1986-11-28_GENERAL DOCUMENTS - C1981017

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Candace Thompson August 4 , 1986 Page two The purpose of the mine bench stipulation, for example, was "to determine specific backfilling, grading, drainage, and reclamation procedures to assure optimum stability of the final reclaimed portal benches" (See page 52 of the September 1984 Findings Document) . The stipulation was not to determine how much backfilling could be accomplished and still attain optimum stability which seems to be Jeff Deckler' s interpretation of the stipulations. Mid- Continent' s approved reclamation plan for the benches described on pages 19-21 of Chapter V should be the plan against which bonding is required rather than some hypothetical plan of an average of seven feet of unavailable materials that Jim Herron proposed. In my June 30, 1986 letter on Estimated Reclamation Costs I covered, in some detail, Mid-Continent' s position on AOC and the desirability and rationale for maintaining the relative level areas where Mid-Continent facilities now exist. Mid- Continent is convinced that any reclamation plan that includes backfilling areas with large tonnages of materials (if they can be found) is inappropriate, unnecessary and wrong for Coal Basin. The company will defend its position on this subject through whatever avenues are available. The width requirement for the haul roads after the rock tunnel is fully operational is 30 to 40 feet during the remainder of the mining operation as stated on pages 8 and 22 of the reclamation plan (Chapter V in Volume 7) and on Page 56 of the August 1984 MLRD Findings Document. This width is required for the type of maintenance and emergency equipment that need to reach the mine portal areas. Also, narrower roads would be difficult to maintain and accomplish snow removal with the large equipment required for those accomplishments in the rugged Coal Basin terrain. Upon cessation of mining the White River National Forest desires a minimum of 12 foot wide road bed plus a 6 foot drainage ditch configuration for a total of 18 feet. They also desire that 22 foot wide passing areas (plus 6 foot drainage ditch) be retained every quarter of a mile. These figures were obtained from Mr. Bob Berg, White River National Forest road engineer. Thus, we have two widths to consider in reclaiming the haul roads; 30 to 40 feet during mining operations and 18 to 28 feet after mining ceases. Mid-Continent believes that the concept outlined in the reclamation plan of moving the drainage ditch in from the cut banks and letting the inside area fill with natural sluffing is a sound and reasonable way to reduce the road width. After one year the sluffed material, plus other that is available on the uphill portion of the road cut, should be smoothed out evenly against the highwalls using a special angled blade on a large grader. The uphill slope can then be revegetated. Mid- Continent is strongly opposed to the concept of pulling up the stabilized fill slope materials to backfill the cut slopes for the reasons covered in my June 30 letter.