TIRE DERIVED FUEL: PRIVATE  

ENVIRONMENTAL CHARACTERISTICS AND PERFORMANCE

Presented by

Terry Gray, President

T.A.G. Resource Recovery

at

The First Northeast Regional Scrap Tire Conference

Albany, New York

June 15, 2004

PERSPECTIVE

	In an ideal world, we would endlessly recover and reuse all resources -
and we would do so without detrimental impact on our environment. 
However, we have significant differences of opinion about practical
compromises required in today's real world.  Some are fixed on achieving
the ideal "perpetual recycling" objective and are unwilling to support
interim compromises for fear of jeopardizing achievement of the ultimate
objective.  Others recognize the value of resources conserved through
interim steps and believe that these steps contribute to the evolution
of even greater conservation.

	This debate has impacted virtually all "waste" materials, including
scrap tires.  Tires represent a significant resource.  Ideally, a tire's
polymerized rubber mixture would be perpetually reused.  However,
today's applications for this material consume less than 15% of the
waste tires generated annually in North America.  These markets are
growing slowly in spite of intense market development efforts, and even
the most optimistic projections show less than 30% utilization in 5
years.  

	Unless other applications are embraced and developed, the remainder of
this resource will be squandered through landfilling or become a
stockpiled public liability posing public health and environmental
hazards.  Since no one consciously wants to waste a valuable resource,
other applications that are compatible with our environment should be
developed.  Avoiding unnecessary consumption of natural energy resources
through alternative use of waste tires is a worthy objective if it can
be done without a counter-balancing negative impact on our environment. 
For perspective, the following sections examine chemical characteristics
and historical environmental experience of waste tires as an energy
resource.

	CHEMICAL CHARACTERISTICS OF SCRAP TIRES

	The chemical characteristics of any energy resource impact its
environmental acceptability.  Tires are a hydrocarbon-based material
derived from oil and gas.  Some inorganic materials are added to enhance
reactions or performance properties.  Tires have a heat content of 7,800
to 8,600 kcal/kg (14,000 to 15,500 Btu/pound), depending on the type of
tire and degree of wire removal.  By comparison, coal that may be
displaced by use of tires typically contains 5,550 to 7,200 kcal/kg
(10,000 to 13,000 Btu/pound).   

	The composition of tires and coal vary depending on type and source. 
However, Exhibit 1 provides representative proximate and ultimate
analyses of tire-derived fuel (TDF) with 90+% of the reinforcing wire
removed and a bituminous eastern US steam coal.   Proximate analysis
defines basic combustion characteristics.  Ultimate analysis defines
elemental composition.

	A comparison of the proximate analyses indicates that tires offer
efficiency advantages versus coal.  For instance, tires generally have
lower moisture content than coal.  Since energy required to heat and
vaporize inherent water is generally non-recoverable in the energy
conversion process, lower moisture content can translate into higher
energy utilization efficiency.  Lower ash content of TDF (without wire)
offers a similar advantage versus coal.  A tire's higher
volatile-to-fixed carbon ratio enhances its ability to combust rapidly
and completely.  Based on proximate analysis, tires compare favorably to
coal as an energy source.

	

	Based on ultimate analysis, tires offer some additional advantages and
disadvantages.  When compared to many eastern coals, TDF's lower sulfur
content (especially in terms of pounds/million Btu) offers the potential
advantage of decreasing SOx emissions.  However, many western coals have
lower sulfur content. 

	TDF has a lower carbon-to-hydrogen ratio, theoretically reducing carbon
dioxide greenhouse gas generation since hydrogen converts to water in
the combustion process.  Lower inherent nitrogen content can marginally
decrease NOx emissions.  

	The chlorine content of tires is higher in this specific example, but
it is comparable to many coals.  In addition, the chlorine content has
been significantly reduced in many newer tires as the chlorinated butyl
inner liner has been replaced by alternative materials.

	Elemental ash analysis provided in Exhibit 2 indicates that tires
generally contain metal concentrations comparable to, or lower than,
coal with one notable exception.  Zinc oxide is added to tires as part
of the rubber vulcanization process at levels approaching 1.0 - 1.5% by
weight.  Therefore, zinc levels in tires are much higher than coal. 
Applications using tires as an energy resource must be able to control
zinc emissions to avoid a negative environmental impact.

