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III. COMMENTS -COMPLIANCE <br />Southfield C-81-014 <br />2 Mar 04 ~~ <br />Page 1/1 <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Southfield mine conducted by Jim Stark of CDMG. <br />George Patterson of EFCI, Berhan Keffelew of the minerals program and Denise <br />Gonzolas of Freemont Paving accompanied me on the inspection. The mine is in <br />permanent cessation and all of the initial reclamation (structural demolition, <br />backfilling and rough grading, topsoil replacement and the seeding of a cover crop) <br />has been completed. The mine has applied for and received a Phase I Bond <br />Release for structural demolition, backfilling and rough grading and drainage control <br />reestablishment. The weather was cold and cloudy and the ground dry. <br />The purpose of this inspection was to attempt to determine if the adjacent minerals <br />operation (south of the east portion of the loadout) has disturbed reclamation at the <br />loadout. <br />We mat at the gravel pit and proceeded to the area in question. It appears as <br />though the gravel pit operator has disturbed approximately 1-'h acres south of the <br />railroad tracks to the southern permit boundary of the loadout. The area is about 600 <br />feet long (east-west) and 100 feet wide (north-south). It was unclear at the time of <br />the inspection if only the vegetation was removed or if material was removed. Upon <br />review of the post-mining topography map, it appears as though material has been <br />removed from the loadout site. <br />Based on the inspection, Berhan Keffelew asked the minerals operator to conduct a <br />title search to determine the landowner and to perform a survey to determine the <br />actual permit boundary of the operation. <br />Based on permit boundary maps, it is the opinion of the coal program that the gravel <br />pit has disturbed outside its permit boundary and into the Southfield Loadout permit <br />boundary. The fact that material was removed directly impacts the requirement to <br />return lands to AOC. The coal program would like the gravel pit to amend their <br />permit to include this disturbance, followed by a release in liability for EFCI. <br />A follow-up inspection has been scheduled for 13 April 2004. <br />