DSHW-2024-008370

September 20, 2024
Mick Thomas, Director
Utah Division of Oil, Gas and Mining
1594 W North Temple Street
Salt Lake City, UT 84116
RE:Hardscrabble Coal Refuse Reclamation Project – Carbon County Landfill Exemption RequestApproval Letter
Dear Mr. Thomas:
On September 5, 2024 the Division of Waste Management and Radiation Control (Division) received the Carbon County Landfill Exemption Request(request) (DSHW-2024-008150) for disposal
of coal refuse at the Carbon County Class IVb Landfill. The request is in association with the Hardscrabble Coal Refuse Reclamation Project (project), located in Hardscrabble Canyon,
west of Helper, Carbon County, Utah. The project (AMR/007/955) is in conjunction with the Carbon County, Utah Commission Department and the Abandoned Mine Reclamation Program (AMRP),
whose purpose is to clean up abandoned mines throughout the State of Utah and reclaim the areas associated with abandoned mine operations.
Project Objective Summary
The objective of the project is to reclaim the abandoned mine areas andpromote surface stability by the re-establishment of drainage channels and roadways that have been washed out,
in large part, by high intensity storm events immediately following the Bear Canyon Fire in June 2021.
Project Methodology Summary
Two onsite project areas will be cleaned up that may consist of both high and low quality coal refuse. High quality coal refuse will be hauled to Sunnyside Cogeneration Associates facility
for energy production purposes. Low quality coal refuse will be disposed of by burial, as much as possible, within onsite cell containment, covered with subsoil/topsoil, and reseeded.
Excess low quality coal refuse that is unable be buried in a stabile way, due to local topographical relief challenges, is proposed to be hauled to and stockpiled at the Carbon County
landfill for use as alternative daily cover. The total estimated quantity of excess low quality coal refuse material to be disposed of at the Carbon County landfill is 3,863 yards.
Project Oversight
Project oversight will be done by overseen by the Department of Interior Office of Surface Mining and Reclamation Enforcement (OSMRE) and Utah Division of Oil, Gas and Mining (UDOGM).
This reclamation technique has beenutilized by the AMR with oversight from OSMRE for over 40 years.
Division Review
The Division has completed its review of the request associated with the proposed project. Items contained in the request and reviewed by the Division include:
Project background and purpose;
Reclamation techniques;
Nature and composition of coal refuse material;
Carbon County landfill and surrounding area geological composition;
Potential threat to human health or environment;
Potential impact of the coal refuse material on groundwater and surface water quality;
Contingency plan for potentially hazardous waste material encountered during cleanup activities;
Extracted coal exemption to hazardous waste regulation per Utah Administrative Code (UAC) R315-261-4(b)(7) and UAC R315-266-112;
Federal and State oversight and use of qualified engineers;
Project location with maps, photos, and design drawings;
Project support letter from Carbon County Commissioner and landfill;
QAQC letter from project Engineer;
Material acceptance letter from Sunnyside Cogeneration Associates; and
Drill logs available for nearest known well locations to the landfill (no groundwater for 400+ feet).
The request contained all requested information and documentation. The Division appreciates thedetails included for project cleanup methodologies, material classification, disposal locations,
potential impacts to human health or environment, and project support from collaborating regulatory and professional entities.
Based on review of the request, the Division accepts the Engineer’s statement and signed certification.Therefore, the project request for disposal of excess coal refuse at the Carbon
County Class IVb Landfill (Permit #9411R2) is approved to accept the waste and use it as alternative daily cover waste in accordance with UAC R315-303-4(4) all other applicable solid
waste rules contained in UAC R315-301 through 320.
If you have any questions, please contact Bryan Watt at 435-503-7658.
Sincerely,
Douglas J. Hansen,Director
Division of Waste Management and Radiation Control
DJH/BS/BW/??
c:Brady C. Bradford, MSPH, REHS, Health Officer, Southeast Utah Health Department
Orion Rogers, Deputy Health Officer, Southeast Utah Health Department
Brandon Pierce, Environmental Health Scientist, Southeast Utah Health Department
Curtis Page, P.E., District Engineer, UDEQ
Steve Christensen, Project Manager, Utah Department of Oil, Gas and Mining ([e-mail])