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These areas were created prior to the enactment of reclamation regulations when the CKD was considered <br />a manufacturing by-product rather than a mining waste. The MLRB issued a Declaratory Order on June <br />23, 1993 (Attachment 2) to allow soil and rock from an adjacent area to be used as cover material for the <br />CKD even though it was not required by the regulations at that time. Based on this information, Holnam <br />was not planning on including these in the revised permit area. <br />Item No. 7 <br />The CKD disposal area on the south side of the pond is not within the permit boundary and should be <br />removed from the list and addressed in the same manner as the two CKD disposal areas discussed in Item <br />6 above. <br />Figure 2 has been revised accordingly. This issue of the revised permit area boundary will also be <br />addressed under the permit amendment application to follow. <br />Item No. 8 <br />Discuss the type of permit the Fremont Sanitation District holds to dispose of the sludge in the CKD <br />disposal areas. What agency issued the permit and when? What agency required the installation of <br />monitoring wells 1, 2, 3 and 4? <br />Fremont Sanitation District (FSD) has no specific permit for the disposal of sludge in the CKD disposal <br />areas. In 1991, when application of the sludge on the CKD was being considered, FSD inquired with the <br />Colorado Department of Public Health and Environment (CDPHE) as to the appropriate regulatory <br />program and permits which would be required. CDPHE determined (see letter dated June 4,1991 included <br />as Attachment 3) that there was no specific program for this activity but reviewed the project against <br />applicable criteria contained in the Domestic Sewage Sludge Regulations. FSD's Class B permit allows <br />the land application of sludge. In addition, FSD reports the gallons and pounds of sludge applied to the <br />CKD in their annual NPDES (National Pollution Discharge Elimination System) report. <br />FSD recognized the potential impacts to ground water from the sludge application and voluntarily installed <br />of monitoring wells MW-1, -2, -3, and ~. As the mining cut where these wells were installed was <br />backfilled with overburden material, the well casings were extended to keep the wellheads above the ever- <br />changing ground surface. After a period of time, FSD stopped monitoring the ground water from these <br />wells because they were concerned that the wells may not be providing reliable sample results. These wells <br />were sampled from May 1991 to June 1994 and analyzed for Total Suspended Solids, Biological Oxygen <br />Demand, pH, nitrates, ammonia and TCLP metals. The results of the groundwater sampling performed by <br />FSD are included as Attachment 4. <br />These wells were abandoned by K-S & Company personnel in April 1999. <br />Item No. 9 <br />Provide any available information regarding the potential disruption of the CKD disposal areas by <br />construction activities (e.g., new crusher and conveyor system) and potential changes in the site hydrology <br />as a result of the diversion of Bear CreelG The diversion of Bear Creek would require a 404 permit and an <br />amendment to the existing mining permit. <br />