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Banks and Gesso, LLC <br />^ 1.0 Executive Summary <br />' At the request of the Division of Minerals and Geology (DMG), cement kiln dust (CKD) <br />from Cemex's Lyons cement plant was sampled and analyzed before and during a trial <br />burn using tires as a supplemental fuel. A comprehensive list of analytes was used and <br />' the results were compared as to the chemistry of the CKD derived from coal and natural <br />gas as fuel versus coal and 19% tires as fuel. The objectives were to determine if CKD <br />chemistry changed as a result of tire burning and to insure that ground water standards <br />are not exceeded in and around the CKD disposal cell. The trial burn was specifically <br />designed to replicate operational practices. <br />' The results of the testing and analysis are as follows: <br />- There is no significant difference in CKD chemistry between coal/natural gas and <br />coal/tires used as fuel <br />' - Leachate from tire derived fuel (TDF) CKD does not exceed applicable ground <br />water standards and there were no exceedances for organic constituents. <br />- All detections were of very low concentrations. <br />- Tire derived fuel CKD will not cause ground water contamination from the <br />disposal cell. <br />' - TDF based CKD does not present a hazard to public health or the environment. <br />- Process upset conditions will not alter the findings of this report. <br />Cemex recommends that no further action is necessary concerning operational use of <br />TDF at the Lyons plant (with respect to CKD disposal). <br />2.0 Introduction and Background -History and Rationale for Tire Derived Fuel <br />Use. <br />Southwestern Portland Cement Co. (subsequently Southdown, Inc., now Cemex, Inc.) <br />received approvals for tire derived fuel (TDF) use at the Lyons plant in 1990. Those <br />approvals include a Certificate of Designation from the Colorado Department of Public <br />Health and Environment (CDPHE), air emissions permit from CDPHE, Air Quality <br />Control Division, and a Special Use permit from Boulder County. All these permits <br />remain valid today and Cemex is fully approved for TDF use. <br />Tires were used as fuel in the kiln for about Three years (from 1990 -1993). Other fuels <br />(i.e. coal and natural gas) were used from 1993 to the present, however Cemex wishes <br />to use tires as fuel again and performed a trial bum in November, 2002. Prior to the trial <br />bum the Division of Minerals and Geology (DMG) requested that cement kiln dust (CKD) <br />be sampled and analyzed both before and during the trial to determine if the tires <br />significantly changed the chemistry of the CKD. Cemex agreed with this request. This <br />report presents the results of the analysis. <br />02053 Cemex, Inc. CKD Tesgng <br />