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Industrial Services February 5,2014 Re: Recycling Spent Material The following narrative is outlining the results of testing performed confirming that the Kleen Industrial Services (KIS) program for the use of Alternate Raw Materials (ARMs) for the manufacture of Portland cement, is compliant with California Health and Safety Code Title 22 § 25143.2 (d)(5)and specifically with 22 California Code of Regulations(CCR) § 66260.200. KIS conducted a demonstration test which consisted of spent industrial materials (such as Copper Slag, Garnet, Steel Shot, Aluminum Oxide, Ferric Iron Chloride, Ferric Iron Oxide and Alumina Catalyst,) all of which have been used historically in the manufacture of Portland cement clinker. Raw Materials: Portland cement is traditionally made from a mix of raw materials rich in the oxides of calcium, alumina, iron, and silica content. ARMs consisting of spent industrial materials such as Copper Slag, Garnet, Steel Shot, Aluminum Oxide, Ferric Iron Chloride, and Alumina Catalyst, are used in the Portland cement manufacturing process as an alternate ingredient for the high iron oxide (Fe203), alumina oxide (A1203), and the silica (SiO3). Since most of these materials have already been calcined, there is no additional CO2 to liberate. Therefore, the CO2 produced per ton of Portland cement using ARMs will decrease. Replacing raw feed with ARMs also eliminates the need to quarry raw material, reducing additional greenhouse gases. Spent secondary industrial raw materials such as these have been used by cement kilns for over 50 years worldwide. Such use is well documented in the literature. Mixing Process: These materials are proportioned and ground into a fine mixture called "'raw mix." This mixture is then sintered in a kiln at temperatures in excess of 2700° F. hi the kiln, the "raw mix" melts as it passes through its liquid phase, irreversibly chemically changing its lattice to form "clinker." This clinker exits the kiln and is air cooled. The cooled clinker is then ground with gypsum to produce Portland cement. Due to the large number of oxide rich materials that may be available throughout the United States and the world, there is no set of national standards or specifications that regulate the use of spent abrasives such as copper slag or any other ingredient(s) for use as raw materials in Portland cement kilns. This does not mean that Portland cement manufacturing is without standards or specifications. Cement manufacturers often use a set of internal standards or specifications to ensure quality of the raw materials. This variability is due to the fact that each Portland cement kiln uses raw materials from varying sources or deposits, making the formula for each Portland cement kiln unique, owing the differences in oxide concentrations found to their raw material sources(i.e., quarry). 5 0 O a k C t . S u i t e 2 1 0 D a n v i l l e C A 9 4 5 2 6 P h o n e : 9 2 5 . 8 3 1 . 9 8 0 0 - F a x : 9 2 5 . 8 3 1 . 9 1 8 3 C:\KIS DOCS\Cement_Kilns\Demonstration_Testing_13'\NC140205-02_Demo_Test_for_Distribution.doc 1