Laserfiche WebLink
Recommendations: <br />A. Expertise: To assess the information at hand would require specific expertise <br />in organic chemistry and experience with tire burning. The Division does not <br />have this expertise, in house, so it falls to the operator to furnish adequate <br />information for the Division to review. <br />B. Rule 1.4.1(2) indicates that qualified persons must prepare tests and <br />analyses. This should be indicated with the next submittal. <br />C. Inorganics testing: The analyses of inorganics thus far indicate that several <br />inorganic materials in the tires report to the ash. Upon receiving an adequate <br />assessment of the organic materials analyses, the Division may establish <br />additional inorganic monitoring parameters to detect these materials in <br />groundwater. <br />D. Organics testing: The list of organic compounds that were analyzed is <br />different from CDPHE's complete list of regulated organic parameters. Some <br />of the organic parameters that were tested are not regulated, and some <br />parameters that are regulated were not analyzed. It is not clear how analytes <br />were selected for the test. The operator should explain how the analytes <br />were selected, and indicate how these analytes adequately represent the <br />conditions of the test burn. <br />E. Physical conditions: The physical conditions of the test burn would be a key <br />condition of any future monitoring. The test burn conditions should represent <br />actual conditions. These conditions should be reported if tire burn ash is to <br />be disposed on site and monitored by the Division. This might be handled in <br />separate reports or in the annual report. The operator might be advised to <br />allow flexibility in the conditions and in the relative percent of fuels used in <br />future operations. <br />F. Report: The tire burn report should describe the test burn methods and <br />parameters, including how materials were prepared, the percent of coal and <br />tires used in the test, and the degree to which this mixture and these <br />conditions represent actual plant conditions. <br />G. Technical revision: Because groundwater monitoring likely will be changed to <br />incorporate tire burn monitoring parameters, these changes should be <br />submitted under a Technical Revision to the Permit. <br />Cc: Carl Mount <br />Bruce Humphries <br />