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Mr. Joby Adams <br />February 23, 2000 <br />Page 2 <br />were included in the fly ash analytical evaluation submitted as part of the certificate of <br />designation application. Mercury and titanium have been identiFed in ash from coal combustion <br />and must be included in effluent sample testing. <br />5. A Quality Assurance Project Plan (QAPP) must be prepared. The QAPP needs to specify <br />sampling process design, sampling method design, analytical method requirements, laboratory <br />quality control, data assessment and oversight and data validation. <br />6. Section 10.1.4 of ASTM D 4874-95, provides a discussion on curing samples prior to testing. <br />Curing is recommended for materials that undergo physical or chemical changes with time. <br />Given the physical changes which occur when fly ash is hydrated, it appeazs appropriate to <br />prepaze the test specimen in a manner that simulates the state the waste will be in as it undergoes <br />leaching in the field. Provide a discussion on this issue. <br />These conclude the Division's comments regarding the proposed method for column testing. If <br />you have any questions, please contact me at (303) 692-3437. <br />Sincerely, <br />Roder Doak <br />Solid Waste Unit <br />Compliance Program <br />cc: Trevor Jiricek, Weld County Department of Public Health and Environment <br />Harry Posey, Colorado Division of Minerals and Geology <br />Ken Niswonger, HMWMD <br />sw/wld/vaz 4 <br />rn ~, oc~r.r nnro c~ nay cccc_~c~_cnc~xpa C~HT?IaIHW 7HH <br />