GENERAL54107

• Permit No: M1977208
• IBM Index Class Name: General Documents
• Doc Date: 10/16/2003
• Doc Name: Review: Tire Derived Fuel Trial Burn
• From: DMG
• To: DMG
• Media Type: D
• Archive: No

DISCUSSION
In manufacturing cement, when limestone and shale aze kilned in the presence of a solid
fuel such as coal or tires, finite amounts of the feed and solid fuel report as kiln dust.
Where tires aze used as the solid fuel, materials that report include organic chemicals and
inorganics including materials from steel belts or metallic reinforcing strands. For the
operation in question, some of the kiln dust is stored permanently on site whereas a part
of it is recycled. At issue is whether the kiln dust may hazbor toxic materials in
concentrations sufficient to adversely affect groundwater.
Conditions of the tests discussed herein mimic actual operations using TDF. Those
conditions were ideal; that is, the tires were completely burned. Under non-ideal
conditions however -incomplete combustion of the TDF -toxic byproducts could form.
Some such byproducts could be water soluble and could present problems for
groundwater quality.
Incomplete burn conditions are not expected of a properly functioning kiln. Test results
for the extant case showed no problems with any of the myriad of organic constituents
that were analyzed by these tests. Thus, as long as the TDF is combusted under
conditions mimicking the test, one should not expect any of the regulated organic
constituents to appeaz in the CKD or, consequently, in groundwater.
Therefore, some remaining questions aze: What could happen if incomplete combustion
were to occur some time during operations? Could toxic chemicals be prevented from
getting into the groundwater, or could such chemicals be precluded from getting into the
CKD?
RECOMMENDATION: The evidence shows that CKD produced via tire derived fuel
would contain no organic chemicals in excess of standards. Furthermore, normal
production techniques should produce complete combustion of TDF. Therefore, it seems
inappropriate for the operator not to monitor the CKD for organic chemicals.
However, upset conditions or shutdowns cannot be precluded from possibility and
production of at least a limited amount of toxic organic materials could be expected,
depending on exactly how such an upset occurred. It would seem most prudent to have
the operator report any upset conditions. The operator should report to DMG any event
of abnormal operating conditions that might be able to produce higher levels of soluble
inorganic constituents; i.e. incomplete burns. Furthermore, materials in the system
during such an upset that might produce toxic organic materials and that might report to
the CICD during such an event should be handled separately from ordinary CKD.
Reporting procedures could be approved through as a revision to the permit. The
revision should lay out procedure for reporting to the Division. At a minimum, I think
the revision should include provisions for a written report, submitted within a week
following any upset that would not assure complete tire combustion. Such report should
include a description of the upset detailing the cause, and a description of how materials