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Home My WebLink AboutDERR-2024-007694Letter No. 031 Response to Letter No. 031 11: See the Response to Common Comment No. 6. 12: See the Response to Common Comment No. 6. 11 12 Letter no. 031 (cont.) Response to Letter No. 031 (cont.) 13:The potential future expansions of shallow aquifer wells by JVWCD are beyond the scope of the Joint Proposal currently before the Trustee. The Sharon Steel and Midvale Slag Superfund sites Records of Decision recognize the JVWCD water rights and potential for future shallow groundwater pumping. Those Records of Decision require fiveyear reviews to monitor for changed conditions and to consider changes in remediation approaches to the slag sites. 12 12 13 Letter No. 032 Response to Letter No. 032 21: See the Response to Common Comment No. 9. 22: See the Response to Common Comment No. 1. 22 21 Letter No. 033 Response to Letter No. 033 31: See the Response to Common Comment No. 9. 32:The NRD Trust Fund was established so that a contaminated source of water could be developed and provided to the public in the Affected Area at a certain quality and quantity for a forty year time period. The cash portion of the settlement (originally $9 million cash) was established to restore, replace or acquire the equivalent lost resource for the benefit of the public in the Affected Area. The Letter of Credit (originally $28 million) was established to fund the provision of 7000 acrefeet per year of municipal quality water (as defined in the 1995 Natural Resource Damage Consent Decree, NRD CD) for a period of forty years, for the benefit of the public in the Affected Area. In 1995, 8235 acrefeet of water was determined to be the volume of water contaminated with sulfate above the State primary drinking water standard. The NRD Trust Fund is precluded from being used in the endeavor suggested. 31 32 Letter No. 0304 Response to Letter No. 0304 41: See the Response to Common Comment No. 8 and No. 9. See also, the Response to Common Comment No. 1 for a response to the request for an environmental impact study to be performed. 42: See the Response to Common Comment No. 6 and No. 7. 43: See the Response to Common Comment No. 12. 44: See the Response to Common Comment No. 9. 45:The Trustee, DEQ, Kennecott, and the Jordan Valley Water Conservancy District recognize the importance of the Great Salt Lake and associated wetlands. 41 41 42 43 44 45 41 44 Letter No. 0304 (cont.) Response to Letter 0304 (cont.) 46: For petitions, see the Response to Common Comment No. 8 and No. 9. 44 41 46 Signatures to Letter No. 0304 Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Signatures to Letter No. 0304 (cont.) Letter No. 0305 Response to Letter No. 0305 51: See the Response to Common Comment No. 6 thru No. 9. 52: See the Response to Common Comment No. 9. 51 52 Letter No. 0305 (cont.) Response to Letter No. 0305 (cont.) 51 Letter No. 0306 Response to letter No. 0306 61: See the Response to Common Comment No. 6 thru No. 9. 62: See the Response to Common Comment No. 9. 61 62 Letter No. 0306 (cont.) Response to Letter No. 0306 (cont.) For petitions, see the Response to Common Comment No. 8. 61 Signatures to Letter No. 0306 Signatures to Letter No. 0306 (cont.) Signatures to Letter No. 0306 (cont.) Signatures to Letter No. 0306 (cont.) Signatures to Letter No. 0306 (con.) Signatures to Letter No. 0306 (cont.) Letter No. 0307 Response to Letter No. 0307 71:The response to the petitions follows. 72: See the Response to Common Comment No. 8 and No. 9. See also the Response to Common Comment No. 1 for a response to the request that DEQ perform an environmental impact study. 71 72 Signatures to Letter No. 0307 Signatures to Letter No. 0307 (cont.) Signatures to Letter No. 0307 (cont.) Letter No. 0308 Response to Letter No. 0308 81:The responses to the petition follows. 81 Letter No. 0308 (a) Response to Letter No. 0308 (a) 82: See the Response to Common Comment No. 3. 83: See the Response to Common Comment No. 6 thru No. 9. 84: See the Response to Common Comment No. 10. 85: See the Response to Common Comment No. 11. 86: See the Response to Common Comment No. 12. 87: See the Response to Common Comment No. 1. 82 83 84 85 86 87 Signatures to Letter No. 0308 (a) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Signatures to Letter No. 0308 (a) (cont.) Letter No. 0308 (b) Response to Letter 0308 (b) 83 Letter No. 039 Response to Letter No. 039 91: See the Response to Common Comment No. 10. 