1 TIRE DERIVED FUEL:

ENVIRONMENTAL CHARACTER ISTICS 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. Ho wever, we have significant differences of opinion about practical compromise s 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 t he ultimate objective. Others recognize the value of resources conserved through interim steps and believe that these steps contribute to the evoluti on 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 r ubber mixture would be perpetually reused. However, today's applications for this material consume less than 15% of the waste tires generated annually in North Am erica. These markets are growing slowly in spite of intense market development effo rts, 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 thr ough 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 consumpti on of natural energy resources through alternative use of waste tires is a worthy objective if it c an be done without a counterbalancing negative impact on our environment. For perspective, the following sections examine chemical characteristics and historical environmental experience of waste tires as

an energy resource.2 CHEMICAL CHARACTERISTICS OF SCRAP TIRES

The chemical characteristics of any energy resource impac t its environmental acceptability. Tires are a hydrocarbon-based material deriv ed 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 remo val. 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 va ry depending on type and source. However, Exhibit 1 provides representative proximate and ultimate analyse s 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 tire s offer efficiency advantages versus coal. For instance, tire s generally have lower moisture content than coal. Since energy required to heat and vaporize inherent water is generally nonrecoverable 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 volat ile-to-fixed carbon ratio enhances its ability to combust rapidly and completely. Based on prox imate 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 easte rn coals, TDF's lower sulfur content (especially in terms of pounds/million Btu) o ffers the potential advantage of decreasing SOx emissions. However, many wester n 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 marg inally 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 notabl e exception. Zinc oxide is added to tires as part of the rubber vulcanization proc ess at levels approaching 1.0 - 1.5% by weight. Therefore, zinc levels in tires are much higher t han coal. Applications using tires as an energy resource must be abl e to control zinc emissions to avoid a3 negative environmental impact.

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

HISTORICAL ENVI RONMENTAL PERFORMANCE

Background

Scrap tires have been utilized as a supplem ental energy source in Japan, Europe

and the United States since t he 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 us ing scrap tires have broadened to include cement kilns, industrial boilers, traditionally-conserva tive utilities and dedicated electrical generation facilities. The following discussion provi des examples of dem onstrated 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 pr ocessing operations. Wood is combusted on moving grates that also transport residual ash fr om 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 f uel (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 vo latile 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 displa ced fossil fuel and system environmental control equipment. The two pr edominant factors controlling environmental acceptability are SOx and particulate (zinc oxide) emissions . SOx emissions may decrease if TDF displaces coal or oil with higher sulfur cont ent. Alternatively, SO x can be controlled by scrubbers present in some systems, especially if the scrubbers operat e at a neutral or basic pH. Particulate emissions can be contro lled by electrostatic precipitators (ESPs) or baghouses. In general, many environmentally a cceptable applications occur when coal is4 displaced in systems with baghouses or ESPs.

Based on data compiled by the Rubber M anufacturers Association, 17 U.S. paper mills used approximately 26 million scrap ti res 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 test ing and existing users have maximized consumption, especially in southeastern fa cilities. 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. Thei r 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 dat a associated with performance testing

conducted at this site. A baseline test wa s conducted using their normal mixture of gas, bark, coal and sludge. TDF was then substitut ed 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 incr eased. Zinc increased signifi cantly percentage-wise, but total quantities remained acceptable. Overa ll particulate emissions remained well within acceptable limits.

