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Brake Shavings Evaluation ® Update on Sears Auto Centers v Sacramento, California August 24, 2011 im Terracon Project No. 60117056 not appear to constitute a significant percentage of the scrap metal material). The report was submitted to the California Department of Toxic Substances Control (DTSC) for review and approval. DTSC responded in their November 10, 1999, letter, concluding that "the subject metal shavings would meet the definition of "scrap metal' and therefore, would be exempted from regulation when recycled, provided those metal shavings are not fine powders, and are not contaminated with hazardous wastes or constituents (e.g., haracteri,ticall} hazardous fine powders, or asbestos) to such an extent that the metal shavings exhibit one or more characteristics of hazardous waste due to the presence of those contaminants. " To address scrap metal exclusion (b)(4), Terracon recommended that Sears assess whether the material may contain other contaminants that could cause the material to be classified as a characteristic hazardous waste (e.g., asbestos). This can be accomplished by documenting "generator knowledge" of the brake rotor constituents and any other substances that could be introduced during the process. It a' At the request of Sears Holdings Corporation, Terracon reviewed the 2008 findings to assess if the conclusions from the 2008 are in accordance with the current regulations. Since 2008, the hazardous waste regulations as regulated under Title 22 CCR Section 66261.6(a)(3)(B) is current without any changes. Assuming that the store operations and assumptions used in the 2008 evaluations haven't deviated, Terracon concludes that the 2008 evaluation is still valid. Additionally, as recommended in the 2008 evaluation, Terracon recommended that Sears assess whether the material may contain other contaminants that could cause the material to be classified as a characteristic hazardous waste (e.g., asbestos or cutting oils).