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2. "Fresh" CKD should never be placed, or allowed to be placed inadvertently, in open <br />Flowing water or in areas, such as flood plains, where open flowing water may reach <br />the "fresh" CKD prior to a few weeks of curing. <br />3. "Fresh" CKD should be spread in thin layers (no more than a few feet thick) and <br />immediately watered. Watering will help control dust and will aid the transformation <br />from CKD to limestone. (Watering is effectively accomplished at the Holnam <br />Portland Quarry in Florence where fresh CKD is covered with sewer sludge.) <br />4. Except where "weathered" CKD is to be subsequently covered and thereby disturbed, <br />"weathered" CKD should not be significantly disturbed so as to re-pulverize it. <br />GROUNDWATER MONITORING PARAMETERS <br />Groundwater monitoring generally seems unnecessary unless "fresh" CKD is to be exposed to <br />surface waters or unless "weathered" CKD is to be pulverized and exposed to groundwater. <br />1. Where groundwater monitoring is deemed appropriate, it is recommended that a <br />representative suite of indicator elements be developed from site specific CKD leach <br />tests and ambient groundwater conditions. Because clay compositions differ from <br />site to site, a single set of parameters does not seem appropriate. <br />2. Monitoring parameters should ideally consist of elements or compounds that <br />consistently reported above detection limits in groundwater samples or that <br />consistently reporte well above detection limits in CKD leach tests. <br />Where sewer sludge, compost, or other organic materials or amendments are <br />anticipated to come into contact with the CICD, or where reducing conditions can be <br />expected to result, Mn might be used as a monitoring pazameter. Mn is a typical <br />component of limestone and can be mobilized under reducing conditions. Use of Mn <br />for monitoring might be given extra consideration <br />4. Even though high alkalinity is a feature of "fresh" CKD weathering, it is not <br />recommended that pH alone be used as a monitoring parameter where pollution from <br />high pH might be anticipated. Because pH is a logarithmic representation of <br />hydrogen ion activity, a unit shift in pH represents a 10-fold increase (or decrease) in <br />H' activity. For instance, a pH 8 solution contains 1000 times greater hydrogen ion <br />activity than a pH 11 solution; thus, unless the pH 11 solution comprises an extremely <br />high percentage of a pH 8 and pH 1 ]solution mixture, pollution by the high pH <br />solution would be masked and not detectable. A 50:50 mixture could not be detected. <br />5. Until the degree of variability on the dust source is well established, period leach <br />testing of [he CKD should be conducted. The technical revision for the Holnam <br />Boettcher Plant requires TCLP testing on CKD samples semi-annually. <br />