91 Letter No. 0310 Response to Letter No. 0310 101: See the Response to Common Comment No. 1 102: See the Response to Common Comment No. 13. 103: See the Response to Common Comment No. 4 and No. 5. Also, see the Response to Common Comment No. 7 104: See the Response to Common Comment No. 6 and No. 8. 101 104 103 102 Letter No. 0311 Response to Letter No. 0311 111: See the Response to Common Comment No. 1. 111 111 Letter No. 0312 Response to Letter No. 0312 121: See the Response to Common Comment No. 1. 121 Letter No. 0313 Response to Letter No. 0313 131: See the Response to Common Comment No. 12. 132: See the Response to Common Comment No. 12. In terms of the acid plume in Zone A, the Environmental Protection Agency Region VIII is currently negotiating with Kennecott regarding the Remedial Design Consent Decree for the remediation of the Zone A plume, including the acid core portion which is extracted but not treated for use as drinking water. This document will include provisions that Kennecott establish financial assurance that the planned remedial efforts will continue. 133: See the Response to Common Comment No. 7. The disposal option for the Zone A CERCLA and NRD actions has been discussed in the TRC meetings for roughly the past three years. The Consent Decree does not preclude Kennecott or the District from having to attain the pertinent permits and approvals for the various aspects of the proposal to the Trustee for the water treatment project. The DEQ would request that the DOGM work with Kennecott to ascertain the need to revise the reclamation permit for the two facilities (tailings pipeline and North Expansion Impoundment). 131 132 Letter No. 0313 (cont.) Response to Letter No. 0313 (cont.) 134:The concerns about water management are not part of the Joint Proposal and were not included as requirements under the settlement of the Consent Decree. As noted before, the operation and maintenance of the Bingham Pit is not addressed in the Consent Decree, and the Consent Decree does not provide funding through the Trust Fund for anything but the restoration, recovery, or acquisition of a replacement for the sulfate contaminate groundwater in the Affected Area. The DERR and the DWQ have been working in cooperation with the DOGM to address a revision of the Bingham Canyon Mine Reclamation plan. Throughout this process all three divisions have recognized a need to maintain water management structures and control of storm water and leach water from within the mining permit area. The DWQ, through the use of the ground water protection permits for mining facilities associated with Bingham Canyon, has been working with Kennecott to maintain best management practices for water management in this area. The water management items stated in the comment are best handled under the regulatory authority of the DOGM and the DWQ during their review of the Bingham Canyon Mine Reclamation Permit. 135: See the Response to Common Comment No. 12. Furthermore, the Joint Proposal (Section 10) discusses the operation, maintenance and replacement responsibilities of Kennecott regarding the Zone A facilities and the Jordan Valley Water Conservancy District (District) regarding the Zone B and Lost Use facilities. The removal of facilities, upon completion of treatment will be accomplished in accordance with existing federal, state, and local laws, as provided in the Consent Decree. If the DOGM believes that Kennecott needs to assure to them that the facilities for the proposed project (within their mine reclamation areas) will be reclaimed at the end of the project, the Trustee is willing to mediate discussions between DOGM and Kennecott to address this concern. 136:The Consent Decree is specific in terms of the use of the established Trust Fund. The monies in the Trust Fund have been set aside to produce drinking quality water for the benefit of the public in the affected area, in conjunction with a project to treat water from the contaminated plumes in the Southwest Jordan Valley and contain and reduce contamination. Also, funding ($815,000) for oversight by DEQ is funded under the 3Party Agreement. 133 134 135 136 Letter No.0314 Response to Letter No. 0314 141: See the Response to Common Comment No.9 142: See the Response to Common Comment No. 1. 143: See the Response to Common Comment No. 2, No. 4, and No. 5. 144: See the Response to Common Comment No. 1. Also, see the Response to Common Comment No. 13. 142 142 141 143 144 Letter No. 0315 Response to Letter No. 0315 151: See the Response to Common Comment No. 6 and No. 8. 