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Gloria Conti Regulatory Assistance Officer RAO@dtsc.ca.Qov Hazardous Substances Scientist DTSC- Cypress branch 714-484-5400 DTSC Regulatory Assistance Officers provide informal guidance only about management of hazardous waste for the convenience of the public. Such oral or electronic mail advice is not binding upon DTSC, nor does it have the force of law. If you would like a formal opinion on a matter by DTSC, please contact the responsible program office directly. You should also refer to the statutes and regulations, DTSC Policies and Procedures, and other formal documents. If you would like to provide us feedback please do so at: http://www.calepa.ca.gov/Customer/CustForm.i)df From: Maclean, Leta [Leta.Maclean(o)aecom.com] Sent: Tuesday, May 27, 2014 9:49 AM To: Regulatory Assistance Office@DTSC Subject: particle size analysis for resurfacing wastes Your guidance states that"...if the resurfacing waste does not contain or consists of fine powders (i.e., the wastes particle size is 0.004 inches and larger [about the size of grains of table salt or larger]), the resurfacing waste may be managed as scrap metal." We have performed particle size analysis for a sample of brake pad grindings to determine if this waste would qualify as scrap metal. Chromium slightly exceeds the maximum concentration limit of 5 ni for STLC so we would like to manage this as scrap metal.A small percentage (less than 10%)of the sample contained fines that were less than 0.004 inches. What is your expectation for managing this waste— does our client need to sieve the grindings and treat the finer particles as hazardous waste, or can we treat it all as scrap metal since over 90%of the grindings meet the criteria? Leta Maclean Project Manager/Senior Chemist Environment D 858.300.2703 M 619.206.9109 leta.maclean(a)aecom.com AECOM 7807 Convoy Court, San Diego, CA 92111 T 858.268.8080 ext. 1203 F 858.292.7432 www.aecom.com This electronic communication,which includes any files or attachments thereto,contains proprietary or confidential information and may be privileged and otherwise protected under copyright or other applicable intellectual property laws.All information contained in this electronic communication is solely for the use of the individual(s)or entity to which it was addressed.If you are not the intended recipient(s),you are hereby notified that distributing,copying,or in any way disclosing any of the information in this e-mail is strictly prohibited.If you have received this e-mail in error,notify the sender immediately,and destroy the communication and any files or attachments in their entirety, whether in electronic or hard copy format.Since data stored on electronic media can deteriorate,be translated or modified,AECOM,its subsidiaries,and/or affiliates will not be liable for the completeness,correctness or readability of the electronic data.The electronic data should be verified against the hard copy. 4