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pH <br />Chloride <br />Sulfate <br />Dissolved Solids <br />Selenium <br />Thallium <br />6.5 -8.5 <br />250 mg/1 <br />250 mg/1 <br />400 mg/1 or 1.25 <br />times the <br />background level <br />0.02 mg/1 <br />0.002 mg/1 <br />issues. Please confirm whether the proposed standards set forth by CEMEX for <br />comparison to the CEM -004 monitoring well data are acceptable to the Division. <br />Comment 3. CEMEX has proposed a set of standards to be applied to the CEM -005 compliance <br />well. The Division cannot accept the proposed set of standards as they are not based <br />on baseline data and therefore could not be defended. The Division understands that <br />the Fort Hayes Limestone formation, in which CEM -005 will be completed, is not <br />used locally as a water source for drinking or agriculture. <br />Technical Revision - 01, approved on January 31, 2000, authorized the Operator to <br />use C -Pit as a CKD disposal site. Following the approval of TR -01, the Operator <br />submitted the analytical results from five quarters of baseline data. The Division <br />reviewed the data and set the numeric protection limits (NPL's) for the analyte suite. <br />The NPL's were based on the most restrictive water quality standards. The Division <br />reviewed the permit file and found that the analytical results of the groundwater <br />sampling have been consistently compared to the lower of either agriculture or <br />drinking water standards. Under Technical Revision - 08, approved on May 9, 2007, <br />the Operator conducted an investigation to determine the source of water entering C- <br />Pit. Once it had been determined where the water was originating, the Operator was <br />to establish a sampling point up- gradient of C -Pit in order to determine baseline <br />conditions. The Operator reported under Technical Revision - 09, that the <br />groundwater elevation data collected in the C -Pit area were not adequate to construct <br />a surface contour map. As a result, a sampling point up- gradient of C -Pit was never <br />established. In the absence of baseline data, the Division will continue to apply the <br />lower of either agriculture or drinking water standards to the CEM -005 compliance <br />well. The following table lists the numeric standards to be applied to CEM -005. <br />Response: CEMEX appreciates the Division's acknowledgement that the Fort Hayes formation <br />does not have enough water to be utilized for a drinking water source or an <br />agricultural source of water. A domestic and/or agricultural well is not available as a <br />source of background information because the formation is not tapped for resource <br />water as noted above. CEMEX has not drilled a well up gradient from C -pit to <br />establish a background level given the costs of drilling a new well. CEMEX will <br />accept the above table standards with two exceptions. The first exception is the total <br />dissolved solids (TDS) standard. High TDS can be an indication of water with a high <br />dissolved mineral content from natural sources; and is not generally considered a <br />primary pollutant (i.e. TDS is not directly associated with negative health effects). <br />Additionally, TDS is typically used as an indication of the aesthetic characteristics of <br />human drinking water and is intended as a guideline for potable water, but not an <br />enforceable standard. There is evidence that ground water in the surrounding area <br />Page 2 of 5 <br />