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NUCLA PR NO. 2 <br /> continually being evaluated. In conclusion, Peabody will not construct <br /> the dragline erection site unless , at the time, a dragline will be used. <br /> Comment: <br /> 9. Page 5 of Attachment 16-1 references the need to dewater the pits. <br /> Some discussion pertaining to this practice and how erosion will be <br /> minimized should be placed in this section. <br /> Response: <br /> Pages 13-6 and 13-10 have been revised. <br /> Comment: <br /> 10. The Division can find no evidence of plans to divert runoff from <br /> undisturbed areas away from disturbed areas. As required by <br /> section 4.05.5 of the regulations , this practice should be <br /> incorporated into your plans . <br /> Response: <br /> Peabody does not think it is feasible to divert a significant portion of <br /> the upstream runoff from undisturbed areas away from disturbed areas. <br /> Section 4.05.5 of the regulation is a list of suggested sediment control <br /> methods which can be used by the operator when feasible. <br /> With most of the permit area proposed for disturbance, a diversion would <br /> have to be constructed above the permit area on land not controlled by <br /> Peabody or, within the permit area where significant grade control <br /> structures or excavations would be required to keep the diversion away <br /> from the mining area. <br /> In conclusion, none of the above alternatives seemed very feasible; <br /> therefore, Pond 007 was designed and sized for "worst conditions" and <br /> all of the watershed area was assumed to drain into this pond. In <br /> addition, the upstream watershed land ownership is not controlled by <br /> Peabody; therefore, construction of a diversion ditch is not possible. <br /> Plus, any diversion ditch, if constructed, would take water from the <br /> upstream area and impact adjacent landowners with runoff which was not <br /> encountered before mining. Peabody has committed not to allow water to <br /> pond in such a manner in which the water will back-up off of the permit <br /> area. <br /> Comment: <br /> 11. Please provide a map which clearly indicates , on one sheet, the <br /> total Nucla East watershed area. Also indicate on this map the <br /> path used to measure the hydraulic length of the watershed. <br /> 18 <br />