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III IIIIIIIIIIIII III ~ ~ ,M _~,-,_ ~g DIVISION OF Abu NERA LS AND GEOLOGY Depdrtmenl OI Ndluld Ra>OUr~BS U I }Sherman $l . Room 21 5 Denver. Colorado 8020} Phone: I}OJI 965-3567 f.,h ~,J0J19}~ 810ti Date: December 3, 1999 (Finalized January I6, ZOOI ) STATL Or COLORADO To: Bruce Humphries Jim Stevens Carl Mount Tom Gillis From: Harry Posey ~C~/ ~°n Allen Sorenson f~~`~~~(i},G~~-~`-- Subject: Cement Kiln Dust: Issues of Long-term Storage at Limestone Mines BACKGROUND AND PERSPECTIVE OIV1510~ ~ ~~l I N E RA GEOLOG a =_c~.~n.,r~c H IN IN G'$AFE Bdl O'.%:m c~.o,~or Greg E. w~l<her E.ecunw D~reuor ~•,~cnaal B Lung o~~~,~on o~re~~or In .August 1999 the Environmental Protection Agency Office of Solid Waste proposed management standards for Cement Kiln Dust (CKD) waste. The following statements aze 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 consols 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 that meet the performance criteria, such as using composite liners in landfills. Requirements for ground-water monitoring, corrective action, closure, and post-closure care are also included. • To control releases of cement kiln dust to air, EPA is proposing performance standards requiring facility owners and operators to take measures to prevent releases from landfills, handling conveyances, or storage areas. .4s an alternative to the performance- based standard, the Agency is proposing technology-based standards that require: (l)