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Gossman Consulting, Inc

CKD Management

Service Description

The management of cement kiln dust (CKD) continues to receive increasing scrutiny. The 1991 boiler and industrial furnace (BIF) regulations brought the issue of a "high volume, low toxicity" waste to the forefront as an issue with the inclusion of the Bevill rule. The 1993 Cement Kiln Dust Report to Congress thoroughly detailed CKD interface with the environment. While the report was extensive and certainly not without significant flaws, it supported the concept of CKD as a "high volume, low toxicity" waste. Since that time, many recommendations have been studied by the USEPA. In addition, many states already have regulations in place that address putting CKD back into quarried sites.

Gossman Consulting, Inc. (or GCI personnel) has been involved with CKD management issues since the late seventies. GCI has worked integrally with various facilities around the country and the appropriate regulatory authorities. Client comments were developed in response to the 1993 CKD report to Congress and we have most recently worked with state regulations/regulators in Illinois, Indiana, Missouri and Texas. GCI also publishes a newsletter which frequently carries stories about local CKD issues. In one instance, a state has forced a facility to begin landfilling stockpiled CKD and in another instance, local citizens in a different state would choose to see the stockpiles continue rather than agree to a new landfill. Issues are varied and often custom solutions are required. Gossman Consulting, Inc. can help you with your CKD management issues.

CKD analysis of properly sampled materials is essential for BIF compliance. Analysis of CKD is also advisable for cement plants that do not burn hazardous waste. Gossman Consulting, Inc. has been involved in designing CKD sampling and analysis programs for many years. Serious compliance testing began with the advent of the BIF rules in 1991. GCI sampling and analysis plans have withstood regulatory scrutiny and even in one case a misapplied (and later withdrawn) enforcement action item. GCI has also been called in to help in instances where facilities have encountered problems with their CKD sampling and analysis plans. Gossman Consulting, Inc. takes great pride in the defensible nature of both our sampling regimen and analytical results.

Some cement kiln dust related issues can be found on the following internet pages within the Gossman Consulting, Inc. web site:

HWF Notes "Rational for the Use of XRF as a Screening Method for Controlling and Monitoring BIF Metal Concentrations in Cement Kiln Process Feeds”, Apr-93

HWF Notes "EPA CKD Sampling Methodology”, Aug-92

GCI Tech Notes "Cement Kiln Dust Testing for Organics" February-98

GCI Tech Notes "The Impact of CKD Recycling on “HCl” Emissions from the Wet Process Cement Kiln”, Aug-96

GCI Tech Notes "The Potential for CKD Insufflation to Impact Metals Emissions from Cement Kilns”, Sept-95

GCI Tech Notes "Cement Kiln Dust and FO39 Limits”, April-95