1999-11-11_REVISION - M1977208

• Permit No: M1977208
• IBM Index Class Name: Revision
• Doc Date: 11/11/1999
• Doc Name: REVIEW DRAFT
• Type & Sequence: TR1
• Media Type: D
• Archive: No

iii iiiuiiiiiiu iii
REVIEW DRAFT
Date: November 11, 1999
To: Bruce Humphries
Jim Stevens
Carl Mount
Tom Gillis
From: Harry Posey
Subject: Cement Kiln Dust
]n August 1999 the Environmental Protection Agency Office of Solid Waste proposed
management standards for Cement Kiln Dust (CKD) waste. The following statements are taken
from EPA's Environmental Fact Sheet issued at the time of the announcement of the proposed
CKD management standards.
• Although current disposal practices cause some environmental damage, the Agency found
that regulating cement kiln dust as a hazardous waste was not appropriate. Since some
controls are needed, EPA is proposing a tailored set of standards for managing cement kiln
dust waste.
• The Agency's preferred option is to provide management standards whereby CKD remains a
nonhazardous waste so long as the waste is managed according to the requirements. Cement
kiln dust becomes a regulated hazardous waste only if significant violations of the
management standards occur.
• Under EPA's proposed standards, cement kiln dust is to be managed in landfills designed to
meet specific performance requirements that protect ground water from toxic metals. In
addition to performance criteria, the Agency is proposing technology-based standards [hat
meet the performance criteria, such as using composite liners in landfills. Requirements for
ground-water monitoring, collective action, closure, and post-closure care are also included.
• To control releases of cement kiln dust to air, EPA is proposing a performance standard that
requires facility owners and operators to take measures to prevent releases from landfills,
handling conveyances, or storage areas. As an alternative to the performance-based standard,
the Agency is proposing technology-based standards that require: (1) compacting and
periodic wetting of CKD managed in landfills; (2) on-site handling of CKD in closed,
covered vehicles and conveyance devices; and (3) keeping cement kiln dust in enclosed
tanks, containers, and buildings when temporarily stored for disposal or sale.
There aze three cement plants in Colorado. The Mined Land Reclamation Board holds permits
on the limestone quarries associated with each of these plants as follows:
Holnam Inc., Portland Quarry, Florence, M-77-344.
Holnam Inc., Boettcher Quarry, Fort Collins, M-77-348