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• box cut that is disturbed twice during the excavation process, and cannot be final Traded <br />until excavation advances away from the box cut area. Further discussion of this <br />situation is presented in Tab 12 and 20. In order to achieve the designed postmining <br />Landform, the necessary backfill material must be available to perform area grading on <br />internal spoil. Generally, adequate material will not be available until excavatiln has <br />developed two spoil. Tab 20 discusses the area grading concept. When the pit <br />configuration is regular (e.g., typically, interior spoil), and where sufficient area is <br />available to perform "area grading", Peabody will maintain bac kfilling and grading ithin <br />two spoil rows. Typically, it will take approximately 90 to 120 days to cyc le the <br />dragline from one end of the coal field and back during the permit term; however, due to <br />coal market and operation considerations, it is periodically required to also cycle the <br />dragline from the south to the north and back. This could add 60 to 90 days to the <br />dragline cycle before a single spoil row is created. Therefore, due to the depth of <br />overburden, and configuration and length of the pit, it could take over one year to <br />generate four spoil rows. <br />four spoil peaks will also be created 6y other mining situations. First, in certain <br />• locations such as along the ramps and the haul road, in the box cut spoil area, along <br />certain inside or outside curves, along irregular coal recovery areas, areas with short pit <br />lengths and adjacent to facilities areas, it could take more than four spoil rows to <br />create sufficient spoil area to allow final grading to "daylight" and blend into the <br />surrounding topography. Second, in some cases, the box cut spoil material is requir ed to <br />be dazed or hauled forward into the mined area. In this case, the pit progression must <br />move ahead more then four pit widths end the coal must be removed before the spoil Icon be <br />extavated and graded to its final configuration. Ramps, roads, or facilities must no <br />longer be required for the mining operation before they can be removed or relocated and <br />the adjacent spoil excavated to final grade. Lastly, the completion of bac kf Tiling and <br />grading of final highwalls may require up to two years following coal removal. T is is <br />due to the larger operational area required for highwall reduction as opposed to i ~erior <br />spoil grading. <br />Therefore, based on the above reasons, a variance under Rule 4. 14(i)(c) is reques tied for <br />the Seneca II-4 mine site. Peabody proposed to utilize the backfilling and Trading <br />sequence proposed on Exhibit 19-1 end the reclamation schedule discussed in Tab~19 to <br />• achieve the proposed pos[mining topography on Exhibit 20-2. In summary, the <br /> 5 Revised <br />