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the Division during the technical evaluation of the bond release application before, during, and <br />after the inspection, including: topsoil depths, vegetation monitoring data and sedimentology <br />demonstration as required by Rule 3.03.1 and approved in the Colowyo PAP. <br />During the Division's office review of the SL-19 application, it was discovered that reclamation <br />parcel EP058 in the East Pit was being requested for partial phase II bond release. Parcel EP058 <br />was previously partially phase II bond released with the issuance of SL-16, as such EP058 was <br />removed from evaluation as part of the SL-19 bond release process. Additionally, as detailed in the <br />Division's inspection report dated September 4, 2020, a large concentration of Musk Thistle was <br />observed in reclamation parcel WP021 which amounted to 10.5 acres. After discussions with <br />Colowyo, it was determined that this area will also be removed from evaluation for phase II bond <br />release. Of the original 281.4 acres being requested as part of SL-19, 238.2 acres are being <br />evaluated for phase II bond release with the removal of EP058 (32.7 acres) and a portion of WP021 <br />(10.5 acres). <br />During the SL-19 bond release inspection, participants walked the bond release request area to <br />allow for visual assessment of compliance with pertinent requirements. Observations were made <br />during the bond release inspection with regard to approved vegetation cover and topsoil depths. <br />To determine compliance with Colowyo's approved variable topsoil depths in the SL-19 area, a <br />total of 49 topsoil verification holes were dug during the August 2020 inspection. A total of 11 <br />points were taken along the East Pit, 36 along the West Pit and 2 at GFO1 and are shown on <br />Figure 2 of this document. More information regarding topsoil replacement associated with the <br />SL-19 areas are discussed later in this section. <br />Topsoil Replacement <br />As stated earlier, a total of 49 topsoil verification holes were dug and measured during the <br />August 2020 inspection prior to the SL-19 bond release inspection in order to verify topsoil <br />depths within the areas being requested for Phase II of the SL-19 application. Colowyo is <br />approved for variable topsoil depth placement and as per Colowyo's PAP, "Topsoil will ... ... be <br />redistributed and graded to a variable replacement depth following the general rule of thin topsoil <br />(<6) inches on ridge tops to gradually thicker topsoil moving down the slopes to the drainage <br />bottoms for the grazingland land use targeted areas. Sagebrush Steppe areas will ideally receive <br />an average of approximately 4 inches of topsoil that will likely be more uniform application to <br />encourage proper seeding depth and overall shrub establishment conditions." <br />Navigation points were placed at random within the SL-19 bond release area in ArcGIS and <br />those points were then downloaded on ArcGIS for ESRI Collector (Collector) prior to the <br />inspection. During the bond release inspection, the Division navigated to the points using the <br />data in Collector and then dug to a minimum depth of 9 inches or until topsoil was visibly no <br />longer present. The depth of each hole was then documented and can be found on Figure 2 and <br />Table 4 of SL-19 Findings Document. The topsoil holes were then immediately backfilled after <br />the depth of topsoil was verified. All topsoil verification holes dug met the requirements stated <br />in Colowyo's PAP and in the SL-19 application. <br />Proposed Decision and Findings of Compliance October 26, 2020 <br />Partial Phase II Bond Release SL-19 Page 6 <br />