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8 <br />CEC has followed an approved grazing plan of 3 acres per Animal Unit Months (AUM) using horses. <br />Topsoil <br />Reclamation in the areas of requested Phase II Bond Release associated with topsoil are in compliance <br />with requirements. Replacing topsoil is considered as a Phase II reclamation activity by the Division <br />to create a seedbed for successful revegetation. Twenty-four inches of topsand (topsoil) is required <br />by the Reclamation Plan of the Permit (Page 114b) over back-filled pit areas. <br />Ten topsoil replacement sample depths were collected (auger holes, tape measurement) during the <br />February 6, 1997 bond release inspection. Sample locations were determined randomly using a grid <br />system. Extent of topsoil was determined by distinct change in soil texture from sandy topsoil to <br />clayey spoil material. <br />Three soil depth verification holes were sampled in the 1985 seeding areas. The resulting topsoil <br />replacement thicknesses were measured at 38 inches, 25 inches, and greater than 24 inches. All three <br />sample locations in the 1985 reclaimed parcel exceeded the required topsoil replacement thickness. <br />Four topsoil verification holes were sampled in the 1986 reclaimed areas. The resulting topsoil <br />replacement thicknesses were 34 inches, 34 inches, 33 inches, and greater than 24 inches. All 1986 <br />reclaimed parcel topsoil samples exceeded the required 24 inch replacement thickness. Three holes <br />were sampled in the 1987 reclaimed areas. The resulting topsoil replacement thicknesses were <br />measured at 32 inches, 37 inches, and greater than 24 inches. All 1987 reclaimed parcel samples <br />exceeded the required 24 inch topsoil replacement thickness requirement. <br />Revegetation <br />The revegetation accomplished by CEC in the areas requested for Phase II Bond Release is in <br />compliance with requirements [meets the criteria of Rule 3.03.1(2)(b)]. <br />The required cover standard for the Keenesburg Mine is found on Page 2.05.4-114-e of CEC's Permit <br />This standard is in agreement with Rule 4.15.8. CEC has proposed to compare the reclaimed area to <br />a reference area approved by the Division in agreement with Rule 4.15.7(3). <br />Total vegetative cover on the reference area was 43.2%. Sand sage accounted for 18.13% absolute <br />cover. Herbaceous vegetative cover accounted for 24.93% absolute cover. Litter was measured at <br />39.2%, with no rock cover encountered during the sampling transects, leaving 17.6% bare ground. <br />The NRCS representative present during the bond release irupection made an observation that, due to <br />the proliferation of sand sage, the reference area (considered by NRCS to be in a Deep Sand range) <br />appeared to be in poor range condition. Verification with the Deep Sand range site descriptiondefined <br />by NRCS indicates that good range condition is reflected by a vegetative community comprised of 75- <br />11 August 98 <br />