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October 14, 2019 <br />Mr. Brian Smith, P.G. <br />Environmental Compliance, EHSS <br />Bridgestone Retail Operations, LLC <br />200 4t" Avenue S. <br />Nashville, TN 37201 <br />Re: Analysis of Brake Rotor Shavings <br />Dear Mr. Smith, <br />At your request, Apex collected bulk samples of brake rotor shavings from ten (10) California Bridgestone Retail <br />Operations owned facilities. The facilities were randomly selected Firestone Complete Auto Care and Wheel Works <br />locations and split between northern and southern California. Sampling was completed for the purpose of <br />determining if the shavings fit the definition of a hazardous waste in California. Specifically, Apex had the samples <br />analyzed for hazardous content, including Title 22 metals and median particle size. <br />Apex utilized the Federal Resource Conservation and Recovery Act (RCRA) and California Title 22 hazardous waste <br />criteria to determine if the content of the shavings designated them as a hazardous waste. In addition, the <br />Department of Toxic Substances Control (DTSC) defines any fine metallic powder with a diameter of less than 100 <br />microns as a hazardous waste, unless it can be tested and shown to be otherwise by a state -certified laboratory. <br />Apex collected four -ounce bulk samples from ten locations, including: <br />Northern California <br />Southern California <br />122173 — Mountain View <br />650153 <br />— Costa Mesa <br />241048 — San Ramon <br />023116 — <br />Moreno Valley <br />012637 — San Francisco <br />019992 — <br />Fountain Valley <br />029947 - Salinas <br />017671 <br />—Chula Vista <br />022845 — San Jose <br />020451 <br />— San Diego <br />The ten bulk samples were composited into one large sample and submitted to Enthalpy Analytical, LLC in Orange, <br />California for Total Threshold Limit Concentration (TTLC), Soluble Threshold Limit Concentration (STLC), and <br />particle size analysis under standard chain of custody. Enthalpy is California -certified and a National <br />Environmental Laboratory Accreditation Program (NELAP) — accredited laboratory. <br />WATER RESOURCES • ENVIRONMENTAL SERVICES • INDUSTRIAL HYGIENE • SAFETY • AIR QUALITY • SUSTAINABILITY AND CLIMATE CHANGE <br />Apex Companies, LLC • (800) 733-2739 • www.apexcos.com <br />