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N011.20.199B 11:3741 DIV/MINERALS&GEOLOGY NO. 142 P.2i4 <br /> Memo to File M-77-342 2 November 19. 1998 <br /> sludge disposal when the waste is generated and disposed on property under contiguous single ownership. <br /> In order to fill the apparent regulatory gap that is created in this case by the differences in the way the <br /> term imported waste is defined by the DMG and the HMWMD, the DMG will become the lead permitting <br /> agency for btAispos�al_of�the sludge at the Henderson Mine in the a e�V tfiat a tec nicarfe—VIsion for <br /> sludge disposal a[Henderson is submitted. This is n]sgical solution because the DMG is charged with <br /> the regulatory authority to issue permits assuring reclamation to a beneficial post mining land-use and <br /> protection of the environment from the potential adverse impacts resulting from the disposal of mining <br /> related wastes. Typically, these mining related wastes are generated within the permit area either through <br /> mining, extractive metallurgical processing, or water treatment, The generation of water treatment sludge <br /> outside the permit area of the Henderson Mine is a result of a singular circumstance where a pre-law mine <br /> with an ongoing water treatment requirement is located in close proximity to an operating mine under the <br /> same ownership. The advantages to the construction of a consolidated water treatment plant for the two <br /> mines are documented in the withdrawn amendment application AM-02 ro the Henderson Mine permit. <br /> The rationale for the consolidated water treatment plant to be located outside the Henderson Mine permit <br /> boundary is also documented in that same withdrawn amendment application. The unique circumstances <br /> relating to the consolidated water treatment plant should not preclude the Operator from using areas <br /> within the Henderson Mine permit boundary for sludge disposal,and the best mechanism for regulation <br /> of the sludge disposal is through the Environmental Protection Plan administered by the DMG. <br /> t <br /> Fp6ri <br /> order to gain approval for disposal of the sludge, the Operator would be refit It' ed to characterize <br /> osludgeand, monstrate tthat the Environmental Protection Facift Pond 1.2 pro_p9sed as a repositoryovids adequate Qrotecuon to the envt onmest the nature ofthesludge changes, either due to <br /> angon the processes used to treat the water,the <br /> erator would be required to notify the DMG and repeat the sludge characterization and environmental <br /> otection demonstration. <br /> It should be noted that during the review of pending technical revision TR-04 to the Henderson Mine <br /> reclamation permit, the DMG raised specific flood management concerns related to the operation_of Pond <br /> 1? as an Environmental r�otectisn Facility.The Operator responded[o chose concerns by staring that <br /> Pond 1.2 was scheduled for decommissioning upon completion of the consolidated water treatment plant, <br /> and that addressing flood agement concerns for a facility that is scheduled for imminent closure <br /> would be coun[erproducd e3�f Pond I,2 is to be recommissioned as a sludge disposal facility, the related <br /> f flood management concerns trust again become an issue. In addition, cover desi and surface <br /> rec amau—C on plan for the proposed sludge_reposiiorymust be approvedithrough the technical revision <br /> I f process. <br /> G Attachment(s) <br /> cc: Carl Mount,DMG(w/arrachmenr) <br /> Bruce Humphries, DMG(w/arrachmenr) <br /> Mike Long,DMG (w/artachmenr) <br /> Glen Mallory,Hazardous Materials and Waste Management Division (iv/attachment) <br /> a1.A idslud.wpd <br /> • <br /> 11 -19-98 22 : 38 RECEIVED FROM : p. 02 <br />