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<br />Memo to File M-1977-348 2 December 13, 2000 <br />It appears that the entire landfill area may not currently be included within reclamation permit M- <br />1977-348. Review of the permit f71e indicates that 10.7 acres of the landfill area were initially <br />included in the permit area, with an additional 6.5 acres subsequently added (total of 17.2 acres). <br />Discussion included in the permit file documents indicates that the landfill is substantially larger <br />than 17.2 acres and probably extends to the south of the reclamation permit boundary while <br />remaining within the Holnam property boundary. <br />2. If it is decided that Colorado Lien will obtain a reclamation permit for the landfill, ii is the <br />Division's position that the entire landfill area must be included. Also, the reclamation plan for the <br />sludge deposit must describe the physical properties of the sludge and describe how the sludge will <br />be capped without causing deleterious settlement or displacement of the sludge. Th.: Division notes <br />that Sam Lien stated during the telephone discussions in early November 2000 that lien Company's <br />direct experience with silica sludge is that settlement and displacement are not a problem during <br />capping operations. However, a more rigorous demonstration will be required prior to issuance of a <br />reclamation permit. The Boettcher Quarry reclamation plan states that the silica sludge will be <br />capped using material from the adjacent and nearby overburden piles. Sufficient stockpiled <br />overburden for sludge capping should be included within the property [o be purchased by Colorado <br />Lien and should be included in the new reclamation permit boundaries. This will avert the necessity <br />of bonding for the importation of capping material, which would drastically increase the bond <br />amount on a new permit to be issued to Colorado Lien. <br />In summary, the Division of Minerals and Geology does no[, under the current regulations, require any <br />additional permitting relative to a transfer of ownership of land within a reclamation permit boundary. <br />A transfer of reclamation responsibility under a permit issued by the Mined Land Reclamation Board <br />does require a permitting action or actions. <br />cc: Mike Toelle, HOLNAM, htc. (via facsimile transmission <br />Sam Lien, Colorado Lien Company (via facsitni[e transmission) <br />c:\windows\personalltilica sludge.doc <br />