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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT <br /> Hazardous Materials and Waste Management Division <br /> INTEROFFICE COMMUNICATION <br /> TO: Glenn Mallory <br /> FROM: Roger Doak <br /> DATE: May 3, 1999 <br /> SUBJECT: Varra Coal Ash Pilot Project <br /> My completeness review of Varra's proposal has raised numerous concerns and questions which <br /> need clarification and/or additional information. Below is a discussion of these issues. <br /> 1. There may be potential `water right' issues with this proposal. For example, if the coal ash <br /> acts as a dam and diverts groundwater away from a current user, and /or if groundwater direction <br /> is altered to an adjacent property which, historical, has been dry and now is saturated. An <br /> evaluation of the potential changes to the hydrogeologic characteristics of the upper most aquifer <br /> is necessary to provide insight to some of these questions. <br /> 2. Staff of the Water Quality Control Division of CDPHE has concluded that a Storm Water <br /> Management Plan (SWMP) is required for the proposed pilot project. Should you have questions <br /> regarding the appropriate and necessary information required for a SWMP, contact Ms. Kathy <br /> Dolan (303.692.3596). <br /> 3. Local groundwater quality (Boulder, Ft. Collins and Greeley area) for unconsolidated alluvial <br /> deposits has been provided. Although this data is useful in terms of discerning the wide range of <br /> constituent concentrations, site specific data is essential to evaluating the groundwater beneath <br /> the facility. <br /> 4. A site map which illustrates the location of the coal ash storage area must be provided. A <br /> discussion regarding coal ash management at the storage area must be included. Engineering <br /> controls must be in place prior to acceptance of waste. Procedures must be established which <br /> address mitigation of potential nuisance conditions (e.g., windblown ash). <br /> 5. Little to no information has been provided for numerous topics (e.g., local geologic data, <br /> hydrologic properties of the uppermost aquifer, POC wells, recordkeeping, closure plan and <br /> financial assurance). Although the applicant has made a commitment to provide this data after <br /> receiving a CD, it is difficult to make an appropriate evaluation without some of this information. <br /> Initially, information on the local geology and hydrology must be provided for CDPHE to <br />