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

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K2T LLC South Central Land & Mining LLC 19 May 2014 Page 4 MW23 is not blocked; if the reference to MW23 is intended to be a reference to MW-NW, then there is a partial obstruction in the well which will not inhibit monitoring any water that may be filling the I' North Sub -Mains area of the Mine at the elevation above the partial obstruction. Item 2: In a letter to Rob Zuber on Oct 18th 2013, Linda stated "In the 1995 AHR Mike Boulay states the manganese exceeds the Basic Drinking Water Standards in MW 65 on Dr Corley's property and also on 19/9/96, 3/24/97, and 9/30/97. Yet, the manganese in MW23 was higher than the maximum for Secondary Drinking Water Standards in Dec, 2010 and June, 2011. Calcium and Magnesium were also high during this time as shown in the chart we had in our Citizen's Complaint in June 2012. MW23 does not meet the requirements of the regulations that it was intended to monitor when it is blocked so monitoring equipment can't get an accurate reading. Response: The issue about applicable water quality standards is the same as raised in Item 1. As to the issue about the water quality parameters calcium and magnesium, EFCI references the determination of the Division that "Based on analysis results there does not appear to be any significant decrease in coal seam groundwater quality resulting from the Southfield Mining operation as compared to coal seam groundwater quality prior to the Southfield Mine operation. " See Intel-office Memorandum, dated June 3, 2013, from Mike Boulay to Dan Hernandez MW 23 is not blocked and is monitored every 6 months in accordance with the requirements of the Southfield permit. Item 3: Well permitting. The wells that are on this property were drilled by Dorchester Coal, the predecessor of EFCI, and to our knowledge, none of the wells has ever been permitted. As reported in the annual inflow report, for coal washing in 1984 -2002, EFCI used millions of gallons of water from three wells that the State Water Engineer had refused to permit. Secondly, we would like an explanation of why MW23 and MW 16 are into coal veins. See notes at the end of this letter. Finally, none of the wells that were used to dewater the mine or any of the monitoring wells have ever been permitted as required by the DMRS regulations and was noted in Stipulation 3 of Robert Liddle, Reclamation Specialist for the Division of Mining in Permit Renewal Report C- 014 -81, June 15, 1985. Stipulation No.3: "Within 180 days of the permit issuance the operator shall provide documentation that the appropriate filings have been made with the State Engineers office or appropriate Water Court regarding the storage and consumptive use of water at the mine." Illegal wells that were applied for and not permitted include: Permit 8571 -AD (Application Denied) 2/22/ 1980 Dorchestor