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second variance area is the southern 'A' pit area in the south block. It will take approximately two years to develop enough spoil piles to effectively rough grade this area due to the mine plan. The third area is the northern (final) 'B' pit in the southern block. This final highwall pit area may require additional time to grade and larger spoil areas to backfill the reduced final highwall. If, in other areas not shown on Exhibit 19-1 or 19-1A contemporaneous reclamation is not operationally feasible, a variance under Rule 4.14.11111c1 will be obtained from the Division before the creation of more than four spoil ridges or extension beyond 180 days following coal removal. SCC proposes to utilize the general backfilling and final grading sequence illustrated by Exhibits 19-1 and 19-1A and the reclamation schedule shown on Table 19-1 to achieve the proposed postmining topography shown on Exhibits 20-2 and 20-2A. In summary, the annual projection of areas graded are based upon certain considerations. First, approximately two spoil rows are normally graded simultaneously, once pit development establishes asteady-state configuration, to achieve the desired postmining land configuration and to effectively maintain topographic continuity between grading sequences. The number of spoil ridges associated with irregular box cuts, certain inside or outside curves, short pits, facility areas, and haulage ramps may exceed four spoil rows to facilitate grading. Second, timing of grading for specific spoil areas is based upon excavation cycle times and pit configuration. Rough backfilling and grading will be kept within four spoil ridges and within 180 days, except as discussed above. Cycle times are dependent upon factors such as pit configurations, excavator performance, and customer demand. Third, once grading begins, the number of acres graded • annually in a given pit is approximately equal to the number of acres disturbed annually. In certain circumstances, this generalization may not apply because of spoil material needed to achieve the designed postmining landform. For example, the backfilling and grading of box pit spoil, final highwalls, and deep ramps typically require the movement of large volumes of spoil for great distances and requires up to two years after coal removal for final grading. Also, grading of certain box cut spoil areas Iwhere box cut material is spoiled on recoverable coal) will be temporarily delayed until the recoverable coal is stripped (see Exhibit 19-1 and 19-1A1~ All of the acres graded in a given year are projected to be topsoiled and seeded as soon as operationally feasible based on the reclamation timetable and site conditions, and will represent reclaimed acres in Table 19-1. Soil replacement will be completed within one year following final grading, provided the area is not being used for facility or monitoring-related activities (i.e., items such as, but not limited to ramps, deadhead routes, light use roads, haul roads, ponds, drainages, diversions, boneyards, office, or shop areasl~ If final grade is achieved during fall or winter months, soil will be redistributed the following summer or fall to accommodate fall seeding. When final grade is accomplished during spring or summer months, soil will be redistributed by fall to accommodate fall seeding. As can be seen from Table 19-1, more than half of the life-of-mine disturbance occurred prior to 1993. The most significant disturbance is advance topsoil removal which must be completed by November 1 • of each year in order to allow the overburden removal operation to continue during the winter and wet 5a Revised 4/01