APRIL 2013 Colrald’...approach differs from others states because all ash ponds in Colorado are...

Colorado’s Toxic Trash Exposed

APRIL 2013

coal ash

Clean Water Fund — www.CleanWaterFund.orgClean Water Fund (CWF) is a national 501(c)(3) research and education organization that has been promoting the public interest since 1978. Clean Water Fund supports protection of natural resources, with an emphasis on water quality and quantity issues. CWF’s program builds on and complements those of Clean Water Action. CWF’s organizing has empowered citizen leaders, organizations and coalitions to improve conditions of hundreds of communities, and to strengthen policies at all levels of government.

Clean Water Action — www.CleanWaterAction.orgClean Water Action (CWA) is a national 501(c)(4) environmental organization with nearly one million members nationwide. Clean Water Action works for clean, safe and affordable drinking water, prevention of health-threatening pollution, creation of environmentally-safe jobs and businesses, and empowerment of people to make democracy work. CWA has organized strong grassroots groups, coalitions, and campaigns to protect our environment, health, economic well-being, and community quality of life.

AcknowledgementsThe research and report were prepared by Erin Adair, Clean Water Fund’s Colorado Program Coordinator. Clean Water Fund staff participating in the review: Jennifer Peters, Lynn Thorp, Kathleen E. Aterno, and Michael Kelly. Special thanks to The Education Foundation of America for funding this research.

For an electronic copy of this report, visit:www.CleanWaterAction.org/cotoxictrashexposed

Or contact:Clean Water Fund

1536 Wynkoop Street B-400 Denver, CO 80202 Tel: 303.405.6755 Fax: 303.405.6754

E-mail: [email protected]

Clean Water Fund requests that you provide appropriate credit on all reprinted materials.

Colorado’s Toxic Trash


Table of ContentsCoal Ash is a National Dilemma .................................................................................4

Where is Coal Ash in Colorado? .................................................................................5

How is Coal Ash Managed? .......................................................................................6

a. Landfill Disposal ..................................................................................................................6

b. Temporary Ash Ponds .........................................................................................................7

c. “Beneficial” Use of Coal Ash ...............................................................................................9

Colorado Regulatory Practices ....................................................................................9

Contaminated Sites ................................................................................................. 10

Common Pathways ..................................................................................................12

Conclusion..............................................................................................................12

References ............................................................................................................. 14

Appendix A: Coal Fired Power Plants in Colorado ......................................................... 16

Appendix B: SMCRA Regulations of Backfilling Abandoned Mines ................................. 17

Appendix C: Human Health Impacts from Heavy Metals ...............................................19

Appendix D: “Beneficial” Use of Coal Ash ...................................................................20

Appendix E: Colorado Solid Waste Regulations ............................................................21

Appendix F: Groundwater Monitoring Contaminants ..................................................... 24

Colorado’s Toxic Trash Exposedcoal ash


Coal Ash is a National DilemmaCoal combustion residuals, more commonly known as

coal ash, are the waste produced by coal fired power plants. As facilities install new scrubbers to capture air pollutants to comply with long overdue Environmental Protection Agency (EPA) air pollution regulations, the concentration of toxic chemicals and heavy metals in coal ash will increase.1 Burning coal produces a large amount of waste — EPA estimates that 140 million tons of coal ash is produced annually. Coal-fired power plants produce more toxic waste than any other industry in the U.S.2 Unfortunately, there are no federal regulations to ensure communities and wildlife are protected from this toxic waste.

Coal ash is currently exempt from the 1982 Resource Conservation and Recovery Act (RCRA) — the law that governs hazardous and solid waste disposal in the U.S.3 This means that the majority of coal ash is dumped in unlined landfills or wet impoundments (often called ash ponds) while the rest is disposed of in abandoned mines or recycled in some form. Many of these dump sites lack adequate safeguards such as protective liners or groundwater monitoring. This leaves nearby

communities and wildlife at risk from potential large scale disasters, like the massive coal ash spill in Tennessee in 2008 which dumped more than one billion gallons of coal ash into the Emory and Clinch Rivers, destroyed three homes and damaged dozens more.4 In response to this disaster EPA, in June 2010, proposed a rule to address coal ash disposal. However, as of early 2013, no rule has been finalized.

Without minimum federal standards to control this toxic waste, coal ash will continue to be managed through a patchwork of weak state programs, which have allowed the water, air, and land in at least 37 states to be poisoned, including Colorado.5 Coal ash contamination that has occurred in Colorado and nation-wide is preventable. This report will discuss how coal ash is managed in Colorado, describe several cases of known contamination, and offer recommendations for how to prevent future spills and leaks.

Coal Ash Residuals Include:Fly Ash: Fine powdery particles that float up the smokestack and are captured by pollution control devices

Bottom Ash: Coarse, heavier materials that fall to the bottom of the furnace

Flue Gas Desulfurization (FDG): Wet sludge or dry powder that results from chemically combining sulfur gases with a sorbent

Boiler Slag: Crystallized pellets that form when molten slag comes in contact with quenching water in the furnace

Source: U.S. Congressional Research Service. “Managing Coal Combustion Waste (CCW): Issues with Disposal and Use.” 7-5700, Janu-ary 12, 2010. Luther, L.

Congress passed Resource Conservation Recovery Act 42 U.S.C. §6901 et seq. in 1976 to protect human health and the environment from potential impacts of waste disposal and to ensure that wastes are managed in an environmentally responsible manner.

Source: U.S. Congressional Research Service. “Managing Coal Combustion Waste (CCW): Issues with Disposal and Use.” 7-5700, January 12, 2010. Luther, L.


Where is Coal Ash in Colorado?There are 13 coal-fired power plants in Colorado; most are concentrated on the Front

Range, with two on the eastern plains and three on the western slope. Over half of these power plants were built nearly 50 years ago. The oldest facility, Xcel’s Arapahoe Station in Denver was built in 1951, and the youngest facility, the Rawhide Station in Larimer County near Fort Collins, was constructed in 1984. See Appendix A for facility details.

As energy demands have increased, power companies have added capacity by building additional units. While Xcel’s Comanche Station added an additional coal burning unit in 2010, most power plants have added capacity through the use of wind, solar and natural gas.6 Some plants will soon transition to natural gas, but we will still have to dispose of decades’ worth of accumulated coal ash.

