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L • <br /> <br />Memo to File M-77-342 ~ November 19. 1998 <br />sludge disposal when Che waste is generated and disposed on property under contiguous sinsle ownership. <br />In order to fill [he apparent regulatory gap that is created in [his case by the differences in the way the <br />term imported waste is defined by Che DMG and the HMWMD, the DMG will become the lead permitting <br />agency for the disposal of [he sludge at the Henderson Mine in [he event that a technical revision for <br />sludge disposal at Henderson is submitted. This is a logical solution because the DIv1G is charged with <br />the regulatory authority to issue permits assuring reclamation to a beneficial post mining land-use and <br />protection of the environment from the potential adverse impacts resulting from the disposal of mining <br />related wastes. Typically, these minins related wastes are generated within the permit area either through <br />mining, extractive metallurgical processing, or water treatment. The generation of water treatment sludge <br />outside the permit area of the Henderson Mine is a result of a singular circumstance where apre-law mine <br />with an ongoing water treatment requirement is located in close proximity to an operating mine under the <br />same ownership. The advantages to the construction of a consolidated water treatment plant for the two <br />mines are documented in the withdrawn amendment application AM-02 to the Henderson Mine permit. <br />The rationale for the consolidated water treatment plant to be located outside the Henderson Mine permit <br />boundary is also documented in that same withdrawn amendment application. The unique circumstances <br />relating to the consolidated water treatment plant should not preclude the Operator from using areas <br />within the Henderson Mine permit boundary for sludge disposal, and the best mechanism for regulation <br />of [he sludge disposal is through the Environmental Protection Plan administered by the DMG. <br />In order to gain DMG approval for disposal of the sludge, the Operator would be required to characterize <br />the sludge and demonstrate that the Environmental Protection Facility, Pond 1.2, proposed as a repository <br />provides adequate protection to the environment. If the nature of the sludge changes, either due to <br />changes in [he character of the water being treated, or changes on the processes used to treat the water, the <br />Operator would be required to notify the DMG and repeat the sludge characterization and environmental <br />protection demonstration. <br />It should be noted that during the review of pending technical revision TI2-04 to the Henderson Mine <br />reclamation permit, the DMG raised specific flood management concerns related to the operation of Pond <br />1.2 as an Environmental Protection Facility. The Operator responded to those concerns by stating that <br />Pond 1.2 was scheduled for decommissioning upon completion of the consolidated water treatment plant, <br />and that addressing flood management concerns for a facility that is scheduled for imminent closure <br />would be counterproductive. If Pond 1.2 is to be recommissioned as a sludge disposal facility, [he related <br />flood management concerns must again become an issue. In addition, a cover design and surface <br />reclamation plan for the proposed sludge repository must be approved through the technical revision <br />process. -. <br />Attachment(s) <br />cc: Carl Mount, DMG (w/attachment) <br />Bruce Humphries, DMG (w/attachment) <br />Mike Long, DMG (w/attachment) <br />Glen Mallory, Hazardous Materials and Waste Management Division (rv/attachm~~ntJ <br />c:\..Viendslud.wpd <br /> <br />