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11 <br /> AF%k <br /> APEX <br /> January 27,2021 <br /> Mr.Dain M.Brandup,P.E. <br /> Environmental Manager <br /> Bridgestone Retail Operations <br /> 200 41"Avenue South <br /> Nashville,TN 37201 <br /> Re: Addendum to 2019 CA Brake Rotor Shavings Waste Characterization <br /> Dear Mr.Brandup, <br /> Upon your request,Apex completed Toxicity Characteristic Leaching Procedure(TCLP)analysis on collected brake <br /> rotor shavings from ten (10) California Bridgestone Retail Operations-owned facilities that were previously <br /> included in our 2019 waste characterization assessment. Apex re-mobilized to the chosen facilities and collected <br /> bulk rotor shavings samples for analysis in July-August of 2020. <br /> Facilities included in the assessment were: <br /> Northern California Southern California <br /> 122173—Mountain View 650153—Costa Mesa <br /> 241048—San Ramon 023116—Moreno Valley <br /> 012637—San Francisco 019992—Fountain Valley <br /> 029947-Salinas 017671 —Chula Vista <br /> 022845—San Jose 020451 —San Diego <br /> During the 2019 waste characterization assessment, Apex collected one large composite sample from the 10 <br /> previously collected facility samples and submitted to Enthalpy Analytical (Enthalpy) for Total Threshold Limit <br /> Concentration (TTLC) and Soluble Threshold Limit Concentration (STLC) analysis. Following analysis, Enthalpy <br /> reported that none of the California listed metals were present in regulated levels. Due to acceptable results for <br /> STLC analysis, Enthalpy stated that the further TCLP analysis was not recommended as "STLC is a much more <br /> aggressive analysis method and will always report a higher result than TCLP from the same sample". Therefore, <br /> TCLP analysis was not completed at that time. <br /> Since identified Cadmium and Chromium are federally listed metals, Apex was tasked with submitting a new <br /> composite sample for TCLP analysis by test method 1311/601 OD based on the levels reported for the initial TTLC <br /> composite sample. A new composite sample was created by combining rotor shavings from the 10 facilities listed <br /> above and submitted to EMSL Analytical,Inc(EMSL). TCLP was requested for only Cadmium and Chromium. <br /> EMSL performed TCLP analysis of the composite sample on January 19,2021. Following analysis, EMSL reported <br /> that both Cadmium and Chromium were non-detect within the sample. Therefore, in supplement to Apex's <br /> October 2019 Brake Rotor Shavings Analysis Report, Apex concludes that brake rotor shavings collected from <br /> Bridgestone Retail Operations facilities in California are not a hazardous waste, as they do not meet regulated <br /> criteria following TTLC,STLC,TCLP,and particle size analysis. <br /> WATER RESOURCES • ENVIRONMENTAL SERVICES • HEALTH&SAFETY <br /> Apex Companies,LLC • (800)733-2739 • www.apexcos.com <br />