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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. Discharge Monitoring Reports and of the Annual Hydrology Reports have consistently shown no sedimentation problems with pond discharges. Inspections by Division personnel over the years have never found any pattern of failure with sedimentation ponds, collection ditches, diversion ditches, or culverts. PHASE 2 BOND RELEASE The Phase 2 bond release portion of Trapper's submittal included maps showing the block and parcel areas, and the locations of the individual transects for vegetation sampling. Also included was a history of the reclamation and management operations performed on each parcel submitted for bond release, as well as documentation, including sampling methodology and data, to verify vegetation success. Finally, the submittal included confirmation of topsoil depths, a demonstration of compliance with sediment limits, and a discussion of the designs and performances of the livestock ponds. The field `inspection for the Phase 2 bond release focused on verification of topsoil depths, the state of vegetative cover and species composition, erosional stability, and the proper construction and functioning of the sediment ponds and permanent impoundments. Topsoil depths were checked by Trapper, using field measurement and scraper load count methods. The Division verified the topsoil depths by direct measurement using a hand auger, during field inspections in 1990 and July, 1996. The Division found that the topsoil depths for the parcels up for Phase 2 bond release were in compliance with the permit requirement of 12 inches. Similar to the Phase 1 bond release portion of the inspection, all of the drainages containing Phase 2 bond release parcels were walked. These drainages which contained the Phase 2 bond release acreages are West Buzzard, East Buzzard, Far East Buzzard, Coyote, No Name, Johnson, West Pyeatt, Middle Pyeatt, and East Pyeatt. During the inspection, the ground cover was examined for adequacy. As stated in Table 2.2-1 of the operator's bond release submittal, the cover standards of 478 for range site C and 528 for range sites A and B were exceeded by percentages of at least 358. Field inspection corroborated the data submittals. Also, the only ground 4