Laserfiche WebLink
7. Non-compliance with groundwater standards should be evaluated at the compliance point, <br />not the monitoring point. <br />8. Natural dilution between monitoring and compliance points is acceptable for reaching <br />compliance. <br />9. Groundwater use between monitoring and compliance points should be under the <br />institutional control of the operator. <br />10. Tn anticipation of and in case of contaminant dischazge, the operator should preclude use of <br />contaminated groundwater between monitoring and compliance points until such <br />contamination is mitigated. <br />Groundwater response plan: <br />)n the event of an upset or exceedance of a groundwater monitoring parameter, there should be in place a <br />goundwater response plan. The Division reviewed the CEMEX Lyons permit and could not locate a <br />goundwater response plan to be implemented in the event of an upset. Therefore, CEMEX will need to <br />address this issue as a revision to the permit by July 26, 2004. <br />In the present case, because the monitoring and compliance station actually comprise bodies of exposed <br />water, the response plan should first consider exposure to wildlife. Fundamentally, the mitigation plan <br />should include procedures for the following: <br />a. Groundwater permit conditions and monitoring parameters with reporting requirements. <br />b. Monitoring that records a possible excursion in monitoring parameter, indicating release of <br />constituents in excess of permit conditions. <br />c. Confirmation sampling, to confirm the report of a possible exceedance. <br />d. Response plan in case of upset or exceedance of monitoring parameter(s). <br />e. Mitigation plan to be developed in case of the upset condition needs mitigation. <br />If you have any questions, please do not hesitate to contact me at 303-866-4943. <br />Sin el , <br />Inca r ' <br />Environmental Protectionn S~list <br />Enclosure <br />ca 'Carl Mount; DMG <br />`Harry Posey; DMG <br />mate Pickford; DMG <br />Paul Banks; Banks & Gesso w/enclosure <br />