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Mar -07-00 03:20pm From-HIGGS FLF'"" R MACK Mr- Doug Wilson March 27, 2000 Page 2 6. Oily wastes. +6196961410 T-047 P. 03/05 F-740 HIGGS, FLETCHER & MACK LLP FRICTION AREA WASH WATERS When QBR washes brake shoes in hot water, the process generates residues. This automated process is a net consumer of water. However, our previous procedure was to clean the washer once per week thereby generating approximately 200 gallons of wash water and residual sludges. QBR characterized the wash water and determined it to be non -hazardous. - See analytical data attached as Exhibit A. Currently QBR manages the wash water by settling mechanical filtration and returns the water fraction to the parts washer. These residues are discussed below. QBR's ultimate goal is to modify this process line to filter continuously the wash water in a closed loop recycling system. QBR will make design sketches available to the agency as soon as possible. FRICTION ABEA SLUDGES The friction area generates two types of sludges. These are: (1) heavy residues that settle to the bottom of the parts washer or which settle out of the wash water after it is removed from the parts washer but prior to filtration; and (2) residues captured on the sand filter. QBR has characterized these residues and determined that they are non -hazardous. See Analytical Data Exhibit B attached hereto. However, because of the variability in the recycled feed stock there remains a potential for trace quantities of asbestos in the friction area sludges. QBR drums the sellable sludges and ships off site for disposal. QBR has chosen to combine the sand filter residues containing the friction area sludges with the brake linings, described below. QBR then disposes of the combined waste stream in a Class 3 landfill as a potentially friable asbestos waste. FRICTION AREA BRAKE LINING WASTE. After QBR thoroughly washes the break shoes, as described above, QBR removes the worn friction linings. In the past, these linings contained significant quantities of asbestos. Today, a very small percentage of brake shoes contain any asbestos at all. However, because of the nature of the recycling industry, QBR can never assure itself that there will be no friable asbestos in any of the brake shoe pads removed. Thus, QBR has chosen to treat all brake shoes and the sweepings in the brake shoe removal area as though they contained friable asbestos and to dispose of them in a Class 3 landfill. ' The wash water does contain asbestos fibers. However, the concentrations do not appear to be characteristically hazardous for aqueous solutions - 297090.2