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Brake Lathe Shavings Generated by O'Reilly Auto Parts Stores(e.g.,Kragen Auto Parts) <br /> in CA are Classified as Exempt Scrap Metal when sent for Steel Recycling <br /> Memo from Safety-Kleen dated October 8,2009 <br /> Page No.2 <br /> hazardous waste under State law, if the metal exhibits any characteristic of hazardous waste or is <br /> contaminated with listed hazardous waste. <br /> Based on the information gained from testing the three representative samples of brake lathe <br /> shavings using ASTM Method D 422 which showed that the metal shavings were 91%, 97%, <br /> and 88% larger than 100 micrometers (see the attached particle size distribution graphs for the <br /> three representative samples analyzed by the independent certified laboratory) and based on the <br /> provisions of California regulations cited in the immediately preceding paragraph, Safety-Kleen <br /> concludes that the metal shavings generated in the course of brake repair operations <br /> conducted at Kragen Auto Parts stores are not subject to regulation as hazardous wastes <br /> under State law because the metal shavings meet the definition of scrap metal specified in 22 <br /> CCR 66260.10 (the shavings are not"fine powder") and are recycled for their steel value at a <br /> foundry. <br /> Please let me know if you need any additional assistance with this matter. <br /> Sincerely, <br /> Bill Ross, P.E. <br /> Vice President of Environmental, Health & Safety <br /> Safety-Kleen Systems, Inc. <br /> 530.795.3554 <br /> bill.rossna,safety-kleen.com <br /> enclosures <br /> cc: Mr. Bob Gillespie, Corporate Safety Manager, O'Reilly Auto Parts <br /> Mr. Chuck Geller,National Account Manager, Safety-Kleen <br />