Memorandum

TO: Rulemaking Docket

FROM: Keith Barnett

SUBJECT: CIS\M ICR Follow Up Request for Information - (ICR No.2286.01; OMB Control

No. 2060-0616; EPA FormNo. 5900-122)

DATE: Aptil25,20ll

Attached to this meülo is the outgoing correspondence requesting additional information on thc

sor¡rc€s of oertain secondary fuels used in Portland cement kilns.

When these emails were printed, several ofthe tables were tnurcated. The four pages just after

this cover page are the truncated tables in their entirety.
Row Labels

Coal:

Bituminou s

Natural

gas

No.2

D¡st¡llâte

No.6

Residual

oil

Petroleum

Coke Propane

ïre

Derived

Fuel{TDF)

ïres

(whole)

Used

Petroleu

m-based

Oils Cemex - AlCemexDemopolis 1 t L 1

Cemex - FlCemexBrookwille 

.2

2

Cemex- FlCemexMiaiùi

L

L

1

1

1

L

1

t

1 Cemex - FlRinkerBrooksrille 1 1 1

Cemex - GACemeXClinchfield

1

1

Cemex - TNCemexKnonrille

L

11

1 Cemex - TXCemexBalconesplant 1 1

Row labels

Alternativ

e Solid

Fuel

Coal:

Bitumino

us'

Coal:

Bituminous

end

Petroleum

Cokä

Corrugate

Grdboard or

Container

Scraps

Diesel

ft¡el

Gþcerol

D¡st¡llat¡on

Bvoroduct

No.2

D¡st¡llate

Other

Petroleu

m-based

Oils

Petroleum

Coke Plastics

Tire

Derived

Fuel (TDFI

T¡res

lwholel

Used

Petroleu

m:based

Oils

1

1

5

1

7

1

2

1

2

2

2

2

eHarleyville

2

2

2

2

L

1 I I 1 1 1

Re: CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No.2060-0616; EPA Form No. 5900-122) *CEMEX* .|l

Keith Barnett rii ftsg¡¡a Henry O'U29t201104:01 pM

í ti Toni Jones

On the other question - we hadn't planed to send a formal letter. ls that a problem?

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

ba rnett. keith@epa. gov

Regina Henry Keith, Please confirm that ËPA will be sending... 0112812011 03:46:38 PM

Frorn:

To:

UC:

Date:

Subject:

Regina Henry <gina.henry@cemex.com>

Keith Barnett/RTP/USEPA/US@EPA

Toni Jones/RTP/USEPA/US@EPA, Satish Sheth <satish.sheth@cemex.com >,

aohare@cement.org

01128t201103:46 PM

Re: CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB Control No.

2060-0616; EPA Form No. 5900-122) .CEMEX*

Keith,

Please confirm that EPA will be sending an 'official'correspondence via US Mail for our records.

Also, it would be helpful to know the calendar date of 'next Tuesday'. I am assuming it is not'this'

Tuesday (February 1), but instead, you are referring to'next'Tuesday (February 8).

Thanks,

Gina

Gina Henry

Sr. Manager, Environmental - United States of America

Office : +1 (71 3)722-5185 Fax +1 (281 )605-5748 Mobile: +1 (71 3)303-5664

Address: 920 Memorial City Way, Suite 100, Houston, TX,77024

e.Mail: gina.henry@cemex.com

www.cemexusa.co'lì

Ple¿se consider the cnvironment before printing this ernail.
Barnett.Keith@epamail.epa.g

ov

011281201101:,14 PM

To R"gin" Henry/US/Cemex@CEMEX, Satish Sheth/US/Cemex@CEMEX

cc Jones.Toni@epamail.epa.gov

Subje CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB Control No.2060-0616;

ct EPA Form No.5900-122)

Dear Gina:

As you probabJ-y know, we are in the process of finalizing the CISWI

rule. In order to do a quick QA check on our CISWI kil-n inventorj-es and

floor kilns, we are following up on our initial data request by

coll-ecting some additional data on specifics of certain secondary fueLs

you reported using. Given the short time frame, we are asking for a

response to the email by COB next Tuesday. If you cannot obtain a

complete response by that time frame, please send us what you can by COB

next Tuesday.

