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Comment 6. <br />sampling for CEM -001 and C -pit, will be reduced to semi - annually. CEMEX also <br />acknowledges that if the numeric standards are exceeded for either CEM -004 or <br />CEM -005 during the semi - annual sampling then all monitoring sites will be sampled, <br />including CEM -001 and C -pit, until there are four consecutive quarters without an <br />exceedance. Once there are four quarters without an exceedance then the sampling <br />can once again resume on a semi - annual basis. <br />The Operator has proposed eliminating monitoring location CEM -001 from the water <br />sampling program based on the low hydraulic conductivity in the bedrock <br />surrounding the C -Pit. The method by which the hydraulic conductivity was <br />determined is a non - conventional method; a slug test would need to be performed to <br />verify the results of the Operator's hydraulic conductivity test. The Division believes <br />there is value to the continued sampling of CEM -001, which is the only monitoring <br />location between C -Pit and the compliance point. <br />The Operator has stated there is no value to continue sampling CEM -001 since the <br />sampling of C -Pit will provide information on how the water exposed to CKD is <br />changing over time. Sampling CEM -001 can provide information on how the <br />chemical composition of the water in C -Pit is altered by flowing through the Fort <br />Hays Limestone formation. In addition, sampling CEM -001 could provide an early <br />warning to potential problems should water from C -pit start to migrate to the <br />surrounding area. <br />At this time the Division does not approve the removal of CEM -001 from the water <br />sampling program; sampling shall continue at the same frequency as the other <br />monitoring locations. <br />Response: CEMEX will continue to sample CEM -001 per the sampling schedule (See Comment <br />5) as requested by the DMRS. CEMEX does not agree that there is a direct flow of <br />water from C -pit to CEM- 001through the Fort Hayes formation to CEM -001. <br />Comment 7. CEMEX has committed to reestablishing the CEM -005 compliance well. Please <br />commit to providing the Division with a well completion report within 30 days of the <br />completion of CEM -005. <br />Response: CEMEX will inform the Division within 30 days of reestablishing the CEM -005 <br />Compliance well. <br />Page 4 of 5 <br />