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Narrative Statement for the 1997 Colorado Special Focus Review of Coal Waste Banks at the Roadside Portals Mine Background OSM and DMG agreed to conduct a special focus review of coal waste banks ("coal refuse piles°) at the Roadside Portals mine under the 1997 attachment to the performance agreement. The special focus I completed included a records review at DMG's Denver office and at the mine office and a review of the three refuse piles in the field. Dan Matthews represented DMG and conducted a partial inspection of the piles on August 5 and 6, 1997. Glen Golden and I represented OSM during DMG's inspection. Mr. Larry Reschke represented Powderhom Coal Company. The 1996-1997 performance agreement states that reclamation of coal refuse piles will be considered successful when the piles are constructed and reclaimed in the manner in which DMG has approved as specified in the permit. To evaluate construction and reclamation, the agreement prescribes determining that the methods approved for coal mine waste bank water control, construction, and reclamation have been followed by the permittee by verifying the following: That the operator inspected the waste banks as required; that the operator constructed and maintained water control measures as required; and that the operator followed construction requirements addressing lifts, compaction, cover, and other features as found in DMG's rules. In that context, the Team agreed the special focus review would be an evaluation of the refuse piles' compliance with the approved mine permit. Review of water controls emphasized comparing flow patterns to the approved plan and determining if problems, such as excessive erosion, occurred and if they had the potential of creating off-site impacts. The team agreed erosion of reclaimed portions of a waste pile would be considered excessive when erosional features prohibit successful reclamation, as provided in section 4.16.6 of DMG's rules. Waste bank construction was evaluated by spot- checking construction details to determine compliance with approved designs. Three coal refuse piles are located at the Roadside Portals mine. They are: The Roadside refuse disposal area (RRDA); Cameo refuse disposal area 1 (CRDA-1); and Cameo refuse disposal area 2 (CRDA-2). Design information for the three piles is found throughout the mine plan. This review focused on the refuse piles and their integral drainage structures. It included only cursory field observations of their associated ponds and didn't address access roads. According to OSM's tracking system, it conducted a complete inspection of the Roadside Portals mine most recently on November 17, 1994. Unfortunately, WRCC's files don't include a Roadside Portals mine file for that evaluation year, so the report wasn't available for review. 3