The information on CEMEX kiln fuets in our current data base is shown

below:

(Embedded image moved to f il-e z píc1.9264.9tf.)

We are requesting this additional information to gain a better

understanding of the source and nature of the materials combusted. We

have the folJ-owing additional questions on tires, TDF' and used

petroleum based oils for the kilns shown above (the numbers indicate the

number of kilns at each facility using the fuel).

!ùhol-e Tires

Please provide the following information on the tires combusted during

the emissions tests you supplied as part of your response to the ICR

noted above. If you cannot quickJ-y determine that information for the

time periods of the emissions tests, we would ask that you provide

information on the sources of tires in the last 30 days.

What is the source of the whol-e tires you combust? Do they come from

tire piles or fandfill-s, or from an estabLished tire management program?

An 'establ-ished tire management program' is one which harvests tires

from vehicles and businesses, and then manages the tires carefully so

they are not thrown away between coll-ection and eventuaL use as fuel,

for example by use of a tracking system.

TDF

If you are recej-ving tires from sources

program, do they undergo processing to

Specifical-Iy, where you indi-cated \TDF'

explain what you meant by TDF, i.e. are

tires, sorting the tires, and removing

and wire from the tires? Or have other

processing to produce the TDF?

other than an established tire

produce a tire derived fuel-?

ín your ICR response, please

you shredding or chipping the

a significant amount of the metalentities done this type of
A separate question relating to Use of l¡lhole Tires as a Fuel_

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of tire. That is, they must be of a

certain size and shape in order for the handling system to work. It has

been suggested that tires that are removed from long abandoned piJ-es or

from within l-andfil-Ls would have to be chipped/ground, or at Least

washed c drained prior to use as fuel- for most facitities in order to maintain consistent size, shape c cleanliness required by the tire

conveying systems. For this reason tires that have col-lected water &

debris/soíl or are deformed from being landfitled generally will not

work in kil-n conveying systems, and are not used. Has this been your

experience with using tires as a fueL?

Used Oil

Does the used oil you burn meet the specíficatíon for used oil fuel

found at 40 CFR section 2'19.1,1,?

Thanks for your help. Contact me if you have any questions.

Keith I¡l . Barnett

USEPA/OAQPS/SPPD/MMG

MaiI Code D243-02

Research Triangle Park, NC 217LL

919-54l_-5605

barnett. keithGepa. sov [attachment "picl9264.gif' deleted by Keith Barnett/RTPruSEPAruS]
CISWI ICR Follow Up Request for lnformation - (lGR No. 2286.01: OMB

Control No.2060-0616; EPA Form No. 5900-122) Clarification

gina.henry, curtis.lesslie, HECTOR.YBANEZ,

Kerrh Barnen ,", gljil i,i,flå1,,:Hi'fåff:1.,1",1[|,1#,31j*' o1t2st2o1103:57 pM

Grady, Jay, tnatz

Cc: ToniJones, Steven Silverman

Clarification - By Next Tuesday I meant Februâry 1. I apologize for the short t¡me frame - but we are

underan immovable deadline here.

KeithW. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-¡02

ResearòhTriangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No. 2060-0616; EPA Form No. 5900-122)

Keith Barnett curtis.lesslie 011281201103:48 PM

, .,. Toni Jones

Dear Curtis:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on Ash Grove kiln fuels in our current data base is shown below:

We are requesting this additional information to garn abetter understanding of the source and

nature of the materials combusted. We have the following additional questions on tires and used

petroleum based oils for the kilns shown above (the numbers indicate the number of kilns at each

facility using the tuel).

V/hole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources oftires in the last 30 days.

