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\b: Alike Houly <br />Ca/arnda Diviriwr afNlnrerak mrAGeolog~ <br />dlarrb 26, 2004 <br />Pale 2 <br />In aaarrlance ,viXh Rafe 2.05.4, please provide a detai/ed timetable for CGe completion f eatb major ttefi in the <br />reclamation plan. Please include the timing for backfilling and grading and correlate this to the mining requente. <br />Response la: All items highlighted in the 11/7/03 TR-25 transmittal letter were not intended as <br />rationale and support for the request for variance from contemporaneous reclamation. Rather, they <br />were intended to identify the elements addressed under the TR-25 revision request and to provide <br />information on technical and operational factors resulting in the request for cevision of the Yoast <br />reclamation plan and variance from contemporaneous reclamation requirements for specific areas. As <br />a recap, key elements of the TR-25 revision request include: <br />1) Tmncation of Haul Road D above Pond 12 due to slope stability concerns and establishment <br />of an ahernate haul route tying to existing Haul Road C <br />2) Updates in timing for mining and backfilling and grading operations reflecting (in order of <br />significance) the adjustments necessary to accommodate delays in getting the highwall miner <br />on site; operational limitations on backfilling and rough grading imposed by existing boxcut <br />areas and the need to keep roads open for coal haulage and reclamation access; shifts in coal <br />production allocations between the Yoast and Seneca IIW operations; and refinements in <br />detailed mine and reclamation planning for these areas <br />3) Adjustments in the postmining topographic configuration consistent with the mining and <br />reclamation plan refinements referenced above, and the resultant timing and sequencing <br />adjustments <br />An area near the southern limi[ of the Yoast SE Mining Area, the central portion of the Valora Pit <br />area, and the final pit of the Yoast West Extension, as shown on the revised Backfillling and Grading <br />Plan Map (Map 19-1A), have been designated as "variance areas" relative to contemporaneous <br />reclamation requirements. The primary reasons for this designation and the requested variance <br />include: <br />1) Deferral of final backfilling and rough grading to accommodate planned highwall mining <br />operations, consistent with the objectives of maximizing coal conservation and recovery <br />2) The designated variance area in the Yoast SE Mining Area corresponds to an existing boxcut <br />and associated boxcut spoils, which must remain in place until final coal removal is <br />completed for the Yoast SE Mining Axea in 2006/2007 <br />3) The need to keep the existing haul road from the Yoast West Extension Area open until <br />active surface mining and subsequent highwall mining operations are completed in the Valora <br />Pit and Yoast West Extension areas. This precludes final backfilling and rough grading in <br />both the central portion of the Valora Pit and the West Extension neck area, since the <br />existing haul road runs through the neck area and is located in the spoils on the east side of <br />the Valora Pit. These spoils will be graded down inro the existing Valora Pit boxcut ro <br />establish the final drainage configuration. <br />Secondary reasons include adjustments in the sequence and timing of mining advance and subsequent <br />reclamation due to changes in coal market demand and shifts in coal production allocations between <br />the Yoast and Seneca IIW operations; and refinements in detailed mine and reclamation planning for <br />these areas. <br />