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• compacting and periodic wetting of CKD managed in landfills; (2) on-site handling of CKD m 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 are three cement plants in Colorado. The Mined Land Reclamation Board holds permits on the limestone quames associated with each of these plants as follows: Holnam [nc., Portland Quarry, Florence, NI-77-344. Holnam Inc., Boettcher Quarry, Fort Collins, M-77-345 Southdown Inc., Lyons Quarry, Lyons, M-77-208 On August 5, 1998 representatives 1>•om Holnam, the American Portland Cement Alliance, DMG and the Hazardous Materials and Waste Management Division discussed potential regulatory management of ChD. Holnam's position on CKD management was as follows: • Protective management standazds for the disposal of CKD are appropriate. • In Colorado, the Hazazdous Materials and Waste Management Division andlor DMG have authority to regulate CKD management. • By exercising existing state authority, Federa] rule may be unnecessary. • Holnam wants to facilitate state agencies obtaining statutory authority to regulate CKD management. • Holnam seeks stringent regulation oT management practices under state authority. As determined by DMG and Hazazdous Materials and Waste Management Division, DMG is the appropriate agency to regulate CKD disposal for the following reasons: A11 of the cement plants in Colorado dispose of CKD in mined out limestone quarry pits. CKD disposal in the quames at all tluee sites has been ongoing for tens of years, and DMG has jurisdiction over the environmental impacts and reclamation o f the quames. DMG routinely permits and regulates the disposal of mining or processing waste generated 1>•om within a reclamation permit azea. DNIG does not generally regulate the landfilling of imported waste unless it meets the definition of inert waste in Rule. I.1(20). By bringing the azeas of the cement plant where CKD is generated, stored or transported into the reclamation permit (see below), CKD becomes in effect amining/mineral processing waste that DMG may regulate. DNIG is the implementing agency for groundwater protection at active mines and thereby has the capacity to monitor for pollutants that may derive from CKD disposal. DNIG has the authority to require stabilization of landfilled CKD, by periodic cover application or water application, to prevent dust generation (34-32.S-1 lb(4)(j), C.R.S.). DNIG has the authority to require final closure and reclamation of CKD landfills within the reclamation permit area. CKD landfills not regulated in accordance with EPA's proposed standards may be cited as unpermitted hazardous waste facilities. To this end, all three of Colorado's cement facilities