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• Vegetation <br />No problems were identified with the vegetation section (2.04.10) or the <br />vegetation section of the reclamation plan (2.05.4). <br />Reclamation Plan <br />The only problems noted in this plan concern mulching and mulch rates. The <br />reclamation plan for the coal load-out areas (Exhibit C of Section 2.05.4) do <br />not call for mulching the areas after seeding. These areas should be mulched <br />or stabilized in some other acceptable manner. <br />In addition, Section 4.05.4(E) (response to Adequacy Comments, dated June 21, <br />1982) states that "Mulching with straw or other suitable material will be used <br />in areas where the potential for excessive erosion exists". <br />The applicant should define what these areas are, state how the mulch will be <br />stabilized such as tacking or crimping, and should provide at what rate the <br />mulch will be appited. A rate of 1 1/2 to 2 tons per acre is recommended. <br />Hydrology <br />1. A review of the past NPDES monitoring reports indicated that discharge <br />point 002 has exceeded discharge limitations four times for total <br />• suspended solids in the past 2 years. Point 3 whose discharge point is <br />002 receives water from mine pumpage and from the wash plant. Problems <br />seem to be caused by water from the wash plant laden with suspended coal <br />sediment mixing with water pumped from the mine. The mixing that occurs <br />does not allow the suspended material to settle before discharge. <br />Because NPDES discharge limitation exceedences area chronic problem at <br />this discharge point the Division requests sufficient modifications to <br />the mine dewatering system and sediment pond to remedy the problem. <br />2. The current PHC section of the permit application consists entirely of <br />responses to MLRD adequacy comments and stipulation responses. This <br />section is very confusing and hard to read, it should be rewritten into a <br />coherent organized document. <br />3. Currently the Southfield Mine is not submitting hydrology monitoring <br />reports in the format specified 1n the monitoring portion of the permit <br />application. This non-compliance is addressed in the enclosed <br />enforcement memo. Compliance deadlines will be set in the Notice of <br />Violation. <br />Subsidence <br />1. Page 31 of the subsidence monitoring and control plan commits to the <br />monitoring of subsidence monuments quarterly and the submittal of results <br />semi-annually; to date the Division has not received subsidence <br />monitoring reports for 1986. These reports should be submitted to the <br />• Division with text discussing the comparison of the observed subsidence <br />-3- <br />