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Seneca Coal Company Seneca II Mine Pre-Law Area Bond Release Request June 2007 • Backfilling and grading was generally completed within 180 days following coal removal and was not over four (4) spoil ridges behind the active pit. The majority of the grading work was performed with dozers and motor graders. In some cases grading was done with scrapers and draglines. All areas affected by the surface mining operations, except as specifically exempted by the Division, were regraded on a timely basis to a stable configuration that conforms with the approved postmining land use (livestock grazing and wildlife habitat). For the most part, grading was done along contour to also minimi>e erosion. Any time operations were conducted on steep slopes that could present safety concerns to the operators, grading was done in a direction other than parallel to contour. Rill and gully surveys are conducted annually in the spring of each year to locate areas that have experienced severe erosion or other signs of instability during spring runoff from snowmelt and pxedpitation events. Minor rills and gullies have occurred and been remediated over the past yeazs 2. All available taproi! war to be removed and replaced on the backfilled andgraded area. The azea of mining within this Pre-Law pazcel was disturbed before this requirement came into effect. Therefore no topsoil was salvaged or replaced on the Pre-Law disturbance. However there was a haul mad constructed across the center of the pre-law mined area to provide access to ongoing mining. This haul road, approximately 8.2 acres, was regraded and topsoil replaced at a depth of one (1) foot. This topsoil came from aeeas disturbed after August 3, 1977. 3. Revegetation had to ettablzrh a diverre, effective, and permanent vegetative cover native to the area of land that war affected and war to be capable of re f regeneration and plant ruccertion without dependence on irrigation, toil amendmentr or fertilizer, at least equal in extent of cover to the natural vegetation of the area prior to any mining. Introduced . pecier crould be utilized on a temporary barir ar a method ofprzparing the land for ertablirhment of native pecier. • Quantitative sampling of the Pre-Law area was conducted in July 2005 by ESCO Assodates. The detailed results are contained in Attachment D, 2005 Revegetation Monitoring Results. The actual report was part of the 2005 Revegetation Monitoring Report, submitted in March 2006 to the DRMS. Following is a summary of the results: Cover: Total average vegetation cover was 34 percent. For herbaceous vegetation, total average cover was 31.2 percent. Average species density was 10 speces per 100 sq.m. Production: Total herbaceous production was 1,631 pounds per acre. Woody Plant Density: Total average woody plant density was 890 stems per acre. The sampling sites for the 2005 xevegetation monitoring are shown on Exhibit G, 2005 Vegetation Sample Sites. 4. Bond releare required the Board to affzrmatively find that reclamation war tuccerrful and complete. Thir judgment war to be bated on completion of the reclamation plan, compliance with the rukt, and the land's capability to curtain the planned Land ure. The Board could require grazing to gauge tolerance to prerrure and could release bond in whole or in part. Reclamation has been completed according to plans and in compliance with the approved permit document. The land has proven capable to sustain the planned land use of wildlife habitat and hvestock grazing. The land is annually grazed in accordance with a grazing schedule that is documented annually in the Annual Reclamation Report submitted to the Division. The final determination will be based on • the detailed results of the 2005 Revegetadon Monitoring and the subsequent Division inspection to verify compliance.