2009-10-05_PERMIT FILE - C1982057A (2)

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TAB 20 BACKFILLING AND GRADING Disturbed Area A total of approximately 4,093 acres are contained within the Seneca II-W permit boundary. This number excludes the Tie-Across Haul Road permit area of approximately 200 acres (see Exhibit 13-11 series of maps). The maximum extent of all areas anticipated to be disturbed by mining, facility, and access construction, and all reclamation activities at Seneca II-W have been identified and are entirely encompassed within the disturbance boundary as depicted on Exhibit 12-2, Operations Plan and, Exhibit 20-2, Postmining Topography and Drainage. The extent of this boundary was conservatively defined, and may include areas, particularly in the vicinity of roads and impoundments, that will not be affected by any disturbance. The area within the mining disturbance boundary includes the mined area, road right-of- ways, facilities areas, the area upon which spoil is deposited and graded, and where final highwalls have been reduced. Exhibit 20-2 also depicts areas that could potentially be disturbed during the reclamation process. The boundaries shown on Exhibit 20-2 were drawn to allow some degree of flexibility in operations. SCC originally permitted more acres for disturbance than was actually needed in the North Area in order to receive permit approval and address various CDMG concerns that were deemed potentially significant at that time. There are portions of the northern II-W permit area that were originally bonded for total disturbance but were never actually disturbed (approximately 126.5 acres). The majority of the reclamation in the northern area was achieved by the end of 2005. No further major disturbance is anticipated in this part of the mine area. When the South Area was included in the II-W Permit Application Package, the "unpermitted" areas between the actual mining disturbance (topsoil removal area) and the downstream sediment ponds were not thought to be a concern or potential problem. However, based on past practice at other SCC operations, this has become an issue of concern for CDMG and violation of the permit conditions. Therefore, these additional "minimal disturbance" areas are an attempt to keep any potential sedimentation from leaving the permitted disturbance area before entering a sedimentation structure. In this revision there are five (5) additional areas (approximately 56 acres) that could be minimally impacted during reclamation efforts depending on the timing and severity of precipitation events and runoff. All of these areas are portrayed on Exhibit 12-2, Operations Plan. If by chance, one of these areas requires emergency disturbance it will be very minor in extent and will cover only the necessary area required to mitigate the impact. PR-05 1 Revised 01/06