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Company Well would not be expected, and Annual Hydrology reports submitted since <br />1986 indicate no drawdown effect is occurring. <br />Records taken over the last 25 years suggest no negative impacts or reduction in flow <br />have occurred from Southfield's use of the water from the Corley Mine Well. <br />Extensive drilling adjacent to the Thompson Well by EFCI did not reveal any laterally <br />continuous aquifer that could serve as a regional water source. The Thompson Well was <br />already affected by historical mining in the Rex Carbon and Jack O'Lantern coal seams. <br />The Thompson Well at this time is not serviceable for production or monitoring of <br />groundwater. The operator is not predicting any additional impacts to this well from their <br />operation due to their location below the well and intervening competent sandstones. <br />EFCI does not have groundwater point(s) of compliance identified or discussed in the permit <br />document. Rule 4.05.13(1) states that, "One or more points of compliance shall be established <br />for any coal operation which, in the judgment of the Division, has the potential to negatively <br />impact the quality of groundwater for which quality standards have been established..." The <br />Division is still in the process of evaluating this mine site for the need to have point(s) of <br />compliance. <br />The Division is also currently reviewing water quality concerns, applicable standards, and the <br />approved water monitoring program. This review is related to pending violation CV- 2013 -002 <br />(concerning the obstruction in MW -NW) and a request by EFCI to terminate water monitoring <br />(TR -43 is in the adequacy review process). The Division Groundwater Memorandum, dated <br />June 3, 2013, provides a full discussion of the Southfield Mine groundwater monitoring program. <br />Surface Water Consequences <br />Impacts of the Southfield Mine on beneficial use of surface water are considered negligible for <br />the following reasons: <br />• Baseline surface water quality data in the permit and adjacent areas reflects the effects of <br />previous coal mining activities. The data shows that high concentrations of TSS, TDS, <br />and iron existed in surface water in the mine area prior to the existence of the Southfield <br />Mine. <br />• Current beneficial use of surface water in both the mine area and loadout area is limited <br />by the ephemeral characteristics of some creeks and by upstream diversions of other <br />creeks. Newlin Creek is diverted by the City of Florence upstream from the mine. Oak <br />Creek is utilized as a primary municipal water source for the town of Rockvale five miles <br />upstream from the loadout area. <br />• All mine water is discharged through an approved discharge point, and all effluent <br />limitations are met before discharge. The Colorado Water Quality Control Division is the <br />agency that approved the discharge points and set the effluent limitations. <br />• There has never been a recorded discharge from the loadout ponds. <br />• Regarding Second Alkali Creek, there will be no surface disturbance in this area other <br />than possible subsidence. <br />22 <br />