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• Mr. David A, That to <br /> October 15, 199 <br /> Page 2 <br /> You note, owever, that the Los Angeles County Fire Department recently began citing <br /> some of your clien for discarding these brake shavings as normal refuse. The'County apparently <br /> has directed the de lerships to either provide a hazardous waste determination for the brake <br /> shavings, substanti ting the claim that they are nonhazardous and can be discarded as normal <br /> refuse, or manage t em as hazardous waste, The County believes that the brake shavings could <br /> contain fine powde and would therefore not qualify for the scrap metal exemption. You state <br /> that the County ins ector was unable to provide guidance on a quantitative method for <br /> conducting the haz rdous waste determination and the County is therefore encouraging the <br /> dealership, and you as their consultant, to.contact us for a regulatory position in this regard, and, <br /> if necessary, a qua itative method for conducting such a determination. <br /> During our hone discussion, we talked about how one would determine whether or not <br /> there was sufficient fine powder in a sample of brake shavings to render the brake shavings a <br /> hazardous waste, a d not scrap metal. In your letter, you note that, " a representative sample'of <br /> brake shavings, wit a known initial mass, would be placed into a 100 micron sieve. Then, that <br /> portion of the camp a which passed through the sieve would qualify as a `fine powder' and would <br /> have a known mass This `fine powder' would then be tested to determine the concentration.of <br /> soluble heavy metal (Waste Extraction Test). Based on the results of this testing, we can use the <br /> rule of proportions lo determine if the entire sample,exhibits characteristics of a hazardous waste <br /> for any one or mort of the heavy metals using the threshold values.given in <br /> Title 22." <br /> Status of the Mate ial under Federal Law <br /> U.S. EPA r cently amended the definition of solid waste to exclude from Resource <br /> Conservation RecoN ery Act(RCRA)jurisdiction processed scrap metal'. Pursuant to 40 Code of <br /> Federal Regulations(CFR) 261.4(a)(13), excluded scrap metal, (which includes processed scrap <br /> metal, unprocessed ome scrap metal, and unprocessed prompt scrap metal)being recycled is not <br /> solid waste. <br /> "Processed crap metal" is scrap metal which has been manually or physically altered to <br /> either separ to it into distinct materials to enhance economic value or to improve the <br /> handling of aterials. <br /> 1 <br /> "Horne scra metal" is scrap metal as generated by steel mills, foundries, and refineries <br /> such as turni gs, cuttings, punchings, and borings. <br /> Federal Register Vol. 2,No.91 May 12, 1997 <br />