1999-10-18_REVISION - M1977208 - Laserfiche WebLink

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~~~ iii~iiiii~~u iii STATE OF COLORADO DIVISION OF h11NERALS AND GEOLOGY Depanmen[ of Natural Resources 1313 Sherman St., Rnom ? 15 Denver, Colorado 80?03 Phone: (303) 866-3557 FAX (303) 832-8106 October 18, 1999 Mr. John Lohr Southdown Co., Inc. P.O. Box 529 Lyons, CO 80 540 DIVISION OF MINERALS GEOLOGY RECLAMATION MINING•SAFETY Bill Owens Governor Creg E. Walther Execwrve Dveuor btichael B. Long Division Director RE: Review of Response to Technical Adequacy Review Comments on theReport on Storage of Cement Kiln Dust at [he Southdown Inc. Lyons Plant, Lyons Quarry, Permit No. #M-77-208 Dear Mr. Lohr, This letter is being written to address both the remaining technical issues which need clarification in the recent report submitted by Banks & Gesso on behalf of Southdown Co., Inc., addressing the storage of Cement Kiln Dust (CKD) in C-Pit at the Lyons Quarry, Permit No. #M-77-208, and the need for a technical revision to include these measures in your current permit. Upon review of this report, and the results of the chemical leach testing and hydrological models for the site, it has become clear that measures such as an interim capping of the disposal site, and an upper limit on the amount of CKD to be stored prior to the capping, as well as any other additional reclamation measures to be included, must be written into the current pet7rtit. Accordingly, [he Division of Minerals and Geology requires that Southdown Inc. submit a technical revision to Permit No. #M-77-208, Lyons Quarry, by November 19, 1999, for the storage of CKD in the C-Pit and the addition of interim capping and volume storage limits prior to reclamation, in accordance with Rule 3.1.7(2)(c )(i) of the Hard Rock Rules and Regulations, which states that "permit conditions shall be protective of the existing and reasonably potential future uses of the groundwater that may be affected." Having received the requested response to our technical adequacy review from Banks & Gesso on September 30, DMG personnel have reviewed the document and have a few concerns which still need to be addressed 1) In Item No. 2: Modeling of the CKD Disposal Site as an Open vs. Closed Disposal Site, it is stated that the open and closed models of the site which were studied in this report were for conditions with an interim cap on the CKD. YVe still have not received any analyses of the site without any capping, open, and with the maximum amount of CKD exposed. Any technical revisions which are submitted to DMG should include this information.