152: See the Response to Common Comment No. 3. 153: See the Response to Common Comment No. 9. 154: See the Response to Common Comment No. 4 and No. 5. Also, refer to Response to Common Comment No. 7. 155: See the Response to Common Comment No. 9. 152 151 151 155 154 153 Letter No. 0315 (cont.) Response to Letter No. 0315 (cont.) 155 153 Letter No. 0316 Response to Letter No. 0316 161: See the Response to Common Comment No. 9. 162: See the Response to Common Comment No. 4 and No. 5. Also, see the Response to Common Comment No. 7 and No. 9. 162 161 Letter No. 0316 (cont.) Response to Letter No. 0316 (cont.) 163: See the Response to Common Comment No. 3. 164: See the Response to Common Comment No. 6. Also, see the Response to Common Comment No. 8. 163 164 162 162 Letter No. 0317 Response to Letter No. 0317 171: See the Response to Common Comment No. 4 thru No. 9. 172: See the Response to Common Comment No. 9. 173: Again, See the Response to Common Comment No. 4 thru No. 8. 171 171 173 172 Letter No. 0318 Response to Letter No. 0318 181: See the Response to Common Comment No. 6, No. 8, and No. 9. 182: See the Response to Common Comment No. 9. 183: See the Response to Common Comment No. 4 thru No. 7. 184: See the Response to Common Comment No. 9. 181 184 183 182 Letter No. 0319 Response to Letter No. 0319 191: See the Response to Common Comment No. 3. 192: See the Response to Common Comment No. 6, No. 8 and No. 9. 191 192 192 Letter No. 0320 Response to Letter No. 0320 201: See the Response to Common Comment No. 6 and No. 8. 202: See the Response to Common Comment No. 9. 201 202 202 Letter No. 0321 Response to Letter No. 0321 211: See the Response to Common Comment No. 9. 212: See the Response to Common Comment No. 4 thru No. 7. 211 212 Letter No. 0322 Response to Letter No. 0322 221: See the Response to Common Comment No. 1. Also, see the Response to Common Comment No. 8 and No. 9. 221 Letter No. 0323 Response to Letter No. 0323 * The responses to the comments in this letter are provided in the responses to E mail No. 037 which is the same as this letter from the same commenter. Letter No. 0323 (cont.) Response to Letter No. 0323 (cont.) Letter No. 0324 Response to letter No. 0324 241: See the Response to Common Comment No. 1. See also the Response to Common Comment No. 6 and No. 8. 241 Letter No. 0325 Response to Letter No. 0325 251: See the Response to Common Comment No. 9 252: See the Response to Common Comment No. 3 253: See the Response to Common Comment No. 8. 254: See the Response to Common Comment No. 9. 252 253 251 254 Letter No. 0326 Response to Letter No. 0326 261: See the Response to Common Comment No. 3. 262: See the Response to Common Comment No. 4 thru No. 9. 263: See the Response to Common Comment No. 9. 261 262 262 263 263 Letter No. 0327 Response to Letter No. 0327 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 271: See the Response to Common Comment No. 1. 272: See the Response to Common Comment No. 3. 271 272 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 273: There are over 300 monitoring well locations within and surrounding the Zone A and Zone B ground water plumes. The locations and depths of the monitoring wells has been evaluated over the last 10 years by the Technical Review Committee, the State of Utah and the EPA as documented in the RI/FS and Final Remedial Design. The data collected from the wells and the ground water model calibrations indicate that the location and depths of the wells within the aquifer are of a sufficient distribution to accurately monitor the containment/migration of the ground water. 274: See the Response to Common Comment No. 10. All of the water extracted for treatment within Zones A and B will be extracted through valid water rights that Kennecott and JVWCD currently hold for Zone A and Zone B respectively. Both Kennecott and the District worked with the Utah Division of Water Rights to reassign water rights both entities have owned historically and used in the past for the development of either production water or drinking water (respectively). Except for the District’s shallow ground water development project, no new well applications were filed to facilitate the proposed extraction activities. Only change applications (for existing water rights) were necessary to provide the amount of water from the two contaminated zones, necessary to meet the requirements of the Consent Decree. 274 273 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 275: See the Response to Common Comment No. 11. 