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<br /> <br />STATE OF III IIIIIIIIIIIII III <br />999 <br />COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanment of Natural Resources <br />1317 Sherman SL, Room 21 ; q` <br />Denver, Colorado R0203 ~~ <br />y <br />Phone: 13031 866-7 567 Il <br />FAX: U03) 832-fl 106 <br /> DEPARTMENT OF <br />May 7, 1996 NATURAL <br />RESOURCES <br />Mr. Forrest Luke Roy ROmri <br />Environmental Manager c°"`•`""` <br />Trapper Mining Inc. IamesS En<hhe,~~l <br />P.O. BOX 187 E~ecume Direr au <br />Craig, Colorado 81626 ^'~rh~"'~" E°^~ <br />Division Din•r ioi <br />Re: Fly Ash Use As Haul Road Subbase, Trapper Mine, Permit No. C- <br />81-010, Trapper Mining Inc. <br />Dear Mr. Luke: <br />The intent of this letter is to provide comments to Trapper Mine <br />concerning the feasibility of using fly ash as a subbase for new <br />haul roads at the Trapper Mine. Trapper Mine had approached the <br />Division concerning this issue. In order to assist in the <br />Division's assessment, Trapper Mine gave the Division a report <br />entitled "Environmental Performance Assessment of Coal Combustion <br />Byproduct Use Sites: Road Construction Applications", prepared by <br />the Radian Corporation for the Electric Power Research Institute. <br />Included in the assessment of this report is the Division's opinion <br />on whether the fly ash could stay in place upon final reclamation. <br />The report given to the Division by Trapper concerns Phase 2 of an <br />ongoing research project that deals with the environmental impacts <br />of fly ash usage in various road construction projects. Phase 2 <br />studied five sites, located in Georgia, Arkansas, Pennsylvania, <br />Kansas and Arizona. Phase I of the project involved two sites, one <br />in Minnesota and the other in Illinois. The following are the <br />Division's comments: <br />1. The Division believes that it would be prudent to require <br />that the flX ash subbase be removed, upon reclamation, <br />and placed in a more appropriate place. Trapper's haul <br />roads pass through the middle of drainages and it would <br />be very possible for surface water to come in contact <br />with the fly ash. <br />2. On page S-8 of this report, it is stated that there had <br />been ground water contamination at the two Phase I sites. <br />This contamination, it was believed, resulted from ground <br />water fluctuations leaching out chemicals from the ash. <br />The ash had been laced upon permeable soils, thereby <br />allowing interaction between the ash and the ground <br />water. The study goes on to say, on page 1-5, that the <br />contamination resulted from soluble ash components, <br />rather than heavy metals. After analyses of the Phase 2 <br />