GENERAL34276

• Permit No: C1981016
• IBM Index Class Name: General Documents
• Doc Date: 10/12/1995
• Doc Name: HAWKS NEST MINE C-81-016 TOXIC WASTE REMOVAL
• From: DMG
• To: LARRY ROUTTEN
• Permit Index Doc Type: RECLAMATION PROJECTS
• Media Type: D
• Archive: No

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STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Deparlmenl of Natural Resources
1713 Sherman 51., Room ?1 5

Denver, Colorado 80203 li~~

Phone [phone] I
FAX. [phone]
DEPARTMENT OF
NATURAL
RESOURCES
DATE: October 12, 1995 co~.e ~o,e,
lames 5. Lochhead

TO:
Larry Routten Eseculrve DueUUr
,.,~ehaei s Long

FROM: G
Erica Crosby (~~ Dmision Direaur
RE: Hawk's Nest Mine (C-81-016)
Toxic Waste Removal
On October 6, 1995, Walsh Environmental contacted the Division to inform us that the
Hawk's Nest barrels contain a high level of PCBs. Lab results show that the PCBs range
from 355ppm to 661ppm. This high level of PCBs classifies the material as toxic waste,
which is regulated by the Toxic Substance Control Act (TSCA) and administered by the
EPA.
When Walsh Environmental submitted their proposal, they were under the assumption that
there would be no PCBs and prepared their proposal assuming the material was "hazardous"
as defined by Resource Conservation and Recovery Act (RCRA) regulations. The discovery
of PCBs require that the material be disposed at aTSCA-approved facility rather than a
RCRA hazardous waste facility. Walsh has received a price quote for disposal and transport
of the drums of oil from USPCI Laidlaw (located in Utah). There are two options to
remove the material, dechlorinate and recycle or incinerate. Incinerating the material would
be a $2,400 additional total cost for the project. Chemical dechlorination and recycling of
the material would be an additional $1,100 additional total project cost. I believe that
incineration would be the best option to reduce the States liability of this material.
Walsh Environmental conducted a TCLP sample on the soil located under the drums of
material. The soil contained a low level of PCBs (.35ppm) and no TCLP volatiles were
detected. The soil is therefore not classified as hazardous or toxic waste. Some high levels
of Cadmium and Lead were detected in the sample (Cadmium .052 mg/L and Lead .210
mg/L).
As you are aware, a natural occurring spring flows through the area where the barrels are
stored and eventually discharges into the North Fork of the Gunnison River. After
consultation with Harry Posey and Barbara Pavlik, I compared the possible water quality
standards of the spring (with the high level of Cadmium and Lead assuming worst case) to