According to estimates from the Energy Information Administration, in 2011 Colorado utilities produced nearly 1.7 million tons of coal ash. Three power plants in Colorado produce nearly 60% of the waste; Xcel’s Cherokee Station in Denver, Xcel’s Comanche Station in Pueblo, and Tri-State’s Craig Station in Moffat County. In 2011, these stations produced a combined 962,600 tons.7

Coal-fired power plants in Colorado Source: Google Maps 2013


How is Coal Ash Managed?Colorado manages coal ash in a few different ways. The majority of Colorado’s coal ash

is eventually disposed of in landfills but it can also be stored temporarily in ash ponds, backfilled in abandoned mines, or sold for “beneficial” use.8

Landfill disposalThere are seven active on-site landfills that are regulated under the Colorado Department

of Public Health and the Environment’s (CDPHE) solid waste guidelines. Power plants with active landfills are Xcel Energy’s Comanche, Valmont, and Pawnee Stations, Platte River Power Authority’s Rawhide, Tri-State’s Nucla and Hayden, and R.D. Nixon, which also accepts waste from the Martin Drake facility.

In 2011, more than one million tons of coal ash from these facilities was disposed of in on-site landfills — that’s over 60% of total coal ash produced in Colorado.9 These landfills primarily hold fly ash, bottom ash, but commonly accept small amounts of excavation solids, pond sediments, scrubber solids and coal impurities. None of the ash disposal landfills have

proper safeguards in place — they are either unlined or have a compacted clay liner. Compacted clay liners are inadequate because they are more permeable than synthetic or composite liners. Freeze-thaw cycles, certain chemicals, and low moisture content can cause fractures in clay liners, which reduces their effectiveness.10 The State requires groundwater monitoring for heavy metals including arsenic, boron, cadmium lead, and selenium with results reported quarterly or bi-annually.11 Because solid waste regulations lack minimum standards for liner design or leachate monitoring systems, Colorado coal ash landfills lack leachate collection or monitoring systems which are a first line of defense in detecting ground water contamination.

Tri-State’s Craig plant is a unique case; the on-site landfill was filled to capacity and closed in 1999. Instead of constructing an additional on-site landfill, Tri-State now transports Craig’s waste approximately five miles south to the Trapper Mine. The Trapper Mine is an abandoned coal mine that is being backfilled with coal ash for reclamation and re-vegetation. This landfill is dually regulated by CDPHE and the Department of Reclamation Mining and Safety (DRMS), the state agency with primary regulatory

Cherokee plant and disposal site near the South Platte River Source: Google Earth 3-27-2013

Leachate Collection Systems are a series of perforated pipes that run between the liner (or bottom of landfill) and waste. Leachate or water that has traveled through the waste is collected to prevent groundwater contamination.

Source: Waste Management. Typical Leachate Collection and Recovery System. http://www.wm.com/about/community/pdfs/Leachate_Collection_System.pdf


responsibility over coal mining in Colorado. There are federal standards for backfilling practices outlined by the Federal Surface Mining Control and Reclamation Act of 1977 (SMCRA). State programs, like Colorado’s operate under SMCRA.12 See Appendix B for details on the State’s program. Backfilling abandoned mines is a problem because of the potential for acid mine drainage (AMD) — the drainage water from mines. Studies indicate that AMD mixed with coal ash increases leachate of heavy metals whether the AMD is highly acidic or alkaline. High acidity conditions lead to the greatest leaching of cobalt, chromium, copper, and zinc, while the leaching of arsenic, antimony, and selenium were greatest under alkaline conditions. Heavy metal leachate can pollute surrounding groundwater and surface water.13

Though the Trapper Mine is the only active site accepting coal ash, there are inactive sites that Xcel Energy used to dispose coal ash from the Valmont, Arapahoe, and Cherokee plants. A retired shale mine in Jefferson County was backfilled and a retired gravel pit in north Denver was backfilled to dispose of over 932,000 cubic yards of Cherokee’s coal ash. Clear Creek and the South Platte River are approximately 500 feet downstream from the Cherokee disposal site. With an over 30-year old compacted clay liner, and no groundwater monitoring conducted since 1999, waste at this site has the potential to pollute groundwater and the South Platte River.

Temporary Ash PondsThere are 16 coal ash storage ponds at seven power plants in Colorado. Colorado’s

approach differs from others states because all ash ponds in Colorado are for temporary storage. Other states typically use ash ponds for final disposal.

Temporary ponds are filled with bottom ash, and then excess water is drained or left to evaporate. The remaining dry waste is then dredged and placed in the on-site landfill for final disposal. The Pawnee and Rawhide Stations are ‘zero-discharge’, which means any water

Plant Ponds14 Lined/Unlined15 Discharge16

Xcel Cherokee Station 3 Unlined NPDES permit

Xcel Valmont Station 2 Unlined NPDES permit

Xcel Comanche Station 1 Lined NPDES permit

Xcel Pawnee Station 3 Lined NPDES permit

PRPA Rawhide Station 2 Lined Zero-discharge

Martin Drake 4 Lined Zero-discharge

Ray D. Nixon 1 Lined Likely Zero-discharge

Xcel Arapahoe Station 0 N/A Likely Zero-discharge

Xcel Hayden Station 0 N/A N/A

Tri-State Craig Station 0 N/A N/A

Tri-State Nucla Station 0 N/A N/A

Lamar Plant 0 N/A N/A

WN Clark Station 0 N/A N/A

TABLE 1: Ash Storage Ponds Distribution for Colorado Power Plants


from ash ponds must remain in a closed loop system. A ‘zero-discharge’ process does not guarantee that all wastewater from ponds will not leak into surrounding water resources. Other stations send excess water through polishing ponds which mix all facility wastewater to adjust for pH and then discharge this waste mixture into surface water. This practice is permitted through the Clean Water Act’s National Pollution Discharge Elimination Systems (NPDES) program.17 NPDES permits regulate point source pollution such as wastewater from a power plant that is discharged directly into a stream, river, or other water body.18 Most states, including Colorado enforce NPDES permits through state water quality programs. CDPHE’s

Water Quality Controls Division oversees the Colorado Discharge Permit System. Facilities in Colorado with individual wastewater NPDES permits are Xcel’s Comanche, Cherokee, and Valmont.

Steam electric power plants can have multiple NPDES permits; most are required to have stormwater discharge permits to account for coal pile runoff and other surface pollutants, some have non-contact cooling water permits for discharges of turbine cooling water, and facilities with ash ponds that are not ‘zero-discharge’ facilities have a permit for wastewater discharges.

