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' • � III liilllllllllllll <br /> STATE OF COLOFADO <br /> DI"ISIO^. OF MINERALS AND GEGLOG'r <br /> DEPkRTNIENT OF <br /> NATURAL <br /> RESOURCES <br /> Date: April 2-, 1999 <br /> To. Bruce Humphries Ee° ;,;"` "r'° <br /> Carl Mount ,w, -,,, : �,,,; <br /> ChristinaKamnikar'r ° n'"'m, <br /> r �From: Harry Posey <br /> Subject: Recommendation to Deny Proposed TR-3 f6r Coal Fly Ash Disposal, Pit <br /> No. 1, Varra Co. Inc., Permit M-74-052. <br /> The Varra Company Inc. has requested through TR-3 that they be permitted to construct <br /> a pilot scale operation in their Pit Number 1 in Weld County to study effects of coal fly <br /> ash on groundwater. Their submittal dated April 7, 1999, which purports to provide all of <br /> the remaining necessary documentation needed for approval of this TR, was reviewed. <br /> Based on a review of leach testing results and an examination of their pilot project, it is <br /> recommended that this TR request be denied. This memo summarizes the reasons. <br /> 1. The proposed test facility lies in the flood plain of St. Vrain Creek. Groundwater is <br /> 5-10 feet below surface and local surface is less than 10 feet above the elevation of <br /> St. Vrain Creek. Based on depth to groundwater, stream elevation, and local <br /> geomorphology, it appears that local groundwater is in intimate contact with St. <br /> Vrain Creek. The two waters are probably alluvial water and surface water <br /> equivalents. Under these conditions, it can be expected that a release of <br /> contaminants from the fly ash could travel in a short period to St. Vrain Creek <br /> surface water. <br /> 2. Leach test results indicate that there is a tendency for Al, Ba, Be, B, Cl-, Cr, F, Pb, <br /> Li, Mn, NO,, NO-,. Se, SO,. and V, to exceed drinking water or agricultural <br /> standards. Some of these (Ba. B, Cr, F, Se, SO, and NO;) were released even under <br /> the least aggressive leach procedures, wherein samples were leached [sing local <br /> groundwater. <br /> 3. The proposal does not compare the leach results to surface water standards. The <br /> leach tests are evaluated in terms of agriculture and drinking water standards only. <br /> However. surface water standards are exceeded in nimerous cases. <br /> -. Precious requests from the Division and from H%IW%ID for groundwater flow <br /> directions have been addressed only with a regional flow map covering the entire <br />