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2. The operator should assure that all parameters will be measured by analytical <br /> methods for which detection limits are low enough to record excursions from aquatic <br /> life values measured at low hardness values. Typically this will include a <br /> combination of ICP, AA, and GFAA procedures. <br /> 3. Unless groundwater in the test area is truly shown to flow away from St. Wain Creek, <br /> a monitoring point should be established on the creek, downgradient of the test area. <br /> 4. Coal fly ash and other bag house dusts typically produce high pH values by the <br /> paste pH method. Fresh fly ash containing CaO will produce a higher paste pH than <br /> cured fly ash where the CaO has combined with atmospheric CO2 to form CaCO3. <br /> I <br /> Analytical results supplied thus tar suggest that the tested materials either derive <br /> from a carbonate-poor material,which is doubtful given the origin of these coals, or <br /> have been in contact with the atmosphere for several months. The operator should <br /> take care to assure that the tested materials will be the same as those that may <br /> ultimately be buried. At the application stage, it might be appropriate to let the fly <br /> ash cure before placing in the water. <br /> 5. Although the sources of test materials for this project appear to be well known and <br /> well characterized,there is no assurance that these will be the sources for the future. <br /> There is no reason to suspect that fly ash from coals in different regions will produce <br /> the same leaching results, nor that the ash from different areas in the same seams <br /> will produce the same results consistently. <br /> The operator should not anticipate applying the results of this field trial to all coals, or <br /> to coals form the same region that will be utilized in the future. A program of <br /> continual ash characterization should be anticipated. <br /> 6. In addition to the groundwater monitoring proposed in this technical revision, the <br /> operator should establish a proposed"groundwater compliance point"as required in <br /> the groundwater regulations. <br /> I <br /> cc: Jim Pendleton <br />