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<br /> <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br /> <br /> <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br />John W. Hickenlooper, Governor | Mike King, Executive Director | Virginia Brannon, Director <br /> <br /> <br />October 31, 2014 <br /> <br /> <br />Mr. Justin Andrews <br />Holcim (US) Inc. <br />3500 Highway 120 <br />Florence, CO 81226 <br /> <br /> <br />Re: Portland Limestone Quarry, Permit No. M-1977-344; <br /> Technical Revision (TR-10) Preliminary Adequacy Review <br /> <br />Dear Mr. Andrews: <br /> <br />On October 20, 2014 the Division of Reclamation, Mining and Safety (Division) received a request <br />for a Technical Revision (TR-10) addressing the following: <br /> <br /> Proposal to remove sodium as groundwater quality parameter. <br /> <br />The submittal was called complete for the purpose of filing on October 20, 2014. The decision date <br />for TR-10 is November 19, 2014. Please be advised that if you are unable to satisfactorily address <br />any concerns identified in this review before the decision date, it will be your responsibility to <br />request an extension of the review period. If there are outstanding issues that have not been <br />adequately addressed prior to the end of the review period, and no extension has been requested, the <br />Division will deny this technical revision. <br /> <br />The Division is not opposed to modifying parameters used to indicate potential impacts to <br />groundwater from buried and/or landfilled cement kiln dust (CKD) at the Portland Limestone <br />Quarry. However, the Division has the following concerns and questions related to the proposal <br />submitted by Arcadis, dated August 4, 2014: <br />1) Increased depth to water vs. higher sodium concentration: Mr. Peters argues that the <br />observed trend in the increased depth to groundwater means there is less Arkansas River <br />water available in monitoring wells MW-7 and MW-13 for dilution. The Division <br />concurs the lower water level may be a contributing factor, but as stipulated by Mr. <br />Peters on the top of page 2, the correlation exhibited in MW-13 is not as strong. <br />Therefore, it is reasonable to assume there are other contributing factors, that Mr. Peters <br />concedes are “not clear”. Further, there is no discussion provided indicating the observed