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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department o' Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />February 10, 2016 <br />Michael Whitehead <br />CEMEX, Inc. <br />P.O. Box 529 <br />Lyons, CO 80540 <br />RE: Lyons Quarry; DRMS File No. M-1977-208; Technical Revision No. 15; Adequacy <br />Review No. 1 <br />Dear Mr. Whitehead, <br />The Division of Reclamation, Mining and Safety (Division) received Technical Revision - 15 <br />(TR -15) for the above referenced site on January 22, 2016. The decision date for this Technical <br />Revision is February 22, 2016. The Division has reviewed the proposed revisions and has the <br />following comments: <br />1. The Operator is proposing to add powder activated carbon and hydrated lime to the effluent <br />gas streams of the cement kiln at the Lyons Plant in order to reduce mercury and hydrogen <br />chloride emissions respectively. The constituents which the Operator is seeking to reduce in <br />the form of air emissions will be disposed of onsite in C -Pit. Pursuant to Rule 3.1.6(1), <br />disturbances to the prevailing hydrologic balance of the affected land and of the surrounding <br />area and to the quantity or quality of water in surface and groundwater systems shall be <br />minimized by compliance with applicable federal and Colorado water quality laws and <br />regulations, including statewide water quality standards. Therefore, the Operator must <br />demonstrate the proposed changes to the Lyons Plant will not result in adverse impacts to <br />groundwater quality. Also, the Operator must demonstrate the change in the waste <br />composition will not result in the waste being classified as a hazardous material under <br />Subtitle C of the Resource Conservation and Recovery Act (RCRA). <br />In order to assess the change in waste composition, the Division requests the Operator <br />perform the following analyses: <br />a) Toxicity Characteristic Leaching Procedure (EPA Method 1311) <br />b) Total Metals (The analysis should include all inorganic analytes listed on Table 1 of <br />the Colorado Department of Public Health and Environment, Water Quality Control <br />Commission 5 C.C.R. 1002-41, Regulation No. 41 — The Basic Standards for <br />Groundwater. The following analytes may be omitted from the analysis: asbestos, <br />cyanide, nitrite, nitrate and total nitrite and nitrate) <br />c) Paste pH test <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br />John W. Hickentooper, Governor I Mike King, Executive Director I Virginia Brannon, Director <br />