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2011-09-06_REVISION - M1977208
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2011-09-06_REVISION - M1977208
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Last modified
8/24/2016 4:42:57 PM
Creation date
9/9/2011 7:46:42 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977208
IBM Index Class Name
REVISION
Doc Date
9/6/2011
Doc Name
Adequacy Review- Response
From
CEMEX
To
DRMS
Type & Sequence
TR11
Email Name
MAC
Media Type
D
Archive
No
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Operator to determine if additional sampling and /or mitigation is required. Please <br />commit to providing a written report within five working days when there is <br />evidence of groundwater discharges exceeding applicable groundwater standards. <br />Response: Once applicable standards have been established, CEMEX will report the results <br />within 5 working days of the receipt of the sample in the alluvial well CEM -004 <br />or in CEM -005. It may be two to four weeks of delay between when a sample is <br />taken and when the data is received from the lab. <br />Comment 4. The Operator has proposed eliminating monitoring location CEM -001 from the <br />water sampling program. The Operator contends the Fort Hays Limestone does <br />not meet the definition of an aquifer. C.R.S. 34- 32.5- 116(4)(h) states disturbances <br />to the hydrologic balance of the affected land and of the surrounding area and to <br />the quality and quantity of water in surface and groundwater systems, both during <br />and after the mining operation and during reclamation, shall be minimized. The <br />classification of a particular formation as an aquifer has no bearing on the <br />Operator's responsibility to minimize disturbances to groundwater systems. The <br />monitoring location CEM -001 is located down gradient of C -Pit and continues to <br />produce water samples. In addition, the Operator has reported fractures in the bed <br />rock transmit changes in head between the C -Pit and CEM -001. Therefore, the <br />Division believes this monitoring location should continue to be sampled on a <br />quarterly basis along with C -Pit and CEM -004. <br />Response: CEMEX proposes to continue monitoring CEM -004, and CEM -005 (once <br />installed; see response below) on a quarterly basis, and discontinue monitoring of <br />CEM -001. As DRMS points out, CEM -001 has had head connectivity to C -Pit <br />and therefore, it is somewhat redundant to use this well as a sampling point. It is <br />CEMEX's understanding that the monitoring and compliance objective is the <br />detection of elevated chemical constituents that could potentially migrate off -site. <br />Any potential off-site transport would be captured by sampling both CEM -004 <br />and CEM -005. Sampling C -Pit will provide information on how the water <br />exposed to CKD is changing over time, and the information from CEM -001 <br />would not add value. An additional reason CEMEX proposes to discontinue <br />sampling CEM -001 is that there is evidence that C -Pit is effectively contained <br />within a fractured bedrock system with very low hydraulic conductivity, and <br />CEM -001 is completed in that same system. At the May 12, 2011, meeting with <br />DRMS, CEMEX was asked to produce site - specific data to confirm this <br />conclusion. The attached document summarizes the available site - specific data <br />that leads us to this conclusion (Site- Specific Values of Hydraulic Conductivity in <br />Surrounding Bedrock Containing C -Pit). The last reason to discontinue sampling <br />CEM -001 is recent data suggests that the well may no longer be representative of <br />the Fort Hays Limestone and Smokey Hill Shale geological units. <br />Page 5 of 6 <br />
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