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Sears Brake Rotor Shavings Evaluation Terracon <br />Terracon Project No. 80087013 <br />June 27, 2008 <br />small percentage of this material that is less than one -hundred microns in size, it does not <br />appear that this material would be excluded from being managed as a recyclable scrap <br />metal due to particle size (i.e. the quantity less than 100 microns does not appears to <br />constitute a significant percentage of the scrap metal material). To address scrap metal <br />exclusion (b)(4), Terracon recommends that Sears assess whether the material may contain <br />other contaminants that could cause the material to be classified as a characteristic <br />hazardous waste (e.g., asbestos). This can be accomplished by documenting "generator <br />knowledge" of the brake rotor constituents and any other substances that could be <br />introduced during the process. <br />Terracon Consultants, Inc. (Terracon) appreciates the opportunity to provide regulatory <br />compliance support services to Sears Holdings Management Corporation. If you have any <br />questions regarding the content of this letter report or if we can be of further assistance, <br />please contact us at 949-660-9718, <br />Sincerely, <br />TER RACON CONSULTANTS, INC. <br />Z - <br />Doug Urry, R.E.A. <br />Office Manager <br />ATTACHMENTS <br />Attachment A: Sieve Analysis <br />Eric R. Powley <br />National Account Manager <br />3 <br />