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The remaining sections of the TR further describe the Pueblo Plant's intent to place the material into the quarry <br />for reclamation including volume, an affidavit that it is clean and inert, commencement of•operations, backfill <br />impacts and engineering plans as defined in Paragraph 9, Section 3.1.5, of Rule .3 (Reclamation Measures - <br />Materials Handling). <br />Volume <br />GCC anticipates approximately 15,000 tons per year (tpy) of kiln feed material from the main •kiln baghbuse for <br />beneficial re -use; vvhichYepresents less-than 1% of the total raw material extracted from the quarry. 'The <br />anticipated 15;000 tpy represents approximately,2 % -of the total overburden materials used for reclamation <br />purposes. As apart of the limestone crushing;ope`rations, some material is separated as crdsherfines. Current <br />mining permit ana plan already allows GCC to use crusher•fines in the.quarry area for reclamation backfill <br />purposes. Crusher fines are comparable to -the physical and chemical properties of the kiln feed *'material from <br />the main kiln baghouse. The kiln feed 'm" <br />aterial proposed to be.beneficiaily re- used'in quarry for reclamation <br />backfill purposes is approximately 4% of the total crusher fines. <br />Signed Affidavit <br />As defined by the DRMS Mineral Materials Rules and Regulations for the J xtraction of Construction Materials, <br />kiin feed material from the main kiln baghouse exhibits properties comparable-to the raw materials currently <br />used and approved °for quarry reclamation purposes. A signed affidavit, stating that-the kiln feed material from <br />the main kiln•baghouse exhibits comparable properties, has been enclosed in Attachment 2. <br />Activity Commencement <br />This proposed,beneficial re =use of the kiln feed material in quarry area for reclamation backfill purposes will <br />commence upon DRMS's approval. <br />Back fill Impact <br />Based on the small quantity of kiln feed material proposed to be beneficially re -used in quarry area for - <br />reclamation backfill purposes, there will be no, anticipated impact on the grading as described in GCC's 2002 <br />Reclamation'Plan. Attachment 3 from the 2002 application provides relevant'maps showing location of quarry <br />reclamation areas. <br />Engineering Plan <br />Proposed beneficial, re-use of kiln feed material fromthe main kiln baghouse in the ,quarry area for reclamation <br />backfill purposes meets the intent of a TR, as the material properties are comparable to the 'raw materials <br />currently approved and ;used in quarry for reclamation purposes. Properties of kiln feed material are <br />comparable to an inert material as defined in DRMS's rules.- The term inert material in :the'Colorado DRMS <br />Mineral Materials Rules and Regulations for the Extraction of Construction Materials is specified as: "...One in a <br />hardened state including masonry, asphalt paving fragments, and other. inert solids." The'rule'defines inert <br />material as a non -water soluble and non- puiiescible solids together wiih'such minor amounts and types of other <br />�,; E ,... ....r...s.a �. <br />materi.. als; unless materials are acid or toxic - producing, as will not significantly affect•the inert nature Iof•such <br />solids. As demonstrated by the TCLP analyses, thekiln feed material .from the main kiln baghouse will not <br />impact surface water and groundwater. Tlie:kiln feed from the main kiln baghouse will be�mixedywith,backfill <br />composed of unconsolidated materials and shale that cover the Fort Hays Limestone. Backfilled a `yeas will be <br />below existing surface elevations. Additionally, the Pueblo Plant will continue to employ storm watencontrols <br />