2011-10-26_REVISION - M1977208

• Permit No: M1977208
• IBM Index Class Name: REVISION
• Doc Date: 10/26/2011
• Doc Name: Adequacy Review
• From: CEMEX
• To: DRMS
• Type & Sequence: TR11
• Email Name: MAC
• Media Type: D
• Archive: No

Comment 1.
October 21, 2011
Mr. Michael Cunningham
Environmental Protection Specialist
Division of Reclamation, Mining and Safety
1313 Sherman Street, Room 215
Denver, Colorado 80203
Dear Mr. Michael Cunningham:
MCEVRO
OCT 26208
Diuldoa ®ff Reclamafok
Mining Safety
Via Certified Mail
Return Receipt Requested
700934100002 0993 8467
RE: Lyons Quarry; DRMS File No. M-1977-208; Technical Revision 11 - Adequacy Review
Below are the responses to your comments detailed in the Division's Adequacy Review letter of
September 23, 2011 regarding this facility's application for Technical Revisionl 1, DRMS File No.
M- 1977 -208 for Lyons Quarry:
The Division approved the addition of calcium, magnesium, potassium and sodium to
the analytes which were sampled for under Technical Revision - 08. The above listed
analytes were selected so that potential impacts to groundwater could be assessed.
The proposed analyte suite was intended for short-term monitoring, with the
understanding that the analytical parameter suite would be evaluated upon completion
of the C -Pit Hydrogeologic investigation. As the Applicant has pointed out, there are
no applicable groundwater standards for calcium, magnesium, potassium or sodium.
The Division has reviewed the analytical results of the groundwater monitoring
program and approves the removal of calcium, magnesium, potassium and sodium
from the analyte suite.
Response: CEMEX appreciates the Division's willingness to remove analytes that have no
applicable groundwater standards from the analyte suite including calcium,
magnesium, potassium and sodium.
Comment 2. CEMEX has proposed applying drinking water standards (CDPHE WQCC 1002 -41
Regulation No. 41) to the CEM -004 monitoring well. Please describe how the
drinking water standards will be applied to the CEM -004 monitoring well; typically
standards are only applied to the compliance well.
Response: If the Division prefers not to have a set of standards with which to compare the CEM
-004 monitoring well data (since CEM -004 is not technically a compliance well),
CEMEX is willing to strike the standards that they have proposed to the Division.
Otherwise CEMEX will provide sample information from the CEM -004 well to the
Division per the revised sampling schedule (See Comment 5) and if the monitoring of
water samples indicates that the samples are higher than the proposed standards,
CEMEX would like to devise a plan with the Division to ameliorate any potential