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numerous changes have occurred at Henderson. Facility expansion, as <br />envisioned in the late 1970s, has not happened to the degree planned at that time. <br />Thus, Henderson no longer requires the full 393 acres of buffer for potential future <br />disturbances. While Henderson does not wish to eliminate any of the 393 buffer <br />acres from the affected area within the Permit boundary, it does propose to reduce <br />the total FW for buffers. <br />Henderson requests a reduction in the FW for buffer areas from 393 acres to 75 <br />acres. Elimination of FW for 318 acres of buffer reduces the FW by $334,854. <br />Henderson proposes that if unforeseen future operational needs require use of <br />buffer areas beyond 75 acres, a FW adjustment would be required prior to any <br />disturbance. <br />3.2 Structural Demolition - On Site Disposal <br />The original Henderson Permit placed tittle emphasis on the particulars of <br />removal of structures during Gosure, stating only that structures would be tom <br />down, salvaged, and removed off-site, while concrete foundations and asphalt <br />would be buried on-site. However, closure experience at other CMC operations <br />and non-CMC sites has shown that unsalvageable, non-hazardous structural <br />material can be buried at the site more efficiently and cost-effectively than hauling it <br />long distances to take up valuable space in public landfills. <br />As part of TR-12, Henderson is requesting a technical change in the Permit <br />allowing the disposal on Henderson property of structural materials that cannot be <br />salvaged. <br />3.2.1 Disposal Locations <br />Henderson is proposing four (4) locations for the subsurface disposal of <br />demolition materials. These locations are noted on Map 1 for the mine and Maps . <br />2 and 2a for the mill. At the mine site, shafts No. 2 and No. 5 would be used as <br />disposal sites prior to permanent shaft closure. Henderson believes that <br />subsurface disposal in this manner is an excellent end-use of these two deep <br />shafts. <br />Two (2} disposal sites have been located on the mill side of Henderson. One <br />large disposal site is at the mill (Area 5) and one is located at the present onsite <br />landfill near the tailings impoundment (Area 18). The mill location is the old coal <br />4 <br />