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<br />Carl Mount - 2 - -- December 5, 1988 <br />Tuttle Draw is located west of the fJucla tdine area and flows <br />southwestward 2 1/2 miles to the San Miguel River. Tuttle Draw serves as <br />a route for irrigation return flow. Irrigation return waters are a major <br />component of the total runoff in this drainage. <br />The drainage design of the sediment control system of the Nucla Mine area <br />appears adequate to minimize sediment loading of offsite waters from this <br />source. Data on permit area water quality discharges indicates <br />acceptable impacts on offsite water quality. <br />Calamity Draw is located south of the Nucla East permit area and flows <br />southwestward Z miles to the San Miguel River. The sediment control <br />system planned for Nucla East appears to be adequate to minimize offsite <br />sediment loading of the nearby surface waters. Plans to control pit <br />waters and other ground water additions also appear to be adequate to <br />minimize TDS level increases to surrounding surface waters. The area of <br />concern to me here continues to be the proposed encroachment into the <br />Calamity Draw buffer zone. To my knowledge more details are still <br />required from Peabody before a final decision is made on this detail. <br />Stipulation ~3 specifies monitoring of Lower Second Paris Irrigation <br />Ditch. This coupled with a monitoring plan for West Lateral Irrigation <br />Ditch should adequately monitor quantities and qualities of water in <br />these structures in order to minimize and quantify any adverse impacts to <br />these water systems. <br />The Nucla and Nucla East mining activities appear adequately designed and <br />monitored to minimize offsite degradation to surface waters. Water <br />rights held by Peabody appear adequate to replace any impacted waters if <br />such an occurence should take place. Thus it appears that the Nucla <br />permit application ground and surface water programs are in compliance <br />with the reclamation laws and regulations as stated in Rule 4.05. When <br />adequate data is received from Peabody, a decision will be made on the <br />proposed Calamity Draw buffer zone encroachment. <br />JMC/yjb <br />1796E <br />