276: See the Response to Common Comment No. 9. 277: Again, See the Response to Common Comment No. 9. 278: See the Response to Common Comment No. 9. 276 277 278 275 274 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 279:The referenced fact sheet was provided as a summary of the proposed project to the State Trustee for Natural Resource Damages. Under the fact sheet section entitled “Consent Decree,” requirement No. 2 states that Kennecott was required to drill a well or wells into the low pH/heavy metals ground water plume and begin to remove contaminants. Other project documentation (NRD Consent Decree, Supporting Document, and the Joint Proposal) recognize the acid extraction requirement of the Consent Decree. Kennecott began pumping from the low pH/heavy metals plume in 1997 to extract on a five year rolling average, 400 acrefeet per year, to address the need to gain containment of this portion of the plume and to begin removing the contaminants of concern. The reference to the Kennecott letter to the State Trustee dated August 26, 2003, makes note of the total amount of acrefeet of contaminated water removed from the low pH/heavy metals plume since extraction began in 1997. The intention of this letter was to notify the Trustee that the Kennecott was meeting the Consent Decree settlement requirement prior to the required anniversary date and was on task to meet the next removal increment ahead of schedule. The water that has been removed from the low pH/heavy metals plume has been pumped to the Kennecott tailings pipeline for delivery to the North Expansion Impoundment in Magna, Utah. Kennecott has been and continues to neutralize the acidity of the extracted water by either using the neutralization potential of the tailings material or by adding lime to the tailings circuit. Water in the impoundment was and is currently recycled from the North Expansion Impoundment into Kennecott’s process circuit during yearly operations or discharged from the impoundment under an approved UPDES permit. 2710 278 279 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 2710:K60 was replaced because of its age, not because it was damaged by acid. The well was originally installed in the 1960s with a steel casing that typically has a 20 to 30 year life. This and other sulfate extraction wells are monitored and will be replaced when and if needed, just like any other well. The Final Remedial Design that was reviewed by the Technical Review Committee and approved by EPA and the State of Utah details the containment, extraction and groundwatermonitoring program. Over 300 monitoring wells are currently in place within and around the plume and are monitored on a monthly to annual basis. Data collected from this monitoring program will be used to evaluate the effectiveness of the containment and extraction program and make adjustments if necessary. 2711:Significant seismic analyses of the tailings impoundment site and method of construction were completed as part of a Final Environmental Impact Statement (FEIS) conducted for the tailings north expansion project completed in 1995. The development of the tailings dam employs the use of cycloned sand tailings using a modified centerline method of construction. The combination of using cycloned sand tailings placed and compacted as an engineered fill in conjunction with an underdrain system provides for a structure that is stable and safe under the design earthquake conditions, the Maximum Credible Earthquake. State statutes define the Maximum Credible Earthquake as “the most severe earthquake that is believed to be possible at the site on the basis of geological and seismological evidence.” 2712:The Final Remedial Design presents the details requested in the bullets above. Please remember (as stated in Response to Common Comment No. 5), the remedial plans for the acid core of Zone A are part of Kennecott’s CERCLA remedial response. See the following web link ( http://www.deq.utah.gov/issues/nrd/documents.htm) to review a copy of this referenced document. In regards to the last three bulleted items, the State Trustee has established a means to disseminate the project information developed in the future to the public with an interest in this particular project. See the Response to Common Comment No. 13. 2710 2711 2713 2712 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 2713:See the Response to Common Comment No. 7. 2714:See the Response to Common Comment No. 4, No. 5 and No. 7. 