132;; avian/1 LEEAU) 28 20W OFFICE COPY sure OK OKLAHOMA 1.0.0 I DEPARTMENT or MINES I: ICE 2915 N. ClasSen Blvd., Suite 213 405/427-3359 Oklahoma amen 73106 REVISION APPLICATION FOR MINING, WNG, RECLAMATION, HANS DATE mean: 0 a ANDPERMITINFORMATION nmm: .E.- 951 more NHGWAL- Date Application Submitted: June 6, 2016 Company Name: MMHF, LLC Permit Number: LE-1857 Mine Name: Reclamation Pit '2 Company Address: P. 0. Box 568 City, State, Zip Bokoshe, OK 74930 Legal Description of Permit: (Section, Tm, Range County) Sections 16, 17, 20, and 21, T8N, R24E, LeFlore Co., Oklahoma Current Permit Acres: 333.0 Permit Acres After Revision Approval: 333.0 Revision Area Involves (a new acres) 0.0 Revision Area Involves (ll old acres) 200.0 Revision Involves Legal Description: (Section, Tourmhip, Range I County) Sections 16 and 17, T8N, R24E, LeFIore Co., Oklahoma EXHIBITS MAY BE ATTACHED WITH PROPER IDENTIFICATION: Please refer to the enclosed plan maps MP4 and NIP-10 DESCRIBE ll DETAIL THE REVISION REQUESTED: Please refer to the enclosed ash bene?cial reuse plan WHY IS THIS REVISION REQUESTED: Process the ash for bene?cial reuse Is revision due to a Notice of Violation (NOV): If Yes, Please provide NOV number Yes No NOV Number: Does this revision require pubic noti?cation? Yes No Are eddllonal required for this revision? lYeeatuchoopyoithe lease. Yes No Is there a bond change required? it Yes, Yes No Amountoflondrequlrediorchanee: TBD Number: TBD 51W SIGNATUREOPCOMPANYOFPICIAL: QR mumm 4? ?30 y?y 1" WW 1141,19 5 NotaryPueIc: Er ?delirium WMMUH RECEIVED RevApplFormMay201 JUN 282017 DEPT. OF MINES ?l Pa ONLY THE ASH PROCESSING ANALYSES OF THIS REVISION APPLICATION PACKAGE ARE TRADE SECRET, PROPRIETARY, AND CONFIDENTIAL INFORMA TI ON. ASH BENEFICIAL REUSE PLAN MMHF, LLC Permit No. LE-1857 Reclamation Pit No. 2 On behalf of MMHF, LLC (MMHF) and pursuant to our recent meetings, the following Permit Revision Application (minor) is submitted for your review. Upon approval, ash product in MMHF Reclamation Pit No. 2 would be beneficially processed into commercial products for sale. All components of the ash product reuse processing will be located within one or two buildings to be located east and adjacent to the existing reclamation pits, within the permitted area. The enclosed Process Flow Diagram, Map MP-10, illustrates the ash product beneficial reuse process and the product recovery equipment utilized, and should be included in the approved PAP. 1. Executive Summary Presently, incoming ash product is mixed with water to control fugitive dust and placed at the site to backfill the orphan coal mine pits left from a previous coal mining operation. The proposed ash product reuse processing operation may be operated by a designated operator, using a proprietary technology to extract saleable industrial MMHF PERMIT NO. LE-1857 products. The ash product would be processed to recover alumina, iron, coarse sand and agricultural lime (ag-lime). The products derived from processing the ash product will be non-hazardous, as shown in the laboratory analytical reports in Appendix of the approved Permit Application Package (PAP). Approximately 20% of the processed ash will be returned to reclamation pits after the products have been recovered. 2. Process Descrit?on Raw Material Handling The ash product bene?cial reuse process building will cover approximately 0.5 acre. At full production, a maximum of 250 tons per hour (tph) of ash product will be recovered from reclamation pits. Front-end loaders and haul trucks will be utilized to recover ash product and transport it to the process building. Additional ash product from the active reclamation pits will be used, after it has been treated with water. The production process does not use dry ash product as a feedstock. The location of the ash product processing facility is shown on the enclosed revised Map MP-4, the Mining/Reclamation Map. 3. Ash product Processing The proposed ash product reuse is a wet process. The