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Page 1 of 1 <br /> Thuy Tran [EH] <br /> From: Thuy Tran [EH] <br /> Sent: Thursday, September 30, 2010 9:38 AM <br /> To: 'jrthoma1 @up.com' <br /> Subject: Metal Grindings <br /> Hello John, <br /> I have information on brake/metal grindings and how it will help you can determine if it is a hazardous waste. <br /> The solid waste in question can be a mixture of small metal particles and fine particulate matter(commonly <br /> referred to as brake grindings). The fine metal particulate matter is of special concern because the particle size <br /> has been found to be less than 100 microns in diameter in cases where sample have been taken and analyzed. <br /> Scrap metals are exempted from regulations when recycled. Scrap metals, defined in California Code of <br /> Regulations, Title 22, Section 66260.10, as: <br /> 1. manufacturered, solid metal objects and products; <br /> 2. metal workings, including cutting, trimmings, stampings, grindings, shavings, and sandings; <br /> 3. solid metal residues of metal productions; or <br /> 4. printed circuit boards that are recycled [except for printed circuit boards referenced in subsection (b)(7)of this <br /> section]. <br /> Scrap metals excludes the following (non-recyclable): ... <br /> 6. sludges, fine powder, semi-solids and liquids solutions that are hazardous waste <br /> Fine powder- means a metal in dry, solid form having a particle size smaller than 100 micrometers (0.004 inches) <br /> in diameter. Fine powder hazardous waste must be managed as either hazardous waste or an Excluded <br /> Recyclable Material (California Health & Safety Code (CHSC) section 25143.2(d)(5) and (6)) <br /> So as a generator, your options are: <br /> If the powder particulate size is less than 100 microns then: <br /> 1. determine whether the brake grindings have characteristics of a hazardous waste (analysis of waste samples <br /> for heavy metal contents can be used to make this determination), and if so manage and dispose of it as required <br /> by hazardous waste regulations OR <br /> 2. determine that the brake grindings waste is a hazardous waste and manage it as an excluded recyclable <br /> material <br /> Hope this helps. If you have any questions, do not hesitate to call or email. <br /> Thuy Tran <br /> Registered Environmental Health Specialist <br /> San Joaquin County Environmental Health Department <br /> 600 East Main Street <br /> Stockton, CA 95202-3029 <br /> Phone (209)468-8257 <br /> Fax(209)468-3433 <br /> http://www.sjgov.org/ehd <br /> 9/30/2010 <br />