EPA has never set minimum standards on the amount of heavy metals coal fired power plants can discharge into surface water, even

though these pollutants are known to harm humans and aquatic life. EPA is drafting new limits on the amount of toxics in wastewater that is discharged into surface water. Even in very small doses, the heavy metals commonly found in coal ash, such as mercury and arsenic, can be harmful because they do not degrade over time and increase in concentration as they pass up the food chain. Dozens of coal ash ponds have spilled or leaked toxic pollutants into surface waters across the country. There are also at least 12 known wildlife damage cases from permitted discharges where toxic pollutants in coal ash has caused fish kills as well as biological and genetic impacts to aquatic life.19 Elevated levels of arsenic, selenium, and cadmium can severely degrade water quality and have serious impacts on the long-term survival of aquatic habitats in rivers, lakes and reservoirs.20

Colorado has five unlined coal ash storage ponds; three at the Cherokee plant in Denver and two at the Valmont plant in Boulder.21 Exposure to toxic heavy metals like arsenic, boron, cadmium, lead, and selenium found in coal ash can cause negative impacts on human health, including increased risk for bladder, lung, liver, and stomach cancers.22 See Appendix C for more details on human health impacts. Ponds or impoundments are regulated separately from landfills and with less stringent oversight from CDPHE. The State lacks information on liner materials for the 11 lined ash ponds. Synthetic composite liners are more protective than compacted clay liners. However, even synthetic liners are porous and can allow small molecules of liquid and harmful constituents to leach into soil and groundwater.23 Threats to groundwater from these ash pond sites are unknown because Colorado has no minimum groundwater monitoring standard for surface impoundments.

National Pollution Discharge Elimination Sytems Permit: Under the Clean Water Act, the NPDES Permit program controls water pollution by regulating point sources that discharge pollutants to United States waterways. Point sources can be pipes, man-made ditches, or industrial and municipal facilities. The NPDES permit program was introduced in 1972 and parts of the program (specifically effluent or discharge limit guidelines for steam electric power plants) need upating to include limits on heavy metals.

Source: U.S. EPA. National Pollutant Discharge Elimination Sytem (NPDES), http://cfpub.epa.gov/npdes/index.cfm


“Beneficial” Use of Coal AshIn 2011 Colorado sold 505,400 tons, or 30% of coal ash for “beneficial” use. More than half

of that comes from Xcel’s Cherokee plant.24 There are two categories of reuse; encapsulated and unencapsulated. Common reuses of coal ash are in concrete and Portland cement (encapsulated) and structural fills and embankments (unencapsulated). EPA has deemed most unencapsulated reuse practices unsafe and does not constitute it as “beneficial” use. EPA’s definition of “beneficial” use — as a means to replace the use of alternate materials that would otherwise need to be obtained through extraction — specifically excludes large-scale fill projects.25 EPA is unsure about the safety of some unencapsulated reuses, like soil amendments. EPA should continue to research the safety of both unencapsulated reuse and encapsulated reuse. See Appendix D for details on “beneficial” uses for coal ash.

There are at least 27 proven cases of contamination from “beneficial” use, and at least seven of them are from unencapsulated fill projects.26 In Bloomington, Indiana there is extensive soil contamination from coal ash cinders being used as stabilizer for a rail bed. This was an unencapsulated structural fill which caused arsenic and lead to exceed Indiana Department of Environmental Management’s Risk-Based Soil Default Closure Levels (DCL’s). DCL’s provide default cleanup levels for soil and groundwater for both residential and industrial uses depending on how that site will be used in the future. Samples taken in the former CSX rail corridor revealed concentrations of arsenic that were 88 times the DCL for residential use and 60 times DCL for industrial use. This is almost 900 times the EPA screening level for arsenic.27 Unencapsulated reuse of coal ash is reckless and poses a threat to human health and ecosystems.

Colorado Regulatory PracticesColorado regulates coal ash through its CDPHE’s Solid Waste and Materials Management

Program. According to the State there is “little to no chance” of coal ash contamination at disposal sites because of the dry climate and low permeability of bedrock formations. As a result, all coal ash landfills are either unlined or have compacted clay liners and do not have leachate collection systems.28 These regulations for facility construction, liner design, leachate collection systems, inspections and groundwater monitoring are loose and inadequate. See Appendix E for a detailed summary of regulations. Coal ash is classified as a non-hazardous solid waste and coal ash landfills are regulated the same, if not less stringently, than municipal solid waste landfills.

In Colorado, groundwater monitoring is one of the strongest regulatory safeguard against toxic heavy metal contamination from coal ash because it follows EPA minimum standards. The ground water monitoring program follows EPA’s 40 CFR Part 258 Solid Waste Disposal Facility Criteria. These guidelines describe requirements for background water quality data, the frequency of sampling and analytical methods used and list the constituents tested for.29 See Appendix F for complete constituent list. However, the groundwater monitoring

Encapsulated Reuse Concrete, cement additive, gypsum wallboard, road base

Unencapsulated Reuse Structure fill/embankments, waste stabilization, soil modification, and other agricultural uses.

TABLE 2: “Beneficial” Use of Coal Ash


program is significantly weakened by following state guidelines for the number and spacing of monitoring wells. The state follows the “Water Well and Pump Installation Contactor’s Act”, Title 37, Article 91, Part 1 for groundwater monitoring wells. Geology and groundwater flow are parameters for number and spacing of wells, but these regulations are vague and provide less guidance than EPA’s 40 CFR Part 258.30 As a result, some sites have as few as two monitoring wells while some sites have eight.

Additionally, our research suggests that the State’s analysis of groundwater monitoring data does not reveal potential threats to groundwater and surface water. Background water monitoring is conducted prior to ash disposal to establish a baseline. Once the site is active, a statistical method of the operator’s choice is used to determine whether or not there is a statically significant increase in current groundwater monitoring results over the baseline.31 Colorado’s method of detecting groundwater contamination excludes science-based EPA water quality standards for aquatic life and drinking water standards that are intended to risk to ecosystems and public health. Recent quarterly groundwater monitoring reports from each power plant are readily available, however baseline water quality data are not included in these reports and are difficult to find. Groundwater monitoring reports are relatively useless to the public without access to baseline water quality data.

Contaminated SitesEPA has identified two contaminated sites and our analysis indicates that there are an

additional three potentially contaminated sites in Colorado. However, no corrective action has been taken at any of these disposal sites because groundwater monitoring results have not shown statistically significant increases of pollutants over background levels. According to EPA, Xcel’s Comanche plant and Tri-State’s Craig plant have contaminated groundwater, and Platte River Power Authority’s Rawhide plant, Xcel’s Valmont plant, and Ray Nixon plant in Colorado Springs have been identified as facilities where groundwater is potentially contaminated with heavy metals found in coal ash.

