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compacting and periodic wetting of CKD managed in landfills; (Z) on-site handling of CICD inclosed, covered vehicles and conveyance devices; and (3) keepin~~, 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 Botud holds permits on the limestone quarries associated with each of these plants as follows: Holnam Ins, Portland Quarry, Florence, M-77-344. Holnam inc., Boettcher Quarry, Fort Collins, M-77-348 Southdown Inc., Lyons Quarry, Lyons, M-77-208 On August 5, 1998 representatives from Holnam, the American Portland Cemant Alliance, DMG and the Hazardous Materials and Waste Management Division discussed pc tential regulatory management of CICD. Holnam's position on CICD management was as follows: • Protective management standards 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, Federal rule may be unnecessary. • Holnam wants to facilitate state agencies obtaining statutory authority to regulate CKD management. • Holnam seeks stringent regulation of management practices under state authority. As determined by DMG and Hazardous Materials and Waste Management Division, DMG is the appropriate agency to regulate CKD disposal forthe following reasons: • All of the cement plants in Colorado dispose of CKD in mined out limestone quarry pits. CKD disposal in the quarries at all three sites has been ongoing for tens of years, and DMG hasjurisdiction over the envirotunental impacts and reclamation of the quames. • DMG routinely permits and regulates the disposal of mining or processing waste generated from within a reclamation pezmit area. DMG does not generally regulate the landfilling of imported waste unless it meets the definition of inert waste in Rule l .l (20). By bringing the azeas of the cement plant where CKD is generated, stored or transported into the reclamation permit (see below), CICD becomes in effect a mining/rnineral processing waste that DMG may regulate. • DMG 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. • DMG has the authority to require stabilization of landfilled C1CD, by periodic cover application or water application, to prevent dust generation (34-32.5-116(4jQ), C.R.S.). • DMG 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