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There has been no disruption of the CKD disposal azeas as a result of the current construction activities in <br />the Holnam quarry. Holnam has submitted an application for a U.S. Army Corps of Engineers 404 permit <br />for the diversion of Bear Creek. The design and location of the diversion will be finalized as part of the <br />negotiations for the 404 permit. If necessary, portions of the diversion channel may be lined in areas where <br />seepage from the diversion channel could potentially come in contact with the land filled CKD. These <br />details and the impacts on the local hydrology will be addressed in the forthcoming permit amendment <br />application. <br />Item No. 10 <br />Provide DMG with representative ambient and post-sludge application water quality data from the <br />monitoring wells MW-1, -2, -3, and -4. <br />As discussed under Item No. 8 above, these wells were sampled from May 1991 to June 1994. Sludge <br />application began on April 1, 1991. FSD recently completed a sludge drying facility and significantly <br />reduced the amount of sludge it disposes in the Holnam quarry as of January of this year. Application of <br />the sludge in the Holnam quarry will be discontinued when the pug mill goes online in June. <br />Item No. 11 <br />Holnam should commit to provide the Division analytical data demonstrating that the nature of the CKD <br />being disposed of remains relatively consistent. The Division recommends TCLP leach testing semi- <br />annuallyprovided with the annual report. <br />Holnam will commit to provide the Division the requested analytical data to demonstrate the consistency of <br />the CKD. Data from the currently operating wet kilns is included as Attachment 5. Additional analytical <br />data from 1997 and 1998 was also included in Appendix E of the Hydrogeologic Assessment, which was <br />submitted with our original application for this Technical Revision in August 1999. The new dry kiln <br />process is expected to be brought online in Tune 2001. Predicting the resultant CKD composition from the <br />new plant is difficult. Even though there are other dry kiln systems operating at other locations, the CKD <br />generated by each plant has somewhat of a unique chemical makeup due to variations in raw materials, kiln <br />design and kiln operating parameters. Analytical data for CKD generated by the new process will be <br />submitted to DMG as soon as it is available. <br />Item No. 12 <br />Holnam should commit to provide the Division information regarding future changes in the kilning process <br />that could significantly change the nature of the leachable chemical composition of the CKD. These <br />changes would include but not be limited to changes offuel type, materials added to the process, etc. This <br />information should be provided within 30 days of a decision to change the process. <br />As DMG is aware, Holnam has been constructing a new state-of-the-art dry kiln to replace the existing wet <br />kilns at [heir Portland facility. As discussed above, it is difficult to predict the nature of the leachable CKD <br />due to variations in raw materials, kiln design and kiln operating parameters. Other than the new process <br />being brought online, Holnam is not making any other changes, which would be expected to affect the <br />leachable nature of the CKD. <br />Item No. 13 <br />