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the findings from the inspection. A summary of the observations are discussed below and the <br />details are further discussed in the inspection report. <br />Impoundments <br />SCC has not supplied a permanent impoundment demonstration, landowner approval letters or <br />SEO documentation for stock pond T -22. Until SCC submits a permanent impoundment <br />demonstration for stock pond T -22, Stock pond T -22 will still need to be reclaimed in <br />accordance with the approved reclamation plan. This feature was exempted from the SL -4 Bond <br />Release as well. Stock pond T -22 was not included in the SL -5 bond release request as shown <br />on Figure 1. <br />Topsoil replacement: <br />In accordance with Rule 4.06.4(2), the Division evaluated SCC's topsoil replacement thickness. <br />Prior to the inspection, the Division generated 19 random topsoil sample points within the Phase <br />11 bond release block using ArcGIS and ArcMap 10. At each topsoil sample point, the Division <br />dug a test hole with a hand shovel. Topsoil material was excavated until a definable <br />color /material change was observed or until the ground became impenetrable with the shovel. At <br />this point, the thickness of the topsoil was measured using a tape measure. The topsoil <br />thicknesses observed ranged from 10 inches to 23.5 inches, with an average of 15.47 inches <br />(1.29 feet). Tab 21 of the permit commits SCC to an average topsoil replacement thickness of 1.1 <br />feet throughout the reclaimed area, and with a minimum thickness of 9 inches (0.75 feet). <br />Results of the topsoil sampling effort were recorded in the August 13, 2013 inspection report. <br />None of the topsoil samples measured less than 9 inches. SCC had replaced topsoil east of the <br />Pond 16 slide area. SCC submitted topsoil verification sampling data with the SL -5 application. <br />Alluvial Valley Floor <br />In accordance with the approved mine plan, SCC's mining and reclamation activities did not <br />affect any alluvial valley floors. SCC did not disturb any alluvial valley floors within the SL -5 <br />bond release block, so no AVF function required re- establishment. <br />SL -3 Exclusion Areas Reassessed <br />Channel PM 4 -D <br />Channel PM 4 -D had been previously removed from the SL -4 phase I bond release application. <br />SCC repaired this drainage in 2013. A gully has formed again in the middle of the channel. <br />SCC has initiated repair of PM -4D in July 2014 in accordance with the rill and gully repair plan <br />as described in the permit. Until adequate vegetation becomes established within the repaired <br />area, SCC requested this channel be removed from the SL -5 Phase II bond release request. The <br />Division will exclude this 4.2 acre parcel area from approval. <br />Page 12 of 18 <br />