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INSPECTION BEPOBT i P~ 4 The MLRD has changed their regulations to tinhtec up the use of and definition of "other treatment facilities" since their approval of this mine plan modification. The regulation'hae been re-written to restrict the "window' that vas used by the operator to request something for drainage control other than the sediment ponds. The current regulations define 'Sediment treatment facilities" {CCMR Section 1.04 (115x)} as any ---- chemical treatment, such as floculation, or mechanical structures, such ac. clarifiers, that have a point-source dieharge and that are utilized to prevent additional contribution of suspended solids to etreamflov or runoff outside the permit area. The definition ae it reads nov limits this site to have drainage control Sn a land form that has a point source discharge utilized to prevent additional contribution of suspended solids to etreamflov or runoff outside the permit areal. The regulations go on to define design criteria far these ponds ar treatment facilities under CCMB Section 4.05.6 (1), (3)(a), (b), (c), (d), and (e). In brief, they address treatment requirements, storage volume requirements, devatering devices, spillway construction requirementt and outflow limitations. There regulations now mirror the Federal Permanent Program standards. A "Phase I" bond release for the grading on the area has been requested by the operator. Their request was submitted ,September 1, 1988. The final decision for approval of the partial bond release by MLRD after they inspected the site for compliance with the plan vas October 11, 1988. I have made an attempt to reviev the findings of the HLRD regarding the approval of something other. than sediment ponds for drainage control on this area. It has been x long and sometimes difficult proceeding but felt that it vas warranted due to the complexity and sensitivity of the issues involved. It vae.my intent and duty to reviev my findings witk the Field Office Director prior to proposing sny enforcement action. That in itself vas no ordinary task. The problem unfortunately, lead to x lengthy reviev and ensuing discussions. It ie obvious that ve have nat agreed on the course of action but it ie my duty to write =his report and file it, accordingly. Mr. Hagen, the Albuquerque Field Office Director, vas patient with my Stance but hoe found contrary to my belief. Ae has _ndicated that the field office should find that it is in .be beat interest of agencies concerned that no enforcement action be warranted for the drainage control ae noted in the approved mine plan and what 1a nov o^ the ground. There are :o major differences between the two but the problem lies in he fact that something vas approved ether than sediment -onde for drainage control.