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17. Section 2.05.6(1) of the PAP should be revised to reflect the current status <br />of the air permit. This section, as well as Exhibit 4, should be revised to indicate <br />the current status of the permit but text should be retained to illustrate the history <br />of the permit. <br />Revised page(s): <br />2.05.6 -1 <br />Exhibit 4 Table of Contents <br />18. Section 2.05.6(3) of the PAP should be revised to correct the following <br />inaccuracies. On page 2.05.6 -10 the text states that Oak Creek is monitored <br />for surface water quality (also on page 2.05.6 -52). On page 2.05.6 -16 the text <br />states that there will be modifications to Magpie Diversion. On page 2.05.6- <br />17 the text states that there are three ponds at the mine site. On page 2.05.6- <br />18 the text discusses the water treatment pond. <br />Revised page(s): <br />2.05.6 -10 <br />2.05.6 -1 Oa <br />205.6 -16 <br />205.6 -18 <br />205.6 -18a <br />205.6 -52 <br />205.6 -52a <br />19. On page 2.05.6 -21 of the PAP there is a discussion of potential <br />problems with TDS in runoff, and the text states that EFCI will implement <br />controls if problems are noted. However, there is no process in place to <br />assess this potential problem below Pond 5. The discharge from this pond <br />is not monitored for TDS or conductivity, and there is no monitoring point <br />in the receiving water below this. (Conductivity is monitored in Newlin <br />Creek, Magpie Creek, and Second Alkali Creek, but not below Pond 5.) <br />EFCI needs to address this issue. <br />RESPONSE: <br />Pond 5 discharges into an unnamed tributary of Magpie Creek. This tributary <br />joins Magpie Creek, then the combined flows enter Newlin Creek <br />approximately one mile northeast of the Southfield mine site. <br />At the time Pond 5 was established as a sediment pond by Dorchester Coal <br />Company (Dorchester), a surface mine owned by GEC Minerals (GEC) was <br />operating adjacent to both Magpie Creek and the unnamed tributary. The GEC <br />mining operations were immediately adjacent to Southfield's surface facilities <br />and Pond 5, and runoff from all GEC disturbance areas flowed into the Magpie <br />Creek stream system. This includes a portion of the GEC site runoff entering <br />the unnamed tributary immediately below the spillway of Pond 5. <br />The GEC mine disturbance area is significantly larger than that of Southfield, <br />and as such has higher potential to impact the stream system below Pond 5. <br />There is no location to monitor downstream of Pond 5 to accurately <br />differentiate any potential problems with TDS attributed to Pond 5 discharge <br />compared to the discharge from the GEC mine site. <br />