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Mr.Garrett Backus,Inspector <br /> 03/26/10 <br /> Re: (UE17L)ITS#107629 <br /> Pg. 2 <br /> Calif.Code of Regula ions Section 66262.11(c)(2)makes clear that generator knowledge may be used to <br /> determine that a waste does not exhibit a hazardous waste characteristic. The waste at issue here is shavings <br /> from steel brake drums. Although the steel alloy contains small amounts of lead,chromium,and nickel,one <br /> would not expect high enough concentrations of any of them to cause the alloy to fail any of the tests for <br /> hazardous waste.Alth Dugh some types of iron casting may fail for lead,such a high concentration in brake <br /> drums would make th m too soft to do their job. <br /> Nevertheless,in respo ase to your Inspection Report,AT&T has had laboratory analysis performed on the fines <br /> less than 100 microns.The analytical results,attached to this letter,confirm that the fines less than 100 microns <br /> do not exhibit a hazardous waste characteristic. <br /> First,please see At ment 2,a report dated March 16,2010 from McCampbell Analytical,Inc.,transmitting <br /> the results of TTLC testing.It shows that none of the 17 metals tested exceed their respective TTLC limits set in <br /> 22 Calif.Code of Regilations Section 66261.24(a)(2)(A). <br /> The TTLC results for five of the metals(lead,copper,mercury,nickel and chromium)exceed ten times their <br /> respective STLC limit set in 22 Calif.Code of Regulations Section 66261.24(a)(2)(A).Therefore,we subjected <br /> another sample of the nes under 100 microns to the Waste Extraction Test.Attachment 3 is a report dated <br /> March 22,2010 from I vIcCampbell Analytical, Inc.,transmitting the results of STLC testing. It shows that,as <br /> one would expect,verlittle(for chromium and nickel)or no detectable amount(for copper,lead and mercury) <br /> of these metals leach cut when subjected to the Waste Extraction Test.Therefore the fines under 100 microns do <br /> not exhibit a character.stic of hazardous waste based on either the TTLC or STLC limits. <br /> These analytical results confirm what generator knowledge would predict,which is that shavings from steel <br /> brake drums,even fins under 100 microns,do not exhibit any characteristic of,and therefore are not,hazardous <br /> waste.Therefore neith r hazardous waste manifests nor scrap metal recycling receipts are required to <br /> demonstrate complian a with applicable hazardous waste rules. <br /> If you have any questions or comments,please feel free to contact me. I will refer you to one of our relevant <br /> subject matter experts if necessary. Thank you for your help. <br /> Sincerely, <br /> James A.Stehr,AIA <br /> Environmental Manag r �� <br /> Tel: 925 823 8866 <br /> Email:js8486@att.co <br /> cc: Andrew Taylor, rea Manager,EH&S <br /> Connie Mitchell,Environmental Site Manager <br /> Linda Alexander Property Manager <br /> James J.La Port <br /> Attach: Metallurgical aboratories <br /> Chain of Custody <br /> Return to Compliance <br />