HomeMy WebLinkAbout991076.tiff ��'l _ ST_A__ T_E OF C_OLO__ RADO
Bill Owens,Governor r � pF Cow
Jane E.Norton, Executive Director 'el" r`
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Dedicated to protecting and improving the health and environment of the people of Colorado te' ,S
HAZARDOUS MATERIALS AND WASTE MANA tSt DIVISION
http://www.cdphe.state.co.us/hm/ TO y
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4300 Cherry Creek Dr.S. 222 S.6th Street, Room 232
Denver,Colorado 80246-1530 Grand Junction,Colorado 81501-2768 Colorado a Departmentublic Ha
Phone(303)692-3300 Phone(970)248-7164
alth
Fax(303)759-5355 Fax(970)248-7198 and Environment
May 3, 1999
Christopher Varra
Varra Companies
12910 Weld County Road 13
Longmont, CO 80504
Re: Proposed V arra Coal Ash Pilot Project-Work Plan and Analytical Data, April 1, 1999.
Dear Mr. Varra:
On April 6, 1999,tf..e Solid Waste Unit of the Hazardous Materials and Waste Management Division (the
Division)received 1/arra Companies application for a Certificate of Designation to perform a pilot
project where coal combustion ash would be disposed in saturated conditions. The pilot project is part of
Varra's proposed reclamation plan for areas previously mined for gravel in Weld County. In accordance
with the Solid Waste Statute (CRS 30-20-103), and with the Solid Waste Regulations (the Regulations)
promulgated there¢ider, 6 CCR 1007-2, a preliminary completeness review of such application is
required within thiry(30) days of receipt.
The Division has completed its 30-day review of the application. In the judgement of the Division, the
application is incomplete and will require further modification/revision to adequately meet the
requirements of the Regulations. Furthermore, based on the information and data provided, the Division
cannot make a favorable determination on the submitted application.
The unfavorable determination is discussed below:
Table 6 of the Work Plan provides a summary of the SELF' coal ash analytical results which exceed
water quality standards established pursuant to Colorado's "The Basic Standards For Ground Water",
Regulation#41, (5 OCR 1002-41). In addition,results of other analytical methods (TCLP, SGCLP,
SGLP) show numerous constituents leaching from coal ash which exceed a relevant groundwater
standard. The analytical data unequivocally shows degradation of the groundwater will occur if coal ash
is placed in a saturated medium. Placing a waste, which has been demonstrated to leach pollutants,
below the water table in an aquifer that is used or has the potential to be used for domestic use is
prohibited.
A request may be made with the state's Water Quality Control Commission for a variance for site
specific groundwater standards. Unless a variance is granted or additional data is provided which
demonstrates exceedance of ground water standards will not occur, the Division will maintain its
unfavorable recommendation for the proposed coal ash pilot project.
991076
R I - fl PL j3C- 0
Christopher Varra
May 3, 1999
Page 2
Attached are two memos which provide further discussions regarding deficiencies identified during
staff's review of the Work Plan and Analytical Data. Items and issues in the attachments must be
adequately addressed before the Division would consider the application complete. Upon our
determination that the application is complete, Division staff would commence with its 150-day
comprehensive technical review of the application.
We want to emphas:ze that our interest and desire are to work cooperatively with Varra Companies and
other interested parties. We are sensitive to the financial costs should Varra continue to pursue the
application without an approved variance for groundwater standards. A meeting between members of
Weld County Health Department, Varra Companies, Colorado Groundwater Resources Services, the
Water Quality Control Division, and the Solid Waste Unit may be arranged at your option - the intent
being to discuss any/all items or issues that have been raised herein.
In closing, please be aware that the Solid Waste Unit is authorized by statute to charge a fee for staff
time spent in technical review of permit applications,remediation plans, etc. The applicant will be
charged $72.47 per hour($10,000 maximum) for time spent on the review.
It is the intent of the Division to provide comments that assist the applicant in generating the most
complete and concise document possible. Should you have any questions or concerns regarding this
matte, please contact Roger Doak at 303-692-3437.
Sin rely, 1
(1O161A
Roger Doak lenn F. Mallory
Environmental Protection Specialist nit Leader
Solid Waste Unit Solid Waste Unit
Compliance Program Compliance Program
enclosures
cc: Weld Couny Board of Commissioners,w/o encl.
Trevor Jiricek, Weld County Health Department,v./encl.
Monica Daniels-Mika, Weld County Planning Depai fluent w/encl.
Joby Adams, CGRS,w/encl.
Harry Posey, Colorado Division of Minerals & Geology,w/encl
Ken Niswonger, HMWMD, w/o encl.
George Moravec, WQCD, w/o encl.
sw/wld/var2
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
Hazardous Materials and Waste Management Division
INTEROFFICE COMMUNICATION
TO: Glenn Mallory
FROM: Roger Doak
DATE: May 3, 1999
SUBJECT: Varra Coal Ash Pilot Project
My completeness review of Varra's proposal has raised numerous concerns and questions which
need clarification and/or additional information. Below is a discussion of these issues.
