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Mr. Doug Wilson <br />April 12, 2000 <br />Page 2 <br />4. Caliper area wash waters. <br />5. Caliper area sludges. <br />6. Oily wastes. <br />HIGGS, FLETCHER & MACK LLP <br />FRICTION AREA WASH WATERS <br />When QBR washes brake shoes in hot water, the process generates residues. This <br />automated process is a net consumer of water. However, our previous procedure was to clean <br />the washer once per week thereby generating approximately 200 gallons of wash water and; <br />residual sludges. QBR characterized the wash water and determined it to be non-hazardo s.2 <br />See analytical data attached as Exhibit QFy Z 2A. j <br />Currently QBR manages the wash water by settling mechanical filtration and returns the <br />water fraction to the parts washer. These residues are discussed below. QBR's ultimate goal is <br />to modify this process line to filter continuously the wash water in a closed loop recycling <br />system. QBR will make design sketches available to the agency as soon as possible. <br />FRICTION AREA SLUDGES <br />The friction area generates two types of sludges. These are 4L) residues that settle <br />to the bottom of the parts washer or which settle out of the wash water after it is removed from <br />the parts washer but prior to filtration; and4),;esidues captured on the sand filter. QBR has <br />characterized these residues and determined that they are nonhazardous. See Analytical Data <br />QBR 2 'attached hereto. <br />However, because of the variability in the recycled feed stock there remains a potential <br />for trace quantities of asbestos in the friction area sludges. QBR drumsth_ _ e settable sludges and <br />ships off site for disposal. QBR has chosen to combine the sand filter residues containing the <br />friction area sludges with the brake linings, described below. QBR then disposes of the <br />combined waste stream in a Class 3 landfill as a potentially friable asbestos waste. <br />FRICTION AREA BRAKE LINING WASTE <br />After QBR thoroughly washes the break shoes, as described above, QBR removes the <br />worn friction linings. QBR has characterized these wastes as nonhazardous for metals. See <br />analytical data attached hereto as QBR 5A and 6A. In the past, these linings contained <br />significant quantities of asbestos. Today, a very small percentage of brake shoes contain any <br />asbestos at all. However, because of the nature of the recycling industry, QBR can never assure <br />itself that there will be no friable asbestos in a y of the brake shoe pads removed. Thus, QBR <br />zThe wash water does contain asbestos fibers. However, the concentrations do not appear to be <br />�c aracteristically hazardous for aqueous solutions. <br />297090.3 <br />