HYDRO28991

• Permit No: C1981010
• IBM Index Class Name: Hydrology
• Doc Date: 2/1/1994
• Doc Name: TRAPPER MINE SOLID WASTE REGULATIONS SW MOF TRA 1A
• From: CDOH
• To: TRAPPER MINING INC
• Permit Index Doc Type: CORRESPONDENCE
• Media Type: D
• Archive: No

TR9PPER i~INING INC.
January 20, 1994
Mr. Glenn Mallo
Colorado De ment of Health
Waste Bement Division
421 t 11th Avenue
nver, CO 80220
Deaz Mr. Mallory:
RECEIVED
JAN 2 4 ]994
Li:•icion ci i ;:neia~s a I,cCCOv
This correspondence concerns Trapper Mine's waste disposal activities and the regulations
promulgated October 1993, 6CCR 1007-2. We wish to clarify the following three areas:
1. On February 11, 1993, Trapper filed correspondence with the Waste
Management Division and the Moffat County Commissioners concerning
wastes to be disposed at Trapper Mine. The intent of the correspondence was
to notify appropriate agencies that only mine-generated wastes and utility
wastes, (i.e. fly ash, bottom ash, scrubber sludge) generated by the Craig
Generating Station will be disposed on the mine site in accordance with our
approved certificate of designation. Municipal wastes from the City of Craig
and Moffat County will not be disposed on the mine site as originally approved
in Trapper's Certificate of Designation but solid wastes generated at Trapper
may be.
2. Colorado Revised Statute, Title 30, Article 20, Section 102, Subsection 4, allows
mining operations, operating under a permit issued by the Mined Land
Reclamation Boazd to dispose of solid wastes generated by such operations,
within the permitted area without obtaining a certificate of designation. Section
1.3.7 and Section 1.4.2 of 6CCR 1007-2 grant exemptions from a Certificate of
Designation and the applicable standards of those regulations for those opera-
tions permitted by the Colorado Mined Land Reclamation Board, pursuant to
Title 34, Article 32, Section 101, et sea.' CRS 1973. Article 32 deals with "non
coal" operations; Article 33 refers to coal operations, which are not specifically
exempted under Sections 1.3.7 and 1.4.2. We assume the intent of the
Department was to also exempt Title 34, Article 33 operations, which are
permitted by the Mined Land Reclamation Board under Sections 1.3.7 and 1.4.2
and the reference was inadvertently excluded.
3. Section 2.0 of 6CCR 1007-2 outlines the minimum standards for solid waste
disposal sites not exempted by CRS 30-20-102 and having a Certificate of
Designation from the Department and Local Governing Body. Trapper
maintains that we are in compliance with Section 2.0 regulations by virtue of our
mining and reclamation permit from the Colorado Division of Minerals and
Geology (DMG) This permit addresses in detail disposal of utility wastes
generated by the Craig Station, including hydrologic monitoring, annual
reporting, site controls, site closure and reclamation. We feel this permit meets
the minimum requirement standards of Section 2.0, including the requirements
P.0. Box 187 Craig, Colorado 81626 [phone]