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2004-11-16_REVISION - M1977208
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2004-11-16_REVISION - M1977208
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Last modified
6/16/2021 6:21:20 PM
Creation date
11/21/2007 6:28:53 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977208
IBM Index Class Name
Revision
Doc Date
11/16/2004
Doc Name
Review
From
DMG-kap
To
DMG-esc
Type & Sequence
TR4
Media Type
D
Archive
No
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4. Under the Monitoring and Compliance Points, the Proposed Sampling and Analysis Plan Lyons <br />Quarry states, "CEMEX proposes to install two wells to serve as monitoring and compliance <br />points. The first well designated as the monitoring point (Well I) will be located midway <br />between A and C Pit along the hydraulic gradient. The second well designated as the <br />compliance point (Well 2) will be located downgradient,fr~A~=Pit as near as feasible to the <br />CEMEX property boundary. Both wells will be drilled a screened to collect groundwater <br />from the Fort Hays Limestone member." Further, under the Well Sampling Protocol, the <br />Proposed Sampling and Analysis Plan Lyons Quarry states, "Samples for laboratory analysis <br />will be collected only after a minimum of three water-column volumes have been purged. [f <br />water is not present in the well following purging, then the sampler shall wait 7 days and attempt <br />to resample. If there is insufficient water in the well after the third attempt, the well shall be <br />deemed dry for that sampling period:' The Division believes that placement of the monitoring <br />and compliance wells into the Fort Hays Limestone member is not the most effective approach <br />to monitoring the groundwater at the site. Unless there are any agricultural or residential wells <br />downgradient of C-Pit that tap into the Fort Hays Limestone, it appears that contamination of <br />groundwater in that member would have no impact on groundwater users. Of greater concern to <br />the Division is the aquifer tapped by users in the azea, which, to the knowledge of the Division, <br />is the Dakota Formation. Additionally, the Division believes that there is a good likelihood <br />that, according to the above sampling protocol, the wells may yield few if any samples due to <br />the tightness of the Fort Hays Limestone member. The Division does not accept a "dry well" <br />result in place of a sample for a monitoring or compliance well. Therefore, in the interest of <br />monitoring the aquifer used in the area and acquiring samples to be analyzed, the Division <br />believes that the monitoring and compliance wells should be drilled and screened into the <br />Dakota Formation. If, in fact, there are users in the area that tap into the Fort Hays Limestone <br />member, the Division may reconsider this position. <br />5. Under the Monitoring and Compliance Points, the Proposed Sampling and Analysis Plan Lyons <br />Quarry states, "Both wells will be sampled quarterly. If four consecutive quarters yield results <br />below the MCL, then sampling frequency will be reduced to annual." The Division does not <br />agree to this predetermined trigger to reduce sampling frequency. The Division believes that the <br />quarterly sampling should continue indefinitely. If, at some point in the future, the Operator <br />desires to reduce sampling frequency, the Operator should submit a Technical Revision request <br />indicating the change in sampling frequency. At that time the Division will review prior <br />sampling results and determine whether reduced sampling frequency is appropriate. <br />6. Under A and C Pits, the Proposed Sampling and Analysis Plan Lyons Quarry states, "A and C <br />Pits will continue to be sampled biweekly until the installation of Well 1. Following the <br />installation of Well 1, both pits will be sampled quarterly. [f four consecutive quarters yield <br />results below the MCL, then sampling frequency will be reduced to annual. If annual samples <br />yield results above MCL, quarterly sampling will resume. Sampling will be discontinued in A <br />Pit once 4 consecutive annual samples yield results below MCL." The Division agrees that once <br />the monitoring well (Well 1) is installed, sampling of A Pit may be reduced to quarterly <br />sampling. The Division does not agree, however, that the frequency of quarterly sampling in A- <br />Pit can be reduced prior to the reduction of pH and selenium levels in C-Pit water. Once the <br />acceptable levels are reached in C-Pit water, if the Operator desires to reduce sampling <br />frequency, the Operator should submit a Technical Revision request indicating the change in <br />sampling frequency. At that time the Division will review prior sampling results and determine <br />whether reduced sampling frequency is appropriate. The Division believes that sampling of A- <br />Pit water should continue throughout the life of C-Pit due to wildlife usage of A-Pit. <br />
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