TVhat is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A Separate Ouestion Relating to Use of Whole Tires as a Fuel (This is an additional question

we are asking other respondents - you already answered this)

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

Row labels

Coal:

Bitumino

us

Coal: Sub

bitumino

us

Natural

sas

Petroleum

Coke

Tires

fwholel

Used

Petroleumbased Oils

Ash Grove - lDAshGrovelnkom 2 2 2 2

Ash Grove - ORAshGroveDurkee 1 L I 1

Ash Grove - TXAshGroveMidlothian 3 3 3 3

Ash Grove - UTAshGroveLearninston 1 I L

Ash Grove - WAAshGroveSeattle 1 L 1
has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Used Oil

Does the used oil you burn meet the specification for used oil fuel found at 40 CFR section

279.n?

Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

ba rnett. ke¡th@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No.

Control No. 2060-0oiO; eÞn Form No. 5900-i22)

Keith Barnett daniel.nugent

Toni Jones

2286.01; OMB

0112812011 02:50 PM

Dear Dan:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on Buzzi kiln fuels in our current data base is shown below:

Rot¿ Labels

carbon

black

Coal:

Bitumino

u5

Natural

sas

Petroleu

m Coke

Spent

Seed

Corn

Tires

(whole)

Buzzi - lLBuzziUnicemOslesbv 1 L t L L

Buzzi- OKLonestarPryor 3 3 3 3

Buzzi - TXLoneStarMarvneal 3 3 3 3 3

We are requesting this additional information to gan abetter understanding of the source and

nature of the materials combusted. We have the following additional questions on tires and spent

seed com for the kilns shown above (the numbers indicate the number of kilns at each facility

using the fuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part ofyour response to the ICR noted above. Ifyou cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources of tireS in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A separate question relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills
would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Spent Seed

What is spent seed? Is it a product that is derived from clean biomass? If so, what is the process

by which it is produced?

Where do you get the spent seed you combust? Is it generated on-site at your facility or another

facility you own?

Thanks for your help.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No. 2060-0616; EPA Form No. 5900-122) (Resend to correct typo)

Keith Barnett Grady, Jay

sisaacson, Toni Jones

0112812011 03:04 PM

Dear Jay:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on Cal Portland kiln fuels in our current data base is shown below:

Rorv Labels

Coal:

Bitumino

us

Natural

gas

Tires

(r',rhole)

Cal Portland - CACAPortlandCementColton 2 2 2

We are requesting this additional information to gain a better understanding of the source and

nature ofthe materials combusted. We have the following additional questions on tires for the

kilns shown above (the numbers indicate the number of kilns at each facility using the fuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part ofyour response to the ICR noted above. If you cannot quickly determine that

information for the time periods ofthe emissions tests, we would ask that you provide information

on the sources of tires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A separate question relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being
landûlled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fr¡el?

Thanks for you help. Please contact me ifyou have questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

. MailCodeD24S-02

Research Triangle Park, NC 27711

91$,541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No.2060-0616; EPA Form No. 5900-122)

Keith Barnett gina.henry,satish.sheth

Toni Jones

0112812011 02:44 PM

Dear Gina:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on CEMEX kiln fuels in our current data base is shown below:

We are requesting this additional information to gan abetter understanding of the source and

nature ofthe materials combusted. We have the following additional questions on tires, TDF, and

used petroleum based oils for the kilns shown above (the numbers indicate the number of kilns at

each facility using the fuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources of tires in the last 30 days.

What is the source of the whole tires you combust? Do they come frorn tire piles or landfills, or

from an established tire management program? An'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

Ror',1 Labels

Coal:

Bitumino

us

Natural

gâs

No.2

Distillate

No.6

Residual

oil

Petroleum

Coke Propane

Tíre

Derived

Fuel

(TDFì

Tires

rtrhole

Cenrex - ALCernexDernopolis :L 1 1 I

Cenrex - FLCemexBrooksville 2 2

Cenrex - FLCemexMiami :L 1 1 1 L 1 L 1

Cemex - FLRinkerBrooksville l- l- L

Cenrex - GACenrexClinchfield L 1

Cenrex - TNCernexKnoxville t 1 L

Cenrex - TXCemexBa lconesP lant I 1 :l
TDF

If you are receiving tires from sources other than an established tire program, do they undergo

processing to produce a tire derived fuel? Specifically, where you indicated 'TDF' in your ICR

response, please explain what you meant by TDF, i.e. are you shredding or chipping the tires,

sorting the tires, and removing a significant amount of the metal and wire from the tires? Or have

other entities done this type of processing to produce the TDF?

