HYDRO27565

• Permit No: M1977208
• IBM Index Class Name: Hydrology
• Doc Date: 3/3/2007
• Doc Name: Response to Citizen Complaint Letter
• From: DRMS
• To: Richard Cargill
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1373 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: (303) 832$106
March 3, 2007 v /
Mr. Richazd Cargill t/
St. Vrain Valley Community Watchdogs
P.O. BOX 82
Hygiene, CO 80533
STATE OF
es~~) ~~b~ G~~al
RE: Cf MEX, Inc., Lyons Mine, Permit No, M-1977-208
esponse to Citizen Complaint Letter
Dear Mr. Cazgill,
COLORADO
DIVISION O F
RECLAMATION
MINING
- &-
SAFETY
Bill Ritter, lr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
The Division of Mining, Reclamation and Safety ("Division" or "DBMS") received your letter
on January 29, 2007 regazding an investigation of the water located in the C-Pit at the CEMEX
Inc., Lyons Mine, Permit No. M-1977-208.
ReaulatorY issues of Cement Kiln Dust (CKD)
The Division routinely permits and regulates the disposal of mining or processing waste
generated from within a reclamation permit area. By bringing the azeas of the cement plant
where cement kiln dust ("CKD") is generated, stored or transported into the reclamation permit,
CKD becomes in effect amining/mineral processing waste that the Division regulates. The
Division is the implementing agency for groundwater protection at active mines and thereby has
the capacity to monitor for pollutants that may derive from CKD disposal (C.R.S. 34-32.5-
116(4)(h)). The Division also has the authority to require stabilization of landfill CKD by
periodic cover application to prevent erosion (C.R.S. 34-32.5-116(4)(j)) and has the authority to
require final closure and reclamation of CKD landfills within the reclamation permit area.
History of CKD disposal and revisions to CEMEX Lyons permit
In 1999, the Division approved a site disposal plan for CKD to be disposed of in the C-Pit at the
CEMEX Lyons site under Technical Revision Ol ("TR-01 ") to the permit. The Lyons cement
plant generates approximately 20,000-35,000 tons of CICD annually. The CKD is removed
from the kiln on a continuous basis and is either re-circulated, sold or hauled to the C-Pit in
open dump trucks. According to CEMEX, CICD is re-circulated by pumping the material into
the silos or blended into the cement product whenever possible. The CICD that is sold and used
off site has several beneficial uses such as lime type application to farms, road stabilization
projects, and general fill. The CICD that is disposed in the C-Pit is sprayed with water from
lazge sprinklers surrounding the disposal area to manage fugitive dust. The CI{D is periodically
capped with a layer of compacted shale or clay soils. The water currently in C-Pit is from
surface runoff, collected precipitation, runoff from the sprinkler system and possibly from
Boulder Feeder Canal seepage.
coo

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Mined Land Reclamation Denver Grand Junction Durango Active and Inactive Mines