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Mr. Mike Boulay -2- August 26, 2009 <br />drainage swale or other sources as a result of the revised reclamation plan and address <br />the potential for impacting the water quality of the wetland areas. <br />SCC: A discussion of any discharges to the wetlands from the proposed <br />drainage swale and other sources was added to amended pages 14-9i and 14-9ii. <br />3. DRMS: SCC did not provide a demonstration as required by Rule 4.05.2(2) for <br />sediment pond removal. The Division may authorize removal of a sediment pond if the <br />disturbed area has been stabilized, the untreated drainage from the disturbed area <br />ceases to contribute additional suspended solids above natural conditions, and the <br />quality of untreated drainage from the disturbed area meets the State and Federal water <br />quality standard requirements applicable after the sedimentation ponds and treatment <br />facilities are removed, if any, for receiving streams. Generally a sedimentology <br />demonstration is provided to meet these requirements. In this case, based on our <br />discussions with SCC and Jim Stover of J. E. Stover & Associates, a sedimentology <br />demonstration may not be relevant because of the active post-mining industrial use of <br />the site and the fact that these ponds (UTL #1 and #2) have never discharged in the past <br />and accumulate only a small amount of water in the spring time at UTL #2. The water <br />that collects west of UTL #2 is essentially the same water that makes up the larger <br />wetland area shown on Exhibit 11 C. Please provide and appropriate demonstration for <br />the removal of ponds UTL #1 and UTL #2 or otherwise provide amended permit text that <br />addresses the suspended solids and water quality requirements of 4.05.2(2). If <br />appropriate, the amended text should explain that a sedimentology demonstration is not <br />necessary. <br />SCC: Enclosed permit page 14-9i has been revised to explain why a <br />sedimentology demonstration is not necessary. <br />4. DRMS: SCC is proposing to leave the 30 inch CMP drainage pipes (spillways <br />from UTL #1 and UTL #2) in place. Typically the Division requires that culverts or pipes <br />that are not permitted as a permanent post-mine feature be removed from the reclaimed <br />area. Each pipe is approximately 100 feet long and their removal from beneath the <br />railroad embankment and track would cause a significant disruption to the railroad. <br />Therefore, SCC proposed to leave them in place and cap the inlets and backfill the <br />intake sides. There is no discussion in the permit text on why the pipes need to be left in <br />place and there is very little detail on how the pipes will be sealed off if left in place. On <br />page 15-2, SCC states that the sediment pond spillway will be capped as shown in <br />Figure 14-16. From Figure 14-16 it is unclear if the inlet or discharge end of the pipe will <br />be capped and there is no mention of removing the risers and backfilling the intake <br />sides. Please describe in the revised permit text the reason(s) for leaving the pipe in <br />place. If approved to be left in place, the Division will require that both ends of the pipe <br />be sealed. Please add more detail to the reclamation plan for sealing the pipes and <br />update Figure 14-16 showing the plan for sealing both the intake and discharge ends of <br />the pipe(s). <br />SCC: Enclosed are revised permit page 14-9i and new permit page 14-9ii. Text <br />has been added to these pages to explain the reclamation of the spillways and the <br />reason to leave the pipes in place. Also enclosed is revised Figure 14-16.