Laserfiche WebLink
TECHNICAL REVISION <br />GCC owns and operates the cement manufacturing plant located in Pueblo. The Pueblo Plant also operates an <br />on -site limestone quarry. The limestone quarry operates under the Mining Permit No. M- 2002 -004 issued by <br />DRMS on August 29, 2003 as a Regular 112 construction material mining operations. Limestone is used as a <br />raw material in the clinker manufacturing process in the cement kiln as well as an additive in the finish mill. <br />With this application, GCC is requesting a technical revision to its 112 Permit Application and Reclamation Plan <br />submitted in 2002 for its Red Rock and Limestone Mine (i.e., quarry), in accordance with the Colorado DRMS <br />Mineral Materials Rules and Regulations for the Extraction of Construction Materials.' Specifically, this TR <br />requests DRMS to modify-its reclamation plan and allow GCC to beneficially re -use kiln feed material from the <br />main kiln baghouse in the quarry for reclamation backfill purposes its quarry covered under Mining Permit No. <br />M- 2002 -004. <br />DRMS requires that a TR request be submitted and filed for a change in the permit, which has only a minor <br />effect upon the approved or proposed reclamation plan. The enclosed TR request demonstrates that the <br />characteristics and physical properties of kiln feed from the main kiln baghouse is comparable to that of inert <br />materials currently used and approved for the quarry reclamation purposes. In addition, the use of kiln feed <br />from the main kiln baghouse in reclamation as backfill will have no anticipated impact on the reclamation <br />design proposed in GCC's 2002 permit application. <br />Accordingly, GCC requests that DRMS review the enclosed TR for approval to include kiln feed material in its <br />reclamation plan. The outline of the TR follows Section 3.1.5, Paragraph 9 of Rule 3 (Reclamation Measures - <br />Materials Handling) of the rules. For a comprehensive description of the proposed changes, each section of <br />Paragraph 9 has been provided in the following summary paragraphs. <br />Narrative <br />GCC is proposing to use kiln feed material from the main kiln baghouse as a backfill material for reclamation of <br />its quarry following installation of a proposed baghouse dust shuttling system. The concept of selective dust <br />shuttling the baghouse dust from the kiln system is common in Europe as an identified Best Available Technique <br />(BAT), and has being applied domestically in many Portland Cement plants across the United States in response <br />to the stringent requirements of the Portland Cement Maximum Achievable Control Technology regulations <br />MACT.z A small portion of the kiln feed material from the main kiln baghouse will be removed and will be <br />transported to the quarry area for reclamation backfill purposes. Once transported to the quarry, the kiln feed <br />material will be placed with overburden backfill materials used to bring the quarry to grade for reclamation <br />purposes. The kiln feed material from the main kiln baghouse will be mixed with the overburden materials <br />including shale and limestone crusher fines. As described in Section G of the quarry permit application, the <br />backfill will be covered with topsoil and seeded. <br />As demonstrated by the recent TCLP analysis, which was conducted in accordance with SW -846, the kiln feed <br />material from the main kiln baghouse exhibits characteristics similar to that of raw materials currently mined <br />at the quarry. GCC analyzed two kiln feed material samples from the baghouse representative of two,operating <br />conditions 140 degrees Celsius and. 180 degrees Celsius when a portion of the kiln feed .material will be <br />removed from the baghouse. A copy of the TCLP analysis has been included in Attachment 1 for reference. <br />' Mineral Materials Rules and Regulations for the Extraction of Construction Materials Promulgated October 1995 <br />2 Hoening, Volker of European Cement Research Academy. "Sources of Mercury, Behavior in Cement Process and Abatement <br />Options." Cement Industry Sector Partnership on Mercury Partnership Launch Meeting, Geneva. June 2013. PowerPoint <br />presentation. <br />