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HIGGS, FLETCHER & MACK LLP FOUNDED 1939 <br />ATTORNEYS AT LAW MEMBER, AMERICAN LAW FIRM ASSOCIATION <br />2600 FIRST NATIONAL BANK BUILDING <br />401 WEST W STREET <br />SAN DIEGO, CALIFORNIA 92101-7910 <br />S. WAYNE ROSENBAUM <br />April 12, 2000 <br />VIA FACSIMILE AND U.S. MAIL <br />Mr. Doug Wilson <br />San Joaquin County Unified Program Agency <br />Environmental Health Division <br />304 E. Weber Avenue <br />Stockton, California 95202 <br />RE: OB Rebuilders, Inc. <br />Dear Mr. Wilson: <br />TEL: (619) 236-1551 <br />FAX: (619) 696-1410 <br />E-MAIL: Info@higgslaw.com <br />rosen@higgslaw.com <br />DIRECT DIAL: (619) 595-4343 <br />E <br />APR 2 0 2000 <br />ENV1R0Nke1E1�' <br />PERMIT I ! r_I"� , i0- 'E"s <br />r <br />Thank you for taking the time to speak with me on Tuesday, March 21, 2000. The <br />purpose of this letter is to describe for you the actions Quality Brake Rebuilders ("QBR") has <br />taken and intends to take to assure its compliance with Hazardous Waste Regulations. Please be <br />advised that this letter contains some de minimis modifications of my earlier fax. <br />WASTE IDENTIFICATION <br />QBR audited its facility to identify and characterize each waste stream. QBR then <br />developed appropriate procedures to handle the wastes it generates. The major waste streams <br />identified are as followsl: <br />Friction area wash waters. <br />2. Friction area sludges. <br />U <br />3. Brake shoe linings; <br />I We have also identified wastes generated from theisholasters, the scrubber, the caliper rustproofing <br />machine, the brake shoe grinders, the vibratory tubsor washers. We have characterized the <br />scrubber waste as nonhazardous. See QBR 1 A and have characterized to shot blast waste as <br />hazardous. See QBR 7A and 8A. We'fi-aive not yetaracterized the vibratory waste, brake shoe grinding <br />waste, caliper rust proof waste or floor washing waste. We intend to do so during the next 90 days. Until <br />QBR fully characterizes these waste streams, QBR will handle the residues as though they were <br />hazardous. <br />297090.3 <br />