Facility Active/Inactive Contaminants Source

Xcel Comanche33 Active Landfill Cadmium, selenium, chloride, sulfates EPA

Tri-State Craig34 Inactive Landfill Arsenic, boron, chloride, manganese, nickel, selenium, sulfate EPA

PRPA Rawhide35 Active Landfill Background levels: boron, iron, manga-nese, total dissolved solids, sulfate EPA

Xcel Valmont Active Landfill Arsenic, boron, cadmium, chloride, selenium Screening Tool

Xcel Comanche Active Landfill Sulfate, cadmium, chromium, chloride, selenium Screening Tool

PRPA Rawhide Active Landfill Boron & sulfate Screening Tool

Ray D. Nixon Active Landfill Arsenic & boron Screening Tool

TABLE 3: Contaminated Landfills


The Craig plant’s retired landfill was found to have arsenic, boron, chloride, manganese, nickel, selenium, and sulfate, and total dissolved solids that exceeded Maximum Contaminant Levels (MCL) or state groundwater standards. The Comanche plant’s active landfill was found to have cadmium, selenium, chloride, and sulfates that exceeded MCLs or state groundwater standards. EPA also indicated that Rawhide’s background water monitoring data exceeded MCLs for boron, sulfate, iron, manganese, and total dissolved solids.32

Environmental Integrity Project (EIP) developed a groundwater monitoring screening tool that can be used to make a basic assessment of whether a facilities groundwater quality report shows evidence of coal ash contamination. Using this screening tool four sites in Colorado were identified as “likely contaminated”; Valmont, Comanche, Rawhide, and Ray

Nixon. The screening tool results for Comanche and Rawhide supports EPA contamination findings. Both analyses for Comanche found elevated levels of cadmium, selenium, chloride, and sulfates. EPA’s analysis for Rawhide found elevated levels of boron, iron, manganese, and total dissolved solids in background monitoring data and the screening tool indicated elevated levels of boron and sulfates in recent groundwater monitoring reports.

MCLs are set based on reducing public health risk in drinking water or for contaminated clean-up site levels, and EPA’s chronic freshwater limits are set to reduce risk for aquatic life that is exposed to a specific body of water long-term. These aquatic limits are much lower for cadmium, chromium, lead and selenium than drinking water standards. Coal ash contamination of groundwater and surface water is dangerous for both human health and aquatic life.

Contaminant EPA MCL36

mg/LEPA MCLG37 mg/L

Freshwater Chronic38 mg/L

CO Groundwater Standards39 mg/L

EIP Threshold mg/L

Arsenic 0.010 0 0.150 0.010 0.010

Cadmium 0.005 0.005 0.00025 0.005 0.005

Chromium 0.10 0.10 0.074 (III) 0.01 0.05

Lead 0.015 0 0.0025 0.05 0.015

Selenium 0.05 0.05 0.005 0.05 0.010

TABLE 4: Contamination Standards

Environmental Integrity Project is a nonpartisan, nonprofit organization established in March of 2002 by former EPA enforcement attorneys to advocate for more effective enforcement of environmental law.

The groundwater screening tool is an interactive spreadsheet that profiles arsenic, boron, manganese, sulfates, antimony, cadmium, chloride, chromium, cobalt, lead, molybdenum, and selenium. Contaminant thresholds are similar to EPA MCLs and groundwater standards. This tool enables users to quickly determine if a site is “probably not contaminated” because of sufficient data and no evidence of contamination; “unknown” because of insufficient data; “possibly contaminated” because of insufficient data with some evidence of contamination; or “likely contaminated” because of sufficient data and evidence of contamination.

Source: www.environmentalintegrity.org


Common PathwaysThere are two primary pathways for coal ash contamination in Colorado. Contaminants can

leak into groundwater and surface water from both landfills and ash ponds, potentially having negative impacts on human health, wildlife and ecosystems.

There are at least five coal ash disposal sites that are closed or retired yet still pose a risk of groundwater contamination. Xcel’s Hayden and Valmont plants both have retired unlined landfills on-site in addition to active unlined landfills that exceed screening tool

thresholds. Closed facilities that are a potential threat to groundwater include a backfilled gravel pit in Denver and a shale mine in Jefferson County that hold thousands of tons of coal ash. These retired coal ash disposal sites are dangerous pathways for groundwater contamination in Colorado; four out of five are unlined and current plans for post-closure care provides inadequate protections.

Xcel’s Comanche, Cherokee, and Valmont stations have NPDES permits that allow for wastewater discharge from ash ponds into surface waters. The streams and rivers these sites are permitted to discharge into are listed impaired waters under the Clean Water Act or are identified by Colorado to have possible water quality issues.40 Comanche discharges into the St. Charles River which is impaired because of elevated levels of selenium. This section of the St. Charles River has had elevated levels of selenium for nearly 10 years.41 Cherokee discharges into the South Platte River upstream from downtown Denver and Cherry

Creek. This section of the South Platte River has been impaired for over 15 years because of elevated levels of cadmium and E. coli.42 Valmont discharges into the Boulder Creek. The State has concerns about Boulder Creek because of increased levels of copper and cadmium along various sections of the Creek, including sections near the Valmont plant.43

303(d) Impaired Waters: The federal Clean water Act requires states to identify waters where discharge limitations are not strong enough to attain water quality standards. this includes waters impaired as a result of non-point source, point source discharges or combined point source and non-point source, and natural sources.i Colorado also has a monitoring and Evaluation List (M&E List) that identifies water bodies where there are suspected water quality issues, but lack complete information to confirm.ii

Sources:iU.S. EPA Impaired Waters and Ttotal Daily Maximum Loads. http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/index.cfm

iiCDPHE. Water Quality Control Commission. Colorado’s Section 303(d) List of Impaired Waters and monitoring and Evaluation List. 5 CCR 1002-93. March 2012

ConclusionThis survey of the situation in Colorado confirms that minimum federal standards for the

handling, storage, and disposal of toxic coal ash are needed. Currently, EPA considers coal ash to be a “special waste” and it is exempt from federal RCRA regulations — which leaves coal ash less regulated than household trash. Without any federal regulations for coal ash, states are left to create a weak patchwork of programs.

In Colorado, coal ash is regulated as a non-hazardous waste along with household trash. Combined with vague regulatory language for liner design, leachate collection systems, groundwater monitoring wells, and post-closure care dangerous pathways for contamination have been created. The State is putting Coloradans and wildlife populations at risk for toxic heavy metal exposure from coal ash contamination. Absent of federal regulations, Colorado


can strengthen state coal ash programs to protect public health, wildlife and aquatic life. Policy recommendations to address the weaknesses in Colorado’s regulation of coal ash are below.

Policy Recommendations

1. Coal ash impoundments should be phased out in Colorado. Power plants discharge wastewater from ash ponds that are laced with heavy metals into surface waters and impaired rivers and streams. Ash ponds threaten both groundwater and surface water in Colorado.

2. The practice of backfilling abandoned mines should be phased out of coal ash disposal practices in Colorado. Current state regulations on backfilling are extremely vague and lack sufficient oversight. Backfilling abandoned mines threatens groundwater and surface water in Colorado.

