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s ,d1z. Sandra L. Bro:c~n <br />Colonrda Divuion afMinera(s fi Geology <br />Decen:Ger 23, 1998 <br />Page S <br />4) .~Ylap 36, Loadout Area Posbnining Topography, shows a solid waste disposal site that was part <br />of TR-17 that was withdrawn. Please remove it from the map. Map 36 also shows the <br />location of two cross-sections and two different <(ope measurements. The cross-sections have <br />not been reviser[ and show the same elevations as proposed in the ortginal permit application. <br />Do the cross-sections need to fie revised given the jour feet of cover over the crusher building? <br />Response: Map 36 and [he associated cross-sections have been reviewed and revised to <br />eliminate the upland disposal site (from TR-17) and address changes in topography due to <br />material disposal, cover, and regrading considerations. <br />SJ Operations of the disposal site must be conducted in accordance with the local, State, and <br />Federal requirements. Please address how Kerr is complying with this requirement at both the <br />concrete burial tipple site and the mining site. <br />Response: Neither the Town of Walden nor Jackson County have applicable solid waste <br />disposal regulations or ordinances, instead deferring to applicable State requirements. The <br />State requirements, in [urn, take precedence over and model applicable Federal solid waste <br />disposal requirements. Under [he applicable Policy/Guidance document issued by the <br />Colorado Department of Public Health and Environment (CDPHE, copy attached for <br />reference), the Certificate of Designation (CD) normally required for inert materials disposal <br />sites would not be required in the case of the proposed coal fines and demolition debris <br />disposal activities for the following reasons: <br />• Statutory Exemption - "Inett materials disposal, which occurs on the site where <br />the waste is generated, is exempt from the CD process under the provisions of <br />Section 30-20-102(3)." (refer to page 2 of Policy/Guidance document, specifically <br />applicable to concrete demolition debris disposal in Kerr tipple area). <br />• Relation to Other State Agencies -Under the Memorandum of Understanding <br />(MOU) between the CDPHE and DMG, an inert material disposal site <br />operating under MLRB permit and regulation which is 20 acres or less and <br />involves disposal of 1,000,000 yds' or less of inert materials is exempt From the <br />requirements for issuance of a CD (refer to pgs 2 and 3 of Policy/Guidance <br />document, specifically applicable to the proposed disposal activities in both the <br />mine and tipple areas). <br />LL' \f f:,TF.IV lflepunv Ln. <br />,}nJiYtl,p! <br />