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• classed as nontoxic as the concentrations in the extract are significantly below the May 1980 RCRA limit of <br />100X primary drinking water standards. The fly ash would also be classified as nontoxic if the RCRA toxicity <br />criteria had been enlarged to include the secondary drinking water regulations. Bottom ash was not <br />subjected to the EP extraction because of its relatively (to fly ash) unreactive nature, as indicated by <br />comparison of Method A leaching results for bottom ash and fly ash. <br />It is highly unlikely that the Craig Station scrubber sludge could be classified as hazardous for the following <br />reasons. A review of available scrubber liquor data from other western scrubbers, as documented in Table <br />4.3-8 reveals that only selenium has exceeded RCRA limits. Selenium is not present in sufficient concen- <br />tration in the Trapper Mine coal to result in a concentration in the EP extract greater than the RCRA limits, <br />even if it were partitioned entirely to the scrubber liquor and scrubber solids and then extracted completely. <br />Cycling of the make-up water due to evaporation in the scrubber will result in the make-up contributing some <br />selenium to the scrubber liquor. However, the selenium concentration in the make-up water would have to be <br />high (0.5 nWher or higher) to contribute a significant amount. <br />4.3.4.4 Coordination with Reaulatory Authorities <br />The Moffat County Commissioners passed a resolution on May 9, 1980, designating the Trapper Mine as a <br />solid waste disposal site (refer to Appendix f). <br />• Trapper Mine submitted a permit application to the Colorado Air Pollution Control Division on December 19, <br />1980, for an emission penult to allow hauling of ash and scrubber sludge from the Craig Generating Station <br />and disposing of the wastes at the Trapper Mine. Permit C-13. 169 (FD) was issued on June 13, 1983 (refer <br />to Section 1.2.2.1). <br />