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standpoint, approval of the amendment makes the CKD an onsite rather than an imported waste. <br />From a technical standpoint, the cement plant must be included in the reclamation permit area in <br />order to provide regulatory controls over the generation of the CKD, e.g., the types of fuel or <br />chemicals used in the kilning process, which may effect the geochemistry of the CKD. [n <br />particular, if a cement plant were to begin using alternative fuels such as wood, tires, or waste <br />oil, the potential changes to the nature of the CKD should be evaluated. <br />This memo discusses some of the details of CKD generation and disposal at the three Colorado <br />cement plants. A discussion of the geochemistry of cement and CKD are provided for <br />background. <br />The Holnam-Boettcher operation and the Southdown-Lyons operation have completed waste <br />characterization studies and have established groundwater monitoring programs. The Holnam- <br />Portland operation has completed waste characterization and some groundwater monitoring, and <br />the division is processing a TR for continued CKD disposal at the Portland plant. Based on (a) <br />leach test results, (b) chemical analysis of pit water adjacent to one of the quarries, and (c) CKD <br />waste handling commitments, groundwater monitoring did not seem justified at the Lyons <br />operation. The latter point - "CKD waste handling commitments" -was most important in <br />reaching that determination and is discussed in the following sections. <br />A PRIMER ON PRODUCTION, CHEMISTRY, AND PROPERTIES OF CEMENT <br />Cement is produced by burning limestone and clay at very high temperatures in an inclined <br />rotazy kiln. It can take up to 2 hours for the raw materials to pass through the kiln depending on <br />its length. As the mixture moves down the cylinder, it progresses through four stages of <br />transformation. Initially, any free water is driven off, then calcination occurs by driving off <br />bound water and carbon dioxide. After calcination, the limestone has been converted to lime <br />(CaO). The third stage is called clinkering, where lime and decrepitated clay combine to form <br />calcium silicates and calcium aluminates as shown in the following equation. The fourth stage in <br />the process is the cooling of the clinker. <br />CaCO3 + SiO~ + AhO3 + Fe~O3 + H~O(bound) + heat <br />(limestone) (clay) <br />~ 3CaO•SiO~ + 2CaO•SiO, + 3CaO•AhO3 + 4CaO•A1~O~•Fe,O~ <br />(tricalcium silicate) (dicalcium silicate) (tricalcium aluminate) (tetracalcium aluminoferrite) <br />The compounds shown on the product side of the equation comprise 90 percent of Portland <br />cement. When water is added the two calcium silicates, which form approximately 75 percent of <br />cement by weight, react to produce tobetmorite gel and calcium hydroxide. Tobermorite gel is <br />the main cementing component of cement paste. The average diameter of a grain of Portland <br />cement as ground from the clinker is about 10 Nm. The particles of the hydration product, <br />tobermorite gel, aze on the order of a thousandth that size. The enormous surface area of the gel <br />(about 3 million cm'/g) results in very large attractive forces, or cementation. <br />