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Minnesota Pollution Control Agency <br /> <br />August 17, 2004 <br /> <br />Mr. Stephen Rohlf <br />Building and Environmental Administrator <br />13065 Orono Parkway <br />Elk River, MN 55330 <br /> <br />Minnesota Pollution Control Agency (MPCA) Comments on the J & B Mining project <br />Environmental Assessment Worksheet (EAW) <br /> <br />Dear Mr. Rohlf: <br /> <br />The EAW for the proposed J & B Mining project (Project) has been reviewed by the MPCA staff. This <br />comment letter addresses matters of concern to MPCA staff reviewing the EAW and is submitted for <br />consideration by the city of Elk River (City), the responsible governmental unit, in deciding whether an <br />Environmental Impact Statement (EIS) should be prepared on the Project. It does not constitute approval <br />by the MPCA of any or all elements of the Project for the purpose of pending or future permit action(s) by <br />the MPCA. We have attempted to identify and consult with interested program staff to identify the <br />MPCA permits that may be required. Additional comments or requests for information maybe submitted <br />in the future to address specific issues related to the development of such permit(s). Ultimately, it is the <br />responsibility of the Project proposer to secure any required permits and to comply with any requisite <br />permit conditions. The following comments are made for your use in revising the draft EAW. <br /> <br />The abstract of the proposed Project found in §6.a. indicates that approximately 1,190,000 cubic yards of <br />material will be mined from the Project area. There is no specific mention of the predicted or expected <br />peat yields from this Project. The amount of peat may be an important factor as certain peat operations <br />(depending on size and/or environmental impact potential) may require a permit from the Minnesota <br />Department of Natural Resources. The MPCA is providing you with a copy of the Peat Operations and <br />Environmental Protection (December 1996) as you proceed with the environmental review process. <br /> <br />In §6.a. of the EAW, it is stated that "...the proposed operation does include gravel washing on a periodic <br />basis" yet there is no specific discussion of two major issues related to gravel washing, namely: 1) the <br />source of the wash water; and, 2) the treatment and disposal of wastewater (Please refer to § 18 of the <br />EAW regarding wastewaters.). This information must be included in the EAW to better assess the <br />potential environmental impacts of the Project. Additionally, this information would be useful to the <br />MPCA during the permitting process. <br /> <br />The former Judicial Ditch Number 1 is discussed in §9. of the EAW, however, the flowpath for this land <br />feature is not delineated on any of the diagrams or figures provided as attachments to the document. It <br />would be helpful to know where the flow from the former Judicial Ditch Number 1 is directed and <br />discharged. <br /> <br />520 Lafayette Rd. N.; Saint Paul, MN 55155-4194; (651) 296-6300 (Voice); (651) 282-5332 ('f-FY); www. pca.state.mn.us <br />St. Paul · Brainerd · Detroit Lakes · Duluth · Mankato · Marshall · Rochester · Willmar <br /> Equal Opportunity Employer · Printed on recycled paper containing at beast 20 percent fibers from paper recycled by consumers. <br /> <br /> <br />