Question # 667

667. A facility is re-mining waste rock which was disposed to land in a prior reporting year. In re-mining the waste rock, a portion of the waste rock previously disposed is taken from the landfill and moved to another location at the facility to allow access to other waste rock that has a metal content sufficient for further beneficiation. Is the waste rock that is taken from the landfill and disposed considered a release to land: Part II section 5.5.4 Other Disposal, despite the fact it was originally reported as release to land for disposal in a prior reporting year?
Yes. Toxic chemicals that have been released in one reporting year, must also be reported in subsequent years when the material undergoes non-exempt activities, provided certain thresholds have been exceeded. The facility is required to report the listed toxic chemical in the waste rock as a release to land because the toxic chemicals have been displaced and subsequently 'released' or disposed in a following reporting year.