3. The practice of unencapsulated reuse of coal ash should not be used in Colorado. EPA has deemed most unencapsulated reuses of coal ash unsafe, and other as questionable. Additionally, further research is required on all forms of “beneficial” use to ensure that groundwater and surface water is protected from coal ash contamination.

4. State regulations should have strict and specific minimum standards for landfill liner design. Current state regulations for liner design have allowed all coal ash landfills in Colorado to be constructed without an adequate liners. Requiring new coal ash landfills to be constructed with synthetic or composite liners will protect communities in the future from coal ash contamination.

5. CDPHE’s Remediation Program should have a specific program to address inactive coal ash disposal sites. Currently the Remediation Program does not include inactive coal ash disposal sites. Most inactive sites are not properly lined and lack consistent groundwater monitoring and are a threat to groundwater and surface water in Colorado.

6. All closed coal ash disposal sites should have a minimum 30 year post-closure care plan. Current state regulations for post-closure care allow for exemptions, and that period can be decreased if the site is not impacting human health or the environment. These exemptions should be removed to reduce impacts to public health and water sources.

7. The State needs to implement stronger groundwater protections with increased transparency and consistency. Current state regulations for groundwater monitoring programs are potentially allowing groundwater contamination to go undetected. Vague language for ground water monitoring wells design and requiring monitoring results to be analyzed against baseline water quality data instead of federal or state groundwater quality criteria leaves Coloradans vulnerable to the risks associated with groundwater and surface water contamination.

Coloradans are at risk of exposure to toxic coal ash contamination. State regulatory programs are filled with exemptions and vague language that do not specifically address the storage, management and disposal of coal ash. Clean Water Fund strongly urges our decision makers in Colorado to consider the recommendations made in this report in order to protect all of Colorado’s natural resources, wildlife, aquatic life and public health from exposure to toxic heavy metals from coal ash.


References1 U.S. Congressional Research Service. “Managing Coal Combustion Waste (CCW): Issues with Disposal and Use”. 7-5700,

January 12, 2010. Luther, L.

2 U.S. Environmental Protection Agency. 2010. Hazardous and Solid Waste Management Systems; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals from Electric Utilities; Proposed Rule, 75 Fed. Reg. 35128, June 21, 2010.

3 U.S. Congressional Research Service. “Managing Coal Combustion Waste (CCW): Issues with Disposal and Use”. 7-5700, January 12, 2010. Luther, L.

4 Evans, L., Becher, M. and Lee, B. State of Failure: How States Fail to Protect Our Health and Drinking Water from Toxic Coal Ash. August 2011. Earthjustice. http://earthjustice.org/sites/default/files/StateofFailure.pdf

5 Earthjustice. In Harm’s Way: Coal Ash-Contaminated Sites. http://earthjustice.org/features/campaigns/in-harm-s-way-coal-ash-contaminated-sites. Updated December 2012. U.S. Environmental Protection Agency. March, 2012.

6 U.S. Department of Energy’s Energy Information Administration, Form EIA-860, Annual Electric Generator Data. 2011.

7 U.S. Department of Energy’s Energy Information Administration, Form EIA-923, Electric Power Data. 2011.

8 Ibid.

9 Ibid.

10 Hughes, K. L., Christy, A. D., Heimlick, J. E. Ohio State University. Landfill Types and Liner Systems Fact Sheet. http://ohioline.osu.edu/cd-fact/0138.html

11 Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division. Regulations Pertaining to Solid Waste Sites and Facilities. 6 CCR 1007-2, Part 1. (Amended May, 2012).

12 U.S. Environmental Protection Agency. Mine Placement of Coal Combustion Waste State Program Elements Analysis. Final Draft. p.14-23. December, 2002.

13 The National Academy of Sciences. Managing Coal Combustion Residues in Mines. p.69-72. http://www.nap.edu/catalog/11592.html

14 Environmental Integrity Project. Data pursuant to Freedom of Information Act Request to U.S. Environmental Protection Agency. “re: Questionnaire results for Steam Electric Power Generating Effluent Guidelines.” June, 2012.

15 Ibid.

16 U.S. Environmental Protection Agency. Enforcement & Compliance History Online (ECHO). http://www.epa-echo.gov/echo/compliance_report_water.html

17 U.S. Environmental Protection Agency. Data pursuant to Freedom of Information Act Request to Xcel Energy. “re: Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. 9604(e).” May, 2009

18 National Pollutant Discharge Elimination System (NPDES), U.S. Environmental Protection Agency. http://cfpub.epa.gov/npdes/index.cfm

19 Lemly, D. A., Skorupa, J. P. Wildlife and Coal Waste Policy Debate: Proposed Rules for Coal Waste Disposal Ignore Lessons from 45 Years of Wildlife Poisoning. August, 2012.

20 U.S. Environmental Protection Agency. Steam Electric Power Generation Point Source Category: Final Detailed Study Report. p.6-7 to 6-18. October, 2009.

21 Environmental Integrity Project. Data pursuant to Freedom of Information Act Request to U.S. Environmental Protection Agency. “re: Questionnaire results for Steam Electric Power Generating Effluent Guidelines.” June, 2012

22 Agency for Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health & Human Services. ToxFAQ. http://www.atsdr.cdc.gov/toxfaqs/index.asp

23 U.S. Environmental Protection Agency. Lining of Waste Containment and Other Impoundment Facilities. p.3-1. September, 1988.

24 U.S. Department of Energy’s Energy Information Administration, Form EIA-923, Electric Power Data. 2011.


25 U.S. Environmental Protection Agency. 2010. Hazardous and Solid Waste Management Systems; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals from Electric Utilities; Proposed Rule, 75 Fed. Reg. 35128. Section 35. June 21, 2010.

26 Ibid.

27 Environmental Integrity Project. Risky Business: Coal Ash Threatens America’s Groundwater Resources at 19 More Sites. December 12, 2011. http://www.environmentalintegrity.org/documents/121311EIPThirdDamageReport.pdf

28 Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division. Regulations Pertaining to Solid Waste Sites and Facilities. 6 CCR 1007-2, Part 1. (Amended May, 2012)

29 Ibid.

30 Colorado Division of Water Resources. Water Well Construction and Pump Installation Contactors Act. Article 91, Part 1, 37-91-110. http://water.state.co.us/DWRIPub/Documents/boe_statutes.pdf

31 Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division. Regulations Pertaining to Solid Waste Sites and Facilities. 6 CCR 1007-2, Part 1. (Amended May, 2012).

