1998-03-23_REVISION - M1977348

• Permit No: M1977348
• IBM Index Class Name: Revision
• Doc Date: 3/23/1998
• Doc Name: EXHIBIT 6
• From: Holnam
• To: DMG
• Type & Sequence: TR3
• Media Type: D
• Archive: No

STATE OF COLc~RADO
DIVISION OF MINERALS AND GEOLOGY
Depanmenl of Natural Resources
131 J Sherman A., Roam 21 5
Denver. Colorado 40203
Phone [phone]
FTS: 17031872-8105
memorandum
Date: 10/27/98
To: File No. M-77348
Cc: Carl Mount, Harry Posey
From: Allen Sorenson ~ 5
RE: Incorporation of Cement Kiln Dust Management Plans into Mined Land Reclamation Permits,
Boettcher Quarry, Holnam, Inc., Permit No. M-77348
~~~~~
DEPARTMEIJT OF
NATURAL
RESOLJIZCES
Roy Romcr
Governor
(amen 5 Lorhhead
Exerueve Director
Mic h. e B Long
Divi.ion Director
Incorporation of a Cement Kiln Dust (CKD) management plan into the reclamation permit for the Boettcher
Quarry will most likely involve the submittal of both a technical revision and a permit amendment. The technical
revision will address the specifics of the CKD management plan, and the amendment will include the cement
plant into the permitted area.
The primary environmental concerns related to the disposal of CKD at the Boettcher Quarry are ground water
protection and dust control. Rule 3.1.7 of the Construction Materials Rules and Regulations of the Mined Land
Reclamation Board details the procedures to be followed to gain approval of a ground water protection plan.
The technical aspects to be followed in cases where a mining or processing waste such a:; CKD is to be
disposed include:
1. Geochemical characterization of the waste in order to determine the contaminants of concern and any
elements or characteristics of the waste that may serve as indicators that ieachate from the waste has
entered ground or surface water.
2. Complete a hydrogeologic characterization study of the area where the waste disposal will occur.
Assess potential ground water flow pathways that may be contaminated by leachate `rom the waste.
Characterize ambient ground water quality. The tens "Ambient Groundwater Quality' is defined in the
Construction Materials Rules at 1.1(5).
3. Design waste disposal facility. Are liners and covers required to protect ground welter? Or is the
geologic setting suitable to allow disposal in an unlined facility?
4. Establish point of compliance monitoring wells and numeric protection levels as described in Rule
3.1.7.
5. Include in the technical revision a dust control plan for the CKD disposal areas. Tflis may include
application of daily cover, application of water or other palliatives.