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� t <br /> ' STA?t OF CALIFORNIA GEORGE DEUKMEJIAN,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION (a3443 ROUTIER ROAD <br /> SACRAMENTO,CA 95827-3098 <br /> ti. <br /> P, <br /> 31 March 1989 <br /> Mr. Robert Fowler y <br /> Frank C . Alegre Trucking, Inc . /-• <br /> 802 North Cluff Ave . <br /> Lodi, CA 95240 <br /> PROPOSED COAL ASH RECYCLING PROJECT <br /> We have reviewed your proposal of 7 March 1989 to mix coal <br /> L t L `^ lant 4 n Sto kto whli— <br /> anti i.tOtii file Energy Factors pGiticr p. .� C.. <br /> sand, and sell this mixture as foundation material, for <br /> building construction . Our review of your proposal is <br /> affected by several unknowns as discussed below. However, <br /> the proposed activities should not pose a threat to water <br /> uality, provided that you take steps to minimize any runoff <br /> rom t e ash at your acility. <br /> Our comments are as follows : <br /> 1 . Will storage of the ash at your facility be done in a <br /> manner which protects water quality? You indicated in our <br /> discussions that ash will be stored at your facility after <br /> mixing with sand and that the on-site storage time will be <br /> minimized . We suspect that the ash has high levels of <br /> soluble salts, expressed as Total Dissolved Solids (TDS) from <br /> the Waste Extraction Test (WET) using deionized water, but no <br /> data is available . Our concern is that water in contact with <br /> the sand-ash mixture could dissolve significant amounts of <br /> salt and carry it into surface or ground water. You need to <br /> insure that runoff from your facility will not be allowed to <br /> cause a water quality problem in surface or ground water . <br /> Management practices for the stockpiled material could <br /> include covering it, storage under a roof, or storage on an <br /> impermeable pad with runoff control measures . <br /> 2 . Since the place of use will determine the potential effect <br /> on water quality, where will the ash be placed and what will <br /> its effect on water quality be in this location? You <br /> indicated that the sand-ash mixture would be used for <br /> foundations of buildings . In general, buildings are con- <br /> structed to drain water away from foundations . This would <br /> avoid contact of ash with water and prevent the dissolution <br /> of constituents in the ash . If limited amounts of the <br /> material are placed in scattered areas, the threat to water <br /> quality, if any, should be minimized. However, we do not <br /> have the resources to study all of the possible sites where <br />