	From a chemical standpoint, tires offer both environmental advantages
and disadvantages versus coal.  Therefore, tires must be used in
applications that utilize their advantages and properly control their
disadvantages for them to provide a valuable and
environmentally-friendly energy resource.

	HISTORICAL ENVIRONMENTAL PERFORMANCE

	Background

	Scrap tires have been utilized as a supplemental energy source in
Japan, Europe and the United States since the 1970s.  The experience
base has increased significantly during the last 10 - 15 years as tires
have been recognized as an acceptable fuel for some combustion
processes.  Applications using scrap tires have broadened to include
cement kilns, industrial boilers, traditionally-conservative utilities
and dedicated electrical generation facilities.  The following
discussion provides examples of demonstrated environmental performance
for major applications.

	Pulp and Paper Industry

	The pulp and paper industry combusts bark and waste wood in
stoker-fired boilers to provide steam and power required for processing
operations.  Wood is combusted on moving grates that also transport
residual ash from the boiler.  Coal, oil or gas can be fired into the
boiler above the grate to enhance combustion and maintain operating
temperatures, especially when waste wood moisture content is high from
rain.

	This application utilizes tire derived fuel (TDF) obtained by
processing scrap tires into uniform, flowable chips less than 2 inches
by 2 inches in size.  Bead wire is often removed magnetically to avoid
fouling of grates and ash handling systems.  TDF can be introduced
separately or as an integral part of the wood mixture with relatively
simple, inexpensive metering systems.  TDF's high volatile carbon
content enhances combustion of wood on the grate and improves fuel
efficiency.

	The environmental impact associated with use of TDF in this application
is dependent upon characteristics of the displaced fossil fuel and
system environmental control equipment.  The two predominant factors
controlling environmental acceptability are SOx and particulate (zinc
oxide) emissions.  SOx emissions may decrease if TDF displaces coal or
oil with higher sulfur content.  Alternatively, SOx can be controlled by
scrubbers present in some systems, especially if the scrubbers operate
at a neutral or basic pH.  Particulate emissions can be controlled by
electrostatic precipitators (ESPs) or baghouses.  In general, many
environmentally acceptable applications occur when coal is displaced in
systems with baghouses or ESPs.

	Based on data compiled by the Rubber Manufacturers Association, 17 U.S.
paper mills used approximately 26 million scrap tires as TDF in 2003 in
compliance with applicable regulations, and others are undertaking
testing.  Usage has fluctuated, but high cost of fossil fuels has led to
a significant resurgence in TDF usage in paper mills as new mills have
completed environmental testing and existing users have maximized
consumption, especially in southeastern facilities.  Usage during 2004
is expected to exceed 30 million waste tires 

	The International Paper facility in Bucksport, Maine has been one of
the largest users of TDF since 1990.  Their boiler is capable of
consuming up to 3.5 tons of TDF per hour (14.5% by heat input) to
produce almost 500,000 pounds of steam per hour. 

	Exhibit 3 provides environmental data associated with performance
testing conducted at this site.  A baseline test was conducted using
their normal mixture of gas, bark, coal and sludge.  TDF was then
substituted for coal at levels representing 6.3%, 10.3%, and 14.5% of
heat input.  At the maximum TDF level, NOx, SOx and total hydrocarbon
emissions remained virtually unchanged, while particulate matter
increased 6%.  Among the metals, beryllium and chromium decreased, lead
remained below detection limits and cadmium increased.  Zinc increased
significantly percentage-wise, but total quantities remained acceptable.
 Overall particulate emissions remained well within acceptable limits.

	Performance data has also confirmed environmental acceptability of TDF
in similar paper mills and industrial boilers in 20 states.  Several of
these states (including Oregon, Washington, California and Florida) are
recognized for their environmental sensitivity and rigorous regulatory
enforcement.  However, these applications must be carefully screened to
define facilities capable of using TDF within environmentally acceptable
limits.  Only a small percentage of industrial boilers have the required
combination of system design, permitting conditions and fuel usage
conducive to appropriate TDF usage.

	Public Utility Boilers

	During 2003, there were at least 29 industrial and utility facilities
consuming the equivalent of 40 million tires according to RMA.  This
industry segment continues to increase with additional growth projected
in the future. 

