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Mr. Justin Andrews <br /> October 29, 2014 <br /> ' Page 2 <br /> ! increased concentrations of sodium are not attributable to impacts from CKD. Please <br /> provide some discussion on this point. <br /> 2) Literature data: An argument is presented that the data presented in the roughly 350- <br /> page Report to Congress on Cement Kiln Dust is from plants similar to the Portland <br /> Limestone Quarry. A review of previous Technical Revisions to this permit (e.g., TR-01 <br /> & TR-06) indicate bio-solids from the nearby Fremont County Sanitation District <br /> wastewater treatment plant are mixed with CKD as part of the backfilling/landfilling <br /> disposal process. Sludge samples analyzed for TR-06 suggest the addition of the bio- <br /> solids alter the chemistry of that typical for CKD. Please provide some discussion <br /> related to the referenced Report to Congress as to whether or not bio-solids are included <br /> in the characterization of CKD at similar cement plants. <br /> r3) The use of the K:Na ratio: The Division is concerned about this approach. Currently,the <br /> observed potassium concentrations are relatively constant (the standard deviation being <br /> ' only 10% of the mean in MW-13), whereas the observed sodium concentrations are less <br /> consistent (the standard deviation being 16% of the mean in MW-13) as seen from the <br /> July 2014 groundwater monitoring report. Mr. Peters proposes a K:Na ratio of 0.5. The <br /> 2009-2010 K:Na ratio for reported values are roughly 0.05, an order of magnitude less. <br /> Furthermore, if Na concentrations continue to increase, while K concentrations remain <br /> essentially the same, the proposed ratio of 0.5 will be quite easy to achieve. Of greater <br /> ' concern is that both Na and K concentrations could increase over time, but as long as the <br /> concentration of Na is at least twice that the K, the proposed standard would be met. <br /> Significant increases in either Na or K and Na should be viewed as a concern from the <br /> Division's viewpoint. A greater discussion on the K/Na chemistry as it relates to CKD <br /> and a more compelling argument for the K:Na ratio needs to be provided to the Division <br /> before this approach can be considered. <br /> If you have any questions or need further information,please contact me at(303)866-3567 x8169. <br /> Sincerely, <br /> Timot . Cazier, P.E. <br /> Environmental Protection Specialist <br /> ec: Tom Kaldenbach, DRMS <br /> Amy Eschberger, DRMS <br /> DRMS file <br /> m'unui'Ic1 framunCm-77-344nortlandhrnestuequwy\trl0\par31oct14.docx <br />