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Banks and Gesso, LLC <br />Samples analyzed were CKD leachates prepared using U. S. Environmental Protection <br />Agency (EPA) SW-846 Method 1312 (Synthetic Precipitation Leaching Procedure or <br />SPLP). CKD leachates developed using this procedure are assumed to contain the more <br />mobile constituents that might be leached from the disposed CKD and potentially impact <br />groundwater. The leachates were analyzed using EPA SW-846 methods. Specific <br />analytical methods used by the laboratory are listed in the results presented in Appendix <br />2. <br />7.0 CKD Test Results <br />Appendix 2 contains the full laboratory test results (Severn Trent Laboratories, Inc.). <br />This section of the report present analysis and interpretation of those results in light of <br />the Division's concern about ground water protection. <br />7.1 Coal and Natural Gas vs. Coal and Tires <br />Table 1 summarizes the laboratory test results. All detected analytes are listed and the <br />' averages of the two samples are shown (average results of 2 samples analyzed from <br />coal and natural gas CKD and 2 samples analyzed from coal and 19% tires CKD). <br />There is no significant difference in the chemistry of the CKD resulting from burning tires. <br />' The results are virtually identical. <br />The Divisions principle question was "does the burning of tires change CKD chemistry?" <br />' and the answer is clearly no. <br />Table 2 lists the constituents analyzed but not detected. It can be readily seen that the <br />number of non-detected analytes greatly exceeds the number of detected analytes and <br />that the detections are of low concentrations. <br />7.2 Comparison to Ground Water Standards <br />Table 3 lists the standards for regulated organic and inorganic ground water constituents <br />and compares them to the CKD test results. There are no significant exceedances of <br />ground water standards with or without tire burning. Given these results the CKD cannot <br />cause ground water contamination (i.e. exceedance of any standards) after disposal in <br />the quarry even if leachate is introduced into the ground water, which is unlikely anyway <br />given the geologic setting of the disposal cell and hydraulic characteristics of the <br />disposed CKD. The already low concentrations of detected analytes would be greatly <br />diluted in ground water. <br />7.3 Non Analyzed Organics and New or Different Analytes Resulting from Tire <br />Burning. <br />The only organic compounds that were not analyzed are herbicides/pesticides. The <br />rationale for this is that tires do not typically contain herbicides or pesticides. <br />Also, the results of the tire CKD tests reveal no new or different organic compounds or <br />metals than those detected in the non-tire CKD tests. <br />02053 Cemex, Inc. CKD Testlng <br />