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Corley Comment #15 <br />In a letter (January 26, 2016), Dr. Mergen wrote the following: <br />There is obvious erosion within the permit boundary, and there is sediment deposition on and erosion <br />of County Road 92, just north of EFCI's permit boundary. We believe that most of the runoff and <br />sediment are coming from within the permit boundary; EFCI has presented no evidence to the <br />contrary, in fact the sediment demonstration in the SL -03 application indicates a significant amount <br />of sediment has been transported off the reclaim area. Also, sediment accumulation in Pond 5 <br />further indicates a problem. Our main concern is that the amount of sediment exiting the Corley <br />property is greater than acceptable standards. <br />Response to Comment #IS <br />EFCI is only responsible for sediment from the areas they disturbed. The sediment demonstration in <br />the SL -03 application indicates that post -mining erosion from the reclamation area is comparable to <br />the adjacent areas. <br />Corley Comment #16 <br />In his letter, Dr. Mergen wrote the following: <br />The SL -03 sediment analysis report was authored by Mr. Kent Gorham of Gorham Energy <br />Consultants, LLC. Since Mr. Gorham is the author and was described as a staff expert of surface <br />water modeling for both operational and bond release purpose we request that his CV be included <br />with this sediment report. We also request that employment dates be included when he was an <br />employee with the Division, when he was a contractor with the Division, and when he was employed <br />as a consultant for EFCI. <br />Response to Comment #16 <br />It is not necessary for EFCI or the Division to provide this information. <br />Corley Comment #17 <br />In his letter, Dr. Mergen stated that the sediment demonstration, including revisions, failed in all <br />aspects. He included many details of the perceived shortcomings of this analysis. <br />Response to Comment #17 <br />The sediment demonstration is acceptable to the Division. EFCI has done an adequate job <br />representing reclaimed areas and non -mined areas in their demonstration, and they used appropriate <br />information for their analysis. <br />The objective of the sediment demonstration is to compare two scenarios (reclaimed condition versus <br />non -mined condition or reclaimed versus pre -mining); it is not to calculate an accurate sediment load <br />from any of the conditions. <br />Corley Comment #18 <br />In his letter, Dr. Mergen wrote the following: <br />The sediment report in the SL -03 application describes the reclamation as problem free and that there <br />are self -healing areas that produce less erosion than the adjacent non -mined lands. The report does not <br />acknowledge obvious erosion, signs of concentrated runoff, and great amounts of sediment yield. <br />Southfield Mine SL -03 Page 7 of 21 February 23, 2016 <br />