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05/13/98 05:50 FAX 3037595355 UL)PHE HALIMAI uua <br /> 12. Would the potential solidification of the material and the tying up of the water be considered <br /> a consumptive use? <br /> 13. The potential of exceeding groundwater standards with leachate from this material needs to <br /> be considered. <br /> 14. Would the disposed material change the direction of groundwater flow to any significant <br /> degree? <br /> -- 15.- issues ofZoordinaiion with the Division of Minerals and Geology, permitting with Weld <br /> County, and the potential need for a certificate of designation under the Solid Waste Act needs to <br /> be considered. <br /> 16. Section 2.1.17 of our regulations prohibits the disposal of solid waste into groundwater. <br /> However, section 1.5.2 may allow a waiver to this restriction if the Division and Weld County can <br /> be convinced that such a project will not adversely affect the groundwater. <br /> In all probability other concerns will surface as we find answers to those listed above. One that <br /> immediately comes to mind is the use of the term "pilot". The proposed fill area is approximately <br /> 40 acres, if I assume a 20 foot fill depth that equates to over 1,200,000 cubic yards of fly ash. <br /> Given that volume, the high probability of the pozzuolanic activity of the ash which may limit the <br /> potential for remediation, if needed, and the large number of trucks needed to haul the material, I <br /> find it difficult to consider this a"pilot" project. <br /> I further suggest that you, your clients, a representative of Weld County, the Department of <br /> Mmerals and Geology, and this office meet to discuss the potential project in more detail after <br /> some initial consideration is done in regards to the above listed questions and concerns. <br /> If you have que Lions concerning this matter I may be reached at 303/692-3445. <br /> ?Sinro' <br /> ryetd <br /> ste Unit header <br /> ce Program ` <br /> cc T. Jiricek, WCHD <br /> B. Humphries,. DMG <br /> D. Goss, Public Service <br />