2715:See the Response to Common Comment No. 6 and No. 8. 2715 2714 2713 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 2716:See the Response to Common Comment No. 8. 2717:See the Response to Common Comment No. 6, No. 8 and No. 9. 2715 2717 2716 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 2718:See the Response to Common Comment No. 12. 2719:The term “concentrate” is technically and scientifically correct in that the waste stream from a reverse osmosis facility is nothing more than the influent or feed water concentrated by a factor of four or five as the clean portion of the water or precipitate is passed through a membrane under high pressure. The term “toxic waste” is not applicable as the concentrate has been repeatedly tested and does not exhibit any hazardous characteristics. The studies and data demonstrate that the concentrate from the Zone A treatment plant meets authorized and permitted discharge limits that are protective of human health and the Great Salt Lake environment. For example, the selenium concentration in the concentrate is approximately 25 ppb. The drinking water standard for human consumption for selenium is 50 ppb. 2718 2719 Letter No. 0327 (cont.) Response to Letter No. 0327 (cont.) 2720:See the Response to Common Comment No. 6 and No. 7. 2715 2714 2720 Letter No. 0328 Response to Letter No. 0328 Letter No. 0328 (cont.) Response to Letter No. 0328 (cont.) 281: See the Response to Common Comment No. 6 thru No. 9. 281 Letter No. 0328 (cont.) Response to Letter No. 0328 (cont.) Letter No. 0328 (cont.) Response to Letter No. 0328 (cont.) 282: See the Response to Common Comment No. 6 thru No. 9. 282 Letter No. 0328 (cont.) Response to Letter No. 0328 (cont.) 283: See the Response to Common Comment No. 8 and No. 9. 284: See the Response to Common Comment No. 6 thru No. 9. 285: See the Response to Common Comment No. 1. Also, see the Response to Common Comment No. 9. The list of questions will be shared with the Steering Committee looking into the issues of selenium in the Great Salt Lake. Lastly, See the Response to Common Comment No. 7. 281 285 282 283 284 Letter No. 0328 (cont.) Response to Letter No. 0328 (cont.) Letter No. 0328 (cont.) Response to Letter No. 0328 (cont.) 286: See the Response to Common Comment No. 9. 286 Letter No. 0329 Response to Letter No. 0329 291: See the Response to Common Comment No. 6 thru No. 9. 292: See the Response to Common Comment No. 9. 292 292 291 Letter No. 0329 (cont.) Response to Letter No. 0329 (cont.) 293:The existing concentration of any pollutant in a water body varies depending on season, contributions by other sources of close proximity, significant hydrological changes along its’ entirety, and various other dynamic factors. The authority and intent provided under the UPDES program is the protection of a water body based on instream pollutant concentrations at the particular point of discharge. As a practical matter, this is accomplished based on water quality standards, and point source effluent limitations based on specific sections of the water body. 294: See the Response to Common Comment No. 9. 294 292 293 Letter No. 0330 Response to Letter No. 0330 301: See the Response to Common Comment No. 6 thru No. 9. 302: See the Response to Common Comment No. 6, No. 7 and No. 9 303: See the Response to Common Comment No. 6 thru No. 9. 304: See the Response to Common Comment No. 8. 301 303 304 301 302 Letter No. 0331 Response to Letter No. 0331 311: See the Response to Common Comment No. 1. 311 Letter No. 0332 Response to Letter No. 0332 321: See the Response to Common Comment No. 10. All of the water extracted for treatment within Zones A and B will be extracted through water rights that Kennecott and JVWCD currently hold for Zone A and Zone B respectively. Both Kennecott and the District worked with the Utah Division of Water Rights to reassign water rights both entities have owned historically and used in the past for the development of either production water or drinking water (respectively). 322: See the Response to Common Comment No. 1. 323: See the Response to Common Comment No. 1. 322 323 321 Letter No. 0333 Response to Letter No. 0333 331:The Consent Decree requires that the damages obtained from Kennecott must be used to “restore, replace, or acquire the equivalent of the natural resource for the benefit of the public in the Affected Area as provided under Section 107(f) of CERCLA.” Consent Decree Section V.D.1 and 4. The Joint Proposal explains how the water from the Zone A and B plants is to be distributed to the municipalities that are within the Affected Area. The distribution of water in the Joint Proposal is consistent with the requirements of CERCLA and the Consent Decree. See the Response to Common Comment No. 10, No. 11, and No. 12. 