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topography are located in Tabs 19 and 20 of the permit application package. <br /> On an annual basis,using photogrammetric methods, Seneca Property, LLC previously <br /> generated a topographic map of backfilled and regraded areas. The map was used to <br /> determine whether regraded areas are consistent with the approved post mining <br /> topography. The map had been submitted to the Division in the Annual Reclamation <br /> Report each year up to 2012 when all backfilling and regrading activities had ceased. The <br /> following findings were made regarding backfilling and grading practices at the mine: <br /> 1. The applicant requested additional time for backfilling and grading following coal <br /> removal in an area strip mine. A detailed written analysis under 2.05.4(2)(c) <br /> demonstrated that additional time was necessary to accommodate highwall mining <br /> and coal haulage access. Therefore, the Division approved backfilling and grading <br /> beyond 180 days following coal removal for select areas of final dragline pits in <br /> existing mining areas. The variance areas described below are depicted on <br /> Exhibitl9-IA, Backfilling and Grading Plan. <br /> In Lower Neck Pit approximately 1,200 ft. of pit backfilling and grading was completed in <br /> 2004 in accordance with the approved variance schedule. In North Valora Pit (directly east <br /> of Pond 12 )the lower 1,800 feet was final graded and topsoiled in 2007 when the haul <br /> road was removed and lower end of Channel YPM-6 was constructed (the material <br /> removed from the haul road and channel area was needed to be placed against the northern <br /> side slope to achieve PMT). Backfilling and grading was completed in 2005 in accordance <br /> with the variance schedule in South Valora Pit. <br /> Mining ceased in the Scraper Pit and Access (north and east of Pond 014), in 2005 and <br /> Seneca Property, LLC conducted final backfilling and grading of the final pit containing <br /> the access and associated spoil area in 2006. <br /> Seneca Property, LLC followed the backfilling and grading sequence shown on Exhibit 19- <br /> IA, Backfilling and Grading Plan, and the associated reclamation schedule to achieve the <br /> post-mine topography presented on Exhibit 20-2 of the permit application package. <br /> Any potentially acid-or toxic-forming spoil material was to be identified by sampling <br /> regraded spoil, and would be chemically treated or buried with a minimum of four feet of <br /> topsoil. By neutralizing and/or isolating any acid- or toxic-forming material from the <br /> surface, and mixing limited quantities of such material with much greater volumes of <br /> benign spoil material, any negative effects of problematic material was to be ameliorated. <br /> 2. The Division previously approved the applicant's plan for disposal of debris, acid <br /> forming or toxic materials, and materials constituting a fire hazard in a manner <br /> designed to prevent contamination of ground or surface waters. A contingency <br /> plan was also developed to prevent sustained combustion of flammable materials. <br /> (4.14.3(1)(a)). <br /> 3. The Division previously approved the method and design specifications for <br /> covering of acid and toxic-forming materials in order to prevent leaching into <br /> surface and ground water and to insure backfill stability((4.14.3(2)). <br /> As mentioned previously in this document, Seneca Property, LLC conducted the <br /> 22 <br />