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2005-01-31_REVISION - M1977208
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2005-01-31_REVISION - M1977208
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Last modified
6/16/2021 6:21:22 PM
Creation date
11/21/2007 11:41:53 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977208
IBM Index Class Name
Revision
Doc Date
1/31/2005
Doc Name
Response to Adequacy Ltrs.
From
CEMEX Inc
To
DMG
Type & Sequence
TR4
Media Type
D
Archive
No
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Response [o Adequacy Letters (dated November 22 and December 17, 2004), CEMEX, Inc., Lyons Quarry, Permit <br />No. M-1977-208, TR-04 and TR-O5. <br />Page 3 of 3 <br />• If seepage transport for C-Pit to the Dakota were possible, the travel time to [he Dakota <br />would likely be several hundred years or more (if the seepage azrived at all, given the <br />artesian conditions in the Dakota). <br />Considering the hydrogeologic setting of C-Pit and the results of the conservative transport <br />model, ponded water in C-Pit is not reasonably expected to impact groundwater quality in the <br />Dakota aquifer. Therefore, water in C-Pit does not required accelerated removal or treatment <br />from a groundwater quality perspective. Furthermore, groundwater monitoring is not required in <br />the Dakota aquifer since it is not reasonable to expect C-Pit seepage to migrate across the <br />intervening low permeability bedrock formations to the artesian Dakota aquifer. <br />Cemex's Proposal for Monitorin¢ and Control of C-Pit Water <br />Cemex's proposal is based on the position that there is no threat to groundwater quality resulting <br />from C-Pit water and no significant short-term threat [o wildlife (based on Cemex's wildlife <br />report by Mike Figgs and responses from the Colorado Division of Wildlife and the U.S. Fish <br />and Wildlife Service). <br />Cemex will install a new detection well to confirm the findings on hydrogeologic setting and the <br />computer model results. The well will be installed southeast of C-Pit and will be screened in the <br />Fort Hays limestone and overlying/underlying shale for approximately 10 feet in each direction <br />(located on Attachment 1). The well will sampled quarterly and analyzed for the following six <br />analytes of concern: dissolved selenium, dissolved thallium, pH, total dissolved solids, sulfates, <br />and chlorides. C-Pit will be sampled quarterly as a surface water source and analyzed for the <br />same six analytes. A-Pit monitoring will cease and no other surface water will be monitored. <br />Water Treatment and Miti ation <br />If water remains in C-Pit after December 2005 that does not meet the water quality standazds put <br />forth in TR-04, Cemex will file a Technical Revision for either treatment of the water and/or <br />mitigation for wildlife impacts. This time frame of approximately one year does not present any <br />threat to groundwater or wildlife and allows Cemex to pump the water to minimum feasible <br />levels as planned. Furthermore, this will allow Cemex and the Division to review the data <br />collected over that time. <br />In order to provide the Division with adequate review time, Cemex respectfully requests an <br />extension of the decision date to Febtvazy 28, 2005. Should you have any questions regazding <br />this submittal, please feel free to contact me at (303) 823-2109 or Mr. Eric Hodek of my staff at <br />(303)823-2115. <br />Sincerely, <br />~~ <br />L.ohr <br />Manager <br />
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