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Pi <br />Sears Brake Rotor Shavings Evaluation <br />Terracon Project No. 80087013 <br />June 27, 2008 <br />Terracon <br />hazardous wastes or constituents (e.g., characteristically hazardous fine powders, or <br />asbestos) to such an extent that the metal shavings exhibit one or more <br />characteristics of hazardous waste due to the presence of those contaminants. <br />Evaluation <br />At the request of Sears Holdings Corporation, Terracon collected representative samples of <br />brake rotor shavings from four Sears Auto Center locations in the Sacramento area for <br />grain size analysis. The samples were collected directly from the pans or containers used <br />to accumulate the material on site; ensuring the samples included shavings produced <br />throughout the accumulation period (i.e. not just the most recent shavings). The percent by <br />weight less than 100 microns was determined by sieve analysis in general accordance with <br />ASTM Method D422. Results are presented in the table below, and laboratory analysis <br />presented as Attachment A. Additionally, the equipment present at each location is <br />documented. <br />Grain Size Analysis Results <br />Based on observations at the auto center locations and information obtained from Sears, <br />each Auto Center generates approximately 3 to 5 gallons of shavings per year. Terracon <br />determined the density of the shavings to be approximately 15 pounds per gallon; therefore <br />the generation rate is approximately 45 to 75 pounds of brake rotor shavings per year at <br />each facility. <br />Based on these sieve analysis results above, on average the amount fine powders <br />associated with the brake rotor shavings is 6.5 percent by weight. Based on the relatively <br />2 <br />Sample <br />Percent less <br />Auto Center location <br />Equipment types <br />mass <br />than 100 <br />(grams) <br />microns <br />1161 Galleria Blvd. <br />1 Bench mounted - AMMCO 6950 <br />501.5 <br />5.8 <br />Roseville, CA <br />1 Portable - Hunter OCL 400 <br />5901 Florin Road <br />1 Bench mounted - AMMCO 6950 <br />512.0 <br />2.7 <br />Sacramento, CA <br />1 Portable - Hunter OCL 400 <br />5900 Sunrise Mall <br />Bench mounted: <br />512.2 <br />6.4 <br />Citrus Heights, CA <br />1 Combo Disk & Drum - Hunter <br />4000 <br />2 Disks - Hunter 7800 <br />2 Drums - Hunter 3800 <br />1 Portable: Hunter OCL 400 <br />1601 Arden Way <br />2 Bench mounted - AMMCO 6950 <br />295.3 <br />11.0 <br />Sacramento, CA <br />1 Portable - Procut PSM 2092 <br />Based on observations at the auto center locations and information obtained from Sears, <br />each Auto Center generates approximately 3 to 5 gallons of shavings per year. Terracon <br />determined the density of the shavings to be approximately 15 pounds per gallon; therefore <br />the generation rate is approximately 45 to 75 pounds of brake rotor shavings per year at <br />each facility. <br />Based on these sieve analysis results above, on average the amount fine powders <br />associated with the brake rotor shavings is 6.5 percent by weight. Based on the relatively <br />2 <br />