	TDF can only be used efficiently in specific types of utility boilers
(primarily cyclone, fluidized-bed and stoker-grate units) offering
adequate retention time for complete combustion of nominal 1 inch (minus
2 inch) TDF.  This is the smallest TDF material that can generally be
produced at costs competitive with coal and other fossil fuels.  These
units consume large quantities of fuel, so small percentages of TDF
(2-4%) can use up to 5,000,000 tires/year in a single boiler. 

	Several factors influence use of TDF in the utility industry,
including:

 (1)	Canada and the United States executed agreements designed to reduce
the impact of acid rain through mandatory reductions in SOx emissions. 
Major coal-fired utilities using Midwestern and eastern coals have been
under intense pressure to achieve mandatory reductions at minimal cost
to their customers.  They are faced with purchasing expensive low-sulfur
coal or making substantial capital investments in additional air
pollution control equipment.  As a direct result, conservative utilities
have begun to recognize the potential value of TDF as an alternative
fuel with a lower sulfur content than some local coal.  Use of TDF
offers an opportunity to concurrently reduce both SOx emissions and fuel
costs, while providing a partial solution to historical scrap tire
disposal and stockpiling problems.

 (2)	Deregulation of utilities has been a double-edged sword in terms of
TDF usage. Some older marginal units that were using TDF have been shut
down, decreasing TDF usage.  However, more utilities are considering TDF
usage as a method of cost reduction in an extremely competitive
environment.  In addition, new fluidized bed boilers have begun to use
TDF with outstanding environmental performance.

 (3)	The Clean Air Act Amendment has not yet been fully developed, but
it could significantly impact all facilities using solid fuels.  It
could force conversion to oil and gas as an alternative to expending
millions of dollars to achieve conformance on existing coal fuel. 
Depending on the final form of this regulation, all solid fuels,
including TDF, could be negatively impacted. 

	TDF usage in utility cyclone boilers is expanding.  Pulverized coal is
introduced tangentially into a large cylindrical chamber and combusted,
with ash falling into a fluid collection system at the bottom.  TDF must
generally meet stringent size restrictions (minus 2 inches in all
dimensions, averaging 1 inch or less) to enhance complete combustion and
material handling through coal systems.  

	Otter Tail Power Company has been using up to 60,000 tons of TDF per
year at its plant in Big Stone, South Dakota.  TDF has reportedly proven
to enhance combustion control and efficiency when added to their primary
low-Btu lignite fuel.  The facility operates in compliance with all
applicable regulations, but detailed data is not available.

	Wisconsin Power and Light has conducted extensive tests using TDF as a
supplemental fuel in its cyclone boiler at Beloit.  The system has an
ESP for particulate control.  Comparative criteria pollutant data is
provided in Exhibit 4.  Particulate, SOx, hydrochloric acid and
hydrofluoric acid concentrations decreased with use of 7% TDF. However,
NOx, CO and hydrocarbons increased, but remained within applicable
permit limits.  WP&L constructed its own TDF processing facility based
on economics and supply considerations, but encountered initial
difficulty in achieving production expectations.  In addition to these
examples, TVA and Illinois Power have conducted extensive trials and are
using TDF in cyclone boilers.  

	Circulating fluidized bed boilers represent one of the newer systems
designed to minimize environmental impact from use of solid fossil
fuels.  High turbulence and uniform heat distribution allow fluidized
beds to operate at lower temperatures to minimize NOx formation. 
Ammonia injection may also be used for supplemental NOx reduction. 
Limestone is commonly used as the circulating bed media, providing
efficient SOx control through integral mixing with combustion gases. 
Sophisticated baghouses and/or electrostatic precipitators provide
particulate removal.  

	These systems represent environmentally-viable candidates for use of
nominal 1-inch TDF.  Stockton Cogen in Stockton, California conducted
extensive trials with financial assistance from the California
Integrated Waste Management Board to define the emissions
characteristics associated with use of up to 20% TDF (by heat).  The
results of this analysis are compared to the facility's pre-existing
lower (state or local) permit limit in Exhibit 5.  All emissions were
well within permit limits, with particulate and hydrocarbons being less
than 25% of established limits.

	Tires have even been used as a primary fuel in dedicated, specially
designed power boilers in California and Connecticut using 5 million and
10 million tires per year, respectively.  After some initial
difficulties associated with scale up of this technology, these
facilities have reportedly operated in compliance with strict new-source
performance criteria.  The Connecticut facility is still operating, but
the California plant has been shut down due to economic and political
factors associated with a major fire (initiated by a lightening strike
during a storm) in an adjacent stockpile that was being abated by
supplying tires to the facility. 

