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The December 2014 Vento comments object to TR43. The content comprises a number of <br />questions and statements relating to surface water and groundwater, as well as procedural <br />comments, requests and demands. The Division's understanding of these comments is <br />summarized as follows: <br />• A general concern over the adequacy of the approved groundwater monitoring plan <br />• An assertion that the Southfield mine has had a negative impact on groundwater <br />quantity, and a related demand that EFCI provide wells to the landowners in order to <br />compensate for the loss of groundwater <br />• A request for additional monitoring of the water quality in Newlin Creek <br />• A request that the Division enforces NOV CV- 2013 -002 <br />• A request that the water quality of pond 4 be tested, based on the assumption that pond 4 <br />will be left as a permanent impoundment <br />• A request for a hearing before the Mined Land Reclamation Board (MLRB) <br />The first five of these six issues will be addressed within the broader content of this review. The <br />request for a board hearing is noted; a response addressing the request was sent to Tena Gallagher and <br />Linda Saunders of the Vento group on December 23, 2014. <br />RESPONSE: <br />✓ The Groundwater Monitoring Plan was approved by DRMS via TR -35 in 2003 and should be supported as approved; <br />✓Groundwater quantity impact is within the predictions of the PHC — in good faith, EFCI offered the <br />Vento Group funding to drill a well(s); <br />✓ Due to concerns of lack of water in Newlin Creek, in good faith, EFCI monitored Newlin Creek extensively as is <br />documented in the 2013 — 2014 AHR's; <br />✓ NOV CV -2013 -002 is in force at this time; <br />✓ Acquiring water analysis for Pond 4 is in process; <br />✓ DRMS responded to Vento representatives concerning a Board Hearing. <br />1) Groundwater <br />It was established during the original permitting of the Southfield mine that groundwater resources at the <br />site could be categorized as either: <br />• Alluvial/colluvial terrace deposits <br />• Laterally discontinuous perched aquifers <br />• Flooded mine workings <br />• Trinidad Sandstone regional aquifer <br />On page 2.05.6 -40 of the Permit Application Package (PAP), in the PHC section, the possible <br />hydrologic connection of these potential groundwater resources with the mine workings is discussed. <br />It is stated that low permeability strata in the intervals between the mine workings and the Rex <br />Carbon coal seam above, and the Trinidad Sandstone below, provide effective hydrologic barriers <br />(see figure 1). As part of the TR43 review, the Division analyzed geologic data from the drill logs in <br />Exhibit 8 of the PAP and constructed detailed cross sections which corroborate these statements; <br />there are 300 -400 feet of interbedded low - permeability units consisting of mudstones, siltstones and <br />shales located both above and below the Southfield Mine workings At the main mine site, <br />groundwater in the alluvium/colluvium and in the Trinidad Sandstone may therefore be discounted <br />from any further discussion, (the water monitoring plan was approved on the basis that these <br />resources would not be affected by mining). <br />3 <br />