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The Adequacy Review proceeds to say that an evaluation of any (quality) impact trends which may exist <br />in the available data is required to approve the revision. This evaluation would include addressing the <br />following PHC prediction: <br />• Potential increases in the levels of TDS and concentrations of specific chemical constituents <br />Also mentioned in the Adequacy Review is a reference to Section 2.04 of the Southfield PAP, though not <br />part of PHC, as follows <br />"Moderately alkaline pH values will decrease the potential for dissolution of soluble metals including <br />iron, nickel and zinc and should result in no significant potential for adverse hydrologic impacts. Sample <br />pH values indicate no potential for development of acidic conditions and only marginal potential for <br />development of excessively alkaline conditions in the hydrologic system." <br />Similar to the above subject, the Division requests EFCI to verify these predictions by evaluating available <br />groundwater data from each groundwater monitoring point. <br />An evaluation of possible mining impacts on groundwater quality is described in detail in Discussion Item <br />#1, above. This discussion substantially agrees with the material provided in the original submittal package <br />where it states that monitoring data do not show any significant trends between the baseline (start of <br />mining) information and recent samples. Likewise there is no discernible trend between up- gradient and <br />down-gradient monitoring points. Therefore, based on analysis results, there does not appear to be any <br />significant decrease in coal seam groundwater quality resulting from the Southfield Mining operation as <br />compared to coal seam groundwater quality prior to the Southfield Mine operations. <br />The Adequacy Review does not raise any issues with information provided by EFCI (in the TR-43 <br />Application package dated October 24, 2014) that the surface water quantity and quality monitoring data <br />that has been presented supports the PHC predictions. The referenced surface water PHC predictions for <br />surface water include the following <br />• Temporary increases in runoff for surface disturbance areas <br />• Minor reductions in surface flows due to operation of sedimentation structures <br />• Alteration of surface flow patterns <br />• Changes in surface water chemistry — Increases in levels of TDS and specific chemical <br />constituents <br />Additional information requested by the Division in the Adequacy Review, related to <br />surface water quantity and quality, are addressed in Discussion Items #2, #3, and #4 <br />above. The analysis of impacts on surface flow quality and quantity support the statements <br />made in the TR submittal, that no discernible trends in any other chemical constituents <br />to occurring comparing the upstream and downstream monitoring data. <br />A tionally, there is no evidence that a Southfield Mine has impacted the quality or <br />quantity of water available as streamflow in Newlin Creek. <br />Allen S. Weaver <br />Mining Engineer <br />