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rangeland C acreage in this bond release.) Trapper's bond release submittal refers to field data on <br />topsoil thicknesses that was collected by Trapper and verified by the Division. <br />IV. OBSERVATIONS AND FINDINGS <br />Reclamation History of Phase II Bond Release Parcels <br />The parcels included in the current bond release request were regraded, retopsoiled, and seeded in <br />1984, 1993, 1994, 1995, and 1996. The parcels were drill-seeded. The parcels result from Trapper's <br />reclamation of the lands that it mined in its D-pit and H-pit in No Name drainage, and in its A-pit <br />in Johnson drainage. <br />Topsoil Thickness <br />Required thickness and replacement history. The permit application, page 3-82 of Volume 3, <br />requires that 12 inches of topsoil be replaced on all reclaimed lands designated as rangeland A, B <br />and C. The bond release parcels aze rangeland A and B. Trapper replaced topsoil contemporaneously <br />with backfilling and grading operations, drawing from live-haul and stockpiled sources. All of the <br />parcels had phosphate fertilizer applied to the topsoil at a rate of 100 pounds per acre. One parcel <br />(D-A-84) also had similar phosphate fertilizer applied to the spoil before topsoil was applied. <br />Confirmation of topsoil thickness. Trapper and the Division confirmed topsoil thicknesses. <br />Trapper field sampled paccel D-A-84 and counted scraper loads for the other nine parcels. The <br />Division verified Trapper's load counts for four parcels by hand augering topsoil during the July <br />1996 inspection. The Division's measurements confirmed that Trapper's measurements reasonably <br />represented minimum topsoil thickness. During various regular monthly inspections, the Division <br />has observed in the field Trapper's topsoil laydown methods for achieving the required 12-inch <br />minimum. <br />Location of Trapper's presentation of topsoil data. The topsoil replacement history and the resulu <br />for mean topsoil thickness for each parcel are summazized in the SL-O1 application on Table 2.3-1, <br />page 2-10. (A duplicate copy of these data are shown in Appendix 2.1 of the SL-Ol application.) <br />Location of Division's record of topsoil data. Appendix 2.3 of the SL-O1 bond release submittal <br />presents the topsoil thickness measurement data that the Division obtained, and which are recorded <br />in the Division's inspection report dated July 15, 1996. In addition, the Division's inspection report <br />of June 21, 1990 contains field measurements of topsoil thicknesses on Derringer pit reclamation. <br />Finally, various Division inspection reports contain observations of Trapper's topsoiling techniques. <br />Compliance of topsoil thickness. Topsoil mean thicknesses exceed the l2-inch minimum on nine <br />of the ten bond release parcels (please refer to Table 2.3-1 of the SL-O1 bond release submittal, or <br />Appendix 1 of the SL-02 submittal for a summary). The single parcel that does not exceed the <br />Trapper Mine <br />Phase II Bond Release Page 5 12/21!99 <br />