	Cement Kilns

	Scrap tires have been used as a supplemental fuel in cement kilns in
Europe and Japan since the 1970s and currently represent the largest
application in North America.  Only Calvaras Cement in California
consumed waste tires 15 years ago.  In 2003, 42 facilities used whole
tires or TDF as a supplemental energy source in 62 kilns, consuming 53
million waste tires according to RMA.  Others are conducting performance
tests targeted at future use. 

	

	Some factors impacting current interest in scrap tires as a
supplemental energy source in kilns deserve mention:

Logistics - Kilns are often located near market population centers with
large waste tire quantities and difficult tire disposal problems,
providing efficient logistics.

Energy Intensity - Kilns are energy intensive, allowing consumption of
500,000 - 1,500,000 million tires/year/kiln.  TDF energy cost savings
versus fossil fuels can provide a competitive economic advantage. 

Rigorous Combustion Conditions - A unique combination of high
temperatures, long residence times and turbulent air flow promote
complete combustion of organic compounds contained in tires.

Inherent SOx Control - Limestone used in cement manufacture is commonly
used in APC systems to absorb SOx, providing inherent SOx control.  

Ash Utilization - Ash resulting from tire combustion becomes an integral
component of the cement product, eliminating ash disposal requirements.

Steel Use - Reinforcing wire is constructively consumed as a replacement
for purchased natural resources or alternative materials containing
iron.

Broad Applicability - Demonstrated technology allows use of tires in
older long kilns, as well as newer preheater and precalciner units. 
Many kilns use whole tires without additional processing.  

	

	Although these factors encourage use of tires as a supplemental fuel in
kilns, demonstrated performance is a critical consideration in
establishing environmental acceptability of this application.  Extensive
environmental data has been generated for a variety of kiln
configurations and fuel displacements.  Time limitations preclude
discussion of all available data, but several examples are included.    
    

	Exhibit 6 provides comparative data resulting from comprehensive tests
conducted by Florida Crushed Stone.  TDF representing 14% energy
displacement was introduced into the riser section of their preheater
kiln.  Particulate and SOx emissions declined with TDF use.  Volatile
organics increased but semi-volatile organics decreased by an even
greater margin, resulting in a net reduction in organic emissions. 
Changes in metal concentrations were nominal.  Comprehensive testing of
dioxins and furans showed a net reduction of over 50% with TDF use. 
Florida Crushed Stone is currently using approximately 800,000 scrap
tires per year as an alternative energy source in full compliance with
all applicable regulations.

	Performance results for Ashgrove Cement's kiln in Durkee, Oregon are
provided in Exhibit 7.  Emissions of particulate, SOx, chlorides and all
heavy metals declined or remained constant.  Total hydrocarbons
increased about 10%, but polynuclear aromatics declined about 10%.  This
facility completed a comprehensive PSD review associated with its use of
other waste fuels, and is fully permitted for waste tire usage.  This
plant's performance is accepted in one of the most
environmentally-sensitive states in the U.S.  

	Several of the southwestern cement plants have undergone extensive
testing.  Results of California Portland Cement Company's emissions
results for its Colton plant are summarized in Exhibit 8.  Some criteria
decreased with use of tires, while others increased.  For example, total
particulate increased less than 10%, while non-methane hydrocarbons
decreased about 18%.  Recognized carcinogens like benzene and toluene
decreased.  Total PCDD/PCDF materials increased nominally in quantity. 
Most PCBs and PAH's declined with tire usage, while hydrochloric and
hydrofluoric acids increased.  Hexavalent chromium, barium, cadmium lead
and nickel emissions declined, while zinc and mercury increased.  While
the most critical impact will probably depend upon the reviewer's
perspective, most changes were relatively minor and the net impact
appears to be relatively balanced.

	In order to place these relative impacts into a technically-structured
perspective, Cal Portland engaged an experienced contractor to conduct a
comparative Health Risk Assessment using the latest versions of the ISC
dispersion model and ACE health effects model specified by the
California EPA.  Based on this evaluation, the individual carcinogenic
risk declined 47% with TDF usage, while the non-carcinogenic health
effects resulting from short-tern exposure (acute hazard index) fell 94%
and the non-carcinogenic health effects of continuous exposure (chronic
health impact) decreased 72%.  None of us like to contemplate any
exposure, and some may even question the assessment methodology, but
most of us prefer reductions like those demonstrated at Cal Portland.

