1999-06-30_REVISION - M1977342

• Permit No: M1977342
• IBM Index Class Name: Revision
• Doc Date: 6/30/1999
• Doc Name: Technical Revision TR-08 application
• From: CLIMAX MOLYBDENUM CO
• To: DMG
• Type & Sequence: TR8
• Media Type: D
• Archive: No

NOV.20.1998 11:36AN DIIW INEP.RLS&GEOLOGY NO. 142 P. 114
•
STATE OF COL01 ADO
DIVISION Of MINERALS AND GEOLOGY
Devanment of Natural Resources Post-it"Fax Note 7671 Date l/70-g Sys►
1317 Sherman St.. Room 215 � To• - � � From/ /
Denver,Colorado 60203 1
Phone:[phone]S67 coiDopt" ' Co.
FAX:(303)832•8106 t Phone
Ph one p ;EPTN�OF
DATE: November 19, 1998 Fax `axn NATURAL
XSOURCES
TO: Anne Beierle, Henderson dine;Jeff Todd, Schafer and Associates Roy Romer
Covemor
FROM: Allen Sorenson lames5.Ex Lochl
ad
<w Direc:
dve DireC:cr
Micurl B.Long
RE: Disposal of Urad Treatment Plant Sludge at the Henderson Mine, Climax Division Director
Molybdenum Company- Operator,Permit No.M-77-342
The Division of Minerals and Geology(DMG) Was recently notified that CIimax Molybdenum Company
(CMC)intends to submit a technical revision requesting approval To dispose of sludge from the
consolidated water treatment plant located at the Urad Mine into Pond 1.2 located at the Henderson Mine.
Pond 1.2 is a lined 30 acre-foot capacity pond that was used in the water treatment process at Henderson
prior to construction of the consolidated treatment plant at Urad. The DMG routinely permits water
treatment sludge disposal at mine sites through t e approval of"Environmental Protection Plans"
(defined in Rule I.1(16) of the Hard Rock/Metal Mining Rules and Regulations of The Mined-Land
Reclamation Board)for sludge generated by water treatment facilities that operate solely fora specific
permitted mine. Sludge disposal in an"Environmental Protection Facility" (Rule 1.1(15)) is required
• under the regulations due to the potential for production of"Acid Mine Drainage" (Rule.1.1(2)). A
complicating factor exists with the permitting of sludge disposal at the Henderson Mine because the water
treatment nlant where the sludge is precipitated�s outside the mine yerntit area.
In 1996, the DMG determined that the consolidated water treatment plant in the Urad valley constituted
an off-site operation not conducted on affected land which did not need to be regulated as part of The
Henderson Mine reclamation permit This was partly because the consolidated water treatment plant
treats water from both the Henderson and Urad Elites. The Urad Mine was closed prior m adoption of
the Colorado Mined Land Reclamation Act and DMG has never regulated or issued a permit for the
URAD Mine. Therefore, the DMG considered the consolidated water treatment plant to be a facility that
treated a component of water from a source outside DMG jurisdiction and not properly included in the
Henderson Mine permit area.
In 1992, the DMG and the Hazardous Materials and Waste Management Division (FMWMD) entered
into a Memorandum of Understanding(MOU)relating to solid waste disposal at mine sites (copy
attached). The MOU states that any facility which imports waste from off-site must obtain a Certificate
of Designation (CD). Since the water treatment;sludge in question is generated outside the Henderson
Mine permit area and since the sludge is partly derived from Treatment of Urad mine water(remembering
that the Urad Mine is a pre-law site for which the DMG has never held a permit), the sludge would be
considered by the DMG[ e an imported waste for which a CD would be required. However, the MOU
Aso staa�C`�tes�la�ersons who dispose of their own waste oTlte own property do not need q CD. The
Urad and Henderson mines are on property un r the common control of Cyprus-AMAX, which would
qualify Urad sludge disposal at Henderson for the.exclusion to the CD requirement. Essentially, the
DMG would call the sludge an imported waste (see item#1 in the MOU; copy attached) and the
. . Mf%;rMD would not. It is unlikely that Clear Creek County would issue a CD for the water Treatment
11 -19-98 22 : 38 RECEIVED FROM : P - 611