2002-12-16_REVISION - M1977344 - Laserfiche WebLink

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DMG December 13, 2002 Page 4 of 5 The CKD disposal plan should show on a revised TR-6 map the location of all existing CKD disposal areas within the permit boundary and the proposed location of additional areas to be used for that purpose far at least the next 10 years. Holcim should also decide whether the pre- law CKD disposal sites south and southeast of the plant area should be brought into the permit area to be regulated by the Division under Holcim's reclamation permit. If Holcim does not bring those areas into the permit, another state or federal agency, at some point in the future, may want to regulate them separately. The plan should discuss any changes from the presently approved CKD disposal process including the possible elimination of liquid sewage sludge for control offugitive dust and any replacement method for the control of dust. Also, provide your plans to protect CKD disposal areas from future disturbance by mining related activities, under the permit. Response: Holcim's CKD Disposal Plan, located at Section 5 of the attached Groundwater Monitoring Plan, considers the issues noted in the DMG review. Note in particulaz: • Holcim has already eliminated the application of sewage sludge to the disposed CKD. Fugitive dust is controlled by the addition of water at the pug mill adjacent to the kiln, prior to loading for disposal. • Regarding the "pre-law CICD disposal sites" south and southeast of the plant area, Holcim reiterates its position, based on the Declaratory Order issued June 23, 1993 by the Mined Land Reclamation Board, that these areas are outside of the jurisdiction of the DMG and do not constitute mining activities. Holcim continues to elect to not bring these areas into the mine permit. DMG: Your plan to characterize ambient ground water conditions and for continued sampling and analysis of the ground water should address all requirements of the Construction Materials Rules and Regulations at section 3.1.7(7). Your plan should also include a commitment to the attached "Ground Water Compliance Protocol. " Your plan may include a monitoring well/s located where water can be sampled under old CKD disposal areas. The Division suggests that the plan include upstream and downstream analysis of Arkansas River water. Response: Holcim's proposed Groundwater Monitoring Plan addresses the issues noted in the DMG review, and is attached to this response. Holcim does not commit to the suggested sampling of the Arkansas River up and downstream of the site, unless DMG can provide a specific regulatory basis for such sampling. Holcim currently operates six (6) outfalls under Colorado Discharge Permit System (CDPS) Permit Number CO-0000671. Four outfalls are on the plant side of the Arkansas River and 2 outfalls are on the quarry side of the river. Under normal operating conditions, cooling water and waste water treatment facility effluent is re- circulated for use in cement production and there is no discharge of plant water to the outfalls. Holcim is permitted to discharge stormwater from three of the permitted outfalls. Sampling frequency and analysis requirements for dischazge from all outfalls is set forth in the CDPS permit. Refer to the discussions in Section 2.2 and 3.2 of the attached Groundwater Monitoring Plan for an assessment of the potential impacts of the site on the river. DMG: Holcim should include in the disposal and monitoring plans a section on the characterization of the CKD/sewage sludge leachate, including information on CKD sampling, leaching methods, and analysis. The Division does not believe that the leachate characterization