A separate question relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or ûom within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

Iandfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Used Oil

Does the used oil you burn meet the specification for used oil fuel found at 40 CFR section

279.11?

Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-s605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No.

Control No. 2060-0616; EPA Form No. 5900-122)

Keith Barnett gary.molchan

Toni Jones

2286.01; OMB

011281201103:03 PM

Dear Gary:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that tíme frame, please send us what you can by COB next Tuesday.

The information on Essroc kiln fuels in our current data base is shown below:

Ror,¿ Labels

Coal:

Bitumino

us

Diesel

fuel

Petroleu

rn Coke

Tires

Iwholeì

Essroc - pAEssrocltalcernentiGrouoBessemer 2 2

Essroc - MDESSROCFrederickPlant 2 2 2 2

Iüy'e are requesting this additional information to gan abetter understanding of the source and

nature ofthe materials combusted. We have the following additional questions on tires for the

kilns shown above (the numbers indicate the number of kilns at each facility using the fuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part ofyour response to the ICR noted above. Ifyou cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources of tires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A Separate Question Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying
sptems. For this rea$on tires that have collectod water & debris/soil or are deformd from being

landfilled generaþ will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D24f02

Research Triangle Parlç NC 27711

919-541-5605

ba rnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No. 2060-0616; EPA Form No. 5900-122)

Keith Barnett hgotsch 0112812011 03:08 PM

Toni Jones

Dear Henry:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The Ínformation on Florida Rock kiln fuels in our current data base is shown below:

Rovu Labels

Coal:

Batumino

us Flv Ash

Natural

sas

No.2

Distillate

Petroleu

m Coke

Tires

(vuhole)

Florida Rock - FLFloridaRock 1 1 I 1 :l_ 1

We are requesting this additional information to gain a better understanding of the source and

nature of the materials combusted. We have the following additional questions on tires.

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part ofyour response to the ICR noted above. Ifyou cannot quickly determine that

information for the time periods ofthe emissions tests, we would ask that you provide information

on the sources of tires in the last 30 days.

What is the source ofthe whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A Separate Question Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?
Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No. 2060-0616; EPA Form No. 5900-122) ( Resent to add a

question)

Keith Barnett

Toni Jones

HECTOR.YBANEZ 0112812011 03:28 PM

Dear Hector:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on Holcim kiln fuels in our current data base is shown below:

Vy'e are requesting this additional information to gan abetter understanding of the source and

nature of the materials combusted. We have the following additional questions on tires, wood

and used petroleum based oils for the kilns shown above (the numbers indicate the number of

kilns at each facility using the fuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources oftires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fi,rel, for example by use of a tracking

system.

Rovu Labels

brorvn

greaSe

Carpet

Scrap

clay

absorben

ts

Corrugate

Cardboard

or

Container

Scraps

Drum

Dryer

Solids Filters

o¡l

Booms

OilFilter

Fluff Plastics

Shredde

cloth

Holcim -

TXHolcirnMidl

olhianPlant 2 2 2 2 2

Holcinr -

UTHolcimDev

ilsSlide L I I 1 1
TDF

If you are receiving tires from sources other than an established tire program, do they undergo

processing to produce a tire derived fuel? Specifically, where you indicated 'TDF' in your ICR

response, please explain what you meant by TDF, i.e. are you shredding or chipping the tires,

sorting the tires, and removing a significant amount ofthe metal and wire from the tires? Or have

other entities done this type ofprocessing to produce the TDF?