32 Environmental Integrity Project. Data pursuant to Freedom of Information Act Request to U.S. Environmental Protection Agency. “re: Questionnaire results for Steam Electric 2009 Part F Section 5. April 2012

33 Ibid.

34 Ibid.

35 Ibid.

36 U.S. Environmental Protection Agency. Drinking Water Contaminants. http://water.epa.gov/drink/contaminants/upload/mcl-2.pdf

37 Ibid.

38 U.S. Environmental Protection Agency. National Recommended Water Quality Criteria: Aquatic Life Criteria Table. http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm#altable

39 Colorado Department of Public Health and Environment, Water Quality Control Commission. Basic Standards for Groundwater. 5 CCR 1002-41.

40 Colorado Department of Public Health and Environment, Water Quality Control Commission. Colorado’s Section 303(d) List of Impaired Waters and Monitoring and Evaluation List. 5 CCR 1002-93. March 2012.

41 U.S. Environmental Protection Agency. Watershed Assessment, Tracking & Environmental Results: 2010 Waterbody Report for St. Charles River. http://iaspub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=COARMA06_3400&p_cycle=2010&p_report_type=

42 U.S. Environmental Protection Agency. Watershed Assessment, Tracking & Environmental Results: 2010 Waterbody Report for S. Platte River – Burlington Ditch to Clear Creek. http://iaspub.epa.gov/tmdl_waters10/attains_waterbody.control?p_list_id=COSPUS15_0600&p_cycle=2010&p_report_type=

43 Colorado Department of Public Health and Environment. Water Quality Control Commission. Colorado’s Section 303(D) List of Impaired Waters and Monitoring and Evaluation List. 5 CCR 1002-93. March 2012.


Appendix A:Coal-Fired Power Plants in Colorado

Power Plants Operator County Coal Ash Generation/yri

Ash Pondsii Landfill

Nucla Tri-State G&T Assn Inc Montrose 157,800 tons None 1 unlined

Craig Tri-State G&T Assn Inc Moffat 352,800 tons None None

Hayden Xcel Energy Routt 128,100 tons None 1 unlined

Rawhide Platte River Power Authority Larimer 76,700 tons 2 lined 1 unlined

Valmont Xcel Energy Boulder 79,800 tons 2 unlined 1 unlined

Arapahoe Xcel Energy Denver 23,800 tons None None

Martin Drake City of Colorado Springs El Paso 73,900 tons 4 lined None

Ray D. Nixon City of Colorado Springs El Paso 74,100 tons 1 lined 1 unlined

W.N. Clark Black Hills Energy Fremont N/A N/A N/A

Comanche Xcel Energy Pueblo 305,600 tons 1 lined 1 unlined

Lamar City of Lamar Prower N/A N/A N/A

Pawnee Xcel Energy Morgan 62,100 tons 3 lined 1 unlined

TOTALS 1,638,900 tons 16 ponds 7 landfills

i U.S. Department of Energy’s Energy Information Administration, Form EIA-923, 2011.

ii Environmental Integrity Project. Data pursuant to Freedom of Information Act Request to U.S. Environmental Protection Agency. “re: Questionnaire results for Steam Electric Power Generating Effluent Guidelines.” June, 2012.


Appendix B:SMCRA Regulations for Backfilling Abandoned Mines

State: Colorado

Permitting Public Availability

of monitoring/inspection

data

Public Participation

in Compliance

Address CCW in SMCRA Permit

Type of Revision

to SMRCA Permit

Additional permit,

notification or approval

Public Participation

in Permitting

Coal Mines YES N/A YES YES YES YES

Noncoal Mines YES YES NO YES N/A N/A

State: Colorado

Address CCW in Site

Reclamation/ Operation

Plan

Address CCW in Site

Characterization /PHC

Determination

Siting Restrictions

Address Acid Mine Drainage/ Acid Base Balance

Formal Risk Assessment Focused on

CCW

Enforceable Limits/

Corrective Action

RequirementsCoal Mines YES YES More than

SMRCA YES YES More than SMRCA

Noncoal Mines N/A YES YES N/A N/A YES

State: Colorado

WasteCharacter-

ization Prior to

Placement

GroundwaterMonitoring

During Placement

Character- istic Limits

Surface H20 Monitoring

During Placement

Post- Closure

During Placement

Post- Closure

Coal Mines YES YES NO YES Same as

SMCRASame as SMCRA

Same as SMCRA

Noncoal Mines YES YES NO Case-by-

caseCase-by-

case N/A N/A

1: Administrative Program Elements

2: Planning and Enforcement Program Elements

3: Waste Characterization and Monitoring Program Elements


State: Colorado

Groundwater Table

Restrictions

Compaction or Other

Waste Conditioning

Interim Cover

Fugitive Dust

Controls

Erosion/ Surface Runoff

Controls

Coal Mines YES Case-by-case NO Same as

SMCRASame as SMCRA

Noncoal Mines YES NO YES YES YES

State: Colorado

Final Cover

Revegetation Financial Assurance/Bonding

Post-closure Site Utilization Restrictions

Coal Mines Same as SMRA Same as SMRA Case-by-case N/A

Noncoal Mines YES YES Case-by-case N/A

4: Design and Operational Program Elements

5: Closure and Post-Closure Program Elements

Appendix B: (cont.)SMCRA Regulations for Backfilling Abandoned Mines

Source: U.S. Environmental Protection Agency. 2002. Mine Placement of Coal Combustion Waste State Program Elements Analysis. Final Draft. P. 14-23. December, 2002.


Appendix C:Human Health Impacts from Heavy Metals

Many heavy metals found in coal ash are harmful to human health. Arsenic, boron, cadmium, chromium, lead, and selenium pose the greatest threat to communities living near leaky and poorly constructed coal ash disposal sites.

Arsenic is a naturally occurring element found widely in the earth’s crust, soil, and minerals. In addition to coal ash, arsenic can also be found in industrial pressure-treated lumber and pesticides. Exposure can cause nausea, vomiting, cardiovascular issues, and increased risk of skin cancer and cancer in the liver, bladder, and lungs. EPA has determined arsenic to be a known carcinogen, and living near a coal ash disposal site can drastically increase chances of developing cancer.i

Boron is a naturally occurring compound often found combined with other substances, like boric acid. Boron is used to produce glass, flame retardants, and some pesticides. Short-term exposure through inhalation can cause eye, nose, and throat irritation. Long-term exposure can cause reproductive damage (especially to the testes) and damage to the stomach, intestines, liver, and kidneys. Exposure to large amount of boron can even lead to death.ii

Cadmium is a naturally occurring element found in the earth’s crust and is in all soils, rocks, including coal and minerals. It can be used products like batteries, pigments, metal coatings, and plastics. Long-term exposure to cadmium can cause kidney disease, lung damage, and fragile bones and is identified by the Department of Health and Human Services (DHHS) as a known carcinogen.iii