331 Letter No. 0333 (cont.) Response to Letter No. 0333 (cont.) 331 Letter No. 0333 (cont.) Response to Letter No. 0333 (cont.) 331 Letter No. 0334 Response to Letter No. 0334 341: See the Response to Common Comment No. 10. 341 Letter No. 0335 Response to Letter No. 0335 351: See the Response to Common Comment No. 6, No. 8, and No. 9. 351 Letter No. 0336 Response to Letter No. 0336 361: See the Response to Common Comment No. 1. 362: See the Response to Common Comment No. 12. 363: See the Response to Common Comment No. 9. 361 363 362 Letter No. 0337 Response to Letter No. 0337 371: See the Response to Common Comment No. 1 372: See the Response to Common Comment No. 12. 373: See the Response to Common Comment No. 9. 371 372 373 Letter No. 0338 Response to Letter No. 0338 381: See the Response to Common Comment No. 1. 382: See the Response to Common Comment No. 12. 383: See the Response to Common Comment No. 9. 381 382 383 Letter No. 0339 Response to Letter No. 0339 391: See the Response to Common Comment No. 1. 392: See the Response to Common Comment No. 12 393: See the Response to Common Comment No. 9. 391 392 393 Letter No. 0340 Response to Letter No. 0340 401: See the Response to Common Comment No. 1 402: See the Response to Common Comment No. 12. 403: See the Response to Common Comment No. 9. 401 402 403 Letter No. 0341 Response to Letter No. 0341 411: See the Response to Common Comment No. 1 412: See the Response to Common Comment No. 12. 413: See the Response to Common Comment No. 9. 411 412 413 Letter No. 0342 Response to Letter No. 0342 421: See the Response to Common Comment No. 1 422: See the Response to Common Comment No. 12. 423: See the Response to Common Comment No. 9. 421 422 423 Letter No. 0343 Response to Letter No. 0343 431: See the Response to Common Comment No. 1 432: See the Response to Common Comment No. 12. 433: See the Response to Common Comment No. 9. 431 432 433 Letter No. 0344 Response to Letter No. 0344 441: See the Response to Common Comment No. 1 442: See the Response to Common Comment No. 12. 443: See the Response to Common Comment No. 9. 441 442 443 Letter No. 0345 Response to Letter No. 0345 451: See the Response to Common Comment No. 1 452: See the Response to Common Comment No. 12. 453: See the Response to Common Comment No. 9. . 451 452 453 Letter No. 0346 Response to Letter No. 0346 461: See the Response to Common Comment No. 1 462: See the Response to Common Comment No. 12. 463: See the Response to Common Comment No. 9. 461 462 463 Letter No. 0347 Response to Letter No. 0347 471: See the Response to Common Comment No. 1 472: See the Response to Common Comment No. 12. 473: See the Response to Common Comment No. 9. 471 472 473 Letter No. 0348 Response to Letter No. 0348 481: See the Response to Common Comment No. 1 482: See the Response to Common Comment No. 12. 483: See the Response to Common Comment No. 9. 481 482 483 Letter No. 0349 Response to Letter No. 0349 491: See the Response to Common Comment No. 1 492: See the Response to Common Comment No. 12. 493: See the Response to Common Comment No. 9. 491 492 493 Letter No. 0350 Response to Letter No. 0350 501: See the Response to Common Comment No. 1 502: See the Response to Common Comment No. 12. 503: See the Response to Common Comment No. 9. 501 502 503 Letter No. 0351 Response to Letter No. 0351 511: See the Response to Common Comment No.1 512: See the Response to Common Comment No. 12. 513: See the Response to Common Comment No. 9. 511 512 513 Letter No. 0352 Response to Letter No. 0352 521: See the Response to Common Comment No. 1 522: See the Response to Common Comment No. 12. 523: See the Response to Common Comment No. 9. 521 522 523 Letter No. 0353 Response to Letter No. 0353 531: See the Response to Common Comment No. 1 532: See the Response to Common Comment No. 12. 533: See the Response to Common Comment No. 9. 531 532 533 Letter No. 0354 Response to Letter No. 0354 541: See the Response to Common Comment No. 1 542: See the Response to Common Comment No. 12. 543: See the Response to Common Comment No. 9. 541 542 543 Letter No. 0355 Response to Letter No. 0355 551: See the Response to Common Comment No. 1 552: See the Response to Common Comment No. 12. 553: See the Response to Common Comment No. 9. 551 552 553