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Varra Coal Ash Pilot Project <br /> May 3, 1999 <br /> Page 2 <br /> continue with its technical review. Prior to acceptance of waste CDPHE, DMG and Weld <br /> County must review and approve all relevant information (e.g., closure plan, financial assurance, <br /> recordkeeping, etc.) which will be provided after issuance of a CD. <br /> 6. The inherent pozzalonic nature of fly ash will affect the ground water behavior beneath this <br /> site. In an effort to evaluate these changes, an adequate number of monitoring points must be <br /> established. Additional wells and/or piezometers must be installed to measure changes in <br /> groundwater elevation, flow direction and quality. The monitoring network provided in the <br /> proposal must be enhanced to provide adequate coverage for changes in the groundwater system. <br /> 7. If adverse changes to water quality are observed, the proposed contingency plan requires <br /> removal of ash from the trench and placement in a dry impoundment. Provide a site map <br /> showing the location of the impoundment. Also, provide construction details for the <br /> impoundment. The impoundment must be constructed prior to acceptance of coal ash. <br /> 8. Groundwater quality action levels must be established for each constituent prior to acceptance <br /> f coal ash. The proposed action levels must be approved by CDPHE, DMG and WCHD. Once <br /> an action level is met or exceeded, abatement and remedial activities must commence. <br /> 9. The applicant anticipates the pilot project will take approximately three (3) months to <br /> complete. This time frame is primarily based on the assumption that water quality parameters <br /> will equilibrate within this time period. Any research project must have a strong scientific basis <br /> and be conducted as a controlled experiment with adequate monitoring over a period of time to <br /> show meaningful results. Therefore, we believe a minimum of one year(four quarters of <br /> groundwater data) is appropriate and necessary to evaluate seasonal changes, water quality <br /> issues, and chemical and physical reactions in groundwater. <br /> 10. St. Vrain River or St. Vrain Creek, which is correct? <br /> 11. Permits which will be required and/or amended for the pilot project include; a Certificate of <br /> Designation, Use by Special Review, Storm Water Management Plan, amended air quality <br /> permit and amended DMG permit. <br /> 12. The disposal of coal ash into saturated conditions will result in a disturbance of the <br /> hydrologic properties of the alluvial materials at this site. In an effort to understand the physical <br /> changes occurring in the aquifer, the applicant must provide an evaluation of the hydrologic <br /> characteristics before, during and after placement of coal ash. Modeling the different hydrologic <br /> scenarios may provide insight which can than be used to understand the dynamics of the <br /> hydrologic characteristics upgradient, within and down gradient of the disposal trench. <br />