2014-03-28_REVISION - C1981014 - Laserfiche WebLink

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Page 2 of 3 3. MT -06 item Number 12: EFCI has not sealed wells MW -08 and MW -10. This needs to be completed and the PAP updated accordingly. Additional Issues The following additional issues with your permit have been identified. 4. Section 2.03.5 of the PAP needs to be updated. The status of infractions that have been terminated should be noted. The most recent infraction, CV -2013 -002, must be added. 5. Section 2.03.8 of the PAP needs to be edited to revise the paragraph with the date for the permit term. It should not read "July 30, 2004." It should be revised to reflect the current status. 6. The permit acreages and disturbance acreages listed in the RN -06 application do not match the numbers in Table 2 (page 2.03 -40 in the PAP). EFCI needs to explain this discrepancy and/or make the approprioate edits to the application or PAP. This same error appears on page 2.05 -8 and needs to be addressed. 7. Section 2.03.10 of the PAP should be revised to provide an updated status of other permits. 8. A more complete description of the pre- operation condition of the portal area is required by Rule 2.04.10(4). Condition of each community type or portion thereof shall be discussed if significant differences exist within a type. (Pre- operation disturbance constitutes a significant difference.) Page 2.04.10 -4 in the PAP states that "all these areas had been disturbed prior to the initial vegetation work conducted at the site." A more thorough discussion could alleviate confusion in the future. 9. EFCI needs to correct the discussion on page 2.04.10 -5 in the PAP regarding the pre- operation vegetation cover for Plot B reference area. As previously pointed out by the Division, the cover value reported by EFCI for the 1980 cover data for Plot B is in error and does not agree with the value reported in Exhibit 11. The cover value for the 1980 sampling of Plot B should read 11.39 percent not 19.1 percent. 10. The grassland reference area for the loadout has apparently been damaged by other parties. EFCI needs to establish a replacement reference area or propose acceptable reclamation success standards for the loadout and update applicable text in Section 2.04.10 in the PAP. For the loadout, EFCI may want to consider using the approved grassland reference area that is currently used for the mine site. 11. Per Rule 2.04.10(5), EFCI needs to verify that the current State and Federal Threatened and Endangered species lists are included in the Southfield permit. 12. Section 2.05.2 of the PAP should be revised to reflect the current status of activities on the mine site. For example, the text in this section indicates that Southfield is still producing coal. 13. Section 2.05.3 of the PAP should be revised to reflect the current status of the ponds. Pond 1, Pond 2, and Pond 3 have been reclaimed, but this is not discussed in the text. It would also be usefull to add a discussion in this section concerning which ponds are planned as permanent. 14. Table 33 in Section 2.05.4 of the PAP (and related Tables 33A and 3313 if necessary) should be revised to confirm the most recently approved seed mixes and to document the revision and date of the latest versions. For example, Table 33 needs to reflect the latest revision; it has been updated more recently than March 2003 with MR -48. 15. Please bring the discussion on page 2.05.4 -27 in the PAP into agreement with pages 2.04.10 -5 and 5a with regard to the average weighted approach discussion. This should include the "new portal reference area." 16. Page 2.05.4 -27a in the PAP requires more clarification regarding measurement of woody plant densities and delineation of shrub clumps. An acceptable way to clarify which area is defined as a shrub clump versus seeded area would be to reference a particular map (e.g., a map in an Annual Reclamation Report). 17. Section 2.05.6(1) of the PAP should be revised to reflect the current status of the air permit. This section, as well as Exhibit 4, should be revised to indicate the current status of the permit but text should be retained to illustrate the history of the permit. 18. Section 2.05.6(3) of the PAP should be revised to correct the following inaccuracies. On page 2.05.6 -10 the text states that Oak Creek is monitored for surface water quality (also on page 2.05.6 -52). On page 2.05.6 -16 the text states that there will be modifications to Magpie Diversion. On page 2.05.6 -17 the text states that there are three ponds at the mine site. On page 2.05.6 -18 the text discusses the water treatment pond. 19. On page 2.05.6 -21 of the PAP there is a discussion of potential problems with TDS in runoff, and the text states that EFCI will implement controls if problems are noted. However, there is no process in place to assess this potential problem below Pond 5. The discharge from this pond is not monitored for TDS or conductivity, and there is no monitoring point in the receiving water below this. (Conductivity is monitored in Newlin Creek, Magpie Creek, and Second Alkali Creek, but not below Pond 5.) EFCI needs to address this issue. 20. On page 2.05.6 -27 of the PAP the text refers to a permit area expansion proposed by a revision. This language is not appropriate for the PAP and should be revised.