Laserfiche WebLink
Banks and Gesso, LLC <br />It is important from a human health risk assessment perspective to recognize that the <br />SPLP test is intended as a rigorous screen to test the leachability of chemicals from a <br />material of interest. The results are typically not intended to be directly compared to <br />criteria for environmental media like soil and water, except in perhaps in a qualitative or <br />screening level fashion. The concentrations of the leachate chemicals, already below all <br />available regulatory criteria, would be orders of magnitude lower when extrapolated to a <br />ground water concentration. This means that the already negligible risks would be even <br />lower by a similar amount, <br />In summary, the chemicals identified in the CKD leachates are low toxicity hydrocarbons <br />typically associated with fossil fuels. There are no significant differences in chemical <br />constituents or concentrations in the leachates caused by the use of tire-derived fuel. <br />The leachate concentrations are extremely low and are of no concern from a public <br />health perspective. <br />9.0 Conclusions and Recommendations <br />Based on the findings contained in this report Cemex concludes the following: <br />- Tire derived fuel use at the Lyons cement plant is a safe and beneficial use of <br />waste tires. <br />- CKD disposal at the site has been greatly improved in recent years and <br />management of this solid waste is appropriate and practical. <br />- No known ground water impacts have occurred in over 33 years of CKD disposal <br />- Laboratory testing of CKD resulting from buming tires as fuel (approximately 19% <br />tires and 81 % coal) revealed no significant difference in chemistry as compared <br />to CKD resulting from using coal and natural gas as fuel. <br />- Leachate from CKD resulting from tine buming did not exceed applicable ground <br />water standards except for pH and sulfate. There were no exceedances for <br />organic constituents. <br />- Disposal of TDF based CKD will not cause ground water contamination. <br />- Disposal of TDF based CKD does not present a hazard to human health or the <br />environment. <br />- Process upset conditions will not alter the findings of this report. <br />Therefore, Cemex recommends that no further action is required concerning CKD <br />management and disposal, if and when TDF use becomes operational at Lyons. <br />02053 Cemex, Inc. CKD Testing <br />