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Mr. David A. Th a to October 15, 19)8 Page 4 The difficu ty, as you note, lies in determining whether or not there are sufficient amounts of fine powders in the bucket that collects that brake shavings to render all of the metal in the bucket a hazardou waste, and not scrap metal. In order to determine whether or not the larger pieces of metal ar contaminated with fine powders in concentrations which would render them hazardous waste, nd not scrap metals, we prescribe the following: 1. Take repre entative samples of metals from the bucket. Sample according to the procedures found in Chapter 9 of SW-846, "Test Methods for Evaluating Solid Waste, Physical/C emical Methods", 2. Take the s ples to a laboratory which has been accredited to perform hazardous waste testing by t e Environmental Laboratory Accrediation Program (FLAP). A list of the laboratorie can be obtained by calling(510) 540-2800. 3. Take a me ured amount of sample and pass it through a 100 micron sieve. Analyze the portion pas ing through the sieve. 4. The concen ration of the regulated constituent in the sample from the bucket(i.e., the waste), is a ual to the concentration in fine powder of the regulated constituent multiplied by the fracti n offine powder in the waste. Therefore, one must divide the weight of the amount tha passed through the sieve by the total amount of the sample. Multiply the resulting qu tient by the concentration of the metal constituent. Compare this result to the regulato threshold (RT) of the total threshold limit concentration.(TTLC)for the constituent. If it exceeds,the RT, it is a hazardous waste. If it does not exceed the RT, there is not nough powder to cause the rest of the metal to be a hazardous waste. The following Let us assume the c nstituent of concern in this case is lead (Pb). Total waste sample = 100 grams Amount that passes through 100 micron sieve= 5 grams(this amount is fine powder) The concentration Pb in the fine powder is 1,000,000 mg/kg(i.e., it's all Pb) 1,000,000 me x ams powder=50,000-mg Pb kg 10 grams waste kg 50,000 mg Pb exce s the RT of 1,000 mg Pb, therefore, the 100 kg sample is hazardous waste, kg kg 1 .