Chromium is a naturally occurring element found in rocks, animals, plants, and soil. There are many forms of chromium and it can be a liquid, solid, or gas. Exposure to chromium through inhalation causes irritation of nose and throat, and breathing issues such as asthma, cough, and wheezing. Ingestion of chromium can cause stomach and intestinal ulcers, anemia and stomach cancer. EPA and DHHS have determined that chromium is a known carcinogen and long-term exposure can lead to lung and stomach cancer.iv

Lead is a metal found in the earth’s crust and much of it comes from burning fossil fuels like coal. Exposure to lead can affect nearly every organ and system in your body, but mainly affects the nervous system. High levels of lead exposure can lead to brain and kidney damage, and miscarriages in pregnant women. Children are more vulnerable to lead poisoning than adults which can affect a child’s mental and physical growth.v

Selenium is a naturally occurring mineral that is found widely in most rocks and soils and is most commonly used in the electronics industry. Low doses of selenium are necessary for human health, but exposure to high levels can cause respiratory irritation, coughing, and bronchitis, and can have neurological effects.vi

i Agency of Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health and Human Services. ToxFAQ for Arsenic. http://www.atsdr.cdc.gov/tfacts2.pdf

ii Agency of Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health and Human Services. ToxFAQ for Boron. http://www.atsdr.cdc.gov/toxfaqs/tfacts26.pdf

iii Agency of Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health and Human Services. ToxFAQ for Cadmium. http://www.atsdr.cdc.gov/tfacts5.pdf

iv Agency of Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health and Human Services. ToxFAQ for Chromium. http://www.atsdr.cdc.gov/toxfaqs/tfacts7.pdf

v Agency of Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health and Human Services. ToxFAQ for Lead. http://www.atsdr.cdc.gov/tfacts13.pdf

vi Agency of Toxic Substances and Disease Registry (ATSDR), U.S. Department of Health and Human Services. ToxFAQ for Selenium. http://www.atsdr.cdc.gov/tfacts92.pdf


Appendix D:“Beneficial” Use of Coal Ash

CCW Product Description Type of CCW Used

ENCAPSULATED USES

Concrete Concrete consists of a mixture of 25% sand, 45% gravel, 15% Portland cement, 15% water.

Certain types of fly ash can replace a % of Portland cement, and are typically less expensive.

Cement Additive Cement clinker is an intermediary prod-uct of the Portland cement manufactur-ing process. Clinker is formed when a raw mix consisting of limestone, clay, bauxite, iron ore and quartz are heated to high temperature.

Fly ash can be blended with limestone or shale and fed into the cement kiln to make clinker, which is ground into Port-land cement.

Gypsum Wallboard Gypsum wallboard (drywall) is used in an interior finish in the construction of build-ings. Wallboard is composed of a layer of gypsum stucco sandwiched between heavy paper.

FDG gypsum can replace 100% of virgin gypsum in wallboard after excess mois-ture has been removed.

Road Base A road base is a foundation layer un-derlying a pavement and overlaying a subgrade of natural soil or embankment fill material. It protects the underlying soil from the detrimental effects of weather conditions and from traffic loads.

Bottom ash can be used to offset virgin sand or gravel in road base.

UNENCAPSULATED USES

Structure Fill/Embankments

Structure fill is an engineered mate-rial used to raise or change the surface contour of an area and provide ground support beneath building foundations. It can be used to form embankments.

Depending on soil type, fly ash can replace a % of virgin rock, dirt, sand, or gravel in structure fill. Generally 50%. Bottom ash can be used to offset virgin sand and gravel in structure fill.

Waste Stabilization CCW can be used in place of Portland cement, cement kiln dust, or lime to solidify and harden wet or liquid waste before it is landfilled.

Certain types of fly ash harden by them-selves in contact with moisture; others can be mixed with another hardening agent, such as Portland cement, in order to be used in waste stabilization.

Soil modification/ Stabilizing/ Agricultural Uses

Gypsum can be used as a nutrient source for crops; as a conditioner to improve soil’s physical properties and water infiltration and storage; to remediate high sodium soils; and to reduce nutrient and sediment movement to surface waters.

Fly ash and FDG gypsum can be used as a soil amendment to neutralize acidic soils.

Source: U.S. Congressional Research Service. “Managing Coal Combustion Waste (CCW): Issues with Disposal and Use”. 7-5700, January 12, 2010. Luther, L. p. 24.


Appendix E:Colorado Solid Waste Regulations

PART A: GENERAL REQUIREMENTS AND INFORMATION

Nuisance Controls �� Noise, fugitive dust, and odors shall not exist at or beyond the site boundary These nuisance conditions shall not pose hazard to human health or wildlife.

�� Facility shall cease operations during periods when high wind warnings are verified on-site

Water Protection �� Sites and facilities shall comply with groundwater protection standards at the relevant point of compliance

�� Solid waste shall not be placed below or into surface and groundwater

�� No aquifer recharge areas shall be adversely impacted

�� Owner/operator shall notify CDPHE and local government in writing within 10 days of a release or possible contamination that will likely cause a statistically significant increase in water monitoring detection.

Site Maintenance �� Sites and facilities shall be adequately fenced or secured to prevent waste material and debris, and to control public access to prevent illegal dumping

Certificate of Designation

�� Sites and facilities who dispose of his own solid wastes on his own property are not required by CDPHE to obtain a certificate of designation

Inspections �� Authorized representatives of the CDPHE shall have access to inspect all such sites and facilities (as well as any property, premises or place where solid waste may be located) during normal business hours

�� Inspections shall be made upon consent or after a search warrant is issued by the CO district court in order to verify compliance

�� No prior notification is needed for such inspectionsEnforcement �� Compliance Advisory maybe be issued when CDPHE deems it appropriate to

notify the site or facility that a violation has occurred or is occurring.

