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a. ', ,ASSe;:sment Office • • Office of Surface Mining May 1.7, 1979 Page Three the McClane Canyon site, SEI was involved in maintenance and construction efforts aimed at performing maintenance and cleaning up from the harsh winter and improving on surface water control facilities at the site. Work of this nature was previously impossible due to the unusually wet winter realized on the western slope. Specific efforts were under way to clean diversion ditches and siltation basins, prepare the site to adhere to recommendations made during the above referenced MLR inspection, and to culvert water from undis- turbed areas past the area of disturbance. The diversion of water from the undisturbed area will pre- clude the necessity of providing additional treatment capability in the siltation basin. As the siltation basin was previously felt adequate to treat runoff, elimination of this source from the basin enfluent would actually in- crease treatment capability of the temporary basin. Work had been undertaken on the siltation basin when the in- spector walked onto the site and the basin was only par- tially intact. During this construction, however, straw dikes had been strategically placed and these were effective in dealing with sedimentation. The disturbed area noted in the violation totals approxi- mately 2.5 acres; runoff from which, during a 10 year 24 hour precipitation event, would total 65,000 gallons. Associated adjacent undisturbed area contributing to the flow of water past the exploration site during this 10 year 24 hour event is approximately 920 acres. Runoff from these associated areas would total 5,663,000 gallons, clearly indicating that, even without the controls that were applied at the time of the inspection, contribution to stream flow from the disturbed area is insignificant. Finally, there is no showing that there was any environ- mental damage as a result of SEI's improvement work on the siltation basin. No credits were given by the OSM inspector for the straw dikes which were in place, and which were functioning as adequate sedimentation controls, in spite of the fact that the inspection took place at a time that SEI was combatting a heavy winter thaw and: four consecutive days of raim and snow. For these reasons, we urge you not to assess a penalty. 3. The third alleged violation states that SEI failed "to - maintain access roads so as to prevent the additional