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<br /> <br />Henderson Permit #77-342 <br />March 19, 1981 <br />Page Five <br />topsoil will be stockpiled as aggregate mining <br />progresses into presently undisturbed areas. <br />7. All compacted areas should be ripped prior to planting. <br />See Rule 6.5(3). <br />See existing permit and amendment application. <br />8. Is there any radioactivity in the mill tailings? If so, <br />please describe the significance of potential hazards <br />and detail plans for mitigation. Also, please supply a <br />complete baseline mill tailing chemical-mineral <br />analysis. Address all potentially toxic substances in <br />detail including plans for their control. <br />A study by PEDCo, Inc. (subcontracting for the <br />EPA), pursuant to the Solid Waste Disposal Act of <br />1980, of Henderson tailing indicated that the EPA <br />Extraction Procedure Acid Extracts of tailing was <br />within the limits specified in the hazardous waste <br />regulations of RCRA. Consequently, the tailing is <br />not classified as a hazardous waste. <br />9. Subsoil may need to be salvaged and stockpiled for <br />replacement on amendment tailing areas prior to topsoil <br />placement. The proposed 6 to 18 inches of topsoil does <br />not appear to be sufficient. Note - mill tailings at <br />the Climax and Urad mines are being covered with 3+ feet <br />of waste rock. <br />We feel this topic was extensively addressed in the <br />existing permit. We are confident that the tailing <br />reclamation plan is sound. If waste rock were <br />readily available for capping the pond, we would <br />probably utilize it for that purpose while at the <br />same time stockpiling little, if any, soil. Waste <br />rock is not readily available; soil is readily <br />available. The one foot cap and seal of soil will <br />adequately control the rate of oxidation of the <br />tailing and provide an excellent growth medium for <br />vegetation. The tailing is not toxic, therefore no <br />significant negative tropism is anticipated when <br />the roots penetrate the tailing/soil interface. <br />Tailing itself can be revegetated with the addition <br />of lime and long term nutrient amendments. The <br />lime amendment in our revegetation plan is not <br />deemed necessary, but simply provides insurance <br />against an excessive oxidation rate. <br />