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Mr. Michael Cunningham March 22, 2ol6 <br /> Colorado Division of Reclamation and Safety HAND DELIVERED <br /> 131 Sherman Street, Room 215 <br /> Denver, CO 80203 RE..r r-V <br /> RE: Lyons Quarry M-1977-208 TR No. 15 MAR 2 8 2016 <br /> DIVISION OF RECLAMATION <br /> Dear Mr. Cunningham: MININGANDSAFETY <br /> CEMEX Construction Materials South, LLC is proposing to add powder activated carbon and <br /> hydrated lime into the kiln baghouse. The Division has asked that CEMEX demonstrate that <br /> the addition of lime and carbon will not have an adverse impact to groundwater. Cement <br /> kiln dust(CKD) is the fine-grained, solid, high alkaline waste removed from cement kiln <br /> exhaust gas by air pollution control devices. CKD is currently categorized by EPA as a <br /> "special waste" and has been exempted from federal hazardous waste regulations under <br /> Subtitle C of the Resource Conservation and Recovery Act(RCRA). <br /> The handling and processing of CKD baghouse dust will not change—The baghouse dust is <br /> collected and transported via screws and pumps to either the A5 Silo for resale or the Dust <br /> Silo for disposal into C-Pit.The lime and carbon will be injected upstream of the baghouse to <br /> allow for effluent mixing. <br /> The Division has requested that CEMEX evaluate the chemical waste composition of the CKD <br /> with the addition of lime and carbon. Specifically, TCLP,Total Metals and Paste pH test. <br /> Because CEMEX has not operated the lime and carbon systems, analytical testing of the <br /> material cannot be completed prior to DRMS approval. <br /> CEMEX proposes to operate the lime and carbon systems in order to gather the analytical <br /> data requested by DRMS. CEMEX proposes to isolate and store all CKD waste with the <br /> added activated carbon and lime collected from the dust silo until analytical data is <br /> evaluated by DRMS and approval is granted. The material would be stored in a capped area <br /> of C-Pit and not comingled with the existing CKD pile. <br /> Activated carbon and hydrated lime will be bound with baghouse dust, CKD. A separate <br /> waste stream would not occur. <br /> 1of3 <br />