2003-02-07_GENERAL DOCUMENTS - M1977208

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~~ Banks and Gesso, LLC ®® ~ February 5, 2003 ~s Ha~y..~~esey; PhD Colorado Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, Colorado 80203 ,,720 Kipling St.,Suite117 Lakewood, Colorado 80215 (303) 274-4277 Fax (303) 274-8329 www. ba n ksa n d g e s so. co m Subject: Laboratory Results, Cement Kiln Dust (CKD), Samples from Before and After the Test Tire Burn, / Cemex, Inc., Lyons Cement Plant Dear Harry: `~FE~ 01.2003 Division of Minerals and Geology Please find attached a copy of the laboratory results for the CKD testing that you had previously requested. Included are two (2) complete suites of analyses from CKD sampled before tires were burned ;samples 1 and 2 dated 11/15/02) and samples taken after about 3 days of tire burning (samples 1 and 2 dated 11/21/02). As you can see from the laboratory results Cemex performed a comprehensive analysis of organic and inorganic constituents of the CKD. I have reviewed the laboratory results along with John Lohr and Steve Mossberg at Cemex, and Scott Klingensmith, at Flatirons Toxicology (whom Cemex has retained to review the air emissions test results from the test tire burn). We all agree with the opinions expressed in this letter (which are put forth below). The laboratory results from before the test tire burn and those from after tires were burned are virtually identical. The chemistry of the CKD resulting from burning 100% coal as the fuel is no different than the chemistry of the CKD resulting form burning 85% coal-15% tires as the fuel. Most of the analyzed organic compounds were not detected within the laboratory reporting limit. The organic compounds that were detected are in the low part per billion range and many are laboratory qualified. The diesel range organics detections (ranging from 380-860 mg/kg) are interpreted to be coal particles in the CKD. It is not believed that the chemistry of the CKD resulting from tire burning presents any significant threat to ground water resources in or around the disposal area, approved by the Division of Minerals and Geology.