1999-05-03_GENERAL DOCUMENTS - M1974052 (4)

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J COLORADO &Il Owens,Governor III 'll'll'lI I'II'II 999 ct lane E.Norton,Executive Director Dedicated io protecting and improving the health and environment of the people of ColoradoHAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION http://wvaw.cdphe.state.co.us/hW 4300 Cherry Creek Dr.S. 222 S.6th Street,Room 232 -- Denver,Colorado 80246-1530 Grand Junction,Colorado 61503 2768 Colorado Deparunent Phone(303)692-3300 Phone(970) 248-7164 of Public Health Fax(303)759 5355 Fax 19701 248 7198 and Environment May 3, 1999 Christopher Varra Varra Companies 12910 Weld County Road 13 Longmont, CO 80504 Re: Proposed Varra Coal Ash Pilot Project-Work Plan and Analytical Data, April 1, 1999, Dear Mr. Varra: On April 6, 1999, the Solid Waste Unit of the Hazardous Materials and Waste Management Division (the Division) received Varra Companies application for a Certificate of Designation to perform a pilot project where coal combustion ash would be disposed in saturated conditions. The pilot project is part of Varra's proposed reclamation plan for areas previously mined for gravel in Weld County. In accordance with the Solid Waste Statute (CRS 30-20-103), and with the Solid Waste Regulations- (the Regulations) promulgated thereunder, 6 CCR 1007-2, a preliminary completeness review of such application is required within thirty (30) days of receipt. The Division has completed its 30-day review of the application. In the judgement of the Division, the application is incomplete and will require further modification/revision to adequately meet the requirements of the Regulations. Furthermore, based on the information and data provided, the Division cannot make a favorable determination on the submitted application. The unfavorable determination is discussed below: Table 6 of the Work Plan provides a summary of the SELP coal ash analytical results which exceed water quality standards established pursuant to Colorado's "The Basic Standards For Ground Water", Regulation #41, (5 CCR 1002-41). In addition, results of other analytical methods (TCLP, SGCLP, SUP) show numerous constituents leaching from coal ash which exceed a relevant groundwater standard. The analytical data unequivocally shows degradation of the groundwater will occur if coal ash is placed in a saturated medium. Placing a waste, which has been demonstrated to leach pollutants, below the water table in an aquifer that is used or has the potential to be used for domestic use is prohibited. A request may be made with the state's Water Quality Control Commission for a variance for site specific groundwater standards. Unless a variance is granted or additional data is provided which demonstrates exceedance of ground water standards will not occur, the Division will maintain its unfavorable recommendation for the proposed coal ash pilot project.