GENERAL52958

• Permit No: M1977208
• IBM Index Class Name: General Documents
• Doc Date: 9/4/2003
• Doc Name: Transmittal of Report on Cement Kiln Dust Testing
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

Banks and Gesso, LLC
The rationale for TDF use is straightforward. TDF is an inexpensive fuel that provides
high BTU value. Waste tires are typically landfilled or placed in open piles and using
tires as fuel is a beneficial alternative for this solid waste problem. Emissions from TDF
use are no different than emissions from coal and natural gas and present no public
health hazard.
3.0 Cement Kiln Dust Management and Disposal Improvements
CKD has been disposed of continuously since the inception of the cement plant in 1969.
The CKD is and has been placed in mined-out quarry pits on the Lyons quarry property.
After 34 years of CKD disposal we are not aware of any significant impacts on surface or
ground water.
As a result of Environmental Protection Agency guidelines, the Division of Minerals and
Geology (DMG) has been regulating CKD disposal since 1999. A Technical Revision to
the mining and reclamation permit (M-77-208} was approved around that time and, as a
result, numerous improvements to the management and disposal of CKD have been
made.
Extensive laboratory testing and ground water modeling was performed ("Report on
Storage of Cement Kiln Dust, Southdown, inc. -Lyons Plant", Banks and Gesso, LLC
and Grant Environmental, Inc. June 21, 1999). The results of the testing and modeling
indicated no significant impact to ground water quality and some precautionary
monitoring of downgradient surtace water (in the A-Pit reservoir) was requested by
DMG.
pH, conductivity, thallium and selenium are the parameters that have been monitored
and no exceedances of ground water standards have occurred since the onset of
monitoring.
There are a number of additional reasons why CKD disposal would not be expected to
impact ground water at the facility. Cemex has reduced the volume of CKD requiring
disposal by 80% since 1999 (from approximately 100,000 tons per year to 20,000 tons
per year). This has been accomplished primarily by recycling the CKD back into the
manufacturing process. Elimination of the volume of solid waste generated is an
excellent management practice.
CKD is moistened in the haul trucks to prevent dusting during transport to the disposal
cell and a sprinkler system has been installed around the disposal cell itself to control
dust.
CKD (being cementitious) hardens in the disposal cell into a relatively impermeable
mass. Also, underlying the disposal cell, is approximately 500 feet of Cretaceous shales
with permeabilites in the range of 2 X 10a cm/sec to 1X 10~ cm/sec. These are
favorable conditions for ground water protection.
4.0 Lyons Cement Plant and Process Description
The Lyons plant was commissioned in 1969 and has been in continuous operation for
over 33 years producing Portland cement. Limestone, shale, and sandstone are
quarried in the Lyons area and delivered to the plant. These minerals contain the
02053 Cemex, Inc. CKD Testing 2