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safe1q,hieefle <br /> PROT'EMON•CHOICES-PEOPLE <br /> MARE GREEN WORK <br /> Conclusion <br /> The metal shavings generated from brake repair operations at O'Reilly Auto Parts stores meet the Federal <br /> definition of "scrap metal," and therefore, are not subject to regulation as hazardous wastes under Federal law <br /> when recycled, irrespective of the manner in which the metal shavings are recycled, or the sizes or chemical <br /> characteristics of the metal shavings. Any metal shavings that are disposed of are obviously not recycled and, <br /> therefore, not eligible for the recycling exemption specified in 40 CFR 261.6(a)(3)(ii). <br /> Pursuant to California Title 22 CCR § 66261.6(a)(3)(B), "scrap metal", as defined in 22 CCR § 66261.10, is also <br /> exempted from regulations under State law, when recycled. California's definition of "scrap metal", however, <br /> differs from the Federal definition of "scrap metal" cited above. The State's definition of "scrap metal" does not <br /> include "fine powder," defined as a metal, in dry powder form, having a particle size of less than 100 <br /> micrometers (0.100 mm) in diameter. In addition, the State's definition of "scrap metal" excludes metal <br /> contaminated with hazardous waste such that the contaminated metal exhibits any characteristic of hazardous <br /> waste or is contaminated with listed hazardous waste. <br /> Process knowledge (e.g., regulated solvents are not used during the process of repairing/restoring vehicle brake <br /> parts) combined with the enclosed analytical demonstrates that the brake lathe shavings generated in the <br /> course of brake repair operations conducted at O'Reilly Auto Parts facilities are not subject to regulation as <br /> hazardous wastes under State law because the metal shavings... <br /> • meet the definition of scrap metal specified in 22 CCR § 66260.10 and are recycled for their steel value <br /> at a foundry <br /> • do not leach regulated concentrations of metals when subjected to both the Federal TCLP and State <br /> WET extraction methods <br /> • were not found to be contaminated with a regulated volatile organic compound (e.g.,listed solvent) <br /> exceeding the RCRA regulatory limit <br /> If you have any questions or require additional information regarding the attached analytical reports, please <br /> don't hesitate to contact me. <br /> Sincerely, <br /> Rick Haskins <br /> Director Research and Development <br /> Safety-Kleen Systems, Inc. <br /> 847.468.6766 <br /> rick.haskins(a-)safety-kleen.com <br /> Enclosures <br /> cc: Mrs. Nahid Toossi, Compliance Manager, Safety-Kleen Systems, Inc. <br /> Mr. Chuck Geller, National Account Manager, Safety-Kleen Systems, Inc. <br /> 2600 North Central Upressway I Suite 4401 Richardson, IX 75000 <br /> 800.669.5740 1972.265.2957 (f) I Safety-Kleen Systems, Inc. I A Clean Harbors Company safety-kleen.com <br />