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(2) RGS will locate drill pads and roads to avoid or minimize, to the extent possible, <br />disturbance to areas with wetland vegetation. <br />(3) Off -road vehicle traffic and equipment use by RGS and contractor vehicles will be <br />prohibited except in emergency conditions. <br />(4) RGS will use, as appropriate, grade dips, culverts, straw bales, silt fencing, wattles, <br />diversion ditches, revegetation, sediment traps, berms and other erosion control <br />techniques. <br />(5) No road crossings of ephermal, intermittent and perennial drainages will be made under <br />the proposed action. <br />Refer to Figure 2, Portal Bench and Surface Admin Support Facility Site layout (Plan of Operations <br />Amendment - 2011) for the location of all planned structures and facilities. <br />Refer to Figure 1a, Stormwater BMP's at the Bulldog Project, for locations of planned BMP's. <br />The designs of the Evaporation Pond, Facility Holding Pond and the Waste Rock Dump Pad will be <br />on site for inspection at all times. <br />c) Be properly prepared, and updated in accordance with Part I. D. 5. c, to ensure compliance <br />with the terms and conditions of this permit. <br />RESPONSE: RGS has prepared this SWMP in accordance with Part I.D.5.c. <br />3. Facilities must implement the provisions of the SWMP as written and updated, from <br />commencement of construction activity until final stabilization is complete, as a condition of this <br />permit. The Division reserves the right to review the SWMP, and to require the permittee to <br />develop and implement additional measures to prevent and control pollution as needed. <br />RESPONSE: RGS will implement the provisions set forth in this SWMP. <br />4. The SWMP may reflect requirements for Spill Prevention Control and Countermeasure (SPCC) <br />plans under section 311 of the CWA, or Best Management Practices (BMPs) Programs otherwise <br />required by a separate CDPS permit, and may incorporate any part of such plans into the SWMP <br />by reference, provided that the relevant sections of such plans are available as part of the SWMP <br />consistent with Part I.D.5.b. <br />RESPONSE: A fuel farm will be located at the facilities site, as will a maintenance shop. A draft <br />SPCC plan has been developed and will be finalized when the requirements become applicable. <br />The SPCC plan will be added to the Plan of Operations and implemented as a stand -alone <br />regulatory requirement under 40 CFR Part 112 and not incorporated into this SWMP. An <br />estimation of the quantity of petroleum products and explosive products that will be stored at the <br />site is shown below in Table 5, Materials and Supplies, as also reflected in the Plan of Operations <br />Amendment (2011). The SPCC plan will be in accordance with all requirements as described in <br />EPA 40 CFR Part 112. In the event that fuel is spilled, RGS and /or its prime contractor will take <br />appropriate measures to control the spill and will notify the Forest Service and /or the Colorado <br />DPHE (Department of Public Health and the Environment), Water Quality Control Division, as <br />required. <br />112 East 12 Street P.O. Box 610 Creede, CO 81130 <br />719 - 658 -1080 Fax 719 - 658 -1082 <br />