2014-05-23_GENERAL DOCUMENTS - C1981014

• Permit No: C1981014
• IBM Index Class Name: General Documents
• Doc Date: 5/23/2014
• Doc Name: List of Directives to EFCI that are Not Completed
• From: Rob Zuber
• To: David Berry
• Permit Index Doc Type: General Correspondence
• Email Name: DIH
• Media Type: D
• Archive: No

Topic /subtopic Compliance Issue
Within the subsidence portion of Section 2.05.6 of
the PAP, there is no discussion of potential impacts
of subsidence on renewable resource lands. This
should be addressed, especially in the context of
Update of PAP /subsidence potential groundwater recharge.
Of
Update of PAP /vegetation
of
of PAP /vegetation
On pages 2.05.6 -55 and 2.05.6 -56 of the PAP, the
list of structures that could be impacted by
subsidence does not include the Corley Company j
Well. This text needs to be edited to include this
!well. EFCI also needs to confirm that no other
(wells are within the areal extent of predicted
subsidence. Also, text in Section 2.05.6 should be
revised to include a discussion of potential damage
to this well (or these wells) and mitigation
measures, including compensation if applicable, to
address any damage caused by subsidence.
A more complete description of the pre- operation
condition of the portal area is required by Rule
12.04.10(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.)
j Page 2.04.10-0 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.
EFCI needs to correct the discussion on page
12.04.10-5 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.
Table 33 in Section 2.05.4 of the PAP (and related
Tables 33A and 33B 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.
Associated DRMS
Date of Directive Method of Directive staff Comments
This is RN -06 item Number 21.
EFCI intends to address this with next
28- Mar -14 RN -06 adequacy RDZ renewal submittal.
This is RN -06 item Number 22.
EFCI intends to address this with next
28- Mar -14 RN-06 adequacy RDZ renewal submittal.
This is RN -06 item Number 8.
EFCI responded; discussions between
28- Mar -14 RN -06 adequacy JHB EFCI and DRMS are ongoing.
This is RN -06 item Number 9.
EFCI responded; discussions between
28- Mar -14 RN -06 adequacy JHB EFCI and DRMS are ongoing.
This is RN -06 item Number 14.
EFCI intends to address this with next
RN_06
Table of Unresolved Directives to EFCI.xlsx Page 3