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groundwater in the study area'? Or is it unclassified'? DNIG is requesting this classification as a result of the <br /> findings of Harry Posey of the Division, in the attached lever. It has also been pointed that pursuant to Rule <br /> 3.1.5(9),backfill material must be clean and inert(non-acidic and/or non-toxic producing)prior to being placed in <br /> groundwater. It does not appear that the Operator has demonstrated that the flyash is inert. <br /> 6) As can be seen in the attachment, the leach test results under even the least aggressive methods showed standard- <br /> exceeding levels of elements in the fly ash tested. Based on these test results, DMG believes that this Fly ash <br /> should not be deposited on a flood plain where storm or flood scouring could breach the facility. Either further <br /> design of the containment facility to prevent these events must be submitted,or proof must be given that this <br /> leaching would not exceed the groundwater and surface water standards which apply to this area. <br /> All details in the new attached letter from Harry Posey of the Division should also be considered and resolved as soon <br /> as possible. Please respond to this adequacy review prior to your current application decision due date of April 29, <br /> 1999, in order for the Division to consider approving this Technical Revision application. Be advised that this <br /> technical revision may be deemed inadequate, and your permit revision may be denied on April 29, unless these <br /> adequacy review items are addressed to the satisfaction of the Division. If you wish to request an extension in order to <br /> address these concerns,please contact the Division in writing or by FAX. <br /> If you have any further questions, feel free to contact me at(303)866-3567. <br /> Sincerely, <br /> Christina L. Kamnikar <br /> Environmental Protection Specialist <br /> Cc: Carl B. Mount, DMG <br /> Harry H. Posey, DMG <br /> H. Bruce Humphries, DMG <br /> Joby L. Adams, Colorado Groundwater Resource Services <br /> Enclosure <br /> I <br />