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16. Please update Map 17, Mine Plan, as it currently shows mining only through 1995. <br />17. Page 2.05.4-8R discusses the method EFCI proposes to use to seal the portal and fan openings. <br />The plan does not include installation of drain pipes for discharge of any water that might <br />accumulate behind the seal. DMG recommends that EFCI revise the portal sealing plan to <br />include drains at final reclamation, so that if the mine should ever fill to the level of the portal <br />seals, they would not have to be reopened to install drains. <br />18. The approved permit application indicates that EFCI is supposed to monitor revegetated areas <br />during yeazs 3 or 4. A review of the Annual Reclamation Reports (ARR) shows: <br /> Acres of Topsoil Acres Veg. Monitoring <br /> on RDA Seeded <br />1991 5.9 0 yes ('83 and '87) <br />1992 3.9 9.3 no <br />1993 0 0 no <br />1994 3.7 0 no <br />1995 0 0 no <br />If the information in the ARRs is accurate, the following would apply: <br />a. EFCI should have done monitoring of the 1992 revegetation in 1995 or 1996. <br />b. The topsoil spread in 1994 should have been seeded in the fall of 1994. <br />c. The 1991 revegetation should be monitored during 1998. <br />19. Section 2.05.4 contains discussions of methods for determining the success of revegetation <br />efforts, based upon comparisons of vegetative cover and herbaceous production between <br />reclaimed areas and approved reference azeas. The methods discussed in this section follow the <br />requirements of Rule 4.15.8. <br />Page 4.15-SR refers to areas previously disturbed by mining where the success of reclamation <br />will be determined by unspecified evaluations of erosion control and comparisons of ground <br />cover with previously mined areas having similar material thickness and characteristics. This <br />discussion appears to be written to conform with Rule 4.15.10(1). That rule requires that <br />certain areas previously disturbed by mining be reclaimed such that vegetative cover is not less <br />than what the best available topsoil can support, and is adequate to control erosion. Based on <br />Map 16, the previously disturbed azea referred to includes the entire facilities area. <br />The discrepancy between the two discussions above needs to be eliminated from the permit. <br />The provision in Rule 4.15.10(1) for revegetation success standards on areas previously <br />disturbed by mining applies to azeas disturbed by mining prior to August 3, 1997 which were <br />subsequently redisturbed. As explained in the DMG's 1988 Guidelines for Compliance with <br />Southfield Mine (C-81-030) gpril I8. 1997 <br />Midterm Revitw $ Third Permit Term <br />