2014-05-19_GENERAL DOCUMENTS - C1981014 (2)

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K2T LLC South Central Land & Mining LLC 19 May 2014 Page 2 regard to such statements nor is EFCI consenting to an expansion of the scope of the requested Hearing. EFCI acknowledges that the Vento Trust Group has obviously spent an extensive amount of time reviewing the regulatory history at Southfield as well as the relevant permits etc. to assist them in their attempt to secure resolution of issues that are clearly quite important to them. We understand the members of the Vento Trust Group are the current landowners who did not share in all of the monetary rewards gained by their predecessors from the mining and sale of the coal resource underlying their property. EFCI has attempted to evaluate the various Items in the context of its understanding of the various regulatory regimes that apply to EFCI and the Southfield mine and has set forth that understanding in this letter. Notwithstanding this understanding, it is possible that an ongoing dialogue between EFCI and the Vento Trust Group might result in some mutual agreements that could address some of the Items within the final reclamation and bond release process. Prior to making detailed responses to the Items, it may be useful to provide some general comments on the groundwater situation at Southfield even though experts for EFCI and for the Division have recently conducted detailed reviews of the hydrogeology and those reports and comments continue to "speak for themselves ". 1. The Southfield Mine is located in an area that has been extensively mined historically and there are very limited records concerning many of the prior mining operations and the exact location of the underground workings associated with the old mines. We are not aware of any detailed groundwater records from the old operations. 2. In general, the area is quite and and groundwater sources are quite limited. There is agreement that the groundwater that is found above the Trinidad Sandstone (which is some 300 -400 feet below the Southfield mine workings) occurs in isolated perched zones and in open underground workings in the area. 3. The coal zones that produce water in and around the Southfield Mine were never intended to be developed for drinking water use because they contain poor quality water. As explained by the Division, naturally occurring poor quality water is not, in and of itself, necessarily "contaminated" ground water. The monitor wells were completed in the coal zones as originally designed, approved and constructed. See Interoffice Memorandum, dated June 3, 2013, from Mike Boulay to Dan Hernandez. 4. As a regulatory matter, water in Southfield's flooded mine workings, as well as water in coal or low permeability rock interbedded with coal down gradient of the flooded mine workings, does not need to meet any drinking water quality standards. See Interoffice Memorandum, dated June 3, 2013, from Mike Boulay to Dan Hernandez. 5. The MW -NW well will continue to be monitored by EFCI until it is reclaimed and EFCI is of the opinion that MW -NW continues to allow monitoring to track progressive mine