GENERAL54948

• Permit No: M1977208
• IBM Index Class Name: General Documents
• Doc Date: 12/30/2002
• Doc Name: Recap of 12/18/02 Meeting
• From: DMG
• To: CEMEX Inc.
• Media Type: D
• Archive: No

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STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
December 30, 2002
Mr. John Lohr
CEMEX
P.O. Box 529
Lyons, CO 80540
RE: CEMEX, Inc., Lyons Mine, Permit No. M-1977-208
Recap of 12-18-02 Meeting
Deaz Mr. Lohr,
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION
MINING•SAFETY
Bill Owens
Governor
Greg E. Walther
Executive Director
Ronald W. Cal[any
Acting Division Director
CEMEX, INC. and the Division discussed three issues during the 12-18-02 meeting. The intent
of this letter is to recap the issues for revised groundwater monitoring pazameters related to
burning of tires in the cement plant, reclamation and bonding of the cement plant, and the bond
release status of the Larimer Pit, Permit No. M-1977-341.
Tire Burning: The issue related to tire burning in the cement plant is the possibility of change
in the geochemistry of the cement kiln dust (CI{D). The Division believes that a change in the
fuel content may result in potential changes to the nature of CKD. The Division's regulatory
authority for CKD is to ensure that groundwater impacts are minimized both during mining and
reclamation of the site (C.R.S. 34-32.5-116(4)(h) of the Colorado Land Reclamation Act for the
Extraction of Construction Materials).
Discussions with CDPHE suggest that the complete combustion of tires would eliminate all
organics. Tire burning involving either complete or incomplete combustion also has the
potential to release metals to the residues. However, incomplete combustion could release semi-
volatiles to the ash and the ash in turn might release those to groundwater. The Division
recommends testing that involves volatile-organic compounds, and focusing on compounds that
act as indicators. As recommended in the Division's letter of November 20, 2002, CEMEX
should consult with an organic chemist on this matter.
Reclamation and Bonding of the Cement Plant: In a letter dated October 28, 2002, the
Division provided two options for CEMEX regarding reclamation and bonding of the cement
plant that is located within the permit boundazy of the Lyons Quarry. The first option is to
change the postmining land use to industrial commercial in the form of a permit amendment,
and include a letter from Boulder County Land Use Depaztment stating that the cement kiln
facility can remain as a part of the postmining end land use once the operation is no longer in
use. The second option is to post a bond for reclamation of the cement facility in accordance
with the 1977 reclamation plan.