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WAZEN <br />• - <br />Hazen Research. Inc. <br />4601 Indiana St Golden,Colo. 80403 <br />Tel. (303) 279 4501 • Telex 45-860 <br />November 11, 1986 <br />Mr. Robert E. Trousil <br />Coors Energy Company <br />P.O. Box 359 <br />Keenesburg•, Colorado 80643 <br />Re: II R[ Project 005-806 <br />Analysis of Fly Ash from Boiler #4 <br />Dear Mr. Trousil: <br />As a part of your effort to obtain permission to dispose of fly ash from the <br />brewery power plant at the Keenesburg mine, you asked Hazen to analyze a <br />sample of fly ash from Boiler #4. <br />_ Since it was not known what analyses would be required for in-pit disposal at <br />r • Keenesburg, I contacted Dennis Ilotovek at the Colorado Department of llealth <br />and 6Vest Potter with the Weld County Health Protection Services. There appear <br />to be no hard and fast requirements regarding specific analyses but, according to <br />these individuals, two types of analyses should be sufficient: the EPA EP Toxicity <br />Test, and a trace metals analysis. In addition, Mr. Potter indicated that he would <br />like to.have a one-pound sample for their own analysis. <br />The EP Toxicity Test results are sf~own in Table 1. Analyses of the extract for <br />eight toxic metals fall well within the limits set by the EPA for hazardous waste. <br />EPA guidelines for defining a hazardous waste are contained in 40 Celt Part 261 <br />published by the Bureau of National Affairs. A copy of this regulation is attached <br />for reference. The definitions of a hazardous waste and test procedures used by <br />Hazen for determining toxicity are contained in tl~e regulation. It should be noted <br />that fly ash and bottom ash are specifically cited in the regulation as not being <br />hazardous wastes (Part 261.4(b) Exclusions). <br />Trace metals analyses are listed in Table 2. The technique used for the analysis <br />was spark source mass spectroscopy, and the work was completed by WAL, Inc. in <br />Golden, Colorado. Elements listed as major components in the fly ash were <br />detected in concentrations exceeding 1000 ppm (1% by weight), and include the <br />following: <br /> <br />