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~~i ~~~~~~~~~~1~~~~~ <br />999 <br />ST~Tt OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />DrParlment of Natural Resources <br />i 31 } Sherma n Sr.. Room ? 15 <br />Denver, Colorado 80201 <br />Phone 13031555-3567 <br />FAX' f303) 832 (1706 <br />Date: December 3, 1999 <br />(Fina}ized January 16, ?001) <br />~~ <br />DIVISION Of <br />MI~tERALS <br />GEOLOGY <br />R E~LAM ATION <br />MINING„$AfE{Y <br />Bdl p..<m <br />To: Bruce Humphries cover^o, <br />Jim Stevens GegE Watcher <br />Cazl [VlOnnt E.ecvri.e O~rec;ar <br />chael B. long <br />Tom Gillis r, q /~ -~ ~'~. ~o~r•~:~^n oar«ler <br />From: Harry Posey ~~~~~~_ W I '' ~ ~~Zy~ <br />Allen Sorenson J <br />Subject: Cement Kiln Dust: Issues ofLong-term Storage at Limestone Mines <br />BACXCGROUND AND PERSPECTIVE <br />In August ] 999 the Environmental Protection Agency Office of Solid Waste proprsed <br />management standazds for Cement Kiln Dust (CKD) waste. The following statements aze taken <br />from EPA's Environmental Fact Sheet issued at the time of the announcement of the proposed <br />CKD management standards. <br />• Although current disposal practices cause some env-vonmental damage, the Agency <br />found that regulating cement kiln dust as a hazardous waste was not appropriate. Since <br />some controls aze needed, EPA is proposing a tailored set of standazds for managing <br />cement kiln dust waste. <br />• The Agency's preferred option is to provide management standazds whereby CKD <br />remains a nonhazazdous waste so Long as the waste is managed according to the <br />requirements. Cement kiln dust becomes a regulated hazardous waste only if significant <br />violations of the management standards occur. <br />• Under EPA's proposed standards, cement kiln dust is to be managed in la»dfills designed <br />to meet specific performance requirements that protect ground water from toxic metals. <br />In addition to performance criteria, the Agency is proposing technology-based standard$ <br />that meet the performance criteria, such as using composite liners in landfills. <br />Requirements for ground-water monitoring, corrective action, closure, and post-closure <br />care are also included. <br />• To control releases of cement kiln dust to air, EPA is proposing performance standazds <br />requiring facility owners and operators to take measures to prevent releases from <br />landfills, handling conveyances, or storage azeas. As an a{temative to the performance- <br />based standard, the Agency is proposing technology-based standards that require: (I) <br />