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Maclean, Leta <br /> From: Schnell,Jessie@DTSC <Jessie.Schnell@dtsc.ca.gov> <br /> Sent: Thursday, May 29, 2014 9:36 AM <br /> To: Maclean, Leta <br /> Cc: Andre Amy; Conti, Gloria@DTSC; Misemer, Mary@DTSC <br /> Subject: RE: particle size analysis for resurfacing wastes <br /> No,there is no percentage required or allowed. If any part of the brake pad grindings meets the definition of a <br /> hazardous waste(e.g.the chromium-containing fine powders smaller than 100 micrometers/0.004 inches),then the <br /> grindings would not meet the definition of scrap metal if the fine powders caused the grindings in general to exhibit a <br /> characteristic of a hazardous waste. If the whole batch of grindings is hazardous because of the fine powders, sieving <br /> the grindings would be considered treatment of a hazardous waste and need authorization from DTSC. <br /> See the definition of scrap metal, and the exclusions from that definition below: <br /> "Scrap metal" means (a) any one or more of the following, except as provided in subsection (b) of this <br /> section: <br /> (1) manufactured, solid metal objects and products; <br /> (2) metal workings, including cuttings, trimmings, stampings, grindings, shavings and sandings; <br /> (3) solid metal residues of metal production; or <br /> (4) printed circuit boards that are recycled [except for printed circuit boards referenced in subsec. <br /> (b)(7) of this section]. <br /> (b) "Scrap metal" excludes all of the following: <br /> (1) lead-acid storage batteries, waste elemental mercury, and water-reactive metals such as sodium, <br /> potassium and lithium; <br /> (2) magnesium borings, trimmings, grindings, shavings and sandings and any other forms capable of <br /> producing independent combustion; <br /> (3) beryllium borings, trimmings, grindings, shavings, sandings and any other forms capable of <br /> producing adverse health effects or environmental harm in the opinion of the Department; <br /> (4) any metal contaminated with a hazardous waste, such that the contaminated metal exhibits any <br /> characteristic of a hazardous waste under article 3 of chapter 11 of this division; <br /> (5) any metal contaminated with an oil that is a hazardous waste and that is free-flowing; <br /> (6) sludges, fine powders, semi-solids and liquid solutions that are hazardous wastes; and <br /> (7) any printed circuit board that has been removed from a universal waste electronic device by a <br /> universal waste handler as a result of the handler's conduct of activities authorized by sections <br /> 66273.71, 66273.72, and/or 66273.73 of chapter 23 of this division and is subject to management as <br /> a hazardous waste pursuant to sections 66273.71, 66273.72 and/or 66273.73. <br /> Please let me know if you still have questions. <br /> Jessie <br /> Jessie Schnell <br /> Senior Environmental Scientist <br /> Hazardous Waste Management Program <br /> Department of Toxic Substances Control <br /> 10011 Street <br /> 1 <br />