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Mr. Justin Andrews <br />October 29, 2014 <br />Page 2 <br />m:\min\tc1\_fremont\m-77-344 portland limestone quarry\tr10\par31oct14.docx <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 />3) 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 /> <br />Sincerely, <br /> <br /> <br />Timothy A. Cazier, P.E. <br />Environmental Protection Specialist <br /> <br />ec: Tom Kaldenbach, DRMS <br /> Amy Eschberger, DRMS <br /> DRMS file