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Mar -27-00 03:20pm From-HIGGS FLF'`R MACK Mr. Doug Wilson March 27, 2000 Page 3 +6196961410 T-047 P. 04/05 F-740 HIGGS, FLETCHER & MACK LLP CALIPER WASH WATER As with brake shoes, one of the first steps in recycling calipers is to wash the parts and remove external residues. QBP, characterized the wash water and determined that it is characteristically hazardous for cadmium and other toxic metals. See analytical data attached as Exhibit C. Presently, QBR cleans the caliper parts washer once a week. QBR drums, labels and disposes of the water and residues as a hazardous waste within ninety days. QBR intends to modify this system so that the wash water is recycled in a closed loop process thereby avoiding the requirement to dispose of the water at all. QBR wishes to discuss the design for the closed loop recycling system with the agency to determine whether any PBR requirements will be triggered. CALIPER SLUDGES When QBR cleans the caliper washer once a week, it removes sludge residues from the bottom of the wash unit. Q13R characterized these residues and found hazardous concentrations of cadmium and other heavy metals. (See analytical data attached hereto as Exhibit D.) Currently, QBR drums these residues with the Caliper Area wash water. QBR labels and disposes of the combined waste stream as a hazardous waste within 90 days. If QBR is successful in developing and implementing a closed loop wash water recycling system, these residues will be captured on a sand filter and disposed of as a hazardous waste although the quantities of waste will be significantly smaller. OILY WASTES When QBR dismantles caliper units, it removes small quantities of brake fluid. QBR labels and manifests the brake fluid off site for recycling. COMPL ANCE H STORY QBR's senior management reviewed the facility's compliance history and conducted a root cause analysis. Over the years, QBR's facility has had at least three different senior managers. Unfortunately, it seems that each manager was, at first, unaware of QBR's compliance obligations. When the senior manager learned of QBR's obligations the facility came into compliance. However, QBR never institutionalized the changes. With each turnover of management, the institutional knowledge was lost. Thus, with each new senior manager the learning cycle began anew. In order to ensure this pattern does not repeat itself, QBR has determined to implement ISO 14001. ISO 14001 is an internationally recognized, third party audited, environmental management system intended to assure that the facility will come into and remain in full compliance with its regulatory obligations. Attached, for your review, as Exhibit E is information concerning the use of ISO 14001 in situations such as this. 297090.2