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iii ~inii~iu~xi~i~ <br />~~ Banks and Gesso, LLC <br />~~ <br /> <br />720 Kipling St.,Suite117 <br />Lakewood, Colorado 80215 <br />(303)274-4277 <br />Fax (303)274-8329 <br />www. ban ksa ndgesso. com <br />j 2-O©1 <br />December 1, 1999 <br />Ms. Christina L. Kamnikar <br />Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />RECEIVED <br />DEC O1 1999 <br />Division of Minetab+4Geob0Y <br />Re: Technical Revision for Southdown, Inc., Lyons Quarry, Permit No. M-77-208 <br />Dear Ms. Kamnikar: <br />This letter is in response to your letter of October 18, 1999, which addresses the <br />cement kiln dust technical issues for the Lyons Quarry, owned by Southdown, <br />Inc., and to thank you for your letter of 11!29/99 extending our filing of the <br />technical revision to 12/1/99. <br />Attached is the additional computer modeling that you requested (the HELP <br />modeling was conducted by Richard Henry of Grant Environmental). This <br />modeling shows that Southdown's proposed management practices protect <br />ground water resources. All of the modeling and investigative work completed to <br />date indicates that no threat to ground water exists in the present or future if <br />Southdown continues their current management practice of limiting the mass of <br />CKD exposed through the use of interim capping. <br />The Technical Revision to Permit No. M-77-208 shall contain the following <br />provisions: <br />The CKD disposed in C-Pit shall be covered with an interim cap of 2 feet of <br />compacted shale and clay. The working disposal area will be limited to 7 <br />surface acres x 20 foot lift. At no time should the exposed CKD mass be <br />larger than these dimensions. The quantity of CKD generated varies <br />dramatically with the types of cement produced. It is expected that capping <br />work would normally occur on a 2 to 5 year frequency. <br />