> a lathe to smooth t ie rotor or drum surface. The amount of metal lathed from the surface varies, <br /> depending on the c ndition of the surface. The brake shavings are collected in a container which <br /> is positioned Belo the lathe assembly. You state that in the past, these shavings were typically <br /> discarded as normal refuse, as it was assumed that a hazardous waste determination was not <br /> necessary, "based on the scrap metal exemption given in Title 22, California Code of Regulations <br /> (CCR), § 66261.6( )(3)(B)." You state that the"assumption was that these shavings fit the <br /> definition of`scrap metal', as given under § 66260.10." <br /> California Environmental Protection Agency <br /> ® Printed on Recycled Paper <br />