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ARCOSA <br /> Site stormwater features including approximate surface water flow directions are shown on <br /> Exhibit G-3. These maps are included in Attachment 2. The updated Exhibit G, including <br /> references to these updated maps, may be found in Attachment 5. A copy of the original water <br /> rights agreement with the Hogan family (Land Owner) is described in Exhibit G and provided <br /> in Attachment 5. A third-party consultant was hired to perform an investigation into Arcosa's <br /> current water rights. A summary of that investigation is provided with Exhibit G. <br /> With regards to the waste materials being placed into the pit, Arcosa provided a response to <br /> DRMS request for information in a Technical Revision dated June 30, 2018, a copy of which is <br /> provided in Attachment 6. In summary the waste materials are comprised of three distinct <br /> materials. <br /> 1. Fines from the Pierre shale mining and crushing operations. This material is native <br /> Pierre shale from the mining area that is screened out prior to the raw product entering <br /> the kiln for further processing. <br /> 2. Baghouse fines. This material is comprised of particulates that are captured by a <br /> baghouse from the exhaust stream prior to entry into the scrubber tower. The baghouse <br /> fines are generally comprised of fine particles of native shale, calcined shale, and <br /> lightweight aggregate that are caught up in the air movement in the kiln <br /> 3. Lime scrubber sludge material. The lime scrubber sludge is a combination of very fine <br /> shale particulates as well as certain chemicals in the gas stream. As this third waste <br /> stream is comprised of more than just native materials, Arcosa conducted further testing <br /> to assess the compatibility for placement in the pit. These tests included an analysis for <br /> 32 metals using EPA Method 1312 (Synthetic Precipitation Leaching Procedure or <br /> SPLP), EPA Method 6010 (Metals Analysis), and EPA Method 365.4 (Phosphorus). <br /> Results were compared with national drinking water standards as well as the drinking <br /> water and agricultural standard presented in Regulation 41 (5-CCR-1002-41). These <br /> data are summarized in Table 1 of the technical revision, which is included in <br /> Attachment 6. At this point Arcosa has ceased backfilling the lime scrubber sludge until <br /> this issue can be resolved. Currently the material is being stockpiled at the processing <br /> area to be blended with shale fines. This blending, as discussed in Exhibit D, will <br /> provide improved compaction and workability of the soil when it is backfilled. <br /> Groundwater modeling was performed to assess whether parameters identified in the scrubber <br /> sludge would impact water quality in nearby drinking water wells. Based on this modeling, it <br /> was determined that the waste stream would naturally attenuate within 150 feet from the source. <br /> More information about water quality and water management is discuss in the revised Exhibit <br /> G, which is included in Attachment 5. <br /> DRMS Reference (underline) and Comment (italics) <br /> EXHIBIT E - RECLAMATION PLAN (RULE 6.4.5): <br /> (1) In preparing the Reclamation Plan, you should be specific in terms of addressing such items <br /> as final grading (including drainage), seeding;, fertilizing, revegetation (trees, shrubs, etc.), and <br /> topsoiling. You are encouraged to allow flexibility in your plans by committing to ranges of <br />