1991-03-25_GENERAL DOCUMENTS - C1981017

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2. HAUL ROADS A. Previously and Currently Utilized Haul Roads (Photo 5) On National Forest System lands, haul roads are causing the most significant adverse impact to water quality within the Coal Basin watershed. At current operational levels, the Twin Adit Tunnels have replaced the need for hauling coal over these roads. However, Mid-Continent maintains that they want to keep their options open to use these roads in the future. On haul roads currently being used, Mid-Continent wants access to Entries #1 and #2 main- tained at the present 50-60 foot widths.They contend that this width is needed for trucks hauling limestone to Brieden Plant and to provide access for vehicles and equipment for maintenance of these entry points. In addition, Mid-Continent stated that these roads will have to be main- tained throughout the winter. Plowing the snow into the steep road fill slopes and maintaining the road ditches can severely limit any revegetation efforts from effectively controlling erosion on both the road cut and fill slopes. At present, extensions of the tunnel have not been constructed to the active mining areas accessed through Entries#3,#4 and#5.According to Mid-Continent's Mine Land Reclamation Division permit, they are planning to keep the roads to these points of entry open to haul coal if future needs arise. All designated haul roads are also undergoing some degree of "Interim Reclamation" which is defined in Mid-Continent's updated Mine Land Reclamation Division permit. "Interim Reclama- tion" includes reducing the width of the roads by allowing the cut slopes to slough-in and the outside berms to accumulate excess materials generated from maintaining the road. Both of these practices were observed causing problems as described below. Haul Road Ditches (Photos 6-8) As approved in their permit renewal with MLRD, Mid-Continent has constructed and is maintain- ing new road ditches along existing haul roads.These have replaced the old ditches which are being allowed to fill-in as these cut slopes unravel or slough-in with soil and rock slope debris. This permit requirement is part of Mid-Continent's interim reclamation plan that is directed at enhancing stabilization of the cut slopes and is intended to ultimately lead to the revegetation of the stabilized slopes and reduced road widths. According to Mid-Continent's interim reclamation plan, "The inside ditch will be moved out approximately 10 feet from the hillside into the road. This will allow material to slough off the hillside and onto the inside of the road. In this way, the present 50-60 foot width of the roads will be narrowed.The culvert drainage system will remain functional.Where the new inside ditch passes over the culvert,the culvert will be uncovered with a backhoe and cut with a torch.When it has been determined that the sloughed material has stabilized, the area will be seeded and mulched." The interim reclamation practice described above results in the accumulation of the freshly sloughed materials in the ditch and subsequent erosion caused by water carried in the ditch. In addition, the sloughed material can divert the water out of the ditch onto the road surface resulting in its erosion. Currently, the new ditches continue to erode due to their placement in relatively unconsolidated road fill (consisting of finer size soil particles) as compared to the consolidated soils from which the original ditches were constructed.