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January 1993 Raton Creek Mira ' Adequary Responses ~ 3 portion of the existing refuse pile and placement of approximately 22,000 ry of borrow material from the azea between the raw coal stockpile and Animas pottal area to backfill the Animas portal and other minor cut areas near the shop building (Ref: Pg. 493 of approved permit). The approved permit did not reflex reclamation of other abandoned mine portals and associated highwalls within the permit area. EFMC, in response to the Division's original renewal comments, and as part of an overall review of mine closure requirements, reevaluated final backfilling and grading plans and requirements. The objective of this review was to make appropriate adjustments in the plan to reflect existing site conditions, minimize additional surface disturbance, and develop a postmining topographic configuration which meets requirements for long-term stability, effective drainage, and compatibility with the proposed postmining land use. The resulting revised reclamation plan, submitted in conjunction with EFMC's 8/92 Renewal Adequary Responses, represents a balanced approach which effectively addresses all of the noted components. EFMC recognizes the specific regulatory provisions cited as they relate to highwall elimination. The Division does however, appear to have some discretionary authority relative to both timing and extent of highwall elimination as provided by Rules 4.14.1(1)(d), 4.14.2(1), and 4.14.2(2). The following factors should be considered relative not only to regulatory language, but also regulatory intent and practical environmental and operational considerations: • Many of the abandoned highwall segments are located in areas where current access is either non-existent or very limited. Establishment of access for backfilling and grading may require signifipnt additional disturbance • The original terrain in this azea was relatively steep, with natural slopes at gradients frequently above the angle of repose for backfilled material. Given this consideration, backfilling and establishment of consistent slopes may require extensive grading and disturbance of upslope, downslope, and adjacent areas. These activities could result in additional erosion and the potential for slope stability problems • Many of the old portals have collapsed and are currently stable with well established drainage and vegetative growth • Natural landforms, including rock outcrops, ledges, drainages, and associated slope breaks occur throughout this area and are similar in configuration to the minor highwall segments which would remain following completion of the activities outlined by the mos[ recent reclamation plan submittal (8/92) The overriding question which should be answered for each of the remaining highwall segments is whether or not additional backfilling and grading will substantially reduce potential associated haurds or result in enhanced stability, drainage, or utility relative to the proposed postmining use. If full highwall reduttion does not result in significant potential benefits, reasonable intermediate alternatives (ie: approval as cut/fill terraces, A:~P56RFSP.LTR 01/05/9) ]pm ACZ /nc. ' P.O. Box 774018 'Steamboat Springs, Colorado 80477 ' (303J 879-6260