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Since the Lyons Plant emissions data for both FF and TDF are relatively low for all these risk <br />drivers when compared to the three California cement kilns, it can be reasonably concluded <br />that the potential health risks for the Lyons plant will also fall in the same low risk range for both <br />these fuel sources that was calculated for those plants. This conclusion is reinforced by the <br />identification of no additional risk driver chemicals in either the FF or TDF emission tests for the <br />Lyons Plant that would significantly alter the risk estimate range observed at the California <br />plants. <br />Specifically, the Lyons Plant emissions tests show that the TDF emission rates for the typical <br />risk driver chemicals are in some cases higher (formaldehyde, chromium, and benzene), lower <br />(dioxins/furans), or similar (carcinogenic PAHs and PCBs) compared to FF. However, the <br />differences between TDF and FF are not significant from a human health perspective. This is <br />because the emission rates for the risk driver chemicals for both FF and TDF were extremely <br />low and the differences in emission rates were not large. Consequently, the cumulative <br />theoretical health risk estimates for the two fuels are both negligible, approximately equivalent <br />and for regulatory purposes, indistinguishable from each other. Overall then, the Lyons Plant <br />emissions tests indicate no potential for adverse public health impacts from the use of TDF <br />compared to FF. <br />4.0 Conclusions <br />The source emissions test data for the Lyons Plant indicate that the plant would remain in full <br />compliance with all its current permit requirements if it used TDF to fire its kiln. The test data <br />also show that FF and TDF emission rates are extremely low for all the primary human health <br />risk driver chemicals typically found in cement kiln emissions. This is true even with the <br />modest elevations in metal emission rates and VOCs observed with TDF. Based on all the <br />data available, it can be concluded that there will be no significant adverse human health risks <br />associated with the use of TDF at the Lyons Plant. <br />13 <br />