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Industrial Services As can be seen from the summary table, the results from the W.E.T. tests for ARMs and the non- ARM cement are as follows; Non-ARM Portland cement sample W.E.T. results are as follows (results are ppm); Element Silo 1 Silo 1 Silo 2 Silo 2 Silo 3 Silo3 Mean PC 1 PC 2 PC 3 PC 4 PC 5 PC 6 Concentration: Cu 0.723 0.255 0.408 0.307 0.208 0.188 0.348 Pb 0.110 0.107 0.101 0.120 0.075 0.073 0.098 Zn 0.146 0.066 0.107 0.083 0.215 (N/D) 0.103 ARM containing Portland cement sample W.E.T.results are as follows(results are ppm); Element Silo 1 Silol Silo 2 Silo 2 Silo 3 Silo 3 Mean PC 7 PC 8 PC 9 PC 10 PC 11 PC 12 Concentration: Cu 0.398 0.188 0.406 0.493 0.885 0.859 0.646 Pb 0.082 0.120 0.108 0.104 0.167 0.226 0.135 Zn 0.702 0.666 0.848 0.942 0.409 0.701 0.711 According to the DTSC 22 CCR §66266.20 and 22 CCR §66266.21 governing Requirements for Recyclable Materials That Are Placed on the Land(Used in a Manner That Constitutes Disposal), after accounting for dilution of the recyclable material in the product, if the final W.E.T. results are lower than the applicable STLC limit,the product has physically and chemically bound up the hazardous constituents in the recyclable material. We used 5% of ARM material giving us a dilution factor of 20. Using the dilution factor, we evaluated the mean concentration of each metal of concern. Dilution Factor of 20 STLC(W.E.T.)Limits Cu 0.646 x 20 = 12.92 mg/L 25.0 mg/L Pb 0.135x20 =2.70 mg/L 5.0 mg/L Zn 0.711 x 20= 14.22 mg/L 250.0 mg/L The final result indicates metals concentrations in Portland cement manufactured with ARMs to be well below the regulatory W.E.T. (STLC) limits for Cu, Pb, and Zn and in compliance with Section 66266.20. This demonstrates that ARMs used in KIS Portland cement manufacturing process is an environmentally safe product; will not contaminate groundwater; and trace constituents have become physically and chemically bound in the Portland cement. All raw material ingredients have become inseparable and, in fact, became a chemically different compound. It also demonstrates that greater concentrations of ARMs could be used and still comply with Section 66266.20 without adversely affecting the STLC results. KIS understands these results to be consistent with what we have experienced with regard to past submittals by Portland cement producers in California when working with DTSC. KIS has demonstrated, by DTSC's own procedures and by approved testing methods, that the use of ARMs such as those used in our testing, as an ingredient in the manufacture of Portland cement, does not constitute "Use Constituting Disposal." KIS respectfully requests that DTSC acknowledge this and issue a letter to KIS concurring that KIS is not engaged in "Use Constituting Disposal." I appreciate your time and effort working together with us. Fionn O'Neill Director of Operations 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 4