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2002-12-16_REVISION - M1977344
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2002-12-16_REVISION - M1977344
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Last modified
5/20/2020 1:01:05 PM
Creation date
11/21/2007 6:14:08 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977344
IBM Index Class Name
Revision
Doc Date
12/16/2002
Doc Name
Second Adequacy Review-Response
From
Holcim (US) Inc.
To
DMG
Type & Sequence
TR6
Media Type
D
Archive
No
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DMG <br />December 13, 2002 <br />Page 2 of 5 <br />monitoring on the east side of the fault zone if Holcim's future CKD disposal needs ever make <br />disposal in the Bear Creek area necessary. <br />Item No. 11 <br />DMG: Holcim will conduct TCLP leach testing [of CKD] semiannually and submit the resulting <br />analytical data to the Division in the annual report. <br />Response.• Holcim commits to providing semiannual CKD leach test data in future annual reports. <br />The testing methodology (TCLP, modified TCLP, or a more representative method) will be <br />discussed and agreed upon with DMG prior to futwe testing. <br />Item No. 12 <br />DMG: Please commit to providing the Division information regarding future changes in the <br />kilning process that could significantly change the nature of the leachable chemical composition <br />of CKD. The Division recommends the following condition for approval of TR-6. <br />"Within 30 days of a decision by Holcim to change the kilning process in a manner that <br />could significantly change the nature of the leachable chemical composition of CKD, <br />Holcim will provide the Division a description of the change/s. Change/s would include <br />but not be limited to new fuel type, materials added or deleted from the kilning process. " <br />Please state whether or not Holcim commits to the above condition of approval. <br />Response: Holcim commits to the above condition, with minor modifications that more <br />accurately describe the current cement process, as indicated below: <br />"Within 30 days of a decision by Holcim to change the burning process in a manner that <br />could significantly change the nature of the leachable chemical composition of CKD, <br />Holcim will provide the Division a description of the change/s. Change/s would include <br />but not be limited to new fuel type, materials added or deleted from the raw mix, etc." <br />Item No. 14 <br />DMG.• Holcim has not adequately responded to this item. Please provide a chemical <br />characterization of the wet kiln process CKD. <br />Response: Tables attached to this response summarize the chemical composition of the CKD <br />from the prior wet process. <br />Item No. 21 <br />DMG: You have stated that a survey indicated the existence of water wells in the general area, <br />but that none were close enough to the site to provide data representative of the groundwater <br />conditions in the area. If any of these wells are within 600 feet down gradient of the proposed or <br />existing CKD disposal areas, show their locations on an Exhibit C Map, show the well depth, and <br />the depth to the static water level. <br />
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