	Cement kilns constructively utilize more waste tires than any other
single application.  Kilns are an important component of waste tire
management in most states considered to have successful programs.  Any
state that is not fully utilizing its waste tire resource may wish to
objectively evaluate the environmental and economic merits of this
application.

	SUMMARY

	Scrap tires can be an environmentally-compatible alternative energy
resource when used in appropriate applications.  Energy utilization is
an important component of successful scrap tire management programs
within the U.S., allowing this resource to be used rather than wasted. 
The net result has been substantial conservation of non-renewable fossil
fuels.  When the demonstrated performance of tires as an energy resource
is objectively evaluated, many jurisdictions have concluded that our
environment is better served by recognizing the value of this resource
rather than wasting it while waiting for ideal solutions.  Good programs
recognize the importance of diverse applications.

Acknowledgement:  This document was written by Terry Gray, President of
T.A.G. Resource Recovery, with guidance and peer review from EPA and
industry members of the EPA RCC TDF Subcommittee.

EXHIBIT 1









COMPARATIVE CHEMICAL CHARACTERISTICS













CHARACTERISTIC	EASTERN BITUMINOUS COAL	 TDF    (90+% WIRE FREE)

 

 

PROXIMATE ANALYSIS (% AS RECEIVED)

 

 

 	 	 

MOISTURE	7.76	0.62

ASH	11.05	4.78

VOLATILE	34.05	66.64

FIXED CARBON	47.14	27.96

  TOTAL	100.00	100.00

 	 	 

 

 

ULTIMATE ANALYSIS (% AS RECEIVED)

 

 

 	 	 

CARBON	67.69	83.27

HYDROGEN	4.59	7.09

NITROGEN	1.13	0.24

SULFUR	2.30	1.83

ASH	11.05	4.78

MOISTURE	7.76	0.62

OXYGEN (by difference)	5.48	2.17

  TOTAL	100.00	100.00

 	 	 



EXHIBIT 2









ELEMENTAL METALS ANALYSIS

(%, OXIDE FORM)









ELEMENT (OXIDE)	EASTERN BITUMINOUS COAL	TDF (90+% WIRE FREE)

 	 	 

Aluminum	2.29	<0.01

Barium	 -	nd

Cadmium	 -	0.0006

Calcium	0.36	0.378

Chromium	 -	0.0097

 	 	 

Iron	2.09	0.321

Lead	 -	0.0065

Magnesium	0.08	<0.01

Manganese	 -	<0.01

Phosphorous	0.07	<0.01

 	 	 

Potassium	0.22	<0.01

Titanium	0.09	<0.01

Silicon	5.30	0.516

Sodium	0.05	<0.01

Strontium	 -	<0.01

Zinc	0.01	1.52

 	 	 

Chloride	 -	0.149

Fluoride	 -	0.001

 	 	 





EXHIBIT 3





	COMPARATIVE EMISSIONS 

INTERNATIONAL PAPER MILL

BUCKSPORT, MAINE





	(EXPRESSED AS POUNDS/MM BTU)





















CRITERIA	BASELINE	14.5% TDF (BY HEAT)	PERCENT CHANGE

 	 	 	 

N O x	0.274	0.273	0

S O x	0.508	0.51	0

PARTICULATE	0.053	0.056	6

TOTAL HYDROCARBONS	1.17 E-3	1.18 E-3	1

 	 	 	 

BERYLLIUM	1.06 E-6	0.73 E-6	-31

CADMIUM	0.60 E-6	0.78 E-6	30

CHROMIUM	12.1 E-6	6.36 E-6	-47

LEAD	<10 E-6	<10 E-6	0

ZINC	0.26 E-3	2.56 E-3	885

 	 	 	 





EXHIBIT 4 













COMPARATIVE EMISSIONS 

FROM A CYCLONE BOILER

WISCONSIN P&L

























CRITERIA	UNITS	BASELINE	7% TDF (BY HEAT)	PERCENT CHANGE

 	 	 	 	 

N O x	LB/MM BTU	0.79	0.91	16

S O x	LB/MM BTU	1.14	0.87	-34

PARTICULATE	LB/MM BTU	0.52	0.14	-73

 	 	 	 	 

