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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1373 Sherman St., Roam 275 <br />Denver, Colorado 80203 <br />Phone: (303) 8664567 <br />FAX: (303) 832-8106 <br />December 17, 2004 <br />Mr. Paul Banks <br />Banks & Gesso, LLC <br />720 Kipling St., Suite 117 <br />Lakewood, CO 80215 <br />RE: CEMEX, Inc., Lyons Quarry; Permit No. M-1977-208 <br />TR-O5; Adequacy Letter <br />Deaz Mr. Banks: <br />COLORADO <br />DIVISION O F <br />MIN SRALS <br />GEOLOGY <br />RECLAMATION•MINING <br />SA FETY•SC IENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive Director <br />Ronald W. Cattany <br />Division DireLTOr <br />Natural Resource Trus[ee <br />The Division received Technical Revision (TR-OS) for the Lyons Quarry, Permit No. M-1977-208 <br />operated by CEMEX, Ina To abate a high pH problem in C-Pit at the Lyons Quarry, CEMEX has <br />proposed a water treatment plan in case pumping water from the pit is insufficient to alleviate the <br />potential risk to wildlife. The Division has the following comments regazding the water treatment <br />plan. <br />The introductory paragraph of the URS report correctly recalls that a prior report indicated <br />there is no risk to groundwater. However, the Division has asked for proof of that lack of <br />risk in the form of a monitoring well drilled into the Dakota Sandstone in the Division's <br />adequacy letter pertaining to TR-04. Nothing in the Operator's citation will be construed to <br />change the Division's position on the need for a deep monitoring well into the first aquifer <br />below the site. <br />2. The proposal under TR-26 has two sections: a cover letter that explains the proposal, and a <br />iJRS Corporation "Water Treatment Plan" report attached. Explanations of the Plan in these <br />two documents are slightly discrepant. <br />The letter says the pit will be pumped down to the "smallest practical size;" that level, which <br />appazently is to be 4 feet water depth, will be determined by "pump limitations," and the <br />remaining pond surface azea after pumping "will be significantly smaller than the <br />approximate 7 acres that the [pond] currently covers." After ptnnping to a 4-foot level - or <br />thereabouts, presumably -water from A-pit will be used in place of the C-Pit water. After <br />pumping to the "smallest practical size the water quality of the water remaining in the pit will <br />be analyzed and compazed to the applicable standards..." through consecutive sampling <br />events and, if standards aze met, "the source will be deemed to have been removed." The <br />letter also indicates that adjustments maybe made to promote pumping even more water <br />from C-pit. <br />The attached URS report states, however, that "[i]n the event that CEMEX is not able to use <br />all of the water ponded in the C-Pit, a contingent water treatment plan is provided in this <br />document to treat the ponded C-Pit water." Thus the two documents aze not in agreement <br />over whether water will be treated or not. <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />