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in terms of water rights. h) The applicant has estimated that Mann Draw contributes "slightly under one percent of the flow of the Canadian River." If this estimate is accurate, then the quantity of water in the Mann Draw alluvium is clearly significant, both in terms of a potential impact on the Canadian River alluvial valley floor, and on water rights. i) Data submitted by the applicant from drill hole 15 A indicate that another aquifer exists about 200 feet below the Sudduth seam. Do you have any additional information on this aquifer? It may also need to be monitored. j) Your proposed groundwater monitoring program is currently being eval- uated, and comments will be forwarded at a later date. The staff will inform you if there are additional parameters which should be monitored. Samples will probably need to be taken quarterly, rather than every six months. k) The Division of Water Resources expressed a number of concerns in their letter regarding water rights for the proposed Bourg mine. The applicant must address these concerns. V. Water Information: Sediment Control a) Considerable additional information will be required in order to demonstrate that the proposed sediment control plan meets the requirements of federal interim regulations. The materials submitted by the applicant on August 13 address the December 13, 1977 regulations. Section 715.77 (e) (Sediment Ponds) has, however, since been revised. We are currently reviewing sediment control plans according to this May 25, 1979 revision. b) The estimate of 50% runoff used in designing the sediment ponds must be substantiated. One way would be to use the SCS curve number method. c) Since the applicant has chosen not to divert runoff from adjoining un- disturbed land, the quantity of this runoff must be calculated and include in the capacity of the sediment pond (both flood storage and sediment storage). d) The applicant has calculated runoff only for disturbed areas not drained by the pit. However, since runoff flowing into the pit will be pumped to the sediment pond, additional volume must be included in the sediment pond capacity to handle this water. e) Preferably water flowing down Mann Draw should be diverted around the pit. If this is~ot possible, this volume of water will also need to be considered in sizing the sediment ponds. d) Finally, the sediment ponds must have sufficient capacity to accomodate any groundwater which seeps into the pit. This could be an important consideration during years 3 through 7 when the pit will intercept Mann Draw. e) As a possible method of handling the water from various sources which is pumped from the pit into the sediment ponds (items c,d,e above), the applicant has the option of pumping this water into the pond only until the sediment storage volume is filled. If any additional water is to be pumped into the ponds, storage capacity must 6e allowed for this water. f) Sediment ponds must also allow fora three year sediment storage volume, as described in 715.17 (e)(2) of the Hay 25 interim regulations. Your (5)