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28. Narrative and exhibits related to schedule for backfilling and grading, including discussion and delineation of <br />specified variance areas aze included in various permit sections, including Tabl2, Tab 19, Tab 2Q, and Tab 25. <br />The current fmdings of compliance document contains the following statement on page 4l. <br />Based on [he justification provided in PR-3 amended narrative, [he Division approves the requested <br />variances from the 180 day rough backfilling and grading requirement of 4.14.](I)(c) for those <br />variance request areas described and depicted in Tab 19 narrative and Exhibit 19-IA. Rough <br />grading and backfilling within the designated variance areas is to be completed in compliance with <br />the schedule specked in [he permit. For the Wadge South Pits and Wolf Creek/Sage Creek Pits <br />within the southern portion of [he South Extension Area, the variance applies solely to the timing of <br />backfilling and grading, and does not allow jor mare t/tan four spoil ridges behind t/te pit being <br />worked. <br />Narrative in Tabs 12, 2Q and 25 are consistent with this statement, and the "worst case" assumption for <br />bonding purposes is based on four spoil ridges behind the open pit. However narrative in Tabl9, under <br />~erted Rarkfilling and Grading Srhednle, includes language indicating that the mining process within the <br />South Extension area might result in more than four spoil ridges in various loosely defined circumstances. Rule <br />4.14.1(1)(c) allows a variance from the 180 day rough backfilling and grading requirement, but the mle does <br />not aliow a variance from the requiremem that rough backfilling and grading "shall not be more than four spoil <br />ridges behind the pit being worked". Please amend the referenced narrative section of Tab 19 to clarify <br />that rough backfilling and grading will not be more than four spoil ridges behind the pit being worked. <br />29. Schedule and deadlines for completion of most major reclamation tasks on an annual basis are specified in <br />tables and text of Tab 19 and Exhibits 19-I and 19-1A. The schedule is relatively thorough, but some <br />clarification and refinement appears to be warranted. The schedule on page 6 states that rough grading will be <br />completed "prior to creating 4 spoil ridges or less than I80 days unless approved by vaziance (see Exhibit 19- <br />I)". Final grading "(Phase 1 bond release is ready for implementation)" is to be completed "Per Schedule <br />shown on Exhibit 19-I". <br />To be consistent with 4.14.1(1)(c) and other permit sections, the time period for rough grading would more <br />properly be stated as "prior to exceeding four spoil ridges...". <br />Also, it is not entirely clear whether the final grading schedule as depicted on Exhibits 19-1 and 19-IA is <br />intended to include final drainage channel construction including ripmp installation. This needs to be clarified. <br />If final drainage channel construction including riprap installation is not included within the "final grading" <br />task, then "final drainage channel construction including riprap installation" should be added as a separate task, <br />to be implemented "within one year after final grading is completed, and prior to topsoiling of slopes adjacent <br />to the channel". <br />An additional clarification is necessary to define the deadline for completion of final grading for areas where a <br />range of 3-5 years is indicated on Exhibit 19-1A. There is an operational "trigger" for rough backfilling and <br />grading (four spoil ridges) for both variance and non-variance areas (see Item 26). However, it is conceivable <br />that Exhibit 19-1 A could be interpreted as to allow for areas to remain in a rough graded state for several years <br />prior to initiation of final grading and subsequent reclamation operations. This would not be acceptable. The <br />narrative schedule and Exhibit 19-1A should be amended to specify that final grading will be completed within <br />three months or less of rough grading. Rough backfiliing and grading would at a minimum include elimination <br />of spoil piles, mine pits, and depressions, and grading [o generally conform to the approved contours. Final <br />grading would include any final surface modification necessary prior to topsoiling to comply with approved <br />PMT, and could be defined to include final drainage channel construction including riprap installation (see <br />discussion in previous paragraph). <br />15 <br />