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capacity of the impoundments which includes the capacity to handle 24 hour, 10 year storm events and <br />24 hour, 25 year events. Another factor for non - discharges is the revegetation success that has stabilized <br />the drainage areas to the ponds reducing the amount of runoff and sedimentation in the respective <br />pond's drainage areas. <br />With the approval of Technical Revision No.35 (TR -35) during 2003 and during the onset of <br />the reclamation activities at Southfield, water monitoring activities were reduced from quarterly <br />monitoring intervals to semi - annual monitoring periods. The schedule for water monitoring is <br />provided in Exhibit 25, Water Monitoring Program located in the permit document. TR -35 (2003) <br />also approved conversion of the north dewatering well to a groundwater monitoring well. The <br />conversion designated the monitoring well as the "MW -NW" monitoring well. <br />Hydrology Monitoring Results and Probable Hydrologic Consequences: <br />The DRMS provided EFCI with a copy of an extensive hydrogeologic review of Southfield submitted <br />as an Interoffice Memorandum from Mike Boulay, DRMS' hydrologist, to Dan Hernandez of the DRMS, <br />dated June 3, 2013. A copy of the review is included with this submittal (Attachment B). In summary, the <br />DRMS hydrogeologic findings concur with the determinations described in the Southfield approved <br />permit document concerning the Probable Hydrologic Consequences for the Southfield operations (page <br />12 of the Memorandum). The Review also concludes that there is no reason to expect further disturbance <br />at the site or further degradation of water quality in the Red Arrow or Jack O' Lantern coal seams or <br />workings. With regard to considering additional monitoring wells, the Review concludes that additional <br />monitoring of the coal zone is not warranted (page 13 of the Memorandum). <br />Probable hydrologic consequences identified in Section 2.05.6 of the Permit are listed below. <br />Groundwater Consequences <br />1. Minor reductions in down - gradient groundwater flows <br />2. Possible dewatering of abandoned mines in the Vento seam <br />3. Localized reductions in the piezometric surface <br />4. Localized alteration of groundwater flow patterns <br />5. Possible increases in recharge as a result of mine dewatering <br />6. Potential increases in the levels of TDS and concentrations of specific chemical constituents <br />Probable groundwater consequences appear to be consistent with the findings made by Boulay and the <br />DRMS (refer to above referenced Memorandum) and are supported by the groundwater data provided in the <br />Annual Hydrology Reports. Historical surface water and groundwater data is included with this submittal in <br />Attachment C. EFCI concurs that there are possible minor reductions in down - gradient groundwater flows <br />due to groundwater inflows to the mine void. There is, however, no evidence of adverse impacts to down - <br />gradient water users (refer to Water Rights Consequences, below). Partial dewatering of abandoned mines in <br />the overlying Vento seam may have occurred due to their close proximity to the Southfield Mine, though <br />there is no monitoring data to support the extent of the dewatering. Further, these mines are likely to be <br />refilling with groundwater given the low vertical permeability of the interburden between the upper seams <br />and the Red Arrow and Jack O' Lantern seams. <br />Localized reductions in the piezometric surface, or more accurately, potentiometric head levels, have <br />occurred according to water level data from the three current monitoring wells (MW -16, MW -23, and MW- <br />65). Review of data provided in the Annual Hydrology Reports show that MW -16 went dry in late 2001 <br />until 2004, recharged briefly, then again went dry from 2006 to present. MW -23 exhibited a rapid water level <br />rise in level between 1979 and 1984, then a steady decline from 1984 to 2003, followed by steady levels <br />2 <br />TR -43 Revised: 10/2014 <br />