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(Page 2) MINE ID # OR PROSPECTING ID # M-1977-208 INSPECTION DATE 9/05/02 INSPECTOR'S INITIALS ESC OBSERVATIONS This was an inspection of the Lyons Quarry conducted by Erica Crosby of the Division of Minerals and Geology. George Martin of CEMEX, Inc. was present during the inspection. The purpose of the inspection was to investigate a citizen complaint regarding the Lyons Quarry. The Division received the citizen complaint letter from the St. Vrain Valley Community Watchdogs on August 12, 2002. The letter specifically complains about the fugitive cement kiln dust ("CKD"} that was noted blowing off the property on May 14, 2002, July 20, 2002 and July 26, 2002. The letter notes several instances where the sprinkler system was not in operation, thus resulting in plume of CKD off the property. Photographs were included with the letter. The Lyons cement plant generates approximately 20,000-30,000 tons of CKD annually. The CKD is made up of fined grained particulates of crushed and calcined limestone, shale, gypsum and silica. It is removed from the kiln and mixed with water prior to truck transport to the C-Pit. Technical Revision 1 ("TR-O1") was approved by the Division on February 1, 2000 that specifically addressed disposal of the CKD. The CKD is disposed in the C-Pit and is required to be covered with an interim cap of 2 feet of compacted shale and clay. The working disposal area will be limited to 7 surface acres at 20' lifts. Capping work would normally occur on a 2 to 5 year frequency. The disposed dust is frequently sprayed with water from a number of sprinklers surrounding the disposal area. The Division inspected the CKD disposal site. At the time of the inspection, the sprinkler System was in operation. According to George Martin, the sprinkler system is on a timer that rotates on 8 sprinklers surrounding the C-Pit. A shale cap was also observed on a portion of the CKD, as required by TR-01. The Division spoke with Gabi Hoe£1 er o£ Boulder County Health Department regarding the CKD disposal site and the issues surrounding fugitive dust. Ms. Hoefler noted that over the past several years the operator has made significant progress regarding the CKD disposal. According to Ms. Hoefler, the Air Permit issued to the operator makes an exemption for a fugitive dust emission as a result of winds over 30 MPH. Numerous complains are received at the County Health Department, but seem to fall in the 30 MPH exemption clause. At this time, the operator is following the CKD disposal plan as noted in TR-O1 with the layering of shale on the material and frequent spraying with sprinklers. Zt appears that the citizen complaint letter is based on dust emissions when the sprinkler system was not in operation. The Division of Minerals and Geology does not regulate fugitive dust emissions. Such activity is generally regulated by the County Health Department and the Colorado Department of Public Health and the Environment; Air Pollution Control Division. The Division ensures the proper disposal of CKD in terms of groundwater protection, closure for final reclamation and what needs to be incorporated into the reclamation cost estimate. The Division reviewed the previous DMG inspection report dated January 20, 1999. In that report it states the possible necessity of bonding for the cement kiln demolition and disposal. Because the CKD is regulated as a waste generated by the mining operation under the DMG Permit, it would require that a bond be posted as part of the facilities which would need to be demolished and decommissioned following the closure of plant operations. The 1999 inspection reports states that at that time, the company believes that this area of Boulder County is grandfathered as non-conforming use and that the complex and kiln are allowed to remain in place after closure as part of its industrial/commercial final end land use. DMG stated that it would like either written confirmation that the cement kiln is allowed under the current zoning and has the approval of Boulder County to remain in place after reclamation is completed, or a Certificate of Designation regarding the disposal of Cement Kiln Dust. The Division further stated that if neither of these measures are taken in the near future, DMG will recalculate the financial warranty for the site based on the cost of decommissioning the kiln, unless such confirmation is received, in which case the financial warranty will be based on the County requirements for leaving