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<br /> <br />STATE Or COLORADO <br />DIVUION OF MINERALS AND GEOLOGY <br />Department of wamral Resources <br />171 } >herman 5... Room ? t 5 <br />Denver, Colorado 80303 <br />."+one 1}031 Boo-i}6: <br />Fnt Li03) 33? 3106 <br />Date: December 3, 1999 <br />(Finalized January l6, 200 f ) <br />To: Bruce Humphnes <br />!im Stevens <br />Carl MOURC <br />Tom Gillis <br />From: Harry Posey ~~ / <br />Allen Sorenson i %~`~- ~~~~~'`-- <br />Subject: Cement Kiln Dust: Issues of Long-term Storage at Limestone Mines <br />BACKGROUND AND PERSPECTIVE <br /> <br />DI `/I SI ON r <br />I~1INERAI <br />G E O L O G <br />d E C L A n A i i C <br />nI NING~SaJE~ <br />Biu G,..-m <br />Co~emar <br />GrrgE wal~_ner <br />Eaecun.e Director <br />~~fchad B Long <br />D~~is~on Duecmr <br />[n August 1999 the Environmental Protection Agency Office of Solid Waste proposed <br />management standards for Cement Kiln Dust (CKD) waste. The following statements aze taken <br />from EPA's Environmental Fact Sheet issued at the time of the announcement of the proposed <br />CKD management standards. <br />Although current disposal practices cause some environmental damage, the Agency <br />found that regulating cement kiln dust as a hazardous waste was not appropriate. Since <br />some conGols aze needed, EPA is proposing a tailored set of standards for managing <br />cement kiln dust waste. <br />The Agency's preferred option is to provide management standards whereby CKD <br />remains a nonhazardous waste so long as the waste is managed according to the <br />requirements. Cement kiln dust becomes a regulated hazazdous waste only if significant <br />violations of the management standards occur. <br />Under EPA's proposed standards, cement kiln dust is to be managed in landfills designed <br />to meet specific performance requirements that protect ground water from toxic metals. <br />In addition to performance criteria, the Agency is proposing technology-based standazds <br />that meet the performance criteria, such as using composite liners in landfills. <br />Requirements for ground-water monitoring, corrective action, closure, and post-closure <br />care are also included. <br />To control releases of cement kiln dust to air, EPA is proposing performance standazds <br />requiring facility owners and operators to [ake measures to prevent releases from <br />landfills, handling conveyances, or storage areas. As an alternative to the petformance- <br />based standard, the Agency is proposing technology-based standards that require: (l) <br />~, <br />