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q e ea <br /> BRASH <br /> NDUSTFUES <br /> December 31, 2007 <br /> Mr. Wayne Rosenbaum,Esq. <br /> Foley&Lardner <br /> 402 West Broadway <br /> 23rd Floor <br /> San Diego, CA 92101 <br /> Subject: December 5, 2007 San Joaquin County meeting with Nexframe <br /> Reference: Department of Toxic Substances Control Sampling Report at the Nexframe <br /> facility dated May 10,2007 <br /> Dear Mr. Rosenbaum: <br /> As a result of the subject meeting,a question was raised as to the findings of total chrome in DTSC <br /> sample"Nex 02"of 2,600 mg/Kg. <br /> In the subsequent discussion on this matter it was mutually agreed that this issue warranted further <br /> evaluation of the findings. The referent document,paragraph VI.Violations: 1 states: ".....and waste <br /> powdery material collected in a trash can contained hazardous waste levels of chromium, were <br /> illegally disposed of at 4819 Fite Court, Stockton, California." <br /> The following report attempts to identify the possible sources of the material comprising Nex02,and <br /> identifies the chromium sources at the Nexframe facility. <br /> Background: <br /> 1. The TTLC regulatory level for chrome is 2,500 mg/Kg, as stated in the referent letter. <br /> 2. In an effort to determine the source of the chrome,a review of the production material was <br /> performed. A Synthetic Precipitate Leaching Procedure(SPLP)was performed on the raw <br /> sheet metal stock used in the Nexframe manufacturing process.The SPLP procedure extracts <br /> a sample based upon a 1:20 ratio(sample mass to liquid mass ratio)with SPLP fluid for 18 <br /> hours. This is essentially an extraction with deionized water, adjusted to a pH of 5.0. <br /> BRASH Industries ■ 4635 Admiralty Way■ Marina Del Rey, CA 90292 <br /> Telephone: 310-305-8637 ■ Fax: 310-574-0875 ■ www.brashind.com <br />