process equipment will be inside the process building. Incoming ash product is initially crushed, screened, mixed with water, and conveyed to two (2) proprietary classifiers that will discharge to electromagnets to recover the iron product inside the process building. Material not recovered by the electromagnets will be conveyed to another classifier to dewater and PERMIT NO. LE-1857 . . ., recover the coarse sand product. Water used in the separation and conveyance of the iron and coarse sand products, and fine sand flow to Storage Cell Approximately 50 fine sand will be recovered from Storage Cell and transported to the disposal cells. At full capacity, approximately 50 iron and 100 coarse sand products could be produced. The enclosed Process Flow Diagram, Map illustrates the ash product beneficial reuse process and the product recovery equipment utilized, and should be included in the approved PAP. Storage Cells and will be the source of ag-Iime and process water, after the iron and coarse sand products have been separated. Ag-lime and water will be conveyed from Storage Cell to Storage Cell Approximately 50 tons per hour of ag-Iime will be recovered from Storage Cell #8 and transported to the ag-lime processing circuit. At the ag-lime processing circuit, the ag-lime will be dewatered in a filter press, if needed, followed by thermal drying. The dry ag-lime will then be pelletized into an agricultural product, suitable for uses such as a soil amendment. Ag-Iime, drying, and pelletizing will be conducted inside the process building. At full production, 50 tons per hour of ag- lime could be produced. Alumina will be the final product to be recovered. Storage Cell discharges to Storage Cell which discharges to Storage Cell Water from Storage Cell which have had iron, coarse sand, and ag-lime products recovered, are pumped to the alumina recovery circuit inside the process building. A proprietary process will separate industrial-grade alumina, also known as aluminum oxide (N203), at a rate of PERMIT NO. LIE-1857 3 approximately one (1) ton per hour. The overflow water from the alumina recovery circuit will be pumped back to the beginning of the process to convey incoming ash. After recovery of the commercial products, approximately 20% of the total original raw ash product will be returned to reclamation pits. Recovery of calcium oxide from the ash will still leave residual magnesium, sodium and potassium oxides acting as an alkaline pH buffer. The post-product extraction laboratory analysis of the residual ash-sand mixture has a pH of 9.06 S. U. This will provide adequate buffering capacity. A new sieve analysis of post-product extraction ash shows the residual material will be 81.63% fine to medium sand by weight. The remaining 18.37% of residual ash by weight will be very ?ne sand to silt size fraction. By comparison, an incoming ash analysis is approximately 29% (Page 0-17, Appendix of the PAP) medium to coarse sand by weight, while the remainder is approximately 69% very ?ne sand to silt size fraction. MMHF PERMIT NO. LE-1857 The following major production equipment will be used to extract the iron, coarse sand, ag-lime, and alumina products from the ash: [farting/mg: Haul Trucks 740B 6x6 agricultural trucks Loaders Bobcats Service Trucks Dozers Lifts Water Trucks Product Recovery: Power Screen lmpactor Crusher/ lmpactor Ortner Magnetic Drums One or two Buildings Approximately 70? 200? each 4. Raw Material and Finished Products The chemistry of the raw ash product and recovered products is summarized below, based on actual laboratory analysis of the products from MMHF ash product feedstock. The enclosed laboratory reports of ash before product extraction, ash after product extraction, and iron, silica, ag-lime, and alumina product analyses should be included in Appendix of the approved PAP. 5. Ash Product Raw ash typically contains the following elements: calcium 55.2%, iron 18.9%, silicon sulfur aluminum titanium 1.4% and potassium Before and after product extraction, Toxicity Characteristic Leaching Procedure (TCLP) metal concentrations are far below their respective action levels. MMHF PERMIT NO. LE-1857 6. Iron The iron product will be a metallic iron powder. Barium content would be 0.085 mg/l, below its TCLP threshold of 100 mg/l. The other seven TCLP metals are below detection limits. 