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E Brake Shavings Evaluation - Update Sears Auto Centers m Sacramento, California ierracon January 17, 2012 a Terracon Project No. 80117000 TTLC Analytical Results The brake rotor and drums shaving samples exhibited various CAM -17 metals concentrations above the laboratory reporting limit: barium, total chromium, cobalt, copper, lead, mercury, molybdenum, nickel, vanadium, and zinc. A summary of the analytical results is presented in Table 1, in Attachment A. As the detected concentrations of the metals are 10 times the STLC limits, the samples were analyzed for STLC CAM -17 metals to evaluate if the waste stream could be classified as California hazardous waste. STLC Analytical Results The STLC analytical results reported the following metals concentrations above the laboratory reporting limit: antimony, barium, chromium, and zinc. The results were compared to California hazardous waste STLC limits. The metals detected in the samples are below the applicable STLC limits, except for total chromium in ARD -1 and SUNR-1 at 5.3 milligrams per liter (mg/L) and 5.7 mg/L, respectively. It should be noted that the concentration of total chromium is the sum of the concentration of Cr -III and Cr -VI, and the state STLC level for Cr -III is 560 mg/L. Therefore, in accordance with the state regulations to help evaluate the applicable STLC limits, the total chromium from ARD -1 and SUNK -1 were further classified into Cr -III and Cr - VI. The analytical results for Cr -VI for samples from ARD -1 and SUNK -1 were not detected above the laboratory reporting limit. Therefore, in accordance with the Cr -III STLC Interpretation, RG document #56, dated August 19, 1993, the state STLC limit for Cr -Ill established at 560 mg/L is applicable for the comparison of the total chromium results detected in the samples. A summary of the analytical results is presented in Table 2, in Attachment A. The detected Cr -III concentrations in the samples are below the STLC limits of 560 mg/L. TCLP Analytical Results The samples were analyzed for TCLP Chromium based on the STLC analysis and the total chromium concentration for the samples collected from ARD -1 and SUNR-1. The TCLP analysis was used to evaluate if the waste stream could be classified as RCRA hazardous waste. The TCLP total chromium concentrations for samples ARD -1 and SUNRA are not detected above the laboratory reporting limit. Based on the waste characterization sample results, the metal shavings derived from the operations at the referenced store locations may be disposed in accordance with the 3