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We understand that if UIC permitting applies, this injection would <br /> be considered a Class V injection activity. As such, unless an <br /> individual permit application is requested, the general permit by <br /> rule authorization of 40 CFR § 144.24 applies. We request EPA's <br /> confirmation in writing that the rule authorization applies. <br /> EPA has requested that the pH of the mine pool be increased as <br /> high as reasonably practicable, and the work plans have been <br /> modified to call for injection of water at a pH of approximately <br /> 12.0. In our discussions with your staff, we were advised that <br /> this injection of alkalinity, as part of a remedial activity, would <br /> not be considered the disposal of a waste material and would not <br /> fall within any of the permitting requirements of RCRA, including <br /> those provisions on corrosive wastes; nor would it result in a <br /> different classification of UIC well. We would specifically ask <br /> your confirmation on that, or we will have to reduce the injected <br /> water below pH 10.5. <br /> Please contact me if you have any questions or need additional <br /> information. We look forward to your early response so that the <br /> project is not delayed. The general construction season in the <br /> Upper Animas Basin is seasonally quite limited. I have also <br /> included the report on injection mentioned at the end of the Mine <br /> Remediation Plan submitted to the State. <br /> Yours Very Truly, <br /> Iva/.S <br /> - 4 <br /> William B. Goodhard <br /> Resident Manager <br /> cc: Bill Robb, Dufford & Brown <br /> Chris Hayes, EBM <br /> Dave Holm, WQCD <br /> Tom Gillis, DMG <br />