1. There maybe potential `water right' issues with this proposal. For example, if the coal ash
acts as a dam and diverts groundwater away from a current user, and/or if groundwater direction
is altered to an adjacent property which, historical, has been dry and now is saturated. An
evaluation of the potential changes to the hydrogeologi.c characteristics of the upper most aquifer
is necessary to provide insight to some of these questions.
2. Staff of the Water Quality Control Division of CDPHE has concluded that a Storm Water
Management Plan (SWMP) is required for the proposed pilot project. Should you have questions
regarding the appropriate and necessary information required for a SWMP, contact Ms. Kathy
Dolan (303.692.M_96).
3. Local groundwater quality (Boulder, Ft. Collins and Greeley area) for unconsolidated alluvial
deposits has been provided. Although this data is useful in terms of discerning the wide range of
constituent concentrations, site specific data is essential to evaluating the groundwater beneath
the facility.
4. A site map which illustrates the location of the coal ash storage area must be provided. A
discussion regarding coal ash management at the storage area must be included. Engineering
controls must be in place prior to acceptance of waste. Procedures must be established which
address mitigation of potential nuisance conditions (e.g., windblown ash).
5. Little to no information has been provided for numerous topics (e.g., local geologic data,
hydrologic properties of the uppermost aquifer, POC wells, recordkeeping, closure plan and
financial assurance). Although the applicant has made a commitment to provide this data after
receiving a CD, it is difficult to make an appropriate evaluation without some of this information.
Initially, information on the local geology and hydrology must be provided for CDPHE to
Varra Coal Ash Pilot Project
May 3, 1999
Page 2
continue with its technical review. Prior to acceptance of waste CDPHE, DMG and Weld
County must review and approve all relevant information (e.g., closure plan, financial assurance,
recordkeeping, etc.) which will be provided after issuance of a CD.
6. The inherent pozzalonic nature of fly ash will affect the ground water behavior beneath this
site. In an effort to evaluate these changes, an adequate number of monitoring points must be
established. Additional wells and/or piezometers must be installed to measure changes in
groundwater elevation, flow direction and quality. The monitoring network provided in the
proposal must be enhanced to provide adequate coverage for changes in the groundwater system.
7. If adverse changes to water quality are observed, the proposed contingency plan requires
removal of ash from the trench and placement in a dry impoundment. Provide a site map
showing the location of the impoundment. Also,provide construction details for the
impoundment. The impoundment must be constructed prior to acceptance of coal ash.
8. Groundwater quality action levels must be established for each constituent prior to acceptance
f coal ash. The proposed action levels must be approved by CDPHE, DMG and WCHD. Once
an action level is met or exceeded, abatement and remedial activities must commence.
9. The applicant anticipates the pilot project will take approximately three (3) months to
complete. This time frame is primarily based on the assumption that water quality parameters
will equilibrate within this time period. Any research project must have a strong scientific basis
and be conducted as a controlled experiment with adequate monitoring over a period of time to
show meaningful results. Therefore, we believe a minimum of one year(four quarters of
groundwater data) is appropriate and necessary to evaluate seasonal changes, water quality
issues, and chemical and physical reactions in groundwater.
10. St. Vrain River or St. Vrain Creek, which is correct?
11. Permits which will be required and/or amended for the pilot project include; a Certificate of
Designation, Use by Special Review, Storm Water Management Plan, amended air quality
permit and amended DMG permit.
12. The disposal of coal ash into saturated conditions will result in a disturbance of the
hydrologic proper:ies of the alluvial materials at this site. In an effort to understand the physical
changes occurring in the aquifer, the applicant must provide an evaluation of the hydrologic
characteristics before, during and after placement of coal ash. Modeling the different hydrologic
scenarios may provide insight which can than be used to understand the dynamics of the
hydrologic characteristics upgradient, within and down gradient of the disposal trench.
Varra Coal Ash Pilot Project
May 3, 1999
Page 3
13. The proposal states that the disposal trench will have one-half filled with only fly ash and the
other half with bottom ash and fly ash. The bottom ash will be placed in the lower one-half of
the saturated portion of the trench and fly ash placed within one foot below ground surface.
Describe how the monitoring points will be constructed to evaluate the bottom ash/fly ash half of
the trench.
14. The applicant has estimated a groundwater flow rate of 100ft. /day below the site. The
groundwater sampling sequence must be appropriate to evaluate the potential rapid changes in
groundwater quality.
15. If the objective of the pilot project is to demonstrate that coal ash exhibits "inert"
characteristics in a saturated medium, than coal ash should be compared to an industry
recognized inert material under identical environmental conditions. With this in mind, CDPHE
suggests that a"control"trench be constructed at this site. This trench would be back filled with
inert material such as, concrete or gravel. The hydrologic properties would be evaluated and
compared to the coal ash trench. In addition, groundwater quality could be sampled
downgradient of the control trench and this data compared to the groundwater quality of the coal
ash trench.
16. Some trace elements in coal are naturally radioactive. These radioactive elements include
uranium, thorium, radium and their numerous decay products. There are questions concerning
possible risk from radiation. In order to accurately address questions regarding radioactive of
coal ash, it is important to determine the concentration and distribution of radioactive elements in
the different sources of bottom and fly ash proposed for this project.