Performance data has also confirmed environmental accept ability of TDF in similar paper mills and industrial boilers in 20 states. Several of these stat es (including Oregon, Washington, California and Flor ida) are recognized for thei r environmental sensitivity and rigorous regulatory enforcement. However, these applications must be carefully screened to define facilities capable of using TDF withi n environmentally accept able limits. Only a small percentage of industrial boilers have the required comb ination 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 RM A. 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) offe ring adequate retention time for complete combustion of nominal 1 inch (minus 2 inch) TDF. This is the smalle st TDF material that can generally be produced at costs competitive with coal and ot her fossil fuels. These units consume large quantities of fuel, so small percentages of TDF (2-4%) can use up to5 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 execut ed agreements designed to reduce the impact of acid rain through mandatory reductions in SOx emissions. Major coal-fired utilities using Midwestern and eastern c oals have been under intense pressure to achieve mandatory reductions at minimal cost to their customers. They are faced with purchasing expensive low-su lfur coal or making subst antial 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 ar e considering TDF usage as a method of cost reduction in an extremely competitiv e 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 ex panding. 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 conduct ed extensive tests using TDF as a supplemental fuel in its cyclone boiler at Be loit. The system has an ESP for particulate control. Comparative cr iteria pollutant data is provided in Exhibit 4. Particulate, SOx, hydrochloric acid and hydrofluoric acid c oncentrations decreased with use of 7% TDF. However, NOx, CO and hydr ocarbons increased, but rema ined within applicable permit6 limits. WP&L constructed its own TDF pr ocessing facility based on economics and supply considerations, but encountered in itial 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 repres ent one of the newer systems designed to minimize environmental impact fr om use of solid fossil fuels. High turbulence and uniform heat distribution allow fluidized beds to operat e at lower temperatur es 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-v iable candidates for use of nominal 1- inch TDF. Stockton Cogen in Stockton, Calif ornia conducted extensiv e trials with financial

assistance from the Califor nia Integrated Waste Managem ent 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 pe rmit limits, with particu late 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 usi ng 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 compli ance with strict new-source performance criteria. The Connecticut facility is still oper ating, but the Califor nia plant has been shut down due to economic and political factors asso ciated with a major fire (initiated by a lightening strike during a storm) in an adjac ent 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 t he largest application in North America. Only Calvaras Cement in California consum ed waste tires 15 years ago. In 2003, 42 facilities used whole tires or TDF as a supplem ental 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 tire7 quantities and difficult tire disposal probl ems, providing efficient logistics.

Energy Intensity - Kilns are energy intensive, allo wing consumption of 500,000 - 1,500,000 million tires/year/kiln. TDF energy cost sa vings 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 pr omote 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, providi ng inherent SOx control.

Ash Utilization - Ash resulting from tire combusti on becomes an integral component of the cement product, eliminating as h disposal requirements.

Steel Use - Reinforcing wire is constructively consumed as a replacement for purchased

natural resources or alternat ive materials containing iron.

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

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

Exhibit 6 provides compar ative 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 organi cs 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 in creased about 10%, but pol ynuclear aromatics declined about 10%. This facility completed a comprehensive PSD review associated with8 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 envir onmentally-sensitive states in the U.S.

Several of the southwestern cement plants have undergone extensive testing.

Results of California Portland Cement Company's emissions re sults for its Colton plant are

summarized in Exhibit 8. Some criteria decreased with use of tires, while others increased. For example, total particulate increas ed less than 10%, while non-methane hydrocarbons decreased about 18%. Recognized carci nogens like benzene and toluene decreased.

Total PCDD/PCDF materials increased nomina lly in quantity. Mo st PCBs and PAH's declined with tire usage, while hydrochloric and hydrofluoric acids increased. Hexavalent chromium, barium, cadmium lead and nickel em issions declined, while zinc and mercury

increased. While the most critical impact will probably depend upon the reviewer's perspective, most changes were relative ly 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 t he ISC dispersion model and ACE health effects model specified by the Calif ornia EPA. Based on this ev aluation, 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 reducti ons like those demonstrated at Cal Portland.

Cement kilns constructively utilize mo re waste tires than any other single application. Kilns are an impor tant component of waste tire management in most states considered to have successful progr ams. Any state that is not fully utilizing its waste tire resource may wish to objectively evaluate t he environmental and economic merits of this application.

SUMMARY

Scrap tires can be an environmentally-compat ible alternative energy resource when used in appropriate applications. Energy utilization is an impor tant component of successful scrap tire management programs within the U.S., allo wing this resource to be

used rather than wasted. The net result has been substantial conservation of nonrenewable fossil fuels. When the demonstr ated performance of tires as an energy resource is objectively evaluated, many ju risdictions have concluded that our environment is better served by recognizing the value of th is resource rather than wasting it while waiting for ideal solutions. Good program s recognize the importance of diverse applications.9 Acknowledgement: This document was writt en by Terry Gray, President of T.A.G. Resource Recovery, with guidance and peer re view from EPA and industry members of

the EPA RCC TDF Subcommittee.10 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 100.00 100.0011 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 - 0.00112 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 88513 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 -2814 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 1.8815 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 1.6816 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 <0.001N

D

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 0.00717 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 NA18 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 9.4119 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