1999-06-14_GENERAL DOCUMENTS - M1974052 (5)

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BERNARD LYONS & GADDIS A PROFESSIONAL CORPORATION ATTORNEYS AND COUNSELORS Ben Patton Glen Mallory Harry Posey June 11, 1999 Page 3 naturally occurring formations within that aquifer. Those formations are not present in the alluvial aquifer in the St. Vrain River basin. The applicant should be required to do significantly more ground water and surface water sampling in this area before consideration of any pilot plan for this location, not after. There are not enough monitoring wells proposed in and around the project site. The report does not mention the changes in ground water levels or water quality which may occur at different times of the year. The amount of ground water, its rate of flow, and its quality may vary from season to season and month to month, based on irrigation use in the area which will in turn have some affect on leaching of heavy metals or other contaminants from the coal ash. The applicant should be required to conduct frequent, periodic samples throughout the year, perhaps for several years, before being allowed to begin a project of this type. Any project should be significantly smaller than proposed by the applicant. Since there is no control over the local hydrology, it would be more appropriate to conduct this type of a test or pilot project outside of the alluvial aquifer altogether. Finally, there is no contingency plan to remove any contaminants that may leach out from the pilot project, or to help well owners or owners of other water rights whose source of supply may be contaminated by this type of project. For all of the reasons stated in this letter, the District urges you to deny the application for this project. If you have any questions, please give me a call. Yours truly, BERNARD, LYONS & GADDIS, — a Professional Corporation B � Steven P. Jeffer SPJ:bl cc: Les Williams Christopher L. Varra Joby L. Adams, P.G. \%G BLG%DATAICL 1ENTS%3%$VLNW%PATTO N-YALLORY-POSEY-L.DOC OB/09/99 4 50 PM