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<br />3 <br />replacement verification done by the Division in a <br />previous inspection on July 14, 1987. Finally, this <br />report states that, "there were no signs of erosion" on <br />the mine site. Copies of these inspection reports area <br />also enclosed. <br />3. Four of five topsoil replacement samples checked at <br />the Rienau site during the Phase I bond release <br />inspection had 16-28 inches of topsoil. The fifth sample <br />encountered rock at six inches. The Meeker permit <br />requires that 12 inches of topsoil be replaced on the <br />Rienau site. <br />Rule 3.03.2(2) of the Colorado regulations requires that the <br />Division "conduct an inspection and evaluation of the reclamation <br />work involved" in a bond release request when application is made <br />for such. The regulations continue to say the inspection should <br />consider, among other things, the results of past inspections and <br />monitoring, the degree and difficulty of remaining reclamation and <br />whether water pollution is or is likely to occur. As discussed <br />above, DMG did inspect the reclaimed areas at the Meeker Mines and <br />evaluated topsoil replacement depths, vegetative cover, erosional <br />conditions, water quality and remaining reclamation work at all <br />three sites. These are the topics discussed in the regulations and <br />pertinent to a Phase II bond release request. <br />The operator submitted a report entitled "Homogeneity of the Meeker <br />Mine Sites" to the DMG on July 22, 1993. This report was prepared <br />to address questions raised by the OSM Western Support Center and <br />the AFO regarding the appropriateness of treating vegetative cover <br />data from the three reclaimed areas as one population. A copy of <br />the report is enclosed. While this report was considered as a <br />part of the review process for the Meeker bond release, DMG does <br />not contend that there is any specific regulatory requirement for <br />such demonstrations of successful vegetation establishment. There <br />are two mathematical errors in the report. However, the <br />conclusions of the report remain valid when these errors are <br />corrected. DMG agrees with the conclusions of the report. Those <br />conclusions are, 1) population variances in the three reclaimed <br />areas are homogeneous (data was actually separated into five areas, <br />accounting for two reclaimed topsoil pile locations), 2) mean cover <br />values in the reclaimed areas are equal and therefore, the <br />populations of the reclaimed areas are homogenous in regard to <br />vegetative cover. It is therefore appropriate to combine data from <br />the three areas for comparison to vegetative success criteria. <br />