7. Coarse Sand The coarse sand product, also known as silica, will contain a trace level of barium at approximately 0.1 mg/l, well below its TCLP threshold of 100 mg/l. The other seven TCLP metals are below detection limits. 8. Ag-Lime The only TCLP metal in the ag-lime would be barium, at 0.20 mg/l versus its TCLP threshold of 100 mg/l. The ag?lime product has been registered with the Oklahoma Department of Agriculture Food and Forestry (ODA). ODA product registration requires proof of product safety and effectiveness, and must be renewed annually. 9. Alumina The alumina product will contain approximately 87% aluminum oxide (Ale3). Other constituents of the alumina product are: siliCa calcium magnesium 1.2% and iron TCLP metals will be below their respective detection limits, except for barium, which would be 0.03 mg/l, well below its TCLP threshold of 100 mg/l. Because the alumina product is an oxide and will be wet, it is not expected to be a potential ?re hazard that would be regulated by the Oklahoma State Fire Marshall. PERMIT NO. LIE-1857 ix 10. Superfund Amendments and Reauthorization Act (SARA) None of the compounds in the ?nished products to be stored on-site are listed under SARA Title II (Emergency Planning and Community Right-to-Know (EPCRA). Therefore. no annual reports will be submitted to DEQ, local ?re departments, or the Local Emergency Planning Committee (LEPC). Because the raw ash product will be converted into commercial products, there will be no ?release to land? as de?ned SARA Title because the ?nished products will be eligible for the ?article exemption? under SARA. Similarly, none of the compounds in the raw ash product are listed under SARA, therefore, no Form will have to submitted to DEQ and the EPA. 11. Water Resources At full production, the production process would use 700 gallons per minute (GPM). Process water will be pumped from Storage Cells B, and C. Water used in the production process is a closed-loop, in which in-process water used to convey raw ash, intermediate product streams, and final finished products will be returned to Storage Cells B, and C. Additional make-up water will be obtained from the reclamation pits, due to Storage Cell evaporation and water entrained in the products after dewatering. The proprietary process recycles process water. Therefore, there will be no process wastewater discharge. MMHF PERMIT NO. LE-1857 12. Air Emissions MMHF Reclamation Pit No. 2 holds DEQ Area Source General Permit Authorization 2013-1222-0. The General Permit requires implementation of effective I fugitive particulate emission controls during all phases of ash product transport and handling. The permit also covers emissions from stationary internal combustion engines. Fugitive particulate emissions from hauling ash product from reclamation pits to the processing plant would be covered under existing permit. The ash product recovery building will be covered under a separate air permit, if required. During ag-Iime product processing, a baghouse will control ag-Iime drier dust. An Applicability Determination (AD) will be submitted to the DEQ Air Quality Division N) (AQD) for the ash product recovery operation as a stand-alone emissions source. The AD will determine the type of permit, if any, will be required by the AQD. We believe the process will be permit exempt for the following reasons: 1) The ash product is not a non-metallic mineral regulated under New Source Performance Standard (NSPS) Subpart 000, 2) No stationary internal combustion engines will be installed, and 3) Expected ash product processing emissions will be below the Minor Source Construction Permit threshold of 5 tons per year of any one regulated pollutant. 