Laserfiche WebLink
3 <br /> Furthermore. use of the term bankrupt is ambiguous. What does become bankrupt mien? <br /> Does this mean SGC has fled for bankruptcy, does it mean that SGC has been adjudicated <br /> bankrupt by s court. or does it just mean SGC is out of money? Finally, the State is restricted <br /> to use the surety funds only to enter and operate the treatment facility at the American <br /> Tunnel. We recommend that the surety be available to allow the State to complete any work <br /> SGC Is required to perform under the Consent Decree. For instance, if SGC were to 90 <br /> bankrupt before they complete the A list projects, the surety should be available to complete <br /> these projects, if the State so chooses. <br /> Aooendix A <br /> 1. Pape 4.a.. Paragraph 1: The response to exceedances of the monthly zinc average at the <br /> reference point needs further definition. SGC should automatically be required to hwastieste <br /> possible causes of elevated zinc values rather than waiting until after a meeting with the State. <br /> How long does SGC have to lower the zinc levels if a problem occurs? Subsequent to the <br /> investigation period which should last a maximum of sixty (60) days, SGC should be required <br /> to submit an investigation report and a mitigation plan to the State. <br /> 2. Pages 4.s. and S.s.:The copy of Appendix A we received had several blanks referencing the <br /> paragraphs in the Consent Decree. These blanks need to be completed. <br /> AomndkL <br /> 1. Pape 1.b. Pant PI(11. Sunnyside Mine Pool;The plan calls for raising the pH in the Sunnyside <br /> Mine to a range of S to S. We are concerned that the range of pH may not be high enough to <br /> handle the zinc and copper concentrations. A pH range of 10 to 11 would appear to be a <br /> more realistic range to assure adequate precipitation of metals within the mine pool. There is <br /> no indication as to how the pH for the injection or the pH in the mine pool will be monitored <br /> end adjusted. Either there should be a requirement for monitoring the mine pool in sufficient <br /> locations to assure that the pH is in the target range or the concentration at the point of <br /> injection should be specified. The concentration at injection should be sufficiently high to <br /> achieve the ultimate range of pH throughout the mine pool at equilibrium. <br /> 2. Pages 1.b. 2.b and 3.b: The plans for mine waste dumps and tailings removals do not mention <br /> removal of the contaminated material underlying the waste rock or tailings. Experience at the <br /> Eagle Mine and Chalk Creek indicates that a significant amount of comaminated soil will be <br /> under the piles. This should be removed and new soil should be placed in the excavation prior <br /> to any attempt at reveoetation. If this does not happen. the revegetation effort will be subject <br /> to failure and the groundwater and surface water leaving this area wig show a significant <br /> increase in metals. These projects should be undertaken with specific soil sampling plans and <br /> removal criteria to assure that the highest level of metals contaminated material is removed. <br /> Criteria for soil cover after removal of the material should also be stipulated. <br /> Detailed ComMon Relftd to the Permits <br /> 1. For all Permits DMRs need to be sent to EPA's now address: <br /> U.S. Environmental Protection Agency (8ENF-T) <br /> Office of Enforcement. Compliance and Environmental Justice <br /> Technical Enforcement Program <br /> 999 1 Sth Street. Suite 500 <br />