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spoil areas and graded final highwalls in the south extension mining block (both Wadge and Wolf Creek/Sage Creek mining areas). Summary Findings Pursuant to 4.05.8(3), temporary storage of acid or toxic forming spoil may exceed 30 days if the operator demonstrates that burial or treatment is not feasible within 30 days due to weather conditions or other specked factors, and will not result in material risk of water pollution or other environmental damage. If deemed necessary by the Division based on the quantity, location, and chemical characteristics of any temporarily stored acid-forming or toxic-forming spoil, such spoil shall be placed on impermeable material. Based on data included in annual reclamation reports, spoils. exhibiting acid or toxic forming potential or excessive clay content have not been replaced on the surface. No indication of the presence of acid forming or otherwise deleterious regraded spoil has been found by the Division during mine inspections. Based on the baseline data and assessment provided in the permit application, monitoring commitments described for both the Wadge and Wolf Creek/Sage Creek spoils, and monitoring results and observations to date (October 2004), the operation is in compliance with performance standards related to acid forming and toxic forming spoil. E. Surface and Ground Water Monitoring Ground Water Tab 7 of the permit application contains baseline ground water hydrology information. Section 7.1 contains the baseline information for the original permit area, while Section 7.2 contains updated information for the Seneca II-W South Extension Area. The ground water information section of the application was most recently updated in 2002 in association with Permit Revision No. 3 (PR-3). Tab 15 describes the operational ground water monitoring program. The current hydrologic monitoring program is presented in Appendix 15-3a of the permit application package, most recently updated in association with PR-3. Monitoring locations are shown on Exhibits 7-1 (for the original permit area) and 7-lA (for the SouW Extension Area). Ground water studies in conjunction with the Seneca II-W Mine site have been concentrated in the Upper Mesaverde Group and alluvial aquifers. Specifically, aquifer characteristics and/or water quality analyses have been performed in the Wolf Creek underburden, Wolf Creek coal, Wolf Creek overburden, Sage Seneca II-W Findings Document 29 November 17, 2004 Permi[ Revision No. 4