1999-04-12_HYDROLOGY - M1974052 (8)

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STATE OF COLOMBO DIVISION MINERALS GEOLOGY I A•pdrlmrnl 01 nl Ndlural Rewurcesces I ,I I Sherman 51.,Room 215 {)v"w"0A."'I In AW03 I Phm„ (1(;U 866-3567 FAX l40 i,ii Q t41i% DEPARTMENT OF DATE: January 7, 1999 NATURAL RESOURCES TO: Chris Kamnikar Rny Ramer Carl Mount S.1mv lames S.Lochhea,l Ereruore Dirrercx FROM: Harry H. Posey Michael 8 LnnR o,"„m,oxernx RE: Review: Proposal to evaluate disposal of coal ash buried in saturated media. Pit No. 1, Varra Companies; TR-002; Permit M-74-052 BACKGROUND The captioned TR covers the application submitted November 19, 1998, to Weld County for an "Amendment to a Site Specific Development and Use by Special Review Permit for a Coal Ash Burial Project." The TR-002 submittal is substantially the same as that submitted to the CDPHE-HMWMD on December 29, 1998. The issue of groundwater as it pertains to areas covered by the Special Use permit application was discussed generally in DMG's letter of December 23, 1998, to Varra Companies. In that letter, we noted that Varra might need to submit either an amendment or a revision to the MLRB Permit. The letter also recalls that CDPHE- HMW MD had not yet decided whether to exercise Solid Waste Disposal authority and regulate groundwater below the coal ash or relinquish that to DMG. The current TR does not clarify the groundwater jurisdiction issue, and we have not received a decision from the HMWMD on this issue. Therefore, I would recommend that the Division proceed with this TR on the assumption that HMW MD will not elect to regulate groundwater that might be affected by the fly ash disposal. The current TR-002 application proposes to evaluate disposal of coal ash buried in saturated media. The saturated media consists of groundwater that has been exposed by open pit mining along St. Vrain Creek. The proposal covers only a pilot test; It does not apply to lands that might be later used for coal ash disposal should the tests prove fruitful for coal ash disposal by this method. TR-002 REVIEW 1. The groundwater flow direction was apparently estimated from the regional groundwater map in Appendix A. This flow direction in the project area is based on too few points to be used for the project. Groundwater monitoring points, which are proposed in Figure 3, should be established after the local groundwater flow direction has been adequately established. I