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-_ ~ • • -15- • The ditch and two ponds are decreed for sediment settling (storage right) as well as for dust control and wildlife use. There are no additional uses of water at the mine that would require a water right, storage right, or permit. Furthermore, the applicant's statement of probable hydrologic consequences does not predict any impact that is or could occur so as to injure adjacent water users. VII. Alluvial Valley Floors -Rules 2.06.8, 4.24 The applicant has conducted a reconnaissance level alluvial valley floor (AVF) study for the proposed mine and adjacent areas. Only one drainage, Tuttle Uraw, was identified as a potential AVF (see Exhibit II of the permit application). The San Miguel River was not taken into consideration. Therefore, the Division undertook a study to determine if the San Miguel River potential AUF could be considered to be adjacent to the Nucla Mine. The San Miguel River is located about 2 1/2 miles from the Nucla Mine. Based only upon visual observations, it is likely that the San Miguel River would be identified as an AVF. However, the distance separatiny the mine from the river is probably sufficient enough to mitigate any impacts that may occur. In addition, the amount of flow that is contributed by Tuttle Draw to the San Miguel River is very small in comparison to the the total flow in the river. No mine-related hydroloyic impacts are anticipated to occur in the San Miguel River hydrologic system. Therefore, tfre San fliyuel River is considered to be located outside of the potentially afFected area and will not be discussed further in the AVF portion of this document. Tuttle Draw was considered to be a potential alluvial valley floor by the applicant based solely upon the identification of unconsolidated stream-laid deposits. The results of the applicant's study indicate that Tuttle Draw does not meet the necessary irrigation criteria to be identified as an AVF. This conclusion is substantiated by the results of a EPA alluvial valley floor study (EPA, 1977) done in western U.S. The basis fur this conclusion is discussed in greater detail below. Geomorphology The applicant has identified about 20 acres along Tuttle Draw which are underlain by unconsolidated stream-laid deposits (see Exhibit II of the permit application). These areas are not considered extensive enouyh to permit the construction of an effective irrigation system. Flood Irrigation Water in Tuttle Uraar is not currently diverted for flood irrigation