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The mine plan area is drained by ephemeral and intermittent stream systems. Starting at the north end of the permit area and proceeding southward, one finds the Sudduth, Williams, Bush and Bolton Draws (with watersheds of 3.6, 4.6, 4.8 and 6.8 square miles respectively). Bolton Draw lays to the south of the permit area and could possibly be impacted by waters from the mine plan area during heavy runoff events. The Marr Strip drainage systems roughly parallel each other and flow to the northeast where they join with the Canadian River, approximately one mile east of the permit area. In 1979, USGS Station 06619420 was installed in Williams Draw downstream from the Marr permit area. This monitoring station has shown that flows occur primarily in response to snowmelt that begins in April and extends usually through May. During this period combined flows of snowmelt and thundershowers have yielded runoff rates of up to 20 cfs. Normally, June runoff decreases rapidly and by July has usually ceased. Occasional thunderstorms may initiate stream flow temporarily. In November, freezing generally occurs and no steamflow is noted until spring thaw some time in April. In this area baseline, ephemeral and intermittent stream water quality analyses show a water with calcium and bicarbonate ion concentrations in an alkaline water with high suspended loads. Minor amounts of iron and sulfates are found in these waters naturally. Baseline total dissolved solids levels range from 68 to 1390 mg/1. The mean value is 505.5 mg/l. In a review of surface water analyses, little degradation of surface waters has been noted. Depending on precipitation, few ponds discharge, and flow into the Draws is intermittent. For example, the Tipple Area sediment pond has never discharged. Except for surface water monitoring Site 306, water quality has been shown to be acceptable. Site 306 has, however, exhibited values for total iron and sulfate that have exceeded Material Damage suspect levels for aquatic life. With no discharges at the tipple area there appears to be little impacts to the surface water around this site. Kerr Coal Company water rights and water augmentation planning are detailed in Volume 10 Exhibit 25. The Augmentation Plan lists a total water consumption of 69.46 acre feet per year. The figure includes 66.9 acre feet for pond dead storage and 2.56 acre feet consumed for dust suppression, other industrial useage and sanitary needs. Kerr Coal claims the 315.2 acre feet of water rights for potential mitigation of adverse impacts to surrounding water users. Based upon the data, Kerr Coal has adequate water rights to mitigate adverse impacts to neighboring water users. 4. The Division finds that the permit area is, subject to valid rights existing as of August 3, 1977, not within: a) An area designated unsuitable for surface coal mining operations b) An area under study for designation as unsuitable for surface coal mining operations (2.07.6(2)(d>(ii));