APPCOR13275

• Permit No: C1984062
• IBM Index Class Name: Application Correspondence
• Doc Date: 9/16/1981
• From: ENERGY FUELS CORP
• To: DISMUKE & DISMUKE INC
• Media Type: D
• Archive: No

DEPART"RENT OF NATURAL RESOURCES
D. P,1o~te vascoe, E.ecu rive D,re<i or
!IL\ED L.a\D REt:L.-111--1'i'iO:~
123 Centennial Building, 1313 Sherman Street
Denver. Colorado 80203 Tel [phone]
David C. Shelton
august 6, 1981 Director
TO: Coal Staff
FROM: Bob Liddle
RE: Application of Sludge to Reclaimed Areas
In consultation with the Colorado Department of Health and MLRD staff, I have
prepared the following document which outlines the procedures and requirements
mine operators should follow to obtain approval from ~~fL.4D for sludge utilization
on land. Compliance with this document does not relieve the operator from
compliance with the Performance Standards of Rule 4, or any other local, State,
or Federal Iaw.
Sect: on 2.07,7(2) requires that the disposal of sludge be made to insure
compliance with the Performance Standards of Rule 4 and which prevents violation
of any other applicable State or Federal law. In a meetinc between MLRD and
representatives of the Department of Health .on July 17, 1981, the questions of
jurisdiction over sludge disposal was discussed. Gregory Starhebaum of the
Colorado Hazardous [tastes Control Division indicated that Mined Land Reclamation
now has final jurisdiction over the disposal~of waste at minine operations due
to a recently passed bill, Don Simpson of the Colorado [Dater 7uality Control
Division indicated that his Division has no enforcement authority over the
utilization of sludge on Land. However, they do request tha[ such disposers
voluntarily comply with Department of Health guidelines in anticipation of
regulations to be promulgated in the future under C.R.S. 1973 30-20-101 et. sue.
Richard Fox of the Colorado Air Pollution Control Division indicated that
dust and odor produced from the sludge is covered under his Division's regu-
lations. However, if the sludge is applied and covered properly and only a smaI1
amount is stored on site, there should not be any oreat problem with the practice
unless a citizen reports the practice as a nuisance, As a result of [his .:.eeting,
it was decided that MLRD would review the sludge utilization request in ccrsul-
tation with the Depa rtmen[ of Health.
The general procedure for obtaining approval from .NERD is as follows:
a. Obtain and submit a "letter of approval" from the De partrent o` Health,
Water Quali CU Con [rot Division.
b. Contact the Colorado Air Pollution Control Division to Setermine what,
if an u, information will be needed to bring the existing air quality permit into
compliance. Document that this has been accomplished either by a Setter from
APCD which states not:~ing is reouired, or a cony of the revised application!
permit.
c. If it was not covered in the original permit, the applicant should provide
a discussion of Che probable hydrologic consecuences of the activity (Rule 2).