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' RATIONALE <br />Tli/RD RENEWAL <br />CDPS GENERAL PERMIT <br />FOR COAL MINING FACILIT/ES (SURFACE RUNOFF ONLY) <br />CDPS NO. COG-850000 <br />~llanges to this general permit upon the third renewal are relatively minor in nature. <br />/. The discharge languagefrom past revisions did not consider discharges to land /n this renewal, /and application language is included <br />1. Antidegradation--The Division reviewed this renewal permitfor compliance with antidegradation regulations. No limitations have changer!. <br />thus there is no increase in loading from those facilities with continuing coverage under the general permit, and any new source, or <br />discharger covered under this permit would not be expected to approach the remaining assimilative capacity. Additionally, discharges <br />authorized under this permit are not expected to occur during lowJlow conditions, they typically occur when stream flows are high due to <br />storm events. It is the Division's determination that antidegradation does not apply to this permit. <br />3. WesrernA/kalineMining&CoalReminingoperationsareexcluded omcoverageunderthisgenera!permit These two newsubcategories <br />were recently published in the Federal Register on January 13,1001. Due to the special requirements that both operations require, it would <br />be more appropriate to be covered under an individual permit. ThesubcategoryjorCool Remining applies to pre-existingdischarges that are <br />located within, or that are hydrologically connected to, pollution abatement areas ofa coal remining operation. The Western Alkaline Coal <br />Mining subcategory establishes effluent limitations and performance standards for alkaline mine drainage from reclamation areas, brushing <br />and grubbing areas, topsoil stockpiling areas, and regraded areas at western coal mining operations. Western coal mining is defined as a <br />surface or underground coal mining operation located in the IOd" meridian west longitude, in an grid orsemi-arid environment with an <br />average annual precipitation oj26.0 inches or less. If in the future, the Division deems it necessary to add provisions to cover these two <br />subcategories, this general permit wi116e reopened to add conditions and monitoring requirements that address the new subcategories. <br />See previous permit rationale for changes that occurred since the origirsal general permit was conceived. <br />Christopher L. Gates <br />February 19,1001 <br />COMMENTS MADE D URING PUBLIC NOTICE <br />~Errvironmenta! Protection Agency made the following comments, with the Division's response, if arty, in bold. <br />The rationale needs to explain how new drscharges and/or new sources will be covered under the permit and how the addition of those new <br />sources/discharges will satisfy the State's Antidegradation Policy. Ifnew sources are to be covered, the effluent limits table must contain New <br />Source Performance Standards (NSPS) limits for total Iron. <br />The Division included additional language in the rationale to address new or increased discharges, stating that there is no increased load from <br />existing discharges and any new source or discharger would not be expected to approach the remaining assimilative capacity. The new or <br />increased discharges will have to comply with the NSPS limit for iron. <br />Federal effluent guidelinesfor total manganese limits have been omitted from the renewal permit. Please review 40 CFR Part 434 Coal Mining <br />and insert manganese limits where applicable. <br />Federal effluent guidelines for total manganese limits have been added to cover acid orferruginous mine drainage and coal plantpreparation <br />activities that would normally be covered under this general permit <br />Lastly, the storm related discharge Itmitations and requirements varyfrom the storm discharge requirements found under 40 CFR §434.63. Please <br />review the requirements under 40 CFR Part 434 and revise appropriately. <br />Changes were made to be consistent with 40 CFR § 434.63 for storm related activities. <br />During the comment review, it was made known by the EPA that two new subcategories were recently published in the Federal Register on <br />January 23, 2002. These two subcategories are for coal remining operations and western alkaline mining. These subcategories shall be <br />mentioned here, but will be excluded from coverage from this general permit due to the special requirements that would be better covered <br />under an individual permit The subcategory for Coal Remining applies to pre-existing discharges that are located within, ar that are <br />hydrologically connected to, pollution abatement areas oja coal remining operation. The Western Alkaline Coal Mining subcategory <br />bushes effluent limitations and performance standardsjor alkaline mine drainagejrom reclamation areas, brushing and grubbing areas, <br />tlstockpilingareas,and regraded areas at western coal miningoperattons. Western coal mining is definedasasurfaceorunderground <br />mining operation located in the lOd"meridian west longitude, in an grid orsemi-arid environment with an average annual precipitation <br />oj26.0 inches or less. Ijin the future, the Division deems it necessary to add provisions to cover these two subcategories, this general permit <br />will be reopened to add conditions and monitoring requirements that address the new subcategories. <br />Christopher L. Gates <br />June S, 1002 <br />