�� There are many ways the compliance advisory can be resolved — most correspondence will be done through letter


Appendix E: (cont.)Colorado Solid Waste Regulations

PART B: STANDARDS FOR SOLID WASTE DISPOSAL LANDFILLS

Regulations �� Regulations for municipal solid waste landfills (MSWLF) are to be equivalent to but no more stringent than 40 CFR Part 258

�� These state regulations also apply to non-MSWLF sites and facilities on a case-by-case basis

Location and Restrictions

�� New landfills and expansions shall not be located in wetlands, unstable areas, floodplains, or below surface water. Landfills should isolate waste from public and the environment and have maximum protection against winds on-site

Design and Operation Plans

�� Design plans must include geologic data, hydrologic data, and engineering data

�� Liner design should consider the barrier layer permeability, barrier layer thickness, barrier layer porosity, slope of barrier layer, hydraulic head on the barrier layer, distance of relevant point of compliance, distance and characteristic of the uppermost aquifer, climate factors, estimated volume, physical characteristics and chemical characteristics of the leachate, and chemical compatibility of the barrier layer to estimate leachate chemical characteristics, distance groundwater is beneath the site would flow during life and post closure period, distance to domestic wells or springs

�� The barrier layer shall be engineered to meet performance standards of 40 CFR Part 258.40(a)(1) and shall be one of the following materials, natural lithology with re-compaction, a soil liner, composite liner, or something of an alternative design

�� Leachate collection systems shall be designed and constructed to maintain less than 12 inch depth of leachate over the barrier layer. Factors to be considered in the design of leachate collection system include; waste type, anticipated leachate generation rate, slope length, % slope, barrier layer, hydraulic conductivity of drainage layer, and long term performance during active life and post closure

�� Owner/operators must cover disposed waste with 6 inches of soil at the end of each day or as much as needed

�� Post-closure of a landfill phase requires care and maintenance like; preventing nuisance conditions, maintaining integrity and effectiveness of final cover, groundwater monitoring, and maintaining and operating leachate collection system


Appendix E: (cont.)Colorado Solid Waste Regulations

PART C: GROUND WATER MONITORING SYSTEMS

Applicability �� Ground water monitoring may be waived by CDPHE after consulting with the local governing body if the owner/operator demonstrates that there is no migration potential for hazardous substances, pollutants and contaminants from solid waste disposal site during life of facility and post-closure

�� If requirements are waived, operator must continue to demonstrate no potential hazard exists by submitting ground water monitoring data every 5 years

Background Monitoring

�� The owner/operator must establish background groundwater quality in hydraulically upgradient or background wells for each parameter or constituent required

�� After background water quality data has been collected, a statistical analysis is performed using multiple comparisons to identify statistically significant evidence of contamination. Control charts are made to track control limits for each constituent

Monitoring Wells �� Monitoring well must have casing that maintains the integrity of the monitoring well bore hole

�� Ground water monitoring wells and points are designed and installed in accordance with applicable rules and regulations in the “Water Well and Pump Installation Contractor’s Act”

�� The number, spacing, and depths of monitoring systems shall be determined based on site specific information that must include characterization of the saturated thickness, ground water flow rate, ground water flow direction

Sampling and Analytical Methods

�� Ground water monitoring program must include consistent sample and analysis procedures that are designed to ensure results that will provide an accurate representation of ground water quality at background and down-gradient well installed

�� Ground water monitoring program must include sampling and analytical methods that will accurately measure hazardous constituents. Analytical methods shall be according to CDPHE guidelines or EPA approved method for constituents

Assessment Monitoring

�� Assessment monitoring is required whenever a statistically significant increase over background data has been detected for constituents listed

�� The parameters for the assessment monitoring program shall be determined based on the types, quantities and concentrations of constituents in wastes, and the mobility, stability, and persistence of waste constituents

�� Within 90 days of finding any constituent detected at a statistically significant level exceeding background concentrations, owner/operator must initiate an assessment of corrective measures

�� Assessment shall include analysis of effectiveness of potential corrective measures to remedy the exceedance

Source: Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division; Regulations Pertaining to Solid Waste Sites and Facilities. 6 CCR 1007-2, Part 1. (Amended May, 2012).


Appendix F:Groundwater Monitoring Contaminants CATIONS �� Magnesium

�� Sodium

�� Potassium

�� Calcium

ANIONS �� Carbonate

�� Bicarbonate

�� Chloride

�� Sulfate

�� Nitrate

�� Nitrite

FIELD PARAMETERS

�� pH

�� Specific Conductivity

�� Temperature

�� Total Organic Carbon

INORGANIC CONSTITUENTS

�� Antimony (Total)

�� Arsenic (Total)

�� Barium (Total)

�� Beryllium (Total)

�� Cadmium (Total)

�� Chromium (Total)

�� Cobalt (Total)

�� Copper (Total)

�� Lead (Total)

�� Nickel (Total)

�� Selenium (Total)

�� Silver (Total)

�� Thallium (Total)

�� Vanadium (Total)

�� Zinc (Total)

ORGANIC CONSTITUENTS

�� Acetone

�� Acrylonitrile

�� Benzene

�� Bromochloromethane

�� Bromodichloromethane

�� Bromoform; Tribromomethane

�� Carbon Tetrachloride

�� Chlorobenzene

�� Chloroethane; Ethyl Chloride

�� Chloroform; Trichloromethane

�� Dibromochloromethane; Chlorodibromomethane

�� 1,2-Dirbromo-3-Chloropropane; Dbcp

�� 1,2-Dibromoethane; Ethylene Dibromide; Edb

�� O-Dichlorobenzene; 1,2-Dichlorobenzene

�� P-Dichlorobenzene; 1,4-Dichlorobenzene

�� Trans-1,4-Dichloro-2-Butene

�� 1,1-Dichloroethane; Ethylidene Chloride

�� 1,2-Dichloroethane; Ethylene Dichloride

�� 1,1-Dichloroethylene; 1,1-Dichloroethene; Vinlyliden Chloride

�� Cis-1,2-Dichloroethylene; Cis-1,2-Dichloroethene

�� Trans-1,2-Dichlorothylene; Trans-1,2-Dichloroethene

�� 1,2-Dichloropropane; Propylene Dichloride

�� Cis-1,3-Dichloropropene

�� Trans-1,3-Dichloropropene; Propylene Dichloride

�� Cis-1,3-Dichloropropene

�� Trans-1,3-Dichlorpropene

�� Ethylbenzene

�� 2-Hexanone; Methyl Butyl Ketone

�� Methyl Bromide; Bromomethane

�� Methlyl Chloride; Chloromethane

�� Methylene Bromide; Dibromomethane

�� Methylene Chloride; Dichloromethane

�� Methyl Ethyl Ketone; Mek; 2-Butanone

�� Methyl Iodine; Iodomethane

�� 4-Methyl-2-Pentanone; Methyl Isobutyl Ketone

�� Styrene

�� 1,1,1,2-Tetrachloroethane

�� 1,1,2,2-Tetrachloroethane

�� Tetrachloroethylene; Tetrachloroethene Perchloroethylene

�� Tolulene

�� 1,1,1-Trichloroethane; Methylchloroform

�� 1,1,2-Trichloroethane

�� Trichloroethylene; Trichloroethene

�� Thrichlorofluoromethane; Cfc-11

�� 1,2,3-Trichloropropane

�� Vinyl Acetate

�� Vinyl Chloride

�� Xylenes

Source: Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division; Regulations Pertaining to Solid Waste Sites and Facilities. 6 CCR 1007-2, Part 1. (Amended May, 2012).

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