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• Mr. David A. Tha to October 15, 19 8 Page 5 Here is another ex mple: Let us assume the onstituents of concern in this case are nickel(Ni) and zinc(Zn). Total waste sampl = 100 grams(i.e,, .1 kg) Amount that passe through 100 micron sieve= 5 grams(i.e., •005 kg)(this amount is fine powder) The concentration f Ni in the fine powder is 4,000 mg/kg and the concentration of zinc in the fine powder is 6,00 mg/kg. 4,000 me x r =200jng Ni or 4 00 mia x 005 kg powder=200 mZ Ni kg 100 gr ms waste kg- kg 1 kg waste kg 6,000 mg x r =300 ng Zn or 6,000 ma x .005 ke powder=300 mg Zn kg •100 gr ms waste kg kg .1 kg waste kg • As the RT for Ni is ,000 mg/kg, and the RT for Zn is 5,000 mg/kg, both of.the levels are below their respective TT C regulatory thresholds. Therefore, there is not enough fine powder which contains concentrat' ns of regulated constituents at amounts which cause the scrap metal to exhibit a characteris is of hazardous waste. Conclusion Taking repr sentative samples of the wastestream and subjecting them to analytical testing and then doing the ove calculations is the most effective way to determine whether or not the brake shavings wou be subject to hazardous waste regulation, If the above method indicates that the shavings ar scrap metal, and they are to be recycled, they may be handled pursuant to the exemption in sectio 66261.6. If they are scrap metal and are,intended to be disposed, they must be tested to determi e if they exhibit a characteristic of hazardous waste. If they do, they must be handled as hazardou waste. While the results of the above analytical procedures may provide information that you clients could perhaps use as general knowledge for the waste classification of their brake lining we would caution that the results should not be used exclusively by any generator. Wastestr am composition can vary from generator to generator based on different factors, and each wa testream should be evaluated pursuant to section 66262.11, 22 CCR by each generator.