2002-12-16_REVISION - M1977344

• 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

DMG
December 13, 2002
Page 3 of 5
Response: No water wells other than those associated with Holcim's monitoring program are
within 600 feet down gradient of the proposed or existing CKD disposal azeas.
NEW ADEQUACY ITEMS:
Item No. 22
DMG: Please send a signed copy of your initial adequacy response
Response: A signed copy of the initial Holcim response is attached.
Item No. 23
DMG: Well MW-10 is no longer down gradient and may be of no use for monitoring for
migration of possible ground water contaminants. Holcim should determine it wants to propose
using this well for the purpose of determining ambient ground water conditions.
Response: As outlined in the attached Groundwater Monitoring Plan, Holcim proposes that MW-
10 be sampled for four (4) additional quarters to compile the ambient groundwater data set for
DMG to consider prior to its determination of the required groundwater monitoring parameters
for this site.
kem No. 24
DMG: Holcim included a summary of the water sample analyses for monitoring wells 5, 7, 8, 9,
and 10 in the submittal for your proposed ftmendment No. /. Please include that summary in
your response to this TR-6 second adequacy review.
Response: A summary table of groundwater sampling data for these wells is included in the
Groundwater Monitoring Plan attached to this response.
Item No. 25
DMG: The Division has approved the location of monitoring well MW-9... The well must be
within the permit boundary. This item can be resolved by changing the boundary by means of
your proposed amendment No. 1, enough to include the well site... Holcim should also include the
boundary change on a revised TR-6 (Fig. 2) map.
Response: The formal permit boundary will be resolved in Holcim's future response to DMG's
adequacy review of proposed Amendment No. 1. In the meantime, Figure 2 from TR-6 has been
revised to address the inclusion of MW-9 within the permit boundary, and is attached to this
response as a figure in the Groundwater Monitoring Plan.
Item No. 26
DMG: We want Holcim to propose a CKD disposal plan that covers a period of at least 10
years; a plan to determine ambient ground water quality and a plan for continued monitoring
and analysis of the ground water including points of compliance.