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MAR-26-2010 16:46 SBC 9259730584 P.03 <br /> Mr.Garrett Backus,Inspector <br /> 03/26/10 <br /> Re: (UE17L)ITS#10769 <br /> Pg.2. <br /> Calif.Code of Regulations Section 66262.11(e)(2)makes clear that generator knowledge may be used to <br /> determine that a waste d©es 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. Although some types of iron casting may fail for lead, such a high concentration in brake <br /> drums would make them too soft to do their job. <br /> Nevertheless,in responsi 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 hazardo4s waste characteristic. <br /> First,please see Attachment 2,a report dated March 16,2010 from McCampbellAnalytical,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 Regulations Section 66261.24(a)(2)(A). <br /> The TTLC results for fiv�of the metals(lead, copper, mercury, nickel and chromium)exceed ten tunes 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 finies under 100 mucrons to the Waste Extraction Test.Attachment 3 is a report dated <br /> March 22, 2010 from M Catxrpbell Analytical, Inc_, transmitting the results of STLC testing.It shows that, as <br /> one would expect,very Uttle(for chromium and nickel)or no detectable amount(for copper,lead and mercury) <br /> of these metals leach out(when subjected to the Waste Extraction Test.Therefore the fines under 100 microns do <br /> not exhibit a characteristic of hazardous wast;based on either the TTLC or STLC limits. <br /> These analytical results cquf=what generator knowledge would predict,which is that shavings from steel <br /> brake drums,even tinesder 100 microns.do not exhibit any characteristic of, and therefore are not,hazardous <br /> waste.Therefore neitherrazardous waste manifests nor scrap metal recycling receipts are required to <br /> demonstrate compliance 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 deceswy. Thank you for your help. <br /> Sincerely, <br /> James A. Stehr, AIA 66 <br /> Environmental Manager <br /> Tel: 925 823 8866 <br /> Email:p8486Cdatt.com <br /> cc: Andrew Taylor,AreEa Manager,EH&S <br /> Connie Mitchell,Environmental Site Manager <br /> Linda Alexander,Poperty Manager <br /> James J. La Porte <br /> Attach: Metallurgical Laboratories <br /> Chain of Custod <br /> Return to Compliance <br />