2013-09-16_REVISION - C1981014 (3)

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Page 4 of 5 east at 400 -450 feet deep. DRMS response: This fact does not discredit EFCI's monitoring of water elevations and quality of subsurface water found in the Red Arrow and Dirty Jack O' Lantern coal seams. The Division finds that the Southfield Mine is in compliance with Rule 2.04.7, Rule 4.05.1(1) and 4.05.1(2). 11. Act 120(2)0)(II)(a): "That in no case shall Federal or State water quality standards be violated" DRMS response: No information was included to indicate which State or Federal water quality standards are being violated. 12. Rule 4.05.8 regarding drainage from acid - forming and toxic - forming spoil or underground development waste into ground or surface water shall be avoided. DRMS response: There is no evidence of any acid - forming or toxic — forming drainage from the designed and constructed Refuse Disposal Area. Pond 4 remains in place, but rarely contains any water from runoff from the RDA. There has been no record of Pond 4 discharging since the mine was reclaimed. MW -10 is located immediately west of the RDA and was previously monitored prior to subsurface failure of this monitoring well. MW -10 had been drilled to 402 feet and measured perforated interval from 342 -402 feet (Pine Gulch coal seam, Upper and Middle Jack O' Lantern coal seams). There are 342 feet of interbedded sandstones, siltstones, mudstones, shale and coal seams between the coal refuse disposal area (RDA) and the Southfield Mine workings. There is no reason to believe that there is any toxic or acid forming drainage from the RDA into subsurface water. Exhibit 08 contains the drilling record for MW -10, previously identified as SR -10. The drilling record did not record encountering any water in the strata from the surface to the bottom of the drill hole in this location. For additional discussion of this topic, please see Southfield permit page 2.05.4 -27a and Exhibit 09. 13. Your August 21, 2013 objection expressed concern regarding Ground Water Recharge capability and cited Rule 4.05.12 and Act 120(2)0)(IV). The objection letter stated that, "MW23 has been drawn down by 50 feet recently and MW65 is drawn down also." DRMS response: Please review the Division's June 3, 2013 memo, as this provides an explanation of the hydro - geology in the Southfield Mine area. 14. MW23 at 145 feet is not and has not tested the groundwater quality or quantity, but is testing water in the Red Arrow Coal Seam at 150'. The Groundwater is at 400 -450' based on wells drilled by Larry Finney, Finney Drilling and John Reeves, Reeves Drilling. DRMS response: As described in section 2.04.7 of the Southfield permit and in Exhibit 25, MW- 23 is completed up- gradient from the Southfield workings, and finished to a depth of 179 feet. The perforated interval is from 149 feet to 170 feet in the Upper and Lower Red Arrow seam. Please read the groundwater description in the Southfield Permit, Section 2.04.7, Section 2.05.6, Protection of Groundwater Recharge Capacity; Section 4.05.12, Probable Hydrologic Consequence; 2.05.6(3)(b)(iii). 15. A new monitoring well into the groundwater needs to be drilled by EF to determine what the status of the groundwater in the only upslope monitoring well that in an area that has not been undermined and away from old mines nearby. This new monitoring well needs to continue to be monitored until the reclamation period is over.