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" ~ ~ RATIONALE THIRD RENEWAL CDPS GENERAL PERMlT FOR COAL MINING FACILITIES (SURFACE RUNOFF ONLY) CDPS NO. COG-850000 a~to this general permir upon the third renewal are relatively minor in nature. The discharge language from past revisions did nor consider discharges ro land. In this renewal, land application language is included. AntideEradation--The Division reviewed this renewalpermitjorcompliancewithantidegradationregularions. No limitations havechangerl, thus there is no increase in loading from those facilities with continuing coverage under the general permit, and any new source, or discharger covered under this permit would not be expected to approach the remaining assimilative capacity. Additionally, discharges authorized under this permir are not expected to occur during low flow conditions, they typically occur when stream flows are high due ro storm events. !t is the Division's determination that antidegradation does not apply to this permit. Western Alkaline Mining & Coal Remining operations are excluded tom coverage under this general permit. These two new subcategories were recently published in the Federal Register on Jonuary 13,1001. Due to the special requirements that both operations require, it would be more appropriate to be covered under an individual permit. The subcategaryfor Coal Remining applies ropte-existing discharges that are located within, or that are hydrologically connected to, pollution abatement areas ofa coal remining operation. The Western Alkaline Coal Mining subcategory establishes effluent limitations and performance standards for alkaline mine drainage from reclamation areas, brushing and grubbing areas, topsoil stockpiling areas, and regraded areas at western coal mining operations. Western coal mining is defined as a surface or underground coal mining operation located in the ]Od" meridian west longitude, in an grid or semi-arid environment with.an average annual precipitation oj16.0 inches or less. Ijin the future, the Division deems it necessary to odd provisions to cover these twn subcategories, this genera/permit will be reopened ro add conditions and monitoring requirements that address the new subcategories. ee previous permit rationale for changes that occurred since the original general permir was conceived. Christopher L. Gates February 19,1001 'OMMENTS MADE D URING PUBLIC NOTICE %te~ronmental Protection Agency made the following comments, with the Division's response, if arty, in bold. 7te r ionale needs to explain how new discharges and/or new sources will be covered under the permir and how the addition of those new ources/discharges will satisfy the State's Antidegradation Policy. Ifnew sources are to be covered, the effluent limits table must contain New source Performance Standards (NSPS) limiu for total Iron. ''he Division included additional language in the rationale to address new or increased discharges, stating that there is no increased load jrorn xisting discharges and any new source or discharger would not be expected to approach the remaining assimilative capacity. The new or ncreased discharges will have fo comply with fhe NSPS limit for iron. ~edera7 eflluenr guidelines for total manganese limits have been omitted from the renewal permit. Please review 40 CFR Part 434 Coal Mining and insert manganese limits where applicable. °ederal effluent guidelines jar total manganese limits have been added to cover acid or ferruginous mine drainage and coal plant preparatiow activities that would normally be covered under this general permit. ,asrly, the storm related discharge limitations and requirements varyfiom the storm discharge requirements found under 40 CFR §434.63. Please ~eview the requirements under 40 CFR Part 434 and revise appropriately. "hanges were made to be consistent with 40 CFR § 434.63 for storm related activities. wring the comment review, it was made known by the EPA that two new subcategories were recently published in the Federal Register on January 13, 1001. These two subcategories are for coo/ remining operations and western alkaline mining. These subcategories shall be nentioned here, but will 6e excluded from coverage from this general permit due to the special requirements that would be better covered ruder an individual permit. The subcategory for Coal Remining applies to pre-existing discharges that are located within, or Jhat are rydrologically connected to, pollution abatement areas aja coo! remining operation. The Western Alkaline Coa! Mining subcategory establishes effluent limitations and performance standards for alkaline mine drainage from reclamation areas, brushing and grubbing areas, o tackpiling areas, and regraded areas at western coo! mining operations. Western coal mining is defined as a surface or underground ~o ingoperarion/ocatedinthe70d"meridian west/ongitude,in an grid orsemi-arid environmentwithanaverageannua/precipitation j26.0 inches or less Ijin fhe future, the Division deems it necessary to add provisions to cover these two subcategories, this general permit vill be reopened to add conditions and monitoring requirements that address fhe new subcategories. Christopher L. Gates June S, 2001