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~~cmcx <br />~~~ElvED <br />DEC 0 22005 <br />i ~-~ <br />~~'~s~~ <br />fliYielOn ttf Minerals and Geelo~y / <br />Ms. Erica Crosby December 1, 2005 <br />Environmental Protection Specialist <br />Division of Minerals attd Geology Via Federal Express <br />1313 Sherman Street, Room 215 Delivery Confirmation Tracking # - <br />T~.,~~~-~,T <br />Denver, Colorado 80203 """ ~ `^ """ <br />/~~Z 3b i<Z r ZS'{ <br />Subject: Technical Revision 06, Permit No. M-1977-208, Lyons Quarry, <br />Cemex, Inc., Cement Kiln Dust Disposal in C-Pit ~ <br />Dear Erica: <br />This letter, attachments and check for $188 constitute an application for Technical Revision 06 <br />(TR-06) to the above referenced permit (the last approved Technical Revision was TR-04, since <br />TR-OS was withdrawn). This Technical Revision addresses pumping of water in C-Pit for <br />consumptive use in the Cemex cement plant at Lyons. <br />Monitoring and Reporting <br />All the monitoring and reporting requirements contained in TR-04 shall remain in force. <br />Modified Consumptive Use Pum~ng <br />TR-04 allowed Cemex to pump water from C-Pit to the cement plant to lower the water level and <br />decrease the surface area. This pumping successfully lowered the water level by approximately <br />four feet until it had to be terminated in August 2005 due to continuing problems with <br />precipitated solids clogging the system and impacting plant operation. Subsequent to this, <br />Cemex and its consultants analyzed the problem further and derived a solution to the problem by <br />neutralizing the flow after it leaves C-Pit and before it enters the cement making process (i.e. the <br />spray tower). This process will keep calcium levels below the saturation point to prevent <br />precipitation of calcite in the pump and delivery system. This solution modifies the previously <br />approved consumptive use approach and keeps it as the preferred alternative. <br />Cemex now proposes to pump water from C-Pit continuously at a higher flow rate than <br />previously, as well as to lower the pH of the water while pumping to prohibit downstream <br />scaling and precipitation. Attachment 1 to this letter is a narrative description of the pumping and <br />neutralization process. Attachment 2 is a map showing the approximate location of system <br />components, and Attachment 3 is a conceptual process flow diagram that outlines the major <br />elements. <br />Cemex will start the pumping no later than March 1, 2006. This time frame is required due to <br />the time needed for design, procurement and testing of the modified system. <br />Cemex will install a totalizing flow meter in the system and will survey the C-Pit water surface <br />elevation monthly. These data will be submitted to the Division on a monthly basis (within 10 <br />days of the water surface elevation measurement). <br />United Stales Operations <br />P.O. Box 529, Lyons, Colorado 80540, USA, Phone: (303) 8232100, Fax: (303) 8232199 <br />