A Separate Ouestion Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as friel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveþg

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Used Oil

Does the used oil you burn meet the specification for used oil fuel found at 40 CFR section

279.tt?

Wood

If you combust wood or wood products, where do you get the wood/ wood products?

Does the wood you combust contain any contaminants (e.g., railroad ties or telephone poles that

contain creosote) or is it clean wood (e.g., forest residue)?

Thanks for your help. Contact me if you have any questions.

Thanks for your help.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No.

Control No. 2060-0616; EPA Form No. 5900-122)

Keith Barnett michael.pelan ' Toni Jones

2286.01; OMB

01t2812011 03:26 PM

Dear Mike:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on Lafarge kiln fuels in our current data base is shown below:

We are requesting this additional information to gan abetter understanding of the source and

nature of the materials combusted. We have the following additional questions on tires, TDF, and

used petroleum based oils for the kilns shown above (the numbers indicate the number of kilns at

each facility using the fuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources oftires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

TDF

Alternati

ve Solid

Fuel

Coal:

B¡tuminous

and

Petroleum

Coke

- lALafarseBuffalo

Lafaree - llLafa

Lafaree - OKLafareeTulsaPlant

PALafarseWh iteha I I Plant
Ifyou are receiving tires from sources other than an established tire program, do they undergo

processing to produce a tire derived fuel? Specifically, where you indicated 'TDF' in your ICR

response, please explain what you meant by TDF, i.e. are you shredding or chipping the tires,

sorting the tires, and removing a significant amount of the metal and wire from the tires? Or have

other entities done this type of processiñg to produce the TDF?

A Separate Question Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Used Oil

Does the used oil you burn meet the specification for used oil fuel found at 40 CFR section

279.11?

Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

ba rnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No.

Control No. 2060-0616; EPA Form No. 5900-122)

Keith Barnett tmatz

Toni Jones

2286.01; OMB

0112812011 03:33 PM

DearTim:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on Lehigh kiln fuels in our current data base is shown below:

We are requesting this additional information to gain a better understanding of the source and

nature of the materials combusted. We have the following additional questions on tires, TDF, and

wood for the kilns shown above (the numbers indicate the number of kilns at each facility using

the tuel).

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. Ifyou cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources of tires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

TDF

Row Labels

Coal:

Bitumino

us

Natural

gas

No.2

Distillate

No.5

Fueloil

No.6

Residual

oil

Petroleu

m Coke

Plantbased

Agricultu

ral

Residue

Lehieh - ALLehighCementCoLeeds 1 t

Lehigh - CALehighsouthvuestReddinePlant :l- :1"

Lehish - lALehiehCementMäsonCitv t 1 L

Lehieh - PALehishCementEvansvil le 2

Lehigh - PALehighCementYork 1 L L 1 L
If you are receiving tires from sources other than an established tire program, do they undergo

processing to produce a tire derived fuel? Specifically, where you indicated 'TDF' in your ICR

response, please explain what you meant by TDF, i.e. are you shredding or chipping the tires,

sorting the tires, and removing a significant amount of the metal and wire from the tires? Or have

other entities done this type of processing to produce the TDF?

A Separate Question Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?

Used Oil

Does the used oil you burn meet the specification for used oil fuel found at 40 CFR section

279.1t?

Wood

If you combust wood or wood products, where do you get the wood/ wood products?

Does the wood you combust contain any contaminants (e.g., railroad ties or telephone poles that

contain creosote) or is it clean wood (e.g., forest residue)?

Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI IGR Follow Up Request for lnformation - (lGR No. 2286.01; OMB

Control No.2060-0616; EPA Form No.5900-122)

Keith Barnett , David Rib

Toni Jones

0112812011 03:36 PM

Dear David:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initiai data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on your kiln fuels in our current data base is shown below:

Row Labels

Coal: Sub

bitumino

us

Natural

ses

Tires

f ruholel

Mitsubishi - CAMitsubishiCement I 1 1

We are requesting this additional information to gan abetter understanding of the source and

nature ofthe materials combusted. We have the following additional questions on tires for your

kiln.

