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the establishment of vegetation which supports the approved postmining land use and which meets the <br />approved success standard for cover... based on statistically valid data collected during a single year of <br />the liability period". In regazd to Phase II bond release, Rule 3.03.2(3)(b) also states, " No more than <br />sixty (60) percent of the bond shall be released so long as the lands to which the release would be <br />applicable aze contributing suspended solids to streamflow or runoff outside the permit area in excess of <br />pre-mining levels as determined by baseline data or in excess of levels determined on ad}acent non- <br />mined azeas". <br />The Trapper permit (page 4-258) commits to an average topsoil replacement thickness of 18 inches, <br />allowing for a range of replacement thickness from 16 to 20 inches on cropland areas. The post- <br />mining land use for the requested bond release blocks is cropland. The crop grown is dryland hay. <br />The hay crop consists of a grass/alfalfa mix. The operator manages the cropland with annual cutting, <br />baling and removal of the baled hay. Cutting operations generally occur when alfalfa reaches 10% <br />flower. Since the reclaimed area is cropped annually, there is no numeric cover standard. <br />Herbaceous productivity is the success standazd that must be met with regard to reclaimed croplands. <br />(Rules 4.15.8 and 4.15.9) Vegetative cover will be found successful when vegetation is established <br />sufficient to control erosion. <br />III. OBSERVATIONS AND FINDINGS <br />PHASE II <br />TMI presented the reclamation success data in two bond release blocks. The bond release blocks were <br />chosen in accordance with DMG's Guideline Regazding Selected Coal Mine Bond Release Issues, dated <br />April 18, 1995. Bond Release Block CR 82-92 consists of nine bond release parcels regraded, <br />topsoiled, and seeded from 1982 through 1992. All parcels in this block were seeded with seed mix 82- <br />92-PHC (Seed mix detail is located in Appendix 1 of SL-03 bond release application). <br />Topsoil: <br />Trapper replaced topsoil on the reclaimed site in advance of revegetation. Topsoil was replaced on <br />regraded slopes utilizing small salvaged topsoil piles and live haul soil. Topsoil was replaced on the <br />two reclamation blocks from 1982-1992 and 1993-1994. Trapper Mine supplied topsoil replacement <br />thickness to the Division in the SL-03 bond release application and in the SL-O1 bond release <br />application. Both resources were consulted with regazds to bond release blocks CR 82-92 and CR 93- <br />94. The Trapper permit (page 4-258) commits to an average topsoil replacement thickness of 18 <br />inches, allowing for a range of replacement thickness from 16 to 20 inches on cropland areas. <br />TMI measured the quantity of replaced topsoil on reclaimed parcels by counting scraper loads of <br />topsoil as they were replaced. TMI calculated that an average of 16.7 inches of topsoil was replaced <br />on the CR-93 area in 1993 (July 2, 1996, SL-O1, topsoil verification letter from TMI to DMG). <br />TMI's SL-03 bond release application lists the replaced topsoil depths in the CR-93 pazcel as 18 <br />Trapper Mine, SL-03, Findings 5 Aprif 19, 2002 <br />