May 3, 1999
To: Glenn Mallory, Roger Doak
From: Ken Niswonger
Re: Comments on Varra Coal Ash Burial Project
1. Composition data on various ashes are provided in the Work Plan Analytical Data document;
however, it is not known from sample descriptions which, if any, are the composition data for the
ashes actually used in the leachate tests. For example, leachate data are presented for a material
named "Bottom Ash", but there are compositional data for bottom ash from the Cameo,
Arapahoe, Cameo 42, and Comanche units. The fly ashes used and named in the leachate tests
cannot be reconciled with compositional data because the sample designations appear to differ
with leachate sample designations.
2. According to the information provided by the power industry regarding ash material and the
manner of generation of ash material considered for the Final Regulatory Determination of Large
Volume Wastes From the Combustion of Coal by Electric Utility Power Plants (Federal Register,
Vol. 58, No. 151), the manner of generation of these wastes typically involve commingling of
bottom ash, fly ash, and possibly, with low volume wastes ranging from plant water to boiler
chemical cleaning wastes. To assist in the evaluation of data generated by the proposed tests as
they are applicable to the universe of potential ashes which may be represented by these data,
please describe the generation, and management of the materials considered for disposal in the
saturated environment present at the Varra Coal Ash Burial Project.
3. The Synthetic Groundwater Leaching Procedure (SGLP), where the samples were rolled for
18 hours in contact with groundwater from the site, does not provide the chemical characteristics
(e.g., pH, Carbonate/Bicarbonate concentrations) of the groundwater prior to, or following these
extraction tests. Furthermore, only one extraction was conducted on ash materials using the
SGLP method. The SGLP results appear to produce dramatically lower concentrations of the
principal metal ions (Al, Ba, Cr, Fe, Mg) and, trace metal ions (Be, B, Cd, Co, Pb, Se, V, Zn, and
Li) as compared tc the Sequential Extraction Leaching Procedure (SELP) at pH 5, 7, or 8.5. It is
not apparent that these observable differences are related to actual chemistries of the
groundwater, or whether the number of extractions performed on ashes using the SGLP
procedure contributes to these differences. The SGLP was conducted following the TCLP
method and substituting groundwater for the extraction fluid.
Varra
May 3, 1999
Page 2
4. The TCLP method was conducted on all waste forms, but the extraction fluid (#1 or# 2)
actually employed was not provided. This ought to be determined in the preliminary evaluations
conducted for each waste form. The pH of the final extract was not provided as specified in
method 1311 - TCLP, section 7.2.14. These data are useful in evaluating the leaching
characteristics of waste form using TCLP, and response to the particular fluid.
5. Of the leach procedures employed for this project, only TCLP is a consensus methodology
with information arid documentation readily available for consultation. As such the particular
reagents, controls, Quality Control features, and related performance data for these, or other
wastes forms are nDt intimately known for the SELP, SGLP, and SCGLP procedures. For
example, the pH o1'the leachate fluid for SELP is provided (5, 7, and 8.5), but the preparation of
these fluids is not discussed. It is not known if buffered solutions were employed, or ratios of
common mineral acids/bases. It is not known what the specification for water was for these
solutions (ASTM Type II ?). The submittal included citations to possibly answer these
questions, and others, but the time allotted for this evaluation, these reference materials could not
be secured. For non-consensus methodologies utilized, provide the actual methods and
deviations for the regulatory reviewer, and the public in general.
6. The first extraction of the SELP test was used to determine the suite of elements for the
SGCLP test. Those not detected, or detected at very low concentrations were eliminated from
further testing. The SGCLP table of elemental parameters indicate that Titanium and Mercury
were actually eliminated from further consideration. There were no detections of Titanium
reported using the SELP procedure for any waste form, or pH. However, not all of the second
SELP extracts were actually analyzed for Titanium. Titanium is present in fly ash ranging frpm
a high of 0.9 % (9000 ug/g) to a low of 0.15 % (1500 u.g/g) as demonstrated by the compositional
data for different f.y, and bottom ash. (See comment#1 relating to the inability to reconcile
compositional data.with materials used in the leach tests). There were positive detections of Hg
in the first SELP extraction volume of two fly ashes, and one positive detection of Mercury in
the second SELP extraction volume at the detection limit. The Mercury detections in the first
SELP extraction volume were, indeed, small, but significantly above the detection limit.
7. As a summary, Table 6 accounts for failures of the groundwater protections standards by the
various ash samples tested by the SELP and SGLP leach tests. Several elemental primary
groundwater standards appear to be exceeded in one, or the other extractions representing the
different fly ashes. None of the fly ash samples exceeded primary standards for Sb, Ag, Ti, As,
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 camments 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 limil.ed 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 qualify 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 sampliag method requirements, analytical method requirements, laboratory quality
control, data assessment and oversight, and data validation/verification.
10. The Table 1-C provides a summary of parameters. The Department would have a preference
for the use of SW-346, method 6010B because of the higher degree of quality control features,
and procedural improvements.
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