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The applicant completed projections of overburden bulking, in order to project post-mining topography within the mined area. The projections included within the original application were completed prior to submittal in 1982. Subsequently, in connection with operations at the existing Seneca II Mine, the applicant has completed topographic observations of reclaimed land. These aerial observations have determined that the actual bulking factor slightly exceeded the original projection (19.8 % in the operator's terminology, versus 15.3 % projection). In completing its review of the amended application, the Division converted the applicant's analytical projections into an analytical format more familiar to the Division. The applicant projects an average overburden swell factor (loose swollen overburden volume divided by bank overburden volume) of 1.32. Further, the applicant projects a bulking factor (swollen backfilled volume divided by excavated pit volume) of 0.91. Considering the average mined depth and extracted seam thickness, this suggests an average post-mining topographic deflation of 4.6 feet. Adjusted for the possible 4.5 percent discrepancy in observed versus original projected bulking discussed above, the post-mirting topography might rise by an additional 1.8 feet, resulting in an average post-mining topographic deflation of 2.8 feet. In either case, the projected post-mining topographic configuration is considered by the Division to constitute an acceptable approximate original contour configuration. The Division has approved a reclamation plan for delay in contemporaneous reclatation, as allowed under Rule 4.14.1(1)(c). The approval was granted due to the nature of the operation plan which entails concurrent mining of two separate mining areas (north and south) with a single dragline. Pit development in both the north and south blocks begins with an initial box cut. Development proceeds from each box cut in opposite directions at different times during the operations plan. The sequence of pit development will not allow for backfilling and grading to be completed within 180 days of coal removal. At the point of maximum disturbance, there will be two open pits within each mining block. Pursuant to Rule 4.14.1(1)(c), the Division is approving a variance from the requirement that rough backfilling and grading be conducted within 180 days following coal removal. This vaziance applies to the entire permit azea. In addition, a variance from the requirement that there be no more than 4 spoil ridges behind the pit currently being work is approved fora 25.5 acre area of the north block and a 41.8 acre azea of the south block. Within these areas, as depicted on Exhibit 19-1, up to 11 spoil ridges will be allowed between the two open pits in the north block and up to 11 spoil ridges will also be allowed between the two open pits in the south block, to allow for sufficient operational area to allow for highwall reduction grading. The additional spoils have been accounted for in the reclamation cost estimate for the reclamation bond. Seneca II-W Findings Document 35 November 3, 1999