HomeMy WebLinkAbout20011104.tiff 5E F COLORADO
Bill Owens,Governor _
lane E. Norton,Executive Director 7 �} :CC•co!�
Dedicated to protecting and improving the health and environment o/the{pe 1ple o/Co '
Colora•do la > o
4300 Cherry Creek Dr.S. Laboratory and Radiation Service i?eisiil _
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Denver,Colorado 80246-1530 8100 Lowry Blvd. r I
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Phone(303)692-2000 Denver,Colorado 80230-6928 ``)
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado of Public Health
http://www.cdphe.state.co.us and Environment
January 31,2001
Weld County Board of Commissioners
915 10t Street
Greeley, CO 80631
RE: Application For Certificate of Designation—Varra Coal Ash Pilot Project
Dear Commissioners:
The Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment(the
Division)has completed its review of Varra Companies'application for a Certificate of Designation to conduct a pilot project in
Weld County. The proposed study area is located at a former gravel quarry near 12910 Weld County Road 13,which is
approximately four miles north of Firestone.
The pilot project will provide a research opportunity to evaluate coal ash in a wet environment. A Certificate of Designation is
being requested for disposal of approximately 400 tons of fly ash that will be placed in a trench measuring 10 feet wide, 100
feet long and 10 feet deep. The fly ash will be placed so that the water table intersects the ash.
It is the assessment of the Division that the proposed pilot project can comply with the technical, environmental and public
health standards of the Act(30-20-100 et seq.)and Regulations (6 CCR 1007-2); if the project is operated and monitored as
detailed in the submitted plan and with the requirements of the Division, as detailed in the attachment. Based on this
assessment,the Division recommends that this proposed pilot project may be approved by the County based on these and
local criteria. If approval is granted, the list of conditions shall be incorporated in the resolution granting such approval.
Please provide the Division with a copy of the County resolution for approval or denial of the application for a Certificate of
Designation. Should you have any questions concerning this matter, please contact Roger Doak at 303-692-3437.
Sincerely / 7
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Roger Doak, Geologist nn F. Mallory
Solid Waste Unit olid Waste Unit, Leader
Compliance Program / Compliance Program
Attachment
Cc: Julie Chester,Weld County Dept.of Planning Services,w/att
Trevor Jiricek,Weld County Dept. of Public Health and Environment,w/att
Joby Adams, CGRS,w/att 2001-1104
Harry Posey, DMG,w/att
Chris Varra,Varra Companies,w/att y/iteio t
George Moravec,WQCD,w/att
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Attachment
Weld County Board of Commissioners
January 31, 2001
Conditions of Approval
Varra Companies—Fly Ash Pilot Project
Weld County
1. A comprehensive site-specific ground water investigation must be completed and approved
prior to placement of fly ash in the trench. The investigation shall include, at a minimum: (1)
the installation of an adequate number of ground water monitoring wells to characterize
ground water flow rate, ground water flow direction including seasonal fluctuations in ground
water flow; (2) a detailed description of materials comprising the uppermost aquifer including
the lithology, thickness, hydraulic conductivity, porosity and effective porosity; and (3) an
evaluation of local ground water quality—analytical parameters must be identical to those
from the column test. The findings from the site investigation must be submitted to Weld
County and the Division for review and approval.
2. Weld County and the Division shall have the option of collecting split samples from each
ground water monitoring well.
3. A one-year monitoring period has been proposed for this project. We believe the length of
the project should be determined by the results of field data. A one—year period should be a
minimum time frame.
4. During the field investigation period, Varra shall submit laboratory results to the Division and
Weld County within seven (7)days of receipt. If a standard is exceeded, the Division and
Weld County shall be notified within 48 hours.
5. The placement of coal ash under saturated conditions is not without risk, therefore, the
circumstances which would terminate this project must be clearly defined, understood and
agreed to by all parties. In addition, conceptual plans to be implemented if impact to ground
water occurs shall be provided.
6. Background ground water quality levels should be accounted for when considering action
levels. Ground water quality standards promulgated under Regulation #41, 5CCR 1002-41
shall be used when a constituent does not have an established MCL. If a standard is
exceeded at a point of compliance (POC)well and confirmation sampling validates the
exceedance, remedial measures shall be implemented.
7. Action level wells must be installed between the disposal trench and POC wells. POC wells
shall be established approximately 50 feet downgradient from the trench.
8. Financial Assurance must be established prior to acceptance of fly ash. Third party cost
estimates (closure activities and post-closure monitoring) and the financial instrument must
be submitted to Weld County and the Division for review and approval. It is the opinion of
the Division that the trust fund option under Section 1.8 of the Regulations is not an
appropriate financial mechanism for a pilot project.
9. Varra has requested to use 5.0 mg/I as a standard for boron. Regulations 41, the Basic
Standards for Ground Water states that the applicable standard for boron is 5.0 mg/I where a
party can demonstrate that a crop watering use of groundwater is not reasonably expected.
Varra has affirmed that there is no crop watering use of ground water at the pilot site.
Additionally, the volume of boron potentially generated by the pilot is small. A rigorous
ground water monitoring program has been established for the pilot project. The pilot project
meets the general criteria necessary to apply the 5.0 mg/I boron standard. However, should
the pilot project demonstrate the feasibility of disposing of fly ash in a saturated media, a re-
assessment of the boron standard shall be necessary before large-scale disposal operations
begin to protect agricultural use of the ground water in the area.
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