1998-03-23_REVISION - M1977348 - Laserfiche WebLink

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Memo to File No. M-77-348 • 3 • O:TOber 27, 1998 The geologic cross-section of the Boettcher Quarry is a textbook example of a ground water recharge zone. Typically, recharge zones would be unsuitable locations for the disposal of ~Naste that may generate a contaminated leachate. However, evidence presented by Holnam in TR-C~3 indicaSes that infiltration rates in the played-out quarries are negligible and CKD has been disposed of at this site for many years with no reports of ground water contamination in down gradient areas. Also, the dip of the formations exposed in the quarries is such that these formations dive to great depths below the ground surface just to the east of the quarry and may not be viable sources for the withdrawe~l and beneficial use of ground water. On the other hand, there may be significant fracture controlled flow of ground water through the formations exposed in the quarry and there has been no rigorous demonstration that these formations are not currently and cannot reasonably be expected to be used as ground water sources. 2. Establishment of a viable ground water monitoring program at the Boettcher Quarry me\y prove difficult both because the formations exposed in the quarry dip quickly to great depth east of the site and because ground water movement is likely to be predominantly fracture controlled. T,~e statement is made in the SEC report referenced above that "(g)round water monitoring of a landfill at this site would be difficult. Any monitoring holes may or may not produce water depending on whether formation joints are intersected" 3. Holnam will be required to address run on and runoff controls related to disposal of CKD in the quarry. This does not appear to be a technically difficult issue given the location of the quarry near the top of the watershed. 4. As discussed at the top of this memo, Holnam will be required to include the cement plant into the site reclamation permit in order for the Division of Minerals and Geology to regulate the disposal of CKD in the quarry. From a regulatory standpoint the cement plant must be included in the reclamation permit because with the cement plant located outside the limits of the reclamation permit boundary, the manufacturing of cement would be considered an "off-site operation(s) not conducted on affected land" (Rule 1.1(27)) and the CKD from the plant would be an "imported waste" (MOU with Hazardous Materials and Waste Management Division, copy attached). The Division of Mineras and Geology routinely permits and regulates the disposal of mining or processing waste generated within the reclamation permit area, but does not generally regulate the disposal of imported vvaste. From a technical standpoint, the cement plant must be included in the reclamation permit e.rea in order to provide regulatory source controls over the generation of the CKD, e.g., the types of fuel or chemicals used in the kilning process, and to provide regulatory controls over the handling, temporary storage, and transportation of CKD prior to final disposal. One result of the inclusion of the cement plant into the reclamation permit area will be she necessity of providing a reclamation plan and financial warranty for the plant buildings, structures and grounds. This will likely necessitate a commRment to and bonding for the demolition of the buildings and structures unless the exemptions listed in Rule 3.1.11 are applicable. In addition, run on and runoff controls for the plant site and surrounding disturbed areas may have to be incorporated into the reclamation permit. Attachments c:\windows\personaNwlnam.doc