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..; DATE: December 10, 1999 TO: Roadside Mine File (1999 Cessation of Operations) FROM: Dan Mathews RE: Meeting with Randy Rotan, Public Service Company Permit No. C-S1-041 I met the morning of December 9, with Randy Rotan of PSC, regarding Roadside Mine facilities on the North Side of [he River. PSC is apparently looking into acquisition of certain PCC holdings, including variotts permitted facility areas. I explained to Mr. Rotan, that existing disturbed areas were required to be reclaimed by the permittee, and would not be available for use until loud bond release was approved, which would be a mirtimum of 10 years following initial revegetation seeding. The only exception would be if PCC were to obtain approval of a postmine land use change revision [o industrial use; which would result in less stringent revegetation success requirements, and a shorter liability time Game. I gave Mr. Rotan copies of regulation sections pertinent to Revegetation Success Criteria for lndus[rial Post mine land use, and requirements for alternative postmine land use (Rules 4.15.10 and 4.16.3). He spec~cally inquired about Minewaler treatment pond 12, and I indicated that, for PSC to use the pond, a revision to approve it as a permanent impoundment, plus land use change and bond release would be On the afternoon of December 9, [ met at the Roadside Mine sire with representative of Powderhom Coal Company (Jim Stover), and representatives of Elam Construction Company (consultant Greg I.ewicki, and three Elam personncl). Elam is considering Ure possibility of succeeding to the permit (for reclamation only), in exchange for considerations including acquisition of gravel deposits in the vicinity of the loadout. I had previously been aware that Elam was interested in mining gravel between the rail loop area and the Colorado River, which would have encroached on the permit area, but would have been outside of areas disturbed by mining operations. Assumedly, the coal permit boundary could have been amended [o allow for a gravel permit area adjacent to, but separate from the coal permit. However, it now appears that Elam would consider assumption of the coal permit in exchange for access to mine gravel from the entire deposit, including the area currently disturbed by the coal stockpile and loadout loop facilities. Items discussed in addition to the loadout area gravel mining issue, included current reclamation plan requirements, and several issues which are of concern but which have not been fully resolved at this lime. These issues include questions regarding the suitability of the rock drop structures in the reconswded Coal Creek channel as permanent swclures, suitability of the current CRDA final reclamation upland diversion design and pile crest conligumtion, and questions regarding permanent minewater drainage from the South Portals Mine. Al this point, the question regarding whether Elam would be able to mine gravel within areas currently occupied by coal loadout facilities, without reclaiming the site to approved standards and waiting a minimum of 10 years until final bond release, is of primary wncern to Elam (and also to Quaker Coal, which is very much interested in unloading their liability). Conceivably, this could be done via a posunine land use change from wildlife habitat to industrial (gravel pit), which would provide for easier and quicker bond release. However, a complicating factor is tlrat the area in question is an alluvial valley floor. Apparently, there had been an irrigated pasture in the loadout area at one time in the past (although i[ had been abandoned and reverted to non-managed brush by the time it was permitted in the early [980's-as near as I can tell). In addition to having apparently been surface irrigated at one time, portions of the area were identified as being subirrigated, and subirtigated vegetation including cottonwoods, willows, cattails, etc., have become established m various locations within the rail loop. Restoration of the essential hydrologic functions for the disturbed AVF area would require facilities demolition, coal cleanup, grading to original topography, and topsoiling, as well as maintenance of alluvial water levels and quality.