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CG999 <br /> ��cE�vEv <br /> April 7, 1999 pQR �21999 w9y <br /> Ms. Christina L. KamnikarooplMt�taK�' <br /> Division of Minerals and Geology <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> RE: Technical Revision to Permit No. M-74-052 <br /> Weld County, Colorado <br /> CGRS No. I-135-2755 <br /> Dear Ms. Kamnikar: <br /> The purpose of this letter is to respond to your letter dated February 4, 1999, regarding our <br /> proposal for performing a pilot gravel quarry reclamation project utilizing coal ash in saturated <br /> conditions. Your letter is attached for reference. 1 have provided two copies of our finalized <br /> Work Plan, which details our proposal. My comments to your issues are provided below. <br /> I - We agree that background water quality should be established prior to placing any <br /> materials in saturate conditions. We believe that obtaining background samples on three <br /> occasions between one and three months apart should provide sufficient background <br /> water quality data. The natural variations of major and minor elements of concern in this <br /> project should have relatively minor seasonal variations. In addition, the project entails <br /> providing background water quality during the project by placing a well sufficiently <br /> upgrdient of the coal ash trench to preclude impact from the coal ash. This will provide <br /> ongoing background data by which impacts or degradation of groundwater quality can be <br /> assessed. We feel the five quarters of pre-monitoring is time consuming and cost <br /> prohibitive and provides little benefit to the project. A surrunary of published water <br /> quality data from unconsolidated alluvial deposits in the vicinity of the study area is <br /> attached for reference. <br /> 2 - Section 4.5, of our work plan addresses remediation. In short, if significant <br /> degradation of water quality occurs the coal ash will be immediately removed and placed <br /> in a dry impoundment within the Varra property boundary. Water quality monitoring <br /> will continue and impacts to groundwater resources will be evaluated and additional <br /> remediation commensurate with the extent and degree of impact. The Division of <br /> Minerals and Geology will be notified of all analytical results within 24 hours of their <br /> receipt by CGRS, Inc. <br /> dmgrespome.dac <br /> RO Box 1489 Fort Comas CO (970) 493 7'80 Fox (970) 493 i'i8F <br />