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(documenting 89,954 cubic yards ob Bench One material to be emplaced on the <br />eastern zones of the Morgan Property to establish total reclaimed topsoil depths). <br />8. OSM, in its technical investigation of PR6 reclamation, soil salvage, and <br />sampling arrived at the independent conclusion that there was a topsoil deficit, <br />which it identified as being evidenced by the fact that only 47% topsoils <br />documented as existing on the Morgan Property prior to disturbance were <br />preserved for reclamation. R. 8945. <br />b. Improper Use of an Inferior Topsoil Substitute to Cover a Topsoil <br />Deficit. <br />9. DRMS states that the Bench One overburden material can be used as a <br />"supplement to topsoil" on the Morgan Property to make up for a topsoil deficit. <br />• • <br />10. PR6 discloses that the Bench One material, which is an overburden material, <br />was already placed on the eastern portion of the Morgan Property as of February, <br />2008. R. 5458. <br />11. A decision was made in PR6 to utilize 33 inches of Bench One combined <br />with mixed topsoil to arrive at a final replacement topsoil depth for the eastern <br />portion of the Morgan Property. R. 5453 -5454. <br />M <br />