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GENERAL52958
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Last modified
8/24/2016 8:38:39 PM
Creation date
11/23/2007 8:13:04 PM
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Template:
DRMS Permit Index
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
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Banks and Gesso, LLC <br />I' 8.0 Impact on Human Health and The Environment <br />' The results of the CKD laboratory analyses indicate no potential for adverse impacts <br />from either fossil fuel (FF) ortire-derived fuel (TDF) CKD on public health under the <br />current management scheme for this material at the CEMEX facility in Lyons, CO. This <br />conclusion is based on the following observations: <br />No significant difference in leachate analvtes for either type of CKD <br />The analytical results for the leachates derived from FF and TDF CKD are quite similar. <br />Less than a dozen organic constituents were identified and reliably quantified in the <br />leachates from the two types of CKD. These constituents, all simple hydrocarbon <br />compounds, are identical for both CKD types, and include napthalenes, <br />trimethylbenzenes, short-chain ketones, and diesel range organics. <br />' In general, the concentrations of these chemicals were slightly higher in the leachate <br />from the FF-derived CKD. Whether these differences were statistically significant or not <br />cannot be ascertained because there only two samples for each type of CKD. In any <br />' event, it is clear that TDF generally did not increase the concentrations of these <br />chemicals in the CKD. <br />' The only exception to this apparent trend was the chemical 4-methyl-2-pentanone, also <br />known as methyl isobutyl ketone (MIBK). This chemical appeared to be elevated in the <br />TDF CKD samples (average 31 ppb vs. 4.2 ppb). However, this difference is of no public <br />' health significance because the concentration is so low and because this chemical is <br />nearly non-toxic, as discussed below. No metals were detected in the leachate and <br />radioactivity levels were similar for both types of CKD. <br />Concentrations of organic constituents are extremely low <br />Concentrations of organic constituents in both leachates are low and range from the low <br />parts-per-billion (ppb) for the volatile organic chemicals (VOCs) to the mid parts per <br />million for the diesel range organics. These concentrations are well below all available <br />state and federal water standards. For example, the ground water standard for xylenes <br />is 10,000 ppb, which is approximately 200 times higher than the leachate concentrations <br />measured from either CKD sample. <br />Chemicals identified in the leachate exhibit low toxicity <br />Generally, these chemicals would be expected in a SPLP leachate test for a fossil fuel <br />sample(coal, oil, kerogen, etc.) These chemicals are all non-carcinogenic compounds <br />that exhibit relatively low toxicity in animal and human studies. Even though <br />environmental regulatory criteria may not exist for all the chemicals, there is sufficient <br />toxicology information available to make an initial public health assessment. For <br />example, one of the chemicals, 4-methyl-2-pentanone, is used in a variety of human <br />foods and beverages as a flavoring agent at levels as high as 10,000 ppm, so clearly, <br />this chemical is unlikely to be toxic at 30 ppb. Similar analyses and considerations apply <br />to all of the organic constituents measured in the two leachates. <br />02053 Cemex, Inc. CKD Testlng 6 <br />
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