2014-01-28_REPORT - C1981028 - Laserfiche WebLink

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Ben Moline; CEC 2012; ARR Review January 22, 2014 Mass Balance Page 2 of 5 CEC submits results of ash disposal with the ARR. The volume of ash placed in the disposal area, and the results on the chemical analysis sample of bottom ash and flyash are included with the report. In 2012, CEC reports that 35,029 tons of mixed flyash and bottom ash were disposed of in B -Pit at the Keenesburg Strip Mine. As indicated above CEC is using a new survey system which changed their surface elevations to improve accuracy. Also, volumes reported were computed using the AutoCAD Land Development Software to improve accuracy in volume reporting. Ash Laboratory Analyses Section 2.05.4 of the Keenesburg Mine permit requires that both the bottom and fly ash be sampled annually. Two samples, one flyash sample and one bottom ash sample, were analyzed for Toxicity Characteristic Leaching Procedure (TCLP) in 2012. For the bottom ash sample, CEC reports the Barium value was found to be 1.9 mg /1 the reporting limit is 1.0 mg /1 and the Maximum Contamination Level (MCL) is 100 mg /1 in accordance with 40 CFR 261. All other parameters analyzed were below the reporting limits. For fly ash, the arsenic value was reported to be .22 mg /1, the reporting limit is .025 mg /1 and the MCL is 5.0 mg /1. Selenium value was reported to be .27 mg /1, the reporting limit is .05 mg /1 and the MCL is 1.0 mg /1. The Accutest Laboratories report submitted with the 2012 annual report indicates the MCL is derived from 40 CFR 261 regulation. It appears the laboratory results are below the MCL required by 40 CFR 261.24. Mapping The contours on the Reclamation Contour and Drainage Plan Map (Appendix Q -1) submitted with the 2012 ARR approximate the contours from the previous contour map Appendix Q -1 from the 2011 ARR with minor exceptions. B -Pit topography has changed as ash has been disposed in the pit. Likewise, minor changes in the long -term spoil pile topography are noted due to the extraction of this material for cover of the ash disposal area. Vegetation Monitoring Review; 2012 CEC hired a consultant; Savage and Savage, Inc. to conduct revegetation monitoring at the Keenesburg Mine during 2012. The following reclaimed areas were evaluated; 23, 29, 30 and 31. These areas were revegetated between 2002 and 2009. Monitoring was conducted between August 7th and 13th 2012. These areas were evaluated for vegetation cover, herbaceous production and species composition. In the report, a comparison is made between the results of the vegetation sampling for each area and the calculated revegetation success standards based on the precipitations measurements taken from September 2011 to July 2012. The 2012 annual reclamation report was submitted prior to the approval of Technical Revision no. 43 (TR43). TR43 updated the predictive equations used to establish the revegetation success criteria for vegetation cover and production. During the review of the 2011 annual reclamation report, it was noted State listed noxious weed species were included in the total mean vegetation cover for each reclaimed area. While it is important to count these species and find the cover contributions, they cannot contribute to meeting the revegetation success standard for bond release purposes. The Division does not allow State listed noxious weed species to be counted toward contributing to revegetation success. The predictive equations used to determine revegetation success was derived from vegetation monitoring data that included state listed noxious weed species. Given this, in order to conduct a fair comparison of the reclaimed areas and the success standard, the predictive equations for total vegetation cover and herbaceous production were revised with TR43. The new predictive equations are based on revegetation monitoring data that does not include contributions of State listed noxious weed species. Since the 2012 annual reclamation report was submitted prior to the approval of TR43, the revegetation success standards