Laserfiche WebLink
Southdown Inc., Lyons Quarry, Lyons, M-77-208 <br />The cement industry has known that EPA would be proposing CKD management standards for <br />some time. On August 5, 1998 a meeting was held with representatives from Holnam, the <br />American Portland Cement Alliance, DMG and the Hazardous Materials and Waste <br />Management Division in attendance. Holnam laid out their position on CKD management as <br />follows: <br />• Protective management standards for the disposal of CKD are appropriate. <br />• In Colorado, the Hazardous Materials and Waste Management Division and/or DMG have <br />authority to regulate CKD management. <br />• By exercising existing state authority, Federal rule may be unnecessary. <br />• Holnam wants to facilitate state agencies obtaining statutory authority to regulate CKD <br />management. <br />• Holnam is seeking stringent regulation of management practices under state authority. <br />It was determined in discussions between DMG and Hazardous Materials and Waste <br />Management Division that DMG is the appropriate agency to regulate CKD disposal. DMG <br />regulation of CKD disposal is appropriate because: <br />All three of the cement plants in Colorado dispose of CKD in mined out limestone quarry <br />pits. CKD disposal in the quarries at all three sites has been ongoing for several years, and <br />DMG has jurisdiction over the environmental impacts and reclamation of the quarries. <br />DMG routinely permits and regulates the disposal of mining or processing waste generated <br />from within a reclamation permit area. DMG does not generally regulate the landfilling of <br />imported waste unless it meets the definition of inert waste in Rule 1.1(20). By bringing the <br />areas of the cement plant where CKD is generated, stored or transported into the reclamation <br />permit (see below), CKD becomes in effect amining/mineral processing waste that DMG <br />may regulate. <br />DMG is the implementing agency for groundwater protection at active mines and thereby has <br />the capacity to monitor for pollutants that may derive from CKD disposal. <br />DMG has the authority to require stabilization of landfilled CKD, by periodic cover <br />application or water application, to prevent dust generation (34-32.5-116(4)(j), C.R.S.). <br />DMG has the authority to require final closure and reclamation of CKD landfills within the <br />reclamation permit area. <br />The cement plants in Colorado are eager to come under DMG regulation of CKD disposal <br />because CKD landfills not regulated in accordance EPA's proposed standards may be cited as <br />unpermitted hazardous waste facilities. To this end, all three of Colorado's cement facilities <br />have submitted technical revisions to incorporate CKD disposal standards into their reclamation <br />permits. The technical revisions detail the geochemistry of the CKD, ground water protection <br />measures and monitoring, dust control, and closure and reclamation. The procedure being <br />followed by the DMG is to incorporate the CKD disposal standards into the permit through the <br />technical revision process, then to include all areas of the operation where CKD is generated, <br />temporarily stored, or transported into the permit through an amendment. From a regulatory <br />