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Brake Shavings Evaluation - Update <br />Sears Auto Centers n Sacramento, California <br />January 17, 2012 n Terracon Project No. 80117000 <br />3. 1601 Arden Way <br />Sacramento, CA <br />4. 5900 Sunrise Mall <br />Citrus Heights, CA 95207 <br />iii <br />The brake rotor and drums shaving samples were collected in laboratory provided certified <br />"clean" containers, labeled, and placed on ice in a cooler. The sample cooler and <br />completed chain -of -custody form were relinquished to Test America, Inc., a State -of - <br />California certified laboratory, in Irvine, California for analysis. Samples were submitted for <br />analysis on an expedited 3 -day turnaround time. <br />Laboratory Analytical Results <br />The brake rotor and drums shaving samples collected from the Sears Auto Center #6719 <br />(PAC -1), Florin Road Center (FLOR-1), Arden Way Center (ARD -1), and Sunrise Mall <br />Center (SUNR-1) were analyzed for California Assessment Metals (CAM) 17 metals/Total <br />Threshold Limit Concentration (TTLC), Soluble Threshold Limit Concentrations (STLC) <br />analysis, and Toxicity Characteristic Leaching Procedure (TCLP). <br />Laboratory results for CAM -17 metals/TTLC, STLC, and TCLP analysis are summarized in <br />Tables 1, 2, and 3 respectively, and included as Attachment A. The laboratory data sheets <br />and executed chain -of -custody form are provided in Appendix B. <br />Data Evaluation <br />In accordance with the Hazardous Waste determination requirements, the data evaluation <br />was conducted as follows and further detailed below: <br />1. The brake rotor and drums shaving samples were analyzed for CAM -17 metals and <br />compared to established TTLC limits; <br />2. For classification evaluation as California hazardous waste, STLC analysis is <br />required for CAM -17 metals, if the constituent metal(s) values is 10 times greater <br />than the established STLC limit; <br />3. For classification evaluation as Resource Conservation Recovery Act (RCRA) <br />hazardous waste, TCLP analysis is required for RCRA metals, if the total metal(s) <br />values is 20 times greater than the established TCLP limit; and <br />4. If total chromium is detected, in accordance with California regulations, the total <br />chromium should be differentiated between trivalent (Cr -III) and hexavalent <br />chromium (Cr -VI) and the appropriate TTLC and STLC limits should be applied <br />accordingly. <br />K <br />