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Andy Sc•lr~:•:•lur • . <br />' November 14, 1980 <br />REQUIREPIENT <br />Application State Federal State Federal <br />Comment <br />4.1 ?.05.2 784.11 - + OSM's concerns appear to be adequately addressed <br />in Section 4.1, Volume O of the February 1980 <br />submission. <br />Please note the extremo organizational differ- <br />ences between the State and Federal regulations. <br />Attached, find a list prepared for cross- <br />reference from a State requirement to the <br />applicable Federal requirement. <br />4.2 2.05.4 784.13 + + OSM's concerns api~ear to be adequately addr^ssed <br />' in Section 42, volume O, February 1980. <br />See letter of June 1980 attached to this summary <br />for Division concerns. <br />4.3 1.05.6 784.19 + + OSM's concerns are unclear therefore nit <br />(3)' ~ addressed here. <br />Regarding the Division's concerns, numerous <br />exchanges of memos, .information, etc., plus <br />changes in responsibility for Empire as well as <br />the Division, contribute to a confusing <br />situation for detailed evaluation. <br />Sediment Control Plan <br />The original sediment control plan was found in <br />compliance of the final Regulations. <br />However, subsequent revisions have clouded this <br />issue. See the attached memo dated August <br />21, 1980. There does not appear to be a <br />response from Empire in our file. Perhaps <br />this issue can be cleared up in the final <br />permit application. . <br />Also note that the pertormance standard <br />requirements for the design of sedimentation <br />ponds has also changed as a result of <br />litigation. Upon review of 4.05.G, Empire <br />may wanC to revise sonr_ information in the <br />application.. <br />1lydroloyic Monitoring <br />Attached are memo's dated July 10, 1980 and <br />February 22, 1980 which summarizes the <br />Division's concerns regarding this requirement. <br />1~, <br />