CO	LB/HR	1.52	7.26	377

TOTAL HYDROCARBONS	LB/HR	5.16	10.27	99

 	 	 	 	 

HCL	LB/HR	25.27	19.89	-23

HF	LB/HR	1.86	1.34	-28

 	 	 	 	 





EXHIBIT 5 









EMISSIONS FROM A 

CIRCULATING FLUIDIZED BED BOILER





STOCKTON COGEN

(STOCKTON, CALIFORNIA)









(EXPRESSED AS POUNDS/HOUR)













CRITERIA	20% TDF        (BY HEAT)	LOWER PERMIT LIMIT

 	 	 

N O x	25.06	39.00

 	 	 

S O x	33.40	59.20

 	 	 

PARTICULATE	2.19	10.00

 	 	 

CO	20.90	22.90

TOTAL HYDROCARBONS	<0.38	1.88

 	 	 





EXHIBIT 6





ENVIRONMENTAL PERFORMANCE DATA

TDF INTRODUCTION INTO THE RISER SECTION

OF FLORIDA CRUSHED STONE'S PREHEATER KILN 

(expressed as pounds/hour)





CRITERIA	BASELINE	14% TDF

PARTICULATE	56.80	52.21

 	 	 

S O x	595.15	551.30

 	 	 

VOLATILE ORGANICS	 	 

  Acetone	0.02	0.02

  Benzene	0.08	0.15

  Toluene	0.01	0.20

  Chloromethane	<0.01	0.03

  Others	<0.03	0.04

    TOTAL	0.15	0.44

 	 	 

SEMI-VOLATILE ORGANICS (C16-C18)	5.01	0.90

 	 	 

METALS	 	 

  Aluminum	6.86	8.13

  Arsenic	<0.004	<0.004

  Barium	0.02	0.02

  Cadmium	<0.005	0.01

  Chromium	0.02	0.01

  Cobalt	0.01	<0.002

  Copper	0.03	0.03

  Iron	1.39	1.30

  Lead	0.13	0.04

  Magnesium	0.50	0.55

  Mercury	0..04	0.01

  Molybdenum	0.02	0..02

  Nickel	<0.02	<0.02

  Selenium	<0.004	<0.004

  Silver	<0.009	<0.009

  Titanium	0.22	0.26

  Vanadium	<0.02	<0.02

  Zinc	3.12	1.68



EXHIBIT 6   (CONTINUED)







	ENVIRONMENTAL PERFORMANCE DATA

TDF INTRODUCTION INTO THE RISER SECTION

OF FLORIDA CRUSHED STONE'S PREHEATER KILN 

(expressed as pounds/hour)







	CRITERIA	  	AVG EMISSION RATE (10 E-6 LBS/HR)	EQUIV 2378-TETRA DIOXIN
EMISSIONS (10 E-6 LBS/HR)

	 	COAL	14% TDF	COAL	14% TDF

DIOXINS	 

 	 	 

  2378-tetra	1.00000	0.004	ND	0.004	ND

  12378-penta	0.50000	0.035	ND	0.017	ND

  123478-hexa	0.04000	0.048	ND	0.002	ND

  123789-hexa	0.04000	0.084	ND	0.003	ND

  123678-hexa	0.04000	0.125	ND	0.005	ND

  1234678-hepta	0.00100	1.210	0.062	0.001	<0.001

  octa	0.00000	5.221	1.100	0.000	0.000

  other tetra	0.01000	0.308	0.061	0.003	0.001

  other penta	0.00500	0.473	0.079	0.002	<0.001

  other hexa	0.00040	0.766	0.114	<0.001	<0.001

  other hepta	0.00001	1.693	0.114	<0.001	<0.001

    SUBTOTAL	 	9.667	1.530	0.037	0.001

 	 

 	 	 

FURANS	 

 	 	 

