1999-01-07_GENERAL DOCUMENTS - M1974052

• Permit No: M1974052
• IBM Index Class Name: General Documents
• Doc Date: 1/7/1999
• Doc Name: MEMO REVIEW PROPOSAL TO EVALUATE DISPOSAL OF COAL ASH BURIED IN SATURATED MEDIA PIT 1 VARRA CO TR2
• From: DMG
• To: CHRIS KAMNIKAR CARL MOUNT
• Media Type: D
• Archive: No

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999 STATE OF COLOMDO
DIVISION OF MINERALS AND GEOLOGY
of
Department of Natural Resources
1 31 3 Sherman 51., Room 215 R
Denver,Colorado 80203
Phone:[phone]
F Ali.[phone]
DEPARTMENT OF
DATE: January 7, 1999 NATURAL
RESOURCES
TO: Chris Kamnikar Rov. Romer
Carl Mount Governor
James S.Lochhead
Evecwive Director
FROM: Harry H. Posey9AVP Michael s Long
L""'on Dveoo,
RE: Review: Proposal to evaluate disposal of coal ash buried in saturated
media. Pit No. 1, Varra Companies; TR-002; Permit M-74-052
BACKGROUND
The captioned TR covers the application submitted November 19, 1998, to Weld County
for an "Amendment to a Site Specific Development and Use by Special Review Permit
for a Coal Ash Burial Project." The TR-002 submittal is substantially the same as that
submitted to the CDPHE-HMWMD on December 29, 1998.
The issue of groundwater as it pertains to areas covered by the Special Use permit
application was discussed generally in DMG's letter of December 23, 1998, to Varra
Companies. In that letter, we noted that Varra might need to submit either an
amendment or a revision to the MLRB Permit. The letter also recalls that CDPHE-
HMWMD had not yet decided whether to exercise Solid Waste Disposal authority and
regulate groundwater below the coal ash or relinquish that to DMG.
The current TR does not clarify the groundwater jurisdiction issue, and we have not
received a decision from the HMWMD on this issue. Therefore, I would recommend that
the Division proceed with this TR on the assumption that HMWMD will not elect to
regulate groundwater that might be affected by the fly ash disposal.
The current TR-002 application proposes to evaluate disposal of coal ash buried in
saturated media. The saturated media consists of groundwater that has been exposed
by open pit mining along St. Vrain Creek. The proposal covers only a pilot test; it does
not apply to lands that might be later used for coal ash disposal should the tests prove
fruitful for coal ash disposal by this method.
TR-002 REVIEW
1. The groundwater flow direction was apparently estimated from the regional
groundwater map in Appendix A. This flow direction in the project area is based on too
few points to be used for the project. Groundwater monitoring points, which are
proposed in Figure 3, should be established after the local groundwater flow direction
has been adequately established.