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources oftires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A Separate Ouestion Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fi¡el substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveþg

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveþg systems, and are not used. Has this been your

experience with using tires as a fuel?
Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No.

ContrclNo.2060-0616; EPA Form No. 5900-122)

Keith Barnett Brent Wilkerson

Toni Jones

2286.01; OMB

0112812011 03:40 PM

Dear Brent:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on your kiln fuels in our current data base is shown below:

Ror,¿ Labels

Coal:

Bitumino

us

Natural

gas

Petroleu

rn Coke

Tires

(rr¡holel

Monarch - KSMonarchCementCoHumboldt 2 2 2 2

rùy'e are requesting this additional infonnation to gain a better understanding ofthe source and

nature ofthe materials combusted. We have the following additional questions on tires for your

kilns.

Whole Tires

Please provide the following information on the tires combusted during the emissions tests you

supplied as part of your response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources of tires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An 'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual use as fuel, for example by use of a tracking

system.

A Separate Question Relating to Use of Whole Tires as a Fuel

Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveying systems, and are not used. Has this been your

experience with using tires as a fuel?
Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov
CISWI ICR Follow Up Request for lnformation - (lCR No. 2286.01; OMB

Control No. 2060-0616; EPA Form No. 5900-122)

Keith Barne¡1 ; . Jerry Stefanik 0112812011 03:44 PM

Dear Jerry:

As you probably know, we are in the process of finalizing the CISWI rule. ln order to do a quick QA check

on our CISWI kiln inventories and floor kilns, we are following up on our initial data request by collecting

some additional data on specifics of certain secondary fuels you reported using. Given the short time

frame, we are asking for a response to the email by COB next Tuesday. lf you cannot obtain a complete

response by that time frame, please send us what you can by COB next Tuesday.

The information on your kiln fuels in our current data base is shown below:

Rorv Labels

Petroleu

rn Coke

Tire

Derived

Fuel

(TDF)

National - CANat¡onalCementofCA I 1

Vy'e are requesting this additional information to gain a better understanding of the source and

nature ofthe materials combusted. We have the following additional questions on tires and TDF

for your kiln.

Whole Tires (Applies if you are actually using whole tires)

Please provide the following information on the tires combusted during the emissions tests you

supplied as part ofyour response to the ICR noted above. If you cannot quickly determine that

information for the time periods of the emissions tests, we would ask that you provide information

on the sources oftires in the last 30 days.

What is the source of the whole tires you combust? Do they come from tire piles or landfills, or

from an established tire management program? An'established tire management program' is one

which harvests tires from vehicles and businesses, and then manages the tires carefully so they are

not thrown away between collection and eventual uso as fuel, for example by use of a tracking

system.

If you are receiving tires from sources other than an established tire progran¡ do they undergo

processing to produce a tire derived fuel? Specifically, where you indicated 'TDF' in your ICR

response, please explain what you meant by TDF, i.e. are you shredding or chipping the tires,

sorting the tires, and removing a significant amount of the metal and wire from the tires? Or have

other entities done this tyrpe of processing to produce the TDF?

A Separate Ouestion Relating to Use of Whole Tires as a Fuel

TDF
Our understanding is that kilns that use whole tires as a fuel substitute rely on a certain grade of

tire. That is, they must be of a certain size and shape in order for the handling system to work. It

has been suggested that tires that are removed from long abandoned piles or from within landfills

would have to be chipped/ground, or at least washed & drained prior to use as fuel for most

facilities in order to maintain consistent size, shape & cleanliness required by the tire conveying

systems. For this reason tires that have collected water & debris/soil or are deformed from being

landfilled generally will not work in kiln conveþg systems, and are not used. Has this been your

experience with using tires as a fi¡el?

Thanks for your help. Contact me if you have any questions.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

ba rnett. keith@epa. gov