  2378-tetra	0.10000	0.096	0.061	0.010	0.006

  12378-penta	0.10000	0.024	ND	0.002	ND

  23478-penta	0.10000	0.036	ND	0.004	ND

  23478-hexa	0.01000	0.048	ND	<0.001	ND

  123678-hexa	0.01000	0.024	ND	<0.001	ND

  234678-hexa	0.01000	0.024	ND	<0.001ND	 

  123789-hexa	0.01000	ND	ND	ND	ND

  234678-hepta	0.00100	0.060	ND	<0.001	ND

  234789-hepta	0.00100	ND	ND	ND	ND

  octa	0.00000	0.048	ND	0.000	ND

  other tetra	0.00100	0.204	0.149	<0.001	<0.001

  other penta	0.00100	0.130	0.088	<0.001	<0.001

  other hexa	0.00010	0.006	0.009	<0.001	ND

  other hepta	0.00001	0.072	ND	<0.001	ND

    SUBTOTAL	 	0.883	0.307	0.017	0.006

 	 

 	 	 

TOTAL  (10E-6 LB/HR)	 	10.550	1.837	0.054	0.007



EXHIBIT 7













ENVIRONMENTAL PERFORMANCE DATA

TDF INTRODUCTION INTO RISER SECTION

OF ASHGROVE CEMENT'S PREHEATER KILN

























CRITERIA	UNITS	BASELINE	9-10% TDF	PERMIT LIMIT

 	 

 	 

PARTICULATE	lbs/hr	5.27	4.83	18

 	 

 	 

S O x	lbs/hr	<1.5	<1.2	6.3

 	 

 	 

CHLORIDES	lbs/hr	0.268	0.197	NA

 	 

 	 

TOTAL HYDROCARBONS	lbs/hr	3	3.3	NA

 	 

 	 

PNA	lbs/hr	0.0058	0.0053	NA

 	 

 	 

HEAVY METALS	 

 	 

  Arsenic	micrograms	0.2	0.2	NA

  Cadmium	"	3	2	NA

  Chromium	"	30	ND	NA

  Nickel	"	30	ND	NA

  Zinc	"	35	35	NA

  Copper	"	37	13	NA

  Lead	"	ND	ND	NA

  Iron	"	400	200	NA

  Barium	"	ND	ND	NA

  Vanadium	"	ND	ND	NA

 	 	 	 	 





EXHIBIT 8





	ENVIRONMENTAL PERFORMANCE DATA

 

CALIFORNIA PORTLAND CEMENT KILN

(expressed as pounds/hour)



	 

CRITERIA	EXPONENT	BASELINE	12%TDF

 	 	 	 

PARTICULATE	 	7.35	8.01

 	 	 	 

N O x (ppm)	 	208.80	104..2

 	 	 	 

CO (ppm)	 	104.20	159.30

 	 	 	 

VOLATILE ORGANICS	 	 	 

  Acetaldehyde 	 	0.34	0.05

  Benzene	 	2.65	2.29

  Formaldehyde	 	0.88	0.11

  Toluene	 	3.98	3.17

  Dichloromethane 	E-3	1.79	0.87

  O-xylene 	E-3	1.89	2.14

  Trimethyl benzenes 	E-3	1.56	3.99

 	 	 	 

METALS	 	 	 

  Antimony	E-4	2.32	<2.28

  Arsenic	E-4	4.05	0.85

  Barium	E-3	1.20	0.48

  Cadmium	E-4	2.27	1.77

  Chromium (Total)	E-4	3.44	3.94

  Chromium (Hexavalent)	E-4	2.33	1.13

  Copper	E-3	1.11	0.72

  Lead	E-3	1.19	0.59

  Manganese	E-3	1.96	2.06

  Mercury	E-3	4.54	8.33

  Nickel	E-4	5.81	3.00

  Selenium	E-4	ND<1.97	ND<6.54

  Silver	E-5	ND<3.94	<4.55

  Thallium	E-5	<2.52	<2.47

  Zinc	E-3	4.71	9.41

 	 	 	 



EXHIBIT 8  (CONTINUED)





	ENVIRONMENTAL PERFORMANCE DATA

 

CALIFORNIA PORTLAND CEMENT KILN

(expressed as pounds/hour)



















 

CRITERIA	EXPONENT	BASELINE	12%TDF

 	 	 	 

NON-METHANE HYDROCARBONS	 	18.16	14.81

 	 	 	 

PCDD/PCDF	E-6	1.58	1.93

 	 	 	 

2378 TCDD TOX EQUIV	E-8	1.05	1.68

 	 	 	 

PCB's	E-6	3.16	2.89

 	 	 	 

PAH	E-2	4.31	3.44

 	 	 	 

HCl	 	<0.017	0.43

 	 	 	 

HF	 	0.016	0.024

 	 	 	 



 

 

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