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Based on the justification provided in PR-4 amended narrative, and the detailed timeframe <br />commitments included in the narrative and amended Exhibit 19-1A, the Division approved <br />the requested variances from the 180 day rough backfilling and grading requirement of <br />4.14.1(1)(c). The variances applied to the variance request areas described and depicted in <br />amended Tab 19 narrative and amended Exhibit 194A. With the approval of PR-4, the <br />"end of 2004" deadline for the "ridgeline pit" approved in 2004, no longer applied. The <br />variance applied solely to the timing of backfilling and grading, and did not allow for more <br />than four spoil ridges behind the pit being worked. <br />In association with PR-4, two changes were made to the Reclamation Scheduling table on <br />page 6 of Tab 19. First, the time period for Final Grading was amended to include specific <br />reference to the schedule on Exhibit 19-1A. Second, a specified time period for permanent <br />channel construction was inserted ("...within one year of completion of final grading of <br />adjacent Backfill slopes..."). <br />Backfilling and grading timeframes (including variance request areas and deadlines) were <br />revised once again by PR-5, as a result of the early cessation of coal extraction, the decision <br />not to implement highwall mining, and associated reclamation plan changes. <br />Backfill and grading deadlines for the timeframe variance areas approved in PR-5 are set <br />forth on pages 5-7 of Tab 19 of the permit application, and depicted on the amended Exhibit <br />19-1 "Backfill and Grading Plan". The Division approved a variance from the 180 day <br />rough backfilling and grading requirement of Rule 4.14.1(1)(c), for the variance areas <br />described as: <br />• 1,600 feet of the "A" Pit Ridgeline Pit; backfilling/grading to be completed by the <br />end of 2005. <br />• 2,800 feet of the Wadge Pit Northern Area; backfilling/grading to be completed <br />by the end of 2005. <br />• 900 feet of the Wadge Pit Central Area to be backfilled/graded by the end of 2005. <br />• 700 feet of the Wadge Pit Central Area to be backfilled/graded by the end of 2006. <br />• 1,400 feet of the Wadge Pit South Area to be backfilled/graded by the end of <br />2005. <br />• Approximately 15 acres of the Wolf Creek area to be backfilled/graded by the end <br />of 2006. <br />As of June 2006, rough grading was completed in all of the variance areas with 2005 <br />completion deadlines. Grading was completed in the Wadge Pit Central Area and Wolf <br />Creek variance areas in 2007. <br />Potentially acid or toxic-forming spoil material was to be identified by sampling regraded <br />spoil, and would be chemically treated or buried with a minimum of four feet of topsoil. By <br />neutralizing and/or isolating any acid or toxic-forming material from the surface, and <br />mixing limited quantities of such material with much greater volumes of alkaline and <br />Seneca II-W Findings Document 48 C1982057 <br />Permit Renewal No. 5 December 9, 2010