1999-05-17_GENERAL DOCUMENTS - M1974052

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Varra May 3, 1999 Page 3 or Hg, but numerous instances of failure of the primary standards for Ba, Be, Cr, Pb, Ni, and Se exist in these data. Also, the fly ash samples exceeded agricultural groundwater standards set for Al, B, Cu, Fe, and V. The bottom ash samples appear to fail only for secondary and agricultural groundwater standards, no failures of the primary groundwater standards were apparent for this material. Given the failures of primary and agricultural groundwater standards, and the proposed management scheme of placing the material into groundwater, these data may define an unacceptable risk to waters of the state. 8. In response to comments regarding the Final Regulatory Determination of Large Volume Wastes From the Combustion of Coal by Electric Utility Power Plants (Federal Register, Vol. 58, No. 151, page 42476), EPA's discussion of this potential management technique suggested that management of ashes from combustion in unlined units sited over shallow groundwater with nearby drinking water wells may constitute a very limited risk to human health and the environment. The proposed management is disposal into saturated conditions. Furthermore, the EPA contemplated exceedances of secondary standards only, and did not forsee failure of the waste materials for primary standards. The EPA observed that applications of these waste forms to agricultural soil (Federal Register, Vol. 58, No. 151, page 42475), may cause some concern with metals uptake in food crops and cattle feed, and that Boron can, and has, infiltrated surface waters to exhibit phytotoxicity to wetlands. For these reasons "wet management"techniques, such as disposal in ponds are being discouraged. The SGLP extraction procedure using native groundwater as the leachate solution produced the lowest concentrations of pollutants, but did produce exceedances for Boron and Selenium. On these observations and facts, I find it interesting that there are no conclusions drawn from the data by the industry, or the proposed investigator. 9. The proposed Quality Assurance Project Plan ("QAPP")for the Varra Coal Ash Work Plan suggests that quality control reporting will not be utilized unless requested. The plan need to specify what types of Quality Control will be accomplished, the frequency it will be accomplished, and the range of acceptable performance. The QAPP appears to be deficient in failing to define quantitative data quality objectives, sampling process design, sampling method design, and sampling method requirements, analytical method requirements, laboratory quality control, data assessment and oversight, and data validation/verification. 10. The Table I-C provides a summary of parameters. The Department would have a preference for the use of SW-846, method 6010B because of the higher degree of quality control features, and procedural improvements.