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Demos Jones Seneca Coal Company Page 2 September 23, 2005 The discussion contained in the AHR and Tab 7 of the Seneca II-W PAP should be verified and substantiated through a ground water point of compliance analysis and implementation as required by Rule 4.05.13(1). As described in Regulation No. 41 The Basic Standards for Ground Water ,ground water may be assigned more than one class because it may have more than one existing or potential use. The point of compliance analysis needs to consider both existing and potential future uses. Based on review of baseline and other AHR data and using the Interim Narrative Standazd approach it appears that at a minimum, Potentially Usable Quality may apply to ground water within the Seneca II-W Mine permit boundary and surrounding area. The TDS Water Quality Standazds given in Table 4 of Regulation 41 apply to ground water classified as Potentially Usable Quality. As indicated in the 2004 AHR, increasing TDS trends are beginning too be observed at most wells down gradient of mining, and agricultural ground water standards were exceeded in 2004 at certain monitoring wells. TDS concentration increases aze evident in alluvial ground water in locations along Hubberson Gulch and Sage Creek. The Division has the following comments regazding water quality monitoring at the Seneca II-W mine site and the data and information presented in the 2004 AHR. As you know, the Division informed our coal-mine operators in a letter dated August 13, 2001 of a significant revision to Rule 4.05.13 regarding establishing ground water points of compliance. Rule 4.05.13 requires that One or more points of compliance be established for any coal mining operation, which in the opinion of the Division, has the potential to negatively impact the quality of ground water for which quality standards have been established by the Water Quality Control Commission. Based on review of recent Annual Hydrology Reports, it appeazs that the Seneca II-W mining operation may have the potential to negatively impact ground water and therefore the Division believes that it is necessary at this time to review the current monitoring program to deterrine the need for points of compliance. Please review your ground water monitoring program specific to establishing points of compliance at your site, and provide the Division with your input and feedback. The Division will work with you to identify the need and if necessary, to determine the specific location(s) for ground water points of compliance.