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Mr. Brian Smith, Bridgestone Retail Operations October 14, 2019 <br />Analysis of Brake Rotor Shavings Page 2 <br />Enthalpy analyzed the composite sample by TTLC analysis and reported that none of the analytes eclipsed <br />regulated TTLC thresholds. However, industry standard is to further analyze any analytes containing >_10x <br />identified STLC thresholds. Analytes identified to contain >_10x the STLC threshold included: Cadmium, <br />Chromium, Copper, and Nickel. Enthalpy further analyzed the four analytes by STLC analysis and reported that all <br />four were below regulated STLC thresholds. Therefore, the shavings do not contain any regulated levels of <br />hazardous metals as regulated by the EPA and State of California. <br />In addition to testing for metals, Enthalpy also analyzed the particle size to determine if the material is regulated <br />as a fine dust. Metallic particles of less than 100 microns in size are regulated in California as a fine dust and cannot <br />be recycled as scrap metal. Enthalpy performed the particle size analysis, as directed by ASTM D422-63, and <br />reported that the median particle size of the bulk sample was 331.083 microns. <br />In summary, Enthalpy Labs reported that the bulk sample did not contain any analytes that eclipsed regulated <br />STLC waste thresholds and the median particle size is more than 3x the 100 -micron limit for fine dust in California. <br />Therefore, Apex concludes that the brake rotor shavings are not a hazardous waste in California. <br />Thank you for allowing Apex to continue to service your environmental needs. If you have any questions, <br />please call me at (858)-558-1120. <br />A <br />APEX <br />Enthalpy Analytical Results — Brake Rotor Shavings Composite Sample <br />Analyte <br />TTLC Result (mg/kg) <br />TTLC Threshold (mg/kg) <br />STLC Result (mg/L) STLC Threshold (mg/L) <br />Antimony <br />29.0 <br />500 <br />N/A <br />N/A <br />Arsenic <br />22.2 <br />500 <br />N/A <br />N/A <br />Barium <br />62.5 <br />10,000 <br />N/A <br />N/A <br />Beryllium <br />ND <br />75 <br />N/A <br />N/A <br />Cadmium <br />22.6 <br />100 <br />0.314 <br />1.0 <br />Chromium <br />1,160 <br />2,500 <br />4.55 <br />5 <br />Cobalt <br />35.8 <br />8,000 <br />N/A <br />N/A <br />Copper <br />1,880 <br />2,500 <br />ND <br />25 <br />Lead <br />48.6 <br />1,000 <br />N/A <br />N/A <br />Molybdenum <br />100 <br />3,500 <br />N/A <br />N/A <br />Nickel <br />314 <br />2,000 <br />ND <br />20 <br />Selenium <br />ND <br />100 <br />N/A <br />N/A <br />Silver <br />ND <br />500 <br />N/A <br />N/A <br />Thallium <br />ND <br />700 <br />N/A <br />N/A <br />Vanadium <br />104 <br />2,400 <br />N/A <br />N/A <br />Zinc <br />82.0 <br />5,000 <br />N/A <br />N/A <br />Mercury <br />ND <br />20 <br />N/A <br />N/A <br />In addition to testing for metals, Enthalpy also analyzed the particle size to determine if the material is regulated <br />as a fine dust. Metallic particles of less than 100 microns in size are regulated in California as a fine dust and cannot <br />be recycled as scrap metal. Enthalpy performed the particle size analysis, as directed by ASTM D422-63, and <br />reported that the median particle size of the bulk sample was 331.083 microns. <br />In summary, Enthalpy Labs reported that the bulk sample did not contain any analytes that eclipsed regulated <br />STLC waste thresholds and the median particle size is more than 3x the 100 -micron limit for fine dust in California. <br />Therefore, Apex concludes that the brake rotor shavings are not a hazardous waste in California. <br />Thank you for allowing Apex to continue to service your environmental needs. If you have any questions, <br />please call me at (858)-558-1120. <br />A <br />APEX <br />