HYDRO28796

• Permit No: C1981010
• IBM Index Class Name: Hydrology
• Doc Date: 5/2/1996
• Doc Name: USE OF UTILITY ASH AS SUBBASE ON TRAPPER HAUL ROADS TRAPPER MINE PN C-81-010
• From: DMG
• To: DAVID BERRY
• Permit Index Doc Type: CORRESPONDENCE
• Media Type: D
• Archive: No

III IIIIIIIIIIIIIIII
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STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Nalu rat Resources
1 ]13 Sherman 51., Room 215
Denver, Colorazlu 80?03
Phone: [phone]
FAS: (3031 8J?8106
DATE: MAY 2, 1996
~~
DEPARTMENT OF
NATURAL
RESOURCES
Roy Romer
Governor
TO: DAVID BERRY
FROM: JOE DIIDASH
RE: DBE OF OTILZ ~ABH
AS BIIBBABE ON TRAPPER HAIIL
ROADS, TRAPPER MZNE, PERMIT NO. C-81-010
~a mes 5. Luchhead
Execwive Director
Michael B. Long
Division Director
Trapper mine was approached by the Tri-State Generation
Corporation, operators of the Craig power plant, with the intent of
using fly ash from the utility as a subsoil base for new haul roads
at the mine site. Tri-State gave a report, entitled "Environmental
Performance Assessment of Coal Combustion Byproduct Use Sites: Road
Construction Applications", to Trapper. Trapper gave the report to
the Division and asked us to comment on the possibility of using
the fly ash as a haul road subbase. Of greatest importance to
Trapper was for the Division to determine how such a use would
affect reclamation of the haul roads. Specifically, Trapper wanted
to know if the ash subsoil would need to be removed, upon
reclamation, or whether Trapper could leave the ash subsoil in
place and simply cover the subsoil with an appropriate amount of
cover material.
The report given to us by Trapper concerns Phase 2 of an ongoing
research project. Phase 2 studied five sites, located in Georgia,
Arkansas, Pennsylvania, Kansas and Arizona. Phase I of the project
involved two sites, one in Minnesota and the other in Illinois. The
following are some comments that I have concerning the report:
1. I believe it would be prudent for the Division to require
that the fly ash subbase be removed, upon reclamation,
and placed in a more appropriate place. Trapper's haul
roads pass through the middle of drainages and it would
be very possible for surface water to come in contact
with the fly ash.
2. On page S-8 of this report, it is stated that there had
been ground water contamination at the two Phase I sites.
This contamination, it was believed, resulted from ground
water fluctuations leaching out chemicals from the ash.
The ash had been placed upon permeable soils, thereby