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Summary <br />The Review Process <br />Section 2.08.5 of the Rules requires that the Division conduct a review of each permit issued <br />prior to its renewal. Based on this review, for good cause shown, the Division may require <br />reasonable revisions to, or modifications of, the permit provisions to ensure compliance with the <br />Act and Regulations. <br />Section 3.02.2(4) of the Rules requires that the Division review the amount of performance bond <br />liability and the terms of acceptance of the bond every 21/2 years. These tasks have been <br />completed as part of the Permit Renewal No. 6 (RN -06) review process (Appendix A of this <br />report). <br />Pursuant to Rule 2.08.5, on October 28, 2013 the Division notified EFCI of the need to renew the <br />permit and that a complete application for renewal must be received by the Division by January <br />31, 2014. The Division received the renewal application on January 21, 2014 (ten days earlier <br />than required), and the application was called complete on January 30, 2014. <br />This permit renewal review process consisted of a detailed review of the Southfield Mine PAP <br />and previous Division findings of compliance to identify any items that may have been <br />overlooked during the initial review. The Division also reviewed all subsequent revisions and <br />stipulation responses to ensure that all permit commitments and conditions were being followed. <br />Problems and observations from past Division inspection reports and issues raised by landowners <br />were also considered. <br />Adequacy Issues <br />The Division sent three adequacy letters to EFCI regarding RN -06. The first letter, sent on <br />March 28, 2014, contained 25 items to be addressed. Many of these items were editorial or a <br />need to update the PAP to reflect current conditions with the mine and permit. More substantive <br />issues entailed the following: <br />• EFCI will need to develop a plan to mitigate damage to the Corley Company well caused <br />by subsidence. (This issue follows from the most recent midterm review, MT -06.) <br />• EFCI will need to add drill hole log information to Exhibit 8 in the PAP. (This issue <br />follows from MT -06.) <br />• EFCI needs to seal wells MW -08 and MW -10. (This issue follows from MT -06.) <br />• EFCI must provide a more complete description of the pre- operation condition of the <br />portal area. <br />• EFCI needs to establish a replacement reference area or propose acceptable reclamation <br />success standards for the loadout. <br />• EFCI needs to verify that the current State and Federal Threatened and Endangered <br />species lists are included in the Southfield permit. <br />• The PAP requires more clarification regarding measurement of woody plant densities <br />2 <br />