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Ll <br />August 24, 2011 <br />Sears Holdings Corporation <br />3333 Beverly Road, B5 -339A <br />Hoffman Estates, IL 60179 <br />Attn: Mr. Michael B. Olsen, P.G. <br />Manager, Environmental Compliance <br />E: Michael.Olsen@searshc.com <br />Re: Brake Rotor Shaving Evaluation - Update <br />Sacramento Area Sears Auto Centers <br />Terracon Project No. 60117056 <br />Dear Mr. Olsen: <br />C] <br />I 1.':� tu f <br />Terracon Consultants, Inc. (Terracon) is pleased to submit an update regarding the Brake <br />Rotor Shaving Evaluation conducted for the above referenced site in April 2008. This <br />update was performed in accordance with an Environmental Work Order, dated August 23, <br />2011. <br />Terracon understands that Sears Auto Centers operate lathes at their facilities to repair <br />automotive brake rotors. The metal shavings from these lathing operations are collected in <br />bins or containers and periodically taken off-site for recycling. <br />Terracon was retained by Sears Holdings Corporation to assess if the brake rotor shavings <br />at the Sears Auto Center locations in the Sacramento area would be characterized as "scrap <br />metal" and thereby be exempt from regulation as a hazardous waste in accordance with <br />Title 22 CCR Section 66261.6(a)(3)(B). <br />As part of the evaluation, Terracon collected representative samples of brake rotor shavings <br />from four Sears Auto Center locations (Roseville, Florin Road Sacramento, Citrus Heights, <br />and Arden Way Sacramento) in the Sacramento area for grain size analysis. Based on <br />these sieve anaiysis results above, on average the amount of fine powders associated with <br />the brake rotor shavings is 6.5 percent by weight. <br />Based on the relatively small percentage of this material that is less than one -hundred <br />microns in size, it does not appear that this material would be excluded from being managed <br />as a recyclable scrap metal due to particle size (i.e. the quantity less than 100 microns does <br />Terracon Consultants, Inc. 16662 Millikan Avenue Irvine, California 92606 <br />P [949] 660 9718 F [949] 660 9732 terracon.com <br />