2012-11-29_HYDROLOGY - M2002004 - Laserfiche WebLink

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DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866 -3567 FAX: (303) 832 -8106 November 29, 2012 Gina Nance Barbara Hodgson GCC Rio Grande, Inc. 3372 Lime Road Pueblo, CO 81004 Ms. Nance and Ms. Hodgson: Mined Land Reclamation STATE OF COLORADO COLORADO D I V I S I O N O F RECLAMATION MINING — &— SAFETY John W. Hickenlooper Governor Mike King Executive Director Loretta E. Pineda Director Re: Pueblo Cement Plant and Limestone Quarry, Permit No. M- 2002 -004, Exceedance of Groundwater Numeric Protection Levels The Division of Reclamation, Mining and Safety (DRMS) has reviewed your Third Quarter, 2012 Groundwater Monitoring Report dated October 17, 2012 and prepared by Contour Consulting Engineering. Results from quarterly sampling of MW -003 indicate an upwards trend in the concentration of both sulfate and total dissolved solids (TDS), with the exception of the latest sampling event (September) when the well was dry. The DRMS acknowledges sulfate exceeded the NPL only in MW -003 during the June 2012 sampling event. The third quarter report also indicates the TDS level in MW -004 has been above the NPL during three of the last four sampling events, although it does not appear an upward trend is indicated for MW -004. The subject report concludes that the upwards trend in the TDS level is due to drought conditions experienced in the area and that "it is unlikely continuous saturated conditions exist between the plant and the compliance wells." As such GCC maintains that the increase in TDS is "not likely" the result of "contamination from the GCC facility ", and "there is no justification to continue quarterly sampling all three monitoring wells." The DRMS concurs that continuing quarterly sampling will not likely produce any additional useful information. Therefore the DRMS requires GCC adhere to one of the following options: A. Submit a remedial action plan to the DRMS as stated in the enclosed December 8, 2009 letter to Brian McGill approving the groundwater monitoring plan and NPLs for the site, or B. Provide the DRMS with documentation demonstrating that the increase in TDS (and sulfate) is not a result of "contamination from the GCC facility ". Documentation for Option B should include a hydrogeologic cross - section that meets the following specifications: a) Extends through the cement plant/ quarry area, monitoring well MW -4, and the St. Charles River, Office of Office of Denver • Grand Junction • Durango Active and Inactive Mines