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OCT 13 '98 13:25 FROM:BOB JUDD 916-444-3314 T-113 P,08/13 F-344 The 1990 source test results from the MELP facility were reported in 1995 to the SJVUAPCD as emission factors on a Ib/MMBtu basis. The annual MELP facility emissions in Table 3 were calculated based on an energy use rate of 190 MMBtu/hr and 90 percent utilization for the year. For many toxic contaminants, no emissions were detected at all. Also, two toxics in the previous tables were apparently not tested. The MELP facility emits only about 235 pounds per year of the toxics addressed here, and only 12 pounds are carcinogens. This is only four one-hundredths of one percent (0.04%) of emissions released by the Tracy tire pile fire and only three one-thousandths of one percent (0.003%) of the carcinogens. Yet, in an entire year, the MELP facility combusts approximately five million tires, or more than eighty percent of the tires consumed by open fire in one week during the Tracy incident. For comparative purposes, Table 4 summarizes emissions from the three sources discussed above, as well as a comparison with a hypothetical open bum of a tire pile one-tenth the size of the Tracy fire. Figure 2 shows total toxics in graphical form. Clearly, controlled burning of tires to produce energy avoids massive production of air pollution, including toxic air contaminants, that would otherwise occur as a result of uncontrolled combustion of waste tires as occurred In the Tracy fire. Data in this analysis were derived from third-party sources. While the authors have exercised care in ensuring the accuracy of findings presented here, we make no representations and assume no responsibilities for the accuracy of our source material. Further, this analysis draws no conclusions with regard to the health effects of emissions produced by the Tracy fire, nor do we estimate the number of remaining waste tire stockpiles in the state. References: California Air Resources Board, Air Toxics Emission Inventory Database. USEPA, 1957, Air Emissions from Scrap Tire Combustion, Report No. EPA-600/R-97- 115, October 1997 5