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. slopes in the box cut area, some of this material will be spoiled ahead of the operation and rehandled during the next cut. The result is an area on each side of the box cut that will receive spoil material during the excavation process, and cannot be final graded until excavation advances away from the box cut area. Further discussion of this situation is presented in Tab 12 and 20. In order to achieve the designed postmining landform, the necessary backfill material must be available to perform area grading on internal spoil. Generally, adequate material will not be available until excavation has developed at least two spoils. Tab 20 discusses the area grading concept. When the pit configuration is regular le.g., typically, interior spoilt, and where sufficient area is available to perform "area grading", Seneca will maintain backfilling and grading within two spoil rows. Typically, it will take approximately 90 to 120 days to cycle the dragline from one end of the coal field and back during the permit term; however, due to coal market and operation considerations, it is periodically required to also cycle the dragline from the south to the north and back. This could add 60 to 90 days to the dragline cycle before a single spoil row is created. Therefore, due to the depth of overburden, and configuration and length of the pit, it could take over one year to generate four spoil rows. Four spoil peaks will also be created by other mining situations. First, in certain locations such as along the ramps and the haul road, in the box cut spoil area, along certain inside or outside curves, along irregular coal recovery areas, areas with short pii lengths and adjacent to facilities areas, it could • take more than four spoil rows to create sufficient spoil area to allow final grading to "daylight" and blend into the surrounding topography. Second, in some cases, the box cut spoil material is required to be.dozed or hauled forward into the mined area. In this case, the pit progression must move ahead more than four pit widths and the coal must be removed before the spoil can be excavated and graded to its final configuration. Ramps, roads, or facilities must no longer be required for the mining operation before they can be removed or relocated and the adjacent spoil excavated to final grade. Lastly, the completion of backfilling and grading of final highwalls may require up to two years following coal removal. This is due to the larger operational area required for highwall reduction as opposed to interior spoil grading. SCC also has plans to conduct auger mining at select locations along final highwalls las shown on Exhibit 12-1) that will necessarily delay contemporaneous backfilling and rough grading of the final pit. In addition, the mining areas have gotten increasingly steeper and, in some cases, narrower as mining has progressed. The advancement of mining into these areas has put an increasing burden on the existing equipment fleet resulting in delays in reclamation commitments. To get the reclamation back on schedule, SCC has, in the interim, rented two additional dozers that are dedicated to the backfilling and grading activities. Given these practical operating constraints that sometimes limit contemporaneous reclamation, a variance under Rule 4.14.11111c) is requested for the various areas of the Yoast mine. The variance areas are depicted on ExhibiI 79-1A, 13ackfiJl and Grading Plan, along with a revised reclamation schedule. 5 Revised 2/02