HYDRO22457

• Permit No: M1977208
• IBM Index Class Name: Hydrology
• Doc Date: 6/18/2004
• Doc Name: Groundwater Monitoring and Cement Kiln Dust Testing
• From: DMG
• To: CEMEX Inc.
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
June 18, 2004 `/
Mr. John Lohr/
CEMEX
P.O. Box 529
Lyons, CO 80540

RE: CEMEX, Inc., Lyons Mine, Permit No. M-1977-208
Groundwater Monitoring and Cement Kiln Dust Testing
Deaz Mr. Lohr,
COLORADO
DIVISION O F
MINaRALS
GEOLOGY
RECLAM ATION•NIN ING
EAiETY•ECIENCE
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
The Division of Minerals and Geology has concluded its review of the Cement Kiln Dust (CKD) fire
derived fuel ash groundwater monitoring requirements at the CEMEX Lyons Mine, Permit No. M-1977-
208. Clmently, the Lyons Mine permit requires twice-yeazly monitoring of pH, conductivity, selenium,
and thallium. CEMEX is required to include the analysis in the annual reports, except in the case of
excursions outside water quality standazds.
At issue is whether groundwater should be monitored for pazameters that exceed standazds in leach tests
of CKD plus fire derived fuel ash. The Division believes that based on evaluation of the SPLP results of
CKD plus fire derived fuel ash (reported to the Division on September 4, 2003), the groundwater
monitoring plan should be revised to include sulfate. Sulfate was the only parameter that exceeded
standazds in the SPLP tests of CKD plus fire derived fuel ash. Therefore, prior to initiating fire derived
fuel at the CEMEX Lyons mine, a technical revision to the permit will need to be submitted and
approved by the Division to include sulfate as a parameter to the groundwater-monitoring plan.
Under normal production techniques at the CEMEX Lyons Plant should produce complete combustion
of the TDF. However, as noted in the Division's letter of October 30, 2004, any upset conditions or
shutdowns must be reported to the Division. Reporting procedures should be submitted as a technical
revision to the Lyons Permit.. The revision should lay out a procedure for reporting to the Division
within a week of any upset condition that would not assure complete fire combustion. At a minimum,
the report should include a description of the upset detailing the cause and a description of how materials
were handled afterwazds to prevent contamination of the ordinary CKD. The revision must be submitted
and approved by the Division prior to use of the TDF at the Lyons Cement Plant.
If you have any questions, please do not hesitate to contact me at 303-866-4943.
Sinc ely,
n~ros
Environmental Protecti pecialist
Enclosure
cc: Qazl Mount; DMG
Harry Posey; DMG
Paul Banks; Banks & Gesso
Office of Office of Colorado
Mined Land Reclamation Acrive and Inactive Mines Geological Survey