13. Hazardous Materials and Wastes No hazardous wastes will be generated. The incoming ash product will be separated into commercial products. After product recovery, 20% of the original processed ash '1 MMHF PERMIT NO. LE-18S7 8 l' product will be returned to the reclamation pits. Minor constituents of the finished products will be non-hazardous, as defined under the Toxicity Characteristic Leaching Procedure (TCLP). TCLP analysis of raw ash product and ?nished products demonstrates lack of hazardous constituents. 14. Final Contours/Pit Reclamation There will be no change to the final contours or the reclamation plan as currently approved in the reclamation plan for Permit No. The ash product processing building will be left permanently for the landowner?s use. 15. ODM Permit LE-1857 The applicant requests the approval of the following changes under this revision to Permit No. LE-1857: Installation of the ash product beneficial reuse processing building within the 1) permitted area. 2) Handling and Processing of the existing ash product fill from the reclamation pits. Residual ash will contain approximately 81% sand after product extraction, which will be used to fill Reclamation Pit No. 2. The residual ash in the pit will have the same solidified, cementitious properties as the original ash fill. PERMIT NO. LE-1857 3) Addition of 20.5 acres to and removal of 20.5 acres from the permitted area for ash product processing (refer to the enclosed location map). The 20.5 acres to be added were included in the original MMHF permitted area. Upon the completion of the revision review process, but before the approval of this revision, all permit maps will be revised to add the 20.5-acres to the permitted area. 4) Adjustment of reclamation bond to re?ect removal of the ash product processing equipment. 16. Bond Calculation Upon the completion of the revision review process, but before the approval of this revision, an updated bond calculations will be submitted to the Department. 17. Other Permits The processing plant may be operated by a designated operator under MMHF. The existing MMHF air permit may have to be modi?ed, and an air permit Applicability Determination for the new processing operation will be obtained from DEQ. 10 PERMIT NO. LE-18S7 OUTSIDE 250 TPH A I ENCLOSED BUILDING 700 GPM Water 500 GPM Water 200 GPM Water 200 GPM Water ALUMINA or RECOVERY 35? GPM Water 0 350 GPM 1 TPH 250 TPH Water I 350 GPM s1 50 TPH Water 250 TPH 350 GPM Water 350 GPM Water 50 TPH 75 TPHC 175 GPM Water 75 TPH 100 TPH 350 GPM Water 175 GPM Water 0 CL 50 TPH (Fine Sand) to Disposal Cells 50TPH 175 GPM Water 11 50 TPH 50 TPH 175 GPM Water (Au-Ume) Backhoe a Backhoe or AG-LIME or Auger Auger STORAGE CELL STORAGE CELL (Ag-lee) (Water) 700 GPM 700 GPM Water Water 100 TPH TPH STORAGE CELL (Ag-Ume Flne Sand) 100 TPH 50 TPH 700 GPM Water 700 GPM I Water I PUMP 50 TPH (Ag-lee) 700 GPM 843E IRON COARSE 1- ma? 700 GPM Water Water COMPONENTS COMPONENTS INSIDE ENCLOSED INSIDE ENCLOSED BUILDING BUILDING COMPONENTS OUTSIDE ENCLOSED BUILDING LEGEND Feeder DP Dewatedng Press OR Crusher DR Dryer/ Baghouse Screen P2 Pelle?zer CL Classi?er TPH Tons per Hour to GPM Gallons per MInu Pile WM on?: rel non wo. OIA PROCESS FLOW I ANO 15? I . . Storage Cell Storage Cell NON COAL LOCATION The Land Reclamation Act. 45 0.5. 1981 9721?723 MAP REFURN Period Of: to partment of Mine: immediately tion is approved. show here, notify the De ng at the location you and/or completed reclama operoti Department is noti?ed reason whatever. you stop I the If. for any . bilIty contInues in effect unti as your lio comm: MMHF. MINERAL TO BE MINED: SHALE AND CLAY ACRES THIS SECTION TO BE COVERED BY PERMIT 6c BOND: 333.0 TOTAL ACRES TO BE COVERED BY PERMIT: 333.0 SECTIONRANGE: 24E COUNTY: LEFLORE AREA AREA DELETED FROM THE: PERMIT FROM THE PERMIT L. PERM BOUN DELETED FROM THE PERMIT 3f 7 Center of L