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f` • STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources I J1 7 Sherman $1., Room 215 Dcnver, Colorado 80207 Phone 1]031866-356i FA%~ (3071 83_'-8106 DATE: November 19, 1993 iii iiiiiiiiiiiuiii I~~ DEPARTMENT' OF NATURAL RESOURCES TO: Anne Beierle, Henderson Mine; Jeff Todd, Schafer and Associates Roy Romer Governor FROM: Allen Sorenson ~ ~ Tames S. Lochhead / E.ecutive Director Michael B Long RE: Disposal of Urad Treatment Plant Sludge at the Henderson Mine, Climax Division Direcror Molybdenum Company -Operator, Permit No. NI-77-342 The Division of Minerals and Geology (DMG) was recently notified that Climax Molybdenum Company (CMC) intends to submit a technical revision requesting approval to dispose of sludge from the consolidated water treatment plant located at the Urad Mine into Pond 1.2 located at the .Henderson Mine. Pond 1.2 is a lined 30 acre-foot capacity pond that was used in the water treatment proce:>s at Henderson prior to construction of the consolidated treatment plant at Urad. The DMG routinely pel~rtits water treatment sludge disposal at mine sites through [he approval of "Environmental Protection Plans" (defined in Rule 7.7(76) of the Hard Rock/Metal Mining Rules and Regulations of the Mined Land Reclamation Board) for sludge generated by water treatment facilities that operate solely for a specific permitted mine. Sludge disposal in an "Environmental Protection Facility" (Rule I. I (l5;) is required under the regulations due to the potential for productior, of "Acid Mine Drainage" (Rule 1.1(2)). A complicating factor exists with the permitting of sludge disposal a[ the Henderson Mine t~ecause the water treatment plant where the sludge is precipitated is outside the mine permit area. In 1996, the DMG determined that the consolidated water treatment plant in the Urad valley constituted an off-site operation not conducted on affected land which did not need to be regulated a:> part of the Henderson Mine reclamation permit. This was partly because the consolidated water [re:ument plant treats water from both the Henderson and Urad mines. The Urad Mine was closed prior to adoption of the Colorado Mined Land Reclamation Act and DMG has never regulated or issued a permit for the URAD Mine. Therefore, the DMG considered the consolidated water treatment plant to be a facility that treated a component of water from a source outside DMGjurisdiction and not properly included in the Henderson Mine permit area. In 1992, the DMG and the Hazardous Materials and Waste Management Division (HMWTvID) entered into a Memorandum of Understandine (MOU) relating to solid waste disposal at mine sites (copy attached). The Iv10U states that any facility which imports waste from off-site must obtain a Certificate of Designation (CD). Since the water treatment sludge in question is generated outside ttte Henderson Mine permit area, and since the sludge is partly derived from treatment of Urad mine water (remembering that the Urad Mine is a pre-law site for which the DMG has never held a permit), the sludge would be considered by the DMG to be an imported waste for which a CD would be required. However, the MOU also states that persons who dispose of their own waste on their own property do not need a CD. The Urad and Henderson mines are on property under the common control of Cyprus-AMAX, which would qualify Urad sludge disposal at Henderson for the exclusion to the CD requirement. Essentially, [he DMG would call the sludge an imported waste (see item #I in the MOU; copy attached) ;rnd the HMWMD would not. It is unlikely that Clear Creek County would issue a CD for the w;,ter treatment