Laserfiche WebLink
a permit may be needed. <br /> Response: SGC has submitted to EPA a letter requesting a determination if it is <br /> subject to a UIC permit, and if so, if it fits under the general permit. <br /> Comment: The target pH in the workings (or pH range) should also be mentioned. <br /> Response: The specifics of the mitigation projects, including the mine pool <br /> mitigation project (with target pH ranges for the injection water and Mine pool), are <br /> appropriately discussed in the Work Plans for the projects attached to the permit for <br /> mitigation projects (Appendix Q. See also response to Appendix B comment 1. <br /> 4. Comment: Pages 13 and 14, Paragraph 9.a.: For the determination of equilibrium - <br /> what is meant by the "rate of rise has leveled off"? EPA suggests adding another <br /> appendix to the Consent Decree which describes the process for determining if <br /> equilibrium has been met. Does the notice by SGC that equilibrium has been reached <br /> need to provide supporting data and describe how SGC reached that conclusion? The <br /> text is a little unclear concerning what exactly is required to be provided. Is it <br /> appropriate to reference the Mined Land Reclamation (AILR) Permit and technical <br /> revisions? <br /> Response: The WQCD's entering into this Consent Decree is partly in response to <br /> the approval by the Mined Land Reclamation Board of SGC's proposal to install <br /> bulkhead seals in the Sunnyside Mine portals. Mine pool equilibrium is defined in <br /> SGC Mined Land Reclamation permit, as stated in the Consent Decree. The WQCD <br /> is providing EPA that portion of SGC's Mined Land Reclamation permit. That <br /> determination is-within the jurisdiction of the Division of Minerals and Geology, not <br /> the WQCD. Therefore, neither adding another appendix to the Consent Decree <br /> describing when equilibrium has been met nor referencing the MLR permit (other <br /> than the existing references to it on pages 4-5), as suggested by EPA, would be <br /> appropriate. <br /> Comment. What does "maintenance" of the portion of the American Tunnel <br /> downstream of the SGC property mean? This term should be defined so it is clear <br /> what action(s) will trigger the release of SGC from its permit for the American <br /> Tunnel. <br /> Response: EPA states that the term "maintenance" is unclear in the sentence "Should <br /> maintenance of the portion of the American Tunnel downstream of the SGC property <br /> line seal and treatment of the American Tunnel discharge be undertaken by the <br /> property owner or other parties, then SGC will be released from any continued CDPS <br /> permit obligation at the American Tunnel." This sentence is taken from the summary <br /> of work, which work is described in greater detail in other parts of the Consent <br /> Decree. This sentence follows another that clarifies that this sentence is relevant only <br /> 3 <br />