GENERAL56368

• Permit No: M1977208
• IBM Index Class Name: General Documents
• Doc Date: 4/25/2003
• Doc Name: Tire Burning Test Results
• From: DMG
• To: DMG
• Media Type: D
• Archive: No

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STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
Date: April 25, 2003
To: Erica Crosby
From: Harry Posey
Re: Tire burning test results, Cemex lnc,
M-1977-208
Lyons Cement Plant,
Following is a review of the tire burn test results for the captioned operation.
Banks and Gesso, LLC forwarded these to the Division on February 5, 2003.
COLORADO
DIVISION OF
MINESRALS
GEOLOGY
REGLAMATION•MINING
SAFETY•s CIENCE
Bill Owens
Governor
Greg E. Walther
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
Background:
The operator has proposed to use tires as a fuel source or partial fuel source at
the cement kiln. Kiln dust containing burned tire residues presumably would be
discarded on site along with other, already permitted kiln dust. At issue is
whether ash from these fuels would produce pollutants in quantities exceeding
water quality standards. The Division, having no particular expertise in the field
of organic chemistry or the chemistry of tire burns, has instructed the operator to
seek expert assistance in developing an appropriate burn test and report back to
the Division. At this point, even though the operator has requested a final review
from the Division, the burn report, dated February 5, 2003, is incomplete.
Sampling and analysis:
The Operator prepared and submitted for analysis two samples each of kiln dust
produced from burned coal, and kiln dust produced from a mix of burned coal
and burned tires. Procedures used to produce these ash materials were not
provided with the submittal. In particular, it is not known whether the ash was
produced under conditions similar to those that would be expected during actual
operations - at a higher or lower temperatures -and, if not, whether the
procedures sufficiently mimic actual conditions. In addition, the percent of coal
and tires used in the mixtures was not noted, and again it is not evident whether
these mimic what will be actual conditions. The operator should eventually
explain the procedures and answer the above questions.
For each sample the lab produced analyses of metals and organics for a solids
sample and a leachate from an SPLP extraction (synthetic precipitation leach
Office of Office of Colorado
Mined land Reclamation Active and Inactive Mines Geological Survey